ReCAP Pilot Project Findings and Recommendations: Monterey Bay Region

Chapter 5: Wetlands


SUMMARY

This chapter examines both wetland resources and the institutional framework used to determine how these resources are protected and managed. The historic, current and projected status of wetland morphology (acreage, fragmentation, and habitat), physicochemical processes (hydrology and water quality), and biodiversity are presented. Institutional analysis focuses primarily on the California Coastal Management Program (CCMP), as implemented by the Coastal Commission and local governments, and secondarily on other federal and State statutes governing wetlands.

PROBLEMS

Wetland resources within the ReCAP region have suffered significant adverse impacts over time. Results from this project generally indicate that:

A framework for regulating adverse affects to natural resources, consisting of the California Coastal Act, the Clean Water Act, and the California Environmental Quality Act, among others, was institutionalized in the early 1970's. By and large, the resulting regulations have prevented significant additional adverse wetland impacts from new development. However, these laws contain several exemptions that limit their universal application, especially for pre-existing land use activities. Various implementation deficiencies also limit the effectiveness of these laws. Limitations on wetland fill are most stringent, while limitations on other types of activities in wetlands (e.g., vegetation removal or draining), and limitations on detrimental development adjacent to wetlands (such as those causing abnormal erosion) are less stringent. A lack of readily available information further limits the ability of regulatory programs to address cumulative adverse impacts to wetlands.

A variety of approaches are possible to address the existing procedural deficiencies. For instance, changes in the way some regulations are implemented to improve consistency would benefit both the regulatory agencies and the regulated community. Additionally, numerous wetland management plans have been and are being prepared to address current wetland issues. Recent and pending federal legislation to control nonpoint source pollution promises new mechanisms at the watershed level to further reduce wetland degradation.[1] Notably, this new generation of comprehensive wetland- and watershed-based planning and regulation, and the resultant information generated, has occurred since the project area's local coastal programs were originally adopted. The challenge faced by the Commission and local governments is to incorporate these new approaches into the CCMP, while continuing to support currently successful protective efforts.

RECOMMENDATIONS

ReCAP's analyses show that in order to more fully address cumulative impacts, wetland issues should be addressed in a comprehensive, watershed-based framework, which is contrary to the typically fragmented practices of the past. The primary recommendation is to establish a regional framework to set priorities, coordinate, provide technical assistance, and otherwise guide preparation and implementation of wetland and watershed management plans (see Wetlands Problem #7). The apparent best course of action is to capitalize on the recently-initiated Monterey Bay National Marine Sanctuary's Integrated Coastal Management (ICM) process, which is currently working to complete a water quality protection program. It is within the ICM framework that specific watershed and wetland management planning should continue, so as to address local concerns from a regional perspective. This chapter recommends some guidelines for preparing wetland management plans and processes for integrating these plans into the CCMP.

In conjunction with this overall recommendation, ReCAP recommends specific improvements in the following categories:

ReCAP's analyses represent only a first level of recommended improvements. As additional information and recommendations are generated, they are expected to lead to further refinements of the existing local coastal programs and other elements of the CCMP. At the same time, implementation of wetland and watershed management plans should lead to enhancement of the region's degraded wetlands. With respect to wetlands, the CCMP must be improved in a manner that leads to more comprehensive management, of which regulation of new development is only one component.

CHAPTER ORGANIZATION

The next section of this chapter presents as background information the policy framework under which wetlands are regulated, summarizes the status and trends of wetland resources in the region, and describes the analytical approach used to assess cumulative impacts to wetlands. Finally, this chapter describes seven problems identified through the cumulative assessment, including a discussion of the apparent causes of the problems, projections for their continuance and resolution, and specific recommendations for correction or improvement. The problems are:

BACKGROUND

Wetlands are a significant, but severely impacted, natural resource within California. Only since the late 1960's have wetlands engaged the attention of individuals from a range of disciplines who endeavor to understand their variety and complexity.[2] Recent but intense interest in wetlands is due largely to their role in aquatic and terrestrial ecosystems, and our changing perceptions of them. Humans have come to understand how important wetlands are to the existence of numerous plants and animals, as well as the many functions they perform (e.g., flood control, ground water recharge, and maintenance of water quality) that are important to our quality of life.

This section provides a description of three elements that play an important role in assessing the cumulative impacts to wetlands within the ReCAP region: (1) the existing policy framework; (2) the current status of wetland resources; and (3) the analytical framework used for this assessment. Each of these elements is described separately, but together form the foundation for ReCAP's identification and analysis of cumulative impacts to wetlands.

POLICY FRAMEWORK FOR WETLANDS PROTECTION

Currently, numerous federal, State, and local agencies administer and enforce a myriad of regulations that limit and control the development and alteration of wetlands in California.[3] (For an example of the regulatory framework for wetlands in the ReCAP pilot area, see Figure 5-1.) Although a few statutes and directives are specific to wetlands, most of the regulatory influence over wetlands occurs indirectly through management or regulation of water quality and quantity, fish and wildlife, endangered species habitat, water navigation, floodplain control, public trust, environmental land use regulations, and coastal resource conservation.[4] However, even with the complex array of existing regulations, California's wetlands do not receive equal protection. Although the federal regulations stipulated in the Clean Water Act (Section 404) and the River and Harbors Act (Section 10) apply to most of the wetlands within the State, only wetlands within San Francisco Bay and the coastal zone are afforded additional protection through specific State coastal program provisions.

Figure 5-1: Relationships Between Various Permits that May be Required for Development in a Wetland Occurring in the Coastal Zone[5]

The Coastal Commission is the lead State agency charged with the regulation of development in California's coastal zone.[6] The California Coastal Act is the document the Coastal Commission relies on for overall guidance and direction in fulfilling its charge. Sections 30230, 30231, 30233, 30236, and 30240 of the Coastal Act relate directly to the preservation and protection of wetlands and other environmentally sensitive areas. The development and alteration of wetlands in the coastal zone, however, are primarily regulated by Section 30233(a) of the Coastal Act. Among other things, Section 30233(a) lists the types of development for which diking, filling, or dredging may be permitted in open coastal waters, estuaries, lakes, and wetlands.[7] This section also stipulates the criteria under which development is permitted (i.e., least environmentally damaging feasible alternative and provision of adequate and feasible mitigation). In addition to the specific provisions of the Coastal Act, the Coastal Commission has adopted the Statewide Interpretive Guidelines for Wetlands and Other Wet Environmentally Sensitive Habitat Areas (1981). These guidelines contain technical definitions for wetlands and riparian areas, discuss conditions for permitting development in these areas, and provide information pertaining to the maintenance and restoration of wetlands. The guidelines were

Figure 5-2: Location of Wetlands in the ReCAP Pilot Area. Click here to view. Figure 5-2.

developed to assist the Coastal Commission, local governments, and the public in the application and interpretation of the Coastal Act and in the development of local coastal programs. Most recently, the Coastal Commission has produced a document entitled Procedural Guidance For The Review Of Wetland Projects In California's Coastal Zone (1994). This document describes a review process the Coastal Commission uses to evaluate proposed wetland development projects.

The California Coastal Act is designed to delegate to local governments much of the Coastal Commission's authority to regulate coastal development through the implementation of local coastal programs (LCPs). To become certified for use, the LCPs must, compared to the Coastal Act, provide equal or greater protection of coastal resources. With a certified LCP, a local government assumes authority for permitting certain types of development in specified areas of the coastal zone, including many of the wetlands in the ReCAP region.

Local governments with jurisdictions in the ReCAP pilot area ensure that their LCPs provide for the regulation of wetland development by identifying wetlands as "environmentally sensitive habitat areas" and, pursuant to Coastal Act Section 30240, limiting development to resource-dependent uses. The LCPs also contain specific language relating to the protection of wetlands within the jurisdiction. For example, the LCPs specify the width of buffer areas around wetlands (see discussion of buffer areas under Wetland Problem #2), specify erosion control measures to prevent excessive amounts of sediment from entering wetlands, and specify management strategies for particular wetlands.[8] Because of the shared responsibility for management of wetlands, program improvements need to be implemented in a coordinated fashion by the Commission and local governments.

STATUS OF WETLAND RESOURCES

The ReCAP project area contains a diverse array of wetlands. Coastal lagoons, large slough complexes, salt and freshwater marshes, lakes, and rivers all occur within the project area. Analysis completed as part of this project revealed 99 wetlands[9] within the project area (Figure 0-2, page 75), totaling approximately 6,200 acres. A review of aerial photographs from 1977, 1986, and 1993 suggests there has not been an appreciable change in total wetland acreage over the last 16 years.[10] Of the 99 wetlands identified in the project area, at least 16 have been placed under more protective status in the last 20 years. Comprehensive management plans have been prepared or are being prepared for at least 24 of the area's wetlands. Restoration projects have been undertaken for at least 32 of the area's wetlands.

It is important to realize, however, that wetland acreage is not the sole determinant of the condition of wetland resources. The quality of a wetland is more accurately determined by acreage and functional capacity. California's coastal wetlands serve a number of important functions such as the provision of habitat for native wildlife, water purification, and flood control. The value of these functions will vary depending on the wetland size, its location in the watershed, and the surrounding land use.

Both natural and anthropogenic processes have historically affected the quality of wetlands in the ReCAP project area. Natural changes involve processes still occurring today: seasonal berm formation at the mouths of coastal lagoons, changes in freshwater inputs due to droughts and floods, and earthquakes. Human-induced changes have involved activities related to agricultural and urban development. Over the previous century, development projects such as the damming of rivers, construction of transportation corridors, and major urban and agricultural development have all diminished the quantity and quality of wetland habitat through the degradation of wetland hydrology, water quality, and direct habitat loss. More recently, however, wetland habitat has been most affected by the lingering effects of earlier development (e.g., point and nonpoint source pollution, chronic reductions in the amount of water reaching wetlands, and the loss of adjacent buffer areas). Although still apparent, the rate at which wetland habitat, hydrology, water quality, sedimentation rates, and biodiversity are adversely impacted appears to have declined since inception of the Coastal Act. On the other hand, there are few examples of positive change from an ecological perspective. Thus, the challenge is not simply to halt, but to reverse the historic adverse impacts, as enhancement and restoration are also Coastal Act objectives (Section 30001.5).

ANALYTICAL APPROACH

Conceptually, a number of factors have the potential of affecting a wetland through changes to one or more of the physical, chemical, or biological attributes (Figure 5-3). The conceptual diagram below illustrates the key attributes of a wetland, the various factors that could impact those attributes, and the principal processes that exert influence over the factors. The connecting arrows depict the pathways by which the processes can influence the various attributes. For example, urban development (an anthropogenic process) may enhance the establishment of introduced species, which can adversely impact wetland biodiversity. In addition, many of the pathways are interconnected. For example, a drought will lead to reduced freshwater inputs, which will affect wetland hydrology (physicochemical), which can ultimately affect both the size (morphology) and species abundance (biodiversity).

Figure 5-3: Original Conceptual Model Showing the Relationships Between Processes, Factors and Attributes in Wetlands

Because of their complexity, the cumulative impacts to wetland resources in the ReCAP project area were investigated through separate study of three key attributes: (1) morphology; (2) physicochemical processes; and (3) biodiversity. Although trophic dynamics was also considered a key attribute, it was not included in this analysis due to a lack of valid information.[11] Based on analyses of the various wetland attributes, this chapter describes, as problem statements, the various sources of impacts, and recommends procedural or policy changes to resolve or reduce the identified problem. This chapter also examines wetland regulatory concerns and comprehensive management issues in an attempt to determine strategies for long-term effective management of cumulative impacts. In all cases, the analyses attempt to answer three basic questions: (1) what has happened; (2) why has it happened; and (3) what will happen if past trends continue. The analyses generally consider two time frames: (1) the Coastal Act period (1973 -1993, emphasizing the second decade, 1983-93, when many of the region's local coastal programs were certified); and (2) to a lesser extent, the pre-Coastal Act period (1972 and earlier).

Although separate analyses were completed for the various attributes, wetlands are not isolated systems. Interactions among wetlands and the surrounding landscape occur continually by way of water, air, and the organisms that rely on them. Thus, impacts to one aspect of a wetland will affect other attributes as well as other wetlands. With this in mind, results of the analyses were also used to revise the conceptual model of wetland impacts (Figure 5-4). These revisions included refinement of the connections between sources of impacts (processes and factors) and the affected attributes. In addition, the connecting arrows were qualitatively weighted (e.g., high, medium, and low). This weighting provides an indication of the contribution various processes and factors made to documented changes in wetland attributes. The results show that anthropogenic processes had the largest cumulative effect on wetlands in the ReCAP project area, which manifest as changes in physicochemical and morphological attributes. Natural processes were also found to affect the wetlands over the last ten years, albeit to a lesser extent, through changes in saltwater or freshwater inputs. There were several indications that wetland biodiversity has been adversely affected, but the available information was limited and did not provide evidence for the magnitude or sources of the impacts.

Figure 5-4: Revised Conceptual Model Showing the Relationships Between Processes, Factors and Attributes in Wetlands

Because wetlands are not isolated systems, assessments that evaluate wetland impacts as isolated occurrences provide an incomplete picture. There is clearly a need to take a landscape approach to protecting and managing wetlands. Resource and regulatory agencies must think about wetlands as part of a bigger system, as integral components of the watershed. Finally, these agencies need to include humans within that bigger system, not only as a source of impacts, but also as the potential solution to the cumulative impacts humans have created.[12]


WETLANDS PROBLEM ONE


DIRECT LOSS OF ACREAGE, FRAGMENTATION, AND HABITAT CHANGE

The amount of wetland acreage in the Monterey Bay pilot region has greatly decreased over the last century and wetlands have become more fragmented, due primarily to human impacts. Neither the CCMP nor any other program comprehensively addresses historic loss. Recent and potential permitted and unpermitted development have resulted in and may continue, absent some regulatory improvement, to result in some additional wetland acreage loss.

ANALYSIS

Morphologic Problems

The disappearance of our nation's wetlands -- an estimated 90% loss in California -- is a major environmental concern.[13] So is the resulting fragmentation: historic wetland connections have been severed and distances between wetlands have increased. In the project area, wetland loss and fragmentation are historic problems that persist with no comprehensive, accepted remedy. In addition, alterations to existing wetlands have resulted in habitat changes, some of which have been adverse.[14]

Historic Wetland Loss

Large portions of the pilot area's historic wetlands disappeared in the century prior to environmentally-based regulation (pre-1970's). Although the total loss has not been quantified, some examples illustrate the magnitude.[15] Table 5-1 shows over 114 acres (33%) lost at Salinas River Lagoon.[16] Neary Lagoon's size diminished 60% from 75 to 30 acres.[17] Wilder Lagoon shrunk by almost 70% from 49 to 15 acres as Figure 5-5 shows.[18] In all cases, human activities, especially diking, draining and filling for agriculture, were largely responsible.[19]

Table 5-1: Historical Areal Changes in Salinas River Lagoon Habitat

Figure 5-5: Wetland delineation of Wilder Pilot Area based on present vegetation, soil, and standing water; and likely historical wetland area Fragmentation. 
Click here to view Figure 5.5
.

This historic loss of wetland acreage also resulted in the fragmentation of wetlands.[20] Fragmentation refers to the severing of physical and ecological linkages between wetlands. Fragmentation affects wetlands adversely by reducing water circulation and limiting the migration of individuals among previously continuous populations of plants and animals. Small, isolated populations are much more susceptible to natural and human-induced stresses and have more difficulty recovering from such stresses than large, contiguous populations. Fragmentation may, therefore, be closely linked with declines in biodiversity. Within the ReCAP region, this is seen most prominently in southern Santa Cruz and northern Monterey Counties. For example, within the coastal zone north of the Salinas River and south of Moss Landing, some wetland areas disappeared altogether,[21] while the two remaining wetlands (Old Salinas River Channel and Tembladero Slough) were reduced to drainage channels.[22] The historic connection between the Salinas River and the Pajaro River north of Moss Landing was lost. The alteration of Upper Watsonville Slough (which connected to the Pajaro River mouth via lower Watsonville Slough) resulted in the severing of historic connections with Harkins, Hanson, Gallighan, and West Branch Struve Sloughs.[23]

Just outside the coastal zone of Monterey Bay a significant example of wetland fragmentation occurred over time along the northern corridor of the Salinas River. A chain of nine lakes spaced over a distance of approximately ten miles has mostly disappeared, due to agricultural activities; only one lake remains.[24]

Habitat Change

The physical character of some of the remaining wetlands has also changed over time. For example, Schwann Lagoon was transformed from a coastal lagoon into a freshwater lake when its connection with the sea was obstructed by road construction. Open water habitat areas in Bonita Lagoon, Carmel River Lagoon, and Salinas River Lagoon have gradually filled in and become vegetated (see Table 5-1 for one example). Conversely, harbor construction has turned portions of the vegetated marsh habitats in Arana Gulch (Woods Lagoon) and the Old Salinas River Channel into open deepwater habitats. The construction of Moss Landing Harbor has been linked to excessive channel erosion, resulting in the loss of intertidal marsh habitat in Elkhorn Slough.[25]

Not all habitat changes are bad. Sometimes such changes are done intentionally as part of wetland restoration efforts. However, most of the unplanned habitat changes (i.e., those that occurred as unintentional consequences of other activities) are likely to result in negative impacts. (For additional details and examples, see endnote #14.)

Regulatory Responses

Continued development pressures coupled with gaps in the regulatory process suggest that further wetland losses, fragmentation, and adverse habitat changes are possible.

The vast changes to wetlands occurred in an era when environmental regulation was absent and economic development of wetlands was more highly valued than their natural state. This changed in the early 1970's with the advent of the California Coastal Act, the California Environment Quality Act (CEQA) and its federal counterpart the National Environmental Policy Act (NEPA), and with the consideration of environmental factors in implementing the Clean Water Act.[26] Coastal Act Section 30233c, for example, prohibits most development in wetlands, except those of a resource-dependent nature that lack less environmentally damaging feasible alternatives, and for which adequate mitigation exists.[27]

As a result of protective legislation, few permits issued in the study area since 1973 have allowed wetland fill; those that have by-and-large required at least equivalent compensation (i.e., required an equal or greater acreage of wetland to be restored or created from dry land elsewhere).[28] The Coastal Act's authority has allowed Commission staff to participate in discussions about potential projects before permit applications are submitted and thereby encourage alternatives to wetland fills. In the few instances where applicants persisted with insupportable fill projects, the Commission has denied the request. Such instances include urban development in Jessie Street marsh, wastewater plant expansion into Neary Lagoon, and road fill in Elkhorn Slough.[29]

In spite of existing regulations, some direct loss of wetland area has occurred over the last twenty years at Moro Cojo Slough, Elkhorn Slough, McCluskey Slough, and Watsonville Slough, due to agriculture activities, and at Spanish Bay due to urban activities.[30] At least temporary losses have occurred at Neary Lagoon, Majors Creek, and Lower Watsonville Slough, where after-the-fact enforcement actions have been initiated to remediate unpermitted fills.[31]

That these instances have occurred, along with other factors, suggest that additional activities resulting in wetland loss will be attempted in the future. These other factors include known pending projects,[32] some unauthorized activities,[33] potentially allowable wetland uses, disputes about what is really a wetland, no guarantees of mitigation success, and private and public ownership of wetlands not in preserve status. In addition, gaps in the CCMP regulatory process can allow incursions into wetlands to occur.[34] These gaps include agricultural exemptions, inconsistent enforcement and condition compliance, inconsistent wetland delineation methods, and permitted uses without guaranteed compensatory mechanisms.

Agricultural Exemptions

The list of allowable wetland uses in Coastal Act Section 30233a does not include agriculture. Most LCPs place wetlands under a resource protection category and do not explicitly show agriculture as a permitted use. However, not all agricultural activities qualify as new "development," and therefore do not require a coastal permit. According to the Commission's Statewide Interpretive Guidelines (1981),

When wetlands are seasonally farmed, the continued use of agriculture is allowed. Expanding farming operations into non-farmed wetlands by diking or otherwise altering the functional capacity of the wetland is not permitted. Farm-related structures (including barns, sheds, and farm-owner occupied housing) necessary for the continuance of the existing operation of the farmed wetlands may be located on an existing farmed wetland parcel, only if no alternative upland location is available for such purpose and the structures are sited and designed to minimize the adverse environmental effects on the farmed wetland. Clustering will be required.[35]

The Coastal Commission has considered that expanding cultivation or grazing into a wetland that has not been recently farmed, even if no diking or grading is involved, is "development". However, others might not share that interpretation based on Section 30106 of the Coastal Act,[36] which states in part:

Development means, on land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, and the removal or harvesting of major vegetation other than for agricultural purposes...

The North Monterey County Land Use Plan is the only plan in the ReCAP region that has a broadened definition of development that includes some agricultural removal or harvesting of major vegetation, but not specifically wetland vegetation.[37]

The result of these regulatory limitations has been the continued cultivation of historic wetlands (especially in the Watsonville Slough complex), a few new (or reactivated) cultivated wetland areas, and expanded grazing in wetlands.[38] The vegetation removal exception may also have been interpreted by agricultural land owners to mean that diking, draining, and filling are allowed without a permit if the purpose of such activities is to allow the continuation of on-going agricultural activities (for example, diking to prevent a wetland from reclaiming part of a cultivated field at the end of a drought).

Condition Non-Compliance and Impediments to Enforcement

Chapter 9 of the Coastal Act provides for judicial review, enforcement, and penalties for violations. Most local coastal programs echo such provisions, and contain procedures for addressing violations on a local level.[39] Staffing limitations have required reliance on discovery by others and have resulted in highly variable follow-up. Lack of consistent reporting and computerized record keeping has further hindered compliance monitoring efforts. Even when enforcement commences, guaranteeing successful mitigation is problematic (see section on mitigation problems below).

The resulting unrectified incursions, discovered through ReCAP's aerial photography interpretation, include, for example, several acres of Moro Cojo Slough that have been diked and cultivated since 1977, and small areas at the margins of McCluskey Slough and Elkhorn Slough.[40] In cases where discovery has already led to enforcement actions being initiated, restoration has not always been achieved. For example, out of 14 required restoration plans, only eight have been formulated and six completed.[41] Unpermitted activities in wetlands represent net wetland acreage losses until restoration is completed.

In cases where wetland alterations are conditionally permitted, similar staffing and tracking limitations constrain the Commission's ability to assure condition compliance (e.g. successful mitigation). Without adequate staffing to conduct field inspections, it is often not known whether permitted losses are successfully mitigated. Unfortunately, limitations in the Commission's tracking and post-construction inspection system mean that there is a lack of sufficient evidence available to evaluate this concern. [42]

Inconsistent Delineation Methods

Coastal Act Section 30121 simply defines "wetlands" as "lands ... which may be covered periodically or permanently with shallow water and include saltwater marshes, freshwater marshes, open or closed brackish water marshes, swamps, mudflats and fens." According to the Coastal Commission's Interpretive Guidelines, the U.S. Fish and Wildlife Service's classification system (1979), commonly known as the Cowardin method,[43] is to serve as the guide for identifying wetlands. Local coastal programs contain the Coastal Act definition. However, only two out of ten LCPs in the ReCAP region reference the Cowardin method (or for that matter any particular delineation method).[44] Various other less encompassing methods have been and are performed for local and state agencies (typically through the CEQA process).[45] Recent wetland delineations are based on the U.S. Army Corps of Engineers' methodology for implementing the Clean Water Act, which itself has undergone changes in the past ten years.[46] Earlier EIRs and other documents often termed what would be "wetlands" under the Cowardin (and possibly the Corps) method as "drainage channels" or "riparian areas." Even the Coastal Commission's guidelines distinguish riparian areas as distinct from wetlands, a distinction not made by the Cowardin method.[47] Furthermore, Coastal Commission Interpretive Guidelines remain advisory. In fact, the Commission has substantial latitude to determine whether an area falls under the Coastal Act definition of "wetland".

The result of wetland delineation uncertainties has allowed some fills to escape Coastal Act Section 30233's requirements. For example, prior to development at Spanish Bay, which had previously been mined, drainage channels and ponds existed that would likely be classified as wetlands under the Cowardin method. However, EIRs and Coastal Commission findings described these features variously, and the Commission ultimately did not classify them as wetlands.[48] Commission staff explained that this was because they were unnatural, the results of water ponding in mined areas.[49] It appears that there was a net (permitted, but unstated) loss of approximately eight of these variously labeled wetland acres.[50]

Two other examples involved eight acres of "seasonally flooded grassland" at Neary Lagoon and about one-half acre of "man made degraded riparian channel" at Schwann Lagoon. Both were ultimately determined not to be "wetlands" by the Commission.[51] In these cases, project proponents (both public agencies: a city and a school district) offered biological opinions against the areas being "wetlands," while concerned citizens countered with pro-wetland biological determinations. Projects filling these areas were approved, without compensating mitigation in the case of Neary Lagoon.

Permitted Uses Without Guaranteed Compensatory Mitigation

Despite requiring compensatory mitigation for identified wetlands, the Coastal Act does not guarantee no net loss, especially of habitat value, because compensatory mitigation success is problematic at best.[52] Examples of the few restoration projects in the pilot area with monitoring tend to support this conclusion. Of two projects funded by and retrospectively analyzed by the Coastal Conservancy, one was a failure.[53] Also, the submitted reports for the Spanish Bay mitigation site, which has been monitored for five years, indicate general success of restoration. However, planted willows have not all survived, sediment has filled an area that now must be redredged, and unauthorized work has occurred.[54] At a mitigation site on the Old Salinas River channel, monitoring reports indicate that the plant communities are developing in a manner similar to that anticipated, with some non-native colonization and various revegetation rates.[55] Independent evaluation offers a more negative perspective, calling the project a mistake for removing an historic pickleweed marsh.[56]

A review of these and other monitoring reports shows continued oversight is necessary to discover problems and recommend corrections. Where staff training or availability is limited, mitigation success will be less assured. This review also suggests that although net wetland acreage may remain constant or increase if compensatory mitigation is successful, habitat differences may result and habitat value may be consequently reduced (see Endnote #14).

Thus, the more development permitted in wetlands, the greater the probability of some continued loss. Consequently, the more leeway in allowing development, the greater the probability of its occurrence. Out of 28 permitted projects involving wetland fill, four were for explicitly permitted uses under Section 30233a (boating and resource restoration) and seven were associated with urban development (which is not listed as a permitted use). The remainder were for public projects (flood control, roads, wastewater facilities) which in some cases may be considered incidental public services under 30233a.[57] Thus, there is a fair amount of discretion built into implementing this section. Local coastal programs have narrowed this discretion, generally limiting allowed development to resource-dependent uses.[58] Seven of these projects were permitted by local governments.

To the extent that riparian areas are not defined as "wetlands" for regulatory purposes (see delineation discussion), there is a higher risk of loss of this type of wetland. Although Section 30240 of the Coastal Act treating riparian areas as "environmentally sensitive habitats" could apply to such areas, the wetland mitigation standards in Section 30607.1 do not.[59] Thus riparian wetland areas may be especially at risk of being developed without adequate mitigation.

Emerging and Potential Responses

Initiatives to standardize delineation methods, achieve "no net loss" and guide restoration could help reduce future wetland loss. Tightening exemptions that allow wetland fill and increasing enforcement and education would provide additional help. Programs extending beyond regulation are also needed to restore and enhance historic wetlands.

Delineation

The Coastal Commission's recently published "Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone" reiterates the Coastal Act's broad wetland definition, suggests the importance of riparian area protection, and emphasizes early involvement in the CEQA process.[60] Comments on CEQA documents could request that appropriate wetland delineations are made early on in the project review process. Incorporating these concepts into the local governments' local coastal program implementation would be a logical follow up.

Federal agencies have standardized wetland delineation methods for regulatory purposes, and California's Resources Agency is attempting to develop a single state definition.[61] Such standardization, followed up with a manual and training course, has the potential to ensure more consistent and complete delineations. However, if the standardized methodology does not account for all wetlands protected under the Coastal Act, as previous attempts did not, then the CCMP will not benefit from this course of action.

No Net Loss

Both Governor Wilson and President Clinton have issued wetland policies that include the goal of "No Net Loss" of wetland quantity or quality.[62] The California Department of Fish and Game also operates under "No Net Loss" directives, applying to habitat values as well as acreage.[63] Codifying the no-net loss principle at all levels of government and establishing guidelines for implementation is a logical next step.

Mitigation Guidance

The Coastal Commission's Procedural Guidance for the Review of Wetland Projects offers criteria aimed at increasing the success rate of compensatory wetland mitigation efforts.[64] Its forthcoming Procedural Guidance for Evaluation of Wetland Mitigation Projects is expected to provide more detailed information. Incorporating the results of these in both the Commission's and local government's practices may improve wetland management.

Regulatory Reform

Possible changes to the Coastal Act and local coastal programs to further restrict allowed wetland uses would reduce the number of potential projects that could cause wetland loss. Such changes could include tightening agricultural exemptions, more explicitly defining and interpreting the categories of permitted uses (e.g., "incidental public services" and "restoration activities"), possibly eliminating some categories of permitted uses, strengthening the criteria for restricting permitted uses, and/or limiting the kinds of wetlands where the uses are allowed. Such initiatives would have to be undertaken in a manner consistent with Coastal Act requirements concerning constitutionally protected rights of property owners.[65] Recent court cases suggest the advisability of examining non-regulatory as well as regulatory innovations to protect remaining wetlands and/or strengthen compensating mitigation requirements.[66] Further impetus comes from the delineation of more areas now as wetlands (usually during the development review process) that do not "look like" wetlands, but have the requisite characteristics.[67]

Wetland Restoration and Creation Programs

Certainly additional regulation will not result in the reappearance of lost wetlands. The Coastal Act supports restoration where feasible. Similarly, the LCPs all mention objectives to restore and increase wetland acreage. In 1983, the Legislature called for an increase by 50% of wetland habitat acreage by the year 2000.[68] Moreover, Governor Wilson's new wetland policy calls for a long-term net gain in the quantity and quality of wetland acreage, as does President Clinton's.[69]

One "new" wetland was created just prior to the establishment of the Coastal Act. As part of a major condominium project, the 3.8 acre Shorebirds Lagoon was constructed north of Pajaro River in an area that earlier was salt marsh.[70] Since establishment of the Coastal Act, major restoration projects have occurred only at Elkhorn Slough and adjacent Parsons Slough. One hundred seventy-five acres of grazing land has been converted back to wetlands.[71] These projects occurred on property owned by the Department of Fish and Game and were publicly funded.[72]

At the beginning of 1994, there were commitments to undertake the following projects:

This latter project is being undertaken by a non-profit group affiliated with Moss Landing Marine Laboratories (Watershed Ecology Outreach Program). WEOP's strategy is to first obtain landowner permission and then to remove agricultural uses and plant with wetland vegetation on as much historic wetland area as possible in southern Santa Cruz and northern Monterey Counties.

Wetland Management Planning

Continuing to follow and improve the implementation of existing regulations should help ensure that additional wetland loss does not occur. Even more assurance can be gained by undertaking a more specific planning process focusing on individual wetlands and their watersheds. A plan for a single or group of wetlands can include an actual wetland delineation, identify specific permitted (from among the eight Coastal Act categories) and non-permitted uses, and recommend changes in any existing detrimental uses or trends (e.g., mechanisms to remove adverse grazing from wetlands). If a plan includes clear objectives, then it will be easier to determine what the least environmentally damaging project alternative would be. A plan can compare ownerships and management authorities to the proposed uses and management strategies and recommend necessary changes (e.g., public acquisitions of privately owned parcels in wetlands).

Wetland management plans could also improve the chances for successful restoration, both for mitigation and redressing historic loss. Such plans could establish objectives for restoration (e.g., optimal mix of habitat types) and identify locations in need of restoration.

Complementary broader-based watershed, natural communities, or regional plans could further guide wetland restoration efforts. Using a landscape-based approach, these plans can identify areas that were historically wetlands and are most appropriate to restore as wetlands; such plans can also identify opportunities to reduce fragmentation. The last section of this chapter discusses the status of and opportunities for these types of broader based planning initiatives.

RECOMMENDATIONS

Program Improvements:

Initial and Mid-range Opportunities:

With respect to preventing further wetland losses:

With respect to reversing historic wetland losses:

Wetland and Watershed Management Plans should:

Longer-range Opportunities:

With respect to preventing further wetland losses:

With respect to reversing historic wetland loss:

Opportunities for further study:


WETLANDS PROBLEM TWO


Inadequate Provision of Buffer Areas

Undeveloped upland areas adjacent to wetlands, which buffer the wetland from human development and activities, have diminished over time and will continue to do so, absent improvements in the regulatory process. This has led to the chronic loss of transitional habitat immediately adjacent to wetlands and a hardening of wetland edges.

ANALYSIS

The upland area adjacent to wetlands is an important habitat for many wetland species. These areas function as transition zones between wetlands and uplands and often exhibit characteristics of both habitats. In situations where development occurs on parcels with land adjacent to wetlands, some portion of the transition zone (usually closest to the wetland) may be left undeveloped and designated a buffer area. As a complement or alternative, restrictions on various activities or uses (e.g., lighting, pets, non-native landscaping) may also be placed on lands bordering wetlands. These areas act to protect the wetland from the direct effects of nearby disturbance (both acute and chronic), and provide necessary habitat for organisms that spend only a portion of their life in the wetland, such as amphibians, reptiles, birds, and mammals.

Buffer areas are incorporated into a significant number of coastal development permits; however, the conditions requiring the establishment and use restrictions of buffer areas are not consistent, and in some cases the resulting buffer area is ineffective due to the small size or non-permanent protection (e.g., no easement or deed restriction). A review of the ReCAP database shows that of the 97 projects permitted adjacent to wetlands, 38 projects (40%) included buffer areas as a permit condition. In those 38 projects, buffer widths ranged from 5 to 500 feet. Of course, buffers are not required for activities, such as on-going agriculture, that are exempt from or predate the permit process. Although it is known that buffers can reduce the adverse affects adjacent development has on a wetland, scientific studies to determine the appropriate size of a buffer are rare.[76] In addition, no investigations have been completed to determine how variations in buffer width have affected wetland resources. Nevertheless, there is a definite need to require buffers, and current standards should be refined as the requisite studies are completed.

Development projects that occur near wetlands often affect the wetland edge as well. Site visits by Coastal Commission staff offered the most revealing information regarding the condition of wetland edges and adjacent transition zones. Staff inspected 20 (20%) of the 99 wetlands identified in the project area. Adverse impacts to the wetland edge and/or transition zone were noted at fourteen of the wetlands inspected (Table 5-2). A time series view of Neary Lagoon (Figure 5-6)[77] provides a clear example of how urban development has obliterated the transitional zone and hardened the edges of this wetland, a scenario common to many wetlands surrounded by urban development. Although many of the documented changes pre-date the Coastal Act, the impacts from these changes continue to the present. For example, agricultural development adjacent to wetlands often includes a cultivation area extending up to the wetland edge. During drought years, the wetland will recede as water inputs are reduced. The cultivation area is then extended into the "now dry" wetland area. In urban areas, transition zones adjacent to wetlands have been used to provide additional public facilities (e.g., lawns, picnic benches, barbecues, and tennis courts) to enhance recreational opportunities. In addition, wetland banks are often armored where roads and railways occur. Ultimately, the loss of transition zone habitat results in the severing of important ecological connections between the wetland and the surrounding landscape. In addition, the hardening of wetland edges limits the ability of wetlands to evolve in response to both natural and anthropogenic alterations. Cumulatively, the loss of transition zone habitat and the hardening of wetland edges have resulted in major adverse impacts to the quality of wetlands in the project area.

Table 5-2: Adverse Impacts to Wetland Edges and Transition Zones

Figure 5-6: Time Series of Development Changes, Neary Lagoon, 1853-1994.

Click here to view Figure 5-6 Panels 1-4 of 8 OR Figure 5-6 Panels 5-8 of 8.

The requirement for buffer zones around wetlands is a contentious issue. The Coastal Act does not contain specific requirements for buffer zones, just general policy language for compatible, non-impacting adjacent development (Section 30240b), so landowners may consider all adjacent upland areas available for development. Although the Coastal Commission's Statewide Interpretive Guidelines (1981) suggest a minimum 100 foot buffer zone around wetlands, in practice wetland buffer widths are determined on a case-by-case basis with widely disparate results. [78] A review of the certified local coastal programs (LCPs) and land use plans (LUPs) covering areas with wetlands shows buffer area provisions vary among local jurisdictions (Table 5-3). The point from which the buffer is measured also varies.[79] These inconsistencies in LCP/LUP buffer area provisions no doubt compound the problem of inconsistent application. Furthermore, most LCPs allow exceptions to the stated criteria, if accompanied by some biological evaluation that a lesser buffer will suffice.

Table 5-3: LCP/LUP Provisions Relating to Wetland Buffer Areas

The scientific information necessary to determine the proper size of a buffer area in California is lacking, so it is not known if any of the LCP/LUP buffer provisions are truly adequate. This problem also carries over to questions regarding the structure a buffer area should provide. Leaving buffer areas in a natural state has obvious advantages, but may not provide proper protection to the wetland from adjacent development. For example, one common objective of buffer areas is to prevent domesticated animals from entering a wetland. Often the most straightforward solution is to erect a fence in the buffer area; however, this would restrict wildlife movement between the wetland and adjacent uplands. Clearly, our lack of information regarding the functions of buffers compounds the policy and procedural problems associated with securing buffer areas as a condition of development.

Regulated (e.g., urban) and unregulated (e.g., agricultural) development are both continuing sources of impacts to transitional zones and wetland edges. Although land use analyses suggest full buildout has nearly been reached in several portions of the project area, population levels are projected to increase. Thus, development pressure will continue. Likely areas for urban development include south Santa Cruz County and North Monterey County. Both areas contain substantial wetland resources including three large slough complexes: Watsonville Slough, Elkhorn Slough, and Moro Cojo Slough. Strong agricultural interests will remain in the project area well into the future. Cultivation practices may begin to change in the near term as a result of concerns over nonpoint source pollution; however, practices affecting buffer areas and wetland edges will probably not change substantially unless specific regulations are implemented.[80]

Based on these analyses, there is little doubt that transition zones and wetland edges will continue to be adversely affected in the future unless changes in management strategies are made. The chronic loss of these areas will adversely affect the quality of wetland habitat eventually leading to a loss in biodiversity and overall degradation of the resource. This is the situation in much of Southern California where the majority of wetlands exist in a degraded state and increasing wetland biodiversity is a primary objective of wetland conservation and restoration projects.

Continuing to follow and improve wetland setback regulations will help ensure that development near wetlands does not adversely impact the resource. Even greater assurance of protection is possible by undertaking a more specific planning process focusing on individual wetlands and their watersheds. A plan for an individual wetland can include an actual wetland delineation, allowing setback requirements relative to an accepted reference point. An inventory of, analysis of, and resultant plan for a wetland can result in a recommended buffer zone tailored to the attributes of that wetland (i.e., its species' needs and its habitat types). A plan can establish one or more optimal buffer zones along the wetland's entire perimeter depending on the type of adjacent development. It can include recommendations to manage the buffer zone and enhance it where degraded or where incompatible uses have encroached. The final problem section of this report details the status of and opportunities for this type of wetland planning.

RECOMMENDATIONS

Program Improvements:

Longer Range Opportunities:

Wetland and watershed management plans should:

Opportunities for further study:


WETLANDS PROBLEM THREE


Impacts to Wetland Hydrology

The hydrology of most wetlands within the project area has been adversely affected by development.

ANALYSIS

The hydrology of coastal wetlands is made complex by their location at the interface between upland and aquatic environments.[81] Tides, waves, currents, freshwater discharge, and ground-water seepage are all important, but variable, elements of coastal wetland hydrology.[82] In California, wetland hydrology will also vary markedly with season, with many wetlands becoming dominated by freshwater during the winter/spring rainy period.[83],[84] In addition, the hydrology of wetlands in the project area is directly affected by the multi-year drought/flooding events that pervade California's climate.

A number of factors, both anthropogenic and natural, can affect the hydrology of wetlands. When human development alters a wetland's hydrology, the changes can adversely affect wetland size, water quality, and habitat quality. For example, past development in the coastal zone, particularly roads and railways, have muted (e.g., at Bennett Slough and Corcoran Lagoon) or in some cases completely severed (e.g., Upper Watsonville Slough and Schwann Lagoon) the connections these coastal wetlands had with the ocean. In most cases a road or other structure was built through the wetland reducing the size of one or more channels and resulting in the placement of culverts, weirs, or tide gates that restrict or exclude tidal flow. As a result, the amount of water that these wetlands receive and the movement of water through the wetland have been diminished. In addition, earthquakes have influenced the hydrology of some coastal wetlands in the project area. For example, the 1989 Loma Prieta earthquake increased the amount of saltwater reaching some wetlands (e.g., Struve and Bennett Sloughs) by rupturing the roads and culverts that restricted tidal flows,[85] and by lowering bottom elevations.

Information reviewed and compiled by ReCAP suggests the hydrology of virtually all wetlands within the project area has been altered to some degree by human activities, such as dam building, road construction, and urban and agricultural development in the surrounding watersheds.[86] A sequence of activities on the Salinas River illustrate the timing and type of activities which have adversely affected numerous wetlands within the region (Table 5-4). Cumulatively, these activities, which mainly occurred prior to the Coastal Act, have resulted in a reduction of the amount of salt- and/or freshwater reaching the wetlands, and changes in the timing and velocity of water flowing into the wetlands. However, natural events within the ReCAP project area have also affected hydrological processes. For example, the drought of 1987 to 1992 resulted in reductions in the amount of freshwater reaching all wetlands. In contrast, the Loma Prieta earthquake in 1989 increased the amount of saltwater reaching some wetlands. The anthropogenic alterations to wetland hydrology have tended to compound the effects of these natural processes leading to synergistic cumulative impacts, including reductions in water quality, changes in habitat composition, and reductions in habitat size and biodiversity.

Table 5-4: Sequence of Human Activities Affecting the Salinas River Watershed[87]

Thirty-five of the wetlands identified in the pilot area are true coastal wetlands, having one or more connections with the ocean (Table 5-5). Of these, 15 have a perennial source of freshwater. Thus, although marine processes dominate the hydrology of these wetlands, freshwater inputs are an important part of the overall hydrology. These coastal wetlands occur at the mouths of rivers as small estuaries or lagoons, or as large systems such as Waddell Creek Marsh and Elkhorn Slough. Sixteen wetlands have a perennial source of freshwater but no connection with the ocean. The hydrology of these wetlands is a function of the freshwater supply, which although always present, will vary with season and weather patterns (e.g., droughts and floods). Coastal and freshwater wetlands with an intermittent supply of freshwater account for 69% of the wetlands in the project area (Table 5-5). These include Arana Gulch, the Marina vernal ponds, and Spanish Bay wetland. The hydrology of coastal wetlands with intermittent freshwater inputs is dominated by marine processes. The freshwater supply to these wetlands will vary with surface runoff, which is highly seasonal.

Table 5-5: Gross hydrologic categories of wetlands in the ReCAP Pilot area

Natural hydrological changes in freshwater supply to a wetland can be inferred through an examination of river outflow data. For example, river outflow data for the Salinas River (Figure 5-7), show annual freshwater inputs between 1983 and 1993 were largely related to regional weather patterns. Freshwater flows were highest in 1983, an extremely wet year, and lowest during the drought years, 1987 through 1992. For those 15 coastal wetlands having a perennial freshwater source, these outflow data suggest hydrological conditions within the wetlands were dominated by marine processes over much of the last ten years. Typically, such a change in hydrology would result in increased salinity throughout the year, and could affect species' distribution and abundance. For example, several species of fish use coastal wetlands as nurseries in the spring when brackish (moderate salinity) waters prevail. During a drought there may not be enough freshwater to maintain brackish conditions throughout the wetland, forcing the fish to reproduce (often less successfully) further upstream or in a different wetland. In this way, substantial droughts, such as occurred between 1987 and 1992, could adversely affect reproductive output of some wetland dependent organisms. For those 64 wetlands relying solely on freshwater as a water source, the impacts could be more direct. The drought related loss of water to these wetlands would result in a reduction in the size of the wetland and loss of wetland habitat.

Figure 5-7: Salinas River Outflow at Sprekles, California

Hydrologic processes within some coastal lagoons occurring in the project area illustrate the interaction between natural and anthropogenic processes and the results that these interactions can have. Several of the major wetlands in the project area are coastal lagoons (e.g., Waddell Creek Marsh, Soquel Creek, Salinas River Lagoon, and Carmel River Lagoon), and thus subject to closure through the formation of berms at the mouth. The opening and closing of a lagoon mouth is fundamentally a natural process; however, anthropogenic alterations such as the upstream diversion of freshwater, excess siltation, or reconfiguration of the mouth have led to unnatural alteration of the timing and extent of this process.

Extended closure of a lagoon mouth can have numerous adverse affects including increasing the potential for flooding, causing extreme changes in water quality, and blocking fish migration. Three examples in the project area with coastal development permits illustrate some of the processes used to prevent the adverse impact of lagoon mouth closure:

(1) Santa Cruz harbor (Arana Gulch) was historically a coastal lagoon that was altered for use as a marina. Hydrologic conditions within the marina coupled with nearshore ocean currents require nearly constant dredging to maintain the harbor mouth. The harbor district has permits to operate a suction dredge at the mouth for much of the year at considerable cost. Even so, the mouth has closed several times over the last ten years inhibiting navigation in and out of the harbor, and resulting in the production of foul odors and fish kills.
(2) The lower San Lorenzo River is another coastal lagoon whose mouth has often closed during the summer, due to low flows and beach buildup. These closures have increased the potential for flooding and could adversely impact salmon and steelhead fish migration. A coastal development permit[89] was approved for placement of an outflow control device at the mouth, as an alternative to artificial breaching. However, the water elevation control device was never installed and the City later abandoned its permit due to liability concerns, so breaching is still proposed.[90] Currently, the Army Corps of Engineers has plans to dredge the lower river channel to improve flood storage capacity; this project would also increase the tidal prism and could reduce the incidence of mouth closures.
(3) Soquel Creek is in a situation similar to the San Lorenzo River. However, unlike the San Lorenzo River, a coastal development permit[91] was obtained to operate a water level control and fish bypass system and to allow breaching of the mouth as necessary. These examples, although of a common problem, illustrate three different approaches taken to achieve a remedy.[92] Overall, these three wetlands have been maintained as lagoon ecosystems, although at substantial costs to the public and natural resources.

Excess erosion or sedimentation is the most obvious result of changes to wetland hydrology. In terms of assessing the magnitude of this problem, Elkhorn Slough is the most well studied wetland within the ReCAP project area. A recent study[93] found that the construction of Moss Landing Harbor in 1946 dramatically altered the Slough's hydrology and initiated ongoing erosion. Between 1988 and 1993, approximately 420,000 cubic meters (approximately 70,000 cubic meters per year) of material was eroded from the subtidal portions of Elkhorn Slough. In addition, intertidal saltmarsh habitat has been retreating from the center of Elkhorn Slough at an average rate of 18 centimeters per year (cm/yr.) since 1946. Present day rates of saltmarsh edge retreat average 39 cm/yr. Thus, excessive development-induced erosion has been a chronic problem in Elkhorn Slough over the last 47 years, and the rate of erosion is increasing.

Meanwhile, excessive sedimentation is an ongoing problem in upper Elkhorn Slough. A recent report by Belden et. al.[94] found that two-thirds of the total sediment (approximately 178,070 tons/years) entering Elkhorn Slough is due to erosion from strawberry farms, although strawberry farms comprised only eight percent of the land use within the watershed. These unnaturally generated sources of excessive sediment will accelerate the conversion of wetland habitat to upland habitat. As wetland habitat is lost, fewer wetland dependent species can be supported. Existing policies governing land use in the coastal zone emphasize the protection of agricultural lands, limiting the regulatory alternatives for controlling agriculturally generated excessive sedimentation.[95]

Although human-induced acceleration of erosion and sedimentation are considered adverse impacts, these processes do occur naturally and play an important role in wetland ecology. A review of aerial photographs taken in 1977, 1986, and 1993 shows the location and size of some coastal wetland outlets have changed over time. For example, the outlet of Waddell Creek Estuary migrated north about 1000 feet between 1986 and 1993. At Scott Creek, the main channel was approximately 75 feet wide in 1986 (an extremely wet year), but only about 20 feet wide in 1993. The San Lorenzo River mouth was approximately 350 feet wide in 1986, but only about 50 feet wide in 1993, when substantially different shoaling and beach conditions existed. In 1986, the Salinas River flowed through the north lagoon before entering the ocean; however, in 1977 and 1993 the river entered the ocean well south of this lagoon. These examples illustrate how wetland hydrology contributes to the dynamic nature of wetlands, an aspect critical to the long-term maintenance and health of this resource.

Changes in wetland hydrology will also affect the plants and animals within a wetland. Reducing the amount of water available to the wetland will alter the types of organisms that occur in the wetland and the density of organisms the wetland can support. For example, Valencia Lagoon is a freshwater wetland that supports the Santa Cruz long-toed salamander, an endangered species. The hydrologic function of this lagoon is critical to the existence of this species. Reductions in salamander density have been linked to a loss of habitat due to adverse impacts to the wetland hydrology stemming from road construction.[96] Similarly, changes in wetland hydrology can result in water quality changes, which in turn can affect the resident biota. The discussion on the closure and maintenance of coastal lagoon openings above is a good example of the relationship among hydrology, water quality, and wetland biota.

Many of the factors affecting wetland hydrology do not occur directly in the wetland, but rather within the wetland's watershed. The project area includes portions of nine major watersheds (Figure 5-8). Much of the drainage area of these watersheds occurs outside the coastal zone; however, many of the wetlands within the pilot area occur at the ends of streams, rivers, and other drainage areas within the coastal zone, and are directly affected by activities occurring throughout the watershed. Urban development increases the amount of impervious surface within the watershed, leading to increased runoff rates and channelization. Timber harvesting and agriculture have resulted in increased rates of erosion and nonpoint source pollution.

Figure 5-8: Boundaries of Hydrologic units in the ReCAP area. Click here to view Figure 5-8.

Urban and agricultural development also increase local needs for freshwater, reducing the amount of water flowing through the watershed and altering the timing of those flows. For example, aerial photograph analysis shows the existence of a substantial number of small detention ponds within the project area (Figure 5-9). These ponds are primarily used by agriculture and industry, but some may serve other functions as well. The ponds are generally small, but together cover a substantial area (Table 5-6). Some ponds are created through impoundment of small streams, but most are created in dry areas and filled with well water.[97] Between 1977 and 1993, the number of ponds increased by 51%. No doubt the presence of these detention ponds has affected the way water moves through the watershed. Although the ecological affects of these ponds are not well studied, it should be mentioned that these ponds are not without benefit. Perennial ponds can provide suitable habitat for freshwater marsh plants, and have increased the distribution of small freshwater wetlands over a broader area.[98] These ponds can provide resting and foraging habitat for migrating birds and wetland dependent animals. Yet it is unknown whether the benefits of these detention ponds outweigh the costs.

Figure 5-9: Relative location and number of detention ponds in the ReCAP area. Click here to view Figure 5-9.

Table 5-6: Summary Information for Detention Ponds

Overall, substantial portions of many watersheds associated with the project area have undergone significant development. Unfortunately, due to jurisdictional boundaries, regulations, for the most part, are not developed or enforced on a watershed basis. For example, between 1988 and 1992, the Department of Fish and Game processed 11 stream bed alteration agreements for projects located in Struve Slough. Although none of these projects occurred in the coastal zone, they all have affects on other locations in the watershed through alterations in the amount and timing of freshwater flows. This is a prime example of how adverse cumulative impacts could continue to occur within the ReCAP project area regardless of any procedural or policy changes made within the coastal zone, and why new watershed-based approaches for addressing these issues must be developed.

A review of the region's LCPs/LUPs shows that with the exception of Santa Cruz County, development projects affecting wetlands are not limited based on their potential to alter wetland hydrology (Table 5-7). Santa Cruz County's LCP contains policies prohibiting construction that alters saltwater inflows to coastal lagoons and limits some dam development based on instream flow requirements. In addition, none of the LCPs/LUPs contain explicit requirements for mitigating adverse impacts to wetland hydrology. Regulation of new development cannot solve hydrologic problems caused by on-going activities. Half of the LCPs/LUPs do suggest programs to restore hydrologic functions in wetlands, but funding and other program implementation is not specified.

Table 5-7: Results of LCP/LUP Review for provisions relating to Hydrologic Alternations

The process for regulating adverse impacts to wetland hydrology is complicated by the fact that wetlands comprise only a portion of larger watersheds that span multiple jurisdictions. Yet a wetland's hydrology is inextricably linked to hydrologic processes within the associated watershed. Hydrologic manipulations at wetland outlets would most likely remain in the Coastal Commission's original permit jurisdiction. However, alteration of freshwater flows could occur anywhere in a watershed. As mentioned previously, the coastal zone includes only a small portion of the watersheds in the Monterey Bay area, and other jurisdictional boundaries often bisect one or more watersheds. Activities permitted in one jurisdiction can have a direct affect on the hydrology of a wetland in another jurisdiction if these jurisdictions share the same watershed.

In terms of future trends, adverse impacts to wetland hydrology will continue unless changes are made to current regulatory and management practices. Although major development activities resulting in the largest changes to local hydrology have long since been completed, population projections suggest substantial increases in regional population over the next decade. Higher population levels would increase the demand for natural resources such as water and require additional development. Undoubtedly this would result in further degradation of wetland hydrology absent comprehensive mitigation measures. In addition, development in other parts of the coastal watersheds will continue. This development could also contribute to the cumulative degradation of coastal zone wetland hydrology. Meanwhile, numerous opportunities exist to restore and enhance the hydrologic functions of wetlands within the region. These projects could provide positive benefits both to the individual wetlands and in a cumulative sense to the natural resources within the region. Efforts to pursue all possible restoration opportunities must continue at all levels of government and within the community.[99] A new publication by the California State Coastal Conservancy entitled Options for Wetland Conservation, A Guide For California Landowners (1994) provides valuable information relevant to this issue.

Continuing to follow and improve existing regulations will help ensure that hydrologic impacts from new development do not occur or are adequately mitigated. Even more assurance can be gained by undertaking a more specific planning process focusing on individual wetlands and their watersheds. Such a plan can describe current and optimal hydrologic conditions to serve as a basis for analyzing new projects.[100] Such a plan can also anticipate likely hydrologic manipulations (e.g., river lagoon breaches) and provide criteria for (or recommend alternatives to) them. Finally, a wetland management plan can also review existing hydrologically-impacting structures (e.g., a broken tide gate) or activities (e.g., pumping) and recommend remedial actions.

There is a definite trend by many government agencies to use a watershed approach as the basis for comprehensive natural resource planning. This approach offers additional opportunities for the management and conservation of wetland hydrology based on processes and activities occurring throughout the watershed. In addition, this approach could help to reduce duplication, foster cooperation and consistency, and result in more efficient use of limited government funds. Such a plan can recommend regulatory improvements to uniformly apply to new development in the watershed as well as necessary programs to address existing contributory activities and uses. The final problem section of this chapter outlines the status of and opportunities for such planning initiatives.

RECOMMENDATIONS

Program Improvement:

Revise local coastal programs to:

Wetland and watershed management plans should:

Opportunities for further study:


WETLANDS PROBLEM FOUR


Impacts To Wetland Water Quality

The water quality status of most wetlands within the project area is unknown, although some wetlands are known to have suffered adverse impacts due to human development.

ANALYSIS

Water quality is defined here as the physical, chemical, and biological integrity of a water body. Proper wetland water quality is necessary to provide an environment that not only supports the existence of wetland plants and animals but allows for their reproduction and growth. Thus, water quality is a direct measure of the health of a wetland. However, interest in wetlands has intensified recently, because of the ability of wetlands to enhance water quality. Through a variety of processes, wetlands are able to remove sediments and both organic and inorganic pollutants from the overlying water.[101],[102]

Unfortunately, much of the water quality information available in the project area is inappropriate or unsuitable for determining the long-term cumulative impacts to wetland water quality. Although a large amount of water quality data has been collected from wetlands within the pilot area, most of the information was collected to answer project specific questions. In addition, sampling methods and testing criteria vary considerably. Thus, much of the available data cannot be readily used to establish general water quality conditions or long-term trends for specific constituents. A 1976 assessment of water quality conditions in Santa Cruz County found that "in-depth examination of the surface and ground water historical water quality records indicates that there is insufficient information to adequately define the long-term, short-term, and areal variations for most of the County".[103] A recent assessment of water quality information by the Monterey Bay National Marine Sanctuary shows relatively little is still known about the quality of water in the project area 

(Table 5-8).

There is information that shows nonpoint source pollution is adversely affecting some wetlands in the project area at various times. For example, there are numerous reports of elevated coliform bacteria counts.[104],[105],[106] Elevated bacterial concentrations typically occur after winter storms, suggesting nonpoint source runoff is responsible. Although coliform bacteria problems mainly occur in wetlands surrounded by pasture lands and agriculture, there have been reports of problems in urban areas. Neary Lagoon provides a recent example. It is estimated that Neary Lagoon receives nearly two-thirds of Santa Cruz city's urban storm water runoff.[107] Fecal coliform levels in excess of 500 percent of the State and Federal water quality standards have been documented in the lagoon.[108] This situation has persisted for a number of years, and only recently has the Regional Water Quality Control Board required Santa Cruz City to apply for a federal discharge permit in an attempt to regulate this problem.

The introduction of pesticides, heavy metals, and other pollutants into wetlands in the project area is of ongoing concern. Unfortunately, long term monitoring data are generally not available. Additionally, the in-depth studies necessary to identify, track, and quantify these pollutants are generally cost prohibitive. The few studies completed show pesticides do exist in some wetlands within the project area. Specifically, studies of Moro Cojo Slough, Elkhorn Slough, Moss Landing Harbor, and the Salinas River Lagoon all concluded that pesticides do occur in these wetlands.[109],[110] Pesticides are thought to enter these wetlands with nonpoint source runoff from surrounding agricultural areas. In contrast, heavy metals and other pollutants such as domestic sewage are thought to enter wetlands with urban runoff. Thus, these pollutants are most prevalent in wetlands surrounded by urban areas and large developments such as central Santa Cruz County, the city of Marina, and Spanish Bay. Urban runoff into some of these wetlands can be substantial given their size. For example, 28% of the watershed draining into Majella Slough (approximately 25 acres) is now part of the Spanish Bay development.[111] Also, Marina Vernal Pond # 1 (approximately 10 acres) receives runoff from approximately 13 acres of an adjacent stretch of Highway One.[112] Thus, while it cannot be determined if water pollution in the project area is widespread, there clearly are areas of concern.

As with hydrology and morphology, many of the factors affecting wetland water quality do not occur directly in the wetland, but rather occur within the wetland's watershed. Along with urbanization come new sources of pollution (e.g., household pesticides, fertilizers, motor oil, and cleansers) that can enter the watershed with stormwater runoff. Timber harvesting and agriculture can result in increased rates of erosion and nonpoint source pollution. These sources of pollution have had adverse impacts on wetlands located in both urban (e.g., Neary Lagoon and Schwann Lagoon) and agricultural (e.g., Elkhorn Slough, Upper Watsonville Slough, and Tembladero Slough) areas.

Point source discharges also exist within the project area. A review of current waste discharge permits shows there are 13 active discharges into local streams and 5 active discharges into local wetlands.[113] These discharges include treated sewage, overflow from settling ponds, cooling water, and effluent from vegetable and meat processing plants. The exact effects of these discharges are not fully known.

A review of the LCPs/LUPs covering areas with wetlands, revealed all but one included some pollution control requirements (Table 5-9). (The City of Pacific Grove's policy is simply to investigate potential pollution problems.)[114] Requirements include provision of erosion controls, as well as sediment and grease traps, which are implemented on a case-by-case basis. Maintenance of such devices is generally stipulated, but there are no requirements to monitor specific pollutants or potential project related sources. With the exception of Pacific Grove, all LCPs/LUPs require wetlands to have buffers (which can help protect wetland water quality). In no case has an analysis been performed leading to information on maximum acceptable pollutant loading into a wetland. All but two LCPs (Capitola's and Watsonville's) suggest programs aimed at reducing existing pollution problems; however, Capitola has recently adopted a management plan to do so for Soquel Creek, its only wetland.

Table 5-9: Results of LCP/LUP Review for Provisions Relating to Water Pollution

It is hard to predict future trends for water quality in the absence of appropriate information. Land use analyses suggest full buildout has nearly been reached in several portions of the pilot area. If more recent activities such as infill development and changes in zoning decline as full buildout is reached, then the adverse impacts to water quality from development activities should stabilize. In contrast, population projections suggest substantial increases in regional population over the next decade. Higher population levels would increase the potential for pollution, particularly nonpoint sources. However, government agencies, such as the Coastal Commission, Monterey Bay National Marine Sanctuary, and Regional Water Quality Control Board, continue to refine and enhance education programs and regulatory measures aimed at reducing and/or preventing impacts to water quality. One such effort is the Coastal Commission's project of special merit to address polluted runoff.[115] These agencies must remain proactive in their work to safeguard water quality. Although the constraints and costs to the individual may at times seem excessive, the cost of remedying chronic and cumulative adverse impacts to water quality is many times greater. Left uncorrected, the cumulative degradation of water quality will ultimately have adverse affects on many other economic resources (e.g., tourism, agriculture, and fishing) within the region.

Continuing to follow and to improve existing regulations will help ensure that adverse water quality impacts from new development do not occur or are adequately mitigated. However, as discussed in the preceding Hydrology section, real progress in addressing water quality is best achieved through watershed planning and management. Such a planning process can comprehensively address all sources polluting a wetland and coordinate responsibilities for controls and remediations. The final problem section of this chapter outlines the status of and opportunities for such planning initiatives.

RECOMMENDATIONS

Program Improvements:

Longer Range Opportunities:

Wetland and Watershed Management Plans Should:

Opportunities for Further Study


WETLANDS PROBLEMS FIVE


Impacts To Wetland Biodiversity

An understanding of wetland biodiversity in the project area is necessary to fully protect and manage wetland resources. However, such an understanding cannot be determined at this time due to a lack of appropriate information. Nonetheless, there are indications that wetland biodiversity has declined due to human impacts.

ANALYSIS

The plants and animals that exist in or rely on wetlands comprise the biological component of the wetland ecosystem. Providing the function of wetland biodiversity, that is, providing the resources that result in the existence and reproduction of a diverse array of species, is considered one of the most important functions of wetlands today. Measurements of species' number and their abundance is one way to quantify the value of this function. The establishment of exotic species, the number of special status species, and changes in the number and abundance of native species are indicators of changes in biodiversity. A reduction in biodiversity is indicative of a wetland that has suffered adverse impacts.

There are several cases where actual changes in biodiversity have been noted; the majority of cases conclude that a reduction in native species has occurred.[117] In terms of animals, fewer steelhead have been found in Carmel River Lagoon, clams have virtually disappeared from Moss Landing North Harbor (once part of the Old Salinas River Channel), fewer fish occur in the Pajaro River Marsh, and fewer invertebrates populate the Salinas River Lagoon. In terms of plants, non-native species have supplanted cattails in Gallighan Slough after it was deepened by peat harvesting, lupines in the UC Santa Cruz Inclusion Area A Seasonal Wetlands disappeared after heavy grazing, vegetation changed at Majella Slough as a result of mining activities, and willows died in the Blohm-Porter Marsh (a portion of Elkhorn Slough) after harbor construction opened it to tidal influence. Grazing and agriculture in McCluskey Slough are thought to have resulted in a loss of native species and a concurrent increase in introduced species. These changes may be responsible for a decline in the abundance of Santa Cruz long-toed Salamanders, which inhabited McCluskey Slough.

Although a large amount of biodiversity data has been collected for wetlands within the project area, much of this information is inappropriate or unsuitable for determining the long-term cumulative impacts to wetland biodiversity. For example, numerous studies contain information related to plant biodiversity. However, a review of several reports shows the study results are highly dependent on the amount of time spent completing the survey and the area covered. Various biological surveys of wetlands in the pilot area found between 2 species of plants in Moro Cojo Slough and 249 species of plants in Elkhorn Slough (Table 5-10). On average, 36 species of plants were found.[118] Surprisingly, few surveys identified the number of special status (rare, threatened, or endangered) species. Slightly more information was available for exotic species.

Table 5-10: Examples of Plant Species Biodiversity Survey Results[119]

Fewer studies included information relating to animal biodiversity (Table 5-11). Much of the data was categorized among animal groups such as mammals, birds, amphibians, and fish (Table 5-12). However, making comparisons among wetlands using these data would be erroneous without first standardizing the data based on a common level of survey effort. As with plants, the data was quite variable. For example, two different surveys of Elkhorn Slough identified 7 and 404 animal species respectively (Table 5-11). Few surveys identified special status species or non-native species. All of the survey reports containing animal species abundance or distribution data reported data for various groups of animals (e.g., birds, mammals, reptiles, etc.). Birds were most commonly identified, followed by mammals. Methods for completing such surveys were rarely stated, although the results suggest a high degree of variability. In particular, many reports included listings of "species that may potentially occur in the wetland based on the presence of appropriate habitat". Identification of appropriate habitat was based on gross observations.

Table 5-11: Examples of Animal Species Biodiversity Survey Results[120]

Table 5-12: Animal Species (By Group) Biodiversity Survey Results[121]

In general, little can be concluded from the review of this data. Much of the variability among surveys is attributed to methodological differences, rather than actual differences in biodiversity. Although repeat surveys were completed in several wetlands, generally the time span between surveys was relatively short. One exception was two surveys completed for Marina Vernal Pond #1. These surveys conducted in 1978 and 1992 found similar numbers of plants and animals in the wetland (Table 5-10 and Table 5-11), although species numbers among animal categories varied somewhat (Table 5-12). Given the available data, however, it is not possible to directly determine the cumulative impacts to wetland biodiversity. These findings point to the critical need for standardized methodologies in assessing wetland biodiversity. The methods used should yield the information necessary to answer project specific questions, as well as the appropriate information for assessing the cumulative impacts to biodiversity over time and space.

Other types of data were also examined in an attempt to characterize regional changes in biodiversity. The presence of special status species or their habitat may provide an indication of a change biodiversity. An inverse relationship presumably exists between biodiversity and the number of special status species. That is, as overall biodiversity is negatively impacted, more species are placed in jeopardy of extinction, some of which receive special status listing (34%). As the number of special status species increases so does the number of habitat types critical to their existence. So the presence of special status species or their habitat may be indicative of a decline in a wetlands' ability to maintain biodiversity. A review of the ReCAP database shows 34 wetlands within the pilot area either contain special status species or appropriate habitat. This suggests that species biodiversity in the project area has been adversely impacted.

A review of the LCPs/LUPs within the region showed they all provide indirect protection for biodiversity through the recognition and enhanced protection of select habitats. Typically, the LCPs/LUPs specifically identify select habitats (e.g., habitat for the Santa Cruz long-toed salamander) or specific areas (e.g., Laguna Grande) that are rare or have received recognition because of their uniqueness in the local area. These habitats are identified as environmentally sensitive habitat areas, which severely limits development under the provisions of Coastal Act Section 30240. However, is it not known if the indirect approach incorporated into LCPs/LUPs to protect biodiversity is preventing the loss of wetland species or appropriate habitat.[122] This suggests a more consistent, direct, and proactive approach is needed to ensure the preservation of wetland biodiversity.

Although there are indications that wetland biodiversity is decreasing in the project area, the lack of consistent long-term biological (e.g., species abundance and distribution) and ecological (e.g., habitat type and condition) information prevents predictions of future trends. In addition, changes in the regional biodiversity of wide ranging species such as birds are affected by processes occurring outside the project area and outside the region, further confounding predictions of future trends. The analyses above suggest that the future condition of wetland biodiversity is to some extent related to land use changes within the region. On a basic level, additional development that directly or indirectly affects wetlands will affect biodiversity.

Continuing to follow and improve the regulatory process can help ensure that new development does not further affect biodiversity. Even greater assurance can be gained by undertaking a more specific planning process focusing on individual wetlands and their watersheds. A plan for an individual wetland can more specifically identify permitted uses, mitigation measures, and buffers to protect its specific plants and animals. Furthermore, in identifying existing habitat types, hydrologic systems, and water quality, such a plan can recommend improvements that would conserve or enhance biodiversity as well. Complementary broader-based natural community, watershed, and regional planning can further advance biodiversity protection and restoration at the level necessary to address entire habitats of species that frequent wetlands and the activities and land uses that affect them. The final problem section of this chapter outlines the status of and opportunities for such planning initiatives.

RECOMMENDATIONS

Program Improvements:

Longer Range Opportunities:

Wetland/Watershed Management Plans Should:

Opportunities for Further Study


WETLANDS PROBLEM SIX


Information Gaps In Decision-Making Process Need To Be Addressed

Each stage of the decision-making process regarding wetland projects -- from project conception and wetland identification to follow-up monitoring and management -- could be improved with the generation of better information and by improving access to that information.

ANALYSIS

Information Problems

ReCAP has found that analysis of cumulative impacts to the project area's wetlands is hampered by the lack of readily available and useable data. Direct access to reliable and accurate data is important in all stages of the CCMP in order to improve identification of wetlands, to assess impacts, to develop appropriate alternatives and mitigation measures, and to evaluate condition compliance and restoration success.

In reviewing Commission and local government permit files, ReCAP found the problem of information gaps evident in several aspects of the CCMP:

Wetland Identification

Knowledge of a wetland's existence and boundaries is crucial to managing the resource. Coastal managers need direct access to an inventory of wetlands to guide wetland site identification and delineation. Without such information, a site visit may not be performed or a wetland may be missed. Access to reliable, updated site delineations would further increase assurance of wetland identification and appropriate regulatory action. Access to maps and descriptions of individual habitat types would also assist coastal managers in identifying adverse impacts and in devising appropriate mitigation requirements.

ReCAP discovered cases where identified wetlands were not acknowledged in previous regulatory actions. These cases arose where previously approved projects were never built and new site information become available upon project resurrection. For example, at Terrace Point, environmental studies in 1981 and 1987 failed to note any wetlands (the area was under cultivation), whereas a 1994 field investigation revealed four wetland areas totaling 12 acres.[123] At a site formerly called Villa Nueva or Rolling Hills I, a small ponded area and a swale not identified in 1982 and 1986 are now delineated as "wetlands" under standard criteria applied by the U.S. Army Corps of Engineers. [124]

Previous efforts to inventory, locate, and delineate all of the area's wetlands have been incomplete. To date, the wetland location map provided in this report is the most comprehensive listing of all of the area's wetlands (see Figure 5-2). Yet, there is no single repository for wetland delineation maps. The U.S. Fish and Wildlife Service began a national wetland inventory program, the National Wetland Inventory, in the 1970's. Although all of the ReCAP area in Monterey County was inventoried, only about 50% of Santa Cruz County has been inventoried.[125] ReCAP identified 99 wetlands totaling about 6200 acres based only on staff review of the literature and aerial photography interpretation. However, some of the wetlands identified by ReCAP staff are not shown on the National Inventory maps. Further, only 59 wetlands (61%) were identified in the aggregate by background work done in the late 1970's to the early 1980's for the Local Coastal Programs (Table 5-13).

Table 5-13: LCP Wetland Identification

It should be noted, however, that the wetlands not identified in the LCP documents are comparatively small, representing only about 3% of the total wetland acreage. The categories of wetlands identified by ReCAP, but not in the LCPs, include:

The existence of some of these wetlands became evident through the regulatory process. Generally, they were noted in environmental impact reports or in biological investigations that were based on actual field work.

The wetland regulatory process would be improved if coastal managers had direct access to a complete inventory of wetland resources. Development of such an inventory will necessitate detailed field work. In turn, successful field work would require manuals and training to identify appropriate indicators, as well as the necessary time, maps, and other tools to perform a complete delineation. Ultimately, wetland management would benefit if all the region's wetlands and their component habitats were named and accurately mapped on a computerized Geographic Information System (GIS) directly accessible to all.

Informational Requirements

In order to increase ease of access to available information, improvements could be made in how information is collected in the regulatory process. Also, ensuring timely and complete information from all permit applicants will assist coastal decision makers in providing a prompt, fair and thorough review. To foster a scientific basis to regulatory actions, it is also important that the information is prepared by qualified persons.

ReCAP encountered a range of informational requirements for projects involving wetlands and varying responses. For example, the California Environmental Quality Act (CEQA) requires biological analysis, but its guidelines do not address specific wetland parameters. Furthermore, approximately one-third of coastal permit applications from 1983-1993 involving the region's wetlands have been found exempt from CEQA provisions. The Coastal Commission staff recently completed a Wetlands Procedural Guidance Document for the Review of Wetland Projects, which lists items that should be included in permit applications.[126] Santa Cruz County has a tiered system. Initially staff performs a biotic evaluation, and based on the results, may then require a more thorough biotic report prepared by a technical specialist.[127] Monterey County's Local Coastal Program appendices spell out required contents of biotic reports. Such reports are required for sites containing or adjacent to a wetland. A cursory review of biological reports submitted with local and Coastal Commission permit applications showed a wide range in content.

In reviewing authorized developments, ReCAP found that monitoring requirements for restoration and mitigation projects varied greatly. Out of 39 projects, 20 required monitoring and 6 apparently did not (the record was unclear for the remaining 13 projects). The most common monitoring period was 5 years. Although thorough evaluation of the scope and effectiveness of local monitoring programs was not attempted, a common finding of a preliminary review was the lack of appropriate information including goal statements, baseline condition presentations, and as-built descriptions and assessments.[128] Currently, the U.S. Army Corps of Engineers has thorough monitoring report guidelines.[129] These guidelines could be used by other agencies who currently lack them. The Coastal Commission is currently developing a procedural guidance document that provides information useful to developing wetland monitoring plans.

Reports submitted with permit applications and monitoring reports typically present only project-specific information (see Water Quality and Biodiversity sections of this chapter and the Coastal Commission's Elkhorn Slough Watershed monitoring report[130]). As a result, cumulative impacts on wetland systems are difficult to quantify. Overall biodiversity or water quality may be declining in a wetland system, while the specific plant species that a project was required to protect or enhance may be flourishing, or the specific discharge that a project was required to control may be lower in concentration than the ambient condition. Ultimately, agreement should be reached on specific standardized indicators and protocols for all required project and monitoring reports.

Systematic Presentation Allowing Cumulative Impact Finding

The background section to this chapter illustrates a systems diagram for wetlands (see Figure 5-4). Depending on the complexity of a project, analysis should assess how the project impacts each component of the system. A systematic understanding is also necessary to recommend and to evaluate appropriate alternatives or mitigation measures. Watersheds would typically define the outer system boundaries. As is the case for wetlands, common identification and descriptions of watersheds is lacking in the region.[131]

A review of 20 coastal permits involving development in and adjacent to wetlands in the Live Oak area of Santa Cruz County revealed that analysis focused almost exclusively on the subject project and site. As illustrated in Table 5-14, there was little discussion of the project areas in the context of the wetland system and hence potential cumulative impacts to wetlands were rarely addressed.

Table 5-14: Cumulative Impacts Analysis Characterization in the Regulatory Process(Live Oak Area)

In other cases, more extensive analyses of cumulative impacts have been attempted.[132] One notable example is at Neary Lagoon where a massive wastewater treatment plant was proposed adjacent to the wetland. As indicated in Figure 5-6, this proposal followed a series of other adjacent developments. The project's EIR qualitatively attempted to discuss the cumulative effect of these structures which "walled" in the lagoon bird habitat.[133] In other cases, cumulative impacts have been addressed (in a limited sense) but the mitigation deferred. For example, permits allowed immediate culvert repairs coupled with the longer-term development of monitoring and/or management plans.

Cumulative impact analysis has also been employed in the regulatory process for two wetland watersheds. At Valencia Lagoon, a breeding pond for the endangered Santa Cruz long-toed salamander, the total amount of potential development was analyzed. As a result, each individual project had to conform to measures intended to mitigate cumulative effects. At Elkhorn Slough, development was supposed to stay within targets designed to prevent
cumulative erosion problems. Until these targets were developed (as part of the local coastal program process), new subdivisions were denied, pursuant to the cumulative impact provision in Coastal Act Section 30250(a).
While comprehensive wetland and watershed planning can best address cumulative impacts (see last section of this chapter), regulators meanwhile develop and use limited cumulative impact information in reviewing individual projects, as these examples illustrate.

Agency Information Sharing and Coordination

Coastal managers can use existing resources more efficiently by sharing information and expertise. Efforts have begun in the pilot region to do this, through ReCAP, the Monterey Bay Initiative and the Coastal Aquatic and Marine Projects Information Transfer System (CAMPITS) program. Development of further mechanisms to share information about other agencies' actions and to increase coordination prior to decisions can improve wetland management.

There are some examples of intergovernmental coordination mechanisms that are useful in resolving potential wetland management problems before much project design and investment has occurred. For example, the U.S. Army Corps of Engineers holds voluntary, monthly interagency meetings (before applications are filed) for projects requiring Corps' Section 404 permits. The Department of Fish and Game, Environmental Protection Agency and other appropriate agencies are invited and usually attend; the Coastal Commission is invited for projects in the coastal zone. Roughly 25% of the applicants to the Corps take advantage of these pre-filing meetings, with a higher attendance rate for larger projects.[134] Although exact figures were not gathered, a number of coastal permits involving wetlands have been the subject of these interagency meetings. In other cases, coastal planners often make informal contact with other agency personnel, but no tabulated accounting of such contacts is available.

After the Coastal Commission approves a permit involving a wetland, it typically conditions permit issuance to receipt of other agency permits, such as those of the Department of Fish and Game and the U.S. Army Corps of Engineers. In contrast, very few locally-issued coastal permits are conditioned for receiving other agency approvals.

In the absence of consolidated wetland project review, coastal managers can continue to improve their information base by increasing and formalizing interagency contacts.[135]

Access to Hydrological and Biological Expertise and Training

Some level of scientific training is desirable for staff involved with the planning, regulating, or managing of wetlands. For example, in order to identify wetlands, a certain level of biological expertise is necessary. In order to understand the wetland system components discussed in this report, knowledge of hydrology and biology is helpful.[136] A basic knowledge of these factors and relationships is helpful in suggesting the contents of environmental reports, in developing alternatives and in making informed decisions. A review of coastal permit applications involving wetlands shows that many technical issues are posed. Out of 64 projects in wetlands, 26 posed hydrologic issues. The majority of these involved culverts and/or associated water control devices or sand bar breaching. A review of restoration projects, discussed above, also showed technical issues present in determining success and suggesting corrective measures.

Coastal managers could improve the ability to evaluate these technical issues by increasing access to, and sharing, available scientific expertise and training. Currently, state and local coastal managers seem to gain information and assistance in wetland science through information in EIRs and the consultants preparing these documents, from the staff of state and federal resource agencies and, in some cases, from Commission technical staff. In cases where biologic information is required, the providers have usually had biological training. A small number of consulting firms with specific wetland expertise and experience now provide the bulk of the technical information required by permitting agencies in the project area. For example, a review of five projects with EIR's in the Live Oak area showed that the preparers of at least the three most recent ones included biologists.[137] LCP requirements for wetland reports typically specify preparation by a "qualified" biologist. Technical consultation and information is sometimes provided to coastal managers by staff of the Department of Fish and Game and the federal resource agencies. Although the Department of Fish and Game (DFG) is a central source of expertise for the Coastal Commission, DFG personnel availability has limited the number of consultations in the region.

Given limited staff and resources, mechanisms need to be developed to make more efficient use of existing expertise in wetland systems. Mechanisms to share staff and to develop staff training programs and technical assistance programs can help increase access to, and knowledge of, wetland management.[138]

Information Storage and Retrieval

The greater the availability of useful information, the more informed staff and decision-makers can become. Varied accessibility has resulted in an uneven approach to using relevant information. Initial steps to improve access to available records were taken in the establishment of the Coastal Resource Information Center in the Commission. Cataloguing and access to available documents is ongoing, albeit slowly. Efforts are underway to make access to library catalogues available from Commission computers. ReCAP examined over 350 documents from Commission records concerning the area's wetlands, but less than 10% are catalogued in the Coastal Commission's library to date. Setting priorities for cataloguing the reminder of these documents would help accelerate access to this information. In the process of ReCAP, many wetland-related reports prepared by other agencies or academicians were discovered that were not known to or available to staff or decision-makers. The same wetlands may be identified by different names and in different ways, thus making comparison among reports difficult. Maps of individual wetland are scattered among these different sources and are of varying scale and quality. It is apparent that there is a fair amount of technical information existing which would help coastal managers and decision makers if it were more directly available.

Emerging Informational Improvements

The above analysis suggests several areas where information or its use can be improved. Fortunately, some improvements are emerging as discussed in the following examples.

One agency, the Department of Fish and Game, is comprehensively reevaluating its programs. The Coastal Commission has recommended increasing information exchange and increasing input on coastal permit decisions from that Department as a way to improve implementation of the CCMP.[139] The Clean Water Act allows for state assumption of some Corps permitting functions in wetlands. While this program has generated controversy and is not necessarily recommended for California, pursuit of the concept may lead to protocols for better utilization of expertise and information among state and federal agencies.[140]

With regard to mapping wetlands and watersheds, the Coastal Commission has available computer hardware and software that should eventually enable the storage and retrieval of such information. Some local governments have such capability, but none has a complete file of computerized wetland identification maps. The State Department of Forestry and Fire Protection is digitizing watershed boundaries for the whole state. Santa Cruz County plans to name its delineated watersheds and perform further, more individualized watershed mapping. The Commission could play an important role in coordinating these efforts.

ReCAP developed a computerized wetland database to summarize information on permits, morphological, physical, chemical, biological, bibliographical, and basic attribute information that it has reviewed. After the database modules are completed and an operational guide written, the database will offer an opportunity fo r agencies and the public to use and exchange the available information.

Informational Relationships To Wetland Planning and Management

Not only will improvements in the flow of information directly assist wetland management and regulatory decision-making, its use in the planning process may lead to improved decision-making. The wetland and watershed management planning processes described in the following section of this cha pter can base recommendations on compiled and analyzed information. The resultant plans thus provide the context on which to base future decisions. For example, a plan may describe an optimal wetland system, including restoration areas and standards. A subsequent applicant could then incorporate such provisions as project mitigation.[141] Planning also offers an avenue through which to address cumulative impacts. Plans can set maximum densities or coverages or requirements that assure cumulative impact thresholds are not exceeded. Individually permitted projects then have to simply comply with these requirements without the need to generate extensive original cumulative impact information. In the above-mentioned cases for Valencia Lagoon and Elkhorn Slough, such provisions were incorporated into the local coastal programs. While regulatory evaluation may still be necessary after planning is complete, it could be performed within a pre-defined context relying on directly available information. Acceptance of such plans by all agencies with regulatory authorities might lead to future efficiencies in the decision-making process itself.

On a regional level, improvements in the flow of information can lead to its use in setting priorities for wetland and watershed improvement initiatives as well as to identify gaps to be addressed by future research. A logical next step would be to identify an appropriate regional framework for wetland information compilation and dissemination.

RECOMMENDATIONS

Program Improvements:

Initial and Mid-Range Opportunities:

With regard to wetland and watershed identification:

With regard to information requirements:

With regard to cumulative impact information:

With regard to interagency information sharing:

With regard to training

With regard to information storage and retrieval:

Wetland and Watershed Management Plans should:

Longer-Range Opportunities:

Opportunities for future research:

See also, the Information Management section of this report.


WETLANDS PROBLEM SEVEN


Comprehensive Wetland Planning and Management Framework Is Absent

The lack of a comprehensive wetland and watershed management framework has led to piecemeal decisions that do not fully protect the region's wetlands. In particular, individual decisions made on projects in wetlands without comprehensive management plans cannot readily account for cumulative impacts.

ANALYSIS

The California Coastal Management Program's primary implementation mechanism -- regulation under local coastal programs -- does not fully address the cumulative impacts to wetlands identified earlier in this chapter. LCPs primarily address new development, whereas ReCAP found that in the pilot area, existing uses and activities are the more significant contributors to cumulative effects. LCPs cover only the coastal zone, but activities throughout a wetland's watershed may have substantial cumulative effects on wetlands in the coastal zone. Many watersheds are bisected by the coastal zone; for some watersheds, only a small portion resides within the coastal zone. LCPs are divided by political jurisdiction, whereas some cumulative effects on wetlands are regional. LCPs primarily regulate the jurisdiction's land use actions, and not typically the regulatory or management actions of other agencies with authority over wetlands (e.g., a Department of Fish and Games decision to allow hunting in a wetland). On the other hand, LCPs can set fairly specific land use standards, but are often not of the detail needed to address many wetland cumulative impact concerns. Initiation of proposed LCP amendments are at the discretion of the local governments, so new or more detailed wetland initiatives are not automatically incorporated into an LCP.

Another complicating factor is that some wetlands or parts of wetlands remain under Coastal Commission permit jurisdiction, even after local coastal program certification.[142] The same regulatory limitations noted here that local governments operate under also apply to the Commission's permitting authority and to some extent, its federal review authority.[143] In some cases, a project in or affecting a wetland may require two separate coastal permits -- one from the Commission and one from the local government -- further fragmenting the decision-making process. The preceding sections of this chapter conclude that new planning and management initiatives at various geographic and jurisdictional levels are necessary to more completely address the identified problems.

Considerations for Wetland Planning by Geographic Area

Within the complex regulatory, ownership, and management milieu that affects wetlands, a strategy to address both the broad and specific aspects of cumulative impact concerns is already emerging in the pilot area. Four levels of planning and resultant management are operating: by region, watershed, jurisdiction, and wetland. Another level, encompassing natural communities, may become a factor. Building on this framework in the short-term and possibly refining it in the longer-term offers a means to further protect wetland resources.

Region

The Monterey Bay National Marine Sanctuary's Integrated Coastal Management (ICM) process is a particularly promising prospect for coordinating regional wetland planning and management in the project area. Through the ICM process, the various agencies with wetland management responsibilities could gather and disseminate information on all the area's wetlands and respective watersheds; continue to analyze the identified problems, especially their interrelationships in a regional context; prioritize problem areas needing attention; and guide and coordinate solutions. Several states and regions are undertaking such an approach, including the San Francisco Bay area, which may serve as useful models.[144]

To date, efforts to plan for wetlands on a regional basis in the Monterey Bay area have been limited: U.S. Fish and Wildlife Service's National Wetland Inventory simply mapped wetlands by habitat type for part of the area in the mid 1970's; Santa Cruz County's Parks, Recreation, and Open Space Plan of 1972 identified many of the County's wetlands and recommended that they be the subject of specific plans; the Coastal Conservancy reviewed the status of wetlands in the area and listed 21 potential enhancement projects in 1979; the California Assembly Resources Committee listed 24 project area wetlands and causes of acreage loss; and Santa Cruz County's local coastal plan called for a (not yet established) task force to identify and prioritize key restoration projects and available funding.[145] Currently, as part of state and federal efforts to protect sensitive sites from oil spills, an inventory and protection strategy for the area's tidally influenced wetlands is being developed.[146] Concurrently, the State prepared an Ocean Resources Management Plan which includes a mapped inventory of sensitive managed areas.[147]

The current ICM process is an interagency effort to protect Monterey Bay's water quality, under the auspices of the Strategic Environmental Assessments (SEA) division of the National Ocean Service's Office of Ocean Resources Conservation and Assessment.[148] As part of the establishment of the Monterey Bay National Marine Sanctuary, a number of agencies, including the Coastal Commission, signed a Memorandum of Understanding to prepare a water quality protection program for the Bay. Using a computerized database, the ICM team has gathered some available water quality and related information, including wetland characteristics for 34 of the major wetlands in the area, and combined the data by aggregate watersheds.[149] Prioritization of problem areas and a resultant regional water quality plan are the expected results. Altering its focus and possibly its structure (e.g. membership, time frame) to include wetland issues besides water quality and to present its findings by individual watershed would be necessary to accomplish the strategy envisioned here.

A logical next step would be to approach SEA and the ICM participants to discuss whether they are interested in assuming this role. If not, other entities could assume the lead effort, such as the Association of Monterey Bay Area Governments (AMBAG, the regional planning agency), the U.S. Environmental Protection Agency, Watershed Ecology Outreach Program, the Coastal Commission, or an interagency task force (which would require some entity to take the lead in organizing it).[150] Major players would also include academic researchers, as much scholarly work on area wetlands could be shared with decision-makers; private consultants, who have collectively amassed the most information on the area's wetlands; and the public, including various user groups. If in the future regional governance emerges, coordination of wetland protection efforts as described here could be one of its functions.

Watershed

At the watershed level, there is no uniform structure nor single entity with comprehensive responsibilities to address cumulative impacts on wetlands; rather, ad hoc advisory groups are forming for individual watersheds. Watershed planning and management are critical to address activities, uses, and growth patterns that affect wetland hydrology and to some extent biodiversity, as discussed in this chapter.[151] Watershed planning is becoming quite popular as a means to address polluted runoff.[152] Wetland protection would be an integral, but not exclusive component or objective of watershed plans, which could also address other issues, such as flood protection and resource utilization.

To date, one watershed plan has been completed in the region. The San Lorenzo River Watershed Management Plan addresses water resources, erosion and sedimentation, flood hazard, water quality, fishery resources, vegetation and wildlife resources, and recreation, scenic and historic resources.[153] It originally had no specific wetland component, but one was developed in a subsequent process.[154] Two draft Carmel River Watershed Management Plans were prepared covering many of the same topics as the San Lorenzo plan.[155] Watershed issues continue to receive attention in the planning for a new dam on the Carmel River.[156] The North Monterey County Land Use Plan was partially based on a watershed analysis to limit sedimentation into Elkhorn Slough.[157] Watershed planning programs are in the formative stages for Soquel Creek, Pajaro River, and Elkhorn Slough. Four wetland based management plans, including the one for Elkhorn Slough, and two which are under preparation, contain some provisions that address activities beyond, but affecting, wetlands proper (but are not comprehensive watershed plans).

The forthcoming watershed initiatives in the pilot area may occur under the auspices of CRMP (Coordinated Resource Management and Planning). Sponsored by a range of state and federal agencies, this planning approach

addresses the dilemma of managing areas with multiple-use ownership, conflicting management objectives and requirements, conflicting land-use demands, and offsite impacts.... CRMP integrates and coordinates resource uses to accomplish specific goals... The process is designed to achieve compatibility between the land and resource uses... All resources are effectively managed for short-term and long-term use and perpetuated for future generations in a condition of high quality.[158]

In the future, more standardized and formalized watershed-based governance entities may emerge which could assume the noted functions. In anticipation of increased watershed planning activities, a logical next step would be continuing to review and enunciate appropriate procedural and content options. As a start, each section of this chapter contains recommendations for topics to include.

Wetland

At the individual wetland level, there is no set structure to address cumulative impacts; rather, a variety of wetland management plans have been and are being prepared under varying circumstances and auspices.[159] Wetland plans provide an opportunity to comprehensively address and relate all wetland issues. Wetland management plans are broadly construed in this analysis to comprehensively address regulation, management, acquisition, restoration, enhancement, monitoring and the like for entire wetland systems. Table 5-15 lists some elements common to wetland plans.

Table 5-15: Frequency of Topics Included in Wetland Management Plans

To date, wetland planning has been extensive. Nineteen wetland plans (some covering multiple wetlands) have been or are being prepared (and another two are just underway). Eighteen out of the 25 largest wetlands are covered.[160] However, as Table 5-15 indicates, these plans are far from comprehensive. Out of the 11 noted topics which ReCAP found to be important in managing cumulative impacts, the average number covered per plan is half (5.5); with a range from 2 to 11.[161] Having standard guidelines for wetland plan contents could improve the ability to manage wetlands.

To achieve solutions to all wetland problems, the planning process requires the participation of affected owners and managers, as well as the public.[162] No one structure appears best for management plan preparation; evaluation of the approaches used to date would be instructive.[163] As noted, wetland plans can result in recommendations for action within watersheds. Conversely, a watershed analysis can lead to wetland recommendations that more comprehensively address cumulative impacts. While logically it would appear that watershed planning should precede (and provide the information base and parameters to) wetland planning, the latter process is currently more advanced and easier to undertake because the geographic scope is typically smaller. At this point, proceeding on both geographic tracks is worthwhile, as long as there is openness to future amendments to ensure consistencies.[164] If a regional framework becomes operational, it could schedule and coordinate future wetland and watershed planning efforts more efficiently.

Jurisdiction

At the City and County level, land use planning is universal; but, as noted, its ability to address wetland issues is limited. In the pilot area local coastal program land use plans were predominantly prepared in the early 1980's, prior to preparation of most wetland management plans. As noted, LCPs are not at the level of detail of subsequent management plans. Local coastal programs for Marina, North Monterey County and Santa Cruz City, for example, simply call for preparation of wetland management plans, although lack explicit criteria for doing so. Santa Cruz City recently amended its local coastal program to incorporate policies and excerpts from its completed management plans; Monterey County, on the other hand, did not.[165] Because many management plans were prepared pursuant to its enforcement and permit issuance authority, the Coastal Commission formally reviewed them. Since most were not explicit components of the LCPs, they have not been amended into the California Coastal Management Program.[166] Future plans may not receive Coastal Commission review (or formal review) or local jurisdictional review unless required as a condition of a locally-issued coastal permit or to resolve an enforcement action.

The CCMP requires local coastal plans to have land uses, intensities, and locations as well as development criteria that result in wetland resource protection, consistent with Coastal Act Sections 30231, 30233, and 30240. ReCAP found that the region's LCPs generally conform; a few improvements can be made as recommended in this chapter. Subsequent wetland and watershed planning can apply these LCP policy and use parameters, as well as other factors, and arrive at a greater level of detail necessary to address wetland resource issues (as Table 5-15 indicates, many wetland plans to date lack a land/water use component). If a wetland planning process results in recommended land use changes (e.g., decreasing maximum bare ground exposure to prevent sedimentation into a wetland or maximum densities in areas served by septic systems to reduce nutrient loading), then commensurate, follow-up LCP amendments will be required (as well as general plan revisions to cover beyond the coastal zone). Broader structural changes in the CCMP, involving integrating watershed and wetland management planning and implementation within the local coastal program or another process, are worthy of evaluation. This should be undertaken in the context of ReCAP's overall investigation of how the CCMP can address all cumulative resource impacts.

Implementation Authority

A comprehensive wetland management plan will likely contain a series of recommendations to address adverse cumulative impacts. Some of these may address minimizing impacts from new development (e.g., setbacks, erosion controls) that can be incorporated into the existing regulatory process. However, other recommendations may address how to manage existing natural processes and existing development; for example, recommendations to remove invasive vegetation, adjust existing tide gates, or sweep streets to prevent polluted runoff. It will thus be necessary for wetland plans to identify appropriate authorities and provisions. Since various authorities may be involved in implementation, they should also be part of the planning process. As Table 5-15 notes, only 7 out 19 plans have significant implementation components and interagency coordination provisions.

ReCAP identified the following complexities that affect implementation of wetland management recommendations in the pilot area: private ownership, multiple ownership, public authorities with competing mandates, extra area authorities, and inadequately constituted authorities.

Private Ownerships:

Many wetlands appear to be at least partially in private ownership.[167] In some cases the owner is knowingly committed to wetland protection (e.g., the Nature Conservancy and the Santa Cruz County Land Trust). In some cases owners have given easements to other entities for management purposes. The extent of other private ownerships engaged in, willing to engage in, or willing to let others engage in protective stewardship is unknown. A logical next step would be to assemble an accurate picture of ownership status (including easement status) and intentions for all of the region's wetlands including their buffer areas. Also, dissemination of general information on private protective stewardship options for wetland owners need not wait for a formal planning process.

Multiple Ownerships and Responsibilities

A second management complexity involves multiple ownerships and responsibilities. At least 11 wetlands are under multiple ownership -- some of these involve a mix of public and private holdings. An example of the management dilemmas encountered with multiple owners involved Lower Bennett Slough. The Slough is separated from Moss Landing Harbor North by a road with culverts, which failed in the 1989 Loma Prieta earthquake. Moss Landing Harbor is under public trust authority by the harbor district. The road is owned by the County; the lower Slough, by the Department of Parks and Recreation and private parties; and the crossing to the upper Slough, by CALTRANS. Since the proposed repair project affected the wetland hydrology, all of these ownerships were potentially affected.[168] After much discussion agreement was reached on a project that could be adjusted in the future if a comprehensive wetland management plan is ever developed.

Beyond ownership, many agencies have management responsibilities which affect Monterey Bay's wetlands. These are not necessarily the same agencies with regulatory responsibilities. Even in the case of a single owner undertaking its own project, other agencies may be involved in regulation, funding, and the like. For example, at Laguna Grande, the three primary owners, the cities of Seaside and Monterey and the Monterey Peninsula Regional Park District, united under a joint powers agreement to undertake a restoration project. Five other agencies also played significant roles.[169]

Public Authorities with Competing Mandates

While some wetlands are owned by public agencies and managed for resource purposes (e.g., at least 16 wetlands are owned by the Department of Parks and Recreation and many have been placed in Natural Preserve status), a few portions of wetlands are owned by CALTRANS, Port Districts, or local governments who have placed management under public works departments. These agencies' stated missions (e.g., flood control, transportation) often conflict with resource management objectives. And, in the cases of breaching coastal lagoon mouths mentioned above, the responsible public agencies are other than the actual owners.

Extra-area Authorities

This chapter has documented instances of development occurring outside of, but affecting, wetlands. In the cases of dams on the Carmel, Salinas, and San Lorenzo Rivers, for example, the managing authorities do not own the downstream wetlands.

Inadequately Constituted Authority

As solutions to cumulative impacts are developed, the logical implementing entities may not exist, may lack authority to fully carry out the recommendations, or may not be adequately constituted to perform the required tasks (e.g., may lack staffing, budget, equipment, training, motivation, etc.). In North Monterey County, for example, a preventative program is in place to clean up soils eroded onto roadways so they will not wash into Elkhorn Slough and then bill property owners for costs. However, program evaluation discovered that soil is sometimes left on the road and that property owners are not always billed. The responsible agency operates the program for traffic safety, not environmental, purposes and lacks staff time and funding.[170] In Santa Cruz City, the Neary Lagoon Management Plan presented a series of recreational, water quality, and habitat management improvements and identified various city departments with authorities to undertake them.[171] However, what was missing was an entity with authority to oversee and coordinate implementation. To remedy this long-standing problem, the plan recommended creating a coordinator position, which was subsequently authorized, funded, and filled. In turn that coordinator has engaged students and volunteers to perform identified tasks that city departments were constrained in performing.

As each wetland is likely to have different management needs, it will be incumbent upon the development and subsequent monitoring of each plan to identify detailed implementation strategies. In some cases, identifying new or restructured authorities or positions, with proper funding, training, and the like may be necessary.

Conclusion

In conclusion, planning for wetland resources requires an understanding of the relationship of all the system components and the effects on them as illustrated in Figure 5-4. It then requires responses that address all of the topical issues at the appropriate geographical levels -- wetland, watershed, region, and jurisdiction. Likewise, knowledge of all the responsible and needed authorities, and a commensurate implementation strategy is necessary to carry out planned long-term management and restoration.

Addressing the information gaps in the decision-making process at the project level would also assist comprehensive plan preparation and implementation. Maintenance and use of a computerized, regional database to enable easy access to ownership, management, project status, watershed locations and similar information for each wetland, such as developed by ReCAP staff, would support and further the identified wetland planning initiatives.

RECOMMENDATIONS

Program Improvements:

Initial and Mid-Range Opportunities:

With regard to a regional framework:

With regard to watershed management planning:

With regard to wetland management planning:

With regard to management authorities:

Wetland and watershed management plans should:

Over the longer term:

Opportunities for further study:

ENDNOTES

  1. See, for example discussion in Chapter 1 of California Coastal Commission, Procedural Guidance For the Control of Polluted Runoff. 1995.
  2. Williams M. Understanding wetlands. Pages 1041 in M. Williams [ed.]. Wetlands: A Threatened Landscape. Alden Press Ltd., Oxford, England. 1991.
  3. For more detailed discussions of individual regulations see Environmental Law Institute. Wetlands Deskbook. Washington D.C. 1993
  4. Dennis, N.B. and M.L. Marcus. Status and Trends of California Wetlands. Final report prepared for the California Assembly, Resources Subcommittee. 1984.
  5. Note that diagram does not necessarily reflect the sequence of project review.
  6. Note that the "coastal zone" as defined in the Coastal Act does not include San Francisco Bay, which is the jurisdiction of the Bay Conservation and Development Commission.
  7. Allowed uses within wetlands include: port-related and coastal-dependent industrial facilities; maintenance dredging; mineral extraction (except in environmentally sensitive areas); restoration projects; nature study, aquaculture, or similar resource-dependent activities; and incidental public service purposes such as utilities.
  8. Since local coastal programs were certified, predominately in the early 1980's, they have been amended, in regard to wetland issues, at least forty times in the aggregate. In many cases, the amendments facilitated development adjacent to wetlands, both private and public (e.g., a park, wastewater treatment plant). On balance, the overall result is slightly more intense development around wetlands; but in some cases, lower adjacent intensities have resulted. In only two cases, did the amendments result in development in wetlands; one for a landfill, one for a school. In these cases, "riparian" rather than wetland loss was acknowledged and compensating mitigation was incorporated (see Problem One section of this Chapter). In general, local coastal program wetland provisions have remained largely in tact since original certifications. California Coastal Commission. ReCAP database. Wetlands and Local Coastal Program modules.
  9. The number and nomenclature of the project area wetlands is somewhat arbitrary. For example, the Independent Report on Environmental Considerations for the Marina Freeway (Caltrans, 1973) and subsequent Environmental Analysis for the Coastal Zone of the City of Marina (Biosystems Analysis, San Francisco, 1980) identified a wetland impacted by the new Highway 1 as Marina Vernal Pond #6. Three nearby ponds were identified as Marina Vernal Ponds #9, 10, and 11. Years later, a Coastal/Vernal Pond Comprehensive Management Plan (Habitat Restoration Group, Felton, 1993) fails to identify Pond #6 (which still exists) and instead calls Ponds #9-11 "Pond #6."
    Some connected water bodies have been given different names (e.g., Laguna Grande and Roberts Lake) and hence, in some cases, are listed as separate wetlands in the California Coastal Commission ReCAP wetland database. On the other hand, there are some connected water bodies or discernible components that are listed as a single wetland (e.g., Elkhorn Slough which includes such components as South marsh, North marsh, and Blohm Porter marsh). Separate water bodies are usually listed separately (e.g., Marina Vernal Pond #1 and #2, etc.), but occasionally are grouped under one name, especially when they were likely once connected (e.g., Pajaro River mouth includes the small seasonally wet pond to the south). Riparian areas were generally not listed unless they were specifically described as wetlands in the literature, a trend that has been increasing in recent years. Detention ponds, golf course ponds, and other artificially created water bodies are not listed.
    This exercise identified as wetlands four sites that would require on-site biological evaluation to arrive at a final determination: Indian Head and Fort Ord Pond in the Fort Ord dunes, Pacific Grove Municipal Golf Course swale, and DeAnza Mobile Estates pond.
    As ReCAP progressed and new field delineations were made, additional small, non-tidal areas were determined to be wetlands. Although within the already listed wetland systems, they are disjunct and could merit separate nomenclature and database entries. In addition to those noted by Moro Cojo Slough (see Endnote #130), these include: an acre wetland behind an old concrete spillway on Wilder Creek about one mile above the lagoon (according to Short, Rob and Brown, Kathy, Wilder Creek Watershed: Facts, Photos and Fish Barriers, UCSC paper for ENVS 167, Santa Cruz, Spring 1994); a freshwater seep adjacent to Old Dairy Gulch (and three others on its tributaries) about one mile above the lagoon (according to Jones & Stokes Associates, Wilder Sand Quarry Draft EIR, Sacramento, August 1994); and a half-acre native marshy slope on a bend of Moore Creek about one mile above Natural Bridges Lagoon. (according to Strelow, Stephanie, Sphere of Influence Amendment, Local Coastal Program Amendment, General Plan Amendment, and Prezoning of Meder Street Properties, Revised Draft EIR, Santa Cruz, December 1990, p. 28.)
  10. California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994. These results are based on an analysis of wetland acreage in the ReCAP project area using the following methodology: the identification and subsequent acreage determinations of wetlands in the project area were completed via manual interpretation of the Coastal Commission's existing vertical color aerial photographs obtained in 1977-78, 1986, and 1993. The nominal scale of the source photography is 1:32,500 (1 inch equals approximately 2,700 feet) for 1977, and 1:12,000 (1 inch equals 1,000 feet) for 1978, 1986, and 1993. Aerial photographs covering each wetland area were examined stereoscopically, and detailed notations were made. Remarks were predominately qualitative, however, in certain cases approximate measurements of length and area were made for purposes of comparison. Although the resolution of the aerial photographs will readily allow detection of linear changes of less than 50 feet, and area changes on the order of less than an acre, the images are not rectified (i.e., free from geometric distortion), nor are they orthogonal (i.e., planimetrically correct). Therefore, the results are considered approximations, appropriate for rough assessments of change only. In addition, other factors such as vegetation composition, seasonal changes, time of day, tidal stage, sun angle, film type, and aircraft position all affect the ultimate content of the image and its utility for wetland analysis. A limited number of wetlands in the pilot area were visually inspected in the field as a means of corroborating photographic analysis; however, these site visits were generally of a reconnaissance nature, and involved no actual surveying.
  11. Trophic dynamics relates to the sources, sinks, and flux of energy within a wetland and the translation of that energy into new individuals. This process is most straightforward for plants using measures of primary productivity.
  12. Johnston, C.A. "Cumulative Impacts to Wetlands". Wetlands. 14(1)49-55. 1994.
  13. Tiner, Ralph W. Jr., Wetlands of the United States: Current Status and Recent Trends, for U.S. Fish and Wildlife Service, Washington, D.C., 1984 notes the net loss of approximately nine million acres of wetlands nationally, since the 1950's, mostly due to agricultural development. Estimates for California's historic loss, (see for example, Gosselink and Baumann, "Wetland Inventories: Wetland Loss Along the United States Coast," Z. Geomorphology., N.F. Suppl.-Bd., 34: 173-187) do not include an estimate for the Central Coast area. Nearby San Francisco Bay is estimated to have lost nearly 95% of its historic wetlands according to Josselyn, Michael, The Ecology of San Francisco Bay Tidal Marshes. Washington, D.C., 1983.
  14. Whether a habitat change is environmentally adverse or not depends on the entire wetland system and any management goals. In the Elkhorn Slough system, for example, increased open water habitat at the expense of vegetated salt marsh habitat and increased salt water at the expense of inland freshwater habitat have resulted in a management plan strategy aimed at reverting the affected area to more historic conditions. See, ABA Consultants, Elkhorn Slough Wetland Management Plan, Capitola, California 1989. In the Old Salinas River channel mitigation occurred absent a management plan and more open water area resulted. According to project critics, "this mistake could have been avoided if a resource management plan were available for Old Salinas River." ABA Consultants, Moss Landing Marine Laboratories, Earthquake Reconstruction Planning Document D, Wetland Enhancement Plan, Capitola, November 1992, p. 12. Such a plan would have considered the entire wetland, resulting in better judgments about optimal types of wetland habitats to restore. In contrast, the change to open water could be beneficial in cases where dense vegetation growth has impaired water circulation and limited plant diversity.
  15. ABA Consultants, Elkhorn Slough Wetland Management Plan, Capitola, California 1989, p. 14 shows an estimate that at least 90% of Monterey Bay's coastal wetlands were ditched and drained from the mid 1800's to the 1940's, but the method for determining this estimate is unstated.
  16. Habitat Restoration Group. et. al., Draft Salinas River Lagoon Management and Enhancement Plan, 1992, Table 5, p. 39.
  17. Jones & Stokes Associates, Inc., Final Neary Lagoon Management Plan, Sacramento, 1992, pp. 5 -8.
  18. Moss Landing Marine Laboratories, Wilder Ranch Wetland Restoration Plan, Moss Landing, 1993, p. 84. This is the only clear example of mapping historic wetland extent in the ReCAP project area.
  19. California Coastal Commission, ReCAP Wetland Database. This database includes any mentioned or inferred causes of historic wetland loss, based on the literature. Some development/activities occurring in wetlands (number of wetlands affected in parentheses) prior to 1973 include agriculture (14 wetlands), road construction (12), flood control (6), grazing (6), boating (5), urban development (4), resource extraction (3), and landfills (3). Quantified losses from such activities are not generally offered.
  20. This fragmentation may have been offset to some degree by the construction of numerous small detention ponds which have developed wetland functions over time, according to Gordon, Burton L., Monterey Bay Area: Natural History and Cultural Imprint, Boxwood Press, Pacific Grove, 1977, p. 224.
  21. United States Geological Survey Map, Monterey Quadrangle, 1911-1912.
  22. Gordon, Burton L., Monterey Bay Area: Natural History and Cultural Imprint, Boxwood Press, Pacific Grove, 1977, p. 234
  23. Hornbeck, David, Landscape Change in the Pajaro Valley, 1840-1880: A Study in Change Processes, masters thesis, Fresno State College, Fresno, 1969, pp. 11, 17.
  24. Gordon, Burton L., Monterey Bay Area: Natural History and Cultural Imprint, Boxwood Press, Pacific Grove, 1977, pp. 85-87.
  25. Crampton, T.A. Long Term Effects Of Moss Landing Harbor On The Wetlands Of Elkhorn Slough. University of California, Santa Cruz. Master of Science Thesis. 1994. 81pp.
  26. Holland, Cindy and Kentula, Mary, "Impacts of Section 404 Permits Requiring Compensatory Mitigation on Wetlands in California (USA)", Wetlands Ecology and Management, 2(3), pp. 158-159.
  27. Section 30607.1 provides a mitigation standard for no net loss or in lieu fees:
    Where any dike and fill development is permitted in wetlands in conformity with Section 30233 or other applicable policies set forth in this division, mitigation measures shall include, at a minimum, either acquisition of equivalent areas of equal or greater biological productivity or opening up equivalent areas to tidal action; provided, however, that if no appropriate restoration site is available, an in-lieu fee sufficient to provide an area of equivalent productive value or surface areas shall be dedicated to an appropriate public agency, or the replacement site shall be purchased before the dike or fill development may proceed. The mitigation measures shall not be required for temporary or short-term fill or diking if a bond or other evidence of financial responsibility is provided to assure that restoration will be accomplished in the shortest feasible time.
    Few LCPs require mitigation of wetland fill, most are silent, probably because they do not explicitly permit wetland fill. Only the North Monterey County Land Use Plan has a specific mitigation ratio, which is 1:1.
  28. California Coastal Commission, ReCAP Wetland Database. ReCAP has so far identified 64 projects as being permitted in wetlands since 1973; 27 fills, mostly in minor amounts.
  29. California Coastal Commission, Coastal permit appeal A-3-STC-85-257; findings for Santa Cruz City Local Coastal Program submittal, July 8, 1981; Coastal permit P-670.
  30. Changes in wetland area are primarily based on a review of aerial photographs from 1977, 1986, and 1993, supplemented by permit files and the literature. California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994. In some cases, 1978 or 1979 aerial photos were used because they were clearer. Habitat changes were difficult to cumulatively describe as they could not be discerned as well from the photos and are often not described in the literature.
  31. California Coastal Commission, ReCAP Wetland Database and Draft Summary of Wetland Enforcement Activity in Santa Cruz and Monterey Counties, November 1994.
  32. California Coastal Commission ReCAP Wetland Database, developed in 1994, identifies eight pending wetland fill projects.
  33. Almost the same number of wetlands (14) were subject to after-the-fact enforcement actions regarding wetland fills as were subject to before-the-fact permit applications for wetland fills (17 wetlands). California Coastal Commission, ReCAP Wetland Database and Draft Summary of Wetland Enforcement Activity in Santa Cruz and Monterey Counties, November 1994.
  34. Other regulatory programs have similar gaps. For example, CEQA, where mitigation measures may be offered to protect wetlands, does not apply to all projects which could affect wetlands, such as emergency repairs to public facilities, water withdrawals from a reservoir, housing in an urbanized area, and pipeline reconstruction. See Remy, Michael et. al., Guide to the California Environmental Quality Act. Point Arena: Solono Press Books, 1993. Under the Clean Water Act, no permit is required to fill less than one acre of wetland.
  35. California Coastal Commission, "Interpretive Guidelines for Wetlands and Other Wet Environmentally Sensitive Habitat Areas," San Francisco, 1981, p. 40
  36. California Coastal Commission, Jurisdiction to Require Coastal Permits for Removal of Major Vegetation Other Than for Agricultural Purposes, Section 30106, memorandum by Roy Gorman and Linda Breeden to Coastal Commission, San Francisco, November 1980. The California Attorney General does not share the Commission's interpretation.
  37. The County Code explicitly states that coastal development permits shall be required for new or expanded agricultural operations on parcels with predominantly 10% or greater slopes and on soils with high or very high erosion potential. This allows the implementation of policies which basically prohibit the conversion of steep slopes in the Elkhorn Slough watershed to agriculture (however, no permits have been issued before such conversions have occurred; this was in response to a series of conversions that occurred in the late 1970's and early 1980's, before the County assumed permit authority in 1988). This clarification would not be helpful in stopping most agricultural intrusion into wetlands, since they are not typically over 10% slope or highly erodible.
  38. Harris, Raymond, Jr., Application of NOAA's Coastwatch Change Analysis Project for Wetland and Upland Change Detection in the Elkhorn Slough Watershed, San Jose State University, May 1994; Habitat Restoration Group, Moro Cojo Slough Management and Enhancement Plan Vol 1 Existing Conditions Report, Felton, March 1994; California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994.
  39. Coastal Commission enforcement procedures are outlined in memoranda that have yet to be consolidated into a guidance manual, although this is currently underway.
  40. It is difficult to discern from aerial photos whether a complete loss of wetland has occurred; or whether the wetland technically remains, but in an altered (degraded) state. Discovery through ReCAP has resulted in initiating enforcement follow-up. Use of aerial photo interpretation on a regular basis would be a valuable enforcement tool.
  41. California Coastal Commission, Draft Summary of Wetland Enforcement Activity in Santa Cruz and Monterey Counties, November 1994.
  42. Based on ReCAP's review of aerial photos, there did not appear to be any cases of wetland loss in the pilot area due to non-compliance. (California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994). However, a more thorough investigation than was possible for ReCAP might have found problems. In an example where an actual field evaluation was performed in Oregon, 46 of 72 compensatory wetland mitigation projects had one or more compliance violations. (Oregon, Division of State Lands, A Report Monitoring and Evaluating Wetland Compensatory Mitigation Projects In Portland, Oregon by Joel Shaich and Ken Franklin, draft memorandum, Salem, February 1994.)
    With regard to paper conditions, half of the area's coastal land use plans require protective easements to be placed over privately owned wetlands, as a condition of permitting development on the property. At least 21 coastal permits required protective easements to be placed over wetland areas. A sampling of five required easement offers at Moro Cojo Slough in the Elkhorn target area, revealed only two had been recorded. A review of the files of 13 restoration projects requiring monitoring reports, revealed that only three had the requisite reports. In one case, Moss Landing Harbor District staff explained that sufficient money was not budgeted to cover a consultant's estimated monitoring costs, and questioned the efficacy of spending substantial sums on monitoring, according to personal communication with Larry Stefan, Harbormaster, June 22, 1994. Review of monitoring costs and ensuring funding are issues worthy of further investigation, See for example, King, Dennis and Bohlen, Curtis, "Estimating the Costs of Restoration," National Wetlands Newsletter, Vol 16, No 3, May/June 1994, pp. 3-8. Whether the lack of documentary condition compliance translates into incomplete wetland mitigation is unknown. Unlike the Coastal Commission's computerized Access Inventory, no comparable database or tracking of easement or monitoring requirements has been established. The ReCAP database can be used for such purposes. There is no record of subsequent monitoring of easement use.
  43. U.S. Fish and Wildlife Service, Classification of Wetlands and Deepwater Habitats of the United States, by Lewis Cowardin, et. al. Washington, D.C. 1979.
  44. Monterey County, Carmel Area Land Use Plan, and City of Santa Cruz General Plan and Local Coastal Program 1990-2005.
  45. "Wetlands" is a generic term without a universally accepted definition. Enlightening discussions of this topic are found in California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994, pp. 41-48; San Francisco Estuary Project, Status and Trends Report On Wetlands and Related Habitats in the San Francisco Estuary, Oakland, 1991, pp. 21-27; Kusler, J.A., "Wetlands Delineation," Environment, Vol 35, March 1992, pp. 6-11+. For purposes of analysis, the most important consideration appears to be the presence of wetland indicators. Variations in definitions and hence delineation methods hinge on the number of the three common wetland indicators -- hydrology, hydric soils, hydrophytic vegetation -- requires before a positive wetland identification is made. According to personal communication with Wayne Ferrin Jr., UCSB Department of Biological Sciences, June 14, 1994, there are potentially significant areas that may not appear to be "wetlands" to the casual observer (because they are not always wet) that qualify under at least the more expansive wetland definitions.
    Interestingly, in some cases significant standing water bodies have been termed "ponds," "lakes," 'bays," etc. and not considered wetlands, However, under Section 30233 of the Coastal Act, open waters and lakes receive almost the same protection as wetlands.
  46. See, for example, "What Is a Jurisdictional Wetland?" National Wetlands Newsletter, Vol 13, #5, September/October 1991.
  47. California Coastal Commission, Interpretive Guidelines for Wetlands and Other Wet Environmentally Sensitive Habitat Areas, San Francisco, 1981. Also see California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994, p.25 for a discussion of this topic.
  48. County of Monterey, Department of Planning, Environmental Impact Report for Spanish Bay Development, Salinas, 1976, p. 28. noted drainage channels into the area and ponds formed in the mined out areas. Environmental Management Consultants, Spanish Bay Resort Environmental Impact Report, Monterey 1984, Appendix H, p. 3 briefly notes the presence of a wetland (riparian corridor). California Coastal Commission, 3-84-226 permit staff report, March 1985, did not mention "wetlands." LSA, Spanish Bay Resources Management Plan, July 1987, p. II-1, VII-1 noted small seasonal wet areas and drainage ways.
  49. California Coastal Commission ReCAP, personal communication with Lee Otter, Coastal Planner, May 3, 1994.
  50. Derived from aerial photographic display maps accompanying Pebble Beach Company, Spanish Bay Resource Management Plan, Fifth Annual Monitoring Report, Pebble Beach, March 1994 compared to California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994. Lacking a pre-development field investigation, it will never be known how much wetland acreage there truly was.
  51. California Coastal Commission Coastal permit appeals A-3-SNC-89-10, -11, & -12; findings on Santa Cruz County Local Coastal Program Amendment # 1-93.
  52. Ray, Daniel and Woodruff, Wayne, Mitigating Impacts to Wetlands and Estuaries In California's Coastal Zone, paper presented at Association of State Wetland Manager's conference, New Orleans, October 11, 1986; San Francisco Bay Conservation and Development Commission, Mitigation: An Analysis of Tideland Restoration Projects In San Francisco Bay, San Francisco, March 1988; California Coastal Commission, Humboldt Bay Wetlands Inventory Project: Data Interpretation and Summary, January 1989.
  53. This project was not mitigation. Josselyn, M., S. Chamberlain, K. Goodnight, H. Hopkins, and A. Fiorello. Evaluation of Coastal Conservancy Enhancement Projects 1978-1992, a report prepared for Reed Holderman, State Coastal Conservancy. Oakland, California. 1993.
  54. Pebble Beach Company, Spanish Bay Resource Management Plan, Fifth Annual Monitoring Report, Pebble Beach, March 1994; Monterey County Coastal Permit PC-7523 (3-MCO-90-077).
  55. Habitat Restoration Group, Moss Landing South Harbor Wetland Restoration Project Monitoring, Second Annual Monitoring Report, Scotts Valley, October 1992.
  56. ABA Consultants, Moss Landing Marine Laboratories Earthquake Reconstruction Planning Document D, Wetland Enhancement Plan, Capitola, November 1992, pp. 12 -14.
  57. See California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994, for a more expansive discussion of this issue of interpreting permitted uses under Section 30233.
  58. For example, only one LCP in the study area explicitly allows boating and only one explicitly allows limited resource extraction (of peat). None, explicitly allow port, energy, or coastal-dependent industrial facilities. For a further discussion of this topic on a statewide basis see California Coastal Commission, "Wetland Task Force Final Recommendations," memorandum from Les Strnad, Santa Cruz, November 1988, pp. 6 -9.
  59. Field work and aerial photo interpretation would be necessary to attempt an after-the-fact study of whether removal of any (non-wetland-considered) "riparian vegetation" would have constituted wetland vegetation under the Cowardin method.
  60. California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994.
  61. California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994, p. 48. The Coastal Commission has provided input to this effort.
  62. California Coastal Commission, "Briefing on Recently Issued State and Federal Wetland Policy Statements," memorandum, San Francisco, September 1993.
  63. California Department of Fish and Game, Wetland Resources Policy, Sacramento, 1987.
  64. California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994.
  65. There may be a few cases where either privately owned parcels are totally wetland or a wetland would have to be filled to accommodate a single family home; further analysis would be necessary to identify these. Given recent court cases, the Commission may face more issues related to proposed wetland fill for a non-priority (i.e., residential) use; see, for example, Berry, James, "The Dolan Case: Grabbing Tigard by the Tail?" Environment & Development, August 1994, p. 3.
  66. Although it was beyond the scope of ReCAP to study the relationship of other agencies' mitigation requirements to the Coastal Commission's and local governments', inconsistency among agencies, which threatens mitigation success, was found on a statewide basis. California Coastal Commission, "Wetland Task Force Final Recommendations," memorandum from Les Strnad, Santa Cruz, November 1988, Recommendations #3 & 4 and pp. 12 -16. See Problem Six Information Gaps section of this chapter for further agency coordination recommendations.
  67. Two pending cases portend this trend. Recently delineated wetland remnants on former agricultural and grazing land at both Terrace Point and what was once known as Rolling Hills respectively are proposed to be filled. Whether fill of small isolated, seasonal, and/or degraded areas with compensating mitigation may result in an overall net habitat improvement is an issue worthy of further study.
  68. California Department of Fish and Game, Wetlands Resources Policy, Sacramento, 1987.
  69. California Coastal Commission, "Briefing on Recently Issued State and Federal Wetland Policy Statements," memorandum, San Francisco, September 1993.
  70. California Coastal Commission Central Coast Region, Vested Rights file # E-3-73-5; Mitchell Swanson Associates and Habitat Restoration Group, Final Pajaro River Lagoon Management Plan, Santa Cruz, May 1993, p. 12.
  71. Coastal permit files 3-83-185 and P-81-162 and California Coastal Commission, Cartographic Unit. ReCAP Photo Interpretation Notes, 1994.
  72. At least two recent enhancement projects involved recreating historic habitat conditions, within existing wetland areas. Restoration of Laguna Grande and Roberts Lake included clearing 4.6 acres of tule vegetation, resulting in open water habitat. Similarly, tule cutting has been permitted at Neary Lagoon on two occasions to result in more open water habitat. Both of these projects were undertaken in concert with wetland management plans based on biologists' beliefs that these smaller wetlands were being choked with too much vegetation. In some cases natural restoration has been documented. At Carmel River Lagoon and Natural Bridges Lagoon, native vegetation had reestablished itself after cessation of farming or grazing activities which had eliminated it.
  73. Moss Landing Marine Laboratories, Wilder Ranch Wetland Restoration Plan, Moss Landing, 1993.
  74. ABA Consultants, Elkhorn Slough Wetland Management Plan, Capitola, California 1989 and ABA Consultants, Biological Assessment, Development and Restoration Plan for the Elkhorn Heights Parcel, Capitola, California, 1991.
  75. Moss Landing Marine Laboratories, Benthic Lab, Watershed Ecology Outreach Program First Progress Report, Moss Landing, September 1994. and personal communication with John Oliver, November 8, 1994.
  76. See Dyste, Rosie, Methods of Delineating and Determining the Effectiveness of Wetland Buffer Zones, student paper for San Jose State University Environmental Studies 200, Spring 1994.
  77. Data sources for Figure 5-6 are as follows: Panels 1-3: U.S. Coast Survey Register No. T-444, Santa Cruz Harbor and Vicinity, 1853, Scale 1:10,000; U.S. Coast and Geodetic Survey Register No. T-444a, Santa Cruz Harbor and Vicinity, 1910, scale 1:10,000; Sanborn Fire Insurance Maps, Sanborn Map Co., 1909 and 1950; California Joint Highway District No. 9, Aerial photograph No. 1, 1928. Panels 4-8: Santa Cruz County parcel base map, scale 1:7,200; California Dept., of Navigation and Ocean Development Aerial photograph No. 76-5-104, April 2, 1970; and Aerial photograph No. 4-12-135, May 6, 1978; California Dept. of Boating and Waterways, Aerial photograph No. 4-123-229, March 26, 1986 Aerial photograph No. 4-123-6, April 19, 1993; Brown and Caldwell, Project Report, Santa Cruz Wastewater Facilities Planning Study, Walnut Creek, 1978; Jones and Stokes Associates, Inc., Final Neary Lagoon Management Plan. Sacramento, 1990.
  78. California Coastal Commission. Statewide Interpretive Guidelines for Wetlands and Other Wet Environmentally Sensitive Habitat Areas. San Francisco, 1981. These guidelines were developed using extensive scientific input as summarized in Castelle, Andrew, et. Al., Wetland Buffers: Use and Effectiveness, Olympia, Wa: February 1992, p. 20.
  79. Since the point will relate to the wetland, how the wetland itself is delineated is a crucial factor; see previous section on "Inconsistent Delineation Methods." Imposing different buffer widths may be appropriate for different situations; however, the discrepancies identified are largely the result of policy decisions, not scientific evidence.
  80. One new initiative regarding vegetated treatment systems is found in United States Environmental Protection Agency, Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Water, Washington, DC., January 1993, Chapter 7,IIC.
  81. Orme, A.R. "Wetland Morphology, Hydrodynamics, and Sedimentation," in Williams, Michael [Ed.]. Wetlands: A Threatened Landscape. Oxford, England: Alden Press Ltd., 1991, pp. 43-94.
  82. Orme, A.R. Ibid.
  83. Josselyn, M. The Ecology of San Francisco Bay Tidal Marshes: A Community Profile. U.S. Fish and Wildlife Service, Division of Biological Services, Washington D.C. FWS/OBS-83/23. 102pp. 1983.
  84. Zedler, J.B. 1982. The Ecology of Southern California Coastal Salt Marshes: A Community Profile. U.S. Fish and Wildlife Service, Division of Biological Services, Washington D.C. FWS/OBS-81/54. 110pp. 1982.
  85. California Coastal Commission Permit File; Permit # 3-90-104.
  86. California Coastal Commission ReCAP Database - Wetlands Module, 1983-1993.
  87. California Coastal Commission ReCAP Database - Wetlands Module, 1983 - 1993.
  88. The Planning Collaborative and John Sanger, Regional Land Use Study, for AMBAG. San Francisco, 1978.
  89. California Coastal Commission Permit File; Permit # 3-92-15.
  90. As a recent alternative to breaching, Coastal Commission staff organized a human rescue effort to transport trapped fish from the lagoon to the Bay.
  91. California Coastal Commission Permit File; Permit # 3-90-41.
  92. These approaches should not be construed to imply that breaching is always the appropriate solution. For example, "recent research of water quality and biological productivity, conducted at other lagoons along the central California coast, demonstrates that sand bar breaching is harmful to lagoon habitats for fish and other aquatic organisms. Breaching in the spring or summer months delays or arrests a lagoon's seasonal conversion to freshwater from the mixed fresh-salt water regime that occurs with an open river mouth in the winter months. The water column in the lagoon becomes stratified, with a hot, saline, anoxic bottom water layer underlying a cooler, freshwater layer above. Under stratified conditions, fish and other aquatic organisms, especially benthic organisms, cannot survive. Without the basis for a healthy food chain, the biological productivity of the lagoon is diminished for fish, birds and other wildlife," from Mitchell Swanson Associates and Habitat Restoration Group, Final Pajaro River Lagoon Management Plan, Santa Cruz, May 1993, p. 3.
  93. Crampton, T.A. Long Term Effects Of Moss Landing Harbor On The Wetlands Of Elkhorn Slough. University of California, Santa Cruz. Master of Science Thesis. 81pp. 1994.
  94. Belden, T., R. Gramlich, D. Leland, T. Panella, and H. To. Policy Strategy to Reduce Erosion in the Elkhorn Slough Watershed. A report to the California Coastal Commission, Central Coast District. 52pp. plus Appendices. 1994.
  95. Belden, et al., ibid. The Coastal Commission did attempt to address the cumulative effects of erosion and sedimentation on Elkhorn Slough from potential additional development. The Coastal Commission proceeded to deny new subdivisions, in the late 1970's while permitting singly-family residences on vacant lots of record. A fairly standard finding was applied to each subdivision permit, creating a de facto moratorium on new lots. Exceptions were made for dividing property that already contained multiple units and a few other situations, on a case-by-case basis. The findings made it clear that such denials were being given until a new plan for the area addressing cumulative impacts could be developed. As background for that plan, a UC Berkeley Sea Grant study identified "bare ground exposure" thresholds for the subwatersheds of Elkhorn Slough (Dickert, Thomas and Tuttle, Andrea, Elkhorn Slough Watershed Linking the Cumulative Impacts of Watershed Development to Coastal Wetlands, Berkeley, October 1980). These were incorporated into the local coastal program along with a tracking system to ensure that they were not exceeded and a subwatershed planning process to address those that were already exceeded. The local plan resulted in a downzoning, but does allow new subdivision based on the new densities. (Hyman, Rick. Unpublished remarks at Methodologies and Mechanisms for Management of Cumulative Coastal Environmental Impacts Workshop, University of Rhode Island School of Oceanography, Narragansett, Rhode Island, May 6, 1993.) Some would argue that this bias against new subdivision (and the commensurate priority given to agriculture) is responsible for more erosion and sedimentation. For further details of this effort, see Strnad, Les and Hyman, Rick, "A Watershed Approach to Coastal Zone Management for the Elkhorn Slough Estuarine Complex," Coastal Zone 1993 Vol 2, Proceedings of the Eighth Symposium on Coastal and Ocean Management, edited by Orville Magoon, et. al. New York: American Society of Civil Engineers, 1993, pp. 1569 -1583. For an evaluation of efforts to control sedimentation in the watershed see the Coastal Commission's forthcoming project of special merit report on Cumulative Impacts of Nonpoint Source Pollution.
  96. Reed, Rhonda. Population Study of the Santa Cruz Long-Toed Salamander at Valencia Lagoon. for California Department of Fish and Game, Aptos, CA, 1978.
  97. Gordon, B.L. Monterey Bay Area: Natural History and Cultural Imprints. Second edition. The Boxwood Press, Pacific Grove, California. 1994.
  98. Gordon. Ibid.
  99. As suggested earlier in this chapter, pursuit of restoration does not guarantee success and may require substantial effort. Although it was beyond the scope of ReCAP to systematically evaluate success of wetland restoration projects, many projects appear to emphasize acreage and habitat over hydrology. The problematic restoration project at the Old Salinas River channel, as well as restoration projects at Elkhorn Slough, are not functioning as planned. Hydrologic evaluation of potential tidal erosion and related factors were not incorporated in project design or monitoring. Personal communication with Les Strnad, November 14, 1994 regarding coastal development permits #3-83-125;P-81-162; 3-88-96.
  100. For example, at Elkhorn Slough, bisected by Elkhorn Road, Monterey County proposed to replace flap gates and earthquake-damaged culverts. The area above the tidegates known as Blohm-Porter marsh was thought to originally be freshwater, but is now tidally influenced. (California Coastal Commission Permit file #3-94-11). At Upper Bennett Slough, bisected by Highway One, CALTRANS proposed to replace a broken culvert for flood control purposes. The area above the culvert, known as Struve Slough, was recently freshwater, but is now saline. (California Coastal Commission pending permit file). In order to evaluate these projects from a wetland hydrology perspective, a baseline objective needs to be agreed upon. In both of these cases, the objective discussed by the various resource agency officials was for a freshwater system. But, neither area has a fully adopted management plan stating this. When such a objective is agreed upon, it may result in a project which, while not the least intrusive development, could be considered the least environmentally damaging in a systems context.
  101. Chan, E., T.A. Brusztynsky, N. Hantzsche, and Y.S. Litwin. The Use Of Wetlands For Water Pollution Control. for Association of Bay Area Governments. Berkeley, California. 1981.
  102. Sather, J.H. and R.D. Smith. An Overview Of Major Wetland Functions And Values. U.S. Fish and Wildlife Service, Office of Biological Services. FWS/OBS-84/18. 68pp. 1984.
  103. Aston, R.P. An Assessment of Water Quality in Santa Cruz County: Problems, Needs and Programs. A report prepared for the Santa Cruz County Board of Supervisors, Health Services Agency, Division of Environmental Health, Watershed Program, May 1976.
  104. ABA Consultants. Elkhorn Slough Wetland Management Plan. Capitola, 1989.
  105. Dames and Moore, Route 1 Improvement Study Background Report: Surface Water Quality of Moss Landing Vicinity, Goleta, (1990?).
  106. Harvey and Stanley Associates, Neary Lagoon Enhancement Plan Part I Environmental Inventory; Part II Interim Enhancement Plan. Alviso, August 1987.
  107. Sugar, K. "State Lowers the Boom on Neary Lagoon," Save Our Shores (SOS) Sanctuary Watch, June 1994, p. 7.
  108. Sugar, K. Ibid.
  109. California Central Coast Regional Water Quality Control Board. Proposed Amendments of the Central Coast Water Quality Control Plan. 1993.
  110. Dames & Moore. Natural Environmental Study for the Widening of Highway 1 from Castroville, Ca to the Santa Cruz Co. Line Monterey Co. Goleta, CA. 1990.
  111. Environmental Management Consultants. Spanish Bay Resort Environmental Impact Report. Appendix D. Monterey, CA. 1984.
  112. Bestor Engineers. Initial Study of Environmental Impact Marina Beach Tract No. 2. Monterey, CA. 1978. p. 15.
  113. California Coastal Commission. Cotter, P. Unpublished data.
  114. Coastal Act Section 30231 provides the policy basis for protecting water quality in the coastal zone. Although the Coastal Commission and local governments can apply this section to new development, primary responsibility for coastal water quality is vested in the State Water Resources Control Board and its Regional Water Quality Control Boards. It was beyond the scope of ReCAP to analyze effectiveness of coastal permits in addressing pollution of wetlands. Such is a focus of the Commission's forthcoming project of special merit, "Cumulative Impacts of Nonpoint Source Pollution."
  115. California Coastal Commission, Procedural Guidance Manual: Addressing Polluted Runoff in the California Coastal Zone, San Francisco: May 1995.
  116. For an example of such procedures see Cotter, P.J., L. Mortello, and L. Strnad. Data Evaluation Report and Monitoring Framework for the Elkhorn Slough Watershed. Draft report. California Coastal Commission, Monterey Bay Initiative. EPA Region IX Near Coastal Waters Grant No. X-009999-01-0. 1994.
  117. California Coastal Commission ReCAP Database - Wetlands Module.
  118. California Coastal Commission ReCAP Database - Wetlands Module
  119. California Coastal Commission ReCAP Database - Wetlands Module.
  120. California Coastal Commission ReCAP Database - Wetlands Module
  121. California Coastal Commission ReCAP Database - Wetlands Module
  122. For example, in the Valencia Lagoon watershed continued development threatened the habitat of the Santa Cruz long-toed salamander. The Coastal Commission devised a two-part protection strategy. Some lots immediately adjacent to the Lagoon were designated "critical habitat." Permits for single-family homes were denied and the lots were eventually purchased by the State Department of Fish and Game. The remainder of the lots could be built on to a maximum of 15% site disturbance. This standard was incorporated into a special "SD" overlay zoning district in the Santa Cruz County local coastal program. No evaluation of the effectiveness of these measures has occurred. (Hyman, Rick. Unpublished remarks at Methodologies and Mechanisms for Management of Cumulative Coastal Environmental Impacts Workshop, University of Rhode Island School of Oceanography, Narragansett, Rhode Island, May 6, 1993.)
  123. City of Santa Cruz, Final EIR on the Westside Lands Final Plan, 1987 and Strelow, Stephanie, Draft Environmental Impact Report, Terrace Point Specific Plan, Santa Cruz, 1994.
  124. Earth Metrics, Final EIR for the Villa Nueva Subdivision, Burlingame, 1982; Earth Metrics, Final EIR for the Villa Verde and Villa Nueva Subdivision, Burlingame, 1986; Jones and Stokes, Moro Cojo Inclusionary Housing Development Project Final EIR, Sacramento, 1994.
  125. U.S. Department of Commerce, National Oceanic and Atmospheric Administration, Coastal Wetlands of the United States: An Accounting of A Valuable National Resource, Washington, D.C., February 1991, p. 55.
  126. California Coastal Commission, Procedural Guidance for the Review of Wetland Projects in California's Coastal Zone, San Francisco, 1994.
  127. Santa Cruz County. Code. Sections 16.32.070 &.080.
  128. See, for example: 1) Ray, Daniel and Woodruff, Wayne, Mitigating Impacts to Wetlands and Estuaries In California's Coastal Zone, paper presented at Association of State Wetland Manager's conference, New Orleans, October 11, 1986; 2) San Francisco Bay Conservation and Development Commission, Mitigation: An Analysis of Tideland Restoration Projects In San Francisco Bay, San Francisco, March 1988; 3) California Coastal Commission, Humboldt Bay Wetlands Inventory Project: Data Interpretation and Summary, January 1989; and 4) California Coastal Commission, Wetland Task Force Final Recommendations, memorandum by Les Strnad, Santa Cruz, November 1988, p. 10.
  129. U.S. Department of the Army, San Francisco District Corps of Engineers, Habitat Mitigation and Monitoring Proposal Guidelines, effective October 1991.
  130. California Coastal Commission, Data Evaluation Report and Monitoring Framework for the Elkhorn Slough Watershed, draft, by Patrick Cotter, Linda Mortello, and Les Strnad. Santa Cruz, November 1994.
  131. Watersheds are theoretically easier to delineate, since they can be drawn from topographic maps. A complication does occur with artificial, unmapped drainages to other watersheds. As suggested in the final section of this chapter, the main issue with watershed delineations is how fine they are drawn; the referenced ICM and the State Water Resources Control Board currently aggregate individual stream drainages into larger hydrologic units. Standardized nomenclature is also lacking.
  132. Timber Harvest permits, reviewed by the Department of Forestry and Fire Protection, and not subject to the CCMP, contain cumulative impact assessments, analyzing the effects of harvests on downstream wetlands.
  133. Jones and Stokes, City of Santa Cruz Wastewater Treatment Plan Modification Addition of Secondary Treatment, Draft EIR Supplement, Sacramento, November 1990.
  134. Personal communication with Craig Vassell, U.S. Army Corps of Engineers, October 6, 1994.
  135. Both President Clinton and Governor Wilson have suggested common wetland regulations as differing requirements are a source of frustration to applicants. California Coastal Commission, "Briefing on Recently Issued State and Federal Wetland Policy Statements," memorandum, San Francisco, September 1993. While this is not a CCMP nor cumulative impact problem, the California Coastal Commission can participate in efforts towards coordination, consolidation, and standardization. For example, it would also be valuable to provide applicants information as to the various wetland regulatory requirements. This can occur at the Corps' interagency meetings. Using Figure 1 as a start, preparation of a guide compiling wetland permit requirements is a worthy interagency task.
  136. See Kusler, Jon. Hydrology: An Introduction for Wetland Managers, Berne, New York (n.d.).
  137. The two other EIRs did not list preparers' expertise, but at least in one case biologists were consulted. Those were earlier EIRs from the mid 1970's, and one was for a project never built.
  138. See California Coastal Commission, "Wetland Task Force Final Recommendations," memorandum from Les Strnad, Santa Cruz, November 1988, Recommendation #1C.
  139. California Coastal Commission, Memorandum by Thomas Crandall on the Department of Fish and Game, San Francisco, September 1994.
  140. See, for example, National Wetlands Newsletter, Vol. 16 #4, July/August 1994 for some discussion of this topic.
  141. To date there are no such known examples in the pilot area, as management plans are either too new or reflect permit conditions (i.e., permit issuance preceded the development of the plan). However, some wetland enhancement projects have been proposed, at Neary Lagoon and Elkhorn Slough, pursuant to previously completed management plans.
  142. See California Coastal Commission, "Post LCP Certification Permit and Appeal Jurisdiction" maps, various dates, which distinguish areas that remain under the Commission's permit jurisdiction (tidally-influences or potential public trust) from those that revert to local jurisdiction after local coastal program certification.
  143. Federal projects are reviewed under consistency review, rather than under coastal development permits. Federal consistency review is the one authority that the Coastal Commission now possesses to review federal projects and federally licensed projects affecting coastal zone resources.
  144. For example, see: (1) San Francisco Estuary Project, Status and Trends Report On Wetlands and Related Habitats in the San Francisco Estuary, Oakland, 1991; and (2) Oregon Division of State Lands, Oregon's Wetland Conservation Strategy, Draft, April 1993. Plans which attempt to rate wetland significance and provide lesser degrees of protection for some classes of wetlands would not be appropriate models, given the Coastal Act's protective policy framework and the significant historic wetland loss in California.
  145. Duncan & Jones and Ribera & Sue, Parks, Recreation and Open Space Plan, Santa Cruz County, California, Berkeley and Oakland, 1972; California State Coastal Conservancy, Update of California Coastal Wetlands Enhancement Needs, Oakland, March 1984; Dennis, Nona and Marcus, Mary. Status and Trends of California Wetlands, Sacramento, 1984, pp. 87-95; Santa Cruz County, Coastal Land Use Plan, Policies 1.14.3 and 1.14.4.
  146. This task is being undertaken by the California Department of Fish and Game, Office of Oil Spill Prevention and Response. Jeanne Lau, California Coastal Commission. Personal communication, November 1, 1994.
  147. California Resources Agency. California Ocean Resources: An Agenda for the Future (Draft), Sacramento, 1994.. Map 3 of 4, Central Coast, Appendix F.
  148. U.S. Department of Commerce, National Oceanic And Atmospheric Administration, National Ocean Service, Monterey Bay National Marine Sanctuary Water Quality Protection Program Workshop Summary Report Issue Identification and Strategy Development, Draft, June 1994.
  149. It would be beneficial at some point to link or merge SEA's database with the Coastal Commission's ReCAP wetland database.
  150. Other emerging efforts include (1) AMBAG's CAMPITS program, described in Work Plan for Water Quality Management Planning Program on Coastal and Marine Water Quality Information Coordination, Integration and Outreach, A Pilot Program for the Monterey Bay Region, July 1992; (2) Moss Landing Marine Laboratories' lead in fostering a Monterey Bay and Salinas Valley Regional Watershed Plan with a main goal of holding fresh water in the watershed by restoring as much of the natural wetland system as possible. The initial report attempts to catalog various restoration projects underway in the Pajaro River valley, Elkhorn Slough, and Salinas River valley watersheds and suggest some future projects, Moss Landing Marine Laboratory's Outreach Program: Moss Landing Marine Laboratories, Benthic Lab, Watershed Ecology Outreach Program First Progress Report, Moss Landing, September 1994.
  151. An emerging geographical framework for performing resource planning is the natural community, which may consist of single or multiple habitats, and would likely not be coterminous with watershed boundaries. However, such boundaries are variable and are not yet defined. For a discussion of this topic, see, National Wetlands Newsletter, Vol 16,#5, September/October 1994.
  152. U.S. Environmental Protection Agency. The Watershed Protection Approach Annual Report 1992. Washington D.C.: 1993. Watershed Protection Approach: A Project Focus. Washington D.C.: 1994. The 1976 Coastal Plan recommended watershed based planning. However, watersheds extended beyond the area determined to be appropriately state-regulated, which was the resultant coastal zone. Additional federal watershed legislation is also being considered by Congress, such as H.R. 3873 Urban Watershed Restoration, H.R. 3894 Conservation Reserve Program, H.R. 42113 River and Watershed Protection and Restoration Act. Congress, see National Wetlands Newsletter, Vol 16, No. 3, May/June 1994, p. 20. "Major legislation is expected to be introduced in the California Legislature in January [1995] on watershed management planning," according to APA Northern News, p. 5.
  153. Santa Cruz County Planning Department & California Resources Agency, The San Lorenzo River Watershed Management Plan, Santa Cruz, December 1979.
  154. Philip Williams & Associates and Harvey and Stanley Associates, The San Lorenzo River Enhancement Plan, February 1989.
  155. Monterey Peninsula Water Management District, Draft Carmel River Watershed Management Plan by John Williams, March 1984 and Monterey Peninsula Water Management District, Draft Carmel River Watershed Management Plan by Ken Greenwood, Monterey, April 1988.
  156. EIP Associates, Supplemental Environmental Impact Report/Statement II Monterey Peninsula Water Supply Project, 1993 lists over 300 documents associated with this project.
  157. Dickert, Thomas and Tuttle, Andrea, Elkhorn Slough Watershed Linking the Cumulative Impacts of Watershed Development to Coastal Wetlands, Berkeley, October 1980. See Strnad, Les and Hyman, Rick, "A Watershed Approach to Coastal Zone Management for the Elkhorn Slough Estuarine Complex," Coastal Zone 1993 Vol 2, Proceedings of the Eighth Symposium on Coastal and Ocean Management, edited by Orville Magoon, et. al. New York: American Society of Civil Engineers, 1993, pp. 1569 -1583 for a history of attempts to plan for the Elkhorn watershed.
  158. CRMP Cooperating Agencies, A Conservation Dilemma A Cooperative Solution, undated brochure.
  159. The following management plans have been completed: Antonelli Pond 1981; Marina Vernal Pond #2 1986; Laguna Grande & Roberts Lake 1986; Younger Lagoon 1987; Marina Vernal Pond #3 1987; Elkhorn Slough (including Parsons Slough) 1989; San Lorenzo River mouth (including Jessie Street marsh) 1989; Soquel Creek Lagoon 1990; Gibson Landing Marsh/Lower Bennett Slough 1990; Neary Lagoon 1992; Ellicott Slough 1993; McCluskey Slough 1993.
    The following seven wetland management plans were well underway in 1994 with review drafts available and included in the analysis: Carmel River Lagoon Enhancement Plan, Coastal/Vernal Ponds Comprehensive Management Plan (for all of Marina Vernal Ponds), Moro Cojo Slough Management and Enhancement Plan, Pajaro River Lagoon Management Plan (includes Lower Watsonville Slough), Salinas River Lagoon Management and Enhancement Plan, Restoration/ Management Options for Schwan Lake, and Wilder Wetland Restoration Plan.
    Two other plans just commencing were for Waddell Creek Lagoon and for the six wetlands of the Watsonville Slough complex, the latter effort the result of many years of prodding by a local citizens group, Watsonville Wetlands Watch.
    For complete bibliographic information see California Coastal Commission ReCAP Database Wetlands module, Wetlands Documents section.
  160. Wetlands lacking plans are Old Salinas River Channel, Upper Bennett Slough/Struve Pond, Scott Creek Marsh, Laguna Creek, and Corcoran Lagoon. The three next largest wetlands lacking management plans are all within Wilder Ranch State Park. Park officials hope to prepare restoration plans for each of them, as soon as the Wilder Lagoon plan is completed, according to personal communication with Ian Calderwood, November 1, 1994. Two large wetland areas (originally Woods Lagoon and part of the old Salinas River Channel) were transformed into harbors and are governed by Master Plans, excerpted into the Santa Cruz City and North Monterey County LCPs respectively. These plans do not contain and could benefit from environmental management components akin to wetland management plans.
  161. The lack of a plan or of a topic does not necessarily mean that management or some aspect of management is not occurring. Rather, it is an indicator of a potential deficiency in attempting to achieve resource protection. A further evaluation of the adequacy of these management measures that are in place is beyond the scope of ReCAP, as is an analysis of the actual implementation of these measures. It can be said, however, that many of these plans have yet to be fully implemented.
  162. Most of the management plans have been prepared by consultants. The lead agency is usually a local government. In some cases technical advisory groups have helped guide plan preparation. Some plans have gone through a public hearing process, others have not. Individuals and groups, such as Friends of Neary Lagoon, occasionally provided public input.
  163. For some of the more recent management plans (e.g., for Moro Cojo Slough), detailed work programs were prepared and revised based on input from Coastal Commission staff and others. For general procedural guidance, see Local Councils of Governments, "Hints on Preparing A Comprehensive Wetland Management Plan," Eugene, February 1992.
    Funding to date has come from a variety of sources, such as the State Coastal Conservancy, State Water Resources Control Board, local governments, and applicants. Some management plans have been required as permit conditions (to address adverse impacts of the permitted developments), while others have been submitted along with applications (e.g., for Lower Bennett Slough and Ellicott pond). Based on recent court cases, there may be a need to more closely scrutinize permit conditions requiring applicants to pay for management plans; however, to date funding for wetland planning has not generated significant controversy and has been readily available.
  164. See Kusler, Jon, Advanced Planning of Wetlands: Wetlands and Watershed (Water Resources) Management A Background Paper, Berne, New York, February 1993, pp. 8-18 for a discussion of the relationships between watershed management plan components and wetland protection issues.
  165. The Elkhorn Slough Management Plan was called for in the local coastal program, then prepared. While Coastal Commission staff did work extensively with the local government (Monterey County) in preparing the plan, it was not formally submitted to the Coastal Commission as a local coastal program amendment (after originally noticing it as one).
    The issue of incorporation of management plans into local coastal programs would benefit from further review. Depending on the wetland's size and issues raised, a good management plan will likely run some 50 to 150 pages and include a fair amount of background information. Since LCPs themselves are already quite bulky documents and any revision to them requires Coastal Commission review, the advisability and popularity of adding entire management plans to them may be low. Alternatives, such as incorporating into the LCPs just policy excerpts from management plans (see next endnote) or separately incorporating plans directly into the CCMP, thus deserve review.
  166. All but one of the completed management plans have been reviewed and either approved by, or formed the basis of a project approved by, the Coastal Commission or local government issuing coastal permits. In two cases the plans provided the background for regulatory review (one permit, one federal consistency) but were not formally approved by the Coastal Commission. In some cases, the essence of the plans (but not the entire documents) have been incorporated into local coastal programs certified by the Coastal Commission. The Coastal Commission retains jurisdiction (e.g., through original permit jurisdiction, appeals, enforcement remediation, previous condition compliance, federal consistency, or State Parks public works plan approvals) over all of the management plans currently under preparation, except for the one on Marina's Vernal Ponds. A plan just released, Habitat Restoration Group and Mitchell Swanson & Associates, Coastal\Vernal Pond Comprehensive Management Plan, Felton, 1994 does not incorporate many of the Coastal Commission staff's comments.
  167. Some wetland (and former wetland) areas, although shown as privately-owned on assessor's rolls, may be subject to the public trust.
  168. California Coastal Commission permit file 3-90-104.
  169. Harvey & Stanley Associates and William Farrel Associates, Wetlands Management/Enhancement and Restoration Program for the Laguna Grande/Roberts Lake Local Coastal Program, Alviso and Santa Cruz, December 1983.
  170. Belden, Timothy, et. al., Policy Strategy to Reduce Erosion in the Elkhorn Slough Watershed, Berkeley: University of California School of Public Policy, May 1994, pp. 15-17.
  171. Jones & Stokes Associates, Inc., Final Neary Lagoon Management Plan, Sacramento, 1992.
  172. These plans can likely be completed in the next two years; other mentioned plans in preparation, such as for Watsonville Slough, Schwann Lake, and Soquel Creek and Pajaro River watersheds can also be incorporated, if completed within a similar

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