planning department

Cross Country Promotions, LLC
Correspondence
•
Email from Jeanne Posey
•
Email from Dennis Morgan
•
Email from Damian Wolin
•
Email from Tom Horgan
•
Letter from Phytosphere Research
•
Letter from Mark Desrosiers
•
Email from Cathy Jauch
•
Letter from William Haigh, U.S. Department of the Interior - BLM
•
Letter from Eric Tattersall, U.S. Department of the Interior - Fish and Wildlife Service
•
Letter from Blueribbon Coalition
•
Letter from Shelia Elworthy
•
Letter from Nicholas Haris, American Motorcyclist Association
•
Letter from Tina Bartlett, State of CA, Department of Fish and Game
•
Letter from Emma Rucker
•
Letter from Mitchell Swett
•
Letter from Kayla Collins
•
Email from Ron Hess
•
Letter from Thomas P. Infusino, Esq.
•
Letter from Barbara A. Holzman, PhD, San Francisco State University
•
Letter from California Native Plant Society (includes a report, available at the Planning
Department)
Planning Departmei1t <pl<:lnning@amadorgov ,org>
Hare Scrambles in Amador County
1 message
jeanne posey <jpose@\'()lcano.net>
To: "@amadorgov.org" <Planning>
Thu, Oct 4, 2012 at 10:49 AM
I have been a resident of Amador county for 25 years. In that time I have seen very few recreational pursuits for
the young people in the area. Not only allowing these 2 events to take place for the youngsters and their families,
it will bring revenue to our county Please consider the benefits and agree to their permit.. .. Sincerely-Jeanne E.
Posey
RECEIVED
Amador Counrv
OCT - 4 2012
PLANNING DEPARTMENT
Support for AMA 036 Motorcycle Events in Amador County - Attention: Susan
Grijalva
'1 message
Morgan, Dennis <[email protected]>
To: "[email protected]" <[email protected]>
Wed, Oct 3,2012 at 11:22 PM
Susan,
I just wanted to drop you a note as a long time Amador County resident and \{)ice my support for the
AMA District 36 e\ent that has been proposed outside of lone. The AMA e\ents are well run and managed family
friendly e\ents. I ha\e only in the last fi\e years really started riding motorcycles off road and participating in AMA
sanctioned e\ents but I was surprised at how supporti\e and friendly the off road community is. I am a current
AMA and District 36 member ha\e found that the my family really enjoys the e\ents, I ha\e ne\er had a problem
with any e\ent I ha\e been to and I am sure would be participating in some capacity in the lone e\ent if it were to
be appro\ed. I make an effort to spend money in the county with our small business owners whene\er I can and
know for a fact these e\ents bring out of town money for local businesses. Hotel's, Gas Stations, Diners and fast
food among others all stand to make good money in these tough economic times. I honestly don't see a down
side to allowing these e\ents that promote family and friendly competition. My family has Ii\ed in this county
since the late 1800's. My children are both attending Amador County Schools (Jackson Jr High and Pine Gro\e
Elementary) and my wife and I are both alumni from Amador County high schools. Bottom line is I support this
e\ent. Let me know if you'd like to chat further I can make the time.
RECEIVEC
Amador COUr !'
OCT - 4 2012
Best Regards,
Dennis Morgan
PLANNING DEPARTMENT
Plannlnf:l Department
<p!anning@am~H.JorgoV.O(J>
District 36 & Cross Country Promotions special use permit
-j
message
DAMIAN WOLIN <[email protected]>
To: [email protected]
Wed, Oct 3,2012 at 7:59 PM
To Amador County Planning Commission,
My Family and I are in support for the Cross Country Promotions special use permit.
Motorcycles have been a part of my growing up and continues to be a part of my family (3 generations and
growing). One of the funny things that we would tell our friends was that a motorcycle was the best babysitter
one could buy. We would spend hours on the weekends riding motorcycles and having lots of fun as a family.
The kids would invite their friends and share the fun.
Not so often does a County have the opportunity to host a OHV event. This could bring tax dollars to the
community with the purchase of gas, camping supplies, dining and motel/hotel etc ...
Please approve this special use permit. Thank you for taking the time to read.
Sincerely,
Damian and Kelly Wolin
Matt, Joe, Anya and Justin
Amador County Resident
.1ECEIVEC
AmaGG-' Courr'.
OCT
-~
4 201 2
PLANNING DEPARTMENT
Planning Department <[email protected]>
AMA District 36 motorcycle even in Amador county
1 message
Tom Horgan <[email protected]>
To: [email protected]
Wed, Oct 3,2012 at 3:29 PM
To whom it may concern,
I recently received notice that a motorcycle club is attempting to coordinate a cross country race event in your area
and that there are local elements that are in opposition to it. Well, I would like to share a few facts about
motorcycle events that you may not be aware of.
First, motorcycling is not a collection of lawless, leather-clad hoodlums like many people may be convinced. I've
spent many years competing as a motorcycle racer and have always been amazed at how the events are focused
on family and family values. I recently started a family with my wife (who also rides a motorcycle) and , as soon as
my daughter is old enough, we plan to introduce her to motorcycling and, if she's interested , motorcycle racing.
Second, motorcycle racing is safe. When compared to riding at a local OHV park where riders may encounter
traffic going the opposite direction, a race is held on a closed course with regular sweep riders and frequent medical
assistance.
Third, motorcycle racing is therapeutic. At a time when it seemed like my family was falling apart - my father
suffered a stroke, my grad mother passed away, my grandfather became seriously ill, and my girlfriend of 8 years
moved out - my mother and my brother were so depressed that they were prescribed antidepressants by their
doctors. I was involved in racing motorcycles and this was the release I needed in order to deal with the difficulties
in my life. This happened again last year. Within one week my wife had a positive pregnancy test and a positive
test for breast cancer! To make a very very long story a little shorter, she went through the surgery to remove the
breast cancer, the chemotherapy to erradicate any remaining cancer cells, and the very serious illness that was a
result of the chemo drugs ... along with morning sickness. She is forever thankful that I was the strong rock that she
could cling to as the waves of depression slammed against her from all directions. My strength comes from
successes in my life and most of those successes involve motorcycle racing .
Fourth, motorcycle racing is stimulating for the economy. I recently attended a motorcycle race in the town of
Chester, California . My wife and I stayed in a local motel, ate at local restaurants for both dinner and breakfast, and
fueled my truck at a local gas station. What's more, the local high-school football team provided lunch to the
competitors throughout the day with the proceeds going to support their team and local charities. Those burgers
were great!
Finally, at this time, my family and I have little reason to visit Amador county. However, if the ability to hold this event
is granted to the club that is seeking it, I guarantee the we'll be there.
Sincerely,
Tom Horgan
Andrea Horgan
Amelia Horgan
RECEIVED
Amador County
OCT - 5 2012
PLANNING DEPARTMENT
I of I
10/5/20128:32 AM
https:llmail.google.com/mail/b/13S/u/0I?ui=...
PHYTOSPHERE RESEARCH
RECEIVED
Amador COU/lty
October 4, 2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
OCT - 5 Z01Z
PLANNING DEPARTMENT
Dear Planning Commissioners:
I am submitting comments on the proposed Negative Declaration for the Cross County Promotions
LLC Use Permit for the lone Hare Scrambles off road motorcycle events.
Based on the description of the project and the environmental documents provided by the applicant,
it is clear that the project is likely to have significant negative impacts on lon e manzanita (federal
threatened species) located on the project site. The impact is assoc iated with the high probability
that Phytophthora cinnamomi, a lethal soil-borne pathogen of lone manzanita and many other plant
species, would be introduced and/or spread throughout the project area by the proposed project.
This impact was not considered by the applicant's biological consu ltant. This is a significant
omission, as the root disease cause by this pathogen has been identified as one of the most
important threats to lone manzanita. The impacts associated with this disease will not be addressed
by the proposed mitigations. As such, Section IV.A. of the Initial Study/Negative Declaration is
inaccurate and should show that the project has a potentially sign ificant impact. Because this issue
cannot be found to be insignificant or mitigable through standard conditions, the Mitigated Negative
Declaration for this project is not supported by facts.
I have been conducting research into diseases affecting lone manzanita since 2001. Significant
disease problems had been noted as affecting this rare species as least as early as 1988. Through our
research, conducted in collaboration with Dr. Barbara Holzman of San Francisco State University
and later in collaboration with Dr. Matteo Garbelotto of the University of California, Berkeley, we
identifi ed a pathogen that threaten s th e presistence of lone manzanita. The introduced water mold
Phytophthora cinnamomi causes a severe and lethal root rot of lone manzanita in large portions the
plant's natural range in the vicinity of lone.
Phytophthora cinnamomi has a very wide host range, and affects a wide variety of agricultura l crops,
horticultural plants, and an increasing number of California native plant communities. The pathogen
attacks and decays roots in the soil. It can persist for many years even in the abse nce of host plants.
Our studies show that P. cinn amomi was introduced into lone manzanita range from multiple
sources and has spread from localized infestations through off-road vehicle and foot traffic. In
Australia, where P. cinnamom i has infested and devastated several hundred thousand hectares of
native forests, new infestations are commonly associated with unpaved logging roads . Once
introduced into an area, the pathogen can also move downhill with flowing water during the wet
season.
Once soil becomes infested with P. cinnamom i, it will no longer support the development of lone
manzanita stands or other susceptible hosts. Since lone manzanita is limited to unusual soils that are
very limited in extent, protecting existing stands from P. cinnamom i introduction is the primary way
to maintain lon e manzanita's dwindling habitat. The references li sted at the end of this letter
provide further information about P. cinnamomi and its effects on lone manzanita.
The proposed project represents one of the worst possible impacts to lone manzanita habitat. The
processes involved - grading of trails and roads; movement of potentially infested soi ls from many
locations on vehicle, shoes, etc.; high levels of vehicle and foot traffic during race events - are
1027 DAVIS STREET, VACAVILLE, CA 95687-5495
email: [email protected] t~ URL: http://Phytosphere.com
(707) 452-8735 voice/fax
10/05/1 2
Page 2 of 2
essentially a recipe for ensuring that this pathogen, and perhaps other damaging Phytophthora
species, become introduced and spread throughout the site.
The biological consultant appears to have been unaware of this impact. Th ey are clearly not
qualified to determine whether the pathogen might already occur on parts of the site. If this is the
case, th e project would facilitate the rapid spread of the pathogen through the site and result in the
permanent destruction of th e ex isting stands over a period of years. If the pathogen is not now
present at the site, it is likely that it will be introduced by event participants and spectators,
especially given that many already infested areas are present in the areas around lone, including sites
used by off road vehicles. Movement of infested soil is favored when soils are wet, either as the
result of water application for dust abatement, or from spring rainfall.
Given the logistics of the events and the overall topography and layout of the site, the proposed
mitigation measures will not prevent introduction and/or spread of this pathogen. It is highly
unlikely that suitable mitigations could be developed or enforced for events of the sort that are
proposed . Restricting vehicular and foot traffic into or near uninfested areas is the primary means for
preventing spread of this pathogen, which is the exact opposite of the proposed project.
I have only addressed th e issue of this disease in my comments, but it is clear that other impacts to
both lone manzanita and Irish Hill buckwheat are not adequately addressed by the proposed
mitigations. I respectfully reco mmend that the Commission reject the proposed mitigated negative
declaration. The site proposed for this project is quite simply unsuited for this use due to its existing
biological resources that are threaten ed by the proposed activities. The applicant should be
encouraged to find a more suitable site.
Regards,
Tedmund J. Swiecki, Ph.D.
Principal/Plant Pathologist
References
Swiecki, T. J. and E. Bernhardt. 2003. Diseases threaten the survival of lone manzanita (Arctostaphylos
myrtifolia). Phytosphere Research, Vacaville, CA. Prepared for San Francisco State Univers ity.
http://phytosphere.com/publi cation s/ionem anzdis.htm
Swiecki, T. J., E. A. Bernhardt, and M . Garbelotto. 2003. First report of root and crown rot caused by
Phytophthora cinnamomi affecting native stand s of Arctostaphylos myrtifolia and A. viscida in California. Plant
Disease 87:1395
Swiecki, T. J., E. Bernhardt, and M. Garbelotto. 2005 . Distribution of Phytophthora cinnamomi within the range
of lon e manzanita (Arctostaphylos myrtifolia). Phytosphere Research, Vacaville, CA. Prepared for California
Department of Fish and Game. http://phytosp here .com/publi cation s/Pc inn_Am yrt_2005. htm
Swiecki, T. J.; Bernhardt, E.; Garbelotto, M.; Fichtner, E. 20 11. Th e exotic plant pathogen Phytophthora
cinnamomi: A major threat to rare Arctostaphylos and much more. pp. 367-371. J. W. Willoughby, B. K. Orr,
K.A. Schierenbeck, and N. J. Jensen [eds.), Proceedings of the CNPS Conservation Conference: Strategies and
So luti ons, 17- 19 Jan 2009, Ca l iforn ia Native Plant Society, Sacramento, CA.
http://phytosphere.com/publications/Pcinn_Arctostaphylos_CNPSConsConf2009.htm
PHYTOSPHERE
RESEARCH
RECEIVED
To:
Susan Grijalva
Amador County Planning Department
810 Court Street
Jackson, Ca 95642-2132
AmadorCoooty
OCT - 5 2012
PLANNING DEPARTMENT
From: Mark Desrosiers
15882 Barney Road
Plymouth, CA 95669
209-245-3670
I am writing today in support of granting the Special Use Permit to Cross Country
Promotions for the event that will be held twice per year on the property near lone.
I consider myself to be a neighbor to the property in question. I live approximately 2
miles away as the Hawk flies. I also am a volunteer firefighter with Battalion 20 of the
Amador Fire Protection District which covers this area and a member of the American
Motorcyclist Association, District 36. I am also a volunteer medic with the National
Motorcycle Patrol and I work many of the types of events as the one planned here.
I can attest to the fact that these are well planned and very organized events, catering to
families from age 4 to age 80.
These events will attract families from all over Northern California, Northern Nevada and
Southern Oregon many of which have never heard of Amador County. These families
will return home after spending many dollars in the county and tell their friends and
neighbors about our wonderful little county, about our hospitality, our many recreational
opportunities, from events such as this, our excellent wineries and the rich history of our
county.
Since I am a neighbor I have heard the false rumors that are being spread, about how they
are building a giant motocross track, with races to be held every weekend, attracting
thousands of people. We know this is not the truth.
Please do not let the false rumors playa factor in granting this Special Use Permit.
Thankyl
/ /
/~7~
~
/ "1
01
yark Desrosiers
_____ ,
. ~, '
Planning Department <[email protected]>
Fwd: The lone Hare Scrambles
1 message
jauchc6@aol,com <[email protected]>
To: [email protected]
Fri, Oct 5, 2012 at 2:09 PM
RECEIVED
Please forward to the Commissioners,
Amador COUllty
OCT - 5 2012
Thank you,
Cathy Jauch
PLANNIN·GDEPARTMENT
-----Original Message----From: jauchc6 <[email protected]>
To: jburns <[email protected]>
Cc: rforster <[email protected]>; jplasse <[email protected]>; boneto <boneto@co. amador.ca. us>
Sent: Mon, Oct 1,20125:11 pm
Subject: The lone Hare Scrambles
Cathy & Duane Jauch
4601 Carbondale Rd
Plymouth, CA 95669
October 1, 2012
Amador County Planning Commissioners
81 0 Court Street
Jackson, CA 95642
Dear Sirs,
We are four generations of cattle ranching in the Willow Springs area alon Irish Hill Rd and Carbondale. Our 1000
ranch sits to the north of the proposed site on the Rancho Arroyo Seco Ranch along Carbondale Rd . It is getting to
be one of few open spaces left in the county. We have kept it going by ranching for over 57 years. It gets harder
and harder to make a go of it each year with the effects of the city moving closer and closer.
We are concerned that an event of this type with parking spaces for 192 vehicles and 175 camping parking spaces
and 1,000 attendees would be hazardous to our area. There is no road between us and the northern border of this
event. If a grass fire were to be started it would effect several ranches along the way and several homes before it
would hit Carbondale Rd. It has been proposed for Nov. and March with the thinking that these are wet months. For
the past 8 years that I know of, our significant rainfall has not happened till mid december and late March/April.
There is still a huge amount of dry grass during the Fall/Winter months. I drive by the proposed area on Irish Hill
road on my way to Galt or lone and notice that there are no cattle fences up on this property, they have all fallen into
ill repair. This would tell me that no current grazing has gone on for quite some time. That would lend to a huge
amount of fuel for fire potential.
I have gone to the web sites of these type of races. The very nature of them lend to cycles with spark arresters
removed to run faster. The proposal from Cross Country Promotions says there will be fencing to keep cycles on the
marked trails. I have seen videos on U-tube
http ://www.youtube.com/watcll?v+zk lf-5_ IqCU
showing contestants going out of bounds of the marked trails. Their own web site for District 36 Motorcycle Sprots
lof2
1015/20123 :24 PM
https:llmail.google.com/mail/b/ 135/U/0I?ui=...
Committee Inc. with association minutes reports of several incidents of contestants off course. An event at Leoni
Meadows a Christian Retreat had 95% off course. This off course would also effect greatly the land in late March
when we have rains. The youtube video I mentioned also shows the damage and mud that result from these races
with wet weather.
I am also concerned that these events will overload our law enforcement services as well as emergency services.
Their Club minutes reflect at least a 10% to 20% injury rate requiring ambulance service as well as life flights. I see
the plans for this also include a heli pad area.
Years ago Plymouth had what they called Hangtown Moto Cross. It did not go well with law enforcement and they
had to shut it down. I don't want to see that in our quiet rural neighborhood .
Both these times of year are very critical to our industry cattle ranching. Fall is calving time and late fall is breeding.
We herd our cattle with horses and also ATV's, but nothing like 300 to 500 motorcycles and the noise they will make
as well as a helicopter and the sound of emergency vehicles. Spring is the time we look for our calves to eat and
grow and bring more money at sale. If they are agitated by all this, they will not put on the gains we need to be
profitable. It is a struggle as it is to be profitable without these outside forces effecting us. If we lost our dry grass in
the late fall from any fires, we would have to buy expensive hay to supplement them until spring when green feed
comes in.
Their proposal says they will only use existing roads and cattle trails and fire breaks for their race course area. I
have seen the videos and they race several motorcycles wide at a time. A cattle trail would not be wide enough to
handle this. Fire breaks in my experience are done along perimeter fences . I don't see much of the race course
along the perimeter either. I would imagine this would lead them to have to move quite a bit of ground area to
accommodate the course. What effect would that have on any plant life? I don't see any mention of vernal pools on
the acreage. I know there are several in the vicinty. Has anything been done to address that as well.
There has been note made that these events are only twice a year for two days. I would suggest that once these
cyclists find this area, they will be back in the off season lending to more and more missuse of the property and
surrounding areas.
I would urge you commissioners not to approve this for this rural area of Amador County. When the investors group
purchased Rancho Arroyo Seco they made a promise to this community to not change its ruralness and open
spaces. I would ask you to ecourage them to keep that promise.
Sincerely,
Cathy Jauch
20f2
10/5/20123:24 PM
https://mail.google.comimaillb/J3S/uiO/?ui= ...
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Mother Lode Field Office
5152 Hillsdale Circle
EI Dorado Hills, CA 95762
www.ca.him. gO\'/Ololhcrlolic
October 5,2012
6840
CA-180.20
RECEIVED
Amador County
Cara Agustin
Amador County Planning Department
810 Court Street
Jackson CA 95642-2132
OCT - 5 2012
PLANNING DEPARTMENT
Subject: Cross Country Promotions Biannual lone Hare Scrambles Events
Dear Ms. Agustin:
We have reviewed the Draft Mitigated Negative Declaration California Environmental
Quality Act document for the proposed lone Hare Scrambles. The Bureau of Land
Management's Mother Lode Field Office manages 55 acres of land approximately one
mile north of the proposed dirt bike track. This land was designated as an Area of Critical
Environmental Concern (ACEC) in 1988 to protect the lone manzanita (Arc/os/apyios
myrtifolia), a federally threatened plant species.
For your consideration, we would like to offer the following comments:
•
There are two federally listed plant species in the projec t area - lone manzanita
and Irish hill buckwheat (Eriogonum apricum var. prostratum). The only place in
the world these species occur is a 16-mile strip of land that extends north and
south of the town of lone. Our experience with OHV use has shown us that to
protect rare plants, orange mesh construction fencing strung along T-posts will
prevent most impacts from OHV users. We were not successful in keeping OHVs
from impacting rare plants when we used stakes and flagging. These obstacles
were easily overlooked.
•
lone mazanita is currently under threat of infection from a fungal disease called
Phytopthora cillilamomi. This is a soil fungus that causes root rot in lone
manzanita. The BLM's lone manzanita population in the lone Manzanita ACEC,
located approximately 1 mile north of the proposed race course, is partially
infected with this disease . Human activities can spread the Phytopthora to
uninfected stands. Especially when soil moisture is present, fungal spores will
easily spread to uninfected stands. This disease is a major threat to the continued
existence of lone manzanita. We have instituted quarantine measures in our lone
Mazanita ACEC to prevent the spread of this disease. Through fencing, published
closures and signing, we have minimized human activities in the ACEC. In
addition, we have funded Ted Swiecki of Phytosphere Research since 2010 to
research this disease and experiment with potential treatment methods.
•
The unique soils of the lone Formation are extremely fragile and erosive. We
designated the lone Tertiary Oxisol Soils ACEC, located approximately one mile
southeast of Buena Vista, in 1986 to protect these sensitive soils. CalFire used
OHVs in another parcel of BLM land approximately 3.5 miles southeast of Buena
Vista for training purposes. It also contains the lone soil formation and was
designated an ACEC. The roads were severely eroded by OHV use due to the
fragility of the lone soils. This negatively impacted lone manzanita along the
roadway due to root exposure and soil run-off.
We appreciate the opportunity to share our knowledge and experience in managing these
federally listed plant species and fragile soils in the lone area. If you have questions or
would like more information, please call Beth Brenneman, Mother Lode Field Office
botanist, at (916) 941-3138.
Sincerely,
William Haig
Field Manager, Mother Lode Field Office
·AECEIVED
In Reply Refer To:
Amador County
08ESMfOO-2013-TA-0002
Amador County Planning Comrnissipn
County Administration Center
".-.. ; ::~ ' ..
810 COUlt Street
Jackson, CA 95642-2132
Subject:
'"
OCT 052012
'. .
OCT - 5 2012
PLANNING DEPARTMENT .
F
,
.. !
Comments on proposed Negative Declaration for the Cross County Promotions
LLC Use P.ermit
Dear Planning Commissioners:
This letter responds to your proposed Mitigated Negative Declaration/Initial EnviroI11liental .
StUdy (MND) regarding a request by Cross Country Promotions, LLC for a Use Permit to allow
the lone Hare Scrambles. The lone Hare Scrambles is an off-road motorcross event that is
proposed to occur twice a year, in fall and in spring, approximately 1 mile nOlthwest the city of
lone near Irish Hill in Amador County, California. The project proposes events that would take
place twice a year (for a total of 4 days per year) and the use permit would expire on December
31, 2017. Approximately 425 pmticipants and 450 visitors would be expected for each event.
The race involves many riders for 2 hour timed events over a two day period with overnight
camping.
We are concerned about the significant impacts to lone manzanita (Arctostaphylos myrtifolia)
and Irish Hill buckwheat (Eriogonum apricum var. prostratum) from the proposed events. The
race would surround and travel directly through listed plant areas of these two taxa.
We do not think that the resource pi'otection measures proposed for endangered and sensitive
species in the use penn it boundary (use pennit condition 7) or discussed in the lone Hares
Scramble Rare Plant and Creek Protection Plan reduce the effects of the project to less than
significant.
The impacts from the project include the likelihood of spreading Phytophthora cinnamomi, a
deadly plant disease, to Arctostaphylos myrtifolia. Root disease cause by P. cinnamomi has been
identified as one of the most important threats to lone manzanita. Although P. cinnamomi was
not known to be present at Irish Hill in 2004, it was known from south and northwest ofIrish
Hill. We believe that bringing motorcycles from multiple outside locations will lead to a
potential spread of this pathogen to a currently undiseased area of A. myrtifolia. The proposed
MND does not mention impacts from P. cinnamomi from the events, nor does it provide any
measures that would ameliorate the likelihood of spreading the pathogen.
We are also concerned about mechanical damage of the Eriogonum apricum var. prostratum and
plants on or near the course from the motorcyles. We do not consider placing lathe with red
.
·"
. .;
~
: . ~;:::.
" ',
." .::~. "',
:fl<).g~r?-g" aqO-ft spacing along any pOltionofthe course where E. apricum var. prosirafttlnJd ,:"
wi$ii? 5tj"feet of the course to pro:y~~eaqequate protection:
.
'
Please contact staff biologist KirsteriTarP or Recovery Division Chief, Josh Hull, at (916) 4146600, if you have any questions regarding this response.
. ~~~
/
.
.. . .. ..... .
Deputy Assistant Field Supervisor
cc: CDFG, Sacramento, California
BLM, E1 Dorado Hills, California
CNPS, Sacramento, California
: :.:
.
. ' , '. '
::. :~.
Sincerely,
";l"
"';'Preserving: Our Natural Re s ourc ';s FOR ~~ ~
The Public Instead Of FROM The Public" ---- .
October 8, 2012
Amador County Planning Commission
810 Court Street
Jackson, CA 95642-2132
Re: Support for Cross Country Promotions/AMA District 36 Event near lone
Dear Commissioners:
This letter of strong support for the motorcycle event under review is submitted on behalf of the
BlueRibbon Coalition (BRC), a national trail-based recreation group. BRC and our members have a long
history for working with, or attending, AMA District 36 sanctioned motorcycle events. They have a
proven track record of providing safe and environmentally-responsible motorcycle events for all age
groups and genders.
As you may know, sanctioned events on private property are an important element in the recreation
opportunity spectrum. Many regional or nationally-known motorcycle events occur on private property.
Those lands are owned by various stakeholder groups that include religious organizations, Indian tribes,
timber companies, mining companies, and many others including country music star, Loretta Lynn.
These events are considered important to the local economy.
BRC encourages you to approve the permit for this event. BRC believes Amador County will find it to be
beneficial to the county and its residents.
Respectfully submitted,
Don Amador
Western Representative
BlueRibbon Coalition, Inc.
555 Honey Lane
Oakley, CA 94561
Office : 925.625.6287
The BlueRibbon Coalition is a national recreation group that champions responsible recreation, and
encourages individual environmental stewardship. With members in all 50 states, BRC is focused on
building enthusiast involvement with organizational efforts through membership, outreach, education,
and collaboration among recreationists. 1-800-BLUERIB - http://www.sharetrails.orq
Elworthy Ranches
10444 Crow Canyon Road, Castro Valley, CA 94552
[email protected]
925.989.3335
RECEIVED
Amador County
Cara Agustin
Amador County Planning Department
810 Court Street
Jackson, CA 95642-21332
Re: lone Hare Scrambles Event
OCT - 9 2012
PLANNING DEPARTMENT
Dear Ms. Agustin:
In reading the objections to the lone Hare Scrambles, I would like to touch on many
misconceptions the local people have expressed.
First off, we are 5 th generation cattle ranchers and run cattle in 5 different counties. We actually
use dirt bikes to gather our cattle along with a few horses. We have been attending and
participating in District 36 Hare Scramble events for eight years. Our entire family races
including myself, a 51 year old female, in a race they call the Diva Race. The District includes a
race for everyone in the family if they would like to participate.
This is a family event, not some hoodlum bearing, beer drinking, rock and roll biker fest. The
kids are all friends and are usually in bed by ten o'clock due to the fact they race the next day.
These kids, and adults are athletes. The families are close knit. These events have helped many
children focus on the sport and keep them active.
As far as garbage all over the streets? These families don't tell their kids to throw the trash out
the window. That is ridiculous. There are either trash receptacles available or we take our trash
bag and put it in the back of the trailer or pickup and bring it home. We are all used to doing
this.
The dangerous winding road hazard? Believe me, if cattle trucks, especially loaded cattle trucks,
and pickups with cattle and horse trailers are capable of driving on Irish Hill Road, any RV
could easily drive on this road. This is only two days, twice a year. These are public roads and
very accessible, certainly not unusual for an event like a Hare Scramble.
The excessive noise? State standard is 96 decimals, to which is a rule for all racers. And as far as
the late night music and amplifiers etc., I would not attend these events if this were a problem.
There are no bands, Drs, dancing etc. People wind down quickly because they are tired.
Now I want to touch on the cattle situation. There will be no cattle on this area of the ranch.
The closest neighbor's fence is 1.8 miles away. Cattle can hear, on an average of 2·3 miles. They
might hear a little "brap", but it certainly isn't going to scare them or start a stampede.
Of course as cattle ranchers, fire is one of our largest concerns. All bikes are checked for spark
arrestors. This is a District rule. I have never seen nor heard of any Hare Scramble where there
has been a fire. I would go along with the no smoking policy in a heartbeat and I would be
willing to even monitor this myself, even though it is rare to see a smoker these days.
We have attended everyone of CCP's races and they are our favorites. Mr. Irwin also has a son
that started racing at a very young age and Mr. Irwin makes safety and course markings his
highest priority. His events all run smoothly and are very fun.
I have looked at the trails on the maps. The endangered species are being protected. Mr. Irwin
has not cut corners and has complied with everything he has been asked to do. He is meticulous
in fixing anything that might have been disturbed.
We are very private ranch people and a "different" church bought the ranch next door to our
home ranch. At first we were so upset and predicted the worst. Now, when the air is just right,
their music comes over the canyon and travels our way. We actually like it now. Things these
days are just getting so complicated for anyone to do anything. I would suggest the neighbors
give it a chance. Yes, it will seem different to see a motorhome or pickup with bikes in it
travelling the roads for two days or extra people in town. Maybe they would really enjoy
attending and doing something different with a positive attitude and have a fun weekend.
Very Sincerely,
Sheila Elworthy
Elworthy Ranches
6981 Kana Drive, Placerville, CA 95667
T: (530) 626-4250 F: (530) 626-47 07
AmericanMatorcyclist.colll
RECEIVED
October 8,2012
Amador County
OCT - 9 Z01Z
Amador County Planning Commission
810 Court Street
Jackson, CA 95642
PLANNING DEPARTMENT
Re: Support for AMA District 36/Cross County Promotions Event Permit Application
Dear Planning Commission Members:
Please accept this letter of support for the proposed motorcycle event permit currently under your consideration,
AMA District 36 has a long established record of providing safe, fun and responsible off-highway motorcycle events
throughout northern California. Currently many regional and national off-highway motorcycle events occur either
partially or entirely on private property.
The American Motorcyclist Association (AMA), founded in 1924, is the premier advocate of the motorcycling
community. We represent the interests of millions of on- and off-highway motorcyclists nationWide. Our mission is to
promote the motorcycle lifestyle and protect the future of motorcycling. We are pleased to note that the Staff has no
technical objections to the Planning Commission approval of this permit application.
The AMA supports the concept of managed recreation and believes it is prudent and appropriate to identify areas
where off-highway vehicle use is appropriate. Opportunities for off-highway motorized recreation, and specifically
competition events, continues to see increased demand from the general public, and in many cases are considered
vital to the surrounding communities economies. Once established these events will often sell out weeks or even
months in advance, with local restaurant, fuel and hotel merchants typically reporting significant increases in
business.
We look forward to many years of a successful partnership between the county and the riding community and
request you approve this permit application without hesitation or delay.
Please do not hesitate to contact me if I can be of further assistance.
Sincerely,
Nicholas Haris
Western States Representative
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State of California -The Natural Resources Aaency
DEPARTMENT OF FISH AND GAME
EDMUND G. BROWN JR .. Governor
CHARL TON H, BONI-IAM, Director
170 '1 Nimbus Road , Suite A
Rancho Cordova, CA 95667
(916) 358 -2900
http://www.clfg .ca .gov
RECEIVED
Amador County
OCT - 9 2012
October 8, 2012
Cara Agustin
Amador County Planning Department
810 Court Street
Jackson, CA 95642
cagustin@amadorgov,org
Subject:
PLANNING DEPARTMENT
Comments on the Mitigated Negative Declaration for the lone Hare
Scrambles Project, SCH# 2012092010
Dear Ms, Agustin:
The California Department of Fish and Game (Department) has reviewed the
County of Amador's proposed Mitigated Negative Declaration (MND) for the Use
Permit to allow a biannual (fall and spring) weekend event (lone Hare Scrambles)
for daytime off-road motorcycle races . The project also includes permission for
overnight camping with lip to 300 participants and 250 visitors throughout the
event.
The Department is providing comments on the MND as both a trustee agency
and responsible agency under the California Environmental Quality Act (CEQA) ,
As trustee for the State's fish and wildlife resources, the Depariment has
jurisdiction over the conservation, protection, and management of fish, wildlife,
native plants, and the habitat necessary for biologically sustainable populations
of such species, The Department may also be a responsible agency for a project
affecting biological resources where we will exercise our discretion after the lead
agency decides to approve or carry out a proposed project or some facet thereof.
The location of the proposed motorcycle race event is in Amador County
northwest of the town of lone, north of State Route 104, east of
Carbondale/Michigan Bar Road , and west of Irish Hill Road (see attached map).
The habitat is described as an oak woodland with grasslands and lone chaparral
at an elevation of 250 to 350 feet above sea level. Based on occurrences
documented in the California Natural Diversity Database and Department
biologist observations and knowledge of the area, an abbreviated list of sensitive
species likely to occur, or known to OCCUI-, in this area are listed below with their
listing status based on the Federal Endangered Species Act (ESA) , California
Endangered Species Act (CESA), Fish and Game Species of Special Concern
(SSC), and/or the California Rare Plant Rank (CRPR):
o
o
lone chaparral (a rare vegetation type)
lone manzanita (Arctostaphylos myrtifolia) , Federal Threatened
Conseruin.g Ca[ifornia)s ([II)iu[[ije .,S'ince 1870
Cara Agustin
October 8, 2012
Page 2 of 8
o Irish Hill buckwheat (Eriogonum apricum var. prostratum), Federal and
State Endangered
o lone buckwheat (Eriogonum apricum var. apricum), Federal and State
Endangered
o Parry's Horkelia (Horkelia parryl), CRPR 1B.2
o Bisbee Peak rush-rose (Helianthemum suffrutescens) CRPR 3.2
o Swainson's hawk (Buteo swainsonil), State Threatened
o Cooper's hawk (Accipiter cooperil), SSC
o Western pond turtle (Emys marmorata), SSC
Listed Species
Based upon a preliminary review, the Department has identified a species
protected pursuant to CESA with potential to occur within the study area that may
be affected by the project, Irish Hill buckwheat (Eriogonum apricum var.
prostratum) and Swainson's hawk (Buteo swainsonil). The MND includes some
information to protect these species; however, it may not be to a level to ensure
take 1 of a listed species will not occur.
The Department has regulatory authority pursuant to CESA over projects that will
result in the take of any species of wildlife designated by the California Fish and
Game Commission as an endangered, threatened, or candidate species. Take
of species protected pursuant to CESA is prohibited (Fish and Game Code §
2080). However, the Department, may authorize the take of these species by
permit if the conditions set forth in Fish and Game Code Section 2081,
subdivisions (b) and (c) are met (see also Cal. Code Regs., tit. 14, § 783.4). If
the project could result in the take of any species protected pursuant to CESA,
an incidental take permit issued by the Department should be obtained. If the
Department issues an incidental take permit, the Department must rely on the
MND to prepare and issue its own findings regarding the project (CEQA
Guidelines §§15096 and 15381). The Department can only use the MND if it
adequately addresses the impacts and mitigation of those project activities which
the Department is required by law to carry out or approve.
Recommendation
The MND should contain a comprehensive discussion of all CESA listed species
with a potential to be impacted by the project, acreage of habitat affected or
potentially affected, avoidance and minimization measures that will be
implemented, and a detailed description of the mitigation measures that will be
performed to reduce impacts to a level of less than significant. Any activity
resulting in loss of habitat, decreased reproductive success, or other negative
effects on population levels of species protected pursuant to CESA should be
addressed. (See Botanical Resources and Protection for Nesting Birds below for
additional recommendations) .
Pursuant to Fish and Game Code Section 86, "'Take' means hunt, pursue, catch, capture, or
.
kill, or attempt to hunt, pursue, catch, capture or kill."
1
Cara Agustin ,
October 8,2012
Page 3 of 8
Botanical Resources
Within the Initial Study documents, a consultant (Vollmar Consulting) provided
information for Irish Hill buckwheat and lone manzanita. The document states
the consultant reviewed remote habitat mapping, ground-truthed the data, and
walked the route of the proposed course. The consultant notes that Irish Hill
buckwheat mapping provided is complete based upon 2009 surveys; although,
no other details of these surveys were provided. In addition, maps of lone
manzanita occurrences do not correlate with the maps representing the location
of lone chaparral (lone manzanita is the signature species for lone chaparral).
Both State and federal listed plants are known to occur within the site. A
comprehensive survey was not conducted and the protection measures
proposed by the applicant may not be sufficient to protect the special status
plants within the project area. If listed plants are impacted because of
construction of this project or use of the course, the applicant may be in violation
of the ESA, CESA, or both. Furthermore, at least two species that warrant
protection from CEQA Section 15380 may also be present.
In addition, lone mazanita is currently under threat of infection from a fungal
disease called Phytopthora cinnamomi. This is a soil fungus that causes root rot
and eventual death in lone manzanita. Human activities can spread the
Phytopthora to uninfected stands, especially when soil moisture is present.
Fungal spores can easily spread to uninfected stands. It is unknown if the
proposed project site is infected with Phytopthora but there is a high likelihood
that it is. Quarantine of the infected area is important to reduce spread.
Recommendations
In order to avoid and minimize impacts to these species, the Department makes
the following recommendations: (Note: the phrase "special status plants" refers
to all plant species protected by CESA and CEQA)
o Botanical survey: The applicant shall hire a qualified botanical consultant
to conduct a comprehensive botanical survey using Department guidelines
(Protocols for Surveying and Evaluating Impacts to Special Status Native
Plant Populations and Natural Communities Nov 24, 2009). The survey
shall be completed before the final course design is established and
before construction begins.
o Trail Design - special status plants: The applicant or his agent shall
adjust the route of the proposed course to avoid any special status plant
species. New trail construction shall not occur within 20-feet of special
status plant occurrences. If this is not possible, please consult with a
Department, North Central Region (Region 2) plant specialist. Final
adjustments to the proposed course shall take place prior to the initiation
of construction.
Cara Agustin
October 8, 2012
Page 4 of 8
o Trail Design - riparian and wetland habitats: Unpaved portions of the trail
shall not be located within 100-feet of South Fork Willow Creek or other
wetland habitats. The applicant or his agent shall reroute the course prior
to the initiation of construction. Final adjustments to the proposed course
shall take place prior to the initiation of construction.
o Plant protection signs: Special status plants that occur within 50-feet of
existing paved or dirt roads shall be marked at 50-foot intervals with
readily visible permanent signs (e.g. road paddles indicating that vehicles
must remain on the road). These signs shall be installed at the edge of
the road along the same side that the plants are found. Signs shall be
printed on both sides so that riders in either direction may read them.
Signs shall be maintained and kept in good working condition by the
applicant whenever the facility is in use. Signage shall be installed prior to
vehicular use of the course.
o Plant protection fencing - unpaved trail/roads: Special status plants that
are found within 50-feet of unpaved traillroad shall be further protected
with permanent fencing (e.g. t-posts with 2 or 3 strands of smooth wire)
installed within 10-feet of the edge of the road. Fencing shall be
maintained and kept in good working condition by the applicant whenever
the facility is in use. Fencing shall be installed prior to vehicular use of the
course.
o Plant protection fencing - paved roads: Special status plants that are
found within 25-feet of paved roads shall be further protected with
permanent fencing (e.g. t-posts with 2 or 3 strands of smooth wire)
installed within 10-feet of the edge of the road. Fencing shall be
maintained and kept in good working condition by the applicant whenever
the facility is in use. Fencing shall be installed prior to vehicular use of the
course.
o
Erosion control: Erosion control shall be installed as needed in order to
minimize trail erosion and to prevent sediment from leaving the trail and
accumulating near special status plant habitat or wetland areas. Erosion
control measures shall be maintained and in good working condition prior
to any precipitation event. Erosion control measures shall be installed
upon completion of the course and prior to vehicular use.
o
Parking/Staging area: Parking, fueling and vehicle maintenance will occur
at a designated staging area. The staging area will be located at least
500-feet from known occurrences of special status plants and 500-feet
from South Fork Willow Creek. Fueling and vehicle maintenance will
occur in a contained area that will prevent contamination of the
surrounding area in the event of an accidental spill or surface runoff. Spill
containment measures shall be kept in good working condition when in
use, or when containing materials that are potentially hazardous to the
Cara Agustin
October 8, 2012
Page 5 of 8
environment. The parking/staging area shall be installed prior to the first
event.
o Phytophthora control- footwear and clothing: All personnel and visitors
that will be within 50-feet of lone manzanita shall wear footwear, clothing,
and safety gear that has been inspected by trained personnel and verified
to be clean and free of any soil or dust. Clean footwear shall be sprayed
or wiped with alcohol in order to complete decontamination and prevent
spread of Phytophthora spores. Phytophthora control shall occur at all
times including during special status plant surveys and construction.
o Phvtophthora control - equipment and vehicles: All equipment, vehicles
and motorbikes (including undercarriage and tires) that operate within 50feet of lone manzanita shall be inspected by trained personnel and verified
to be clean and free of any soil or dust. A pressure washing station shall
be established within the parking/staging area so that soil can be
effectively removed from equipment and vehicles upon arrival and prior to
departure. Runoff from this station shall not be allowed to flow within 50feet of any lone manzanita plants. Phytophthora control shall occur at all
times including during special status plant surveys and construction.
o
Phytophthora control- wet season: No personnel or vehicles shall be
allowed to operate within 50-feet of lone manzanita when soil moisture is
present except on paved roads. Phytophthora control shall occur at all
times including during special status plant surveys and construction.
o Plant protection awareness documentation: The applicant shall ensure
that all employees and visitors read and sign a plant protection awareness
document. This document shall describe the special status plants and
habitats in the area, protection measures for the special status plant
species and habitats, measures to minimize the spread of Phytophthora,
and the need to avoid driving off course in the signed areas. Employees
and contractors shall review this document and initial it on an annual
basis. All other visitors shall review and sign this document prior to each
event. The plant protection awareness document shall be prepared and
put into effect prior to construction.
Lake or Streambed Alteration Agreement
The MND addresses that the race course will not impact South Fork Willow
Creek to the north of the site; however, the U.S. Geological Survey (USGS) map
for this area shows un-named tributaries in multiple locations throughout the site
(see attached map). When a watercourse (ephemeral, intermittent, or perennial)
is substantially altered a Notification to the Department is necessary (pursuant to
Section 1602(a) of the Fish and Game Code (FGC». Based upon the USGS
map. MND. and satellite imagery of the project site. it appears that numerous
unnamed tributaries occur and converge on the site. Construction of the race
Cara Agustin
October 8, 2012
Page 6 of 8
course may impact these tributaries that the MND did not include as the DFG
jurisdictional waterways.
Recommendation
Provide within the MND the exact race course and what habitats it will affect, and
the course construction details; such as, if tree removal, or vegetation clearing is
necessary, and/or addition of rock or a road base to any tributary crossings. All
such activities may be subject to FGC Section 1602(a).
Or provide a description of why these blue-line watercourses shown on the
USGS map are not watercourses that fall under the jurisdictional of the FGC
Section 1602.
Protection of Nesting Birds
The MND does not provide an analysis of habitat and what birds or raptors may
be nesting within the project area. No bird surveys were provided and the
measures to avoid take (destroy, damage, or cause to fail) of nests (FGC 3503)
or non-listed raptors (FGC 3503.5) may not be adequate to protect the
birds/nests during their nesting period. In addition, no information was provided
on how the project will comply with the Federal Migratory Bird Treaty Act of 1917.
Recommendation
The Department recommends the MND include a requirement to perform precourse construction and pre-event surveys for passerines and raptors, in order to
determine if birds have begun their nesting activities near or within the project
area. Also, the MND shall add site-specific measures to avoid the potential take
of any non-listed birds or raptors, and their nests and eggs in accordance with
FGC Section 3503 and 3503.5, such as but not limited to:
If activity on site is to occur during the critical breeding period of birds
(February 1st - August 30th), 15 days prior to race course construction or
maintenance and prior to any race event have a qualified biologist perform
a survey for any nesting birds. The results of the survey shall be
submitted to the Department. If active raptor nests are found, a 500 foot
initial temporary nest disturbance buffer shall be established. If active
passerine nests are found, a two hundred foot initial temporary nest
disturbance buffer shall be established. If project related activities within
the temporary nest disturbance buffer are determined to be necessary
during the nesting season, then an on-site biologist/monitor experienced
with the species' behavior shall be retained by the project proponent to
monitor the nest, and shall along with the project proponent, consult with
the Department to determine the best course of action necessary to avoid
nest abandonment or take of individuals. Work may be allowed to
proceed within the temporary nest disturbance buffer if birds/raptors are
not exhibiting agitated behavior such as defensive flights at intruders,
getting up from a brooding position, or flying off the nest. The designated
on-site biologist/monitor shall be on-site daily if necessary while
Cara Ag ustin
October 8,2012
Page 7 of 8
construction related activities are taking place and shall have the authority
to stop work if birds/raptors are exhibiting agitated behavior. In
consultation with the Department and depending on the behavior of the
birds/raptors, over time it may be determined that the on -site
biologist/monitor may no longer be necessary due to the birds/raptors "
acclimation to construction related activities.
Otherwise the disturbance buffer shall be maintained until:
o
the young are capable of sustained flight and can take prey
independently,
o
the nest has failed after June 1st as determined by a qualified
biologist, or
o
the young or adults are not detected in this disturbance buffer for
2 consecutive visits after July 15th.
If a listed bird is found nesting, then activities shall be stopped a quartermile from the nest to establish a temporary disturbance buffer for listed
species during the critical period of the species, in order to avoid "take"
prohibited by Fish and Game Code § 2080.
We appreciate your consideration of the Department's comments . The
Department personnel are available for consultation regarding biological
resources and strategies to avoid, minimize and mitigate impacts. If you have
questions please contact Sandra Jacks, Staff Environmental Scientist, bye-mail
at [email protected] or by phone at (916) 358-2916 .
Sincerely,
.Ic(1 12' /)rVL
V "--
0- Tina Bartlett
t Acting Regiona l Manager
ec:
Ca lifornia Department of Fish and Game
Jeff Drongesen
Jennifer Navicky
Sandra Jacks
United States Fish and Wildlife Service
Ryan Olah , Forest & Foothill Division Chief
Ryan [email protected]
Cara Agustin
October 8, 2012
Page 8 oi 8
Attachment: USGS Topographical Area Map with CNDDB Species Occurrences
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lone Hare Scrambles
SCH# 20-120920 '10
Amador County
Legend
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CA NJturJI Diver!;itv DJtJbJ!;t?
,
10/8/2012
Amador Planning Department
810 Court Street
Jackson, Ca 95642
Attention: Susan Grijalva, Director
I am writing to show my support for the proposed Irish Hare Scrambles motorcycle event.
I had the pleasure of attending an event as a volunteer and family member two years ago; I was
surprised to see the number of families with young children attending. It was apparent that this event
provides a spirit of community among the families who regularly attend. Many of the families consisted
of single mothers and their children; I was pleased to see fathers from other families reaching out to
these children to give them guidance.
These events are not wild or out of control, they have an atmosphere of family and community about
them .
Another reason that I support this event being held in lone is that it will bring business to the
community, not only will attendees venture into surrounding downtown areas to spend money but as
most people are charmed by our lovely local downtowns, they are likely to return again and again to
stay and shop.
Sincerely,
Emma Rucker
RECEIVED
Amador Coooty
OCT - 92012
PLANNINGDEPARTMENT
October 8, 2012
Amador County Planning Department
To whom it may concern,
My name is Mitchell Swett; I am a local resident of Amador County. I have been to many of
these types of motorcycle races as a family member of a participant, as an employee, and as a fan.
Starting as a young child I attended motorcycle races all over the State and some into Nevada. The
atmosphere is always kid friendly as most people attending are there to support their children. It is
always fun for the whole family. Another benefit to the county is all the money it will bring in. The
hundreds if not thousands of attendees will patronize many local restaurants, gas stations, grocery
stores. Another benefit of all those new people coming to our area is that they will get to see our
wonderful downtown areas in lone, Jackson, Sutter Creek, and all the other small towns we have in the
county. All in all it is a good idea to approve the application and allow this family friendly event to occur
in our county.
Sincerely,
Mitchell Swett
RECEIVED
Amadof County
Gel - 92012
PLANNING DEPARTMENT
October 8, 2012
Amador Planning Department
810 Court Street
Jackson, CA 95642
To whom it may concern;
I am writing to show my support for the motorcycle event. I have volunteered for the
events for many years. The events are very family friendly; there has never been an
incident that has occured that could cause harm to anyone or anything. The events are
very well structured and planned out. I have also seen the events bring business to the
smaller towns because the attendees venture into the towns after the races.
Sincerely,
Kayla Collins
RECEIVED
Amador County
OCT - 9 2012
PLANNING DEPARTMENT
Planning Department <[email protected]>
Hare Scram bles
1 message
ron hess <[email protected]>
To: [email protected]
Tue, Oct 9,2012 at 12:18 PM
Attention: Susan Grijalva
I am writing you to show support for the proposed District #36/AMA, "Hare Scrambles Motorcycle Event" to be held
in Amador County. This is a great opportunity for Amador County businesses and especially for the City of lone.
I have been riding Hare Scrambles for over 30 years. Hare Scrambles is a great family sport, which includes
camping, motorcycle riding and quality family time. With all the bad influences out in the world today, we need these
type of events! With the limited places to ride, this is a positive step in keeping our sport alive so that my grand kids
may be able to ride a Hare Scrambles someday?
As a resident of Amador County I am asking for your support on this event and to please vote for this event permit.
Maybe you could come out during the event and witness for yourself the family atmosphere and feel the positivity
this event promotes!
Thank You
RECEIVED
Amador County
Ron Hess
lone, Ca
OCT - 9 2012
PLANNING DEPARTMENT
10fl
1019120124:03 PM
https://mail.google.comimaillb/13S/U/0I?ui=.. .
Thomas P. Infusino, Esq.
P.O. Box 792
Pine Grove, CA 95665
(209) 295-8866
[email protected]
RECEIVED
Amador County
OCT - 9 2012
PLANNING DEPARTMENT
10/9112
Amador County Planning Commission
810 Court Street
Jackson, CA 95642
RE: Item 2 on Tuesday's Agenda: Please relocate the lOlle Hare Scrambles events
Dear Planning Commissioners,
I am submitting these comments on behalf of the Foothill Conservancy. We strongly encourage
the Planning Commission to reject the use permit application for the lone Hare Scrambles and
encourage Cross County Promotions LLC, Rancho Anoyo Seco, project neighbors, lone rare
plant experts and other concerned parties to see if they can find a more-suitable location for this
event somewhere else on Rancho Arroyo Seco's 17,000-acre ranch.
I. Summary
As you know the applicant, their consultants, and the Planning Department have prepared a
Mitigated Negative Declaration regarding the Hare Scrambles dirt bike racing event. However,
even with the successful application of proposed mitigation measures, there is substantial
evidence in the record that the event may still have very significant impacts on federally listed
lone rare plants on the site, which are endemic to Amador County and grow in very few places
(see Swiecki, Letter of 10/4112; Holzman Letter, 10/5112). These letters identify an impact to the
rare plants from the project that was not discussed or even mentioned in the Mitigated Negative
Declaration. In addition, the project's dust, noise, and potential fire risk pose a threat to the
neighbors' quiet enjoyment of their land and the operation of their working ranches. Because
there is substantial evidence that the project may have a significant impact on the environment,
the county cannot legally approve this use permit based on a Mitigated Negative Declaration,
and an ElR must be prepared.
II. CEQA Requirements
"[T]he 'foremost principle' in interpreting CEQA is that the Legislature intended the act to be
read so as to afford the fullest possible protection to the environment within the reasonable scope
of the statutory language." (Communities for a Better Environment v. California Resources
1
Agency (2002) 103 Cal.App.4th 98, 110; citing Laurel Heights Improvement Association v.
Regents of University of California (1988) 47 Cal.3d 376, 390.) "The EIR requirement is the
heati of CEQ A." (CEQA Guidelines, sec. 15003, citing County of Inyo v. Yorty, 32 Cal. App. 3d
795.) In practice this means, when in doubt on close calls, the lead agency should require
completion of an environmental impact report. This instance is not a close call, and an EIR is
needed.
A Mitigated Negative Declaration is an acceptable form of CEQA analysis only when, "[T]here
is no substantial evidence in light of the whole record before the public agency that the project,
as revised, may have a significant effect on the environment." (Public Resources Code, sec.
21064.5; see also CEQA Guidelines, sec. 15170.) Ifthere is substantial evidence in the record
that the project may have one or more significant impacts on the environment, as in this case,
then an EIR is required. (CEQA Guidelines, sec. 15064; No Oil, Inc. v. City a/Los Angeles (1974)
13 Ca1.3d 68).) For the purposes of CEQA, substantial evidence means, "[E]nough relevant
information and reasonable inferences from this information that a fair argument can be made to
support a conclusion, even though other conclusions might also be reached." (CEQA
Guidelines, sec. 15384.)
In practice, this means that, even if the lead agency's expert claims that the project will have no
significant impact, if somebody else makes a "fair argument" based on evidence in the record
that the project may have a significant impact, then the lead agency must prepare an
environmental impact report before approving the project. As a result, this has become known as
the "fair argument" standard. It poses a very low threshold for those challenging a Mitigated
Negative Declaration to meet. As a result, generally speaking it is much harder for a lead agency
to defend a Mitigated Negative Declaration in court than it is to defend an EIR.
III. An EIR is required due to the potential for significant impacts of the project on lone
rare plants.
There are two letters in the record now from lone rare plant experts that make very convincing
arguments that the project may have significant impacts on those federally listed rare plants (see
Swiecki, Letter of 10/4112; Holzman Letter, 10/5112). Doctors Holzman and Swiecki have
studied the rare plants in the area for years. They present credible testimony that the project may
have very significant impacts on the lone Manzanita and the Irish Hill Buckwheat. As a result,
the County may not approve the project prior to the completion of an environmental impact
report. Furthermore, since the damage to lone Manzanita seems impossible to mitigate on this
site from a project of this type, even after completing an ErR, the County could not approve the
use permit and project unless it adopts findings and a statement of overriding considerations.
2
IV. Practical options to preparation of an EIR for this specific project
1) Find another event site on Rancho Arroyo Seco.
The event is located on a 17,OOO-acre ranch. Perhaps those concemed about this project could
work together with project proponents to identify a site for this event that will not have the same
impacts on neighbors, wildlife and rare plants. Then the applicant will have a site that can
potentially be used for similar events for years to come.
2) Develop a Specific Plan for the area.
Piecemealing a mine here, a mineral processing facility there, a sand and gravel operation here,
and an OHV recreation area at still another location is not an ideal means of land use planning.
There is always the potential that the initial project locations may be inconsistent with
subsequent project phases. For example, if you want to locate residential development on the
site, you may have to move it away from the OHV recreation area, the mine, and the mineral
processing facility you already built.
Also, unintentional impacts in early phases of development may trigger even more severe
mitigation measures for subsequent phases. In EI Dorado County, careless piecemeal
development of rare plant habitat resulted in the County ultimately being forced to set aside rare
plant preserves. Better planning and mitigation up front could have avoided this.
We strongly encourage the Rancho Arroyo Seco partners to work collaboratively with local
residents and other concemed citizens to develop a Specific Plan for the ranch that will avoid any
harm to the County residents, the special biological resources of the ranch, and the greater
environment.
Sincerely,
Thomas P. Infusino
3
SAN FRANCISCO
-----------------STATE UNIVERSITY
BARBARA A. HOLZMAN , PHD
DEPARTMENT OF GEOGRAPHY AND
HUMAN ENVIRONMENTAL STUDI ES
1600 Holloway Avenue
San Francisco, CA 94132
Tel : 415/338-7506
Fax: 415/338-6243
October 5,2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
RECEIVED
Amador County
OCT - 9 2012
PLANNING DEPARTMENT
Dear Planning Commissioners:
I am submitting comments on the Initial Environmental Review and proposed Mitigated
Negative Declaration for the Cross County Promotions LLC Use Permit for the lone
Hare Scrambles off road motorcycle events. I am a professor of Geography and
Human Environmental Studies and San Francisco State University and researched the
area from 2001 to 2009 with several graduate students. I have read the proposed
mitigated negative declaration and I am very concerned that the native endemic lone
manzanita (Arctostaphylos myrtifolia), lone buckwheat (Eriogonum apricum var
apricum), and Irish Hill buckwheat (Eriognum apricum var. prostratum), all federally
listed species with very restricted distribution, were not given due consideration. In
addition, the potential spread of the pathogen Phytopthora cinnamomi, which is known
to affect lone manzanita within Amador County and spread through soil movement, was
not mentioned.
lone manzanita and lone buckwheat are unique species that have very limited
distribution. lone manzanita is a federally listed threatened species and Irish Hill
buckwheat is a federally and state listed endangered species. The buckwheat is a
small plant that can easily be overlooked, particularly when racing through the area .
Running motorcycles through it can cause irreparable damage. It is not clear to me how
flagging these plants as using lathe can possibly stop vehicle from encroaching on
these areas. The difficulty in keeping racers within the boundaries without going off trail
may be extremely difficult, leaving these plant communities extremely vulnerable to
destruction.
You should also be aware that Ted Sweicki of Phytosphere Research has been
investigating this pathogen Phytopthora cinnamomi in Amador County since 2001. He
THE CALIF ORNIA STATE UNIVERSITY, Bnkersfield, Ch.nnel Islands, Chico, Domingu""t Hills, East Bay, Fresno, Fullerton, Humboldt, Long Beach, Los Angeles,
Maritime Academy, Monterey Bay, Northridge, Pomona, Sacramento, Sail Bernardino, San Diego, San Francisco, San Jose, San Luis ObiSpo, San Marcos, Sonoma, Stanislaus
has confirmed this pathogen has killed manzanita in other areas of Amador County,
north and south of this area. Phytophthora cinnamomi is a water mold that causes
severe and lethal root rot of lone manzanita in large portions the plant's natural range
within Amador County. The pathogen moves through the soil and is exacerbated by soil
disturbance which will clearly occur with the proposed project. The proposed project
allows for the pruning of trees and bushes; any movement of plants with heavy
equipment increases the risk of disease spread in this community as well as the
potential for moving the disease to other communities. Watering down areas to prevent
dust is akin to a perfect storm for the movement of the pathogen, as it is known to travel
from location to location via water. Having vehicles drive through the wetted areas and
then through the habitat is a perfect way to spread the disease through the roads and
trails on the entire property, add in seasonal rains and whatever was spread via the
bikes now continues to spread off roads and trails into the entire area.
I wanted to be sure the Planning Commission was fully aware of the potential
consequences to the endangered plant community should they allow this project to
continue. I am sympathetic to the economic needs of the county and the landowner but
I believe the risks associated with this project are too great for the endangered plant
community to allow it to go forward. Approving this project is a major risk to the future of
lone Manzanita and lone buckwheat in the county. Since your county is the only
location of these species, the risk is the loss of these species completely. I ask you to
seriously consider the ramifications of approving this mitigated negative declaration and
urge you to reject it. Minimally, an Environmental Impact Statement should be required
to address the issues noted above. I hope the landowner can find more suitable
activities for his property that would not seriously endanger this plant community and
the biodiversity of Amador County.
Sincerely,
Barbara A. Holzman, PhD
Email: bholzman@sfsu .edu
IIB.ECElVED
rvllado/' Counry
October 9,2012
Ms. Susan Grijalva
Planning Director
Amador County Planning Department
810 Court Street
Jackson, CA 95642
OCT - 9 2012
PLANNING DEPARTMENT
Ms. Grijalva:
Please find enclosed and fully consider these comments from the California Native Plant Society
regarding the proposed Biannual lone Hare Scrambles project, and the Amador County Planning
Commission's (the Commission) proposed issuance of a Conditional Use Permit (CUP) and a
Mitigated Negative Declaration (MND) for this project.
The California Native Plant Society (CNPS) is a non-profit organization whose mission is to
protect California's native plant heritage and preserve it for future generations. Our nearly 10,000
members promote native plant appreciation, research, education, and conservation through
statewide programs and 33 regional chapters in California.
The applicant, Cross Country Promotions, LLC, proposes to conduct motor cross races across
land that is habitat for the threatened and endangered plants, lone manzanita, Arctostaphylos
myrtifolia (federally threatened), and Irish Hill buckwheat, Eriogonum apricum var. prostratum
(federally and state endangered). We provide comments regarding the distribution, potential
project impacts, and proposed mitigation measures for both these plant species.
Irish Hill buckwheat (Eriogonum apricum var. prostratum)
Irish Hill huckwheat is a perennial native plant endemic to soils derived from the lone geologic
formation whose nutrient conditions are extremely unfavorable for most other plants, but to
which Irish Hill buckwheat has evolved and adapted over time. Irish Hill buckwheat was listed
as CA Endangered under the California Endangered Species Act (CESA) in 1987, and as
Federally Endangered under the Federal Endangered Species Act in 1999. Its status within the
CNPS Rare Plant Inventory as a California Rare Plant Rank (CRPR) IB.l species indicates that
it is seriously endangered in California and elsewhere. The California Department ofFish &
Game (DFG)'s Biogeographic Data Branch has determined Irish Hill buckwheat's Natural
Heritage rank as S 1 / G 1, meaning that this plant is critically imperiled not only in California
(S 1), but globally (G 1).
Irish Hill buckwheat is known to occur in only two locations in the world. One population,
consisting of several plant individuals, occurs on the northeast portion of the proposed project
site. The only other known population occurs approximately 4.5 miles to the northwest, near the
Amador / Sacramento County border (see Figure 1, attached).
As CEQA lead agency for this propose project, Amador County (the County) has the
responsibility to ensure that potential project impacts to Irish Hill buckwheat are fully
considered, are avoided where possible, and if necessary, mitigated to a level of less than
significant as a condition of project approval. Because in this case a CESA-listed species is
involved, the County is required by the CESA to consult with DFG concerning all CESA-listed
species, and to incorporate DFG's recommendations regarding these protected species into their
lead-agency review process.
CNPS strongly disagrees with County planning staffs conclusion that the mitigation measures
described in the applicant's Rare Plant and Creek Protection Plan (Vollmar Natural Lands
Consulting, 2012), will avoid and/or reduce impacts to Irish Hill buckwheat to a level ofless
than significant. We therefore recommend that the County NOT approve either the proposed
CUP or MND for this project based on the current plan, for the following reasons:
• Proposed activities will involve over 400 participants riding on motorcycles, traveling
approximately 20 mph on unpaved routes, in an effort to pass each other and win a race. Hare
Scramble racers will, and often do, drive off established routes and drive "short laps." The
applicant's protection plan for Irish Hill buckwheat is based on the premise that a wooden slat (of
unspecified height) affixed with red flagging, placed at 10-foot intervals will deter and/or prevent
every one of 400 racers, traveling at 20 mph, from running over a road-side plant that is 3 inches
high. The adequacy ofthis proposed mitigation measure is neither credible nor defensible.
• Race activities will likely increase the amount of dust and dirt that would naturally settle on
roadside plants. This fugitive dust could reduce the productivity (photosynthesis) of affected
vegetation, including Irish Hill buckwheat, thereby reducing the long-term survival and recovery
of this species. The potential impact of fugitive dust on the productivity and survival of the
CESA-listed Irish Hill buckwheat has not been addressed as part of this Initial Study / MND.
• CNPS has only recently learned of this project proposal and have had very limited time to
provide comments. We have many questions and concerns regarding Irish Hill buckwheat that
we list below in order to include them in the administrative record at this time:
a) What assurance is there that racers will stay outside of fenced area during races?
b) What assurance is there that ORV use will not occur during non-race events?
c) How will the potential impacts ofrace activities on plant population over time be monitored
and assessed?
d) Who will pay for the long-term monitoring and assessment?
e) What actions will be taken, and by whom, if/when plants are found to be affected by race
activities?
f) Will there be a requirement for someone with the authority and means to stop race activities to
be on-site to ensure repeated impacts do not occur? If not, how does the County propose to
monitor and prevent event impacts and enforce protection measures / infractions?
We also recommend that the County advised the app licant regarding the high likelihood that a
CESA incidental take permit consultation with DFG will most likely be part of an lone Hare
Scramb le future at this location, and require the applicant to develop a Rare Plant Mitigation &
2
Restoration Plan along with a bonding requirement, to be held in trust at the County, to pay for
plan implementation should it be necessary.
lone manzanita (Arctostaphylos myrtifolia)
lone manzanita, is a native evergreen shrub whose distribution, like Irish Hill buckwheat, is
restricted to soils derived from the lone geologic formation. lone manzanita was listed as
Threatened under the FESA in 1999. It is listed as a CRPR 1B.2 species in the CNPS Rare Plant
Inventory indicating that it is fairly endangered in California and elsewhere. The California
Department ofFish & Game (DFG)'s Biogeographic Data Branch has determined lone
manzanita's Natural Heritage rank as S2 / G2, meaning that this plant is imperiled not only in
California (S2), but globally (G2). Threats to this plant include mining, erosion, development,
and fungal infection.
lone manzanita's global distribution is limited to populations occurring across western Amador
County and one population in northwest Calaveras County, USA. A small fraction of this plant's
known habitat is protected on lands managed by the US Bureau of Land Management (BLM) as
Areas of Critical Environmental Concern (ACECs) and by the CA DFG (see Figure 2, attached).
The proposed motorcycle racing event will create routes that cut through lone manzanita habitat,
which will fragment and encroach upon already fragile and limited living space for this globally
imperiled species. It is a fundamental tenet of conservation science, that habitat fragmentation is
the foremost cause of habitat loss worldwide. Opening new ground within an intact stand of lone
manzanita will have a cascade of serious, negative impacts to this population. That increased
erosion and introduction of invasive species (those that occur on edaphic soils) will occur as a
result of building and using proposed routes is beyond doubt. Both will have negative, long-term
impacts to the lone manzanita population in the project area.
Of greater immediate concern is the real likelihood that proposed project activities result in the
infecting ofthe project site with Phytophthera cinnamomi, a fungal relative of the Sudden-Oak
Death fungus, which has been documented from as early as 2003 as a known pathogen ofIone
manzanita at risk of spreading across the plant's range. We attach herein and incorporate by
reference three reports, commissioned by the CA DFG, that address the distribution ofIone
manzanita and P. cinnamomi, the pathogenesis of this fungus on the manzanita, and the longterm recovery ofIone manzanita.
The well-documented, immediate threat of Phytophthera cinnamomi to the continued survival of
the Federally Threatened Arctostaphylos myrtifolia was never addressed in either the applicant's
Rare Plant and Creek Protection Plan, or the County's Use Permit or Initial Study / MND
documents. Yet, the County staff concludes that, "[ s]taff has no technical objections to the
Planning Commission approving this Use Permit." (Environmental Review: Initial Study
document, p.l). We believe the County's current CEQA review of this project is lacking
significant, substantial evidence regarding potential impacts to listed species, and urge the
County to re-analyze the project with respect to this potentially fatal impact to on-site lone
manzanita populations.
3
Lastly. we incorporate by reference two comment letters, from the authors of the DFGcommissioned reports referenced above, that specifically point to the seriousness of threat posed
by P. cinnomomi, and the project's current lack of analysis of this threat (see letters from Dr.
Barbara Holzman, and Dr. Tedward Swiecki, attached).
Conclusions
CNPS believes that the current project, as analyzed, does not satisfies the conditions of having
fully considered impacts to Irish Hill buckwheat and lone manzanita, and has not developed
mitigation measures that can reduce impacts to a level ofless than significant. We feel that the
proposed project is entirely inappropriate for this site due to the extremely high probability that
endangered plant populations will be negatively impacted by race activities. Furthermore,
substantial evidence exists to support the claim that race activities can significantly impact
Federally and State listed endangered plant populations at this site, and that these impacts have
either not yet been addressed, or have been addressed but inadequately so. Based on these
conclusions, we recommend that the County NOT approve the CUP or MND for this project.
We strongly urge the Amador County Planning Commission to ensure avoidance of these
potential impacts by requiring the applicant to site the proposed project elsewhere, where
negative impacts to endangered species and other environmental factors are not an issue. At a
minimum, the County and applicant must develop together more meaningful and effective
avoidance and impact minimization measures of on-site rare plant populations that include but
are not limited to, long-term monitoring and mitigation requirements, thresholds for remedial
enforcement and restoration actions, and a bonding requirement to ensure there will be funding
to pay for the applicant's mitigation, and the County and DFG's monitoring and enforcement that
will be necessary.
Please contact me if you have questions or would like clarification concerning our comments.
CNPS would be glad to offer further recommendations regarding this project as the County
processes this application.
Respectfully,
Greg Suba
Conservation Program Director, CNPS
2707 K Street, Suite 1
Sacramento, CA 95816
(916) 447-2677 x-206
[email protected]
rJJrotecff11j Cafi{ornfa J' nafjve (fora since {96~
2707 K Street, Suite 1 Sacramento, CA 95816-5 1'13
4
• Tel: (9 16) 447-2677 • www.cnps,mg
SAN FRANCISCO
-STATE UNIVERSITY
BARBARA A. HOLZMAN, PHD
DEPARTMENT OF GEOGRAPHY AND
HUMAN ENVIRONMENTAL STUDIES
1600 Holloway Avenue
San Francisco, CA 94132
Tel: 415/338-7506
Fax: 415/338-6243
October 5, 2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
Dear Planning Commissioners:
I am submitting comments on the Initial Environmental Review and proposed Mitigated
Negative Declaration for the Cross County Promotions LLC Use Permit for the lone
Hare Scrambles off road motorcycle events. I am a professor of Geography and
Human Environmental Studies and San Francisco State University and researched the
area from 2001 to 2009 with several graduate students. I have read the proposed
mitigated negative declaration and I am very concerned that the native endemic lone
manzanita (Arctostaphylos myrtifo/ia), lone buckwheat (Eriogonum apricum var
apricum), and Irish Hill buckwheat (Eriognum apricum var. prostratum} , all federally
listed species with very restricted distribution, were not given due consideration. In
addition, the potential spread of the pathogen Phytopthora cinnamomi, which is known
to affect lone manzanita within Amador County and spread through soil movement, was
not mentioned.
lone manzanita and lone buckwheat are unique species that have very limited
distribution. lone manzanita is a federally listed threatened species and Irish Hill
buckwheat is a federally and state listed endangered species. The buckwheat is a
small plant that can easily be overlooked, particularly when racing through the area.
Running motorcycles through it can cause irreparable damage. It is not clear to me how
flagging these plants as using lathe can possibly stop vehicle from encroaching on
these areas. The difficulty in keeping racers within the boundaries without going off trail
may be extremely difficult, leaving these plant communities extremely vulnerable to
destruction.
You should also be aware that Ted Sweicki of Phytosphere Research has been
investigating this pathogen Phytopthora cinnamomi in Amador County since 2001. He
THE CALIFORNIA STATE UNIVERSITY: Bakersfield, Channel Islands, Chico, Dominguez Hills, East B3y, Fresno, Fullerton, Humboldr, Long Beach, Los Angeles,
Maritime Academy, Momerey Bay, Northridge, Pomona, Sacramento, Sail Bernardino, San Diego, San Francisco, San Jose, San Luis ObiSpo, San Marcos, Sonoma, Stanis.laus
has confirmed this pathogen has killed manzanita in other areas of Amador County,
north and south of this area. Phytophthora cinnamomi is a water mold that causes
severe and lethal root rot of lone manzanita in large portions the plant's natural range
within Amador County. The pathogen moves through the soil and is exacerbated by soil
disturbance which will clearly occur with the proposed project. The proposed project
allows for the pruning of trees and bushes; any movement of plants with heavy
equipment increases the risk of disease spread in this community as well as the
potential for moving the disease to other communities. Watering down areas to prevent
dust is akin to a perfect storm for the movement of the pathogen, as it is known to travel
from location to location via water. Having vehicles drive through the wetted areas and
then through the habitat is a perfect way to spread the disease through the roads and
trails on the entire property, add in seasonal rains and whatever was spread via the
bikes now continues to spread off roads and trails into the entire area.
I wanted to be sure the Planning Commission was fully aware of the potential
consequences to the endangered plant community should they allow this project to
continue. I am sympathetic to the economic needs of the county and the landowner but
I believe the risks associated with this project are too great for the endangered plant
community to allow it to go forward. Approving this project is a major risk to the future of
lone Manzanita and lone buckwheat in the county. Since your county is the only
location of these species, the risk is the loss of these species completely. I ask you to
seriously consider the ramifications of approving this mitigated negative declaration and
urge you to reject it. Minimally, an Environmental Impact Statement should be required
to address the issues noted above. I hope the landowner can find more suitable
activities for his property that would not seriously endanger this plant community and
the biodiversity of Amador County.
Sincerely,
Barbara A. Holzman, PhD
Email: [email protected]
1f}
PHYTOSPHERE RESEARCH
ft-/- - - October 4, 2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
Dear Planning Commissioners:
I am submitting comments on the proposed Negative Declaration for the Cross County Promotions
LLC Use Permit for the lone Hare Scrambles off road motorcycle events.
Based on the description of the project and the environmental documents provided by the applicant,
it is clear that the project is I ikely to have significant negative impacts on lone manzanita (federal
threatened species) located on the project site. The impact is associated with the high probability
that Phytophthora cinnamomi, a lethal soil-borne pathogen of lone manzanita and many other plant
species, would be introduced and/or spread throughout the project area by the proposed project.
This impact was not considered by the applicant's biological consultant. This is a significant
omission, as the root disease cause by this pathogen has been identified as one of the most
important threats to lone manzanita. The impacts associated with this disease will not be addressed
by the proposed mitigations. As such, Section IV.A. of the Initial Study/Negative Declaration is
inaccurate and should show that the project has a potentially significant impact. Because this issue
cannot be found to be insignificant or mitigable through standard conditions, the Mitigated Negative
Declaration for this project is not supported by facts.
I have been conducting research into diseases affecting lone manzanita since 2001. Significant
disease problems had been noted as affecting this rare species as least as early as 1988. Through our
research, conducted in collaboration with Dr. Barbara Holzman of San Francisco State University
and later in collaboration with Dr. Matteo Garbelotto of the University of California, Berkeley, we
identified a pathogen that threatens the presistence of lone manzanita. The introduced water mold
Phytophthora cinnamomi causes a severe and lethal root rot of lone manzanita in large portions the
plant's natural range in the vicinity of lone.
Phytophthora cinnamomi has a very wide host range, and affects a wide variety of agricultural crops,
horticultural plants, and an increasing number of California native plant communities. The pathogen
attacks and decays roots in th e soil. It can persi st for many year s even in the absence of host plants.
Our studies show that P. cinnamomi was introduced into lone manzanita range from multiple
sources and has spread from localized infestations through off-road vehicle and foot traffic. In
Australia, where P. cinnamomi has infested and devastated several hundred thousand hectares of
native forests, new infestations are commonly associated with unpaved logging roads. Once
introduced into an area, the pathogen can also move downhill with flowing water during the wet
season.
Once soil becomes infested with P. cinnamomi, it will no longer support the development of lone
manzanita stands or oth er susceptible hosts. Since lon e manzanita is limited to unusual soils that are
very limited in extent, protecting existing stands from P. cinnamomi introduction is the primary way
to maintain lone manzanita 's dwindling habitat. The references listed at the end of this letter
provide further information about P. cinnamomi and its effects on lone manzanita.
The proposed project represents one of the worst possible impacts to lone manzan ita habitat. The
processes involved - grading of trails and roads; movement of potentially infested soils from many
locations on vehicle, shoes, etc.; high levels of vehicle and foot traffic during race events - are
.l~?LQ.~YJ~.§I~§_~IL.Y.'~f~.Y!~~_~!..~~...~?§~.:?_~~~......__ ._...._......_._..... ._...._._ .... __.__..............(?:9!l.1.?5:~?:~!?~lc:.(3!.!~~_
email: [email protected] ~ URL: http://Phytosphere.com
10/05/12
Page 2 of 2
essentially a recipe for ensuring that this pathogen, and perhaps other damaging Phytophthora
species, become introduced and spread throughout the site.
The biological consultant appears to have been unaware of this impact. They are clearly not
qualified to determine whether the pathogen might already occur on parts of the site. If this is the
case, the project would facilitate the rapid spread of the pathogen through the site and result in the
permanent destruction of the existing stands over a period of years. If the pathogen is not now
present at the site, it is likely that it will be introduced by event participants and spectators,
especially given that many already infested areas are present in the areas around lone, including sites
used by off road vehicles. Movement of infested soil is favored when soils are wet, either as the
result of water application for dust abatement, or from spring rainfall.
Given the logistics of the events and the overall topography and layout of the site, the proposed
mitigation measures will not prevent introduction and/or spread of this pathogen. It is highly
unlikely that suitable mitigations could be developed or enforced for events of the sort that are
proposed. Restricting vehicular and foot traffic into or near uninfested areas is the primary means for
preventing spread of this pathogen, which is the exact opposite of the proposed project.
I have only addressed the issue of this disease in my comments, but it is clear that other impacts to
both lone manzanita and Irish Hill buckwheat are not adequately addressed by the proposed
mitigations. I respectfully recommend that the Commission reject the proposed mitigated negative
declaration. The site proposed for this project is quite simply unsuited for this use due to its existing
biological resources that are threatened by the proposed activities. The applicant should be
encouraged to find a more suitable site.
Regards,
Tedmund J. Swiecki, Ph.D.
Principal/Plant Pathologist
References
Swiecki, T. J. and E. Bernhardt. 2003 . Diseases threaten the survival of lone manzanita (Arctostaphylos
myrtifolia). Phytosphere Research, Vacaville, CA. Prepared for San Francisco State University.
http://phytosphere.com/publications/ionemanzdis.htm
Swiecki, T. L E. A. Bernhardt, and M. Garbelotto. 2003. First report of root and crown rot caused by
Phytophthora cinnamomi affecting native stands of Arctostaphylos myrtifolia and A. viscida in California. Plant
Disease 87:1395
Swiecki, T. L E. Bernhardt, and M. Garbelotto. 2005. Distribution of Phytophthora cinnamomi within the range
of lone manzanita (Arctostaphylos myrtifolia). Phytosphere Research, Vacaville, CA. Prepared for California
Department of Fish and Game. http ://phytosphere.com/publications/Pcinn_Amyrt_200S.htm
Swiecki, T. J.; Bernhardt, E.; Garbelotto, M.; Fichtner, E. 2011. The exotic plant pathogen Phytophthora
cinnamomi: A major threat to rare Arctostaphylos and much more. pp . 367-371. J. W. Willoughby, B. K. Orr,
K.A. Schierenbeck, and N. J. Jensen [edsl Proceedings of the CNPS Conservation Conference: Strategies and
Solutions, 17-19 Jan 2009, California Native Plant Society, Sacramento, CA.
http://phytosphere.com/publications/Pcinn_Arctostaphylos_CNPSConsConf2009.htm
PHYTOSPHERE RESEARCH
Correspondence Submitted
During the 10/9/12
Planning Commission Meeting
DISCUSSION:
• Event Overview
• Socioeconomic Benefits
• Traffic Plan
• Parking Plan
• Plant/Tree habitat
• Creeks/Streams
DISCUSSION PAGE 2
•
Recycle/Solid Waste
•
Fi re Safety
•
Rider Safety
•
Noise Mitigation
• Concerns from local residents
EVENT OVERVI EW
•
Event Promoter since 2005 goals of outdoor family
pleasure and high quality events.
Permit request for 2 day Me off-road event 2 times per
year.
• The location is on portions of 6 different parcels near Hwy
104 and Irish Hill Rd
•
•
•
Property currently used for seasonal cattle and mining.
This is not is not a MX event, it is a natural terrain off-road
course.
• If successful the event will provide family recreation, help a
local charity and the local economy.
• Event hours between 8:30am and 4pm Saturday and
Sunday twice per year
• Guests will arrive beginning Friday at 4pm and all
departed by Sunday 5pm.
• Guests will arrive and depart at various times during
the weekend based on when their event takes place
and how long they wish to stay.
• Charter member AMA and D-36.
• Governed by 2 rulebooks and state/local laws.
SOCIOECONOMIC BENEFITS:
• Provide local recreation for residents
• Merchants benefit from local food, fuel,
lodging revenue
• On-site vendors such as Clark's Corner
and Pizza Factory
• Donations to Interfaith Food Bank
TRAFFIC PLAN
Guests arrive from Highway 104
Turn north on Irish Hill Road
Proceed approximately 1.2 miles to entrance
10 MPH Speed limit on event roads
Exit gate guests turn south on Irish Hill Road
Proceed approximately 114 mile to Highway 104
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PARKING PLAN
• Guests checked-in on gravel Rd 3/8 mile in
from Irish Hill Rd
• Each vehicle escorted to parking area
• Parking/Camping area with 192 spaces
• Many are 20 feet wide to accommodate RV
awnings
• Additional space for 40 plus vehicles
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PLANT/TREE HABITAT
•
•
•
•
•
Course designed with assistance from Vollmar
Natural Land Consulting
No Oak trees removed
Botanist defined 3 areas of habitat for rare
plants (High, Low, Medium quality)
Trails avoid all levels habitat that may be
desirable to rare plants
Course travels through habitat only on existing
fire roads
RARE PLANT MITIGATION
• lone Manzanita: within 20' of a plant
lathe/ribbon required
• Irish Hill Buckwheat: within 50' of plant
lathe/ribbon required
• Rare plant information provided to
participants
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RECYCLE/SOLID WASTE
• Trash bags to all participants at entrance.
• Recycle bins and garbage cans next to each
portable toilet/wash station.
• Courses cleaned up of all markings Sunday
afternoon/evening.
• Final cleanup crew to pick up anything left
behind
FIRE SAFETY
• Typically event dates mid-November and
February during the lower fire risk times.
• Parking/Camping areas will be mowed to 2"
height.
• One campfire if approved 1 week prior by CDF.
• Spark arrestors required per eve 38000
• Fire extinguishers camping/parking and
pit area
• Data provided by State Parks depicts
level of fire danger
RIDER SAFETY
• Safety apparel per AMA and D-36
rulebooks
• Course markings
• Mobile Course workers to assist riders
• Mobile Course workers have radio
communication to home check
NOISE MITIGATION
• Quiet time is 10pm to 7am
• There will not be a PA system
• Participant information sheet will
contain requirement of no loud music
• Motorcycles mufflers tested for
38000 compliance
eve
SOME CONCERNS OF SOME LOCAL RESIDENTS
•
Motocross people party too much
•
Poach animals along the road
•
Dumping trash anywhere
•
Rare plants destroyed from clearing trails for motocross
• Campers leaving behind their garbage
•
Fire hazard from trimmed brush
•
Motocross riders remove their spark arrestors from their
bikes
• Campers may not contain their campfires
• Premature breakdown of asphalt on Irish Hill Rd from
RV's
• High risk of traffic overflow parking onto Irish Hill Rd
and Highway 104
• Li m ited pa rki ng
• Spectators will travel all over the course crushing rare
plants
• Will the caution tape be removed after the event?
• Sound level of 96db from the bikes is the same as
commercial aircraft taking off and landing
• Promoter will want to increase from to events per year
to increase profits
Amador County
Planning Commission
October 9, 2012
OPPOSITION TO
Request by
Cross County Promotions, LLC
for a Use Permit
to allow the
lone Hare Scrambles
opposition to Location for lone Hare Scrambles Motocross Event
Page 1
Overview of Proposed Dirt Bike Track
LEGEND: Solid e
igh Yellow = Adult Track only (4.46 miles), Solid Red = Youth Track only (.27 miles)
Solid
Yellow =Youth & Adult Track (1 .66 miles) Dashed Line =Track Follows Existing Road
NOTE:
Adult Course
=6.12 miles (apprx. 2 miles existing road),
Youth Course
= 1.93 miles (apprx. % mile existing road)
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Opposition to Location for lone Hare Scrambles Motocross Event
Page 2
Saturday: 5 Races on Youth & Women's Course
(1.93 mile course)
Approximately 1,400 laps (totaled among all participants) during about 7 hours of racing.
3 Races on Adult Course
Sunday:
(6 .12 mile course)
Approximately 1,600 laps (totaled among all participants) during about 6 hours of racing.
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Page 3
Note: The close proximity of sensitive plant species on East Race Track
Red Triangle = lone Manzanita. This species is federally listed as threatened and listed as endangered in CA.
etlo
Triangle = Irish Hill Buckwheat. This species is listed as endangered both federally and in California.
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Opposition to Location for lone Hare Scrambles Motocross Event
Page 4
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"SERVING THE AMATEUR COMPETITOR SINCE 1955"
DISTRICT 36 MOTORCYCLE SPORTS COMMITTEE, INC.
'"\~t~
Referee's Meeting
February 15, 2012
America's Best Value Inn, Vacaville, CA
Meeting called to order at 7:39 p.m. by President Dave Pickett
Roll Call: 14 of 31 ClubslPromoters in Attendance
Minutes from December 2011 and January 2012 meetings approved as written.
Guests:
Eric Peddicord
Dave Wood
Committee Reports:
Sanctioning: Steward Jeff Henning not in attendance:
• Dirt Track Sanction meeting was held in January. Great participation.
•
Stanlpede HS cancelled
• Rockn' Horse National H & H rescheduled to June 23-24,2012.
Youth Cross Country: Steward Al Fitch reported:
• February 11, 2012: E Street CC hosted by E Street MX. There were 16 C 50s, 5 AlB 50s, 11 AlB Kids, and
87 C Kids for a total of 118 youth riders. Lots of issues with no spark arrest<2!§.., Promoter "allowed riders to k"
race without spark arrestors and were all disqualified. Thank you all of the CC Corrimitteemen that help'on
'youth days.
Cross Country: Steward Kraig Traum reported:
• February 12,2012: E Street CC hosted by E Street MX. Course was too short (3.5 miles) for amount of
riders who showed up, scoring crew could not keep up at homecheck. We have a protest in the "A-250"
class to hear at the competition meeting. There were 13 AA, 95 A, 112 B, 264 C, 7 JR Sportsmen, 10
Vintage Blue Plate, 2 Vintage Exhibition, 1 Pioneer for a total of 504 adult racers.
• Cycle Gear Holeshot Awards: Youth - C 50 4-6 years went to Drake Sahagun $50 gift certificate
• Cycle Gear Holeshot Award: Adult - Vintage Blue Plate went to Matt Patterson $100 gift certificate
• The next event is Picacho Creek National HS at Clear Creek February 18-19, 2012.
•
Rock'n Horse 100 National H&H in Sparks, NV has been postponed until June 23-24,2012.
• Stampede Western National HS on 3/3-3/4 has been cancelled.
• Stampede HS on 11110 and 11111 has location to be announced.
Cross Country Scoring: Liz Chamblee reported:
• February 11-12, 2012: E Street CC hosted by E Street MX. We sold 74 transponders, 25 helmet stickers
and had 33 rentals. Next event is February 18-19 at Picacho Creek hosted by Salinas Ramblers.
Women: Ray Spore reported on behalf of Steward Jennifer Spore:
• January 29,2012: Bearfoot Family Enduro. There were 5 C, 7 Divas for a total of 12 women.
• Next Family Enduro is the Wild Piglet on March 11,2012 at Hollisters Hills SVRA.
• The next enduro is Sawmill on April 1, 2012 at Cow Mountain.
• February 11-12, 2012: E Street CC. There were 4 Beginner, 6 Diva, 14 C, 5 C Vet, 7 B, 1 B Vet, 1 A, 1 AA
for a total of 39 women.
• The next cross country event is Picacho Creek HS at Coalinga on February 18-19,2012.
Page 1
t1t~~
Board Meeting
November 16,2011
America's Best Value Inn, Vacaville, CA
Meeting called to order at 9:32 PM. by President Dave Pickett
Roll Call: 9 of 9 members in Attendance.
New Business:
Debby Rocha presented her distaste of certain events that took place over the year.
Banquet: Sheila presented menu ideas. Need staging and scissor lift.
Old Business:
Oakland MC disappointed with conflicting date between their long standing Enduro and new West Coast Enduro
series. Jeff Santos will go to West CHEK series and ask for conflicting date to be a wild card.
Discussion regarding concern over having motorcycles on same course as minicycles.
New Business:
Randy Kremlacek distributed investment "losses".
Randy Kremlacek: Requested approval to send a letter of recognition to Bob Bellino for his contributions to D36.
All Board members signed letter.
Dave Pickett: Discussion regarding Newsletter. Will advise the Newsletter Editor to make the cover of the next
newsletter to be about the Carnegie rider appreciation day.
Discussion regarding 2012 Tucker Rocky contingency. Ed Santin moved to accept the proposal as written with
allowance for Jeff Irwin to request changes. Vote 8-0, 1 abstain.
AI Fitch: Some £lJmlOters allow riders without spark arrestors. Are we enforcing the rule book or does the Referee
h~e the option to make up his own rules? Yes we always enforce the rule book.
Kraig Traum collected $595 cash plus $1200 LAO funds and gave to Rich Fern.
Kraig Traum looking into credit card processing via cell phone. Randy Kremlacek moved to authorize Kraig Traum
to obtain a credit card reader with appropriate fees to be reviewed in 6 months. Vote 8-0, 1 abstain. Motion passes.
Kraig Traum requested approval to cover repair costs for the Mule that is used for Cross Country events. Bill
McGibbon moved to cover the repair costs to Al Fitch's Mule. Vote 8-0, 'I abstain. Funds to come from general
fund.
Jeff Irwin: putting together proposal for new rule proposal guidelines.
Jeff Irwin: Rule proposal submitted tonight by Ralph Lee and will be distributed to the Board.
Jeff Irwin: Add to agenda for next month - How can we segment D36 business items and how can we become more
effective?
Meeting adjourned at 12:05 AM Thursday November 17,2011.
Respectfully Submitted,
LiJ~
Secretary
Confidential
Page 4
Competition Committee Meeting
February 15, 2012
America's Best Value Inn, Vacaville, CA
Meeting called to order at 8: 11 PM. by Director Jeff Irwin
Roll Call: 21 of 49 members in attendance.
•
Cross Country Protest: rider Brady Hoover, # 295H at E Street Cc. Devin Osanna, Referee, stated his position.
Brady Hoover stated his position. Room cleared of non-committee members for discussion. Called for the vote
to uphold the protest 15 - 0, 4 abstain. Protest upheld.
Meeting adjourned at 8:25 PM.
Email Minutes
January 19 - February 15, 2012
January 19, 2012: Randy Kremlacek moved to authorize the purchase of an annual subscription to Quickbooks
Online Plus. Vote 8-0 (YES: Traum, Fouts, Santin, Pickett, Fitch, Henning, Irwin, Davis)
February 3, 2012: John Davis moved to allocate up to $100.00 for shipping of 2011 Enduro series awards. Vote 5-0
in favor, motion carried. (YES: Davis, Kremlacek, Traum, Santin, Pickett)
Board Meeting
February 15, 2012
America's Best Value Inn~acaville, CA
Meeting called to order at 8:39 PM. by President Dave Pickett
Roll Call: 7 of 9 members in Attendance. Missing were Jerry Fouts and Jeff Henning.
Discussion regarding the 2011 banquet budget and financials. Sheila provided suggestions for future banquet
chairman. Randy Kremlacek moved to develop a budget for the 2012 Banquet by April 2012. Vote 7-0. Add to
agenda.
,
I
l
Discussion regarding promoters/clubs allowing riders to race without spark arrestors and intentionally defying the
D36 Operations Manual. John Davis moved that any promoter or club knowingly violatingthe DIstrict 36
Operations Manual are subject to a penalty of up to $500.00. (Place new paragraph under paragraph 4 page 6) New
policy effective tomorrow Vote 5-0, 1 abstain.
Presentation by Dave Wood. Discussion regarding Tahoe National Forest Litigation.
Finance Committee: Purchased Quickbooks 2012 desktop version. Paypal account is set up. Treasurer distributed
financial reports to Board members.
Kraig Traum moved to reimburse Liz Chamblee for scoring supplies. Vote 5-0.
Kraig Traum moved to reimburse Mike Carli for soda for the banquet. Vote 5-0. /
Old Business:
Discussion regarding District 36 website presented by Randy Kremlacek.
New Business:
Discussion regarding AMA & Dirt Track Amateur Nationals. Why didn't AMA contact District 36 rather than Lodi
MC?
Dave Pickett moved to purchase CC entry forms. Vote 5-0.
Page 3
Live Fuel
Moisture% .
Species
Sample
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Change
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Date
Sampled
9/13/2012
Tonzi Road
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Amador County
New Growth
TonziRoad
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Amador County
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10/3/2012
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Auburn, CA 95603
October 9, 2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
Subject: Cross Country Productions Biannual lone Hare Scrambles Events
Dear Planning Commissioners:
This is a summary of testimony I plan to present to the Commission when I speak at the October 9, 2012
meeting discussing Cross Country Productions Biannual lone Hare Scrambles Events. My comments are
meant to supplement the comment letter sent by Ted Swiecki, Ph.D., of Phytosphere Research. He is
the foremost authority on the most important disease affecting lone manzanita, Phytophthora
cinnamomi. In fact his team identified the disease initially.
I gained experience working with lone manzanita and the disease (Phytophthora cinnamomi) in Amador
County in the 20 years I was botanist for the Bureau of Land Management, Mother Lode Field Office. (I
retired in 2010.)
•
Phytophthora cinnamomi is a water mold that affects many plant species, but is particularly
lethal to some species like lone manzanita. It causes root rot, depriving the plant of water and
nutrients. It is found in soils and plant tissues, and can persist in soils for many years. Transport
of soil containing the pathogen is the primary way that new infestations begin.
•
lone manzanita has limited habitat because of very specific habit at requirements. It is adapted
to the acidic, aluminum rich, nutrient poor soils of the lone formation.
Once the pathogen is introduced to a stand of lone manzanita, the pathogen can spread from
shrub to shrub by root contact or proximity, and also by surface water flow, resulting in whole
stands being exposed to the disease and dying.
Long term and perhaps permanent elimination of habitat can occur because of the persistence
of the pathogen in the soil. After the old stand has died, new plants cannot reestablish on the
site because the soil still contains spores of the disease.
•
If the pathogen is already present along the race route, the spread of the pathogen along the
long route of this race will be a major impact.
Surveys that look for lone manzanita will not be sufficient to ascertain ifthe pathogen is
present. Other manzanita species support the pathogen, for instance white leaf manzanita. If
infected white leaf manzanita occurs along the course, the disease is likely to spread along the
course to lone manzanita near the course. A survey by a biologist with specialized experience
identifying symptoms of this disease is needed to assess the potential for this kind of disease
transmission.
The pathogen is present approximately one mile north of the property on which the race is
planned, on public and private land. It is not known how far south this occurrence of the
pathogen extends.
•
There are 4 main clusters of lone manzanita in western Amador County. Two of these clusters
(near State Route 88 and near Carbondale Road) already have Phytophthora cinnamomi
occurrences. The other two clusters (near Irish Hill Road and near N. Camanche Parkway) are
disease free as far as we know. The Irish Hill Road area where the race is proposed is one of the
areas that is disease free, at least as far as we know. That increases the potential for the long
term survival of lone manzanita in the Irish Hill area, and increases the importance of preserving
this habitat for conserving the species.
•
BLM hygiene measures include:
1) Closure of BLM parcels with lone manzanita to public use.
2)
BLM personnel and contractors do not enter the parcels during the wet-soil portions of
the year except for emergency purposes.
3)
During the dry-soil portions ofthe year, when BLM personnel and contractors enter
areas with lone manzanita, vehicle tires and undercarriages are washed thoroughly
beforehand. Boots are brushed and sprayed with 70% isopropyl alcohol initially when
personnel leave the vehicle, and then at intervals.
•
According to the applicant they project 550 visitors and participants on Sundays of race
weekends. They also expect that some participants and visitors on Saturdays will not return for
Sunday, so there will be additional Saturday-only attendees. Presumably there will be additional
staff to run the event. So if we use the figure of 650 people arriving for the event, (the
possibility of up to 1000 people attending the event is mentioned elsewhere in the Event Plan)
and if we assume 2 people per vehicle, that means 325 highway vehicles would arrive for each
race weekend. The applicants project 300 riders on Sunday, and additional riders who will just
participate Saturday. So well over 300 dirt bikes are expected. Overall, on a race weekend over
600 vehicles are expected to converge on the area, anyone of which might transport soil with
the pathogen . Dirt bikes, because they almost always are ridden on bare soil, are more likely to
be exposed to the pathogen. Because their knobby tires and their tendency to kick up soil as
they cross difficult terrain, they are well adapted to picking up and transporting soils that may
contain the pathogen . Cumulatively the combined vehicle and foot traffic makes the
introduction of the pathogen likely, especially ifthe race is run repeatedly. For instance if there
is only a 10% likelihood of introduction of the pathogen with a single running of the race, after 4
years (8 races) there is a 57% chance that the disease will be introduced. And wet soils are a
possibility during the fall, and very likely during the early spring. when the races are proposed.
Wet soils increase the likelihood of disease transmission.
•
Because the CEQA documents submitted by the proponent do not discuss Phytophthora
cinnamomi, the analysis is inadequate to assess the impacts of this project.
I appreciate the opportunity to present this additional information to the Commission.
Sincerely,
AI Franklin, Botanist
(with BLM from 1990-2010)
PHYTOSPHERE RESEARCH
October 4, 2012
Amador County Planning Commission
County Administration Center
810 Court Street
Jackson, CA 95642-2132
Dear Planning Commissioners:
I am submitting comments on the proposed Negative Declaration for the Cross County Promotions
LLC Use Permit for the lone Hare Scrambles off road motorcycle events.
Based on the description of the project and the environmental documents provided by the applicant,
it is clear that the project is likely to have significant negative impacts on lone manzanita (federal
threatened species) located on the project site. The impact is associated with the high probability
that Phytophthora cinnamomi, a lethal soil-borne pathogen of lone manzanita and many other plant
species, would be introduced and/or spread throughout the project area by the proposed project.
This impact was not considered by the applicant's biological consultant. This is a significant
om iss ion, as the root disease cause by this pathogen has been identified as one of the most
important threats to lone manzanita. The impacts associated with this disease will not be addressed
by the proposed mitigations. As such, Section IV.A. of the Initial Study/Negative Declaration is
inaccurate and should show that the project has a potentially significant impact. Because this issue
cannot be found to be insignificant or mitigable through standard conditions, the Mitigated Negative
Declaration for this project is not supported by facts.
I have been conducting research into diseases affecting lone manzanita since 2001. Significant
disease problems had been noted as affecting this rare species as least as early as 1988. Through our
research, conducted in collaboration with Dr. Barbara Holzman of San Francisco State University
and later in collaboration with Dr. Matteo Garbelotto of the University of California, Berkeley, we
identified a pathogen that threatens the presistence of lone manzanita. The introduced water mold
Phytophthora cinnamomi causes a severe and lethal root rot of lone manzanita in large portions the
plant's natural range in the vicinity of lone.
Phytophthora cinnamomi has a very wide host range, and affects a wide variety of agricultural crops,
horticultural plants, and an increasing number of California native plant communities . The pathogen
attacks and decays roots in the soil. It can persist for many years even in the absence of host plants.
Our studies show that P. cinnamomi was introduced into lone manzanita range from multiple
sources and has spread from localized infestations through off-road vehicle and foot traffic. In
Austral ia, where P. cinnamomi has infested and devastated several hundred thousand hectares of
native forests, new infestations are commonly associated with unpaved logging roads. Once
introduced into an area, the pathogen can also move downhill with flowing water during the wet
season.
Once soil becomes infested with P. cinnamomi, it will no longer support the development of lone
manzanita stands or other susceptible hosts. Since lone manzanita is limited to unusual soils that are
very limited in extent, protecting existing stands from P. cinnamomi introduction is the primary way
to maintain lone manzanita's dwindling habitat. The references listed at the end of this letter
provide further information about P. cinnamomi and its effects on lone manzanita.
The proposed project represents one of the worst possible impacts to lone manzanita habitat. The
processes involved - grading of trails and roads; movement of potentially infested soils from many
locations on vehicle, shoes, etc.; high levels of vehicle and foot traffic during race events - are
1027 DAVIS STREET. VACAVILLE. CA 95687-5495
email: [email protected] .. URL: http://Phytosphere.com
(707) 452-8735 voice/fax
10/05/1 2
Page 2 of 2
essenti all y a recipe for ensurin g th at thi s path ogen, and perh aps oth er damag in g Ph ytophtho ra
spec ies, beco me introduced and spread throughout the site.
Th e bi ologica l con sultant appears to have bee n unaware of thi s impact. Th ey are cl early not
qu alifi ed to determin e wh eth er th e path oge n mi ght already occur on parts of the si te. If thi s is th e
case, the project wo uld fac ilitate th e rapid spread of th e path ogen through th e site and result in th e
perm anent destru cti o n of th e ex isting stand s over a peri od of years. If th e pathogen is not now
present at the site, it is likely th at it will be introduced by event parti cipants and spectators,
es pecially given that many already infested areas are present in th e areas around lon e, includin g sites
used by off road vehicles . Movement of infested soil is favored wh en so il s are w et, eith er as th e
res ult of w ater appli cati on fo r du st abatement, or from sprin g rainfall.
Given th e logistics of th e events and th e overall topography and layout of the site, the proposed
mitigation meas ures will not prevent introduction and/or spread of thi s pathogen. It is hi ghly
unlikely that suitabl e miti gati ons could be developed or enforced for events of th e sort that are
proposed. Restri ctin g vehi cul ar and fo ot traffi c into or near uninfested areas is the prim ary means for
preventin g spread of thi s path ogen, whi ch is the exact opposite of th e proposed proj ect.
I have only addressed th e iss ue of thi s di sease in my co mm ents, but it is clear that oth er impacts to
both lon e manza nita and Irish H ill bu ckwheat are not adequ ately addressed by th e proposed
mitigation s. I res pectfully recomm end th at th e Commi ss ion reject th e proposed mitigated negative
decl arati on. Th e site proposed for thi s project is quite sim ply un suited for thi s use due to its ex isting
biologica l resources th at are threatened by th e proposed act ivities. Th e applicant should be
encouraged to find a more suitabl e site.
Regard s,
Tedmund J. Swi ecki, Ph .D .
Prin cipal/Plant Pathol ogist
References
Swi ecki, T. J. and E. Bernh ardt. 2003. Diseases threa ten th e surviva l of lone manza nita (A rctostaph ylos
m yrtifolia). Ph ytosphere Research, Vacav ille, CA. Prepared for Sa n Francisco State University.
http://phytosp here.com/pub li cations/ionemanzdi s. htm
Swi ecki, T. J., E. A. Bernh ardt, and M. Garbelotto. 2003. First report of root and crown rot ca used by
Phytophthora cinnamomi affecti ng native stands of Arctostaphylos myrtifolia and A. viscida in Ca lifor nia. Plant
Disease B7 :1 395
Swieck i, T. J., E. Bernhardt, and M . Garbelo tto. 2005. Di stribu tion of Ph ytoph thora cinnamomi wi th in th e range
of lone manza nita (A rctostaph ylos m yrtifo lia). Phytosphere Research, Vaca vill e, CA. Prepared for Ca lifornia
D epartm ent of Fi sh and Game. http://phytosphere.com/ publica ti ons/Pcinn_Amyrt_2 005.htm
Swieck i, T. J.; Bernh ardt, E.; Garbelotto, M .; Fichtn er, E. 2011 . Th e exotic plant pa th ogen Ph ytophtho ra
cinn amomi: A major threat to rare A rctos taphylos and much more . pp. 367-37 1. J. W. Will oughby, B. K. O rr,
K.A. Schierenbeck, and N. J. Jensen [eds. ], Proceedin gs of th e CNPS Conserva tion Conference : Strategies and
So luti ons, 17- 19 Jan 2009, Ca liforni a Nati ve Pl ant Society, Sacramen to, CA.
http://phytosp here.com/p ub li ca ti ons/Pcinn_Arctostaphylos_CNPSConsConf2009.htm
PHYTOSPHERE RESEARCH
Iris.htiill NeigqborllQod Petition
Attention: Amador County Planning Commissioners
810 Court street, Jackson, CA 95642
Sept. 15, 2012
Susan Kohler-Lockett
16003 Irish Hill Rd
lone, CA 95640
209 2 744478
[email protected]
We, the undersigned, oppose the request for land use in the Irish Hill area for the proposed "off road
motorcycle events" The lone Hare Scrambles planned by Cross Country Promotions, LLC. We are dismayed
that such an event would even be considered in this rural, agricultural community. We are property owners,
tax payers, cattle ranchers, voters and residents who live and work our land in peace and harmony with our
neighbors. Some of us have lived out here for 6 generations, being the descendants of early settlers who
carved homesteads out of the brushy wilderness. We are caretakers for our properties as well as the
environment.
The negatives for these events far outweigh any positive outcomes, other than profit for the event holders or
special interest groups who wish to receive grant monies.
The county road is not designed to handle this amount of traffic. The noise, dust and fire dangers presented
by such events threaten our way oflife, safety and the pasture lands we depend upon for cattle grazing. There
are numerous endangered botanical species cataloged here, within the proposed off road event areas, which
will be destroyed. Other problems associated with such events include road side garbage dumping, loud
music and parties, alcohol and drug abuse issues, and numerous injuries and fatalities, including children.
(see attachments)
Simply put, we do not want 300 to 500 contestants, particip&nts and spectators invading the privacy of our
neighborhood.
The owners of the Arroyo Seco Land Grant specifically stated upon purchase of the land, that "non-developed
lunda would bc sct asidc providing wildlifc habitat". Off-'road motorcyclc racing events do not fit thin land uac
description. The owners further stated that "much of the la~d would maintain its original use" that being;
cattle grazing. They also acknowledged "willingness to preserv the endangered species identified on their
property and that they would meet with neighbors prior to development or land use".
Please do not adopt a Mitigated Negative Declaration for this land use proposal. A complete Environmental
Impact Assessment should be ordered.
Please close the door on this proposal as it is not acceptable land use for this area.
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September 29,2012
Amador County Planning Commission
810 Court st.
Jackson, CA 95642
RE: OPPOSED to Use Permit requested by Cross Country Promotions for lone Hare Scrambles
I am strongly opposed to this Use Permit. It will be detrimental to Amador Co. for these reasons:
I Safety
Fire:
•
•
•
•
High risk of fire in the dense brush and dry range areas at the eventl race site caused byTrimming and leaving behind brush (fire fuel) along the race track in preparation for the event.
Operation of motorcycles by participants who remove spark arrestors to improve performance.
Participant and visitor smokers who are unfamiliar with the flammability of the terrain.
Open outdoor fires in and around the campground; use of bar-b-ques & outdoor cooking.
Traffic: Risk of accidents due to the high volume of left tums crossing oncoming traffic during• Ingress onto Irish Hill Rd. from Highway 104,
• And more hazardously, at day's end, by exhausted participants who egress onto Highway 16,
with left turns at Michigan Bar Road, Forest Home Road, and Carbondale Road.
I Health
Hazardous Materials: The transport, storage, and spills of oil, gasoline and lubricants used for
motorcycles pose a risk for the environment, fire, as well as humans with respect to vapors/ fumes.
Trash: Litter will be dropped by the participants & viSitors; it will overflow from trash receptacles and
be left behind by campers-which will migrate to the nearby roads and onto the neighboring ranches.
I Peace and Comfort
Noise: This area, zoned R1-A as a single-family residential-agricultural district, is a rural peaceful
setting. Several noise-producing elements of the proposed race/ event threaten this setting with• Motorcycles revving before & after races. Two consecutive days of many motorcycles on the
track simultaneously racing from 8:30am - 4pm - almost 8 continuous hours.
A May 2006 Sacramento Business Journal article titled "Moto Money" describes motorcycle
events as follows "the settings are dusty, muddy, noisy, intense."
•
Generators used to power equipment to run the race & make repairs, for RVs, and lighting.
Outdoor Lighting: The potential exists for race organizers, participants, and campers to use outdoor
lighting causing light pollution which will disrupt the dark night time sky of this area.
I General Welfare of persons residing and working in the Irish Hill Road neighborhood
Road Wear: Trips for the event will cause asphalt breakdown not otherwise incurred on Irish Hill Rd• Road travel will occur for race preparations (brushing), race participation and viewing, vendor
set-up and clean-up, portable toilet transport & pumping services, and waste hauling.
Parking: With fewer than 200 spaces for vehicles (many with trailers) for 325 participants/ visitors on
Saturday & 550 on Sunday, the risk is high for vehicles to overflow onto Irish Hill Rd. & Highway 104.
Again, I am strongly opposed to this Use Permit- for one time, for one year, or for anytime.
Karen Vaira, Co-owner
15942 Irish Hill Road
lone, California
Page 1 of2
Fran & June Vaira
~e-~ '0-~'-olql\L
From:
To:
Cc:
"Fran & June Vaira" <[email protected]>
<[email protected]>
"Dale Vaira" <[email protected]>; "Jim Vaira" <[email protected]>; "Karen Vaira (gmail)"
<[email protected]>
Sent:
Tuesday, October 02,20123:49 PM
Subject: Opposition to Use Permit for lone Hare Scramble
Commissioners,
Please "Vote No" on the request for the Use Permit requested by Cross Country Promotions, LLC for a
Hare Scramble Motocross event on property located on Irish Hill Road.
The event should not be allowed in this location because of the two sensitive plant species that are
struggling to grow on this property. "The most important step in conserving the lone plant
community is to preserve the habitat." 1.
• The Irish Hill Buckwheat is listed as an endangered species federally & in Califomia--a small
plant, only 3 to 8 inches in height, with very few occurrences.
• The lone Manzanita which is federally listed as threatened and is listed as an endangered
species in California--a plant species vulnerable to a soil bome root pathogen.
"Soil transportation through mechanisms such as vehicles, OHVs, walking through an
infected area, mining and soil operations should be restricted ... particularly in wet
seasons." 1.
Unfortunately, the Protection for these sensitive species appears minimal and highly unlikely to be
effective during a race event in which hundreds of spectators walk and hundreds of dirt bikes
competitively ride near the plants for over thousands of laps.
The Protection proposed in the Event Plan,2. and restated in the Conditions of Approval
section of the Mitigated Negative Declaration is the following:
• Place lathe with red flagging at 10ft spacing ...where Irish Hill Buckwheat is within 50
feet
• Place lathe with red flagging at 10 fl. spacing ...where lone manzanita is within 20
feet ...
"If however, there is any observed or suspected damage to lone manzanita or Irish hill
buckwheat during any race, the County should be notified."2.
WeaskyouVv110 is responsible to "observe or suspeCt damage?"
Vv110 is responsible to notify the County?
Vv11at actions will the County take for "observed or suspected damage?"
Vv11at actions, by whom, will be taken to rehabilitate and restore the sensitive plant species?
Again, we request a "No Vote" on the request for this Use Permit.
The Francis J. Vaira Family
15942 Irish Hill Road
lone, Califomia
10/312012
Page 2 of2
Sources:
1. Conservation and Recovery of lone Endemic Plants: Mapping the lone Plant Community; Final Report
prepared for California Department of Fish and Game; September 1,2004; Barbara Holzman, Ph.D. pages, 2, 6.
2. lone Hares Scramble Rare Plant and Creek Protection Plan; Vollmar Natural Lands Consulting; August 16,
2012; John Vollmar; "Resource Protection during Races."
10/3/2012
Overview of Proposeq Dirt Bike Track
LEGEND: Solid "
_
Yellow = AcjLjlt Track only (4.46 miles), Solid Red = Youth Track only (.27 miles)
YeIlQW::; Youth <$< AclLJlt Track (1.66 miles) Dashed Line = Track Follows Existing Road
Solid
NO.~I;::
Adult. Course
~ ..
=6,12 miles (apprx. 2 miles existing road),
Youth Course =' 1.93 miles (~pprx. Y4 mile existing rOqd)
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Opposition to Location for lone Hare Scrambles Motocross Event
Page 2
Saturday: 5 Races on Youth & Women's Course
(1.93 mile course)
Approximately 1,400 laps (totaled among all participants) during about 7 hours of racing.
3 Races on Adult Course
Sunday:
(6.12 mile course)
Approximately 1,600 laps (totaled among all participants) during about 6 hours of racing .
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Opposition to Location for lon e Hare Scrambles Motocross Event
Page 3
September 28, 2012
Amador County Planning Commission
810 Court st.
Jackson, CA 95642
Subject:
OPPOSITION to Use Permit requested by Cross Country Promotions for lone Hare Scrambles
I am a native of lone and treasure the environment and wildlife located on Irish Hill Road. My
family has lived and run businesses in the lone area since the 1880's. We own a family ranch
located on Irish Hill Road very close to the location slated for the Hare Scramble dirt-bike
events, on the property owned by Bill Bunce and partners.
As I reviewed the Application in the Amador County Planning Department office, I was filled with
questions about the appropriateness of this event in this rural agricultural ranching location.
In thinking about this event, I have to ask each of you What are the benefits of this race for the citizens Amador County? Or, for the
residents of Irish Hill Road? Or, for the environment?
•
How can a plant that is an endangered species 1 be protected by caution tape from a dirtbike rider who is competitively motivated to win the race?
•
Will that caution tape remain in place race after race after race over the course of the
two days of competitive racing?
•
Will that caution tape be replaced, in the appropriate locations, again and again and
again in preparation of every future event?
•
Do you expect a dirt-bike rider, at thrill-seeking racing speeds, to pay attention to, and be
cautious around, an endangered plant species?
Please listen (in your mind) to 2 consecutive days, of loud noise occurring for over 8 hours each
day. Hear the sound of motorbikes revved to around 96 decibels (dB)- that's a sound louder
than a jackhammer from 50 feet away (95db),2-continuously roaring and exceeding OSHA
Daily Permissible Noise Levels. 3
• How will the wildlife endure the noise? Will they "scramble" to escape the disruption of
their environment?
Would you be willing to have this dirt-bike race occur on land near your property?
I am strongly opposed to this Use Permit. I am requesting a "No vote" on the Use Permit for
Hare Scramble dirt bike events on the Irish Hill Road location.
June (Winter) Vaira
15942 Irish Hill Rd.
lone, California
1
lone Manzanita (federally listed as threatened, listed as endangered in CAl; lone & Irish Hill Buckwheat (both
listed as endangered federally & in CAl, Conservation and Recovery of lone Endemic Plants, Report prepared for
California Department of Fish and Game, Barbara Holzman, Ph.D., September 1, 2004.
2
Decibel (Loudness) Comparison Chart, Carol Galen Audio, San Antonio, Texas
3
OSHA Daily Permissible Noise Level Exposures allows 97dB for 3 hours a day and 95dB for 4 hours a day.
RECEIVED
In Reply Refer To:
Amador County
08ESMFOO-20 13-TA-0002
Amador County Planning Commission
" ',, :
County Administration Center
810 Court Street
Jackson, CA 95642-2132
Subject:
OCT 052012
OCT - 5 2012
PLANNING DEPARTMENT
Comments on proposed Negative Declaration for the Cross County Promotions
LLC Use P,ermit
Dear Planning Commissioners:
This letter responds to your proposed Mitigated Negative Declaration/Initial Environmental
Study (MND) regarding a request by Cross Country Ptomotioris, LLC for a Use Permit to allow
the lone Hare Scrambles. The lone Hare Scrambles is an off-road motorcross event that is
proposed to occur twice a year, in faU and in spring, approximately 1 mile northwest the city of
lone near Irish Hill in Amador County, California. The project proposes events that would take
place twice a year (for a total of 4 days per year) and the use permit would expire on December
31, 2017. Approximately 425 participants and 450 visitors would be expected for each event.
The race involves many riders for 2 hour timed events over a two day period with overnight
camping.
We are concerned about the significant impacts to one manzani'Qr (Arctostaphylos myrtifolia)
and Irish Hill oucl{w e (Eriogonum apricum val'. prostratutn) fTom the :Qroposed events. Th
ace would surround and travel direc 1)' through lis.te p ant area of tliese two taxa.
Mle do not think: that the resource protection measures prop,o e for enclangered and sensiti'®
species in the use permit boundary (use pennit condition 7) or discussed in the lone Hare
$cramble Rare Plant and Creek Protection Plfjn reduce the effects of the project to less th
significan.
n
impacts from the project include the likelihood of spreading Phytophthora cinnamomi, a
deadly plant disease, to Arctostaphylos myrtifolia. Root disease cause by P. cinnClrnorni has beel
iOentified s one oflhe most important tBIeats to lone anzanita . Although P. cinnamoml was
not known to be present at Irish Hill in 2004, it was lmown from south and northwest of Irish
Hill. We believe that bringing motorcycles from multiple outside locations will lead to a
potential spread of this pathogen to a currently undiseased area of A. myrtifolia. The proposed
MND does not mention impacts from P. cinnamomi from the events, nor does it provide any
measures that would ameliorate the likelihood of spreading the pathogen.
We are also concemed about mechanical danlage of the Eriogonum apricum var. prostratum and
plants on or near the course from the motorcyles. We do---not consider I=!lacing lathe with real
. ~ ::.
:; : ....
;.
':: " ~' ....
·f1~gging.·-.at !O~ft spacing along any ponion o:f1Jie cours
Where . apricum VID'.
wl~~ 5(J'-feet bfthe coW'se to prov~de adequate protection:
prosircriiimi~:" "
:";.
Please contact staff biologist Kirsteri Tarp or Recovery Division Chief, Josh Hull, at (916) 4146600, if you have any questions regarding this response.
Sincerely,
'.
~
. ~. ~· _ /7v ...
, ll)f Eric Tattersall
/
cc: CDFG, Sacramento, California
BLM, EI Dorado Hills, California
CNPS, Sacramento, California
Deputy Assistant Field Supervisor
'; .'
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Mother Lode Field Office
5152 HIllsdale Circle
EI Dorado Hills. CA 95762
www.ell hlm.llm/lllolhcrlodc
October 5, 2012
6840
CA- \80.20
RECEIVED
Amador County
Cara Agustin
Amador County Planning Department
810 Court Street
Jackson CA 95642-2132
OCT - 5 2012
PLANNING DEPARTMENT
Subject: Cross Country Promotions Biannual lone Hare Scrambles Events
Dear Ms. Agustin:
We have reviewed the Draft Mitigated Negative Declaration California Environmental
Quality Act document for the proposed lone Hare Scrambles. The Bureau of Land
Management's Mother Lode Field Office manages 55 acres of land approximately one
mile north of the proposed dirt bike track. This land was designated as an Area of Critical
Environmental Concern (ACEC) in 1988 to protect the lone manzanita (Arl'tostapyios
myrtifolia), a federally threatened plant species.
For your consideration, we would like to offer the following comments:
•
There are two federally listed plant species in the project are -. lone manzanita
and Irish hill buckwheat (Eriogonum apricum var. pros/ratum). [ffj~only place in
the world th-e-se species occur is a I6-mile strip of land tha~extends north and
outh of the town of lone. Our experience witlrOHV use has shown us that ta
protect rare plant orange mesh construction fencing strung along T-posts ill
preven most impa-cts from 0HV users. We were not successful in keeping OHVs
from impacting rare plants when we used stakes and flagging. These obstacles
were easily overlooked.
-
•
lone mazanita is currently under th-reat or-infection from a fungal disease called
PhY../opthora cinnam01ni. This is a soil fungus tha( causes root rot in lone
manzanita. The BLM's lone manzanita population in the lone Manzanita ACEC,
located approximately I mile north of the proposed race course, is partially
infected with this disease. Human activities can spread the Phytopthora to
uninfected stands. Especially when soil moisture is present, fungal spores will
easily spread to uninfected stands. Thi disease is a major toreal.to the con1i:n.u.ed
existence of lane manzanita We have instituted quarantine measures in our lone
Mazanita ACEC to prevent the spread of this disease. Through fencing, published
closures and signing, we have minimized human activities in the ACEC. In
addition, we have funded Ted Swiecki of Phytosphere Research since 2010 to
research this disease and expe11ment with potential treatment methods.
•
The unique soils of the lone Formation are extremely fragile and erosive. We
designated the lone Tertiary Oxisol Soils ACEC, located approximately one mile
southeast of Buena Vista, in 1986 to protect these sensitive soils. CalFire used
OHVs in another parcel of BUylland approximately 3.5 miles southeast of Buena
]sta for training purposes. It also contains the lone soil fonnation and was
designated an ACEC. Thel'IDlas were severely el'oded by OHV use due to the
fragility of the lone soi, s. This negatively impacted lone manzanita along the
roadway due to root exposure and soil run-off.
We appreciate the opportunity to share our knowledge and experience in managing these
federally listed plant species and fragile soils in the lone area. If you have questions or
would like more information, please call Beth Brenneman, Mother Lode Field Office
botanist, at (916) 941-3138.
Sincerely,
William Haig
Field Manager, Mother Lode Field Office
P H YTOSPHERE RESEARCH
RECEIVED
Amador County
October 4, 2012
Amador Co unty Planning Co mmi ss ion
County Admin istration Center
8 10 Co urt Street
Jackso n, CA 9564 2-2 '132
OCT - 5 201 2
PLANNING DEPARTMENT
Dear Plannin g Commi ss ion ers:
I am subm itt ing co mm ents on th e propo sed Negative Decl aration for the Cro ss County Promoti ons
LLC Use Perm it for th e lon e Hare Scrambles off road motorcycl e events.
Based on th e description of the project and the environmental documents prov ided by the appli cant,
it is clear that th e proj ect is likely to have signifi cant negative impacts on lone manzanita (federal
threatened species) loca ted on the project site. The impact is assoc iated with the hi gh probabi lity
th at Phytophthora cinnamomi, a lethal soi l-born e pathogen of lon e manza ni ta and many other pl ant
species, w ould be introdu ced and/or spread throughout the proj ect area by th e proposed proj ect.
Thi s impact was not con sid ered by the app licant's biologica l con sultant. Thi s is a signifi cant
omi ss ion, as th e root di sease cause by thi s pathogen has bee n identifi ed as on e of th e most
important threats to lon e manzanita. The impacts associated with thi s di sease wi ll not be addressed
by th e proposed miti gation s. As such, Section IV.A. of the Initial Study/N egative Declaration is
in accurate and shou ld show th at th e proj ect has a potentially signifi cant impact. Beca use thi s issue
ca nnot be found to be insignifi cant or miti gable through standard condition s, the Miti gated Negative
Declaration for thi s proj ect is not supported by facts.
I have bee n condu cting research into d iseases affecting lone manza nita since 2001. Signifi cant
disease prob lems had bee n noted as affecting thi s rare spec ies as least as earl y as 198 8. Through our
research, condu cted in co ll aboration with Dr. Barbar a Holzman of San Francisco State University
and later in coll aborati on with Dr. M atteo Garbelotto of th e University of Californi a, Berkeley, w e
id enti fied a pathogen th at th reatens th e presistence of lone manzanita. Th e introdu ced water mold
Phytophthora cinnamomi ca uses a severe and leth al root rot of lone manzanita in large portion s the
plant's natura l range in th e v icinity of lone.
Phytophthora cinn amomi has a very wid e host range, and affects a wide vari ety of agri cultural crops,
hort icultural pl ants, and an in creas in g number of Ca liforni a native pl ant co mmuniti es. The pathoge n
attacks and decays roots in th e so il. It ca n persist for many years even in the absence of host pl ants.
O ur studi es show that P. cinnamomi w as introduced in to lon e manza nita range from mu ltip le
sources and has spread from loca li zed infestati ons through off-road vehicl e and foot traffi c. In
Au stra li a, wh ere P. cinnamomi has infested and devastated several hundred thou sand hectares of
native forests, new infestation s are commonly associated with unpaved logging roads. Once
introdu ced into an area, th e pathogen can also move downhi ll with flow ing w ater during the w et
season.
O nce so il becomes infested with P. cinn am omi, it will no longer support th e development of lone
manza nita stand s or other susceptibl e hosts. Sin ce lon e manzan ita is limited to unusual so ils th at are
very limited in extent, protectin g ex isting stands from P. cinn amomi introdu cti on is the primary w ay
to maintain lone manzanita's dwindling habitat. Th e references li sted at the end of thi s letter
provide furth er inform ation about P. cinn amomi and its effects on lone manza nita.
Th e proposed proj ect represe nts one o f the worst poss ib le impacts to lone manzanita habitat. The
processes involved - grading of trai ls and roads; movement of potenti ally infested so i ls from many
loca tion s on vehicl e, shoes, etc. ; high levels of vehicl e and foot traffi c durin g race events - are
1027 DAVIS STREET, VACAVILLE, CA 95687-5495
URL: http://Phytosph ere.com
email: [email protected]
(707) 452-8735 voice/fax
10/05/12
Page 2 of 2
esse nti ally a recipe for ensurin g that this pathogen, and perhaps other damaging Phytophthora
spec ies, become introd uced and spread throughout the site.
The biological co nsu ltant appears to have been unaware of this impact. They are clearly not
qualifi ed to determine whether the pathogen might already occur on parts of the site. If this is the
case, the project would facilitate the rapid spread of the pathogen through the site and result in the
permanent destruction of the ex isting stand s over a period of years. If the pathogen is not now
present at the site, it is likely that it will be introduced by event participants and spectators,
especially given that many already infested areas are present in the areas around lone, including sites
used by off road vehicl es. Movement of infested so il is favored wh en soi ls are wet, either as the
result of water app li cation for dust abatement, or from spring rainfall.
Given the logistics of the eve nts and the overall topography and layo ut of the site, the proposed
mitigation measures will not prevent introduction and/or spread of this pathogen. It is hi gh ly
unlikely that suitab le mitigations cou ld be developed or enforced for events of the sort that are
proposed. Restricting vehicular and foot traffic into or near uninfested areas is the primary means for
preventing spread of this pathogen, which is the exact opposite of the proposed project.
I have on ly addressed the issue of this disease in my comments, but it is clear that other impacts to
both lon e manzanita and Iri sh Hill buckwheat are not adeq uately addressed by the proposed
mitigations. I respectfully recom mend that the Comm iss ion reject the proposed mitigated negative
declaration. The site proposed for this project is quite simply un su ited for this use due to its existing
biological resources that are threatened by the proposed activ iti es . The app li cant sho uld be
encouraged to find a more suitab le site.
Regards,
Tedmund J. Swiecki, Ph.D.
Principal/Plant Pathologist
References
Swiecki, T. J. and E. Bernhardt. 2003. Diseases threaten the survival of lone manzanita (Arctostaphylos
ll1yrtifolia) . Phytosphere Research, Vacaville, CA. Prepared for San Francisco State University.
http://phytosphere.com/publications/ionemanzdis.htm
Swiecki, T. J., E. A. Bernhardt, and M . Garbelotto. 2003. Fi rst report of root and crown rot caused by
Phytophthora cinnall10mi affecting native stands of Arctostaphylos myrtifolia and A. viscida in California. Plant
Disease 87:1395
Swiecki, T. J., E. Bernhardt, and M. Garbelotto. 2005. Distribution of Phytophthora cinnamoll1i within the range
of lone manzanita (Arctostaphylos ll1yrtifolia) . Phytosphere Research, Vacaville, CA. Prepared for Californ ia
Department of Fish and Game. http://phytosphere.com/publications/Pcinn_Amyrt_2 005.htm
Swiecki, T. J.; Bernhardt, E.; Garbelotto, M.; Fichtner, E. 2011. The exotic plant pathogen PhytophtllOra
cinnamom i: A major threat to rare Arctostaphylos and much more. pp. 367-371 . J. W. Willoughby, B. K. Orr,
K.A. Schierenbeck, and N. J. Jensen [eds.t Proceedings of the CNPS Conservation Conference: Strategies and
Solutions, 17-19 Jan 2009, Ca liforn ia Native Plant Society, Sacramento, CA.
http://phytosphere.com/publications/Pcinn_Arctostaphylos_C NPSConsConf2009.htm
PHYTOSPHERE RESEARCH
Planning Department Meeting, October 9
th
-
Heidi
For Golden Eagle Cam - Connie Murdock
www.beoutside.org
click on: Utube
Select first eagle video of 4-25
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Locatio~lMap
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The Cou:tty 01 Amador assurnot. no res~ ity arising
t-cm uso 0 ' thiS lnform.:Jtion. THE tI.APS AND
ASSOCiATED OATA ARE PROVlD::D WITHOUT
WARRANTY OF PJoN KINO. ItXOI'e$Sed or im.pHed.
ro udtng ~..I1 not limited la, h implied wourantiM of
nerchanlabil.ty and fitnas for a pertia.d5r purpos.e. Do
not m:lic.8 ;,ny bu'SintSs deCIsions oa::.d on tt'tis c2t3
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August 2, 2012
Page 8 of 201
Page 19 of
Adull T'D Orly (Hem)
- - VOOJ1h Trod< o.ly (0.21 m)
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FIGURE!
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PROPOSED DIRT BIKE TRACK
R:.\D~ Ar.royo Seco Project Site
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