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Issue: Bolinas Lagoon


Documents from Gordon Bennett, Conservation Co-Chair for Sierra Club Marin Group:
(Click any of the following to jump to the document)

Historical reference: "Dredging up Trouble 5 YEARS, 2 MONTHS, AND 3 WEEKS LATER:
March 9, 2001

“DREDGING UP TROUBLE?”

5 YEARS, 2 MONTHS, AND 3 WEEKS LATER: 3/9/01

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Dredging Up Trouble? SF Chronicle 12/7/95 (edited)
West Marin residents agree that Bolinas Lagoon must be saved from silt that threatens to destroy it. What they can't agree on is how…
Bolinas Lagoon -- one of the California coast's most stunning sanctuaries for shorebirds, fish and harbor seals -- has been gradually filling up with silt.With studies showing that the lagoon has lost about a quarter of the water it held two decades ago, the debate over how to preserve the lagoon has intensified. 
The struggle focuses on whether the estuary should be dredged to increase the tidal flows vital to the area's wildlife or whether less intrusive measures -- such as removal of illegal dumps or preventative erosion control -- should be tried first. In some quarters, dredging --

“the D word'' -- is viewed as an over-zealous disruption of the lagoon's fragile ecological system. 

There are many options to repair the lagoon,” said Ed Ueber, manager of the Gulf of Farallones National Marine Sanctuary. “Probably the most invasive option is dredging, and it is probably the last option I would pick. Several years ago, many people considered dredging a quick way to resolve the problem, but since then a lot of people have come to realize dredging causes problems of its own. Large-scale dredging would remove the lagoon's top layer of mud, which is the primary food- producing source for birds and fish in the lagoon. So we need a better grasp of what all the options, including dredging, would do ecologically before we could go ahead.”

Experts generally agree that the sediment has built up in part because of runoff from Pine Gulch Creek and from past logging, development and illegal dumping, but they say more study is needed before any plan can be devised.

Though Seadrift dwellers deny it, some critics are worried that the development's residents will push a dredging quick- fix because they fear their property values will plummet if the lagoon dries up.The Save the Bolinas Lagoon Committee, which includes some Seadrift dwellers, believes…that dredging is likely to be part of the solution. That assertion is worrisome to some. 
There seems to be some effort to view the project in terms of its engineering challenge -- in other words, can engineers figure out ways to dredge out large parts of the lagoon -- when in fact the problem is a lot more complex than that,” said Jack Siedman, a lawyer and a director of the Bolinas Community Public Utility District. 

This is about grappling with reversing the silting process,” he said, “while at the same time not adversely affecting the natural habitat and wildlife.” Siedman's concern is one shared by many in the community where he lives. 

John Jones, a Seadrift resident who is chairman of the Save the Bolinas Lagoon Committee, said the committee isn't “plugging for dredging. All we want is a biological, hydrological study that will tellwhat can and should be done.” 

Jones also acknowledged that there is little doubt that the Seadrift development contributed to the lagoon's silting build-up. “I do think it (the development) had a deleterious effect on the life of the lagoon. There was not the ecological concern then that there is today.” 

He added, “The Sierra Club...didn't have the power it does now.”


 
Today abundant ecological concern has generated friction over how severe the lagoon's problem is and what to do about it.The Committee to Save Bolinas Lagoon published a brochure that includes the pronouncement: By 2008, we think the lagoon will only be a meadow.” Jones said in retrospect it was unfortunate to specify a date when the lagoon might turn into a meadow, but he added: “We haven't been trying to scare people. Most people who live out here don't need to read a pamphlet to become alarmed.” 
The pamphlet’s contents didn't sit well with some activists concerned about a thoughtful approach to the lagoon's silt problems.The Bolinas Lagoon Technical Advisory Committee, said member Ron Miska “had a lot of problems with that brochure. They were putting out this brochure that was very alarmist, suggesting something drastic needs to be done as soon as possible.”
Skip Schwartz, director of the Audubon Canyon Ranch and a member of the technical advisory committee for the past 20 years, said: “I have to tell you there are a lot of people with strong opinions. One extreme is the people who think it's a foregone conclusion that the lagoon should be dredged, and on the other extreme, you have people who feel the lagoon should never be tampered with. 
“For this reason, because we have opinions but we lack the studies on which to base recommendations, it is really important to try and do a very good study of the lagoon.” 

“I have respect for the scientific method which requires that facts dictate conclusions, and we don't yet have the information needed to decide whether remedial action is possible or desirable.”

Susan Sward, Chronicle Staff Writer




5 YEARS, 2 MONTHS, AND 3 WEEKS LATER,
THE SIERRA CLUB CONTINUES TO BE CONCERNED THAT
Studies propose "a date when the lagoon might turn into a meadow,"
which suggests "something drastic needs to be done as soon as possible."  And while there remain "many options to repair the lagoon,"
ONLY DREDGING ALTERNATIVES EXIST!

5 YEARS, 2 MONTHS, AND 3 WEEKS LATER,
THE SIERRA CLUB CONTINUES TO INSIST THAT:
It remains "really important to try and do a very good study of the lagoon," yet
we still "lack the studies on which to base recommendations" and
we still "need a better grasp of...ALL the options, including dredging"
we still believe "preventative erosion control should be tried first"

BOLINAS LAGOON NEEDS
MORE THAN QUICK-FIX DREDGING!
THE WATERSHED MUST BE RESTORED!
THE PROJECT NEEDS A WATERSHED COUNCIL!
SAVE BOLINAS LAGOON!

contact: sierraclubmarin9@aol.com
info: www.sierraclub.org/chapters/sanfranciscobay/marin/issues.htm



Letter to Bolinas Lagoon Technical Advisory Committee on February 22, 2001 (1 of 2)

Bolinas Lagoon Watershed Working Group
c/o Gordon Bennett

February 22, 2001

Bolinas Lagoon Technical Advisory Committee (BLTAC)
c/o Ron Miska,
MCOSD, 3501 Civic Center Drive, San Rafael, CA

Dear Ron:

Thank you for your written response to our letter of November 22, 2000, which covered three concerns: the applicability of the Brown Act, the incorporation of Adaptive Management Principals, and the broadening of the Bolinas Lagoon Technical Advisory Committee (BLTAC) to include advocacy groups.

Brown Act: We disagree with County Counsel's position that the Habitat Evaluation Expert Panel (HEEP) is not subject to the Brown Act.  As the Bylaws of the BLTAC indicate, the BLTAC itself is subject to the Brown Act, therefore, the HEEP, which is advisory to BLTAC and which consists of a quorum of the BLTAC must also be subject to the Brown Act.  We do agree that subsequent to August 24, HEEP meetings did take place in public and with proper public notice.  The Sierra Club further agrees "that it is in the project's best interests to have the Panel's deliberations as open as possible" and we trust that future BLTAC and HEEP meetings will be conducted in accordance with this statement.

Adaptive Management Principals: We agree with your statement that "thorough consideration [should] be given to adaptive management as it applies to the restoration of the Lagoon [but] the project simply isn't that far along."   One of our jobs as an environmental advocacy organization is to make sure that certain concerns appear on the radar screen, even before they might become immediate.  Adaptive management appears to be the only way to help insure that such an immensely complicated project as the Lagoon Restoration does not result in unintended and destructive consequences.  The Sierra Club will continue to advocate for the maximum project flexibility and the increased monitoring necessary for the adaptive management "insurance policy" to work.

Environmental Representative:  We disagree with your statement that "BLTAC is not an advocacy body but a technical advisory committee", and that "there is already broad stakeholder representation on the BLTAC".  While it is true that a majority of BLTAC members are scientists, BLTAC also includes non-scientists who represent local communities.   Clearly their job is not to provide technical advice, but rather to advocate for the benefit of their local constituents.   The Sierra Club supports such advocacy, however all interested constituencies should be offered the same opportunity.   The Sierra Club represents the interests of over 7,000 Marin County residents, which is more than the number of community residents in the Bolinas Lagoon watershed.   We agree that a Bolinas Lagoon Watershed Council is "worthy of further consideration," however, the time for that consideration is not, as has been suggested "around the time that restoration efforts begin", but rather it is now, as the planning process is on-going.

The limitations of the current BLTAC structure may be becoming increasingly apparent in the progress of the Bolinas Lagoon Restoration Plan.  BLTAC's purview extends only to the Lagoon's edges and the Corps of Engineer's experience is primarily in dredging.  Consequently, perhaps, the entire discussion about Bolinas Lagoon Restoration alternatives has revolved around various Lagoon dredging alternatives.  It appears increasingly likely that Restoration alternatives will be selected without any of the key information from the Watershed Study.  A properly designed Watershed Study could generate watershed alternatives that would increase natural scouring of the Lagoon with less reliance on dredging, as our accompanying letter describes.   Limiting the Restoration planning only to dredging alternatives not only increases the environmental risk of the project, but also increases the risk of a successful CEQA/NEPA challenge.

As previously noted, the Clean Water Action Plan's Unified Federal Policy, to which the Army Corps of Engineers subscribes states: "We will expand opportunities for participation by interested stakeholders. We will seek participation by interested stakeholders in watershed planning and management decisions using available mechanisms in existing planning processes. We will: a) Identify specific opportunities for review and comment by interested stakeholders during Federal land and watershed planning efforts; b) Provide opportunities for interested stakeholders to participate in monitoring and assessing watershed conditions and in implementing watershed restoration projects; and c) Seek early feedback on key decisions affecting watershed management and carefully consider this feedback in agency decision-making.

Additionally, Marin County is an active participant in the FishNet4C project.   "The Goals for County Polices and Planning that emerged from Recommendations in the FishNet 4C Study" conclude that "counties should support and be active members of multi-stakeholder groups working on watershed issues.  With several community advocates already on BLTAC and substantial Restoration planning already underway, it would appear most expedient and most efficient simply to expand BLTAC's membership and focus, rather than creating an entirely new group.  Given that increased stakeholder participation is a desired outcome, the Sierra Club would welcome further discussions as to how most expeditiously this can be accomplished.
 

Sincerely,

Gordon Bennett, Conservation Co-Chair



Letter to Bolinas Lagoon Technical Advisory Committee on February 22, 2001 (2 of 2)

Bolinas Lagoon Watershed Working Group
c/o Gordon Bennett

February 22, 2001

Bolinas Lagoon Technical Advisory Committee (BLTAC)
c/o Ron Miska,
MCOSD, 3501 Civic Center Drive, San Rafael, CA

Dear Ron:

The Sierra Club is concerned that the Bolinas Lagoon Restoration Plan presently contains only dredging alternatives and no watershed restoration alternatives.  We are concerned that Restoration alternatives are being selected without any of the key information from the much-delayed Watershed Study.  A properly designed Watershed Study could generate watershed alternatives that would increase natural scouring of the Lagoon with less reliance on dredging.   Limiting Restoration planning only to dredging alternatives not only increases the environmental risk of the project, but also increases the risk of a successful CEQA/NEPA challenge.

We believe that the process of the watershed eroding sediment into the Lagoon with its reduced tidal prism should be viewed as a large faucet running water into a bathtub with a small open drain.  The current Restoration Plan suggests that since the water (sediment) is filling up the bathtub (Lagoon), faster than the drain (scouring from tides and floods) can empty it, then the solution is to bail out the tub (dredge the Lagoon).  The Sierra Club agrees that Bolinas Lagoon should be restored, however, the appropriate solution is to adjust the faucet, not bail the tub, or in other words to control sediment in the watershed, not simply to dredge it from the Lagoon.   Please be advised that we are working with Dr. Eugene Kojan, an engineering geologist who was extensively involved in the work to stop the infamous Bolinas Harbor District's 1960 Bolinas Lagoon Master Plan, which the current Bolinas Lagoon Restoration Plan is unfortunately coming to resemble.  With the assistance of Dr. Kojan, we offer specific criticisms of the current Project and also specific recommendations that we believe must be included if the project is to go forward with the support of and absent challenge from the environmental community.

The USACE rational for the Bolinas Lagoon Restoration Project is that the mouth of the Lagoon is in danger of closing, which allegedly would turn the Lagoon into a meadow and diminish its biological and recreational value.  The problem is defined as an unnatural pulse of sediment from logging and overgrazing that has relatively recently upset the natural flushing and periodic seismic settlement.  The proposed solution to enhance the probability that the mouth would stay open is to dredge the Lagoon, whose increased tidal prism will widen the mouth.  A wider mouth is less susceptible to closure from rainless storm events that bring in sediment from the ocean side without creating the offsetting flood flow to flush it out.
The Sierra Club believes, however, that the modeling methods used by the USACE for the inlet closure analysis overstate the possibility that the mouth of the Lagoon will close.   The watershed, after all, will continue to collect roughly the same amount of rainfall and an open mouth is the most energy efficient method of discharge.  We also believe that the lagoon interpretive model, based on a relatively small number of core samples, ignores the cut-and-fill dynamics present in all lagoons.  Therefore the model over-states the long-term response of the lagoon to past, localized impacts, such as the severe logging abuse of 1969, while it under-states the response to the current, widespread and cumulative impacts from grazing, vegetation conversion, and the construction of impervious surfaces (buildings and roads).  These significant new sources of erosion are caused by the adverse hydrologic effects created by the cumulative and on-going impact of development within the watershed.

The great preponderances of erosion volumes are delivered to watershed stream channels during exceptional storm events (the so-called "100" to "1000" year storms that actually seem to recur every 5 to 20 years).  Major erosion sources are site specific, limited in area and recurrent. Landslides, for example, once triggered, are typically reactivated and remain major sources of stream sediment in subsequent major storms, often decades or more following the initial failure.  In northern California, typically more than 90% of all erosion volume sources are site specific and associated with long period ("100" to "1000" year flood or seismic events) whose thirty years of USACE data could not capture.  As the 6/10/99 Bolinas Lagoon Ecosystem Restoration Findings document remarks: there is "limited information due to the relatively short period of available data ('68 to '98 for predicting 50+ years)."

Even giving credence to this limited information, which predicts that current sedimentation rates are approaching "normal", the same Findings document concludes that "between 1988 and 1998 the sedimentation rate was .26 million ft³/yr above the estimated normal infilling rate."  That is still a long way from "normal." Given the current, widespread and cumulative impacts from development in the watershed, the Sierra Club believes that the current sedimentation rate will not return to "normal" without extensive upland sediment control work.  The USACE correctly concludes that simply dredging the Lagoon's mouth will not keep it from reverting to its previous condition as determined by the Lagoon.  But likewise simply dredging the Lagoon will not keep it from reverting to its previous condition as determined by its watershed.  Human activities have in the past and continue to severely exacerbate the response of the watershed to exceptional storm events.

The watershed is already formed of highly erodable natural soils and prior logging and overgrazing have created huge additional volumes of unstable soils.  Even more unstable soil has been created by the replacement of native coastal scrub with lawns, crops, forage, homes, roads and culverts.   These current land uses also convert natural runoff patterns into focused discharges that increase both the intensity and the frequency of flood peaks.  The floodplains that should trap this sediment are now "protected" by levees that channel the sediment directly into the Lagoon to create displaced floodplain deltas.  Yet even these displaced floodplains are not allowed to do their sediment-trapping job. The Pine Gulch Creek "overflow path" cleared by the Open Space District facilitates transport of sediment directly into the Lagoon rather than allowing the Creek to overflow and impact private property by dropping its sediment on its former floodplains. "Saving" Bolinas Lagoon by dredging of the existing Pine Gulch Creek delta is particularly ill-conceived and will simply create a head-cut that will soon re-create the delta.  Meanwhile a generation of endangered black rails will have been lost.  All of these on-going land use practices continue to fill Bolinas Lagoon with sediment.  And while multi-million dollar dredging alternatives are discussed, the designated sediment traps and the sediment-filled culverts continue to go un-emptied, choking the Lagoon with an estimated 260,000 cubic yards of excess sediment every year.

It is not clear from the Tetra Tech public presentation of March 3, 2000 that the parameters of the current watershed study are adequate.  The Sierra Club believes that this watershed study has likely been under-funded and is likely too limited in scope.  Without doubt, whatever information will come from the existing study will come too late to have a meaningful role if the current focus on dredging alternatives continues.   The Sierra Club believes that the discussion of alternatives should not go forward without careful review of the existing watershed study and consideration that extensive additional analysis would likely be required.

Specifically, Dr. Kojan suggests creating a watershed map of all debris slides, rotating slides and earthflows greater than ten feet square.  This would be done at random points within 300 feet of any stream.   Non-timbered areas could be surveyed by comparing existing stereo air photos of 1940 to those of 1996, the most current.   Timbered areas would require site visits by a team composed of a geologist, a hydrologist and a geomorphologist.  Such a team might require 2-3 months to complete the maps required in order to appropriately position site-specific erosion control structures in the watershed.   Erosion control structures would include fences in streamside grazed areas set at 1.5 times the distance from the stream's center point to its alp (the point at which the streamside slope changes).  On former logging roads, skid trails, and landings, water bars would be placed at every 10 feet of grade change, with perforated pipe running down to the stream channel.   In severe erosion sites where landslides toe out into stream channels or where streams are head cutting, gabions would be installed, either 3 feet below grade in salmonid habitat, or above and below in non-salmonid habitat.  Furthermore, Project funding should be made available to purchase flood easements and enable property owners in floodplains to move or elevate structures in order to restore more of the naturally functioning floodplain.  While these site-specific remedies are applied to correct past problems, both Marin County and the National Park should be aggressive in preventing future problems by defending streamside conservation setbacks.  Lastly, the Sierra Club shares the frustration within BLTAC at the seeming unwillingness of Cal-Trans to permit and/or execute simple and cost effective culvert and sediment trap clean-outs.

In summary, watershed restoration could permit the level of sediment in-flow to the Lagoon to be reduced below the level of sediment out-flow caused by natural scouring, so that tides and floods would do much of the "dredging", not the Corps of Engineers.   This natural scouring could be a more habitat-friendly method of insuring that Bolinas Lagoon would not choke up from excess sediment.  However, these potential benefits cannot be realized without a meaningful watershed study.  Dr. Kojan estimates the total cost for such a meaningful survey and the resulting remedial stabilization work to be about $3 Million, as compared to the $100,000 currently allocated to the watershed study plus untold millions more for dredging.
The Sierra Club recognizes that watershed restoration is itself complex and that it may be difficult to achieve full control of all sediment sources.  Furthermore, modeling of watershed restoration impacts may be more complicated and outcomes and timings more difficult to predict.  Nevertheless, for BLTAC to continue to narrow its focus to dredging only alternatives and continue to permit further delay in meaningful watershed data could be a serious mistake. The Sierra Club requests that BLTAC include on the agenda for its next meeting, the opportunity for Dr. Kojan to make a presentation on the geology of the watershed and the potential benefits of watershed restoration on Bolinas Lagoon.

The Sierra Club does recognize that limited dredging may provide stopgap insurance against Lagoon mouth closure while the longer-term watershed work takes effect.  However, we believe that any such dredging must be focused when and where it least harms wildlife.  The upper two feet of sediment contain invertebrates that form the base of the food chain supporting birds, fish and seals.  Current wide-scale dredging proposals could destroy this base and possibly facilitate re-colonization of the exposed sediment by exotic species. The Sierra Club would not oppose tightly focused and limited dredging, such as to the Bolinas wharves, if it were part of a meaningful watershed restoration plan.   Dredging a narrow, deep channel to the Bolinas wharves would slightly increase the tidal prism, would remove sediments that may contain unwanted residues and would more insulate Kent Island wildlife from easy human access.

The Sierra Club believes that Bolinas Lagoon has always been a shallow muddy lagoon. These vast inter-tidal mudflats are amongst the most biologically rich in the world, as recognized by the Lagoon's designation by the United Nations as a RAMSAR site of international significance.  This habitat should not be put at risk by ill-conceived and wide-scale dredging projects.  The Pacific Coast Pilots, official U.S. Government navigational guides, have long described Bolinas Lagoon as:

"except for small crooked channels...bare at low tides and filled with small islets [with] an entrance of but one hundred yards wide. (1869)"
"The entrance to Bolinas Lagoon is...a very contracted channel having only one foot upon its bar at low water [and] ten feet of water at highest tide(1889)"
The current conditions are not materially different from those 130 years ago and we believe the Lagoon is not in immanent risk from anything other than wide-scale dredging.  Dredging, whether done within biologically appropriate timeframes, or done using adaptive management principals, or done avoiding endangered species habitat, should not be the sole focus of the Bolinas Lagoon Plan.  Dredging is not a long-term solution to the sediment problem and it carries high short-term risks for the habitat.  Watershed restoration alternatives must be brought forward to balance and perhaps substantially replace dredging alternatives in Bolinas Lagoon Restoration Plan.   Please be advised that just as the Sierra Club is working vigorously to promote watershed restoration to help save Bolinas Lagoon in the long term, we will just as vigorously oppose wide-scale dredging projects that could harm the Lagoon in the short term.  We hope our comments and Dr. Kojan's offer of a presentation are helpful to the Project.

Sincerely,

Gordon Bennett, Conservation Co-Chair



Letter to Bolinas Lagoon Technical Advisory Committee on November 15, 2000

Bolinas Lagoon Watershed Working Group
c/o Gordon Bennett

November 15, 2000

Bolinas Lagoon Technical Advisory Committee (BLTAC)
c/o Ron Miska,
MCOSD, 3501 Civic Center Drive, San Rafael, CA

Dear Ron:

The Sierra Club and its 7000 Marin County members wishes to bring to the attention of the BLTAC three urgent concerns.

The recently adopted Clean Water Action Plan (www.cleanwater.gov/ufp/), summary states: "The Departments of Agriculture, Commerce, Defense, Energy and the Interior, the Environmental Protection Agency, the Tennessee Valley Authority, and the Army Corps of Engineers are adopting a unified Federal policy on watershed management. This policy, which provides a framework for a watershed approach to Federal land and resource management activities, is one of the action items in the President's Clean Water Action Plan: Restoring and Protecting America's Waters.  This Unified Federal Policy further states: "We will incorporate adaptive management principles into our programs....Adaptive Management: A type of natural resource management in which decisions are made as part of an ongoing science-based process. Adaptive management involves testing, monitoring, and evaluating applied strategies, and incorporating new knowledge into management approaches that are based on scientific findings and the needs of society. Results are used to modify management policy, strategies, and practices.  Since two of the federal agencies that have adopted the Clean Water Action Plan are represented on BLTAC and the Bolinas Lagoon Restoration Plan is a federal "resource management activity" undertaken by the Army Corps of Engineers, who has also adopted the Clean Water Action Plan, the Sierra Club therefore requests that BLTAC place on its agenda for immediate action the following motion:

BLTAC shall incorporate Adaptive Management Principals into the Bolinas Lagoon Restoration Plan.

This Unified Federal Policy further states: "We will expand opportunities for participation by interested stakeholders. We will seek participation by interested stakeholders in watershed planning and management decisions using available mechanisms in existing planning processes. We will: a) Identify specific opportunities for review and comment by interested stakeholders during Federal land and watershed planning efforts; b) Provide opportunities for interested stakeholders to participate in monitoring and assessing watershed conditions and in implementing watershed restoration projects; and c) Seek early feedback on key decisions affecting watershed management and carefully consider this feedback in agency decision-making.  We will expand opportunities for dialogue with private landowners. In priority watersheds with a mix of Federal and private lands, we will work with private sector landholders to involve them in the watershed management process. We will work closely to help ensure that Federally funded projects involving private cost-share partners fully consider watershed management objectives for both public and private lands.  Therefore the Sierra Club requests that BLTAC place on its agenda for immediate action the following motion:

BLTAC shall add to its membership representatives from stakeholders representing agricultural and environmental interests.

Lastly, the Brown Act in California prevents private meetings amongst a quorum of any public entity, which the Sierra Club believes includes the BLTAC and many other groups advisory to Marin County.  The Brown Act also prohibits a quorum from engaging in a serial meeting, which the Sierra Club believes includes email and telephone discussions.  At the fall BLTAC meeting, the HEP meetings were stated to be public meetings as a result of the HEP being composed of a majority of the BLTAC member agencies.  However, after that first HEP meeting, which was public, it appears that subsequent HEP deliberations were conducted through emails, phone calls, and letters.  The Sierra Club believes that these non-public HEP deliberations may be a violation of the Brown Act.  The public has a right to hear the entire deliberations, not just the final decisions, of an official advisory body such as BLTAC.  These deliberations are public as matter of California Law in order that citizens have a meaningful way to participate in the regulatory and governing matters that affect it.  The certain instance, the HEP deliberations are critical to understanding any decisions affecting the final form of the Bolinas Lagoon Restoration Plan and the Sierra Club is concerned that the alternatives for the proposed Bolinas Lagoon Restoration Plan may have been subject to internal pressures that could only occur outside the realm of public scrutiny, making mockery of any subsequent public hearings.  This possible violation of the Brown Act could be substantially mitigated by making public all the emails, letters and phone conversations substantially prior to any putative public hearing.   Therefore the Sierra Club requests that the BLTAC place on its agenda for immediate action the following motion:

BLTAC shall make public at least 30 days prior to any public hearing on the Bolinas Lagoon Restoration Plan all the relevant emails, letters and phone conversations relevant to BLTAC's recommendation of the alternatives to be modeled for the USACE Bolinas Lagoon Restoration Plan.

In summary, the Sierra Club supports the widest possible consideration of Bolinas Lagoon Restoration alternatives, the widest possible disclosure of matters important to the public, and the widest possible inclusion of stakeholder groups in the decision making process.  The Sierra Club and its 7000 members look forward to BLTAC's adherence to federal policy and California Law.  If BLTAC determines to act otherwise than as requested by the Sierra Club, then the Sierra Club requests a written, specific response to each of the three Club requests.

Sincerely,
 

Gordon Bennett, Conservation Committee Co-Chair



Letter to US Army Corps of Engineers and Bolinas Lagoon Technical Advisory Committee on May 24, 2000

Gordon Bennett BLTAC Representative

May 24, 2000

Roderick A.Chisolm III,
US Army Corps of Engineers
333 Market Street, SF, CA 94105-2197

Chief, Planning Ron Miska, BLTAC Representative
Marin County Open Space District
3501 Civic Center Dr, San Rafael,  CA  94913

Gentlemen:

The Sierra Club has received a copy of the 4/10/00 letter from USACE to MCOSD outlining the next steps in the Bolinas Lagoon Restoration Project.   This letter notes that the "habitat evaluation expert panel" will be given "general information on five combinations (of the six dredging Alternatives) that will be analyzed in (the) hydraulic model."    According to our calculations, there are over 60 possible combinations of the six Alternatives.   Budget constraints may weigh against modeling all possible combinations, but the USACE has made a pre-judgment and ruled out 90%.

The Sierra Club requests that these budget constraints on modeling be made public.  We request that USACE work cooperatively with the habitat evaluation expert panel to mutually decide which of the subsequently budgeted combinations to move forward to the hydraulic modeling stage.  We request that information supporting all decisions be made public and that the decision-making process itself be made public.

We also understand that the Seadrift Lagoon Alternative has generated concerns about private benefit derived from public funding and about the possible lack of public access to a publicly funded restoration site.  Although we have not fully investigated the merits of these concerns, we note that none of the other Alternatives have any such possibly problematic aspects.

The Sierra Club requests that the private benefit and public access concerns be considered as factors in the decision on whether any combination including the Seadrift Lagoon Alternative should move forward to the hydraulic modeling stage.

As previously stated, we believe that the Bolinas Lagoon Restoration should be adaptively managed, by which we mean that monitoring of the Project should be on going, the Project should be phased to allow time to incorporate monitoring data, and both the baseline model and subsequent implementation phases should be adjusted or eliminated based on the monitoring data.

The Sierra Club requests that the Bolinas Lagoon Restoration Project be confirmed as a project that will be implemented using the techniques of adaptive management.

We request that this letter and all prior Sierra Club letters be included in the documents for the scoping process for the Bolinas Lagoon Restoration Project.

Sincerely,
 

Gordon Bennett, Conservation Co-Chair
 



Letter to Point Reyes Light on March 29, 2000

Gordon Bennett BLTAC Representative

March 29, 2000

Editor, Point Reyes Light

Re the 3/23 letters on Bolinas Lagoon Pullouts.

As the Sierra Club's representative to the Bolinas Lagoon Technical Advisory Committee, I have been following the proposal to remove highway pullouts from Bolinas Lagoon, and have visited all of them.  I want to assure Light readers that none of the paved Cal-Trans slow-traffic pullouts or paved bus stops are proposed for removal.  Of the two-dozen unofficial pullouts under consideration, about half are too small, too narrow, or too dangerously sited for anyone, disabled or not, to use safely.  Several different groups, including the Sierra Club have spoken up for the need for continued public access to the Lagoon, but the removal of these unsafe sites will have a very minor, if not benign, impact on access.

Of the dozen safe sites, about half are suggested for no action at all, and half for a restoration that includes safe pullout parking.  The answer to the prior writer's question "what bird would nest that close to a busy road?" is a very desperate bird.  Bolinas Lagoon is home to about 20 black rails, about 10% of the world's population.  These endangered species nest in the only available suitable spots, which sometimes happen to be adjacent to the road.  Careful restoration of certain pullouts could expand habitat, yet still retain safe parking for wildlife viewing, fishing and other Lagoon activities.

The same writer notes correctly that "filling in of a lagoon is a natural occurrence" but Bolinas Lagoon is unusual in that the natural rate of filling has been almost perfectly balanced for 10,000 years by periodic earthquakes that drop the floor of the Lagoon by an amount equal to the sediment deposited. Army Corps of Engineer studies have, in my opinion, fairly conclusively shown that unsustainable logging and grazing practices of the past 100 years are the sources of an excess sediment load that threatens to upset the natural balance that has kept Bolinas Lagoon open.  The removal of unsafe pullouts that serve no useful purposes and the restoration of other pullouts to serve very useful purposes could play a role in increasing the tidal flows that can help flush out this excess sediment.  Assuming current upland practices are no longer contributing to excess sedimentation, then proposals sensitive to both the environment and public access that help remove the excess sediment of the past 100 years will help restore the natural balance of the Lagoon for the next 10,000 years.

Gordon Bennett, Conservation Co-Chair