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3/9/2005 - STAFF REPORTS (7)
Coachella Valley MSHCP Loss of Highway Improvements March 9, 2005 110, Z Funding to Acquire Private Land for Habitat Conservation State and Federal Local 44% 56% (Source: Draft Coachella Valley MSHCP, October 2004, Section 5.1 .1 ) Funding to Acquire Private Land for Habitat Conservation State and Federal 44% W Local No Funding Allocated 56% (Source: Draft Coachella Valley MSHCP, October 2004, Sections 5.1 .1 and 5.2,4) Comparison of Land Values Market Study MSHCP High Value Fair Market Location Conservation Area Per Acre Value Per Acre North of 1-10 Thousand Palms $30,000 $60,000 No. Cathedral City Willow Hole $4,500 $10,000 Desert Hot Springs Mission Creek / Morongo Wash $2,000 $30,000 North of Indio East Indio Hills $1 ,500 $17,500 Northern Coachella Desert Tortoise and Linkage $1 ,000 $12,500 West of Hwy, 86 Santa Rosa & San Jacinto Mtns $2,500 $7,500 North of Salton Sea CV Stormwater Channel & Delta $500 $10,000 MSHCP Market Study High Value Percent of Fair Market Value: 32% (Source: Draft Coachella Valley MSHCP, October 2004, Appendix I, Table A5-1 ) Projected Acquisition Costs for Land Within Conservation Areas CVAG Estimate Fair Market Value Total 2003 Acquisition Cost $138,351 ,200 $438,791 ,900 Total 30-Year Acquisition Cost — using 3% annual increase in land value $227 million Total 30-Year Acquisition Cost — using 30% annual increase in land value first 5 years; 3% annually thereafter) $2.8 billion (Source: Draft Coachella Valley MSHCP, October 2004, Section 5.1 .2.1 , Table 5-3c, and Appendix I, Table A5-1) Conservation Quota ■ Cities are obligated to acquire 100,600 acres of private land for conservation within 30 years. ■ "Over the 30-year acquisition period , the following schedule shall be used to determine if additional Conservation is needed to keep Development and Conservation in rough proportionality." (Source: Draft Coachella Valley MSHCP, October 2004, Section 5.2.2.3) Rough Proportionality/ Conservation Quota Year Test for Rough Proportionality — Percent of Conservation Quota Conservation Obligation Conserved Acres 5 17% 17, 100 10 33% 33,200 15 50% 50,300 20 67% 671400 25 83% 83,500 30 100% 100,600 (Source: Draft Coachella Valley MSHCP, October 2004, Section 5.2.2.3) New Federal Oversight ■ "The Local Permitees must also comply with all other terms and conditions of the MSHCP . . . including , but not limited to: Ensure that habitat preservation is occurring in rough proportionality with Development." ■ "If the Local Permitees do not maintain `rough proportionality' between Development and Conservation . . .the Wildlife Agencies may initiate revocation or suspension of all or part of the Permits." (Source: Draft Coachella Valley MSHCP, October 2004, Sections 6.6. 1 , 6.7, and 7.2.3) Loss of Highway Improvements Insufficient Insufficient Loss of Permits Funding = Land = for Highway Acquisitions Improvements Highway Congestion I Levels of Service Lfovu.t uar v.'° o is ate- n. q ?yr� ry M'�I q w (f.E� '�4W.86aQpsilB ��i �.��0.19 �� Lf 6 Q72 a :SzI ¢2°6s5'afi Cs � "a7 •eQ6'.7�0, a E1 O.iB a35016 asy u� 'u�;�a�gx• e o6s o.;s � � IM `oSA� �t�o '��Tq@ ���� a M.11 a1•a, 11]l a• 22 R4O g Fa n.11 FI F74 \ I Palms — 'q _. y0.33 Cr. 3? faz w w y. ar ^ 8-7 m ": 069 reu NAP � � '•�'.FP �......._�... ..—..... � rah _ S � ixJ14���q' �ic Cathedral Cl ^ '7pl, ry LEVEL®'F SEkVffE LDS' B j r` rY 1 G� � w i god — LEVEL OF SERVICE LEVEL OF SERVICE LOS C o in @ 9 nRy v s I " y^ yL LOS p xzx E LOS E -- - exert � rus— yea.... LEVEL OF SERVICE (LOS) F u i ats �.tc Ch Ila 7 L^'"ro.s NlN a 7� Laprxinla�7� (Source: Summary of the Transportation Analysis for the Circulation Element of the Proposed Riverside County General Plan, April 2002) Level of Service - D i :. ,kz " A Level of Service -- E Level of Service - F Oki 2 who! Immm Coachella Valley MSHCP Loss of Highway Improvements March 9, 2005 Funding to Acquire Private Land for Habitat Conservation State and Federal Local 0.4% 56 IS.Ur�.or.ft cao�h�u,Veuev MSHCP OWN,aon4 scennn 511) Funding to Acquire Private Land for Habitat Conservation State and Federal 44%- Local No Funding 56% Allpn:ad (s.vn Onh Oushdla Vnlley MSHCP OC100,20114 S.ct.n:51 1 and 5 2 4) r Comparison of Land Values Market Sillily MSHCP Higb Value Fair Markel Luc.dimi Cm,atrveliai,Arta Poi Aert V.dno Per Aere North of 1-10 111nu6Antl Palme 530 coo SC coo No 21lh1dr1l C,ry Wdluw here $4 Lilo Sig OCO Oeud hlol5pnng. M,..on CruX/M...r,Wash S2000 S30000 Not I Aludla Earl li dlla Hdle 51500 517500 Nimhorn roechella Desert lotloleo and Linkage 51 CCU 512500 Wn•t of l lwy to Sale,F iA Saif-I lnto Min, $),500 1 $7,500 North of Salton Ste CV Sorri Ch,mol A reeds S5000 1 510000 MqH CP M,rkri;I,my Hyll vnli In Vrrcm ;nt Fnir Mrrkrl Value +PS fSeLre, Drall Coachella Valley MSHCP Oclobor 2004 Appendix Table A51) Projected Acquisition Costs for Land Within Conservation Areas CVAG Psi Fal r Markat Value Total 2110 A,nplaOian Coat 5135351 Zoo 5438701900 Teal 3 en-Aoqulsldin Coat-ucmg Pr annual mono,In led viper 5227 million Total 30 Year Acqul•Wn C•st-using 30a.annual thamIn land value Yat 5 year.3"e annwlly ..agor) 529 billion (50lIRe Dart COMIIP1a valley MSHOP 0012004 Seobcn 5 12 1 Table 5-3c and Append,l T,bla A5.1) Conservation Quota • Cities are obligated to acquire 100 600 acres of private land for ccnservanon Within 30 years • Over the 30-year aCgUIS111011 period Site following schedule shall be used to determine if additional Conservation IS needed to keep Development and Conservation in rough proportionality (SOW LC 0,afl COdChi-I1a Valli MSHCP CClablr 2004 5ae,om 32 ):0 Rough Proportionality/ Conservation Quota Year Teri for Bo unh Proportio wht,-Pircem or Cnneuvatlon Otlma collson'lflon Oi'lhfil110n Corson,c� _ ArYOP_______ 1 71A 10 23%._. _._. ...__..___ 33200 15i .... .__._50%_____.___. D5 __B3^.__.. I .._..._.-83500 .— '40-- --- 1oou 100,300 ($mPrP pl nn CmchPlln Valley Mi Ocobnr A04 Seeoon 522 21 New Federal Oversight . 'The Local Permltees must also comply with all other terms and Condibons of the M51-lCP Including but not limited to Ensure that habitat pieservatlnn is occurring In rough proportionality with Development ."If the Local Permdees do not maintain rough proportionately between Development and Conservation the Wlldllfe Agencles may Initiate revocation or suspension of all or part of the Permits [Sour., Dreft Coacheils Vall ry MSHCP Cotobe,2004 Sodium GGt Gi and i 22) Loss of Highway Improvements Insufficient Insufficient Loss of Permits Funding = Land = for Highway Acquisitions Improvements �wYil w� 4 kn r [i Q Draft Coachella Valley MSHCP—October 2004 Facility Conservation Area Avoidancelinininsization Measures Required SR 74 widening front Mesa None None' View Dr to Jet. SR-111, and O&M SR 86 widening from Imperial Coachella Valley Stormwater None' Co Line to Jet.I-10, and O&M Channel and Delta SR I I I widening from Imperial Dos Palmas Desert pup$sh Co.Line to Jet. SR86 Route Break SR I I I widening from N Jet, Rte None None' 86 to Ave 45 SR 111 widening from Ave 45 to None None' Jet. 86 SR 111 widening from 86 to Jet. none None' Rte 74 SR I I I widening from Jet. Rte None None' 74 to Palm Desert City Limit SR 111 widening from Palm None None' Desert City Limit to Bob Hope Dr SR 111 widening from Bob None None' Hope Dr to Gene Autry Trail SR 111 widening from Gene None None' Aun Trail to Chctokee Way SR 111 widening from Cherokee None None' Way to Mesquite Rd SR 111 widening from Mesquite Nono None' Rd to Vista Chino SR I I I widening from Vista None None' Chino to Roberto Miguel SR 111 widening from Roberto None None' Miguel to Palm Can on Drive SR 111 widening from Palm None None' Canyon Drive to Begin Indep. Align Lt lanes SR 111 widening from begin Snow Creek/Windy Point None' Indep.AURn to End Ind` . Align SR I I I widening from end Snow CreeWWmdy Point Fluvial sand transport; Indep.Align to Jet. I-10 Biological Corridor;Desert tortoise The project is either outside a Conservation Area or has no impact requiring specific avoidance and minimization measures. The projects are mitigated through Caltrans' land acquisition and monitoring and management obligations, as described in Section 6.6.2. 7-5 Draft Coachella Valley MSHCP—October 2004 Avoidance, minimization, and mitigation measures for the road projects identified in the table are described in Section 4.4. The mitigation obligation for these projects is described in Section 6.6.2. 7.2.3 Local Transportation Projects The Permits will also provide Take Authorization for the local transportation projects shown in Table 7-3. Figure 7-4 shows the location of these local transportation projects. TABLE, 7-3: CVACr Transportation Projects PS=Palm Springs, UNC=Unincorporated, DHS=Desert Hot Springs, CC=Cathedral City, RM=Rancho Mirage, PD=Palm Desert,IW=Indian Wells, IN=Indio, LQ=La Quinta, COA=Coachella, CAL=CALTRANS STREET NAME AGENCY SEGMENT DESCRIPTION NORTH—SOUTH REGIONAL ARTERIALS GENE AUTRY TRAIL PS Vista Chino to Whitewater River Crossing PS Whitewater River Bridge Crossing PS IN River to So. of Railroad Crossing PS Railroad Crossing to Salvia Road PS Salvia Road to and including I-10 Interchange PALM DRIVE DHS Two launch Palms to Hacienda Avenue DHS Hacienda Avenue to Pierson Boulevard DHS Pierson Boulevard to Mission Lakes CATHEDRAL CANYON CC Bridge over Whitewatcr Channcl DATE PALM DRIVE CC Palm Canyon to Gerald Ford including Whilewater Bridge widening CC Gerald Ford to Dinah Shore CC Dinah Shore to Ramon Rd. CC Vista Chino to I-10 (IC & RR Bridge) CC 1-10 to Varner Road (includes realignment) DA VALL ROAD CC Da Vall I-10 Interchange 7-6 Draft Coachella Valley MSHCP—October 2004 IN Pred Waring Drive to Indio Blvd. IN 1-10 Interchange and Bridge over Railroad IN I-10 to Avenue 40 IN Avenue 40 to Avenue 38 MADISON STREET UNC 60th Avenue to 58th Avenue LQ 58th Avenue to 56th Avenue (Airport Blvd.) LQ 56th Avenue to 54th Avenue LQ 54th Avenue to 52nd Avenue (missing link) IN/LQ 52nd Avenue to 50th Avenue (Includes Bridge over All American Canal) IN 50th Avenue to 49th Avenue (missing link) IN 49th Avenue to Hwy. 111 (Includes missing link .25 miles north of 49th Avenue) IN Hwy. 111 to Miles Avenue IN/UNC Miles Avenue to Fred Waring Drive (missing link) IN Fred Waring Drive to Indio Blvd. IN 1-10 Interchange and Bridge over Railroad VAN BUREN STREET IN/UNC Indio Blvd. to 48th Avenue COA 48th Avenue to 50th Avenue COA/UNC 50th Avenue to 52nd Avenue COA/UNC 52nd Avenue to 54th Avenue COA/UNC 54th Avenue to Avenue 56/Airport INDIAN CANYON PS Ramon Road to Tahquitz DRIVE PS Tahquitz to Alejo PS Alejo to Tacheva PS Tacheva to Vista Chino PS Vista Chino to Racquet Club PS Racquet Club to Old City limits PALM CANYON DRIVE PS Vista Chino to Tacheva PS Tacheva to Alejo PS Alejo to Tahquitz PS Tahquitz to Ramon PS Ramon to Mesquite PS Mesquite to East Palm Canyon 7-8 Draft Coachella Valley MSUCP—October 2004 PS East Palm Canyon to Sunrise PS Sunrise to Farrell PS Farrell to Gene Autry CC Westerly City Limits to Cathedral Cyn Dr. including widening bridge at West Cathedral Canyon Channel CC 200 ft. west of Sungate to easterly City Limits INDIAN AVENUE PS Old City Limit to RR Crossing (including bridge over Whitewater River) PS RR Crossing to 20th Avenue PS I-10 Interchange (in IND2) PS Intersection of Indian Av. & 20th Av. PS 20th Av. to 19th Av- PS/UNC 19th Av. to Dillon Rd UNC Dillon Rd to 14th Av. DHS 14th Av. to Pierson Blvd. DHS Pierson Blvd. to Mission Lakes DHS Mission Lakes to SR-62 LITTLE MORONGO DRS Mission Lakes Blvd. to Pierson Blvd. ROAD DHS Pierson Blvd. to Two Bunch Palms Tr, DHS Two Bunch Palms to Dillon Road MOUNTAIN VIEW DHS Hacienda Av. to Dillon Rd. DHS Dillon Rd. to 20th Av. UNC/CC 20th Av. to Varner Rd. THOUSAND PALMS UNC Ramon Rd to Dillon Rd. RD CHASE SCHOOL ROAD UNC I-10 to south of the Whitewater Flood Control Project levee MONROE STREET IN/UNC 40th Avenue to I-10 Interchange IN I-10 interchange to Miles Ave. IN Miles Ave. to 48th Ave. IN 48th Ave. to 50th Ave. IN 50th Ave to 52nd Ave. IN Monroe Street I-10 Interchange 7-9 Draft Coachella Valley MSHCP—October 2004 JACKSON STREET IN/UNC 40th Avenue to I-10 Interchange IN I-10 interchange to 46th Ave. IN 46th Ave. to 48th Ave. IN/COA 48th Ave. to 50th Ave. IN/UNC 50th Ave. to 52nd Ave. IN/UNC Jackson Street I-10 Interchange GOLF CENTER PKWY IN Golf Center Pkwy. I-10 Interchange INDIO BOULEVARD IN Jefferson/I-10 to Madison IN Madison to Monroe IN Monroe to Jackson IN Jackson to Hwy I I I PORTOLA AVENUE PD Hwy. 1 l I to Magnesia Falls Dr. PD Magnesia Falls Dr. to Country Club Dr. PD Country Club Dr. to Frank Sinatra Dr. PD Frank Sinatra Dr. to Gerald Ford Dr. PD Bridge over Whitewater Channel PD Portola Avenue 1-10 Interchange IIIGHWAY 111 RM Bob Hope Drive to Fairway Drive (relinquished by Caltrans to the City of Rancho Mirage) EAST— WEST REGIONAL ARTE&ALS VISTA CHINO PS Palm Canyon Dr. to Sunrise Way PS Gene Autry Trail to Whitewater River PS Whitewater River Bridge Crossing CC East Bank of Whitewater Bridge to Landau Blvd. CC Date Palm to Da Vall (missing link parallel to Railroad RAMON ROAD PS Palm Canyon 17nve to Indian Canyon Drive PS Indian Canyon to Sunrise Way (includes crossing of Baristo Storm Channel) PS Sunrise Way to Farrell Drive 7-10 Draft Coachella Valley MSH'CP—October 2004 PS Farrell Drive to El Cielo Road PS El Cielo Road to Gene Autry Trail PS/CC Gene Autry Trail to West Bank of the Whitewater River PS/CC Bridge at Whitewater River CC Landau Blvd. to Date Palm Drive CC Date Palm Drive to Da Vail Drive RM/UNC Da Vall Drive to Bob Hope Drive UNC Intersection of Ramon Road &Varner Road UNC I-10 to Monterey Avenue UNC Intersection of Ramon Rd. & Monterey Av. UNC Monterey Av. to Thousand Palms Canyon Rd. GERALD FORD DRIVE PD Portola Avenue to Cook St. FRANK SINATRA RM Whitewater River Bridge (within FS 1) DRIVE RM Bob Hope Drive to Vista Del Sol Road RM Vista Del Sol Road to Monterey Avenue PD Cook Street to El Dorado Drive PD El Dorado Drive to Tamarisk Row Drive RM/UNC Intersection of Frank Sinatra& Monterey RM Intersection of Frank Sinatra & Bob Hope COUNTRY CLUB RM Bob Plope Drive to Monterey Avenue DRIVE PD/UNC Monterey Avenue to Portola Avenue PD Portola Avenue to Cook Street PD El Dorado Drive to Oasis Club Drive UNC/PD Oasis Club Drive to Washington Street FRED WARING DRIVE IW Intersection of Eldorado &Fred Waring PD California Dr. to Elkhorn Trail (north side) (part of FW4) PD/UNC/IW Elkhorn Trail to Washington Street LQ/UNC Washington Street to Jefferson Street IN/UNC Silverwood Drive to Indio Blvd. PD Intersection of Portola and Fred Waring PD Hwy. I I I to Town Center Way (including bridge) 7-11 Draft Coachella Valley MSHCP—October 2004 TWO BUNCH PALMS DHS Indian Ave. to Little Morongo Rd. (missing link) DI-IS Little Morongo Road to Palm Drive DHS Palm Drive to Miracle Hill MILES AVENUE IW/UNC Hwy 111 to Washington Street IW/UNC Whitewater River temporary undercrossing (missing link) (in MILI) LQ Washington to Jefferson IN Jefferson to Clinton IN Clinton to Monroe IN Monroe to Indio Blvd. The road projects in the table will comply with all applicable avoidance, minimization, and mitigation measures described in Section 4.4. The Pennittees' mitigation obligation to acquire land and fund the Monitoring Program, the Management program, and Adaptive Management is described in Section 6.6.1. 7.3 Activities in Conservation Areas Implementation of the Plan will provide Permits for Covered Species for the Covered Activities in the Conservation Areas described in 7.3.1 and 7.3.1.1, and for the Compatible Activities in the Conservation Areas described in Section 7.3.3. 7.3.1 Covered Activities Implementation of the Plan will provide Permits for Covered Species for the following Covered Activities within the Conservation Areas: • Construction and maintenance of trails and public access facilities, except those portions which are on federal land, as provided for in this Plan consistent with the Species Conservation Goals and the Conservation Objectives for the Conservation Areas, and consistent with the guidelines for trails and public access in Section 7.3.4.2. As applicable, these activities are subject to the avoidance and minimization measures described in Section 4.4. See also Section 7.3.3.2 for a description of the various types of recreational uses that are Allowable Uses in the Conservation Areas and Section 7 3.4.1 for a description of conditionally compatible uses. • Specific projects and operation and maintenance activities listed in Tables 7-1 through 7-11. Where indicated in the tables, these activities are subject to the avoidance and 7-15 Draft Coachella Valley MSk(CP --October 2004 6.6.1 Obligations of the Local Permittees The Local Permittees are the cities of Cathedral City, Coachella, Desert Hot Springs, Indian Wells, Indio, La Quinta, Palm Desert, Palm Springs, and Rancho Mirage; the County; County Flood Control; County Parks; County Waste; CVCC, CVAG, CVWD; and IID. The Local Permittees will conserve 100,600 acres (inclusive of Caltrans' obligation), as of 1996, in the Conservation Areas. Of this, 7,500 acres are already owned by Permittees and that acreage will be conserved through the Plan. The Local Permittees shall establish an endowment to fund the Monitoring and Management Programs for those lands in perpetuity. The Local Permittees must also comply with all other terms and conditions of the MSHCP and IA (See Section 13.0 of the IA), including, but not limited to: ➢ Within Conservation Areas Ensure achievement of the Plan's Conservation Goals and Objectives and Required Measures in each Conservation Area and attainment of the Species Conservation Goals and Objectives. As described in Sections 4.1.2 and 4.2.2.2.1, conserve Local Permittee owned land in the Conservation Areas. Except as otherwise set forth in this section, the Local Permittees shall commit them currently not-conserved lands to conservation in perpetuity within 3 years of Permit issuance. Participate in the Joint Project Review Process for projects within Conservation Areas as described in Section 6.6.1.1, Applicable Permittees will employee HANS as described in Section 6.6.1.2 as appropriate. Jurisdictions that received Take Authorization for the Coachella Valley fringe- toed lizard pursuant to the Incidental Take Permit issued for that species pursuant to the CVFTL HCP will relinquish the Permit and comply with Section 6.6.1.3. ➢ Within and Outside Conservation Areas Ensure that habitat preservation is occurring in rough proportionality with Development and that Reserve Assembly occurs as contemplated in the MSHCP. Ensure compliance for public and private projects with all applicable Required Measures in Section 4.4. If a project shares a common boundary with a Conservation Area, require compliance with Land Use Adjacency Guidelines set forth in Section 4.5. Ensure compliance with Plan requirements for public projects. Impose adopted Local Development Mitigation Fees. The Local Permittees shall be responsible for collecting all revenues generated within their respective jurisdictional boundaries for Plan implementation and transferring those revenues to CVCC within thirty (30) clays of collection. Adopt an appropriate Plan implementation mechanism as set forth in Section 11.1 of the 1A. Maintain a record of total acres and location of Development within its jurisdiction and transmit this information to CVCC mondtly. 6-15 Coachella Valley Trail Users Coalition 2439 Calle Palo Fierro • Palm Springs, CA 92264 Telephone: 760,323-9432 - or - 760.340.3539 email: hikenbike@dc.rr.com - or -- ianecudall@earthlink.net Prepared for the Palm Springs City Council Meeting on Wednesday, March 9, 2005 Regarding: "Trails Plan" in Public Review Draft of CVAG's Coachella Valley Multiple Species Habitat Conservation Plan and Natural Community Conservation Plan and EIS/EIR Speakers: Gary Lueders, Chuck Nisbet and Jane Udall Coachella Valley Trail Users Coalition is made up of the valley's six major trail user groups Chuck Nisbet, Coachella Valley Hiking Club Gary Lueders, Desert Bicycle Club Allen Woodruff, Desert Cities Track Club Nanci Stacy, Desert Riders Jane Udall, Desert Trails Hiking Club Ben Travis, Palm Springs Triathlon Club The Coachella Valley Trail Users Coalition supports the conservation objectives of the draft CVMSHCP. Our coalition seeks the continued use and enjoyment of the trails in the Plan area in a manner compatible with the Peninsular bighorn sheep. However,we oppose the"trails plan" as written in the Public Review Draft of October 15, 2004. A year-long study of the "trails plan" and, more recently the EIS/EIR, resulted in a 117 page response plus a 7 page Addendum to these documents. Copies of the full report are available to anyone interested- For a copy, please call Chuck Nisbet at 760-323-9432. A Coalition of Trail Users: tV" p Coachella Valley Hiking Club Desert Bicycle Club • Desert Riders b Desert Trails Hiking Club ✓�ti OL �R Desert Cities Track Club - Palm Springs Triathlon Club - Jr gL y1N'W'�`Ir.q,�„F.9� �'rf�(„�!II�yA4M+'A+-'•Ivrw+-•I.+r.wm,,.npr•. ..rlv �y prwr ' - nw I+r M u .. ".v. MrHY ♦�r9✓, miwlvp�+r l------ 'r I V9,'�f�,'IIMwft,+N'NSx�M'1F I • n. xof .r ,rr I' f�py +p�h 'f >iA1�A'FNIbeMl d'*� � ., � 11 e•. low" f NnNNW"I A+'w fx r r• ,M1py,.•Dp.YI r Nll rr�� I A ` � TyM r. A� � ^✓A� I.Iw.w•,l i tic% yJL+r.Ma s ell, �ma....r. Nwrr . . �. �. " + .� . , /n r r r .r .. n 1 Aw.r w L�..n a.0 ur.Mu...:rll.'ww.r. Gl'w it Iw•.arro�•xuv. .n.n..�nwnrr +h � r qe r n a v 800 700 .,7 "a 600 500 40'0 300 n + 200 100 1994 1996 1998 2000 2002 2004 'r.r. .- rV.,W», fN.na` ...w'w�l, � ruyauy� ..4 pV°,�1�NWM p _ '3,•• ��k W.'r iJ,r<,+..r4 nrfn:r.�W✓.rl" �41 d�." a, gyyW.,r l r .� . I .. I�w,yl.,r.�rr./ru �IINro+A`rn+!'YMI.m.prMwk�r,�ry�wdr�2A I r v. ga•yrrq. I ,. 1". .A, ., rt ,r_�cro+ Mn^�+•r,>'.�.ra,«rw,. r+r.,..,�,rrdnW�•r4�Mbht'I��fnr.�^�.I.�ep,'r.nr»gn�wmyi�k,�e�kW RpMMA�.�...r,�-.„„ .. . r �-.,. w.. . ,, 1. . . �, .. . „NMww ,anr�NM'NF'WM'YR4hl'^rMr +fNYOu" ,' Mi ryl y,�r,.v,tirr .,rn, Ir..l+.�•1'».•Ilr+, r rrr r w•". Estim..ated Bi-glhprn Sheep �' u Mo. .,h,t . il a ns P o p u. afioin�:" Sa ................. 1,1. 1" 1" NA^Wo 1-111 1 Wl I ......... IN 0 ......1- NI, lip, I WA Af4NO P ............ ------ drm rin ........... ww" 1"0 0- oh b,11 (AR IN, v I 50 0 1983 1985 1987 1989, 1991 1993 1,995 1 9§5, 199719992 1 Adowr", lolo�omw !7=T===',7 17=" I N;;�.r.'.�_:::.:.. . :.. .:ter.', .�w .::W:� r.,; _,,..�. .:_.. . . .;. .. ,. .*�,r:_,..�-,,��.;�.�r..•M.,: J�`L _r--r'- �•. -ram L � J'L .. ,.�yrMN ur4A6+iYAMeWYwr,�c..... G ©� � �nr x.�Yflll{WMIIMp1.alwr.+M u,.rn�� r '� '+� •�..-«�,r...v. W,.....e+�w� i�C 1.r«Nr n. .vr.�.wrNrwr.�a�r..�,n, ' .. .-,.Y.urwJ .d�w.n.... n .r�r,rkw''L ��rW.. �.� ..-.. i �1 -.. , . ,.n ,..r...W� e� ,..,.._. . ..-. .�..•..w .111.r..Ne Wrlrr�wYfMtl+.r+ E7) ✓ J` L702 .. . . ._y.wA�wYr+_._. _� ••ypWr41wW1411wr,�w�raw raw w.r.r.rW+w.rr.�w.xr aW_.n,N.y w..._.,.r _�..�..._.....,_..___ ...e_ a d".6 �..i� 'I .,• i /rltlYi�Y/MYWWWwiyWY,Yw+A II � vwwMi d�^,'M1WGyw�-�T .� r�- ..�JS' :. r � -�w•ra . ...___,.r�T+nrn"^,rq,r�r• me F`I r.W�+•., n..wl.p^T Nd rTR'w-' r . i_. n..x:w•, . e frn• n, Iti� y, .41 dk:S Cll4 f _ 7:14 . nn,I r, r . .. . , r.m.,... . .., . p �. it y��y�� n�MW 'I n i .. WMNL ,nW• i ri., . �W/i �WY1- i ' V•.wrr drvilF rvan. .r .r,. .. e r r.. . . . .. .,�yry-..qr-.N� ' r i � ��rrrrrr ` . ~NNwr � � u,w..n.,YFy�.yr,u.,�r, ..�.mr ._,»rrw ...... .......�. . n,., . ,.err.-o-w�._,w... rj i p:riE•- ..,r . .�. �w� lew.4r� .. r. .{,r�raraur„wrn.r•w+. . ...... ......r.n_, W . ..r.r...,.,....,., L.,r...w,,...�wr..� n ' I I�-t??�. � =w�1' p1iN.r, I .,rw�w.r.+��re Wwra��...,urr ...w.�.. .r...r..,,«.r.._>r�vW. � ...��...-._ _.r .. •I ,.r -r.rw+�.l rGw � �. .r I� � I Mw1�M4rAl1 .�� i .r.. r r J Aim, r imrYy arr. � i ,•..I Y Mr.. I � � r I I I � � y� ,n I �+I. I Oil - !rhl{ YI_. flnvl_. _ I J�u Ir- �.e_ L.: J 1 r�n � Yn•�� qq IIaxw� � ..M��M MW�... Y .r, q . Yw.i.w,1 t ._ . . r i .a n r•. o n aMm � rn i r'r w,a,..rx rwt�.iMY..'ar.N'NM.'Foirµ Wo-g F —.A.,...,.»+,w...w.iw...r...w .a, The Best Available Science Standard In establishing the conservation planning methodology to be followed while developing the Conservation Plan,the authors of the Plan adopted the standard of the"best available science" as described below: (Appendix I, page 17-18). "From the outset, a goal was established to base the preparation of this Plan on a strong foundation of scientific data and ecological principles. The importance of establishing a baseline of scientific credible data has been emphasized in several recent reviews of the HCP process (Noss et aL 1997, Hood 1998, Harding et al. 2001). The USFWS addresses the need for use of the "best available"science in their policy document on HCP preparation,including the Habitat Conservation Planning Handbook (USFWS and NMFS 1996)_ This handbook calls for the availability of up-to-date biological information on the species being considered within the Plan area_ It also recognizes, however, that for habitat-based HCPs the protection of habitat types for a particular species through an HCP and associated mitigation program may obviate the need for additional distribution studies. The California Natural Communities Conservation Plan (NCCP)guidelines state as a criterion: "The Plan provides a conservation strategy that is based on recognized principles of conservation biology, as well as the best available scientific information about species and habitats. "" "In the initial phases of this Plan's development efforts were focused on gathering all available information on the Covered species and conserved natural communities. The effort to obtain and review up-to-date biological information was ongoing throughout the preparation of the Plan. " Unfortunately,when it came to the"trails plan" and bighorn sheep,the authors did not adhere to the"best available science" standard described above. The"trails plan"foundation contained no science. Not a single peer reviewed published study on hail users was cited as evidence for"trail plan"policies. The trails plan consisted entirely of untested assumptions, conditional statements, and value judgments. Trails plan authors improperly cited five studies of intentional/researcher/observer harassment of bighorn sheep that had nothing to do with trail users. The"best available science" on trail users consists of five studies that were ignored by"trails plan" authors. The conclusions of these studies were in conflict with policies suggested by "hails plan" authors. Population estimates of Peninsular bighorn sheep from 1983 to 2003 was available to Plan authors, yet they elected not to include the data in any of their analyses or to provide it to the public as informational background. Again,the best available science was not included, In summary, authors of the"trails plan" failed to live up to and abide by the standard of the "best available science" as set forth in the Plan documents. Authors of the"trails plan"failed to live up to and abide by the standard of the"best available science" as set forth in the 1973 Endangered Species Act. Bighorn and Trail Users Studies : The Best Available Science © Wehausen 1977 and 2000 ® Hicks and Elder 1979 A Purdy and Shaw 1981 0 Hamilton et al . 1982 n I'.rl;' I ix' j�'� ipPa'l� 'lll}'Itlll�, 'i' II'll'I,II,I , 'I,I.'I oIIIJ I, ''I''I,, III6, I•r ,IIIII' ICI rl �:I���� All Ir' ,,rl,l.',:,,Idi!� �IImrllll IIII I;Ilk;,� ' dl!I Id,ill,l „I' I'Ima II. - r, .,•r�,fir IIln �I�:.,:,~',f+1�,4�,h"v�;,�,Cr^„`.,v.:�I �, I M r n, del.r r "xw, �„rr,l{, r,w,�r�YxwM1,5N'Inw e"Nr°R utl M ,an.PP�ttJ�iW Ir�v'rf 'rr^.,r r,flm r d',,. , I„ tl . f r ,. rt.J. nvys" . 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Ilr I 1v1nI111r'!�l I l Bighorn Harassment Studies Used to Support Trails Plan MacArthur et al . 1979 and 1982 • Miller and Smith 1985 • King and Workman 1986 • Popouchis et al . 2001 • i li�'i 1, "Id,ll IiIM 1y� , I� li'',(I�'i^ 'rll�ll },"',i li•,ILI^ ;� ' ,' i1 n.p 11I,ld-1'I.r'iIr11h�11„111l,6,i, .11ed,rJ„lll lklI, t, �yI 111d 111111 � d l I' ,v,'uri '1 w"l USX'° y j(f !pmif L'i' .N A' k, dex *, d„ i#Ko f19. ul nr,l1.1Y, NNu v. io 41,x L?M M. >N; ^"rvv �„Jin,ry° „fN m1,+�,n. " ,�1"",j'; .�r,�u°"rt�u.,i��k" t �'la r rrl"!; I � �k; Wilw•u 5.l:vn�,ty%rt�.,x�', ',�,r; ' d ..a`„�r. ,d�,v�+,,,; .. e�;� r, ,�1�� Rif' QE•" -(^':"dW�iuw�' .i' ' in, .d ."..�,. .,°V,w, ..Fl"�, n✓i�yJ „ � �I�'hfw.y{s'�.M9•Xfp„Y i�V Y%w'MYA'�ximV��'*^��! 'r�yOA•X' r��^yF� "' �y, '�h�+;�^�.rild : . 4"�+W;hs�'+��f. „ ��� �'�,h' yr �{ ,:� � •. h' Sr r� fl�lt r . ,Guru, ° ��} If 'l'r, ® %,I• i a„ y%; . ✓y. .d;�r`7,,};^^�` .r , )1.W. 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LL, ...�µ''" Mi � r Yki1 x e�W'�k rYrGYwoY mn' nOrn.yWkW.'yek. vrrjr�'Mw+•.a irrr i. . .I.,�xrhi x,r,'nr n � ,�dr AN�MM^"P°. 411 Al w`r5.� ' •w P•,�rr.,r.u,lr.� ..r.i rp Ygwcrn�yWK°y.W�+Y�ry.,rW+yur�.rw�.m .re ,r, du..s,e r• 'IWraY[ "qi' Ww}111w�FNn4.7,wVkJna`MY,c4t0,.}P.NW4' N6 �I m 4Nl,.i Table 9 Coachella Valley Public HikesITrails` _ Affected by hikesltrail miles Trails Plan tlea�sy l ^location 1 Pushawalla Palms and Canyon 6 no 1000 Palms 2 Willis Palms and West Mesa 3 no easy 1000 Palms 3 Earl Henderson 3 no easy Palm Springs 4 Theilman 4 no leas � Palm Spring totals 16 1 Carrizo Canyon 5 yes moderate Palm Desert 2 Shannon Loop 7 no moderate Palm Spring 3 Araby 3 no moderate Palm Springs 4 Garstin 3 no moderate Palm Springs 5 South Lykken 5 no moderate Palm Springs 6 North L kken 4.5 yes moderate Palm Springs 7 Palm Spring Desert Museum 2 no moderate Palm Springs - 8 Mirage 1 4 yes moderate Rancho Mirage- 9 Eagle Canyon 2 yes moderate Palm Springs 10 Magnesia Falls 5 no moderate Rancho Mirage. 11 Clara Burgess 3.5 yes moderate Palm Springs 12 Cathedral Canyon 6 yes moderate Cathedral City 13 Berns 1 no moderate Palm Springs _14 Schey yes moderate Palm Desert 15 Wildhorse 3.5 no moderate Palm Spring_ �16 Goat Trails 4 yes moderate Palm Springs totals 60.5 _ 1 Garstin/Wildhorse/ 9 no strenuous Palm Springs 2 Eagle Canyon/Clara Burgess/MurrayHill 8 es strenuous Palm Springs 3 Araby/Clara Burgess/Murray Hill 10 yes strenuous Palm Springs 4 Bear Creek Canyon Ridge 8 yes strenuous La Quetta 5 Boo Hoff to Lost Can on 10 es strenuous La Quinta 6 Art Smith 16 es stenuous Palm Desert 7 Hahn-Buena Vista Loop 16 es • stenuous Palm Springs 8 Skyline 10 yes strenuous Palm Springs 9 Palm Desert to Palm Springs 17 yes strenuous Valley Wide �10 Guadalupe to Sugarloaf Caf6 15 yes strenuous La Quinta • �� totals 119 Summary: Total Valle Public Hikes/Trails _� 30 _ Total Valley Public Hikes/Trails Affected by Trails Plan 17 Total Valley Public Hikes/Trails Unaffected by Trails Plan 13 Total Miles of Valley Public HikestTrails 196 Total Miles of Valley Public Hikes/Trails Affected by Trails Plan 1 141 Total Miles of Valley Public Hikes/Trails Unaffected b Trails Plan 55 rNole, "Public means free to user. This excludes Indian Canyons and Eisenhower Peak Loop with entrance fees and hikes above the tram. Hikes in Idyllwild, Mecca, and Joshua Tree National Park are considered outside of the Coachella Valley. Ferranti 2000, CVAG and EIS/EIR . 3-83-86 March 6, 2005 ADDENDUM To The Coachella Valley Hiking Club Critique and Recommendations, submitted in response to the"Trails Plan"in Public Review Draft, Coachella Valley Multiple Species Habitat Conservation Plan and Natural Community Conservation Plan.and EIS/EIR, by Charles Nisbet, Ph.D, President, Coachella Valley Hiking Club, official response copy submitted to CVAG, Wednesday, January 26, 2005. ----------------------- -------------------------------------------------------------------------------- A Public Records Act request to CVAG for all correspondence to and from Dr. John Webausen was made December 14, 2004. February 23, 2005, I was notified by CVAG they had 49 pages of correspondence. This correspondence was distributed as follows: 2003 2004 10/13 1/2 10/30 1/9 12/2 1/17 12/2 1/18 12/2 12/2 12/3 12/4 12/8 12/14 12/17 12/26 The names of people receiving or sending this correspondence are identified as follows: Katie Barrows, Coachella Valley Mountains Conservancy (author trails plan) John Criste, Terra Nova(Authors of EIS/EIR) Elorentzen, Bureau of Land Management James Foote, Bureau of Land Management Linda Hansen, Bureau of Land Management Bill Ilavert, Coachella Valley Mountains Conservancy(author trails plan) Elena Misquez, Bureau of Land Management James Sullivan, Coachella Valley Association of Governments John Wehausen, Univ. of California, White Mountain Research Station John Wohlmuth, Coachella Valley Association of Governments Gavin Wright, Bureau of Land Management Larry LaPre, Bureau of Land Management N It appears we do not have all the correspondence. October 13, 2003 starts off in mid stream. No initial correspondence discussing work to be undertaken and no contract particulars appear. There is reference to a December 11, 2003 memo that was not included. No correspondence was found for the past 13 months. The copies we received reveal that this consultant, one of California's leading bighorn sheep experts offered to CVAG, Terra Nova and the Bureau of land Management some of the same concerns and reservations about the trails plan as we stated in our January 26, 2004 CVHC response. Dr.Wehausen provided substantive advice and recommendations that were ignored in the final drafting of the trails plan. His input was completed one year before the release of the trails plan. What follows is a listing of key points. We believe this illustrates again how and why the trails plan and EIS/EIR are deficient. October 13 2003. Criste wrote to Wehausen "We met with CDFG and FWS last week and discussed this matter of trail use again. I have to say that our efforts to raise the limits of trail use did not go well. Both agencies think there is a basis currently for the application of draconian limits on the number of hikers on trails. " This documents the problem squarely. The plan to restrict public access to trails came directly from Wildlife agencies that were expected to base their policies on best available science. Further correspondence from Wehausen questions their use of scientific evidence. October 30, 2003. Wehausen sent comments to ??? Wehausen responds to `Biological Evaluation of Effects of the Trails Plan for the Santa Rosa and San Jacinto Mountains Conservation Area of the MSHCP." Under ,,some more glaring problems," he writes: "The only really scientifically valid test of human disturbance effects has to be measured at the level of population parameters of the sheep. On p. 41 of the Biological Evaluation near the bottom it is stated regarding Bear Creek Canyon Trail that the sheep in this area has had consistently high lamb recruitment and low adult mortality. What has effectively been stated is that human disturbance in that area has clearly not had a negative effect on the sheep. Consequently, the notion that human use on that trail needs to be limited is a contradiction. One could use the data presented here to argue more widely that the demographic problems of the sheep immediately north of the ones referred to here had nothing to do with human disturbance on trails, but instead to the urban interface that the sheep used, which is what differed. This is like a simple natural experiment. I would like to see demographic data for the sheep in other areas slated for limitations to see if similar contradictions exist. What this example alone tells me as a reader is that this plan lacks a scientific basis and leads me as a reader easily to a conclusion that there is 2 little real interest in this management being based on credible analysis of data. If this key piece of information is ignored, what else will be?" Aid the authors submit demographic data from other areas slated for limitations as Wehausen called for? Apparently not; the authors of the trails plan and EIS/EIR, instead, seem to have reacted to this critique by removing the Bear Creek Canyon Trail evidence from the plan. This scientific evidence did no support their preconceived notion of rationing, so it was removed. What does this say about the quality of their scientific work? Wehausen goes on: °°This is an example of why the monitoring and research component of this plan has to be laid out in sufficient detail prior to establishment of trail limitation in order for adaptive management to work" Ignoring this advice and warning, CVAG proceeded as originally conceived. The monitoring and research components are void of detail and thus adaptive management is but an empty phrase. Responding to the claim,"Current management activities by BLM have resulted in reduced human disturbance,°°Wehausen wrote: "YVe cannot say this has had any effect on sheep." "...under San Jacinto Mountains it states: researchers do not fully understand...... (why the population of PBS remains small)Wehausen wrote, "I think a lot more is understood and can be stated. Key factors have been lion predation and a sex ratio of offspring favoring males." November 23,2003. Wehausen, sent comments to V? Wehausen comments on draft MCHCP'Trails Alternatives in the,EIS "It is listed that 2300 permits will be allowed during the 5 month season. This translates to an average of about 1.5 per day per trail. I suggest that this be stated up front far the reader. The reader should not have to make that division to understand this. " Here again,Wehausen's advice was rejected. The final trails plan lists 2300 individual permits and leaves it up to the reader to determine how many that represents per day and per trail. CVAG chose not to present the math, preferring to obfuscate the draconian nature of the trails plan. By rejecting Wehausen's advice, CVAG demonstrated its intentions. 3 I Webausen comments on the three key elements of a trail management plan for bighorn sheep. "Again this leaves out the key element of demographic data on populations in question. I would list that as the first data element needed. " A major criticism we leveled at the trails plan and EIS/EIT2 was that it included no time series data on bighorn sheep. We even supplied CVAG and Terra Nova in the spring of 2004 with the time series data. Doesn't this now demonstrate that when their own consultant said use the data and when a local trails user group provides the data,that CVAG had no interest in including bighorn population data? Why not? Could we guess it is because including the data undermines the entire trail rationing approach of the trails plan? December 2,2003. Criste wrote to Wehausen, and LaPTe After receiving trail use data from BLM and population data from Jim DeForge, Criste says, "This seems to demonstrate that there is no meaningful correlation between the current level of trail use and adverse effects on PBS. " As for bighorn adaptation and habituation. "I would refer Larry to the issues raised by the photographed behavior of sheep at Mirada walking within ZS feet of an operating concrete truth which they preferred over the three biologists and planners watching them. " What happens to these two conclusions in the ETS/EIR? Criste said,"The permit system is the crux (?) of the issue for CVAG and the trail users. Solve this permit matter and you will solve 90%of the politics associated with this project "'T'he primary writer of the EIS/EIR has moved from science(his assignment) to politics. December 17, 2003 Wehausen wrote to Barrows. LaPre, Criste, and Havert He warns about the continued conjecturing about human disturbance impacts upon bighorn sheep and suggests a problem analysis approach instead. `A proper adaptive management approach would begin with no limitations on trails. Ivey variables identified in the problem analysis would be measured and trail use would be limited ifineasurements crossed trigger values. Obviously, demographic variables would be among the most important. Given the situation you are dealing within which there is insistence on limitations of trails use (i.e., by wildlife agencies—Nisbet's 4 clarification) in the absence of any supporting scientific data for the population in questions (PBS), apossible adaptive management approach would entail: (I) admission up front that there is no scientific support for limitations (I disagree that the literature provides support and would like to rewrite that review as part of the problem analysis); (2) make a new problem analysis that identifies important variables that should have been considered before any limitations (on trails) were even considered; (3) set up some important measures to be made; and(4) set trigger values that lead to removal of trail restrictions. The removal of restrictions could be set up to make a good experimental situation spatially and temporally. I would use demography and sheep distribution as the key trigger variables. If the NS Rosa population continues to increase in years when rainfall occurs in key months and there is no evidence that sheep have been avoiding areas with trails, additional trail restrictions will be removed each year. This puts the burden of`proof' on those who insist that human disturbance is important to these sheep in the absence of evidence. The removal of restrictions should start quickly, i.e. after one year. Otherwise the potentially false statement will be made that the population increases are due to limitations on human use. In contrast, if the population continues to increase despite increasing human use of trails it will be a strong refutation that trail use is important. That would be a clean result as this kind of science goes. " Note all parties are aware that USFWS and CFG are insisting on limiting trails use despite having no scientific basis for doing so. All are aware the trails plan is flawed, but proceed anyway. His warnings and suggestions were not accepted and acted upon. December 26, 2003 Wehausen wrote to Ctiste, Wright. LaPre, Havert and Sullivan "What lam finally starting to f gure out is that there was no attempt to see if sheep were avoiding areas with trails. If that is the case, it should be pointed stated. " To our knowledge CVAG never took this suggestion. To the paragraph, "Although there is considerable information about the ecology of Peninsular bighorn sheep, there is uncertainty about the effects ofreereation on bighorn sheep. It is acknowledged that bighorn sheep react to humans. But the level of effect is not well understood. Whether recreation related disturbances cause an individual or population level effect on bighorn sheep cannot be ascertained in the context of this Trails Plan. However, the endangered status of this population of desert bighorn compels us to manage the risk of disturbance to ewes and lambs to ensure these groups are undisturbed during the spring and to ensure sheep have unimpeded access to water during the hot season."--Wehausen wrote, "This paragraph is the core conceptual statement about what analyses this plan is based upon. It basically states that this plan is based upon an animal welfare approach rather than on the basis ofscientific analysis. This paragraph will be singled out by some of the reviewing public and may well be the basis of law suits. " Thus, CVAG was told a year before they released the trails plan that it was not based upon scientific analysis but went ahead with it anyway. 5 Wehausen wrote, «I recently received in the mail a review of the draft Sierra Nevada bighorn sheep recovery plan by a lawyer for Desert Riders. That review was done as a comparison between the Sierra RP and the.Peninsular RP and its general approach, including approaches to human disturbance. I state this only to warn you that they are ready to pounce. The question is whether this plan is created with credible and rational scientific basis now or is forced to later. " How prophetic is this statement? The following two statements from Wehausen illustrate his critique of the inappropriate use of literature for the support of the trails plan. "But, this paragraph illustrates the biased nature of this literature review. The word 'linked" implies to the reader cause and effect. However, the Santa Catalina Mts. situation that Etchberger studied(and I think was the topic of the Harris dissertation and probably what the Krausman reference is about) was investigated only as the bighorn population was nearly extinct. It is not clear that human disturbance was the cause .....the Hamilton study concluded that human disturbance was not a factor of any importance." "I have never been convinced of the Pusch Ridge situation. It was studied too late to make any strong conclusions about human disturbance. The population might have dwindled for any of a lot of reasons. The statements are basically all conjecture. " To the following statement, "These dogs could cause serious disturbance to any sheep in the area, especially if they get off leash. Candids, by instinct, will pursue sheep and sheep, having coevolved with the coyotes as predators, are likely to experience severe stress when seeing domestic dogs even it the dogs are kept leashed " Wehausen responds, "This is another false generalization, along with needing to get stress out of it. It is ewes with young lambs that mostly show strong reactions to dogs in my experience. " To the following statement, "Bear Creek Canyon Trail: This area has consistently high recruitment of lambs and low adult mortality." Wehausen responds, "This stands out as a clear fag that this plan lacks a scientific basis. The first sentence alone states by its implications that human disturbance here is not important. Yet, the plan proposes trail limitations. This represents a logical disconnect. " Wehausen wrote, "a strong population increase will falsify the hypothesis that the prevailing human use patterns were an important negative physiological influence on the population" Could this be why time series population data was omitted from the "trails plan" and EIS/EIR? Wehausen wrote, "Note that I am still looking for studies that provide convincing data including long term avoidance by sheep of areas of high human use other than paved roads. What the literature says to me substantially is the sheep readily work around human use patterns to get the resources (e.g. water, minerals) that they need." The new perennial water source at the entrance to Magnesia Falls Canyon is certainly an example in the NSR Mountains that supports Wehausen. 6 A .lanumX 9, 2004 Wehausen wrote to Barrows, Misquez, Sullivan, WoMmuth, LaPre, Foote, Criste, and Wright "In short, there is no evidence that trail use has had any adverse effect on these sheep populations. " This was one of our major points. Apparently CVAG elected to ignore Wehausen's warning `....that the recovery plan (USFWS 2000) calls far lion control(which never was implemented" We argued that CVAG's main action variable was trail users instead of proven variables like predation. "Overall the literature is misused to try to support an unsupportable position."Here is perhaps Wehausen's most telling criticism. Our response documented the misuse of literature in Appendix[ C of the EIS/EIR. February 18, 2004 Wehausen wrote to Barrows, Misquez, Sullivan, Wohlmuth, LaPre, Foote, Criste, Wright, Ilavert, Hansen and Elorentzen "Above vs. below and escape terrain. Above is bad only if that represents escape terrain for the sheep and the humans are thereby between the sheep and their preferred escape route. "This clarifies the often quoted simple statement that sheep don't like being approached from above or below that is then taken as fact. In summary,why were Wehausen's critiques ignored. It seems to us, many of the points he made in criticizing the plan were put before the writers long before the plan was finalized. This was a highly respected, independent scientist they employed to advise them. What happened? 7 Conclusions and Recommendations: I am.lane Udall, Desert Trails Hiking Club, to conclude our presentation to you tonight, we summarize the key findings and where we want to go from here: The key findings are as follows: 1. The Trails Plan and EIR/EIS are flawed. They are not based on the best available science. They are based instead on studies that bear little relevance to 4te question at hand, which is, "Do trail users negatively impact sheep recovery?' 2. CVAG received ample waning from a respected sheep biologist that the plan was not sound, not based on facts, and not supportable. 3. Population data on bighorn sheep, astonishingly absent from the Plan, indicate significant recovery rates since 1996 and numbers very close to those required for removal from the Endangered Species List, assuming they are sustained for twelve years_ The problem is nearly solved_ There is no justification for restricting trail use since both trail use and sheep populations have been increasing for at least eight years running. 4. The proposed Trails Plan has no public support. Further, support for the Voluntary Avoidance Program which has been in effect for several years bas eroded to a significant degree as the public has come to understand that it is not based on any scientific evidence. Our recommendations are these: 1. The Coachella Valley Trail Users Coalition wants its representatives to work directly with the wildlife agencies to develop a new plan that is based on good science and therefore can enjoy public support. 2. We would support a plan which allowed for a. year round open access on all trails, b. development of perimeter trails c. development and preservation of trailheads in new developments allowed under the Habitat Conservation Plan c_ using a management model whereby trail specific concerns can be analyzed and a plan of intervention developed, and d, a public education program that stresses the importance of staying on trails and not allowing dogs within sheep habitat.