November 8, Members: Ms. Eileen Mackin-Getzoff Chair Dr. Yarrow Nelson Vice Chair Mr. Robert Carr Mr. Ryan Andrews Mr.

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- Jim Suty, President 15131 Garcal Drive San Jose, CA 95127 805-994-9309 E-mail: jim@oceanodunes.

1 - Jim Suty, President Garcal Drive San Jose, CA November 8, 2017 San Luis Obispo County Air Pollution Control District Hearing Board Members and Alternates c/o Alyssa Roslan, Clerk of the Hearing Board 3433 Roberto Court San Luis Obispo, Ca Members: Ms. Eileen Mackin-Getzoff Chair Dr. Yarrow Nelson Vice Chair Mr. Robert Carr Mr. Ryan Andrews Mr. William Johnson Alternates: Mr. Paul Ready Dr. Thomas Richards Mr. James Anderson Mr. Rick Rittenberg Re: The November 13 abatement hearing. Honorable Members of the Hearing Board, These comments are filed on behalf of Friends of Oceano Dunes, Inc. ("Friends"), which is a California not-for-profit corporation, representing approximately 28,000 members and users of the Oceano Dunes State Vehicle Recreation Area ("SVRA") located near Pismo Beach, California. We would like to address the following points: a) Friends would like to offer an adaptive management process to meet the needs of all involved Balanced Recreation b) Historical acreage lost and APCD proposals ask to take more away c) Natural dunes need to be appropriately defined 28,000 supporters. We represent environmentalists, equestrians, campers, fishermen, families and off-road enthusiasts who enjoy the benefits of Public Access through Responsible Recreation at the Oceano Dunes State Vehicular Recreation Area (ODSVRA). We want to maintain Access For All! Page 1 of 22

2 a) Friends would like to offer an adaptive management process to meet the needs of all involved Balanced Recreation Friends believes that the entire acreage needs to be revisited to establish a new SVRA that balances the needs of all involved. This is exactly what the Public Resources Code desired: (a) The Legislature finds that off-highway motor vehicles are enjoying an ever-increasing popularity in California and that the indiscriminate and uncontrolled use of those vehicles may have a deleterious impact on the environment, wildlife habitats, native wildlife, and native flora. (b) The Legislature hereby declares that effectively managed areas and adequate facilities for the use of off-highway vehicles and conservation and enforcement are essential for ecologically balanced recreation. (c) Accordingly, it is the intent of the Legislature that: (1) Existing off-highway motor vehicle recreational areas, facilities, and opportunities be expanded and be managed in a manner consistent with this chapter, in particular to maintain sustained long-term use. (2) New off-highway motor vehicle recreational areas, facilities, and opportunities be provided and managed pursuant to this chapter in a manner that will sustain long-term use. What Friends recommends is: The park acreage meet the intent of the Public Resources Code and the acreage be divided in half to support balanced recreation acres divided by 2 = 1795 acres for OHV and camping and 1795 acres for species protection, dust mitigation and other adaptive management needs. Establish a no net loss philosophy to ensure continued use and protective measures. If acreage is needed for dust mitigation or species protection, then a 1:1 replacement occurs where acreage is opened to offset the need to close other acreage. Provide State Parks the ability to apply adaptive management practices which meet the needs of all involved by managing the balanced acreage use with a no-net-loss philosophy. State Parks is the land manager who needs the flexibility to manage the park in the most effective manner. Page 2 of 22

b) Historical acreage lost and APCD proposals ask to take more away The ODSVRA has been used for camping and off-road recreation for over 100 years.

3 b) Historical acreage lost and APCD proposals ask to take more away The ODSVRA has been used for camping and off-road recreation for over 100 years. There is a long history of enjoying the entire Guadalupe Dune Complex, which includes the Oceano Dunes SVRA. In 1982 a significant portion of the dunes were closed. Page 3 of 22

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5 Over time, there have been many actions taken which have continued to reduce the area for camping and recreation acreage for beach camping reduced 2001 acreage for beach camping reduced Page 5 of 22

6 2002 acreage for beach camping further reduced & acreage for 1000 foot seasonal buffer taken 2003 acreage for beach camping further reduced and exclosure moved to Pole 6. Page 6 of 22

2017 APCD & CCC Staff recommends permanently closing and vegetating acreage with further reduces the park Further reductions in the parks acreage adds congestion

7 2017 APCD & CCC Staff recommends permanently closing and vegetating acreage with further reduces the park Further reductions in the parks acreage adds congestion and increases the risk of injury of the visitors. Significant economic impact may occur if beach access is reduced to protect the safety of the visitors. Page 7 of 22

8 c) Natural dunes need to be appropriately defined Many see vegetated dunes and think it is natural, but as we will show you they are not. In order to understand and appreciate the current landscape, one must also review the landscape from years gone by. For this reason, we have put together the following document to aid in discussion. The Oceano Dunes and surrounding area has been a great place for tourists and recreation for approximately one hundred years. Due to this popularity, there have been many photographs taken and stories written to remind us of this history. For example, let s first look at the area now known as Pier Avenue. Many years ago this was just a solitary road leading out to a hotel, which looked out over the beautiful coast. The following is a photo of a photo, which hangs on the wall inside the Guiton Realty office in Oceano. The Guiton family has lived in Oceano for many generations and they have provided a plethora of old photographs and information. The hotel sits where Pier Avenue currently meets the beach. Please note the barren sand north of the hotel. Page 8 of 22

The following aerial photo was taken in 1956. If one looks closely at the photo to the left, one will clearly see the Oceano Airport and Pier Avenue.

9 The following aerial photo was taken in If one looks closely at the photo to the left, one will clearly see the Oceano Airport and Pier Avenue. Looking north, one will see that the area is virtually void of foredunes and vegetation. Please remember, when this photo was taken in 1956, most vehicles were forced to stay on the hard wetpacked sand because of their skinny, hard tires, which did not perform well in the sand. Therefore, one cannot assume that the lack of vegetation is due to vehicles, because the previous picture also helps show this area as being void of vegetation. Page 9 of 22

However, the foredunes are starting to develop with the help of the locals trying to prevent sand movement.

10 The following photograph shows the old wooden ramp at the end of Pier Avenue and the lack of vegetation to the north of Pier Avenue. However, the foredunes are starting to develop with the help of the locals trying to prevent sand movement. Today (see below, picture taken 9/5/02), one sees massive amounts of vegetation. Is this natural? Locals remember people planting and watering this area to develop these plants for dune stabilization. Page 10 of 22

11 When looking at these pictures, one must ask, How were these dunes formed and what was the sequence of events to get them where they are today. The Dune Center offers an excellent video on the formation of the entire Nipomo Dunes complex. This video depicts sand moving down the Santa Maria River and into the ocean over many thousands of years. The sand is then washed up onto the shore, dried, and then blown inland forming the dunes. Thousands of years of this activity have created these dunes. Now one must ask which came first, the sand or the vegetation? This question is similar to the chicken and the egg. The old photos and written word give a better understanding of what natural is. The Pavilion Hill area is one of the best-known locations within the dunes. It was this location that locals brought wood and nails down with horse and wagon to build the large two-story Pavilion in the early 1900 s. In addition, plots of land could be purchased in the El Pizmo Beach Resort. Some people still own plots in this area from the old El Pizmo Beach Resort.. Page 11 of 22

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13 Note lack of vegetation in front of the Pavilion in this photo. Page 13 of 22

14 Note the vegetation added to stabilize the dunes. Page 14 of 22

15 The book, The Duneites, was written by Norm Hammond and was published by the South County Historical Society in The Duneites gives considerable history for the dunes and surrounding area, while focusing on some early inhabitants of the dunes. It is a great book and worthwhile for all to read. Page 12 of the Duneites reads: Work began on a grand pavilion at La Grande; the new pavilion would be larger and more expensive than the one at Oceano. It would stand in the heart of La Grande Estates, on the highest dune in the five-mile stretch of sand between Oceano and Oso Flaco Lake. The pavilion would face the ocean, just a few hundred yards from crashing surf. Page 13 of the Duneites reads: Succulent ice plant and European dune grass were planted in the huge dune at La Grande to stabilize the moving sand and prevent wind from cutting the foundations Page 13 of the Duneites reads: The grand opening was scheduled for July 4, Local papers carried advertisements promoting a free barbecue, clambake, horse racing and dancing all day. Page 13 of the Duneites reads: By 1915, the La Grande Pavilion and its pier stood deserted and in ruins. Page 14 of the Duneites reads: The sea wind cut through the dune grass and iceplant. It cut a small notch next to the redwood foundation of the pavilion and slowly widened until a man on horseback could ride beneath its northwest corner. The foundation weakened, and the northwest tower of the pavilion began leaning over into the wind. It creaked and swayed for months, until the final grain of sand had been whisked away, letting the ornate tower collapse sadly in the night. As one moves south along the coast and looks at some of the older pictures, one can see the beach has always had areas of barren sand. Page 15 of 22

16 The vegetation island that protrudes out towards the water (near the center of the photo) is referred to as Pavilion Hill. Pavilion Hill is where a dance hall was built in the early 1900 s. The builders of the Pavilion, trying to stabilize the dune, planted the large amount of vegetation. Note the lack of foredunes up and down the coast. Page 16 of 22

17 Moving further south. Pavilion Hill is at the bottom of this photo (north). Page 17 of 22

18 At the top of this photo is Oso Flaco Creek. Page 18 of 22

19 In the middle of this photo, one can see Oso Flaco Creek. Note the lack of vegetation in the dunes above the creek (south). Page 19 of 22

20 This photo was taken September 5, This is Oso Flaco Creek note the beginning of massive amounts of vegetation smothering the dunes. Oso Flaco Creek on the left looking south. Page 20 of 22

21 South of the Oso Flaco Creek. Page 21 of 22

22 Friends of Oceano Dunes is deeply concerned that the APCD is ignoring historical evidence which supports barren dunes as being natural. Sand blowing is also natural and is the basis for making the sand dunes, which also includes the Nipomo Mesa. Sincerely, Jim Suty President Friends of Oceano Dunes CC: Tom Roth FRIENDS Board of Directors Page 22 of 22

Visitor s Survey Summary for the Pismo State Beach and Oceano Dunes State Vehicular Recreation Area Public Works Plan and Environmental Impact Report

January 2019 Visitor s Survey Summary for the Pismo State Beach and Oceano Dunes State Vehicular Recreation Area Public Works Plan and Environmental Impact Report Prepared for: California Department of