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February 10, 2006 Meg Caldwell, Chairperson California Coastal Commission 200 Ocean Gate, Suite 1000 Long Beach, CA 90802 Subject: File # 5-05-476, Horse Arena, Upper Newport Bay Dear Chairperson Meg Caldwell: It has recently come to my attention that a permit application was submitted for a horse arena at Upper Newport Bay Nature Preserve. I am requesting that the California Coastal Commission and any other agencies involved in approving this project, deny the permit application. I understand why the equestrian community needs a horse arena to exercise their horses, however, a large storm drain exists next to the proposed horse arena, which creates direct drainage of rainwater into the bay. The horse arena should not be constructed adjacent to the Nature Preserve for the following reasons: 1. The horse arena will be detrimental to the water quality of Newport Bay as it is being located next to a flood control channel. Silt, horse manure (coliform bacteria), vectors and dust are sources of pollution that must be kept out of Newport Bay. This is not only an environmental concern but also a public health and safety concern. It is apparent from the current and ongoing lack of cleanliness on trails that horse waste will enter the flood channel and bacteria levels will increase in the bay. We need to consider the existing horse waste on the trails; horse owners need to make an effort to keep that out of the bay. 2. “Newport Bay is one of the most important environmental and recreational resources in Orange County, but is listed as impaired for excess sediment on the Clean Water Act Section 303(d) list” This is a quote from the County website: www.ocwatersheds.com. A horse arena will add sediment to the bay, thereby violating the requirement to reduce sediment. The NPDES permit requires the state to keep waste out of the bay. 3. In June 2004 a guidance document titled “Equestrian-Related Water Quality Best Management Practices” was published 1. This document was a cooperative effort among private and public entities. This document describes the water quality issues of concern and it recommends that new facilities be located away from creeks and floodplains. The location of this horse arena has a direct impact to the flood control channel. 4. The proposed development is located near sensitive habitat. Two endangered species (California Nat Catcher and Light Footed Clapper Rail) are living within 150 feet of this project. The horse arenas will disturb the sensitive habitats and the endangered species as it is too close to the nature preserve. 5. The mission of the Newport Bay Naturalists and Friends is to support education, restoration and enhancement of the Nature preserve as wildlife preserve. A horse arena does not provide education, restoration or enhancement and is detrimental to the ecosystem of the wildlife in the preserve. 6. Access to the horse arena only benefits a select group of individuals for a recreational activity that is not suited to a Nature Preserve. In addition, a 1-ring horse arena already exists on the hill top, east of the proposed 3-ring arena, which in my opinion should be removed and restored with native vegetation. 7. Access to the arena is a concern in that parking is limited and horse trailers will take up space. If you believe that only local residents will use the arena and not park cars or trailers nearby, then refer back to #3. There is concern that the larger arena will be used for private lessons on public land, thereby increasing the traffic and impacts to the bay. It is my understanding that the Army Corp of Engineers has been evaluating this area for a mitigation project to add riparian habitat to help improve the water quality. This type of project is more suitable to this area. The horse arena is not a natural area and would create an added source of pollution into the bay. A horse arena is better suited to be located in an area away from the flood control channel and the nature preserve. It should be located where recreation is the focus of the park rather than preservation for wildlife. I respectfully request that you re-consider the impacts of this project and deny the permit. Sincerely, Sylvia Marson smarson@argo-tech.com Environmentalist Volunteer Naturalist (individual), Newport Bay Naturalists & Friends County of Orange, Costa Mesa, CA Taxpayer 1 Equestrian-Related Water Quality Best management Practices, June 2004, Information contact: www.swrcb.ca.gov, www.ocwatersheds.com, NPDES Coordinator, Chris.crompton@pfrd.ocgov.com cc: Please accept my emails as copies: Ann Blemker, Staff Analyst, Coastal Commission, ablemker@coastal.ca.gov Regina Fodor, President Newport Bay Naturalists and Friends, regina.fodor@sbcglobal.net Scott Thomas, County of Orange, HBP Resources & Devel. Mgmt. Dept., scott.thomas@rdmd.ocgov.com Nadeem Majaj, County of Orange Flood Control Division, nadeem.majaj@rdmd.ocgov.com Mark Esslinger, County of Orange Staff Liaison Back Bay Equestrians and SA Hts. PAC mark.esslinger@rdmd.ocgov.com Larry McKenney, Co. of Orange, Watershed & Coastal Resources Division, larry.mckenney@pfrd.ocgov.com Chris Cromptom, Co. of Orange, Environmental Resources Section, chris.crompton@pfrd.ocgov.com Dave Kiff, Newport Beach Assistant City Manager, dkiff@city.newport-beach.ca.us Leslie Daigle, Newport Beach City Council Member, lesliedaigle@aol.com |
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