Dear Coastal Commissioners,

We the undersigned disagree with the Staff Recommendations, and urge that the Commission find Appeal A-2-SMC-11-010 raises a Substantial Issue. The Dardenelle Trail is a beautiful 1/4 mile trail located within the Fitzgerald Marine Reserve in Moss Beach, California.

The San Mateo County Parks Department trail design does not fit the natural setting and is being justified as necessary to comply with ADA requirements. ADA compliance requires a trail be three to four feet wide. The existing trail is mostly 3-4 feet wide and the proposed width is 8 feet. This would more than double the trail width near the wetland vegetation.

The Coastal Commission Staff Recommendation states that the WRA Environmental Consultant's report is not conclusive because the wetland observations were done in August, the driest month of the year.

"The Commission's staff biologist has reviewed the WRA report and concluded that the area in question could be considered a wetland pursuant to the Coastal Commission's definition of a wetland, found in California Code of Regulations 13577 and LUP policy 7.14 (see Exhibit 5). In fact, 50% of the herbaceous vegetative cover at one of the sample locations was provided by species designated Obligate and Facultative Wetland, indicating they most commonly occur in wetlands. In comparison, the WRA report concludes that although there are wetland species present, the area is not a wetland due to upland conditions observed. However, the observations done in the report were conducted in August, and the conclusion that the area did not pond water during the rainy season was an anecdotal recollection by a Park Ranger. In addition, lack of inundation does not mean the area may not saturate near the surface during the rainy season. Therefore, the data collected and the analysis by WRA Environmental Consultants is insufficient to enable the Commission to conclude that the area is not a wetland."

(page 3 and 4)

This biologically sensitive area has regional, state, and national significance, as recognized by:

Inclusion within the Monterey Bay National Marine Sanctuary and the Gulf of the Farallones National Marine Sanctuary (which have joint responsibility for management of resources below the average high tide line)

Inclusion within the boundary of the Golden Gate National Recreation Area

Designation as a Marine Life Refuge under the State Water Resources Control Board's designation as an Area of Special Biological Significance (ASBS)

Inclusion within the Central California Coast International Biosphere Reserve, as part of the Man and the Biosphere Program of UNESCO

Inclusion within the Critical Coastal Area (CCA) program, a multi-agency collaborative effort working towards reducing coastal non-point source polluted runoff and improving watershed health

The 2002 Master Plan for the Fitzgerald Marine Reserve recognized the area's rich natural resources through its guiding principles:

"The fundamental concept underlying the Master Plan is that protection of the outstanding natural resources of the Fitzgerald Marine Reserve will require a new approach to management of ecological systems and visitors in future years, and the best way to accomplish this goal is to emphasize the sensitivity of the resource, to enhance the educational value of the Reserve, to manage visitation, and to limit use of the Reserve as a recreation destination."

We urge the Commission to consider preserving this trail for future generations.

Thank you for reading our letter.