Conservation Actions & Archives
Tomales Dunes is not only a valuable, fragile natural resource; it is also the site of Lawson’s Landing, a large agricultural operation and the biggest RV campground on the coast of California. Lawson’s Landing has 233 permanent RVs and up to 1,000 additional RVs each night. Cars and RVs damage the sensitive dune wetlands. On busy weekends, Lawson’s Landing is transformed into the biggest town in West Marin.
Lawson’s Landing has operated for decades without the required County and Coastal Commission permits. Apart from porta-potties, the campground is served by about 100 primitive, un-permitted cesspits, most sited along a seawall next to Tomales Bay. A sand quarry operated in the dunes for years, but has recently been forced to close due to permit violations. Invasive European beach grass has been planted to protect the campers from being bombarded by wind-blown sand, but it is taking over the mobile dunes, and if unchecked will destroy them within a very few years.
The California Department of Fish and Game maintains the California Natural Diversity Database (CNDDB). The CNDDB program uses NaturServe's Heritage Program methodology defined for Natural Community Conservation Ranks to confer rarity rankings for vegetation alliances (see www.natureserve.org).
Alliances marked with a G1 through G3 are rare and threatened throughout their range. Alliances marked with a G5 and an S1 through S3 are secure through their range outside the state but are rare and threatened in California. A G4 / S4 alliance may or may not be endemic to California and is secure statewide.
Based on vegetation types described in Baye and Wright 2004 (groundtruthing surveys are required to confirm these findings), rare and unusual vegetation types of the Tomales Dunes area include (but are not limited to) the following:
Dune communities (CNDDB rarity rankings (G = global / S = State))
Dune slack, coastal wetland and marsh communities:
The G indicates the alliance's rarity and threat globally, and the S indicates the alliance's rarity and threat in California.
CNPS Plant Protection Recommendations:
CNPS considers Marin County’s review of and action upon the proposal to be deficient as regards both the process and the final outcome.
The County used a baseline environmental assessment that included a wide range of unpermitted and unlawful activity resulting in a report that seriously understated the environmental impacts of the campground and associated infrastructure. Further, the County failed to require a systematic biological survey and mapping of the unusual plant species and communities for which the site is known. The project was thus designed without adequate regard for the protection of these important resources. We hope that the Commission’s decision will rectify these shortcomings.
CNPS understands that the Commission will give de novo review to this matter and that the applicant’s proposal has changed since 2008. We therefore emphasize the following points here:
The last six of these taxa occur in the site’s wetlands. None is mentioned in the Revised Project Description, dated June 6, 2011, nor do their precise locations in relation to the proposed development appear in the record, to the best of our knowledge.
CNPS believes that the presence of no fewer than three taxa of taxonomic uncertainty together with 5 others with biogeographic significance warrants the adoption of strong protective measures. Being rare or thriving outside the heart of these species’ range, these plants can be considered ecological or genetic outliers-- that is, they could be slightly differently adapted to their environment or resistant to disease, pathologies or environmental changes that could wipe out the core populations. Only if adequately protected can these unusual plants serve as refugia or a colony of survivors in the event of a population collapse brought about, for example, by climate change.
The Marin Local Coastal Program [LCP] embraces the concept of conserving such unusual populations in its definition of “sensitive habitat areas,” stating “such habitat may… be unique, rare or fragile, provide habitat for rare or endangered species of wildlife and thus be vital to species’ survival or be of particular scientific or educational interest.” LCP Unit II at 70 [emphasis added]. Certainly these taxa would be of scientific interest and the presence of several such plants within the same vicinity suggests that the site’s wetlands (or some of them) may be ecologically unique.
The campground site consists almost entirely of “sensitive habitat areas,” several of which exemplify recognized plant communities or vegetation types: coastal dune scrub, mobile dunes, wetlands, and dune slacks. Any approved plan should protect these areas to the maximum extent possible.
While the execution of an adequate conservation easement would, in theory, address our concerns, there is much uncertainty about the availability of public or private funds to bring this about and, most importantly, it is unknown whether the wetlands and dune habitats that support the site’s unusual plants are within the proposed easement area.
CNPS recognizes the value of maintaining public access to the Tomales Dunes and the special difficulty of balancing this interest with resource protection in this matter. Still, the fact that the campground has existed illegally for decades should not absolve the applicants of the responsibility to protect and manage the site’s unique natural resources. CNPS is counting on the Commission to enforce the provisions of the Local Coastal Program by assuring that the project is designed and constructed so as to adequately protect these areas.
Reference: Peter Baye, Biogeographic Assessment of Tomales Dunes, California: Vegetation, Flora and Invertebrates (August 2004)
The California Coastal Commission will be reviewing the status of Lawson’s Landing on July 13th at the Marin Civic Center around 10:00 AM. Please join these hearings to ensure Lawson’s Landing is properly protected.