Oceano Dunes sits on California’s Central Coast as part of the Guadalupe Nipomo Dunes complex, one of the largest intact coastal dune systems in the state. Oceano Dunes State Vehicular Recreation Area is one of the only remaining places in California where the public can lawfully recreate with off-highway vehicles on the beach and in the dunes. For generations, this area has supported family recreation, outdoor tourism, and the local economy while remaining home to sensitive coastal species.
For years, however, Oceano Dunes has faced sustained closure pressure. Anti-access interests have repeatedly used litigation and regulatory leverage including the Endangered Species Act to pursue permanent elimination of motorized recreation rather than balanced conservation. As a result, access at Oceano Dunes has often been dictated by rigid restrictions instead of adaptive, science-based management tied to species recovery.
The U.S. Fish and Wildlife Service is now considering an Incidental Take Permit and Habitat Conservation Plan for operations at Pismo State Beach and Oceano Dunes SVRA. There are 4 alternatives to this plan, and BRC supports a modified version of Alternative 2 because it reflects how the Endangered Species Act is intended to be administered, and it will allow for continued and/or expanded access for OHV use on Oceano Dunes. Public comments are accepted through January 23, 2026.
Endangered Species Act Background in Oceano Dunes
The Endangered Species Act is the nation’s primary law for protecting imperiled plants and animals. Its purpose is not only to prevent extinction, but to promote the recovery of listed species so that they no longer require federal protection. The Act prohibits the take of listed species unless authorized through specific mechanisms such as an Incidental Take Permit supported by a Habitat Conservation Plan. This framework allows lawful activities to continue while ensuring impacts to listed species are minimized, mitigated, and managed using the best available science. The Fish and Wildlife Service is considering issuing an incidental take permit and habitat conservation plan for the SVRA.
This new incidental take permit will authorize California Department of Parks and Recreation to take (kill or harm) four animal species (California least tern, tidewater goby, western snowy plover, and California red-legged frog) incidental to otherwise lawful activities that are authorized by a Habitat Conservation Plan developed by CDPR (see below). The activities allowed by the plan include motorized and non-motorized recreation activities and wide range of activities related to protecting and studying these four species. While it is rare that any of the approved activities could lead to the take of the protected species, the purpose of the incidental take permit is to set an allowable limit of impact to these species as long as measures to minimize and mitigate impacts are followed. Taken together, the take permit and habitat conservation plan are designed to allow continued recreation in the area while also allowing for the best science to be used to recover these species.
The Draft Habitat Conservation Plan evaluates four alternatives:
The No Action alternative would deny the permit, leaving State Parks without ESA authorization and increasing the likelihood of enforcement actions, litigation, and sudden closures.
The Proposed Action alternative (Alternative 2) would issue a permit using an adaptive, performance-based management approach. Under this alternative, protective areas could be reduced after measurable biological performance and recovery standards are achieved.
The Maintain Current Exclosure alternative would issue a permit but lock existing closures in place regardless of habitat conditions or species response.
The Year-Round Exclosures alternative would impose the most restrictive management and further limit public access.
Why BlueRibbon Coalition Supports Alternative 2
BlueRibbon Coalition supports a modified version of Alternative 2 because it reflects how the Endangered Species Act is intended to be administered. Alternative 2 ties management decisions to measurable biological outcomes rather than permanent or precautionary restrictions. Species protections remain strong, but management actions are accountable, adaptive, and responsive to actual habitat conditions.
Importantly, the Draft HCP documents that portions of Exclosure Areas 6, 7, and 8 have experienced increased vegetation and dune formation that reduce their suitability as nesting habitat. Despite expanded closures, nesting use in these areas has declined. Alternative 2 allows these underperforming areas to be reevaluated and potentially reopened once recovery benchmarks are met, while continuing to protect high-quality habitat elsewhere. The map below shows where these three areas are located.
However, support for Alternative 2 must be paired with clear administrative safeguards. Adaptive management must be mandatory, not discretionary. Access restoration must be an explicit outcome when standards are met. Emergency and seasonal closures must be limited, justified, and reviewed. Take determinations must be based on documented cases of species mortality or harm or measurable biological effects and not assumptions or speculation. Species listed as threatened should require more flexible recovery frameworks and fewer restrictions than species listed as endangered. Without these commitments, even a well-intentioned permit could be misused to justify long-term or permanent closures.
This is especially important given longstanding concerns that some within California Department of Parks and Recreation may view the permit as a ceiling rather than a pathway to recovery-based access restoration. At the same time, the broader federal policy environment is emphasizing more practical, outcome-driven implementation of the ESA, including reconsideration of how “take” is defined and applied. This permit must reflect that shift.reation can coexist and provides regulatory certainty for public access, local communities, and long term stewardship of Oceano Dunes.
Comment in Support
As the last area where coastal OHV use is allowed, we support any management actions that maintain/expand current access. This new Incidental Take Permit and Habitat Conservation Plan provide a chance to update Endangered Species Act restrictions based on updated regulations and scientific understanding. Adopting the proposed action would lead to expanding riding areas. We encourage our members to support this action before January 23, 2026.
