Right of Entry License Agreement for San Diego Bay Nonnative Sea Lavender Mapping and Control


SCH Number
Public Agency
San Diego Unified Port District
Document Title
Right of Entry License Agreement for San Diego Bay Nonnative Sea Lavender Mapping and Control
Document Type
NOE - Notice of Exemption
Document Description
The proposed project is a Right of Entry License Agreement (ROELA)/ Right of Entry (ROE) to Conservation Biology Institute (Licensee/Grantee) to enter certain properties located in wetlands areas throughout District Tidelands. The area proposed for use under this ROELA/ROE would be used by the Licensee/Grantee and their authorized agent(s) and contractors(s) for the purpose of mapping and removing two species of invasive, non-native sea lavender: Limonium ramosissimum (Algerian sea lavender) and Limonium durisculum (European sea lavender). Ingress and egress would also be included in the ROELA/ROE in support of those activities. The proposed project is part of a joint effort between the U.S. Fish and Wildlife Service, San Diego Bay National Wildlife Refuge (NWR), Tijuana Slough NWR, U.S. Department of the Navy, California Department of Parks and Recreation, and the District (collectively referred to as the Partners) to map the extent of these sea lavenders throughout San Diego Bay and conduct control efforts for removal. This joint effort currently has funding for one year and is expected to begin in Summer 2022, and if the Partners can secure funding, anticipate an additional four years to continue to map and remove these invasive, non-native sea lavenders. To remove sea lavenders, the Licensee/Grantee would use solarization or tarping, which involves covering the sea lavenders with thick, black landscape plastic for a duration of time (estimated to be approximately 2-5 months, depending on the density of the sea lavender in the area). Tarping or solarization can result in nearly 100% mortality and elimination of the sea lavender plants and their seed banks, and native species recruitment or recovery has shown positive results after tarping, with some results increasing native plant cover after the solarization or tarping treatment. Sea lavenders are currently known to occur at the D Street Fill (Chula Vista), former power plant site (Chula Vista), J Street marsh (Chula Vista), Chula Vista Wildlife Reserve (Chula Vista), and Emory Cove (Coronado), and sea lavender removal treatments would begin at these locations. As the mapping effort continues, if additional sea lavender is identified throughout San Diego Bay, removal would occur in those areas as well. The mapping of the sea lavenders is anticipated to be conducted through Geographic Information Systems technology, however the Partners may conduct field surveys on their respectively managed lands (i.e., District staff would conduct surveys on District Tidelands) to contribute data to the mapping effort. It is anticipated that the ROELA/ROE would have a total term of approximately five (5) years, or upon completion of the work, whichever occurs earlier. The ROELA/ROE may be terminated by the District as a matter of right and without cause at any time upon providing twenty-four (24) hours’ notice in writing to the Licensee/Grantee of such termination. Due to its nature and limited scope, construction of the proposed project would generate a minor amount of vehicle trips and would require limited use of equipment. Therefore, impacts related to air quality, greenhouse gas emissions, and transportation and traffic are not anticipated to occur. Furthermore, the Grantee/Licensee would be responsible for complying with all applicable federal, state, and local laws regarding construction demolition debris, hazards and hazardous materials, and stormwater.

Contact Information

Lily Tsukayama
Agency Name
San Diego Unified Port District
Job Title
Senior Planner
Contact Types
Lead/Public Agency


Chula Vista, Coronado, Imperial Beach, National City, San Diego
San Diego
Southern California
Other Location Info
Wetlands areas throughout District Tidelands

Notice of Exemption

Exempt Status
Categorical Exemption
Type, Section or Code
15304; 15306; 15307
Reasons for Exemption
The proposed project is determined to be Categorically Exempt pursuant to the CEQA Guidelines and the Sections of the District’s Guidelines for Compliance with CEQA as identified below. These are appropriate for the proposed project because: the project involves minor alterations in the condition of land, water, and/or vegetation that would not involve the removal of mature, scenic trees; involves basic data collection, research, experimental management, and/or resource evaluation activities which would not result in a serious or major disturbance to an environmental resource, and it involves actions taken by regulatory agencies to assure the maintenance, restoration or enhancement of a natural resource where the regulatory process involves procedures for the protection of the environment. The District has determined none of the six exceptions to the use of a categorical exemption apply to this project (CEQA Guidelines Section 15300.2).
County Clerk
San Diego


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