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HomeMy WebLinkAboutCDP 97-25; Carlsbad Municipal Golf Course; Coastal Development Permit (CDP) (15)IOUNQtO 1111 sari Diego chapter, Sierra club office (619) 299-1743 3820 Ray Street Conservation (619) 299-1743 California Coastal Commission 7575 Metropolitan Drive, Ste. 103 San Diego, CA 92108-4402 June 9,2003 RE: Coastal Commission Hearing on June 12,2003: LCP Amendment - City of Carlsbad; Substantial Issue - Appeal (Golf Course) Dear Commissioners: INTRODUCTION The San Diego Chapter of the Sierra Club has been involved in the Multiple Habitat Conservation Program (MHCP) planning process since its inception. Our reprcsentativcs have served on the Advisory Committee and, in April 2002, we joined with scveral other conservation organizations to write a detailed comment letter on the draft EIS/EIR for the MHCP. The City of Carlsbad's Habitat Management Program (HMP) is a subarea plan under the MFICP, Our letter on the draft MMCP EISEIR included detailed comments on the HMP. Those comments (and the responses thereto) are available from the Sierra Club upon request. The LCP Amendment that you are considering today incorporates the MMP, including the proposed City of Carlsbad golf course, part of which is in the Coastal Zone. DISCUSSION The San Dieg6 Chapter of the Sierra Club supports regional habitat planning and acquisition of valuable habitat by public agencies for inclusion in the MHCP Preserve. The purpose of the Preserve is to protect endangered, threatened, and other sensitive species and their habitats. We have been working to protect the maximum amount of remaining valuable habitat in the MHCP study area, since over 70% of the natural land in this area has already been lost to development and other uses. In our April 2002 comment letter on the Carlsbad HMP, we expressed numerous concerns. We were disappointed that the City of Carlsbad made no substantive changes to the HMP in response to the comments that we wrote. However, we understand that they have been responsive to the Coastal Commission's concerns and that they have provided a second addendum to the HMP and Carlsbad LCP that addresses some of the Commission's concerns. Our comments that follow are based on the Commission's staff reports of May 7,2003 (report on golf course issue) and May 22,2003 (staff recommendation on LCP Amendment including HMP), discussion with Coastal Commission staff (Keri Akers), and the second addendum to the HMP, which was attached to the May 22 report. In general, the revisions to the HMP as described in the staff report of May 22 are positive, and we appreciate the work that has been done by both the City and the Coastal Commission to improve the HMP. However, there are some concerns that we want to bring to your attention. Section I includes concerns other than the golf course; Section I1 contains concerns about the golf course. I. CONCERNS AND ISSUES (other than golf course) a. Continuing loss of valuable habitat (called ESHA in your staffs reports). The MHCP identifies the Biological Core and Linkage Area (BCLA), which includes all large contiguous areas of habitat, all areas supporting major and critical species populations or habitat areas and all important functional linkages and movement corridors between them. The Final h4HCP Plan states, "Conservation of large habitat areas and functional linkages and corridors should be maximized within the final preserve." (Final MHCP Plan, Vol. 1, p. 2-21). While the Sierra Club would like to see every remaining piece of valuable habitat in the MHCP protected, we realize that preserving large blocks of habitat makes the most sense. Therefore, we have become used to the idea of loss of some sensitive habitat provided that there is appropriate mitigation in areas that contribute more to an optimal Preserve design. Therefore, we are not adverse to loss of some habitat provided that mitigation measures are appropriate. The mitigation measures detailed in your staffs report of May 22 seem appropriate. Your staffs report of May 22 spells out mitigation requirements for loss of ESHA: 2: 1 for coastal sage scrub 3: 1 for all other rare native vegetation except wetlands 3 : 1 for riparian areas 4: 1 for vernal pools, other seasonal wetlands and salt marsh We acknowledge the California Public Resources Code requirements as they relate to impacts to wetlands (see page 39 of the May 22 report). We note that that on page 41 of the May 22 report, paragraph 1 states, "The HMP will promote the continuing conservation of existing wetland areas and protect their biological hnctions through concentration of development away from existing wetland resources and establishment of appropriate buffer areas. No negative impact to wetlands is anticipated as a result of the proposed amendments to the Mello I, Mello I1 or Agua Hedionda land use plans. If permitted impacts to a wetland are allowed consistent with Section 30233 requirements, mitigation shall be provided at a ratio of 3: 1 for riparian impacts and 4: 1 for saltwater or freshwater wetland or marsh impacts. 'I This seems satisfactory. Mitigation should occur as close to the impact site as possible. Impacts to ESHA in the Coastal Zone should be mitigated in the Coastal Zone, except under highly unusual circumstances. We note that there is a statement in the May 22 report that casts some doubt on where mitigation may occur. The statement is at the end of the first full paragraph on p. 20 and reads, "Habitat mitigation requirements other than the creation or substantial restoration component may be partially or wholly hlfilled by acquisition of existing like habitat and/or retirement of development credits on existing like habitat with permanegt preservation as part of the HMp preserve management plan." Does this mean that rnjtigation pn occur ai?)where in the HMP preserve area? Again, we believe that mitigation for coastal resources should occur in the Coastal Zone, to the greatest extent possible. b. Need to preserve wildlife corridors to link core biological areas. Because the BCLA is so fragmented, it is extremely important that viable wildlife corridors be preserved. We appreciate the Commission's and City's efforts to protect the wildlife corridor on the east side of the Manzanita Partners, Maldonado, Namikas, Suddath, Kevane and Reiter properties, as shown in Exhibit No, 18 of the Second Addendum. The MHCP document, "Biological Goals, Standards, and Guidelines for Multiple Habitat Preserve Design" (Ogden, Feb. 1998), which was intended to guide development of the MHCP subarea plans, contains design guidelines for wildlife corridors. Item 8. on page 6-4 of that document states that barriers such as major roads through wildlife corridors should be minimized. It is noted that the extension of Poinsettia Lane will cut across the wildlife comdor. The Second Addendum to the HMP (p, 9, item K.) states, "Consider wildlife crossing through Poinsettia Lane if required by wildlife resource agencies.'' It is important that this wildlife undercrossing be part of the plans for the extension of Poinsettia Lane. It should be of sufficient size to allow the largest species using the wildlife corridor to pass under the road. It should also be fenced to channel animals toward the wildlife underpass. We urge that a wildlife undercrossing be included in the plans for the extension of Poinsettia Lane. c. Minimization of edge effects on the Preserve. Because the MHCP Preserve is highly fragmented, edge effects from the activities of humans and domestic animals can have a serious negative impact on the wildlife that the Preserve is intended to protect. Edge effects should be minimized at every opportunity. We note in the May 22 report that some incursions into the protected areas may be permitted. On page 45 of the May 22 staffreport, the first fill paragraph states, "As proposed, the HMP and LUP amendments allow for public recreational trails within the buffers required between development and the preserve habitat areas; however, such trails are limited to the 15 feet of the buffer closest to development. In addition, passive public recreational uses are allowed within the steep slopes and native vegetation on the Veteran's Memorial Park site, with only minimal grading permitted. 'I On page 28 of the May 22 report, the first paragraph states, "The revised language should indicate that deveIopment in steep slopes and native vegetation shall be limited to passive recreational facilities, such as trails and picnic areas. Within the proposed development areas, grading of steep slopes with native vegetation shall be limited to the minimum amount necessary to allow those passive recreational uses." We would rather see no incursions into Preserve areas. However, trails in buffer zones may not do too much damage. But picnic areas that require grading of steep slopes should not be permitted. Picnic areas must be constantly monitored and cleaned up -- picnickers tend to leave food and trash behind, This food and trash can be hazardous to the wildlife in the Preserve. Why create a maintenance headache like this? Pl.gase keep picnic areas out of the Preserve. x --C Other types of edge effects on the Preserve relate to noise and lighting. The MHCP "Biological Goals, Standards, and Guidelines" document, previously cited, states, "Corridors should have a minimum amount of human disturbance, especially at night, and have low ambient noise levels during the time (nighttime) that the target species are expected to use the corridor. Corridors should be shielded from artificial lighting from adjacent development." (p. 6-4, item 7.) We believe that these guidelines should apply to all Preserve areas, not just corridors. The proposed buffer areas adjacent to the Preserve should reduce the noise sufficiently. Lighting could be a problem, especially at the park(s) and golf course. We request that lighting be set well away from Preserve areas and be directed away from the Preserve. Low-intensity lighting is preferred. 11. CONCERNS AND ISSUES (golf course) We concur with the staffs recommendation that a substantial issue exists with the golf course and urge the Commission to concur with that recommendation. Our major concerns with the golf course as described in the staff report of May 7 are: 1. Impacts to wetlands. The golf course described in the May 7 report would include impacts to wetlands. On page 7, the last paragraph states, "Approximately 0.15 acres of wetlands impact are associated with three golf cart paths that are proposed to cross the riparian corridor and streambed to provide access to holes 13 and IS on the north side of the stream. The remaining impacts to wetland resources result from various components of the development (golf holes, driving range, club house, industrial pads and drainage facilities) and are scattered over the site." The Second Addendum to the HMP states that two golf cart crossings of Macario Canyon Creek shall be allowed and that no riparian impacts shall occur for either crossing. (p. 8, item a,) However, the other wetlands impacts that are "scattered over the site" are not mentioned. We would like to be assured that there are no wetlands impacts due to the golf course. In our HMP comment letter of April, 2002, p. 19, item CNPS-107, we stated the following: "Where golf courses are contiguous with native habitat specific criteria need to be provided to prevent adverse impacts on the native habitat from golf course operations. Golf courses have significant and adverse impacts on the environment. These include increased run-off and run-off containing large amounts of fertilizers and pesticides. This run-off soaks into the water table and ends up in our creeks and lagoons. All of the sensitive species that depend upon this riparian habitat are impacted. ... New courses especially should be required to meet the newest standards to minimize golf course impacts." (Reference: Crooks, K.R., and M.E. Soule. 1999. Mesopredator Release and Avifaunal Extinctions in a Fragmented System. Nature 400: 563-566) We would like to reiterate that the golf course is likely to have negative environmental impacts on the Preserve. These impacts result fiom the use of herbicides and pesticides and the pollution of the runoff and groundwater due to these sources and to fertilizers. The creek in Macario Canyon flows into Agua Hedionda Creek and Lagoon. As you know the lagoon is on the 303(d) list as an impaired water body. Agua Hedionda Creek is proposed for listing as an impaired water body due to TDS. How to keep pollutants fiom the golf course out of these water bodies needs to be researched and addressed in the golf course proposal. Thank you for considering our concerns related to the LCP amendment and the golf course issue. We sincerely appreciate the work that the Csastal Commission and its stafF has put into protecting the valuable coastal resources in the Carlsbad area. ~ x Sincerely, Eric Bowlby, vc Co-Chair, Coastal Committee Sierra Club, San Diego Chapter cc: U.S. Fish and Wildlife Service California Department of Fish and Game ,