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HomeMy WebLinkAboutLCPA 02-10; Habitat Management Plan; Local Coastal Program Amendment (LCPA) (36)US Fish and Wildlife Service Carlsbad Fish and Wildlife Office 60 10 Hidden Valley Road Carlsbad, California 92009 California Department of Fish & Game South Coast Regional Mice 4949 Viewridge Avenue San Diego, California 92123 (760) 43 1-9440 (858) 467-4201 FAX (760) 431-5902 FAX (858) 467-4299 In Reply Refer to: FWS-SDG-847.2 Mr. Mike Reilly, Chair California Coastal Commission San Diego Coast District 7575 Metropolitan Drive, Suite 103 San Diego, California 92 108-4402 Re: City of Carlsbad Local Coastal Program Major Amendment 1-2003B Dear Mr. Reilly: The California Department of Fish and Game (Department) and U.S. Fish and Wildlife Service (Service), the wildlife agencies, have reviewed the Carlsbad LCPA No. 1-03B, including the second addendum to the Carlsbad Habitat Management Plan @IMP). The wildlife agencies have worked for several years with the City of Carlsbad to develop its HMP, which provides for significant conservation of important habitat areas supporting many sensitive species, as well as delineates appropriate areas for focusing development, consistent with the joint state and federal regional conservation planning effort, the Natural Community Conservation Planning (NCCP) program. The HMP represents one subarea planning unit within the larger north San Diego County subregional conservation planning area, known as the Multiple Habitat Conservation Program (MHCP). We believe that the LCP Amendment, with the California Coastal Commission (Commission) staffs suggested modifications, represents an appropriate balancing of the goals and objectives of the NCCP and the Coastal 14ct. Implementation of the HMP and LCP Amendment (modified) will result in more predictable, efficient and focused growth and development; greater overall conservation of sensitive biological resources; more open space that is accessible to the public; and management of those open space lands. We are in support of Commission staff recommendation of approval of the City of Carlsbad Local Coastal Program Amendment as modified by the May 22, 2003, staffreport. We are also support the Commission staff recommendation for a conditional concurrence regarding the Federal consistency determination. The HMP proposes to preserve large, contiguous blocks of habitat that support the highest concentrations of sensitive species, with linkages to ensure that these large blocks remain fbnctional. Consistent with a key tenet of conservation biology, the resulting reserve system will avoid the potential for fragmentation of habitats that often results from the application of avoidance and mitigation requirements in the absence of an overall conservation strategy. Individual projects that are processed through the HMP will conserve the majority of the sensitive c Mr. Mike Reuy cF\Ns-SDG-847.2) 2 resources on-site or mitigate fbr unavoidable impacts by assisting in the acqujsitiodprotection of areas that have been identified as important to the long-term. The HMP emphasizes development to be focused in less-sensitive locations, although this would not avoid all impacts to EnVironmerrtany Sensitive Habi;tat Areas @SHA). However, by emphasi conservation of the meas that support the highest resource values, and allowing existing fragmented or less-sensitive meas to be impacted, the overaU comervation benefits are rmximimd. Within the context of the proposed habitat reserve system, the cornbination of avoidance and mitigation will provide more conservation than could occur in the absence of the HMP. This approach to balancing cowmation goals between &e NCCP and Coastal Act has been considered and was adopted by the Coastal Commission kt its approval of the City of M&%u LCP Land Use Plan (September 13,2002). The Land Use Policies ofthat LCP state that “If a comprehensive NCCP is certified by the Commission as consistent with the: Coastal Act through amendment to the City of Malibu LCP, the ammdmmt will include revised ESW maps and criteria as appropriate, which designate meas of ESHA where development can be dowed and areas that wiu continue to be protected and will be managed in pephuty fbr their ecological resource values.” We believe that the crtrlsbad HMP (with second addendum) and the LCP amendment (with suggested modifications) fuuy meet the expectations ofthe Coastal Commission to provide for the conservation of coastal resams, the regional conservation goals of the wildlife agencies, and the economic and social goals of the City of Carlsbad, We greatly appreciate the hard work of tbe Coastal Commission and City st& to reach an equitable balance between the LCP and HMP processes. Please contact Mi. Bill Tippets, Deputy RegiOnal Manager (Depwtmenk), at (858) 467-4212 or Ms. Lee Ann Carranza, Chiec North San Diego Branch (Service), at (760) 43 1-9440, if you have any comments regardiag this correspondence. Sincerely, I/ C. F. Raysbrook Regional hhager South Coast Region CA Department of Fish and Game Field Office Supervisor Carlsbad Fish and Wildlife Office U. S. Fish and Wild& Service cc: CA Department of Fish and Game Ron Rempel, Deputy Director, HabiW Conservation Division