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HomeMy WebLinkAboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (22)P.O. BOX 480 OCEANSIDE, CA 920490110 28 January, 1994 Peggy Savary Chairman, Planning Commission Planning Department, City of Carlsbad 2075 Las Palma Dr. Carlsbad, CA 92009 Re: Green Valley Master Plan and Master Tentative Map Agenda items 3598 to 3605 Dear Madam Chairman and Commissioners, Thank you for the opportunity to speak at last week's public hearing on the Green Valley project. We appreciate the careful planning that has gone into the project so far, and the courteous and informative discussions we have held with the Planning Department staff. I would like to clarifL,my oral comments with a written note, subsequent to discussions with Christer Westman of the Planning Department, and informal discussions with Phil Behrends of Dudeck and Associates, biologist for the Carlsbad HMP. 1. Impacts to the Riparian Wildlife Comdor. The EIR lists four measures which can be undertaken to mitigate impacts to the corridor, in order of preference: .- 1. Eliminate both creek crossings. 2. Eliminate Levante Street, and redesign Calle Barcelona. 3. If options 1 and 2 are found to be infeasible, eliminate Calle Barcelona, and redesign Levante Street. 4. If 1-3 are infeasible, leave both crossings in, and redesign them both. It is our understanding that one of these is required. We agree that option 1 is clearly infeasible because of traffic circulation problems. However, options 2 and 3 have not yet been investigated. The project currently assumes that it will use option 4. Fieldstone asked in comment C1 "What effect would the elimination of the Levante access have on the overall traffic and noise impact to Calle Barcelona and the Arroyo La Costa project?" The response concludes #I... no negative impacts would result to that intersection." It would seem that alternative 2 would be feasible fiom the point of view of external traffic flow. We would ask that feasibility of options 2 and 3 be addressed, incorporating an additional crossing at Leucadia boulevard. Associate Planner Westman has indicated that this would not be a major undertaking fiom a planning point of view. Please note that the redesign would not reduce the currently planned number of access routes into the project, but would greatly reduce impacts to the riparian corridor. BVAS r f 2. Site specific review for impacts to the HMP and the MHCP. Although the HMP and the MHCP are still in the planning stages, a mechanism for such review is already in place. A technical committee of the MHCP has been instituted specifically for the Green Valley region, because of its crucial importance to the success of the HMP. The regulatory agencies (USFWS, CDFG) as well as the cities of Encitas and Carlsbad are members of the committee. Such review would provide detailed commentary on potential impacts such as the proposed location of signs in or adjacent to habitat, noise impacts, the appropriateness of buffers, and the appropriateness of the final bridge design. It has been stressed by Phil Behrends to the MHCP that wildlife corridor standards cannot be applied to a project without such site specific review. 3. Further issues. There are fbrther biological issues which have not been adequately addressed in the EIR, although the extra bridge is the major one. These include no mitigation for noise impacts the to the riparian corridor caused by the project. The stated reason is that noise levels are expected to increase in the fiture without the project. Finally, I would like to stress the importance of the riparian corridor as habitat, not only as a wildlife corridor. We have lost over 95% of the willow woodland which used to exist here, which has led to the listing of the least Bell's Vireo, and the imminent listing of the willow flycatcher. Both of these species occur on this site. The two planned bridge crossings would fragment this island of remaining habitat, greatly reducing its value for these species. As the EIR states, the preferred mitigation is "no impact", which would mean no creek crossing at all. In light of this, it seems very reasonable to ask project proponents to do a feasiblity study to move one creek crossing firther nnrtb Thank you for your time and consideration. Sincerely, Karen Messer Conservation Chair cc: Christer Westman, Planning Department Don Rideout, City of Carlsbad Nancy Gilbert, USFWS Fred Worthley, CDFG WAS