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HomeMy WebLinkAboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (29)-1 P.O. BOX 2736. LEUCADIA, CALIFORNIA 92024 January 17, 1994 Planning Commission City of Carl sbad 1200 Csbd. Village Dr. Carlsbad, CA 92008 RE; CARLSBAD PARTNERSIGREEN VALLEY DRAFT EIR Dear Commissioners: Thank you for this opportunity to comment. The Friends oppose any impacts to the natural resources on this property. We appreciate the planning which is centered on the disturbed and previously farmed portion of the property. We are also pleased to see that the vegetated portions of the property will be left intact. However, even this careful planning does not address all impacts sufficiently. r Bridging Encinitas Creek will adversely impact the riparian area. Encinitas Creek is historical Bells Vireo habitat. What are the rules for protection of Bells Vireo habitat? What is the City doing to assure that these protections are carried out? What area of buffer is needed to assure the continued use by Bells Vireo in this habitat? We support the recommendation of the Draft EIR that the extension of Leucadia Boulevard be the access ta this development and that the Levante crossing be eliminated. We also would like to see the density of this project be further reduced so that the crossing at Calle Barcelona could be eliminated. What density of development would be allowed if the Leucadia connection were the only access to this property? BUFFER ZONE What is the justification for the 50 foot buffer? Since this creek is easily accessible to human and ferral animals, a wider buffer should be set aside. r The purpose of the buffer is to protect the wild area from intrusion. Birds and animals require a space separation from human contact. The more narrow the riparian area, the wider the buffer should be. Allowing a trail sustem INSIDE the 50 foot buffer reduces the buffer to less than 50 feet. When a trail sys,tem is allowed INSIDE a buffer zone, that space cannot be called a buffer. What is the Resource Agency prosition concerning this problem? We ask the decision makers to require the trail system to be OUTSIDE the buffer zone. Will you require the trail system to be OUTSIDE the buffer zone? FIRE CONTROL ZONES Too often, construction in allowed so close to natural areas that it is necessary to depopulate or thin out natural areas in order to protect buildings. The bluffs in this area are populated by Southern Maritime Chaparral which is not replaceable and which does not recover when soil is disturbed. Where exactly will it be necessary to disturb the cliff vegetation for reasons of fire prevention? We would like specific maps or photos and overlays. The information in the DEIR is inadequate in this aspect. Fire prevention intrusion into natural areas is dealt with in general terms of degree and height of slope. Disturbance of native vegetation is not quantified, and locales are not specified. Will you please add this information to the DEIR? r GNATCATCHERS We have specific information concerning gnatcatcher sites that is not specified in the DEIR. We would like to see a site map with gnatcatcher sightings marked. Will you provide this information? Gnatcatchers fly low, and auto traffic is hazardous to them. What provisions are being made to assure that these birds can disperse to the lagoon? Across the property to Encinitas Creek? East along the creek to inland areas? Do gnatcatchers use or inhabit any of the portions of native plants that wiil need to be adapted for fire control reasons? If so, where? And how can these portions be set aside? COMMERCIAL LIGHTING 24 hour lighting on this property is not acceptable. Will it be possible to impose a lights-out time period for parking lot and commercial 1 ighting? IMPACTS BY CHILDREN AND PETS These bluffs may be steep, but nothing is too steep for determined children and pets. Because the vegetation, Southern Maritime Chaparral, is so rare and will not grow except in hard sandstone, and because pet's and children's feet will soften the soil so that it will no longer support Southern Maritime Chaparral, we ask that no pets be allowed in the proposed apartments, that education concerning the chaparral be presented to the occupants of the housing at least yearly, that the bluffs be thoroughly and completely set off limits, and that a security guard be hired in perpetuity to protect these bluffs from intrusion. Will you comply with the above requests? What assurance do we have that the bluffs will be protected? ,/- DESILTATION/DEPOLLUTANT BASINS Will these basins be large enough to protect the lagoon during the 100 year floods? BLUFF EDGE: According to the maps in the DEIR, the edges of the existing bluffs will be graded. This is not acceptable. What is the quantity of intrusion that is being allowed into the bluffs and existing vegetation? Since southern Maritime Chaparral cannot be mitigated, revegetating the upper canyons cannot be used to allow intrusion into the bluff. Are we reading the maps correctly that destruction of Southern Maritime Chaparral is being allowed? If not, esactly what plants are included in those posrtions that will be graded, and what is their biomass? c REVEGETATION PLANT SURVIVAL RATE The Deir states the plant survival rate must be at 80% at 2 years. Is this the end of the monitoring? What about at the end of 5 years? 10 years? When does the proponent’s obligation cease? Who is obliged to oversee the protection of native vegetation after 2 years? Who will oversee the success of non-success and replanting of the revegetated areas through time? MONITORING BIOLOGIST Who is the monitoring biologist? To whom is this biologist responsible? Who will pay his/her salary? Who will read hislher report? What will be monitored by the monitoring biologist besides pest control? What constitutes a pest? Raptors nest and feed around Batiquitos Lagoon. Ground squirrels and rabbits a.re choice morsels for raptors. Gnatcatchers feed on insects. Would these be considered pests to a monitoring biologist? If so, why? - What would a gopher or ground squirrel have to do to be considered a pest by a monitoring biologist? Under what circumstances would a monitoring biologist be allowed to kill insects? Who monitors the monitoring biologist? REGIONAL IMPACTS The intersection of Olivenhain Road and El Camino Real will fail whether this project is built or not. Encinitas Creek is designated a wildlife corridor by the MHCP, but no plans are being made to assure its continued use by wildlife. La Costs Boulevard is being widened with no wildlife crossings being planned. Southern Maritime Chaparral on the bluffs will be destroyed and the bluffs breached by the Leucadia connection. Under all this pressure, regional planning is impotent if not collusive. We announce the failure of Governor Pete Wilson’s Natural Communities Conservation Plan to provide guidance or help in this area. We denounce the collection of development plans that are being pushed forward without regard for the natural resources of this area. We ask what Carlsbad intends to do, if anything? to coordinate development with other jurisdictions that will reduce impacts to this area, the bluffs, the creek, the lagoon, and the wildlife? What will Carlsbad do to assure that Encinitas Creek becomes a wildlife corridor as recommended by the HMP and the MHCP? Very truly yours, I Dolores Welty Conservation Chair