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HomeMy WebLinkAboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (37)I Southwest Research Associates Incorporated t 3 November 1993 Mr. Christer Westman City of Carlsbad 2075 Las Palmas Drive Carlsbad, CA 92009 Dear Mr. Westman; Southwest Research Associates, Inc. (SRA) has carefully reviewed the Draft Environmental Impact Report (DEIR) for the Green Valley Master Plan. The proposed development plans show good faith efforts to mitigate the environmental impacts associated with this development, however, our review identified a number of serious deficiencies that should be addressed before the EIR is finalized. Biology - 1. The DEIR indicates that the project will result in the take of 1.0 acres of salt marsh habitat, without describing any mitigation measures. Insofar as salt marsh habitat is the single most depleted habitat type in California, take without mitigation is unacceptable. The DEIR Executive Summary indicates that the project proponents propose to mitigate this take by creating 2.0 acres of new salt marsh habitat. SRA recommends that mitigation be based on a ratio of 3 to 1 as proposed for the riparian take (considering restoration and enhancement). SRA recommends that the salt marsh mitigation be done onsite or in Batiquitos Lagoon. Mitigation plans for both the salt marsh and coastal scrub habitat restoration must include provisions for long term monitoring (5 year) and objective success criteria (typically >go%). The project proponents should be required to place funds for monitoring and replanting in an escrow account. 2. The DEIR indieires ths+ the pm-icct vi!! rrsn!r in ~?e :&e of 0.6 acres of cozstd sage scrub, Given the extreme depletion of this habitat type, SRA recommends that the project be redesigned to avoid this take. If the project proponents are unwilling to avoid this impact by redesign onsite revegetation mitigation should be required at the 5 to 1 ratio used to offset other coastal sage impacts on the site, and under the same terms and conditions of restoration described in comment one above. 3. The project proponents have taken great pains to design span crossings of the riparian corridor that will allow the fauna onsite to travel up and down the riparian corridor. The size of these spans is certainly not an exact science. The only guidance to date has been developed in support of the Otay Ranch project. A specific span to width ratio has been developed for that project and endorsed by the resource agencies. The Green Valley Project proponents maintain - 2006 Palomar Airport Road Suite 207 Carlsbad, California 92008 Phone 619/431-5640 Fax 619/437-8964 c 3 November 1993 Green Valley DEIR Page 2 of 3 they cannot meet these guidelines using the precast span bridges they propose. SRA recommends that if these guidelines cannot be achieved then the number of crossings through the riparian corridor should be reduced from two to one. Alternative access to the project could be taken from the proposed Leucadia Boulevard extension. Reduction in the number of crossings through the riparian corridor would preserve habitat quality. 4. The DEIR describes in detail the measures that are being taken to preserve the bluff and riparian corridors on the property. Unfortunately, as proposed these corridors dead-end at La Costa Avenue, which precludes conr.ection to Batiquitos Lagoon. The need foi a dead-end corridor from the Leucadia Boulevard extension to La Costa Avenue is not clear, and certainly not biologically important. Therefore SRA recommends that the design for this project and the City of Carlsbad’s La Costa Avenue Road Widening be amended to include a span crossing that would allow fauna to use the corridors to reach Batiquitos Lagoon and the natural habitat north and east of the lagoon. Traffic 1. The DEIR does an adequate job of describing the traffic impacts associated with this project. However, it dismisses analysis of the impacts attributable to development of the Ecke property to the south and the Home Depot site to the southeast because they are not currently permitted. While this approach is permissible under CEQA and Carlsbad planning requirements it defies common sense. Certainly odds are that both these projects will go in. Surely some reasonable estimate of the traffic loading associated with these projects can be made. (What are consultants for but to dream up numbers). Given projected traffic levels than an integrated traffic management plan should be developed that will prevent El Camino Real in Carlsbad from becoming grid locked like El Camino Real in Encinitas. The current trend in land use planning is for regional consideration. SRA suggests the City of Carlsbad broaden their horizon’s and consider the cumulative impact of all the large commercial projects proposed for this relatively small and confined area. - Residential Development 1. SRA questions the wisdom of siting a 400 multi-family residential development in close proximity to sensitive natural resources. The presence of high density residential development makes it much more difficult to protect the natural resources adjacent to the project given the proclivities of children and (*) domestic animals to explore and damage the environment. The project proponents recognize this damage and propose to use cactus to as a natural barrier to limit this impact. While this may control children it will not stop cats and dogs. Furthermore when push comes to shove cactus and children are not a good mix and in fact may represent an unacceptable liability to the developer. SRA suggests that the residential development be eliminated or greatly reduced. If the development is not eliminated strict regulations (CC&Rs) rc 2006 Palomar Airport Road Suite 207 Carlsbad, California 92008 Phone 619/431-5640 Fax 619/437-8964 - 3 November 1993 Green Valley DEIR Page 3 of 3 must be enacted and enforced to control of domestic.animals. Cats should be banned from the development and dogs should be kept in fenced runs or on a leash. Convenience Store Development 1. The convenience store development proposed for the corner of La Costa Avenue and El Canizc Real represents ;t? unxzci;~t;!e ixpxt :;, thc, Eakpi:~~ Lagcc-~fi vkwsbcd. Gikm ht the project proponents are requesting over 600,000 square feet of commercial development in the first place, the need for a relatively small convenience store development is unclear. The DEIR should more fully describe the aesthetic and traffic impacts related to this component of the development. Why wasn’t a photo simulation prepared of this area? What will be the impacts on traffic circulation at the corner of La Costa Avenue and El Camino Real? Thank you for the opportunity to comment on this import environmental review document. Sincerely, .. .-- Seth Schulber&--- . . Manager, Environmental Assessment Program City of Carlsbad Parks and Recreation Commissioner Z@B PalomarAirportRoad Suite207 Carlsbad, California 92008 Phone 619/431-5640 Fax 619/431-8%4