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
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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.
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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