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HomeMy WebLinkAboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (71)Sweetwater Environmental Biologists, Inc, 3545 Camino del Rio South, Suite 0. San Diego. California 92108 (619) 284-4165 FAX 284-4216 c- March9, 1993 Ms. Sarah Madson Coleman Planning Group 138 Escondido Avenue, Suite 209 Vista, California 92084 Re: Justification for additional rare plant surveys Dear Sarah: Sweetwater Environmental Biologists, Inc. (SEB) is pleased to provide you with our justification for the additional rare plant surveys. In reviewing the survey methodology and the Plant Species of Concern tabIe in the report, we found the following items were lacking and would need to be accounted for with additional surveys. 1. The surveys conducted were not done at the appropriate time of year for several sensitive plant species. Unless the applicant specifically surveyed during the flowering period for these species their presence on site is not known. The table in the Existing Conditions Section of the report details sensitive species that were both observed and/or are expected to occur onsite. It does not indicate whether specific surveys for each species was completed. For example, San Diego thornmint, listed as endangered in California and is a candidate for federal listing, is described as occurring in Encinitas and not onsite. However, unless a specific survey was conducted during the flowering period of San Diego thornmint (ApriVMay), its presence onsite will not be known. This same justification can be provided for each of the sensitive species described in my letter dated March 8, 1993; Orcutt's spineflower (MarcWApril), thread-leafed brodiaea (May), short-leafed dudleya (ApriMay), Orcutt's brodiaea (MayIJune), San Diego goldenstar (March- May), Blocban's dudleya (May/June), Palmer's grappling-hook (MarcWApril), Encinitas baccharis (AugudSeptember) and Del Mar sand aster (AugustISeptember). 2. Because of the expected impacts to diegan coastal sage scrub and/or southern maritime chaparral, SEB recommends that these detailed surveys be conducted for the open space areas as well the impacted area. Except for Spiny rush, no population estimates for the species found onsite were provided. This is significant because if there are impacts to a species, it is impossible to determine the significance of the impact. For example, if bidogicol studies wildlife management hobnat restorutix environmental reSBOIch regulatory compliance resource planning. assesvnent. ond mitiQotion revegetotion planning, implementuhon. and monitoring 1 *r .-.. -. there were 100 individuals of a certain species that were impacted onsite and only 100 individuals of a certain species are known to exist that impact would be considered significant. Therefore, population estimates are essential to a thorough impact analysis. Further, as a part of the mitigation requirements, the applicant is keeping the bluffs as open space. However, due to the limited sumeys conducted in the bluff area, species present as well as populations estimates are not known. This lack of information does not allow the client to quantifL the species present in open space versus the species impacted. One item of note, in my original proposal I erroneously indicated that vireo surveys should be completed between March 15 and July 15, those dates should be April 15 and June 15 respectively. Therefore, the soonest a biological technical report could be submitted would be June 15, 1993 and that would not include the August/September rare plant survey. The information from these later surveys could be addressed at a later date but may cause delays to the project if significant populations of sensitive species are founci. To avoid this problem, SEB recommends that the client wait until the mid to end of September for the completion of the report. If you have any fbrther questions or comments, please don't hesitate to call or have Christer call SEB directly. Thanks for all your support. Sincerely, Susan Brownlee Chief Financial Officer i 1 I, CURRENT ENROLLMENTlENROLLMENT CAPACITY IN PERMANENT & PORTABLE CLASSROOMS IN SCHOOLS IN THE SAN DlEGUlTO UNION HIGH SCHOOL DISTRICT DIEGUEAO JR. HIGH SCHOOL 1 19(38%) 401 OAK CREST JR. HIGH SCHOOL 23 (53%) 549 SAN DlEGUlTO I HIGH SCHOOL 30 138%) 713 1 ., EARL WARREN JR. HIGH TORR EY PINES I .. I SUNSET HIGH SCHOOL 9 (100%) 135 I TOTAL I 116(39%) 2586 31 934 (62%) 1309 1319 385 101 20 564 (47%) 1113 1053 489 249 50 1375(62%) 2088 1890 515 173 .. I 22 645(54%) 1052 890 245 165 NIA I 135 I 182 I 182 I 95 185 5221(61%) 7781 7234 201 3 622 NOTE: Enrollment over 30% State standards for portable/relocatable teaching stations expressed as: % of portable capacity over 30% X total teaching stations X district loading standards 28 students X 90% at jr high school level or 30 students X 85% at high school level EJHlbas 1 1/3/93 enrcap.cht 93/94