HomeMy WebLinkAboutLCPA 02-10; Habitat Management Plan; Local Coastal Program Amendment (LCPA) (5)January 9,2002
City of Carlsbad
Planning Department
Attn: Don Rideout
1635 Faraday Avenue
Carlsbad, CA 92008
Dear Mr. Rideout:
Please accept the following comments on the Proposed LCP Amendment on behalf of
San Diego Audubon Society; Surflider Foundation, San Diego Chapter; Preserve
Calavera; California Native Plant Society, San Diego Chapter; and National Wildlife
Federation. We are pleased that the current LCP amendments for the Carlsbad HMP
provide much stronger protections than the original draft HMP. We appreciate the City’s
good-faith attempt to address the concerns raised in earlier comments. In general the
LCP amendments do a good job of ensuring consistency with the HMP and of complying
with the Coastal Act and habitat conservation planning requirements. We have some
concerns about the following issues and would urge that modifications be made to
address them.
Invasive Plant Species
Our organizations are very concerned with increasing problems associated with invasive
non-native species in the coastal area. We urge you to take an active role in preventing
the spread of invasive plant species. The problems caused by invasives can be witnessed
in any North County coastal lagoon (Buena Vista, Hedionda, and Batiquitos, for
example), and along most major thoroughfares (including 1-5, Palomar, 101, or Canon
Rd.). Pampas Grass (Cortaderia selloana) is the most problematic species, but Tamarisk,
Arundo, Myoporum, and others have found refuge and are taking up too much space in
our natural areas as well. The State of California will soon list the following plants as
noxious weeds Arundo (Amndo dona) and Tamarisk (Turnurix sp.).
The problem lies in the ease of acquiring these invasive species. Homeowners and
developers can readily go into local nurseries and buy Pampas Grass and Myoporum. If
they plant them on property that borders open space the impact to habitat is direct. Even
when planted remotely, the impacts are significant, as both plants are wind dispersed and
can spread their seeds for miles. In order to truly preserve our ecologically sensitive
coastal habitats and protect the public’s investment of tax dollars in the MHCP program,
we feel a greater emphasis should be placed on controlling the widespread use of invasive
exotic plant species.
Please see the enclosed Guide to Environmentally Sensitive Brush Management (City of
San Diego) for a complete listing of invasive exotic plants threatening California’s open
space. We urge the City of Carlsbad to prohibit the use of invasive exotic plants for all
new development within the coastal development. An important supplement would take
h
the form of a public education program to increase the awareness of the habitat
degradation caused by invasive exotic plants as well as the benefits of using native plants
in landscaping (such as the promotion of drought tolerance, increased erosion control,
and improved water quality). Information on this topic is available fiom the Metropolitan
Water District, the California Native Plant Society, and the National Wildlife Federation.
Brush Management
The LCP amendment says that Zone 3 of the brush management zone may occur in open
space areas “when fire retardant planting is permitted to replace high and moderate fuel
species required to be removed.” Appendix A, section d, of the Carlsbad Landscape
Manual (CLM) defines examples of Zone 3 plants. It includes Acacia redolens and
Cassia as typical species found in Zone 3. Acacia redolens and certain species of the
Cassia genus are not native to San Diego and have demonstrated their ability to
naturalize in open spaces and should not be used within or near open space (Zone 3 and 4
defined in the CLM). A better choice for Zone 3 plants would be Heteromeles arbutifolia
(Toyon) and Rhus integrifolia (Lemonade Berry). Although Appendix F of the CLM
identified both Toyon and Lemonade Berry as moderate hazard species in regards to
combustibility, the City of San Diego uses them for fire-resistant planting (please see
enclosure) and we wonder if their appropriateness might be reconsidered.
Habitat Connectivity
One of the most important elements of regional habitat conservation planning is the
increased focus on ensuring habitat connectivity within a region. We are particularly
concerned that planning be coordinated across jurisdictional borders. While we are
aware that the Multiple Habitat Conservation Program (MHCP) cities have been working
together to develop the plan for years, we are concerned with what appears to be
significant differences in the timelines for approval of the various Subarea Plans. We
urge the City to work with the surrounding cities to ensure connectivity.
Additionally, regarding the timelines for approval of the Carlsbad Subarea Plan, it seems
out of sequence to process amendments for a portion (the coastal zone) of the City’s
HMP package when neither the HMP or the regional MHCP plan (tentatively scheduled
for approval by the SANDAG Board on March 28‘h) have yet been approved. It is our
understanding that there will be modifications to the Draft MHCP. How will the city
assure that the LCP Amendments are consistent the MHCP and the HMP (we have been
told the resource agencies have required a new public comment on the City’s permit
application)?
.
Funding
Page 38 (Policy 3-1, 3d Paragraph) of the LCP states that “[Tlhe creation of an effective
habitat preserve requires a careful balancing of acquisition, preservation and mitigation
requirements, as well as enforceable monitoring, remediation, and an adequately funded
maintenance program for the preserve area.” We agree that adequate fbnding is key to
the success of the program. We urge the City to work with SANDAG on identifying a
regional funding source. We also urge the City to make a regular and significant
allocation from its general fund for education, and to institute the Habitat Take Permit
Fee for maintenance, management, administration, etc.
Water Ouali t y
We encourage you to mirror the language for water quality protections in the recently
approved Malibu LCP. Water quality provisions in the proposed LCP amendments
should be at least as stringent as those in the Malibu LCP. Also, it is strongly
recommended that a strong stream buffer zoning policy that is consistent with the
Carlsbad Watershed Management Plan be adopted. This can be found in further detail in
the Carlsbad Watershed Management Plan, section 5-4, Action #l.
Golf course
The golf course design exhibits are not included in the LCP. Please send them to: SD
Audubon, 4891 Pacific Highway, Suite 112, San Diego, CA 921 10 when they are
available.
The Coastal Act explicitly limits allowable impacts to Environmental Sensitive Habitat
Areas (ESHAs). Golf courses are not one of the impactshses allowed. Many activities
permitted in flood plains, such as public parks, golf courses, and agriculture, eliminate or
drastically reduce riparian habitat and are very damaging to riparian wildlife (Faber 1989
- see enclosure). Our wetlands in California have been reduced to 5% of their historic
range; therefore, we strongly oppose the development of the golf course in sensitive
wetland areas.
It has been proven by scientists such as Phyllis Faber that a Golf Course has negative
impacts to its surrounding areas. Golf courses within the coastal zone are of particular
concern because of the potential for leaching of biocides and fertilizers into ponds and
coastal waters. These chemicals then enter the food web and degrade water quality,
thereby threatening animal and human health. Research has found that the average golf
course uses the following: 200 tons of fertilizer per month, 18 pounds of pesticide per
treated acre per year- 5 times as much as agriculture, and 1,000,000 gallons of water per
day. New golf course designs have become more environmentally friendly, but the
specific requirements to assure that have not been built into this LCP or the city’s general
guidelines. An example of such a course is at Kiawah Island in South Carolina, adjacent
to a fragile coastal wetlands area. Standards to assure such design need to be adopted
now.
Additionally, public opinion puts open space ahead of public golf courses in terms of
priority. In 1999 and 2000, the City of Carlsbad conducted public opinion surveys to
ascertain the attitudes and concerns of residents regarding the quality of life in Carlsbad.
For two years in a row, residents named excessive growth and development as their top
concern, followed closely by increasing traffic congestion. In addition, the preservation
of open space was residents’ top priority with regard to city programs and facilities.
When rating the importance of facilities, “Open Space” was first, followed by “Nature
Trails,” “Swimming Pools,” “Basketball Courts,” and finally, “Public Golf Courses.” We
urge you to consider this information when analyzing the potential golf course.
Thank you very much for considering these comments.
S inc ere1 y,
Allison Rolfe, San Diego Audubon Society
Marco Gonzalez, Surfrider Foundation, San Diego Chapter
Diane Nygaard, Preserve Calavera
Carolyn Martus, California Native Plant Society, San Diego Chapter
Steve Torbit, National Wildlife Federation, Western Natural Resource Center