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HomeMy WebLinkAboutLCPA 92-01; Aviara Phase III; Local Coastal Program Amendment (LCPA) (13)i - I Stat. of Caliinia z Memorandum To 'Mr. Chuck Damm Dote : July 11, 1994 2- California Coastal Commission 3111 Camino Del Rio North, Suite 200 San Diego, Caljfornia 92108-1725 .i I. LI .. .. b ,. Cd I-- From : Department of Fmh and Gam. Local Coastal Plan Amendment for the Aviara Phase 111: LCPA 92-01, San Diego County Subject : Department of Fish and Game (DFG) biologists familiar with the area, including the DFG Natural Community Conservation Planning (NCCP) staff, have reviewed the referenced LCPA Coastal Sage Scrub Mitigation Program and offer the following comments: 1. Page 2, paragraph one under "Existing Site Conditions": Chaparral habitat on site is categorized as either chamise chaparral or southern mixed chaparral. However, the presence of Del Mar manzanita (Arctostaphylus glandulosa spp. crassifolia) and warty stem ceanothus (Ceanothus verrucosus) indicates that some, if not all, of the southern mixed chaparral on site should be classified as southern maritime chaparral. This plant community is considered sensitive by both the DFG and the U.S. Fish and Wildlife Service (USFWS), and several plant species (e.g., Del Mar manzanita) within this community have been proposed for placement on the Federal endangered species list. The preferred method of mitigation for this habitat is on-site preservation. habitat type, including transplantation of Del Mar manzanita, has not been successfully demonstrated. How impacts will be mitigated if the transplant efforts fail, needs to be discussed in the mitigation and monitoring reports. If on-site mitigation is not biologically sound, it may be more appropriate to acquire and protect southern maritime chaparral habitat off site than to try to recreate it on site. The DFG is concerned that creation of this 2. Page 3, "Grading Regulations - California Gnatcatcher": Item A - The breeding season for the gnatcatcher is not March 1 through June 1, but February 1 through mid-August. Items B through D - No habitat grading or removal should occur during the gnatcatcher breeding season. Gnatcatchers. commonly renest through the breeding season and may bring off multiple clutches of young. Therefore, finding no nest in a particular location at a particular time in the breeding season does not mean that site will not be used later in the season. Also, 100 foot buffer zones around gnatcatcher nests may protect a nest, but if all of the foraging habitat around it is removed, the nest will fail. I Mr. Chuck Damm July 8, 1994 Page Two The DFG does not agree that removal of gnatcatcher habitat during the breeding season is appropriate, and it is inconsistent with the NCCP criteria for the issuance of a habitat loss permit under the 4(d) Rule. 3. Page 4, paragraph 2, last sentence: The report states that "...it is expected that coastal sage scrub habitat may become established in time" on the habitat enhancement sites. This would seem to indicate that chances for a successful restoration are not very high. appropriate to acquire and preserve coastal sage habitat off site if on-site restoration is not likely to be successful. It may be more 4. The DFG agrees with the basic seed mixes and planting- strategies proposed in the mitigation plan, although we are concerned that supplemental fertilization and irrigation of revegetation areas may be counterproductive and encourage weeds more than native plants. We recommend that a nursery with experience in revegetating native sage scrub and chaparral species be consulted on this issue before the mitigation plan is begun. 5. To adequately evaluate the mitigation program, the DFG needs to review the monitoring program. detail how revegetation will be monitored, success criteria for evaluating progress and mechanisms to deal with not meeting the goals of the plan. A minimum of 5 years of monitoring and maintenance should be required. From a regional perspective, the DFG is concerned with the This program needs to Aviara development adding to the cumulative impacts to coastal sage scrub, southern maritime chaparral and the California gnatcatcher. The City of Carlsbad is in the process of developing a Habitat Management Plan (HMP) that would establish a habitat preserve system within the City to conserve sensitive biological resources and help avoid future listings of species. The City's HMP is part of a North County regional habitat conservation plan (Multiple Habitat Conservation Program, or MHCP) which is a cooperative effort between the North County jurisdictions and landowners to deal with the same natural resource aiid economic issues. The MHCP is also part of a State- sponsored regional conservation program, NCCP, focusing on preserving coastal sage scrub habitat. Several projects within the City of Carlsbad are seeking Commission and wildlife agency approval at this time. Aviara Phase 111, Bramalea of California and Poinsettia Hills Ltd. are Mr. Chuck Damm July 8, 1994 Page Three all projects within fairly close distance to one another. occur in or affect Preserve Planning Area #4 within the City of Carlsbad's proposed HMP. The DFG is concerned that the approval of these projects at this time will result in increased habitat loss and fragmentation within this preserve planning area, which could preclude the establishment of a portion of the City's preserve system. The DFG believes that these projects should be processed after the City's HMP has been finalized to assure that preserve plannhg options are not prematurely and irrevocably lost and that these projects conform to the design and mitigation guidelines necessary to create a preserve system. Because of previous development in this area of the City, the number of options for habitat connectivity is already reduced. If the City of Carlsbad, at this time, can demonstrate that the buildout of these projects will not jeopardize the HMP, that would alleviate DFG concerns on regional conservation issues. All Thank you for the opportunity to comment on this project. Any questions regarding this subject should be addressed to Mr. Tim Dillingham, Wildlife Biologist, at our San Diego office, (619) 525-4215, or Mr. David Lawhead, Environmental Specialist, at (619) 688-0116. cc: Dr. Larry Eng, NHD Department of Fish,and Game Sacramento, California Mr. Tim Dillingham Department of Fish and Game San Diego, California Mr. David Lawhead Department of Fish and Game . San Diego, Cal!.fornia Mr. Ken Corey Carl'sbad, California - U.S. Fish and Wildlife Service Region 5 Mr. Gary Wayne, Assistant Planning Director City of Carlsbad Planning Department Carlsbad, California