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Email Alert #19-b
January 11, 2002
******URGENT ACTION******
Email needed by Thursday, January 17
The Army Corps of Engineers has received an application for a permit to impact wetlands along San Marcos Creek (and other places) in southern San Marcos. These impacts will be caused by phase 1 (Tentative Map I) of the University Commons (UC) development project, which includes 695 residential units plus commercial and industrial units.
As part of the project, the developers (Brookfield/Brouwer) want to extend Melrose Dr. through one of the last remaining patches of coastal sage scrub habitat on the property and a known use area of the endangered California Gnatcatcher. The road would also cross San Marcos Creek, an important wildlife corridor. Further impacts to San Marcos Creek would occur from a realignment of San Elijo Dr. on the southern side of the creek.
There are several problems with the public review documents for this project. For example, it is not clear what the nature of the creek crossing will be. This is critical if San Marcos Creek is to remain a viable wildlife corridor. Also, no alternatives to extending Melrose Dr. are even considered. Because of these inadequacies and the apparent impacts of this project, the Sierra Club is requesting a Public Hearing. Emails and letters from the public are needed in support of this request. In the past, the Army Corps has been reluctant to hold public hearings on these types of permit applications. However, they are very interested in the amount of public interest in this project and if they receive a large number of comment letters they may grant this request.
Send a comment letter to the Army Corps of Engineers regarding the "Application for a Permit to Impact Wetlands (404d permit) by Brookfield/Brouwer (B/B) in the University Commons project in southern San Marcos". In the letter express your concern about the environmental impacts to wetlands from this project and request a public hearing. Some specific talking points and additional information are given below.
The deadline for comments on this application is Jan. 17, 2002.
Comments can be sent by e-mail to: sbryant@spl.usace.army.mil.
They can be mailed to:
U.S. Army Corps of Engineers, Los Angeles District
Regulatory Branch -- San Diego Field Office
ATTN: CESPL-CO--200100025-SKB
16885 W. Bernardo Drive, Suite 300-A
San Diego, CA 92127
1. Please express your concern about the environmental impacts to the wetlands due to the Brookfield/Brouwer project. These concerns include:
2. The extension of Melrose Drive will eliminate one of the few remaining patches of coastal sage scrub habitat on the property. The road extension will cut through a gnatcatcher use area.
3. San Marcos Creek is a recognized wildlife corridor, proposed for 100% conservation in the San Marcos Subarea Plan of the Multiple Habitat Conservation Plan (MHCP). The MHCP guidelines state that roads crossing wildlife corridors should be avoided. If they cannot be avoided, then bridges are the preferred type of crossing, to allow larger mammals such as mule deer to safely cross under the road. The road should also be adequately fenced to direct animals to the undercrossing. The proposed crossing of Melrose Dr. across San Marcos Creek does not appear to be a bridge. However, since the Figure depicting the crossing was not included in the Public Notice package, it is not possible to determine specifically what is being proposed.
4. Alternatives to the proposed project were not included in the Public Notice package. One alternative that must be addressed is not extending Melrose Drive into the gnatcatcher use area and across San Marcos Creek.
5. It appears that the proposed realignment of San Elijo Road along the south side of San Marcos Creek is much too close to the wetlands and that the grading for the road will almost reach the creek.
6. It is difficult to tell from the figures in the Public Notice package exactly where and how the wetlands will be impacted.
7. Because of these concerns and inadequacies in the Public Notice package, please call for a public hearing and support the Sierra Club's request for one.
There are significant environmental issues involved, as discussed in the following summary.
1) The Brookfield/Brouwer (B/B) property includes San Marcos Creek from about a half mile south of the dam at Lake San Marcos all the way to Rancho Santa Fe Road. San Marcos Creek is a regionally significant waterway. On the B/B property, which is currently open space, it provides water resources for wildlife. West of Rancho Santa Fe Road, in Carlsbad, San Marcos Creek flows through a significant landform, Box Canyon. Finally, the creek discharges into Batiquitos Lagoon in Carlsbad.
2) The B/B property is in the middle of the Core Gnatcatcher Conservation Area of the Multiple Habitat Conservation Program (MHCP). Because of the Harmony Grove fire in 1996, a tremendous amount of the gnatcatcher habitat (coastal sage scrub or CSS) in this area was destroyed. However, the Wildlife Agencies have taken the position that fire is a natural successional agent in CSS and chaparral vegetation communities and that pre-existing conditions will recover. According to the Biological Resources Report for the project, the small amount of CSS currently existing on the B/B property is adjacent to San Marcos Creek. Not surprisingly, this is an observed gnatcatcher use area. The developer proposes to construct a major road, Melrose Drive, through this gnatcatcher use area. Just south of the gnatcatcher use area, the proposed Melrose Drive would cross San Marcos Creek.
3) San Marcos Creek through the B/B property is a recognized wildlife corridor. The Biological Resources Study for the project identified 151 wildlife species on the site, including mule deer. The City of San Marcos has proposed 100% conservation of the area surrounding the creek in their MHCP Subarea Plan. The MHCP Guidelines for roads through wildlife corridors call first for avoidance; second, if a road must cross a wildlife corridor, the MHCP guidelines call for a bridge-type crossing, to allow larger mammals, such as deer, to cross safely under the road. The road should also be fenced by at least a 10-foot fence that channels animals toward the wildlife underpass, according to the MHCP guidelines. It is not clear in the 404d permit application what kind of a crossing the developer is proposing for Melrose Dr, but it is not a bridge. It appears to be a culvert, but the Figure that was supposed to describe the crossing was left out of the Public Notice package.
4) In addition to the environmental damage done by building Melrose Dr. across San Marcos Creek, the road building for the project creates pinch points along the creek and wildlife corridor. In particular, it appears hat the proposed alignment of San Elijo Road along the south side of San Marcos Creek is much too close to the wetlands and that the grading for the road will almost reach the creek.
5) There are several wetlands impacts identified in the application package. The exact impacts of each are not identified on the maps, just the general locations. This makes it very difficult to determine exactly what is being proposed.
Because of the above concerns and the inadequacies in the Public Notice document, whose purpose is to inform the public of the exact nature of the impacts to wetlands of this project, the Sierra Club is going to request a public hearing on this permit application.
If you have any questions, please contact Mary Clarke at ClarkeMH@aol.com or at (760) 510-9684
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