Download San Diego Chapter of the California Native Plant Society P O Box

San Diego Chapter of the California Native Plant Society
P O Box 121390
San Diego CA 92112-1390
[email protected] | www.cnpssd.org
December 10, 2013
Mr. Norman Pedersen
City of San Marcos Planning Division
1 Civic Center Drive
San Marcos, CA 92069
Tel: (760) 744-1050 ext. 3236
Email: [email protected]
RE: San Marcos Highlands Mitigated Negative Declaration Issues
Dear Mr. Pedersen:
We appreciate the opportunity to comment on the San Marcos Highlands ("Project"). Mitigated
Negative Declaration ("MND"). The San Diego Chapter of the California Native Plant Society
(CNPSSD) works to protect California's native plant heritage and preserve it for future generations. CNPS
promotes sound plant science as the backbone of effective natural areas protection. We work closely with
decision-makers, scientists, and local planners to advocate for well informed and environmentally friendly
policies, regulations, and land management practices. We are writing to question the botanical analysis.
Based on our study of the document and a visit to the project location, we believe that significant impacts
were not analyzed, and that the project requires a full Environmental Impact Report EIR, not a Mitigated
Negative Declaration as proposed.
There are three major issues. The reassessment of biological resources is insufficient, the impacts
of mountain bikers and other people are not considered, and MND fails to analyze how the project to will
affect the ability of the impacted vegetation to adapted to global climate change. These last two will
result in substantial, unmitigated impacts. As a result, the Project is likely to generate unmitigated and
unmitigable impacts, requiring a full EIR.
The issue with Mr. Everett's reassessment of biological resources is obvious in the text, quoted
here:
" I reviewed these reports in detail and reviewed the current California Natural Diversity
Database (CNDDB) to determine if any other sensitive species have been reported since
the 1999 field work was conducted. I also examined the 1999 vegetation community
mapping and compared it with recent color satellite photographs of the site. Then,
beginning in March 2013, I visited the site three times spending a total of 8.5 hours
comparing current conditions with those reported on in 2001 and 2005. I not only
compared the previous mapping with current conditions, but compared the current
various plant species’ qualitative diversity and abundance (Plant Community
Associations) with that previously reported."
Unfortunately, Mr. Everett gives no indication that he performed any sensitive plant or
animal surveys as part of his reassessment. Rather, he only reviewed the CNDDB database,
which is notoriously incomplete. Certainly, 8.5 hours on site is barely enough to confirm that the
plant communities are roughly the same as previously mapped, and inadequate for any kind of
2
systematic floristic survey. Mr. Everett gives no mention of whether he has the knowledge
necessary to perform targeted surveys for sensitive plants. Did his field work contain anything
other than a re-evaluation of previous vegetation mapping? If not, does the MND rely on
outdated species surveys? When were the last thorough floristic surveys performed?
Most reputable environmental consultants use the CNDDB as a tool to determine what
sensitive species might be present on a site, and then perform comprehensive ground surveys to
determine whether these species are present. Given that a sensitive plant species was found in
1989 but not in 1999 (Ceanothus verrucosus, San Diego County list B, State Rare Plant Rank 2),
a current survey needs to be performed to determine whether it still exists on the site. California
walnut (Juglans californica, San Diego County List D, State Rare Plant Rank 4) was seen in
1989, 1999 and by Dr. Landis in a site visit of December 8, 2013, and it is not mentioned in the
MND at all. Given the apparent age of the site and the diversity of microhabitats not mapped (see
next paragraph), the site must be properly surveyed during the spring and fall, to insure that
sensitive, rare, or endangered species (especially small annuals) are not impacted. When were the
last targeted surveys for sensitive species performed?
Was the vegetation mapping correct? In a visit to the site on December 8, 2013, Dr.
Landis noted small patches of perennial grassland dominated by needlegrass within the coastal
sage scrub matrix. Why were these areas not mapped? Were they and other small patches (such
as the side canyons) thoroughly surveyed for sensitive, rare, or endangered species? If so, when
was the last survey?
Were human impacts properly considered? The islands of habitat created by the project
bisecting the existing wild area will be impacted by increased invasive weeds carried by more
people into the smaller space. Worse, erosion and habitat loss caused by mountain bikers and
vandals, a widespread problem on the site at present (Dr. Landis personal observation, December
8, 2013). We could not find analysis or mitigation of these impacts in the MND or any related
documents. They are proving to be the major problem in reserves such as Del Mar Mesai where
1600 cyclists per month were observed, and less than 100 were planned for. Concentrating their
activity into smaller spaces will only increase their impacts. At present, neither San Diego
County nor any city within the County has an effective plan to deal with mountain bike impacts
to conservation areas.
The climate change issue is more complex, but briefly, coastal sage scrub species are
likely to be impacted by climate changeii. To summarize, warming, drying climate will force
species to either adapt or migrate to cooler, wetter places. Plants migrate too, by spreading seeds.
This migration may be somewhat ameliorated by complex topography. A species may find a
cooler, wetter refuge on the north side of a nearby hill, rather than migrating many miles northiii.
Unfortunately, migration in the face of climate change only works if there is a route to
the nearest climate refuge. The Project, as proposed, will bisect a migration corridor for coastal
sage scrub species and destroy several cool draws that could serve as refugia in a warmer, drier
climate. What are the landscape impacts of this blocking a migration corridor in a changing
climate?
Yes, the MND proposes restoration of disturbed coastal sage scrub away from the Project
footprint, but it will almost certainly involve planting of common species in locations where they
presently occur, not necessarily where they will survive in the future. Uncommon species will
not even be replanted, but will be left to migrate across the development, if they can. To put this
in context, the plants first seen in 1989 are likely those present on the site today (Dr. Landis'
observation, based on plant size and the presence of lichens on many stems), as coastal sage scrub
plants live at least 50 years. The plants planted on restoration sites if the Project is approved will
be the ones facing climate change, and there is no provision in the MND or any related document
for their offspring to migrate if the restoration sites prove too hot and dry. While CNPS is
concerned with plants, it should be noted that stressed plants make poor habitat for birds such as
the California gnatcatcher.
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Additionally, projects that create isolated islands of native plants doom those patches to
loss of species, especially when local climate becomes less favorable to the survival of those
species. This is an application of the well-know theory of island biogeography, and it applies
whenever urbanization turns a natural area into an isolated island. There are also effects of
trophic cascades, where the loss of carnivores such as coyotes due to too-small habitat sizes
causes booms in herbivore populations, with resulting loss of plant species.
Overall, the description of the site is incomplete, because current sensitive species
surveys are missing. Worse, the project fails to properly consider or mitigate increased human
impacts in the smaller spaces forced by the project footprint. Finally, the MND as presented fails
to consider how the Project will impact the ability of sensitive coastal sage scrub species to
migrate to deal with climate change. Because of this, there is the strong probability of
undocumented impacts to undocumented plant species and to sensitive plant communities.
Moreover, significant vegetation losses are to be expected beyond the level mitigated for, and at
least some of these impacts probably cannot be mitigated. Therefore, CNPSSD believes that the
MND is insufficient and a full environmental impact report is required for the Project.
One word about credentials: this letter was prepared by Dr. Frank Landis, who has a MA
in botany from Humboldt State University, where he studied plant community ecology under Dr.
John Sawyer, one of the authors of the Manual of California Vegetation. He received a PhD in
botany from UW Madison, where he studied plant ecology under Dr. Thomas Givnish. He has
grew up in southern California, where he has worked as a botanist in southern California since
2006, and in San Diego since 2009.
Thank you for considering our comments. We will be happy to provide more
information as needed.
Sincerely,
Frank Landis, PhD (Botany)
Conservation Chair
California Native Plant Society, San Diego Chapter
i
http://www.delmartimes.net/2013/10/10/local-residents-react-to-stronger-enforcement-of-del-mar-mesa-preservetrails-use/
ii
E.g. Riordan and Rundel. 2013. The future of California sage scrub in an era of increasing urbanization and
climate change. Fremontia 41(3) 2-7.
iii
Lancaster and Kay. 2013. Origin and diversification of the California flora: re-examining classic hypotheses with
molecular phylogenies. Evolution 67(4):1041-1054