DEIR for the Former South Coast Quarry Amended Reclamation Plan
February 8, 2006
Mr. Jerry Hittleman
Senior Planner
City of Oceanside , Planning Department
300 North Coast Highway
Oceanside , California 92054
Subject: DEIR Scoping Comments on the Amended Reclamation Plan for the Former South Coast Material Quarry
Dear Mr. Hittleman:
On behalf of more than 400 Oceanside and Carlsbad households who are members of the Buena Vista Audubon Society, as well as approximately 800 other North County BVAS members, we offer the following comments on the DEIR for the Amended Reclamation Plan for the Former South Coast Material Quarry.
Our interest is in seeing this site restored to a more naturally functioning riparian corridor, with the high habitat values needed to support a full variety of native plants and wildlife. We believe the DEIR fails to properly consider more environmentally sensitive alternatives for the reclamation plan, and understates significant shortcomings in the proposed project.
Some of our specific concerns with the DEIR and the project as proposed include:
- The drastic reengineering of the natural streambed. Digging out and then raising the level of the streambed introduces several potential impacts, none of which seem adequately addressed in the DEIR. The streambed elevation alteration would require significant amounts of imported fill of unspecified origin and composition. Would the fill be taken from adjacent naturally contoured lands, and if so, how would that impact be mitigated? If the fill is imported from distant sites, would the imported soils be compatible with the requirements of the natural plant community intended for this reclamation site? What impact would the elevated streambed have on the water requirements of the riparian plant community planned for the restored streambed which would now be an additional 22 feet above the existing water table?
- Large expanses of buttressed banks and grouted rock floodways. The use of grouted rock and concrete banks and spillways as a form of flood or erosion control introduces as many issues as it solves. These artificial impervious devises prevent vegetation from growing and providing their natural function of flow dissipation and erosion control. These devices might prevent erosion on site, but it would seem that the unchecked water flow would simply gain speed and energy and cause even greater erosion and sedimentation downstream. How is the project proposing to mitigate for these likely off-site impacts?
- An unnatural floodplain inadequate in width to contain and dissipate even moderate storm events. The narrow width of the proposed streambed would not allow for the natural historic meandering of Buena Vista Creek in this area. By channeling the streambed between two sloped containment banks, the creek would become little more than a soft-bottomed version of the old-style flood control channels of Los Angeles and Orange Counties. How long would it be before owners of the adjacent future development would begin demanding that the channel be cleared of vegetation to prevent a backup of flood waters and overspill onto their properties? The DEIR does not adequately consider how future vegetation would affect the functioning of this narrow channel.
- A constricted corridor of habitat which would restrict wildlife passage and exacerbate detrimental edge effects from future development. Providing for the free movement of wildlife along the riparian corridor of Buena Vista Creek should be an essential component of the reclamation of this site. The DEIR inadequately addresses the probable difficulty which many species would face when encountering the grouted rock drop structure contemplated in this project. It would seem that lack of adequate cover from predators and poor traction over hard and slick surfaces would make the drop structure a significant impediment for wildlife.
Many of these issues also involve aesthetic considerations. We feel that a reclamation plan for an area which has been significantly altered through grading and gravel extraction should have as a goal the return of the site to its former natural condition. This project would substitute natural restoration with additional artificial devices, contouring, and channeling, all seemingly for the purpose of maximizing the development potential of the remainder of the property. We feel this is shortsighted, and that significant improvements in the appearance and functioning of the Buena Vista Creek could be made with minor impacts on the potential future development of adjacent land. We would like to see the DEIR address the aesthetic loss of a natural streambed and riparian corridor.
Thank you for the opportunity to comment on this DEIR.
Sincerely,
Andrew Mauro, Conservation Chair
Buena Vista Audubon Society