Robertson Ranch DEIR

November 28, 2005

Barbara Kennedy

Associate Planner

City of Carlsbad

1635 Faraday Ave

Carlsbad, CA   92008

 

RE:  Robertson Ranch Draft Environmental Impact Report:

 

Dear Ms. Kennedy,

On behalf of more than 200 Carlsbad households who are members of the Buena Vista Audubon Society, as well as approximately 1,000 other North County BVAS members, we offer the following comments on the DEIR for the Robertson Ranch project.

 

The importance of creating and maintaining suitable wildlife habitat on the mitigation lands contained within the Robertson Ranch development is critical.  The biological survey found evidence of at least two endangered bird species on the property, as well as a number of other animal and plant species on the threatened or endangered list.  Evidence suggests that these several species of concern have been expanding in recent years on this property, perhaps partially as a result of the loss of suitable habitat on adjacent lands due to development.   

 

In general, we are concerned that the density of the proposed development as outlined in the DEIR would simply overwhelm the areas that are to be set aside for natural open space, and severely impact the potential wildlife habitat value of these areas.  The establishment and maintenance of high wildlife habitat values in the designated natural open space areas should be considered a mandatory mitigation requirement for the dense development of the Robertson Ranch. 

 

We take issue with the conclusion in the DEIR that various species of concern would not be significantly impacted by the development.  Current agricultural land usage offers a much more modest impact on existing wildlife in the area than would the dense residential development being planned for the Ranch.  The planned layout of the residential areas calls for an extensive interface with the mitigation land, greatly increasing the likelihood of negative edge effects on the habitat.  We would prefer to see more effort made to create a real separation between mitigation habitat and residential development.  Methods for accomplishing this might include some or all of the following:

 

1.      Better use of roads, schools, or planned recreational areas as buffers.

2.      Expanding the width of habitat lands at narrow chokepoints.

3.      Requiring appropriate fencing and signage at all points necessary to control illegal dumping or off-trail access into the habitat by people and domestic pets.

4.      Limiting allowed access to the habitat to a small number of designated trailheads.

5.      Creating a defined trail system which controls access into sensitive areas and discourages off-trail exploration.   

6.      Disallowing the use of mechanized vehicles, bikes, or horses within the mitigation lands.

7.      Establishing CC&R restrictions which address such concerns as free-roaming domestic pets, use of invasive exotics in landscaping, night lighting intrusions into the habitat, improper trash disposal, use and storage of hazardous materials, and uncontrolled water runoff.

8.      Providing official notification to all potential home purchasers of the existence of adjacent protected wildlife habitat, with a discussion of possible impacts and homeowner responsibilities.

9.      Requiring all fire department-recommended wildfire buffer zones to be placed on non-mitigation land.

 

Finally, in the West Village area, we would like to see the developer required to immediately curtail all agricultural pursuits and begin restoration on any land that would ultimately be included in the open space and wildlife corridor reserves.  It will take time to restore healthy habitat values to these lands.  Any delays in starting the rehabilitation will further the degradation of this land and impact the ultimate success of the restoration.

 

Thank you for the opportunity to comment on this development. 

 

Sincerely,

 

Andrew Mauro, Conservation Chair

Buena Vista Audubon Society