audubon and preserve calavera comments

8/8/2019 Audubon and Preserve Calavera Comments

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flow and increase the number of vehicles trips the road can carry without increasing thenumber of lanes. Transportation Demand Management strategies would reduce the number ofvehicle trips and miles traveled through the promotion of telecommuting, change of workschedules to even out the pattern of vehicle use on the road, muting the effect of the morningand afternoon rush hours. We urge that the EIR not be certified in its current form and that itbe recirculated with these alternatives analyzed, and compared with the more damagingalternatives that are in the current draft for their mid and long term impacts.

Visual Impacts/Aesthetics/Community Character

The I-5 corridor in the project area is the northern gateway to the San Diego region and isunique as a coastal freeway with ocean views. It traverses coastal communities withexpansive views of river valleys, coastal lagoons, beaches, scenic hillsides, and Torrey PinesState Reserve, with low density development and open space near these natural features. TheI-5 passes through a number of cities which have designated the I-5 as a protected viewcorridor because of the importance residents place on these scenic qualities. The trees andmedian and slope vegetation along the freeway provide positive visual impacts, as well assequester pollutants. Large structures such as retaining walls and noise walls are currentlylargely absent from the corridor. However, the road expansion project would introduce agreater mass of roadway and an array of road infrastructure that would transform this sceniccorridor into an urbanized concrete-dominated arterial characteristic of the Los Angelesregion. The proposed concrete retaining walls, sound walls (up to 45 feet in height), anddirect access overpasses, would obscure ocean views and other scenic features from both I-5travelers and the nearby and distant communities, and would have a significant impact on thevisual and community character of the area. The walls would create a tunnel effect that wouldobscure the regions unique visual identity and character. The sound walls will also tend toobstruct bird flights from one side of the freeway to the other. The need for these sound wallsalone should preclude this approach. How will Caltrans address the above concerns on visualimpacts?

Air Quality/Climate Change

Motor vehicle emissions contain a number of pollutants that adversely affect human healthand natural ecosystems. These emissions represent the most significant source of ultrafineparticles which have shown to be more toxic than the larger particles. Studies published inthe Journal of Air and Waste Management Association and in Atmospheric Environmentshow that proximity to a major freeway dramatically increases exposure to ultrafine particleswhich are linked to neurological changes, pulmonary inflammation, and cardiovascularproblems. USC researchers found that children living within 82 yards of a major road had 50percent greater risk of exhibiting asthma symptoms than those living more than 328 yardsaway. Asthma is a major cause of hospital admissions in children. Asthma that begins inchildhood by exposure to ultrafine particles usually becomes a medically costly, lifelongcondition. This condition limits physical activity which subsequently contributes tochildhood obesity another preventable epidemic. Research by UCLA scientists published inthe journal Atmospheric Environment indicates that air pollutants from LA Interstate 10 inSanta Monica extend more than 1.5 miles downwind, further than previously thought. Theincrease in vehicle volume will significantly increase impacts on air quality. This in turn will

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result in adverse health effects which disproportionately imperil our most vulnerablepopulations of children and the elderly.

The I-5 expansion project would ultimately result in increases in greenhouse gas emissionsfrom both the massive construction and increased freeway use. It is therefore not consistentwith national and state goals to reduce greenhouse gases from vehicle use. Everywhere in thecountry, individuals and governments are looking for ways to reduce their carbon footprint.

They are doing this to address climate change and global warming, and its potentialdevastating effects on human populations, as well as native wildlife. The DEIR states thatbecause stop-and-go traffic is reduced in the short term from the added lanes, greenhousegases will decline after project completion. However, the DEIR disregards studies thatindicate that in the long term the added lanes will encourage more vehicle use, more highspeed traffic and eventually more stop-and-go traffic and, therefore, more greenhouse gaseswill be released into the air. How will Caltrans address the above concerns on air qualityimpacts?

Biological Resources and Water Quality

The road widening would impinge upon and impact a number of sensitive natural areas thatcontain habitat and wildlife that are both state and federally protected, and of regionalsignificance. The project would impact the major coastal wetlands in the North Countyregion as it crosses five lagoons, San Dieguito Lagoon, San Elijo Lagoon, Batiquitos Lagoon,Aqua Hedionda Lagoon and Buena Vista Lagoon, and is situated adjacent to Los PenasquitosLagoon and Marsh Preserve. It also crosses rivers and creeks that terminate in the ocean andprovide wildlife corridors from inland San Diego County to the coastal region, including LosPenasquitos Creek, Carmel Valley Creek, San Luis Rey River, Cottonwood Creek, Loma AltaCreek and Encina Creek. Cottonwood Creek, that has steeply sloped banks and runs parallelto I-5, will be severely impacted by fill and other earth moving activities involved inconstruction. Because of the historical loss of wetlands in the Coastal region due todevelopment, the impacts to these wetlands are individually and collectively significant.

The coastal wetlands and adjoining uplands support a variety of sensitive habitats and thewildlife that depend on them. The wetlands support a year-round resident bird population thatis attracted to these highly productive marshes and riverine systems. Because the coastalwetlands are located on the Pacific flyway, they also provide feeding, resting, and breedinggrounds for migratory bird populations. The expansion of the additional lanes and supportinginfrastructure will result in a significant loss of wetland habitat and a degradation of thathabitat during the construction phase and upon completion due to ultimate increases in thevolume of traffic. These coastal wetlands will also be significantly affected by waterpollution from freeway runoff and from the aerial deposition of contaminants from vehicles,including copper, tire particles, oil leakage, and litter, that will be deposited in the lagoons bythe increased vehicle traffic. Even if totally effective capture and cleansing of runoff water isincorporated into the project, it will still have a significant unmitigated water quality impactdue to the airborne deposition of contaminants and litter that will result from the additionaltraffic.

During construction, the excavation of soils and other earth moving activities adjacent to theroad will release residues of a variety of pollutants, including but not limited to, petroleumhydrocarbon particulate matter and aerosols, and lead. These toxic substances have

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accumulated over the years in soils adjacent to freeways. When disturbed, theywill quickly find their way into the lagoon food chain and, during tidal flushing, could alsoaffect ocean organisms. These are harmful substances that persist and accumulate in theenvironment due to incomplete degradation, and bio-concentration in the food chain, which isaided by their solubility in lipids and fats. Many are known to be genotoxic and carcinogenicto aquatic organisms. Also during construction, earth moving activities will result in siltcontaining soil nutrient movement into the wetlands causing excessive sedimentation in the

lagoons and contributing to algal blooms in the lagoon and ocean. These water bodies,already overloaded at current pollutant levels, are subject to anoxic conditions.

As traffic volumes increase on I-5 over time to fill the added lanes, the adjacent wetlands willreceive greater quantities of pollutants released from vehicles. In addition, there will beongoing project impacts to wetland wildlife from elevated noise levels, greater amounts oflight pollution from freeway and vehicle lighting, and increases in litter and debris. Any oneof these impacts could interfere with the life cycles of wetland organisms, including feedingpatterns, breeding, and overall physiology. How will Caltrans address the above concerns onbiological and water quality impacts?

Piecemealing of CEQA Review

The widening of I-5 along Buena Vista Lagoon cannot occur without addressing theinterchange of I-5 and I-78. The combined impacts from these two projects will be muchgreater than those of the widening itself. The full impacts of the two projects need to beconsidered, so it is possible to determine that project alternatives are both feasible and reducethe combined impacts. It is a violation of the CEQA process to artificially divide a projectinto smaller components that appear to reduce the impacts, but that in fact could result in aneven more damaging project when the full project is considered. How will Caltrans addressthese concerns?

Indirect Impacts to Agriculture

The DEIR has failed to adequately consider the cumulative impacts of this project onAgricultural Resources. Carl Bell, Director of the San Diego Farm Bureau, identifies twocritical factors affecting the sustainability of agriculture in San Diego water pricing andcompetition with lower priced imported food. Part of the justification for this project is tosupport freight and goods moving through the Mexican Border crossing, and these goodsinclude an increasing amount of food products. Agriculture in San Diego County is not justimportant for our local economy, it affects land use, watershed function, and habitat.Agricultural land provides important movement, foraging and migrating areas for local,national and even international wildlife populations. Facilitating the movement of lowerpriced food, from long distances away, will reduce the viability of local agriculture. It alsocontributes to excess carbon dioxide leading to global warming and to increased levels ofnitrous oxides that form smog. None of these issues were adequately considered in theDEIR. How will Caltrans address these concerns on impacts to agricultural resources?

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Inadequate Mitigation

Two coalitions of non-profit organizations in North San Diego County, the North CountyOpen Space Coalition (NCOSC) and Carlsbad Watershed Network (CWN), had a series ofmeetings with Caltrans staff over this project in 2006. Attached is a copy of the three page

list of potential mitigation measures for the Buena Vista Watershed that they asked to beconsidered for inclusion as this project moves forward. All of these measures are related towatershed function and habitat conservation. We cannot find that any of these mitigationmeasures have specifically been included in the DEIR. These are all feasible, reasonablemitigation measures that would provide some offsetting benefits for the huge direct andindirect impacts from this project. We again request that all of these mitigation measures beconsidered for inclusion in the final project, and, if they are not included, that the final EIRprovide an explanation for their exclusion. Why werent biological mitigation measures inthe Buena Vista Watershed included in the DEIR?

Conclusion

In conclusion, the proposed expansion of I-5 will have significant, unmitigable, andirreversible environmental impacts to biological resources, air quality, water quality, efforts toavoid climate change, visual aesthetics and community character, agriculture, and humanhealth. In addition, the DEIR does not meet the requirements of CEQA because it does notevaluate less impactive alternatives, such as the public transit alternative. Therefore, theDEIR should not be certified by Caltrans as meeting the requirements of CEQA. It should berevised to include transportation alternatives that will benefit, not degrade, our region andthen be reissued.

Respectfully,

/s/ Diane NygaardJoan M. Herskowitz James A. Peugh Diane NygaardConservation Co-Chair Conservation Chair PresidentBuena Vista Audubon Society San Diego Audubon Society Preserve Calavera2202 South Coast Highway 4010 Morena Blvd, Ste. 100 5020 Nighthawk Way

Oceanside, CA 92054 San Diego, CA 92110 Oceanside, CA 92056760-439-2473 619-224-4591 [email protected] [email protected] [email protected]

ATTACHMENT

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ATTACHMENT

Buena Vista Lagoon/Watershed Revised 5/01/06Potential Projects Related to I-5 Widening/Interchange

This list of potential projects is submitted on behalf of member organizations of theNorth County Open Space Coalition (NCOSC) and Carlsbad WatershedNetwork(CWN). The framework for this list is the Carlsbad Watershed ManagementPlan, and the position of NCOSC in support of the salt water alternative for therestoration of the Buena Vista Lagoon. Our key objective is to support improvedcoordination of watershed and habitat conservation efforts.Assessing the impacts for the two projects, the I-5 widening and the I-5/#78interchange, and planning effective mitigation for the impacts should be doneconcurrently.

Hydrology

- support lagoon restoration plan

We're quite far along now in the planning and EIR development phase, and adecision on the approved restoration plan should be forthcoming within a reasonabletime frame. The timing of the two projects could neatly coincide. The cost of therestoration will be in the $100 million range.

- expanding the width of the I-5 bridge

Assuming the selected lagoon restoration is restoring it to a natural salt watercondition, expanding the width of the I-5 bridge would probably be considered acritical component. The design of the new bridge should best accommodate ourpreferred alternative of an all-saltwater estuary.

- add gauging stations

There are currently no gauging stations on Buena Vista Creek so there is littlequantitative/historical data available on discharge rates, and variation in surface flow.Adding such stations would support the lagoon restoration effort as well asimproved storm water management in the watershed.

Public Education/Access Programs

- Boardwalk Interpretative Trail

BVAS has the concept plans for this project already in hand. It involves a loopboardwalk trail which begins and ends at the Nature Center, and incorporates raisedobservation platforms and interpretative signage. The second, more problematicproject would be a pedestrian boardwalk running along the east side of Pacific Coast

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Hwy and linking the small picnic park and lagoon overlook in Carlsbad with the BVASNature Center.

- north side lagoon trail

This proposed trail would go from the Nature Center east along the north side of thelagoon. The trail would probably need to deadend at the freeway, but such a trail

would greatly expand the ability of BVAS to serve as a focal point for natureeducation about the lagoon.

- Watershed/ monitoring component

This would be similar to the program the University of California has at theheadwaters of the Santa Margarita River - Reserve Station. The BV Nature centerwould be provided with high speed access - wireless access as field stations for on-going research, mitigation and protection of the local wildlife and watersheds. Thenature center would function as a working field station with mobile carts and wirelesslaptops that go along with ancillary monitoring devices. These along with onsite and

upstream monitoring equipment needs to be in place for nearby high school anduniversity student for on-going conservation studies and research.

- expand educational component of annual creek clean-ups

There have been broad based community clean-up efforts along the creek and to thecoast. What these efforts haven't included is a strong public education component.Hundreds of volunteers turn out for this event. Interactive exhibits at the event, hand-out materials etc could be designed with age appropriate messages about watershedprotection.

Land Acquisition

- coordinate habitat conservation planning within the watershed

Sections of the watershed are included in separate subarea plans for the MSCPNorth County(being finalized), city of Vista (draft not issued), city of Oceanside(second draft under revision), and city of Carlsbad (plan adopted.) . There is anopportunity to improve the functioning of the riparian corridor and wildlife movementby coordinating habitat planning across these four plans.

- acquire key parcels along the lagoon or strategically located within the watershed.

The list of potential acquisition parcels should include the following for consideration:

- the Boardwalk parcel adjacent to the inner lagoon

This parcel was recommended for acquisition in the lagoon restoration plan.and isthe top priority for direct lagoon benefit. It is ideally located for wetlands restoration.

- lower basin area around tributary entrance

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This area of non-native grassland is between high quality riparian woodland anddisturbed wetlands. It is identified as a Biological Core and Linkage Area in theMHCP.

- conservation easement of the Marron Adobe site

This is within the key connecting linkage between Oceanside and Carlsbad and

adjacent to the pending Sherman acquisition. Homesite has been continuouslyoccupied by the original land grant family descendents. And while current occupantis committed to preservation, without such an easement there is no protection of thissite from future sale for development.

- Sherman parcel

A conservation acquisition is currently underway through the Trust for Public Land.There is currently a small funding shortfall for financing the acquisition.- segment of South Coast parcel that parallels Marron Rd extension and the creek

This area next to the reclamation plan site and the Sherman acquisition would resultin significant protection of this entire valley.

- Hughes parcel next to pump station in the outer basin.

Hard to believe this is actually potentially developable.

- undeveloped parcel east of College between the two senior facilities along LakeBlvd

This acquisition could be combined with replacing the concrete channel through thisarea- using the adjacent parcel to provide for improved natural vegetation and creekbiological function.

Habitat Restoration/Enhancement

- TET site along Mossey Nissan in Oceanside

This is one of the unmanaged TET mitigation sites. Several invasive plants need tobe removed and former homeless encampments and erosion areas requirereplanting.

- Hosp grove restoration

This area has a planned restoration program that has been hampered by funding.Eucalyptus need to be replaced with native species in this preserve area right acrossthe street from the outer basin of the Lagoon .

- continuation funding for CWN invasives removal project

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Initial focus was on Arundo donax and pampass grass. Mapping of key invasives hasbeen done. Funding is needed to complete the removal/restoration effort of othertarget species.

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