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Brisbane Friends, here are just a few reasons to reject this latest EIR Addendum:
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By refusing to consider this revised development plan in light of present day conditions, the Addendum is fundamentally flawed, and we believe out of compliance with CEQA law. See full letter from Daniel Cooper, Lawyers for Clean Water, Inc. at www.mountainwatch.org.
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According to court rulings, a project’s impacts on global warming must now be considered.
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This plan fragments the grassland. Fragmentation leads to extinction. Callippe silverspot are no longer seen on Icehouse Hill, and were not recorded for two years on the north side of Guadalupe Canyon Parkway. Splitting of the Callippe habitat will lead to genetic isolation of the butterflies and threatens their survival.
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There is no safe migration corridor in the current plan. The corridor suggested by the USFWS is completely unrealistic and laughable, if not so tragic in results. It depends on the butterflies crossing Guadalupe Canyon Parkway, then Carter Street, then back over Guadalupe, and then over a grove of eucalyptus trees. Without a viable flight corridor, the SBMt. population of Callippe butterflies will be split, and isolated. This has proven to lead to extinction of similar species and has already caused the population of this species to decline dramatically on our mountain and surrounding hilltops.
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Viola pedunculata, the only Callippe host plant, has been very difficult to propagate and has not been able to survive long-term in recreated habitat.
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To date, the HCP has not stopped the invasion of exotics or the advance of coastal scrub. Mitigation measures used do not have a track record of success. In 26 years, less than 3 acres of Mission Blue habitat have been restored. Before more native habitat is destroyed in exchange for money thrown at the problem, successful habitat restoration should be proven.
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Since the HCP came into effect 26 years ago, 330 acres of habitat have been permanently destroyed (new houses and roads), and 230 acres are "temporarily" and perhaps permanently disturbed--that’s a total of 560 acres. Most of the disturbed land will never return to native habitat, and some has perpetual erosion problems. In that same time period, 122 acres were lost to coastal scrub succession. The HCP will "sunset" in 2012. During its duration, far more habitat will have been lost to development and accompanying disturbances than to coastal scrub advance and invasive species. We need to see successful methods at work on San Bruno Mountain before any more habitat is taken by development.
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More development in the middle of the expanse of habitat reduces the means of fighting scrub advance, especially since fire can no longer be used there even though recommended by the EIR. At the same time, the likelihood of invasive plants and animals escaping from the development increases the threat to the habitat.
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Brookfield now has a poor track record as a builder in the area:
- Both NER developments have been sued for poor workmanship by their homeowners;
- Poor stewardship record – clean water act violations, years of willful delay before cutting eucalyptus trees;
- Unnecessary and reckless scraping of habitat at end of September, right before rainy season;
- Poorly-engineered graded slope above Mission Blue Center is eroding, sending silt into the bay; and
- Conditions of covenants agreed upon in the present developments are not being monitored or met.
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Regional changes have resulted in denser population and more traffic. The Baylands development will add more traffic and housing. San Francisco and Daly City are building dense housing on our borders. The cumulative traffic impacts need to be considered in the present and future, not in 1989 terms.
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All of the sewage from the City goes to the San Francisco Southeast Water Pollution Control Plant. The San Francisco sewer system is averaging 10 Combined Sewer Overflows each year resulting in millions of gallons of raw sewage discharged each year into San Francisco Bay and the Pacific Ocean. This proposed project will only increase the City’s contribution to such sewage discharges. This is new substantially important information which must be analyzed in a subsequent EIR.
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