| |
-
Experts agree that the 1982/1989 EIR is out of date:
“The 2007 EA relies exclusively on the findings in the 1982/1989 EIRs for the Northeast Ridge Developments and mitigation measures contained therein to arrive at a not significant finding with regard to substantial erosion or siltation. …
Stormwater management has progressed greatly since the 1980s. The entire regulatory structure has changed with the advent of NPDES permits for stormwater discharges during construction.”
-Bruce Bell, Ph.D., P.E., BCEE, President, Carpenter Environmental Associates: Initial Study/Mitigated Negative Declaration for San Bruno Mountain Habitat Conservation Plan, Amendment #5 - Comments
“The City Council would be best served by telling Brookfield to come back with a project that won’t result in significant adverse environmental impacts. Here, there is substantial evidence, including the conclusions of the proposed 2007 Addendum, that the project as proposed will cause significant adverse water quality impacts from storm water runoff, water quality impacts from cumulative sewage discharge, geological impacts, biological impacts and traffic impacts.”
-Daniel Cooper, Attorney, Lawyers for Clean Water, Inc: Initial Study/Mitigated Negative Declaration for San Bruno Mountain Habitat Conservation Plan, Amendment #5 - Comments
San Bruno Mountain Watch sued Brookfield Homes over the clean water issue. Settlement resulted in the adoption of highest standard of site stabilization and storm water runoff protection, award of fees and an $80,000 Supplemental Environmental Project to mitigate for damages done. (The $80,000 is being held in trust by The City of Brisbane for purchase of open space when available.)
- CEQA law now requires that proposed projects consider the impact of global warming, something that was not recognized as an issue when the 1982/1989 EIR was done.
“The California Environmental Quality Act (CEQA) requires that lead agencies consider the reasonably foreseeable adverse environmental effects of projects they are considering for approval. Greenhouse gas (GHG) emissions have the potential to adversely affect the environment because they contribute, on a cumulative basis, to global climate change. In turn, global climate change has the potential to result in rising sea levels, which can inundate low-lying areas; affect rain and snow fall, leading to changes in water supply; affect habitat, leading to adverse effects on biological and other resources. Thus, GHG emissions require consideration in CEQA documents.”
Sacramento Metropolitan Air Quality Management District,
CEQA Guide 2009, Chapter 6
- The proposed development will cut the habitat of the callippe silverspot in two. What happens when such fragmentation occurs? Here’s what LSA Associates, environmental consultants who have frequently done work for the City of Brisbane pertaining to San Bruno Mountain, say about it:
“The callippe silverspot butterfly is also vulnerable to the effects of habitat fragmentation. Further reduction of population size and genetic interchange among populations through isolation, genetic drift, and inbreeding depression, may result in less vigorous and adaptable populations of the callippe silverspot butterfly. Small isolated populations are vulnerable to extinction from random fluctuations in population size or variations in population characteristics (e.g., sex ratios) caused by annual weather patterns, food availability, and other factors.”
-LSA Associates,
Callippe Silverspot Butterfly Species Account, 2004
- Won’t the butterflies be able to fly from their habitat on Butterfly hill to the hill west of the proposed development? That depends on how they treat potential barriers to their flight. Here is what Thomas Reid Associates, the HCP operator, said about this:
SUMMARY OF CALLIPPE RESPONSES TO VARIOUS BARRIER SITUATIONS
(Listed in order of Severity) |
| 1. | Heavily built up areas such as nearby cities and industrial parks |
Nearly total barrier; no observed penetration in the Industrial Park or in nearby cities. |
| 2. | Dense plantings of tall trees such as along Eucalyptus Road |
Severe barrier; occasional penetration; observed preference for relatively clear corridors (20’ wide) |
| 3. | Major paved roads, four lanes or more (Guadalupe Canyon Pkwy.) |
Partial barrier; observed some crossings with some turning back. Transfer data show several crossings. |
-Thomas Reid Associates: section 4, Pg.31, 33, 35, San Bruno Mountain Butterfly Flight Survey, 1982
- But Brookfield has promised to endow the HCP with 4 Million Dollars, and there will be additional Homeowner’s assessments. Won’t that solve the problem?
“The premise that “additional” funding (endowments, Homeowners Association assessments) of the HCP from development of the Northeast Ridge would result in habitat improvements is entirely unsupported by reference to data, despite more than two decades of monitoring. Funding programmatic mitigation under the HCP, in itself, cannot physically or biologically offset an adverse impact unless the substantive mitigation measure is reasonably reliable and effective. The contrary appears to be true…”
-Peter Baye, Ph.D., Botanist, Coastal Ecologist: Initial Study/Mitigated Negative Declaration for San Bruno Mountain Habitat Conservation Plan, Amendment #5 - Comments
- A big part of the problem for the callippe silverspot is that its host plant, johnny jumpup, (viola penducalata) has not been successfully propagated outside a nursery. Here’s what Thomas Reid Associates, the operator of the San Bruno Mountain HCP, says about that:
“While habitat islands have been created for the mission blue butterfly, and can be created for the San Bruno elfin butterfly, it is unknown if the habitat island approach is appropriate for the callippe silverspot butterfly. The callippe relies on much larger areas (minimum of several acres) that consist of large colonies (i.e. several hundred plants or more) of its host plant Viola pedunculata in combination with topographic high points. Due to the high cost and difficulty of propagating viola, restoration of callippe habitat at this time is likely better served through large scale brush removal that opens up grassland habitat and allows for natural recruitment of viola.”
-Thomas Reid Associates: Pg.2, San Bruno Mountain Habitat Management Plan 2007
“The loss of these grasslands cannot be mitigated. That is to say, we cannot recreate the soil structure, seed bank, plant ecology, biological diversity, and butterfly habitat that has taken millennium to evolve and survive…
Around the Bay Area, what were once fourteen colonies of Callippe Silverspots is now down to two, with the largest one here at San Bruno Mountain. … I have witnessed the decline of Callippes and Mission Blues at the Northeast Ridge over the past twelve years. Significant damage has been done to endangered butterfly populations during this time - many thousands of Callippe Silverspots, Mission Blues, and thousands of their host plants have already been destroyed. Over time, there will be fewer buffers against extinction, and more barriers blocking chances of survival...
What happens to butterflies when their homes are gradually chopped up into smaller and smaller pieces, separated by roads and houses? It is similar to making compost - you chop up the branches and organic debris into little pieces so that greater surface area is available for bacteria, fungi, and beetles to eat it up. Decomposition is fast because creatures are coming at you from all sides. Fragmentation is this process by which these ancient lands become divided, built upon, and butterfly populations plummet slowly over time. Would you like to live in a neighborhood at the edge of highways 280, 101, next to the industrial factories, downwind from the smoke stack? How do you think your kids will fare crossing the road? Or, would you prefer a close-knit neighborhood of diverse and mutually supportive friends, a park to ride a bike or a scooter, and cars moving a little below the speed limit? Development kills the butterflies outright. Then, over time, other knife wounds gradually render populations extinct.”
-Thomas Wang, M.S., Lepidopterist, Ecologist, author of only independent research on San Bruno Mountain butterflies not conducted by developer-funded consultants:A Survey of the Grasslands of the Northeast Ridge (Guadalupe Hills) as Habitat for the Mission Blue Butterfly (Icaricia icarioides missionensis) and the Callippe Silverspot (Speyeria callippe callippe) and Initial Study/Mitigated Negative Declaration for San Bruno Mountain Habitat Conservation Plan, Amendment #5 - Comments
“Upon review of the last 25 years of endangered butterfly habitat management on San Bruno Mountain as part of the original HCP, has lead me to conclude that the proposed development may have a significant impact of the long term survival of the Callippe silverspot butterfly on San Bruno Mountain. The actions proposed in the negative declaration and Habitat Management Plan, 2007 are unlikely to adequately mitigate these proposed impacts due to the limited success in past management of these endangered species’ habitat.”
-Joe Cannnon, M.S. Ecologist: Initial Study/Mitigated Negative Declaration for San Bruno Mountain Habitat Conservation Plan, Amendment #5 - Comments
|
|