HomeMy WebLinkAbout05_24-25_2017 PC Correspondence - San Luis Ranch (ECOSLO)
Mail: P.O. Box 1014 Phone: (805) 544-1777
San Luis Obispo, CA 93406 Email: info@ecoslo.org
Office: 246 Higuera St., SLO Online: ecoslo.org
Protecting and enhancing the Central Coast since 1971
Planning Commission, City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Subject: Comments on the “San Luis Ranch” Housing project
Dear Planning Commission:
ECOSLO believes the San Luis Ranch as proposed is a flawed project. We have examined the site and
the FEIR and have the following topics to call your Commission’s attention to. These focus on the Heron
Rookery, the “wildlife corridors,” and the lack of specific mitigation for the impacts of the project on the
natural environment.
Great Blue Heron Rookery
The rookery has been demonstrated active from at least 1979 through 2016; therefore, this is a significant
resource. Yet, mitigation fails to compensate for the complete loss of the rookery. The project proposes
to "relocate mature trees containing nests to the Laguna Lake Open Space.” However, the trees in this
area are enormous and cannot be relocated. Relocating trees with nests and having great blue herons
successfully tend the active nests has never been demonstrated a viable method.
No reasonable mitigation ratios for loss of habitat are presented (such as 3:1, 4:1 - habitat created or
enhanced:habitat lost). There is no mitigation for the loss of nesting habitat. The project proposes
replacing eucalyptus with native trees for monarchs and herons; however, natives generally have lower
suitability for these species.
Project proponents need to provide details on the habitat enhancement plan: i.e. where (onsite vs.
offsite), acreage, monitoring schedule, success criteria.
Wildlife Corridors
The FEIR states that the pedestrian and bike paths will be located in close proximity to the creek, in some
cases under the riparian canopy. However, a recreational pathway does not constitute a wildlife corridor.
Frequent human disturbance from recreational use of the pathway, including night use, and proximity of
existing homes on Oceanaire, as well as the proposed homes, preclude the recreational path from being
a functional wildlife corridor.
How will the recreational path be vegetated? If it is developed in a park-like setting, even using native
species, it will not be wildlife habitat and open space. Even if the proposed bikeway along Prefumo Creek
could be considered a wildlife corridor (it's not, as currently designed), it only runs along the Northwest
edge of the project site and does not connect to San Luis Creek. Additionally, the proposed Froom Ranch
Road represents a barrier to wildlife movement and requires a wildlife undercrossing and fencing to direct
wildlife to the undercrossing!
Although agricultural habitat that will remain between Prefumo Creek and Highway 101 can be used for
wildlife movement, it is not ideal habitat and there should be a strip of land set aside in this area for
corridors and connectivity. As well, a wildlife undercrossing for Highway 101 would be needed to join this
corridor with San Luis Creek.
Specific Plan maps show the pedestrian path/corridor width to have inadequate setback from the
residential development to reasonably be used by wildlife. In the Specific Plan, the corridor is called an
"active linear park" - how is this a wildlife corridor? The Specific Plan does not describe how this area will
be restored, maintained, or monitored for wildlife uses - it only describes allowable uses as
park/playground, community gardens, special events, sports, recreation facilities, sales, transit stops,
trails, yet these do not constitute open space.
Conclusion
The FEIR incorrectly states that the impacts to movement of migratory birds and raptors along Prefumo
Creek would be temporary and significant. Impacts would be permanent, significant, and not mitigable
(Class I). None of the mitigation measures proposed address the loss of wildlife habitat. The cumulative
effects of previous development in the wetland and riparian habitats in this area, the construction of
barriers to movement such as highways and busy roads, and the proposed development will eliminate
wi ldlife movement completely.
The project site is in the floodplain between Laguna Lake, Prefumo Creek and San Luis Obispo Creek.
Almost all of the project site is within a 100 year flood event. Consider this as it relates to our changing
climate.
The FEIR also incorrectly states "Buildout of the General Plan would retain Prefumo Creek and
associated areas of sensitive wetlands, and would minimize habitat fragmentation and protect wildlife
corridors, consistent with City policy." However, there is no minimization of habitat fragmentation of this
project; in fact, it is a prime example of habitat fragmentation.
Sincerely,
Mary Ciesinski, Executive Director Melody DeMeritt, Chair, Board of Directors