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November 01, 2016


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Please email a copy of your public comment to stopquarryrezone@gmail.com

The so-called "mitigation" bank would be an artificial wetland, not a natural one, with all the ecological simplification and lessened, superficial biodiversity that goes with such attempts. Due to inadequate knowledge, scientific and otherwise, no one knows how to create a truly natural wetland from a non-existing wetland in this location or anyplace else. As just one example, the "wetland" created in Montara as one of the mitigations for the Devil's Slide tunnels is a laughable failure. Thus, the mitigation bank project comes off as a convenient ruse with no more reason for existence than manufactured justification for the adjacent high-density housing project.

Also forced out of notice in the background is the unspecified development that would be allowed off-site (goodness knows where) through use of the mitigation bank. Consequently, the potential cumulative effects of the mitigation bank are not addressed.

I despise the greenwashing that commercial rental-biologists and other sell-out scientists attempt in projects like this to serve their clients.

Email to: Janelle.D.Leeson@usace.army.mil

To: Janelle D. Leeson, Regulatory Project Manager, South Branch, U.S. Army Corps of Engineers, San Francisco Office

Re: U.S. Army Corps of Engineers Regulatory Public Notice 2015-00286S (Project: Pacifica Quarry Mitigation Bank)

The public notice says "The project does not occur in the coastal zone, and a preliminary review by USACE indicates the project would not likely affect coastal zone resources." This is incorrect. The site is in the coastal zone and will likely have significant impacts on coastal zone resources.

The public notice says that the USACE has made a preliminary determination that the project does not require the preparation of an Environmental Impact Statement. The public notice also says that USACE has made a determination that there are Federally-listed species present at the project location or in its vicinity, and may be affected by project implementation. The project site contains suitable habitat for the Federally-listed threatened California red-legged frog (CRLF) and surveys confirm the presence of CRLF within the project boundary. The public notice also states that “Suitable habitat for the San Francisco garter snake (SFGS) is located throughout the project site.” There should be an analysis of impacts on the SFGS and CRLF and their habitat.

The proposed mitigation bank site is part of a much larger development site. The development application filed with the city of Pacifica shows 206 multi-family units immediately adjacent to the proposed mitigation bank site and a road between the residential units and the proposed mitigation bank site. There is no mention of this in the public notice.

The site map included as Figure 2 is dated March 7, 2016 and conflicts with the map in the development application to the city of Pacifica which shows a road going through the proposed mitigation bank site.

The public notice does not mention that the entire quarry including the mitigation bank site is the subject of Measure W on the Nov. 8 ballot. The ballot measure, if passed, would authorize the rezoning of the entire quarry site to allow 206 residential units up to 4 stories high, right next to the proposed mitigation bank site. The measure is very controversial and there is a grass-roots campaign to defeat it. If Measure W is defeated, it is unknown what the quarry owner will do. The defeat of Measure W would put the proposed mitigation bank on hold and could result in the permit application being pulled. The application should wait until after the Nov. 8 election.

The map in the mitigation bank public notice also is in conflict with the map that is incorporated in the text of Measure W. Read the text and see the conceptual site plan map at: https://shapethefuture.org/elections/2016/nov/candidates_measures/documents/CityofPacificaInitiativeMeasureResolution.pdf

I'll try to do that tomorrow.

It would be very helpful if someone would post a sample letter that can be sent by those of us who don't have time to read through the paperwork to figure things out, but who want to object. Thanks!!

This parcel is in a delicate coastal zone rich in biodiversity. The absence of an actual plan with hasty decision-making to move forward with a zoning change for a housing development is not in the best interest of our community. The wildlife that will be displaced, disturbed, or killed in the development cannot be "restored" by further mass excavation of this parcel and the alleged construction of a wetlands habitat that may or may not be connected to our sewage treatment plant. The environmental damage is one piece of a host of concerns about this housing development. For those who recognize the traffic patterns in Pacifica, the morning commuters coming from inside this development have two very limited ways to access Highway 1. The new residents either have to drive south on Old County Road or Dondee Street to access the light at Rockaway Beach Avenue @ Highway 1 and jump through the cross-traffic entering onto Rockaway Beach Avenue (which will increase due to development) or they would have to construct a road through the quarry so the new residents could access Highway 1 at Reina Del Mar (the most problematic intersection in Pacifica). The latter would not be constructed for YEARS due to the proposed wetlands project and the constant flow of trucks and equipment entering and exiting the highway. Neither intersection can accommodate traffic of that magnitude, which is WHY that parcel is zoned commercial and not residential. Housing is inconsistent with current zoning; it IS in a protected coastal zone; and that language must be corrected. Without a plan in place for any piece of this project, voters should send a clear message to the owner and demand a plan PRIOR to our vote. Vote No on W!

Click the link that says "Public Comments." It's the Public Notice about the permit application to the U.S. Army Corps of Engineers. It says, "The project does not occur in the coastal zone, and a preliminary review by USACE indicates the project would not likely affect coastal zone resources." This is obviously false.

The Public Notice doesn't say anything about the site being part of a much larger development proposal that would put 206 multi-family units in buildings up to 4 stories tall right next to the proposed mitigation bank. It also doesn't mention that those 206 units are the subject of Measure W on the November 8 ballot. What happens to the mitigation bank permit application if Measure W loses?

What other problems are there in the application? There won't be time to find out before the public comment period closes on October 27 because the Permit Manager for the Army Corps says that to see a copy you must make a Freedom of Information Act request. Of course, that can take weeks or months.

Please read the Public Notice and submit comments to janelle.d.leeson@usace.army.mil by October 27.

Vote NO on W!

There are two glaring issues with this application.

Figure 2 of the restoration plan is inconsistent with the development application submitted to the city. The application shows a public road from Highway 1 that cuts across part of what the restoration plan shows as wetlands, with part of the wetlands being designated as a park. It also includes a private road parallel to Highway 1 that isn't shown at all in the restoration plan.

Second, the Public Notice says: "Coastal Zone Management: The project does not occur in the coastal zone, and a preliminary review by USACE indicates the project would not likely affect coastal zone resources." That is obviously false. There's no mention of the actual development that would occur right next to the restored area.

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