Newland Sierra Environmental Report: Too many fundamental flaws, needs to be revised and recirculated, ECO SD comment letter

Newland Sierra Environmental Report: Too many fundamental flaws, needs…

The Environmental Center of San Diego (ECO SD) filed a comment letter on on the Draft Environmental Impact Report (DEIR) for the Newland Sierra development project in
North County. We support the submittals by the Endangered Habitats League, Sierra Club, California Native Plant Society, San Diego Chapter, and the Golden Door and incorporate their comments by reference.
ECO SD focussed our comments on several fundamental fatal flaws in the analysis. These foundational mistakes cause the subsequent analysis to be flawed having been based on incorrect
assumptions and facts. This DEIR analysis should be withdrawn, significantly revised to correct the fatal flaws, and re-circulated prior to any certification.
In general, ECO SD finds the following fundamental flaws which undermine the entire DEIR and mitigation plan:
A. DEIR analysis grossly misrepresents the content and impacts of the Existing General Plan alternative.
B.  DEIR does not recommend the most environmentally appropriate alternative and it should.
C. DEIR fails to include all ‘reasonably foreseeable’ projects in the cumulative impacts analysis.
D. DEIR and project consideration is premature and violates the conditions required under the Planning Agreement with the natural resources agencies, and is not consistent with the draft
NCMSCP.
E. There are several impacts to wildlife that are not acknowledged or mitigated such as connectivity and significant edge effects.
F. Reliance on a gnatcatcher habitat mitigation site location over 20 miles away that has no gnatcatchers is unacceptable and inappropriate as mitigation for these habitat losses.
G. DEIR attempts to ‘piecemeal’ the analysis by failing to include the interchange and roadway improvements in this analysis.
H. Proposed project puts multi-family homes and a school in a known unhealthful location near a freeway putting peoples’ health at risk. This is bad planning and immoral.
I. DEIR fails to include required blasting plan.
J. Project is premature coming as it does before the County’s Climate Action Plan.
K. Requisite findings for a Habitat Loss Permit cannot be made. The project should be redesigned so that the necessary findings can be made if a Habitat Loss permit is to be issued.

The complete letter can be found here: ECO Newland Sierra DEIR Comment letter_14AUG2017