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Comments on Draft EIR for Newhall Ranch Mission Village Development DMEC Project No. 10-0181 1/3/2011 Page 24 D:\DMEC\Jobs\Friends_SantaClaraRiver\Newhall-MissionVillage\DMEC_comments_on_Newhall_MissionVillage_DEIR-20110103.doc DMEC Swaid 1991 44 , and Panthi 2010 45 ) have shown that climate changes dramatically, in particular temperature, when a natural area is developed. In conclusion, it is clear that the SFVS is highly restricted in its range, only occupying about 30 acres throughout its known range. Numerous surveys have occurred in the SFVS distribution range without finding historic or new populations. Those that have studied the SFVS do NOT understand why it occurs where it does, and they do not understand what the environmental triggers are for germination. Since they do not understand the ecology of the plant, it is not logical or reasonable to conclude that they know what is necessary to conserve the plant. It is both illogical and unscientific for them to conclude that reducing the known population by 30% and surrounding five of the biggest portions of the Newhall Ranch population by urban development will not put this taxon at jeopardy of extinction. SCP Goals and Objectives SCP, starting on page 8, states: “The goal of this plan is to ensure the long-term persistence of spineflower within the project study area. As proposed by the applicant in this plan, the long-term conservation of spineflower will be achieved first by establishing a system of preserves to protect the core occurrences of spineflower in the project study area, and second, by implementing management and monitoring within an adaptive management framework to maintain or enhance the protected spineflower occurrences”. The SCP goes on to list specific goals, each supported by two or more objectives, which are listed below. “Goal 1: Maintain or increase San Fernando Valley Spineflower populations within the preserves”, which is supported by several objectives: �� “Objective 1.1 - Maintain or increase the distribution of the spineflower within each preserve �� Objective 1.2 – Maintain or increase the abundance of the spineflower within each preserve �� Objective 1.3 – Reduce or prevent the increase of identified stressors or anthropogenic factors that negatively impact spineflower individual and population performance �� Objective 1.4 – Increase understanding of the ecological factors influencing the distribution, abundance, and population persistence of the spineflower in order to inform management and monitoring within the preserves �� Objective 1.5 - Plan and conduct small scale experimental management trials to test the effects of proposed on-the-ground management treatments and evaluate effectiveness and spineflower’s response” 40 Oke, T.R. 1981. Canyon Geometry and the Nocturnal Urban Heat Island: Comparison of Scale Model and Field Observations. Journal of Climatology 1(3):237-254. 41 Oke, T.R. 1998. On the Confounding Role of Rural Wetness in Assessing Urban Effects on Climate. Second Urban Environment Symposium, Albuquerque, New Mexico, Americam Meteorological Society. 42 Oke, T.R., and R.F. Fuggle. 1972. Comparison of Urban/Rural Counter and Net Radiation at Night. Boundary-Layer Meteorology 2 (1972) 290-308. 43 Santamouris, M., N. Papanikolaou, I. Livada, I. Koronakis, C. Georgakis, A. Argiriou, and D.N. Assimakopolous. 2001. On the Impact of Urban Climate on the Energy Consumption of Urban Climate on the Energy Consumption of Buildings. Solar Energy 70(3), 201-216. 44 Swaid, H. 1991. Nocturnal Variations of Air-surface Temperature Gradients for Typical Urban and Rural Surfaces. Atmospheric Environment 25B(3):331-341. 45 Panthi, Jeeban. 2010. Urban Micro Climate and its Effect on Environment. Blog at http://jeebanpanthi.wordpress.com/2010/05/03/urban-micro-climate-and-its-effect-on-environment/
Comments on Draft EIR for Newhall Ranch Mission Village Development DMEC Project No. 10-0181 1/3/2011 Page 25 D:\DMEC\Jobs\Friends_SantaClaraRiver\Newhall-MissionVillage\DMEC_comments_on_Newhall_MissionVillage_DEIR-20110103.doc DMEC “Goal 2: Maintain or enhance the structure and native species composition of the native communities within the spineflower preserves”. Goal 2 is supported by four objectives, one of which is subdivided into two sub-objectives: �� “Objective 2.1 - Maintain a mosaic of naturally occurring native communities within the preserves. Under this objective, management would be implemented if a 25% or greater change is observed in the absolute cover of existing native plant communities within each preserve, as measured through a combination of remote sensing and aerial mapping at 10-year intervals �� Objective 2.1(a) – Restore damaged habitats potentially capable of supporting spineflower, within the preserves �� Objective 2.1(b) – Revegetate areas within preserves that have been damaged and do not support native habitats but are unlikely to support spineflower in the future �� Objective 2.2 – Maintain or increase the absolute cover of native plant species by 15% within each preserve every 10 years �� Objective 2.3 – Maintain or increase the diversity of native plant species within each preserve by at least 15%, as measured within each preserve every 10 years �� Objective 2.4 – Increase understanding of the ecology of the native communities needed to inform management of the preserves by undertaking the studies specified as part of the adaptive management program” “Goal 3: Facilitate the natural ecological processes required to sustain the native populations and communities in the preserves” is supported by two objectives: �� “Objective 3.1 – Maintain or enhance opportunities for migration of plant and animal populations, including spineflower, between potentially isolated preserves �� Objective 3.2 – Maintain the hydrologic conditions within the preserves” DMEC believes that these goals have not been achieved under the current proposed preserve design. In order for the SFVS to be actually protected and preserved, much less mitigate for the proposed impacts to the species under any of the project development alternatives, except maybe the No Project alternative, the SCP must truly preserve the SFVS onsite, in perpetuity. It does not. The shortcoming of the SCP are described below. SFVS Knowledge Lacking The SCP acknowledges that there is fundamentally no baseline understanding of the processes governing the distribution and abundance of the SFVS. The SCP states regarding historical knowledge of processes determining spineflower abundance: “Historical records do not include information regarding the abundance of SFVS (page 14)”. Preliminary hypotheses about the processes determining SFVS distribution and abundance are based on population survey data collected from Ahmanson Ranch and the proposed project areas at Newhall (Table 2, page 14). The SCP was developed and assessed in the project EIS/EIR. The SCP presents several biological objectives for the conservation of the SFVS as described above. Among them is, as presented on page 8 of the SCP, “Objective 1.4: Increase understanding of the ecological factors influencing the distribution, abundance, and population persistence of the spineflower in order to inform management and monitoring within the preserves”. This objective should rather be to “Increase understanding of the ecological factors
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