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Comments on Draft EIR for Newhall Ranch Mission Village Development DMEC Project No. 10-0181 1/3/2011 Page 50 D:\DMEC\Jobs\Friends_SantaClaraRiver\Newhall-MissionVillage\DMEC_comments_on_Newhall_MissionVillage_DEIR-20110103.doc DMEC Eriastrum densifolium ssp. mohavense – rare in Ventura County (Magney 2010); represented in Los Angeles County by only 3 populations (Consortium of California Herbaria 2010) and should be treated as a rare species. Chorizanthe fimbriata – only record for Los Angeles County is on Newhall Ranch with no other known population in Los Angeles County (Consortium of California Herbaria 2010); not in adjacent Ventura County. Eriogonum viridescens – uncommon in Ventura County (Magney 2010); represented in Los Angeles County by about 6 populations (Consortium of California Herbaria 2010), most of which were collected before 1930. It should be treated as a rare species. Lastarriaea coriacea – rare in Ventura County (Magney 2010); represented in Los Angeles County by no more than 10 extant populations (Consortium of California Herbaria 2010) and should be treated as a rare species. Rumex maritimus – rare in Ventura County (Magney 2010); represented in Los Angeles County by no more than 7 extant populations (Consortium of California Herbaria 2010) and should be treated as a rare species. Galium nuttallii ssp. nuttallii – CNPS List 4, occasional (not rare) in Ventura County (Magney 2010); represented in Los Angeles County by no more than 8 extant populations (Consortium of California Herbaria 2010) and should be treated as a rare species. Parthenocissus vitacea – Rare in California and in Los Angeles County, not found in adjacent Ventura County; represented in Los Angeles County by no more than 6 extant populations (Consortium of California Herbaria 2010), all on Newhall Ranch, and should be treated as a rare species. Eleocharis rostellata – rare in Ventura County (Magney 2010); represented in Los Angeles County by no more than 7 extant populations (Consortium of California Herbaria 2010) and should be treated as a rare species. Scirpus robustus = Bolboschoenus robustus – rare in Ventura County (Magney 2010); represented in Los Angeles County by only one other extant population in the Liebre Mountains (Consortium of California Herbaria 2010) and should be treated as a rare species. Juncus longistylis – not found in Ventura County; no other populations in Los Angeles County other than Newhall Ranch (Consortium of California Herbaria 2010); loss of the only population of this taxon in Los Angeles County should be considered a significant impact. Juncus triformis – rare in Los Angeles County; not found in Ventura County; represented by only 1 extant populations in Los Angeles County on Newhall Ranch (Consortium of California Herbaria 2010); loss of this one Los Angeles County population or individuals of this taxon should be considered a significant impact. Lemna minuscula – rare in Ventura County (Magney 2010); represented by only 5 historic populations in Los Angeles County (Consortium of California Herbaria 2010); loss of one or more populations of this taxon should be considered a significant impact. Lemna valdiviana – uncommon in Ventura County (Magney 2010); represented by only 9 historic populations in Los Angeles County (Consortium of California Herbaria 2010); loss of one or more populations of this taxon should be considered a significant impact. Brodiaea terrestris ssp. kernensis – rare in Ventura County (Magney 2010); represented by only 5 historic populations in Los Angeles County (Consortium of California Herbaria 2010); loss of one or more populations of this taxon should be considered a significant impact.
Comments on Draft EIR for Newhall Ranch Mission Village Development DMEC Project No. 10-0181 1/3/2011 Page 51 D:\DMEC\Jobs\Friends_SantaClaraRiver\Newhall-MissionVillage\DMEC_comments_on_Newhall_MissionVillage_DEIR-20110103.doc DMEC Yucca schidigera – rare in Los Angeles County; not found in Ventura County; represented by only 1 extant population in Los Angeles County on Newhall Ranch (Consortium of California Herbaria 2010); loss of this one Los Angeles County population or individuals of this taxon should be considered a significant impact. Is this planted onsite and not native on the ranch? Potamogeton foliosus – rare in Ventura County (Magney 2010); represented by about 10 historic populations in Los Angeles County (Consortium of California Herbaria 2010); loss of one or more populations of this taxon should be considered a significant impact. The loss of any of these 35 plant taxa should be analyzed for significance. There is no doubt as to their rarity in Los Angeles County, the only area in California in which the County has any jurisdiction, but these plants that are rare in Los Angeles County were not considered in the DEIR as significant biological resources. As is practiced in other jurisdictions, such as Ventura County, the loss of a population of any of these taxa would be considered a significant impact, and appropriate mitigation proposed, if feasible. This was not done in the EIR, rendering it inadequate in this area. Special-status Wildlife in the DEIR The DEIR takes great leaps in its assessment that all the proposed mitigation measures will fully reduce impacts to almost all special-status wildlife species to less-than-significant levels. Their logic is flawed and not supported by the evidence, as explained below. The Western Spadefoot Toad (Spea hammondii) is likely to occur in the same habitat as the Southwestern Pond Turtle and two-striped garter snake. As the draft EIR/EIS states: “Suitable breeding habitat for the western spadefoot toad on site includes riparian areas and seasonal drainages containing seasonal pools and suitable aestivation habitat includes surrounding uplands within at least several hundred meters of breeding sites. Because western spadefoot toads are associated with specific microhabitats, however, their total suitable habitat on site was not quantified” (page4.5-984). The Mission Village DEIR (page 4.3-191) states that it was observed from two sites within the Mission Village development area. Given the known occurrence, and likely presence of the Western Spadefoot Toad in the same habitat as Southwestern Pond Turtle and parallel dependence on both terrestrial and aquatic habitat elements, the determination of “significant unavoidable impacts” should be made for the Western Spadefoot Toad following the same reasoning that was used to determine this status for the Southwestern Pond Turtle. The determination that there will be no significant impacts to the Western Spadefoot Toad after mitigation is thus arbitrary and wrong. Unarmored Threespine Stickleback is a California Fully Protected Species. The DEIR states that authorization for take was issued by CDFG on page 4.3-405. However, this is misleading as there is no take provision for Fully Protected Species. Only the footnote for Table 4.3-20 on page 4.3-406 clarifies that take was not issued by CDFG for this taxon. A more casual read of the DEIR clearly gives the reader the distinct impression that Newhall Ranch had been previously issued a permit to “take” Unarmored Threespine Stickleback, which is not true and would be illegal under current law. Special-status Mollusks in the DEIR Following the thread started above, focusing on mollusks, the DEIR provides a description of the mollusks found onsite on page 4.3-65:
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