MAR 26, 2018 Endangered Habitats League (EHL) submits comments
Endangered Habitats League (EHL) submitted comments on the Draft Environmental Impact Report (DEIR) for Bonsall Unified School District’s proposal for a huge 1,500-student school north of the 76, at the southern end of Gird Valley.
“…the consulting biologist did not conduct protocol level surveys as requested by USFWS/CDFW for the arroyo toad or focused/protocol level surveys for gnatcatchers.”
…the proposed development is in conflict with San Diego County’s Multiple Species Conservation Program (MSCP) and its San Luis Rey River Park Plan.
“The DEIR may have used an improper baseline in connection with biological impacts. It is our understanding that before biological surveys were conducted, the district cleared the property by using goats which likely removed sensitive plant species and impacted sensitive animal habitat. This issue should be candidly addressed in the DEIR and biological reports and the appropriate baseline should be employed. The project site’s pre-clearing status should have been used to assess biological impacts and mitigation and avoidance strategies. An applicant cannot avoid the environmental review process by preemptively clearing the property of all environmental sensitivity.”