04 ATTACHMENT 10 - Laserfiche WebLink

;� � Alameda Creek Alliance PO Box 228 !Niles. CA !94538 ! (510) 498 -9183 February 3, 2009 I lonorable Jennifer Hosterman, Mayor and City Council City of Pleasanton P.O. Box 520 Pleasanton, CA 94566 Dear Ms. Hosterman and members of the City Council: The Alameda Creek Alliance (""ACA") is opposed to the certification of the St nerid e Drive Specific Plan ArrnendmentStapls Ranch Final Environnrnental Impact Deport "`EIR" because as currently drafted the analysis and proposed mitigations fail to meet the legal requirements to reduce environmental impacts to less than significant levels. Our later of June 4, 2008 detailed ACA's concerns about the adequacy of proposed mitigation n measures contained in the Draft EIR and the City has failed t make the necessary changes to the EIR. Biological Resources The EIR does not assess mitigation requirements based on impacts to habitat. While protecting individuals of a particular species is importwt, ultimately species will not survive without adequate habitat. The proposed mitigation measures do not fully mitigate for the impacts of the project. Since the project site provides potential habitat for a number of special-status wildlife and plant species, we reconut end that as much mitigation as possible be done on site, and if than is not feasible, then sufficient offsite habitat be preserved in perpetuity. San Joaquin Spearscaie tr1 ova 1*niana The EIR asserts that mitigation provided for the adjacent Arroyos Project can count towards the impacts from this proposed project. ?`his is an unacceptable approach — it does not mitigate for the habitat that currently exists on the site. As an annual species, San Joaquin spearscale impacts cannot be measured by the number of plus present, but rather by the amount of occupied habitat present. Yesterday, ACA was finally able to review the "'Wetlands Mitigation and Monitoring Plan Arroyo Las Positas Realignment Arroyo f iocho Widening, Alameda County, California" that contains the requirements of Special Condition 1 of the Corps Permit for the Arroyos Project. We now know that in 1993 the Staples Ranch site had 12 ages of occupied San Joaquin spearscale habitat. It is well documented that the populations of annual plant species can fluctuate widely from year to year due to climatic conditions. In many cases not all potential habitat is occupied every gear. The Ells acknowledges and maps the location of Saxe Jo aquin spearscale populations as they were found in July 2006 on the project site. However, the FIR does not provide information about how many acres of San Joaquin spearscale habitat would be last to the project, nor hoer much occupied habitat exists in the so-called mitigation area. The FIR claims that the plant counts from 2006 show the Maples Ranh Project is mitigated.