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You can also go to http://LAWetlands.org/oaks.htm and print off letters. There are also links to find out more about the project, including pics of ancient trees. But if you do nothing, ACE will be helpless to avoid issuing the permit, and there will not be any in-depth examination of the terrible losses. On the Hellman project in Seal Beach, when they bulldozed just 18 acres, hundreds of rabbits were homeless, found in streets and lawns for months, and hopelessly wandering back over the plowed soil piteously seeking their lost burrows -- and dead relatives. Meanwhile, our raptors go hungry and our land grows a little more cancerous concrete. Trabuco is a little more hidden away, but no less vulnerable. WRITE TODAY! HERE IS THE LETTER I SENT, FEEL FREE TO USE ALL OR PART OF IT, OR MAKE UP YOUR OWN. THERE IS AN ARMY CORPS ADVISORY, IF YOU WISH, I WILL FAX IT TO YOU OR MAIL A COPY. JUST GIVE ME A CALL. ----------------------------------------------------------- Attn.
Jae Chung, Army Corps of Engineers Dec. 20, 2002 RE: Oppose CESPL-CO-R-200100733-YJC, Saddle Creek VIA EMAIL, FAX and US MAIL Dear A.C.E. Mr. Chung: Please hold a public hearing on this project, known as "Saddle Creek" (and "Saddle Crest") by Rutter Development, which, at minimum, requires a federal Environmental Impact Statement, in my view, because of the very serious effects on the waters of the USA, the already impaired Aliso Creek, and the potential effects on the Coastal Zone via over-urbanization of open land, and for other reasons. 1.
THE PROJECT WOULD FILL 10,155 FEET OF STREAMS OF THE UNITED STATES by
dumping 4,000 cubic yards of fill into upper tributaries and seasonal
streams of Aliso Creek. This would destroy .43 acres of delineated wetland
as well as unknown impacts on the vital 4.86 acres in ACE jurisdiction.
This would result in loss of rural habitat in a region rapidly losing
such resources due to rampant development, magnifying the effects of the
loss to great numbers of people in the area. Hundreds of truck trips would
be required to cross streams, according to a recent hearing before the
Orange County Planning Commission. 3. TESTING FOR FAIRY SHRIMP, ARROYO TOAD and other endangered species was admittedly difficult due to the dry season, lack of moisture and attendant extended dry period for many seasonal streams, pools and wetland habitat. Much more intense and extended testing over periods of varying rainfall and other conditions are necessary due to the nature of seasonal habitat and potential of listed species which may depend on such ephemeral resources. 4. ARCHAEOLOGICAL TESTING HAS NOT BEEN ADEQUATE. There are several archaeological sites within the project area including several prehistoric archaeological sites. While some testing has occurred, the appropriate Juaneno (Acjachemen) Tribal authorities must be consulted, and the survey must be peer-reviewed just as occurred during the excavation of ORA-264 in Seal Beach. Some of these sites might qualify for Section 106 status (National Register of Historic Places) and, if so, destruction of them would result in irretrevable loss of cultural resources (sources available during the hearing). 5. SURVEY OF HISTORIC SITES HAS NOT BEEN ADEQUATE. The project area includes the probable location of the first school in Orange County, and an historic farmstead associated with an olive grove. These, and others, must be evaluated for potential Section 106 clearance. The project might impact the Aliso Creek National Register District, extending along the entire Aliso Creek drainage, which may have been determined as eligible for listing. Sites within a National Register District could mean that the resources are eligible as contributing elements to the District. There may be a disconnect between whatever CEQA testing on-site and their National Register status (sources available during the hearing). 6. A COASTAL PERMIT MAY BE REQUIRED if runoff from the project impacts the Coastal Zone as specified in the Coastal Zone Management Act. Bio-swales and retention basins proposed in the project may not be adequate to protect the watershed, parts of which are listed under Sect. 303d of the Clean Water Act as an impaired body. 7. COMPENSATORY MITIGATION PROPOSAL IS INADEQUATE, and the effects of the project have not been equated with the hypothetical benefits of off-site mitigation credits. 8. Foothill Trabuco Specific Plan (F/TSP) has recently been modified by the Orange County Planning Commission to accomodate this project. These changes may weaken F/TSP and change the character of the NCCP areas and the entire region. Such changes must be evaluated, and the regional effects considered in the EIS. 9. PROJECT PURPOSE IS RESIDENTIAL DEVELOPMENT, which may be inappropriate for the area in question. Fire danger, flooding, earth movement and other catastrophic dangers might require federal bailout of housing via FEMA, resulting in the United States assuming inordinate risk for the benefit of a private developer's profit. 10. ACE PROPOSED SPECIAL CONDITION 1 IS NOT ADEQUATE to offset project effect. "Restoring" 2.6 other acres "within the Aliso Creek watershed" is a game of musical chairs -- after a period of "monitoring", the "restored" area might not survive. There is only so much habitat, leaving it alone may be the best restoration. What is certain if the project goes forward is the loss of existing resources, resulting in a net loss of wetlands. 11. ACE PROPOSED SPECIAL CONDITION 2 would allow potential take (kill) of California gnatcatcher and other unknown as yet effects on endangered and stressed species. 12. ACE PROPOSED SPECIAL CONDITION 3 is inadequate to protect potential archaeological resources. In addition to a qualified archaeologist, the Hellman project in Seal Beach required 4 Native American monitors chosen from the local tribe, and with communication with all members of the tribe. This project would require similar protection of at least 4 Native American monitors. 13. WETLANDS MITIGATION IS NOT ADEQUATE, because there is just no suitable habitat in the area which can replace existing wetlands. Habitat cannot be *constructed* at will, or moved from one place to another. Even setting high mitigation ratios, such as 5:1, is not adequate because there just is no suitable potential habitat for replacement candidate in the area. Once these resources of the United States are gone, they are gone forever, with only paper guarantees of "good intentions" to replace them. Thank you, Signature_______ Back to T.O.C. 2
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