HomeMy WebLinkAbout3.1 Supplement ITEM 3.1
SUPPLEMENTAL NO. 1
COMMITTEE FOR SIERRA. I l`\ y'}� CALIFORNIA
GREEN FOOTHILLS CLUB Santa Clara Valley NATIVE PLANT SOCIETY
Audubon Society
August 30,2016.
Suzanne Avila,Planning Director
City of Los Altos Hills
26379 Fremont Road
Los Altos Hills,'CA 94022
Dear Ms.Avila,
Re: Mitigated Negative Declaration for Stirling Subdivision
Please accept the following comments on behalf of the California Native Plant Society(CNPS),
Committee for Green Foothills(CGF), Santa Clara Valley Audubon Society(SCVAS),and the
Loma Prieta Chapter of the Sierra Club(LPSC)regarding the proposed subdivision project at
28030 Natoma Road in Los Altos Hills. The Initial Study/Mitigated Negative Declaration(MND)
submitted in October 2015 is inadequate in establishing baseline conditions for the project site
and in addressing potential impacts to biological resources and water quality.The MND fails to
comply with the requirements of CEQA,and the City must require an environmental impact
report(EIR)that analyzes potentially significant environmental impacts,proposes adequate
mitigation,and assesses alternatives.
The development is on a largely undeveloped, environmentally sensitive 18-acre parcel and one
of the largest remaining wildlife-significant,privately owned lots in Los Altos Hills(LAH). The
site is located at the Matadero Creek headwaters,contains hundreds of mature heritage oak trees
and abundant native flora and fauna, and is a hub for wildlife moving between major open space
preserve lands in the area.
We have reviewed the letter submitted to the City by the Friends of Upper Matadero Creek and
support their concerns about both the project as proposed and the inadequacy of the MND. Our
concerns include:
Impacts on Matadero Creek.The MND proposes a footbridge over Matadero Creek,but
provides no description of this bridge or its potential impacts. The applicant has not determined if
the planned bridge will require permits from the agencies with potential jurisdiction and thus
reflects neither input from those agencies nor any permit conditions that might mitigate impacts.
The MND also fails to adequately describe how increased stormwater run-off will be managed.
Impacts on wildlife.The project site is used by numerous species for movement,cover,
sustenance and nesting. Species include deer, coyote,bobcat,fox,raccoon,possum,many small
mammals,reptiles, and amphibians,as well as local and migratory birds,including species of
special concern(e.g.,white-tailed kite,Nuttall's woodpecker,oak titmouse).The project as
proposed has potential to cause loss of wildlife habitat and obstruction of established wildlife
movement routes.
The site provides vital,well-established wildlife movement routes between Arastradero Preserve,
Foothills Park,Poor Clare's Monastery lands, and Byrne Open Space Preserve,with links to
lands to the west owned by the Midpeninsula Open Space District.The cumulative impact of
property-line fencing on lots surrounding the project has made existing corridors through this
largely undeveloped parcel even more critical.Without additional open space buffers and/or
fence setbacks around and within the project site,wildlife will be forced onto local roads.
Maintaining wildlife corridors is beneficial to all; it helps keep wildlife off roads,maintains
healthy population balance of species,allows foragers(deer,rabbits).to thin brush volume and
fireload,and allows predators to remove diseased animals.
The LAH General Plan specifies planning for wildlife.Section 315 of the Conservation Element
of the Los Altos Hills General Plan provides as follows:
There is a need for planning to provide for effective protection and conservation of the
Town's wildlife heritage,while continuing to allow appropriate development and land
use. Planning for natural movement of wildlife can help to avoid,minimize and
compensate for serious negative impacts on wildlife and humans. Areas that link wildlife
habitat have become vital because native animals such as deer,fox,bobcat and coyote are
prevented by roads,fences,homes,and other development from moving freely as they
once did.
Although a conservation easement is proposed for part of the slope above the creek,the project as
proposed will block wildlife movement along the opposite(eastern)border and funnel it to a
hazardous blind curve on Natoma Road.Relying on public roads for movement of wildlife is
detrimental and dangerous to both animals and people.
Surveys for special-status plant species.The MND failed to conduct surveys for special-status
plants that have potential to occur on the site.Further,the developers proposed.tosurvey only the
"impact area"rather than the entire site,under the assumption that other areas will be left
undisturbed.Because LAH allows removal of plants from conservation easements,the entire site
must be surveyed.
We urge you to reject the MND and require further environmental review and mitigation.
Respectfully submitted,
/4-;/-404'd
Shani Kleinhaus Alice C. Kaufman
Environmental Advocate Legislative Advocate
Santa.Clara Valley Audubon Society Committee for Green Foothills
(X44.sie-- .. 1G�
Linda Ruthruff Michael Ferreira
Chair,Conservation Committee Conservation Chair
California Native Plant Society Sierra Club,Loma Prieta Chapter