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Old 06-17-2004, 04:27 PM
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Default 14-Mile Border Infrastructure System

From: Cindy cindyburrascano@cox.net
Date: 09/13/02
Time: 02:36 AM


I attended a meeting for the 14-Mile Border Infrastructure System (Triple Border Fence Project). The gentleman responsible for the EIS stated that there was no reason for them to try to minimize impacts to the local habitat conservation plan preserve. Habitat Plans fall under Section 10 Consultation of the ESA and since they are a federal agency, they are only subject to Section 7 of ESA. Essentially any federal agency can ignore protections provided in a habitat plan. I would suggest CNPS change its stance on supporting any HCP/NCCP if USFWS can't even get a Federal agency to work with other agencies (NOAA,EPA, USFWS, Coastal Conservancy, DFG, State Parks) to find alternatives that will minimize impacts to a preserve. The draft EIS for the border infrastructure system will impact a Core Biological Area that was to be preserved under MSCP. It will take State Parks lands that support rare species and important archaelogical sites. The sole U.S. population of Dudleya attenuata ssp orcuttii occurs in the State Park and adjacent mesa and will be impacted by the project. The project will take County Park lands purchased with 1988 Bond Act funds that require an act of state legislature and a public vote to change land uses or condemnation must be used. The project will impact wetlands identified as critical habitat for Least Bell's vireo and Southwestern willow flycatcher. The draft EIS did not identify the presence of Aphanisma blitoides, Camissonia lewissii, Coreposis maritima, Heterotheca sessiliflora, Lasthenia coronaria, Lotus nuttallianus, Nemacaulis denudata, Phacelia stellaris, Ribes viburnifolium, or Senecio aphanactis in the plan area although all are known from the project area. No mitigation was proposed for impacts to Ornithostaphylos oppositifolia, Ferocactus viridescens, Euphorbia misera, Cordylanthus orcuttianus, Agave shawii, Bergerocactus emoryi, Dudleya attenuata ssp orcuttii, Opuntia parryi serpentina, or Atriplex pacifica. Habitat mitigation ratios for the project were less than what is required for the approved habitat plan when this plan isn't even compliant with the requirements of the plan. Maritime succulent scrub was defined as deerweed, desert encelia, sweet fennel, Miner's lettuce, little barley, white-stemmed filaree, and Italian ryegrass in the document which is so wrong it is pitiful. There are two species, Desert encelia and Coreopsis gigantia, listed for the area that don't even occur in the plan area. Plant assemblages that only occur in the U.S. on the coastal mesas in this specific area will be lost. The project with use fill material cut from adjacent mesas to build a road structure across a major drainage moving over 2 million cubic yards in just that single drainage (there is additional cut and fills with the project at other sites). The soils being moved are identified as being severely erodible and unstable yet 1.5:1 slopes are being planned for the project. The City of San Diego Planning Department will not let developers build with those slopes on those soils as the slopes are subject to failure and/or they cannot be adequately revegetated to prevent erosion problems and they informed Border Patrol and Army Corps of Engineers of that fact. The project hasn't been changed. This is occurring within 3 miles and less of the Tijuana Estuary which already has a major siltation problem. Approximately $450,000,000 taxpayer dollars have been invested in acquisition, cleanup, restoration, and enhancement in the Tijuana River Valley and Border Highlands and these funds will be largely wasted if the preferred alternative is built. The cut will impact 41% of the sole U.S. population of Ornithostaphylos oppositifolia, a state listed species. Please contact Senators Feinstein, Boxer, and Lieberman to ensure that the Hunter Rider that was attached to the Homeland Security Bill is ommitted from the Bill that gets sent to the President. The Rider will ensure that Border Patrol continues to ignore the requests by agencies, jurisdictions, and environmental groups to find a less impactive alternative. Reptiles and birds do not fair well with the preferred alternative either and Burrowing owl impacts are such that the species will be jeopardized in area. Occupied Quino Checkerspot butterfly habitat is proposed for major blasting of rock areas by Otay Mountain to permit construction of infrastructure. The likely impacts to the estuary from a failed road structure (they are proposing 2 eight foot culverts in a drainage that has parts of houses flowing down from Mexico in wet years) will be devastating. Cordylanthus maritimus occurs in the salt marsh. In January of 2002, Chief Border Patrol Agent William Veal boasted before a congressional subcommittee that apprehensions along the 66-mile long San Diego sector were "at a 28-year low". The current staffing is apparently sufficient to stem the flow even when there is an area of the current fence where one can walk over the fence and another area where the fence has been washed away for years (?). The 14-mile Infrastructure project has already exceeded by 2x the original funding for the project and the expensive remaining approximately 5 miles of the project will at least double the figure that has already been spent to build and mitigate. At tonight's meeting I asked for figures on how many people are crossing in the areas where the multiple border fences have already been built and no one could give me an answer. Having talked with agents previously, I know people are crossing those areas. The Border Agency Fire Council reported that in 1994 prior to Operation Gatekeeper there were 24 fires in the southern portion of the San Ysidro Mountains where immigrants are now crossing. In 1996, there were 354 fires. Multi-millions of dollars have been spent on fire control efforts due to Operation Gatekeeper. A 2002 Public Policy Institute of California report (accessible from their website) found 1) there is no evidence that the border enforcement build-up has substantially reduced unauthorized border crossings, 2) the is strong evidence that unauthorized migrants are staying longer in the U.S. during the period of increased enforcement, 3) the total number of unauthorized immigrants residing in the U.S. increased substantially during the mid to late 1990s (the number of unauthorized farm workers increased substantially during the period of increased border enforcement), 4) the border enforcement strategy has changed crossing places of migrants and increased costs associated with crossing of the border, 5) the number of unauthorized migrants who died while attempting to cross the border has increased. Perhaps a better, less expensive successful approach to the problem would be developing a worker permit program. The current buildup has been effective at reducing crossings in the coastal area but has not stemmed the problem. Why does an estuary and a habitat plan have to be impacted?
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