Fallbrook Village News June 9, 2011 Issue 23
Fallbrook Community Planning Group formally asks Riverside County Planning Department to reject adoption of a Statement of Overriding Considerations
FALLBROOK - On May 16, the Fallbrook Community Planning Group and Fallbrook Design Review Board formally asked the Riverside County Planning Department to reject adoption of a Statement of Overriding Consideration for the Liberty Quarry project in the Rainbow area. In a letter sent to David L. Jones, the Fallbrook group cited numerous reasons for their opposition to the proposed project.
The letter, provided to the Village News by FCPG Chairman Jim Russell, reads as follows:
"The Fallbrook Planning Group was authorized to review the Liberty Quarry Draft Environmental Impact Report (Draft EIR) by the San Diego County Board of Supervisors in 2006. We commented on that report with a letter on September 2, 2009. Recently the County of Riverside published their responses to the comments received on the Draft EIR. The Fallbrook Planning Group reviewed these responses as well as the comments submitted to the County of Riverside by other groups and individuals and the County's responses to their comments as well. This letter is the result of the May 16th meeting of the Fallbrook Planning Group when all the responses and comments related to the Draft EIR were discussed.
"The following motion was passed: "The Fallbrook Planning Group joins with the City of Temecula, the Rainbow Planning Group, Friends of Santa Margarita River, Endangered Habitats League and the Nature Conservancy in opposing this project on the grounds of the negative aesthetics of the project on the surrounding communities and the project's risks to public health and safety."
"Some of the major points felt to still be outstanding in light of the responses are:
1) The most impressive list of comments was provided by the City of Temecula. They not only had applied professionals within their agency focus on the report in their fields of expertise, but also had private sector professionals respond to the report as well. While lengthy responses were provided, there appears to be a clear difference of view on the completeness of the report and its ability to withstand professional scrutiny. The Fallbrook Planning Group agrees with the City of Temecula in requesting that the reports in the EIR be modified and re-circulated prior to presenting it to the Riverside Board of Supervisors.
2) The Group felt that the response to our concern about the sound studies not addressing the effects on animals was not adequate. Noise generated in rock mining is created by multifaceted processes in the production of various types of construction materials required for residential and commercial purposes. These components consist of blasting, crushing, filtering, and hauling of the finished product to the final destination. Blasting, although often considered as a major noise component of the rock mining operation contributes a small amount of noise do to the "bored hole" blasting techniques universally applied in rock mining. The major components of non indigenous noise are generated by sustained operations to reduce large rock components to usable portions of rock and the hauling of the finished material to the construction site. This "crushing" and "hauling" operation generates "noise" components far above the human audible spectrum but not that of the indigenous wildlife in the surrounding area. Since the noise sensors were located only on I-15 and the conclusion only states that the noise level increase is not significant relative to I-15 traffic, how is that relevant to the rest of the surrounding area and the wildlife that resides there? Since the wildlife audible spectrum is higher in frequency than the human spectrum, and since wildlife does not usually reside next to I-15, we continue to maintain that the "noise" studies are flawed and do not truly represent the impact on the wildlife indigenous to the area. Without additional noise studies with wide frequency spectrum capability, it is not possible to conclude that "the noise impact is not significant."
3) The importance of the wildlife corridor which provides a linkage between the Palomar Mountain Range and the Santa Ana Mountains has not been sufficiently addressed. This corridor is essential to the future of the Mountain Lion, top of the Ecosystem. Since the Liberty Quarry project extends beyond the Special Linkage Area designated in the Riverside County MSHCP, its operations will inhibit the free movement of wildlife. San Diego County has designed their Habitat Conservation Plan to provide connectivity to the Riverside County plan for this necessary linkage, and we urge Riverside County to do the same. The limited mitigation measures listed in the FEIR cannot adequately or reliably provide safe passage for these large predators.
As a more adequate mitigation measure, Liberty Quarry should support and promote the "Potential Bridge" indicated in the DEIR. This could be funded, as suggested by the Liberty Quarry representative at public meetings, by a per-truck fee which would provide funding for the bridge while partnering with Environmental Agencies.
4) In the comments from the County of San Diego Department of Planning and Land Use, the requirements of the I-15 Corridor Design Guidelines are mentioned. The response to this comment was to outline the project answer to the guidelines. But we maintain that the proposed cuts and fills for the access road to the project will exceed the slope grading and the ridgeline grading limits contained in the I-15 Corridor Design Guidelines. These guidelines will not be met as long as the access road climbs the steep slope adjacent to the weigh station.
5) The biggest problems, however, continue to be the overall Air Quality, Biological Resource, Traffic/Transportation and Utility impacts of this project. The Draft EIR admits that these are significant and unavoidable impacts that cannot be mitigated. The response simply concludes that a statement of overriding concern must be adopted by the Riverside Board of Supervisors. The Fallbrook Planning Group, after reviewing all of the comments and responses on these topics, can find no clear evidence that warrants a statement of overriding concern (required by CEQA). Such a statement essentially requires that the aesthetics of the surrounding communities and the public health and safety of the residents be compromised in order to permit a project like this in this location.
"The Fallbrook Community Planning Group, with sincere thought and consideration of the many issues involved and the serious potential impacts for the residents of northern San Diego County, urges the County of Riverside to reject the adoption of a Statement of Overriding Consideration for this project."
The letter, provided to the Village News by FCPG Chairman Jim Russell, reads as follows:
"The Fallbrook Planning Group was authorized to review the Liberty Quarry Draft Environmental Impact Report (Draft EIR) by the San Diego County Board of Supervisors in 2006. We commented on that report with a letter on September 2, 2009. Recently the County of Riverside published their responses to the comments received on the Draft EIR. The Fallbrook Planning Group reviewed these responses as well as the comments submitted to the County of Riverside by other groups and individuals and the County's responses to their comments as well. This letter is the result of the May 16th meeting of the Fallbrook Planning Group when all the responses and comments related to the Draft EIR were discussed.
"The following motion was passed: "The Fallbrook Planning Group joins with the City of Temecula, the Rainbow Planning Group, Friends of Santa Margarita River, Endangered Habitats League and the Nature Conservancy in opposing this project on the grounds of the negative aesthetics of the project on the surrounding communities and the project's risks to public health and safety."
"Some of the major points felt to still be outstanding in light of the responses are:
1) The most impressive list of comments was provided by the City of Temecula. They not only had applied professionals within their agency focus on the report in their fields of expertise, but also had private sector professionals respond to the report as well. While lengthy responses were provided, there appears to be a clear difference of view on the completeness of the report and its ability to withstand professional scrutiny. The Fallbrook Planning Group agrees with the City of Temecula in requesting that the reports in the EIR be modified and re-circulated prior to presenting it to the Riverside Board of Supervisors.
2) The Group felt that the response to our concern about the sound studies not addressing the effects on animals was not adequate. Noise generated in rock mining is created by multifaceted processes in the production of various types of construction materials required for residential and commercial purposes. These components consist of blasting, crushing, filtering, and hauling of the finished product to the final destination. Blasting, although often considered as a major noise component of the rock mining operation contributes a small amount of noise do to the "bored hole" blasting techniques universally applied in rock mining. The major components of non indigenous noise are generated by sustained operations to reduce large rock components to usable portions of rock and the hauling of the finished material to the construction site. This "crushing" and "hauling" operation generates "noise" components far above the human audible spectrum but not that of the indigenous wildlife in the surrounding area. Since the noise sensors were located only on I-15 and the conclusion only states that the noise level increase is not significant relative to I-15 traffic, how is that relevant to the rest of the surrounding area and the wildlife that resides there? Since the wildlife audible spectrum is higher in frequency than the human spectrum, and since wildlife does not usually reside next to I-15, we continue to maintain that the "noise" studies are flawed and do not truly represent the impact on the wildlife indigenous to the area. Without additional noise studies with wide frequency spectrum capability, it is not possible to conclude that "the noise impact is not significant."
3) The importance of the wildlife corridor which provides a linkage between the Palomar Mountain Range and the Santa Ana Mountains has not been sufficiently addressed. This corridor is essential to the future of the Mountain Lion, top of the Ecosystem. Since the Liberty Quarry project extends beyond the Special Linkage Area designated in the Riverside County MSHCP, its operations will inhibit the free movement of wildlife. San Diego County has designed their Habitat Conservation Plan to provide connectivity to the Riverside County plan for this necessary linkage, and we urge Riverside County to do the same. The limited mitigation measures listed in the FEIR cannot adequately or reliably provide safe passage for these large predators.
As a more adequate mitigation measure, Liberty Quarry should support and promote the "Potential Bridge" indicated in the DEIR. This could be funded, as suggested by the Liberty Quarry representative at public meetings, by a per-truck fee which would provide funding for the bridge while partnering with Environmental Agencies.
4) In the comments from the County of San Diego Department of Planning and Land Use, the requirements of the I-15 Corridor Design Guidelines are mentioned. The response to this comment was to outline the project answer to the guidelines. But we maintain that the proposed cuts and fills for the access road to the project will exceed the slope grading and the ridgeline grading limits contained in the I-15 Corridor Design Guidelines. These guidelines will not be met as long as the access road climbs the steep slope adjacent to the weigh station.
5) The biggest problems, however, continue to be the overall Air Quality, Biological Resource, Traffic/Transportation and Utility impacts of this project. The Draft EIR admits that these are significant and unavoidable impacts that cannot be mitigated. The response simply concludes that a statement of overriding concern must be adopted by the Riverside Board of Supervisors. The Fallbrook Planning Group, after reviewing all of the comments and responses on these topics, can find no clear evidence that warrants a statement of overriding concern (required by CEQA). Such a statement essentially requires that the aesthetics of the surrounding communities and the public health and safety of the residents be compromised in order to permit a project like this in this location.
"The Fallbrook Community Planning Group, with sincere thought and consideration of the many issues involved and the serious potential impacts for the residents of northern San Diego County, urges the County of Riverside to reject the adoption of a Statement of Overriding Consideration for this project."
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