Protect San Diego's Canyons and Creeks From Excessive Clearing

Master Storm Water Channel Maintenance Permit PEIR

Recommendations For Decision Makers pdf

Background The MSWMP poses unnecessary and costly impacts to over 70 acres of wetlands, wetlands functions, water quality, natural flood/erosion control, wildlife corridors, and ~29 acres of upland wildlife habitats.

1) Please do not certify this PEIR as written. The MSWMP documentation admits to diminishing important resource values including unmitigated impacts to water quality.

2) The scope of the project should be reduced to focus only on areas that have been demonstrated to result in property damage from flooding. This should save the City money. Staff has removed only a few targeted areas in Rose Canyon due to public comment.

3) Establish a process to address the concerns and issues being raised and the legal deficiencies of the PEIR.

4) Please support a fair CEQA process with public review and comment on the details of each annual plan (or other appropriate interval). Use a "Process IV" with approval by the Planning Commission and appealable to City Council. The current PEIR violates CEQA because it doesn't provide the necessary details for public comment such as maintenance methods, access roads, resource impacts and mitigation. The City proposes to provide the details for a list of channel locations on an annual basis but they will not allow a public review period to comment on these details as required by CEQA!

5) Require that project impacts on water quality and biology and mitigation performance be evaluated and reported on an annual basis.

6) Thoroughly analyze alternative, win-win maintenance methods including:
• Opportunities to increase wetlands for flood and erosion control. Wetlands serve to slow and absorb storm water runoff, thus reducing downstream flooding. They also trap sediment and filter pollutants from runoff before it reaches our coastal waters. Implementation of the adopted Chollas Creek Enhancement Program would serve this purpose.
• Restoration of incised canyon streams could also serve this purpose.
• Low Impact Development techniques such as infiltration, conversion of impermeable surfaces to permeable surfaces, and detention basins where they could capture and filter runoff before discharge to the creek channels. Increased use of residential rain barrels could both reduce storm water runoff and provide a beneficial use of rain water to residents.

7) Mitigation measures should be conducted as close to the project impact site as possible. Mitigation should not be exported out of project areas especially away from urban areas where wetland filtration values, and urban greening are needed most.

8) Giant reed (Arundo donax) rhizomes should be certified dead before removal begins.
It has been proven that mechanical removal of live arundo causes rhizome fragments to spread and arundo to propagate throughout the creek system.

9) Delete the "Enhancement" alternative (mitigating by only removing invasive, non-native plant species in another location). This is a waste of money. Without replacement by native plant container stock the weeds will just grow back.

WRITE A LETTER to your City Councilmember.

Comment Letters on this plan:

San Diego Canyonlands pdf

California Dept of Fish & Game pdf

California Native Plant Society, San Diego Chapter pdf

Friends of Rose Canyon pdf

Friends of 32ND St Canyon pdf

San Diego Audubon Society pdf

Other communities that are solving this problem in better ways

• The SUSTAINABILITY solution adopted by the City of Los Angeles - the Watershed Management Strategic Plan. 
• Reevaluating Stormwater: The Nine Mile Run Model for Restorative Development and Appendix
• 21st Century Water Systems: Scenarios, Visions, and Drivers

The photo below shows an area in Rose Canyon which could be affected by this storm water project. This area has no access roads, and has a natural stream channel, with zero possibility of having property damage from floods, as houses are high above on the mesa top. This area is list as a potential site for 100 feet of clearing using heavy equipment such as bulldozers.

County of San Diego General Plan update

Comment letters 

• Attorney General
• Fege
• CNPS-San Diego

San Diego Open Space Dedication Bill

On December 4, 2007 the San Diego City Council ratified Senator Christine Kehoe’s bill for dedication of roughly 6,600 acres of city-owned land.

• The measure includes over 6000 acres in three regional parks at Mission Trails, Otay Valley, and Los Penasquitos Canyon Reserve.
• The measure also contains 600 plus acres of our urban Canyonlands that underwent a public vetting process and were approved for dedication by the Park and Recreation Board in 1992.
• Dedication provides a layer of protection for the land that requires a 2/3rds vote of the people of San Diego to sell the land or develop the land for any uses other than open space. There is however a provision in the Charter allowing roads/utilities through dedicated lands and allowing active recreational uses.
• Passing the measure saved the City over $1 million in unnecessary surveying and entitlement costs usually associated with the dedication process.

A list of parcels that may be included in future dedication process: Nov. 9, 2006 Report from City Staff: Parcel List

City Council (Parcels Dedicated) December 4, 2007 City Council Dedication