BIOLOGICAL STUDY LTR 2020-02-11
February 11, 2020
Mr. Garrett Simon
CM Wave Development LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
SUBJECT: BIOLOGICAL RESOURCE STUDY COMMENTS
GENERAL PLAN AMENDMENT 2019-0002
ZONE CHANGE 2019-0004
SPECIFIC PLAN 2019-0003 (AMENDMENT 5 TO SP 03-067)
TENTATIVE TRACT MAP 2019-0005 (TTM 37815)
MASTER PROJECT 2019-0004
Dear Mr. Simon,
The City’s Planning staff has completed review of the project’s biological resources report,
prepared by LSA, and has the following comments:
1. The Study is uneven in its description of non-listed sensitive species. Although specific
mitigation for burrowing owl and bats is discussed, no discussion of the plants, reptiles
or other birds’ likelihood of occurring on site is provided, nor is there any mitigation
described. For all 10 species listed on page 7 or the study, an explanation of their
likelihood to occur, and the reason why they do or do not require mitigation should
be provided. For example, does the site provide appropriate nesting or foraging
habitat for the raptors listed? The description of burrowing owl should also describe
the requirements for the species under the CVMSHCP, what suitable habitat was
identified, whether the species or its sign was identified on the site, etc.
2. The mitigation measure for bats appears incomplete. Although a relocation plan and
consultation with CDFW is described, no performance standards are provided. These
should be added, so that it can be demonstrated that the impact would be fully
mitigated.
3. There should be a subsection, before the Cumulative Impact section, of Mitigation
Measures, which lists all requirements in one location.
If you have any questions please contact me at ncriste@terranovaplanning.com, and/or at (760)
777-7132 or (760) 341-4800.
Sincerely,
Nicole Sauviat Criste
Consulting Planner