EHL submitted CEQA comments on ill-conceived “villages” whose disastrous impacts have fully come to light 26 years after initial approval, as well as on a damaging new proposal in the North County.

In 1992, the City of Chula Vista and County of San Diego adopted a massive development scheme for the 20,000-acre Otay Ranch. While touting its habitat set aside, in reality, development targeted prime coastal sage scrub and important raptor foraging habitat, leaving only the steep slopes untouched. Fragmentation of habitat was severe. In fairness, the most urban parts of the development were ahead of their time in being transit friendly – but only the most urban parts.

Approval of the project was against wildlife agency advice. Needs of the California gnatcatcher – not listed until a year later – were overtly ignored by the Board of Supervisors. EHL worked hard to put in place a better reserve design, but to no avail.

When the MSCP was adopted, the wildlife agencies negotiated for and obtained some concessions, such as an acquisition area and land exchanges. But as the most damaging development bubbles now come forward years later, the depth of the ecological disaster has become fully apparent. In response, EHL has already submitted detailed CEQA comments on biology, legal, and other subjects. We will submit more in the coming weeks.

The Otay Ranch “Resort Village” north of Otay Lake would develop the most important habitat in San Diego County for the highly endangered quino checkerspot butterfly. It is unlikely that even a scaled back development would preserve this critical population. The quino is not a covered species under the MSCP and its take would need subsequent ESA take permits. 

Compounding the impact, the nearby Proctor Valley development would create “donut holes” in the surrounding National Wildlife Refuge, with grave consequences for golden eagles, quino, and the ecosystem as a whole. EHL has used an eagle behavior model from the US Geological Survey to graphically show the severity of the eagle impacts. Tragically, past opportunities to purchase Proctor Valley were lost, and the current owner is not a willing seller.

A complicating factor for the Proctor Valley development is that portions of the property are excluded from the MSCP take permits. However, the County is proposing to develop these lands using a mechanism not allowed by the MSCP. EHL has submitted legal analyses in support of the wildlife agency position. We will also continue to work with the Resort and Proctor Valley landowners and the County on solutions.

This same general pattern is evident in the North County. There, Newland Sierra is proposing 2,100 units of automobile dependent sprawl (with no affordable housing). The project preserves only 1/3 of a large habitat block needed for the North County MSCP, now under preparation, as well as blocks wildlife connectivity. County staff has recommended granting an unjustified exemption from the County's Resource Protection Ordinance to facilitate the project. Staff has also misconstrued the General Plan in order to make findings that that project was consistent with growth guidelines.

EHL submitted biological comments under CEQA and testified against the project at the Planning Commission. Against wildlife agency advice and the recommendation of all three affected County Planning Groups, the Commission nevertheless rubberstamped the proposal.

As a last resort, EHL is prepared to pursue legal action in order to save species and ecosystems.