Re.: Ordinance Amendment #OA 1-2005; expanding Mining and Processing Use to Asphalt Plants
Dear Supervisors:
Peregrine Audubon has reviewed the Ordinance Amendment # OA 1-2005 staff report and found the negative declaration entirely inappropriate for the following reasons.
This major zoning change will have long-term consequences that are not fully addressed in the report. Careful consideration of the consequences of this proposed action is warranted and we therefore request an EIR before action be taken on the issue.
Expanding the potential location of such industrial plants to numerous gravel-mining sites would lead to the degradation and interruption of plant and animal habitat and introduce risk of toxic contamination in many remote locations. Creating islands of industry on Resource lands is inconsistent with the General Plan and increases biological fragmentation. The existing zoning code correctly recognizes that simple mineral extraction and such heavy industrial processing activities are not compatible.
The Biological Study was based on exactly TWO site visits (8/3/04 and 9/16/04) by two different individuals.Ý Surveys conducted at that time of year could not have adequately addressed either special status annual plants or breeding birds.
The first recipient of this County action appears to be Harris Quarry, operated by Northern Aggregates. Such industrial operations in this location are inconsistent with all the land conservation easement actions currently in progress with the Church of the Golden Rule.
Another permanent asphalt and concrete plant is not needed. According to the staff report for OA 1-2005, existing asphalt and concrete batch plants operate far below production capacity. Current zoning allows for temporary plants in non-industrial areas for specific projects, such as the Highway 101 by-pass. The existing exemption for a specific project already allows for competition.
Thank you for your time and attention to these concerns.
Sincerely,
Roger W. Foote
President
Peregrine Audubon Society