February 1, 2022 Mr. Rob Hingtgen Land Use/Environmental Planner County of San Diego Planning and Development Services 5510 Overland Avenue San Diego, CA 92123 Subject:
Sandia Creek Drive Bridge Replacement and Fish Passage Project PDS2020-LDGRMJ-30309; PDS2020-LDPIIP-60093; Log No. PDS2021-ER-21-02-005
Reference:
Santa Margarita River Hydrology, Hydraulics and Sedimentation Study, dated July 2000, by WEST Consultants Sandia Creek Drive Bridge Replacement Alternatives Analysis and 30% Design, dated February 2018, by River Focus Hydraulic/Scour Report, dated May 2021, by River Focus
Mr. Hingtgen: Thank you for the opportunity to comment on the referenced project on Sandia Creek Drive. For background, we have worked in the area for over 10 years, completing both a steelhead habitat assessment and the alternatives analysis reference above. We have had the good fortune to meet and befriend many locals and find the Santa Margarita River to be a hidden jewel of northern San Diego County. As advocates for open space and community we support fish passage projects, however, we have developed serious concerns regarding the project as proposed and want to share them with you and the local community. Our comments are intended in the spirit of the rigorous review necessary to complete a valid and competent project. We have offered our concerns to both CalTrout and the CA Department of Fish and Wildlife; our apprehension lies not with the proposed bridge itself but in the flood flows that will affect Sandia Creek Drive downstream from the proposed bridge if it is constructed. Historical reporting and local experience, together with the evening news, all document that Sandia Creek Drive from the area of De Luz Road to the project site floods at the design criteria of the bridge. We have concluded that the proposed bridge will be inaccessible from the southern approach during large storms; from the north, the proposed bridge will deceptively facilitate access to a narrow and flooded canyon during 25-, 50-, and 100-year flood events. Our work herein provides greater detail on the genesis of those concerns. The Hydraulic/Scour Report contained in the CEQA document is of particular relevance to our concerns. Figure 1 reproduces the cover of that report. Note that the proposed bridge structure is in the lower right quadrant, and the lower left quadrant is downstream from the bridge.
South Coast Chapter
3154 Glendale Blvd. #117 Los Angeles, CA 90039 SouthCoastTU@gmail.com www.SouthCoastTU.com