Ventana Chapter retained expert coastal ecologist Peter Baye, Ph.D. to submit comments on the biological resources in the Draft Environmental Impact Report (DEIR) for the proposed horse racing track and housing development on the former Fort Ord military base. The Applicant seeks a project which proposes to construct Monterey Downs, a racetrack and other equestrian use facility, 1280 dwelling units (detached single-family and multi-family), a mix of commercial, office and hotel uses and more.

Dr. Baye comments address 5 deficiencies in the DEIR including: 1. The project description's failure to correctly identify the environmental setting of the project site and vicinity as a stabilized ancient dune system or paleodune. This is a significant omission because of the environmental importance and very limited geographic distribution of this ancient geomorphic feature in California, and its association with relict endemic species. Paleodunes include distinctive variations of the following vegetation types: coastal prairie (grassland), maritime chaparral, seasonal and perennial freshwater marshes, and oak woodlands.

2. The DEIR fails to assess impacts to wetlands habitats and fails to provide minimal survey information regarding the presence, extent, or distribution of wetland habitats. No information is provided regarding the areas surveyed, the dates of surveys, the rainfall year(s), or the qualifications (wetlands expertise) of the observers. 3. Special-status plant species impact criteria are invalid and unsound in terms of biological or regulatory meaning and the DEIR provides inadequate biological analysis of the number, size, viability, and distribution of special-status plant species populations.

Deficiencies 4. and 5. relate to the fact that the project would have significant and unmitigated impacts on California tiger salamander and two important vegetation types, oak woodlands and riparian woodlands. For more information and a full description of these biological concerns see Dr. Baye's letter. (Attached PDF here).