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North Coast Chapter
P.O. Box 1067
Arcata, CA 95518
July 16, 2004
David Ammerman, Permit Manager
Army Corps of Engineers
333 Market Street
San Francisco, CA 94105-2197
Re:
Public Notice Number 28433N
Martin Ranch, Del Norte County, CA
Project Applicant: Elk Valley Rancheria
Dear Mr. Ammerman,
The California Native Plant Society (CNPS) is a nonprofit organization of nearly 10,000
amateurs and professionals dedicated to the preservation of California's diverse native
flora. CNPS conducts a variety of conservation efforts focused on long-term protection
and preservation of native flora in its natural habitat. The Society has been assessing the
status of rare plant species for over 30 years, and is the foremost non-governmental
organization working to protect rare, threatened, and endangered plants in California. The
North Coast Chapter is one of 32 chapters and represents 300 members in Humboldt, Del
Norte and Trinity Counties.
We are writing this letter on behalf of CNPS and the Environmental Protection
Information Center (EPIC) of Garberville, California to urge you to deny the Section 404
permit to fill 9.46 acres on this site. The proposed project does not adequately address
direct, indirect and cumulative impacts, nor does it propose acceptable mitigation for
wetlands slated for destruction. In addition to biological issues, various procedural issues
are not adequately addressed by the Public Notice currently under review. The Army
Corps of Engineers (ACOE) should postpone consideration of this permit until a federal
consistency determination is made by the California Coastal Commission, and until an
Environmental Impact Statement is released for public review and comment. At this point
in time, the project applicant has not met the requirements of applicable federal law, nor
does the public have all the information necessary to review and comment on the
proposal.