Blackwater Notice of Preparation Comments

The DPLU prepares a "Notice of Preparation" or "NOP" that is the starting point for the Environmental Impact Report (EIR). These comments and questions are incorporated into the EIR document, and must be all answered or mitigated in the report. Blackwater will hire a number of consultants to prepare the report to address all these concerns. Then, the DPLU staff looks at the report and it is their job to question the findings of the consultants.

Bringing up multiple issues at this point can make it more difficult for a successful EIR to be produced that makes it through the planning commission. Therefore, we have established this set of pages to collect information from any interested parties, and we will submit these pages to the DPLU staff prior to the deadline. (You may also submit separately).

The strategy of submitting these documents is discussed further down on this page.

Please refer directly to the EIR Notice of Preparation: and then make your comments on one of the appropriate pages, below.

EIR Sections

The following pages contain comments about each of the EIR sections. The description here is a condensed summary of the category. Click on the name of the section to access that page and make your comments. See Help On Making Comments to get started.

I. Aesthetics

Does it impact scenic vistas, damage scenic resources, degrade the visual character of the site, or create light or glare?

According to the CEQA initial study, DPLU said there would be no impact on the aesthetics in terms of scenic vistas. This conclusion is frankly quite ridiculous, as the site is now used as a agricultural use, and would be spoiled by building quite a number of huge buildings, all of which have no design elements. They are just large metal buildings. The large driving track, fuel tank, helicopter pad, and shooting ranges will spoil the natural setting of the valley, and departs substantially from the character of the surrounding areas. The Pacific Crest Trail is only 3.35 miles away, and the peaks nearby, such as Los Pinos Mountain and Morena Butte have clear views into the property, as well as adjacent BLM and Cleveland National Forest Lands.

The property is adjacent to the Cleveland National Forest, and a portion of the site extends into the Forest boundary. In addition, the Hauser Wilderness additions are proposed adjacent to the site. It is clear that approving a huge mercenary soldier boot camp is vastly out of place at this location.

The subject property can be seen from public lands, national forest lands, and wilderness areas, including from the Pacific Coast Trail. The character of the valley will be irreversibly changed from a agricultural use to a very urban setting, with urban simulation area, paved roads and huge buildings. Any lights will result in reflected and leaking light that will reflect into the sky, reducing the aesthetics of the natural dark skys. Star gazers and professional astronomers will not appreciate the additional light produced by this large facility and the additional traffic.

It is inconceivable that this planning group has approved this project on this element alone, and submitted no comments with regard to the aesthetics of this priceless valley.

II. Agriculture Resources

Does it convert farmland, conflict with existing zoning, or change the environment that could threaten farmland?

The project site has land designated as prime farmlands. The site is zoned A70 and A72, Limited Agriculture and General Agriculture. The A70 Use Regulations are intended to create and preserve primarily agricultural crop production. The A72 Use Regulations are intended to create and preserve areas for raising crops and animals. In addition, the site has a special area “A” designator. This denotes that land is a County agricultural preserve. A permit is required to remove the special "A" designator because the intended use clearly violates the agricultural preserve concept.

This site should be preserved as an Agricultural Preserve, and preferably, combined with the Hauser Wilderness areas. The approval of this planning group without addressing this concern points to the complete disregard for the approved zoning of the property, and the wishes of the residents and general public that has an interest in one of the few remaining largely unspoiled valleys in San Diego County.

The property is zone for agriculture, and has been used in that manner. There are no paved roads in the valley. The proposed project will paving these roads, as well as the two-mile driving track, helicopter pad, skid area, etc. The firing ranges convert chicken ranching into those ranges. The large petroleum tank and 18,000 sqft armory may produce hazardous materials that could irreversibly damage the environment of the valley, polluting the ground for generations.

The use of the property under the proposed project would substantially change its use from agricultural to a paramilitary boot camp. This should not be allowed.

III. Air Quality

Does it conflict or obstruct the San Diego Air Quality Strategy, violate any air quality standard, result in considerable net increase in pollutants, or expose sensitive receptors to substantial pollutant concentrations?

There are significant impacts to Air Quality during the construction phase and operational phase of the project. Specific operational issues will include the driving track and shooting ranges. In addition, nearby neighbors (some on the border of the property) have located in the Potrero area specifically due to sensitivities to chemicals or other air contaminants. The exhaust of constant driving track use, as many as 300 shooters at a time, would significantly impact these sensitive receptors within a quarter mile of the site. The air quality issue has been cast aside in the initial environmental impact. The fact that this planning group is doing nothing to address each of these issues speaks volumes regarding to the inappropriate approval of this project prior to adequate airing of the issues. Therefore, the planning group should rescind its decision, consider all these issues in an open forum, and vote on the project AFTER these open meetings have taken place and all the questions of the public have been aired.

IV. Biological Resources

Would it adversely affect any species identified as a candidate, sensitive, or special species status; or would it adversely affect any habitat or other sensitive natural community; or would it adversely affect federally protected wetlands; or interfere with migration patterns; conflict with any Habitat Conservation Plan?

This is perhaps the most significant impact. Not only will the project impact natural vegetation and riparian areas that may never fully recover, but will significantly impact "native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites." Specifically, we are very concerned about the golden eagle nests and recently reported sighting of California Condors flying up from Mexico toward the Laguna mountain areas. There were ten California Condors established in Mexico with the expectation that they may reestablish themselves in the wild. The fact that one has been sighted flying nearby sends a clear message that placing a mercenary bootcamp in this region is substantially out of place.

There are many other animals that will be significantly impacted in addition to the California Condor, and Golden Eagles, such as Stephen's kangaroo rat, least Bell's vireo, Southwestern willow flycatcher, orange-throated hiptail, San Diego horned lizard, turkey vulture, white-tailed kite, loggerhead shrike, Southern California rufous-crowned sparrows, Arroyo toad, California gnatcatcher, and Quino checkerspot butterfly.

Plain and simple, this is the wrong place for a mercenary boot camp.

V. Cultural Resources

Does it change a historical, archaeological, or paleontological resource; does it disturb human remains?

Twenty-one new cultural sites and four isolates have been surveyed on-site. All but one of the sites and isolates are prehistoric resources. At least 11 of these sites are proposed to be destroyed by the project. Loss of these sites will be a terrible consequence of this project, and there is really no way to appropriately preserve them when the region is turned into an urbanized area.

The preliminary assessment is that the area around Cottonwood Creek may have been the site of Kumeyaay village. The project site may have supported several Kumeyaay households at various times throughout the year. Therefore, there is the potential for human remains.

VI. Geology and Soils

Will the project rupture a known earthquake fault, cause strong seismic ground shaking, liquify the ground, cause landslides, soil erosion, loss of topsoil, create unstable geological conditions; be located on expansive soil, have soil incapable of supporting septic tanks?

The project has prepared a Storm water Management Plan. This document is has not been accepted and is not available for public review. The number of people populating the valley when in full operation (350 trainee soldiers) and 60 staff. The typical size of septic system for up to six bedrooms (13 people) would have a liquid capacity of 1,500 gallons (~125 gallons per person). Assuming this can be extrapolated to accommodate nearly 400 persons on site, they would need about 50,000 gallons of tank capacity, or approximately 25 2000-gallon tanks. The proposal only calls for 3 septic tanks. This is about 1/8 of the septic capacity normally calculated for the same number of residences (The population would be equivalent to about 50 residences). Since the soldier-trainees would be residing on-site, we would expect water usage comparable to typical residents, including bathing, drinking, food preparation, cleaning, laundry, etc.

The valley in question is clearly an area where water gathers in a small pond that grows in extent based on the amount of rainfall ("The project site contains drainage swales, which are identified as being 100-year flood hazard areas."). In fact the site plan calls for rainwater detention ponds in various areas. Such an area typically will not handle the amount of water from such a facility, and will require back-up leach fields. In wet years, it may not be feasible to discharge the volume of water likely to be generated by the facility and have it be effectively treated by beneficial microorganisms.

This aspect of the project is clearly a problem and should be more fully addressed by the Potrero CPG.

VII. Hazards and Hazardous Materials

Will the project create a hazard through the transport, release, or emit of hazardous materials, esp. within 1/4 mile of an existing or proposed school; would the project create a hazard for an airport or airstrip; would it impair an emergency response plan?

The project proposes a military and law enforcement training facility including shooting ranges and a driving track. These two project elements involve the routine use, storage and transportation of hazardous materials including ammunition, fuel and oil. The nature of the project could result in the deposition of hazardous materials at the site in the form of lead or other substances related to the military and law enforcement training operations.

The proposed project is adjacent to wildlands that have the potential to support wildland fires. The project proposes a huge 18,000 sqft armory (nearly 1/2 acre) specifically to store dangerous guns and ammunition. A accident at this facility may result in a huge fireball which would result in a massive fire, likely including Potrero and surrounding communities.

There is inadequate escape routes from this valley and the establishment of a densely populated training camp is a terrible idea given the dangerous fires we've seen in recent years. In the last cedar fire, we witnessed gigantic firewalls moving at high rates of speed that would easily trap the trainees in the valley and ignite the ammunition and gasoline to be stored on site, resulting in a unprecedented catastrophe.

VIII. Hydrology and Water Quality

Would the project violate waste discharge requirements, increase pollutants to a water body, degrade surface or groundwater quality, substantially deplete groundwater supplies, alter the drainage pattern, create runoff exceeding drainage systems, provide additional sources of polluted runoff, place housing in a flood hazard area, or increase flooding?

The project proposes the use of well water. It is on a limited aquifer that is shared amongst the residents of the area. This project proposes a substantial population (2-3 time the number of people expected if built out into 20 ranchettes), as well as drawing water for use in fire-suppression training, road-hazards, and the like. As a result, this aquifer will be under severe stress, and will likely result in other wells in the area going dry, and those wells may need to be drilled deeper to access the water. This would be a catastrophe for residents in the area.

Storm water runoff from this valley is part of the system of streams and creeks that feed Barrett Lake and other water systems. With the lead ammunition and petroleum products being used on site, these waters would become contaminated and would need to be further purified for human consumption. Wildlife that depends on clean and pure water will be impacted.

The existence of drainage swales, which are identified as being 100-year flood hazard areas, does not deal with the simultaneous production of a significant amount of waste water from septic system that will not properly leach when such floods occur.

The hydrology and water quality issues in this project are severe and have not be adequately addressed by this planning group or the DPLU.

IX. Land Use and Planning

Will the project divide an established community, conflict with an existing land use plan, policy or regulation of an agency with jurisdiction over the project?

The proposed project is considered an "Environmentally Constrained Areas (ECA)" because it is a County Agricultural Preserve.

The project site is subject to two General Plan Land Use Designations (20) General Agriculture and (23) National Forest and State Parks. The (20) General Agriculture designation is “applied to areas where agricultural use is encouraged, protected and facilitated”. Other uses supportive of and/or compatible with agriculture are also permitted. The (23) National Forest and State parks designation subsection (b) applies to this project. This designation is for those private land-holdings lying within the boundaries of the Cleveland National Forest and outside of Country-Town.

The initial study states that the Agricultural zoning of A72 can allow this project as a "Utility". However, no one agrees that this project is a utility, which is typically a resource commonly used by a community, such as a power station, water station, or communications station. It is nothing of the sort, and classifying this as a utility is nothing more than outright deception.

Therefore, this project should not be allowed to progress based on this fact alone. A mercenary boot-camp is not a utility, plain and simple. It is an outrage to see this attempt to reclassify this as a utility without any serious objections from the Potrero CPG. It is a specific exception that a utility can progress with a Major Use Permit. However, a bootcamp is not a utility, and allowing it under this pretense is truly ridiculous.

X. Mineral Resources

Will the project result in the loss of a known mineral resource or mineral resource recovery site?

XI. Noise

Will the project: Expose people to noise in excess of standards, to excessing groundborne vibration or noise levels, or result in permanent or periodic increase in ambient noise levels in the project vicinity?

Noise one of the most serious problems of this proposal. The project proposes development of shooting ranges, tactical simulation environments, driving track, building facilities and emergency helipad that may all increase noise levels on-site. The applicant claims to have conducted a computerized model of the noise produced by the project, and this was mentioned both in the Potrero CPG meetings and in the project file at the DLPU. However, when the computer model was requested, nothing was provided by DPLU and the request is still outstanding.

According to a simple noise model, noise from gunfire (typically 170 dB at 6 feet) will not get down to loud conversation (60 dB) for 20 km (or about 12 miles). The requirement is 50 dB at the property boundary, and so it is not comprehensible that it is in compliance with this requirement. It is likely that people living within about 8-10 miles will hear constant gunfire from up to 300 or so firearms.

Placing this sort of noise near the Hauser Wilderness areas and the Cleveland National Forest is unforgivable. Rancho La Puerta, a luxury resort within 8 miles of the site will be subject to constant gunfire noise at about the level of normal conversation.

The ad-hoc noise test proposed by the Potrero CPG was canceled and no new test is scheduled. Such a test was a precondition of the approval of the CPG and therefore, its approval should be rescinded and no approval provided until this concern is adequately addresssed. According to the transcription, the actions of the December meeting were recounted as follows:

Motion by Thell Fowler, seconded by Emil Susu to recommend that the Round Potrero Ranch Property is an acceptable site for a possible Blackwater Training Facility with the following conditions: that a noise check be done involving locals to determine acceptable sound levels.

Also, this was supposed to be documented in the rule that the conditions were to be in writing, and such conditions are not found in the file at the DPLU. Therefore, since the original vote and approval had the precondition that a local noise test be conducted, the planning group should make it very clear that no approval has been granted.

XII. Population and Housing

Will the project induce substantial population growth in the area, displace substantial numbers of existing housing or people?

The rated population of the site is substantially higher than that allowed by the zoning, about 2.6 times more. Yet, almost all these people will be essentially incarcerated at the facility, and will not be spending money in beautiful downtown Potrero.

According to Brian Bonfiglio, Blackwater representative, most of the 60 positions could be filled by local workers, but there no guarantee that they would come from the existing population.

XIII. Public Services

Will the project impact the provision of fire or police protection, schools, parks, or other public facilities?

XIV. Recreation

Will the project increase the use of parks, or other facilities; does it include recreational facilities that might adversing impact the environment?

XV. Transportation/Traffic

Will the project increase traffic substantially, exceed the level of service standard for designated roads or highways, result in a change in air traffic patterns, increase traffic hazards, result in inadequate emergency access or parking capacity, or conflict with adopted policies, plans, or programs supporting alternative transportation?

Traffic is a severe concern of this project. The roads leading to the property are winding roads with some sections that are unpaved. They were not designed for traffic from the additional 400 people who may be on site. The Potrero CPG has done nothing to require additional improvements to Round Potrero Road such as widening, paving, and redesigning some of the twists and turns. The initial report says that a traffic study will be provided, but no study is available.

Hwy 94 is already an area of high traffic, far more than intended for the two-lane road due to the proximity to the border crossing at Tecate. Adding more traffic to a densely populated area for this boot camp will exacerbate an already large problem.

Until these traffic studies are provided, the Potrero CPG has no business approving the project.

Emergency access is an obvious huge problem. There is no way to exit the valley except for Round Potrero Road. In the event of a wildfire, residents would be trapped in the valley with a huge stockpile of highly explosive munitions and gasoline. A single helipad is insufficient for evacuation from the site, and should be disallowed on these grounds alone.

XVI. Utilities and Service Systems

Will the project exceed wastewater treatment requirements, result in the construction of new water treatment facilities which could could significant environmental effects, require new storm water drainage facilities, have sufficient water supplies, result in a determination by the wastewater treatment provider, be served by a landfill with sufficient capacity, and comply with solid waste regulations?

The project proposes to discharge domestic waste to on-site wastewater systems (OSWS), also known as septic systems. Discharged wastewater must conform to the Regional Water Quality Control Board’s (RWQCB) applicable standards, including the Regional Basin Plan and the California Water Code.

However, the septic systems proposed are vastly inadequate for the job, only 1/8th the size required for that density of people. 50,000 gallons of tank capacity, or approximately 25 2000-gallon tanks would be required. The proposal only calls for 3 septic tanks. This is about 1/8 of the septic capacity normally calculated for the same number of residences (The population would be equivalent to about 50 residences). Since the soldier-trainees would be residing on-site, we would expect water usage comparable to typical residents, including bathing, drinking, food preparation, cleaning, laundry, etc.

XVII. Mandatory Findings of Significance

Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of fish or wildlife, threaten a plant or animal community, reduce the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?


-- Raymond Lutz - 15 Apr 2007
Topic revision: r7 - 07 May 2008, RaymondLutz
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