July 11, 2008

Mr. Jarret Ramaiya
County of San Diego Department of Planning and Land Use
5201 Ruffin Road, Suite B
San Diego, CA 92123-1666

Dear Mr. Ramaiya:

On behalf of the many members of the San Diego County Farm Bureau who farm in the Twin Oaks Valley Community/Regional Planning Area we appreciate this opportunity to comment on the Draft Project Environmental Impact Report for the proposed TERI Center for Research and Life Planning (Draft EIR).  While we appreciate the important work done by the TERI organization in our community, please know that it is our concern that the farmers in this region be allowed to apply their farm practices unfettered by any new restrictions or impacts due to the location of a school facility directly adjacent to or in the vicinity of working farms.

In the analysis of the direct and indirect impacts to existing and possible future agricultural operations within the Zone of Influence, the Draft EIR dwells on and doesn’t move much beyond the use of methyl bromide or other fumigants used in the preparation of soil for planting.  While that is a practice that may be used by farmers, this singular view is too narrow a perspective of the possible impacts to local agriculture.  We would suggest an expanded analysis that better addresses the potential impacts from placing a heavily populated urban use in an agricultural community.  That analysis should include:

1) Discovery, discussion, and suggested mitigation should future agricultural chemical use buffers around school sites be adopted and applied to this particular location.
 
2) Examination beyond the suggested mitigation of traffic signals and Transportation Impact Fee payments of the potential conflicts between school generated traffic and the large trucks needed to deliver farm supplies and move outgoing shipments of finished farm products.
 
3) Assessment, in addition to the stated lack of off site trails, of the potential for trespass, theft, and vandalism on farms due to increased urban activity in the area.

4) The potential impacts and mitigation for new farm operations or changes in crops on existing farms that would not enjoy the protections of the San Diego County and State of California Right-to-Farm laws.
 
5) The impact to farmers from dealing with registered complaints due to noise, dust, and odors emanating from traditional farm practices as a result of adjacent urbanization whether those complaints prove to be founded or not.

Again, thank you for this opportunity to comment.  Should you have any questions please feel free to contact us at any time.

Sincerely,

Eric Larson
Executive Director