Comment from Carl Wishner, Botanist, Envicom
“I think it's very important to include checklists in CEQA documents. It's one of the best indications of the competence and thoroughness of the investigators. I have recently had to take over several EIR preparation tasks where supposedly all the biological survey work had already been done by others, and I am supposed to write the documents based on their work. In each case, the prior work was beyond inadequate. Moreover, it was obvious the investigators were incorrect in many of their determinations. In one example, a firm that I shall not name had been studying a property for over two years, and had a species list of 43 vascular plant taxa. I examined the site on two consecutive days and found 238 taxa. In another recent example, another reputable firm had been studying a site for more than two years, and had a species list of 68 species. Again, I examined the site on two consecutive days and found 220 taxa. There are many more examples that I could cite. Unfortunately, there's no real objective way to recognize such incompetence and inadequacy, except by careful examination of species lists, and usually some field checking by someone with experience. The same goes for wildlife observations. When I see that observers have seen only a handful of lizards and birds, I realize they didn't get out of their cars when they did their surveys.”
|