Comment from Jim Greaves, Ornithologist
“I haven't got a problem with having a list of actually found taxa attached. I do however OBJECT to what I see as generalized lists that include many taxa that one has either not actually seen, or one is under some impression "ought to be" at a site. We see these lists ALL the time in government CEQA documents, which list every species ever found in a county, as if they always will, or ought to be on THAT particular site under review. This is misleading at best, and disingenuous at the worst. I've seen too many subsequent agency requirements built on such erroneously fostered expectations, rather than realities of a site and its potentials... Case in point: just because Least Bell's Vireo breeds in riparian habitat in Santa Barbara County, what is the purpose of putting it on a list of "expected taxa" for every piddly little water course anywhere in the county, many with no water in 99% of the year? None that I can see, other than to foist agendas onto neutral process, which often mislead otherwise "well-intentioned" albeit sometimes ignorant agency people (no offense intended to anyone by the use of neutral term "ignorant") into taking that list and requiring "protocol-level surveys" for LBV (or whatever taxa comes to mind), when there is neither historical evidence of, nor sufficient other indication that, the species EVER bred there, or could if it once did. I've seen this extended to include some man-made such places. This is the surest way to destroy the CEQA process I can imagine!”
|