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Old 07-08-2008, 12:22 PM
njensen njensen is offline
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Default Comment from Rob Preston, Botanist, Jones & Stokes Associates

“I agree entirely with you on the reasons that it is very important to have a species checklist as part of the CEQA documentation. My specific comments:
1) A general species checklist is worthless. This type of checklist is what was done 30 years ago, based on what someone would expect to occur on a site, not what was actually observed. What is needed are specific checklists based on current site surveys.
2) A species checklist is useful, but the complete site survey report should be part of the public record. To suggest that access to the survey reports is “not needed” would be disingenuous. I’ve seen EIRs in which the information from the original survey report was distorted, misrepresented, or misinterpreted by a non-botanist who did the write-up; you need to see the original report to assess the veracity of the EIR section.
3) Publication and distribution costs can be a legitimate reason for not publishing all of the technical reports in appendices. However, these technical reports are still part of the public record and must be made readily available. I agree that the practice of making documents available only as hard copies in a few locations is inexcusable. If not published as appendices, technical reports should still be readily available via the web.”
“The only reason for not including a survey/checklist in a CEQA document (either as an appendix or as part of a web-accessible public record) is to conceal information, either about the project or about the survey methods.”
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