07.01.2013 Views

David Magney Environmental Consulting - California Native Plant ...

David Magney Environmental Consulting - California Native Plant ...

David Magney Environmental Consulting - California Native Plant ...

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

Comments on Draft EIR for Newhall Ranch Mission Village Development<br />

DMEC Project No. 10-0181<br />

1/3/2011<br />

Page 42<br />

D:\DMEC\Jobs\Friends_SantaClaraRiver\Newhall-MissionVillage\DMEC_comments_on_Newhall_MissionVillage_DEIR-20110103.doc<br />

DMEC<br />

time honeybees are mentioned is on page D-25 of the Adaptive Management Program Module, Loss of<br />

Genetic Diversity:<br />

“European honeybees have been observed visiting spineflower’s at the Laskey Mesa site (Jones et al.<br />

2002) and may be able to transfer pollen between preserves. It is believed that European honey bees<br />

currently may be experiencing colony collapse syndrome, and pollination relying upon them therefore<br />

may be tenuous.”<br />

Page 5, paragraph 2, Section 3.8 Phenology, Seed Production and Pollination, states, “However, ants are<br />

not efficient pollinators, and the rate of fruit set measured by researchers was high, which would indicate<br />

another, more effective pollinator was visiting the plants (USFWS 2004)”. This statement alone is strong<br />

evidence that the SCP should have examined in greater detail what other pollinators are present, and the<br />

EIS/EIR should have assessed how the proposed project would impact those pollinators.<br />

The preserves need to be large enough to ensure viable populations of SFVS pollinators existing onsite, and<br />

will persist onsite over the long term.<br />

4. Seed Dispersal<br />

Little is known about dispersal of SFVS seeds. As discussed above, Argentine Ants may pose a threat to<br />

native SFVS seed dispersers. Potential interactive effects of granivory and invasion by the Argentine Ant,<br />

which may displace native invertebrate granivores, could be significant. In addition, trapping studies<br />

conducted by Sapphos in 2001 on Ahmanson Ranch did not clarify whether small mammals play a role in<br />

SFVS seed dispersal (SCP, page 4.9-27).<br />

DMEC believes that the buffer areas as proposed under the current plan will be inadequate protection from<br />

the invasion of the Argentine Ant within the preserves areas. There will be further discussions on the threat<br />

of Argentine Ant and a critique of the Integrated Pest Management (IPM) proposed later in the letter.<br />

5. Soils<br />

With the use of a representative model described later, Dudek found that SFVS occurrences varied among<br />

combinations of sandy and gravelly silt and clay loams as discussed in Section 5.3.2 of the SCP. Soil<br />

texture and soil chemistry both proved not to be good predictors of whether a site represents potentially<br />

suitable habitat for SFVS.<br />

On both the Ahmanson Ranch and Newhall Land properties, SFVS is also in areas with disturbed soils and<br />

in areas disturbed by fossorial rodent activity. The SCP suggests that soil disturbances might also directly<br />

facilitate spineflower performance by increasing soil nutrients (J. McGraw, unpublished data) (Adaptive<br />

Management Module D-51). It is possible that SFVS relies on fossorial rodents since SFVS was found<br />

often occurring in areas disturbed by fossorial rodent activity. The size of the preserves may impact the<br />

rodent populations if they are too small.<br />

It is clear that more investigation needs to focus on the soil requirements of the SFVS, especially since SCP<br />

suggests that enhancement should occur if there is a decrease in SFVS populations within the preserves.<br />

There is not information to make these important decisions.

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!