P.O. Box 369
Rancho Cordova, 95741-0369
phone/fax 916-635-9078
www.tws-west.org
| Western Section of The Wildlife Society P.O. Box 369 Rancho Cordova, 95741-0369 phone/fax 916-635-9078 www.tws-west.org |
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May 2, 2002 The Honorable Joseph Canciamilla, Chair Assembly Committee on Water, Parks, and Wildlife State Capitol, Room 6011 Sacramento, CA 95814 Subject: The Western Section of The Wildlife Society Comments on AB 2290 adding Section 21084.1.1 to the Public Resources Code Dear Assemblyman Canciamilla and Members of the Committee: The Western Section of The Wildlife Society is writing to support the addition of new language to the Public Resources Code (PRC) modifying the California Environmental Quality Act (CEQA) with respect to defining impacts to wetlands. The Western Section of The Wildlife Society is writing to recommend potential issues to be addressed in the Programmatic Environmental Impact Statement (PEIS) for the Bureau of Land Managements (BLM) proposed program for vegetation treatments on BLM lands in the western U.S. Our comments and recommendations are based on review of the information contained in the 22 January, 2002, Federal Register notice announcing BLM's intent to prepare the PEIS under the National Environmental Policy Act (NEPA), information received during the public scooping process, and BLM's 1988 California Vegetation Management EIS to chemically treat 50,000 acres of land per year. The Wildlife Society is a national organization comprised of professional wildlife biologists employed in the private and public sectors, natural resource management agencies and academia. The Western Section currently consists of about 1,000 members in nine chapters in California, Nevada, Hawaii, and the Pacific Islands. Western Section members include field biologists, wildlife managers, and policy makers from a broad range of disciplines who are regularly engaged in resolving land use and conservation issues stemming from impacts to wildlife and the habitats upon which they depend. Our goal is to enhance the capability of wildlife professionals in conserving natural diversity, sustaining productivity, and ensuring responsible use of wildlife resources for society's benefit. The principal objectives of TWS include development and promotion of sound stewardship of wildlife resources and of the environments upon which wildlife and humans depend; taking an active role in preventing human-induced environmental degradation; increasing awareness and appreciation of wildlife values; and seeking the highest standards in all activities of the wildlife profession. Perennial and seasonal wetlands are an important resource to wildlife in California. Continuing loss and degradation of wetlands has been a contributing factor in the decline of some aquatic wildlife species. The proposed addition to the PRC would clarify the meaning of a wetland in CEQA with respect to making a finding of significance during the impact assessment and evaluation process. A mandatory significance finding for adverse changes to wetlands, as defined by the new Section, would likely result in more thorough impact analyses and protection and conservation of wetlands by local government. In particular, proposed PRC Section 21084.1.1(b)1 which establishes and defines a "Special aquatic site", is a clear and meaningful attempt to link ecological processes to wetlands. The recognition of this linkage would be important for establishing effective avoidance and mitigation measures and protecting wetland values. We recommend that the "special aquatic site" designation in Section 21084.1.1 include California's unique aquatic habitat types and features that are often ephemeral in their aquatic nature, such as dry washes, arroyos, alluvial fan pools, and vernal pools. These habitat types provide extremely valuable migratory corridors and staging areas for several terrestrial species, and important feeding and breeding areas for many rare aquatic and semi-aquatic species. These areas currently receive little legal protection, other than that conferred by Sections 1601 and 1603 of the Fish and Game code, which applies primarily to areas with a defined bed, bank, and channel. Thank you for considering these comments. Please contact me at 530-757-1403 to discuss our comments, answer questions related to our recommendations, or provide technical expertise to the Committee as required. Sincerely, Barrett A. Garrison, Past-President Western Section of The Wildlife Society |