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BIOLOGICAL IMPACTS ASSESSMENT

Under CEQA, "[A] paramount consideration is the right of the public to be informed in
such a way that it can intelligently weigh the environmental consequences of any
contemplated action and have an appropriate voice in the formulation of any decision."
The public needs information that is thorough, relevant, unbiased, and honest; the
public needs full disclosure of the environmental setting and possible cumulative
impacts. Documents presenting information from a biased perspective will tend to
include omissions, logical fallacies, internal contradictions, and unfounded responses to
substantial issues. Therefore, my assessment of the SEIR and also considers omissions
and bias, which bear on the sufficiency of the SEIR.

I found that the SEIR and supporting documents disclosed only some of the relevant
information and was far short of thorough. Given the lack of thoroughness and lack of
foundation for many conclusions related to project impacts and appropriate mitigation,
I found the SEIR biased in favor of the project. For example, the only general wildlife
surveys performed over the last decade occurred at unreported times of day and
unreported timespans over 3 consecutive days in April 2014, which was a very narrow
time window within one season at the peak of the most intense drought in California's
recorded history. According to the SEIR (201?:5.2-4), these surveys were conducted
simultaneously with vegetation mapping, which suggests the focus was not on wildlife
survey. Many of the conclusions related to project impacts on species were unfounded
or flawed by not following logically from premises, as I will address in my comments
that follow.

According to the SEIR (2017:5.2-4), "No mammal trapping was conducted because it
was not considered warranted (i.e., there are no Threatened or Endangered mammals
expected to occur in the study area)." There might not be threatened or endangered
mammals in the study area, but there was likely a special-status species in the southern
grasshopper mouse. Not addressed in the SEIR were multiple additional special-status
species of small mammals with geographic ranges overlapping the project area,
including San Joaquin pocket mouse (Pergonathus inornatus, BLM special animal),
Tehachapi pocket mouse (Perognathus alticola inexpectatus, California species of
special concern), Los Angeles pocket mouse (Perognathus longimembris brevinasus,
California species of special concern), and desert woodrat (Neotoma lepida intermedia,
California species of special concern). There could have been other species, as well, but
one truth I learned from 23 years of wildlife ecology is that not looking for species is a
sure way to not find them - especially special-status species, which tend to be rare and
cryptic.

No surveys were performed for detecting bats, either. Acoustic detectors coupled with
SonoBat could have been deployed to identify species using the study area. A thermal
imaging camera could have been used to quantify activity patterns seasonally and
spatially, and some information could have been collected on likely species present
based on body size and flight behaviors. Again, not looking is an easy way to remain

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