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1 <br />RAY BUTLER <br />www.rwbutler338@att.net <br />March 6, 2013 <br /> <br />Ms. Denyelle Nishimori <br />Town of Truckee Community Development Department <br />10183 Truckee Airport Rd. <br />Truckee, CA 96161 <br />Via electronic mail this date <br /> <br />RE: Comments on Biological Resources Chapter, Canyon Springs Draft Environmental <br />Impact Report (DEIR) <br /> <br />Dear Ms. Nishimori: <br /> <br />Thank you for the opportunity to comment. The following comments are entirely my own <br />and do not represent the official policy or position of Nevada County, CA. Although I <br />currently hold an appointed position on the County’s Fish and Wildlife Commission, and <br />have for 25 years, my positions is advisory only to the Board of Supervisors. Only the <br />Board of Supervisors can address, decide, and communicate policy matters for the <br />County of Nevada. <br /> <br />This review is restricted to Chapter 4.4, Biological Resources and the associated <br />Appendix E, Mule Deer Reports and References. <br /> <br />FINDINGS <br /> <br />1. The Biological Resources chapter does not meet new State standards adopted on <br />September 2010 (as required by SB 85, 2007 Session) for describing vegetation types. <br />Details can be found at www.dfg.ca.gov/biogeodata/vegcamp. <br /> <br />2. The basic references used in Chapter 4.4 and Appendix E, including Mayer and <br />Laudenslayer (1988), Sawyer and Todd Keeler-Wolf (1995), Holland (1986), and <br />Barbour and Major (1988), have been significantly revised and published, and more <br />importantly, are integrated into the new State standard. The correct citations for these <br />works are found in the references listed at the end of this letter. <br /> <br />3. Editing and quality control in the document is egregious. Four plant species are <br />incorrectly classified at the genus level (pp. 19 – 26). With the Jepson eFlora website <br />available to all, there is simply no excuse for an error of this magnitude. There is no <br />Martis Creek National Recreation Area (p. 30). Site visit dates for biological surveys are <br />inconsistent between Appendix reports. <br /> <br />4. Other frequently cited references, including those of Jones and Stokes Associates, <br />Albert Beck, PhD, and many of the “personal communications” references (especially