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Alternative A represents a 0.6% increase in the developed area draining to the
Crescent City Marsh, the impact is not considered significant, given that the
western lily presently exists with stormwater runoff from 500 acres of developed
lands. In fact, the western lily has been found to be in severe decline in the past
several years, possibly as a result of the developed acreage within the
watershed. There is no data presented to determine whether the western lily
populations are presently thriving; there is no data on which to base these
statements of non-significance. Furthermore, there is no cumulative impacts
analysis, other than the unsubstantiated claim of "less than significant" for all
biological resources on page 4.12-3.
According to 14 Cal. Code Reg. 15065 (a), a lead agency shall find that a
project may have a significant effect on the environment where the project has
the potential to substantially reduce the number or restrict the range of an
endangered, rare or threatened species. CNPS believes that this project has the
potential to substantially reduce the number of the federally endangered western
lily, and by definition such a project must be found to have a significant impact.
The western lily (Lilium occidentale) is a federally listed endangered species
known from early successional fens and coastal scrub from northwestern
California to central Oregon It was listed as endangered without critical habitat in
1994. More than half of all known flowering plants occur at the Crescent
City Marsh Wildlife Area
. The population is currently estimated at 2,000 plants
and represents the only recovery-level population as defined by the federal
recovery plan for the species (Bencie and Imper 2003; U.S. Fish and Wildlife
Service 1998). The population at the Crescent City Marsh Wildlife Area has been
in decline for the past five years, and this decline may be associated with impacts
to water levels of past development within the watershed. The western lily
populations in the Crescent City Marsh and nearby wetlands exhibited severe
declines this year, perhaps in response to late heavy rainfall (Wear unpublished
data). This decline may be an indication of further impacts from increases in
summer runoff and other hydrologic changes that could occur as a result of the
Since the proposed project seeks to develop within the watershed of the only
recovery-level western lily population, it is likely that such development would
have significant direct, indirect, and cumulative negative impacts to the species,
and in fact could lead to its extinction. The creation of impervious surfaces in
close proximity to upslope wetlands will alter the hydrology and seasonality of
runoff that will flow into wetlands that are within the watershed of the Crescent
City Marsh. The DEIS does not provide adequate information to determine how
changes in the quantity and/or seasonality of runoff will impact downslope
wetlands. It is clear that even small changes in water table levels, precipitation,
and hydrology may have significant impacts on the western lily.