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` SAN JOAQUIN <br /> Y <br /> AUDUBON SOCIETY <br /> To: Kerry Sulivan FEB FEE-Li, 1993 <br /> San Joaa uin Planning Dept.. COMMUNITY DEVELUrm ENT DEPT. <br /> From: Waldo Holt PLANNING DIVISION <br /> San. Joaquin Audubon Society <br /> Re: DESK Buckeye Ranch Development ,. Supplemental Biotics Study <br /> Dear Kerry, <br /> The DEM. for Buckeye. Ranch Development is deficient. The reason <br /> itTis deficient is because it fails to properly present impacts ,to <br /> } Special Status Taxa:. <br /> 1.. United States Fish and Wildlife biologists report in,"The <br /> Distribution, Habitat,. and Status of the Valley Elderberry Longhorn <br /> Beetle" ,(Barr,. USFWS,, Nov. 1991, that at those sites where evidence <br /> of VELB is found it is found in only 20% of the- elderberry shrubs <br /> present at that site. Thus it is very likely that a " spot survey " <br /> or u random survey " will miss evidence of VELB. A complete and <br /> D147 <br /> thorough survey for VELB was not done on project site by DEM <br /> biologists. Therefor it is not correct to state categorically <br /> that VELBs are not present onsite and thus it is not correct to <br /> assume that project will have no impacts on VELE. <br /> We note that in the above mentioned USFWS survey , 230 sites <br /> in the California Central Valley were surveyed 7and of the actual <br /> beetles encountered , 75% came from the banks of the 24okelumne river <br /> in San Joaquin county.. <br /> VI-121 <br />