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Karner Blue Habitat
First, the Common Council should not accept this
DEIS until the Common Council determines what the City of Albany’s policy
is on extinction of species. The City of Albany should clearly
outline its policy on extinction of species, including whether
or not it values protecting species in danger of extinction.
Because the entire site is within 200 meters of
an occupied Karner Blue butterfly habitat, it must be considered
occupied habitat, until proven otherwise. Notes from the Federal
Karner Blue Butterfly Recovery Team observe: “Our definition
of “occupied” habitat also includes all suitable
nectar plants (plants that provide nectar to small butterflies
and that bloom during the first and second flight periods) and
grassy areas that provide shelter for KBs (areas not regularly
mowed during the growing season) within the lupine patch and
extending 200 meters from the edge of the lupine patch. ”
This site clearly fits the definition of "occupied habitat" according
to the Federal Recovery Team. Please see attached letter from
Dr. John Shuey.
Karner Blue Butterflies need three things that
are in the working definition of occupied habitat. 1- Larval
hostplants (the wild blue lupine), 2 - adult food resources (aka
flowers) and 3, appropriate night-time roosting sites. Studies
have shown that Karner Blues sometimes roost a distance from
lupine plants. Unless all three of these resources are absent
from the site of the proposed hotel, building the hotel on the
site would be considered a “taking” under
State and Federal law. The DEIS alludes to the existence of nectar
sources on the site and does not mention whether the site was
monitored for night roosting of the Karner Blue. The City should
put the onus on the Applicant to prove that Karner Blues never
occupied this site and that construction of this hotel is not
a taking.
Also, the DEIS cites data from a long time ago.
Much has happened in the past 15 years in the Pine Bush. Many
scientific studies have been conducted since that time. The DEIS
must rely on more recent information.
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Want to Get Involved?
Email Lynne Jackson at lynnejackson@mac.com
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