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Save the Pine Bush
Written Comments in Response
to Draft Environmental Impact Statement

written by Lynne Jackson

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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

 

This page last modified January 12, 2008
Contact Save the Pine Bush at pinebush@aol.com.