From YourSITE.com
The Center for Biodiversity Comments on 2006 DEIR
By Center for Biodiversity
Jun 19, 2006, 23:41
LOS ANGELES OFFICE
Protecting endangered species and wild places through science, policy, education, and environmental law
-
June 9, 2006
Joan Wolff, Project Planner
City of Fullerton
Development Services Department
303 W. Commonwealth Avenue BY ELECTRONIC MAIL
Fullerton, CA 92832-1775 joanw@ci.fullerton.ca.us
Re: Revised Draft Environmental Impact Report SCH#1997051056; West Coyote
Hills Specific Plan and Robert E. Ward Nature Preserve; Amendment No. 8 to
Coyote Hills West Master Specific Plan 2-A.
Dear Ms. Wolff:
The following comments on the Revised Draft Environmental Impact Report
SCH#1997051056; West Coyote Hills Specific Plan and Robert E. Ward Nature
Preserve; Amendment No. 8 to Coyote Hills West Master Specific Plan 2-A. (the
“RDEIR”) are submitted on behalf of the Center for Biological Diversity (the “Center”).
The Center is a non-profit environmental organization dedicated to the protection of
native species and their habitats in the Western Hemisphere through science, policy,
and environmental law. The Center has over 22,000 members throughout California and
the western United States, including residents of Los Angeles and Orange Counties in
the vicinity of the West Coyote Hills area.
The RDEIR indicates that the proposed project site has high natural resource values
based on the estimated 48-60 pairs of California gnatcatchers (Polioptila californica
californica) that are known to occur on the proposed project site and the presence of
designated California gnatcatcher critical habitat. In 2003, the Center submitted
comments on the DEIR for the previous version of this project. We remain concerned
that the proposed measures to mitigate the project’s impacts to gnatcatchers are wholly
inadequate – indeed, gnatcatcher-specific mitigation discussion included in the 2003 EIR
has been removed. The revisions to the DEIR have not rendered it legally adequate
under CEQA.
In addition, we remain concerned that the project’s impacts on other biological
resources, air quality, and climate change have still not been adequately addressed in
the RDEIR. Our previous comments are attached as Exhibit A and incorporated in these
comments by reference.
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CBD comments on WCH-RDEIR
Page 2 of 22
The RDEIR Fails to Adequately Analyze the Project’s Impacts to Biological
Resources
(a) The RDEIR Fails to Include a Number of Essential Plans for Review and
Therefore Fails Mitigate Significant Impacts to Biological Resources
The document acknowledges that wetlands and waters of the United States, as well
as jurisdictional water regulated by the California Department of Fish and Game will
be impacted by the project as proposed. However, mitigation ratios, location of
mitigation, mitigation plans, success criteria, and performance milestones are not
included in the document. Their absence precludes our review of adequacy for the
significant impacts that will be occurring to these precious and rare resources in
southern California. As of 1989, southern California had already lost over 98% of our
wetlands (Bowler 1989). Undoubtedly more have been lost in the intervening 17
years. The EIR states, “Ideally, the project will result in a no net loss of wetland
habitat (acreage) and habitat value.” Pg 4.12-48. Specific guarantees and
contingency plans need to be included to assure that the goal of no net loss of
wetlands is achieved – the mere precatory language that “ideally” the no net loss
goal will be met is insufficient under CEQA.
The RDEIR acknowledges that raptors (and coyotes) will sustain direct, indirect and
cumulative impacts from the proposed project. The RDEIR relies on a “raptor
enhancement plan” to reduce this impact to a less than significant level. However
this plan is not included for review in the RDEIR. Therefore we cannot evaluate if the
impact is adequately addressed. An issue of concern regarding raptors is the
recommendation (not requirement) that “The use of poisons shall be discouraged”.
The effects of rodenticides on predators (including some raptors currently living on
the site) are well documented. We support sustaining all the predators in the area,
and believe that a requirement to preclude the use of poisons is essential not only for
coyotes, but for the federally protected birds. Such a measure should be required for
future reserve managers and included as an enforceable condition in the homeowner
CC&Rs.
The RDEIR acknowledges that significant impacts may occur to the intermediate
mariposa lily (Calochortus weedii var. intermedius). Mitigation measures proposed
to reduce impacts to a less than significant level include the preparation and
implementation of a mitigation plan. The RDEIR needs to include the plan, so that
we can evaluate its adequacy. In addition to the other recommendations (which are
confusing as written) in the RDEIR on what will be in the plan, we also request that
maintenance and monitoring requirements be clearly identified as well as success
criteria. The mitigation recommendations in the RDEIR rely on transplantation of the
bulbs of the intermediate mariposa lily and seed collection and sowing – notoriously
unsuccessful strategies for most rare plants, resulting in a less than 10% success
rate (D. Hickson, CDFG, personal communication). In the absence of any mitigation
plan for review, we recommend the acquisition and conservation in perpetuity of
extant intermediate mariposa lily populations.
The RDEIR acknowledges that 11 of the 51 pairs of gnatcatchers will be “taken”, but
indicates that the US Fish and Wildlife Service (USFWS) believes that the project will
not result in long-term impacts to the gnatcatcher. We contend that the
CBD comments on WCH-RDEIR
Page 3 of 22
restoration/revegetation/enhancement plan for coastal sage scrub (CSS) is an
essential component in achieving the revolving CSS habitats upon which the
resource agencies are relying. No restoration/revegetation/enhancement plan is
included in the RDEIR. On the contrary, the RDEIR deletes many of the detailed
mitigation measures and performance standards that were specified for CSS
restoration and management in the previous EIR. Therefore we cannot evaluate if
the on-going impacts will actually result in no net loss to the gnatcatchers.
(b) The RDEIR Fails to Note the Regional Uniqueness of the Proposed Project Site
The RDEIR goes to great lengths to downplay the ecological value of the project site for
wildlife and makes sweeping generalizations without scientific support to avoid the
requirement to mitigate for impacts to the special-status resources that occur on the
project site. These generalizations are not supported by scientific evidence in the
RDEIR. For instance, while the RDEIR acknowledges that the proposed project site
includes federally designated Critical Habitat for the California gnatcatcher, and states
that 109.2 acres of coastal sage scrub within this designated critical habitat will be
permanently impacted, it is not clear how that impact will be mitigated. According to the
Endangered Species Act, (“ESA”),
The term “critical habitat” for a threatened or endangered species
means-
(i) the specific areas within the geographical area occupied by the
species, at the time it is listed in accordance with the provisions of section
4 of this Act, on which are found those physical or biological features (I)
essential to the conservation of the species and (II) which may require
special management considerations or protection; and
(ii) specific areas outside the geographical area occupied by the
species at the time it is listed in accordance with the provisions of section
4 of this Act, upon a determination by the Secretary that such areas are
essential for the conservation of the species.
16 U.S.C. § 1532(5)(A).
“Conservation” is defined the ESA as:
the use of all methods and procedures which are necessary to
bring any endangered species or threatened species to the point at which
the measures provided pursuant to this Act are no longer necessary.
Such methods and procedures include, but are not limited to, all activities
associated with scientific resources management such as research,
census, law enforcement, habitat acquisition and maintenance,
propagation, live trapping, and transplantation, and, in the extraordinary
case where population pressures within a given ecosystem cannot be
otherwise relieved, may include regulated taking.
16 U.S.C. § 1532(3).
It is clear that the purpose of critical habitat designation is to facilitate recovery of listed
species, not merely to ensure the survival of individuals or occurrences within a
fragmented and disturbed landscape of unsuitable or destroyed habitat. Recent court
CBD comments on WCH-RDEIR
Page 4 of 22
decisions have supported this definition (Gifford Pinchot Task Force v. U.S. Fish &
Wildlife Serv., 378 F.3d 1059 (9th Cir. 2004); Sierra Club v. U.S. Fish & Wildlife Service,
245 F.3d 434, 441-42 (5th Cir. 2001); Natural Resources Defense Council v. U.S.
Department of the Interior, 275 F. Supp.2d 1136, 1148 (C.D. Cal. 2002)). Other cases
have stressed the requirement for separate consultation regarding adverse modification
and jeopardy (e.g. Greenpeace et al. vs. National Marine Fisheries Service et al., 55
F.Supp.2d 1248 July 13, 1999). Accordingly, the RDEIR must explain how the loss of
109.2 acres of designated gnatcatcher critical habitat promotes the recovery of the
species.
Typically a mitigation ratio (3:1 or 5:1) for critical habitat is identified, either onsite or off-
site. Considering the constraints of the West Coyote Hills site, both on-site and off-site
mitigation is appropriate, yet only on-site revegetation/enhancement is proposed in the
DEIR. Critical habitat is based on the recovery standard for species, and a mitigation
ratio of 1:1 simply does not allow for species recovery.
The document also does not indicate except on Exhibit 4.12-3 that the proposed project
site sustains the greatest number of California gnatcatchers left in southern Los Angeles
and northern Orange Counties, and may be integral to maintaining the genetic integrity
of the northern Orange County populations (USFWS 2004). Clearly, the regional
significance of this population has not been adequately addressed in the RDEIR.
(c) The Onsite CSS and Gnatcatcher Preserves are Highly Fragmented and Do Not
Effectively Mitigate the Project’s Direct and Indirect Impacts
The RDEIR proposes to mitigate the loss of a large, contiguous area of CSS that serves
as gnatcatcher habitat by the creation of an on-site reserve that is located largely on the
perimeter of the site. The reserve design fails to incorporate essential conservation
biology tenets. It is infrequent that we have the opportunity to conserve the largest
population of California gnatcatchers in a region (i.e. regionally significant population),
and to guarantee that it will not go extinct in the future. The reserve design does not
consider many of the basic conservation biology tenets that need to be incorporated into
a reserve that will actually function. They include (Noss et al, 1997):
• Large blocks with large populations is best – small blocks with small populations
creates a number of challenging issues, including more opportunity for invasion
by exotics, greater vulnerability to extinction as a result of deterministic or
stochastic events, and a predictable decrease in genetic variation within the
populations;
• Contiguous blocks of habitat are better than fragmented blocks – the current
reserve design is a series of small fragmented areas;
• Small area to edge ratio for the reserve;
• Contiguity of preservation areas – the closer together the blocks of habitat are,
the better;
• Interconnected blocks are better than isolated blocks;
• Blocks of habitat that are not roaded or otherwise inaccessible to humans are
better;
• In the specific case of the California gnatcatcher, conservation areas need to
allow for movement of the populations around within the conservation areas;
• Boundaries need to be determined by reference to ecology, not politics;
• Reserves need to be surrounded by lands with low-intensity development,
CBD comments on WCH-RDEIR
Page 5 of 22
because they fare better than reserves surrounded by high-intensity
development, such as housing subdivisions.
Additional concerns that we request to be included in the Conservation Plans include:
• A map of the current known locations of sensitive resources juxtaposed with the
proposed reserve areas;
• Quantitative evaluation of the number of individuals in the current known
locations;
• Assurances that the reserves are firmly protected and adequately managed;
• Specific commitments to and funding for management of the preserves;
• Performance standards for the preserves;
• Monitoring of the rare populations to evaluate trends;
• No fire clearance/fuel modification zones are to be included in the preserve
areas.
• Invasive species control plan be included.
While the RDEIR briefly discusses reserve management and funding, detailed
performance standards for reserve management are not included. Although the
previous EIR contained more detailed information indicating how the reserve areas
would be managed and restored, this information, which is essential for fulfilling
CEQA’s informational requirements and for understanding how the reserves will
mitigate for the project’s direct and indirect gnatcatcher impacts, has been deleted.
(d) The RDEIR Relies on a Biological Opinion that is Based on Outdated Information
and Fails to Consider Cumulative Impacts to Gnatcatchers.
The RDEIR relies on the Biological Opinion (“BO”) issued by USFWS to the U.S. Army
Corps of Engineers for the project in 2004 to suggest that the project’s gnatcatcher
impacts will be fully mitigated. The BO, however, is based on the 1998 gnatcatcher
surveys of the site and thus substantially understates the site’s conservation value and
the magnitude of the project’s impact. The BO and the RDEIR also fail to account for
cumulative gnatcatcher losses. Neither the BO nor the RDEIR quantify the take of
gnatcatchers that has been permitted for other projects in the region or assess the
significance of the site’s gnatcatcher population in light of the destruction of thousands of
acres of CSS in fires in 2003 and 2005. Please see our previous discussion of the
cumulative take of gnatcatchers authorized for other projects and the cumulative loss of
CSS associated with the fires of 2003 contained on pages 4 and 5 of our 2003
comments, attached as Exhibit A.
In our previous comments, we documented that the USFWS had authorized take of 783
gnatcatcher pairs via individual biological opinions, and at least 253 additional pairs
through the “Proposed Special Rule to Authorize Take of the California Gnatcatcher”
pursuant to Section 4(d) of the ESA and the California Natural Communities
Conservation Planning (“NCCP”) process. We specifically noted that incidental take has
been authorized for at least 319 pairs of gnatcatchers in Orange County since the
species was listed in 1993. These figures do not include reflect most of the incidental
take authorized in 2003 and obviously do not include additional take authorized since
2003. The RDEIR, however, fails to consider the cumulative take of gnatcatchers.
CBD comments on WCH-RDEIR
Page 6 of 22
(e) The RDEIR Fails to Evaluate and Mitigate Significant Impacts to Biological
Resources
A number of large and small animals are currently using the site as habitat and
movement corridors. The RDEIR recognizes that the nearest open space is the “East
Coyote Hills approximately two miles to the east and the Puente Hills are located
approximately three miles to the north of the site” (Pg 4.12-20). The RDEIR argues
without scientific reference that “Although these areas of habitat may be appropriate for
most avian species to move between them, California gnatcatchers are unlikely to travel
those distances based on the current understanding of the species”. However, the
Biological Opinion (FWS 2004) states that “Both of these areas [East Coyote Hills and
the Puente Hills] are within the potential dispersal distance of juveniles, and occasional
emigration from the West Coyote Hills to these populations likely occurs (Bailey and
Mock 1998). In addition, the 2003 proposed critical habitat designation for the
gnatcatcher states that gnatcatchers are capable of dispersing up to 14 miles through
highly fragmented or disturbed habitat, including remnant coastal sage scrub habitat that
occurs along highways or utility corridors, and riparian areas. 68 Fed. Reg. 20228,
20230, attached as Exhibit B.
This may be important for genetic exchange among the fairly small and isolated
populations that remain in northern Orange County” (BO, pg 12). The impact to wildlife
connectivity and migration corridors especially for the federally threatened California
gnatcatcher is dismissed as nonexistent in the RDEIR. CEQA requires the evaluation of
the proposed project on biological resources as they currently exist.
The impacts to the riparian and waters of the U.S. is incomplete. While the RDEIR
proposes a mitigation strategy, the detailed plan of how the mitigation is achieved
(location of mitigation lands, “restoration” plan, etc.) needs to be included in the RDEIR
as well. Additionally, the “conserved” wetlands will be affected by the proposed
development due to habitat fragmentation, introduction of invasive species, introduction
of domestic pets, and runoff of sediment and pollutants, including domestic fertilizers,
herbicides, and pesticides, yet no analysis of the effects is included in the RDEIR. We
request that that analysis be included.
(f) The RDEIR Fails to Address the Impacts to Biological Resources From Fire
Protection Activities
No discussion of fire clearance/thinning is discussed in the RDEIR. The RDEIR does
state that “brush management zones and most interim disturbed areas adjacent to roads
would be revegetated with southern cactus scrub.” (Pg. 4.12-43) While this type
conversion to southern cactus scrub (“SCS”) will benefit the cactus wren, it will decrease
the habitat for the California gnatcatcher. We request that all brush management/road
sides be included in the “footprint” of the proposed project, not in the preserve areas.
The increased size of the “footprint” to include the brush management/road sides need
to be identified, analyzed for impacts to the resources and mitigated appropriately. We
have generally outlined a 100 foot area around the development that is proposed for this
type conversion to SCS (See Attachment 1). Because of the large edge to area ratio of
the development, the edges that will be converted are significant in acreage and need to
be evaluated for their biological impact. The RDEIR fails to include this analysis. In fact
some of the coastal sage scrub corridors will be eliminated as habitat for California
gnatcatchers based on the proposed action. Additionally, no fire clearance/thinning
CBD comments on WCH-RDEIR
Page 7 of 22
should occur within the boundaries of any open-space, natural area or wildlife movement
corridor, but should occur and be analyzed as part of the proposed project activities,
because of the degradation that fire clearance/thinning activities.
The RDEIR Fails to Evaluate Feasible Mitigation Measures for the Project’s
Significant Air Quality Impacts
The RDEIR concludes, even after implementation of all mitigation measures, that the
project could result in significant, unavoidable impacts due to construction emissions of
reactive organic gases (“ROG”) that contribute to ozone formation, oxides of nitrogen
(“NOx”), and carbon monoxide (CO), and will result in significant unavoidable operational
emissions of ROG, NOx, and CO.
Additional feasible mitigation measures are available for all of these impacts.
Construction impacts could be further reduced by requiring the use of low-sulfur diesel
fuel in addition to the particulate traps required by MM 4.4-1 and MM 4.4-4.
For operational impacts, the RDEIR must consider design features that would avoid or
minimize the air emissions. The project is located in an area that is ideally suited for
rooftop solar generating installations or tiles. A requirement that some or all units
include generating installations or tiles could reduce or eliminate the project’s operational
air quality and greenhouse gas emissions impacts by reducing the local or regional
emissions associated with power generation. The RDEIR provides no indication that this
measure was considered. Based on the area’s climate, the effectiveness of this
measure may be readily determined. In addition, based on the net savings over the life
of equipment and the subsidies and other financial incentives available for the
installation of such equipment, this measure is feasible as that term is understood in
CEQA. (CEQA Guidelines § 15364.)
Additional feasible mitigation is also available for all project-related emissions in the form
of offset credits. The RDEIR should consider the availability and economics of
purchasing emissions credits to offset some or all of the air quality impacts that are
described as “significant and unavoidable.” Without additional consideration of these
additional feasible mitigation measures, there is no basis for the RDEIR’s conclusion that
the residual air quality impacts are significant and unavoidable.
In our comments on the previous EIR, we noted that the EIR failed to address the issue
of nitrogen deposition associated with project air emissions. We noted that nitrogen
deposition is impacting vegetation in southern California and in particular causing losses
of coastal sage scrub. See attached Exhibit C. The RDEIR does not address the
project’s direct and cumulative contributions to nitrogen deposition, even though
nitrogen deposition may contribute to further harm to California gnatcatchers.
The RDEIR Fails to Adequately Analyze and Mitigate the Project’s Contribution to
Greenhouse Gas Emissions
(a) Global Warming is one of the Greatest Problems Facing California and the World
CBD comments on WCH-RDEIR
6/9/06
Page 8 of 22
Global warming, or climate change, is caused by society’s production of
greenhouse gases, primarily through the burning of fossil fuels for energy. These gases
accumulate in the atmosphere and decrease the amount of solar radiation that is
reflected back into space, warming the earth’s climate much like the interior of a
greenhouse. The three most important greenhouse gases are carbon dioxide, methane,
and nitrous oxide. Carbon dioxide accounts for approximately 85% of total emissions,
and methane and nitrous oxide together account for almost an additional 14%. Because
of the persistence and mixing of these gases in the atmosphere, emissions anywhere in
the world, including those associated with this project, impact the climate everywhere
equally. Therefore, the impact of greenhouse gas emissions produced in California will
impact not only California, but the rest of the world as well.
The Intergovernmental Panel on Climate Change (“IPCC”) has concluded that the global
average temperature has risen by approximately 0.6° C ± 0.2 C during the 20th Century
(IPCC 2001). There is an international scientific consensus that most of the warming
observed has been caused by human activities (ACIA 2004; IPCC 2001), and that it is
“likely”1 that it is largely due, specifically, to emissions of greenhouse gases (IPCC
2001). Carbon dioxide emissions, carbon dioxide concentrations, and temperature over
the last 1,000 years are correlated (ACIA 2004). Mean temperatures during the 20th
century were the highest in 1,000 years (Albritton et al. 2001). Global climate has
changed in other ways as well. For example, precipitation has increased by 0.5 to 1%
per decade in the 20th century over most mid- and high latitudes of the Northern
Hemisphere continents, and to a lesser degree over the tropical land areas in the
northern hemisphere (IPCC 2001).
Global average temperature increases mask significant regional variation. Due to a
number of positive feedback mechanisms, warming in the Arctic has been and will be
greater and more rapid than in the rest of the world (ACIA 2004). Warming in the Arctic
is in many ways a harbinger of what is to come in other areas. Changes already
observed in some areas of the Arctic dwarf global averages. In extensive areas of the
Arctic, air temperature over land has increased by as much as 5° C (9° F) over the 20th
century (Anisimov et al. 2001).
Global warming will continue and accelerate if greenhouse gas emissions are not
reduced. All climate models predict significant warming in this century, with variation
only as to the rate and magnitude of the projected warming (ACIA 2004). Determining
the degree of future climate change requires consideration of two major factors: (1) the
level of future global emissions of greenhouse gases, and (2) the response of the
climate system to these emissions (“climate sensitivity”)(ACIA 2004a).
Because hard data are not available for events that have not yet occurred, the future
level of society’s greenhouse gas emissions must be projected. The IPCC has produced
a Special Report on Emissions Scenarios (“SRES”) (Naki_enovi_ et al. 2000) that
describes a range of possible emissions scenarios based on how societies, economies,
and energy technologies may evolve, in order to study a range of possible scenarios
(ACIA 2004a; Albritton et al. 2001).
1
In the IPCC 2001 report, “likely” means a 66-90% chance that a conclusion is true
(IPCC 2001a).
CBD comments on WCH-RDEIR
Page 9 of 22
Climate models make different assumptions regarding how various aspects of the
climate system will respond to increased greenhouse gas concentrations and warming
temperatures. These differing assumptions are expressed as climate sensitivity, defined
as the equilibrium response of global mean temperature to doubling levels of
atmospheric carbon dioxide (Stainforth et al. 2005). The IPCC (2001) used climate
sensitivities of 1.3-5.8K for projections of warming from 1990-2100 (Stainforth et al.
2005).
Using the SRES emissions scenarios and the world’s leading climate models, the IPCC
predicts that the global average temperature will warm between 1.4 and 5.8°C by the
end of this century. Warming will be greater in the Arctic, where the annual average
temperatures will rise across the entire Arctic, with increases of approximately 3-5° C
over the land areas and up to 7° C over the oceans. Winter temperatures are projected
to rise even more significantly, with increases of approximately 4-7° C over land areas
and approximately 7-10° C over oceans (ACIA 2004a). Year-to-year variability is also
projected to be greater in the Arctic than in other regions (ACIA 2004a).
(b) Warming Projections Likely to be Revised Substantially Upwards
For a number of reasons, IPCC (2001) and ACIA (2004) projections may be significant
underestimates of the amount and rate of warming. First, the planet is already
committed to an additional 1° F warming from the excess solar energy already in our
climate system, due to lag time in the climate response (Hansen 2005). Second, actual
worldwide greenhouse gas emissions may be on the high end or above the range of the
IPCC scenarios. All scenarios utilized by the IPCC assume that energy use will shift
away from fossil fuels to a greater percentage of sustainable energy sources and that
worldwide greenhouse gas emissions will begin to decline during this century (IPCC
2001). Yet the most recent energy projections show that if current policies continue,
worldwide greenhouse gas emissions will be 52% higher in 2030 than they are today
(IEA 2005).
Third, climate sensitivity may be substantially greater than the levels used by IPCC
(2001). Results from the climateprediction.net experiment indicate that much larger
climate sensitivities of up to 11.5K are possible (Stainforth et al. 2005). Chapin et al.
(2005) studied the warming amplification caused by the expansion of shrub and tree
cover in the Arctic and resulting increase in solar absorption. This amplification could be
as much as two to seven times (Chapin et al. 2005), and is not accounted for in the
climate models used in IPCC (2001) (Foley 2005).
Recent data on the unexpectedly fast rate of warming in the Arctic also reinforces the
likelihood that the IPCC (2001) projections will need to be revised upwards. Overpeck et
al. (2005) concluded that the Arctic is on a trajectory towards an ice-free summer state
within this century, a state not witnessed in at least the last million years (Overpeck et al.
2005). These scientists conclude that there are few, if any processes or feedbacks
within the arctic system that are capable of altering the trajectory toward this ice-free
summer state. In September, 2005, scientists reported a new record Arctic sea-ice
minimum for the month of September (NSIDC 2005). These scientists called the sea ice
reduction “stunning” and concluded that Arctic sea ice is likely on an accelerating, long-
term decline (NSIDC 2005).
CBD comments on WCH-RDEIR
Page 10 of 22
(c) A Pattern of Increased Weather Variability and Extremes and Possible Abrupt
Changes
Global warming consists of more than just increases in global average temperature. In
2001 the IPCC predicted a 90-99% chance of the following weather changes:
• Higher maximum temperature and more hot days over nearly all land areas;
• Higher minimum temperatures, fewer cold days and frost days over nearly all
land areas;
• Reduced diurnal temperature range over most land areas;
• Increase of heat index over land areas;
• More intense precipitation events.
Albritton et al. 2001.
The IPCC also predicted a 66-90% chance of the following:
• Increased summer continental drying and associated risk of drought;
• Increased in tropical cyclone (hurricane) peak wind intensities;
• Increase in tropical cyclone mean and peak precipitation intensities.
Id.
Increased intensity of precipitation events due to global warming has long been
predicted by climate models and remains a consistent result of the most advanced
modeling efforts (Cubasch and Meehl 2001). In global simulations for future climate,
extreme precipitation events over North America are predicted to occur twice as often
(Cubasch and Meehl 2001).
Greenlandic ice cores indicate that the climate can change very abruptly. Scientists
caution that thresholds may be reached that trigger rapid and extreme climatic changes
that are difficult to predict but could be devastating. Examples include the shut down of
the North Atlantic thermohaline circulation, which transfers heat from the equatorial
regions to the Arctic, which could plunge northern Europe into a new ice age. The more
rapid melting of the Greenlandic ice sheet, once thought to be several centuries away,
could trigger this impact and also result in global sea level rise of up to six meters,
completely eliminating many coastal areas. As in the case of the shift to an ice-free
Arctic summer, scientists warn that we may be very close to crossing thresholds of rapid
climate change from which there is no return.
(d) The Impacts of Global Warming
The impacts of global warming, once envisioned to be experienced by future
generations, are already upon us, bringing profound climactic and ecological changes,
great loss of human life, and likely extinction for many of the planet’s non-human
species. As written recently in the New England Journal of Medicine
Since [the release of the Third Assessment Report in] 2001, we’ve
learned substantially more. The pace of atmospheric warming and the
accumulation of carbon dioxide are quickening; polar and alpine ice is
melting at rates not thought possible several years ago; the deep ocean is
heating up, and circumpolar winds are accelerating; and warming in the
lower atmosphere is retarding the repair of the protective “ozone shield” in
CBD comments on WCH-RDEIR
Page 11 of 22
the stratosphere….Given the current rate of carbon dioxide build-up and
the projected degree of global warming, we are entering uncharted seas.
As we survey these seas, we can see some of the health effects that may
like ahead if the increase in very extreme weather events continues.
Heat waves like the one that hit Chicago in 1995, killing some 750 people
and hospitalizing thousands, have become more common. Hot, humid
nights, which have become more frequent with global warming, magnify
the effects.
Epstein 2005.
In 2002, more than 1,000 people died in a spring heat wave in India (Gelbspan 2004). In
the spring of 2003, 1,400 people died in another heat wave in India and Pakistan. Also
in 2003, a summer heat wave in Europe killed between 21,000-35,000 people (Epstein
2005).
In 1998, Hurricane Mitch dropped six feet of rain on Central America in three days, and
was followed by soaring incidences of malaria, dengue fever, cholera, and leptospirosis
(Epstein 2005). In 2000, after rain and three cyclones hit Mozambique over a six week
time period, the incidence of malaria rose by five times (Epstein 2005). In June, 2001,
Houston suffered the single most expensive storm in modern history when tropical storm
Allison dropped thirty-five inches of rain in one week, resulting in $6 billion in damages
(Gelbspan 2004). In November, 2001, record flooding killed more than 1,000 people in
Algeria (Gelbspan 2004). Also in 2002, more than 12 million people were displaced by
severe flooding in South Asia (Gelbspan 2004).
In the Eastern United States, the effect of sea level rise over the last century (primarily
from thermal expansion as the oceans warm) has also exacerbated the beach erosion
and flooding from modern storms that would have been less damaging in the past
(Folland and Karl 2001). In August, 2005, Hurricane Katrina killed hundreds and
destroyed the city of New Orleans (Epstein 2005). Katrina was quickly followed by Rita,
and then Wilma, putting 2005 on track to setting a new record for hurricane season
destruction.
While it is may not be possible to link individual episodes to global warming, this overall
pattern of increasingly violent weather is very clearly linked to human-caused global
warming. But even more subtle, gradual changes can profoundly damage public health
(Epstein 2005). During the past two decades, the prevalence of asthma in the United
States has quadrupled, at least in part because of climate-related factors (Epstein 2005).
Increased levels of plant pollen and soil fungi may also be involved, as experiments
have shown that ragweed grown in twice the ambient levels of carbon dioxide produces
60% more pollen (Epstein 2005). High carbon dioxide levels also promote the growth
and spore production of some soil fungi, and diesel particles then help to deliver these
aeroallergens deep into human lungs (Epstein 2005).
Widening social inequities and changes in biodiversity caused by global warming have
also contributed to the resurgence of many infectious diseases (Epstein 2005). Global
warming is credited with the current spread of Lyme disease, as well as malaria,
hantavirus, and West Nile virus (Epstein 2005). Floods are also frequently followed by
disease clusters, as downpours can drive rodents from burrows, deposit mosquito
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breeding sites, foster fungus growth in houses, and flush pathogens, nutrients, and
chemicals into waterways (Epstein 2005). Droughts also weaken trees’ defenses
against infestations and promote wildfires, which can cause injuries, burns, respiratory
illness, and deaths (Epstein 2005).
Shifting weather patterns are jeopardizing water quality and quantity in many countries,
where groundwater systems are overdrawn (Epstein 2005). Most montane ice fields are
predicted to disappear during this century, further exacerbating water shortages in many
areas of the world (Epstein 2005).
An even greater threat to human health comes from illnesses affecting wildlife, livestock,
crops, forests, and marine organisms (Epstein 2005). One recent report found that 60%
of resources examined, from fisheries to fresh water, are already in decline or being
used in unsustainable ways (Epstein 2005). This is a grim prognosis indeed as global
population continues to rise even as global warming accelerates.
As discussed further below, global warming will also have profound impacts on the
earth’s biological diversity and threatens many thousands of species. The primary
prevention and mitigation of all of these climate impacts is to reduce the nation’s energy
use and halt the extraction, mining, transport, refining and combustion of fossil fuels
(Epstein 2005). Experts believe that a substantial reduction in energy use would have
innumerable health and environmental benefits along with stabilizing the climate
(Epstein 2005).
(e) The Impacts of Global Warming on California
California is extremely vulnerable to the impacts of global warming. The following
impacts will be experienced in California on both an acute and chronic basis:
• A diminishing Sierra snowpack of up to 90 percent during the next 100 years
threatens California’s water supply and quality as the Sierra accounts for almost
all of the surface water storage in the state.
• Increasing temperatures from 8 to 10.4°F, as expected under the higher emission
scenarios, will cause a 25 to 35 percent increase in the number of days
Californians are exposed to ozone pollution in most urban areas. This will offset
many of the state’s efforts to reduce pollution. Temperature increases are likely
to mean an increase in heat-related deaths. Children, the elderly, and minority
and low-income communities are at greatest risk.
• Potential impacts from limited water storage, increasing temperatures, and salt
water in the levees would threaten this industry and its economic contribution to
the state. Direct threats to the structural integrity of the state’s levee system
would also have immense implications for the state’s fresh water supply, food
supply, and overall economic prosperity.
• Erosion of our coastlines and sea water intrusion into the state’s delta and levee
systems may result from a 4- to 33-inch rise in sea level during the next 100
years. This will further exacerbate flooding in vulnerable regions.
• Pest infestation and increasing temperatures would make the state’s forest
resources more vulnerable to fires. Large and intense fires threaten native
species, increase pollution, and can cause economic losses.
• Increasing temperatures will boost electricity demand, especially in the hot
summer season. By 2020 this would translate to a 1 to 3 percent increase in
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demand resulting in potentially hundreds of millions of dollars in extra energy
expenditures (California EPA).
The precise nature of the impacts over the next decades will depend upon whether
worldwide total greenhouse gas emissions continue to increase at current rates, or
whether the current rate of increase is slowed, and emissions actually reduced.
Scientists model future impacts based on different emissions scenarios.
Under a low emissions scenario, by the end of this century heatwaves and extreme heat
in Los Angeles will quadruple in frequency and heat-related mortality will increase two to
three times (Hayhoe et al. 2004). Alpine and subalpine forests are reduced by 50-75%,
and Sierra snowpack is reduced 30-70% (Hayhoe et al. 2004). Under a higher
emissions scenario, heatwaves in Los Angeles will be six to eight times more frequent,
with heat-related excess mortality increasing five to seven times (Hayhoe et al. 2004).
Alpine and subalpine forests would be reduced by 75-90%, and snowpack would decline
74-90%, with impacts on runoff and streamflow that, combined with projected declines in
winter precipitation, could fundamentally disrupt California’s water rights system (Hayhoe
et al. 2004).
(f) The Impacts of Global Warming on Endangered, Threatened, and Rare Species
Climate change is a leading threat to the California and the world’s biological diversity.
Species have already been profoundly impacted by the worldwide average temperature
increase of 1 °Fahrenheit (0.6 °Centigrade) since the start of the Industrial Revolution
(IPCC 2001). Yet the warming experienced to date is small compared to the 2.5- 10.4
°F (1.4-5.8 °C) or more of warming projected for this century. The ways in which climate
change threatens species are varied and sometimes complex. Below we present an
overview of impacts observed to date and projections for the future.
Scientists have predicted three categories of impacts from global warming: (1) earlier
timing of spring events, (2) extension of species’ range poleward or upward in elevation,
and (3) a decline in species adapted to cold temperatures and an increase in species
adapted to warm temperatures (Parmesan and Galbraith 2004). A recent survey of
more than 30 studies covering about 1600 hundred species summarized empirical
observations in each of these three categories and found that approximately one half of
the species were already showing significant impacts, and 85-90% of observed changes
were in the direction predicted (Parmesan and Galbraith 2004). The statistical
probability of this pattern occurring by chance, as opposed to being caused by climate
change, is less than one in a billion (Parmesan and Galbraith 2004).
Changes in the life cycles and behaviors of organisms such as plants blooming and
birds laying their chicks earlier in the spring were some of the first phenomena to be
observed. These changes may not be detrimental to all species, but depending on the
timing and interactions between species, may be very harmful.
The Edith’s checkerspot butterfly, which occurs along the west coast of north America,
has been severely impacted by such changes in the lifecycles of organisms. The Edith’s
checkerspot’s host plant, Plantago erecta, now develops earlier in the spring while the
timing of caterpillar hatching has not changed. Caterpillars now hatch on plants that
have completed their lifecycle and dried up, instead of on young healthy plants
(Parmesan and Galbraith 2004). The tiny caterpillars are unable to move far enough to
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find other food and therefore starve to death (Parmesan and Galbraith 2004). Because
of this, many Edith’s checkerspot butterfly populations have become extinct. Many
more populations have been lost in the southern portion of the species’ range than in the
northern portion, resulting in a net shift of the range of the species northward and
upwards in elevation. All these changes have occurred in response to “only” 1.3°
Farenheit regional warming (Parmesan and Galbraith 2004).
The southernmost subspecies, the Quino checkerspot butterfly, already listed as
endangered under the Endangered Species Act due to habitat destruction from urban
development, has disappeared from nearly 80% of otherwise suitable habitat areas due
to global warming (Parmesan and Galbraith 2004). The Bay checkerspot and Taylor’s
checkerspot butterflies, also listed under the Endangered Species Act, have been
similarly impacted (Parmesan and Galbraith 2004).
Butterfly species are impacted in other ways as well. The northward expansion of the
treeline into alpine meadow butterfly habitat can impede dispersal, fragment habitat, and
increase mortality via butterfly collisions with the trees (Krajick 2004, Ross et al. 2005).
While theoretically some species can adapt by shifting their ranges in response to
climate change, species in many areas today, in contrast to migration patterns in
response to paleoclimatic warming, must move through a landscape that human activity
has rendered increasingly fragmented and inhospitable (Walther 2002). When species
cannot shift their ranges northward or to increased elevations in response to climate
warming, they will become extinct (Parmesan and Galbraith 2004). Therefore, the least
mobile species will be the first to disappear.
The pika is a small, vegetarian relative of the rabbit, that is adapted to life on high,
treeless mountain peaks. Because pikas need cold, bare habitat, it is not surprising that
their numbers are plummeting all over the globe (Krajick 2004). Fossil evidence shows
that pikas once ranged widely over North America but their range has contracted to a
dwindling number of high peaks during the warm periods of the last 12,000 years
(Krajick 2004). Alpine species like the pika are unable to shift their ranges as warming
temperatures and advancing treelines, competitors, and predators impact their mountain
habitat (Krajick 2004). Pikas are further limited by their metabolic adaptation to their
cold habitat niche, which allows them to survive harsh winters but also causes them to
die from heat exhaustion at temperatures as low as 55° F (25.5° C) (Krajick 2004).
American pika populations at seven of twenty-five previously recorded localities
in the Great Basin of the western United States have disappeared in recent years
(Beever 2003). Based on work conducted in the late 1990s, researchers documented
that the average elevation of surviving pika populations was 8,310 feet, up from a prehistoric
average of about 5,700 feet between 7,500 and 40,000 years ago (Beever 2003;
Grayson 2005). Most recently, researchers announced in December 2005, that at least
2 additional populations have become extinct, and the average elevation of surviving
populations has increased by another 433 feet.
In the Yukon, collared pikas declined 90% between 1999 and 2000, when
unprecedented midwinter snowmelts, rain, and refreezing eliminated the insulating snow
and then iced over the pika’s forage plants (Krajick 2004). A pika species endemic to
the mountains of northwest China, discovered only in 1986, was not located in extensive
surveys in 2002 and 2003 and may be extinct.
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Alpine dwelling marmots which rely upon the treeless tundra to visually spot and avoid
predators, are also at risk as treelines advance, providing cover for predators like wolves
and cougars.
Alpine plants, which have little or no capability to shift their range to higher elevations as
the climate warms, may be most at risk. One study predicts that a 3° Centigrade
temperature rise over the next century will eliminate eighty percent of alpine island
habitat and cause the extinction of between a third and a half of 613 known alpine plants
in New Zealand (Krajick 2004).
A study of 15,148 North American vascular plants found that 7%-11% of all species
(1,060 to 1,670 plants) could be entirely out of their climate envelopes with just a 5.4° F
(3° C) warming, the lower limit of climate change predicted for this century by the IPCC
(Morse et al. 1995). At the upper boundary of climate change predicted for this century,
10.4° F (5.8° C), the percentage of plants completely outside their envelope increases to
25-40% (Morse et al. 1995). By contrast, about 90 North American plant species are
believed to have become extinct in the past two centuries (Morse et al. 1995).
Species are also at great risk because climate change can alter conditions for diseases
and their vectors in a way that allows the incidence of disease to increase and spread.
Global warming can exacerbate plant disease by altering the biological processes of the
pathogen, host, or disease-spreading organism (Harvell et al. 2002). For example, cold
winter temperatures limit disease in some areas because the cold kills pathogens.
Warmer winter temperatures can decrease pathogen mortality and increase disease
(Harvell et al. 2002). Warmer temperatures can also increase pathogen growth through
longer growing seasons and accelerated pathogen development (Harvell et al. 2002).
The most severe and least predictable disease outbreaks will likely be when climate
change alters host and pathogen geographic ranges, so that pathogens introduced to
new and vulnerable hosts (Harvell et al. 2002).
Climate change will also influence wildlife diseases by affecting the free-living,
intermediate, or vector stages of pathogens (Harvell et al. 2002). Many vector-
transmitted diseases are currently climate limited because the parasites cannot
complete development before the vectors are killed by cold temperatures (Harvell et al.
2002). Well-studied vector borne human diseases such as malaria, Lyme disease, tick-
borne encephalitis, yellow fever, plague, and dengue fever have expanded their ranges
into higher latitude areas as temperatures warm (Harvell et al. 2002).
Increased ocean temperatures also cause marine pathogen range expansions. One
example is the spread of eastern oyster disease on the east coast of the United States
from Long Island to Maine during a winter warming trend in which the cold-water barrier
to pathogen growth was removed (Harvell et al. 2002).