Good morning Commissioners, I would like to highlight several concerns regarding the adequacy of the biological analysis. First, the map presented on page 22 of the Biological Resource Assessment appears to depict a project site near Esparto in Yolo County, rather than the project area under consideration. This raises questions about the accuracy and reliability of the document. In addition, the environmental documents do not include current California Natural Diversity Database (CNDDB) mapping or updated species occurrence information. Recent observations from the Lake County Water Resources Hitch Monitoring Program report over 500 Clear Lake hitch in Adobe Creek this month. This sensitive, endemic species is not addressed in the Biological Assessment, despite its known presence in the watershed. The documents also fail to evaluate the presence or potential impacts of Mediterranean Oak Borer (MOB), an invasive pest that is rapidly contributing to oak mortality throughout Lake County. This omission is particularly concerning given the importance of oak woodlands to ecosystem function and habitat value. Taken together, these gaps indicate that current environmental conditions are not adequately reflected. This raises concerns regarding compliance with
CEQA Guidelines §15125, which requires an accurate baseline based on existing conditions. CEQA Guidelines §15064, which requires preparation of an EIR where substantial evidence supports a fair argument of potential significant impact. CEQA Guidelines §15064(h), which requires evaluation of cumulative impacts. Additionally, the Biological Assessment does not include recent, multi-seasonal field surveys, further limiting its reliability. Finally, I would note that the draft Cannabis Ordinance, draft Local Area Plans, and the draft General Plan 2050 are all currently under review and may have direct relevance to decisions being made today. Without updated and site-specific biological data, it is difficult to fully evaluate potential impacts. Thank you for your time and consideration.