California Native Plant Society Letter about the Bombing Range Issue   Monterey Bay Chapter, California Native Plant Society, Mary Ann Matthews, Conservation Chair, Mar. 2, 2001   Our organization has been studying the flora of Fort Hunter Liggett and working to protect it for over 25 years. We would like to ask that the following issues be examined thoroughly in the Environmental Assessment for the proposed practice bombing activity now being scoped. If, as seems likely, the impacts are found to be significant, then an Environmental Impact Statement should be prepared as provided under NEPA.   1. Presence of Rare, Threatened, or Endangered Plants: Because we have never been permitted to visit Stony Valley, site of the proposed project, we are unfamiliar with the flora of the site. We understand that the Floristic Survey carried out recently also did not include Stony Valley. Therefore we ask that a survey by qualified academics be carried out so as to cover the long blooming period at FHL. We are aware that a rare member of the mustard family, Streptanthus albidus ssp. peramoenus, was collected there by Alice Eastwood (later Curator of Botany at the California Academy of Sciences) in 1897. We also know that there are a number of vernal pools in Stony Valley that could well support rare species found elsewhere at FHL. The Floristic Survey of FHL contains a list (pp. 32-33) of the 57 plant species of concern that should be considered in the survey.   2. Impacts on Wildlife: In our effort to preserve intact ecosystems, we recognize the importance of protecting such species as the bald eagle, California condor, kit fox, arroyo toad, red-legged frog, California tiger salamander, and other sensitive species described in the document which we co-authored in 1997, 'Fort Hunter Liggett Natural resources Conservation Report.' For example, the diversity of breeding birds at FHL has been shown to be higher than any other site in southern Monterey Co.   3. Impacts on nearby Wilderness Areas: Our members have been visiting the Ventana and Silver Peak Wilderness Areas for many years (Silver Peak was only designated a few years ago, but it has always been a de facto wilderness) for nature study, recreation, and solitude. The area is known to attract visitors from all over the country and beyond for its spectacular scenery, extraordinary biological values, and unspoiled natural condition. The impact on these activities is not easy to measure, but it is likely to be significant, resulting in economic losses to surrounding communities. Further, both government agencies and local and national conservation groups are in the process of spending substantial millions of dollars to acquire inholdings to preserve and protect the natural values of the Santa Lucia Mountains. These organizations should be contacted about potential impacts on their efforts.   4. Impacts on Native American and Archeological Sites: If as little is known about these subjects in Stony Valley as about the native flora, then surveys must be carried out to determine what might be at risk from errant practice bombs or from the noise alone. There are a number of studies of damage to indian ruins in the southwest from the shock waves from low-flying aircraft.   5. Health Impacts: There is a growing body of studies on the impacts on human and wildlife health from excessive noise. Decibel studies should be conducted by a qualified expert to determine the level at various sensitive points.   We appreciate the opportunity to comment at the scoping stage of this project, and we look forward to receiving a copy of the EA or EIS.