Comments on 2007 EPA Report on the Environment Draft Science Report

Submitted by

Bruce A. Stein, Vice President and Chief Scientist, NatureServe

July 3, 2007

p\. 6-8, line 8. NatureServe is described (parenthetically) as a
"private foundation." NatureServe is not a foundation, which has
specific legal and tax connotations. Instead, it should be described as
it is elsewhere in the report as a "private organization" or "private
research organization."

p\. 6-30, footnote #28. The statement confuses the total number of
species that NatureServe reports as having been scientifically described
in the United States (200,000) with the number of species for which
NatureServe manages conservation-relevant information. Additionally,
NatureServe integrates data from both *ad hoc* as well as systematic
studies. Suggested revisions to this footnote are "...a private sector
organization, NatureServe, working in concert with state Natural
Heritage Programs, has done much to assimilate and integrate data from
*ad hoc* [and systematic studies to assess the status of nearly 40,000
U.S. species and to quantify populations of more than 20,000 at-risk
species]{.underline}."

[Fish Faunal Intactness Indicator]{.underline}

While the representation and write-up of this indicator for the most
part accurately reflects its underlying data, during the editing process
the date 1970 has been misinterpreted and over-emphasized, leading to a
significant problem in the depiction of this indicator.

For purposes of this indicator we used "historical" to reflect baseline
conditions. The indicator metadata states: "The threshold for what
constitutes \'historical\' occurrence was set at 1970 (i.e., 25 years),
consistent with established NatureServe guidelines for assigning
population viability assessment ranks (\'EO Rank Specifications\')."
This means that the "historical" fauna consists of native fish species
documented in a watershed at any time prior to 1970. It does not mean
that the historical fauna was based on surveys "conducted in 1970" (as
stated on p. 6-34, paragraph 2). Nor does it mean that the historical
diversity of native fish species represented in Exhibit 6-11 existed in
1970 (as indicated in the legend for that Exhibit). Nor does it mean
that the percent reduction in fish species diversity represented in
Exhibit 6-10 necessarily took place since 1970.

To put this in concrete terms, the Snake River sucker (*Chasmistes
muriei*) is an extinct species last observed in 1927. The species was
only known from the Snake Headwaters watershed (HUC #17040101). For
purposes of this indicator, this species is considered to be a part of
the "historical" fish fauna of the six digit HUC within which that
8-digit Snake Headwaters HUC occurs. This species was extinct long
before 1970, yet is included in the "historical" tally represented in
Exhibit 6-11.

Given that clarification, several changes are required in the
representation of this indicator.

p\. 6-34, line 8: "...historical data are based on surveys conducted
[prior to]{.underline} 1970."

p\. 6-34, line 31/32: "...have lost 10 percent or more of their native
fish fauna. \[delete "since 1970."\]

p\. 6-35, Exhibit 6-10. For reasons discussed above, the title of this
exhibit must be changed to eliminate the erroneous reference to 1970. My
suggestion would be: "Percent reduction in native fish species diversity
in the contiguous U.S. from historical levels to 1997-2003.

Similarly, the footnote in this exhibit must be changed. Suggested
changes would be: "...based on the number of native species present
during the period 1997-2003, compared with historical numbers documented
prior to 1970."

p\. 6-35, Exhibit 6-11. Again, the title of this exhibit needs to be
changed to eliminate erroneous reference to 1970. My suggestion would
simply be to drop "1970" from the title. This would therefore read:
"Historical diversity of native fish species in the contiguous U.S."