ML19331B285

Affidavit Re L Holcomb 720614 Testimony Re Plant Impact on Area Wildlife Populations

ML19331B285
Person / Time
Site:	Midland
Issue date:	07/08/1972
From:	Gysel L MICHIGAN STATE UNIV., EAST LANSING, MI
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NUDOCS 8007280888
Download: ML19331B285 (11)

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LJ UITITED STATES OF A> ERICA ATOMIC' ENERGY C0b2ESSION In the Matter of )

)

Consumers Power Company ) Docket No. 50-329

) Docket No. 50-330

'(Midland Plant Units 1 and 2) )

STATE OF IECHIGAN )

4

) SS, COUNTY OF INGHAM )

Affidavit of Leslie Gysel Leslie Gysel being duly sworn deposes and says that he is a Professor in the Departments of Forestry and Fisheries and Wildlife of Michigan State University; that the attached statement was prepared under his supervision; that he has read the same and knows the contents thereof and that the matters contained therein are true and correct to his personal knowledge.

/s/ Leslie Gysel Leslie Gysel Subscribed and sworn to before me this 8th day of July,1972.

/s/ Richard K. Ridenour (SEAL) Richard K. Ridenour Notary Public, Ingham County, Michigan My Cocnission Expires Jan. ik, 197h 8007280 1

Statement of Dr. Leslie Gysel Regarding the Testimony of Dr. Larry Holcomb at the June 14, 1972 Session of the Midland Nuclear P3 ant Proceeding I have previously appeared as a witness in this proceeding and have been sworn. I have reviewed the testimony of Dr. Larry Holcomb which appears in the transcript of the proceeding beginning on page 8517 end have the following ecmments to offer.

It is clearly Dr. Holccmb's opinion that a meaningful analysis of the site and a meaningful cost-benefit analysis can only be made if a complete census is made of every plant and animal located at the sita. I disagree with this opinion. The ecological survey which we performed was not an attempt to identify every species of plant and animal at the site or to make definitive population estimates of such species. We concen-trated our- efforts on describing dominant species and their ecological re-lationships to the Midland site environment. The ecological survey described the primary vegetation ecxamunities with vegetation =aps and habitat foz.nulae.

The ecological survey listed those vildlife species that we per-sonally had observed at the site, those for which we had observed signs (tracks, seats, den sites, etc.) and those that had been observed by local residents and plant site security personnel. These lists were reviewed vith the Departnent of Natural Resources field biologist in the area, who was in general agreement with the content of the lists. While greater definition of the number end population of species at the site could be made, such an effort does not appear to be useful. The site, except for

2 a few areas, has been extensively affected by preconstruction activities and is on the whole an undesirable area from the standpoint of wildlife habitat. Based on analysis of the existing habitat, sightings and other evidence, a representative listing of the dominant vildlife population has been made.

Detailed speculatica on the population of vildlife prior to preconstruction activities is an essentially sterile task. I am unaware of any accurate census of all animal populations in a specific location of the type which Dr. Holecmb advocates. My department has attempted de-tailed census of various populations in several ecosystems and has found that with existing methods accurate census are practically impossible.

As an example, although reasonable estimates of songbird populations can be made at nesting time through identification of nests, the difficulty in differentiating individuals enkes it practically impossible at any other period of the year. M mmni populations are difficult, short of trap-ping and marking each individual, at all times of year. Double and triple

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counting of the same individual is always a hazard. Amphibian and reptile populations are even more difficult to establish accurate figures for.

While detailed census have been done of various small site, 5 to 10 acres, these census generally have consisted of attempting to evaluate only one spe21es. Even then it is an involved task. As Dr. Holecab indicated, he was able to find a detailed census of song sparrows but no detailed census of all bird populations at a single site. I would venture that there is no scientifically accurate census of this type in existence, partially be-cause of the difficulty of such a census and partially as a result of the inordinate expense that would be involved. Dr. Holecab misrepresents our

3 testimony in indicating that population estimates are not possible. My previous testimony was that meaningful population est1 mates for the site beyond tne general estimates contained in the ecological survey are not possible on the basis of available data. If the methods referenced by Dr. Holcomb from stEndard textbooks are utilized to collect additional data, scmewhat more definitive data vould be available and for some species more detailed population estimates could be made. However, for many species, no methodology for making detailed accurate population estimates is presently available.

A total ecosystem study of the type advocated by Dr. Holcomb would take many years, perhaps up to ten, of observations and trappings during all seasons and could cost several millions of dollars. Such an ecosystem study would require substantial efforts by experts on birds, mammals, amphibians, reptiles, insects, plants and ecological and food chain relationships. For many species very little is known of their habits and such information would have to be developed during the study before i any evaluation could take place. Additionally, to do a study of adjacent undisturbed sites to detemine if surrounding territories are filled, as  !

l suggested by Dr. Holcomb, vould be extremely difficult, particularly as the territorial behavior of nucerous species is unknown or only partially understood. Having performed these elaborate studies over many years, we would'have reasonable approximations of the various site populations l and would have added to the store of man's scientific hiovledge. However, I do not believe that such a study would enable one to make a more meaning-1 ful judgment as to the major effects of construction than is possible with

4 the present evaluation of dominant species and their ecological relation-ships. The study which we made was sufficient to evaluate the major ef-fects of construction and loss of habitat en the surrounding comunity.

Being more definitive in naming species and developing population estimates vill not enable one to make any significant improvement in evaluating the effects on the surrounding comunity. This is particularly so when one realizes, as Dr. Holcomb's analysis demonstrates, that meaningful monetary values cannot be assigned to the animal losses.

Dr. Holcomb lists three divisions of plants containing twelve classes and numerous animal phyla that veren't listed in the ecological survey. He, however, makes no meaningful reference as to how the inclu-sion of these plaats and animals in the survey would have been of use in making an evaluation. There is no doubt that, if present, all of thes l

vould play some role in the ecosystem and that many would centribute

, significan'.ly at some level of the food chain. However, there have not l l

been many ext,ensive studies of the numerous complex food chains in ter-restrial ecosystems and their interrelationships and I would not expect 1

1 such knowledge to be obtained without tremendous, patient effort by great numbers of highly trained individuals over extremely lengthy periods of time. Until such knowledge is developed, we would be largely unable to evaluate the roles of such plants and antmnis and the consequences of 1

their removal with any accuracy so as to eczne to any meaningful ecological conclusions.

It is hard to believe that Dr. Holccmb is serious when he alleges that a cost factor slatld be made for the oxygen produced by the pia t life

5 removed from the site. Recent compilations indicate that Midland County is 50% forested and almost 39% agricultural (Kimball and Bachman, County and District Land Use Patterns in Michigan, Michigan State University Cooperative Extension Service, January 1969). This small removal in rela-tion to the area cannot be expected to have any impact on the orygen supply in the area.

Dr. Holecmb makes extensive listings of birds and marrals that may be on the site based on his reading of standard texts giving area 4

extensions of various birds and mammnis. It is my opinion that such list-ings constitute pure speculation. Dr. Holcomb merely listed those birds and mnmmals that were shown on the maps as occurring in this part of the State of Michigan. The fact that a map shows large areas in which certain animals occurs does not mean that you can expect to find that animal on ,

I any specific si+e within the map's boundaries. See specifically Burt and j l

Grossenheider, "A Field Guide to the Mamals" 2d Ed 1964 p. xv. While it i l

1s possible that some of the birds and mamals listed by Dr. Holecmb could occur at the site, the fact remains that they have not been observed and that at least for several of them their presence is unlikely, e.g., least shrev, badger, gray fox, mink. In fact, the maps shown in Burt's Mamals of the Great Lakes, which was cited by Dr. Holcanb as the basis for his de-l cision that certain mamals were missing from our site survey, do not in-clude the Midland area within the range of the least shrew and the boreal redback vole. Yet he has included them as being present and assign d an-nual values of $12,000 and $1,00G, respectively, for their loss . Midland is on the very edge of the maps for shorttail vessels, which fact, depending on the accuracy of the map and its aethod of compilation, may or may not be significant. Additionally, as noted in Burt, gray fox and badger are very

to rare in the Great Lakes region.

In spite ol' this, Dr. Holcomb has decided that this relatively unattractive site vill have 36 badgers and 5 gray fox annually at values of $1,800 and $250, respectively. A glaring error in his compilation, and one which indicates his seriousness in compiling this list, is his estimate of populations of 4800 deer mice, 2h00 prairie deer nice and 2400 voodland deer mice.

This is merely a fantastic example of double counting.

The deer mouse, Peromyscus maniculatus, is a species of mouse which in the lover peninsula of Michigan is represented solely in the form of two subspecies the prairie deer mouse, Peromyscus maniculatus ~~

bairdi, and the woodland deer mouse, Peromyscus maniculatus gracilis There are thus no deer mice in the Midland area that are not either prairie deer mice or woodland deer mice. Dr. Holcomb has thus assigned a value of

$h8,000 for deer mouse loss and then recounted them as subspecies at $

each.

These obvious errors account for abnost $63,000 of Dr. Hoicomb's an-nuel tctal.

D .*

Holcomb does not indicate his basis for his population esti-mates.

It is my opinion, based on many years of observation in this area of Michigan, that he has overestimated the size of most of the vildlife population.

Because of the habitat available at the site, I believe he has particularly overestimated the population of mallards, ring-necked pheasants, opossum (not cocmon in this the northern part of its range), bobvhite quail (a very marginal species in this part of Michigan), and fox squirrel. In estimating his populations he has not taken into account natural mortality factors or territerial competition between species. Thus his population

7 estimates and cost analysis assume that all animals produced at the site are lost as a result of construction of the Plant. This, of course, is an absurdity as in most cases the cultural mortality factor (construction) vill merely replace natural mortality factors (e.g., predation, disease and star-vation). Dr. Holccmb himself admitted during exnMnation by the Board that '

predation alone in pheasants would decrease the species population at the site by as much as 50% in only a couple of months. It has been found in Michigan that hunters can harvest up to approximately 80 percent of the rab-bit population each fall without causing a decline in the next year's popu-laticn. Additionally, Dr. Holcomb assumed that all species presently at the site would be lost due to construction rather than displaced to sur-rounding sites because all territories surrounding the Plant vould be oc-cupied. While this may or may not be true, depending on the species, he took to account in his projections of population lost as a result of the Plant for the fact that much of the offspring of many species that would have been born at the site if there had been no Plant vould have been lost also as a result of the territories at the site and on surrounding land being  !

occupied to capacity (assu=ing such to be the case). In making his popu-lation projections he implies that he divided the site by the size of the  !

territory of a pair of animals or birds so as to calculate the population for the whole site. If he did this on a straight basis for each species of bird, for example, his esti=ates vould be overestimated because of the 1 j

fact that various species compete for the same territory. Thus, numerous of the pest species, e.g., starlings and red-winged blackbirds, ccmpete with more desirable species for nesting and breeding habitat.

8 Additionally the monetary values he places on each species is meaningless. The use of replacement cost to measure the loss of enimsis that no one vill attempt to replace and in most cases which no one vill have any interest in replacing is clearly unreasonable. The only purpose of replacin6 the vildlife would be if habitats were available in which to place the animals. Following operation of the Plant, the cooling pond could be drained and its dikes leveled and the vildlife vould quickly repopulate the site at no additional cost. One hundred and three thousand dollars of Dr. Holcomb's estimate for loss of birds relates to his replace-ment value of six generally recognized pest species: red-winged blackbird, brown-headed covbird, common grackle, crov, starling and house sparrov (alsocalledEn611shsparrov). Not cnly are these species generally of questionable value, there are active campaigns to discourage their abun- j 1

dance. The laws of the State of Michigan provide bounties on English spar-l rows (house sparrows), ICLA 5433 281; crows and starlings, MCLA 5433 301.

In several localities in Michigan, particularly along Saginaw Bay, money is spent each year to prevent anmnge to agricultural crops by red-winged blackbirds and comon grackles. Another example of a particularly unreason-able estimate is $5,000 per year for the house mouse. Considering l l

Dr. Holcomb's concern for the Kirtland's varbler, I might point out that there appears to be considerable evidence that brown-headed covbird para-sitism is a potentici factor in lowering the breeding success of this scarce bird. It is my opinion that no meaningful monetary measure can be made of the cost of loss or displacement of animal and plant life from the site. Dr. Holcomb's effort merely demonstrates the complexity and futility of the task. Certainly a more meaningful measure of the value A .,

e

9 of loss of habitat is the price at which such land changes hands in the market place.

To the extent Dr. Holecub's estimates attempt to quantify the cost of the loss or_ displacement of these biological populations to the public they have little value for the following reasons:

1. The proposed site does not contain any unique vild-life habitats or rare or endangered species populations. This conclusion is based on my knowledge that one vould not expect to find any rare or endangered species in this type of habi-tat in this part of Michigan and that there are no reports or signs of the existence of such species in the area. Con-sultations with the Department of Natural Resources have fur-ther confirmed this opinion.

2 The site is not an area which would hold much at-traction to bird watchers, hunters or other nature enthusi-asts and it is unlikely that many have visited the site for  ;

i i this purpose in the past. I 3 The site's location near a large industrial complex ,

I and near an expanding city and the fact that it is zoned for )

i industrial and residential use limits its value as a natural area.

4. The number of birds and mamnals from vildlife popu- l i'

laticns on the site that would be viewed by residents in other geographic areas such as in migration route or in vin-tering areas would be very few.

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i

10 5 Old field, forested and cropland connunities are all common ia the' Midland area and would be populated with similar species. For example, a recent compilation indicates that ap-proximately Sof, of the land in Midland County is forested ani 39f2 is devoted to agriculture (Kimball and Bachman, County and District Land Use Patterns in Michigan, Michigan State Univer-sity Cooperative Extension Service, Jcnuary 1%9) .

My conclusion remains that there is nothing unique or particularly desir-able about the majority of the proposed site and that removal of the vild-life populations previously resident there vill have no noticeable effect on vildlife populations in the Midland area. For the reasons stated above.

Dr. Holecab's estimates of the vildlife populations and the dollar values are totally unrelated to reality and in no way represent a meaningful cost.

Dated July 8,1972