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Submitted by Elaine Rua Rodriguez Rochedo, Comissão Nacional de Energia Nuclear
   Commenting as an individual
Document Reference animals and plants
 
I send some comments yesterday but as they have not been included I will try to summarize them here again.

In general, the document is interesting but needs more development on the "use" of Reference animals and plants (RAP). In fact, the focus of the document is the RAP list. This list was clearly developed to address temperate climate countries (e.g., “hibernating” frog, flat fish typical of “cool temperate waters”, large “temperate” water crab, earthworms that “occur naturally in Europe, Western Asia and North America”, pine trees that can be found “across the whole Northern hemisphere”, deer characteristic of northern hemisphere”, and so on). Although individuals of similar species may be found in tropical climate areas, most of them are hardly typical or adequate to address tropical climate areas.

The level of detail in the description of habits and modeling conflicts with the “broad” definitions suggested in the text. Also, reptiles were not included in the list and may be relevant to some scenarios.

The effort on deriving methodologies and guidance to deal with environmental impact assessment is, of course, relevant and for sure is a need to the whole world. The use of a common approach to be applied everywhere is welcome. But the selected RAP is not adequate to be applied as a worldwide reference list. Consequences of an inadequate list may be high to tropical and/or developing countries.

My suggestion is to put more focus on the development of guidance on deriving such lists and on how to use them, while systematically referring to the current list as “example RAP list” or to change the name of the document to something like “Environmental protection: the concept and use of reference animals and plants as applied to temperate climate areas”