Conservation Comment Letters

CNPS routinely comments on developments and projects that could have an impact on native plant communities throughout California. Recently CNPS has been involved in the Desert Renewable Energy Conservation plan (DRECP), the BLM programmatic EIS for solar power, and the Fish and Wildlife services effort to modify the listing status of six endangered species . Our letters regarding these issues are listed below;

Letters regarding Forestry and Fire Protection

• On February 25 2013 CNPS submitted a letter to the State Board of Forestry and Fire Protection asking that the Draft Programmatic Environmental Impact Report for the Vegetation Treatment Program not be certified in its current form. Read that letter here (231kb PDF)

Letters regarding the DRECP

• On July 2nd 2009 CNPS also submitted its own letter with specific recommendations from CNPS. CNPS provided guidelines on solar energy project siting, and recommended that the DRECP be completed as a natural community’s conservation plan. Read that letter here (1Mb PDF)
• On May 27th 2010 CNPS wrote a letter to the Director of the DRECP requesting that CNPS be added to the stakeholder advisory committee to serve as a voice for plant conservation. Read that letter here (91kb PDF)
• On September 10th 2010 CNPS commented on the recommendations of the Independent Science Advisers report for the DRECP. CNPS voiced concerns over the nature of mitigation to take place due to solar development impacts. Read that letter here (104kb PDF)
• On September 17th 2010 CNPS wrote a supplemental request to the director of the DRECP to be included as a stakeholder in preparing the desert renewable energy conservation plan. Read the request here (212kb PDF)
• On November 16th 2010 CNPS commented on the Covered Species Preliminary Description for the Desert Energy Renewable plan. CNPS encouraged the DRECP to give equal consideration to plants and to locate disturbed areas that would be ideal sites for Solar Energy projects. Read the letter here (115kb PDF)
• On April 25th 2011 CNPS wrote a letter to the project manager of the DRECP regarding which native plant species should be addressed by the DRECP. Read that letter here (168kb PDF)
• On June 24th 2011 CNPS wrote detailed comments about the DRECP Framework Conservation Strategy Report citing key issues of language, and the resolution being used to assess native plant communities. Read that letter here (70kb PDF)
• On June 29th 2011 CNPS and other conservation organizations wrote a letter to the DRECP offering general siting criteria for Solar Energy projects that would minimize conflict. Read that letter here (78kb PDF)
• On July 26th 2011 CNPS the REAT agencies recommended removing two plants from the proposed covered species list on the DRECP. CNPS sent a response to this action. Read more here (43kb PDF)
• On August 16th 2011 CNPS wrote the DRECP covered species workgroup and provided additional comments regarding the impacts that Desert projects may have on native plants, specifically those that are rare inside California but more common elsewhere. Read that letter here (138kb PDF)
  

Letters regarding BLM’s Solar Programmatic

• On September 11, 2009 CNPS commented and the process of identifying and researching Solar Energy Study Areas as possible sites for energy development. CNPS encouraged BLM to rank sites according to ecological importance, and voiced opposition to siting energy development on intact desert communities. Read more here (141kb PDF)
• On May 2nd 2011 CNPS wrote a comment letter to the BLM regarding their draft programmatic environmental impact statement for Solar Energy development in California. CNPS voiced strong concerns over several locations slated to be solar energy zones, including; Iron Mountain, and the Pisgah Solar Energy Zone. Read more here (320kb PDF)
• On January 27 2011 CNPS submitted additional comments to the BLM on the Supplement to the Draft Solar Programmatic Environmental Impact Statement. CNPS supports the Modified Solar Energy Zone Program Alternative and opposes the "variance option" for siting projects outside of identified Solar Energy Zones. Read more here (194kb PDF)

Letters regarding delisting/reclassification of six endangered species

• On March 23rd 2010 CNPS and other organizations wrote the Fish and Wildlife Service a letter in opposition to the reclassification and possibly delisting of the endangered plants Eureka valley dune primrose, and Eureka Valley Dunegrass. CNPS pointed out that the impacts of global warming to the plants had not been properly explored and that prohibiting OHV’s in their habitat was not sufficient criteria for delisting. Read more here (706kb PDF)
• On March 21st 2011 CNPS and the Center for Biological Diversity (CDB) commented on the USFWS proposal to delist six species currently listed as endangered under the Endangered Species Act. CNPS and CDB strongly opposed the delisting of Eureka Valley Dune Primrose, and Eureka Valley Dunegrass , as well as the delisting of the Tidewater Goby. Read more here (108kb PDF)