(Draft Desert Renewable Energy Conservation Plan and Environmental Impact Statement/Environmental Impact Report)
Full text of the letter
February 23, 2015
California Energy Commission
Sent via electronic mail to email@example.com
Subject: DRECP NEPA/CEQA (comments on the Draft Desert Renewable Energy Conservation Plan and Environmental Impact Statement/Environmental Impact Report)
To Whom It May Concern:
CNPS is a California 501c(3) non-profit organization with nearly 10,000 members representing 34 Chapters across California and Baja California, MX, all working to protect California's native plant heritage and preserve it for future generations.
We appreciate the opportunity to provide the DRECP agencies with these native plant-focused comments regarding the draft DRECP and associated NEPA/CEQA reports. The comments in this letter supplement comments submitted in two other letters sent to the DRECP agencies by a desert NGO coalition of which CNPS is a partner. Those letters address our shared concerns with what we feel are fundamental problems with the draft, and with the draft agreement between the California Department of Fish and Wildlife (CDFW) and the U.S. Bureau of Land Management (BLM) and the draft Agreement's ability to ensure lasting protections on BLM-managed lands and meet the conservation and recovery requirements of the NCCP Act. We incorporate the comments of the group letters herein by reference, and have attached copies for your reference.
CNPS has remained committed to the DRECP process since it formally began in 2009, and has been a member of the Stakeholder Group since 2010. We continue to devote considerable organizational resources to ensuring the DRECP (or Plan) will ultimately achieve its highest potential to conserve desert species and develop renewable energy in appropriately sited places.
While we afirm our continued commitment to the Plan's development, we can not support this version of a draft DRECP because of serious flaws that we believe prevent the draft Plan from providing sufficient conservation for desert native plant species and communities given the scope of development proposed. We articulate our concerns herein, and feel the Plan will need to undergo significant revision in order to address the breadth of concerns that we and others have collectively raised. Where we can, we have included recommendations for actions that can address our concerns. In this way we strive to work with the DRECP agencies, the energy industry, fellow Stakeholders, and local community members to find the path that leads to a successful Plan.
1. Draft DRECP Natural Communities
The draft Plan fails to establish clear, quantifiable, and measurable NCCP BGOs and BLM LUPA Conservation and Management Actions (CMAs) for DRECP natural communities. As a result, it is not possible to evaluate whether the conservation strategy for DRECP natural communities is achievable.
The draft DRECP also fails to use available information to identify areas where important natural communities occur across the Plan Area. This is of critical concern for key areas of natural community ranges where models and empirical field data indicate there is potential for future range expansion under changing climate conditions.
Lacking this information, the draft Plan proposes land designations that conflict with and potentially eliminate the conservation value of lands critical to the future of DRECP natural communities including Joshua tree woodland, microphyll woodland, dune, and other rare (S1-S3 ranked) natural communities. We provide examples of these concerns below. While not an exhaustive list of examples, they are representative of the type of problems that need to be addressed through revision of the current draft DRECP.
Joshua tree woodland
The draft DRECP fails to use available information to clearly identify areas where Joshua tree woodland is known to occur across the Plan Area (see Figures JT-1 [ Large | Small ], JT-2 [ Large | Small ], and JT-3 [ Large | Small ]). The draft Plan also fails to establish clear, quantifiable, and measurable NCCP BGOs and BLM LUPA Conservation and Management Actions (CMAs) for this natural community, especially for key areas of its range where models and empirical field data indicate potential for future range expansion under changing climate conditions. (see Figures JT-7 [ Large | Small ], JT-8 [ Large | Small ], JT-9 [ Large | Small ], JT-10 [ Large | Small ], JT-11 [ Large | Small ], JT-12 [ Large | Small ], JT-13 [ Large | Small ], and JT-14 [ Large | Small ]).
The Plan must be revised to establish clear, quantitative, and measurable conservation targets for natural communities, and to remove ambiguity from, and thereby strengthen, avoidance and minimization CMAs for natural communities. A revised Plan must also include additional analyses to identify priority conservation areas for natural communities that are consistent with revised BGOs and CMAs. We provide more detail regarding these recommendations below.
"Create a Plan-wide reserve design consisting of a mosaic of natural communities with habitat linkages that is adaptive to changing conditions and includes temperature and precipitation gradients, elevation gradients, and a diversity of geological facets that provide for movement and gene flow and accommodate range shifts and expansions in response to climate change." (Landscape Features and Habitat Connectivity Plan-Wide BGO Goal L1),
"Conserve unique landscape features, important landforms, and rare or unique vegetation types identified within the Plan Area, including: ...areas of dense Joshua tree woodland" and "rare natural community alliances." (Goal L1, Objective L1.4) Both at DRECP Appendix C, p. C-9.
In principle, these are admirable goals and objectives. However, by not specifying the quantity of a natural community's baseline distribution to be conserved and where, the draft DRECP provides no means by which to analyze whether these goals and objectives are achievable under the proposed conservation strategy.
In earlier drafts, DRECP BGOs had clearly defined conservation targets for natural communities. 1 These earlier quantitative-based BGO proposals have been removed from the current draft DRECP with no explanation or rationale provided for their removal. For example, earlier BGOs developed for microphyll woodland and dune natural communities included,
"Conserve the areal extent of at least 90% of all existing microphyll woodlands relative to existing levels in each Conservation Area." (April 10, 2013)
"Within existing microphyll woodlands, conserve the areal extent of at least 95% of smoke tree woodland, honey mesquite riparian form and desert willow microphyll woodland rare alliances relative to existing levels in each Conservation Area." (April 10, 2013 memo)
"Conserve the entirety of the eight rare alliances in the Reserve System, and ensure that Covered Activities in the DFAs do not diminish or obstruct eolian transport into the Reserve System." (May 20, 2013 memo)
Here was a conservation strategy being driven by clear, quantitative BGOs that state the target quantity of natural community to be conserved and where. In the current draft, the heart of the conservation strategy for covered natural communities is summarized by a generic statement repeated for each natural community listed in the Appendix C BGO tables,
"conserve (insert natural community name) in the (insert name) subarea(s)" where it occurs. (Appendix C, Table C-1 pp. C12-C20)
This direction is too generic to be meaningful as a conservation strategy for natural communities, and is a gross oversimplification of the more detailed BGOs for natural communities that appeared in previous draft DRECP documents. We attach the previous documents for your reference and as examples of the type of quantitative BGO targets we had expected would be developed for the DRECP, and that we feel are essential to its ultimate success as a conservation plan.
The acreage for Joshua tree woodland (Yucca brevifolia alliance) provided in DRECP's Natural Community tables does not include all available mapped acreage for this community (see section ii below), and there are no quantitative Plan-wide or subarea-specific BGO conservation targets. Without an accurate baseline or an acreage target for Joshua tree, the draft DRECP has provided no means to determine whether cumulative impacts from covered activities and/or other activities over the term of the Plan will have exceeded the threshold of viability for the natural community in the Plan Area.
The insufficiency of the BGOs are exacerbated by weak conservation language used to develop avoidance and minimization Conservation and Management Actions (CMAs) for natural communities under the DRECP's BLM LUPA component. CMAs call for avoidance and minimization of natural communities, "to the maximum extent practicable." While requiring maximum avoidance and minimization of impacts is commendable, the ambiguous and subjective nature of the CMA requirement provides no certainty that the community will remain viable in the face of cumulative impacts. The amount of impacts to DRECP natural communities becomes even less constrained through the "unavoidable impacts to resources" allowance associated with natural community CMAs (e.g., CMA AM-DFA-RIPWET-1 p. II.3-49, and elsewhere).
The draft BGO L1.4 for Joshua tree woodlands which states, "Conserve...[a]reas of dense Joshua tree woodland," is unclear. Within the context of BGO L1.4, what is the definition of "dense"? What is the baseline distribution of "dense" Joshua tree woodland? How much of this baseline must be conserved to meet the goals of the DRECP, and where? The draft DRECP fails to provide clarity to these fundamental questions. We recommend removing the word "dense" as a qualification threshold for Joshua tree woodland conservation. If retained, then "dense" must be defined, and a quantitative conservation target for "dense" stands established.
The National Vegetation Classification System's (NVCS) membership rules for Joshua tree woodland (Yucca brevifolia Woodland Alliance) is for Joshua trees to be "evenly distributed at ≥1% cover."2 The 2013 DRECP, the 2013 revised JTNP, and the 2004 MDEP vegetation maps all used a ≥1% canopy cover threshold for mapping Joshua tree woodland. Therefore, if defining "dense" Joshua tree woodland is based on available vegetation map data, then the most applicable definition is the ≥1% canopy cover standard.
The 2013 DRECP vegetation map, covering approximately 7 million acres of the DRECP Plan Area, used three density classes to map Joshua tree woodland; <1%, 1-5%, and >5% canopy cover. It delineates approximately 16,400 acres of Joshua tree woodland at >5% canopy cover, and these usually are only found at higher or wetter sites where clonal stands occur. Woodland stands at >5% cover represents less than 2% of the combined acreage of woodland stands (≥1% cover) mapped in California to date. See Figure JT-4 [ Large | Small ]. While these higher-density stands are definitely a conservation priority for Joshua tree woodland, they must not be the type and density that defines a DRECP conservation requirement. We recommend removing the term "dense" from Joshua tree woodland natural community BGOs. If the term is not removed, the NVCS membership rule of ≥1% canopy cover should define "dense Joshua tree woodland."
For a subsequent draft revision, we recommend establishing a range of conservation targets for Joshua tree woodland, whereby a 100% aerial extent BGO target is set for the uncommon, >5% canopy cover stands of Joshua tree, and for Joshua tree woodlands in transitional habitat areas. In other areas, a lower aerial extent target could be appropriate. We offer the following model from which to build quantitative BGOs for Joshua tree woodland, and other rare natural communities within the DRECP Plan Area.
a. Conserve 100% of the aerial extent of Joshua tree woodland alliance with >5% canopy cover within the subareas where they occur. See Joshua tree conflicts in Bird Spring Canyon related to the proposed Tehachapi Wind project and SRMA that highlight the need for this conservation target.
ii. Revise DRECP Joshua tree distribution map (see Figures
JT-1 [ Large | Small ],
JT-2 [ Large | Small ],
JT-3 [ Large | Small ],
JT-4 [ Large | Small ],
JT-5 [ Large | Small ], and
JT-6 [ Large | Small ])
The draft DRECP Joshua tree map (Appendix C, Figure C-17) displays a combination of Joshua tree woodland distribution from the 2013 DRECP and 2013 JTNP vegetation maps, but not the 2004 MDEP map. Rather, the DRECP combines the MDEP Joshua tree information into its related vegetation Macrogroup, the Mojave and Great Basin upper bajada and toe slope (MGUT) community. Furthermore, Joshua tree woodland alliance mapped by the MDEP within the CDCA but outside the DRECP boundary has been clipped from the draft DRECP map since it is not a resource within the Plan Area. As a result, important Joshua tree woodland areas originally in the MDEP map that occur in important CDCA LUPA conservation areas are indistinguishable from the aggregated MGUT layer and become, in practice, invisible to planning and conservation considerations. A revised DRECP must include a complete Joshua tree woodland distribution map.
CNPS recommends revising the DRECP distribution map for Joshua tree alliance to show all available mapped distribution information for California. This can improve conservation planning decisions by helping to prioritize conservation actions for Joshua tree, especially at the periphery of its range and/or where populations have the opportunity to expand into new, transitional habitats without direct management intervention (i.e., assisted migration). A more complete map will also better illustrate where this community occurs within proposed BLM LUPA designations, and add to the importance and relevance of administering proposed ACECs and/or NLCSs for Joshua tree conservation.
iii. Revise BLM LUPA ACEC / NLCS worksheet language to state that Joshua tree woodland natural community conservation is a management priority.
Joshua tree woodland is an iconic natural community of the Mojave Desert that supports a high biological diversity including nesting habitat for native birds and a food source for Mohave ground squirrels. Joshua tree woodland vegetation alliance has a rank of S3, and is threatened by many factors including; development, grazing, vandalism, direct removal, habitat fragmentation, exposure to increased wildfire from the result of continuing urbanization and agricultural expansion, and climate change. Management of the (name) ACEC / NLCS will address the conservation of Joshua tree woodlands by monitoring population trends, removing and /or preventing threats to this natural community, and taking remedial actions when impacts to Joshua tree woodland occurs.
List of LUPA designations to which Joshua tree language should be added:
iv. Prioritize Joshua tree conservation in potential transitional habitat areas
Although each of these areas is consistent with draft BGO Goal L1 and Objective L1.4, and the information presented in the following Figures JT 7-13 (JT-7 [ Large | Small ], JT-8 [ Large | Small ], JT-9 [ Large | Small ], JT-10 [ Large | Small ], JT-11 [ Large | Small ], JT-12 [ Large | Small ], JT-13 [ Large | Small ]) is available - though not easily accessible - within the DRECP, none of the six areas shown are noted in the Plan for Joshua tree woodland conservation. Along with the lack of quantitative BGO conservation targets for natural communities, we highlight these areas as examples of additional analysis and revisions needed in the draft DRECP.
Western Antelope Valley / Tehachapi Mountains transitional habitat Figure JT-9 [ Large | Small ]
Southern Sierra Nevada Mountains transitional habitat Figure JT-10 [ Large | Small ]
We recommend managing lands across this area to conserve Joshua tree woodland and transitional habitat from Rose Valley into the Southern Sierra Nevada mountains. Joshua tree stands occur across BLM-managed lands in this area, however new vegetation mapping for Joshua tree is needed to map their distribution with accuracy. A composite range map of available vegetation maps, literature search results, and expert opinion was compiled by Kenneth Cole and others in 2003. This range map, together with TNC forecast model results provide a guide to transitional Joshua tree range in this area.
Centennial Flats / Conglomerate Mesa transitional habitat Figure JT-11 [ Large | Small ]
Shadow Valley / Mesquite Mountains / Kingston Range transitional habitat Figure JT-12 [ Large | Small ]
Lucerne Valley transitional habitat Figure JT-13 [ Large | Small ]
Pinon Hills / Countyline transitional habitat ACEC Figure JT-14 [ Large | Small ]
v. Establish an avoidance and minimization CMA for Joshua tree woodlands in DFAs
The loss of Joshua tree woodland as the result of projects within proposed DFAs should be recognized by the DRECP agencies as a significant impact from covered activities unless mitigated below a significant level. The draft DRECP needs to include a more stringent CMA for natural communities that occur within DFAs, including Joshua tree woodland. We off the following mitigation concepts related to Joshua tree for inclusion in a revised CMA.
Joshua tree woodland on project sites should be avoided and preserved in perpetuity from further development. If avoidance is not feasible, off site Joshua tree woodland of equal or superior quality should be acquired at no less than a 1:1 mitigation ratio, where a minimum of 1:1 mitigation ratio should be employed only for degraded Joshua tree woodland habitat. Greater than 1:1 mitigation is required for impacts to higher quality habitat. The 2013 DRECP vegetation map includes 5 specific attributes that quantify disturbance within Joshua tree habitat occurring within the DFAs of the Western Mojave and Eastern Slopes ecoregion subarea. These habitat quality map attributes, along with project-level habitat assessment can be used to determine woodland habitat quality and appropriate mitigation ratios.
Mitigation for remaining Joshua tree woodland must occur within the same subarea to avoid local extirpation and promote population resiliency to climate change. Acquired habitat should be adjacent to large tracts of existing Joshua tree woodland that have been identified by resource agencies as having a high priority for acquisition for conservation. All mitigation lands preserved on site or acquired off site should be deeded to a local land conservancy and protected in perpetuity under a conservation easement to prohibit incompatible uses on the site.
Salvage and transplantation of Joshua trees should not be considered the default mitigation action for loss of Joshua tree woodland vegetative communities as these methods are experimental and there are no assurances of their success. If used as mitigation and/or restoration action of last resort, CNPS recommends following Joshua tree salvage, transplantation, and management protocols practiced by BLM Nevada Las Vegas District, and by the California Wildlands Conservancy. Both entities have transplanted Joshua tree individuals while monitoring and measuring their success and failure, and tracking resources required to maintain transplanted individuals over several years.
Summary of recommendations for Joshua tree woodlands
In terms of vegetation classification hierarchy, the microphyll woodland-containing natural community SCOWS, along with the Mojavean semi-desert wash scrub (MOWS) natural community both belong within the vegetation MacroGroup, Madrean Warm Semi-Desert Wash Woodland/Scrub, or (MAWW) natural community. This has relevance to microphyll woodlands since all microphyll woodlands belong within both the SCOWS (Group) natural community, and the MAWW (MacroGroup) natural community, BGO and CMA references. Therefore all Plan references to SCOWS and/or MAWW natural communities can apply to microphyll woodlands, including map references, BGOs, and CMAs.
Our comments regarding the insufficient conservation value of draft BGOs and CMAs for the Joshua tree woodland natural community extend to the microphyll woodland natural community. DRECP natural community map information for microphyll woodland distribution are incomplete and need revision. The draft Plan lacks quantitative conservation targets for microphyll woodlands, and CMAs for microphyll woodland communities must be strengthened.
i. The draft DRECP microphyll woodland map, and BGO subarea list are incomplete and need to be revised
There are microphyll woodland (mesquite) stands in Preferred Alternative DFAs within the West Mojave and Eastern Slopes subarea that do not appear on the DRECP microphyll woodland map, or the DRECP SCOWS natural community map (Appendix C, Figure C-25). See Figure MW-3 [ Large | Small ].
The West Mojave and Eastern Slopes subarea needs to be added to the BGO for the SCOWS natural community (Appendix C, p. C-19) as one of the Plan subareas where microphyll woodlands occur.
There are additional microphyll communities that do not appear on DRECP maps that intersect or are adjacent to the Charleston View DFA and Variance lands in Mesquite Valley, both within the Kingston and Funeral Mountains subarea. The Mesquite Valley mesquite bosque UPA occurs here yet this microphyll vegetation does not appear on DRECP maps. The area encircling the mesquite bosque is designated Variance land that should be removed to protect this example of a vanishing groundwater-dependent microphyll community type. (Figure MW-3 [ Large | Small ])
More microphyll woodland occurs within the Daggett Triangle DFA in the Mojave and Silurian Valley subarea. Including these woodland areas on DRECP maps will help identify potential development conflicts with these resources. The draft DRECP appears to have overlooked these rare natural community occurrences. (Figure MW-3 [ Large | Small ])
It is not clear how the DRECP baseline acreage totals for microphyll woodlands were calculated. There is no explanation within draft Plan documents, and acreages listed within the attribute table of the DRECP microphyll woodland map are confusing. For example all records sourced from the NECO vegetation map are duplicated within the attribute table. If baseline acreage was calculated using this data table, then we question the veracity of the values that appear in the Baseline Biology Natural Communities table (Appendix Q, Table 4-1).
More importantly, as with Joshua tree woodland natural community, the baseline mapping and acreage calculations for microphyll woodland needs to be revised and reanalyzed, and the methods used clarified.
ii. establish quantitative, measurable BGO conservation targets for microphyll woodland natural communities
We recommend the draft DRECP be revised to, among other things, reestablish quantitative BGOs for microphyll woodlands and other natural communities. With them, the process for determining allowable impacts becomes more transparent. Without them,
iii. clarify what activities, if any, are allowed within riparian and wetland buffers
Summary of recommendations for microphyll woodlands
Other DRECP Natural Communities
The draft DRECP recognizes rare special stands of vegetation (technically not an alliance) and provides conservation measures for them as exemplified by Wislizenia refracta, a special stand of dune vegetation listed in the North American warm desert dunes and sand flats community. The same treatment must be applied to Crucifixion thorn special stands.
Additionally, botanists have recently documented perhaps the largest Crucifixion thorn stand in California north of the Rice Valley wilderness area. This occurrence falls within the proposed Chuckwalla-Chemehuevi desert tortoise linkage ACEC. We recommend the following language be added to the Vegetation section of the BLM worksheet for this proposed designation (Appendix L1_Part5-2):
Management Action: Protect special status vegetation including rare plants and rare natural communities, including Crucifixion thorn (Castela emoryi) special stands. The largest documented Crucifixion thorn population in California occurs in Rice Valley within this ACEC as described in Bell and Herskovits (2013). 7 We have included the Bell and Herskovits article as an attachment for your reference.
Wetland CMA requirements
Additional LRO natural community
Elements of the draft that should be retained in future revisions
2. Refining Preferred Alternative DFAs
There are areas of DFAs proposed in the Preferred Alternative that should be refined in order to avoid sensitive biological resources, important ecological processes, and project siting conflicts. We recommend making the following DFA refinements.
Riverside East DFA
1. McCoy Wash area (Figures LUPA-2 [ Large | Small ], LUPA-3 [ Large | Small ], LUPA-4 [ Large | Small ], LUPA-5 [ Large | Small ])
To conserve microphyll woodlands and avoid complications with project siting, we recommend refining both the Preferred Alternative DFA and the Solar PIES SEZ boundaries to the southeast, in alignment with the proposed Alternative 3 DFA boundary for this area (Figure LUPA-14 [ Large | Small ]). The Alternative 3 DFA boundary conforms to the microphyll woodland wash avoidance approach we have described. We further recommend that avoided lands be redesignated from DFA / SEZ to ACEC and thereby expand the McCoy Wash ACEC designation proposed in the Preferred Alternative.
2. Blythe Variance lands (Figure LUPA-6 [ Large | Small ])
3. Southwest of McCoy Peak (Figures LUPA-7 [ Large | Small ], LUPA-8 [ Large | Small ]).
5. Palen Dunes area (Figures LUPA-9 [ Large | Small ], LUPA-10 [ Large | Small ], LUPA-11 [ Large | Small ])
Figure LUPA-11 [ Large | Small ] shows where an aeolian sand transport corridor mixes with alluvial fans flowing downslope from the Palen Mountains wilderness. These mixed soils support dense microphyll woodlands (Blue palo verde - Ironwood). Dense microphyll woodland communities, unstable soils, and a sand transport corridor make this place a logistical challenge for project siting. We recommend modifying the DFA boundary to avoid microphyll and rare dune natural communities, and the Aeolian transport corridor as per Alternative 3's DFA alignment. Previously designated DFA lands should be redesignated as Palen/Ford ACEC lands.
5. Desert Center area (Figures LUPA-12 [ Large | Small ], LUPA-13 [ Large | Small ])
Silurian Valley DFA
West Mojave DFAs
Figure LUPA-15 [ Large | Small ] maps areas along the margins of Antelope Valley where rare natural communities living on the edges of their range are in conflict with DFA designations. Lands south of HW-18 in the El Mirage Valley DFA are rich in higher-density Joshua tree woodlands and a suite of rare natural communities. Moving the DFA boundary north of HW-18 would avoid almost all these important communities.
The same issues occur on DFA-designated lands near Palmdale, in Fremont Valley, and at the western-most reaches of Antelope Valley. We recommend selectively removing some Antelope Valley DFA lands to conserve components of these rare communities, as per the intent of the Plan-Wide BGO L1, and associated Objective L1.4.
Johnson Valley DFA
3. NLCS and ACEC LUPA Designations
CNPS does not support modifying the designations of any existing ACECs or DWMAs through the DRECP LUPA process, including but not limited to the Barstow wooly sunflower, Kelso Creek monkeyflower, Mojave monkeyflower, Parish's Phacelia, and Soggy Dry Lake creosote clone ring ACECs. We do support the following designations proposed in the Preferred Alternative.
Chuckwalla to Chemehuevi Tortoise Linkage ACEC / NLCS
As noted above in Section II, botanists from the Rancho Santa Ana Botanic Garden have recently documented perhaps the largest Crucifixion thorn stand in California north of the Rice Valley wilderness area. This occurrence falls within the proposed Chuckwalla-Chemehuevi desert tortoise linkage ACEC. We recommend the following language be added to the Vegetation section of the BLM worksheet for this proposed designation (Appendix L1_Part5-2) in order to incorporate the protection and management of this rare natural community into the ACEC / NLCS as a Vegetation management priority:
Vegetation Management Action: Protect special status vegetation including rare plants and rare natural communities, including Crucifixion thorn (Castela emoryi) special stands. The largest documented Crucifixion thorn population in California occurs in Rice Valley within this ACEC as described in Bell and Herskovits (2013). 10 We have included the Bell and Herskovits article as an attachment for your reference.
McCoy Valley ACEC
A DFA alignment as proposed for this area in Alternative 3 would avoid removal of hundreds to thousands of acres of microphyll woodlands that would be necessary to site utility-scale projects here. (see Figures LUPA-2 [ Large | Small ], LUPA-3 [ Large | Small ], LUPA-4 [ Large | Small ], LUPA-5 [ Large | Small ], and LUPA-14 [ Large | Small ])
Only the northern portion of the Cadiz Valley-Iron Mountain region is included in the National Conservation Lands in the Preferred Alternative. It is critically important that, with the exception of salt mines, the Colorado River Aqueduct and other developments, the remainder of this highly scenic, ecologically important and still largely wild region be included as well.
The center of the Castle Mountains is rugged and rocky, with hidden canyons containing a diversity of rare desert annuals, including nine-awned pappus grass (Enneapogon desvauxii) and Clark Mountain spurge (Euphorbia exstipulata). Steep canyons spill out into wide valleys that surround the range. They are home to dense and extraordinarily healthy stands of Joshua trees that are part of a desert savannah containing a diversity of native annual and perennial grasses. Around two dozen grass species are found here, of which half a dozen are rare grasses. Some species, such as burro grass (Scleropogon brevifolius) and false buffalo grass (Munroa squarrosa), are part of unique desert grasslands found nowhere else in California. Closer inspection also reveals a plethora of other rare plant populations such as matted cholla (Grusonia parishii), Abert's sanvitalia aster (Sanvitalia abertii), and red four o'clock (Mirabilis coccinea).
The Castle Mountains are a botanical frontier where botanical collections hold important discoveries that will allow us to further understand our rare plant populations and their distribution in the California desert. We attach with this letter a vouchered checklist of plant species of Castle Mountains being developed by Duncan Bell and Jim André. This list helps demonstrate the diverse, rare, and special botanical qualities of the Castle Mountain.
Conglomerate Mesa / Centennial Flats NLCS designations: Alternative 2
Brisbane Valley Monkey Flower
4. Rare plant species
Eight of ten Plant Covered Species have quantitative conservation acreage targets associated with them in their Step Down BGOs. This is a good first step to ensuring as robust a conservation strategy as possible is designed in the DRECP for these plants.
Unfortunately, little else about their conservation reserve design is clear. What criteria were used to calculate the acreage targets? Where in the Plan Area, or in the DRECP NCCP Reserve area are these acres to be acquired? Once lands of suitable habitat for a plant Covered Species is acquired and added to the reserve, CMA# AM-RES-RL-PLANT-1 states:
Impacts to suitable habitat for all plant Covered Species within lands added to the reserve will be limited to 1% of their suitable habitat in the Plan Area. (italics added for emphasis). P. II.3-79.
According to this CMA, the disturbance cap for lands added to the Reserve for plant Covered Species can disturb most or all of the lands added. For example, the BGO for Mojave monkeyflower says there are 9,000 acres of suitable habitat in the Plan Area for this plant (it is unclear how this number was derived). If 100 acres of land are acquired and added to the Reserve for Mojave monkeyflower conservation, the disturbance cap as per the draft CMA is 1% of suitable habitat within the Plan Area, not within the parcel just added to the Reserve. 1% of suitable habitat in this case is 90 acres. So in accordance with this CMA for lands added to the Reserve, a 90-acre disturbance on a 100 acre conservation acquisition parcel is part of the DRECP conservation strategy for plant Covered Species. This CMA clearly needs revision.
Several plants still need to be considered for Covered Species list
A rare plant not on the covered species list in the footprint of an energy project might avoid immediate harm if the project pushes its footprint to the side, or builds around rather than on top of a population. Over time however, indirect impacts of living so closely to an industrial site could be fatal to the individual. Continued fragmentation and encroachment to the population could be fatal to the species.
Of the 347 rare plants documented to occur within the Plan Area, 159 (CRPR 1B and 2 species) have ≥ 75% of their documented California distribution entirely within the Plan Area. Of those 159 plant species, 15 have ≥ 75% of their documented California population entirely within the Plan Area and outside of LLPA lands. Of those 15 species, 2 are currently on the plant Covered Species list. They are, alkali mariposa lily and desert cymopterus.
CNPS is concerned that the conservation of the plant species have been critically under-addressed in the draft DRECP. Foremost among the list of overlooked species is Nye milkvetch (Astragalus nyensis). Nye milkvetch is a CRPR 1B.1, S1, G3 plant which means it is rare and vulnerable to extremely threatened throughout its ecological range (CA, NV, AZ, UT). 100%, of this plant's documented occurrences in California (CA) fall within the Charleston View DFA boundary. Reputable desert botanists surveyed specifically for this plant intensively between 2010-2012 throughout areas they felt represented appropriate habitat in the eastern Mojave, both in California and Nevada (NV) (and 2011 was a wet year). They found 1 occurrence in Stewart's Valley in NV, and no other CA populations outside the DFA.
DRECP Covered Activities within the Charleston View DFA could potentially extirpate the species from CA and push its Global population closer to listing or even extinction. Our knowledge of Nye milkvetch ecophysiology and management needs are equivalent to how much we know about other plants currenlty on the Covered Species list. Given the generic nature of Planwide and Step-down BGOs for the 10 plant CS currently on the list, the BGO management prescriptions for the current 10 covered plants can basically be cut and pasted for Nye milk vetch to the same management result. What's more, the restricted distribution of Nye milk vetch in CA makes it is possible to develop a confident target conservation acreage for the species within the DFA.
Therefore if the Charleston View area remains on the DRECP map as a DFA, putting Nye milkvetch on the Covered Species list would increase its long-term chances of surviving impacts from covered activities through the development of a reserve strategy for the species, even at the expense of a portion of its population (take permits). Absent a place on the Covered Species list, project avoidance for rare plants like Nye milkvetch on solar projects to date has been either significant footprint re-design to preserve larger intact rare plant areas, which is preferred, or avoidance of individual occurrences of plants within "halos" of polyester roping in between panels in fields of solar arrays. Absent a core reserve strategy, Nye milkvetch within the Charleston View DFA will likely face gradual fragmentation and decline from life between panels.
Other plants that need to be considered during draft DRECP revision are:
These are all threatened by wind development in the Tehachapi / southern Sierra Nevada mountains.
Other rare plant concerns
5. Revise DG Alternative
Recommendation: the DRECP must reanalyze the Distributed Generation alternative which is deficient and was considered but rejected in the current draft. This analysis must consider factors included in the a letter prepared by Basin and Range Watch, signed by a list of concerned individuals and organizations, including CNPS, and submitted to the DRECP regarding, among other things, the California Energy Efficiency Strategic Plan and its relationship to DRECP purpose and need. Such an analysis will provide guidance for achieving a greater percentage of renewable energy goals from rooftops, parking lots, and smaller-scale (<20MW) ground-mounted facilities sited on disturbed lands closer to end users.
While much work will be required to revise and develop a supportable draft DRECP, CNPS believes it is possible to do so. We have dedicated significant resources to engage in the DRECP process, and remain committed to working with the DRECP agencies, stakeholders, and local communities to build a supportable DRECP.
Julie Anne Hopkins
1 Draft DRECP 4-BGO Driver memo of April 10, 2013, and Draft DRECP 3-BGO Driver memo of May 20, 2013.
2 Sawyer, J., T. Keeler-Wolf, J. Evens. 2009. A manual of California vegetation, 2nd Edition. California Native Plant Society. Sacramento, CA. p. 301.
3 see DataBasin Joshua tree distribution model maps for the Southern Sierra Nevada at: http://databasin.org/search/#query=joshua%20tree&scope=all
4 Barrows, C. and M. Murphy-Merescal. 2012. Modeling impacts of climate change on Joshua trees at their southern boundary: How scale impacts predictions. Biological Conservation. 152: 29-36.
6 2013 DRECP Vegetation Map, Joshua Tree National Park Vegetation Map, Anza Borrego State Park Vegetation Map, and the MDEP Vegetation Map. The NECO vegetation map data included in the DRECP microphyll woodland map is based on Holland classification, not NVCS alliances, and is not included in Figure MW3.
7 Bell, D. and T. Herskovitz. 2013. A newly discovered large and significant population of Castela emoryi (Emory's Crucifixion thorn, Simaroubaceae) in California. Aliso, 31(1): 43-47.
8 2013 DRECP Vegetation Map attributes; Exotics, Roadedness, Development, Antrhopogenic Alteration, Hydromodification. Located within the map geodatabase's Attribute Table. The 2013 DRECP Vegetation Map geodatabase and GIS files are publicly available at: http://www.dfg.ca.gov/biogeodata/vegcamp.
9 Membership rules for microphyll woodland alliances are trees >2% or >3% canopy cover, depending on the type.
10 Bell, D. and T. Herskovitz. 2013. A newly discovered large and significant population of Castela emoryi (Emory's Crucifixion thorn, Simaroubaceae) in California. Aliso, 31(1): 43-47.
Joshua Tree maps
Microphyll woodland maps
Land Use Plan Amendment maps