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-   -   Original Message: Question by David Magney June 27, 2008 (

njensen 07-08-2008 11:44 AM

How important are species checklists in project CEQA reports? David Magney 7/27/2008
I am interested to know from each of you how important you think it is to have a species checklist included in a CEQA document, at least as an appendix, to CEQA documents. I personally find them very important when reviewing a CEQA document, for a variety of reasons, including:
• seeing the species richness of the site,
• seeing what taxa where observed,
• seeing what taxa where not observed,
• looking for locally rare species,
• evaluating the completeness of the survey(s) and assessment,
and probably some other aspects that I am forgetting at the moment. What do you think?

njensen 07-08-2008 11:50 AM

Comment from Mark Capelli, NOAA Fisheries
“The check-list can be important and useful if it based on actual field investigations, or previous site-specific studies. General check-lists derived from regional field manuals (unless they are based on citable references) have less utility, but eliminating the need to generate a relevant, up-to-date check list would not serve one of the basic purposes of CEQA - to provide a description of base-line conditions of the project site and affected area(s).”

njensen 07-08-2008 11:53 AM

Comment from Michael Charters, Botanist, CalFlora
“I definitely agree on the importance of species checklists for the reasons you indicate and simply for the historical record of what species were growing where. I think this will be of great significance especially in the coming years as the climate causes species changes to occur. The more records that exist the better.”

njensen 07-08-2008 12:05 PM

Comment from Elihu Gevirtz, Senior Associate Biologist, LFR, Inc.
“A list of all species observed on the site should be included as an appendix to most CEQA documents if the initial study indicated that there was a potential for significant impacts to biological resources. The document should also include a table that lists the sensitive taxa that occur in that USGS quad and the surrounding quads and an assessment of their presence/absence and likelihood of occurrence on the site based largely on habitat suitability.”

njensen 07-08-2008 12:09 PM

Comment from Steve Boyd, Botanist/Herbarium Curator, Rancho Santa Ana Botanic Garden
“I agree with your reasoning completely. One can ascertain considerable information about the quality of a botanical survey by looking at the species list. I believe rare or sensitive plant surveys should (almost) always be "floristically" based, that is, addressing completely what was found at the site, and elaborating on what rare or sensitive species were expected, what rare or sensitive species were found (including those not expected), and so on. As an herbarium curator, I also believe there should be a greater, not lesser, expectation for those conducting botanical surveys to collect voucher specimens and deposit these in regionally appropriate herbaria. In the case of "new" records for rare or sensitive taxa, I think this should be an absolute requirement. I know the cost of this activity is generally not covered by contracts, and may often be prohibited or strongly discouraged by project proponents, but from a professional standards and ethics standpoint, I do think it is something we should all push for whenever possible.”

njensen 07-08-2008 12:09 PM

Comment from Andy Sanders, Botanist/Curator UC Riverside Herbarium
“They are essential, IMO. Besides the points you make, they are the best tool for evaluating the competence of the person/group preparing the report. Gross misidentifications (indicated by out of range species, etc.) show a group didn't know what they were doing, as does a ridiculously short species list. Many times a quick look at the attached species list will tell you that the survey was done by someone unfamiliar with the flora of CA, or that the list was copied from some general list and doesn't apply to the site at all -- and hence calls the whole report into question as a possible fraud. Personally, I think that not only should a species list be present, but the native species should be at least 50% vouchered, and deposited in a public herbarium, so that IDs can be checked/confirmed. Biological surveys for development projects are probably the single largest expenditure of money on biodiversity issues in CA, yet much of the work is essentially wasted scientifically because there is no permanent record of the alleged findings. Vouchered records of sensitive species, for example, become part of the permanent record and contribute to future reevaluations of the taxa. Vouchers of "common" taxa can contribute to reevaluation of the taxonomy of the group and hence recognition of additional sensitive taxa not previously recognized. Reports of this or that by some unknown person (or even by you or me) are of little or no use at all for these purposes.”

njensen 07-08-2008 12:10 PM

Comment from Roxanne Bittman, Botanist, CDFG CNDDB,
“A species list is something DFG wants to see in CEQA documents. See 12b. on pg 4 of the attachment, which is unofficial but soon to be released and posted on our website here: The new version will replace the old, 2000 version currently on the website.”

njensen 07-08-2008 12:11 PM

Comment from Carl Wishner, Botanist, Envicom
“I think it's very important to include checklists in CEQA documents. It's one of the best indications of the competence and thoroughness of the investigators. I have recently had to take over several EIR preparation tasks where supposedly all the biological survey work had already been done by others, and I am supposed to write the documents based on their work. In each case, the prior work was beyond inadequate. Moreover, it was obvious the investigators were incorrect in many of their determinations. In one example, a firm that I shall not name had been studying a property for over two years, and had a species list of 43 vascular plant taxa. I examined the site on two consecutive days and found 238 taxa. In another recent example, another reputable firm had been studying a site for more than two years, and had a species list of 68 species. Again, I examined the site on two consecutive days and found 220 taxa. There are many more examples that I could cite. Unfortunately, there's no real objective way to recognize such incompetence and inadequacy, except by careful examination of species lists, and usually some field checking by someone with experience. The same goes for wildlife observations. When I see that observers have seen only a handful of lizards and birds, I realize they didn't get out of their cars when they did their surveys.”

njensen 07-08-2008 12:11 PM

Comment from Jim Greaves, Ornithologist
“I haven't got a problem with having a list of actually found taxa attached. I do however OBJECT to what I see as generalized lists that include many taxa that one has either not actually seen, or one is under some impression "ought to be" at a site. We see these lists ALL the time in government CEQA documents, which list every species ever found in a county, as if they always will, or ought to be on THAT particular site under review. This is misleading at best, and disingenuous at the worst. I've seen too many subsequent agency requirements built on such erroneously fostered expectations, rather than realities of a site and its potentials... Case in point: just because Least Bell's Vireo breeds in riparian habitat in Santa Barbara County, what is the purpose of putting it on a list of "expected taxa" for every piddly little water course anywhere in the county, many with no water in 99% of the year? None that I can see, other than to foist agendas onto neutral process, which often mislead otherwise "well-intentioned" albeit sometimes ignorant agency people (no offense intended to anyone by the use of neutral term "ignorant") into taking that list and requiring "protocol-level surveys" for LBV (or whatever taxa comes to mind), when there is neither historical evidence of, nor sufficient other indication that, the species EVER bred there, or could if it once did. I've seen this extended to include some man-made such places. This is the surest way to destroy the CEQA process I can imagine!”

njensen 07-08-2008 12:11 PM

Comment from Fred Roberts, Botanist
“Definitely I would agree that they are important, even if we would prefer better documentation. These days I am more concerned that we appear to be losing rare species data as well - many documents are just putting dots on maps and a total number of plants found within the project area and not indicating how these numbers are distributed. The worst examples I can think of was the Orange Co. Transportation Corridor tollway and the Rancho Mission Viejo HCP. Well I guess at least we have dots, even if some times they are on really small maps.”

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