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

njensen 07-08-2008 12:24 PM

Comment from Rick Burgess, Planner/Botanist, City of Thousand Oaks
“I think that species checklists are an essential part of any CEQA document involving development in natural habitat. A good species checklist indicates that an adequate biotic survey was undertaken and provides valuable information on potential impacts to biodiversity, rare and endangered species or locally rare species. It is also a strong reflection of the biological credentials of the consulting firm conducting the survey. One tends to doubt the credibility of the entire environmental document when the species checklist is poorly done. Unfortunately, too many of these checklists are, at best, rudimentary and, at worst, contain gross errors, often including plants which are clearly out of range. In many cases, these lists are compiled using range maps from field guides or a CNDDB run and reflect no familiarity with the site. There seems to be a dearth of qualified botanists out there at present. At the City of Thousand Oaks, we bounce reports until they are properly done or, in some cases, go out there and do our own checklist. So, to reiterate, species checklists are very important.”

njensen 07-08-2008 12:25 PM

Comment from Elihu Gevirtz, Senior Associate Biologist, LFR, Inc.
“It's likely to be a good discussion at the conference, but unlikely to be controversial among those at the table. The focus will need to be on preparing a paper that provides the reasoning that supports DFG's revision to the survey guidelines currently in draft form. The major work effort will be and should be in outreach to the many public agencies that produce CEQA documents. Some effort should be put into thinking out how that will occur beyond what CNPS already does so that the conversation leads to positive results.”

njensen 07-08-2008 12:25 PM

Comment from Roxanne Bittman, Botanist, CNDDB
“I have to agree with Elihu. The Guidelines (or Protocols, as they will soon be known) are really not an option. They are supposed to be a requirement. Figuring out the best ways to reach public agencies to educate them is definitely the challenge. I and colleagues can do some personal outreach (which we do), but it isn't enough. Creative ideas at the conference would be very helpful.”

njensen 07-08-2008 12:26 PM

Comment from Elihu Gevirtz, Senior Associate Biologist, LFR, Inc.
“Thanks Roxanne. Perhaps there is someone out there who could reach out to groups of agencies (such as the one for California Counties) and there are probably others for cities, sanitary and water districts, community services districts, schools, prisons, etc. That person could personally invite a representative of those groups to attend a round table discussion at the CNPS conference to see how mutual respectful cooperation working to achieve plant protection could be fostered.”

njensen 07-08-2008 12:28 PM

Comment from Scott White, Botanist
I apologize for replying late. I don't have time to say much about the
question but I agree w/ David and Steve. I only want to add that, (1)
Both CDFG and US FWS have rare plant survey guidelines and both
emphasize that surveys should be "floristic in nature," should attempt
to find and identify as many plants as possible on a project site, and
should include a complete species list. A purported "rare plant survey"
report not including a species list is not in compliance with the most
basic survey guidelines. A CEQA document circulated for public & agency
review should certainly include the entire rare plant survey report(s)
as an appendix. Without it, then review agencies and the public are
deprived of the opportunity to review an important element of the
project. Since CEQA documents are often posted online now, and paper
copies of EIRs can just attach the appendices on a disc in .pdf format,
there's just no reason to exclude them.
(2) Species lists need not be as long as they often are. Each taxon need
take up only 1 line on a page, in about 9 or 10 point typeface (even
less if the page is formatted in 2 columns), there is no need for blank
space between families or blank pages preceding the list. In my reports,
a longish species list runs about 7 pages, but I put more info in them
than a simple list would necessitate. Sample attached for entertainment.
(3) Rare plant survey contracts already include funds to make
collections for identification. The breakdown occurs when the specimens
are thrown out after identifying them. As a result, there's never any
way to verify the IDs. Contracts can and should include additional funds
to press and label the specimens and transfer them to an herbarium.
Compared with the other costs of the field surveys, these costs are
almost negligible.

DeanWmTaylor 11-18-2008 03:12 PM

I am going to come at the question from a different angle: concern over the adequacy of field survey for RTE plants is warranted, but needs qualification. A species list alone is not a very sharp instrument.

Theory [and a modest literature] dictates that no single person can locate ALL of the species in a given area; exactly which plants escape the attention of a given investigator has not been subject to direct investigation [save for one paper I have found, from Finland]. We all know that repeated visits to a given area will invariably document additional species, and that for the most part the species/effort curve for ordinary field work follows a diminishing-returns curve form.

If in fact we want to produce surveys with the highest probability of detection of rare plants, we ought to either resurrect and clone Jepson, or more realistically, opt for requirements other than professional certification [if certification is even possible under the California code]

That said, I pose an alternative: ‘single blind’ surveys. For major CEQA projects [dams, bullet trains, new towns etc.] botanical field surveys should be conducted by two DIFFERENT , independent botanists or teams of botanists whom do not share contact during the survey. The adequacy of the survey would be based on the comparison of the two result sets: a good comparison would indicate that the CEQA assessment might be robust. Differences between investigators could point the way to uncertainties of the assessment. Blind trials originated for expressly this bias. The observer effect alone [when awareness of being observed affects performance] would in my view be a very effective adjunct to aid effective botanical assessments for CEQA projects.

Chuck Hughes 01-09-2009 06:03 PM

Great thread. It seems like everyone agrees site-specific species lists should be included, for a number of reasons. I agree too. The main problem with this is that it takes another botanist to identify what is a good species list. This precludes the species list from being useful to the overwhelming majority of public reviewers and public agency people. In most cases another botanist never reviews the work.

The underlying problem here seems to be that there is no widely enforced standard for who does the surveys. The DFG/CNPS guidelines specify that the surveyors possess experience, knowledge, familiarity, etc, but those are fuzzy terms. How much experience is enough? For most of the local jurisdictions I work in, even if they were aware of the guidelines (they're not), I doubt they would pay much attention to the qualifications section.

Most other disciplines that prepare technical documents to support CEQA review have some framework for determining who is qualified to do the work. CNPS should certify professional botanists.

StephenRae 01-27-2009 11:00 PM

Need for Checklists
Checklists of plants observed and identified are important in determining whether 1) the site supports taxa of interest, 2) the site supports a representative flora for the association or alliance identified and 3) the observer seems to have the capability of conducting an appropriate survey. There is little value in listing plants that should occur unless they are sensitive taxa which are known from similar habitats within the review area. After all, the purpose of the botanical survey is to convey both what is there and what of consequence could have been there but was not encountered.

However, too many reports list a genus with sp. after. This suggests that the material is too difficult or incomplete for determination although the author stops short for taxa within which there are no sensitive target species. But, there is a feeling during review that perhaps the genus id may be faulty as well. There are just too many sensitive taxa around to stop at sp.?. I suppose I am suggesting that reports should be more thorough.

c michael hogan 04-06-2011 07:01 PM

Agree with Stephen that there are too many reports which do not specify the exact species. While the genus level may occasionally be appropriate, it is overused and clouds the matter of what taxa are really present.

dlmagney 12-01-2017 03:45 PM

A Decade Later - CEQA still around
Wow, it has been a full 10 years since I started this post! How time flies.
The consensus is that, yes, lists of plants observed at a project site is extremely important to include in a CEQA review document.

Now, here is another important question about CEQA that most people don't seem to know, including many consulting botanists.

Who enforces compliance with CEQA?
This question stumps many people. The question might be better phrased as, who has the responsibility to initiate enforcement of CEQA?

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