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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.”

njensen 07-08-2008 12:12 PM

Andy Sanders, UCR Herbarium, reply to Carl Wishner
“Carl, Well said! A lot of these "reputable firms" seem to hire inexpensive recent graduates, who have never had a field course in their lives and know essentially nothing about the biota of CA, and send them out to do surveys. The results are as you describe. They sometimes send me jpegs to ID or confirm. What they don't know is often amazing, and what they think they know is worse. If they're struggling to ID Malva parviflora and Ailanthus altissima, they obviously have no clue what they're doing. I recently had those come here as jpegs -- and the Ailanthus was tentatively IDed as Ligustrum lucidum! The half dozen such jpegs were probably the whole bot. survey for this site.”

njensen 07-08-2008 12:12 PM

Comment from Heather Wylie, Project Manager, U.S. Army Corps of Engineers
“I agree. Another problem associated with this, is that the government employees "reviewing" these documents are not qualified to know when the wool is being pulled over their eyes or not (if they even care). Additionally, they are discouraged from soliciting third party opinions.”

njensen 07-08-2008 12:13 PM

Comment from Cher Batchelor, Plant Ecologist, Rincon Consultants
“I too agree that species lists are extremely important for completeness of surveys. So many times I am asked what the condition of a project is (is it highly disturbed or relatively pristine?), and often an efficient way to demonstrate existing conditions is to present the species richness of a site. Further, all plant community descriptions (most of which are written back in the office) are based on plant assemblages of a project site. How are we supposed to adequately convey habitat descriptions if we do not reference a field list of plant species observed onsite, especially for dominant plants and their specific associate species? These conditions are often scrutinized especially when reviewers are trying to determine if sensitive habitat exists for special-status wildlife species. Finally, if surveys do not require a species list, biologists/botanists are more likely to miss special-status plant species on a particular project site simply because they are just not looking closely enough at the plants onsite.”

njensen 07-08-2008 12:13 PM

Comment from Tasha La Doux, Botanist, UC Riverside
“Hi Steve [Boyd] - Thanks for including me in the e-mail. I agree that a species list is important for the reasons pointed out by David in his e-mail. Ideally consultants could establish this with their clients from the beginning, and even include paid herbarium time, as this is often the crippling factor in getting accurate ID and/or vouchers from the area. A species list is like a litmus test for the quality of the botanical surveys (and can be entertaining to read). I can see where the client would not necessarily want to pay for a species list to be the main goal (depending on the area to be surveyed and the reason it is being surveyed), however it is an easy by-product of targeted rare plant surveys. And by requiring a species list to be recorded, it encourages more careful observation and I believe will lead to more discoveries of rare plants unknown to occur there and/or significant range extensions.”

njensen 07-08-2008 12:14 PM

Comment from Mary Carroll, Botanist, Santa Barbara Botanic Garden
“I agree with the other comments you have received to date. Species lists tell us about biological diversity, ecotones, transition zones, and many other subtleties. I do wish that folks with less experience wouldn't just put their perceived list of dominants on a list because they think those plants "should be" present. I have observed plants being listed for a site that I have carefully searched for, something common like Encelia californica or Rhus integrifolia that drop out at certain elevations or inland sites (or don't, in which case it is very interesting!). I try to avoid labeling an entire company or institution as incompetent, though, as our skills are varied within a company and as time passes. I think many of us, however, have found rare taxa - sometimes unexpected rare taxa - that have been overlooked by others, so field work and subsequent reporting, along with appropriate documentation, form a body of knowledge that deepens our understanding of a site.”

njensen 07-08-2008 12:15 PM

Comment from Rosi Dagit, Biologist/Arborist
“I am with you! I find them very helpful as well!”

njensen 07-08-2008 12:16 PM

Comment from Cindy Burrascano, Botanist, CNPS Representative
“In reviewing EIRs I have found species lists invaluable. They tell me something about the quality of the habitats being impacted and/or the skill of the person doing the surveying. In looking over a list included from a prior biological survey attached as an appendix on a document, I once found two listed species identified that had been "overlooked" in the more recent surveys. The project was redesigned. They are well worth the extra paper for a reviewer.”

njensen 07-08-2008 12:17 PM

Comment from Betsey Landis, Botanist, CNPS Representative
“I think species lists are essential to evaluating impacts on natural resources. However, lately all I have seen are lists from the CNDDB, usually for an entire mountain range or an entire county. The City of L.A. particularly abuses and bypasses the CEQA process (the developers pay all administrative expenses of the Planning Agency). I have been reading all the excellent comments. This would be a great article for the Bulletin and I hope someone is going to talk about this topic at the CNPS Conservation Conference "Strategies and Solutions" January 17-19, 2009. The Chapters need to know they can demand better species lists and that field surveys be done under CEQA when natural resources may be impacted by a project.”

njensen 07-08-2008 12:17 PM

Comment from Jennifer Kalt, Botanist, CNPS Representative on Timber Harvest Plans
“David, I feel it is the only method currently at our disposal to assess the qualifications of the surveyor. If someone (e.g. a timber company forester or "botanist") has few to no grass or graminoids, or if they ID every species of Salix and Carex to species, then I judge them either inexperienced or a hack. I would guess that DFG staffers would have a similar view. "Too expensive"??? Sounds like just another cry to get around the environmental review process to me.”

njensen 07-08-2008 12:18 PM

Comment from Diana Hickson, Botanist, CDFG
“I collected all the comments and forwarded them to Tony LaBanca, (before I noticed he was on the list!) who is chairing the impact assessment and mitigation session [for the CNPS Symposium in January 2009]... I hope someone submits an abstract dealing with this issue. A survey of what lead agencies (and my own Department) is requiring would be enlightening.”

njensen 07-08-2008 12:18 PM

Comment from Lynn Houser, Botanist, Milo Baker Chapter (Sonoma Co) CNPS
“Great comments, everyone. I agree that a full species list (more than one visit!) should be made whenever possible. It can help in mitigation monitoring (what was there?) and serves as a record to the public. More funding for herbarium time would assist the biologists who need help identifying the plants, so the spp. list can number in the 200's instead of the 40's as was reported.”

njensen 07-08-2008 12:19 PM

Comment from Margot Griswold, Principal/Senior Restoration Ecologist, EARTHWORKS
“As a plant ecologist specializing in habitat restoration, I rely on a qualified botanist to perform detailed plant surveys of projects if no good survey or species checklist is available. So I whole heartedly agree with Carl [Wishner] that a checklist must be complied by QUALIFIED BOTANISTS, and that this should be essential to any project and especially a CEQA development type project. In reviewing projects for LA CO ERB, I find that good species lists are hard to find ... usually a cut and paste job and not specific to the site. I thought that it was a requirement to have a specific plant checklist. Another important issue is the qualification of the botanist compiling the checklist. In my long ago job as a project manager for a consulting firm that shall remain nameless, I learned the hard way why it is essential to have a qualified botanist perform plant surveys. I will never forget receiving a castigating review of the plant list for a project that was compiled by the consulting firm's "botanist". I was presented with SEATAC's review, and the fact that many species on the list were outside of their range .... Needless to say, I don't work without consulting a botanist that is qualified for specific areas. I think that there are very few truly qualified botanists as demonstrated by the number of species Carl comes up with versus an inexperienced biologist's list. This leads to the idea of some type of certification process that I believe might be in the works now.

njensen 07-08-2008 12:19 PM

Comment from Allison Shilling, CNPS Representative
“As a non-botanist who nevertheless uses the results of botanical surveys, I think that a species list can be invaluable. A few years ago, Andy Sanders of UC Riverside was employed, in September of a dry year, to survey an area proposed for an OHV park. He listed many species with a notation to the effect "suitable habitat, not observed at this time", and it enabled me to argue that a supplementary survey was needed, and I got it in the budget.”

njensen 07-08-2008 12:20 PM

Comment from Jim Greaves, Ornithologist
“In fairness, it might be pointed out to the email listees that all of my surveys have been done in NON-NCCP areas, so I wonder how relevant your comments are to my point, since those areas require different criteria, my point being that agencies rely on non-ornithologists to determine whether or not something is "suitable LBV habitat", and that reliance is based on a simple-minded botanical species list, which is often as useless as a simple-minded bird species list. Remember, the purpose of the list is for current project, not some nebulous future plan that may or may come forward, at which time a rare plant or bird discovered decades earlier, may or may not be relevant. A willow does not LBV habitat make - yet agencies are asked daily to determine whether or not costly surveys are necessary based on a botanical survey, with no other data or information being provided by botanists as to whether or not their "professional" NON-ornithological assessments is even nearly correct. I KNOW this because I have just completed two site assessments (1 in Santa Barbara and 1 in Santa Cruz) whose project proponents were told by government agents, based on plant lists, and the presence of "willows" at both sites, and who'd never even seen the sites (to my knowledge), based on plant species lists, that LBV protocol-level surveys were needed [that's 7 unnecessary surveys, spread over an additional 60 days from the first site visit by the ornithologist -- potentially delaying and/or costing a project proponent unnecessary expenses]. At neither site did I think it necessary -- even before I visited the sites -- and my site visits confirmed it - -at least in my mind -- that protocol-level surveys were warranted (habitat was wrong, too small, isolated or distant from known areas (including historical from Grinnell and Miller) -- based on my 30 years of experience and KNOWLEDGE of whether or not LBV would even be in the two locations, regardless of the sites being "within the range" (the point of my sarcasm about the 8000 feet -- as anyone with any knowledge of LBV knows, they do not breed at that elevation, nor likely in pine forests even at their "preferred" elevations).”

njensen 07-08-2008 12:21 PM

Comment from Fred Roberts, Botanist
“While Jim may make a valid point in a limited number of cases, species lists are not used universally to determine whether there is appropriate endangered species habitat on a site. More often this would (and should) come from the assessment of vegetation communities. Every list or assessment method runs a small risk of being abused or misunderstood by a third party. Just as if you want to be critical there are mistakes in the CNDDB. However these are often limited and in now way diminishes the overall value of the CNDDB. In that same way, species list are critical to better understanding a site. Once and a while some one will overestimate the value of something on the list, real or not. The solution to this though is better training of the agency personal and those that review these lists, not eliminating the lists themselves.”

njensen 07-08-2008 12:21 PM

Comment from Sula Vanderplank, Botanist, Rancho Santa Ana Botanic Garden
“Steve [Boyd] forwarded this message, and I just wanted to echo that to me this is an issue of standards, and standards need to be higher. I think many consultants are trained just to look for the 3 rare species suspected in a given area and may miss a lot by not taking a floristic approach. Also, the value of a site, as you both mention, is often more dictated by species composition and richness and the presence/absence of invasive weeds, than by the presence/absence of a handful of rare species. Certainly higher standards in floristic surveys should be enforced, and a serious pressure should be arising within our community to carry out such surveys with due diligence, making herbarium specimens and documenting floristic diversity for future generations.”

njensen 07-08-2008 12:22 PM

Comment from Rob Preston, Botanist, Jones & Stokes Associates
“I agree entirely with you on the reasons that it is very important to have a species checklist as part of the CEQA documentation. My specific comments:
1) A general species checklist is worthless. This type of checklist is what was done 30 years ago, based on what someone would expect to occur on a site, not what was actually observed. What is needed are specific checklists based on current site surveys.
2) A species checklist is useful, but the complete site survey report should be part of the public record. To suggest that access to the survey reports is “not needed” would be disingenuous. I’ve seen EIRs in which the information from the original survey report was distorted, misrepresented, or misinterpreted by a non-botanist who did the write-up; you need to see the original report to assess the veracity of the EIR section.
3) Publication and distribution costs can be a legitimate reason for not publishing all of the technical reports in appendices. However, these technical reports are still part of the public record and must be made readily available. I agree that the practice of making documents available only as hard copies in a few locations is inexcusable. If not published as appendices, technical reports should still be readily available via the web.”
“The only reason for not including a survey/checklist in a CEQA document (either as an appendix or as part of a web-accessible public record) is to conceal information, either about the project or about the survey methods.”

njensen 07-08-2008 12:23 PM

Comment from Deborah Hillyard, CDFG Staff Environmental Scientist
“I am compelled to chime in here on two counts, one we need to remember why we do surveys at all, and the other is that professional biologists should be exercising their professional judgment when asked to do professional work. CEQA is a disclosure document, and the point is to identify potential impacts of a project, and then mitigate those impacts, or make findings as to why that was not feasible. In addition, the ESA and CESA regulate "take" of listed species, and surveys for those species have even more importance, since unauthorized take of listed species would be a violation of the state and/or federal acts. Identification of listed species on a project site (or their confirmed absence) is important responsibility of the consulting biologist to keep their clients from engaging in a violation via unauthorized incidental take of a listed species, and to keep the approving agency (City or County) from being an unwitting, but equally responsible, accomplice to an illegal act. The standard for doing rare plant surveys has included the requirement for doing a floristic survey and submitting a complete species list, and that standard has been in place since 1983, when DFG and CNPS first put together the Guidelines (which Roxanne so kindly distributed the newest soon-to-be-adopted version to everyone on the list). That would be for the last twenty five (25) years, the STANDARD for doing rare plant surveys includes doing a complete floristic survey... so Counties/Cities that accept something less are way behind the times. In addition, it requires that the surveys be done by knowledgeable individuals, at the appropriate time of year, and that associate disinformation be collected and reported. The guidelines disallows focused plant survey work (looking only for one or two T&E species); as well as "predictive" surveys since they do not identify what is on site, nor do they identify what is not on site, only what could be on site. Additionally, many, many occurrences of rare species have been discovered during floristic surveys...and some of those occurrences have been for species which were not known from any "potentially occurring" list that was based on an NDDB print-out...things like Plagiobothrys diffusus or Trifolium depauperatum hydrophyllum, both taxa thought to be extinct until sharp-eyed botanists identified them on site during floristic surveys. A professional botanist knows when it is too early, too late, or just too dry that year to detect plants which may occur on site, and should schedule multiple visits, or a recommendation to revisit the site the following season; all of that information should be in their report as well. This applies similarly to LBV, where there is a certain amount of professional judgment which has to be exercised. The very first part of the LBV protocol, which you can view at, states that if unusual circumstances occur, the surveyor may request a reduced survey effort, with the example of "small, marginal, or extra-limital habitat" as possibly warranting a reduced effort. That path is always available to the surveyor, and should be exercised when an experienced professional surveyor believes that it is justified. The guidelines also indicate that if the experience surveyor believes that additional, more rigorous protocol with an extended season or additional visits is warranted, then they should be conducted. The purpose of rare plant surveys, as well as protocol surveys for animal species, is as important for what is NOT there, as it is for what is there. For the LBV surveys which provided the animal example, the Service and DFG rely on protocol level surveys to make the call of "not present", which then leads to the determination that no take would occur, and no permits required (and no mandatory finding of significance and no preparation of an EIR). Imagine what a bummer it is for the applicant to have a consultant say that their professional recommendation is to dispense with "7 unnecessary surveys" (or a complete botanical survey) and then have a listed species identified on site, delaying the project while permits are negotiated, and the environmental document re-written to address impacts to listed species. Again, I think that we need to remember why we do these surveys...for disclosure under CEQA, and to guide compliance with other state and federal laws...and follow recommendations of the public trust agencies, and organizations like CNPS, as to what constitutes a reasonable effort to identify sensitive resources on the project site.”

njensen 07-08-2008 12:23 PM

Comment from Tony LaBanca, CDFG Environmental Scientist
“Thanks to Dave for asking the question. I can concur with many of the comments regarding the essential nature of species lists for disclosure under CEQA, as well as while analyzing projects and impacts. It is an important piece of the analysis puzzle, to be used in coordination with other pieces, to get a more complete picture of what is and is not present, make a accurate assessment, and take appropriate action. Also, thanks to Diana [Hickson] for suggesting mining the group for potential presenters for the 2009 CNPS Conservation Conference. Other writers have suggested, and I agree, the topic could use more in-depth coverage. This specific topic, along with many other aspects of botany resource assessment, impact and conservation needs improved outreach to expose agencies, project proponents, and citizens to the importance on conserving native plants and native plant communities. Please consider submitting an abstract for a presentation at the 2009 CNPS Conference helping us to share your work assessing impacts and conserving native plants and native plant communities. The session I am hoping to assemble will:
• Provide an overview of policy and methods related to assess impacts to sensitive plants and communities.
• Identify specific biological parameters to be considered when developing mitigations
• Provide examples of successful and unsuccessful mitigation approaches
• Develop a better understanding of the role effectiveness monitoring and monitoring methods
• Share and discuss ideas and present case studies on impact assessment and mitigation.”
“The deadline for submission of abstracts has been extended to July 25, 2008. You can find instructions for submitting abstracts at: Please contact me if you have any ideas or questions.”

njensen 07-08-2008 12:24 PM

Comment from Jim Greaves, Ornithologist
“When I used the example of "7 unnecessary surveys" I was referring to sites with "a few willows" and/or EVEN "perennial water" along a deeply cut ravine next to houses on one side and less than 100 feet away a major highway on the other in Santa Cruz County, over-canopied by Eucalyptus and other "montane" trees, underlain with the usual "northern California understory vegetations", hardly a situation that an "experienced" LBV surveyor would, or might, or rationally COULD, even SUSPECT LBV to be present, regardless of how many surveys some CEQA requirement, or disclosure, "might" reveal [to Deborah's point about nebulous expectations]. I was NOT attempting to even remotely suggest circumventing the "intent" of CEQA, which is usually clear, and was clear, for instance, in the cases of "coastally-dependent" projects that "should" only allow for fishing or other maritime industry construction, but are often perverted to provide "low cost" or other houses for rich yuppies or major CEOs, obvious "exceptions" that are not "coastally-dependent". Yet the process gets perverted -- even, as I recall, by Governor [Moonbeam] Jerry Brown's own environmentally-aware and liberal appointees to the Coastal Commission [former LA Mayor Brown, for example], who, one would have THOUGHT, might keep the requirement of "coastally-dependent" in mind while approving unparalleled filling of coastal wetlands and creeks for houses and other "tax-producing" projects throughout the southern coast of California -- the supposed anathema of every "liberal" politician of every stripe when running for election in environmentally/politically-correct-controlled California.... However, I agree and have no problem with, it being up to the intelligent, professional opinion of the professional hired to make SOME kind of judgment call as to whether or not "full protocol" for (for example) Least Bell's Vireo should be made [in my example, Santa Cruz County], where none have been recorded as having bred in at least a hundred years of surveying, nor might even be likely to breed due to the constraints of a site -- including before Cowbirds and the DDT blitzes of the 1940's and 1950's, the latter of which I contend has more to do with having depressed birds and some other wildlife than any single or conglomeration of projects or biological parameters in the history of California [aside from cattle in the interior, or the cutting of redwoods for decks and hot-tubs used by liberal environmentalists attempting to "get back to nature"]. Just my 2 cents' worth.”

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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