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Old 07-08-2008, 12:28 PM
njensen njensen is offline
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Default 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.
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