[njensen]

“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).”