David,
You ask, "Is Allium praecox a common species? Should it be given a rarity status warranting protection in those counties where it is rare? Should such species be looked at/assessed under CEQA only from a statewide perspective?", and provide some important information about existing distribution knowledge of the species.
The questions --and their answers--would reach far beyond Allium p., I suggest.
A "common" species ? In what contexts ? By whose criteria ? For what purposes ?
Yes, you provide a scenario in which "common" may be circumscribed (i.e., the local developers' challenge to the County status and protection under CEQA). But, is "common" defined legally ? Is that definition adequate to the presumed goals to which any such legal definition of "common" is to apply ?
"...given a rarity status warranting protection (locally)..." ? Is this a legal question, or an ecological question, or an ethical question ?
Each of those qualified questions, and others that could be raised as well, entails quite different considerations and perhaps profoundly different answers.
Yes, the context you provide for asking the question seems to suggest a "simple" concern over how to make Allium p. CEQA-protected, i.e., a legal tactic. But, again, there _is_ the larger question we environmental activists wish to address, which is "should we be concerned about protecting plant species / populations which may not clearly fit into the existing legal framework of protection?" E.g., is Allium p. "rare" in that sense? Should specific populations be "protected" from local extirpation ? Are our existing laws adequate ?
"...CEQA ... only from a statewide perspective?" What does CEQA say ? Is this a (legal) question about how the existing CEQA is to be interpreted, or a(n ecological or population biology) question about how CEQA should be revised (in law) in order to address some perceived inadequacy(s), especially concerning situations such as the Allium p. case ?
I'm not trying to be rhetorical, nor to divert attention from your fair and practical questions about the Allium p. case. I'm suggesting the answers may be more far reaching and important than "just" for Allium p.
Peter
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