CNPS Consulting Botanist Certification
In this post, we’re discussing the CNPS Consulting Botanist Certification, starting with Why. Why do we need certification, and why should someone go to the trouble of getting certified? “A firm might have somebody within the firm with the qualifications to perform a botanical survey, but that wouldn’t be the person who actually went out and wrote the report,” he explains. “Or, they wouldn’t pay a consultant enough to take the time needed for an adequate review.”
To help answer this question, we spoke with Dan Klemann, deputy director of long range planning for the Santa Barbara County Planning and Development Department. Dan has been instrumental in working with two of the most forward-thinking planning departments in the state and shares his perspective on challenges and possible solutions toward effective environmental review in the planning process.
Talent to Task
A consulting botanist is a Swiss Army Knife of expertise. Seasoned consultants combine extensive knowledge in plant science, public policy, survey skills, and even cartography – all of which someone might learn in college, but none of which are combined into a cohesive degree program. Only in the field do consulting botanists develop the combined and applied experience needed to inform sound land-use decision-making.
So when a development proposal crosses the desk of a county agency, how do those employees know whether the accompanying environmental assessment is trustworthy and complete, or whether a truly qualified professional completed it? And, for well-meaning biologists and botanists, how do they get the support they need to conduct the most thorough reviews possible?
The Problem in Real Life
A few years ago, Dan Klemann was working as the manager of residential permits for Ventura County where he and his team reviewed Initial Study Biological Assessments (ISBAs). Like many peers in similar positions, Klemann observed both egregious and benign failures to provide sufficient information in these reports. Applications often showed clear bias toward the applicant’s position on the project. The county was vulnerable to commercial interests who aimed to skirt environmental law and find loopholes:
“A firm might have somebody within the firm with the qualifications to perform a botanical survey, but that wouldn’t be the person who actually went out and wrote the report,” he explains. “Or, they wouldn’t pay a consultant enough to take the time needed for an adequate review.”
At that time, Dan’s team partnered with CNPS Rare Plant Program Manager David Magney (then an established consulting botanist and the lead conservation volunteer for the CNPS Channel Islands Chapter) to develop a standard ISBA template to help ensure county planners had quality information to guide development decisions.
“The biological resource assessments were (and still are) often appalling,” says Magney. “I saw biological consultants failing to identify sensitive resources, not doing adequate baseline surveys, not establishing supported significance thresholds. Just putting blinders on.”
But most consulting biologists and botanists are conservationists at heart, say both Magney and Klemann. They want to do good work.
During his time at Ventura County, Klemann worked with the Planning Division biologists to implement a procedure for preparing a list of “qualified consultants” and companion MOU to help mitigate the problem. We spoke with Klemann about what he learned along the way. Here are some excerpts from the conversation (C is CNPS, D is Dan Klemann):
C: Why did Ventura County create this new process? What criteria did that agency use to determine who is qualified?
D: When you’re on the regulatory side of the process, there’s a big challenge in that there’s always a degree of subjectivity that doesn’t exist in lab science. The challenge is trying to get a product that’s accurate, objective, and not biased in favor of applicants and developers for the project. At Ventura County, each consultant is required to demonstrate that the consultant meets the minimum qualifications to prepare initial study biological assessments (ISBAs) (e.g., a minimum number of years of relevant, local experience analyzing project impacts to biological resources pursuant to CEQA and other relevant environmental regulations, and a commitment that only qualified biologists for a consulting firm will prepare the ISBAs). They must also submit a signed MOU whereby the consultant agrees to adhere to the county’s protocol for preparing ISBAs. They are supposed to submit an updated MOU every two years and when designated, qualified individuals at a consulting company change.
C: How has that been working?
D: Even with the steps we’ve taken, it’s not fool proof. After implementing the procedures, particularly in regard to botanical studies, the consultants weren’t keeping up with CDFW requirements, and we were still having to reject them. We knew there were biologists out there claiming they had the expertise to identify certain species, but they didn’t have that knowledge. These are problems agencies face all over the state. When applicants unknowingly hire unscrupulous or unqualified consultants with a history of preparing inadequate reports, there is a sort of ethos among regulatory agency staff not to notify applicants that this is occurring—mainly due to a concern about how elected officials and others might perceive such actions. We really need a more neutral body to govern who is qualified to submit these reviews.
C: How do you ultimately know what information and what firms you can trust?
D: There are so many different types of specialists when it comes to doing bio-analysis of resources. It’s hard to find experts in botany. Many more people are into wildlife biology, so they’re getting contracts that they’re really not qualified to do. That presents a number of questions: What are we going to accept? Are we only going to contract out ourselves? If we allow applicants to consult, how do we avoid problems?
C: How might botanist certification help?
D: Certification gives us a neutral way to address these problems. It takes the responsibility of determining qualification out of our hands and into those who know much more than we do. We’d know, “Hey this person went through this program and has the certification.” Also, in the event that someone is doing something unscrupulous, we can go to the certification board. Licensing or certification gives us a good mechanism for following up when things go awry.
C: What would you say to consultants reluctant to enter the certification process?
D: Many biologists want to do good work, but they aren’t getting paid to do the work they need. If they were given authorization to do that work, it would support them. I also see really good consultants who get passed over for work, because they give an honest estimate of the time it takes to do meaningful assessments. When other firms say they can do it for half the time but do a poor job, it hurts everyone. This is a way to support people who do great work.