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the recovery goal of downlisting to threatened will certainly not be met, and the
species as a whole is likely to be jeopardized.
Public review and comment is premature since a formal consultation has yet to
be initiated. The public should be given the opportunity to review the Biological
Opinion issued as a result of the formal consultation. CNPS respectfully
requested that the DEIS be revised and released from public review and
comment after the formal consultation process is complete and the Biological
Opinion made public.
Non-Listed Species and Sensitive Plant Communities
Direct, indirect, and cumulative impacts to rare, threatened, and endangered
plant species are not adequately addressed by the DEIS.
Direct impacts to botanical resources cannot be evaluated at this time due to lack
of substantial information. Botanical surveys must be conducted according to
state and federal standards (CDFG 2000; U.S. FWS 1996) and the results
submitted for review before impacts to sensitive species can be evaluated. The
DEIS fails to include basic requirements of appropriate botanical surveys,
including a scoping list of sensitive plants known to occur in the vicinity, complete
list of species present, qualifications of surveyors, survey routes, and number of
field-person hours. Without such information, CNPS cannot assess whether
botanical surveys were conducted in accordance with standards set forth by the
Department of Fish & Game (CDFG 2000) and the U.S. Fish & Wildlife Service
(U.S. FWS 1996).
The Crescent City Marsh and environs are home to more than 230 plant species,
at least a dozen of which are considered rare, threatened, or endangered by
state and federal laws (CNPS 2001; CDFG 2002). Rare, threatened, or
endangered plants of the wetland (fen) habitats include the following species, all
of which qualify for consideration under 14 Cal. Code Reg. 15380:
Western lily (Lilium occidentale)
Arctic starflower (Trientalis arctica)
Great burnet (Sanguisorba officinalis)
Green sedge (Carex viridula var. viridula)
Lyngbye's sedge (Carex lyngbyei)
Marsh pea (Lathyrus palustrus)
Marsh violet (Viola palustris)
Vanilla grass (Hierochloe odorata)
Several rare plant communities occur in the Marsh, at least one of which is found
nowhere else in California. Known as buckbean marsh, this plant community is