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HABITAT MANAGEMENT PROGRAM DRAFT PROPOSED UPDATES FEBRUARY 2023

Review Request

At this stage in the Viable Species Composition Working Group process, we are requesting public review of the Viable Species Composition Working Group’s draft proposed updates. We hope to focus your review on the following questions for discussion:

  1. What suggestions would you make to improve the HMP development and HMP compliance process?
  2. What are your concerns regarding the draft proposed updates to the HMP?
  3. Do you have recommendations on how the HMPs may better apply best available science in a way that is feasible for all Grant Applicants?
  4. Are there any other comments or topics that were not captured in the questions above that you would like to address?

The Draft HMP Proposals for review in this document have already undergone review and comment from Grant Applicants. The Draft HMP Proposals for review have been revised in consideration of Grant Applicant comments and suggestions. 

You may submit written comments and feedback, via this site, by March 17, 2023.

Contacts: 

California State Parks: Michelle Forsha Michelle.Forsha@parks.ca.gov

Technical assistance with this comment form: Ryan Mottau ryanm@migcom.com
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Bruce Whitcher Apr 4 2023 at 8:11PM on page 9

Concern
USFS MIS are included in most Forest BA/BE's (NEPA) related to OHV roads and trails. Removing the MIS from the HMP would be minimally helpful.

With respect to California Rare Plant Ranks 3 and 4, they are supposed to be considered in CEQA documents, so this might be a concern. One of the main difficulties with the HMP is keeping the Plan up to date with the ever increasing numbers of new species reported to the CNDDB. This places an enormous demand on limited staff, especially because of the amount of field work needed for monitoring. Fortunately once fully developed the HMP can be updated for significant changes, which is less onerous than having to prepare a new or extensively revised HMP.

Bruce Whitcher Apr 4 2023 at 7:21PM on page 8

Question
Would "risk factors" , which are defined as potential project effects, also need to be evaluated if they are related to OHV recreation?

Presumably the results of monitoring and Mitigation/avoidance meaures would be included in the appropriate section of the HMP.

Bruce Whitcher Apr 4 2023 at 7:08PM on page 7

Agreement
The current definition of "viable species composition" seems problematic because there are many factors that affect reproduction of a species far more than OHV recreation or related projects, including the presence of competing species, genetic variation, the health of individuals within the population, and more recently the effects of climate change. Additional concerns are pointed out in " The Issue" section.

A revised definition of "viable species composition" such as the one being proposed is a needed improvement. This is more in keeping with the current approach to resource management which is to minimize impacts, but not eliminate them altogether which is usually impractical.

Joanne Heraty Mar 17 2023 at 7:09PM on page 8

Suggestion
It may be important to include State Rare as a category here for those plant species that are state listed rare by the Fish and Game Commission and fully protected under the Native Plant Protection Act. I recognize those species are technically encapsulated in the "California Rare Plant Rank 1A-4" category below but state listed rare plants under NPPA are offered a more formal protection status than the California Rare Plant Rank.
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