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HABITAT MANAGEMENT PROGRAM DRAFT PROPOSED UPDATES

Review Request

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

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

Viable Species Composition Working Group staff will host a HMP Proposal Workshop with Grant Applicants. This workshop will allow Grant Applicants to review and discuss the draft HMP proposed updates. Grant Applicants wishing to submit comments on the draft HMP proposals may do so in two ways:

  1. You may submit written comments and feedback, via this site, by October 7, 
  2. You may submit verbal comments during the HMP Proposal Workshop with Viable Species Composition Working Group staff, scheduled for Sept 28, 2022.

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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R Jan 4 2023 at 6:07PM on page 1

Comment test

Briana Halstead Oct 6 2022 at 6:54PM on page 9

Suggestion
This is an excellent addition/update. I caution that it might lead to complications on your end when it comes time to receiving these plans from the grantees, but you have lined out the requirements quite clearly here and even stated that the "Applicant specifically identifies the page numbers of the plan that contains the listed information"

One suggestion I would offer is that you might include a visual example of how the applicant might submit and alternative plan with page identifiers to the corresponding required information.

Otherwise this update offers the flexibility that many applicants might find very appealing.

Briana Halstead Oct 6 2022 at 6:47PM on page 8

Concern
This change does not make much sense. Any areas that have USFS or BLM sensitive species would require these species to be tracked/monitored for federal purposes regardless, so there is no time-saving in effect if this change were implemented.

Additionally, if there are 3rd party applicants applying for grants on federal lands that are not the BLM or USFS it might give them the impression this data was not required, when, in fact is still is.

Briana Halstead Oct 6 2022 at 6:42PM on page 7

Agreement
I see no real problem with this change. I believe that the buffer requirement size is needed to be addressed. 1-mile might be a bit large as some have suggested, but not entirely unreasonable.

HMP part 1, Item 1 and part 2, section II, Table 2 are both desktop exercises which should not require field work. These are based on suitable habitat, so no species should be included in these tables/sections if suitable habitat is not present. These tables are used to determine which species will actually be carried forward for monitoring based on data and first hand knowledge of what is present on the ground. If no suitable habitat is present within the buffer- no monitoring should be needed.

Briana Halstead Oct 6 2022 at 6:19PM on page 6

Concern
To me, this wording is clunky and unclear - especially to the possibly "lay" reader. Reading this, it is not entirely obvious that the definition of Viable Species Composition for the purposes of an OHV grant HMP is being amended to be special status species and habitats.

I also don't necessarily see the need to include the points about degradation due to "implementation of grant-funded activities or OHV recreation directly facilitated by grant-funded activities" within the amended definition of Viable Species Composition. This would be more appropriate for an amendment of the HMP definition or description.

Briana Halstead Oct 6 2022 at 6:01PM on page 5

Concern
For projects where the project area is an entire field office or ranger district (i.e. an area-wide restoration grant) and where site-specific project locations may not be known at the time of the application, the species can be shown spatially within the project area perimeter, but not necessarily their spatial relationship to all project activities because they may not be known yet.

Martin Oliver Sep 30 2022 at 9:54PM on page 10

Suggestion
Due to the timing that grant funding is received in our fiscal year, and the difficulties we have hiring staff due housing cost, location, etc., it may be difficult for us to meet some of the HMP requirements. Can the OHV Program (CDPR,OHMVR) hire biological consultants to do the some of the HMP work (monitoring/reporting), this could also improve consistency across the state on how the HMP is implemented.

Martin Oliver Sep 28 2022 at 7:59PM on page 10

Suggestion
Agree with need to update template. Some of the tables seems to have repeating information. Is it possible to have only 1 table formatted in an excel document? some fields would only be required based on previous response?
If nothing else try to set tables up so column headers repeat at the top of each page. I often found myself lost in document.

Martin Oliver Sep 28 2022 at 7:49PM on page 8

Suggestion
At least for plants from a BLM perspective, this will not change the workload. BLM sensitive plants/special status are captured under Federally listed species and CRPR 1 plants. Focusing only on those species (T&E and CRPR 1plants) would allow for staff to better focus on the species "most vulnerable to impacts".

Martin Oliver Sep 28 2022 at 7:08PM on page 5

Concern
For projects where an entire field office or ranger district is the project area, but the grant funded activities are only occurring on existing routes over a small portion of the area, the need to include all special status species within a field office boundary is too broad. However if we change our projects to more limited geographic areas, this may lead to areas being neglected from needed maintenance or restoration work.

Martin Oliver Sep 28 2022 at 7:01PM on page 6

Concern
How are defining OHV activities "directly" facilitated by grant funded activities? I am concerned that to be consistent with the HMP we are going to have monitor and report to the standards of the HMP (which may be beyond what we are already doing) in areas where OHV funded work is not occurring.

Brett Holman Sep 28 2022 at 5:13PM on page 9

Suggestion
Give example of successful alternative plans from existing management plans from previous grant cycles?

Brett Holman Sep 28 2022 at 5:10PM on page 10

Suggestion
Update the template, Copy/Paste functions, provide examples of HMP's and include HMP workshop with or before annual OHV workshop.

Brett Holman Sep 28 2022 at 5:07PM on page 7

Concern
Worried that this requirement will cause us to lose the field office wide project area and have to focus on small project areas that limit flexibility and the ability to adapt during the grant cycle.

Ann Roberts Sep 22 2022 at 5:19PM on page 7

A one mile buffer is too broad; it should be 1/4 mile. That is the size buffer commonly used for species such as fisher and spotted owl, and would cover most species with potential to occur in the area of affect.

Garrett Villanueva Sep 9 2022 at 2:04PM on page 7

Concern
Adding a 1 mile buffer to project areas would create arbitrary requirements to survey in areas that are not suitable habitat for special status species. Botanical and biologic specialists are most knowledgeable regarding special status species in the areas they work within, this CA wide approach would require survey and analysis in areas where special status species would not necessarily occur thus diverting professionals from focusing on areas of greatest importance.

Bruce Whitcher Sep 4 2022 at 12:12AM on page 5

This approchto commenting works pretty well, but some of my comments aren't aligned with the right quesiton. It was difficult to move the comments once I entered them. You can probably identify the corresponding question by the response, but if not let me know.

Bruce Whitcher Sep 4 2022 at 12:09AM on page 8

Agreement
I've observed that there is some duplication between monitoring in the HMP and the SCP. This may or may not add anything to the reports, but this needs to be reviewed on a case bu case basis. I am not directly involved in preparation of the HMP because we submit the Los Padres HMP as supporting documentation. We are fortunate to be able to do this because there is no way we could prepare the HMP ourselves. The minimum criteria listed here seem reasonable, and align well with the goals and objectives of the current HMP. I would submit that they do not lower the standards for the program, and maybe they would lead to higher quality monitoring because they are better defined than some of the current HMP documents, that seem obscure at times.

Bruce Whitcher Sep 3 2022 at 11:59PM on page 8

Concern
Although this proposed change might be well intended, the USFS must complete NEPA documents for OHV trail maintenance. These usually address mitigation and avoidance measures for USFS MIS and USFS FSS, so these species need to be monitoried to some extent for NEPA Compliance in most cases. Although I am not directly involved in preparation of the HMP, I think this information is routinely collected along with information about T&E species, so not requiring this info would help some, but not that much. The Forest biologists would be better able to comment on this issue.

Bruce Whitcher Sep 3 2022 at 11:48PM on page 7

Concern
The Los Padres HMP is accompanied by maps that show the locations of sensitive species and sensitive habitat. In cases where the potential habitat is a large area, it is shown by a circle of appropriate diamater to include not only the project area, but also potential habitat. In other cases the narrative in the HMP describes locations of species occurrences and their proximity to the project area, which is usually a trail that is to be maintained. Adding a requirement to evalute species within a 1 mile buffer could unecessarily expand the area that must be surveyed, making the HMP more burdensome to prepare. As the HMP is currently employed, the surveyors may use discretion based on their expert knowledge of the area, and include a larger or smaller area as they feel is approriate to meet the goal of maintaing a viable species composition. In addition the Los Padre HMP is a mature document with includes survey informtion from several previous years for comparison. This should be sufficient information ro document the effects of OHV trails on sensitive species and habitat without unnecessarily expanding the scope of work.

Bruce Whitcher Sep 3 2022 at 11:35PM on page 7

Agreement
the HMP part 2, Section IV, Table 3, Column 3 of the includes a heading that states: "Management Objective(s)
(Related to Concerns/Risks/Uncertainties)". This column in thiss particular HMP does not include much information about risk factors for mos species, but does indicate" Avoid all direct physical impacts to individuals, and reduce indirect effects to habitat such as soil compaction, erosion, altered hydrology and disturbance that may facilitate non-native species." all of which are known risk factors. I believe the professional surveyors were aware of what might constitute risk factors. I don't believe adopting a formal definition would hurt, but I doubt it would add any information in the case of he Los Padres HMP.

Bruce Whitcher Sep 3 2022 at 11:23PM on page 6

Suggestion
Table 3 of the Los Padres HMP includes one column for Management Objectives, one of which is to "Maintain viable populations where species presently occur adjacent to OHV trails." In addition there is a column for "success critera". One entry states: "Viable populations adjacent to trails are maintained and OHV activity does not expand into habitat areas." This indiates that the HMP surveyor is aware of the need to maintain a viable species composition in the project area. You can amend the definition, but it seems that in this HMP there is a high level of awareness of the neeed to maintain a viable species composition for special status species and sensitive habitats, so an amendment may not be needed. This might represent a lack of awareness of some of the content that should be included in the HMP to assure regulatory compliance.
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