July 26, 2011
DRECP Covered Species Work Group
Attn: Kristy Chew
Cc: Scott Flint, Kim Delfino, Rick Miller
Re: Draft Agency / Consultant Team recommended "Remove from List" plant taxa
On June 23, 2011, CNPS submitted a list of native desert plant taxa that we feel should
be reviewed for inclusion as DRECP Covered or Planning Species, along with an
extensive data folder containing literature search results (including .pdf's of research
articles) for several taxa on our list. I submitted this information via the DRECP
Consultant's ftp service. I am resending our list as an attachment to this letter, for your
records. I can make the full literature search results available upon request (the full file is
about 2 GB).
The Agency / Consultant Team has recommended that two plant taxa included in our list
be removed from further DRECP consideration; San Fernando Valley spineflower
(Chorizanthe parryi var. fernandina), and Parish's popcorn flower (Plagiobothrys
parishii).
San Fernando spineflower
The population of San Fernando Valley spineflower along the western edge of the
DRECP boundary (near Lake Hughes) is an historic occurrence with low geographic
location resolution, and does not represent a priority taxa relative to other plant taxa that
occur in areas of potential development within the plan boundary.
Parish's popcorn flower
Populations of Parish's popcorn flower occur in the northernmost DRECP area of Owens
Valley in, Inyo County on Los Angeles Department of Water and Power (LADWP)
lands, and in the Rabbit Springs area of Lucerne Valley. There are additional populations
of Parish's popcorn flower in northern Owens Valley but outside of the DRECP area.
CNPS disagrees with the recommendation to remove Parish's popcorn flower from
further DRECP consideration for the following reasons:
1. LADWP has demonstrated an interest in developing renewable energy projects in
Owens Valley. Parish's popcorn flower occurs on LADWP lands in Owens Valley.
DRECP Covered Activities could affect populations of Parish's popcorn flower in Owens
Valley, and LADWP's role in the DRECP has yet to be determined.
2. The Rabbit Springs population is dependent upon the hydrologic features for which the
area is named. A geologic fault runs east to west through Lucerne Valley to the south of
Rabbit Springs and north of the San Bernardino NF, preventing groundwater inputs to
Rabbit Springs from the south. Agricultural lands occur to the northeast of Rabbit
Springs, east of HW 247 (Barstow Rd.). If future renewable energy generation facilities
are built on these agricultural lands, and if the cumulative use of groundwater by
potential future projects impacts Rabbit Springs, then the Rabbit Springs population of
Parish's popcorn flower could be impacted by DRECP Covered Activities.
3. We consider the Lovejoy Springs population of Parish's popcorn flower near Lake Los
Angeles to have been extirpated.
The global rarity of Parish's popcorn flower, together with the potential future threats
from renewable energy projects make the case to leave Parish's popcorn flower on the
Covered / Planning species list for further review and analysis using the Covered Species
Filter.
Sincerely,
Greg Suba
CNPS
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