Annapolis Field Station

Peter R. Baye, Ph.D.

Coastal Plant Ecologist

33660 Annapolis Road

Annapolis, California 95412

707.886.0515 / 415.305.2586 / baye@earthlink.net

Forest Practices
California Department of Forestry
135 Ridgeway
Santa Rosa, CA 95401

COMMENTS - THP 1-00- 171SON – Fairfax Conversion (Cordonieu Napa Inc.) Annapolis, Sonoma County

May 19, 2003

To the California Department of Forestry:

I would like to submit the following comments on THP 1-00 484SON, the Timber Harvesting Plan (THP) for the “Fairfax Conversion”, yet another vineyard project concentrated on Goldridge soils of Annapolis, replacing successional mixed coastal coniferous forest. This conversion is proposed in addition to the growing stock of Annapolis vineyards by Kendall-Jackson, Campbell, Elin, Jones, Putnam, and Ridge Top Partners, most of which have been established or proposed in the last 7 years.

I am a professional plant ecologist and field botanist (Ph.D, plant sciences, University of Western Ontario, Canada) specializing in coastal plant communities and species for over 25 years. I have 7 years experience in NEPA and Section 404 Clean Water Act compliance with the U.S. Army Corps of Engineers, San Francisco District (management of EIS and environmental assessments, including joint CEQA document preparation with California state lead agencies), and 6 years experience preparing endangered species recovery plans and Section 7 consultations for the U.S. Fish and Wildlife Service (Sacramento Office). In addition, I have substantial experience with the vegetation and flora of the Annapolis area in particular, as a local resident. My current work includes preparation of an EIR/S on contract with state and federal resource agencies.

My comments concern (1) the scientific accuracy, consistency, and adequacy of biological and ecological data, analysis, and interpretation in the THP and responses to comments (prepared by Ann Hamilton, Registered Professional Forester, of North Coast Resource Management (NCRM), Calpella, CA) and Special Species Status Report/Botanical Survey, Artesa-Fairfax Conversion, prepared by Dean D. Schlichting of NCRM; (2) the consistency of the THP analysis of environmental impacts, mitigation, alternatives, with CEQA Guidelines (regulations), case law, and precedents.

The THP contains substantial errors of fact, omission, and self-contradiction regarding potentially significant impacts to jurisdictional wetland, plants, and endangered species. The type and pattern of errors I was able to detect in the botanical report and THP raise substantial doubt about the overall completeness and accuracy of other data that could be verified only through site inspections by independent qualified observers. The types of errors in the consultant documents would be difficult to make if the scientific references which were cited in the THP and botanical report were actually consulted by qualified professionals. This is particularly a concern, because other RPF-prepared THPs I have reviewed in the past year in the Annapolis area have also contained uncorrected, substantial errors of omission, and substantial indications of low quality control for vegetation and botanical survey data. The quality of biological data in this plan are in marked contrast with the high quality found in other THPs in Sonoma County, such as the Seaview conversion (THP 1-01-223SON). If CDF and California resource agencies rely primarily on consultant-prepared THP data for their review and determinations, this indicates a systematic problem regarding the consistency of quality control of environmental impacts analysis in THPs and conversions. These findings are explained in detail below.

An equally serious problem in this THP is the disregard for CEQA standards of review based on CEQA regulations, precedents of CEQA lead agencies, and case law. The pattern of arbitrary deviation from established CEQA guidance consistently leads to understatement of significance of impacts, dismissal of cumulative impacts, and uncritical acceptance of mitigation measures in the THP. Again, this stands in contrast with high fidelity to CEQA review standards in other plans, such as the aforementioned Seaview THP. As a professional environmental scientist who has reviewed and prepared joint CEQA-NEPA documents for over a decade, I am very concerned that the THP process is often “CEQA-equivalent” in name only. The substance of impact analysis in the Fairfax THP is equivalent only to a defective CEQA document. For example, the invalid use of the “ratio approach” (a common CEQA fallacy applied to analysis of cumulative impacts; see detailed discussion below) and arbitrary bounds for the geographic and ecological scope of analysis of the THP, render the most significant potential cumulative environmental impacts of this project entirely obscured. Even more remarkably, the response to comments by the RPF state that the conversion will cause “significant” visual impacts (NCRM letter, Feb 22, 2002, # 21), yet the THP states the project will not result in any significant impacts. Given the convergence of many independent lines of analysis which systematically under-represent the potential for significant environmental impacts, this trend of impact understatement appears to be either a systematic error, or a deliberate one. It is CDF’s responsibility to ensure that adequate CEQA standards of review are used consistently in THPs.

Specific aspects of the THP are discussed in detail below.

I. Biological and Ecological Impacts in the THP analysis.

Wetlands, ponds, and “vernal pools”

The THP omits identification of widespread, common wetland plant species despite disclosing the presence of “a manmade “pond” that is providing ephemeral aquatic habitat...[that]...will be removed”. The botanical report includes almost none of the common wetland plants found in ditches, pools, and obstructed drainages along Annapolis Road, including Callitriche marginata, Juncus bufonius, J. xiphioides, J. bolanderi, Mimulus guttatus, Mentha pulegium, and many wetland Trifolium species. The deficiency in detection of wetland species despite the presence of wetland habitats is remarkable given the report’s claim that “additional search emphasis was placed on...unique habitat areas such as springs, seeps, wet areas...Special attention was paid to wet areas and watercourses” (p. 7, botanical report). Yet the report discusses no wetland plant communities, and omits most of the characteristic wetland plants in the region that occur in seasonal ponds, springs, and ditches. The THP clearly describes a seasonal pond on p. 25 of the THP: “a small man-made “pond” that is providing ephemeral aquatic habitat will be removed as part ofthe proposed vineyard development....This pond is located in a swale...and is approximately 50 feet in diameter and a maximum of 4 to 5 feet deep. The pond is not spring fed, therefore it dries up in early summer”. This is an excellent description of a deep vernal pool, a type of seasonal wetland that desiccates in summer. The THP responses to comments, however, flatly deny that “vernal pools” are present on the site (NCRM response to comments, Sept. 16 2001, # 10). It also implicitly describes (undisclosed) suitable habitat for the northern red-legged frog, Rana aurora aurora, a wildlife species of concern. The THP fails to disclose the presence of wetlands, despite evidence that they exist, including the “pond” described, as well as other seasonal wetlands that were not described at all. One seasonal pond is visible on the site from Annapolis Road. The presence of seasonal wetlands (including man-made vernal pools) or ponds on site, and the proposed removal, is by definition a wetland impact. The plant survey report and the description of these seasonal pond wetlands are inconsistent, and together avoid disclosure and assessment of impacts to wetlands and other waters.

The THP must identify the acreage of wetlands on site, perform a wetland habitat assessment, and prepare a wetland jurisidictional delineation consistent with federal wetlands delineation procedures used by the U.S. Army Corps of Engineers or Natural Resources Conservation Service, as appropriate. These tasks were, by contrast, performed for the Seaview THP (101-01-223SON). The extent and nature of wetlands on the site must be disclosed to be consistent with CEQA. Fill impacts to wetlands should be avoided or minimized, and any fill in wetlands must be mitigated in at least a 1:1 compensation ratio for losses. In the absence of any minimization, avoidance, or compensatory mitigation, the destruction of seasonal wetlands in Annapolis (where they are rare) should be considered significant. The omission of wetlands assessment in the THP, and substantive disrepancies between the ponded habitats described and plant species reported (or omitted) in the botanical survey report, indicate a need for additional study and disclosure.

Taxonomic and survey errors

The THP and supporting documents misidentify some of the key plant species present on the site, fail to identify other species entirely, report non-existent as well as merely misspelled plant names. These are non-trivial botanical errors. The NCRM Botanical Survey report states that “in some places a thick almost impenetrable shrub layer is dominated by; Arctostaphylos patula platyphyla...” [sic]. The report cites as flora references A Flora of Sonoma County (Best et al. 1996) and The Jepson Manual (Hickman 1993). Greenleaf manzanita, A. patula, occurs neither in nor near Sonoma County, and is not included in the the Sonoma-Mendocino complex of manzanita species. It is also not included in the Sonoma County flora cited. A. patula is an interior high-elevation montane species (high North Coast ranges), not a central coast range species. If either of the authoritative floras cited as references were actually consulted, this geographic information would be evident, regardless of the taxonomic difficulty of the genus as a whole. (The distinctive golden-glandular shoots and low-growing circular clones of A. patula, however, make it virtually impossible to confuse with the tall, arborescent, non-glandular manzanitas present in Annapolis).

There are in fact two (and probably only two) manzanitas on the site, evident along Annapolis Road: the common and easily identifiable coastal species, bristly manzanita (A. columbiana) and a unique, endemic, anomalous entity, described in the Flora of Sonoma County as a hybrid complex including A. manzanita and A. stanfordiana. The center of this putative hybrid complex is on the sandy soils between Quarry Road (site of the proposed Elin Vineyard) and eastern end of the proposed Fairfax/Cordonieu vineyard conversion; it is scattered in distribution on road cuts beyond this center. The Flora of Sonoma County clearly identifies this unique, distinctive plant with tree-like stature and intermediate floral and foliar characters of A. stanfordiana, which is distributed in interior ranges of Lake, Mendocino, Napa, and Marin county. This is botanically significant, because two special-status manzanitas recognized by CNPS as “List 1B” (rare, threatened or endangered in California) include Contra Costa manzanita (A. manzanita ssp. laevigata) and Konocti manzanita (A. manzanita ssp. elegans), have been interpreted as originating from the same hybrid parentage, but are less narrowly endemic and taxonomically distinctive than the Annapolis manzanita. The Annapolis manzanita may be an old, unrecognized parallel subspecies, rather than a recent hybrid swarm. Two vineyard conversions in Annapolis, Elin and Fairfax, cumulatively threaten to exterminate the core population of this distinctive, poorly studied endemic manzanita complex before its taxonomic status is researched. The THP neither identifies the nature or presence of this manzanita complex, nor does it assess the cumulative threat to its continued existence.

The THP itself cites a bewildering set of non-existent combinations of plant genera and species epithets, and mispelled botanical names on p. 81: “Arbutus patula...Cornuta californica...Rosacea gymnocarpa”. The errors are not trivial typographic ones, and indicate a low level of botanical literacy even by undergraduate student standards. There are also other probable plant misidentifications (e.g. Castilleja exserta is likely C. densiflora) and many omissions of widespread species indicated by the habitats present. Trivial, careless nomenclature or spelling errors are also common in the botanical report.

In view of the demonstrated low level of familiarity with the regional flora and botanical texts in the NCRM documents, and quality control in accuracy of basic species identifications (and possible lack of species detection), the data and conclusions in botanical report cannot be presumed to be generally reliable. The rote “rare plant” search list used by NCRM is biased towards state-listed maritime species which are unlikely to occur in the project area (at the landward limit of regular coastal fog influence), while more species which are regionally rare (significant elements of regional biological diversity of forest and grassland habitats) and more likely to occur were omitted from focused search. Significant impacts to floristic diversity of this subregion during its recovery from excessive logging during the 1950s and 1960s may occur if THPs do not focus survey efforts on regionally rare or uncommon species. The conservation biology principles in this approach are well supported (Hunter et al. 1994). A relatively complete list of species that may occur in forest, scrub, and grassland habitats in this subregion is provided in Attachment A. Note that some regionally uncommon to rare species, such as Pacific yew, are extremely difficult to detect (easily misidentified as immature, shade-grown redwood or Torreya) without focused surveys.

Because CDF relies heavily on consultant documents for biological data, there appears to be a need for independent scientific review by qualified experts to screen for error, in adequacy, or methodological error in consultant data. I suggest that University extension services may be a starting point for establishing healthy scientific peer review of THP documents.

Threshold for endangered species impacts

The NCRM argument equivocates “impact” and “take” in the narrow sense (direct harm to individuals of an endangered species), and thereby underestimates project-related cumulative and individual impacts to the distribution and recovery of the northern spotted owl. This is misleading and inappropriate. The THP states (p. 80) that the federally endangered northern spotted owl (NSO) has occurred within the biological assessment area. It correctly identifies small mammals as the species’ prey base (in fact, wood rats, which are common in the second-growth woodlands of Annapolis, are favored prey in this part of the NSO range), and the presence of permanent water and mature forest as essential habitat elements. The recovery of this species through its range along the north coast depends on regeneration and maturation of depleted suitable habitat, degraded by excessive past logging. The proposed project, and similar ones, clearly affect the recovery of this habitat and the endangered species it supports.

The minimization of “take” by avoiding direct harm or harassment of individuals after surveys is only one aspect of logging impacts to the NSO. The permanent deforestation of a NSO foraging site within a known territory, and the permanent prevention of mature habitat regeneration, together are far more significant, multi-generational impacts to population viability of this species than “take” of a single individual. There is in fact no mitigation proposed for the permanent loss of NSO foraging and potential nesting habitat caused by the Cordonieu vineyard conversion. Furthermore, the entire Annapolis vineyard conversion corridor has been, or is in the process of becoming, permanently precluded habitat recovery for this species. This represents a significant, long-term, adverse cumulative impact to the recovery of this species, compared with existing conditions. Neither individual nor cumulative impacts to the recovery of the NSO were assessed or mitigated. This constitutes a mandatory finding of significance under the California Environmental Quality Act (CEQA: Pub. Res. Code Sec 21083) for projects that “reduce the numbers or range of a rare or endangered species”, or “reduce fish or wildlife habitat”.

For these reasons, the NCRM response to comments (March 13, 2002 #22) that “there will be no significant adverse impacts to raptors or Northern Spoted Owls as a result of the proposed timberland conversion and vineyard development” is incorrect as a matter of fact and interpretation pursuant to CEQA and the federal Endangered Species Act impact threshold of “may affect” or “likely to adversely affect” in terms of “survival and recovery” of listed species.

II. CEQA issues

CEQA impact analysis issues

Abuse of “ratio approach” in cumulative impacts assessment

The THP and supporting documents (response to comments by NCRM) trivialize potentially significant environmental impacts through invalid analysis using the “ratio approach”, which is generally unacceptable in CEQA review. For example, in the NCRM February 22, 2002 response to comments from J. Hall, states

Analysis of these animals and their habitat requirements relative to the habitat types available in the Biological Assessment area indicate that the proposed timberland conversion will not result in a significant reduction in habitat for these animals. The proposed timberland conversion will affect only 1.5% of the existing habitat within the biological assessment area....

Similar “ratio approach” analyses were used to dismiss comments about impacts of habitat loss and agricultural conversion, and general plan land use impacts. This perspective inverts the CEQA principles (and regulations) for assessment of cumulative impacts, and the very definition of cumulative impacts and their significance (Guidelines 15355, 15065, 15165). Reliance on an individual project’s relatively small percent contribution to large baseline conditions (especially arbitrarily inflated assessment areas) to demonstrate “insignificant” impacts is invalid when no numeric thresholds of CEQA significance are established by a Lead Agency. This has been established in case law: Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, Citizen Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748. Cumulative impact assessment must review additive, compound, interactive, and incremental effects of projects in relation to other projects; they cannot diminish impacts by comparison to the resource as a whole instead of other projects.

Public controversy and expert disagreement

There exists substantial evidence of public controversy and scientific expert disagreement over the environmental impacts of northwestern Sonoma forest conversions to vineyards. The administrative record of the THP, and reports in local and Santa Rosa newspapers, both demonstrate this. The THP concedes at least one significant impact after mitigation (visual), and many substantial and expert comments indicate the potential for other significant environmental impacts of the project. Even if this were a “marginal” case in which the significance of the project’s impacts were unclear, CEQA regulations (Guidelines 15064(h)) stipulate that CEQA Lead Agencies shall treat as significant those impacts over which experts disagree about significance, or those over which there is serious public controversy. In the present case, all these thresholds are met or exceeded. Thus, an EIR is required, and the negative declaration is invalid under CEQA.

Alternatives analysis

There are several basic defects in the analysis of alternatives by CEQA standards of review. The “reasonable range” of alternatives evaluated is arbitrarily reduced, compared with the standard programmatic range in CEQA documents: only “no Project” and “conservation easement” are evaluated. No “reduced project” alternative, minimizing impacts by reducing the scope of conversion, the reducing the intensity of project impacts, and buffering its impacts on adjacent environments, is considered. No offsite alternatives are evaluated, despite obvious indications of vineyard suitability elsewhere in the region (i.e., rapid vineyard development). The arguments in the “conservation easement” discussion are incorrect. The THP states that the site “is not a likely candidate for protection” because it currently lacks old growth redwoods. This is contradicted by the Soda Springs Reserve (virtually across the street on Soda Springs Road), and the prevalence of non-redwood, non-old growth parks and reserves in northern Sonoma County, such as Kruse Rhododendron reserve, Salt Point State Park, Sonoma County Regional Park beaches from Sea Ranch to Gualala Point, and the entire Warm Springs/Lake Sonoma forest/serpentine chaparral landscape. The THP also states it is “extremely unlikely” that any public or private party would consider conservation easement or purchase. The THP fails to identify obvious potential organizations and agencies that may do so, such as collaborations between land trusts, open space districts, and others who have been highly active at protecting open space in other parts of Sonoma County.

The alternatives analysis is deficient in both CEQA form and substantive content. At minimum, a reduced project alternative and an accurate alternative land use option should be evaluated. A reduced project alternative should evaluate the feasibility of concentrating or limiting vineyard development to non-forested areas on the site. An alternative site analysis should be performed.

CEQA substantive impact assessment issues

Fire hazards

I was unable to find an assessment of the individual or cumulative increase in risk of forest fire ignitions by vineyard operations. Given the recent forest fire ignited in the summer of 2002 by vineyard workers at the new vineyard directly across Annapolis Road from the proposed Cordonieu Napa vineyard, and the fire prevention mandate of CDF, this is surprising. The use of weed-whackers, fuels, engines, and employment of workers who are may not be non-smokers, adjacent to forests, clearly indicates fire risk. Since these activities occur on well over 1000 acres of Annapolis (over 100 in the proposed project alone), in an area that just 10 years ago supported only one small vineyard and about 1000 acres more forest, grassland, and scrub, indicates that there is a significant cumulative increase in fire risk to the forests of Annapolis. The Annapolis forest fire near Grasshopper Creek in summer 2002 occurred on a hot, dry, day with westerly winds. It placed not only the hillsides and creeks of recovering redwood-douglas fir forests at risk, it threatened the property and lives of a rural residential community. I appreciate the excellent work of CDF crews in promptly controlling the fire. I would appreciate it equally if CDF considered preventing the causes of such by more carefully assessing fire ignition sources of projects it approves through THP conversion permits.

I recommend with the strongest possible emphasis that CDF take its fire prevention mandate as seriously as its administrative THP approval process, especially when the basic purpose of a THP is conversion (deforestation). The double-jeopardy of deforestation by agricultural conversion and elevated forest fire risk from agricultural operations should provide sufficient incentive for CDF to rigorously review these potential impacts from the perspective of its dual mandates. To do otherwise would be at best irrational, and at worst, destructive.

Noise Impacts

The THP fails to assess the significance of noise impacts associated with the 105 acre timber removal, vineyard construction, and vineyard operation, in the context of noise intensity, duration, noise receptor sensitivity and rural residential land use settings under existing conditions. Assessment of noise impacts is a standard feature of CEQA review. Chronic operation of heavy equipment in an area surrounded by steep canyons (high echo) of the Fuller Creek and Grasshopper Creek watersheds may have significant short-term and long-term noise impacts.

Visual Impacts

The THP does acknowledge that the project will have “significant” impacts, after considering mitigation, on visual (esthetic) resources of the eastern Annapolis Road viewshed (Cumulative Impacts Assessment, THP; also NCRM response to comments, February 22, 2002, # 21). This interpretation is clearly made in the context of a CEQA-equivalent document, and plainly indicates the need to prepare an EIR. The finding a negative declaration is invalid under CEQA.

Traffic impacts

The NCRM response to comments regarding traffic assessment, and the THP assessment, are invalid and inaccurate. The assessment of traffic impacts requires assessment of the existing level of service of the roadway affected, including seasonal variation. The cumulative effect of a series of major vineyards on a 3 mile segment of Annapolis Road, with synchronous annual cultivation and harvest operations due to identical climate and grape varieties, is well beyond the threshold of “significance” for a rural road with a CEQA impact assessment baseline of existing conditions. In addition, the type of traffic (heavy trucks and equipment during harvest), commute distance and direction and time of harvest employees (early morning and evening, Skaggs Springs Road to Healdsburg/Cloverdale vicinity) indicate a potential for significant cumulative and individual impacts to traffic. An traffic analysis by qualified professionals is needed to assess this; the breezy dismissal in the response to comments is insubstantial and inadequate.

Imbalanced public interest review under CEQA

The NCRM response to comments that the proposed vineyard development is contrary to the public interest indicates an imbalanced public interest review pursuant to CEQA. The THP and response to comments consider public interest solely in terms of economic, employment, and private benefit due to agricultural conversion, without reference to the balance of public and private need for forestry, wildlife, and agricultural resources. This is particularly ironic for a CEQA document prepared by a forestry professional for a forestry agency. In any case, this public interest review is inconsistent with CEQA statute policy, Public Resource Code 21001. For CEQA policy on economic or social effects, see CEQA Guidelines 15131.

Cumulative impact analysis

A full critique of the invalid and erroneous analyses of cumulative impacts is beyond the scope of this comment letter. There is a systematic deficiency in cumulative impact analysis both this THP and its supporting documents, and in CDF’s general approach to cumulative impacts in all THPs. The specific conflict between the “ratio approach” fallacy and CEQA case law was noted above. CDF and the RFPs who prepare the nominally CEQA-equivalent THP documents have so far failed to provide even maps of past, present, and “reasonably forseeable” future vineyard conversions on the Goldstone soils of Annapolis, the very minimum graphic representation of cumulative impacts. The treatment of “future projects” in the cumulative impacts section of the THP (p. 135) is simply not credible: it makes no quantitative or geographically explicity reference to Annapolis vineyard development, and offers only pointless, bland generalities such as “Due to the good market for high quality wine grapes that currently exists, it is likely that viticulture will continue to increase...”. It is plain even to non-experts that all parcels on the gently sloping hills in Annapolis are under intense agricultural development pressure, as reflected in local real estate sale prices, sales, and speculative real estate markets, as well as observed vineyard conversion rates. The lack of minimally adequate cumulative impact assessments with common-sense, “rule of reason” geographic scope of analysis, is a serious failure of both CEQA procedure, disclosure and diligence. The systematic under-reporting and disingenuously skewed analyses of cumulative impacts by THP preparers and CDF is a serious violation of CEQA.

CEQA lead agencies have limited discretion in their interpretation of cumulative impact analyses. California case law has consistently held that CEQA should be interpreted “so as to afford the fullest protection of the environment within the reasonable scope of the statutory language” (Friends of Mammoth v. Board of Supervisors (1972) 8 Cal.3d 247, 104 Cal. Rptr. 76). This intent is not reflected by CDF review of cumulative impacts of Sonoma County timberland-vineyard conversions.

Conclusion

Based on the evidence and analysis presented, I recommend that CDF revoke the invalid Negative Declaration for this THP, and require remedial surveys and analyses to compensate for the deficiencies of the present THP. Given the proposed fill of jurisdictional wetlands and other waters of the United States as part of the project, I recommend that CDF consult with the U.S. Army Corps of Engineers regarding wetland jurisdictional delineation and the need for a Section 404 Clean Water Act authorization and potential joint EIR/S preparation.

Sincerely,

Peter R. Baye, Ph.D.

Coastal Plant Ecologist

cc:

California Department of Fish and Game, Yountville

California Native Plant Society, Point Arena

Interested Parties

LITERATURE CITED

Best, Catherine, J.T. Howell, W. & I. Knight, and M. Wells. 1996. A Flora of Sonoma County: Manual of the Flowering Plants and Ferns of Sonoma County, California. California Native Plant Society, Sacramento, California.

Hickman, J., ed. 1993. The Jepson Manual: Higher Plants of California. University of California Press.

Hunter, M.L., Jr. and A. Hutchinson. 1994. The virtues and shortcomings of parochialism: conserving species that are locally rare, but globally common. Conservation Biology 8: 1163-1165.

ATTACHMENT A: Comments on THP 1-01-171SON (P. Baye)

Annapolis Field Station

33660 Annapolis Road

Annapolis, California 95412

baye@earthlink.net; 707.886-0515 / 415.305.2586

Timber Harvest Plan Plant Species of Concern:

Plantation-Cazadero-Annapolis-Gualala

(NW Sonoma/SW Mendocino) Subregion

The purpose of the following list of plant species is to provide a relatively comprehensive, floristic review of plants with contemporary conservation significance, specific to the forested areas of northwestern Sonoma County. The context for conservation significance in this list is regional rarity, substantial regional population decline, or biogeographic distinctiveness. Geographic range limits, disjunct populations (outliers), relict populations, severely reduced populations, are all considered significant in this context. These criteria for conservation significance are not narrowly focused on global taxonomic rarity or legal protective status. They address contemporary concerns in conservation biology about range collapse and community-level conservation of biodiversity. The list is proposed as a preliminary evaluation tool for identifying sensitive botanical resources reviewed in timber harvest plans.

The following subregional conservation list of vascular plants was derived from a combination of literature sources and field observations. The primary floristic review was based on Best et al. 1996. A Flora of Sonoma County, California Native Plant Society, Sacramento, California, and CALFLORA, an on-line database synthesizing multiple herbaria and literature sources. Nomenclature follows Hickman et al. 1993. The Jepson Manual: Higher Plants of California, University of California Press. Distribution comments (in quotations) are cited from Best et al. 1996 unless otherwise indicated. California Native Plant Society rankings follow the Rare Plant Scientific Advisory Committee, CNPS, in: Tibor, D.P., ed. 2001. Inventory of Rare and Endangered Plants of California, 6^th edition, California Native Plant Society, Sacramento, California. Incidental field observations and directed surveys within the subregion were conducted Peter Baye, Ph.D., Annapolis Field Station, from 1995 to present. CNPS rankings are based on statewide and continental distributions. The Flora of Sonoma County evaluations of distribution are based on Sonoma County alone.

The general geographic and ecological scope of this review focuses on mixed coniferous forest and woodland habitats in the coastal belt, including secondary successional grassland and woodland, inland from the first coastal ridge between Gualala and Timber Cove. The review considers plant species either historically reported, collected, or likely to occur in habitat types within this subregion where potential timber harvest plans or land use conversions in timber lands may occur. The list is not exhaustive, and may omit species with erratic significant disjunct populations. The list does not cover “serpentine endemic” species (species rarely found outside of serpentine soils), or species very narrowly associated with specialized soil or climate conditions in the region(bogs, fens, dunes, beaches, coastal bluffs and terraces, vernal pools, and acidic, poorly drained sandstones). Presence of these distinctive soil and climate-conditioned habitats would require intensive site-specific plant surveys and historical documentation, but are seldom associated with timber harvest plans.

Categories of conservation significance:

Special Regulatory or Policy status

FT – Federally listed as threatened

FE – Federally listed as endangered

CT – State-listed as threatened

CT – State-listed as endangered

CR – State-listed as rare

CNPS 1B – listed by California Native Plant Society as rare, threatened or endangered in California and elsewhere, based on statewide review by CNPS botanical experts and network of field observers.

CNPS 2 – listed by CNPS as rare/threatened/endangered in California, but more abundant elsewhere.

CNPS 3 – CNPS “need more information” category: unresolved taxonomic and distribution data on plants apparently in decline.

CNPS 4 – CNPS “watch list” of plants with limited distribution, vulnerable to decline.

Biogeographic, biological status, inferred from literature and survey information.

RR – regionally rare, globally more widespread or abundant

RL – at or near geographic range limit, uncommon to rare

DP – distinctive or atypical populations but consistent with type

including stabilized hybrid/introgressant populations)

TL – type locality (botanical historic significance)

AT – ambiguous or anomalous taxonomy (potential cryptic taxa, new taxa)

FERNS AND FERN ALLIES

Dryopteris expansa (Presl) Fraser-Jenkins & Jermy

Spreading wood-fern

“Rare, coastal woods: Hwy 1 four mi. s. of Stewarts Point acc. Baker...”

Polystichum dudleyi Maxon

Dudley shield fern

“Rare, deep canyons: near bridge on Gualala River near Annapolis acc. Baker...”

Polystichum imbricans (D.C. Eaton) D. H. Wagner

Rock sword fern

“Rarely detected or reported, rocky ground...” Records E. Sonoma Co.

Marsilea vestita Hooker & Greville

“rare, buddy banks, edges of ponds, vernal areas, swale bottoms”

Pilularis americana A. Braun

Clover-fern

“Rare, heavy soils, vernal pools”

Botrychium multifidum (S. Gmelin) Ruprecht

Grape-fern

“rare, wet meadows, brushy flats”

Adiantum aleuticum (Ruprecht) C.A. Paris

Five-finger fern

“Rare, deep shaded ravines”, stream banks, forest seeps, springs

Aspidotus californica (Hooker) Copeland

California lace-fern

“Rare, rocky places” (primarily E Sonoma Co.)

CONIFERS

Taxus brevifolia Nuttall

Pacific yew

“Very rare or rarely detected open coastal slopes in wooded shaded canyons; the only Sonoma County record is that of Baker: ‘Gualala Canyon near Annapolis Bridge’...” . Populations recently confirmed on Fuller Creek and moist north-facing slopes of its canyons.

Tsuga heterophylla (Rafinesque) Sargent

Western hemlock

“Rare, Gualala River drainage in coastal woods, probably the southernmost distributional limits; 3 ½ miles se. of Gualala...vallye crossing at Gualala River....between Cazadero and Plantation acc. Baker.”

RR, RL

FLOWERING PLANTS

Aralia californica S. Watson Apiaceae

Elk clover, spikenard

“Infrequent, somewhat shaded and moist spots”. Forest seeps, springs, shaded moist creek banks.

Erigeron supplex A. Gray Asteraceae

Supple daisy

“Rare, near coast..”

RR, CNPS 1B

Vancouveria hexandra (Hooker) Morren & Decaisne Berberidaceae

Northern vancouveria

“Rare, deep shade, coniferous woods: Plantation road near Hwy 1, acc. Baker, the only record known from Sonoma County, probably the southernmost distributional limit”.

RR, RL

Cornus nuttallii Audubon Cornaceae

Mountain dogwood

“Occasional, mountain woods”. Poor regeneration following timber harvest; in decline.

Allotropa virgata A. Gray Ericaceae

Sugar stick

“Occasional, thick humus”. Rare outside of mature forest soils.

Arctostaphylos manzanita x A. stanfordiana Ericaceae

Local, Annapolis: “The population needs more study. Maybe it needs a name!”

Limited distribution, eastern Annapolis

RR, DP, AT

Chimaphila menziesii (D. Don) Sprengel Ericaceae

Pipsissewa

“Rare, shady woods: Stewarts Point quad...”

Chimaphila umbellata (Linnaeus) Bartram Ericaceae

Prince’s pine

“Rare, dry forest edges”

Hemitomes congestum A. Gray Ericaceae

Gnome plant

“Uncommon, in humus...” . Rare outside of mature forest soils.

Pityopus californicus (Eastwood) H. Copeland Ericaceae

California pinefoot

“Uncommon, deep shade....”

Pyrola picta Smith Ericaceae

Shinleaf, white-veined wintergreen

“Occasional, wooded slopes...Annapolis quad...”

Lotus aboriginus Jepson Fabaceae

“Uncommon, borders of woods: near Kashia school on Stewarts Point-Skaggs Springs Road...”

Trifolium buckwestiorum Isely Fabaceae

“Rare, known only from Sonoma and Santa Cruz counties, waste or grassy areas: n. of Cazadero....”

Romanzoffia californica E. Greene

“Occasional, shaded or open, damp, rocky areas: n.-facing rocky roadcuts on Stewarts Point-Skaggs Springs Road just e. of Annapolis Bridge...”

Circaea alpina Linnaeus ssp. pacifica (Ascherson & Magnus) Raven Onagraceae

Enchanter’s nightshade

“Rare , deep woods”

Actaea rubra (aiton) Willdenow Baneberry Ranunculaceae

“Occasional, moist woods: Annapolis quad....”. Very local, few records.

Ceanothus incanus Torrey & Gray forma spinosissimus Klein

“Uncommon: Kelley Road in flatland few mi. e. of Annapolis...”

Keckiellia corymbosa (Bentham) Straw. Scrophulariaceae s.l.

Redwood penstemon

“Uncommon, rocky slopes...” Present on cliffs of Gualala River, Wheatfield Fork, E. Annapolis,

disjunct coastal population

Synthyris reniformis (Doughlas) Bentham var. reniformis Scrophulariaceae s.l.

Snow queen

“Uncommon, moist shaded embankment of forests....”

Dirca occidentalis A. Gray Thymelaceaeae

Western leatherwood

“Very rare, coastal brush area...”

CNPS 1B

GRASSES, SEDGES

Carex hendersonii L. Bailey

Henderson’s sedge

“Uncommon, shaded areas, moist coastal woods....the southernmost collections”

RR, RL

Carex mendocinensis Olney

Mendocino sedge

“Rare, wet soil, springs, marshes...”

Calamagrostis bolanderi Thurber

Bolander’s reed-grass

“Occasional, meadows, openings in coniferous forest...”

RR, CNPS 1B

LILY ALLIES

Erythronium revolutum Smith

“Rare, margins of wamps, bogs, or wooded streams...”

RR, CNPS 2. On Oregon “watch” list, state-listed as “sensitive” in Washington.

Lilium columbianum Baker

Oregon lily, Columbia lily

“Rare, among ferns and brush...”

Lilium maritimum Kellogg

Coast lily

“Occasional, usually sand y soil, woods, brush, occasionally marshy areas...”, primarily Sea Ranch-Plantation-Salt Point area, reduced probability of occurrence with distance inland.

RR, CNPS 1B

Lilium pardalinum Kellogg ssp. pardalinum

Leopard lily

“Occasional, springy places, stream banks...” (Gualala River locs.)

Mostly restricted to old riparian vegetation, usually extirpated in disturbed riparian zones.

Lilium rubescens S. Watson

Redwood lily

“Occasional, woody brushy ridges and slopes..”

RR, CNPS 4

Maianthemum dilatatum (Wood) Nelson & J.F. McBride

False lily-of-the-valley

“Uncommon, damp shaded embankments..”

Trillium albidum

white trillium

“Occasional, damp shady areas..”

Veratrum fimbriatum A. Gray

Fringed false hellebore

“Infrequent, wet openings, meadows...”

ORCHIDS

Cephalanthera austinae (A. Gray) A.A. Heller

Phantom orchid

“Uncommon, dry woods...”, associated with thick leaf litter/humus of older forest soils.

Corallorhiza mertensiana Bongard.

Western coralroot

“Uncommon, rich wooded areas”, associated with thick leaf litter/humus of older forest soils. No recent records; northern affinity.

Corallorhiza striata Lindley

Striped coralroot

“Occasional, rich wooded areas...”, associated with thick leaf litter/humus of older forest soils. Most records old; may be in regional decline.

Cypripedium californicum A. Gray

California lady-slipper

“Rare, wet hillsides and rocky ledges...”; few records, one extirpated by logging.

Near southern limit (Marin), RR. CNPS 4.

Cypripedium montanum Lindley

Mountain lady-slipper

“Rare, damp woods...” Only one recent record; possibly modern southern coastal limit.

RR, CNPS 4.

Goodyera oblongifolia Rafinesque

Rattlesnake-plantain

“Uncommon, dry forest floor....”

Piperia candida R. Morgan & J. Ackerman

White-flowered piperia

“Rare, coniferous forest...”

RR, CNPS 4.