Every spring survey is slightly different. While some species — plants and butterflies to name two — have variable survey seasons, others have well established or federally-mandated survey seasons. Missing a survey window can adversely impact a project’s schedule.
The key to managing mandated surveys is to combine the needs and schedule of the development project with a thorough understanding of the various species survey protocols and regulatory requirements.
Some approaches to consider are:
Determining whether a survey is really needed this year based on the project’s schedule, or is it better to complete it next year to more effectively utilize immediate funds and ward against survey aging.
Determining which surveys are required. The vegetation communities and other factors may require different surveys, each with its own timing and protocol. Missing one of these survey windows can adversely affect agency coordination, project roll-out or lead to additional surveys down the road.
Understanding the basic resources present on or within a 10-mile buffer of the development site (e.g. soil types, vegetation communities, wetland resouces if any). Your project biologist can provide initial assessment of the potential resources that might affect the project and help devise a plan for conducting the appropriate studies to get you through the regulatory process. Doing this early can help ensure that you don’t miss critical survey windows or needs.
Communicating early with the appropriate local, state, and federal regulatory agencies to gain their buy-in on the suite of surveys and methodologies proposed. We have found that regulatory agencies appreciate the opportunity to participate early in the process and are much more willing to work through logistical issues with project proponents when they are at the table early and feel like they are a partner in the process. Seemingly daunting issues, such as out-of-season surveys, or too few surveys, can often be handled when there is trust and partnership.
Make sure that your biologist is conversant with the most recent versions of the following:
- Draft Eagle Conservation Plan Guidance (USFWS 2011) that provides interpretive guidance on applying the 2009 Final Eagle Permit Rule permit standards and also explains the USFWS’ approach to issuing programmatic eagle take permits, and provides guidance to applicants and biologists on the development of Eagle Conservation Plans to support permit issuance.
- Draft Voluntary Land-Based Wind Energy Guidelines (USFWS 2011) used by developers, federal agencies, and state organizations for selecting sites for wind energy projects and analyzing short and long-term effects of development
- California State Senate Bill 618 which, in part, modifies the language of the Natural Communities Conservation Planning Act (NCCP) to include “Fully-Protected” species to the “Covered Species” definition. This allows a mechanism for previously impossible take where there is an NCCP in place or in process.
Your biologist should also be conversant with the relevant local policies, wetland permitting policies, and habitat conservation planning efforts (e.g. Desert Renewable Energy Conservation Plan) taking place in your region.