West Mojave Plan FEIR/S - Desert Managers Group

Monitoring: Monitoring is often the most expensive of all environmental protectioncosts. Depending on the project, an authorized biologist may remain on site for an hour, as asmall parcel is brushed, or up to months and years, as an interstate pipeline is installed or ahighway widened. Revegetation costs may also be very high, requiring the purchase of nativeseeds and the labor of contractors to broadcast and imprint the seed and to salvage cactus andyuccas. At present (2002), most monitoring costs are about $35 to $50/hour. Monitoring costs,then, may run from several hundred dollars for a day, up to $1,400 to $2,000 per week, $5,600 to$8,000 per month and, for long-term monitoring, $291,200 to $416,000 annually.Consultation and Incidental Take Permit Processes Compared: The comparisonsgiven above for eight Section 10(a) permits indicates that tortoises were neither handled(harassment take) nor accidentally killed (mortality take) during construction and operation onthe sites. Given the delay between the presence-absence tortoise survey and permit issuance,which was found to be about three years, it is likely that tortoises were extirpated in the interim.Alternatively, tortoises still occur in adjacent areas but were not directly affected by the project.As such, under current management compensation fees ranging from $500 to $5000/acre haveserved to compensate lost habitat where tortoises have not been directly affected, and has donelittle to minimize the indirect impacts that are likely to affect the tortoises in adjacent areas.Most of the existing development outside city limits occurs on private lands, where therehave been only nine Section 10(a) permits issued in California in the past 12 years. For example,of the 47,538 structures digitized from 1995 aerials, 46,150 (97%) were found on private lands.Most of this land occurs within the known historic range of the tortoise, and much of it (i.e.,3,079,403 acres (4,812 mi 2 ) of Survey Areas on public and private lands outside DWMAs) isexpected to continue to support tortoises. In fact, of 78 tortoise surveys performed in urbanizingareas, LaRue reported finding tortoise sign on 25 sites, or about a third (32%) of those surveyed.For comparison, only 1,388 of the 47,538 structures (3%) in 1995 occurred on public landsadministered by the BLM, where there had been 50 biological opinions issued between 1990 and1995.In addition to BLM’s 50 biological opinions, 42 were issued to the Department ofDefense, NASA, and U.S. Army Corps of Engineers (Circle Mountain Biological Consultants1996, LaRue and Dougherty 1998). During the same period, only three or four Section 10(a)permits were issued for private development. Relative private and public land acreage cannotexplain this disparity between Section 7 and Section 10(a) authorizations. The disparity appearsto be due to several other factors (see also discussion in LaRue 1994):• Many private land developers have opted to abandon projects when faced with mitigationcosts and permitting delays. Examples include the 160-acre Carl Jones site in AppleValley, and the 52-mile long Copper Mountain Mesa pipeline, which was originallyintended to be 102 miles long (LaRue, pers. comm.). The costs of permitting underSection 7 are invariably less because a consultant is not needed to draft the HCP,environmental assessment or impact statement, implementing agreement and otherassociated documents. In addition, Section 7 implementing regulations require theissuance of the biological opinion in 135 days, while no such time limit exists forprocessing a Section 10(a) permit.Chapter 3 3-41