Michael Boyd, President

Californians for Renewable Energy

(CARE)

821 Lakeknoll Drive

Sunnyvale, CA  94089

(408) 325-4690

 

 

STATE OF CALIFORNIA

State Energy Resources

Conservation and Development Commission

 

 

In the Matter of:                                     )

                                                              )                     Docket No. 99- AFC-3

                                                              )                    

                                                              )                     Comments on the Preliminary

                                                              )                     Staff Assessment of the Metcalf

                                                              )                     Energy Center by K. Shawn

_________________________________ )                Smallwood, Ph.D.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                                                   

 

           June 30, 2000                                                      Michael  E. Boyd, President CARE

 

 

            (p Proof of Service Attached)

Comments on the Preliminary Staff Assessment of the Metcalf Energy Center

 

K. Shawn Smallwood, Ph.D.

 

            I have reviewed the CEC Preliminary Staff Assessment (PSA) of the Application for Certification 99-AFC-3, Metcalf Energy Center.  I applaud Linda Spiegel for what appears to be a commendable effort to deal comprehensively with many of the issues related to biological resources.  Many of her conclusions and recommendations appear sound, or at least provide an excellent start for further investigation and analysis.  There are some issues that remain for me, however, and I would like to address these issues herein and in the Public Workshop on Biological Resources to be held in San Jose on June 22, 2000.  In addition, my work on this project is only in its preliminary phase.  I am sure there will be a significant number of additional issues that will need to be addressed, or addressed differently. 

 

My qualifications for responding to the PSA are summarized in my short biography and Curriculum Vitae, which area attached.

 

Environmental Setting

 

            The reconnaissance-level biological surveys at the proposed project site by CH2MHILL and CEC biologists appear to be fairly thorough.  However, there are significant shortfalls.  Some of them are the absence of bat surveys, small mammal trapping, and use of camera traps.  I saw no evidence of netting or acoustical sampling for bats.  Since multiple bat species are considered Species of Special Concern by our state and federal governments, I regard this shortfall as significant.  I also saw no attempt to sample the small mammal species using traps, which severely constrains an understanding of which species are present.  I recommend that proper sampling be implemented for bats and small mammals.

 

I want to point out a couple of findings I made at the site during my visits of 11 April and 2 May, 2000.  My findings are significant because, as is typical with CEQA or CEQA-equivalent document preparation and assessment, the biologists of the lead agency are expected to limit their examination of any changes in existing physical conditions in the affected area since they occurred at the time of the notice of preparation (NOP).  However, this baseline may not be the appropriate one from a scientific, biological standpoint, nor from the standpoint of maximizing environmental protection while avoiding or minimizing environmental harm, which constitutes CEQA’s foremost principle.  Biologists are familiar with natural changes in physical conditions and with periodic changes in site occupancy by species (Taylor and Taylor 1979).  That is, if a species appears absent from a site at the time of the NOP, it could easily have been there prior to the NOP and it could very well be there again in the near future so long as the site supports suitable habitat.  I want to present certain of my findings that demonstrate the need for prudent caution in determining which species exist at Tulare Hill, Fisher Creek and the adjacent upland area (proposed MEC site).

 

For example, I found an arboreal salamander on the west side of Fisher Creek downhill from the large spring on Tulare Hill (Photo 1), a western skink on the east side of Fisher Creek, a deer mouse on Tulare Hill, western fence lizards, pocket gophers, Tree Swallows, and Western Kingbirds.  These species apparently were not found by CH2MHILL (2000: Table B-1, page 9-3).  These species have no special status under California and federal laws and policies, but my finding them after other biologists visited the site on numerous occasions demonstrates the frustrating reality that animal species are always missed during site visits, no matter how exhausting. 

 

            As another example, the PSA concludes that California Horned Lizards are unlikely to occur on Tulare Hill or the proposed project site, because the habitat is unsuitable.  However, I found numerous harvester ant colonies on Tulare Hill (Photo 2), and harvester ants are the major prey of California Horned Lizards.  I recommend that the likelihood of California Horned Lizard presence be reconsidered, and I recommend that some assessment be made of the possible impacts of NOx deposition on harvester ants. The California Horned Lizard is a California Species of Special Concern. To meet CEQA’s foremost principle, this type of enhanced examination is absolutely essential.

 

            Also, I acquired photographs taken by one of the former land holders during 1992.  These photographs of Tulare Hill and the upland area next to Fisher Creek show that this site was not as degraded as it is today (Photos 3-10).  The junk piles were not there as they are today, and the vegetation was more lush on both Tulare Hill and the upland area next to Fisher Creek.  These photographs were taken approximately the same time of year as my site visits, so the vegetation conditions should have been comparable with respect to phenology.  The reduced plant height and density on Tulare Hill might indicate an impact from atmospheric pollutants since 1992, or part of a cyclic change in vegetation conditions with local climate variables.  Whatever the reason for the apparent change in vegetation conditions, the biological species we see there today might not compose the same assemblage of species that was there in 1992, and it might not be the same assemblage that will be there in 10 years from now.

 

            CH2MHILL prepared a summary of their biological surveys, entitled “Biological assessment for the Metcalf Energy Center Project, Santa Clara County, California.”  Overall, this document was well prepared and served as useful source material for Linda Spiegel’s PSA.  However, I found some problems with the CH2MHILL document.  For example, California ground squirrels are reported to occur primarily on the western bank of Fisher Creek (page 1-12), and to not occur on the center portion of the site (page 2-11).  This is not the case.  Contrary to the claim made on page 2-11, construction of the MEC will not avoid potential aestivation habitat for California tiger salamander.  California ground squirrels occupy the entire upland area where the applicant proposes to build Metcalf Energy Center, and these squirrels are abundant to the top of Tulare Hill.  The widespread distribution of California ground squirrels is significant because their burrows serve as habitat for California tiger salamanders and red-legged frogs.  In Table 1 (page 2-4), the potential impacts to these two species are downplayed because the impacts avoid aquatic habitat.  Both the California ground squirrel and the red-legged frog require animal burrows, principally ground squirrel burrows, in upland areas away from the aquatic environment of streams such as Fisher Creek.  Contrary to the claim made on page 2-11, construction of the MEC will not avoid potential aestivation habitat for California tiger salamander.

 

            The likelihood of red-legged frogs occurring in Fisher Creek is downplayed on page 2-11 because bullfrogs occur there.  Bullfrogs do not necessarily exclude red-legged frogs, even though they prey on tadpoles of red-legged frogs. The minimization of the potential significance of impacts on irreplaceable biological resources, whether intentional, accidental, or due to institutional bias, violates the spirit as well as the letter of CEQA’s foremost principle.  To comply with CEQA, this minimization must be avoided.

 

            I disagree with the conclusion on page 4-4 that because the effluent stacks of the MEC would be below the elevation of Tulare Hill, and because transmission lines already exist in the area, migrating birds would be unlikely to collide with these stacks.  This is a perfect example of the tendency to minimize the potential significance of the project’s impacts.  It is also an example of going out of one’s way to come up with creative ideas to minimize that significance, which is directly opposite to the foremost principle of the CEQA statutory scheme.  Under CEQA, it is far more appropriate to creatively ideate in the areas of thoroughness in assessing potential impacts and coming up with effective measures capable of avoiding or mitigating those impacts.  For example, during my visit of May 2, 2000, I found an injured Common Raven at the base of one of the transmission towers on Tulare Hill (Photo 11).  I draw the reasonable inference that this raven was injured by colliding with the tower or the wires.  Just because this raven was removed from the candidate pool of birds that can collide with the MEC’s stacks does not preclude other individuals or other avian species from doing so.  Manville (2000) and Hoving and Sealy  (1987) report disturbing fatality rates due to avian collisions with tall, lit towers.  I recommend that CH2MHILL not downplay the significant threat posed by MEC’s stacks to nocturnally migrating birds.  I also recommend that the collision hazard be reduced to the extent possible and that it be factored into the formulation of mitigation.

 

Direct Impacts

 

            At this early stage, I generally agree with Linda Spiegel’s assessment of direct impacts, but I would add impacts that include the following.  The power plant, laydown area, and access roads will destroy the ground squirrel burrows there.  CH2MHILL (2000) is incorrect to conclude that this area is so disturbed by dogs that California ground squirrels do not occur in abundance there.  Again, this is another example of taking the wrong perspective aimed at trivializing the severity of impacts, rather than maximizing environmental protection, as CEQA requires.  California ground squirrels occupy the extent of the upland area at this location.  If California tiger salamanders or red-legged frogs aestivate in those burrows, then they will be destroyed as well, and their habitat will be taken.

 

Indirect Impacts

 

            At this early stage, I generally agree with Linda Spiegel’s assessment, although I suspect, among other things, that noise and light levels will be more disruptive to wildlife than has been expected by the CH2MHILL and CEC biologists.   Artificial light levels can interfere with dispersal movements of mammalian carnivores (Beier 1995), the mating-related singing behaviors of birds (Derrickson 1988, Bergen and Abs 1997), the behavior of nocturnal frogs (Buchanan 1993), the nocturnal emergence and foraging activity of salmonids (Contor and Griffith 1995), the activities and predation risk of moths (Frank 1988, Rydell and Baagoe 1996), the congregatory behavior and distribution of certain species such as American Crows (Gorenzel and Salmon 1995), the orientation and mobility of nocturnal, non-volant insects such as ants (Klotz and Reid 1993) and crawlers (Summers 1997), and all of these documented effects are relevant to the environmental conditions at the proposed MEC site.  Far more work is needed before CEQA’s stringent standards are met.

 

Cumulative Impacts

 

            I agree with Linda Spiegel’s conclusion that the NOx  emissions from the proposed Metcalf Energy Center would create cumulative impacts to an already stressed ecosystem.    The fact that the South Bay Area already exceeds federal air quality standards forces the conclusion that any additional emissions of these pollutants would exacerbate an already intolerable situation.  Therefore, under CEQA not only must these potential impacts be deemed significant, but they must be carefully analyzed with regard to mitigation.  I agree with Spiegel’s recommendation that the applicant produce an cumulative impacts assessment.  The cumulative impacts assessment performed by CH2MHILL (2000: page 7-1) is entirely inadequate.  An adequate cumulative impacts assessment is absolutely essential, and failing to perform one would, in my opinion, violate CEQA.  I also recommend that the applicant perform this assessment according to the standards described by McCold and Holman (1995).  The preferred approach under CEQ is an identifiable, quantitative as well as qualitative, or performance-level assessment of a particular, potential environmental effect, which I think would be appropriate for assessments of cumulative impacts, and direct and indirect effects.  Such performance levels of environmental effect also need to be built into adaptive management and monitoring (discussed below).

 

            The estimated contours of NOx deposition illustrate the areas of vulnerability of soil-vegetation complexes, as well as their associated faunal assemblages.  However, it would be more helpful if the applicant would overlay these contours with a map depicting the various levels of sensitivity of soil-grassland complexes to pollutants.  Such an overlay can be used to forecast spatially-explicit impacts, much like Zhang et al. (1998) provided for excess nitrogen concentrations in ground water.  Zhang et al. (1998) compared the spatial distribution of nitrogen inputs for agricultural crops to the spatial distribution of soil leaching potential.  The inputs increasing the vulnerability of groundwater to nitrogen contamination and the inherent attributes of the soils made them more or less sensitive to such inputs.  Zhang et al. (1998) forecast impacts that closely matched the measured impacts (i.e., nitrogen concentration in ground water sampled from wellheads).  CH2MHILL should have the spatial data, software, and expertise to make such overlays and forecasts of impacts.  CEQA requires nothing less.  I recommend that this type of impact analysis be performed for NOx deposition.

 

Mitigation

 

        CEQA requires the mitigation measure to be roughly proportional to the project’s impacts.  Typically, proportional mitigation is estimated as a ratio of the area to be taken to the area to be conserved.  The area of the MEC, laydown area, and access roads is easy to calculate and it is easy to match with a conservation easement or fee title purchase of similar habitat conditions elsewhere.  Not so easy to calculate is the roughly proportional mitigation for the impacts of pollutants from stack emissions.  Which of the estimated contours of NOx deposition should the CEC use to determine the roughly proportional area that needs to be conserved as mitigation?  I recommend that, given the uncertainty of impacts, the entire area projected to receive NOx deposition should be considered when determining a roughly proportional mitigation.  From the standpoint of maximizing environmental protection, and avoiding and minimizing environmental harm, this is the safest approach and thus the one that CEQA requires.

 

        One of the mitigation options proposed by the applicant is to invest in a regional Habitat Conservation Plan (HCP).  In so doing, the applicant defers the formulation of this portion of the mitigation to a later date when an HCP might be prepared. Under CEQA, the EIR should justify the choice of a particular mitigation measure, and with few exceptions it is improper to defer formulation of the mitigation to a later date.  The mitigation measures need to be described explicitly and thoroughly in the EIR, along with the alternatives that were not chosen and an explanation as to why they were not chosen.  The same should be done in the applicant’s planning documents, in this case.

 

Additionally, HCPs are mitigation plans that facilitate the takings of endangered species more quickly and over larger areas than otherwise would be possible (Shilling 1997, Smallwood 2000, Smallwood et al. 1999).  The applicant essentially would be investing in a vehicle to foster more land conversions to houses and commercial uses.  An HCP would enable project proponents to destroy an even greater area of habitat than otherwise would occur.  These land conversions would increase demand for electrical energy, and might possibly benefit Calpine-Bechtel.  Therefore, I view this proposed mitigation as self-serving on the part of the applicant, but detrimental to the conservation of endangered and other species in the San Jose area.  This is simply not allowed under CEQA, and the failure to correct this glaring deficiency will surely expose the environmental documentation to a successful legal challenge based on the EIR’s inadequacy.

 

Adaptive Management

 

            The applicant proposes to implement adaptive management based on habitat responses to cattle grazing on Tulare Hill.  I encourage the CEC staff to demand more details of explicitly what this adaptive management would entail.  Based on my professional experience, many project proponents have been proposing adaptive management strategies, without a proper understanding of what an adaptive management strategy entails.  Adaptive management has been addressed in over 80 scientific publications, including several key papers and books (Holling 1978, Walters 1986, Lancia et al. 1996, McLain and Lee 1996).  This literature describes a well thought-out step-by-step approach to learning about a managed environment while also provisioning the manager(s) with options to adopt alternative management practices.  Management prescriptions, hypothesized environmental effects, and alternative management prescriptions are all specified prior to implementation.  Many project proponents appear to think of adaptive management as a remedial, trial-and-error approach to problem-solving (see also CH2MHILL 2000: page 5-8).  I encourage the CEC staff to determine whether the applicant really understands adaptive management.  To be certain that the applicant does understand it, it should be described in detail in the application documents, along with the details of an integrated monitoring program.

 

Monitoring

 

            Spiegel recommended that Calpine-Bechtel invest in an endowment fund to manage Tulare Hill in perpetuity, rather than settle for their proposed 30-year monitoring of impacts.  However, if the NOx deposition, or some other contaminant borne in the stack effluent, destroys the existing ecological relationships of Tulare Hill, then an endowment to manage Tulare Hill in perpetuity may be badly spent in perpetuity.  I encourage the CEC to consider recommending a more rigorously described monitoring program to ensure that we learn about the impacts of such an energy facility on the ecological community that is adapted to serpentine soils.  We also need to learn about the impacts of the 145-foot-tall stacks.  Monitoring their impacts on birds for three years will not be helpful if it turns out that intolerable numbers of migrating birds are colliding with the stacks.  Something would need to be done about it (see my discussions of Adaptive Management and Changed Circumstances).

 

Spiegel points out that serpentine-based rock represents 1% of California’s geologic base, yet contains 10% of California’s floral species.  The proposed Metcalf Energy Center is unique among energy facilities permitted by CEC in that it poses impacts to this serpentine-grassland complex that supports 10 times the average floral species richness across the other 99% of California. This proposed facility would also be unique for threatening the contiguity of habitat between the serpentine soils of the Santa Cruz Mountains and the Diablo Range.  Tulare Hill is recognized as the site of a satellite population of Bay Checkerspot Butterfly (USFWS 1998), so its degradation as habitat would contribute to habitat fragmentation of Bay Checkerspot Butterfly (Wilcox and Murphy 1985, Weiss cf in CH2MHILL 2000).  This is a serious problem, of which CEQA requires careful, in-depth analysis.  Much more work is needed to meet CEQA standards.

 

Given the lack of empirically based knowledge on NOx and other pollutants on serpentine-based communities, it would be especially prudent, in accordance with CEQA’s high standards, to establish a scientifically defensible monitoring program, including out-of-area control sites and both an impact-gradient design and before/after-control/impact (BACI) pairs design.  In other words, I recommend that distance to source be factored into the sampling design, as well as before and after sampling at both Tulare Hill and the control sites.  Without these types of designs, the monitoring program will be pseudoreplicated and unlikely to be informative (Hurlbert 1984).  Data collected in an adequate monitoring program would likely include the following variables:

 

·         Nitrogen deposition rates

·         Soil chemistry

·         Biological species composition

·         Plant biomass

·         Plant height

·         Plant density

·         Root depth

·         Incidence of disease

·         Numerical distributions of dependent fauna, including Bay Checkerspot Butterfly and Opler’s Longhorn Moth.

 

Additional variables would likely also be important, but they all need to be identified and described now, not later.  These variables would also need to be collected at elevations spanning the bottom to top of Tulare Hill and at locations spanning the north-south breadth of the Hill.  This design would need to be repeated on the comparison, control sites.  This type of a rigorous sampling design would cost more than $30,000/year.  Outside (non Calpine-Bechtel) employees should conduct the monitoring work.

 

CEC Staff Proposed Mitigation

 

I recommend that staff consider a 1:1 conservation-to-take ratio of the upland area to be converted to the power plant, laydown area and access roads.  This area may be disturbed, but upland areas next to water channels, disturbed or not, are important dispersal areas for wildlife.  This upland area could be used for aestivation and dispersal by California tiger salamander and red-legged frog.  Another nearby upland area that is adjacent to a stream should be conserved in equal area and in perpetuity (or until the hydrological system has changed locations and relief).

 

            Similar to the recommended endowment fund, I recommend that the CEC require a fund to be available for changed circumstances.  Alternative management strategies might be needed to mitigate the impacts of NOx depositions onto Tulare Hill.  For example, if exotic weeds colonize Tulare Hill in response to nitrogen augmentation, then Calpine-Bechtel might need to perform weed management in support of the food plants of Bay Checkerspot Butterfly and Opler’s Longhorn Moth.  In another example, if the MEC’s stacks cause an intolerable number of migratory bird collisions, then additional mitigation would be needed, or changes to the stacks might be needed.

 

Conclusions

 

            Although it is far too early for any final conclusions, generally speaking we have gotten off to a good start in this preliminary phase.  But a lot more hard, thorough, and unbiased (or biased in favor of the environment) work is necessary.

 

            Tables 1 and 2 summarize my comments and recommendations on this Preliminary Staff Assessment and on the applicant’s documents.

 

 

 

 

 

 

                                                  6-29-00

__________________________________                ______________

Shawn Smallwood, Ph.D.                                               Date

 

Table 1.  Status of PSA, and some of the consequence of existing shortfalls.

 

 

Defect of PSA and applicant documents

 

 

Evidence

 

Consequence

 

1.  Biological surveys are incomplete

 

No sampling methods were described for bats and small, non-volant mammals

 

The environmental setting remains incompletely described, thus the project impacts remain incompletely described

2. Baseline environmental conditions are too recent and narrowly described

Photos of the site from 1992 depict a more lush vegetation on Tulare Hill and the MEC site;  I found species that CH2MHILL and CEC biologists did not find

The environmental setting remains incompletely described, and the impacts are assumed smaller than they will really be

3.  The numerical/spatial distribution of ground squirrels was inaccurately described

Contrary to CH2MHIlLL (2000), I saw ground squirrels across the upland area and the extent of Tulare Hill

Ground squirrels are keystone species, and their burrows are used by California red-legged frog and California tiger salamander.  Therefore, the PSA underestimates potential impacts

4. The likelihood of California red-legged frogs occurring in Fisher Creek is underestimated

Ample scientific reports exist that refute the claim of CH2MHILL (2000) that the presence of bullfrogs negates the presence of California red-legged frogs

The PSA and supporting applicant documents downplay the potential of red-legged frogs to occur at this site

5.  The hazards of the MEC stacks and new power lines to birds are underestimated

During one of two site visits I found an injured Common Raven under a transmission tower;  Scientific reports are available to refute the claim that the stacks and transmission lines will not be a hazard because they will be below the highest elevation of Tulare Hill

The impacts to nocturnally migratory birds are downplayed and trivialized

6.  Indirect impacts are inadequately assessed

The effects of increased lighting and noise are mentioned, but the scientific evidence of their relative effects are is not

The impacts of increased lighting and noise are downplayed and underestimated

7.  Cumulative impacts are inadequately assessed

The standards of McCold and Holman (1995) and Smallwood et al. (1999) were unmet

Cumulative impacts are downplayed and underestimated

8.  The mitigation measures are misdirected and will be ineffective

The upland area next to Fisher Creek is not included in the conservation-to-take ratio, nor is the entire area of NOx deposition;  HCPs are mitigation plans for take permits and defer formulation of mitigation measures to a later date

The types of land being conserved do not match the lands being effected; Funding an HCP promotes more environmental impacts

9.  Adaptive management is improperly described

>80 scientific publications describe adaptive management as a structured process designed to enable learning of manipulated environments, and to respond with planned alternative prescriptions; Adaptive management described by the applicant appears to be remedial trial-and-error

The applicant’s plan will not enlighten the CEC about the effects of cattle management on Tulare Hill, so appropriate alternative management strategies will be unlikely applied

10.  The proposed monitoring plan is inadequate

The applicant describes no design attributes of the monitoring

Little will be learned from the monitoring and the lack of thresholds of significance will likely preclude any remedial actions to disturbing trends

 

 

 

 

 

 

 

Table 2.  My recommendations for amending the PSA and applicant documents prior to approval of the MEC.

 

 

Issue

 

 

Recommendation

1

Proper sampling methods should be implemented for bats and small, non-volant mammals, and at the appropriate spatial and temporal scales

2

The regional and temporal context of the site needs to be described more thoroughly and realistically, including the inter-annual cyclicity of the weather patterns, the likely former biological occupants of the site, and the possible future occupants after the site use is changed

3

Ground squirrel burrows should be counted and mapped, and a burrow probe used to view the interiors for special status species during repeat visits

4

The literature on California red-legged frogs and California tiger salamander should be reviewed for the impacts of bullfrogs on these species, and agency-protocol surveys should be made of Fisher Creek on site and up- and down-stream of the site

5

Monitoring of the avian impacts of existing power lines, maintained by PG&E, should be implemented immediately, or existing monitoring data examined (if they exist);  The literature and experts on avian impacts with tall structures should be consulted and a more realistic impact assessment conducted;  A reasonable mitigation plan should be formulated

6

The scientific literature on artificial noise and lighting should be thoroughly reviewed, and indirect impacts assessment conducted, and a reasonable mitigation plan formulated

7

A cumulative impacts assessment is needed, and should meet the standards of McCold and Holman (1995) and Smallwood et al. (1999);  The ecological indicators approach would be appropriate to assess the likely areas of impact from NOx deposition (see Zhang et al. 1998)

8

The proposal to fund an HCP as mitigation for this project should be rejected;  An endowment fund should be established for long-term, scientifically defensible monitoring, as well as changed circumstances;  Real adaptive management should be formulated and implemented;  Conservation-to-take ratios should factor in the entire area of NOx deposition, as well as the type of physiography converted to the MEC

9

The scientific literature on adaptive management should be reviewed, and a real adaptive management plan formulated for cattle management on Tulare Hill

10

A detailed monitoring plan should be described prior to project approval, and should include attributes of impact-gradient design and before/after-control/impact (BACI) pairs, detailed descriptions of variables to be measured, out-of-area control sites, identification of who will conduct the monitoring (qualified expert[s] not employed by Calpine-Bechtel), thresholds of significance for making management adjustments, and integration into a well-described adaptive management plan

 

 

 

 

References

 

Beier, P.  1995. Dispersal of juvenile cougars in fragmented habitat. Journal of Wildlife Management 59:228­237.

Bergen, F. and M. Abs.  1997. Etho-ecological study of the singing activity of the blue tit (Parus caeruleus), great tit (Parus major) and chaffinch (Fringilla coelebs). Journal fuer Ornithologie 138:451­467.

Buchanan, B. W.  1993. Effects of enhanced lighting on the behaviour of nocturnal frogs. Animal Behaviour 45: 893­899.

CH2MHILL.  2000.  Biological assessment for the Metcalf Energy Center Project, Santa Clara County, California.  Calpine Corporation and Bechtel Enterprises Holdings, Inc., Pleasonton, California.

Contor, C. R. and J. S. Griffith 1995. Nocturnal emergence of juvenile rainbow trout from winter concealment relative to light intensity.  Hydrobiologia 299: 179-183.

Derrickson, K. C. 1988. Variation in repertoire presentation in northern mockingbirds. Condor 90: 592­606.

Frank, K. D. 1988. Impact of outdoor lighting on moths: An assessment.  Journal of the Lepidopterists' Society 42: 63-93.

Gorenzel, W. P. and T. P. Salmon.  1995. Characteristics of American Crow urban roosts in California.  Journal of Wildlife Management 59: 638­645.

Holling, C. S. (ed.).  1978.  Adaptive environmental assessment and management.  John Wiley & Sons, New York.

Hoving, E. J. and S. G. Sealy.  1987.  Species and age composition of a sample of birds killed in Fall 1979 at a Manitoba [Canada] TV tower.  Prairie Naturalist 19: 129-134.

Hurlbert, S.H.  1984.   Pseudoreplication and the design of ecological field experiments. Ecological Monographs 54:187-211.

Klotz, J. H. and B. L. Reid.  1993. Nocturnal orientation in the black carpenter ant Camponotus pennsylvanicus Degeer (Hymenoptera: Formicidae).  Insectes Sociaux 40: 95­106.

Lancia, R.A., C.E. Braun, M.W. Collopy, R.D. Dueser, J.G. Kie, C.J. Martinka, J.D. Nichols, T.D. Nudds, W.R. Porath, and N.G. Tilghman.  1996.  ARM! For the future: adaptive resource management in the wildlife profession.  Wildlife Society Bulletin 24:436-442.

Manville, A.M., II.  2000.  The ABCs of avoiding bird collisions at communication towers: the next steps.  Proceedings of the Avian Interactions Workshop, December 2, 1999, Charleston, SC.  Electric Power Research Institute (EPRI), Palo Alto, California. 

McCold, L., and J. Holman.  1995.  Cumulative impacts in environmental assessments: how well are they considered?  The Environmental Professional 17:2-8.

McLain, R.J. and R.G. Lee.  1996.  Adaptive management: promises and pitfalls.  Environmental Management 20:437-442.

Rydell, J. and H. J. Baagoe.  1996. Street lamps increase bat predation on moths.  Entomologisk Tidskrift 117: 129­135.

Shilling, F.  1997.  Do Habitat Conservation Plans protect Endangered species?  Science 276:1662-1663.

Smallwood, K.S.  2000.  A crosswalk from the Endangered Species Act to the HCP Handbook and real HCPs.  Environmental Management 26, Supplement 1:23-35.

Smallwood, K.S., J. Beyea, and M. Morrison.  1999.  Using the best scientific data for endangered species conservation. Environmental Management 24:421-435.

Summers, C. G. 1997.  Phototactic behavior of Bemisia argentifolii (Homoptera: Aleyrodidae) crawlers. Annals of the Entomological Society of America 90:372-379.

Taylor, R.A.J. and L.R. Taylor.  1979.  A behavioral model for the evolution of spatial dynamics. Pages 1-28 in R.M. Anderson, B.D. Turner, and L.R. Taylor (eds.) Population dynamics. Blackwell Scientific Publications, Oxford, U.K.

USFWS (United States Fish and Wildlife Service).  1998.  Draft Recovery Plan for serpentine soil species of the San Francisco Bay Area.  Sacramento, California.

Walters, C.J.  1986.  Adaptive management of renewable resources. McGraw-Hill, New York.

Wilcox, B.A., and D.D. Murphy.  1985.  Conservation strategy: the effects of fragmentation on extinction.  American Naturalist 125:879-887.

Zhang, M., S. Geng, and K.S. Smallwood.  1998.  Nitrate contamination in groundwater of Tulare County, California.  Ambio 74:170-174.

 

 

Short Biography of Shawn Smallwood, Ph.D.

 

 

Dr. Shawn Smallwood is an ecologist with 15 years of professional experience with wildlife, ecosystems, and endangered species issues.  He has authored 73 publications, more than half of which were peer-reviewed.  He has served as Associate Editor  and Editorial Board Member of two international scientific journals, and he has reviewed many professional papers.  Dr. Smallwood understands what it takes to produce scientifically defensible research, survey and monitoring results, as well as impacts assessments.

 

Dr. Smallwood’s work has focused on both endangered species conservation and animal damage control.  He has worked to conserve such state or federally threatened species as red-legged frogs, giant garter snakes, Swainson’s Hawks, and Northern Goshawks.  He has also developed lethal and non-lethal methods to control pocket gophers and many other species.  Since 1985, he has also conducted the California track count for monitoring the statewide numerical and spatial trends of mountain lions, bobcats, coyotes, gray fox, black bear, and other mammalian Carnivores, as well as for deer.  Dr. Smallwood also developed quantitative methods to identify individual animals by their tracks, and he developed new monitoring and counting methods for pocket gophers and other fossorial animals.  He developed a new quantitative measure of treatment effect for use in animal damage control efforts.  He also conducted his Ph.D. thesis research on exotic species, particularly those that species of mammals and birds that invaded California and caused economic or environmental damage.

 

Dr. Smallwood also applies the tenets of landscape ecology to his work, and develops ecological indicators for use with GIS.  Dr. Smallwood has integrated GPS into his field studies, and has developed new statistical procedures for analyzing spatial data.  Dr. Smallwood is also one of the world’s leading experts on animal density and spatial patterns of distribution, and he has an extensive collection of density and numerical estimates published for many species of mammal, bird, reptile and amphibian.  He uses these estimates to predict patterns of spatial distribution for species with which he works in the field, and he uses them to interpret patterns observed in his field work.  Dr. Smallwood also works on operationalizing the habitat concept, and focuses research on how to accurately quantify the selection and use of habitat by animal species.

 

Much of Dr. Smallwood’s consulting work has centered on assessing the foundation of conclusions in environmental documents prepared by project proponents and their consultants.  He works to protect the interests of stake-holder groups by assessing the impacts of completed, ongoing and proposed projects and he assesses the adequacy of related environmental documents.  He has served as an expert witness in litigation against the nuclear weapons industry and the chemical manufacturing industry, as well as against ocean floor dredging and an airport expansion, for example.  Dr. Smallwood has written numerous expert reports, declarations, and depositions, and has testified often before attorneys, City Councils, County Supervisors and other governmental bodies.