**ATTACHMENT 1\
USAF Comments**

**USAF COMMENT #1**

**[PURPOSE]{.underline}**

Headquarters Air Force Space Command (AFSPC) and the 30^th^ Space Wing
at Vandenberg AFB (VAFB), hence referred to as the U.S. Air Force
(USAF), must ensure that management of natural resources on VAFB is
capable of supporting ongoing and future mission requirements by
minimizing unnecessary encroachment. Encroachment may be defined as any
action that reduces availability of the natural infrastructure (land,
water, and air resources) to support military operations and training.
Consequently, the USAF seeks exclusion of VAFB from critical habitat
designation for the La Graciosa thistle (*Cirsium loncholepis*) under
Endangered Species Act (ESA) § 3(5)(A) and 4(b)(2) of , 16 U.S.C.
1531-1544, as amended, based on the following reasons:

-   Designation of critical habitat would limit the amount of natural
    infrastructure that is available for mission execution and military
    training critical to national security;

-   The benefits of critical habitat exclusion outweigh the benefits of
    designation; VAFB exclusion would not result in the extinction of
    the subject listed species; and critical habitat designation would
    not provide additional protection to land essential to conservation
    of this species;

-   Existing and foreseen space and missile launch operations at VAFB do
    not constitute a long-term threat of destruction or adverse
    modification of suitable habitat for the thistle;

-   The 30^th^ Space Wing is currently revising an Integrated Natural
    Resources Management Plan (INRMP) to ensure adequate conservation
    and protection of the La Graciosa thistle. The INRMP contains
    special management activities that adequately address the
    conservation of suitable habitat important to long-term protection
    and recovery of the thistle and subsequently would preclude the need
    to designate critical habitat in Proposed Units 4, 5, and 6;

    -   The USAF must prepare and implement the INRMP in cooperation
        with the United States Fish and Wildlife Service (USFWS) and an
        appropriate State agency such as the California Department of
        Fish and Game in accordance with the Sikes Act, 16 USC 670(a),
        and the Administrative Procedures Act, 5 USC 500; the INRMP must
        "reflect the mutual agreement of the parties concerning
        conservation, protection, and management of fish and wildlife
        resources" as required by the Sikes Act"

    -   Furthermore, the USAF must comply with the ESA to conserve and
        protect threatened and endangered species and their habitat.

-   VAFB has proactively worked with USFWS staff in Ventura, CA to
    assess on-base distribution, develop management actions, and
    schedule surveys for the La Graciosa thistle in summer 2008, with
    another follow-up survey in 2009.

**[BACKGROUND]{.underline}**

On March 17, 2004, the USFWS published a Final Rule for designation of
critical habitat for La Graciosa thistle \[69 Federal Register (FR)
12553\]. The rule noted that ESA § 7(a) requires Federal agencies to
evaluate their actions with respect to any species that is listed as
endangered or threatened. The final critical habitat rule excluded lands
managed by VAFB, because the benefits of excluding lands managed by VAFB
outweighed the benefits of including them, which resulted in the entire
removal of three units and modification of two units. The economic
analysis recognized that costs would be incurred from delays associated
with reinitiating completed consultations after the critical habitat
designation.

La Graciosa thistle was first documented on VAFB in 1958 by Clifton
Smith. These plants co-existed with agricultural and VAFB activities at
that time. However, the 1969 flooding of the Santa Ynez River may have
significantly impacted and possibly extirpated that historical Santa
Ynez River Valley population in Proposed Unit 6 (see USAF Comment #2).
On San Antonio Terrace, Proposed Unit 5, La Graciosa thistle was
reported but misidentified (see USAF Comment #3). Subsequent
observations in the 1990s did not locate La Graciosa thistle on San
Antonio Terrace. Therefore, Proposed Unit 5 was not historically
occupied by La Graciosa thistle. According to the Proposed Rule, the
type locality may have occurred in one of two locations, one of which is
the mouth of San Antonio Creek (in Proposed Unit 4) and the other near
Orcutt. However, the more likely occurrence is near Orcutt based on
naming conventions of the Orcutt area, evidence supporting Alice
Eastwood (who collected the type specimen) traveling to that area, and
lack of evidence that she traveled to the mouth San Antonio Creek (see
USAF Comment #4).

With regards to ongoing conservation and management activities on VAFB,
an INRMP, which includes the Endangered Species Management Plan as an
attachment, and a Programmatic Biological Assessment consultation are
currently under development providing an opportunity to work closely
with the USFWS to ensure that the plan and conservation measures provide
a conservation benefit to La Graciosa thistle. In the interim, the
30^th^ Space Wing has initiated protocol surveys and a monitoring
program for the species.

Protocol-level surveys at VAFB are being conducted by recognized
botanists in all suitable habitats in Proposed Units 4, 5, and 6 with
the primary constituent elements that support La Graciosa thistle. All
areas mapped as Occupied At Time of Listing, Reported Occupied - Not
Documented, and Extirpated At Time of Listing have been surveyed this
year. The general search for La Graciosa thistle was restricted to
potential habitats, including wet dune swales, seeps, and riparian areas
along stream courses, and their margins. In some cases, especially
adjacent to wetland margins, special scrutiny was given to open areas
with relatively low frequency and cover provided by shrubs and
herbaceous perennials. Special attention was given to sites with species
reported to be indicators of swales or frequent associates of La
Graciosa thistle (CNDDB Rarefind, Version; other references). These
included willows (*Salix spp.*), rushes (*Juncus spp,*), tules (*Scirpus
spp.*), cattails (*Typha spp.*), common yarrow (*Achillea millefolium*
L*.*), yerba mansa (*Anemopsis californica* (Nutt.) Hook. & Arn.),
sedges (*Carex spp.*), coyote brush (*Baccharis pilularis* DC),
saltmarsh Baccharis (*Baccharis douglasii* DC), saltgrass (*Distichlis
spicata* (L.)), Menzies' goldenbush (*Isocoma menziesii* (Hook. & Arn.)
G. Nesom), marsh jaumea (*Jaumea carnosa (Less.) A. Gray*), silverweed
cinquefoil (*Potentilla anserina* L.), blackberry (*Rubus discolor*
Weihe & Nees, *R. ursinus* Cham. & Schldl.), and nettle (*Urtica dioica*
L.).

We reviewed literature, online and archived records, and images of
*Cirsium loncholepis* to develop a search strategy for potential
habitats and plants. We surveyed over 50 areas of varying size,
primarily within the three proposed units designated by the USFWS as
part of the Critical Habitat designation. We also attempted to visit all
potential sites proximate to the seven sites that were designated as
element occurrences by the California Natural Diversity Database
(CNDDB). Although we found numerous sites that provided suitable habitat
and were dominated by species reported to be associated with *Cirsium
loncholepi*s, we did not observe any evidence of the species'
occurrence. *Cirsium brevistylum* and *C. vulgare* were the only species
found at many potential sites, including most of the CNDDB element
occurrences. As of September 4, 2008, no La Graciosa thistle have been
identified in Proposed Units 4, 5, and 6 (VAFB 2008). Therefore, VAFB
does not currently have areas occupied by La Graciosa thistle and may
not have had the plant on base since the 1959 survey performed by
Clifton Smith.

**[Overview of Vandenberg Air Force Base]{.underline}**

VAFB is on the south-central California coast, approximately 55 miles
northwest of Santa Barbara. The 99,492-acre base extends along
approximately 42 miles of Santa Barbara County coastline and varies in
width from 5 to 15 miles. A 15,000-foot runway, boat dock, railway
system and several major highways service VAFB. The coastline, variable
elevations, unique habitats, and seasonal rainfall all contribute to
VAFB's distinct biological diversity, which is transitional between
northern/central and southern California.

VAFB operates as a missile test base and aerospace center, supporting
west coast launch activities for the USAF, Department of Defense (DOD),
National Aeronautics and Space Administration (NASA), and commercial
contractors. VAFB is headquarters for the 30th Space Wing, the Air
Force's Space Command unit that operates VAFB and the Western Test
Range. The Western Test Range begins at the coastal boundaries of VAFB
and extends westward from the California coast to the western Pacific
Ocean, including sites in Hawaii.

### [DISCUSSION]{.underline}

**1. ESA** § **4(b)(2) Analysis (National Security Implications,
Benefits Analysis, and Economic Impacts)**

ESA § 4(b)(2) requires USFWS to consider the impact on national security
as well as the economic impact and to assess the benefits of designating
versus not designating critical habitat on lands managed by the DOD.

***a. Mission Impacts and National Security Implications***

VAFB's unique location provides restricted airspace for space launches,
ballistic missile tests, aeronautical operations and military exercises.
DOD considers VAFB to be critical to national security. The USAF must
sustain the natural infrastructure to support ongoing and future
missions as well as to maintain native ecosystems. In cases where
mission and conservation activities conflict, mission activities must
continue while conserving natural resources to the greatest extent
practicable. The majority of the property on VAFB consists of native
vegetation that is infrequently disturbed.

Designation of critical habitat on VAFB would generally reduce the
availability of unencumbered, natural infrastructure to support missile
operations and essential maintenance activities. Short-notice,
mission-critical activities not previously analyzed may be delayed to
conduct ESA §7 consultations when/if they may affect potentially
suitable habitat that has not been observed to be occupied by La
Graciosa thistle.

***b. Benefits Analysis***

1). [Potential benefits of designating critical habitat]{.underline}

Potential benefits of designating critical habitat for La Graciosa
thistle on VAFB are limited due to our comprehensive natural resources
management program and availability of suitable habitat on VAFB.
Furthermore, La Graciosa thistle is not known to occur on VAFB.
Designation of critical habitat is more beneficial on lands where no
proven, long-term conservation and management regime exists and where
other Federal protections do not apply.

[2). Benefits of not designating critical habitat]{.underline}

Designation of critical habitat on VAFB would provide no additional
benefit to La Graciosa thistle for several reasons. First, VAFB is
developing an Endangered Species Management Plan for La Graciosa Thistle
in cooperation with the USFWS. Approval of the management plan will
ensure that conservation measures are implemented to enhance recovery of
the species. This management plan will be incorporated into the INRMP.
In addition, Federal lands are subject to other Federal environmental
laws that aim to conserve natural resources. Those regulations result in
overlapping protections that collectively ensure sufficient quantity and
quality of resources.

For example, the National Environmental Policy Act (NEPA), 42 U.S.C.
4332 requires consideration of the impact of proposed activities on the
environment and to human health and safety. USAF policy, codified in 32
CFR Part 989, *The Environmental Impact Analysis Process (EIAP),*
provides critical planning guidance to ensure compliance through the
administrative procedures of NEPA. Long-term impacts to potentially
suitable habitat at VAFB would typically result from construction. When
these proposed actions are determined through ESA §7 consultation to
affect threatened or endangered species and/or occupied habitat,
appropriate conservation measures are established in the USFWS
biological opinion and reflected in the NEPA document to minimize short-
and long- term effects. Most operation and maintenance activities, such
as mowing, result in minor impacts that are often minimized by
implementing best management practices and monitoring.

Other benefits of not designating critical habitat include:

-   Reducing encroachment on national priority missions and national
    security.

-   Reducing administrative burdens and costs associated with
    unnecessary consultations. Limited resources are better spent on
    actual implementation of ecosystem management activities.

***c. Economic Impact***

Designating large areas of VAFB as critical habitat would result in
additional ESA Section 7 consultation requirements for activities in
these areas that would otherwise have no effect on threatened and
endangered species or occupied habitat. Specifically, for those proposed
actions where an environmental assessment (EA) would suffice, critical
habitat designation may raise the level of required environmental
analysis. This additional analysis would unnecessarily delay projects
and increase financial costs as well as costs of time and staff. For
example, the cost of an EA at VAFB ranges from \$50K to \$100K. The cost
of an Environmental Impact Statement (EIS) can be as much as \$1
million. In addition to preparing an EA for activities proposed within
critical habitat, the USAF would also need to prepare biological
assessments and other data gathering to support ESA Section 7
consultations. Assuming that USAF staff spend at least 1 hour per day
for the duration of an ESA Section 7 consultation, it could add another
\$10K in costs for manpower.

**2. Integrated Natural Resources Management Plan (INRMP) Substitution**

The National Defense Authorization Act for Fiscal Year 2004 (Public Law
108-136) amended ESA §4(a)(3), imposing a limitation on designation of
critical habitat on DOD lands. Specifically, the Secretary of Interior
shall not designate as critical habitat any lands or other geographical
areas owned or controlled by DOD, or designated for its use, that are
subject to an INRMP prepared under section 101 of the Sikes Act (16
U.S.C. 670a), if the Secretary of the Interior determines in writing
that the plan provides a benefit to the species for which critical
habitat is proposed for designation and that not designating critical
habitat on DOD lands would not lead to extinction of the species. INRMPs
must meet the following criteria to preclude designation of critical
habitat on DOD lands:

-   The INRMP provides a conservation benefit;

-   The INRMP provides assurance that the management plan will be
    implemented; and

-   The INRMP provides assurance that the conservation effort will be
    effective.

Under the Sikes Act (16 U.S.C. 670a), "cooperative preparation" of the
INRMP is required with USFWS and the appropriate State fish and wildlife
agency such as the California Department of Fish and Game. The act
directs that "the resulting plan for the military installation shall
reflect the mutual agreement of the parties concerning conservation,
protection, and management of fish and wildlife resources." VAFB will
address how the INRMP will address each of all criteria and provide
specific management intentions for La Graciosa thistle.

***a. The INRMP provides a conservation benefit***

The VAFB INRMP implements principles and practices of ecosystem
management and biodiversity conservation to address these issues not
only on VAFB lands, but also within an eco-regional context. These
ecosystem management principles and guidelines require VAFB to:

-   Maintain and improve ecosystem sustainability and native biological
    diversity;

-   Administer by considering ecological units and time frames;

-   Support sustainable human activities;

-   Develop an ecosystem health vision;

-   Develop priorities and reconcile conflicts;

-   Develop coordinated approaches to work toward ecosystem health;

-   Use the best science available;

-   Use benchmarks to monitor and evaluate outcomes;

-   Use adaptive management; and

-   Implement thorough installation plans and programs.

VAFB invests significant resources to implement the INRMP. While the
plan has been revised numerous times over the years, it has never been
formally approved by USFWS. Despite this, the plan has historically and
presently served as the foundation for implementation of conservation
measures across the installation using an ecosystem based management
approach. For example, since fiscal year 2002 VAFB has invested
approximately \$17.42M in ecosystem management. Ecosystem management
activities have direct and indirect conservation benefits for the La
Graciosa thistle. This ongoing investment results in conservation of
large areas of quality, contiguous dune, riparian and upland habitat.

Additionally, the Sikes Act requires VAFB to ensure sufficient numbers
of professionally trained personnel to manage natural resources and
provide enforcement under its INRMP. VAFB maintains a highly-qualified
staff consisting of wildlife biologists, rangeland specialists,
botanists, and conservation law enforcement officers. VAFB also supports
a USFWS position located at the USFWS Ventura Office. This position is
funded to provide technical and regulatory assistance to VAFB.

***b. The INRMP provides assurance that the management plan will be
implemented***

The INRMP assures implementation of the management plan through annual
review requirements, mandatory tracking of project execution, and
specifications that call for coordination of projects that may impact
native ecosystems. Furthermore, the INRMP contains conservation and
management activities that are programmed and budgeted for funding.
INRMP implementation is required for regulatory and statutory
compliance. INRMP activities are programmed to maintain compliance with
specified timelines and implementation schedules. Activities that will
result in non-compliance with federal or state requirements if not
implemented are programmed at the highest rated risk level. Funding
priorities are based on potential risk to the military mission and to
natural resources. Higher risk items receive priority over lower risk
items. Generally, INRMP and ESA requirements are considered "must fund"
requirements.

INRMP activities requiring fiscal resources may also be funded with
revenues generated from selling hunting and fishing permits, timber and
other forest product sales, and grazing and cropland outleases. A large
portion of VAFB's conservation law enforcement program is funded by
selling hunting and fishing permits. INRMP goals and objectives are also
met through non-traditional resources such as cooperative agreements,
volunteers, prison labor, non-governmental organizations, academic
institutions, and mitigation dollars provided by non-Air Force tenants
and program activities. VAFB maintains several cooperative agreements
with non-governmental, not-for-profit organizations to enhance
capabilities.

INRMP implementation is determined by assessing whether or not specific
INRMP and strategic plans goals and objectives were met. This
determination is made by coordinating with the USFWS and California
Department of Fish and Game (CDFG).

***c. The INRMP provides assurance that the conservation effort will be
effective***

INRMP effectiveness is assured through a combination of internal and
external assessments and implementation of adaptive management
principles. All Air Force installations conduct internal Environmental
Safety and Occupational Health Compliance Assessment and Management
Program (ESOHCAMP) each year and our Major Command (MAJCOM) conducts one
externally every third year to assess compliance with environmental
regulatory and statutory requirements. INRMP implementation is assessed
as part of the ESOHCAMP natural resources protocol. ESOHCAMP
non-compliance findings are provided to installation commanders to help
them understand where they need to focus their resources. Findings also
support long-term programming, planning, budgeting, and annual resource
allocation decisions.

In addition to ESOHCAMP, VAFB applies adaptive management strategies
during annual INRMP revisions and five-year review requirements. INRMP
revision and review is closely coordinated with the USFWS, National
Marine Fisheries Service, and the CDFG, at which time program goals,
objectives, and projects may be revised to improve effectiveness.

**[CONCLUSION]{.underline}**

In summary, the USAF requests that VAFB be excluded from designation of
critical habitat for the La Graciosa thistle because the INRMP and its
Endangered Species Management Plan, which are being prepared with USFWS
cooperation, meets or exceeds protection for this species that critical
habitat designation would provide. In addition, critical habitat
designation establishes unnecessary regulatory burdens and costs and
could potentially impact ongoing and future national defense mission
activities; therefore, the benefit of not designating critical habitat
outweighs potential benefits. The VAFB Preliminary Draft Endangered
Species Management Plan for La Graciosa thistle and the Draft INRMP will
provide conservation benefits to the species and suitable habitat.
Excluding VAFB from critical habitat would not lead to extinction of La
Graciosa thistle.

**[REFERENCE]{.underline}**

Vandenberg Air Force Base (VAFB). 2008. Threatened and Endangered Plant
Surveys: La Graciosa thistle (*Cirsium loncholepis*), a federally
endangered species, July 15 -- September 3, 2008. Prepared by the Santa
Barbara Botanic Garden, Santa Barbara, CA

**USAF COMMENT #2**

The Proposed Rule did not note the 1969 flood of the Santa Ynez River
that may have significantly impacted and possibly extirpated the
historical Santa Ynez River Valley population of the La Graciosa thistle
in Proposed Unit 6 on VAFB (See USAF photos below). During a series of
storms in January and February 1969, the Santa Ynez River reached a
stage of 24.2 feet (7.4 meters) with a maximum discharge of 80,000 cubic
feet per second (2,264 cubic meters per second) near Lompoc (USGS 1996).
More than 100 million tons of sediment was flushed out of the Santa Ynez
Mountains. The 1969 flood is key to properly assess activities that may
have adversely affected the historical population. The river has not
reached this level since 1969, and improvements at Bradbury dam in 2000
have increased the capacity of Lake Cachuma to reduce the incidence
major spill events.

*1969 Flood, Santa Ynez River, Vandenberg AFB photos at the vicinity of
the historical population of Cirsium loncholepis.*

![](media/image1.jpeg){width="6.154861111111111in"
height="5.095138888888889in"}

![](media/image2.jpeg){width="5.875694444444444in"
height="4.763194444444444in"}

![](media/image3.jpeg){width="5.947916666666667in"
height="4.810416666666667in"}

![](media/image4.jpeg){width="6.1194444444444445in"
height="4.933333333333334in"}

**[Reference]{.underline}**

USGS. 1996. California Hydrologic Data Report, Santa Ynez River at
Narrows. Retrieved from
[http://ca.water.usgs.gov/archive/waterdata/96/11133000.html on 27
August
2008](http://ca.water.usgs.gov/archive/waterdata/96/11133000.html on 27 August 2008).

**USAF COMMENT #3**

With regards to the Reported Occupied, Not Documented localities in
Proposed Unit 5 (San Antonio Terrace), VAFB obtained information to
verify that another plant was misidentified as the La Graciosa thistle
on VAFB, buttressing our contention that critical habitat designation is
not necessary on VAFB. In a biological assessment conducted in support
of the MX Test Facility project (USAF 1980), the assessment indicated
observations of La Graciosa thistle during the plant surveys in 1979.
However, these observations later proved erroneous. Thomas Mulroy, who
assisted with identification of La Graciosa thistle on that project,
conveyed the following in an email to VAFB:

The information from the M-X missile project was based on
misidentifications caused partly by the timing of the surveys. The error
wasn't discovered until we saw the plants in flower after the reports
had been written and submitted. This was in 1979 or so. As I recall the
species we observed turned out to be C. brevistylum, which at the time
was relatively abundant in the mesic habitat around dune swales on San
Antonio Terrace, where we were working. I've carried around that M-X
report for years through every office move, but for some reason I can't
put my fingers on it now. I'm sure it will turn up. Ann Howald did the
surveys and the initial plant write-ups for the project and I did the
Q/A and contributed to the misidentification I'm sorry to say.

In 5 years of work between 1990 and 1995 in the same general San Antonio
Terrace area we did not see C. loncholepis.

(Mulroy 2008)

In addition, Ann Howald, who was part of the survey team, reported that
she is now convinced that these plants were actually misidentified *C.
brevistylum* populations and not *C. loncholepis* (Hendrickson 1990);
vegetative material only was present and erroneously attributed to *C.
loncholepis*. Based on verification that the La Graciosa thistle was
misidentified in Proposed Unit 5 and that field work done between 1990
and 1995 did not find the thistle, the La Graciosa thistle did not
historically occur in Proposed Unit 5, as reported.

**[Reference]{.underline}**

Hendrickson, Beth. 1990. Report on [Cirsium loncholepis]{.underline} for
The nature Conservancy: Current status of populations and some
ecological observations.

Mulroy, Thomas. 2008. Email correspondence on Cirsium loncholepis on
Vandenberg, September 9, 2008.

U.S. Air Force. 1980. Biological Assessment for Proposed MX Test
Facility Locations on Vandenberg Air Force Base, California, Volume 1.

**USAF COMMENT #4**

In reference to the type locality of the La Graciosa thistle, there is a
great amount of speculation attributing the type collections to the
mouth of San Antonio Creek. There is convincing evidence that La
Graciosa was a small oil town established in 1868 south of modern-day
Orcutt; and, therefore, was not located at the mouth of San Antonio
Creek. The town of La Graciosa was torn down in 1877 (Hendrickson 1990,
Durham 2000). Alice Eastwood (1859-1953), who collected the type
specimen for La Graciosa thistle in 1906, visited her friend Ida May
Blochman in 1896, collected around that time and visited the Santa Maria
area in 1906 (Hendrickson 1990). Graciosa and Graciosa Canyon have been
mapped south of Orcutt on a 1905 topographic map (UC Berkeley 2004). The
22^nd^ Annual Report of the USGS reports La Graciosa Hills on what is
currently Graciosa Ridge (Figure 1) and La Graciosa Creek is referenced
although not mapped on what is presently Harris Canyon (Eldridge 1901,
USGS 1959). Orcutt planning documents also placed La Graciosa south of
Orcutt (Santa Barbara County 1995).

References to the mouth of San Antonio Creek as the type collection
locality by Alice Eastwood are not substantiated with documented
evidence of Alice Eastwood traveling in that area. The closest
documented location on the 1905 U.S. Geological Survey map (Palmer 1999)
is Narlon, 1.5 miles (2500 meters) to the northeast, and Tangair, three
miles (4800 meters) to the southeast, with the train crossing San
Antonio Creek 0.9 mile (2850 meters) inland (Narlon and Tangair could
have possibly been passenger train stations, but they are currently rail
maintenance stations). No stations or towns documenting Graciosa or La
Gracioa are documented at the San Antonio Creek river mouth or on the
terrace. If Alice Eastwood collected at the mouth of San Antonio Creek,
why are there no journal references of traversing San Antonio Terrace
dunes or specimen collections in the dunes where she would have walked
through in order to collect at the river mouth? Documentation of the
town of La Graciosa, Graciosa, and Alice Eastwood's travel localities
provide strong evidence that the type collection for La Graciosa thistle
was near Orcutt and not within San Antonio Terrace.

The river mouth may have suitable habitat for La Graciosa thistle.
However with speculation about the affilation of "La Graciosa" at the
mouth of San Antonio Creek (Keil and Holland 1998, Oyler *et al*. 1995,
Smith 1976, Smith 1998), the question needs to be investigated of
whether Alice Eastwood consistently named type collections after name
variations described by Fray Juan Crespi and Pedro Font in 1769 and 1776
where they visited, or whether Alice Eastwood's naming convention of
type collections were more consistent with other documented maps and
places she traveled as mentioned above. Fray Juan Crespi describes a
lagoon as Laguna Graciosa in 1769 and may have visited the mouth of San
Antonio Creek. There is evidence that the Anza trail may not have
traveled along the dunes and river mouth but instead, they traveled
inland (Figure 2).

Based on the existing information, there is no evidence that the type
collection of La Graciosa thistle was made in Proposed Unit 4 at the
mouth of San Antonio Creek and extirpated at the time of listing as
indicated in the Proposed Rule.

**[Reference]{.underline}**

Durham, David L., 2000. Durham\'s Place Names of California\'s Central
Coast: Includes Santa Barbara, San Luis Obispo, San Benito, Monterey &
Santa Cruz Counties, Quill Driver Books, pp 81.

Eldridge, G.H. 1901. Asphalt and Bituminous Rock Deposits of the United
States, 22^nd^ Annual Report of the US Geological Survey, 1900-1901, pp.
424-425.

Hendrickson, Beth. 1990. Report on [Cirsium loncholepis]{.underline} for
The Nature Conservancy: Current status of populations and some
ecological observations.

Keil, D.J. and Holland, V.L. 1998. Documented Flora of Vandenberg Air
Force Base. The Nature Conservancy, pp 83-84.

Oyler, D.O., Holland, V.L., and Keil, D.J. 1995. Rare Plants of
Vandenberg Air Force Base. The Nature Conservancy, pp 1-76.

Palmer, K. 1999. Central Coast Continuum---From ranchos to Rockets, A
Historic Overview for an Inventory and Evaluation of Historic Sites,
Buildings, and Structures, Vandenberg AFB, CA. 1905 USGS map on pp. 71.

Santa Barbara County. 1995. Orcutt Community Plan Update, Proposed Final
Environmental Impact Report 95-EIR-01, Section 5. Website
<http://longrange.sbcountyplanning.org/planareas/orcutt/orcutt.php>
accessed September 2008

Smith, Clifton F. 1976. A Flora of Santa Barbara Region, California.
Santa Barbara Museum of Natural History, Santa Barbara, CA, pp. 282.

Smith, Clifton F. 1998. A Flora of Santa Barbara Region, California,
Second Edition. Santa Barbara Botanic Garden & Capra Press, Santa
Barbara, CA, pp. 153-154.

UC Berkeley. 2004. Historic Topographic Maps of California, Earth
Sciences and Map Library, University of California, Berkeley. Lompoc
Quad 1905. Website
<http://www.lib.berkeley.edu/EART/CA/CA_125k/30_minute2.html#lompoc125k>
accessed September 2008.

U.S. Geological Survey (USGS). 1959. Orcutt Quadrangle, 7.5 Minute
Series (Topographic), Photo revised 1964 & 1974.

Figure 1. Map with La Graciosa Hills near Graciosa (Eldridge 1901).

![](media/image5.jpeg){width="6.5in" height="3.895138888888889in"}

Figure 2.

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height="8.425694444444444in"}