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www .epsys.com

Phone: 510-841-9190

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S A C R A M E N T O

Phone: 916-649-8010

Fax: 916-649-2070

D E N V E R

Phone: 303-623-3557

Fax: 303-623-9049

FINAL DRAFT REPORT

ECONOMIC ANALYSIS OF CRITICAL HABITAT

DESIGNATION FOR THE CALIFORNIA GNATCATCHER

Prepared for: 

Division of Economics

U.S. Fish and Wildlife Service 

4401 N. Fairfax Drive

Arlington, VA 22203

Prepared by: 

Economic & Planning Systems, Inc.

Under subcontract to:

Industrial Economics, Incorporated 

2067 Massachusetts Avenue

Cambridge, MA 02140

February 24, 2004

EPS #12594 
TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY AND REPORT ORGANIZATION ............ ............ ...... 1

Introduction ............ ............ ............ ............ ........ 1

Organization of Report ............ ............ ............ ........... 2

Critical Habitat Designation ............ ............ ............ ....... 2

Summary of Framework and Approach ............ ............ ........ 4

General Analytic Steps ............ ............ ............ ........... 6

Key Findings ............ ............ ............ ............ ........ 7

I. INTRODUCTION & BACKGROUND ............ ............ ............ . . 24

Species Description and Distribution ............ ............ .......... 25

Proposed Critical Habitat Designation ............ ............ ......... 25

Framework for the Analysis ............ ............ ............ ...... 31

Creation of Habitat Conservation Plans ............ ............ ........ 39

Other State and Local Laws ............ ............ ............ ...... 41

Time Delays and Regulatory Uncertainty ............ ............ ...... 42

References ............ ............ ............ ............ ......... 47

Potentially Affected Activities ............ ............ ............ .... 49

II. REGULATORY BACKGROUND ............ ............ ............ ...... 51

Baseline in Areas Proposed for Critical Habitat ............ ............ . 52

Baseline in Areas Proposed for Exclusion ............ ............ ...... 63

Potential Future Baseline Regulations ............ ............ ......... 70

Western Riverside County Multi-Species Habitat Conservation Plan ...... 71

Southern Orange County HCP/NCCP ............ ............ ......... 71

Northern San Diego County Multiple Habitat Conservation Plan ......... 72

North County Subarea Plan to the MSCP ............ ............ ...... 72

City of Palos Verdes HCP/NCCP ............ ............ ............ . 73

Other Future Regional HCPs ............ ............ ............ ..... 73
TABLE OF CONTENTS (continued)

PAGE

III. DESIGNATION IMPACT ON PRIVATE LAND DEVELOPMENT ............ ....... 74

Analytical Approach and Methodology ............ ............ ........ 74

Projected Land Development with a Federal Nexus ............ ......... 77

Regulatory Baseline and Section 7 Compliance ............ ............ . 82

Significance for Regional Real Estate Market ............ ............ ... 88

Estimated Project Modification Costs ............ ............ .......... 91

Estimated Administrative Consultation Costs ............ ............ . . 96

Summary of Private Land Development Impacts ............ ........... 98

IV. IMPACT OF PROPOSED DESIGNATION ON PUBLIC LAND DEVELOPMENT ........ 99

Transportation and Road Construction ............ ............ ........ 99

Local and Regional Water Projects ............ ............ ........... 109

Municipal Power Supply ............ ............ ............ ....... 113

Federal Land Management ............ ............ ............ ..... 117

Bureau of Land Management ............ ............ ............ .... 119

Federal Emergency Management Options ............ ............ .... 120

Military Property and Operations ............ ............ ............ 121

Habitat Conservation Plans ............ ............ ............ ..... 128

Reinitiation of Section 7 Consultations ............ ............ ........ 129

Tribal Lands ............ ............ ............ ............ ...... 130

V. OTHER ECONOMIC EFFECTS ............ ............ ............ ...... 131

Time Delay ............ ............ ............ ............ ....... 131

Uncertainty/Stigma ............ ............ ............ ............ 134

CEQA-Related Indirect Costs ............ ............ ............ ... 138

VI. SMALL BUSINESS REGULATORY ENFORCEMENT ACT ............ .......... 141

VII. ENERGY IMPACT ANALYSIS ............ ............ ............ ....... 155

Section 7 Effect on Energy Distribution Costs ............ ............ . . 156
TABLE OF CONTENTS (continued)

PAGE

VIII. UNFUNDED MANDATES ANALYSIS ........... . ........... . ........... . . 159

IX. POTENTIAL BENEFITS OF PROPOSED CRITICAL HABITAT ........... . ........ 165

Abbreviation and Acronym Index ............ ............ ............ ........ 4

APPENDICES

A. Demographic Projections and Methodology

B. U.S. Army Corps Jurisdiction Assumptions, Methodology, and GIS Analysis

C. Summary of Selected Section 7 Biological Opinions

D. Real Estate Market Data and Land Value Calculations

E. Project Modification Cost Calculations for Private Land Development

F. Consultation Cost Model

G. Project Modification Cost Calculations for Public Land Development

H. Time Delay Calculations

I. Small Business Regulatory Effect Analysis Calculations

J. Benefits
LIST OF TABLES AND FIGURES

PAGE

Table 1: Estimated Costs of the Proposed Designation by Unit ............ ... 8

Table 2: Estimated Costs for Areas Proposed for Designation and Exclusion ... 9

Table 3: Administrative and Project Modification Costs by Project Type ...... 10

Table 4: Caveats to the Economic Analysis ............ ............ ....... 11

Table 5: Approximate Proposed Critical Habitat, Essential Areas, and

Excluded Areas ............ ............ ............ ........... 27

Table 6: Proposed Critical Habitat Acreage by City and Land Ownership .... 29

Table 7: Summary of Baseline Regulations ............ ............ ........ 64

Table 8: Calculation of Projected Growth Acres with a Federal Nexus ........ 78

Table 9: Projected Growth Acres by County ............ ............ ...... 80

Table 10: Calculation of Mitigation Acres Associated with Section 7 .......... 83

Table 11: Average Coastal Sage Scrub Mitigation Ratios by County ........... 87

Table 12: Regional Significance of Acres Impacted by Section 7 ............ ... 90

Table 13: Private Land Development Project Modification Costs ............ . 93

Table 14: Residential and Commercial Market Data ............ ............ . 94

Table 15: Coastal Sage Scrub Mitigation Bank Prices ............ ............ 95

Table 16: Private Land Development Costs ............ ............ ........ 97

Table 17: Public Land Development Costs ............ ............ ........ 100

Table 18: Biological Opinions for the Gnatcatcher at Camp Pendleton ........ 123

Table 19: Cost of Section 7 Time Delays ............ ............ .......... 134

Table 20: Upper-End Mitigation Ratios ............ ............ ........... 136

Table 21: Upper-End Mitigation – Section 7 Project Modification Costs for

Private Land Development ............ ............ ............ 138

Table 22: Estimated Annual Number of Small Businesses Affected by

Critical Habitat Designation ........... . ........... . ........... 143
Table 23: Estimated Annual Number of Small Governments Affected by

Critical Habitat Designation ........... . ........... . ........... 144

Table 24: Estimated Annual Effects on Small Businesses in

Land Development & Real Estate Industry (SIC Code 6552) ........ 145

Table 25: Estimated Annual Effects on Small Governments ........... . ..... 153

Table 26: Energy Impact Analysis Summary ........... . ........... . ...... 158

Table 27: Unfunded Mandate Reform Act (UMRA) Calculation Summary .... 161

Table 28: Physical/Biological Improvements Expected to Result from

Implementation of Section 7 of the Act ........... . ........... . . . 168

Table 29: Species Likely to Benefit From Coastal Sage Scrub Protection

Measures Associated with Critical Habitat Designation for

the Gnatcatcher ........... . ........... . ........... . .......... 173

FIGURES

Figure 1: Proposed Critical Habitat Units .................................. 3

Figure 2: Total Cost Distribution by Development Type ..................... 12

PAGE

LIST OF TABLES AND FIGURES (continued)
ABBREVIATION AND ACRONYM INDEX

Act The Endangered Species Act of 1973, as amended

ANF Angeles National Forest

BIA Bureau of Indian Affairs

BLM Bureau of Land Management

BOR Bureau of Reclamation

BO Biological Opinion

Caltrans California Department of Transportation

CEQA California Environmental Quality Act

CH Critical Habitat

CHD Critical Habitat Designation

CNF Cleveland National Forest

CSS Coastal Sage Scrub

DEM digital elevation model

DFG California Department of Fish and Game

DoD Department of Defense

EIR/EIS Environmental Impact Report/Environmental Impact Statement

EPS Economic & Planning Systems, Inc.

EUA Existing Use Area (under the Central/Coastal HCP/NCCP)

Fallbrook U.S. Naval Weapons Station Seal Beach, Detachment Fallbrook

FEMA Federal Emergency Management Agency

FHWA Federal Highway Administration

GIS Geographic Information Systems

HCP Habitat Conservation Plan

HLP Habitat Loss Permit

INRMP Integrated Natural Resource Management Plan

KV kilovolt

MCAS Marine Corps Air Station 

MHCP Multiple Habitat Conservation Plan (northern San Diego County)

MHPA Multiple-Habitat Planning Area (under the MSCP)

MSCP Multiple Species Conservation Plan (San Diego County)

MSHCP Multiple-Species Habitat Conservation Plan (western Riverside

County)

MWD Metropolitan Water District

NCCP Natural Community Conservation Plan
NRPPA North Ranch Policy Plan Area (under the Central/Coastal

HCP/NCCP)

PCEs primary constituent elements

RTP Regional Transportation Plan

SAIA Sikes Act Improvement Act

SANDAG San Diego Association of Governments Service

SBNF San Bernardino National Forest

SBREFA Small Business Regulatory Enforcement Fairness Act

SCAG Southern California Association of Governments

SCE Southern California Edison

SCGC Southern California Gas Company

SDG&E San Diego Gas & Electric

the Service United States Fish & Wildlife Service

SLA Special Linkage Area (under the Central/Coastal HCP/NCCP)

TCA Transportation Corridor Agency

UMRA Unfunded Mandate Reform Act

USACE United States Army Corps of Engineers

USFS U.S. Forest Service

USGS U.S. Geological Survey

USMC U.S. Marine Corps

ABBREVIATION AND ACRONYM INDEX (continued)
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

1

1 EXECUTIVE SUMMARY AND REPORT ORGANIZATION

INTRODUCTION

The purpose of this report is to identify and analyze the potential economic effects of

the proposed designation of critical habitat (CH) for the coastal California Gnatcatcher

6 (Polioptila californica californica), hereafter referred to as the gnatcatcher. The U.S. Fish

and Wildlife Service proposed CH for the gnatcatcher on April 24, 2003 for

approximately 495,795 acres of land in Los Angeles, Orange, Riverside, San Bernardino,

and San Diego counties in California. This report has been prepared by Economic &

Planning Systems, Inc. (EPS), under subcontract to Industrial Economics, Inc., for the

11 U.S. Fish and Wildlife Service's Division of Economics.

Section 4(b)(2) of the Endangered Species Act (the Act) requires the U.S. Fish and

Wildlife Service (Service) to designate CH on the basis of the best scientific data

available, after taking into consideration the economic effect, and any other relevant

16 effect, of specifying any particular area as CH. The Secretary of the Interior may

exclude areas from critical habitat designation (CHD) if the benefits of exclusion

outweigh the benefits of including the areas within CH, provided the exclusion will not

result in extinction of the species.

21 The focus of this economic analysis is on section 7 of the Act, which requires Federal

agencies to insure that any action authorized, funded, or carried out is not likely to

jeopardize the continued existence of any endangered or threatened species or result in

the destruction or adverse modification of CH. Federal agencies are required to consult

with the Service whenever they propose an action that may affect a listed species or its

26 designated CH. 

The Service published a determination of threatened status for the gnatcatcher on

March 30, 1993 (58 FR 16742). On October 24, 2000, the Service published a Final Rule

designating approximately 514,000 acres as CH(65 FR 63680). In response to a number

31 of lawsuits filed subsequent to the designation, the Service requested a remand of the
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

2

designation, which the U.S. District Court for the Central District of California granted

on June 11, 2002. The Court ordered the Service to complete a new proposed rule by

April 11, 2003, and held that the designation should remain in place until a new, final

regulation becomes effective. 

36 ORGANIZATION OF REPORT

This report is organized into six chapters. Following the Executive Summary, Chapter I

provides an introduction to this report, describes the species and its habitat, and lays

out the framework and methodology for the analysis. Chapter II describes the relevant

regulatory context, and its relationship to coastal sage scrub (CSS) habitat. Chapter III

41 focuses on the economic impact of section 7 on private development activities. Chapter

IV addresses the effects of section 7 on public land development activities. Chapter V

evaluates other categories of economic impact, including delay, uncertainty, and

indirect effects. Chapter VI presents the Small Business Regulatory Enforcement Act

analysis, Chapter VII presents the Energy Industry Effects analysis, Chapter VIII

46 presents an Unfunded Mandate Reform Act (UMRA) analysis, and Chapter IX

discusses the benefits of the proposed CHD.

CRITICAL HABITAT DESIGNATION

On April 24, 2003, the Service published a proposed rule in the Federal Register

outlining its proposal to designate CH for the gnatcatcher. The proposed rule

51 delineated 13 CH units in six counties in California – San Diego, Riverside, San

Bernardino, Orange, Los Angeles, and Ventura. The proposed designation consists of

approximately 495,795 total acres, which include 431,785 acres (87 percent) private land,

45,380 acres (9 percent) Federal land, and 18,630 acres (4 percent) State or local land. 

The proposed rule also identified an additional 264,280 acres of “essential” gnatcatcher

56 habitat that was proposed for exclusion from final CH boundaries because of either

existing special management considerations, or an evaluation of economic and other

relevant impacts. Proposed CH boundaries are shown in Figure 1.






	



















	


	
	
 

 	




   

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Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

4

SUMMARY OF FRAMEWORK AND APPROACH

This Draft Economic Analysis, provides an estimate of the economic effects of the

designation of CH, as proposed on April 24, 2003, for the gnatcatcher. These effects

include direct costs that result from compliance with section 7 of the Act, such as

66 administrative costs of completing informal and formal consultations with the Service

and the project modification costs occurring as a result of these activities. This analysis

also evaluates indirect effects of the designation, such as costs of project delays and

regulatory uncertainty, and costs associated with changes in implementation of other

laws such as the California Environmental Quality Act (CEQA).

71

This analysis does not consider any costs that would occur in the absence of the

designation, such as other land use regulation by Federal, State, or local governments. 

The one exception to this statement is the total cost associated with section 7, which

may result either from the listing of the species (the jeopardy standard) or from the

76 designation itself (the adverse modification standard). Because it can be difficult to predetermine the standard that drives a section 7 consultation, all costs related to the

implementation of section 7 are included in the total cost estimates presented in this

document.

81 The direct compliance costs mentioned above represent a reasonable approximation of

how society as a whole will be affected by the designation when compliance activity is

not expected to significantly affect housing or other markets. This analysis evaluated

the estimated impacts in relation to the regional housing market to determine whether

an analysis of changes in consumer and producer surplus within the market for new

86 homes would be appropriate.

Other economic effects considered in the analysis include the benefits of the designation

and distributional impacts on small entities, the energy industry, and local/tribal 

governments and private industry in accordance with the UMRA. Potential benefits of

91 the designation are discussed qualitatively.

This analysis estimates the economic effects of the proposed designation through 2025,

beginning on the publication date of the proposed rule.

This analysis differs significantly from the economic analysis completed in September

96 2000 in support of the Service’s original CHD for the gnatcatcher. Major differences are

described below.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

5

• Both analyses apply a baseline approach that compares the “world without

critical habitat” to the “world with critical habitat.” However, the earlier

101 analysis assumed that all costs associated with the listing of the species,

including impacts resulting co-extensively from the jeopardy provision of

section 7, were part of the baseline. This analysis acknowledges that given the

similarity in regulatory definitions between the terms “jeopardy” and “adverse

modification,” in practice it can be difficult to pre-determine the standard that

106 drives a section 7 consultation. In order to ensure that no costs of CH are

omitted, this analysis includes all section 7 costs, including those resulting solely

or co-extensively from the jeopardy standard. As a result, this analysis likely

overstates the costs associated with the proposed designation.

111 • Because the Service asserted that no project modifications would be requested

beyond those implemented to avoid jeopardy, the 2000 economic analysis found

that the designation would not result in project modification costs attributable to

CH. This analysis quantifies the costs of project modifications associated with

both the jeopardy and adverse modification standards.

116

• Both analyses identify potential additional costs associated with section 7

administrative activities, project delays, and regulatory uncertainty. These

impacts were discussed qualitatively in the 2000 analysis and are quantified in

this analysis.

121

• This analysis also considers potential indirect effects of the designation resulting

from the triggering of additional requirements under CEQA, and it addresses

potential impacts to the regional economy and the housing market.

126 • This analysis relies on a broader range of information/data obtained from a

number of different sources.

• The 2000 economic analysis reflected the final designation of 513,650 acres (i.e.,

areas proposed but ultimately excluded from the final designation were not

131 considered in the final economic analysis). This analysis considers potential

impacts resulting from the designation of 495,795 acres that are proposed for

inclusion in the final designation, as well as 264,280 acres that are proposed for

exclusion from the final rule.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

6

GENERAL ANALYTIC STEPS

136 This report relies on a sequential methodology and focuses on distilling the salient and

relevant aspects of potential economic impacts of the designation. These are the steps

followed in this analysis:

• Describing current and projected economic activity within and around the

141 proposed CH area;

• Identifying whether such activities are likely to involve a Federal nexus;

• For activities with a Federal nexus, evaluating the likelihood that these activities

146 will require consultations under section 7 of the Act and, in turn, result in any

modifications to projects.

• Estimating the direct costs of expected section 7 consultations, project

modifications and other economic impacts associated with the designation;

151

• Estimating the likelihood that current or future activities may require additional

compliance with other Federal, State, and local laws as a result of new

information provided by the designation;

156 • Estimating the likelihood that projects will be delayed by the consultation

process or other regulatory requirements triggered by the designation;

• Estimating the likelihood that economic activity will be affected by regulatory

uncertainty, and/or property values affected;

161

• Estimating the indirect costs of the designation, as reflected in the cost of

compliance with State and local laws, project delays, regulatory uncertainty, and

effects on property values;

166 • Estimating the potential fraction of total section 7 costs that likely would not

have occurred but for CHD (i.e., attributable solely to the designation);

• Assessing the extent to which CHD will create costs for small businesses as a

result of modifications or delays to projects;

171
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

1

Costs have been calculated using a 12 percent discount rate for private development projects and a 7

percent discount rate for public projects.

7

• Assessing the effects of administrative costs and project modifications on the

supply, distribution, and use of energy; and

• Determining the benefits that may be associated with CHD.

176

As noted above, this analysis considers both the efficiency effects and distributional

effects that could result from this designation. It begins by considering direct

compliance costs associated with the designation, as well as potential indirect effects,

such as those effects associated with compliance with other Federal, State, and local

181 laws, project delays, and impacts to property values. As necessary, regional economic

impacts are described, as are impacts on significantly affected markets. Impacts on

small entities and the energy industry are discussed separately, in Chapter VI and

Chapter VII, respectively. Impacts to local/Tribal governments and private industry

are discussed in Chapter VIII, in accordance with UMRA. Potential benefits of critical

186 habitat are discussed qualitatively, in Chapter IX.

KEY FINDINGS

This section summarizes the economic costs associated with section 7 implementation in

areas proposed for gnatcatcher CH. Summary descriptions of key findings – including

total costs, costs by unit, and costs by project type – are provided below. Summaries of

total estimated section 7 costs by proposed Unit are presented in Table 1.

1

191 Table 2

provides a comparison of total section 7 costs for areas proposed for designation versus

areas proposed for exclusion – these results are discussed briefly in the relevant unit

summaries, below (a more detailed summary of combined analytical results for areas

proposed for designation and exclusion is presented in Appendix H). Table 3

196 summarizes administrative and project modification costs by activity. Table 4

summarizes key assumptions employed in this analysis and the likely direction of bias

each assumption represents. Figure 2 shows total cost distribution by project type.
Table 1

Estimated Costs of the Proposed Designation by Unit (1)

Proposed Project Modification Administrative Delay Uncertainty Total

CH Unit Costs Costs (2) Costs Costs Cost Percent

Unit 1 $2,230,500 $387,500 $63,300 $1,333,000 $4,014,400 0.4%

Unit 2 $2,027,500 $281,500 $55,500 $1,168,600 $3,533,100 0.4%

Unit 3 $6,329,300 $532,500 $188,100 $3,959,300 $11,009,200 1.2%

Unit 4 $2,448,900 $266,700 $200 $3,300 $2,719,100 0.3%

Unit 5 $6,978,600 $709,000 $277,600 $5,841,900 $13,807,000 1.5%

Unit 6 $85,111,800 $966,100 $173,200 $2,817,900 $89,068,900 9.7%

Unit 7 $4,883,800 $83,200 $19,600 $319,700 $5,306,400 0.6%

Unit 8 $332,700 $116,400 $0 $0 $449,100 0.0%

Unit 9 $38,074,200 $392,500 $254,200 $3,950,100 $42,671,000 4.7%

Unit 10 $435,551,700 $3,069,900 $2,213,000 $19,072,900 $459,907,500 50.2%

Unit 11 $90,433,200 $297,300 $233,000 $2,400,900 $93,364,400 10.2%

Unit 12 $3,649,200 $64,900 $44,000 $271,800 $4,029,800 0.4%

Unit 13 $168,719,000 $1,723,800 $2,156,400 $12,858,000 $185,457,200 20.3%

Total Cost $846,770,400 $8,891,400 $5,678,200 $53,997,300 $915,337,200 100%

Annualized Cost (3) $105,461,200 $1,022,500 -- (4) $6,995,900 $113,479,600 --

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) Assumes discount rates of 12% for private development projects and 7% for public development projects.

(2) Average administrative consultation costs (low and high) were allocated among units in proportion to the number of projected growth acres 

in each unit with a Federal nexus (see Table 8).

(3) Represents the annual amount that is equivalent to the Total Costs, when distributed over a 23-year period. Annualized costs for Project Modification 

and Administrative cost categories were calculated using discount rates of 12 and 7 percent for private and public development projects, respectively. 

Reported annualized costs for Uncertainty totals are an overestimate of the actual cost because private/public cost categories could 

not be differentiated in the unit summary format. A 12 percent discount rate was therefore applied universally to this cost category, rather than selectively 

applying a 7 percent discount rate to the public projects. 

(4) Delay costs are assumed to occur in Year 1 only, and were therefore removed from the calculation of annualized costs (which assume equal distribution through 2025).

The reported annualized value for 'Total Costs' is an estimate of annual costs Years 2-23; annual costs in Year 1 would be equal to this amount plus the full delay 

costs (approximately $119 million). 

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Table 2

Estimated Section 7 Costs for Areas Proposed for Designation and Exclusion

Proposed Total (3)

CH Unit

Unit 1 $4,014,400 $70,687,500 $74,701,900

Unit 2 $3,533,100 $0 $3,533,100

Unit 3 $11,009,200 $0 $11,009,200

Unit 4 $2,719,100 $0 $2,719,100

Unit 5 $13,807,000 $3,669,600 $17,476,600

Unit 6 $89,068,900 $395,100 $89,464,000

Unit 7 $5,306,400 $6,841,600 $12,148,000

Unit 8 $449,100 $0 $449,100

Unit 9 $42,671,000 $0 $42,671,000

Unit 10 $459,907,500 $0 $459,907,500

Unit 11 $93,364,400 $0 $93,364,400

Unit 12 $4,029,800 $0 $4,029,800

Unit 13 $185,457,200 $0 $185,457,200

Project-Specific HCPs (4) $0 $141,500 $141,500

Total Cost $915,337,200 $81,735,300 $997,072,400

Annualized Cost (5) $113,479,600 $10,788,100 $124,267,700

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) Summary of economic cost calculations -- including project modification, administrative, time delay, and uncertainty costs -- 

for areas proposed for critical habitat designation on April 24, 2003 (see Table 1). Assumes 12% discount rate.

(2) The Proposed Rule published on April 24, 2003 proposed that a number of areas containing essential habitat not be designated 

(under section 3(5)(a)) or be excluded from critical habitat designation (under section 4(b)(2)) of the Act. This analysis 

evaluates the economic cost of designating these areas, however, to allow the Service to consider "economic and any other 

relevant impacts" in deciding whether to exclude these areas in the final designation. These values are equal to "Total" 

costs minus costs of "Areas Proposed for Critical Habitat." It is important to note these costs do not represent areas 

that have been proposed for critical habitat designation.

(3) This analysis evaluates the potential economic costs if the Service designated critical habitat for all areas proposed for both 

designation and exclusion. A summary table for this separate cost model is included as Appendix H. 

(4) Because the location of all existing project-specific HCPs was not known, this item is reported individually.

(5) Represents the annual amount that is equivalent to the Total Costs, when distributed over a 23-year period (2003-2025). 

 Assumes a discount rate of 12 percent (private/public costs could not be separated in the Unit Summary table)

Proposed for Critical 

Habitat (1)

Proposed for Exclusion 

(2)

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Table 3

Administrative and Project Modification Costs by Project Type for the Proposed Designation (1)

Project/Consultation Relevant

CH Unit(s)

Private Land Development All

CSS mitigation requirements $709,957,400 -- --

Other project modifications $32,854,500 -- --

Subtotal, Private Land Development $742,811,900 $5,720,900 $748,532,800

Public Land Development 

Transportation and Road Construction

Caltrans District 7 8,9,12,13 $369,200 -- --

Caltrans District 8 10-11 $42,301,400 -- --

Caltrans District 11 1-5 $23,500 -- --

Caltrans District 12 6,7,9 $443,800 -- --

Subtotal, Caltrans $43,137,900 $1,691,000 $44,828,900

Transportation Corridor Agency 6 $35,085,000 $18,100 $35,103,100

Municipal Water Supply

Regional Infrastructure All $6,628,600 $115,700 $6,744,300

Flood Control All $153,300 $66,900 $220,200

Municipal Power Supply All $11,535,900 $52,100 $11,588,000

Federal Land Management

Angeles National Forest 11-13 $196,000 $52,400 $248,400

Cleveland National Forest 1,2,4-6,9-10 $203,800 $339,500 $543,300

San Bernardino National Forest 11 $49,000 $47,200 $96,200

Bureau of Land Management All $25,800 $58,700 $84,500

Federal Emergency Management Activities All -- $385,700 $385,700

Military Operations

Camp Pendleton (non-training areas) 6 $4,833,300 $177,700 $5,011,000

Fallbrook 4 $2,110,000 $114,500 $2,224,500

El Toro 7 -- $14,600 $14,600

Future Habitat Conservation Plans (HCPs) All -- $36,500 $36,500

Reinitiated Section 7 Consultations All -- $0 $0

Subtotal, Public Land Development $103,958,500 $3,170,500 $107,129,200

Total Costs $846,770,400 $8,891,400 $855,662,000

Annualized Cost (2) $105,461,200 $1,022,500 $106,483,700

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) Assumes discount rates of 12% for private development projects and 7% for public development projects. 

(2) Represents the annual amount that is equivalent to the Total Costs, when distributed over a 23-year period and assuming the discounts rates in footnote (1). 

Project Modification Costs

Administrative 

Costs

Total 

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206 Table 4. Caveats to the Economic Analysis

Key Assumption Effect on Cost

Estimate

69 percent of projected private development will have a Federal nexus through U.S.

Army Corps of Engineers section 404 permitting.

+/-

211 The section 7 biological opinions summarized in Appendix C express on-site setaside, off-site preservation, and restoration ratios that are representative of future

section 7 consultations.

+/-

The California Environmental Quality Act (CEQA) is a baseline regulation in San

Diego and Orange counties, where it requires baseline mitigation for CSS impacts at

216 a 2:1 ratio.

+/-

The 4(d) Special Rule is a baseline regulation in San Diego County, Orange County,

and Rancho Palos Verdes (Unit 8). CSS impacts from projects that qualify for 4(d)

Rule approval will be regulated through the 4(d) Rule and not through section 7. 

-

All estimated project modifications (and costs) are assumed to be attributable

221 entirely to the gnatcatcher, even when other endangered species or environmental

considerations may be present.

+

- : This assumption may result in an underestimate of real costs.

+ : This assumption may result in an overestimate of real costs.

+/- : This assumption has an unknown effect on estimates.

226
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Figure 2. Total Cost Distribution

FEMA

0%

Private Devel. -- Mitigation

77%

Private Devel. -- Other Proj.Mods.

4%

Private Devel. -- Admin.

1%

Caltrans

5%

TCA

4%

Regional Water Infrastructure

1%

BOR

0%

Municipal Power Supply

1%

Military Operations

1%

Future HCPs

0%

Uncertainty

5%

Delay

1%

Federal Land Management

0%
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2

CSS is the primary habitat type associated with the gnatcatcher, and is the most predominant habitat

in the proposed designation. Because the link between CSS, the gnatcatcher, and its habitat is well

established in both biological and regulatory terms, this analysis evaluates CSS development as a

proxy for regulation under the Act, when appropriate.

3

The term “mitigation” is given a specific meaning within the regulations that support the Act – it is

typically used to describe measures taken in response to provisions of section 10, and is not generally

used in the context of section 7. Nonetheless, this analysis uses the terms “mitigation” and

“mitigation ratio” broadly to refer to habitat compensation measures and mechanisms negotiated

through the section 7 process, in part due to the widepread use of these terms in the context of other

land use regulations prevalent in southern California (i.e., regional HCPs, CEQA, etc.). In this

analysis, “mitigation” is used to describe the suite of land-based project modifications that applicants

often implement in association with section 7 consultations, including “conservation measures” that

Federal Action Agencies and/or project applicants can take to avoid jeopardy.. The term "mitigation

ratio" is used to describe the relationship between acres developed and acres preserved in the context

of historical and projected future, section 7 consultation outcomes. In practice, the Service addresses

each project individually, and does not rely on fixed mitigation ratios to determine the amount of

habitat preservation required. 

13

TOTAL ECONOMIC IMPACT

The total future potential economic impact from section 7 consultations associated with

231 the gnatcatcher listing and proposed CHD is estimated to be $915 million through the

year 2025, or $113 million per year on an annualized basis. This is an estimate of the

“co-extensive” cost of both the listing and proposed CHD for the gnatcatcher under

section 7; no attempt was made to estimate the economic impact solely attributable to

the proposed CHD. The year 2025 was selected as the appropriate timeframe for

236 analysis because 2025 is the last year for which the Southern California Association of

Governments (SCAG) provides demographic projections. The bulk of this impact –

over 77 percent – results from the on- or off-site preservation or restoration of CSS

habitat2 as a result of section 7 consultations (referred to as “CSS mitigation”) in

association with private development projects.3 Estimates of CSS mitigation associated

241 with section 7 consultations deduct mitigation likely to be required through pre-existing

regulations (such as the 4(d) Special Rule and the California Environmental Quality Act,

for example), and costs therefore represent “net” mitigation costs attributable solely to

section 7. The components of this total economic impact are further described below.
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246 Economic Impact by Proposed Critical Habitat Unit

Unit 1. This unit encompasses approximately 25,100 acres in San Diego County, and

includes the San Diego National Wildlife Refuge as well as several areas without

approved subarea plans under the Multiple Species Conservation Plan (MSCP).

Although a moderate amount of development is projected in this unit given its size,

251 pre-existing baseline regulations through the 4(d) Special Rule and California

Environmental Quality Act (CEQA) significantly limit the project modification costs

attributable to section 7. Total section 7 costs are estimated at approximately $4 million. 

If areas proposed for exclusion are designated as CH, the additional section 7 cost is

estimated to be approximately $71 million, or more than a 18-fold increase in total costs. 

256 The additional projected cost is associated almost entirely with CSS mitigation for

development in the City of Poway, where minimal baseline conditions are assumed to

apply. 

Unit 2. This unit includes approximately 16,000 acres in and around the upper San

261 Diego River drainage and Cleveland National Forest. A moderate amount of growth is

projected within the unit, though the presence of 4(d) Rule and CEQA baseline

requirements result in a small amount of future estimated CSS mitigation associated

with section 7. Total costs for proposed CH are approximately $3.5 million. No areas in

Unit 2 have been proposed for exclusion. 

266

Unit 3. Unit 3 includes approximately 32,000 acres within the proposed North San

Diego County Multiple Habitat Conservation Plan (MHCP) planning area. A large

amount of growth is projected within this unit relative to its size, though the presence

of 4(d) Rule and CEQA baseline considerations result in relatively few acres mitigated

271 in association with the section 7 consultation process. The total estimated economic

costs for this unit are approximately $11 million. It is worth noting that if the MHCP is

approved, a significant portion of future development in CSS habitat would be

regulated by the MHCP and would not be attributable to section 7. No areas in Unit 3

have been proposed for exclusion.

276
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4An evaluation of the impact of CHD on military readiness is beyond the scope of this analysis.

15

Unit 4. Unit 4 encompasses approximately 8,700 acres within U.S. Naval Weapons

Station Seal Beach, Detachment Fallbrook (Fallbrook). Almost no future development is

281 projected by the San Diego Association of Governments (SANDAG) within this unit. 

Construction of weapons storage facilities and other infrastructure is expected to result

in section 7 costs of approximately $2.7 million through 2025. No areas in Unit 4 have

been proposed for exclusion.

286 Unit 5. Approximately 35,000 acres of CH have been proposed for Unit 5, which

includes the North County subarea of the MSCP for unincorporated San Diego County. 

A large amount of growth is projected in this unit relative to its size, although 4(d) Rule

and CEQA baseline regulations result in a relatively small number of acres mitigated in

association with section 7 consultation. Total section 7 costs for this unit are

291 approximately $13.8 million. The Pala Band of Mission Indians Reservation has been

proposed for exclusion, and would add approximately 7,700 acres to Unit 5 if it were

designated as CH. The estimated economic cost associated with the Pala Reservation

would result in additional section 7 costs of approximately $3.7 million through 2025,

primarily associated with housing and infrastructure construction involving Bureau of

296 Indian Affairs (BIA) funds.

Unit 6. Approximately 44,000 acres of CH have been proposed for Unit 6, which

includes the Southern Natural Community Conservation Plan (NCCP) Subregion of

Orange County, as well as habitat linkages to Units 3 and 4, and non-training areas in

301 Camp Pendleton, in San Diego County. Significant growth is projected in this unit. 

Though the 4(d) Rule constitutes a regulatory baseline in both San Diego and Orange

counties, this analysis assumes that one or more large-scale, proposed development

projects in southern Orange County will take place that will not qualify for 4(d)

approval (baseline requirements under CEQA is still assumed, however). The resulting

306 economic cost estimate is approximately $89 million through 2025. If mission-essential

training areas at Camp Pendleton, which have been proposed for exclusion, are

designated as CH in Unit 6, this analysis estimates that additional section 7 costs would

be approximately $400,000.4
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311 Unit 7. Unit 7 encompasses approximately 5,800 acres, which includes the El Toro

Reuse Area, the Irvine Ranch Land Reserve, and Existing Use Areas (EUAs) within the

Orange County Central/Coastal NCCP planning area. Only Planned Activities covered

by the NCCP are allowed within El Toro and the Irvine Ranch. Limited private

development is projected within EUAs. The resulting costs are estimated at

316 approximately $5.3 million, which takes into account CEQA as the only applicable

baseline regulation. All remaining reserve areas under the NCCP, totaling over 35,000

acres, have been proposed for exclusion. Although a very large land area, the proposal

of these reserves as CH would result in an estimated additional cost of only $6.8

million, because little private development is anticipated, and nearly all future projects

321 would be addressed by the NCCP (which would constitute a baseline regulation).

Unit 8. Critical habitat (CH) has been proposed for approximately 7,200 acres in Unit 8

within the Palos Verdes Peninsula in Los Angeles County, including the City of Rancho

Palos Verdes Multiple Species Habitat Conservation Plan (MSHCP). This analysis

326 estimates minimal future section 7 costs – approximately $450,000 through 2025 – due

both to low projected growth and the presence of the 4(d) Rule as a baseline regulation. 

No areas in Unit 8 have been proposed for exclusion.

Unit 9. This unit includes approximately 22,600 acres in northern Orange, eastern Los

331 Angeles, and parts of western Riverside and San Bernardino counties. Moderate

growth is projected within the unit, though the fact that CEQA regulation in northern

Orange County constitutes the only baseline consideration results in significant total

costs relative to the unit’s size. Total costs are estimated at approximately $43 million

through 2025. No areas in Unit 9 have been proposed for exclusion.

336

Unit 10. Unit 10 is the largest proposed unit, encompassing over 176,000 acres

throughout western Riverside County. The unit lies entirely within the proposed

planning area of the Riverside County MSHCP. Based on very large projected growth

estimates, the absence of any baseline regulations, and the size of the unit, this analysis

341 concludes that section 7 costs in Unit 10 are approximately $460 million through 2025 –

over 50 percent of the total cost estimate for all units. It is worth noting that although 
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17

no baseline regulations were identified, if the MSHCP is approved, a significant portion

346 of future development in CSS habitat would be regulated by the Plan and would not be

attributable to section 7. No areas in Unit 10 have been proposed for exclusion.

Unit 11. Approximately 15,000 acres of CH have been proposed for Unit 11 in

southwestern San Bernardino County. A significant amount of growth is projected

351 relative to the size of the unit, and the absence of any baseline regulations means that all

future project modifications are attributable to section 7. The estimated future section 7

costs associated with the proposed designation is approximately $93 million, which

represents about 10 percent of total costs for all units. No areas in Unit 11 have been

proposed for exclusion.

356

Unit 12. This unit encompasses approximately 3,900 acres in eastern Los Angeles

County. Although this analysis identified no applicable baseline regulations, a

relatively small amount of growth is projected in this unit. Total section 7 costs are

estimated at approximately $4 million. No areas in Unit 12 have been proposed for

361 exclusion.

Unit 13. Unit 13 is the second largest unit, encompassing more than 103,000 acres in

western Los Angeles and Ventura counties. Based on large projected growth estimates,

the absence of any baseline regulations, and the size of the unit, this analysis concludes

366 that section 7 costs in Unit 13 are approximately $185 million – over 20 percent of the

total cost estimate for all units. No areas in Unit 13 have been proposed for exclusion.

Economic Impact by Project Type

371 The discussion below addresses project modification and administrative costs for future

projects anticipated within proposed CH boundaries (indirect costs due to delay or

uncertainty are not included here). The costs described below are summarized in

Table 3. 

376 Private Land Development. The total section 7 cost related to projected private land

development is estimated at approximately $749 million through 2025, which

represents roughly 82 percent of total estimated costs. This total includes estimates of
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(1) project modification costs related to mitigating future development of CSS habitat

through on-site set-aside, off-site preservation, and restoration; (2) project modification

381 costs related to biological monitoring, fencing, and education programs; and (3)

administrative costs incurred through section 7 consultation. These costs are assumed

to be associated with an estimated 866 future private development projects that will

involve a Federal nexus through the United States Army Corps of Engineers (USACE). 

The largest component of total cost is the estimated loss in land value for acres set-aside

386 through the section 7 process, and therefore permanently removed from developable

land supply.

This analysis estimates that about 12,500 acres of CSS habitat will be set-aside through

2025 as a result of section 7 consultations associated with projected land development. 

391 This represents approximately 1.7 percent of total projected land development in the

six-county region over the same period. This percentage is not considered a regionally

significant reduction in future development opportunities and is not expected to affect

regional real estate market prices. As a result, the primary burden of section 7

regulation for private land development is expected to fall on the regulated landowners

396 rather than consumers at large. 

Transportation and Road Construction. Future transportation projects include road

construction by California Department of Transportation (Caltrans) Districts 7, 8, 11,

and 12, and the Transportation Corridor Agency (TCA). Total costs for the four

401 Caltrans districts are estimated at approximately $45 million, or roughly 5 percent of

total costs. This analysis estimates that all Caltrans districts combined will participate

in 191 formal consultations resulting in project modification costs, though construction

in Riverside and San Bernardino counties is expected to result in significantly higher

section 7 costs that any other district. The TCA’s proposed SR-241 Foothill-South toll

406 road is estimated to result in an estimated section 7 cost of approximately $35 million,

based on an average of two potential development scenarios. 

Municipal Water Supply. This analysis estimates that the Metropolitan Water District

(MWD) and the San Diego County Water Authority will engage in 13 future regional

411 water infrastructure projects requiring section 7 consultation. This analysis estimates

that the Bureau of Reclamation (BOR) will participate in 12 informal section 7
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consultations and three formal consultations involving a combination of local water

reuse and flood control projects. This analysis assumes that local-level utility projects,

such as those carried out by local retail water agencies, are associated with urban

416 development, and related section 7 costs are therefore captured in the private

development section. Combined regional water projects are estimated to result in total

section 7 costs of approximately $7 million.

Municipal Power Supply. This analysis estimates that the Southern California Gas

421 Company, San Diego Gas and Electric, and Southern California Edison will require six

total future section 7 consultations for regional gas and electric infrastructure projects

through 2025. Though very little project-specific information was available, this

analysis estimates that total section 7 costs will be approximately $11.6 million.

426 Federal Land Management. Angeles National Forest, Cleveland National Forest, San

Bernardino National Forest, and the Bureau of Land Management will all engage in

land management projects (fire prevention, prescribed burns, etc.) that are expected to

require section 7 consultation. These agencies collectively estimated a total of 3

technical assistance calls, 81 informal consultations, and 50 formal consultations. These

431 consultations and associated project modifications are estimated to result in a total

section 7 cost of approximately $1 million through 2025.

Federal Emergency Management. By the nature of its activities, the Federal Emergency

Management Agency (FEMA) is not able to provide estimates of future planned

436 projects. Based on historical projects, FEMA estimates it will participate in

approximately 75 informal and 30 formal consultations through 2025, most likely

related to flood control and fire prevention activities. This analysis estimates that

administrative consultation costs for these activities will be approximately $386,000. No

information was provided that allowed quantification of project modification costs.

441

Military Operations. Military lands proposed for CHD include parts of United States

Marine Corps (USMC) Camp Pendleton (non-training areas only), the U.S. Navy’s

Naval Weapons Station Seal Beach, Detachment Fallbrook (Fallbrook), and the U.S. 

446
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Navy’s El Toro Reuse Area. Based on previous section 7 consultation history and costs,

this analysis estimates 37 formal consultations for Camp Pendleton through 2025,

resulting in total costs of approximately $5 million. 

451 Fallbrook staff estimate that future construction of storage facilities for explosive

ordnance will result in approximately 16 formal section 7 consultations, and will result

in total costs of approximately $2.2 million. 

Finally, one road construction project is anticipated with the El Toro Reuse Area, a U.S.

456 Navy parcel currently managed as a reserve to the Central/Coastal Orange County

NCCP. This project is a Planned Activity under the NCCP, however, and has already

been mitigated in full, so no section 7 project modification costs are anticipated. The

estimated administrative cost of the single consultation is $14,600.

461 Existing Habitat Conservation Plans. All existing project-specific habitat conservation

plans (HCP) that address the gnatcatcher either do not meet the definition of CH (under

section 3(5)(a)) or have been proposed for exclusion (under section 4(b)(2)). If these

HCPs were designated as CH, each would require an internal consultation between the

Service’s section 7 and section 10 branches to insure the plan is consistent with section 7

466 requirements. This analysis assumes that 28 HCPs would require internal, informal

consultations, and that costs would be borne entirely by the Service. In addition, future

projects with a Federal nexus within HCPs that are designated as CH would require

section 7 consultation. This analysis assumes that any mitigation requirements for such

projects would be determined by the HCP, so only administrative costs are estimated. 

471 Based on previous consultation rates for such projects, this analysis estimates 8

additional formal section 7 consultations would be required. The total estimated costs

for these 28 informal and 8 formal consultations is approximately $142,000. These costs

are shown in Table 2 (column 2), but not in Table 1 or Table 3, because all existing

HCPs have been proposed for exclusion. 

476

Future Habitat Conservation Plans. In order to be approved, any future HCP that

addresses the gnatcatcher or includes land designated as CH will require an internal

consultation between the Service’s section 7 and section 10 branches to insure the plan

is consistent with section 7 requirements. These consultations will be informal. This
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481 analysis identified 16 planned or proposed HCPs, all of which are assumed will reach

completion and require consultation by the Service. The estimated administrative cost

of these consultations is estimated at approximately $37,000, which would be borne

entirely by the Service.

Reinitiated Consultations. No information regarding the number of previous section 7

486 consultations that will require reinitiation following the designation of CH was

identified. Public comment is specifically requested for this issue.

Time Delay. Private development projects could be delayed due to restrictions on land

development activities during specific periods of the year. Section 7 regulation

491 associated with the gnatcatcher will require projects not to conduct habitat-disturbing

land development activities during the breeding season, a six-month period from

February 15 to August 15. It is assumed that all land development projects expected to

occur in the 12 months following CHD will be delayed by 6 months. It is also assumed

that projects further away from development will be able to plan habitat disturbing

496 land development activities outside the breeding season and will not experience any

additional time delays. The analysis finds that the economic costs associated with

section 7 time delays experienced by private development projects will be

approximately $5.7 million.

501 Uncertainty/Stigma. Uncertainty effects may result due to the case-by-case nature of

section 7 consultations and the corresponding uncertainty associated with the scope and

level of project modifications. The economic cost associated with uncertainty is likely to

lie somewhere between zero and the additional cost associated with an upper-end set of

mitigation requirements associated with section 7. Once known factors such as clear

506 differences in habitat quality and the presence of other species are accounted for, the

remaining uncertainty appears to be in the plus-or-minus 25 percent range based on a

review of “effective” mitigation ratios from biological opinions (BOs) provided by the

Service. The analysis estimates an uncertainty cost of about $54 million, or roughly 6

percent of total costs. Stigma represents another form of uncertainty, and while real, is

511 likely to be arbitraged away as the true uncertainty over project modifications becomes

apparent. 
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CEQA Indirect Costs. This analysis evaluates the possibility that CHD might result in

516 additional costs to project applicants through lead agencies’ administration of CEQA. 

CH may result in additional indirect costs if (1) lead agencies are compelled to require

additional habitat mitigation based on new information provided by the designation,

(2) the required level of CEQA review is elevated, or (3) applicants incur additional

expense to address CH in preparing CEQA documentation. Though in some cases CH

521 can result in one or more of these cost effects, this analysis concludes that none of these

indirect effects is likely due to CHD for the gnatcatcher. Due to the presence of a

number of pre-existing regulations, public processes, and information sources that

address the gnatcatcher, it is not likely that this CHD will provide lead agencies with

new information, or compel them to change how they apply and enforce CEQA

526 regulations. 

Effects on Small Businesses and Governments. As required by the Small Business

Regulatory Enforcement Fairness Act of 1996, this analysis evaluated the effects of the

proposed rule on small businesses and governments. The analysis concluded that

531 potentially affected entities would be limited to small businesses in the land

development and real estate industry (SIC 6552) and small governments. The analysis

estimated that 1.1 percent of small businesses and 6 percent of small governments

would be affected annually. A comparison of annual per-business gross revenue

estimates with per-business section 7 costs determined that those small businesses

536 affected by the proposed designation would experience a reduction in annual revenues

of approximately 1.5 percent. Affected small governments would experience effects

equal to approximately 0.02 percent of their gross annual revenue.

Effects on the Energy Industry. Following guidance from the OMB, this analysis

541 evaluated the effect of the proposed designation on the energy industry. The analysis

screened all OMB criteria, and concluded that the only relevant consideration was

whether the proposed rule would result in an increase in energy distribution costs

greater than one percent. After comparing annualized section 7 costs with reported

annual distribution costs for the three major energy utilities in southern California, this

546 analysis concluded that the annual section 7 costs represent only 0.14 percent of annual 

distribution costs. Because this is well below the one-percent significance threshold,
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23

this analysis concludes the proposed designation would not have a significant effect on

the energy industry.

551

Unfunded Mandate Reform Act. UMRA guidance requires that a written statement be

prepared if annualized effects to either non-Federal (State/local/Tribal) governments or

the private sector exceed $100 million. This analysis estimates that average annual costs

for non-Federal governments will be approximately $7.9 million, and annual costs for

556 the private sector will be approximately $112 million. Because annual private sector

costs were estimated to exceed $100 million, this analysis provides an evaluation of

relevant criteria to help the Service prepare a written statement; this analysis does not

provide an official written statement as required by UMRA. This analysis concludes

that the annual effect to the private sector represents approximately 0.008 percent of

561 National Gross Domestic Product (GDP), and less than 0.07 percent of total California

Gross State Product (GSP) or California GSP for private industries. Consistent with

OMB screening criteria, the proposed rule is unlikely to result in a significant effect on

the national economy, or on a particular geographic region or economic sector.

566 Benefits. Potential benefits of the proposed CHD include improved ecosystem health

and water quality, educational benefits, increased support for existing conservation

efforts and amenity/ open space-driven land and development value increases. 

However, insufficient data is available to accurately monetize the ecological and

economic benefits of this CHD.

571

Key Assumptions

The following table presents the key assumptions of this economic analysis, as well as

the potential direction of the bias introduced by each assumption.

576
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I. INTRODUCTION AND BACKGROUND

On April 24, 2003, the U.S. Fish and Wildlife Service (the Service) proposed designating

critical habitat (CH) for the coastal California gnatcatcher (Polioptila californica

581 californica), hereafter referred to as the gnatcatcher, on approximately 495,475 acres of

land in Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura

counties, California. The purpose of this report is to identify and analyze the potential

economic effects that would result from this designation. This report was prepared by

Economic & Planning Systems, Inc. (EPS), under subcontract to Industrial Economics,

586 Inc., under contract to the Service's Division of Economics.

Section 4(b)(2) of the Endangered Species Act (the Act) requires that the Service base

the designation of CH upon the best scientific and commercial data available, after

taking into consideration the economic impact and any other relevant impact of

591 specifying any particular area as CH. The Service may exclude areas from critical

habitat designation (CHD) when the benefits of exclusion outweigh the benefits of

including the areas within CH, provided the exclusion will not result in extinction of

the species.

596 Upon the listing of a species, section 7(a)(2) of the Act requires Federal agencies to

consult with the Service in order to ensure that activities they fund, authorize, permit,

or carry out are not likely to jeopardize the continued existence of the species. The

Service defines jeopardy as any action that would appreciably reduce the likelihood of

both the survival and recovery of the species. For designated CH, section 7(a)(2) also

601 requires Federal agencies to consult with the Service to ensure that activities they fund,

authorize, permit, or carry out do not result in destruction or adverse modification of

CH. Adverse modification of CH is construed as any direct or indirect alteration that

appreciably diminishes the value of CH for conservation of a listed species.
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 U.S. Fish an d Wildlife Service, Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat

for the Coastal California Gnatcatcher (Polioptila californica californica) and Determination of Distinct Vertebrate

Population Segment for the California Gnatcatcher (Polioptila californica), Ap ril 24, 2003 (68 FR 20228).

25

606 SPECIES DESCRIPTION AND DISTRIBUTION

A brief description of the gnatcatcher, is provided below. Refer to the proposed rule for

a more complete description of the species, its associated habitat types, and relevant

citations.

5

611 The gnatcatcher is a long-tailed member of the old-world warbler and gnatcatcher

family (Sylviidae) characterized by dark blue-gray plumage above and grayish white

below, mostly black tail, and distinctive white eye-ring. The male population is further

distinguished by a black cap, which is absent during the winter. The U.S. population of

the gnatcatcher is restricted to coastal southern California from Ventura and San

616 Bernardino counties to the north, to the U.S.-Mexico border to the south. The

gnatcatcher typically occurs in or near sage scrub habitat, which is a broad category of

vegetation that includes various sage scrub communities. Refer to the proposed rule for 

a detailed description of each type of sage scrub community. 

PROPOSED CRITICAL HABITAT DESIGNATION

621 On March 30, 1993, the gnatcatcher was listed as a threatened species pursuant to the

Act (58 FR 16742). When a species is listed as threatened or endangered, the Act

stipulates that the Service must also "to the maximum extent prudent and

determinable...designate critical habitat." On October 24, 2000, the Service published a

Final Rule designating approximately 514,000 acres as CH for the gnatcatcher (65 FR

626 63680). The Service prepared an economic analysis of the original CHD prior to

publication of the Final Rule. As described in the Executive Summary, the assumptions

and methodology employed in this analysis differ significantly from those employed in

the original. 
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631 In response to a number of lawsuits filed subsequent to the designation and economic

analysis, the Service requested a voluntary remand of the designation, which the U.S.

District Court for the Central District of California granted on June 11, 2002. The Court

ordered the Service to complete a new proposed rule by April 11, 2003, and held that

the designation should remain in place until a new, final regulation becomes effective. 

636

On April 24, 2003, the Service published in the Federal Register a proposed rule

outlining its proposed CHD for the gnatcatcher. The proposed rule delineated 13 CH

units in Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura

counties, totaling approximately 495,795 acres. The proposed rule also identified an

641 additional 264,280 acres that it recognized as “essential” habitat, but proposed for

exclusion from the final CH boundaries, citing sections 3(5)(a) and 4(b)(2) of the Act. A

summary of proposed CH acreage, as well as lands considered essential, and those

excluded, is presented in Table 5. 

646 Table 5. Approximate Proposed Critical Habitat Area, Essential Areas, and

Excluded Areas

Areas considered essential 760,075 acres

Areas excluded under 3(5)(a) – special management or protection 6,740 acres

651 Areas excluded under 4(b)(2) – economic and other relevant impacts 257,540 acres

Proposed Critical Habitat 495,795 acres

Section 3(5)(a) defines CH as areas within the geographic area occupied by the species

that contain physical and biological features (I) essential to the conservation of the

656 species, and (II) which may require special management consideration and protection. 

Under section 3(5)(a), CH must therefore meet both provisions of the definition. The

proposed rule identified approximately 6,740 acres in San Diego County, corresponding

to MCAS Miramar Air Station, that the Service proposed for exclusion from CH under

section 3(5)(a). The proposed rule states that MCAS Miramar has completed a final

661 Integrated Natural Resource Management Plan (INRMP) that provides for adequate

management and protection of the gnatcatcher, and that lands covered by the plan

therefore do not meet the second provision of the definition of CH pursuant to section

3(5)(a)(i)(II). Furthermore, to the extent any of these lands do meet this second
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27

provision of the definition, the proposed rule states that it is additionally appropriate to

666 exclude these areas from CH pursuant to the “other relevant impacts” provisions of

section 4(b)(2), as described below. 

Section 4(b)(2) of the Act stipulates that CH shall be designated on the basis of the best

available scientific data after taking into consideration the economic impact, and any

671 other relevant impact, of specifying any particular area as CH. An area may be

excluded from CH if it is determined that the benefits of exclusion outweigh the

benefits of specifying the area as CH. The proposed rule identified 257,540 total acres

that the Service proposes for exclusion based on a determination that the benefits of

exclusion outweigh the benefits of designating those areas as CH. Areas proposed for

676 exclusion include mission-essential training areas on Marine Corps Base Camp

Pendleton, reserve lands in the San Diego Multiple Species Conservation Program

(MSCP) and the Orange County Central-Coastal NCCP/HCP, Tribal lands of the Pala

Band of Mission Indians, and lands covered by individual completed and approved

HCPs that address the gnatcatcher. 

681

The primary focus of this document is to evaluate and report the likely economic impact

of the proposed CHD, which in this case is limited to the 13 proposed CH units

described below. However, to ensure that the Service is able to fully consider the

economic and any other relevant impacts in deciding to exclude certain biologically

686 essential areas under section 4(b)(2), this analysis will also evaluate the likely economic

impact were CH to be designated for areas currently proposed for exclusion in the

proposed rule. 

691 PROPOSED CRITICAL HABITAT UNITS

Section 3 (5)(a) of the Act defines CH as "the specific areas within the geographic area

occupied by a species...on which are found those physical or biological features...

essential to the conservation of the species and...specific areas outside the geographic

area occupied by a species...upon a determination that such areas are essential for the

696 conservation of the species." In order to delineate potential CH boundaries, the Service

must first use the "best available scientific information" to identify those physical and
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biological features — or primary constituent elements (PCEs) — that are essential to the

conservation of the species. PCEs for the gnatcatcher include various types of sage

scrub communities as discussed above. The Service used PCEs, distribution and

701 occurrence data, and occurrence ranking criteria to delineate habitat areas essential for

the conservation of the species. A more complete discussion of gnatcatcher

occurrences, land ownership within each unit, specific PCEs, and factors considered in

delineating CH can be found in the proposed rule.

706 Each of the 13 proposed CH units is described briefly below. Table 6 also summarizes

the approximate area of proposed CH by county and land ownership. Refer to the

proposed rule for a more complete description of each unit. 

• Unit 1 encompasses approximately 25,100 acres of land within the MSCP

711 planning area. The proposed unit contains lands essential to the conservation of

the gnatcatcher within the cities of Chula Vista, El Cajon, and Santee; major

amendment areas within the San Diego County subarea plan; the OtaySweetwater Unit of the San Diego National Wildlife Refuge Complex; and water

district lands owned by Sweetwater Authority and Otay Water District. This unit

716 contains core populations of the species, sage scrub and areas providing

connectivity between core populations and sage scrub.

• Unit 2 encompasses approximately 16,075 acres in the upper San Diego River

drainage. This unit also contains a core population of the species, and includes

721 lands that serve as a corridor connecting the adjacent core population on

Cleveland National Forest lands to populations located in Unit 1.

• Unit 3 encompasses approximately 32,465 acres of land within the North San

Diego County MHCP planning area in northwestern San Diego County. 

726 Included are lands within the cities of Carlsbad, Encinitas, Escondido, Oceanside,

San Marcos, Solana Beach, and Vista. This unit provides connectivity among core

populations in Units 1, 5 and 6.
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731 Table 6. Proposed Critical Habitat Acreage by County and Land Ownership

County Federal* Local/State Private Total

Los Angeles 6,825 acres 2,010 acres 68,900 acres 77,735 acres

Orange 1,045 acres 4,535 acres 48,580 acres 54,160 acres

736 Riverside 10,740 acres 8,740 acres 150,465 acres 169,945 acres

San Bernardino 830 acres 1,590 acres 20,890 acres 23,310 acres

San Diego 25,940 acres 1,755 acres 97,110 acres 124,805 acres

Ventura 0 0 45,840 acres 45,840 acres

Total 45,380 acres 18,630 acres 431,785 acres 495,795 acres

741 *Federal lands include Bureau of Land Managem ent, Department of Defense, National Forest,

Tribal, and Fish and Wildlife Service lands.

• Unit 4 encompasses approximately 8,690 acres of land on Fallbrook Naval

Weapons Station in northern San Diego County. This unit contains core

746 gnatcatcher population supporting adjacent populations in Units 5, 6, and 10.

The northern boundary of this unit also functions as an essential linkage

connecting coastal populations with inland populations in San Diego and

Riverside counties.

751 • Unit 5 encompasses approximately 34,705 acres of land within the planning area

for the North County Subarea of the MSCP for San Diego County. This unit

contains several gnatcatcher populations and intervening linkage areas of sage

scrub. This unit constitutes the primary inland linkage along the I-15 corridor

between San Diego populations and those in southwestern Riverside County

756 (Unit 10).

• Unit 6 encompasses approximately 44,340 acres of land within the planning area

for the Southern NCCP Subregion of Orange County. This unit contains some of

the largest, most robust populations known, as well as essential regional

761 populations. This unit also provides primary linkage for core populations in

Units 3, 4, and 7. Proposed CH in Camp Pendleton is limited to lands outside

training area boundaries, and includes a coastal corridor linking populations in
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30

San Diego and southern Orange counties, Wire Mountain and De Luz housing

areas, and State Park lease lands (San Onofre State Beach).

766

• Unit 7 encompasses approximately 5,775 acres of land within the Orange County

Central/Coastal NCCP planning area. This unit includes core gnatcatcher

populations and sage scrub habitat within select Existing Use Areas (EUAs),

portions of the Irving Ranch Land Reserve, and the designated reserve

771 (panhandle portion) of the El Toro Reuse Area.

• Unit 8 encompasses approximately 7,160 acres of land within and adjacent to

the subregional planning area for the Palos Verdes Peninsula in Los Angeles

County, including the City of Rancho Palos Verdes MSHCP area. This unit also

776 includes a core population of gnatcatcher and essential sage scrub habitat.

• Unit 9 encompasses approximately 22,595 acres of land in East Los Angeles

County. The unit contains core populations and also provides primary

connectivity between core gnatcatcher populations and sage scrub habitat in

781 Units 7, 10, and 12.

• Unit 10 encompasses approximately 176,720 acres within the proposed planning

area for the Western Riverside County MSHCP. These areas include core

populations and CSS habitat that provides connectivity between core

786 populations within Riverside County and to populations in San Diego, San

Bernardino, Orange, and Los Angeles counties. Lands proposed as CH within

Unit 10 are generally encompassed by the proposed Criteria Area (from which

the future preserve area will be delineated), designated as part of the ongoing

MSHCP process.

791

• Unit 11 encompasses approximately 14,990 acres of land along the foothills of

the San Gabriel Mountains in San Bernardino County. This unit contains

populations that persist in complex habitat assemblages not found in other

proposed Units.

796
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6

 This analysis considers the effects of the regulatory action as proposed in the Federal Register on

April 24, 2003 (68 Federal Register 20228, April 24, 2003).

7

 16 U.S.C. § 1533(b)(2).

8

 Executive Order 12866, “Regulatory Planning and Review,” September 30, 1993; Executive Order

13211, “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or

Use," May 18, 2001; 5 U.S.C. §§ 601 et seq; and Pub Law No. 104-121; and 2 U.S.C. §§658-658g and

1501-1571.

31

• Unit 12 encompasses approximately 3,890 acres of land in eastern Los Angeles

County. This unit functions as an archipelago of persistent populations toward

the northern end of the range of the species, and is a likely source population for

the pairs that are reported from the foothills of the San Gabriel mountains north

801 of the Los Angeles basin.

• Unit 13 encompasses approximately 103,290 acres of land in eastern Ventura and

western Los Angeles counties. It includes the only known breeding population

of the gnatcatcher in Ventura County, and constitutes the northern and western

806 distributional extreme of its current range.

FRAMEWORK FOR THE ANALYSIS

The primary purpose of this analysis is to estimate the economic impact that will result

from the designation of CH for the gnatcatcher.

6

811 This information is intended to assist

the Secretary in making decisions about whether the benefits of excluding particular

areas from the designation outweigh the benefits of including those areas in the

designation.7 In addition, this information allows the Service to address the

requirements of Executive Orders 12866 and 13211, the Regulatory Flexibility Act

816 (RFA), as amended by the Small Business Regulatory Enforcement Fairness Act

(SBREFA), and the UMRA.8

This chapter provides the framework for this analysis. First, it defines the economic

effects considered in the analysis. Second, it establishes the baseline against which

821 these effects are measured. Third, it describes the measurement of direct compliance

costs, which include costs associated with, and generated as a result of, section 7

consultations. Fourth, it identifies potential indirect economic effects of the rule
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resulting from (1) compliance with other parts of the Act potentially triggered by CH,

(2) compliance with other laws, and (3) time delays and regulatory uncertainty. Fifth, it

826 discusses the need for an economic assessment of the benefits of CHD. Finally, the

section concludes by discussing the time frame for the analysis and the general steps

followed in the analysis.

Types of Economic Effects Considered

831

This economic analysis considers both the economic efficiency and distributional effects

that may result from the designation. In the case of CHD, economic efficiency effects

generally reflect the “opportunity costs” associated with the commitment of resources

required to comply with the Act. For example, if the activities that can take place on a

836 parcel of private land are limited as a result of a designation, and thus the market value

of the land reduced, this reduction in value represents one measure of opportunity cost

or change in economic efficiency. Similarly, the costs incurred by a Federal action

agency to consult with the Service under section 7 represent opportunity costs of the

designation. 

841

This analysis also addresses how the impacts of the designation are distributed,

including an assessment of any local or regional economic impacts of the designation

and the potential effects of the designation on small entities, the energy industry, or

governments. This information can be used by decision-makers to assess whether the

846 effects of the designation might unduly burden a particular group or economic sector.

For example, while the designation may have a relatively small impact when measured

in terms of changes in economic efficiency, individuals employed in a particular sector

of the economy in the geographic area of the designation may experience relatively

851 greater effects. The difference between economic efficiency effects and distributional

effects, as well as their application in this analysis, are discussed in greater detail below.

856
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9

 Executive Order 12866, “Regulatory Planning and Review,” September 30, 1993; U.S. Office of

Management and Budget, “Draft 2003 Report to Congress on the Costs and Benefits of Federal

Regulations; Notice,” 68 Federal Register 5492, February 3, 2003; and U.S. Office of Management and

Budget, “Appendix 4: Guidelines to Standardize Measure of Costs and Benefits and the Format of

Accounting Statements,” in Report to Congress on the Costs and Benefits of Federal Regulations, March 22,

2000.

10 For additional information on the definition of “surplus” and an explanation of consumer and

producer surplus in the context of regulatory analysis, see Gramlich, Edward M., A Guide to

Benefit-Cost Analysis (2nd Ed.), Prospect Heights, Illinois: Waveland Press, Inc., 1990; and U.S.

Environmental Protection Agency, Guidelines for Preparing Economic Analyses, EPA 240-R-00-003,

September 2000, available at http://yosemite.epa.gov/ee/epa/eed.nsf/ webpages/Guidelines.html.

33

Efficiency Effects

At the guidance of the Office of Management and Budget (OMB) and in compliance

861 with Executive Order 12866 “Regulatory Planning and Review,” Federal agencies

measure changes in economic efficiency in order to understand how society, as a whole,

will be affected by a regulatory action.9 In the context of this regulatory action, these

efficiency effects represent the opportunity cost of resources used or benefits foregone

by society as a result of CHD. Economists generally characterize opportunity costs in

terms of changes in producer and consumer surpluses in affected markets.10 866

In some instances, compliance costs may provide a reasonable approximation for the

efficiency effects associated with a regulatory action. For example, a landowner or

manager may need to enter into a consultation with the Service to ensure that a

871 particular activity will not adversely modify CH. The effort required for the

consultation represents an economic opportunity cost, because the landowner or

manager’s time and effort would have been spent in an alternative activity had the

parcel not been included in the designation. When compliance activity is not expected

to significantly affect markets -- that is, not result in a shift in the quantity of a good or

876 service provided at a given price, or in the quantity of a good or service demanded

given a change in price -- the measurement of compliance costs can provide a

reasonable estimate of the change in economic efficiency.

Where a designation is expected to significantly impact a market, it may be necessary to

881 estimate changes in producer and consumer surpluses. For example, a designation that

precludes the development of large areas of land may shift the price and quantity of
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11 Office of Management and Budget, “Draft 2003 Report to Congress on the Costs and Benefits of

Federal Regulations; Notice” 68 Federal Register 5492, February 3, 2003.

12 5 U.S.C. § 601 et seq.

34

housing supplied in a region. In this case, changes in economic efficiency can be

measured by considering changes in producer and consumer surplus in the real estate

market.

886

This analysis begins by measuring reasonably foreseeable compliance costs resulting

from the designation. As noted above, in some cases, compliance costs can provide a

reasonable estimate of changes in economic efficiency. However, if the designation is

expected to significantly impact markets, the analysis will consider potential changes in

891 consumer and/or producer surplus in affected markets.

Distributional and Regional Economic Effects

Measurements of changes in economic efficiency focus on the net impact of the

896 regulation, without consideration for how certain economic sectors or groups of people

are affected. Thus, a discussion of efficiency effects alone may miss important

distributional considerations concerning groups that may be disproportionately

affected. OMB encourages Federal agencies to consider distributional effects separately

from efficiency effects.11 This analysis considers several types of distributional effects,

901 including impacts on small entities; impacts on energy supply distribution and use;

impacts on governments; and regional economic impacts. It is important to note that

these are fundamentally different measures of economic impact than efficiency effects,

and thus cannot be added to or compared with estimates of changes in economic

efficiency.

906

Impacts on Small Entities, Energy Supply, Distribution and Use, and Governments

This analysis considers how small entities, including small businesses, organizations,

and governments, as defined by the RFA, might be affected by CHD.12 In addition, in

911 response to Executive Order 13211 “Actions Concerning Regulations That Significantly
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13 Executive Order 13211, “Actions Concerning Regulations That Significantly Affect Energy Supply,

Distribution, or Use,” May 18, 2001.

14 2 U.S.C. §§658-658g and 1501-1571.

35

Affect Energy Supply, Distribution, or Use,” this analysis considers the impacts of CH

on the energy industry and its customers.13 Finally, in accordance with UMRA, this 

analysis considers the effects of the regulatory action on State, local, and tribal

governments and the private sector.14

916

Regional Economic Effects

Regional economic impact analysis provides an assessment of the potential localized

effects of CHD. Specifically, regional economic impact analysis produces a quantitative

921 estimate of the potential magnitude of the initial change in the regional economy

resulting from a regulatory action. Regional economic impacts are commonly measured

using regional input/output models. These models rely on multipliers that

mathematically represent the relationship between a change in one sector of the

economy (e.g., hydroelectric power generation) and the effect of that change on

926 economic output, income, or employment in other local industries (e.g., manufacturers

relying on the electricity generated). These economic data provide a quantitative

estimate of the magnitude of shifts of jobs and revenues in the local economy.

The use of regional input/output models in an analysis of the impacts of CH can

931 overstate the long-term impacts of a regulatory change. Most importantly, these

models provide a static view of the economy of a region. That is, they measure the

initial impact of a regulatory change on an economy but do not consider long-term

adjustments that the economy will make in response to this change. For example, these

models provide estimates of the number of jobs lost as a result of a regulatory change,

936 but do not consider re-employment of these individuals over time. In addition, the flow

of goods and services across the regional boundaries defined in the model may change

as a result of the designation, compensating for a potential decrease in economic

activity within the region. 

941
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15 U.S. Office of Management and “Draft 2003 Report to Congress on the Costs and Benefits of

Federal Regulations; Notice,” 68 Federal Register 5492, February 3, 2003; and U.S. Office of

Management and Budget, “Appendix 4: Guidelines to Standardize Measure of Costs and Benefits and

the Format of Accounting Statements,” in Report to Congress on the Costs and Benefits of Federal

Regulations, March 22, 2000.

16An evaluation of every local land use regulation that could potentially address development of

gnatcatcher habitat was beyond the scope of available resources for this analysis. This analysis

considered only those local land use regulations that were specifically identified by the Service. In

omitting potential local regulations that may in fact constitute a regulatory baseline, this analysis is

more likely to overestimate than underestimate the actual cost of the proposed designation.

17 Certain regulations that provide baseline protection for the species and its habitat may also be the

source of indirect costs resulting from new information provided by the designation.

36

Despite these and other limitations, in certain circumstances, regional economic impact

analysis may provide useful information about the scale and scope of localized impacts. 

It is important to remember that measures of regional economic effects generally reflect

shifts in resource use rather than efficiency losses. These types of distributional effects,

946 therefore, should be reported separately from efficiency effects (i.e., not summed). In

addition, measures of regional economic impact cannot be compared with estimates of

efficiency effects.

Defining the Baseline

951

OMB guidelines for conducting economic analysis of environmental regulation direct

Federal agencies to measure the costs of a regulatory action against a baseline.15 In its

guidance, OMB states, the "baseline should be the best assessment of the way the world

would look absent the proposed action" (i.e., absent the designation of CH). In other

956 words, the baseline includes the currently existing regulatory and socio-economic

burden imposed on landowners and managers potentially affected by the designation

of CH. The baseline burden may include, for example:

• Local zoning laws16;

961 • State natural resource laws; 

• Enforceable management plans and best management practices applied by other

State and Federal agencies; 

• Federal, State, and local protections already in place in the same geographic area

for other (Federal and State) listed species;17 and/or 
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966 • Statutory protections provided for the species by the Act that exist in the

absence of designated CH. 

This analysis also assumes that any costs already incurred or agreed upon as a result of

the original CHD in October 2000 are part of the baseline. Existing baseline laws,

971 regulations, and policies are described in greater detail in Chapter II of this analysis. 

This analysis describes impacts that are expected to occur above and beyond the

baseline. In other words, it measures the costs of compliance with the Act that would

not occur in the absence of the currently proposed CH. Importantly, economic impacts

976 associated with sections 9 and 10 of the Act, with a few exceptions, are considered to be

part of the regulatory baseline and thus are not addressed in this report. These costs are

considered to be part of the baseline, because they remain unaffected by the designation

of CH. 

981 Direct Compliance Costs Associated With Section 7 of the Act

The measurement of direct compliance costs focuses on the implementation of section 7

of the Act. This section requires Federal agencies to consult with the Service to ensure

that any action authorized, funded, or carried out will not likely jeopardize the

986 continued existence of any endangered or threatened species or result in the destruction

or adverse modification of CH. The administrative costs of these consultations, along

with the costs of project modifications resulting from these consultations, represent the

direct compliance costs of designating CH.

991 This analysis does not differentiate between consultations that result from the listing of

the species (i.e., the jeopardy standard) and consultations that result from the presence

of CH (i.e., the adverse modification standard). Consultations resulting from the listing

of the species, or project modifications meant specifically to protect to the species as

opposed to its habitat, may occur even in the absence of CH. However, in 2001, the U.S.

996 10th Circuit Court of Appeals instructed the Service to conduct a full analysis of all of

the economic impacts of CHD, regardless of whether those impacts are attributable
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18 New Mexico Cattle Growers Ass'n v. U.S.F.W.S., 248 F.3d 1277 (10th Cir. 2001).

38

co-extensively to other causes.18 Given the similarity in regulatory definitions between

the terms “jeopardy” and “adverse modification,” in practice it can be difficult to

pre-determine the standard that drives a section 7 consultation. Consequently, in an

1001 effort to ensure that this economic analysis complies with the instructions of the 10th

Circuit as well as to ensure that no costs of the proposed designation are omitted, the

potential effects associated with all section 7 impacts in or near proposed CH are fully

considered. In doing so, the analysis ensures that any critical habitat impacts that are

co-extensive with the listing of the species are not overlooked. As a result, this analysis

1006 likely overstates the regulatory effects under section 7 attributable to the proposed

designation of critical habitat.

Indirect Costs

1011 The designation may, under certain circumstances, affect actions that do not have a

Federal nexus and thus are not subject to the provisions of section 7 under the Act. The

potential exists for several types of such indirect effects: three examples are discussed in

this section. First, some landowners may voluntarily elect to complete a habitat

conservation plan (HCP) in response to having their land designated as critical habitat. 

1016 Second, some State laws may require landowners and managers to consider the effects

of their actions on sensitive species and habitat. Thus, designation of critical habitat

could trigger additional regulatory burden due to new information provided by the

designation. Third, the consultation process may result in time delays for upcoming or

ongoing projects, and the designation may foster regulatory uncertainty for prospective

1021 projects. If such additional efforts would not have occurred in the absence of critical

habitat (i.e., “but for” critical habitat), then they are considered by this analysis to be an

impact of the designation. The three most common categories of indirect effects are

discussed further below. 

1026
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19 U.S. Fish and Wildlife Service, “Endangered Species and Habitat Conservation Planning.” 

From: http://endangered.fws.gov/hcp/, as viewed on August 6, 2002. Sections 9 and 10 of the Act

do not apply to plants.

20 See Industrial Economics, Incorporated, Draft Economic Analysis of CHD for the Nine Bexar County

Texas Invertebrate Species, prepared for the U.S. Fish and Wildlife Service, October 2002.

39

CREATION OF HABITAT CONSERVATION PLANS

Under section 10(a)(1)(B) of the Act, a non-Federal entity (i.e., a landowner or local

1031 government) may develop an HCP for an endangered animal species in order to meet

the conditions for issuance of an incidental take permit in connection with the

development and management of a property.19 The HCP intends to counterbalance

potential harmful effects that a proposed activity may have on a species, while allowing

the otherwise lawful activity to proceed. As such, the purpose of the habitat

1036 conservation planning process is to ensure that the effects of incidental take are

adequately minimized and mitigated. Thus, HCPs are developed to ensure compliance

with section 9 of the Act and to meet the requirements of section 10 of the Act. HCPs

are not necessarily precipitated by a CHD. 

1041 However, a connection may exist between the creation of HCPs and the costs these

plans impose and CHD. The Service, being a Federal entity, must formally consider

whether an HCP will jeopardize a listed species or adversely modify its designated

critical habitat before approving the plan. This review process may be a direct impact

under section 7 of the Act. However, in certain circumstances, the effort involved in

1046 creating the HCP and associated conservation actions may also generate indirect effects

associated with CHD. For example, in one past instance, landowners preemptively

developed HCPs in an effort to avoid having their property designated as critical

habitat.20 In this case, the effort involved in creating the HCP and undertaking

associated conservation actions were considered to be an effect of designation.

1051

The following scenarios regarding HCP creation provide general guidance regarding

the degree to which associated costs should be considered within the context of a

critical habitat economic analysis: 

1056 • In cases in which an HCP existed prior to a proposed designation, the costs of

developing the HCP and the added costs of management imposed by the HCP
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21 Project modification costs associated with the jeopardy standard are not considered for the

following reason. Section 10(a)(2)(B) of the Act requires that for the issuance of an incidental take

permit, the HCP must assure that “the taking will not appreciably reduce the likelihood of survival

and recovery of the species in the wild.” According to the Service’s Habitat Conservation Planning and

Incidental Take Permit Processing Handbook, “the wording of this criterion is identical to the “jeopardy”

definition under the section 7 regulations (50 CFR Part 402.02)...Congress was explicit about this link,

stating in the Conference Report on the 1982 ESA amendments that the Services will determine

whether or not to grant a permit, “in part, by using the same standard as found in section 7(a)(2) of

the ESA, as defined by the [Services’] regulations.’” (U.S. Department of the Interior and U.S.

Department of Commerce, Habitat Conservation Planning and Incidental Take Permit Processing

Handbook, November 4, 1996). As a result, during the HCP process, actions undertaken to meet the

jeopardy provision of section 7 are also required under section 10 of the Act and are therefore

considered to be part of the baseline of this economic analysis.

40

should not be considered in the analysis of the effects of the designation. These

costs are appropriately considered to be part of the regulatory baseline, because

their creation was driven by the listing of the species and the need to avoid

1061 “take,” which is prohibited under section 9 of the Act. However, in cases where

designated critical habitat overlaps with completed HCPs, the economic analysis

will need to consider the cost to the Service to re-consult on the plan’s impact to

critical habitat and whether or not this process may result in additional

conservation actions. 

1066

• In cases in which an HCP is proposed, or reasonably foreseeable absent CHD,

the administrative costs associated with the required internal section 7

consultation should be included in the economic analysis of total section 7 costs,

because the Service will need to consider the effects of the plan on designated

1071 critical habitat. In addition, if, as a result of the designation, additional project

modifications will be recommended by the Service and incorporated into the

HCP in order to avoid adversely modifying critical habitat, the costs of these

project modifications should also be included in the economic analysis of critical

habitat.21

1076

• In cases in which development of one or more HCPs can be documented as

being precipitated by CHD (i.e., to avoid designation or to reduce the costs of

the designation), the costs of development of the HCP and the added costs of
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22 Article 19 of CEQA provides a list of categorical exemptions, which are descriptions of types of

projects that usually do not have a significant effect on the environment (e.g., replacement or

reconstruction of existing facilities, actions taken by regulatory agencies as authorized by State

law or local ordinance to assure the maintenance, restoration, or enhancement of a natural

resource.) (http://ceres.ca.gov/ceqa/flowchart/exemptions/ categorical.html, as viewed on April

21, 2003.)

41

management imposed by the HCP should be included in the critical habitat

1081 economic analysis. In such cases the analysis should be presented with

appropriate caveats as to the uncertainty regarding the extent to which the HCP

would have existed absent CHD.

OTHER STATE AND LOCAL LAWS

1086 Under certain circumstances, CHD may provide new information to a community about

the sensitive ecological nature of a geographic region, potentially triggering additional

economic impacts under other State or local laws. In cases where these costs would not

have been triggered “but for” CHD, they are included in this economic analysis.

1091 For example, CEQA requires that lead agencies -- public agencies responsible for project

approval -- consider the environmental effects of proposed projects that are considered

discretionary in nature and not categorically or statutorily exempt. Among other

effects, the CEQA statutes specifically require lead agencies to consider a project’s

effects on rare or endangered plant and animal communities. To approve qualifying

1096 projects, lead agencies must require applicants, who are not “categorically exempt,” to

mitigate effects to less than significant levels for projects that are not granted a

“statement of overriding considerations.”22

In some instances, CHD can have an indirect effect on CEQA- related requirements.

1101 This is most likely to occur in areas where the Federal designation provides clearer

information on the importance of particular areas as habitat for a listed species. In

addition, applicants who were “categorically exempt” from preparing an

Environmental Impact Report under CEQA may no longer be exempt once critical
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42

habitat is designated. In cases where the designation triggers the CEQA significance

1106 test or results in a reduction of categorically exempt activities, associated costs are

considered to be an indirect effect of the designation. 

In these and other cases in which costs are incurred by landowners and managers

above and beyond what would be required under State or local law and policy in the

1111 absence of the designation, these costs are considered to be an indirect effect of the

designation. As such, these economic effects are reported in the analysis.

TIME DELAYS AND REGULATORY UNCERTAINTY

In addition to the indirect effects of compliance with other laws triggered by the

1116 designation, project proponents, land managers and landowners may face additional

indirect impacts. These can include costs due to project delays associated with the

consultation process or compliance with other regulations, or, in the case of land

location within or adjacent to the designation, loss in property values due to regulatory

uncertainty, and loss (or gain) in property values resulting from public perceptions

1121 regarding the effects of critical habitat. These categories of potential effects are

described in greater detail below.

Time Delays

1126 Both public and private entities may experience incremental time delays for projects

and other activities due to requirements associated with the section 7 consultation

process and/or compliance with other laws triggered by the designation. The need to

conduct a section 7 consultation will not necessarily delay a project, as often the

consultation may be coordinated with the existing baseline regulatory approval process. 

1131 However, depending on the schedule of the consultation, a project may experience

additional delays, resulting in an unanticipated extension in the time needed to fully

realize returns from the planned activity. To the extent that delays result from the

designation, they are considered in the analysis. Specifically, the analysis considers

costs associated with any incremental time delays associated with section 7 consultation

1136 or other requirements triggered by the designation above and beyond project delays

resulting from baseline regulatory processes.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

23 Designated critical habitat may also reduce such costs in the sense that boundaries are legally

defined in the rule, which in some cases, clarifies the importance of specific land parcels.

43

Regulatory Uncertainty

The Service conducts each section 7 consultation on a case-by-case basis and issues a BO

1141 on formal consultations based on species-specific and site-specific information. As a

result, government agencies and affiliated private parties who need to consult with the

Service under section 7 may face uncertainty concerning whether project modifications

will be recommended by the Service and what the nature of these modifications will be.

This uncertainty may diminish as consultations are completed and additional

1146 information becomes available on the effects of critical habitat on specific activities. 

However, a degree of regulatory uncertainty may persist. In some cases, this

uncertainty may be incorporated by the project proponent into the costs of completing a

proposed activity. For example, mining companies uncertain about potential

restrictions to their activities in designated areas of critical habitat may lease mining

1151 rights at a reduced rate. Additionally, landowners may incur costs determining

whether their property constitutes critical habitat.23 They may retain outside experts or

legal counsel to better understand their responsibilities with regard to critical habitat.

Where appropriate, the analysis considers the potential costs associated with regulatory

uncertainty.

1156

Stigma

In some cases, the public may perceive that CHD may result in incremental changes to

private property values, above and beyond those associated with anticipated project

1161 modifications and regulatory uncertainty described above. That is, the public may

perceive that, all else being equal, a property that is designated as critical habitat will

have lower market value than an identical property that is not within the boundaries of

critical habitat. Public attitudes about the limits and costs that critical habitat may

impose can cause real economic effects to the owners of property, regardless of whether

1166 such limits are actually imposed.
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February 24, 2004

24 Executive Order 12866, “Regulatory Planning and Review,” September 30, 1993.

25 U.S. Office of Management and Budget, “Draft 2003 Report to Congress on the Costs and

Benefits of Federal Regulations; Notice,” 68 Federal Register 5492, February 3, 2003; and U.S. Office

of Management and Budget, “Appendix 4: Guidelines to Standardize Measure of Costs and

Benefits and the Format of Accounting Statements,” in Report to Congress on the Costs and Benefits

of Federal Regulations, March 22, 2000.

44

Conversely, the direction of property value effects resulting from critical habitat may be

positive rather than negative. For example, property owners may believe that CHD will

increase property values, if they believe that such designation will slow sprawling

1171 development in a given community (i.e., protect the rural character of an area) o

increase water quality of neighborhood streams and rivers. This perception alone may

result in real increases in land values, even in cases where the economic analysis

predicts no additional requirements on activities taking place in the area. In either case,

as the public becomes aware of the true regulatory burden imposed by critical habitat,

1176 the impact of the designation on property markets should decrease. This analysis

considers the implications of public perceptions related to critical habitat on private

property values within the proposed designation.

Benefits

1181

The published economics literature has documented that real social welfare benefits can

result from the conservation and recovery of endangered and threatened species. Such

benefits have also been ascribed to preservation of open space and biodiversity, both of

which are associated with species conservation. Likewise, regional economies and

1186 communities can benefit from the preservation of healthy populations of endangered

and threatened species, and the habitat on which these species depend. Finally, in some

cases the preservation of open space may result in increased property values, either to

on-site or adjacent parcels, due to the amenity value associated with owning property

next to permanently protected open space. 

1191

In Executive Order 12866, OMB directs Federal agencies to provide an assessment of

costs and benefits of a proposed regulatory action.24 However, in its guidance for

implementing Executive Order 12866, OMB acknowledges that often, it may not be

feasible to monetize, or even quantify, the benefits of environmental regulations.25
Final Draft Report

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45

1196 Where benefits cannot be quantified, OMB directs agencies to describe the benefits of a

proposed regulation qualitatively. This report provides insight into the potential

economic benefits of CHD based on information obtained in the course of developing

the economic analysis. It is not intended to provide a complete analysis of all of the

benefits that could result from the designation. Given these limitations, the Service believes

1201 that the benefits of CHD are best expressed in biological terms that can be weighed against the

expected cost impacts of the rulemaking.

Analytic Time Frame

1206 The analysis examines activities taking place both within and adjacent to the proposed

designation. It estimates impacts based on activities that are “reasonably foreseeable,"

including, but not limited to, activities that are currently authorized, permitted, or

funded, or for which proposed plans are currently available to the public. Accordingly,

the analysis bases estimates on activities that are likely to occur through the year 2025,

1211 beginning on the day that the current proposed rule becomes available to the public. 

As discussed in Chapter III, official regional demographic projections for the majority

of counties included in the proposed designation are available only through 2025. 

Because EPS did not have adequate data to provide reliable forecasts beyond 2025 for

the majority of the proposed designation, this timeframe was deemed the most

1216 appropriate for the analysis. 

General Analytic Steps

This report relies on a sequential methodology and focuses on distilling the salient and

1221 relevant aspects of potential economic impacts of the proposed designation. The steps

followed in this analysis consist of:

• Describing current and projected economic activity within and around the

proposed critical habitat area;

1226

• Identifying whether such activities are likely to involve a Federal nexus;
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46

• For activities with a Federal nexus, evaluating the likelihood that these activities

will require consultations under section 7 of the Act and, in turn, result in any

1231 modifications to projects;

• Estimating the direct costs of expected section 7 consultations, project

modifications and other economic impacts associated with the designation;

1236 • Estimating the likelihood that current or future activities may require additional

compliance with other Federal, State, and local laws as a result of new

information provided by the proposed designation;

• Estimating the likelihood that projects will be delayed by the consultation

1241 process or other regulatory requirements triggered by the designation;

• Estimating the likelihood that economic activity will be affected by regulatory

uncertainty, and/or property values affected;

1246 • Estimating the indirect costs of the designation, as reflected in the cost of

compliance with State and local laws, project delays, regulatory uncertainty, and

effects on property values;

• Assessing the extent to which CHD will create costs for small businesses as a

1251 result of modifications or delays to projects;

• Assessing the effects of administrative costs and project modifications on the

supply, distribution, and use of energy; and

1256 • Determining the benefits that may be associated with CHD.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

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47

As noted above, this analysis considers both the efficiency effects and distributional

effects that could result from this designation. It begins by considering direct

compliance costs associated with the designation, as well as potential indirect effects,

1261 such as those effects associated with compliance with other Federal, State, and local

laws, project delays, and impacts to property values. As necessary, regional economic

impacts are described, as are impacts on significantly affected markets. Impacts on

small entities and energy production and consumption are discussed separately, in

Chapter VII. Potential benefits of critical habitat are discussed qualitatively, in Chapter

1266 VIII.

REFERENCES

Publications

1271

CEQA, Article 19. http://ceres.ca.gov/ceqa/flowchart/exemptions/ categorical.html, as

viewed on April 21, 2003.

Gramlich, Edward M., A Guide to Benefit-Cost Analysis (2nd Ed.), Prospect Heights,

1276 Illinois: Waveland Press, Inc., 1990.

Industrial Economics, Incorporated, Draft Economic Analysis of Critical Habitat

Designation for the Nine Bexar County Texas Invertebrate Species, prepared for the

U.S. Fish and Wildlife Service, October 2002.

1281

U.S. Department of the Interior and U.S. Department of Commerce, Habitat Conservation

Planning and Incidental Take Permit Processing Handbook, November 4, 1996.

U.S. Environmental Protection Agency, Guidelines for Preparing Economic Analyses, EPA

1286 240-R-00-003, September 2000.

U.S. Fish and Wildlife Service, “Endangered Species and Habitat Conservation

Planning.” From: http://endangered.fws.gov/hcp/, as viewed on August 6, 2002.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

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48

1291 U.S. Office of Management and Budget, “Appendix 4: Guidelines to Standardize

Measure of Costs and Benefits and the Format of Accounting Statements,” in

Report to Congress on the Costs and Benefits of Federal Regulations, March 22, 2000.

U.S. Office of Management and Budget, “Draft 2003 Report to Congress on the Costs

1296 and Benefits of Federal Regulations; Notice,” 68 Federal Register 5492, February 3,

2003.

Legislation

1301 2 U.S.C. §§658-658g and 1501-1571

5 U.S.C. §§ et seq; and Pub Law No. 104-121.

5 U.S.C. § 601 et seq.

1306

50 CFR Part 402.02.

Executive Order 12866, “Regulatory Planning and Review,” September 30, 1993.

1311 Executive Order 13211, “Actions Concerning Regulations That Significantly Affect

Energy Supply, Distribution, or Use," May 18, 2001.

New Mexico Cattle Growers Assn. v. U.S.F.W.S., 248 F.3d 1277 (10th Cir. 2001).

1316
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

49

POTENTIALLY AFFECTED ACTIVITIES

Any activities on Federal lands that may affect the gnatcatcher or its CH, as well as any

activities on State or private lands that require Federal agency approval or oversight,

would be subject to section 7 consultation. In particular, the proposed rule identified

1321 the following activities that, when funded, authorized, or carried out by a Federal

agency, may affect the gnatcatcher or its CH:

1. Development on private lands requiring permits from Federal agencies, such as

authorization from the United States Army Corps of Engineers (USACE)

pursuant to section 404 of the Clean Water Act, or a section 10(a)(1)(B) permit

1326 from the Service, or some other Federal action that includes Federal funding that

will subject the action to the section 7 consultation process (e.g., from the Federal

Highway Administration, Federal Emergency Management Agency, or the

Department of Housing and Urban Development);

2. Military activities of the Department of Defense on its lands or lands under its

1331 jurisdiction;

3. The release or authorization of release of biological control agents by the U.S.

Department of Agriculture;

4. Regulation of activities affecting point source pollution discharges into waters of

the United States by the Environmental Protection Agency under section 402 of

1336 the Clean Water Act;

5. Construction of communication sites licensed by the Federal Communications

Commission (FCC); and

6. Authorization of Federal grants or loans.
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50

After reviewing the above listed activities, and conducting interviews with the relevant

1341 Federal agencies, the following activities were identified that may affect the gnatcatcher

or its habitat, and will be the foci of this analysis:

1. Private development requiring USACE permitting under the Clean Water 

Act;

2. Transportation projects by Caltrans and the TCA that either require USACE

1346 section 404 authorization or receive Federal funding (e.g., FHWA funds);

3. Construction of regional municipal water infrastructure by the San Diego

County Water Authority (SDCWA) and the MWD that involves USACE section

404 authorization; 

4. Flood control and water treatment projects that receive funds from the BOR;

1351 5. Construction of regional gas and electricity infrastructure by SDG&E, SCE, and

the SCGC that involves Federal Energy Regulatory Commission (FERC)

approval or USACE section 404 authorization;

6. Land management practices (e.g., fire prevention) by the USFS and Bureau of

Land Management (BLM);

1356 7. Emergency management actions by FEMA;

8. Military operations and land management by the USMC and U.S. Navy; and

9. Internal section 7 consultations required by the Service to approve existing and

future Habitat Conservation Plans that address the gnatcatcher.
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February 24, 2004

26

In attempting to define the baseline regulatory environment, this analysis also considered Riverside

County’s local grading permit application requirement. Through this process, permit applicants are

required to perform a habitat assessment if the County alerts them that their property “may contain

vegetation...which could support the [gnatcatcher].” Negative survey results allow applicants to

receive grading permits, while positive survey results require them to perform additional surveys

and engage the Service, if necessary. The survey requirement is a purely informational procedure,

and thus does not provide any additional protection to the species or its habitat. The costs

associated with the preliminary habitat assessment may overlap with similar activities undertaken

during a biological assessment as part of a section 7 consultation. However, the reduction in section

7 administrative costs resulting from this baseline requirement is assumed to be negligible. 

Therefore, this analysis does not attempt to net out the baseline costs of surveying that result from

Riverside County’s grading permit approval process. 

 

51

1361 II. REGULATORY BACKGROUND

This chapter describes the existing regulatory environment relevant to gnatcatcher and

CSS habitat in California. As described, a number of existing regulations and

regulatory regimes require agencies and applicants to consider the impacts of their

1366 actions or projects on CSS, and thus gnatcatcher habitat, and to mitigate those impacts

independent of section 7. In other words, in the “world without section 7,” project

applicants would be required to mitigate CSS impacts under these baseline regulations

and regulatory regimes. As discussed in Chapter I, the costs associated with such

mitigation requirements are therefore appropriately considered as baseline, and are not

1371 attributed to project modification requirements under section 7.

The relevant baseline regulations identified as part of this analysis include:26

1. Section 4(d) Special Rule,

2. CEQA,

1376 3. Project-Specific Habitat Conservation Plans,

4. Regional Habitat Conservation Plans, and

5. Integrated Natural Resource Management Plans.
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

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27Although all of the areas proposed for designation in Unit 1 lie within the planning area of the

MSCP, only the Otay-Sweetwater Unit of the San Diego National Wildlife Refuge Complex (SDNWR)

is officially enrolled in the MSCP. The MSCP is not considered a baseline regulation for the SDNWR

because it is a federally owned refuge – this analysis assumes that future projects would be purely

Federal in nature and any project modifications would be negotiated through the section 7

consultation process. The MSCP is not considered a baseline regulation for the remaining areas in

Unit 1 because these areas are not within the boundaries of approved sub-area plans.

52

This analysis evaluates the economic impact of critical habitat in areas proposed for

1381 designation as well as in areas proposed for exclusion. As described in Chapter I, areas

proposed for exclusion include lands within a variety of existing project-specific HCP

reserves, lands in approved regional HCP planning areas (i.e., the MSCP and Orange

County Central/Coastal NCCP/HCP), areas covered by an existing INRMP (MCAS

Miramar), and lands excluded due to a consideration of economic and other relevant

1386 impacts (i.e., mission-essential training areas at Camp Pendleton and Tribal lands of the

Pala Band of Mission Indians). 

The following discussion is divided into three sections: the first describes baseline

regulations relevant to lands proposed for designation (i.e., regulations 1 and 2, listed

above); the second describes baseline regulations relevant to lands proposed for

1391 exclusion (i.e., regulations 1-5, listed above); and the third describes ongoing regulatory

processes that could potentially constitute baseline regulations, if approved. Table 5

provides a schematic summary of where and to what extent each of these regulations

applies.

BASELINE IN AREAS PROPOSED FOR CRITICAL HABITAT

1396 The following discussion addresses project-specific HCPs, the Orange County

Central/Coastal NCCP/HCP, the 4(d) Special Rule, and CEQA, which this analysis

considers to be a complete list of all baseline regulations that apply to lands proposed

for CHD. As discussed in the next section, some of these regulations may also

constitute baseline conditions for areas proposed for exclusion.27
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

28 Participating landowners are the San Joaquin Hills Transportation Corridor Agency, the

Foothill/Eastern Transportation Corridor Agency, the Orange County Fire Authority, the Orange

County Flood Control District, the Regents of the University of California, the Santiago County

Water District, the Irvine Ranch Water District, the Metropolitan Water District of Southern

California, Southern California Edison, M.H. Sherman Company, Chandis Security Company,

Sherman Foundation, and The Irvine Company.

53

1401 ORANGE COUNTY CENTRAL/COASTAL NCCP/HCP

This analysis assumes that no future section 7 project modification costs will be incurred by

Participating Landowners in the Plan. Any future section 7 consultations required for projects

with a Federal nexus that are carried out by non-participating landowners in EUAs may result

in project modification costs attributable to section 7. Two additional section 7 consultations are

1406 anticipated within the El Toro Reuse Area and the Irvine Ranch Land Reserve, which would

result in administrative section 7 costs only.

Background

The Central/Coastal Orange County NCCP/HCP is a regional HCP that was approved

and adopted on July 17, 1996. Regional HCPs generally encompass larger planning

1411 areas than project-specific HCPs and are designed to provide systematic processes for

granting incidental take to a broad range of future projects or activities. This plan

reflects conservation measures committed to by the County of Orange, cities within

Orange County, and Participating Landowners, and approved by the Service. 

Participating landowners are agencies or entities that participated in the development

1416 of the plan and contributed land and/or funds for administration, management, or

reserve creation.28 The plan established a defined reserve system, composed of both

public land and private land dedicated by participating landowners, parts of which –

the El Toro Reuse Area and the Irvine Ranch Land Reserve – have been proposed for

CHD in Unit 7. The plan also established several classes of “non-reserve supplemental

1421 habitat areas,” including Special Linkage Areas (SLAs), EUAs, and the North Ranch

Policy Plan Area (NRPPA). Several EUAs have also been proposed for critical habitat

as part of Unit 7.

The Central/Coastal HCP/NCCP is a conservation plan that provides conservation

1426 measures to minimize and mitigate the impacts of take resulting from planned activities

by participating landowners. By contributing land or money through the plan
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

29 Section 8.3.5(e) of the Implementation Agreement for the Central/Coastal HCP/NCCP stipulates

that “in the event that a CH determination is made for any CSS Species [such as the

Gnatcatcher]...no additional mitigation in the form of land or financial compensation shall be

required of any Participating Landowner in connection with Planned Activities through the

section 7 consultation process under FESA or otherwise.”

54

development process, participating landowners received assurances that they had

satisfied their mitigation requirements for future “take” occurring as a result of planned

activities. These assurances also apply to planned activities within the reserves, as

1431 described below. In accordance with its “No Surprises” policy, and consistent with the

plan’s goal of conserving habitat essential to the gnatcatcher within the HCP’s

boundaries, the Service assured Participating Landowners that any future CHD would

not require additional mitigation by participating landowners for activities covered by

the plan.29 

1436 Application to Economic Cost Calculation

This analysis assumes that no section 7 project modification costs will be incurred for

planned activities by participating landowners within the Central/Coastal HCP plan

area (and thus within proposed CH unit 7). As described below, certain activities by

non-participating landowners that have a Federal nexus may result in project

1441 modification costs. All future projects with a Federal nexus within Unit 7, including

those by participating landowners, will incur administrative section 7 consultation

costs. Consultations for activities by participating landowners are assumed to be

streamlined informal consultations. The estimated administrative cost of these

anticipated section 7 consultations is shown in Appendix Table A-9. The assumptions

1446 within each planning areas are as follows: 

C El Toro Reuse Area: The only Planned Activity with a Federal nexus is the

proposed construction of Alton Parkway by the County of Orange through the

southeast corner of the El Toro parcel. As a planned activity in an established

1451 reserve area, CSS impacts for this project have already been mitigated in full,

and the project applicants would incur only administrative section 7 costs.
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55

C Irvine Ranch Land Reserve: The only Planned Activities with a Federal nexus

are potential future trail construction projects throughout the reserve that may

1456 require USACE section 404 authorization; other land uses are prohibited by a

conservation easement, which is considered a baseline regulation that is not

attributed to section 7. Service staff have indicated they do not expect these

projects to require section 7 consultation because the Irvine Company has made

extensive efforts to collaborate with the Service and to design all its projects in

1461 reserve areas to avoid impacts to CSS and gnatcatcher habitat. As a conservative

measure (i.e., to more likely overestimate than underestimate economic

impacts), this analysis assumes that future trail construction will lead to one

informal section 7 consultation. As a planned activity, CSS impacts for this

project have already been mitigated in full, so the project applicant would incur

1466 only administrative consultation costs.

C Existing Use Areas: CH has been proposed for approximately 3,200 acres that

have been established as EUAs in the Orange County NCCP/HCP. EUAs are

private land owned by non-participating landowners. Current land uses are

1471 allowed, but any future changes in land use would require consultation with the

Service (under section 7 or section 10). Incidental take has not been authorized

for any EUAs. Any future development with a Federal nexus would require

section 7 consultations with the Service, and may incur administrative and

project modification costs.

1476 SECTION 4(D) SPECIALRULE

This analysis assumes that the 4(d) Rule constitutes a regulatory baseline for qualifying projects

in southern Orange County, the City of Rancho Palos Verdes (Los Angeles County), and San

Diego County, outside the San Diego National Wildlife Refuge. Future projects in these areas

that have a Federal nexus would incur administrative section 7 costs, but would not incur

1481 project modification costs attributable to section 7. Future projects with a Federal nexus that are

carried out only by a Federal agency, or do not meet 4(d) Special Rule qualifying criteria, will be

processed entirely through section 7, and all administrative and project modification costs will be

attributable to section 7 and/or other baseline regulations.
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56

1486 Background

In December 1993, following the listing of the gnatcatcher as a Federally threatened

species, the Service issued a Special Rule under section 4(d) of the Act (hereafter, the

4(d) Rule). The 4(d) Rule exempts from the take prohibitions of section 9 of the

Endangered Species Act incidental take of gnatcatchers resulting from projects in local

1491 jurisdictions that have voluntarily enrolled lands in the NCCP program, and that are

actively developing NCCPs that address the gnatcatcher and CSS. It allows these

jurisdictions to approve projects that will alter CSS habitat by issuing Habitat Loss

Permits (HLPs). If the Service concludes the project is consistent with the 4(d)

guidelines, the HLP allows an applicant to remove a specified amount of CSS without

1496 having to obtain an incidental take permit through section 10(a) of the Act for any

associated take of the gnatcatcher. 

As discussed in more detail below, projects with a Federal nexus must still consult

under section 7 to obtain incidental take authorization, though any required CSS

1501 mitigation is processed according to 4(d) Rule standards. When the HCP/NCCP is

ultimately approved, all ensuing CSS impacts will be processed through the approved

plan and the 4(d) Rule no longer applies. 

For a project to be approved under the 4(d) Rule, the local jurisdiction must insure, with

1506 the Service’s approval, that each HLP it issues meets all of the following criteria:

C The habitat loss does not exceed five (5) percent of the total available CSS at the

time the 4(d) Rule took effect.

C The habitat loss will not preclude connectivity between areas of high habitat

1511 value.

C The habitat loss will not preclude or prevent the preparation of the sub-regional

NCCP.

C Habitat loss has been minimized and mitigated to the maximum extent

practicable.

1516 C The habitat loss will not jeopardize the continued existence of the coastal

California gnatcatcher.
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57

C Any take is incidental to the pursuit of otherwise lawful activities.

Participating Areas

Currently, San Diego County, southern Orange County, and the City of Rancho Palos

1521 Verdes (Los Angeles County) are the only areas within the proposed CH boundaries

that are enrolled in the 4(d) Rule program and are authorized to issue HLPs. The

remaining counties and jurisdictions either have approved NCCPs/HCPs in place

(central/coastal Orange), have chosen not to participate in the 4(d) Rule by declining to

enroll lands in the NCCP program (Riverside County), or are not actively pursuing

1526 regional HCP/NCCPs that address the gnatcatcher and CSS (northern Orange, San

Bernardino, Los Angeles, and Ventura counties). Within San Diego County, projects in

the SDNWR (Unit 1) are assumed to involve only Federal agencies on Federal land –

these projects would be processed entirely through section 7, and the 4(d) Rule would

not constitute a baseline regulation.

1531 The 4(D) Rule and Section 7

The 4(d) Rule is intended primarily to obviate the need for private entities to seek

individual section 10(a) permits when their projects are likely to result in the take of

gnatcatchers and the local jurisdictions in which the proposed project is located are

actively engaged in the NCCP process. Projects with a Federal nexus that may affect

1536 the gnatcatcher but still comply with the 4(d) Rule criteria listed above will require

independent section 7 consultation, and the Service would authorize any incidental take

through issuance of a BO. Based on input from the Service, and on an independent

review of selected BOs for projects in the 4(d) Rule area, CSS mitigation incorporated

into projects that go through the section 7 process is equivalent to mitigation typically

1541 required for HLP issuance under the 4(d) Rule. Furthermore, loss of CSS habitat

identified in the section 7 process is deducted from the enrolled jurisdiction’s fivepercent allotment as established by the 4(d) Rule, including CSS take authorized for

Federal projects only (i.e., those with no third party applicant). 

1546 These facts demonstrate that (1) applicants with a Federal nexus would incur the same

mitigation costs under the 4(d) Rule if they were not required to consult under section

7, and (2) both the Service and local agencies in 4(d) Rule areas track incidental take of

CSS permitted through section 7 consultation with reference to levels established by the
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58

4(d) Rule. In other words, in the “world without section 7,” projects with a Federal

1551 nexus would be required to mitigate CSS impacts under the 4(d) Rule, and the overall

amount of habitat loss would be the same (five percent). This analysis therefore

considers the 4(d) Rule a baseline regulation in San Diego County, southern Orange

County, and the City of Rancho Palos Verdes, and project modification costs for CSS

impacts are not considered attributable to section 7. All projects with a Federal nexus in

1556 4(d) Rule areas will incur administrative section 7 consultation costs.

Projects Without 4(d) Rule Baseline Protection

It is important to note that not all future projects within the 4(d) Rule area will meet all

five criteria listed above. Any project that does not meet all of the criteria is entirely

exempt from the 4(d) Rule process, and those exempt projects with a Federal nexus

1561 would require independent section 7 consultation. All administrative and project

modification costs of any such project would be entirely attributable to section 7. 

According to Service and local agency staff, no proposed projects have been denied 4(d)

Rule approval in Orange County or the City of Palos Verdes, though some have had to

agree to project redesigns in order to secure approval. A small number of projects in

1566 San Diego County have been denied 4(d) approval, though Service staff estimates that

greater than 95 percent of projects seeking 4(d) approval are successful. In general, the

only projects that are likely to be denied 4(d) approval are very large, identifiable ones. 

In San Diego and Orange counties, these projects are also likely to be regulated under

the requirements of CEQA, as described further below. 

1571 CALIFORNIA ENVIRONMENTAL QUALITY ACT

This analysis assumes that lead agencies’ enforcement of CEQA regulations in San Diego and

Orange counties constitutes a regulatory baseline for projects not already covered by the 4(d)

Rule. However, CSS mitigation required through the CEQA process may not be as onerous or

consistently applied as typical project modifications under section 7 – in such cases, the

1576 difference between CSS mitigation associated with section 7 and that associated with CEQA

would be attributable to section 7. In contrast, all project modification costs for projects with a

Federal nexus in Riverside, San Bernardino, Los Angeles and Ventura counties are assumed to

be attributable to section 7. CEQA is not considered a baseline regulation for purely Federal
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

30Much case law has been devoted to clarifying the definitions of “project” and “discretionary”

since CEQA’s adoption in 1970. In general, a project is defined as “any activity that has the

potential for a direct physical change or a reasonably foreseeable indirect physical change to the

environment.” A discretionary project is one that requires an exercise of judgement or

deliberation on the part of a public agency (as opposed to a “ministerial” project subject to

automatic approval). A list of categorical exemptions can be found in the CEQA Guidelines (14

C.C.R. 15301 et seq), and a list of statutory exemptions can be found in the CEQA Statutes (Pub.

Res. Code 21080 et seq).

31 Ap p en d ix G of th e CEQ A Gu id elin es (14 C.C.R. 15000 et seq) requ ires lead agen cies to issue a

“m an d atory find ing of sign ifican ce” w he n p erform ing an Initial Stu d y if a p roject has th e

p ote n tial to “...red u ce th e n u m ber or restrict th e ran ge of a rare or en d an gered p lan t o r an im al.”

32Unlike the National Environmental Policy Act (NEPA), which is considered purely an

informational act, CEQA requires lead agencies to ensure applicants mitigate their projects to a

“less than significant” level. A lead agency may consider the adverse environmental effects of a

project “acceptable,” and issue a statement of overriding considerations if it finds and

demonstrates that the “...specific economic, legal, social, technological, or other benefits of a

proposed project outweigh the unavoidable adverse environmental effects” (14 C.C.R. 15093).

59

projects with no third party applicants. All future projects with a Federal nexus will require

1581 administrative section 7 consultation costs.

Background

CEQA requires that lead agencies – public agencies responsible for project approval –

consider the environmental effects of proposed private projects that are considered

“discretionary” in nature, and that are not categorically or statutorily exempt.30 Among

1586 other effects, the CEQA statutes specifically require lead agencies to consider a project’s

effects on rare or endangered plant and animal communities.31 To approve qualifying

projects, lead agencies must require applicants to mitigate effects to “less than

significant” levels for projects that are not granted a “statement of overriding

considerations.”32 In certain cases, therefore, it is possible that a lead agency’s

1591 enforcement of CEQA regulations will result in mitigation for impacts to rare or

endangered species’ habitat independent of section 7 or section 10 requirements. In

these cases that involve a Federal nexus, CEQA enforcement of CSS mitigation would

constitute a baseline regulation, and associated costs would not appropriately be

attributable to section 7. For a discussion of potential indirect economic effects due to

1596 lead agencies’ enforcement of CEQA guidelines, refer to Chapters I and IV. 
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33The California legislature passed the NCCP Act in 1991, designed in part to establish a proactive

mechanism to preserve CSS habitat in southern California and to potentially avert the need to list

the gnatcatcher under the Endangered Species Act. Since then, a number of cities and counties in

southern California have voluntarily enrolled lands in the NCCP program. Once enrolled, CEQA

Guidelines require lead agencies to consider whether a project would “conflict with the

provisions of an adopted...Natural Community Conservation Plan” in performing an Initial

Study (Appendix G, 14 C.C.R. 15000 et seq.). 

60

Regional Difference in CEQA Implementation

The California Department of Fish and Game (DFG) has officially assigned CSS habitat

a sensitivity ranking, recognizing it as a “very threatened” (S2.1) habitat type on its list

1601 of “Sensitivity of Top Priority Rare Natural Communities in Southern California”.

Though this official recognition may compel certain lead agencies to pay special

attention to CSS impacts, and possibly require mitigation accordingly, it does not legally

require lead agencies to do so. CEQA implementation and enforcement is therefore

entirely at the discretion of the lead agency with respect to CSS mitigation. As a result,

1606 CEQA provides effective baseline mitigation for CSS habitat in certain regions, and

does not in others, depending on the likelihood the region’s local lead agencies require

CSS mitigation. Research conducted during the course of this analysis indicates that the

following regions address CSS under CEQA as follows:

1611 C San Diego and Orange Counties. According to DFG staff, nearly all lead

agencies in San Diego and Orange counties currently require mitigation for CSS

impacts as part of their administration of the CEQA process. This is likely due

to either the fact that (1) lead agencies voluntarily require CSS mitigation under

CEQA, and/or (2) these regions contain lands enrolled in the NCCP process

1616 through the NCCP Act of 1991, and CEQA enforcement therefore specifically

requires consideration of impacts to CSS.33 As discussed previously, the 4(d)

Rule constitutes a baseline requirement in San Diego County and southern

Orange County. This analysis assumes that CEQA constitutes a baseline

requirement for CSS mitigation in areas in Orange County outside 4(d) Rule

1621 jurisdiction (e.g., EUAs) , and when projects in either county do not qualify for

4(d) approval.
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34 Personal communication with Jeff Drongensen, Senior Environmental Scientist, Inland Desert

District, California Department of Fish and Game, on March 3, 2003.

35 Personal com m u nication w ith Don Chad w ick and Morgan Weh tje, Senior Environm ental

Scien tists, Sou th Coa st District, Califor n ia D ep artm en t o f Fish an d Gam e, on Feb ru ary 28 an d

M arch 3, 2003.

61

C Riverside and San Bernardino Counties. DFG staff indicates that lead agencies

1626 in Riverside and San Bernardino counties have not historically required CSS

mitigation as part of the CEQA process.34 This analysis assumes that CEQA

does not constitute a baseline requirement for CSS mitigation in these counties. 

C Los Angeles and Ventura Counties. According to DFG staff, lead agencies in

1631 Los Angeles and Ventura counties have not historically exhibited a clear pattern,

requiring CSS mitigation under CEQA in certain cases and not requiring it in

others.35 This analysis assumes that CEQA does not constitute a baseline

requirement for CSS mitigation in these counties. 

Level of CSS Mitigation Required Under CEQA

1636 The level of CSS mitigation required under CEQA is an important factor in determining

the incremental cost of section 7 above CEQA baseline requirements. Service staff has

indicated that in areas where lead agencies have required CSS mitigation under CEQA,

those mitigation standards have typically been similar to project modifications resulting

from section 7 consultations for the gnatcatcher. DFG staff has concurred that, on

1641 average, mitigation requirements under CEQA are similar to the on-site measures that

typically result from section 7 consultations. However, overall the mitigation

requirements of CEQA may not be as onerous and consistently applied as those under

section 7 due to the following factors:

1646 1. Large projects under CEQA may be able to proceed with “statements of

overriding considerations,” an option not available under section 7;and

2. The CEQA mitigation requirements are generally based on a different set of

considerations than those under section 7. Specifically, CEQA mitigation

1651 requirements are focused on CSS rather than the gnatcatcher per se and thus
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may ignore factors such as jeopardy or the preservation of key habitat areas

(e.g., “stepping-stones”).

Due to the foregoing considerations, this analysis assumes that in areas where lead

1656 agencies have traditionally required CSS mitigation under CEQA (and other baseline

standards are assumed not to apply), section 7 consultation may generate slightly

greater project modification costs than those that would have been required under

CEQA. In other words, in the “world without section 7,” all projects in San Diego and

Orange counties not addressed by the 4(d) Rule would be required to mitigate CSS

1661 impacts under CEQA to a slightly lower degree than would be required under section

7.

DFG staff have indicated that, on average, it encourages local lead agencies that enforce

CSS mitigation under CEQA to employ a 2-to-1 mitigation ratio. While the actual ratio

1666 implemented for any particular project may vary, this is considered a reasonable

estimate of baseline CSS mitigation standards under CEQA in San Diego and Orange

counties. Therefore, this analysis considers the difference between this 2-to-1 baseline

standard and the mitigation levels typically resulting from section 7 to be attributable

entirely to section 7 – that this increment represents the “net” CSS mitigation ratio

1671 attributable to section 7. Furthermore, because both the Service and the DFG suggest

that additional project modification costs incurred as a result of section 7 generally take

the form of project redesign/avoidance, the cost of the additional section 7 mitigation

will be calculated assuming it represents an on-site set-aside requirement (as opposed

to off-site preservation or restoration). 

1676

Finally, any project with a Federal nexus within proposed CH will incur administrative

section 7 consultation costs.
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BASELINE IN AREAS PROPOSED FOR EXCLUSION

This section evaluates baseline regulations that would apply if critical habitat were

1681 designated in areas that have currently been proposed for exclusion. As described in

Chapter I, areas proposed for exclusion include approved project-specific HCPs that

address the gnatcatcher, areas within the MSCP and Orange County Central/Coastal

NCCP/HCP planning areas, MCAS Miramar, mission-critical training areas at Camp

Pendleton, and Tribal lands owned by the Pala Band of Mission Indians. The 4(d) Rule

1686 and CEQA also apply to some of the areas proposed for exclusion; in contrast, several

other baseline regulations – most notably the two approved regional HCPs and INRMP

for MCAS Miramar – apply only to areas that have been proposed for exclusion. Table

7 provides a summary of each baseline regulation’s applicability. 

1691 CEQA would constitute a regulatory baseline for areas proposed for exclusion that are

considered “non-reserve supplemental habitat areas” within the Orange County

Central/Coastal NCCP/HCP (see below for a more detailed discussion of these areas). 

Regulatory baseline conditions for all other areas that have been proposed for exclusion

are addressed either through approved HCPs (project-specific or regional) or military

1696 INRMPs. No regulatory baseline has been identified for Tribal lands of the Pala Band

of Mission Indians. The 4(d) Rule does not constitute a regulatory baseline for any

lands proposed for exclusion (all lands in San Diego and Orange counties would be

addressed by either approved HCPs, CEQA, or INRMPs; Federal activities on military

and/or Tribal land would not qualify for 4(d) approval). A discussion of regulatory

1701 conditions related to approved HCPs is provided below.

PROJECT-SPECIFIC HABITAT CONSERVATION PLANS

If critical habitat were designated in established project-specific HCP reserve areas, no section 7

project modification costs would be incurred. Projects with a Federal nexus could require

administrative section 7 consultation costs, though future projects within established HCP

1706 reserves are considered unlikely. Finally, each HCP would require one internal, informal

consultation by the Service if CH were designated.
Table 7

Summary of Baseline Regulations that Address the Gnatcatcher and Coastal Sage Scrub

Region

Small-scale MSCP 4(d) Rule Central/ CEQA INRMP Admin. Project

HCPs Coastal NCCP Modification

Areas Proposed for Designation

San Diego County

Unit 1

Cities of Chula Vista, El Cajon, and Santee -- -- X -- P -- Yes Some (2)(3)

County MSCP major amendment areas -- -- X -- P -- Yes Some (2)(3)

San Diego National Wildlife Refuge -- -- -- -- -- -- Yes Yes

Water district lands -- -- X -- P -- Yes Some (2)(3)

Fallbrook Naval Weapons Station (Unit 4) -- -- -- -- -- -- Yes Yes

Remainder of County (Units 2, 3, & 5) -- -- X -- P -- Yes Some (2)(3)

Orange County

Southern Orange County -- -- X -- P -- Yes Some (2)(3)

Northern Orange County -- -- -- -- X -- Yes Some (3)

Central/Coastal Orange (HCP/NCCP)

EUAs -- -- -- -- X -- Yes Some (3)

El Toro and Irvine Ranch Reserves -- -- -- X P -- Yes No

Riverside County -- -- -- -- -- -- Yes Yes

San Bernardino County -- -- -- -- -- -- Yes Yes

Los Angeles County

City of Rancho Palos Verdes -- -- X -- -- -- Yes No (4)

Remainder of County -- -- -- -- -- -- Yes Yes

Ventura County -- -- -- -- -- -- Yes Yes

Areas Proposed for Exclusion

San Diego County

Multiple Species Conservation Plan (MSCP)

Cities of San Diego & La Mesa; SD County -- X -- -- -- -- Yes No

City of Poway -- -- -- -- X -- Yes Some (3)

MCAS Miramar -- -- -- -- -- X Yes No

USMC Camp Pendleton (training areas) -- -- -- -- -- -- Yes Yes

Pala Band of Mission Indians Reservation -- -- -- -- -- -- Yes Yes

Orange County

Central/Coastal Orange (HCP/NCCP)

Reserves -- -- -- X -- -- Yes No

Approved Project-specific HCPs (all Units) X -- -- -- -- -- Yes No

Notes:

X : For the purposes of this analysis, this baseline regulation is treated as the primary determinant of CSS mitigation requirements in this region.

P : For the purposes of this analysis, this baseline regulation applies in this region but is not the primary determinant of the CSS mitigation requirement.

-- : This baseline regulation is assumed not to apply to this region.

(1) Answer to question: "For projects with a Federal nexus, will there be costs attributable to section 7?"

(2) : The 4(d) Rule is the primary baseline requirement with respect to CSS mitigation. CEQA requirements are considered a 

 baseline regulation when a project does not qualify for 4(d) Rule consideration. 

(3) : Project modification costs above the "CEQA baseline" are attributable to section 7.

(4) : According to City staff, no projects in Rancho Palos Verdes have been denied 4(d) approval.

Applicable Baseline Regulation Section 7 Costs (1)

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1711 Background

An HCP is a conservation plan provided for in section 10(a) of the Act that identifies

conservation measures an applicant will undertake to minimize and mitigate the

impacts of “take” on a listed species. In return for committing to develop an HCP

consistent with the statutory criteria of section 10, the applicant is granted an

1716 “incidental take permit” for the species. An HCP must be approved by the Service and

applied within a specified geographic area. 

The project-specific HCPs that have been proposed for exclusion are limited to reserve

areas identified in approved HCPs that address the gnatcatcher. For some HCPs the

1721 Service has not proposed critical habitat because the approved HCP already establishes

adequate management for the species (in which case the areas do not meet the

definition of critical habitat under section 3(5)(a)); other HCPs have been proposed for

exclusion based on the Service’s determination that the benefits of exclusion outweigh

the benefits of inclusion (in which case they have been proposed for exclusion under

1726 section 4(b)(2)).

Any future projects that take place within these reserve areas will be regulated by the

terms and conditions of the HCP and its implementing agreement, which would

therefore constitute a regulatory baseline if critical habitat were to be designated on

these lands. The section 10(a) permits associated with these HCPs authorize a range of

1731 activities, including incidental take for discrete development projects as well as a

variety of ongoing and planned activities by a particular applicant. In all cases, the

associated HCPs specify reserve areas to be preserved as mitigation for expected take. 

Through the terms of these project-specific HCPs, land has already been acquired for

these reserves (either through fee-title or conservation easement) and reserve

1736 management established.

Application to Economic Cost Calculation

In general, approved HCPs contain assurances to the applicant that activities covered

by the HCP will not require additional mitigation or project modifications above those

already negotiated as part of the HCP. As a result, if critical habitat were to be

1741 designated within these project-specific HCP reserve areas, future section 7 costs would
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be limited to (1) the administrative cost of section 7 consultations for future projects

with a Federal nexus, and (2) the administrative cost of an internal consultation (for

each HCP) by the Service to insure the HCPs are consistent with the adverse

modification standard. This analysis assumes that land use activities consistent with

1746 and inside project-specific HCPs would not accrue added project modification costs as a

result of CH.

SAN DIEGO MULTIPLE SPECIES CONSERVATION PLAN

If CH were designated in areas proposed for exclusion that are within approved MSCP sub-area

plans, this analysis concludes that the CHD would not result in any additional project

1751 modification costs for projects that require section 7 consultation within the sub-area boundaries

of San Diego County or the cities of San Diego or La Mesa. In contrast, projects with a Federal

nexus in the City of Poway’s sub-area plan would incur projects modification costs attributable

to section 7. Finally, all costs for Federal projects with no third party applicants as well as all

administrative consultation costs for projects with a Federal nexus in the MSCP are attributable

1756 to section 7.

Background

A regional HCP generally encompasses a larger planning area than a project-specific

HCP and is designed to provide a systematic process for granting incidental take to a

broad range of future projects or activities. The MSCP is a regional HCP/NCCP that

1761 encompasses a 582,000-acre planning area in San Diego County. The City of San Diego

was the lead agency for the Plan, and the City’s subarea plan – the first approved under

the MSCP – was approved in July 1997. The plan area is divided into jurisdictional subareas for administration. Four jurisdictions currently have approved sub-area plans –

San Diego County, and the cities of San Diego, Poway, and La Mesa. Additional sub1766 area plans are proposed or pending for the northeast County (MSCP North), the Otay

Water District, and the cities of Chula Vista, Santee, Coronado, Del Mar, and El Cajon. 

Because these sub-area plans have not officially been adopted, however, this analysis

does not consider them participating jurisdictions in the MSCP. 

1771
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The MSCP provides for the creation of a 172,000-acre habitat preserve, which will be

established over time within the boundaries of a multiple habitat planning area

(MHPA), within the larger MSCP planning area. Each approved sub-area plan defines

the MHPA boundaries within its plan area and establishes a mechanism by which

1776 future development within the plan area will contribute to the establishment of

preserves inside the MHPA. Each sub-area plan also defines the types of future land

uses that will be permitted in each jurisdiction’s preserve. 

The MSCP and Section 7

Proposed CH Unit 1 contains land within all four approved MSCP sub-area plans, as

1781 well as land within proposed or pending sub-area plans. All areas proposed for

designation are within the MHPA and consist of land that is either already preserved,

or is intended for preservation.

In issuing local permits for development, jurisdictions with approved sub-area plans

1786 are required to comply with and enforce the terms of the MSCP, including requiring

CSS mitigation consistent with the MSCP. Private development projects – either with or

without a Federal nexus – that need local agency approvals must therefore negotiate

CSS mitigation with local implementing agencies independent of section 7 consultation. 

In other words, in the “world without section 7,” project applicants would be required

1791 to mitigate impacts to CSS habitat in a manner consistent with the terms and conditions

of the MSCP for all projects inside approved sub-area plan areas. Federal projects with

no third party applicants must always consult purely through section 7, and the MSCP

is not considered a baseline regulation for these activities. 

Applicability to San Diego County, San Diego City, and La Mesa 

1796 Based on input from Service staff and an independent review of selected section 7 BOs

addressing impacts to the gnatcatcher for projects within approved sub-area plan

jurisdictions, this analysis assumes that section 7 consultation will not require any

additional project modifications (e.g., mitigation) over and above what is already

required by the relevant sub-area plan. Typically, the section 7 consultation for projects

1801 within the MSCP area consists of a letter of concurrence from the Service that an

applicant has appropriately mitigated according to the standards of the approved subarea plan. This analysis therefore assumes that projects with a Federal nexus that are
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proposed in areas covered by approved sub-area plans will incur only administrative

informal section 7 consultation costs, and will not incur any project modification costs

1806 attributable to section 7.

Applicability to Poway

The City of Poway’s approved sub-area plan provides one exception to the general

assumption above. Unlike other jurisdictions with approved sub-area plans, the City of

Poway does not require project applicants to participate in the MSCP process. 

1811 Individual applicants have the option of pursuing an independent section 7

consultation (assuming there is a Federal nexus) or an independent section 10 incidental

take permit (assuming there is not Federal nexus). In reality, it is very likely that most

future applicants, particularly those whose projects lack a Federal nexus, will choose to

participate in the City’s HCP, in recognition of the greater regulatory certainty and

1816 faster permit approval process, rather than pursuing individual consultation with the

Service. Nevertheless, in order to be more likely to overestimate than underestimate

section 7 economic impacts, this analysis conservatively assumes that all future

applicants with a Federal nexus within the City of Poway’s jurisdiction will decide to

pursue independent section 7 consultation. In such cases, all administrative and project

1821 modification costs will be attributable to section 7.

CENTRAL/COASTAL ORANGE COUNTY HABITAT CONSERVATION PLAN

The proposed rule identified approximately 35,000 acres of NCCP reserve lands that either do

not meet the definition of critical habitat or have been proposed for exclusion under section

4(b)(2). The only future projects allowed in these reserves are Planned Projects under the NCCP. 

1826 This analysis did not identify any Planned Projects with a Federal nexus in the reserve areas

proposed for exclusion, so no section 7 costs are anticipated.

The Orange County Central/Coastal NCCP/HCP includes both lands that have been

proposed for CHD and lands that do not meet the definition of critical habitat (under

1831 section 3(5)(a)) or have been proposed for exclusion under section 4(b)(2). As described 
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Since the NCCP has been enacted, USACE has not initiated any section 7 consultations covering

the gnatcatcher for Planned Activities in the HCP reserve areas. Based on this consultation

record, this analysis assumes that the USACE will not initiate future consultations for Planned

Activities in the reserve areas. 

69

above, the Irvine Ranch Reserve, the El Toro Reuse Area, and certain EUAs have been

proposed for designation. The proposed rule also identifies approximately 35,000 acres

1836 of habitat reserves that have been proposed for exclusion. 

The only projects allowed in the Reserve area are Planned Projects by Participating

Landowners. The Implementing Agreement for the HCP specifically states that CH will

not result in any additional mitigation or costs for Planned Projects under the HCP.

1841 Therefore, the only section 7 costs would be administrative consultation costs for

Planned Projects with a Federal nexus. This analysis did not identify any Planned

Projects within the reserve areas proposed for exclusion that would involve a Federal

nexus.

36 This analysis therefore assumes there will be not be any administrative or

project modification costs associated with these areas.

1846 INTEGRATED NATURAL RESOURCE MANAGEMENT PLANS

The Sikes Act Improvement Act (SAIA) of 1997 requires Department of Defense (DoD)

military installations to develop INRMP to provide for the conservation, protection, and

management of wildlife resources. Military areas proposed for exclusion include

USMC Camp Pendleton (mission-essential training areas), and MCAS Miramar. 

1851 Although mandatory, an INRMP must reflect the mutual agreement of the DoD and the

Department of Interior, acting through the Service. A completed INRMP that meets the

requirements of SAIA must provide for, among other things, the following:

C Fish and wildlife management, land management, forest management, and fish1856 and wildlife oriented recreation;

C Fish and wildlife enhancement or modifications,

C Integration of, and consistency among, the various activities conducted under

the plan; and
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C Establishment of specific natural resource management goals and objectives and

1861 time frames for proposed action.

Given the above, a completed INRMP can provide a baseline set of requirements for the

protection of the gnatcatcher and/or CSS if completed and approved. In other words, in

the “world without section 7,” future projects or activities on DoD military installations

1866 would mitigate for impacts to the gnatcatcher and/or CSS. The costs associated with

such mitigation requirements are appropriately considered as baseline, and are not

attributed to project modification requirements under section 7. However, CHD may

provide additional requirements over and above those specified in an existing INRMP. 

Consequently, although a completed INRMP constitutes a baseline requirement, the

1871 designation of CH may result in consultations and/or project modifications above and

beyond those already specified in the INRMP. These incremental costs are evaluated

separately for the three military installations included in the gnatcatcher CH that have

INRMPs (Pendleton, Miramar, and Fallbrook).

POTENTIAL FUTURE BASELINE REGULATIONS

1876 The discussion above describes regional HCPs that have been approved and officially

adopted, and can therefore be considered "baseline" regulations. In contrast, this

analysis does not consider regional HCPs that are currently under development as part

of the baseline, as they have yet to be officially approved or adopted. As described

below, however, a number of regional HCPs that will address the gnatcatcher are

1881 currently under development, and are expected to be completed in the near term. The

approval of one or all of these HCPs would impose an additional layer of land use

regulation specifically focused on CSS and gnatcatcher habitat, which would be applied

independent of section 7. In turn, such approved HCPs could therefore significantly

reduce the "net" cost burden attributable to section 7. 

1886

Following is a brief description of four regional HCPs that could potentially be

completed in the near term, including a preliminary evaluation of relevant baseline

considerations, based on the most current information publicly available. A complete 
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1891 analysis of the regulatory baseline effects of each of these plans can not be developed

until the plans are officially approved and adopted.

WESTERN RIVERSIDE COUNTY MULTI-SPECIES HABITAT

CONSERVATION PLAN

1896 Western Riverside County is actively developing a regional HCP. Service staff expect

that the plan will be approved as early as Fall of 2003. Take authorization will apply to

all projects in the planning area, and all projects will contribute to establishing a

500,000-acre reserve (including 153,000 acres of private land to be acquired through

mitigation). No specific parcels have been identified as reserves, though the 153,000

1901 acres will be acquired from within the "MSHCP Criteria Area." The Plan establishes an

incentive system to encourage private landowners in the Criteria Area to contribute

land to the reserve.

Preliminary estimates suggest that the proposed Unit 10 lies entirely within the MSHCP

1906 planning area. If the MSHCP is approved in its current form, take authorization and

CSS mitigation would therefore be regulated through the MSHCP. Future projects with

a Federal nexus would require consultation, but project modification costs would not be

attributable to section 7. As discussed in the Executive Summary, this analysis

estimates that economic costs for Unit 10 constitute approximately 50 percent of the

1911 total section 7 costs. Approval of the NCCP would shift a significant portion of the

estimated costs from section 7 to the NCCP. 

SOUTHERN ORANGE COUNTY HCP/NCCP

As part of the Southern Orange County Coordinated Planning Process, southern

Orange County is actively developing an HCP/NCCP that will address the gnatcatcher

1916 and CSS. No specific information is available regarding the status or expected

completion date of this regional HCP/NCCP.

Research indicates that the NCCP will likely cover approximately 91,000 acres in

southern Orange County. Preliminary estimates suggest that all portions of proposed

Unit 6 that are within Orange County lie within the proposed NCCP planning area. If
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1921 approved, all future incidental take of CSS habitat will be regulated by the NCCP, and

future project modification costs will not be attributable to section 7. As discussed in

the Executive Summary, this analysis estimates that future projects in Unit 6 account for

approximately 9 percent of the total cost estimate. Approval of the NCCP would shift

the portion of the cost burden related to projects in southern Orange County from

1926 section 7 to the NCCP. These estimates take into account baseline conditions under the

4(d) Rule and CEQA

NORTHERN SAN DIEGO COUNTY MULTIPLE HABITAT

CONSERVATION PLAN

Northern San Diego County governments are currently developing a regional HCP that

1931 will address the gnatcatcher and CSS. The public comment period on the Draft EIR/EIS

closed in April 2002, and public comment on the majority of draft subarea plans was

completed in 2001. The plan is expected to be adopted sometime in 2003. 

The HCP will authorize incidental take of CSS habitat (but will not authorize

1936 purposeful take of gnatcatcher individuals), and will establish differential mitigation

standards inside/outside "Focused Planning Areas" (potential future reserves areas). 

Preliminary estimates indicate that proposed Unit 3 lies within the MHCP planning

area. If approved, future CSS take would therefore be mitigated through the Plan, and

project modification costs would not be attributed to section 7. As discussed in the

1941 Executive Summary, this analysis estimates that economic costs in Unit 3 constitute

approximately one percent of total section 7 costs. Approval of the HCP would shift a

portion of these costs from section 7 to the HCP. 

NORTH COUNTY SUBAREA PLAN TO THE MSCP

The County of San Diego is currently developing a subarea plan to the MSCP that will

1946 apply to unincorporated areas in the northern County. If approved, CSS mitigation

within the subarea plan boundaries would be regulated under standards consistent

with the MSCP (and therefore section 7). Preliminary estimates suggest that proposed

Unit 5 lies within the planned subarea boundaries. If approved, future CSS mitigation
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would therefore not be attributed to section 7. As discussed in the Executive Summary,

1951 this analysis estimates that economic costs in Unit 5 constitute approximately one

percent of total section 7 costs. Approval of the HCP would shift a portion of these

costs from section 7 to the HCP. 

CITY OF PALOS VERDES HCP/NCCP

No specific information was obtained regarding the status, scope, or expected

1956 completion date of this Plan. However, because Palos Verdes currently processes CSS

take through the 4(d) Rule, they must, by definition, be actively pursuing an NCCP that

addresses the gnatcatcher and CSS. Proposed Unit 8 would likely be included in the 

future NCCP planning area, and future CSS mitigation would be regulated according to

the NCCP. As discussed in the Executive Summary, this analysis estimates that

1961 economic costs in Unit 8 constitute less than one percent of total section 7 costs. 

Approval of the HCP would shift a portion of these costs from section 7 to the HCP. 

OTHER FUTURE REGIONAL HCPS

In addition to the regional HCPs discussed above, EPS understands that at least two

other regional HCPs have been proposed to address the gnatcatcher and CSS -- San

1966 Bernardino Valley MSHCP and the Matrix NCCP Subregion of (northern) Orange

County. The planning areas for these HCPs would correspond with proposed Unit 11

and Unit 7, respectively. Preliminary indications suggest, however, that negotiations

have stalled for these plans, and that they therefore might not be considered

"reasonably foreseeable" within the context of this analysis.
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74

1971 III. DESIGNATION IMPACT ON PRIVATE LAND

DEVELOPMENT

This chapter evaluates the economic impact of section 7 and the proposed CHD on

private real estate development activities and markets. Specifically, it focuses on the

effect of section 7 and CH on the supply and demand for land used in residential and

1976 commercial real estate development. Chapter IV addresses the economic impact of

section 7 and the proposed CHD public sector projects and activities. The indirect

effects of CH, such as the potential for increased uncertainty, project delay, and

additional CEQA-related costs, are estimated separately in Chapter V.

1981 An overview of our general methodology and approach for evaluating the economic

impact of section 7 and the proposed CHD on private development is provided below

followed by a presentation of the analysis and estimated total economic costs.

ANALYTICAL APPROACH AND METHODOLOGY

Potential modifications to land use projects stemming from section 7 and the

1986 designation of CH can affect landowners, consumers, and real estate markets in general. 

The total economic impact will depend on the scope and intensity of section 7

consultations and project modifications, the pre-existing regulatory framework in the

region, and the nature of regional land and real estate markets. In order to accurately

account for all of these factors, and to estimate the corresponding economic impacts,

1991 this evaluation employs a series of methodological tasks, as described below (as noted

above, indirect effects such as time delay, uncertainty, and CEQA effects are estimated

separately in Chapter V).
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75

1. Determine Overlap between CHD and Land Development with Federal Nexus

1996

The first step in evaluating the effect of section 7 on private land development is to

identify the amount, type and location of land included in the proposed designation. 

The effect on private development only includes projects on land that can be developed

during the timeframe being considered that are also likely to have a Federal nexus. For

2001 example, the analysis excludes non-developable areas such as parks and other

permanent open space (the effect of CH on public activities and major infrastructure

projects is evaluated separately in Chapter IV). 

2. Identify Mitigation Associated with Section 7 and Baseline Requirements

2006

The actual effects of section 7 on applicable land development projects ultimately

depend on the type and level of project modifications likely to result from section 7

consultations. Thus, the second step is to estimate the expected modifications to land

use projects associated with section 7, including on-site land set-asides, habitat

2011 restoration, and off-site mitigation. This step includes the subtraction of the

requirements associated with pre-existing regulations or land use restrictions, including

state, local, or regional laws and agreements (see Chapter II for the “baseline”

regulations relevant to the gnatcatcher). 

2016 3. Evaluate Effects on Regional Real Estate Market and associated Cost Incidence

The third step is to determine the significance of the additional section 7-related land

use project modifications relative to regional real estate demand and supply dynamics,

and the resulting regulatory cost incidence. The incidence or burden of the project

2021 modification and other compliance costs will ultimately depend on their scope and

intensity and the nature of the regional real estate markets. The cost incidence either

falls primarily on individually affected landowners or on consumers of real estate

products (e.g., homes and commercial buildings).
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76

2026 The economic impacts are likely to extend beyond the regulated landowners and affect

the real estate market, real estate consumers, and the regional economy if: (1) the

amount of land set-aside (e.g., not developed as a result of section 7 is high relative to

the total developable land in the region, and/or (2) other compliance costs are high

relative to real estate development value and cover a significant proportion of

2031 developable land. In these cases, landowners and developers pass on the costs to real

estate consumers in the form of higher prices.

Conversely, if project modification costs are low and/or section 7 only affects a small

fraction of the total developable land supply in a region, then the economic effects are

2036 likely to be limited to the sub-set of individual landowners and/or projects with a

Federal nexus. In this case, the regulated landowners will not be able to pass on their

increased costs to consumers and their development projects will either relocate to

other available sites or proceed with a reduced land value. 

2041 4. Estimate Economic Impacts

The fourth step involves taking the data and conclusions from the first through third

steps and estimating the potential economic costs associated with section 7. The

approach to economic cost estimation is different depending on the cost incidence. If

2046 the project modification requirements do not affect the overall regional real estate

market dynamics due to the limited scale of the designation, cost impacts are borne by

the regulated landowners and reduced land values are estimated. The economic costs

are estimated based on the loss in land value associated with required on-site set-asides,

increased mitigation costs, and other project modifications incurred by individual

2051 landowners/developers. 

If, however, the scale and intensity of the CHD is sufficient to affect regional real estate

dynamics, regulatory requirements will primarily affect consumers through some mix

of increased real estate prices and reduced real estate production. Producers or

2056 landowners will also be affected although those with land outside of the designation 
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37 Consu m er surp lu s is the d ifference betw een the total value consu m ers receive from a particu lar

good and the total am ou nt th ey p ay for that good . When the p rice of a good goes u p , consu m er

su rp lus falls since a p ortion of the consu m ers fall ou t of the m arket altogether an d the rem aind er

p ay a h igher p rice. Producer surplus, alternatively, is the difference between the total market

value associated with a particular level of output and the total market costs associated with

supplying that level of output.

77

area will actually gain from the reduced supply and corresponding price increase. The

2061 total economic effect is measured through the change in producer and consumer

surplus, a measure of social welfare.37

PROJECTED LAND DEVELOPMENT WITH A FEDERAL NEXUS

A total of about 41,517 acres out of the 495,795 acres proposed for designation are expected to

overlap with projected land development through 2025 with a Federal nexus. 

2066

Following the methodology outlined above, this section estimates the number of acres

of projected development within proposed CH that will involve a Federal nexus. This

calculation starts with the total number of acres within the proposed CH area and

deducts from this the amount of land that is unlikely to be affected by the designation

2071 (e.g., there is no nexus, or it would not be developed in any case). A summary of this

calculation is provided in Table 8 and further described below. 

PRIMARY DATA AND TIME HORIZON

The estimated number of acres of private development potentially affected by CH is

based on the designation boundary maps provided by the Service and regional

2076 demographic projections by census tract. Specifically, Geographic Information Systems

(GIS)-level maps of the proposed CH boundaries were correlated with census-tractlevel land use projections provided by the Southern California Association of

Governments (SCAG), and the San Diego Association of Governments (SANDAG). 

2081
Table 8

Calculation of Projected Growth Acres with a Federal Nexus

Critical 

Habitat

Unit

Unit 1 25,100 12,868 1,684 1,162

Unit 2 16,075 13,902 1,821 1,256

Unit 3 32,465 27,241 6,769 4,670

Unit 4 8,690 11 6 4

Unit 5 34,705 27,889 6,864 4,736

Unit 6 44,340 34,027 4,909 3,387

Unit 7 5,775 4,468 117 81

Unit 8 7,160 6,991 80 55

Unit 9 22,595 17,595 1,498 1,034

Unit 10 176,720 164,085 22,650 15,628

Unit 11 14,990 12,581 4,502 3,106

Unit 12 3,890 2,032 213 147

Unit 13 103,290 101,983 9,057 6,250

Total 495,795 425,674 60,170 41,517

(1) Excludes proposed acres occupied by parks and other public lands not subject to private development.

(2) Total projected growth for portions of all census tracts within each unit that were proposed for critical habitat designation.

 For census tracts partially covered by critical habitat, growth acres within critical habitat were estimated assuming 

 even distribution of projected growth throughout all developable areas in the census tract.

(3) Assumes 69 percent of acres in each unit have a Federal nexus though the USACE as described in Chapter III and Appendix B.

in CH (2025) [2] Federal Nexus (3)

Growth Acres

Projected Growth

Acres with a 

Total Acres Total Projected

Proposed 

for CH

Proposed CH 

Acres Available

for Development (1)

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79

SCAG and SANDAG are quasi-governmental agencies responsible for providing

official demographic projections for the counties of Los Angeles, Ventura, Riverside,

2086 San Bernardino, and Orange counties, and San Diego County, respectively.

The timeframe for this analysis is 2025, which corresponds to the time frame for the

regional demographic and economic projections provided by SCAG (rather than 2030 as

provided by SANDAG). Because EPS does not have adequate data to provide reliable

2091 forecasts beyond 2025 for five out of the six counties included in this analysis, the SCAG

time horizon was deemed most appropriate. The land use projections are calculated as

undeveloped acres slated for residential, retail, office, or industrial development.

SANDAG provides acreage estimates for these land use categories while SCAG data

were converted to an acreage format based on assumptions regarding employees and

2096 households per acre. These calculations are further described in Appendix A. A

summary of projected land development for each County based on SCAG and

SANDAG data is shown in Table 9. 

PROJECTED GROWTH IN PROPOSED CRITICAL HABITAT

Prior to screening which census tracts intersect with proposed CH, land areas identified 

2101 as parks, permanent open space, and other publicly owned areas are removed from the

analysis of private real estate development. This analysis assumes future private

development will not occur in these areas. The potential for public land development

activities on publicly owned lands is addressed in Chapter IV. As shown in Table 8,

approximately 426,000 acres of proposed CH remain available for private development. 

2106

A GIS analysis was performed to identify all census tracts that intersect the remaining

proposed CH acres. For census tracts that were partially covered by CH, projected

growth was assumed to be evenly distributed throughout all land available for

development in that census tract. The amount of growth projected within CH was then 

2111
Table 9

Projected Growth Acres by County

County Source Total

Residential Office Industrial Retail

San Diego County SANDAG 252,614 871 6,701 5,063 265,248

Orange County SCAG 11,917 27,430 19,698 8,815 67,860

Riverside County SCAG 46,236 87,041 52,517 33,494 219,288

San Bernardino County SCAG 35,350 31,578 21,737 11,602 100,266

Los Angeles County SCAG 71,871 27,670 -33,101 7,462 73,902

Ventura County SCAG 4,737 7,204 4,307 2,416 18,663

Total 422,724 181,795 71,858 68,852 745,229

Sources: SCAG; SANDAG; Economic & Planning Systems, Inc.

Projected Growth Acres in County by 2025

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estimated according to the amount of land available for development in CH, relative to

the amount available in that census tract as a whole. Census tracts were grouped

2116 according to CH unit, and projected growth was summed by development type

(residential, office, etc.). As summarized in Table 8, approximately 60,000 acres of

growth are projected in proposed CH through 2025.

FEDERAL NEXUS ASSUMPTIONS

Based on input from the Service and the development community, as well as a review

2121 of historical section 7 consultations involving the gnatcatcher, this analysis assumes that

the primary Federal nexus for future private development activities is the issuance of

section 404(b) permits by USACE. Under section 404(b) of the Clean Water Act, the

USACE regulates development in jurisdictional “waters of the U.S.,” which are often

defined broadly and potentially encapsulate a large amount of future development. 

2126

A GIS analysis was performed to estimate the approximate percentage of land proposed

for CH that the USACE would consider “waters of the U.S.” The GIS analysis

compared the relationship between United States Geological Survey (USGS) “blue line”

stream networks and “waters of the U.S.,” as identified by the USACE in a detailed

2131 survey of the San Jacinto/Santa Margarita drainage basin in Riverside County. A digital

elevation model was used to estimate the prevalence of “waters of the U.S.” relative to

slope classes and “blue line” stream coverage. Results of this “pilot area study” were

then applied to slope classes and “blue line” streams throughout the entire proposed

CH area. This analysis estimates that approximately 0.03 percent of the total land area

2136 proposed for CH contains “waters of the U.S..” Detailed calculations and a summary

report are presented in Appendix B. 

This analysis recognizes that, in practice, the Service considers the entire project area

when evaluating species and habitat impacts, rather than only that portion of the site

2141 containing “waters of the U.S.” (i.e., the Service’s “action area” is often larger than the

USACE’s “scope of analysis”). This analysis assumes an average future project size of

300 acres, based on a review of previous private development projects that have

required section 7 consultation for the gnatcatcher. A GIS analysis using a 300-acre grid

system determined that approximately 69 percent of land within proposed CH would
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82

2146 be subject to a Federal nexus through the USACE. Detailed calculations and a summary

report are also presented in Appendix B. As shown in Table 8, this analysis estimates

that 41,517 acres of projected growth with a Federal nexus will occur within proposed

CH through 2025.

REGULATORY BASELINE AND SECTION 7 COMPLIANCE

2151 Subtracting the baseline regulatory requirements, a total of about 25,233 acres of projected land

development through 2025 will face additional regulation under section 7. Regulatory

requirements will include the set-aside of about 12,500 acres on-site, off-site preservation of

about 8,000 acres, and restoration of about 2,800 acres, among others. 

2156 Land developers in California often implement a variety of measures designed to off-set

or mitigate impacts to sensitive biological resources. As discussed in Chapter II, the

amount and type of mitigation associated with CSS, the gnatcatchers’ predominant

habitat, will be determined both through the section 7 process and through enforcement

of a number of baseline regulations that predate the designation of CH. Thus, this

2161 analysis distinguishes between the CSS mitigation clearly required due to regulatory

provisions other than section 7 and the incremental CSS mitigation likely to occur in

association with section 7 consultation alone.

As summarized in Table 10, this analysis estimates that approximately 41,500 acres of

2166 future private land development through 2025 will require section 7 consultation due to

a Federal nexus through the USACE. Projected growth acres in CH that are subject to

CSS mitigation under the 4(d) Rule are subtracted, leaving approximately 25,000 acres

growth acres estimated to be subject to some form of habitat mitigation (e.g. on-site and

off-site habitat set-aside and/or restoration) related solely to section 7. Finally, an

2171 estimated 12,485 acres, out of the 25,000 acres, will be removed from the private

development pipeline as a result of the on-site habitat set-aside resulting from section 7

consultations. This estimate of “net” acres subject to mitigation solely in association

with section 7 consultation, and the typical project modifications arising from that 
Table 10

Calculation of Mitigation Acres Associated with Section 7

Critical 

Habitat On-Site Off-Site CSS

Unit Set-Aside Preservation Restoration

Unit 1 1,162 72 4 0 0

Unit 2 1,256 58 3 0 0

Unit 3 4,670 215 12 0 0

Unit 4 4 0 0 0 0

Unit 5 4,736 292 16 0 0

Unit 6 3,387 426 275 0 0

Unit 7 81 100 64 0 0

Unit 8 55 0 0 0 0

Unit 9 1,034 951 482 0 265

Unit 10 15,628 14,376 7,745 7,982 42

Unit 11 3,106 2,858 2,086 0 215

Unit 12 147 135 41 0 68

Unit 13 6,250 5,750 1,757 0 2,207

Totals 41,517 25,233 12,485 7,983 2,798

(1) From Table 8.

(2) Excludes projected growth acres in areas covered by the 4(d) Rule. 

(3) Calculated by applying "net" section 7 mitigation ratios to "Projected Growth Acres Affected by Section 7." 

 These values reflect mitigation implemented through the section 7 process, and do not include acres mitigated through CEQA.

 See Appendix E for detailed calculations

Projected Growth Estimated CSS Mitigation Acres (3)

Acres with a 

Federal Nexus (1)

Projected Growth

Acres Affected 

by Section 7 (2)

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38Several baseline regulations are also relevant to calculating the “net” section 7 effect in the areas

proposed for exclusion. Specifically, private development will not occur in reserve areas already

established under project-specific HCP agreements. In addition, approved MSCP subarea plans

(i.e. San Diego County and the cities of San Diego and La Mesa) are expected to result in CSS

mitigation requirements identical to section 7, so the “net” mitigation ratio associated with

section 7 would be zero. The only exception is the approved subarea plan within the City of

Poway where it is conservatively assumed that future applicants would choose to pursue

independent section 7 consultation rather than participate in the city’s HCP.

84

consultation, serve as the basis for determining the effect on regional real estate market

dynamics and calculating the total costs by unit. The derivation of these estimates are

further described below.

2181 REGULATORYBASELINE REQUIREMENTS

To determine the “net” level of CSS mitigation attributable to section 7, the private land

development projections were adjusted to account for the following baseline

requirements:38

C Central/Coastal Orange County NCCP (Unit 7): The NCCP contains areas for

2186 which mitigation has already been secured (e.g., the El Toro Reuse Area and the

Irvine Ranch Reserve) and areas for which mitigation must be negotiated

independently. The reserve areas covered by the plan have already been

mitigated in full, so the “net” mitigation associated with section 7 is zero. In

contrast, future development in EUAs is not covered by the NCCP, so all project

2191 modifications (e.g., mitigation) in these areas will be associated with section 7.

C 4(d) Rule (Units 1-6, 8): All areas outside the jurisdiction of approved

HCPs/NCCPs in Units 1 through 6 and all of Unit 8 are subject to regulation

under the 4(d) Rule. CSS mitigation for projects that meet all 4(d) Rule criteria is

assumed to be consistent with section 7 and attributable to the 4(d) Rule. Thus,

2196 for these projects the “net” mitigation ratio associated with section 7 is zero. 

However, this analysis assumes that 5 percent of future projects in 4(d) Rule

areas in San Diego County (Units 1-5) fail to meet 4(d) criteria and are therefore

subject to mitigation associated with section 7.
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85

For Unit 6 (Orange County), the Service’s records indicate that no past projects

2201 have been denied approval under the 4(d) Rule. However, this analysis assumes

that all residential growth projected in the vicinity of the proposed FoothillSouth toll road will not qualify for 4(d) approval, and will be addressed by

section 7 and other baseline regulations. The scale of this proposed

development makes 4(d) approval unlikely. Finally, staff from the City of

2206 Rancho Palos Verdes (Unit 8) indicate that all future projects will meet the

requirements of 4(d), resulting in no additional section 7-related mitigation

costs. 

C CEQA (Units 1-6, 7, 9): As described in Chapter II, this analysis assumes that

CEQA constitutes a baseline requirement only in San Diego and Orange

2211 counties. Specifically, based on input from Service and DFG staff, lead agencies

in San Diego and Orange counties are assumed to require 2-to-1 mitigation for

CSS impacts under CEQA. Any difference between mitigation standards

associated with section 7 and this 2-to-1 baseline is considered the “net”

mitigation ratio for that county that is attributable to section 7. Lead agencies in

2216 Riverside, San Bernardino, Los Angeles, and Ventura counties are assumed not

to require CSS mitigation under CEQA, so no baseline condition exists in these

counties.

MITIGATION STANDARDS

The economic impact of CHD on private sector land development will be directly

2221 linked to the type and level of CSS mitigation likely to be associated with future section

7 consultations. Thus, this analysis reviewed a number of historical section 7 BOs to

generate county-specific estimates of typical “effective mitigation ratios” following

implementation of the conservation measures described in each BO. The majority of

BOs reviewed were issued following the designation of gnatcatcher CH in 2000, so the

2226 resulting mitigation standards provide an accurate estimate of section 7 consideration of

both jeopardy and adverse modification standards. A detailed summary of each of the

BOs is presented in Appendix C. 
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39

The net effect of the presence of other Federally-listed species in the proposed critical habitat

areas for the gnatcatcher is that the number of consultations conducted for the gnatcatcher alone

is likely to be smaller than would be expected in the absence of these species. Indeed, most past

consultations on the gnatcatcher have involved at least one or two other species per consultation. 

Thus, the cost of a consultation that involves the gnatcatcher may not be fully attributable to the

presence of this species or its habitat. Nonetheless, because consultations must consider project

related effects to each listed species separately, a certain amount of research and time will be

spent on the gnatcatcher regardless of the presence of other species. In order to present a

conservative estimate of the economic impacts associated with the implementation of section 7,

this analysis assumes that all future section 7 consultations within the extant boundaries of the

proposed critical habitat are fully attributable to the presence of the gnatcatcher and its habitat.

40Baseline mitigation under CEQA typically occurs via on-site set-aside requirements. When

possible, the 2-to-1 CEQA baseline is thus subtracted from the relevant on-site section 7 ratio to

calculate the “net” on-site set-aside ratio. In the case of San Diego County, however, the section 7

on-site set-aside ratio was less than 2 (i.e., 0.77-to-1). In this case, the CEQA baseline was

subtracted from the total section 7 mitigation ratio (2.06-to-1), yielding a “net” ratio of 0.06-to-1. 

This “net” ratio was applied as an on-site ratio throughout the subsequent calculations.

86

While an attempt was made to obtain BOs that represent a range of development

2231 types and a diverse geographic distribution, it is not possible to collect a discrete

sample that is perfectly representative of all future projects. In particular, fewer BOs

were provided for certain geographic areas than for others, and many of the reviewed

BOs involve impacts to breeding gnatcatcher pairs and/or multiple listed species. In

such cases, the calculated “effective mitigation ratios” may overestimate the actual

2236 amount of future mitigation in areas that do not contain breeding pairs or than

contain only the gnatcatcher and/or its habitat.39 While the average “effective

mitigation ratios” calculated from these sample BOs are generally considered

representative of likely future section 7 outcomes, these potential sources of error are

nonetheless worthy of mention. It is also worth noting that applying these mitigation

2241 ratios to future projects is more likely to overestimate than underestimate actual

section 7 costs attributable to the gnatcatcher. 

Table 11 summarizes the resulting CSS mitigation ratios—divided among on-site setaside, off-site preservation, and restoration—and sorted by county. The reported ratios

2246 represent the ultimate level of CSS mitigation that is enforced in each county, and thus

reflect a combination of pre-existing baseline requirements and section 7 consultations. 

The “net” mitigation ratio associated with section 7 deducts the typical mitigation

standards that would apply under CEQA independent of section 7 (in Orange and San

Diego counties only).40
Table 11

Average Coastal Sage Scrub Mitigation Ratios by County

County

On-site Off-site Restoration Total

San Diego 0.77 1.28 0.01 2.06 0.06 (2) (3)

(SD Military) 0.00 2.00 0.00 2.00 same as "Reported Ratios"

Riverside 1.14 1.22 0.00 2.37 same as "Reported Ratios"

San Bernardino 2.70 0.00 0.40 3.10 same as "Reported Ratios"

Orange 3.82 0.00 0.00 3.82 1.82 (2)

Los Angeles 0.44 0.00 0.93 1.37 same as "Reported Ratios"

Ventura (3) N/A N/A N/A N/A same as Los Angeles

Average, All Counties 1.26 1.04 0.08 2.39

(1) Ratio reflects the number of implemented mitigation acres for every acre of CSS habitat disturbed, as determined from the 

 selected Biological Opinions summarized in Table C-1.

(2) This "net" ratio reflects deduction of assumed CEQA 2-to-1 baseline mitigation ratio.

(3) This ratio is applied to subsequent calculations as "on-site set-aside," which yields the most conservative cost estimate.

(4) No biological opinions were obtained from Ventura. Los Angeles ratios were used as a proxy.

N/A = Not available

Reported Mitigation Ratios (1) "Net" Section 7

Mitigation Ratios

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NET AREA AFFECTED BY SECTION 7

The “net” mitigation ratios described above were applied to the projected growth acres

with a Federal nexus to calculate project modifications and conservation measures (e.g.,

2256 “mitigation”) attributable to section 7. Detailed calculations by development type are

shown in Appendix E, with a summary of projected mitigation acres associated with

section 7 provided in Table 10. As shown, projected “net” CSS mitigation associated

with section 7 is estimated to include approximately 12,500 acres of on-site set-aside,

8,000 acres of off-site preservation, and 2,800 acres of restoration. 

2261 SIGNIFICANCE FOR REGIONAL REAL ESTATE MARKET

The scale and intensity of the additional project modification requirements associated with

section 7 and CHD are not sufficient to affect regional real estate market dynamics. As a result,

the cost burden of project modifications falls on the regulated landowners.

2266 The cost incidence or economic burden of land development project modifications

stemming from section 7 will be determined by their impact on the regional real estate

market (i.e., on overall real estate production and prices). If project modification

requirements are expected to significantly constrain development opportunities in a

regional real estate market, the economic burden will be felt by consumers as well as

2271 landowners and developers. This is most likely to occur in regions where development

opportunities are already limited and project modifications and associated on-site setaside requirements affect a significant proportion of remaining developable land. 

Conversely, if project modifications due to section 7 represent a relatively insignificant

component of total market supply, then the economic burden will be felt primarily by

2276 individual landowners / developers rather than consumers at large.

To determine the significance of section 7-related project modifications for regional real

estate markets, the lost development potential associated with the project modifications

should be compared to the total regional development potential. Specifically, on-site

2281 land set-aside requirements should be compared with the total supply of developable
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41 Off-site set-aside requirements are not included in this analysis as they are assumed to be

satisfied by the large amount of non-developable CH land.

89

land in the region.41 In reality, accurate estimates of total regional development

potential are not readily available. Consequently, for the purposes of this analysis,

projected acres of growth through 2025 in the five counties covering the CHD are used

as proxy for regional market supply.

2286

A comparison of the total acres of on-site habitat set-aside stemming from section 7

consultations with the total projected acres of growth through 2025 for each county is

provided in Table 12. As shown, the estimated habitat set-aside represents

approximately 1.7 percent of future growth in the six counties through 2025. San Diego

2291 County, Orange County, and Los Angeles County are the lowest at 0.01 percent, 0.8

percent, and 1.7 percent, respectively; San Bernardino County and Riverside County,

both with ample developable land, follow with 2.4 percent and 3.4 percent, respectively;

and Ventura County is the highest, with 4.2 percent. If the areas proposed for exclusion

from CHD are included, the estimated habitat set-aside as a percent of future growth in

2296 the six counties increases by less than 0.1 percent. This marginal difference is due to the

fact that most of the excluded areas are already covered by existing baseline

regulations.

It is important to note that the 1.7 percent estimate provided above represents an over2301 estimate of the section 7 effect on regional development opportunities. The following

factors suggest that the section 7-related on-site habitat set-aside will actually represent

a much smaller proportion of the regional real estate market.

1. Regional land supply is greater than projected demand through 2025. The

2306 above estimate relies on projected land consumption through 2025 as a proxy for

long-term supply. In reality, the long-term land supply is greater than demand

through 2025 because many of the communities within the six-county area are

expected to reach build-out significantly beyond that date.
Table 12

Regional Significance of Acres Impacted by Section 7

County Acres 

Residential Office Industrial Retail Total Set-Aside

On-site (1)

San Diego County 252,614 871 6,701 5,063 265,248 37 0.01%

Orange County 11,917 27,430 19,698 8,815 67,860 566 0.8%

Riverside County 46,236 87,041 52,517 33,494 219,288 7,444 3.4%

San Bernardino County 35,350 31,578 21,737 11,602 100,266 2,391 2.4%

Los Angeles County 71,871 27,670 -33,101 7,462 73,902 1,258 1.7%

Ventura County 4,737 7,204 4,307 2,416 18,663 790 4.2%

Total 422,724 181,795 71,858 68,852 745,229 12,485 1.7%

(1) The total on-site set-aside acreage for each Unit (total residential, office, industrial, and retail, as shown in Appendix E) was allocated 

 among the counties composing that Unit according to the relative proportion of proposed CH available for development (see Table 8).

Sources: SCAG; SANDAG; Economic & Planning Systems, Inc.

County Growth

Projected Growth Acres in County by 2025 Acres Set-aside

as % of Projected

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2. Developers will adjust to reduced land supply by increasing density. The

above estimate assumes that development in areas unaffected by CHD cannot

occur at higher densities. In practice, densification and revitalization of under2316 utilized “in-fill” sites can continue to provide significant development

opportunities in land constrained markets.

3. Developers will integrate on-site habitat set-asides into project design. The

above analysis assumes that the set-aside acres represent a 1-to-1 reduction in

2321 development capacity. In reality, many developers will incorporate habitat

reserve acres into their project design, thereby minimizing the impact on total

project size. In addition, habitat reserves often serve as an open space amenity

that can enhance the value of the remaining developable areas.

2326 Given the factors described above, and the fact that 1.7 percent is itself a relatively small

component of real estate supply, the project modifications associated with section 7 are

not expected to have a significant impact on the dynamics of the regional real estate

market. Hence, housing prices in each county are not expected to be affected, and

regulated landowners will bear the cost incidence associated with section 7 and CHD. 

2331 Some projects will be distributed to other parts of the respective counties, while other

projects may proceed with higher mitigation costs and lower land values.

ESTIMATED PROJECT MODIFICATION COSTS

“Co-extensive” project modification costs associated with the listing and proposed CHD are

2336 estimated to be approximately $743 million through 2025. These costs will be borne by regulated

landowners and experienced through lower land values. These estimates do not include

consideration of any potential increases in land values associated with the amenity values of open

space. Landowners outside of CH may experience increased land values as some growth is

distributed towards their land.

2341

The cost of section 7 was estimated by calculating:

1. the loss in land value for acres set-aside under “net” section 7 requirements, 

2. the cost of acquiring off-site mitigation acres under “net” section 7 requirements, 
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92

2346 3. the cost of restoring CSS habitat under “net” section 7 requirements, and 

4. the costs to implementing other project modifications (biological monitoring,

exclusionary fencing, etc.) for each project. 

These costs are described further below, and are summarized for each proposed CH

2351 unit in Table 13. Detailed time-series calculations are presented in Appendix E. Costs

were calculated assuming proposed development is distributed evenly through 2025,

and assuming a discount rate of 12 percent to account for the opportunity cost of

investment decisions in the private real estate development market.

2356 Residential, commercial, and market data for each of the six counties were used to

estimate the cost, or lost value, of on-site set-aside acres. A summary of raw market

data is presented in Table 14. Appendix D shows assumptions and detailed

calculations of how these data were used to develop per-acre estimates of residual land

values for each development type. The residual land value is an estimate of the value of

2361 a raw, unimproved parcel with no infrastructure. This measure is appropriate because

a developer seeking project entitlement will not invest money in infrastructure or other

improvements on land designated as a habitat set-aside through the consultation

process. 

2366 The analysis also collected market data from a number of private CSS mitigation banks

in relevant counties (no private mitigation banks exist in Los Angeles or Ventura

counties) to determine average off-site mitigation prices by county. A summary of

these data and the estimated averages by county are presented in Table 15. To estimate

restoration costs, this analysis assumes an average per-acre cost of $30,000 across the

2371 entire proposed CH area. 

Finally, based on a review of the section 7 BOs summarized in Appendix C, this

analysis estimates that each future private development project will incur costs related

to full-time biological monitoring during construction activities, the construction of

2376 exclusionary fencing to protect adjacent gnatcatcher individuals and habitat, and the

development and implementation of an employee education program. This analysis 
Table 13

Private Land Development Project Modification Costs

Critical 

Habitat On-Site Off-Site CSS Other Project Total

Unit Set-Aside Preservation Restoration Modifications

Unit 1 $472,600 $0 $0 $919,400 $1,392,000

Unit 2 $414,300 $0 $0 $994,100 $1,408,400

Unit 3 $1,403,700 $0 $0 $3,696,000 $5,099,700

Unit 4 $1,200 $0 $0 $3,100 $4,300

Unit 5 $2,071,200 $0 $0 $3,748,100 $5,819,300

Unit 6 $40,541,500 $0 $0 $2,680,500 $43,222,000

Unit 7 $4,600,200 $0 $0 $64,000 $4,664,300

Unit 8 $0 $0 $0 $43,800 $43,800

Unit 9 $33,519,600 $2,000 $2,669,000 $818,100 $37,008,700

Unit 10 $334,138,600 $42,861,400 $422,900 $12,367,400 $389,790,400

Unit 11 $80,919,300 $0 $3,110,500 $2,458,300 $86,488,100

Unit 12 $2,491,200 $0 $878,500 $116,200 $3,485,900

Unit 13 $122,056,200 $0 $37,383,400 $4,945,500 $164,385,100

Total $622,629,600 $42,863,500 $44,464,300 $32,854,500 $742,811,800

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) Assumes a discount rate of 12%. 

Project Modification Costs (1)

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Table 14

Residential and Commercial Market Data

County/Region

Office (2) Industrial (3) Retail

Los Angeles $394,230 $193 $43 $144

Riverside (4) $250,923 $125 $41 $108

San Bernardino (5) $202,240 $125 $41 $108

Orange $464,304 $220 $59 $142

San Diego $410,435 $195 $65 $124

Ventura (6) $415,458 $175 $69 N/A

N/A: Not Available

(1) 2002 sales prices are reported by RAND in 1998 dollars. These values 

were adjusted to 2002 dollars assuming a 3% annual inflation rate.

(3) Reported sales price for suburban space between 100,000 and 250,000 square feet.

(4) & (5) Commercial Sales Price for these counties come from the sales price of Inland Empire.

(6) Retail data for Ventura County was not available, so data for Los Angeles was used as a proxy.

Average Residential 

Sales Price (1)

Commercial Sales Price ($/SqFt)

(2) Weighted average, class A space outside central business district. Rates for San 

Diego are CBD space.

Source: RAND; Marcus & Millichap Retail Research Report, November 2002; Economic & 

Planning Systems, Inc.

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Table 15

Coastal Sage Scrub Mitigation Bank Prices

Average Price

Low High

Riverside $6,500 $9,500

San Diego $17,125 $19,750

Orange $75,000 $78,333

Average, All Counties $28,846 $31,692

Per Acre Cost

Notes: no approved CSS mitigation banks are located in Los Angeles or Ventura 

counties. 

Source: personal communication with various mitigation bank personnel, 

February 2003.

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Based on query of USACE consultation database through January 15, 2003, provided by Michael

Jewel, Acting Chief, Regulatory Branch, USACE Los Angeles District.

96

assumes that a single full-time biological consultant will be employed for one year at an

annual cost of $85,000, that exclusionary fencing will cost approximately $18,000 per

2386 project, and that developing an employee education program will cost $10,000 per

project.

Based on records provided by the USACE, there have been approximately 88 section 7

consultations for private development projects involving gnatcatcher CH since October

24, 2000, when the Service designated CH for approximately 514,000 acres.42 Adjusting

2391 this rate to the current proposed designation of 495,795 acres yields an average annual

rate of 37.6 consultations per year, or 866 future section 7 consultations through 2025. 

This analysis assumes that each of these consultations will involve implementation of

the additional project modifications described above, resulting in total project

modification costs of approximately $743 million, as summarized in Table 13. 

2396 ESTIMATED ADMINISTRATIVE CONSULTATION COSTS

Administrative consultation costs are estimated to be approximately $5.7 million through 2025.

As described above, this analysis assumes that 866 future private residential projects

will require section 7 consultation through 2025, based on a historical consultation rate. 

2401 Each of these is expected to be a formal consultation, and consultations are assumed to

be distributed evenly through 2025. Table 16 shows the estimated administrative costs

for these consultations. These costs were estimated using the consultation cost model

described and shown in Appendix F. Total costs were calculated by multiplying the

number of consultations by the average cost per participant. Because this calculated

2406 value essentially represents the administrative costs assuming all consultations

occurred in Year 1, it was adjusted to reflect a discount rate of 12 percent. 
Table 16

Private Land Development Costs

Critical 

Habitat Project Administrative Total

Unit Modification Costs Costs (2)

Unit 1 $1,392,026 $160,097 $1,552,123

Unit 2 $1,408,444 $173,110 $1,581,554

Unit 3 $5,099,691 $643,577 $5,743,268

Unit 4 $4,267 $538 $4,804

Unit 5 $5,819,257 $652,654 $6,471,911

Unit 6 $43,222,017 $466,755 $43,688,772

Unit 7 $4,664,263 $11,148 $4,675,412

Unit 8 $43,756 $7,619 $51,376

Unit 9 $37,008,671 $142,456 $37,151,127

Unit 10 $389,790,380 $2,153,533 $391,943,914

Unit 11 $86,488,072 $428,058 $86,916,129

Unit 12 $3,485,931 $20,237 $3,506,168

Unit 13 $164,385,059 $861,162 $165,246,220

Total $742,811,835 $5,720,944 $748,532,779

(1) Assumes a discount rate of 12%. 

(2) Average administrative consultation costs (of low and high) were allocated 

 among units in proportion to the number of projected growth acres in 

 each unit with a Federal nexus (see Table 8).

Total Section 7 Costs (1)

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2411 SUMMARY OF PRIVATE LAND DEVELOPMENT IMPACTS

Total “co-extensive” costs associated with section 7 regulation of private development in

proposed CH are estimated to be approximately $749 million through 2025.

Table 16 summarizes the estimated project modification, administrative, and total costs

2416 due to section 7 regulation of private development in proposed CH for the gnatcatcher. 

The bulk of these costs are borne by regulated landowners. As shown in Table 13, the

bulk of these costs (approximately $623 million) are primarily associated with the loss in

development value of land required for on-site set-aside. This impact is a result of the

2421 on-site set-aside of approximately 12,500 acres, which represents about 1.7 percent of

total projected development within the six-county region through 2025. This degree if

impact is assumed not to affect the dynamics of the regional real estate market, housing

prices are not expected to be affected, and regulated landowners will bear the cost

incidence associated with section 7 regulation. 

2426
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February 24, 2004

43

The public agency officials contacted for this analysis provided data and analysis for the

combined CH areas proposed for inclusion and exclusion. The estimates provided in the text on

areas proposed for inclusion only are scaled down based on the proportional reduction in CH

acres. The estimates for the combined inclusion and exclusion CH areas are provided in Table 5.

44

The project modification costs calculated in Tables G-1 through G-19 were based on public agency

interviews conducted prior to publication of the proposed rule. Agencies were asked to estimate

impacts assuming all known CSS was proposed as CH. The impact estimates summarized in Table 3

and Table 17 were calculated by multiplying the estimates in Appendix G by the project-specific

acreage-adjustment factors indicated in each Appendix table. 

99

IV. IMPACT OF DESIGNATION ON PUBLIC LAND

DEVELOPMENT

This chapter evaluates the economic impact of the proposed CHD on public projects

and activities, such as major utility or infrastructure projects, that have a Federal nexus. 

2431 The discussion includes a description of the activity, how the activity would be affected,

and a calculation of the associated costs due to section 7.43

A summary of administrative and project modification costs for public projects and

activities is shown in Table 17 – again, these estimates are of “co-extensive” section 7

costs, attributable to both the listing and the proposed designation. Detailed

2436 calculations of project modifications and costs by agency/project are presented in

Appendix G.

44 The consultation cost model is provided in Appendix F. The estimated

project modification costs summarized in the text below were calculated using a

discount rate of 7 percent, which is consistent with OMB guidelines. 

TRANSPORTATION AND ROAD CONSTRUCTION

2441 This analysis used data from the California Department of Transportation (Caltrans)

regarding future road construction projects within the proposed CH area. Though

Caltrans is a State agency and its projects do not necessarily require section 7

consultation, many of its projects receive funding from the Federal Highway

Administration (FHWA) and many impact “waters of the United States” under USACE

2446
Table 17

Public Land Development Costs

Critical 

Habitat Project Modification Administrative Total

Unit Costs (2) Costs (3)

Unit 1 $838,500 $88,700 $927,200

Unit 2 $619,100 $95,900 $715,000

Unit 3 $1,229,600 $356,700 $1,586,200

Unit 4 $2,444,600 $300 $2,444,900

Unit 5 $1,159,300 $361,700 $1,521,000

Unit 6 $41,889,800 $258,700 $42,148,400

Unit 7 $219,500 $6,200 $225,700

Unit 8 $288,900 $4,200 $293,200

Unit 9 $1,065,600 $78,900 $1,144,500

Unit 10 $45,761,300 $1,193,500 $46,954,800

Unit 11 $3,945,200 $237,200 $4,182,400

Unit 12 $163,200 $11,200 $174,400

Unit 13 $4,334,000 $477,200 $4,811,200

Total $103,958,600 $3,170,500 $107,129,000

All dollar values have been rounded to the nearest hundred; summed totals 

may not add exactly.

(1) Assumes a discount rate of 7%. 

(2) Project modification costs were allocated among units assuming 

 area-weighted distribution among 'relevant units,' as indicated in Table 3.

(3) Average administrative consultation costs (of low and high) were allocated 

 among units in proportion to the number of projected growth acres in 

 each unit with a Federal nexus (see Table 8).

Total Section 7 Costs, Scenario A (1)

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jurisdiction, both of which constitute Federal nexuses under section 7. The four

Caltrans regulatory districts that overlap with proposed gnatcatcher CH include;

2451 District 7 (Los Angeles County), District 8 (Riverside County), District 11 (San Diego

County), and District 12 (Orange County).

In general, Caltrans personnel were unable to provide detailed estimates of future

projects that will require section 7 consultations. Consequently, the project

2456 modification costs estimated in the following sections are based on a variety of

information provided by each Caltrans districts. In contrast, future administrative costs

due to section 7 consultations are based on aggregated information for all four districts

from the USACE. Specifically, the USACE estimates that there have been 20 section 7

consultations since the original gnatcatcher CHD in October 2000 that have addressed

2461 transportation projects with impacts to the gnatcatcher or its habitat. After accounting

for the reduced size of the proposed CHD, this consultation history yields an average

rate of 5.6 transportation consultations per year for the four Caltrans Districts that

overlap the proposed gnatcatcher CH. Over 23 years, the USACE is therefore expected

to have to initiate 129 formal section 7 consultations for transportation projects within

2466 the proposed gnatcatcher CH. The total estimated administrative cost (average of low

and high estimates) due to future section 7 consultations is $1.7 million, as summarized

in Table 3. Section 7 project modification costs have been estimated separately for each

Caltrans district, as described below. 

CALTRANS DISTRICT 7 (LOS ANGELES AND VENTURA COUNTIES)

2471 According to a preliminary estimate provided by Caltrans District 7 staff,

approximately six (6) acres of CSS will be impacted by planned or proposed projects

through 2025, and that CSS mitigation costs would be approximately $117,000 per acre

disturbed. Caltrans was unable to provide information regarding the number or timing

of projects contributing to this impact estimate, however. For the purposes of

2476 estimating a total project modification cost, this analysis assumes that Caltrans will

consult on six separate projects, each of which will impact one acre of CSS, and each

spaced evenly through 2025 (one every four years, beginning in 2003). As shown in

Table 3, this results in a total project modification cost estimate of $369,200. 
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

45 Personal communication with Paul Gonzales, Senior Environmental Planner, Caltrans District

8, on January 30, 2003.

46 Personal communication with Joe Monaco, Senior Project Manager, Dudek & Associates, on

February 10, 2003.

102

CALTRANS DISTRICT 8 (RIVERSIDE AND SAN BERNARDINO COUNTIES)

2481 According to Caltrans District 8 personnel, estimated impacts to CSS habitat as a result

of future transportation projects were developed as part of the ongoing Western

Riverside MSHCP.45 After reviewing the available supporting data, the biological

consulting firm to the MSHCP estimated that approximately 750 acres of CSS habitat

would be disturbed by future transportation projects in western Riverside County.46

2486 While some of these impacts may be associated with “long term” projects beyond the

2025 time horizon, this analysis conservatively assumes that all projects will occur prior

to 2025. Caltrans personnel recommended assuming that all projects would involve a

Federal nexus, either as a result of FHWA funding or USACE section 404 permitting

requirements. 

2491

The MSHCP data is limited to future projects in Riverside County, and does not include

CSS impacts related to projects in San Bernardino County and Caltrans personnel could

not provide additional information regarding projects in San Bernardino County. 

Consequently, this analysis assumes that future CSS impacts in San Bernardino due to

2496 transportation construction projects will be proportional to projected urban

development within proposed CH area, based on Riverside data. Specifically, dividing

750 acres of future CSS impacts in Riverside County (Unit 10) by 22,650 acres of

projected growth in CH, as summarized in Table 8, yields a factor of 33 acres of CSS

impact for every 1,000 acres of projected growth. Applying this factor to the 4,502 acres

2501 proposed in San Bernardino County (Unit 11) yields an estimate of 149 acres of CSS

impact, or a total estimate of 900 acres for Caltrans District 8.

According to Caltrans personnel, previous projects in gnatcatcher habitat requiring

section 7 consultation have mitigated direct impacts at ratios between 2-to-1 and 3-to-1,

2506 and have mitigated indirect impacts (e.g., noise, lighting, “growth inducing effects”) at
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

47 Personal communication with Scott Quinnell, Environmental Planner, Caltrans District 8, on

February 10, 2003.

48 Personal communication with Charles Stoll, Deputy Director of Environmental Planning, and

Bruce April, Environmental Stewardship Branch Chief, February 6, 2003. 

49 Personal communication with Kim Kawada, Manager of Transportation Planning, and Steven

Bouchard, SANDAG, February 11, 2003.

103

a 1-to-1 ratio.47 Caltrans has typically mitigated through private mitigation banks, and

has recently paid approximately $32,000 per acre, including land and management

costs. Assuming an overall mitigation ratio of 3-to-1, a per-acre mitigation cost of

$32,000 per acre, and impacts to the 900 acres are spread evenly through 2025, the net

2511 present value of project modification costs is approximately $42 million, as shown in

Table 3. As mentioned in Chapter II, if the western Riverside MSHCP is approved,

mitigation costs associated with future Caltrans activities in Riverside County will be

attributable to the MSHCP and not to section 7. 

CALTRANS DISTRICT 11 (SAN DIEGO COUNTY)

2516 According to Caltrans District 11 personnel, the best source of information regarding

planned or proposed transportation projects and impacts to CSS habitat is SANDAG’s

2030 Regional Transportation Plan (RTP).48 The RTP identifies all planned or proposed

new road construction projects, road widenings and improvements, light rail transit

construction, and high-speed coastal rail construction in San Diego County through

2521 2030. SANDAG personnel researched the supporting RTP data and estimated that

approximately 143 acres of CSS habitat would be developed through 2030.

49

 

The 143-acre estimate of impacted CSS habitat includes proposed road development

through Camp Pendleton associated with the Transportation Corridor Agencies’

2526 (TCA’s) proposed Foothill-South toll road. This proposed toll road is one of only two

new road construction projects proposed in the County and is located entirely within

the proposed CH area. Consequently, it is likely that a significant amount of the total

143-acre CSS is due to this project. Specifically, based on the estimated CSS impact per

linear road mile for the Foothill-South toll road, and the length of this road in the

2531 County, EPS estimates that approximately 50 percent of the 143-acre CSS impact is due
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

50This estimate of projected growth in CH is derived by running the private land development model

described in Chapter III assuming all “essential habitat,” including areas proposed for exclusion, are in

fact designated as CH. For certain counties these estimates therefore differ from those summarized in

Table 8. 

104

to this project. The economic impact on the toll road due to CHD is estimated

separately below since it is not a Caltans project. Consequently, approximately 72 out

of the 143 acres CSS impact is attributable to Caltrans projects. 

2536 This analysis assumes a typical net mitigation ratio of 0.06 -to-1 based on conservation

measures described in historical BOs, and after accounting for CEQA baseline

requirements, as shown in Table 11. For every habitat acre preserved off site, Caltrans

estimates land acquisitions costs of approximately $20,000, average supporting costs

(e.g., appraisals, surveys, administration) of $6,000, and average on-going maintenance

2541 costs of $6,000, resulting in a total average cost of $32,000 per off-site acre. As shown in

Table 3, the total net present value of these “net” off-site habitat acquisition costs,

assuming a 7 percent discount rate and equal acres mitigated each year through 2025, is

approximately $24,000.

CALTRANS DISTRICT 12 (ORANGE COUNTY)

2546 Caltrans District 12 staff were unable to provide estimates of future projects or likely

impacts to CSS through 2025. As a proxy, this analysis assumes that the relationship

between road construction activity and urban growth in Orange County is similar to

that in neighboring San Diego County. As described above, approximately 72 acres of

CSS impact are estimated in San Diego County, which is associated with approximately

35,000 acres of projected growth in Units 1 through 5 (San Diego County).

50 2551 This results

in a factor of approximately 2 acres of CSS impact for every 1,000 acres of projected

development. Applying this factor to the 11,486 acres of projected development in

Units 6, 7, and 9 (Orange County) yields a total estimate of 24 acres of CSS impact. 

2556 This analysis assumes that CSS in Orange County is mitigated at 1.82-to-1.0, as shown in

Table 11; the per-acre cost for off-site mitigation is $32,000, as shown in Table 15; and

projects are evenly distributed through 2025. The total estimated section 7 project

modification cost is approximately $444,000, as shown in Table 3. 
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

51 EPS contacted the TCA to obtain information to evaluate the economic impacts of proposed

CH, but no information was provided before completion of this draft analysis. 

105

TRANSPORTATION CORRIDOR AGENCY TOLL ROAD

2561

Background

The TCA is a multi-jurisdictional agency with joint powers authority that currently

owns and operates several toll roads in southern California. The TCA has proposed to

expand the SR-241 toll road (Foothill-North) from its current terminus at the Oso

2566 Parkway, south to Interstate 5 near San Clemente (the proposed Foothill-South

extension). The proposed alternatives for this road all lie within proposed CH Unit 6,

which straddles southern Orange County and northern San Diego County (San Onofre

State Beach Park). This project involves a Federal nexus through the USACE. Several

of the proposed alignments currently under review transect significant portions of

2571 proposed gnatcatcher CHD. Much of this habitat is also occupied by a number of other

State and/or federally listed endangered and/or threatened species, and includes

designated CH for other species.

The TCA is engaged in active planning for this project, and is currently in the process of

2576 preparing a joint draft Environmental Impact Report/Environmental Impact Statement

(EIR/EIS), which is expected to be completed in the 3rd quarter 2003. As the project is

still in the early environmental review phase, very little information is publicly

available regarding the details of various proposed alignments, including estimates of

potential impacts to CSS.51 The presence of multiple listed species and their habitat, the

2581 existence of a number of complex land use regulations in southern Orange County

(CEQA/NEPA, the 4(d) Rule, local zoning restrictions, CESA, section 7, etc.), as well as

general local concerns about growth and development in the region, further complicate

this project. The public review, comment, and approval process is expected to be timeconsuming and politically contentious, and the ultimate outcome is impossible to

2586 predict at this time. 

Whatever alignment is ultimately constructed will have a significant impact on local,

and possibly regional, traffic flow. In turn, future differences in traffic flows and

volumes can have a variety of economic outcomes, including opportunity costs of labor,
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February 24, 2004

106

2591 efficiency of goods delivery, and growth-inducing effects, among other factors. In

addition, TCA points out that because the “Far East Alignment” has been included in

the County’s RTP, many local jurisdictions have incorporated this project in their future

growth plans and projections. 

2596 Given the politically-charged climate surrounding this project, which involves a

complex interplay of public opinion, multiple species issues, and pre-existing land use

regulations other than section 7, this analysis does not consider the ultimate selection of

a particular alignment to be dependent on section 7. This analysis therefore does not

consider the various economic effects of the alignment selected – other than CSS

2601 mitigation – to be attributable to section 7 regulations associated with the gnatcatcher. 

In reality, a portion of the future section 7 costs will be attributable to other listed

species, though this analysis assumes all section 7 costs are due to the gnatcatcher. 

Alternatives Considered

According to TCA’s website, the EIR/EIS will evaluate six alternatives for Foothill2606 South. This analysis focuses on two scenarios – the “Far East Corridor” and a

combination of the “Arterial Improvements” and “I-5 Improvements” alternatives. The

Far East Corridor was selected because it represents TCA’s preferred alternative, has

been included in the County’s RTP, and appears to intersect more undisturbed habitat

than any other alternative. The Arterial and I-5 Improvements alternatives were

2611 selected because the combined scenario appears to disturb the least amount of CSS of all

alignments that still achieve the objective of providing a connection between FoothillNorth and the I-5 (as opposed to the I-5 widening alternative alone). In that respect,

these two scenarios represent good approximations of “high-impact” and “low-impact”

case studies. The two cost estimates bracket a reasonable range of expected costs, while

2616 the average of the two can be considered a “best guess” of total costs, given the current

state of uncertainty over final project approval.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

52 This assumed right-of-way width was selected based on input from Caltrans District 11 staff

regarding the average width of new highway construction.

107

Impact of Designation by Toll Road Alternative

Far East Corridor

2621 The Far East Corridor is TCA’s preferred alternative, and will provide the highest

future roadway capacity between Oso Parkway and I-5 of all the alternatives under

consideration. According to an article published in the Los Angeles Times, this

proposed alternative consists of 16 miles of new road construction. As summarized in

Table G-5, EPS estimated potential impacts to CSS by assuming all 16 new road miles

2626 intersect CSS habitat, and that the average right-of-way width is 300 feet – resulting in a

total estimate of 583 acres of CSS impacts.52

While section 7 consultation will likely result in project modifications to minimize and

mitigate this impact, both the 4(d) Special Rule and CEQA constitute baseline

2631 regulations for CSS mitigation in southern Orange County, as described in Chapter II. 

This analysis assumes that the scope of this project would make it ineligible for

approval under the 4(d) Special Rule. According to the DFG, lead agencies in Orange

County have historically required CSS mitigation at an average ratio of approximately

2-to-1. As discussed in Chapter III, EPS’ review of historical section 7 BOs in Orange

2636 County identified an average effective mitigation ratio of approximately 3.8-to-1,

meaning that the net CSS mitigation ratio above the CEQA baseline is approximately

1.8-to-1 (Table 11).

This analysis assumes that all impacted CSS acres will be mitigated through purchase of

off-site preservation credits at a private mitigation bank. As described previously, EPS’

2641 review of mitigation banks in Orange County determined an average price per-acre of

approximately $78,000. According to TCA’s website, the Foothill-South project is

expected to be constructed between 2005 and 2008. The net present value of the

estimated mitigation costs incurred over this time period is approximately $61.4 million,

as shown in Table G-5. The estimated administrative costs of the single formal

2646 consultation is $18,100, as calculated in Appendix F and summarized in Table 3. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

53 These estimates were made based on review of proposed alignments, highway maps of

southern Orange County, and aerial photographs overlayed with gnatcatcher biological and

habitat data.

108

Arterial and I-5 Improvements Alternatives

According to TCA’s website, the Arterial Improvements alternative consists of

widening Antonio Parkway and Avenida La Pata and installing “smart street”

technologies on Ortega Highway, Camino Las Ramblas, and Avenida Pico. The I-5

2651 Improvements alternative involves adding additional lanes between the SR-405

intersection and Cristianitos Road near Camp Pendleton. As summarized in Table G-6,

EPS estimates that approximately 10.4 miles of arterial roads will require widening,

approximately 9.4 miles of arterial roads will be constructed with smart street

technology, and approximately 4.5 total miles of I-5 will be widened in areas where CSS

is present.53 2656 This analysis assumes that arterial and I-5 widening will consist of

installing two new lanes (10 ft. each), and the expanded right-of-way (ROW) will extend

an additional 10 feet on either side of the new lanes, for a total expanded ROW of 40

feet. It is also assumed that installation of smart street technology will increase the

ROW by 10 feet. All habitat traversed by these road miles is assumed to be CSS,

2661 mitigable under section 7.

As described for the Far East Corridor, this analysis assumes an effective CSS mitigation

ratio above CEQA baseline of 1.8-to-1, and an off-site mitigation cost of $78,000 per acre

in Orange County. As shown in Table G-6, the estimated project modification cost of

2666 the Arterial and I-5 Improvement scenario is approximately $8.8 million. The estimated

administrative costs of the single formal consultation is $18,100, as calculated in

Appendix F and summarized in Table 1. 

Total Economic Cost of Designation on Toll Road

Given the uncertainty surrounding which alignment will ultimately be constructed, this

2671 analysis presents the section 7 cost of the TCA’s proposed Foothill-South toll road as a

an average of the two potential outcomes described above. Because these two cost

estimates are assumed to bracket the potential section 7 costs of all the proposed

alignments that meet project objectives, their average represents a reasonable
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

54 Personal communication with Karl Seckel, Assistant Manager, Municipal Water District of

Orange County, and Dan Ferons, Chief Engineer, Santa Margarita Water District, on January 30,

2003.

109

approximation of the likely economic outcome. The average section 7 project

2676 modification cost is $35.1 million. 

PRIVATE ROADS

Private road development would require section 7 consultation for future projects with

a Federal nexus. This analysis assumes that the vast majority of future road

construction by private parties will be associated with the forms of private land

2681 development (residential, commercial, industrial, etc.) addressed in Chapter 3. All road

construction associated with these future projects will be incorporated in the project

description, and any required project modifications required because of road-based

impacts to CSS will be addressed in the BO for the project as a whole. This analysis

therefore assumes that no additional private road construction projects will require

2686 section 7 consultation, and that there will be no additional economic cost. 

LOCAL AND REGIONAL WATER PROJECTS

The Metropolitan Water District of Southern California (MWD) is responsible for

constructing and maintaining the water delivery system to the majority of southern

California water users, with the exception of San Diego County. In general, the MWD

2691 provides “regional” water delivery infrastructure, while the local “retail” water districts

are responsible for constructing and maintaining municipal water infrastructure to endusers on a local scale. In San Diego County the SDCWA provides water delivery

infrastructure between the MWD network and the local distribution systems. 

2696 Local water agencies indicate that the vast majority of construction projects undertaken

by local retail agencies occur in association with, and as a result of, new residential

development.54 This analysis assumes that the section 7 consultations required for

residential development projects will also address and cover the cost of any new water
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

55 According to SDCWA staff, the SDCWA may undertake projects that are not listed in the

Master Plan. Staff also pointed out, however, that CSS-impact estimates may include habitat

acreage that is not considered suitable for the gnatcatcher. On the whole, the SDCWA therefore

considers the estimates provided as accurate an approximation of future CSS impacts as is

currently available.

110

(or other utility) infrastructure that is specifically associated with those projects (see

2701 Chapter II). This analysis therefore concludes that no additional section 7 consultations

will be required for construction projects by local retail water agencies beyond those

that serve and are paid for by new development.

This analysis assumed that CSS impacts related to regional water supply activities

would be associated with 13 future formal consultations, based on information

2706 provided by the utilities and acreage adjustments reflecting the amount of CSS

proposed for CHD. The estimated administrative cost of these consultations is

approximately $116,000, as shown in Table 3. 

SAN DIEGO COUNTY WATER AUTHORITY

The SDCWA has recently completed a 25-year Water Facilities Master Plan, which

2711 outlines planned or proposed projects likely to occur within that timeframe. SDCWA

staff estimate that approximately ten (10) future projects will require section 7

consultation, eight of which will result in impacts to CSS habitat.55 As summarized in

Table G-7, the SDCWA provided estimates of the potential impacts of each project

(permanent vs. temporary), and the likely timing of each project. EPS assumed that CSS

2716 impacts were evenly distributed throughout the indicated timeframe, and applied

“net”CSS mitigation ratios of 2-to-1 and 1.2-to-1 (permanent and temporary,

respectively), which take into account baseline CEQA mitigation in San Diego County. 

Based on SDCWA input, EPS also assumed both off-site mitigation and restoration will

cost approximately $15,000 per acre, resulting in a total project modification cost

2721 estimate of approximately $538,000, when adjusted to CSS acreage proposed for CH. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

56See footnote 52.

111

METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA

MWD staff were unable to provide estimates of future projects or CSS acres impacted

within proposed CHD. As a proxy, this analysis assumes that the relationship between

2726 regional water infrastructure and projected urban growth for the counties served by the

MWD is the same as it is for San Diego County. As discussed above, the SDCWA

authority anticipates 10 future consultations impacting a total of 146 acres of CSS

through 2025. Approximately 35,000 acres of future growth is projected in Units 1

through 5, yielding a ratio of 4.2 CSS acres for every 1,000 acres of projected growth.56

2731 Applying this factor to the estimated 48,000 acres of projected growth in the remaining

CH units yields an estimate of 199 acres of impact. This analysis assumes that these

impacts will be associated with 14 future formal section 7 consultations, based on a rate

of one consultation for every 14.6 acres of CSS impact.

This analysis assumes that future CSS impacts will be mitigated at a 2.1-to-1 ratio and at

2736 a per-acre cost of approximately $48,000. These estimates represent the average ratio

and cost, respectively, for counties other than San Diego, taking into account CEQA

baseline in Orange County. Assuming future impacts are distributed evenly through

2025, the total estimated cost of section 7 project modifications is approximately $6.1

million, when adjusted for CSS acres actually proposed for CH. 

2741 BUREAU OF RECLAMATION

The Bureau of Reclamation (BOR) develops and maintains water projects such as dams,

canals, irrigation systems and water reclamation. BOR personnel indicated that

previous section 7 consultations involving the gnatcatcher have generally fallen into

two categories – relatively small-scale water reuse project initiated by local water

2746 agencies that involve BOR funds, and larger-scale water delivery infrastructure projects

that involve BOR funds and oversight. Based on historical and anticipated project

frequencies, BOR staff suggested assuming that each five years the BOR will initiate

four section 7 consultations for small-scale reuse projects, and one consultation for a
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

112

large-scale infrastructure project. This analysis assumes that three of the small-scale

2751 reuse projects will require informal consultations, and the remaining two projects will

require formal consultation, including the preparation of a BO. Based on this

frequency, and adjusting for the amount of CSS acreage actually proposed for CHD, this

analysis estimates that the BOR will initiate 12 informal consultations and 3 formal

consultations through 2025.

2756

Typical section 7 project modifications and costs differ for the two types of projects

described above. According to BOR staff, the small-scale reuse projects usually occur in

San Diego County and tend to be located in already developed areas or along existing

rights of way. These projects therefore often disturb very little CSS habitat, if any

2761 (which is why many only require informal consultation). Based on consultation with

BOR staff, this analysis assumes that each reuse project will impact 0.5 acres of CSS

habitat, for which the applicant will mitigate through off-site preservation at standard

San Diego mitigation ratios and acquisition costs. BOR staff also indicated that these

applicants must comply with the MSCP and CEQA regulations, as appropriate.

2766

As mentioned above, the BOR anticipates being involved in approximately one largescale infrastructure project every five years, which could occur in any of the six counties

proposed for critical habitat. The BOR suggested using the San Sevaine Creek Water

Project section 7 consultation to develop assumptions of future project modifications

2771 and costs. As described in the summary of the BO (see Appendix C), this project

involved the construction/ replacement of a levee, a debris basin, and over 13 miles of

flood control channels. The project impacted 64 acres of gnatcatcher habitat, and is

assumed to be representative of future large-scale flood control projects. This analysis

applies a “net” section 7 ratio of 0.06-to-1 to all projects requiring formal consultation,

2776 which takes into account baseline CEQA mitigation in San Diego County.

As shown in Table 15, the average price for CSS mitigation credits across the proposed

CH area is approximately $32,000 per acre. As shown in Table 3 , the net present value

of project modifications for the “large-scale” consultations is approximately $153,000. 

2781 The total estimated administrative cost for three formal consultations and twelve

informal consultations is $67,000, as calculated in Appendix F and summarized in Table

3. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

113

MUNICIPAL POWER SUPPLY

Regional-scale gas and electric service to southern California residents within the

2786 proposed CH boundaries is provided primarily by three companies – San Diego Gas &

Electric (SDG&E), the Southern California Gas Company (SCGC), and Southern

California Edison (SCE). SDG&E and the SCGC are owned by the same parent

company, Sempra Energy. SDG&E provides gas and electric service to residents of San

Diego County while SCGC provides natural gas service to southern California residents

2791 outside San Diego County. SCE provides electricity service to southern California

residents outside San Diego County. Both companies own and operate a large network

of utility infrastructure, including power generating stations, substations, transmission

lines, and natural gas pipelines.

2796 As with municipal water supply (see above), the analysis assumes that new gas and

electric infrastructure at the local scale will be associated with new private

development. As such, the section 7 consultations required for those private

development projects with a Federal nexus will incorporate and address the associated

local-serving gas and electric infrastructure. No additional section 7 costs are estimated

2801 for these local-scale developments. Regional-scale gas and electric infrastructure would

not be addressed by the section 7 consultations for private developments, however. An

evaluation of section 7 costs associated with regional projects planned or proposed by

SDG&E, the SCGC, and SCE is provided below. This analysis assumes a total of six

future formal consultations for the municipal power supply projects described below. 

2806 This estimate is based on projected consultation rates provided by the major utility

companies. Total estimated administrative costs are approximately $52,000, as shown

in Table 3.

SOUTHERN CALIFORNIA EDISON

SCE delivers electricity to over 4.8 million customers throughout much of southern and

2811 central California, including parts of Ventura, Los Angeles, San Bernardino, western

Riverside, and northern Orange counties. SCE owns and operates power generating

stations and substations as well as a large network of transmission lines. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

57 Personal communication with Dan Pearson, Manager, Land Services & Environmental Affairs,

Southern California Edison, February 10, 2003.

58 Mr. Pearson qualified this assumption by stating that if the Service requires mitigation for

indirect effects (e.g., mitigation for the growth inducing effects of providing electricity

infrastructure to an area), that the mitigation costs would escalate exponentially. He stated that

SCE would strongly oppose any effort by the Service to require mitigation for anything other

than direct impacts to habitat. 

59These estimates represent the average ratio and cost, respectively, for counties other than San

Diego, taking into account CEQA baseline in Orange County. 

114

SCE personnel estimate that approximately four future projects will require section 7 

consultation due to the gnatcatcher.57 2816 Due to the competitive nature of the electricity

industry and the difficulty in forecasting infrastructure projects in the long-term, SCE

staff were not able to provide project-specific detail. In general, one new 500-kilovolt

(KV) substation and two new 500-KV transmission lines are expected within the next 10

years, and an additional “large-scale” project is expected by 2020 based on historical

2821 infrastructure construction cycles. Federal nexus would be in the form of Federal

Energy Regulatory Commission approval of the new transmission line(s), USACE

section 404(b) regulation, or the need to traverse BLM, United States Forest Service

(USFS), or other federal land for one or more of the projects. SCE staff estimated that

the substation would be located entirely within one county (location undisclosed),

2826 while one 500-KV line would traverse two counties and one would traverse three

counties (route undisclosed).

SCE personnel estimated that approximately 250 acres of CSS habitat would be

disturbed by the four projects, and suggested that EPS assume mitigation ratios

2831 consistent with other linear utility projects, and mitigation costs consistent with private

mitigation banks in the southern California region.58 EPS assumed the four projects will

be constructed in years 3, 6, 9, and 15, and CSS impacts are evenly distributed among

the projects. Assuming a 1.5-to-1 mitigation ratio for 250 acres,59 and an average

mitigation price of $48,000 per acre (an average of prices in mitigation banks outside

2836 San Diego County), total estimated project modification costs are approximately $7

million, when adjusted for acreage proposed for CHD.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

60 Personal communication with Don Haines, Manager, Land Planning & Natural Resources

Group, Sempra Energy, February 13, 2003. Mr. Haines cited the uncertainty of capital

improvement projects and the energy market through 2025, as well as the commitment of staff

resources that would be required to develop an estimate, in declining to provide information.

61

See footnote 52.

115

SAN DIEGO GAS & ELECTRIC

2841 While it is possible that future construction, operation, and/or maintenance activities

conducted by either SDG&E or the SCGC may result in section 7 consultations

involving the gnatcatcher, Sempra Energy personnel declined to provide any

information regarding the likelihood of future consultations or estimates of any

resulting costs.60 According to staff at the California Public Utilities Commission,

2846 SDG&E has conceptualized construction of a 500-KV transmission line sometime in the

timeframe of this analysis that could potentially intersect proposed gnatcatcher CH. 

CUPC staff called this potential line the “Imperial Valley-to-Miguel line,” which they

said might parallel the US-Mexico border just south of San Diego. No additional

project-specific information was provided, however. 

2851

Though SDG&E staff were unable to provide estimates of future projects or

modification costs, this analysis assumes that the relationship between regional

electricity infrastructure and projected urban growth is the same for San Diego County

as for remaining counties proposed for CH. As discussed above, SCE anticipates four

2856 future consultations impacting a total of 250 acres of CSS through 2025. Approximately

48,000 acres of future growth is projected in proposed units outside San Diego, yielding

a ratio of 5.2 CSS acres for every 1,000 acres of projected growth. Applying this factor to

the estimated 35,000 acres of projected growth in San Diego County yields an estimate

of 183 acres of impact.

61

2861

This analysis assumes that future CSS impacts will be mitigated at a net 0.06-to-1 ratio

and at a per-acre cost of $19,750 (the average ratio and cost, respectively, for San Diego

County). Assuming future impacts are distributed evenly through 2025, the total

estimated cost of section 7 project modifications is approximately $70,000, when

2866 adjusted for acres proposed for CH. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

62 Personal communication with Don Haines, Manager, Land Planning & Natural Resources

Group, Sempra Energy, February 13, 2003. Mr. Haines cited the uncertainty of capital

improvement projects and the energy market through 2025, as well as the commitment of staff

resources that would be required to develop an estimate, in declining to provide information.

116

It is worth noting that many of SDG&E’s operational activities are addressed in its

“Subregional Natural Community Conservation Plan,” which was approved by the

Service in 1995 and therefore constitutes a “regulatory baseline” for covered activities. 

2871 In approving the plan, the Service issued a 50-year section 10(a) permit covering the

installation, use, maintenance, and repair of the existing gas and electric system and

typical expansions to that system. Because the 50-year permit establishes mitigation

requirements for all covered activities under the plan, any potential section 7 costs

would be limited to administrative consultation costs, and project modification costs for

2876 activities not covered in the plan. 

SOUTHERN CALIFORNIA GAS

As mentioned above, Sempra Energy personnel declined to provide any information

regarding the likelihood of future consultations or estimates of any resulting costs.

62 In

order to provide an estimate of future project modification costs, this analysis assumes

2881 that future CSS impacts resulting from SCGC regional infrastructure projects will be

roughly proportional to those estimated for electricity infrastructure projects conducted

by SCE. This analysis uses SCE as a proxy because SCE and SCGC have similar service

territories (southern California outside San Diego County), and both are involved in the

construction of “linear” regional utility infrastructure. 

2886

The SCE company website indicates that SCE’s service territory encompasses

approximately 50,000 square miles. As described above, electric utility projects through

2025 built to serve this territory are estimated to impact approximately 250 acres of CSS

habitat. The SCGC website indicates its service territory is approximately 23,000 square

2891 miles. Assuming habitat impacts due to infrastructure construction are proportional to

service territory size, this analysis estimates that SCGC infrastructure projects through

2025 will result in impacts to approximately 115 acres of CSS habitat. Applying the

same scaling factor to SCE’s anticipated four consultations yields an estimate that SCGC

will be involved in two projects through 2025 that require formal section 7 consultation. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

63 Personal communication with Forest Biologist, Bill Brown, Angeles National Forest January 30,

2003.

117

2896 To estimate the cost associated with these utility projects, this analysis assumes that

section 7 project modifications will include off-site mitigation at a 2.11-to-1 ratio, and

that per-acre CSS acquisition costs will be approximately $55,000. These assumptions

correspond to the average “net” mitigation ratio and costs for counties other than San

Diego, as shown in Table 11 and Table 15, respectively. The estimated project

2901 modification cost for these projects is approximately $4.4 million, after adjusting for

acreage proposed for CH. 

FEDERAL LAND MANAGEMENT

Future activities on Federal land constitute a section 7 Federal nexus. Categories of

Federal land proposed for gnatcatcher CH include land owned or managed by the USFS

2906 and BLM. USFS activities likely to require section 7 consultation primarily consist of

protecting CSS habitat during prescribed burns conducted as part of fire

control/prevention programs. The BLM anticipates a number of future section 7

consultations involving the gnatcatcher, but is unable to predict the specific projects

that will require consultation. 

2911 U.S. FOREST SERVICE LAND

Angeles National Forest

The Angeles National Forest (ANF) estimates that one informal consultation will occur

each year for prescribed burns and that numerous phone calls and field visits may be

necessary.63 In 2002, one informal consultation was required for a joint prescribed burn

2916 with the County due to the presence of coastal sage scrub. This analysis estimates 23

informal consultations through 2025 associated with prescribed burns in the ANF.

ANF staff estimated that project modifications required to protect CSS adjacent to burn

areas typically result in an additional cost of approximately $10,000 for every 100 acres

2921 of CSS habitat protected. ANF personnel indicated that there are approximately 4,000

acres of CSS remaining within the ANF.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

64 Personal communication with Forest Biologist, Kirsten Winter, Cleveland National Forest

January 28, 2003. Ms. Winter was interviewed again on June 18, 2003 to confirm this estimate in

light of the recently completed programmatic section 7 BO for the 4 Southern California Forests. 

Ms. Winter stated that the programmatic BO specifically did not address future activities such as

prescribed burns, and that given the amount of CSS habitat in the AN F, she believed her original

estimate remained accurate. 

118

Estimating project modification costs for future prescribed burns is difficult given

uncertainties inherent in fire management practices. However, in order to be more

likely to overestimate than underestimate costs, this analysis assumes that all 4,000

2926 acres of CSS will require protection as a result of the 23 prescribed burns anticipated

through 2025. As shown in Table 3, the total estimated project modification cost for

these future prescribed burns is approximately $196,000. The estimated administrative

cost of the 23 informal consultations is approximately $52,000, as calculated in

Appendix F and summarized in Table 3.

2931 Cleveland National Forest

The Cleveland National Forest (CNF) estimates that two to three formal consultations

and three informal consultations a year may be required through 2025 due primarily to

protecting coastal sage scrub during prescribed burns.64 In 2001, the CNF was involved

in three section 7 consultations regarding grazing, a prescribed burn, and the forest

2936 management plan due to the presence of coastal sage scrub. This analysis assumes 41

informal consultations and 41 formal consultations through 2025, after adjusting for

acreage actually proposed for CHD, half of which will require Biological Assessments. 

Based on previous consultations, the CNF estimated that formal consultations for

2941 prescribed burns would add an additional $10,000 for every 100 acres of coastal sage

scrub requiring protection. While CNF staff indicated that an extra $4,000 may be

required if an in-house species survey is required, this analysis assumes these costs are

represented in the cost of preparing Biological Assessments. Staff estimated that

approximately 20,000 acres of CSS is present within the CNF. 

2946

Estimating project modification costs for future prescribed burns is difficult given

uncertainties inherent in fire management practices. However, in order to be more

likely to overestimate than underestimate costs, this analysis assumes that all 20,000

acres of CSS will require protection as a result of the 41 prescribed burns anticipated
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

65 Personal communication with Forest Biologist, Steve Loe, San Bernardino National Forest

February 13, 2003. 

66 Personal communication with Wildlife Biologist, Joel Schultz, January 27, 2003 and Endangered

Species Specialist, Ed Lorentzen January 29, 2003.

119

2951 through 2025. As shown in Table 3, the total estimated project modification costs for

these future prescribed burns is approximately $204,000. The estimated administrative

cost of the informal and formal consultations is approximately $340,000, as calculated in

Appendix F and summarized in Table 3. 

San Bernardino National Forest

2956 The San Bernardino National Forest (SBNF) estimated that three to five formal

consultations and three to five informal consultations may be required through 2025

due primarily to protecting coastal sage scrub during prescribed burns.65 This analysis

assumes that five informal and five formal consultations will be required through 2025. 

2961 Staff indicated that approximately 1,000 acres of CSS habitat is present in the SBNF, and

that the costs to protect CSS during prescribed burns are similar to those of the other

National Forests ($100 per acre of CSS protected). Assuming that all 1,000 acres will

require protection through 2025, the total estimated project modification cost is

approximately $49,000 as shown in Table 3. The estimated administrative cost of 5

2966 informal and 5 formal section 7 consultations is approximately $47,000, as summarized

in Table 3.

BUREAU OF LAND MANAGEMENT

The BLM estimated that it will participate in approximately 4 formal and 12 informal

section 7 consultations through 2025. Three technical assistance calls were also

estimated over the same time period.66 2971 

The BLM has been involved in several formal and informal consultations involving the

gnatcatcher, though only one formal consultation was recent enough to have records

available on project modification costs. In that consultation, the BLM was required to

2976 mitigate construction and maintenance activities on four acres of CSS habitat through

off-site acquisition of CSS at a 2-to-1 ratio, maintenance outside the breeding season,
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

67 Personal communication with FEMA Program Manager, Chris Barkley, URS Corporation

(contracted with FEMA to handle technical support), February 2, 2003

120

redirection of roads around habitat areas, and closure of trails leading through

gnatcatcher habitat. The BLM was able to acquire CSS habitat off site at $1,500 per acre. 

2981 BLM staff were unable to provide any estimates of likely habitat impacts for future

projects requiring section 7 consultation. In the absence of any additional supporting

data, EPS assumed that future consultations are similar in size, scope, and cost to the

single BLM historical consultation described above (i.e., each requiring 4 acres of 2-to-1

mitigation at $1,500 per acre). The estimated net present value of project modifications

2986 associated with future consultations is $26,000. The estimated administrative cost of 4

formal consultations, 12 informal consultations, and 3 technical assistance calls is

$59,000, as calculated in Appendix F and summarized in Table 3. 

FEDERAL EMERGENCY MANAGEMENT ACTIONS

The Federal Emergency Management Agency (FEMA) has engaged in formal and

2991 informal consultations for construction, prescribed burns, and flood prevention. FEMA

personnel estimate that 30 formal consultations and 75 informal consultations involving

the gnatcatcher will be required through 2025.67 

FEMA staff estimated that formal consultations will require preconstruction surveys,

2996 avoidance of construction activities during breeding season, and avoidance of CSS

habitat when possible. FEMA staff were unable to provide estimates regarding likely

impacts due to future projects or the extent of avoidance required. Due to the lack of

available information, this analysis assumes that the future project modification costs

will be limited to preconstruction survey costs, and that these costs are captured by

3001 consultation cost model estimates for Biological Assessments. The estimated

administrative cost of future consultations is approximately $386,000, as calculated in

Appendix F and summarized in Table 3.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

68The economic cost estimates do not account for the potential effect of CHD, if any, on military

readiness. Such an estimate is beyond the scope of this analysis.

121

MILITARY PROPERTY AND OPERATIONS

This section estimates potential section 7 economic costs associated with military base

3006 property and operations in areas proposed as critical habitat and areas proposed for

exclusion.68

MARINE CORPS BASE CAMP PENDLETON

Some areas within Marine Corps Base Camp Pendleton have been proposed for CH

while mission-essential training areas have been proposed for exclusion. This section

3011 first addresses the economic costs associated with those areas proposed for CH. The

economic cost of designating mission-essential training areas is evaluated separately

below to assist with weighing the benefits of exclusion against the benefits of inclusion.

Description of Areas Proposed and Areas Proposed for Exclusion

The Marine Corps Base Camp Pendleton has approximately 16,471 acres of proposed

3016 CH. Of this amount, approximately 3,546 acres represent lands leased to the State of

California for use as a State Park (i.e., San Onofre State Beach). The remaining 12,925

acres are located within or adjacent to existing developed or urbanized areas of the

Base, including Marine Corps housing and other base support-related land uses. The

proposed CH does not include military training areas, although these areas are known

3021 to include essential gnatcatcher habitat. The Service has proposed for exclusion all

mission-essential training areas that contain essential gnatcatcher habitat, citing section

4(b)(2) of the Act.

Consultation Background

The current INRMP for Camp Pendelton was completed in October 2001. Although the

3026 INRMP meets the requirements of the SAIA, the Service has expressed concern that the

document possesses a number of inadequacies with regard to resource and ecosystem
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

69 See USFWS letter to the Lupe Amas, Commanding General of Marine Corpse Base Camp

Pendelton, October 19th, 2001 (FWS-MCBCP-2317.1)

70Camp Pendleton maintains a 20-acre CSS Restoration bank located near the O’Neil Heights

housing area in the south east portion of the Base. Approximately 7.7 surplus acres currently

remain. 

122

management.69 Consequently, for the purposes of estimating the economic costs of

CHD, this analysis assumes that the INRMP does not serve as a baseline regulatory

requirement for the gnatcatcher. This is a conservative approach (e.g., more likely to

3031 overestimate than underestimate actual costs) because in reality the INRMP does

articulate guidelines and protection measures for gnatcatcher habitat, as do existing

biological opinions.70

A summary of the consultation history for the gnatcatcher on Camp Pendleton is

provided in Table 18. As shown, there have been a total of 17 biological opinions

3036 issued for the gnatcatcher since 1995, 13 of which pertain to activities outside the

military training area boundaries. In addition, the Service is currently involved in a

programmatic section 7 consultation with Camp Pendleton regarding numerous

activities that are ongoing or expected to occur within the upland areas, the primary

location for training activities. Once completed, this document will provide further

3041 protection for gnatcatcher habitat.

Estimated Economic Costs

Because the analysis assumes that the existing INRMP and BOs provide no baseline

protection for the gnatcatcher, all future consultation and project modifications costs are

attributable entirely to section 7. Camp Pendleton staff provided no information

3046 regarding future projects that may require section 7 consultation, so future cost

estimates are based on the historical consultation rates as calculated in Table 18. As

shown, the non-training areas average about 1.6 consultations and $428,800 in CSS

mitigation/restoration costs per year (or 37 consultations through 2025). Assuming

these costs will be incurred at the same rate over the next 23 years, the estimated net
Table 18

Biological Opinions for the Gnatcatcher at Pendleton (1995 to Present)

Location / Project Name Service Date of Estimated

Project # BO Permanent Temporary Cost (1)

Non-Training Areas

San Onofre Sewage Effluent 1-6-95-F-25 3/30/1995 0 0.3 $11,400

Bridge Retrofit - Interstate 5 1-6-96-F-31 8/15/1996 0 1.08 $41,040

Santa Margarita Sewage Effluent 1-6-96-F-36 10/21/1996 26.3 0.8 $2,029,200

Slope Stabilization at SDGE Talega Substation1-6-98-F-27 9/8/1998 0 3.5 $133,000

DeLuz Housing 1-6-98-F-38 11/23/1998 3.93 0 $298,680

Ammunition Handling Facility 1-6-99-F-30 4/19/1999 2.57 1.07 $235,980

Santa Margarita River Levee 1-6-95-F-02-R10 7/19/1999 1.65 0 $125,400

PPM Burn at San Mateo 1-6-00-F-34 5/12/2000 5.0 0 $380,000

Las Flores Estancia 1-6-01-F-910.2 2/2/2001 0.74 0 $56,240

SDGE Talega Substation Expansion 1-6-02-F-1988.2 12/10/2001 0 0 $0

SDGE Access Road 1-6-02-F-2464.2 1/31/2002 0 0 $0

San Onofre Housing Firebreak 1-6-02-F-2869.1 5/23/2002 0.77 0 $58,520

San Mateo BEQ Parking 1-6-02-F-2729.3 5/30/2002 2.21 0 $167,960

Subtotal 0 43.17 6.75 $3,537,420

Amount Per Year 0.00 5.23 0.82 $428,778

Training Areas

Northern Power Line 1-6-99-F-45 6/28/1999 0.0013 0.148 $5,723

SFPP Petroleum Pipeline 1-6-99-F-54 8/23/1999 0 0 $0

Electrical Towers M3-T3 1-6-99-F-76 10/28/1999 0.17 0.12 $17,480

Range 314 Road Upgrade 1-6-03-F-3001.3 1/10/2003 3.5 0 $266,000

Biological Assessment of Upland Habitat on-going - - -

Subtotal 0 3.6713 0.268 $289,203

Amount Per Year 0.00 0.45 0.03 $35,055

(1) Assumes a 2:1 total mitigation requirement for permanent impacts, 1:1 restoration for temporary impacts, 

and a cost of $ per mitigated or restored acre. Does not represent actual amount paid.

Source: US Fish & Wildlife Service; Fallbrook Naval Weapons Station; Economic & Planning Systems, Inc.

Acres of CSS Impact

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71 Conversation with Service staff on March 6th, 2001.

124

present value of project modification costs is $4,833,000, as shown in Table G-17 and

Table 3. These estimates assume a CSS mitigation/restoration cost of $38,000 based on

information provided by the Fallbrook Naval Weapons Station. The estimated

3056 administrative cost of the 37 future formal section 7 consultations is $178,000, as

calculated in Appendix F and summarized in Table 3. 

Using the methodology described for non-training areas, mission-essential training

areas will average about 0.6 consultations and $35,100 in CSS mitigation/restoration

costs per year (or 14 consultations through 2025). Assuming these costs will be

3061 incurred at the same rate over the next 23 years, the estimated net present value of

project modification costs is $395,000, as shown in Table G-17. The estimated

administrative cost of 14 future section 7 consultations is $67,000. Because training

areas have been proposed for exclusion, these administrative and project modification

cost estimates are not included in the total economic impact summary provided in

3066 Table 3 or in totals calculated in Appendix F. These value are included in the Unit

summaries provided in Table 2 (“Proposed for Exclusion” column).

MARINE CORPS AIR STATION MIRAMAR

Background

The Marine Corps Air Station (MCAS) Miramar contains approximately 2,524 acres of

3071 essential habitat that have been proposed for exclusion. Thus, the cost estimates

provided herein are designed to provide information for weighing the benefits of

exclusion against the benefits of inclusion, and are not included in the total cost

summary in Table 3.

3076 The current INRMP for Miramar was completed in May 2000 and is well regarded by

the Service.71 In addition, MCAS has completed two other documents that articulate

standards and obligations for the protection of CSS and the gnatcatcher. These include:

(1) a BO/Conference Opinion for the Realignment of Naval Air Station Miramar to

Marine Corps Air Station Miramar completed in April 11, 1996, and (2) Implementation,

3081 Maintenance and Monitoring of Coastal Sage Scrub Restoration on Marine Corps Air
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125

Station Miramar, completed on December 8, 1999. The standards and commitments

outlined in these documents include, but are not limited to, the following:

C A commitment to develop and implement land management practices consistent

3086 with the guidelines that established for other sub-area plans through the

Multiple Specials Conservation Program (MSCP) adopted by a number of San

Diego County jurisdictions.

C Mitigation at a 2-to-1 replacement ratio for the authorized destruction of suitable

3091 gnatcatcher habitat and at a 1-to-1 ratio for other CSS. The unauthorized

destruction of CSS habitat will be mitigated or restored at a 5-to-1 ratio.

C Limit of land-use activities disruptive to gnatcatcher habitat to the non-breeding

season.

3096

C A commitment and detailed plan to restore, manage, and maintain

approximately 87.5 acres of abandoned agricultural fields to a permanent CSS

plant community.

3101 EPS has identified a total of five BOs related in part or in whole to the gnatcatcher and

CSS habitat on Miramar since 1993, which equates to an average of approximately 0.5

consultations per year. These BOs, which articulate conservation measures that require

continued management on Miramar, include the following:

3106 1. BO on the proposed maintenance, improvements, and use of existing roads, lots,

driveways, and loading docks at Miramar (1-66-99-F-64) completed in August

1999.

2. BO on Nobel Drive/I-805 Interchange and Extension project San Diego County

3111 (1-6-97-F-30) completed on August 1, 1997.

3. BO / Conference Opinion for the realignment of Naval Air Station Miramar to

Marine Corps Air Station Miramar completed on April 11, 1996.
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72 Personal communication with Robert Knight, Station Biologist and Jan Larson, Director of

Environmental Operations March 6, 2003.

73 Fallbrook staff also provided information on projects currently undergoing section 7

consultation and estimated conservation fund allocations expected to be expended on the CAGN. 

These data were not considered relevant to a consideration of future section 7 costs for the

CAGN.

126

3116 4. BO for the Fiesta Island Replacement Project/North Sludge Processing Facility

and West Miramar Landfill Overburden Disposal (1-6-94-F-37) completed on

September 29, 1994 (an amendment to this opinion was completed on January

12, 1995).

5. BO on Nave Family Housing at Eucalyptus Hills San Diego County, (1-6-93-F3121 33) completed on November 12, 1993.

Estimated Economic Costs

As described above, the Miramar INRMP, past BOs, and other documents represent a

strong set of existing commitments, standards and obligations for the protection and

mitigation of CSS and gnatcatcher habitat. Consequently, this analysis assumes these

3126 documents constitute a regulatory baseline for future measures designed to protect

gnatcatcher habitat, such as CSS mitigation or restoration. In other words, these

mitigation costs will be incurred independent of future section 7 consultations. 

However, this economic analysis assumes that the administrative costs associated with

future section 7 consultations are attributed to designation. Thus, at an average of 0.5

3131 gnatcatcher-related consultations per year, there will be 12 estimated consultations over

the next 23 years with a total administrative cost of $58,000.

U.S. NAVAL WEAPONS STATION SEAL BEACH, DETACHMENT FALLBROOK

The Naval Weapons Station Seal Beach, Detachment Fallbrook (Fallbrook) is a facility

operated by the U.S. Navy that is charged primarily with storing and replenishing

3136 military ordnance; no training activities occur on site. CH has been proposed for

Fallbrook as part of critical habitat Unit 4, which overlaps the eastern portion of Camp

Pendleton; no areas within Fallbrook have been proposed for exclusion. Fallbrook staff

estimate that approximately 16 formal consultations for the CAGN will be necessary

through 2025.72 Future projects include:73
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74 Personal communication with Gordon Brown, Remedial Project Manager on February 3, 2003,

and Robert Palmer, Biological Consultant on January 2, 2003. 

127

C Widening of Ammunition Road and installation of fencing in the 1st 3141 quarter

2004, which is expected to disturb 20 acres of CSS.

C Construction of up to 10 magazines (earth-covered storage vaults for explosive

ordnance) between 5 and 25 years out, each disturbing a maximum of 5 acres of

habitat.

3146 C One future road construction project every 5 years, each with an assumed ROW

coverage of approximately 6.7 acres, 50 percent of which (3.3 acres) is assumed

to contain CSS.

C Construction of one warehouse building in year 15, which is expected to disturb

approximately 5 acres of CSS.

3151

Based on previous section 7 consultation experience, Fallbrook personnel suggested

assuming future impacts to CSS would be mitigated through on-site restoration at a 1-

to-1 ratio at a cost of $38,000 per acre. As shown in Table 3, the total estimated cost of

section 7 project modifications is $2.1 million. The total estimated administrative cost of

3156 the 16 formal consultations is $115,000.

EL TORO REUSE AREA

The El Toro Reuse Area is a former military installation that the U.S. Navy currently

manages as a reserve area for the Central/Coastal Orange County HCP/NCCP. CH has

been proposed for El Toro as part of Unit 6; no areas within El Toro have been proposed

3161 for exclusion. El Toro staff estimate that, at most, one project requiring formal

consultation for the CAGN will be necessary through 2025.74 This possible consultation

would address construction of the Alton Parkway, which could affect up to 4,000 acres

of CSS habitat. As discussed in Chapter II, this project is a Planned Activity under the

Central/Coastal Orange County HCP/NCCP, and CSS mitigation has already been

3166 addressed by the Plan, so no section 7 project modification costs are anticipated. The

required formal section 7 consultation will result in administrative costs of $14,600, as

shown in Appendix F and Table 3. 
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HABITAT CONSERVATION PLANS

EXISTING CONSERVATION PLANS

3171 All established reserve areas within existing, approved project-specific HCPs that

adequately address the gnatcatcher have been proposed for exclusion. This section

evaluates the economic impact were these reserve areas to be designated as critical

habitat, in order to allow the Service to weight the costs of inclusion with the costs of

exclusion. 

3176

This analysis was unable to estimate accurately the number of future activities that have

been authorized under existing project-specific HCPs that would involve a Federal

nexus. Furthermore, neither the Service’s nor the USACE’s section 7 consultation

record consistently specifies whether a particular consultation involves a project

3181 authorized by an existing HCP, or is within the plan area of a project-specific HCP,

which makes it difficult to estimate a historical consultation rate. The Service’s

consultation record (2000-2003) appears to indicate, however, that at least one informal

and one formal consultation were completed in 2000 for proposed developments within

a project-specific HCP boundary. 

3186

Assuming this rate of one formal and one informal consultation every three years, this

analysis estimates approximately eight formal and eight informal section 7

consultations would be required through 2025 for future projects in existing HCP

reserves. In addition, based on a review of Service records, this analysis assumes that

3191 28 existing HCPs would require internal, reinitiated section 7 consultations. This

analysis assumes each of these would be informal consultations, and all costs would be

borne entirely by the Service. Estimated administrative costs of the 8 formal and 36

informal section 7 consultations are $142,000, as shown at the bottom of Table 2, in the

“Proposed for Exclusion” column.

3196

FUTURE HABITAT CONSERVATION PLANS

Any future HCP that addresses the gnatcatcher or includes lands designated as CH will

result in an internal section 7 consultation between the Service’s Habitat Conservation

Branch and its section 7 branch. Each consultation is assumed to be approximated by
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129

3201 an informal consultation, and will result in administrative costs that will be borne solely

by the Service.

Based on research conducted during the course of this analysis, at least 16 regional and

project-specific HCPs are planned or proposed that will address the gnatcatcher and

CSS. While it is not certain at this point that every one of these proposed plans will

3206 reach completion and be adopted, this analysis assumes that all 16 are “reasonably

foreseeable” within the scope of this analysis. One informal section 7 consultation is

assumed to be required for each of the following planned HCPs:

3211 C Chula Vista subarea plan to MSCP

C Otay Water District subarea plan to MSCP

C East County subarea plan to MSCP

C North County subarea plan to MSCP

C Joint Water Agencies Subregional Plan

3216 C San Diego County MHCOSP

C Western Riverside County MSHCP

C Palos Verdes HCP/NCCP

C San Bernardino Valley MSHCP (planned)

C Bonelli Water Park HCP, San Dimas (planned)

3221 C Newport Benning Ranch HCP, Coastal Orange

C Southern California Edison HCP

C Southern Orange County NCCP

C SD Water Districts HCP(s)

C SD County Water Authority

3226 The estimated administrative cost of informal section 7 consultations for these 16

assumed future HCPs is approximately $37,000, as shown in Appendix F and Table 3. 

REINITIATION OF SECTION 7 CONSULTATIONS

No information was available regarding the number of future consultations that may

require reinitiation as a result of the proposed CHD.
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75Personal communication, Ted Griswald, February 24, 2003.

76Personal communication, Robert Smith, Pala Tribal Chairman, and Lenore Volturno, Pala Tribal

Environmental Protection Agency, March 10, 2003.

130

3231 TRIBAL LANDS

The Pala Band of Mission Indians is a federally recognized sovereign Nation, which

owns and occupies a 13,000-acre reservation in northern San Diego County. All Tribal

lands on the Pala reservation that contain essential gnatcatcher habitat have been

3236 proposed for exclusion under section 4(b)(2). This analysis evaluates the economic

impacts if the essential habitat within the Pala reservation were proposed for CHD. 

According to the Pala tribe’s attorney, virtually all decisions made by the Pala Tribal

Government can require section 7 consultation, either because the decision involves the

use of Federal funds (e.g., United States Department of Housing and Urban

3241 Development housing grants) or because the decision requires approval by the Bureau

of Indian Affairs (e.g., project approval by the Pala Environmental Protection Agency).75

Pala tribal representatives anticipate that approximately 60 housing projects (one

private residence per project) and five community development projects (gymnasium,

3246 medical clinic, recycling facility, etc.) will require section 7 consultation for the

gnatcatcher through 2025.76 This analysis assumes that each housing project will

require informal consultation, and the community facility projects will require formal

consultation. Based on input from tribal representatives, this analysis assumes that

each housing project will disturb one acre of land and that each community project will

3251 disturb five acres. GIS-based calculations indicate that approximately 26 percent of the

reservation is within proposed CH, resulting in an estimate of approximately 22 acres of

CSS disturbed. 

Assuming the housing projects are evenly distributed through 2025, and one

3256 community project is constructed every five years, starting in Year 1, the estimated total

section 7 project modification cost is $433,000, and the estimated administrative cost of

the 60 informal and 5 formal consultations is approximately $256,000. These costs are

included in the Unit 5 cost summary shown in Table 2 for areas proposed for

exclusion. 
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3261 V. OTHER ECONOMIC EFFECTS

This chapter evaluates the other economic effects of CHD on private land development

activities. It focuses on the designations potential to result in project delays, increase

costs due to regulatory uncertainty, and/or trigger other regulatory requirements such

3266 as CEQA.

TIME DELAY

CH designation of the gnatcatcher adds an additional layer of regulatory requirement

to private land development projects. This requirement may include the conduct of

section 7 technical assistance, informal, and/or formal consultation for projects with a

3271 Federal nexus. The need to conduct section 7 consultations in and of themselves does

not automatically delay private development projects as these consultations can

generally be coordinated with existing baseline regulatory processes and do not

necessarily increase the time to obtain approvals. CHD could, however, cause time

delays to some private land development projects through requirements not to conduct

3276 certain land development activities (e.g., grading and clearing) during specific periods

of the year. 

Section 7 and CHD for the gnatcatcher will require projects not to conduct habitatdisturbing land development activities during the breeding season of the gnatcatcher, a

3281 six and one-half month period from February 15 to August 31. Depending on the

timing of the final designation of critical habitat, this requirement may delay some

projects that would have begun construction during this period. Projects that might

have begun shortly before the start of the breeding season might also be delayed to

avoid the costly process of starting, stopping, and re-starting construction activities. 

3286 Private development projects further down the path of development are not expected to

be affected. It is assumed that most private development projects can time their habitatdisturbing land development activities to avoid the six month non-breeding period.

The following assumptions were made to estimate the economic cost of time delay

3291 associated with the CHD breeding season requirements:
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C Projects expected to begin more than 12 months after CHD are not expected to

face any additional delay due to section 7, as land development activities can be

planned around the gnatcatcher breeding season. 

3296 C Section 7 will delay all private land development projects slated to begin

development in the 12 months following designation.

C The average delay to projects slated to occur in the next 12 months is 6 months.

3301 C Private land development will occur at a constant rate over the next 23 years.

C The land value loss associated with this delay can be estimated by applying the

appropriate discount rate – a measure of the time value of money. As discussed

in Chapter 3, the private land developer annual discount rate is about 12

3306 percent, though an alternative annual three percent social discount rate is also

considered. These discount rates are halved to calculate the time loss associated

with a six-month delay.

Table 19 summarizes the results of the economic cost of time delay by unit, with a more

3311 detailed summary provide in Appendix I. As shown, about 12,700 acres of private land

development with a Federal nexus is expected to occur in CH over the next 23 years

(projected land development affected by section 7 minus required on-site set-aside). Of

this, one-twenty third (1/23), or 554 acres, are expected to be developed in the first 12

months after designation and are expected to be delayed by an average of 6 months.

3316 Assuming a 12 percent discount rate, this time delay results in a total land value loss of

approximately $5.7 million. 
Table 19

Cost of Section 7 Time Delays

Unit Developable Acres Acres Land Value of Value Impact

with nexus in CH Delayed Delayed Acres of Delay

through 2025 (2) (3) (4)

(1)

Unit 1 68 3 $1,055,700 $63,300

Unit 2 55 2 $925,500 $55,500

Unit 3 203 9 $3,135,600 $188,100

Unit 4 0 0 $2,600 $200

Unit 5 276 12 $4,626,600 $277,600

Unit 6 151 7 $2,886,200 $173,200

Unit 7 35 2 $327,500 $19,600

Unit 8 0 0 $0 $0

Unit 9 469 20 $4,236,600 $254,200

Unit 10 6,631 288 $36,883,300 $2,213,000

Unit 11 772 34 $3,882,900 $233,000

Unit 12 94 4 $733,500 $44,000

Unit 13 3,993 174 $35,940,000 $2,156,400

Totals 12,747 554 $94,636,000 $5,678,200

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) See Table 10. Equals 'Projected Growth Acres Affected by Section 7' minus 'On-site Set-aside' requirements.

(2) First year of land development after CHD is conservatively assumed to be delayed by six months due to lack of time to plan 

to avoid breeding season. Acres delay represents developed acres divided by 23, the number of years of the projection.

(3) Represents value of raw, entitled land ready for development. Based on 'Residual Value of Vacant Gross Acre' estimated in Table D-1.

(4) Based on 6 percent discount rate, as delay lasts six months (i.e., one-half of 12% annual discount rate).

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3321 UNCERTAINTY/STIGMA

UNCERTAINTY

Developers face uncertainty over the required project modifications due to CHD. The

outcome of section 7 consultations are by their nature uncertain. The Service conducts

each consultation on a case-by-case basis and issues BOs and recommends project

3326 modifications based on species-specific and site-specific considerations. While some

differences in recommended project modifications are clearly linked to habitat quality

and other determinable factors, an element of uncertainty remains. The costs estimated

in Chapter III considered the economic costs associated with the average expected

project modifications. While these represent the average economic costs, costs for

3331 individual landowners/ developers will fluctuate above and below this level. 

The economic effects of this uncertainty depend on the degree to which developers are

risk-averse. If developers are only mildly risk averse, they will discount the value of

potential land purchases at close to the average project modification cost. If, however,

3336 they are significantly risk averse, the element of uncertainty introduced by CHD will

result in a further discounting of the land value. The quantity of discount will never,

however, exceed the level of discount associated with a likely upper-end estimate of the

project modification cost. On average, the level of discount is likely to fall between the

discount associated with the average project modification cost and the likely upper-end

3341 project modification cost. This analysis estimates a likely upper-end project

modification scenario and assumes the average economic cost associated with

uncertainty will be the mid-point between the upper-end and average project

modification cost. 

3346 A review of the relevant past BOs provided by the Service and summarized in

Appendix C implies that a reasonable upper-end scenario involves mitigation ratios 25

percent above the average (see Table 20). This estimate was derived based on Counties

where more than one BO was available with outliers removed. The outliers do not

reflect uncertainty, but rather reflect differences in habitat quality or the inclusion of 

3351
Table 20

Upper-End Mitigation Ratios

County Avg. High Percent 

Difference

San Diego 2.06 2.35 114%

Riverside 1.93 2.46 127%

Orange 3.82 4.64 121%

(1) From Table 11.

Highest ratio for each region from BOs summarized in Table C-1. Outliers, such as the 4.55:1 on-site ratio for

Riverside County were excluded. Such outliers are likely connected to specific, identifiable differences in

habitat quality or include mitigation for other species. As a result, the average and high ratios are adjusted.

Sources: USFWS, Carlsbad Office; Economic & Planning Systems, Inc.

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77 A 25 percent increase in the mitigation cost ratio does not increase land set-aside by 25 percent. 

As a result, the costs increase by less than 25 percent.

136

other mitigation requirements beyond those associated with CSS and the gnatcatcher. 

As shown, increases above the average mitigation ratio were 14, 21, and 27 percent,

3356 respectively, for San Diego, Orange, and Riverside counties.

The 25 percent increment was applied to the average mitigation ratios estimated in

Chapter III (see Table 11). On-site, off-site and restoration mitigation requirements

were all increased by 25 percent. The overall average mitigation ratio for all counties

3361 increased from 2.39 to 2.99. As a result, the overall land value loss increases by about 15

percent, from approximately $743 million to $851 million (see Table 13 and Table 21,

respectively).77 Costs associated with on-site set-asides, off-site preservation, and

restoration costs all increase, though on-site set asides represent the majority of the

project modification cost. Administrative costs do not change based on the uncertainty

3366 calculations.

The additional economic cost associated with uncertainty (i.e., cost above and beyond

that associated with the average project modification scenario) lies somewhere between

a zero and 15 percent increase. Taking a mid-point, an estimate of the uncertainty effect

3371 of CHD on directly affected private landowners is that it increases costs by

approximately 7.5 percent above the estimated average project modification costs. As a

result, the increased land value loss is estimated at approximately $54 million, as shown

in Table 1.

3376 STIGMA

The uncertainty costs estimated above do not include stigma-related effects. Stigma

effects are a form of uncertainty that relate less to actual fluctuations in project

modifications and more to perceived fluctuations when there is limited information on

actual outcomes. Stigma effects last for a limited time period as increasing levels of

3381 information erode the perceived fluctuations, replacing them with a more accurate

assessment of the actual uncertainty. They also tend to last only as long as the “fastest

learners” remain unclear about the actual uncertainty associated with CHD. In a

situation where some market actors are clear about the effects and are able to 
Table 21

Upper End Mitigation - Section 7 Project Modification Costs for Private Land Development (1)

Critical Other Project Total

Habitat On-Site Off-Site CSS Modification

Unit Set-Aside Preservation Restoration Costs (3)

Unit 1 $3,138,700 $0 $0 $919,400 $4,058,100

Unit 2 $2,751,400 $0 $0 $994,100 $3,745,600

Unit 3 $9,322,400 $0 $0 $3,696,000 $13,018,300

Unit 4 $7,800 $0 $0 $3,100 $10,900

Unit 5 $13,754,900 $0 $0 $3,748,100 $17,503,000

Unit 6 $46,177,300 $0 $0 $2,680,500 $48,857,800

Unit 7 $5,239,700 $0 $0 $64,000 $5,303,700

Unit 8 $0 $0 $0 $43,800 $43,800

Unit 9 $38,238,000 $2,759,600 $3,093,100 $818,100 $44,908,800

Unit 10 $367,849,000 $47,272,700 $447,100 $12,367,400 $427,936,200

Unit 11 $85,543,200 $0 $3,288,300 $2,458,300 $91,289,800

Unit 12 $2,893,000 $0 $1,020,200 $116,200 $4,029,400

Unit 13 $141,742,700 $0 $43,412,900 $4,945,500 $190,101,100

Total, All Units: $716,658,100 $50,032,300 $51,261,600 $32,854,500 $850,806,500

All dollar values have been rounded to the nearest hundred; summed totals may not add exactly.

(1) Assumes discount rate of 12.0%.

(2) Results of land development model described in Chapter III, using 'High' mitigation ratios summarized in Table 20.

(3) 'Other Project Modification Costs' are assumed not to change based on uncertainty factors, and are the same as reported in Table 13.

Estimated Mitigation Costs (2)

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appropriately discount the land values, while others incorporate a stigma and discount

the land further, arbitrage is likely to occur. The “fastest learners” will buy the land

from others, gradually increasing the land price until it reaches the value of land

3391 associated with actual uncertainty discounting only. 

The previous designation of critical habitat for the gnatcatcher brings with it a history of

knowledge concerning the types of project modifications required. As a result, the

knowledge of the actual level of uncertainty is greater than in many other CHD cases. 

3396 Furthermore, as noted above, the stigma effect primarily results in a land value

distribution to the “fastest-learners” from others, all on the same site. The only actual

stigma costs are the transaction costs associated with arbitrage (e.g., buying and selling

of land, to the extent it occurs) and the investment made in understanding the project

modification requirements. As a result, stigma impacts from the gnatcatcher CHD are

3401 expected to be short-lived and relatively minor and are not quantified as part of this

analysis.

CEQA-RELATED INDIRECT COSTS

As described in Chapter II, CEQA is a California state statute that requires state and

local agencies (known here as “lead agencies”) to identify the significant environmental

3406 impacts of their actions and to avoid or mitigate those impacts, if feasible. It is possible

that CH could provide new information regarding the location of sensitive habitat areas

to lead agencies (typically a county/city community development or planning

department in the case of land development projects), which could result in additional

costs to the project applicant. Because neither CEQA nor the Endangered Species Act

3411 specifically requires lead agencies to address Federally-designated CH, these potential

effects are considered indirect effects, and potentially include one or more of the

following:

1. The lead agency may be more likely to require mitigation for habitat loss as part

3416 of the CEQA process.
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3421 2. Projects that would have submitted either a mitigated negative declaration or a

negative declaration under CEQA prior to CHD must now complete an EIR

because of assumed unavoidable impacts to an environmental resource of

critical concern.

3426 3. The project applicant may incur additional costs in considering/addressing

designated CH in the context of preparing required CEQA documentation

(negative declaration, EIR, etc.)

CEQA statutes specifically require lead agencies to consider a project’s effect on rare or

3431 endangered plant and animal communities. However, in the case of the gnatcatcher, it

is unlikely that CHD will alert many lead agencies to the presence of CSS that they did

not already recognize. The assumption that lead agencies are currently aware of the

presence and significance of CSS is based on the following regulations and

observations, all of which predate the proposed CHD:

3436

• The State legislature officially recognized CSS as a sensitive habitat type in the

1991 NCCP Act.

• The DFG has also officially recognized CSS as a “threatened” habitat type,

3441 assigning it an S1.2 ranking on the “Sensitivity of Top Priority Rare Natural

Comminutes in Southern California” list, and unofficially encourages lead

agencies to require 2-to-1 mitigation, as discussed in Chapter II. Again, the S1.2

ranking for CSS predates the gnatcatcher listing.

3446 • Two approved regional NCCPs and a number of regional NCCPs currently

under development reflect an effort by many local/regional planning agencies to

address the effects of land development on CSS habitat.

• Despite the CHD for the gnatcatcher in 2000 and the requirements under CEQA,

3451 which included units in Riverside and San Bernardino counties, local lead

agencies in these counties do not currently require CSS mitigation under CEQA,

as discussed in Chapter II.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

78 Personal communication with senior staff from RBF Consulting (San Jose, CA), EDAW

(Sacramento, CA) and HT Harvey & Associates (Watsonville, CA), February 24-28, 2003.

140

Given the historically widespread, well-publicized nature of CSS as a sensitive habitat

3456 type, as well as the previous designation, it appears that lead agencies are unlikely to

require additional CSS mitigation or change CEQA reporting protocol due to the CHD. 

Both DFG and Service staff confirmed this conclusion and were not aware of any

specific examples in which CEQA reporting or mitigation requirements were expanded

due to CH. 

3461

This analysis also concludes that CHD will not result in additional costs during the

preparation of CEQA documentation. A series of consultants who specialize in EIRs

were asked whether the presence of CH on a project site added to the cost of preparing

the EIR and seeing it through public hearings as part of the project's entitlement

3466 process. The consensus view in the consultant community is that CHD adds no

measurable CEQA-related cost for the project applicant.78 Two primary reasons for this

are described below.

First, where listed species are present on the project site, the EIR's biological component

3471 will be required to discuss and evaluate habitat impacts. This requirement is

unchanged after federal CHD. Second, where species are not present on the project site,

CEQA directs the EIR to inventory the important natural resources on the project site

and characterize project impacts to important habitat types. CEQA makes no reference

to critical habitat, and methods used by EIR biologists are unlikely to change if CH is

3476 designated. In fact, according to State officials, State agency oversight of the quality and

completeness of a project EIR concentrates wholly on the biological values of habitat in

proximity to the project and on potential project impacts to that habitat, and not on the

property’s status as federally designated CH.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

79 5 U.S.C. 601 et. seq.

80 Thus, for a regulatory flexibility analysis to be required, impacts must exceed a threshold for

“significant impact” and a threshold for a “substantial number of small entities.” See 5 U.S.C. 605

(b).

141

VI. SMALL BUSINESS REGULATORY ENFORCEMENT ACT

3481

POTENTIAL IMPACTS ON SMALL BUSINESS

Under the Regulatory Flexibility Act (as amended by the Small Business Regulatory

Enforcement Fairness Act (SBREFA) of 1996), whenever a Federal agency is required to

3486 publish a notice of rulemaking for any proposed or final rule, it must prepare and make

available for public comments a regulatory flexibility analysis that describes the effect

of the rule on small entities (i.e., small businesses, small organizations, and small

government jurisdictions).79 However, no regulatory flexibility analysis is required if

the head of an agency certifies that the rule will not have a significant economic impact

on a substantial number of small entities.80 3491 SBREFA amended the Regulatory Flexibility

Act to require Federal agencies to provide a statement of the factual basis for certifying

that a rule will not have significant economic impact on a substantial number of small

entities. Accordingly, the following represents a screening level analysis of the

potential effects of CHD on small entities to assist the Secretary in making this

3496 certification.

This analysis estimates the number of small entities potentially affected by the CHD for

the gnatcatcher in counties supporting CH areas. It also estimates the level of effect the

designation will have on small entities. For both estimates, this analysis conservatively

3501 examines the total estimated section 7 costs calculated in earlier sections of this report.

Federal courts and Congress have indicated that a Regulatory Flexibility Act/SBREFA

analysis should be limited to direct and indirect impacts on entities subject to the

requirements of the regulation. As such, entities indirectly impacted by the gnatcatcher

3506 listing and CHD, and, therefore, not directly regulated by the listing or CHD, are not

considered in this screening analysis.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

142

This analysis begins by identifying all formal and informal consultation activities

generated by the proposed rule that may involve small entities (business or

3511 governments). The analysis then estimates the number of small entities that are

potentially affected. Finally, the level of impact on those entities is examined. As

specified in the proposed rule, certain “essential” conservation lands have been

proposed for exclusion from CHD. In order to evaluate the economic and other

relevant impacts of excluding these areas from CH, this analysis performs the

3516 calculations described above for both areas. The “Proposed” column in Tables 22

through 24 represents an estimate of the effect(s) on small businesses if CH is

designated only for those areas currently proposed; the “Prop. & Excluded” column

represents an estimate of the effect(s) if CH is designated for all areas, including those

currently proposed for exclusion. 

3521

IDENTIFICATION OF ACTIVITIES THAT MAY INVOLVE SMALL ENTITIES

Chapters III and IV of this report identify land use activities that are within the

proposed CHD for the gnatcatcher and potentially impacted by section 7

3526 implementation (i.e., requiring consultations or project modifications) under the “with

section 7” scenario. 

Of the projects that are potentially affected by section 7 implementation for the

gnatcatcher, some do not have third party involvement (i.e., only the action agency and

3531 the Service are expected to be involved). Thus, small entities should not be affected by

section 7 implementation for affected projects with the following agencies:

C Forest Service (prescribed burns)

C Bureau of Land Management (fire break projects)

3536 C FEMA (construction, prescribed burn, and flood prevention)

C Marine Corps (various base operations and maintenance activities)

C Navy (construction and maintenance of base infrastructure)
Table 22

Estimated Annual Number of Small Businesses Affected by Critical Habitat Designation

2,953 2,953

3,313 3,313

89% 89%

34 51

1.1% 1.7%

Sources: Dun and Bradstreet; Economic & Planning Systems, Inc.

Land Development SIC 6552

Proposed Prop. & Excluded

Annual percentage of small businesses affected (number of 

small businesses affected) / (total number of small businesses)

Number of small businesses in industry within study area

38

Total number of all businesses in industry

Percent of businesses that are small (number of small 

businesses) / (total number of businesses)

Industry Name

Annual number of small businesses affected (number of affected 

businesses ) * (percent of small businesses)

58

Annual number of affected businesses in the industry (equal to 

the number of annual consultations)

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Table 23

Estimated Annual Number of Small Governments Affected by Critical Habitat Designation

24 28

76 80

32% 35%

1.5 2.5

6% 9%

Sources: 2001 California County Profiles , California Department of Finance; Economic & Planning Systems, Inc.

Proposed Prop. & Excluded

Small Governments

5 7

Industry Name

Annual number of affected governments (equal to the annual number 

consultations)

Annual number of small governments affected (Number of affected 

governments) * (Percent of small governments)

Annual percentage of small governments affected (Number of small 

governments affected) / (Total number of small governments)

Total number of all governments

Percent of governments that are small (Number of small governments) / 

(Total number of governments)

Number of small governments in industry within study area

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Table 24

Estimated Annual Effects on Small Businesses in Land Development and Real Estate Industry 

Land 

Development 

SIC 6552

"Small 

Businesses" 

SIC 6552

Land 

Development 

SIC 6552

"Small 

Businesses" 

SIC 6552

300 27 300 27

$10.26 $10.26 $10.26 $10.26

2 2 2 2

$67,016,615 $6,000,000 $67,016,615 $6,000,000

$988,028 $88,458 $678,156 $60,715

1.5% 1.5% 1.0% 1.0%

Proposed & Excluded

Per-business Annual Gross Revenue [(project size x 43560sf 

x land value/sf)/project duration]

Per-business Cost

Per-business Effect (per-business cost/annual gross revenue)

Proposed

(1) This is calculated by taking the average of improved residential, office, industrial and retail land values for the six counties 

presented in Table D-1, D-2 and D3. Without the specific knowledge of where and what type of land-use development a small 

business will undertake, it is deemed appropriate to take gross average of improved land value for all land-use types. Although land 

values may differ significantly across the six counties, because they are proportional to both the gross revenue and the section 7 

related costs, the average land value does not take geographic differences into account.

(2) Assuming that the required land-use zoning exists, land development projects take one to two years to complete (this process 

involves obtaining necessary permits, entitlements, etc.) To be conservative, this analysis assumes that each of the future private 

development projects will take about 2 years to complete. 

Industry Name

Project Size (acres)

Improved Land Value/SF (1)

Project Duration (2)

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Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

146

In addition, major infrastructure and utility projects are potentially affected by section 7

implementation. These projects are expected to involve large public agencies and

corporations such as TCA, MWD, SDCWA, SDG&E, SCGC, and SCE, which exceed the

3551 Small Business Administration’s annual sales threshold for small utility corporations or

population threshold for small governments. Therefore they do not fit the category of

small entities. 

C FHWA (construction and maintenance of state highways)

3556 C USACE (expansion of SR-241 toll road; construction and maintenance of regional

utility infrastructure)

C BOR (construction/replacement of levee, basin, and flood control channels)

C Federal Energy Regulatory Commission (construction of utility infrastructure)

C Bureau of Land Management (construction of utility infrastructure )

3561 C Forest Service (construction of utility infrastructure)

After excluding these two sets of agencies and consultations noted above from the total

universe of impacts identified in the body of the analysis, one action agency and 311

associated consultations remain. This subset represents the action agency and

consultations that may produce significant impacts on small entities. Specifically, these

3566 actions feature activities that do not occur exclusively on Federal lands and may involve

costly project modifications due to section 7 implementation: 

C USACE (private land development)

3571 DESCRIPTION OF AFFECTED ENTITIES

This section describes the industries most likely to be affected by section 7

implementation for the gnatcatcher. More information about the affected projects can

be found in Chapters III and IV of this report.

3576

Land Development and Real Estate (SIC 6552)

The Small Business Administration defines small businesses within the land

development and real estate industry as having less than $6 million in average annual

3581 receipts (also referred to as sales or revenues). Projects permitted by USACE that
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

81 U.S.C § 601.

82 This estimate is based on the past consultation history provided by the U.S. Fish and Wildlife

Service. This analysis assumes that the past consultation rate will remain constant throughout the

next 23-year period. 

147

involve section 7 consultations for gnatcatcher species may affect small businesses

under SIC code 6552. In order to determine whether or not small businesses in the land

development and real estate industry are affected by USACE projects, the $6 million

threshold must be considered in the analysis. 

3586

Significant levels of Federal agency review and permitting are often required for land

development projects by public and private entities. This analysis assumes that the

primary Federal nexus for future private development activities is the issuance of

section 404(b) permits by USACE under the Clean Water Act for impacts to “waters of

3591 the U.S.” If the project is located within proposed CH, the nexus through a 404(b)

permit from the ACOE would trigger a section 7 consultation with the Service.

As discussed in Chapter III, past consultation history provided by the USACE serves as

a basis for estimating the number of future private development projects that would

3596 involve the gnatcatcher. It is estimated that 866 formal consultations will take place

involving businesses in the land development and real estate industry over the next 23-

year period. 

Activities Funded by Small Governments 

3601

The SBREFA defines a “small governmental jurisdiction” as “governments of counties

with a population of less than fifty thousand.”81 This analysis assumes that the counties

and cities in the study area will be involved in approximately 12.5 percent of the future

private development projects.82 County and/or city governments may get involved in

3606 future private developments, and therefore section 7 consultations, through various

permits, local utilities and infrastructures. All small governments for cities and

counties that have a population that is less than 50,000 persons within the total study

area constitute the universe of small governments in this analysis. It is estimated that

about 108 out of the 866 formal consultations for future private development will

3611 involve cities and counties in the study area over the next 23-year period. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

83 Dun Market Identifiers, File 516: Dun and Bradstreet, February 2003.

148

ESTIMATED NUMBER OF AFFECTED ENTITIES THAT ARE SMALL

To be conservative, (i.e., more likely to overstate impacts than understate them), this

analysis assumes that each of the consultations in a given year is undertaken by a

3616 unique small entity, so the number of businesses/governments affected annually is

equal to the total annual number of consultations (both formal and informal). This

analysis also limits the universe of potentially affected entities to include only those

within the counties in which CH units lie; this interpretation produces a more

conservative analysis than including all entities nationwide. 

3621

Activities of the Army Corps of Engineers and Effects on the Land Development and

Real Estate Industry (SIC 6552)

First, the number of affected small businesses for the land development and real estate

3626 industry is estimated. As shown in Table 22, the following calculations are used to

arrive at this estimate:

C Estimate the annual number of businesses within the study area affected by

section 7 implementation (assumed to be equal to the number of annual

3631 consultations). Thirty-eight formal consultations are estimated annually for USACE

projects that are likely to affect businesses in the land development and real estate

industry (866 total consultations over 23 years). 

C Calculate the percent of businesses in the affected industry that are likely to be

3636 small. This is calculated by dividing the total number of small businesses in the

study area for the SIC code (using the annual sales thresholds from the Small

Business Administration described in the previous section ) by the total number of

businesses in the study area that fall under the same SIC code.83 The analysis shows

that 89 percent of the land development and real estate (SIC 6552) businesses within

3641 the study area are small.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

84 Population count for the study area was obtained from California County Profiles – A Companion

to the 2000 California Statistical Abstract, California Department of Finance, 2002. All cities and

counties within the study area that have a total population less than or equal to 50,000 persons was

considered small (according to Small Business Administration guidelines).

149

C Calculate the number of affected small businesses. This is calculated by

multiplying the percent of small businesses in the affected industry by the total

3646 number of annual consultations. According to this calculation, 34 small businesses

in the land development and real estate industry are expected to be affected

annually.

C Calculate the percent of small businesses likely to be affected by CH. This is done

3651 by dividing the number of affected small businesses by the total number of small

businesses in the study area. This analysis reveals that approximately one percent

of all the small businesses in the study area for the land development and real estate

industry are likely to be affected by gnatcatcher consultation activities.

3656 Activities of the Army Corps of Engineers and Effects on Small Governments

First, the number of affected small governments in the study area is estimated.84 As

shown in Table 23, the following calculations are used to arrive at this estimate:

C Estimate the annual number of governments within the study area affected by

3661 section 7 implementation (assumed to be equal to the annual number of 

consultations). Five formal consultations are estimated annually for USACE

activities that would involve government entities in the study area. 

C Calculate the percent of governments in the study area that are likely to be small. 

3666 This is calculated by dividing the number of small governments by the total number

of governments in the study area. The analysis shows that 32 percent of the

governments within the study area are small.

C Calculate the number of affected small governments in the study area. This is

3671 calculated by multiplying the percent of small governments by the total number of

annual consultations. This analysis shows that less than 1.5 unique small

government(s) in the study area are affected annually. 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

150

C Calculate the percent of small governments likely to be affected by CH. This is

3676 done by dividing the number of affected small governments in the study area by

the total number of small governments in the study area. This analysis reveals that

six percent of the small governments in the study area are likely to be affected by

gnatcatcher consultation activities. 

3681 ESTIMATED EFFECTS ON SMALL ENTITIES

Activities of USACE and Effects on the Land Development and Real Estate

Industry (SIC 6552)

3686 As concluded in the previous section, less than one percent of small businesses (12

businesses) in the land development and real estate industry in the study area is

expected to be affected by section 7 consultation activities. Costs of CHD to small

businesses consist of the administrative cost of participating in section 7 consultations

and the cost of project modifications. To be conservative, this analysis assumes that the

3691 small businesses undertaking future development projects own the land that is to be

developed. In other words, a developer will bear all the costs involved in a consultation

including on-site mitigation cost in the form of a reduced land value. In reality,

however, a developer may purchase raw land from an individual landowner at a

reduced price due to the costs (actual or perceived) associated with the designation. In

3696 this case, potential mitigation costs would likely be reflected in the selling price of the

land, and therefore be incurred by the landowner. 

In order to estimate the level of effect the designation may have on the 12 affected small

businesses in the land development and real estate industry, this analysis calculates a

3701 per-business annual gross revenue of the affected small businesses in the industry and

compares the cost to per-business cost of engaging in section 7 consultation. Steps

taken to arrive at the estimate are described below and summarized in Table 24:

• Calculate the per-business revenue. As discussed in Chapter III, each of the

3706 future private land development projects in the study area is assumed to be 300

acres in size. This analysis makes the conservative assumption that an affected

small business undertakes only one development project at a given time. As such,
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

85 As shown in Table 1, the majority of section 7-related costs for private land development

projects come from project modifications involve setting aside on-site and purchasing off-site

mitigation land, and these mitigation measures are directly correlated to project size. 

151

gross annual revenue of an affected small business is calculated by dividing the total

revenue generated by selling a 300-acre parcel of developed land by the number of

3711 years taken to complete the project (see Table 24 for the illustration and details of

the calculation). This calculation yields an average annual per-business gross

revenue of approximately $67 million for the entire land development and real

estate industry. Despite the conservative assumption made, this annual gross

revenue is $61 million higher than the small business threshold of $6 million for the

3716 industry. This illustrates the reality that a small business is not likely to undertake a

project of such magnitude. As shown in Table 24 (“Proposed,” column 2), this

analysis assumes that project size is proportional to annual gross revenue, and that

small businesses with revenues of $6 million will be associated with projects around

27 acres in size. 

3721

C Calculate the per-business cost. This consists of third-party administrative and

project modification costs of participating in a section 7 consultation. The average

per-business cost for the entire land development and real estate industry is

calculated by dividing the total consultation and project modification costs for

3726 future private development projects (Table 3) by the total number of consultations. 

As shown in Table 24 (“Proposed,” column 1), this calculation yields a per-business

cost of approximately $990,000. Although project modification costs will vary across

regions due to differences in land values, average project modification cost is used

to derive the per-business cost because this section examines impact on small

3731 businesses in the entire study area. As shown in Table 24 (“Proposed,” column 2),

the estimated per-business cost for businesses with annual revenues of $6 million or

less (and therefore defined as “small”) is approximately $88,000, because project size

is also assumed to be proportional to section 7 consultation costs.85 
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

86 The 24 small governments in the study area have a wide range of revenue from $1 million to $75

million. Because the specifics of small governments likely to be affected by future section 7

consultation activities are unknown, the analysis uses the median to represent the per-government

revenue. 

152

3736 C Estimate the level of effect on small businesses. This is calculated by taking the

per-business cost and dividing it by the per-business revenue. As presented in

Table 25 (“Proposed”), this calculation estimates an impact equivalent to 

approximately 1.5 percent (1.5%) of the annual per-business revenue for the affected

small businesses in the industry. 

3741

Activities of the Army Corps of Engineers, and Effects on Small Governments

As concluded in the previous section, approximately six percent of small governments

in the study area are estimated to be affected by section 7 consultation activities. Costs

of CHD to small governments are expected to be limited to the administrative costs of

3746 participating in section 7 consultations, because private developers are likely to bear the

cost of project modifications. The following steps describe the methodology used to

estimate the effect of section 7 consultation activities on directly affected small

governments in the study area (see Table 23):

3751 C Calculate the per-government costs. This consists of the cost to a third party of

participating in a section 7 consultation. The average per-government cost of

participating in section 7 consultations for future development projects is estimated

to be approximately $3,500. This estimate is derived by dividing total consultation

costs for the small governments by the total number of consultations.

3756

C Determine the per-government revenue for the small governments in the study

area. This is derived by listing the revenues of all 24 small governments in the study

area in ascending order and taking the mid-point—i.e., the median. 86

3761 C Estimate the level of effect on small governments. This is calculated by taking the

per-government cost and dividing it by the median revenue to determine the

percent of revenue represented by the per-government cost of a consultation. As

presented in Table 25, small governments are likely to experience impacts equal to

less than one percent of their median revenue. 

3766
Table 25

Estimated Annual Effects on Small Governments

Median revenue of all affected small governments[1] $16,800,428

Per-government cost $3,500

Per-government effect (per-government cost/median revenue) 0.02%

[1] The median is calculated based on 1999 Cities Annual Report, California State Controller, and City of 

Rancho Santa Margarita Financial Transactions Report accessed at http://www.cityofrsm.org/rsm_website 

/citiesfinanrpt.asp, March 2003. These are represented in 2002 dollars.

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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

87Although a reduced impact may be counterintuitive given an increase in the assumed size of the

designation, this result can be explained by the fact that the relative increase in annual affected small

entities (18 vs. 12, or a 50 percent increase) is greater than the relative increase in total private

development project modification costs ($748 million vs. $727 million, or a 3 percent increase). A

greater total cost is therefore allocated among an even greater number of businesses, resulting in a

smaller estimated per-business cost.

154

SUMMARY

3771

Section 7 implementations for the gnatcatcher are likely to affect small businesses in the

land development and real estate industry (SIC 6552) as well as small governments in 

the study area. According to the calculations above, about 34 small businesses in the

land development and real estate industry would be affected annually, which

3776 represents approximately one percent of the total number of small businesses in the

industry for the study area. These affected small businesses are likely to experience

impacts equivalent to about 1.5 percent of their per-business annual gross revenue. For

the small governments in the study area, approximately 1.5 agencies are likely to be

affected annually, which represent about six percent of the total number of small

3781 governments in the study area. Affected small governments are likely to experience

impacts equivalent to less than one percent of the median revenue of small

governments in the study area. 

Finally, as shown in Tables 23 through 25 (“Proposed & Excluded” column), CHD in

3786 areas currently proposed for exclusion would annually impact seventeen (17) additional

small businesses in the land development and real estate industries, or 51 small

businesses affected in total. This analysis estimates that each of these 51 small

businesses would experience an economic effect equal to approximately one percent of

its annual gross revenue. This estimate is approximately two-thirds of the per-business

impact estimated for the small businesses within proposed critical habitat alone.87 3791 For

the small governments, approximately two additional agencies are likely to be affected

annually, or 7 total small governments each year. However, the level of impact on

affected small governments is estimated to remain the same.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

88

Memorandum For Heads of Executive Department Agencies, and Independent Regulatory

Agencies, Guidance For Implementing E.O. 13211, —01-27, Office of Management and Budget,

July 13, 2001, http://www.whitehouse.gov/omb/memoranda/m01-27.html 

89

Id.

155

3796 VII. ENERGY IMPACT ANALYSIS

Pursuant to Executive Order No. 13211, “Actions Concerning Regulations that

Significantly Affect Energy Supply, Distribution, or Use,” issued May 18, 2001, Federal

agencies must prepare and submit a “Statement of Energy Effects” for all “significant

3801 energy actions.” The purpose of this requirement is to ensure that all Federal agencies

“appropriately weigh and consider the effects of the Federal Government’s regulations

on the supply, distribution, and use of energy.”88 The Office of Management and

Budget has provided guidance for implementing this executive order that outlines nine

outcomes that may constitute “a significant adverse effect” when compared without the

3806 regulatory action under consideration: 

• Reductions in crude oil supply in excess of 10,000 barrels per day; 

• Reductions in fuel production in excess of 4,000 barrels per day;

• Reductions in coal production in excess of 5 million tons per year;

3811 • Reductions in natural gas production in excess of 25 million mcf

• Reductions in electricity production in excess of 1 billion kilowatt-hours per year or

in excess of 500 megawatts of installed capacity;

• Increases in energy use required by the regulatory action that exceed the thresholds

above;

3816 • Increases in the cost of energy production in excess of one percent;

• Increases in the cost of energy distribution in excess of one percent; or

• Other similarly adverse outcomes.89

•

Research conducted during the course of this analysis did not reveal any instances in

3821 which the proposed designation was anticipated to affect the construction of any new

power-generating facilities, or the operation of any existing facilities. Furthermore, the

proposed designation is not expected to affect crude oil supply or increases in energy

use. This analysis therefore concludes that the effects of the proposed designation on
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

156

the energy industry will be limited to increases in the cost of delivering energy to end

3826 users due to additional costs incurred through the section 7 consultation process. The

proposed designation is not expected to affect energy production, use, or supply. As a

result, only one screening criterion is relevant to this energy impact analysis – potential

increases in the cost of energy distribution in excess of one percent. Below, we analyze

whether the electricity and natural gas industries are likely to experience “a significant

3831 adverse effect” as a result of section 7 implementation for the gnatcatcher. 

SECTION 7 EFFECT ON ENERGY DISTRIBUTION COSTS

3836 The annualized section 7 costs borne by the energy industry within proposed CH represent 0.14

percent of annual distribution costs, which is well below the one-percent significance threshold

established by the OMB. This analysis therefore concludes that section 7 regulation under the

proposed designation will not result in a “significant adverse effect” to the energy industry. 

3841 This section evaluates whether the estimated section 7 administrative and project

modification costs that will be borne by the energy industry represent greater than one

percent of current energy distribution costs. The estimated administrative and project

modification costs for agencies involved with municipal power supply are summarized

in Table 3; project modification costs are calculated in Appendix G. This section

3846 compares these costs (on an annualized basis) to expenses incurred by the energy 

industry to operate, maintain, and improve its gas and electric distribution systems in

2001 to determine whether the one percent “significance threshold” has been exceeded. 

A summary of data sources and calculations is shown in Table 26. 

3851

As described in Chapter IV, this analysis identifies three regional energy companies

with future projects that will likely require section 7 consultation – SCE, SDG&E, and

SCGC. Regional electricity supply is delivered by SDG&E (San Diego County) and SCE

(remainder of proposed critical habitat area); regional natural gas supply is delivered by

3856 SDG&E (San Diego County) and the SCGC (remainder of proposed critical habitat area).
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90This includes approximately $390 million in capital improvement costs incurred in 2001 to

support the energy distribution system(s). EPS was unable to find any historical information to

estimate average annual capital improvement costs, so these values are assumed to be

representative. The CPUC – the state agency responsible for regulating energy rates – instructed

EPS to use these figures, which represent official submittals by the energy companies to support

their rate increase applications. 

157

As shown in Table 3, this analysis estimates that these three companies will incur

section 7 administrative and project modification costs of approximately $12 million

through 2025. This is equivalent to an annualized cost of approximately $1 million over

23 years, assuming a discount rate of 7 percent. 

3861

To estimate annual distribution costs, EPS obtained General Rate Case applications

submitted by each of the three companies to the California Public Utilities Commission

(CPUC) in 2002. The CPUC is responsible for authorizing utility rate increases, which it

evaluates on the basis of cost/revenue data and projections submitted by each utility

3866 company in its General Rate Case application. According to CPUC staff, the most

recent applications were submitted in 2002, and contain official company statements of

2001 O&M and annual capital improvement expenditures made to support the

gas/electric distribution system(s). As summarized in Table 26, total distribution costs

for these three companies in 2001 were approximately $754 million.90 

3871

Based on the annual distribution costs described above, section 7 regulation following

the proposed designation would have to result in costs to the energy industry greater

than $7.54 million per year for the impact to be considered a “significant adverse

effect.” As described above, the estimated annualized cost of the proposed designation

3876 on the energy industry is approximately $1.5 million – or 14 percent of the significance

threshold based on distribution costs. This analysis therefore concludes that the

proposed designation of critical habitat for the gnatcatcher will not result in a

significant adverse effect on the energy industry. 
Table 26

Energy Impact Analysis Summary

Item/Value Total

SCE SDG&E SCGC SDG&E

Distribution Costs (2001):

O&M Costs (1) 218,821,000 $53,152,000 $82,532,000 $9,964,000 $364,469,000

Annual Capital Improvements (1) N/A $237,557,000 $127,438,000 $24,879,000 $389,874,000

Total Distribution Costs 218,821,000 $290,709,000 $209,970,000 $34,843,000 $754,343,000

Estimated threshold for a "Significant Adverse Effect:" (2) -- -- -- $7,543,430

Estimated Impact of Designation (3) -- -- -- -- $11,588,000

Annualized Impact (4) -- -- -- -- $1,028,017

Annualized Impact as Percent of Distribution Costs 0.14%

Annualized Impact as Percent of Significance Threshold: -- -- -- 14%

(1) From General Rate Case Applications to the California Public Utilities Commission (Application numbers 02-05-004 [SCE], 

02-12-027 [SCGC], and 02-12-028 [SDG&E]) filed in 2002, based on 2001 data. 

These include only those costs related to operating, maintaining, and construction the energy distribution system.

(2) A "significant adverse effect" is defined as a increase in the cost of energy distribution in excess of one percent. 

(3) From Table 3.

(4) Represents the annual amount that is equivalent to the total impact estimate, when distributed over a 23-year period assuming a 7% discount rate.

and assuming a 7% discount rate. 

SCE -- Southern California Edison

SDG&E -- San Diego Gas & Electric

SCGC -- Southern California Gas Company

Electricity Natural Gas

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91 2 USC 1532.

92 UMRA includes several other requirements that may pertain to this rulemaking. Section 203

requires the Service to develop a Small Government Agency Plan for any rule that may significantly

or uniquely affect small governments, regardless of whether the rule exceeds the $100 million

thresholds (i.e., thresholds for governments or the public sector) (2 USC 1533). In addition, section

204 requires the Service to develop an effective process that allows for meaningful and timely input

during regulatory development by State, local, and tribal governments (2 USC 1534). The Service’s

compliance with these requirements is addressed separately from this analysis.

93

 2 USC 1532.

159

VIII. UNFUNDED MANDATES ANALYSIS

Title II of the UMRA of 1995 requires Federal agencies to assess the effects of their

3886 regulatory actions on State, local, and tribal governments and the private sector. Under

section 202 of the UMRA, the Service must prepare a written statement, including a

cost-benefit analysis, for significant regulatory actions that include a Federal mandate

resulting in the expenditure by State, local, and tribal governments, in the aggregate, or

by the private sector, of $100 million or more in any one year.91 Federal rules are

3891 exempt from the UMRA requirements if: (1) the rule implements requirements

specifically set forth in law; or (2) compliance with the rule is voluntary for State and

local governmental entities. Although CHD is required by the Act, the Secretary has

discretion in designating specific geographic areas. Therefore, these two criteria are not

met.

3896

If a written statement is needed, section 205 of UMRA requires the Service to identify

and consider a reasonable number of regulatory alternatives.92 The Service must adopt

the least costly, most cost-effective or least burdensome alternative that achieves the

objectives of the rule, unless the Secretary publishes an explanation why that alternative

3901 was not adopted. These requirements apply to both proposed and final rules.

This analysis first determines whether a written statement is required, based on the

criteria set forth by UMRA. If such a statement is needed, section 202 of UMRA

provides specific direction regarding the contents of the cost-benefit analysis that must

accompany such a statement.93 3906 This analysis describes and discusses each of the types

of costs that must be addressed.
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94

Although the analysis categorized regional utility projects as “public” projects due to the publicnature of utility infrastructure provision (as opposed to private real estate development), the

majority of large utility companies addressed in this report (e.g., MWD, SDG&E, SCE, and SCGC)

are privately held companies. Section 7 costs are therefore appropriately attributable to the

private sector. 95

Had it been possible to determine the year in which consultations and associated project

modifications would take place, the annualized expenditure method would not be necessary. The

actual costs are likely to vary unevenly from year to year, as fiscal and market conditions change,

with some years receiving a greater share of the costs than others.

160

Significant Regulatory Action Under UMRA

3911 As shown in Table 27, the total estimated section 7 cost for State, local, and tribal

governments is approximately $89 million. This estimate includes section 7 project

modification and administrative costs for all public projects, except regional utility

projects (e.g., water, power, etc.).94 The total estimated section 7 cost for the private

sector is approximately $826 million, which includes project modification,

3916 administrative, delay, and uncertainty costs for all private development projects, as well

as project modification and administrative costs for regional utility projects. 

Annualized costs are estimated to be approximately $7.9 million for State, local, and

tribal governments, and approximately $112 million for the private sector in the first

3921 year following CHD. In general, this analysis relies on annualized expenditures instead

of a multi-year series of costs because most costs estimated in this document are

uncertain with regard to timing; one exception, however, are delay costs, which are

expected to occur entirely in Year 1.95 In order to estimate the maximum single-year

annualized private sector expenditures, this analysis used cost estimates for Year 1,

3926 which include annualized costs for cost categories other than delay ($106.4 million),

plus the full delay cost estimate ($5.7 million).

Based on the criteria set forth by UMRA, CHD for the gnatcatcher may result in

expenditures by the private sector of more than $100 million annually. Therefore, a

3931 written statement is required.
Table 27

Unfundated Mandates Reform Act (UMRA) Calculation Summary

Measure Non-Federal Private 

Governments (1) Sector (2)

Total Cost $88,796,900 $826,540,600

Requirement for Written UMRA Statement (3)

Annualized Cost (4) $7,877,500 $112,029,100

Percent of $100M Threshold 8% 112%

Effect on State/National Economy (5)

Percent of National GDP (6) 0.001% 0.008%

Percent of California GSP (7) 0.01% 0.06%

Percent of GSP, State & Local Gov't (8) 0.08% --

Percent of GSP, Private Industries (9) -- 0.07%

(1) Includes project modification and administrative costs for all public projects, except regional utility 

 (e.g., water, power) projects.

(2) Includes project modification, administrative, delay, and uncertainty costs for all private development 

 projects, plus project modification and administrative costs for regional infrastructure projects.

(3) UMRA guidelines require that a written statement be prepared if aggregate expenditures by State, local, 

 or tribal governments, or expenditures by the private sector, in any one year exceed $100 million.

(4) Assumes a discount rate of 7 percent for non-Federal governments and 12 percent for the private sector.

 For the private sector, the 'Max. Year Annualized Cost' was calculated by (a) calculating the annualized cost of all 

 private sector costs minus delay costs, and (b) adding the full delay cost to the annualized subtotal in (a). This 

 calculation reflects an estimate of annualized costs in Year 1, which is expected to be the most expensive year for 

 the private sector because all delay costs are experienced in this year. 

(5) Evaluates the estimated Total Costs of the proposed rule relative to leading State and National 

 economic indicators.

(6) The FY 2002 National GDP was $10,446.2 billion, as reported by the U.S. Bureau of Economic Analysis (BEA).

(7) The FY 2000 California Gross State Product (GSP) was $1,344.623 billion, as reported by the BEA.

(8) The FY 2000 GSP for State and local governments was $109.023 billion, as reported by the BEA.

(9) The FY 2000 GSP for private industries was $1,203.513 billion, as reported by the BEA.

Sources: Economic & Planning Systems; Bureau of Economic Analysis

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162

Written Statement Requirements

3936

Section 202 of UMRA provides a list of the items that must be included in the written

statement accompanying the rule. The components of the written statement must:

I. Identify the authorizing legislation;

3941 II. Provide a qualitative and quantitative analysis of costs and benefits,

including the impacts on State, local, and tribal governments and on the

private sector, and the impacts on health, safety, and the environment;

III. Estimate, to the extent possible, future compliance costs and

disproportionate budgetary effects on particular geographic regions or types

3946 of entities;

IV. Discuss effects on the national economy (e.g., effects on productivity,

economic growth, full employment, creation of productive jobs, and

international competitiveness); and,

V. Describe the Service’s consultations with elected officials.

3951 This purpose of the remainder of this section is to provide the Service with the

economic information required to complete a written statement under UMRA. This

section is not meant to be the actual statement, nor does it provide information on

all of the issues (e.g., information about the Service’s consideration of comments

provided by State, local, or tribal governments) that must be addressed by the

3956 Service.

1. Authorizing Legislation. Section 4(a)(3)(A) of the Act requires the Secretary, to

the extent prudent and determinable, to designate critical habitat at the time the

species is listed. Section 4(b)(2) requires CHDs to be made on the basis of the best 

3961
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

96 16 USC 1533.

97 2 USC 1532.

98 Sally Katz, Administrator, Office of Information and Regulatory Affairs, Office of Management and

Budget, Memorandum: Guidance for Implementing Title II of S.1., March 31, 1995.

163

scientific evidence available, taking into consideration the economic impact of the

designation and any other relevant impacts.

96

3966

2. Costs and Benefits. The costs associated with the proposed designation of

critical habitat for the gnatcatcher are described in the executive summary, as well

as Chapters III through V. Chapter III and Chapter V focus on the effects on

private landowners, the group that is likely to experience the majority of the impact

3971 from this designation. Chapter IV provides detailed information about impacts to

public sector entities. The benefits of the designation are addressed qualitatively, in

Chapter VIII. Impacts to health, safety, and the environment are beyond the scope

of this analysis and will be addressed by the Service.

3976 UMRA also requires an analysis of the extent to w hich th e costs to State, local, and

tribal governments may be paid with Federal assistan ce.97 [placeholder - FWS to

provide information about financial assistance options for governments] 

3. Compliance costs and disproportionate budgetary effects. The magnitude and

3981 likelihood of compliance costs resulting from the designation are d iscussed

extensively in Chapters III and IV. These costs are presented by region and by

agency in th e Executive Summary. In addition, Chapter VI examines the

distributional impacts to small entities, and Chapter VII considers the effects of the

designation on th e energy industry. 

3986

4. Effect on the national economy. UMRA directs the Service to consid er th e effect

of the proposed gnatcatcher d esignation on the national economy (i.e., the

macroeconomic effects of the rule). According to OMB, economic imp acts of less

than 0.25 to 0.5 percen t of the Gross Domestic Prod uct (GDP) are unlikely to result

3991 in measurable effects to the national economy, unless the effects are focused on a

particular geographic region or economic sector.98 As shown in Table 27, the total
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

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164

estimated section 7 costs for State, local, and tribal governments rep resent

approximately 0.001 percent of the National GDP, and estimated costs for the

private sector rep resent approximately 0.008 percent of th e Nation al GDP. 

3996

To evalu ate th e effect of the proposed ru le on sub-regions or distinct economic

sectors, this an alysis also compared estimated section 7 costs to the total Californ ia

Gross State Produ ct (GSP), as well as the “State and Local Government” and

“Private Industries” GSP industry segments. As shown in Table 27, this an alysis

4001 revealed that total section 7 costs within both the State/ local/ tribal and private

sector categories represent less than 0.08 percent of all economic ind icators. Because

these percentages fall well below the 0.25 to 0.5 percent threshold recommended by

the OMB, this an alysis concludes that the proposed designation will not result in a

significant effect on th e national economy, or on a particular geographic region or

4006 economic sector. 

5. Consultations with elected officials. The consultations with representatives of

State, local, and tribal governments will be described in greater detail by the Service.
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

165

4011 XI. POTENTIAL BENEFITS OF PROPOSED CRITICAL

HABITAT

The published economics literature has documented that real social welfare benefits

4016 can result from the conservation and recovery of endangered and threatened

species (Bishop (1978, 1980), Brookshire and Eubanks (1983), Boyle and Bishop

(1986), Hageman (1985), Samples et al. (1986), Stoll and Johnson (1984)). Such

benefits have also been ascribed to preservation of open space and biodiversity,

both of which are associated with species conservation (see examples in Pearce and

4021 Moran (1994) and Fausold and Lilieholm (1999)). Likewise, regional economies and

communities can benefit from the preservation of healthy populations of

endangered and threatened species, and the habitat on which these species depend

(ECONorthwest [2002]).

4026 However, a purpose of the Act is to provide for the conservation of endangered and

threatened species. Thus, the benefits of actions taken under the Act are primarily

measured in terms of the value placed by the public on species preservation (e.g.,

avoidance of extinction, and/or an increase in a species’ population). Such social

welfare values may reflect both use and non-use (i.e., existence) values. For

4031 example, use values might include the potential for recreational use of a species

(e.g., bird viewing opportunities) should recovery be achieved. Non-use values are

not derived from direct use of the species, but instead reflect the utility the public

derives from knowledge that a species continues to exist. 

4036 In addition, as a result of actions taken to preserve endangered and threatened

species, various other benefits may accrue to the public. Such benefits may be a

direct result of modifications to projects made following section 7 consultation, or

may be collateral to such actions. For example, a section 7 consultation may result

in the conservation of buffer strips along streams, in order to reduce sedimentation

4041 due to construction activities. A reduction in sediment load may directly benefit

water quality, while the presence of buffer strips may also provide the collateral

benefits of preserving habitat for terrestrial species and enhancing nearby

residential property values (e.g., preservation of open space). 
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166

4046 The remainder of this chapter describes the categories of benefits resulting from

implementation of section 7 of the Act in the context of areas affected by the proposed

designation. First, it qualitatively describes the types of benefits likely to result from

section 7 protections. Then, it addresses both the benefits associated with species

preservation as well as habitat protection. 

4051

As discussed below, it is not feasible to fully describe and accurately monetize the

benefits of this designation in the context of this economic analysis. The discussion

presented in this report provides insight into the potential benefits of the designation

based on information obtained in the course of developing the economic analysis. It

4056 is not intended to provide a complete analysis of the benefits that could result from

section 7 of the Act. Given these limitations, the Service believes that the benefits of critical

habitat designation are best expressed in biological terms that can be weighed against the

expected cost impacts of the rulemaking.

4061 Categories of Benefits

Implementation of section 7 of the Act is expected to substantially increase the

probability of conservation for the gnatcatcher. Such implementation includes both the

jeopardy provisions afforded by the listing as well as the adverse modification

4066 provisions provided by the designation. Specifically, the section 7 consultations that

address the gnatcatcher will assure that actions taken by Federal agencies do not

jeopardize the continued existence of the species or adversely modify its habitat. Note

that these measures are separate and distinct from the section 9 “take” provisions of the

Act, which also provide protection to this species.

4071

The benefits of critical habitat designation can therefore be placed into two broad

categories: (1) those associated with the primary goal of species conservation and (2)

those that derive mainly from the habitat protection required to achieve this primary

goal. In the case of the gnatcatcher, habitat is generally restricted to coastal southern

4076 California and typically occurs in or near coastal sage scrub (CSS), which is a broad
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

February 24, 2004

99 Refer to the Proposed Rule for a detailed description of each type of sage scrub community

167

category of vegetation that includes a variety of sage scrub communities.99

Environmental benefits associated with recovery of the gnatcatcher and protection of

its habitat may include:

4081 • Preservation of open space resulting from acquisition of mitigation lands;

• Improved stability of native flora/fauna communities resulting from

removal of exotic species among coastal sage scrub habitat;

4086 • Decreased habitat loss resulting from habitat protection, restoration, and

enhancement projects including revegetation; and

• Improved quality and decreased destruction of coastal sage scrub habitat

resulting from restoration activity on marginal coastal sage scrub habitat

4091 acres.

Table 28 details those activities expected to generate section 7 consultations leading

to project modifications associated with the proposed critical habitat for the

gnatcatcher, organized by the category of physical/biological improvement expected

4096 to result from the project modification. For example, of the approximately 311 formal

consultations anticipated, it is expected that the majority of these will result in project

modifications providing for decreased habitat loss. These ecological and

environmental benefits are expected to result from consultations regarding private

development, transportation projects, utility projects, and Federal land management

4101 spread across the 13 proposed critical habitat units.
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February 24, 2004

168

Table 28

Physical/Biological Improvements Expected to Result from Implementation of Section 7 of the Act

Physical/Biological Improvement Land Use Activity Expected Project Modification Critical Habitat Units Number of Expected Consultations

with project modificationsa

4106 Restoration of CSS habitat

Decreased habitat loss for gnatcatcher

Improved survival rates of gnatcatcher

4111

Preservation of open space

Improved survival for other species

found within gnatcatcher habitat

4116

Improved stability of native flora/ fauna

communities

Increased public awareness

Private

Development

Transportation

Projects

Utility Projects/

O&M

Federal Land

Management

On-site set-aside

Off-site preservation

Restoration of CSS habitat

Timing restrictions (e.g., construction

outside breeding season)

Biological monitoring & construction

practices (surveys, fencing, etc.)

Shield lighting away from habitat

Landscape with native vegetation

Education programs (employee & public)

Cowbird trapping program

Unit 1

Unit 2

Unit 3

Unit 4

Unit 5

Unit 6

Unit 7

Unit 8

Unit 9

Unit 10

Unit 11

Unit 12

33916145850446710000

4121 Decreased habitat loss

Expansion of coastal sage scrub

habitat (post-burn re-colonization)

Federal Land

Management

Protecting CSS habitat during prescribed

burns

Unit 13 253

a 4126 This analysis assumes that any benefits from section 7 of the Act stem from the application of project modifications. Therefore, this analysis assumes that the projected number of

consultations recommending project modifications most accurately represents the level of protection the gnatcatcher may receive as a result of section 7 implementation.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

169

The physical/biological improvements implied by Table 28 may in turn provide for a

variety of economic benefits. For example, the conservation of open space in areas

previously planned for development may enhance the value of property located outside

4131 of critical habitat and adjacent to the open space. The discussion below provides

qualitative descriptions of the economic benefits associated with these environmental

improvements. While it is possible to estimate the number of projects that will generate

consultations requiring project modifications, as well as the number of acres set aside as

project mitigation, existing data do not allow for complete monetization of the

4136 ecological or economic implications of these modifications. 

Benefits Associated with Species Conservation

The primary benefit of designating critical habitat is to increase the chance of

4141 conservation for the gnatcatcher. Quantifying the benefits associated with improved

chance of conservation requires an assessment of the public’s value for the designation

of critical habitat for species such as the gnatcatcher. This may include both a use and

non-use (i.e., existence value) component.

4146 Use Value

The value that the public holds for conservation of the gnatcatcher and its habitat may

include a direct use component related to viewing opportunities. Some bird species are

sought by recreational bird watchers. Thus, individuals may value species preservation

4151 to the extent that it increases the probability of future sightings. When large numbers of

birding enthusiasts visit an area to see one or more species, the regional economy can

also benefit (Manion et al., 2000). Several economic studies have considered the

economic benefit that accrues to birdwatchers. However, data do not exist to allow for

estimation of the number of additional bird viewing trips, or improved trips, that will

4156 result from actions taken to protect the gnatcatcher under section 7. Thus, it is not

possible to monetize this category of benefit. 
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

170

Existence Value

4161

Existence value reflects the utility the public derives from knowledge that a species

continues to exist. A number of published studies have demonstrated that the public

holds values for endangered and threatened species separate and distinct from any

expected direct use of these species (i.e. willingness to pay to simply ensure that a

4166 species will continue to exist). These studies include Boyle and Bishop (1987), 

Elkstrand and Loomis (1998), Kotchen and Reiling (2000), and Loomis and White (1996). 

There is little doubt that the gnatcatcher provides intrinsic values, and that these values

will be enhanced by its survival and conservation.

4171 This analysis attempts to assess the benefits of protections afforded the gnatcatcher as a

result of designating an additional unit of critical habitat. The existing economics

literature does not provide quantitative estimates of these benefits. Instead, the data

provided by the literature may be indicative of the value the public places on the

protection of sensitive bird species in general, but do not represent the specific values

4176 sought by this economic analysis. To accurately quantify the existence value benefits

for the gnatcatcher as described above would require information regarding the

public’s marginal willingness to pay for an incremental unit of critical habitat, in terms

of the increased probability of conservation or increase in abundance of the species.

4181 Benefits Associated with Habitat Protection

Open Space Preservation and Real Estate Effects

Section 7 consultations may result in less dense development and/or on-site set asides of

4186 land at a project site located within critical habitat. The portions of the site that might

otherwise have been developed represent a cost of the designation. However, that cost

in terms of development value foregone is off-set, to some degree, based on enhanced

property value for homes located on larger lots or near open space. The net effect of onsite project modifications on land values is considered in Chapter III.

4191

Additional benefits of open space preservation are likely to result from off-site

preservation. Section 7 applicants and third parties are sometimes advised to mitigate

for developing habitat acres by purchasing a specified quantity of compensatory acres

at an off-site location. For private development of CSS habitat, off-site mitigation

4196 usually includes purchase of credits at a private mitigation bank. Thus preservation of

these acres represent a public benefit in terms of the value that the public places on the
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

100 These figures do not include acres for which CSS mitigation is required due to baseline regulations

other than section 7.

101 Furthermore, one study (Correll et al (1978)) found that by integrating open space into a housing

development during the initial conceptual phase (i.e., purchased prior to construction), the positive effect

on property values in the adjacent neighborhood is greater, than when land is acquired and conserved as

an afterthought.

171

existence of undisturbed, open space. Off-site land preservation may also enhance

property values of homes located outside of critical habitat and near the mitigation

banks. As shown in Table 10, approximately 7,982 acres in unit 10 are expected to be

preserved off-site as a result of section 7 consultations.100 4201

As noted in Chapter III, this report assumes that land mitigation set-asides will not

interfere with the demand for housing in the areas affected by critical habitat (i.e.,

development will not be precluded, but rather displaced). Therefore, it is possible that

4206 displaced development attributable to critical habitat may result in (a) an increase in

development density elsewhere (i.e., a net gain in surplus associated with open space

preservation) or (b) an increase in low density development outside of critical habitat

(i.e., no net gain in surplus). To the extent that displaced development occurs in

existing urbanized areas or at higher densities, a net gain in open space may be

4211 realized. Where low density development is simply displaced to alternative locations

outside of critical habitat, no net gain in open space is expected.

Various studies have documented the positive affect of environmental amenities,

including open space, on the value of nearby residential and commercial properties

4216 (Thibodeau and Ostro (1981), Nelson (1985), Lacy (1990), Garrod and Willis (1992), 

Bockstael (1996), Geoghegan (1998), Acharya and Bennet, 2001)). The enhancement of

real estate values depends on, among other things, the proximity of homes to open

space, the existing supply of conserved land, and local development pressure. Future

project modifications involving the purchase of off-site mitigation lands in and around

4221 the proposed critical habitat units are likely to occur in areas of significant development

pressure. Future residential and commercial growth in these areas will lead to a

reduction in the supply of open space within developing communities, which will likely

increase the value of existing and acquired open space, based on its relative scarcity.

4226 A review of the economics literature demonstrates that increasing the quantity of open

space (i.e., greenbelts, wetlands, wildlife corridors, and riparian areas) in a community

can lead to enhanced residential property values.101 To calculate the benefits of

additional open space, additional data are required. Fo example, as noted above, the

value of open space in a community depends upon a number of factors. Information on
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Economic Analysis of Critical Habitat Designation for California Gnatcatcher

102 Non-native species that commonly threaten coastal sage scrub habitat include artichoke thistle

(Cynara cardunculus), European annual grasses (e.g., Bromus spp., Avena spp., Schismus spp.),

and mustards (e.g., Brassica spp.).

172

4231 the extent of existing open space in communities affected by the proposed critical

habitat would need to be compared with the existing levels of open space in

communities assessed by the hedonic literature. As discussed above, information is not

available regarding the extent of open space within the areas of the designation relative

to the extent of open space in areas outside of the proposed designation (i.e., locations

4236 that absorb the “displaced development” attributable to critical habitat). Various other

data would be required to make a defensible transfer of “open space value” as

identified in the literature to a community or neighborhood impacted by the

designation of critical habitat (e.g., median price of homes, available housing stock,

demand for housing, etc).

4241

Benefit to Other Species

The habitat protection measures recommended for the gnatcatcher generally encompass

stretches of CSS, which incidently provides ancillary benefits to other species that

4246 cohabit these areas throughout California. That is, protecting the primary constituent

elements for the gnatcather through future project modifications will lead to habitat

improvement benefits for other threatened and endangered flora and fauna. Table 29

provides a list of other species included in historic section 7 consultations with the

gnatcatcher and that are found in or around CSS habitat. Each one of these organisms

4251 may in turn provide some level of direct or indirect benefit to the public (e.g., existence

value) and/or local economies. Conservation recommendations that may benefit other

species include:

1. Exclusionary fencing, which restricts domestic pets from sensitive habitat areas;

4256 2. Redirecting of city lights to avoid illuminating habitat area for predators;

3. Timing restrictions to prevent land grading during breeding season (between

February 15 and August 15);

4. Cowbird trapping to capture and remove non-native, predator bird species

known to disturb the gnatcatcher and other sensitive bird species in coastal sage

4261 scrub habitat; and

5. Exotic species control which requires applicants to re-vegetate with native plant

communities and to eradicate nonnative species, thereby improving the stability

of native flora and fauna communities.102
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173

Table 29. Species Likely to Benefit From Coastal Sage Scrub Protection Measures

4266 Associated with Critical Habitat Designation for the Gnatcatcher

Riverside fairy shrimp Orcutt's spineflower

Palos Verde Blue Butterfly slender-horned spineflower

Delhi sands flower loving fly Laguna Beach live-forever

Pacific pocket mouse Santa Ana River woolly star

4271 San Diego Thornmint willowy monardella

San Diego ambrosia spreading navarretia

Del Mar Manzanita California Orcutt grass

San Jacinto Valley crownscale Lyon's pentachaeta

Encinitas baccharis Otay mesa mint

4276 Thread-leaved brodieae big-leaved crown beard

Vail Lake ceanothus

These project modifications contribute generally to the maintenance of biodiversity and

collectively act to protect CSS habitat. The purchase of mitigation lands (as described

4281 above) will also contribute to the preservation of this ecosystem. While these benefits

can be described qualitatively, existing data are not available to monetize these changes.

Recreational Benefits

4286 Protecting critical habitat for the gnatcatcher may result in preservation of habitat

suitable for low-impact recreational uses, such as hiking, picnicking, and bird-watching. 

Project modifications involving the purchase of mitigation lands by residential

developers sometimes allow for the limited trail use. In other circumstances, however,

mitigation set-asides include fencing and restrict the development of recreational

4291 facilities (e.g., benches, picnic tables), thereby reducing potential recreational benefits. 

However, preservation of natural areas as parks or preserves for both species

conservation and public enjoyment may provide public benefits. Monetization of these

benefits, however, would require data on the number of additional trips or increased

quality of trips resulting from the designation. Such data are not currently available. 

4296
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103 Note that in some cases restoration is recommended to mitigate for “temporary project impacts” (i.e.,

excavation of CSS to install a pipeline and then revegetation after installation). This does not represent a

net benefit to other species, because the species are no better off following restoration.

174

Other Benefits

4301 Additional benefits of designating critical habitat for the gnatcatcher may include the

following:

Coastal Sage Scrub (CSS) Restoration. On-site restoration of otherwise degraded

habitat may be recommended through section 7 consultation.103 Frequently, CSS

4306 restoration is associated with purchase of on-site mitigation lands in order to convert

marginal habitat into suitable habitat for the gnatcatcher and other species that depend

on CSS. Restoration of marginal habitat may represent a benefit to other species in

terms of improved possibility of conservation. Based on our analysis, approximately

3,000 acres of on-site set-asides are expected to benefit from active restoration, primarily

4311 in Units 8 through 13. 

Educational/informational benefits. Both the gnatcatcher and other species that

inhabit CSS habitat will likely benefit from employee and public education programs

designed to improve understanding of how to protect these areas. To the extent that

4316 these educational programs improved best management practices (e.g., keeping

equipment staging areas out of the habitat, minimizing potential for spills, etc) and/or

increase awareness of issues related to habitat preservation and concern for endangered

species in general, species that inhabit other habitat types may also experience benefits. 

At this time sufficient information does not exist to quantify or monetize these benefits.

4321
APPENDIX A

DEMOGRAPHIC PROJECTIONS AND METHODOLOGY
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104 SCAG provided employment estimates that combined industry classifications into Retail,

Service, and Other. These broad categories did not correspond to the Employment Density

report. By applying EDD percent of employment in each industry, EPS was able to create

estimates for employment that were consistent with SCAG’s employment density report.

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APPENDIX A: DEMOGRAPHIC PROJECTIONS AND METHODOLOGY

The estimates for employment-related developed acres in the five SCAG counties

4331 derive from three separate variables: (1) employment estimates (derived from SCAG

employment projections), (2) employee distribution among landuses (taken from SCAG

employment density report), and (3) employees per acre factor (taken from SCAG

employment density report).

4336 Employment estimates are based on the SCAG total employment projections by place of

work for 2000 and 2025.

104 The State of California Economic Development Department

(EDD) provides an estimate of the distribution of employment among industry

categories in 2000. Applying these percentages to the SCAG employment estimates at

the census tract level, provides an estimate of employment per industry category. 

4341 Appendix Table A-1 shows the distribution of employment by industry in each county.

Within each industry, the landuse requirements vary. SCAG provided a distribution of

landuses by industry in “Employment Density Study Summary Report” (October 31,

2001). Appendix Table A-2 shows the distribution of landuses among the nine industry

4346 categories surveyed in the report. These industry categories match exactly with the

employment by industry estimates discussed above. 

In “Employment Density Study Summary Report” (October 31, 2001), SCAG provides

an estimate for the number of employees per acre in each landuse category. As stated

4351 in the report, “the most appropriate factors are the regional employment density

factors.” Therefore, the weighted average regional factors were applied to each county,

rather than distinct county estimates. Appendix Table A-3 shows the employment

densities employed for each land use category.
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4356 By applying the employees per acre of landuse factor to the estimated number of

employees in each landuse, EPS arrived at an estimate for acres developed for

employment purposes in 2000 and 2025. 

EPS made an additional estimate for residential development based on common

4361 residential development densities throughout California, as shown in Appendix Table

A-4. Combining the residential acreage and employment acreage estimates provided

the total developed land estimates.

In heavily populated urban areas, landuse patterns differ from the surrounding county. 

4366 Agriculture and Open Space are not logically situated in urban areas. EPS assumed that

in the most heavily populated areas employment attributable to these landuses would

shift to the “All Other” landuses category.
Appendix Table A-1

Distribution of Employment by Industry in Each County

Industry Riverside San Bernardino Los Angeles

Farming 3.73% 0.73% 0.19%

Mining 0.09% 0.13% 0.10%

Construction 10.08% 5.87% 3.21%

Manufacturing 11.45% 13.10% 15.37%

Transportation & Public Utilities 2.98% 6.73% 5.98%

Wholesale Trade 3.67% 5.72% 6.63%

Retail Trade 20.04% 19.50% 15.55%

Finance, Insurance, & Real Estate 3.22% 3.11% 5.64%

Service 26.71% 25.22% 33.08%

Government 18.03% 19.89% 14.25%

Total Employment 100.00% 100.00% 100.00%

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Appendix Table A-2

Distribution of Employees per Land Use Category

Land Use Category Mining Construction Manufacturing TCU Wholesale Retail FIRE Services Government

Trade Trade

Commercial

1 Regional Retail 0% 0% 0% 0% 0% 4% 1% 1% 0%

2 Other Retail/Svc 11% 14% 8% 14% 14% 49% 27% 22% 11%

3 Low-Rise Office 10% 6% 5% 8% 9% 6% 19% 11% 11%

4 High-Rise Office 24% 2% 2% 3% 2% 2% 11% 5% 3%

5 Hotel/ Motel 1% 0% 0% 2% 1% 1% 2% 2% 0%

6 Misc. Commercial 0% 1% 0% 2% 1% 1% 1% 1% 3%

Industrial

7 R&D/Flex Space 1% 1% 2% 1% 2% 1% 1% 1% 0%

8 Light Manufacturing 13% 27% 50% 22% 37% 7% 5% 9% 6%

9 Heavy Manufacturing 0% 0% 0% 0% 0% 0% 0% 0% 0%

10 Warehouse 1% 1% 5% 5% 5% 1% 0% 1% 0%

11 Misc. Industrial 6% 2% 1% 2% 2% 0% 0% 0% 1%

Public/Other

12 Government Offices 0% 1% 1% 6% 0% 0% 1% 1% 25%

13 Primary/Secondary School 1% 1% 0% 0% 0% 1% 0% 4% 1%

14 Colleges and Universities 0% 0% 0% 0% 0% 0% 0% 1% 1%

15 Transportation 1% 1% 2% 9% 1% 1% 0% 1% 1%

16 Utilities 0% 1% 1% 1% 1% 0% 1% 0% 1%

17 Other Institutional 1% 1% 0% 1% 1% 1% 1% 2% 7%

18 Hospitals 0% 0% 0% 0% 0% 0% 1% 4% 0%

19 Agriculture 3% 1% 2% 1% 2% 1% 1% 1% 1%

20 Open Space 5% 6% 5% 5% 6% 5% 5% 6% 5%

21 All Other 9% 3% 4% 4% 3% 4% 4% 4% 11%

22 Residential 14% 32% 11% 13% 14% 16% 18% 23% 13%

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Appendix Table A-3

Employment Density per Land Use Category

Land Use Category Weighted Average

Commercial

1 Regional Retail 19.71

2 Other Retail/Svc 21.98

3 Low-Rise Office 43.95

4 High-Rise Office 175.49

5 Hotel/ Motel 33.07

6 Misc. Commercial 13.4

Industrial

7 R&D/Flex Space 20.53

8 Light Manufacturing 17.83

9 Heavy Manufacturing 31.14

10 Warehouse 11.4

11 Misc. Industrial 2.41

Public/Other

12 Government Offices 51.67

13 Primary/Secondary School 5.65

14 Colleges and Universities 6.93

15 Transportation 4.88

16 Utilities 1.86

17 Other Institutional 15.2

18 Hospitals 37.7

19 Agriculture 0.34

20 Open Space 0.12

21 All Other 3.48

22 Residential 1.4

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Appendix Table A-4

Residential Development Density Assumptions

Type Units per Acre

Multi-Family Development 35

Single-Family Development 7

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APPENDIX B

U.S. ARMY CORPS JURISDICTION ASSUMPTIONS,

METHODOLOGY, AND GIS ANALYSIS

SOURCE: ELLIS GEOSPATIAL
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APPENDIX B: U.S. ARMY CORPS JURISDICTION

ASSUMPTIONS, METHODOLOGY, AND GIS ANALYSIS

4386 GIS EVALUATION OF GNATCATCHER HABITAT UNITS, SCAG AND SANDAG

EXECUTIVE SUMMARY

Three major objectives were successfully completed across SCAG and SANDAG using GIS

technology:

4391 • Determination of acreage and spatial relationships between habitat units (HU), census

tracts, parks, and military bases

• Determination of probable extent of wetlands and waters within HUs

4396 • Impact of wetlands and “waters of the US” on 300- and 100-acre development tracts

fully or partially within HUs

The GIS analysis defined how much HU acreage was in each census tract and how

much of the HU was covered with park and/or military. The analysis also provided

4401 statistics on the total amount of park and military within census tracts with HU. In

addition, how much land was available for development (outside of HU, parks, and

military) was also calculated to support the economic analysis.

For those development tracts that intersect a HU, 69% of 300-acre tracts and 60% of 100-

4406 acre tracts will also intersect a Corps-defined, waters of the US. This is valid for large

samples of tracts but the map derived in this study cannot be applied to individual

tracts. The GIS models 2.74% of the HU area as covered with wetlands while 0.03% are

covered with waters of the US.
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4411 INTRODUCTION

GIS provided essential information on the spatial distribution and intersection of the

various features of interest in SCAG and SANDAG. These features of interest included:

• Gnatcatcher HUs

4416 • Census Tracts

• Slope and Elevation

• Wetlands and Waters of the U.S.

• 300- and 100-Acre Development Tract Grids

• Parks and Military Bases

4421

The objectives of the GIS study included:

• Determining how much area HUs occupy in a Census Tract

• Determining how much Park and Military cover HUs in a Census Tract

4426 • Extrapolating the Corps of Engineers wetlands and “waters of the U.S.” findings

from a Pilot Study in Riverside County to the rest of SCAG and SANDAG

• Documenting slope and elevation similarities and differences

• Evaluating the impact of Corps wetlands and waters of the US on 300- and 100-

acre development tracts

4431 • Determining how much Park and Military acreage is within each Census Tract

DATA

The data used in the study were provided by EPS and Fish & Wildlife, Carlsbad office. 

These GIS layers were received in different map projections and datums - all the layers

were georectified to UTM, NAD-27, Zone 11 and integrated into ESRI's premier natural

4436 resource software, ArcInfo, at HJW GeoSpatial in Oakland. The layers included:

• Gnatcatcher HUs

• Census Tracts for SCAG and SANDAG

• California Blue Lines (drainage)

4441 • USGS Digital Elevation Models (DEM's) as 7.5' Quads

• Parks for SANDAG (downloaded from SANDAG's GIS - layer 14)
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• Parks from Fish & Wildlife for SCAG

• Military Bases (with some parks) from MapInfo

• Corps of Engineers Pilot Study wetlands and Waters of the U.S., portions of

4446 Riverside County (see Lichvar and others, 2002)

• County Boundaries

• Color Landsat TM image of Southern California (30 m pixels - from HJW)

• 300 Acre and 100 Acre Grid (developed by HJW)

4451 Excel speadsheets were supplied by EPS with 2000, 2025, and 2000-2025 change

development statistics. These data were linked to the GIS census tract data as attributes.

METHODOLOGY

GIS was used to integrate the mapping layers and development data across SANDAG

and SCAG. Interactive manipulations were done to determine areas, intersections of

4456 lines with polygons and polygons with polygons between different layers, and

relationship of different features to slope and elevation. 

ESRI's ArcInfo GIS was used for the vector (line and polygon) analysis while Leica's

ERDAS image processing software was used for raster and grid (satellite imagery and

4461 DEM) analysis. The primary data analysis was done with UNIX servers and

workstations. The GIS ArcInfo coverages were routinely transferred from the UNIX

workstations to NT and XP systems for viewing with ESRI's ArcView 3.x software and

integration with the Corps of Engineers Pilot Study in Riverside County that provided

ArcView shapefiles of wetlands and waters of the U.S.

4466

As the data were being loaded, considerable time was spent on designing the analysis

and formatting the data to answer the questions being posed by EPS. The study was

largely focused on determining spatial relationships of different features (census tracts,

parks, military bases, waters of the U.S., etc.) with HUs. During the conclusion of the

4471 study, however, more general questions were asked about the distribution of parks and

military bases within census tracts that required modifying the established GIS work

processes.
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4476 The DEM's from the USGS were mosaicked and projected into UTM NAD-27. The

elevation model was sliced at 2500' to visually determine how much HU was above

2500' (Figure 1). The HUs were checked for integrity and reasonable shapes/locations

by superimposing them over an enhanced Landsat TM image of the SCAG and

SANDAG area (Figure 2). The satellite image also was used effectively to check the

4481 integrity and reasonable shapes/locations of parks and military bases and to evaluate

the accuracy of the California blue lines and the dense drainage network developed by

the Corps of Engineers in the Pilot Area. 

Park and military base polygons were obtained from different sources - duplication was

4486 edited. SANDAG's parks were available via a download from their GIS site (layer 14) -

this layer was exceptionally accurate. SCAG's parks came in several layers from Fish &

Wildlife in Carlsbad, California. A MapInfo "Parks" layer contained mostly military

bases and proved very useful for the analysis of SANDAG (Figure 3). 

4491 The different map layers had varying degrees of accuracy and precision (see Figure 4). 

When the layers were superimposed, offsets and slivers could be seen along the

margins of some of the polygons. When layers were combined, these erroneous slivers

would become individual polygons that provided acreage amounts either in or out of

the HU, park, or military base. To minimize the effect of slivers and reduce the number

4496 of polygons, polygons with areas <0.1 acre were largely eliminated from the database

provided to EPS.

Spatial dimensions (area and intersection) of overlapping polygons and lines could be

accurately calculated because all the GIS layers were in one map projection and datum,

4501 the layers were relatively accurate, and the polygons and lines were correctly formatted

and attributed.

RESULTS

Three major objectives were successfully completed across SCAG and SANDAG using

GIS technology:

4506

• Determination of acreage and spatial relationships between HUs, census tracts,

parks, and military bases
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Determination of probable extent of wetlands and waters within HUs

4511 Impact of wetlands and “waters of the US” on 300- and 100-acre development tracts

fully or partially within HUs

Habitat Units in relation to Census Tracts, Parks, and Military Bases

Polygons for census tracts, parks, and military were spatially layered with HUs to

determine acreage amounts within overlap zones (Table 1). The initial calculation was

4516 to locate those census tracts that had HU acreage within their boundary and calculate

the total HU acreage. Then we queried the GIS about the characteristics of the HU –

was it covered by park (and by how many acres), was it covered by military (and by

how many acres), and was it covered by both park and military (and by how many

acres)? If the HU was not covered by park or military, the total HU acreage within the

4521 census tract was considered at risk.

Toward the end of the analysis, the focus shifted from HU-centric queries to more

general questions (Table 1). Queries were made about how much total park was in a

census tract and how much of the census tract was not in park and available for

4526 development? If the census tract overlapped with military, the GIS was queried for

how much military acreage was in the tract, how much military acreage was coincident

with park acreage, and how much further was acreage available for development

reduced due to military (Table 1 and Figure 4)? 
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4531 Table 1. Sample of GIS calculations derived from Census Tracts, HU, Parks, and Military

Polygons

(Left side of one Spreadsheet – see next page for continuation of rows 1-9, 198-207)

4536
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(Right side of above Spreadsheet)
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4541 Extrapolation of Corps Pilot Area, Wetlands and Waters of the USA findings

for HU 10 to rest of HUs across SCAG and SANDAG

The Corps of Engineers completed a wetlands and waters of the US study of San

Jacinto and portions of Santa Margarita watersheds, Riverside County in

November 2002 (Lichvar and others, 2002). Their report documented their

4546 methodology, aquatic resources, and map units. Most importantly for this study,

their report provided digital ArcView GIS 3.x shapefiles – these were reprojected

and integrated with the gnatcatcher project’s mapping layers. 

The GIS statistics developed within the Pilot Area were compared to the rest of

4551 SCAG and SANDAG to determine how similar the Pilot Area was to the rest of

the gnatcatcher project area. If the geomorphic parameters were similar, then

extrapolating statistics from the Pilot Area to the rest of SCAG and SANDAG

could be justified.

4556 Lichvar and others’ (2002) report contained data and information useful for this

study on p. 27, 28 (Table 8), and 31 (Table 10). They interpreted and digitized

“first order, ephemeral, and intermittent streams” from aerial photography and

noted that this category of streams are “typically up to 10 feet wide.” They also

digitized streams farther downslope – second and third order Stahler streams

4561 and noted these as having “narrow width...” due to “...human influences that

caused down cutting in the channel.” They noted that their methodology

resulted in more streams compared with the USGS 7.5 minute quadrangle map

(Lichvar and others, 2002, p. 15).

4566 Our gnatcatcher HU GIS study focused on the Corps mapping that was within HU 10

(Figure 5). Acreage within each wetland class were determined (Table 2). The USGS

DEM was used to subdivide the slopes into 0-5, 6-15 and >16% (Figure 6). The length of

the Corps-digitized drainage (waters of the US) within HU10 was calculated using the

GIS (Table 3). In addition, the length of the State of California “blue lines” streams

4571 within HU10 were determined (Table 2). By multiplying the Corps-defined waters of

the US length by the width (10’ for 3 meters), an acreage was determined (Table 3).
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Table 2. Wetlands Acreage by class for Corps Pilot Area

Wetlands Data

4576 HU Acreage in Pilot Area

Class Acreage %

1 1603 54

2 56 2

3 268 9

4581 4 172 6

5 27 1

6 835 28

Total 2961

4586 Table 3: Example of Using GIS to Derive Acreage and % Area for Three Classes of Slope in

the Corps of Engineers Pilot Area, Riverside County

DETAILS

HU acreage in Pilot Area

Slope Acres %

4591 AREA 0-5 20,377 19

6-15 39,927 37

>16 47,836 44

TOTAL 10,8140

4596

Slope Acres %

CA BLUE LINES 0-5 151,329 37

6-15 150,014 37

>16 104,631 26

4601

TOTAL length 405,974

TOTAL area (assume 3m wide) 1,217,922 m2 5 acres

CORPS DEFINED Slope Acres %

4606 W OF US (m apped) 0-5 281,951 14

6-15 735,051 37

>16 962,636 49

TOTAL length 1,979,638

4611 TOTAL area (assume 3m wide) 5,938,914 m2 24 acres

(taken from data sheet delivered to EPS)
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After the Pilot Area was analyzed, the rest of the SCAG and SANDAG area was

evaluated for slope and CA blue line measurements. The slope and CA blue line data

4616 for HUs in the “rest of the area” were relatively similar to that measured in the Pilot

Area. This similarity encourages extrapolation of the wetlands and waters of the US

from the Pilot Area to the rest of the area (see also Figure 5). Adjustments can be made

to the factors and assumptions used in the extrapolation, as the procedure is further

analyzed.

4621 A summary of some of the observations and assumptions that came out of this

extrapolation is shown in Table 4. To determine the total HU acreage covered or

intersected by wetlands and waters of the US, the pilot study and “rest of the area”

acreages/percentages were summed (Table 5).
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Table 4. Some Observations and Assumptions

4626

1. HU in rest of area 5.43 x size of HU in Pilot Area.

2. HU in rest of area has lower average elevation (~1200’) compared to Pilot Area

(~1800’)

3. HU in rest of area has 7.35 x the length of CA blue line drainage compared with Pilot

4631 Area

a. Probably because terrain is steeper on average in HUs outside of Pilot Area

4. Corps-defined W of US for area outside of Pilot Area estimated by multiplying Pilot

Area stream s by 7.35 (based on CA Blue Line ratio).

5. Area for Corps-defined W of US derived from length of mapped streams by

4636 multiplying by 3m (p. 15 of Nov. 2002 report – Planning Level Delineation - San

Jacinto and portions of Santa Margarita Watersheds – states that the digitized lines of

1

st order, ephemeral, and intermittent streams “...are typically up to 10 feet wide...”

6. Area for CA Blue Lines not substantiated......used 3m based on Corps’ observation

above for their interpreted streams as place holder in analysis.

4641 7. ~7% of the blue line drainage in the Pilot Area is not duplicated by the Corps’ W of US

mapping effort – based on visual inspection. Added 3 acres from CA blue line total to

W of US total.

8. Add the Pilot Area Totals to the extrapolated outside of the Pilot Area Totals to arrive

at solutions for different questions.

4646 9. 300 acre tracts intersect m ore drainages on a % basis than 100 acre tracts. This

study summed tracts that were fully and partially contained within a HU.

The Corps Pilot Study enables acreage of wetlands and waters of the US across SCAG

and SANDAG to be approximated using GIS technology (Table 5).
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4651 Table 5. Summary of GIS Study for Wetlands and Waters of the US

HU Area Covered/Intersected by Wetlands/Waters of the US in SCAG/SANDAG

BY HABITAT UNITS

Corps Corps

% of HUs Class of W etlands % W etland

4656 1.47% Class 1 100%

0.05% Class 2 67-98%

2.74% of HUs are wetlands 0.25% Class 3 32-66%

0.16% Class 4 2-32%

0.03% Class 5 <2%

4661 0.80% Class 6 uplands

0.3% of HUs have Corps-defined W of US (1st order, ephemeral, intermittent streams) with %

of CA Blue Line

4666 BY DEVELOPMENT TRACTS

55% of full/partial 300 acre tracts intersect CA blue line drainage

69% of full/partial 300 acre tracts intersect Corps-defined W of US

46% of full/partial 100 acre tracts intersect CA blue line drainage

60% of full/partial 100 acre tracts intersect Corps-defined W of US

4671 (taken from data sheet delivered to EPS)

Impact of Wetlands and Waters of the US on 300- and 100-acre development tracts in

HUs

Starting at the SE corner, a 300- and 100-acre grid was generated by the GIS (Figure 7). 

4676 Within the Pilot Area, the intersection of both CA blue line drainage (from USGS 7.5’

maps) and the Corps more dense digitized drainage with the grid cells was determined. 

The analysis was completed for both cells fully contained within the HU and those that

partially covered the HU (Figure 8).
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4681 The process developed in the Pilot Area was extrapolated to the rest of SCAG and

SANDAG. The pilot area and rest of area measurements were summed for the overall

statistics (Table 5). Statistics for both full and partial grid cells were compiled. This

study combined the statistics derived from full and partial grid cells (Table 5)

4686 For those development tracts that overlap with a HU, 69% of 300-acre tracts and 60% of

100-acre tracts will intersect a Corps-defined, waters of the US. This is valid for large

samples of tracts, but the map develop for this project by the GIS (portions shown in

Figure 7 and 8) cannot be applied to individual tracts as the grid’s arbitrary starting

point will determine which cells intersect the drainage. 

4691 CONCLUSION

GIS effectively generated statistics on features of interest that can be used to support

economic modeling. Taking the time to understand what will be asked of the GIS and

to design and plan the GIS framework prior to processing was critical. Remote sensing

(satellite and airborne) provided an excellent and cost-effective QC tool for checking the

4696 accuracy and integrity of different map layers and for interpreting waters of the US and

wetlands in the Pilot Area.

REFERENCES

Lichvar, R., G. Gustina, M. Ericsson, 2002, Planning Level Delineation and Geospatial

Characterization of Aquatic Resources for San Jacinto and Portions of Santa

4701 Margarita Watersheds, Riverside County, CA. U.S. Army Corps of Engineers

Engineering and Research Development Center (ERDC), Cold Regions Research and

Engineering Laboratory (CRREL), Hanover, NH. Final Report to the Riverside

County Flood Control District and U.S. Army Corps of Engineers, Los Angeles

District, Regulatory Branch, the U.S. Environmental Protection Agency, Region IX. 

4706 Digital ArcView 3.2 GIS shapefiles provided of wetlands and waters of the U.S.

provided.

Ellis GeoSpatial Excel Spreadsheets “wetlands_wofus_hu2”, “sand_hu_county_park3”,

“ventura_hu_county_park3”, and “scag_hu_county_park3” delivered to EPS 20 Feb

- 3 Mar 2003.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

14

H:\12594gnatcatcher\Report\DEA _Feb2004\CAG N_D EA_Feb2004.wpd5

4711 ACKNOWLEDGMENTS

Hugh Dodd of HJW GeoSpatial, and the technology base at HJW GeoSpatial, enabled

this GIS Project to be successfully undertaken and completed. Jason Tundermann and

Christine McMillan of EPS, and Stacy Love of Fish & Wildlife, Carlsbad provided timely

guidance and data.

4716
APPENDIX C

SUMMARY OF SELECTED SECTION 7

BIOLOGICAL OPINIONS
Table C-1

Selected Section 7 Formal Consultations 

No. Project Project Project Action Applicant Date Consultation Date BO City/

Name Type Description Agency Initiated Issued County

1 Padova Padua Hills Housing 125 single-family units on 112 ac site USACE Pomona College 12/20/2000 4/5/2001 Claremont/ 

62.5 ac of CH to be graded, incl. Los Angeles

26.5 ac of CSS

2 Sycamore Creek Housing 1,733 units, school, 4 parks, fire station, USACE Sycamore Creek 8/25/2000 1/31/2001 Unincorporated

Development commercial area, major roadway, trails, Associates, L.P. Riverside

detention basin, sewer lines/lift station,

on 722 acres

3 Blackmore Housing 172 single family homes on 64.4 acres 4/8/2002 10/21/2002 Murieta

Development within 102 acre project site Riverside

Project

4 Walnut Hills Housing/ 268 SF units & 18 hole golf course on USACE Standard Pacific 4/18/2002 (reinit.) 8/7/2002 Walnut/ 

Golf Course 551 ac site, incl. 89.41 ac CSS. Homes Los Angeles

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Table C-1

Selected Section 7 Formal Consultations 

No. Project Project Project Action Applicant Date Consultation Date BO City/

Name Type Description Agency Initiated Issued County

5 Spring Mtn. Ranch Housing/ 785 ac master-planned community USACE Eastbridge 3/1/2002 9/13/2002 Unincorporated

Specific Plan Land Fill incl. elem school, commercial, water Partners L.P. Riverside

treatment facility, water tanks, & 177 ac

landfill

Also incl. 129 ac in CAGN CH

6 Arroyo Trabuco Golf Course 18-hole golf course on 230 ac project USACE DMB San Juan 4/18/2001 6/11/2002 Mission Viejo

Golf Course site including range, clubhouse, and Golf Associates Orange

extension of existing hiking trails (agent is Rancho

Mission Viejo)

7 Brookfield Homes/ Housing/ 695 SF and MF homes on 126 ac; USACE Brookfield Homes 2/6/2002 5/15/2002 San Marcos

University Commons Road extension/realignment of San Elijo Road San Diego

Extension of Melrose Dr.; Development

of 2.1 ac commercial, 12.8 ac light

industrial, and 26-33 ac of private rec'l

use. Includes 138.1 ac open space.

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Table C-1

Selected Section 7 Formal Consultations 

No. Project Project Project Action Applicant Date Consultation Date BO City/

Name Type Description Agency Initiated Issued County

8 Calavera Hills Housing Maximum of 781 units on 300 ac., incl USACE McMillan 8/7/2001 3/14/2002 San Marcos

Phase II local infrastructure (3.5 miles local roads Land Development San Diego

, sewer, storm, and water)

9 La Sierra Avenue & Road Grading & widening of 2.13 miles of USACE Riverside County 11/20/2000 5/31/2001 Riverside

El Sobrante Road two roads (no additional lanes; not Transportation Riverside

Improvement Project growth inducing) Department

10 La Estrella/Nutmeg Road Construction of 0.49 miles of new 4-lane USACE Lennar 3/21/2002 8/23/2002 Murrieta

Street Extension road (88' ROW) and 0.57 total miles of Communities Riverside

new 2-lane roads (46'-66' ROW) to serve

Lennar's Greer Ranch development.

Project includes 6 new detention basins

(0.21-1.3 ac) and one 9'X13' culvert.

177 ac of CH w/ PCEs remain onsite 

11 Rancho Potrero Road Construct 2.6 mile (28' wide) road on USACE County of Orange 5/9/2001 8/23/2002 Unincorporated

Leadership Academy existing unpaved roads and trails, incl. Probation Dept Orange County

(Access Road) replacing 2 existing culverts and (Santa Ana Mtn)

constructing 2 new culverts

12 Hunte Parkway Road 1.67 miles of 6-lane arterial roadway USACE 4/26/2002 10/7/2002 Chula Vista

Project connecting Olympic and Eastlake San Diego 

Parkways to Otay Ranch (Village 11)

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Table C-1

Selected Section 7 Formal Consultations 

No. Project Project Project Action Applicant Date Consultation Date BO City/

Name Type Description Agency Initiated Issued County

13 SR-125 South Road Construction of approximately 12.5 mi. FHWA Caltrans 2/26/1999

of new 4-lane controlled access hwy. San Diego

between SR-905 and SR-54.

14 Realignment/ Road Realign existing SR-133 from I-405 to FHWA Caltrans 6/8/1999 3/4/2000 Unincorporated

Widening of Laguna SR-73, and widen road to 4 lanes. Orange

Canyon Rd, SR-133 Project includes variable-width median,

split-grade configuration, 8-ft bike lanes,

and 4 detention basins. 

15 Moreno-Lakeside Water 4.85 mi underground pipeline (50-60" di.) USACE SD County 1/8/2001 6/8/2002 Lakeside/Santee

Pipeline requiring construction corridors b/t 60 Water Authority San Diego

and 110 ft. Includes pumping station 

(50' X 100') & flow control facility (0.59 ac)

16 San Sevaine Creek Water/ Reinitiation of consultation (based on new BOR San Bernardino 4/10/2000 2/7/2002 Rancho 

Water Project Flood Control biol. Info) for flood control/water storage County Transportation Cucamonga &

(Reinitiation) facilities. Project includes replacement and Flood Control Fontana, and 

of existing levee, 55 ac. debris basin, District unincorporated

excavation & concrete lining of 13.4 miles San Bernardino

of existing flood control channels, and 9

miles of public trails.

34,000 ac "action area."

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Table C-1

Selected Section 7 Formal Consultations 

No. Project Project Project Action Applicant Date Consultation Date BO City/

Name Type Description Agency Initiated Issued County

17 Las Flores Estancia Military Remove CSS surrounding historic building US Marine Marine Corps 9/13/2000 2/2/2001 Camp Pendleton

Camp Pendleton (Grading) because it is damaging foundation Corps Base Camp Pendleton San Diego

(per National Historic Preservation Act)

18 Parking Construction Military Cut hillside to grade to construct parking US Marine Marine Corps 3/29/2002 5/30/2002 Camp Pendleton

for Bachelor Enlisted (Parking) associated with new military residences Corps Base Camp Pendleton San Diego

Quarters

19 Fallbrook Fire Military Fire Plan designed to protect weapons US Navy Fallbrook Naval 2/28/1994 2/8/1995

Management Plan (Fire Plan) storage area composed of grazing, Ordnance Center

firebreak maintenance, and prescribed

burnings on 7,360 ac undeveloped land.

20 Improvement/Use Military Repairs to perimeter road and road, US Marine Marine Corps 6/16/1999 9/21/1999 Miramar

of Roads, Lots, and (Grading) loading dock pavement repairs, and other Corps Air Station San Diego

Loading Docks road repairs are activities that may result Miramar

in incidental take.

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

1 Padova Padua Hills

2 Sycamore Creek

Development

3 Blackmore 

Development

Project

4 Walnut Hills

Other Listed CAGN Conservation Measures

Pairs Nearest CH Habitat Acres Pairs Species Present

Detected Breeding Site Present Corridor

None 7 miles Yes Infrequent 62.6 (CH) None None 1. Transfer 1207.2 ac within CH to City as open space (mandated by City un

2. Dedicate 55 ac Cons. Easement adjacent to CH (FWS...not breeding hab

3. Enhance/Revegetate 6.2 ac CSS within CH (breeding)

N/A N/A Yes Important 107 (occ.) 6 Munz's Onion (E) 1. 71 ac wildlife corridor (support 2 pr CAGN), to incl.

regional In SKR HCP area passive recreation only, preserved onsite (2 pr CAGN)

corridor (no effects) 2. Purchase mitigation credits for 192.2 ac. (and 4 pairs

CAGN) at Wilson Creek Conservation Bank.

3. Biological monitoring during clearing/grading

4. Revegetate 27.1 acres sage scrub and develop Sage 

Scrub Revegetation Plan

5. Landscaping and lighting tailored to CAGN needs

6. Sage scrub removal outside CAGN breeding season

7. Temporary fencing/buffers near occupied CAGN habitat

during construction

1 male ID'd breeding behavior Yes Essential 54.6 ac RSS No take Least Bell's Vireo 1. Purchase 110 ac RSS credits from Wilson Cr Mit Bank

observed on site 55.2 ac CH authorized In SKR HCP area 2. 20.4 ac conserved onsite (within CAGN CH)

(no effects) 3. Vehicular/pedestrian access restrictions on easement

4. Biological monitoring during all construction activities

5. No grading between Feb 15 and Aug 31

6. Employee education program for construction workers

7. Lighting directed away from natural areas.

8. Exclusion fencing adjacent to residential areas

9. Educational program for the public

10 On site No Critical 62.67 ac 4 None 1. Avoid 27.37 ac CSS on site (incl. Cons. Easement)

suitable habitat (8 sensitive spp.) 2. Create 58 ac. CSS (incl. Cons. Easement)

3. Biological monitoring before/during site disturbance

4. Mitigate areas outside designated footprint at 5:1 ratio

5. Site grading between Aug 31 and Feb 15 only

6. Place/maintain cowbird traps

7. Include deed restrictions to: shield lighting near open

space; avoid introducing invasive plant spp.; discourage

access to restoration areas

8. Implement an approved Habitat Restoration Plan

9. Implement an approved Landscape Plan

CAGN Biological Information CAGN Impacts/ITP

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

5 Spring Mtn. Ranch

Specific Plan

6 Arroyo Trabuco

Golf Course

7 Brookfield Homes/

University Commons

Other Listed CAGN Conservation Measures

Pairs Nearest CH Habitat Acres Pairs Species Present

Detected Breeding Site Present Corridor

CAGN Biological Information CAGN Impacts/ITP

One male breeding behavior Yes Essential 103.9 ac CH "Take" of SBKR suitable 1. Wildlife conservation easements over 112.8 acres to

observed on site in project site 1 CAGN habitat (no spp.) offset impacts to project site.

23.6 ac CH (harm) In SKR HCP area 2. A 107.3 ac conservation easement for the landfill site.

in landfill site (no effects) 3. Restore 50.5 ac CAGN habitat in cons. easement.

4. Plant 4 ac of scrub

5. Develop/implement Resource Management Plan

(including annual CAGN surveys)

6. 45 ac set aside as open space, w/ 16.4 ac as scrub

7. Biological monitoring during all construction

8. Presence/absence surveys within 500 ft of CAGN habitat

(Construction stops if CAGN determined to be present)

9. Permanent fencing around all conservation areas

10. All lighting directed away from conservation areas

11. Employee training program for all construction personnel

12. Develop/implement a revegetation/restoration plan

13. Develop educational program for the public 

12 pairs & observed on site Yes Critical 11.9 ac CSS 4 pairs least Bell's vireo 1. Dedicate onsite 55.2 ac CSS (10 prs and 2 ind. Males)

3 individuals (Unit 6) 79.4 ac other & revegetate and/or restore 4.0 ac CSS as part of 360 ac

in study area Part of southern suitable habitat open space dedication

5 pairs & 1 subregion of 2. Biological monitoring before and during construction

male are in Orange County (work postponed if nest found w/in construction areas)

project area NCCP 3. Sedimentation fencing around CSS during construction

4. Implement contractor education program

5. Conduct cowbird trapping program for 20 yrs

6. No golf cart bridge maintenance during breeding season

7. Golf course and range will be unlit

7 (pre-1996)* N/A Yes Essential 130 ac CSS 6 None 1. Minimize noise impacts during construction

3 (2011) (Unit 3) (In MHCP Core 6.6 ac valley grass 2. Project redesign to contribute to 1,000-ft wildlife linkage

Area and San 13.2 ac chaparral 3. Onsite set-aside of 115.6 ac of CSS/suitable habitat

Marcos Subarea 0.15 ac nonnative grass 4. Offsite preservation of 170.9 ac of CSS/suitable habitat

Plan) 169.2 ac in CH 5. Add'l 17.5 ac to be preserved off-site from willing seller

6. Biological monitoring before/during construction

7. Construct bridge for Melrose Dr. extension to preserve

1,000-ft wildlife corridor

8. Revegate with original soil and native species

9. Chainlink fencing around conservation areas near roads

10. Develop/implement monitoring & management plan

11. Insure preservation of at least 6 CAGN pairs within the

on- and off-site preservation areas

12. Restoration of 8 ac CSS in off-site preserve

13. No clearing during breeding season

14. Develop employee education program

15. Shield road lighting from habitat areas

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

8 Calavera Hills 

Phase II

9 La Sierra Avenue &

El Sobrante Road

Improvement Project

10 La Estrella/Nutmeg

Street Extension

11 Rancho Potrero 

Leadership Academy

(Access Road)

12 Hunte Parkway 

Project

Other Listed CAGN Conservation Measures

Pairs Nearest CH Habitat Acres Pairs Species Present

Detected Breeding Site Present Corridor

CAGN Biological Information CAGN Impacts/ITP

7 pairs N/A Yes Regionally 91.2 ac CSS 3 pairs least Bell's vireo 1. Onsite preservation of 87.3 ac CSS (in CH)

significant (65.4 ac in CH) 2. Revegetation of 2.4 ac CSS on site (in CH)

corridor 27.5 ac chaparral 3. Preservation of 35.6 ac CSS in adjacent Calavera 

("Link A" in (19.2 ac in CH) Nature Preserve (in CH)

Carlsbad HMP) 2 ac nonnative grassland 4. Off-site preservation of 51.3 ac CSS

5. Lighting shielded from undeveloped areas

6. biological monitoring 

7. employee education program

8. wildlife undercrossing beneath College Blvd. (not only CAGN)

up to 7 N/A Yes No 3.6 (occ.) 2 Least Bell's Vireo 1. Purchase of 8.8 ac of CSS from Wilson Creek Mit. Bank

nearby 2. Pre-construction surveys to determine CAGN presence

3. Biological monitoring during construction

4. Lighting directed away from natural areas.

One ind. N/A Yes Stepping stone 9.7 ac CH** No Take Least Bell's Vireo 1. Set-aside 254.9 ac (177.4 in CH) at Greer Ranch

observed (Unit 10) (w/in already Authorized In SKR HCP Plan 2. Preserve 10.77 ac Hollingsworth Strip area (in CH) near

onsite* diminished Area Greer Road (thin linkage corridor)

habitat corridor) 3. Restore 10.69 ac of transitional habitat within wildlife

movement corridor (not req'd by USFWS)

"Action Area" 4. Prohibit human activities in preserved areas

also includes 300 graded ac 5. Pet/cat exclusion fencing abutting all residential areas

at Greer Ranch, which and potential access points

had previously avoided 6. Lighting directed away from preservation areas

consultation, but was now 7. Education program for public

included due to "indirect" 8. All clearing will occur outside CAGN breeding season

(gross inducing) effects. 9. Biological monitoring before/during all construction

10. Employee education program

11. Revegation of disturbed areas with RSS

One adult Breeding behavior Yes N/A 46.1 ac CH One pair Arroyo Toad (w/ CH) 1. Preserve 44.1 ac CSS onsite

pair and observed onsite (Unit 6) (14.7 ac CSS) 2. Create 2.1 ac oak woodland onsite

3 juveniles 3. Create 4.8 ac native grassland

4. Avoid grading/construction during breeding season

5. Biological monitoring before/during construction

6. Incl weekly reports during grading and annual surveys

7. Contractor education program

8. Direct lighting away from habitat

One pair Breeding behavior Yes N/A 3.3 ac CH 2 pairs Otay Tarplant 1. Preserve 1.2 ac CSS onsite

on-site observed onsite (Unit 1) (0.6 ac CSS) (and proposed CH) 2. Preserve 3.0 ac non-native grassland onsite

(33 pr in 1200 [incl Otay & Quino Checkerspot 3. Revegetate road boundary adjacent to preserves with

ac ownership Quino proposed Butterfly CH non-native, non-invasive shrubbery (CAGN barrier)

area) CH] (and proposed CH) 4. Preserve-side fill slope planted w/ CSS seed

5. Site grading/construction outside breeding season

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

13 SR-125 South

14 Realignment/

Widening of Laguna

Canyon Rd, SR-133

15 Moreno-Lakeside

Pipeline

16 San Sevaine Creek

Water Project

(Reinitiation)

Other Listed CAGN Conservation Measures

Pairs Nearest CH Habitat Acres Pairs Species Present

Detected Breeding Site Present Corridor

CAGN Biological Information CAGN Impacts/ITP

32 pairs On-site No 60.5 ac CSS 32 pairs least Bell's vireo 1. Off-site preservation of 1,100 total acres CAGN habitat

(prior to (direct) Quino Chkspt Btfly incl 731 ac in Rancho San Diego Mitigation Bank*

2000) 45.2 ac CSS SD fairy shrimp (supporting 32 pairs), and purchase of development rights

(indirect) Otay tarplant 2. Clearing outside breeding season

spreading navarettia 3. Pre-construction surveys and avoidance of nest sites

4. Unauthorized destruction of CSS to be offset at 5:1 ratio

5. Employee education program

6. Biological monitoring during construction

2 pairs (direct) No N/A 21.51 ac CSS 6 pairs least Bell's vireo 1. Implement resource management plan, including surveys,

4 pairs (indirect) (prior to (add'l fragmentation SW willow flycatcher biol monitoring, and noise reduction.

2000) of 16.49 ac CSS)

10 pairs in N/A No N/A 0.54 ac CSS 2 pairs arroyo toad 1. Permanent impacts to 0.54 ac mitigated at 2:1 ratio at

project area (permanent) (and CH) applicant's Crestridge Habitat Management Area

2 pairs in 5.34 ac CSS 2. Temporary impacts to 5.35 ac mitigated through 1:1 

proposed alignment (temporary) revegatation onsite, and 1:1 offsite mitigation at the 

applicant's Crestridge Habitat Management Area

3. Revegetated areas that do not reestablish in 2 yrs will be

mitigated offsite at add'l 1:1 ratio (2:1 overall mitigation)

4. Preconstruction CAGN surveys

5. Biological monitoring during all construction/mitigation

6. CSS grading outside breeding season

7. Develop mitigation/management plan

10 in action N/A Yes Yes 64 ac RASS One pair SBKR (w/ CH) 1. Preservation of 329 to 343 ac (174 contiguous with CAGN

area since (7,272 ac CH; remaining acres primarily for SBKR).

1994 in action 2. Endowment of $1,000/ac for long-term management

area) 3. Revegetate 56 ac (CAGN, SBKR, and others)

4. Long-term Maintenance and Monitoring Plan

5. Biological monitoring before/during construction

6. No clearing during breeding season

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

17 Las Flores Estancia

Camp Pendleton

18 Parking Construction

for Bachelor Enlisted

Quarters

19 Fallbrook Fire

Management Plan

20 Improvement/Use

of Roads, Lots, and

Loading Docks

Other Listed CAGN Conservation Measures

Pairs Nearest CH Habitat Acres Pairs Species Present

Detected Breeding Site Present Corridor

CAGN Biological Information CAGN Impacts/ITP

1 in project N/A No Stepping stone 0.74 ac CSS One pair None 1. Debit 1.48 ac credits (2:1) from Coastal Sage Scrub

site for local Restoration Bank.

dispersal 2. Remove CSS outside breeding season

1 (incidental N/A No N/A 2.21 ac CSS One pair None 1. Debit 4.42 ac credits (2:1) from Coastal Sage Scrub 

sighting; no Restoration Bank.

surveys) 2. Restore 1.18 ac CSS on adjacent slope (part of 2.21 ac)

3. No clearing during breeding season

4. Shield parking lot lighting away from habitat

Throughout N/A No Yes Unknown 5 pairs least Bell's vireo 1. Maintain at least 2,000 ac suitable CSS at all times

project area (2 mortality; SKR 2. Rely on grazing/mowing as preferential fire prevention

3 harass) 3. Only habitat containing fewer than 2 pairs CAGN can be

4. considered for prescribed burns

5. Focused CAGN surveys immediately prior to burns

6. Fire management activities outside breeding season

66 pairs on No 0.22 ac CSS One pair SD Fairy shrimp 1. Mitigate occupied CAGN habitat at 2:1 restoration

base 0.44 ac Chap. (harass) SD button celery 2. Mitigate unoccupied CAGN habitat at 1:1 restoration

0.66 total SD mesa mint 3. Construction outside breeding season

4. No noisy construction w/in 500 ft of nest

5. Biological monitoring

6. Exclusion fencing

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

1 Padova Padua Hills

2 Sycamore Creek

Development

3 Blackmore 

Development

Project

4 Walnut Hills

Voluntary/Recommended

Project Modifications

Salvage/translocate CSS & sensitive plant spp. 0.88:1 non-breed hab pres. Off

Shield lighting adjacent to open space 0.1:1 breed hab restoration

Avoid introducing invasive plants spp.

Management of easement @ $13.5K (Yr1), 0.66:1 onsite

$20K (Yr2-5), and $40K (Yr 6), adj CPI after. 1.8:1 off-site

Original proposal to include picnic benches in 

easement were abandoned

CAGN pairs @ 1:1

RSS @ 2:1 off-site

0.4:1 onsite

Unknown 0.44:1 on-site

0.93:1 creation

Mitigation

Ratio(s))

Effective 

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

5 Spring Mtn. Ranch

Specific Plan

6 Arroyo Trabuco

Golf Course

7 Brookfield Homes/

University Commons

Voluntary/Recommended

Project Modifications Mitigation

Ratio(s))

Effective 

1.09:1 onsite (cons easement)

0.16:1 onsite (open space ded.)

4.55:1 onsite (landfill)

4.64:1 onsite

CAGN pairs @ 2.75:1

0.9:1 onsite

1.45:1 offsite

CSS @ 2:1

grassland @ 2:1

Chaparral @ 1:1

Nonnative grassland @ 0.5:1

CAGN individuals @ 1:1

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

8 Calavera Hills 

Phase II

9 La Sierra Avenue &

El Sobrante Road

Improvement Project

10 La Estrella/Nutmeg

Street Extension

11 Rancho Potrero 

Leadership Academy

(Access Road)

12 Hunte Parkway 

Project

Voluntary/Recommended

Project Modifications Mitigation

Ratio(s))

Effective 

0.96:1 onsite

0.95:1 offsite

0.03:1 restoration

g beneath College Blvd. (not only CAGN)

2.44:1 offsite

0.82:1 on-site

0.03:1 offsite preservation

Project footprint reduced to avoid CH impacts CSS @ 3:1 on-site 

(44.1/14.7=3)

Oak Woodland @ 1:1 on-site

native grassland @ 1:1 on-site

CSS @ 2:1 on-site (1.2/0.6 =2)

Non-native grassland @ 1:1 onsite

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

13 SR-125 South

14 Realignment/

Widening of Laguna

Canyon Rd, SR-133

15 Moreno-Lakeside

Pipeline

16 San Sevaine Creek

Water Project

(Reinitiation)

Voluntary/Recommended

Project Modifications Mitigation

Ratio(s))

Effective 

Informal consultation process included review CSS direct effects @ 2:1 offsite

of 17 build variations for project. Realignments CSS indirect effects @ 1:1

to both northern and southern sections of CAGN pairs @ 1:1 [key factor often 

roadway were selected to avoid significant resulting in larger acreage set-asides 

impacts to CAGN. Project review required than habitat mitigation alone]

considerable time from all participants. (Effective Mit. Ratio of 18.2:1)

Recommend selecting least damaging road Mitigation through Central/Coastal

alignment HCP/NCCP

Recommend measures to minimize roadway 

noise

Recommend wildlife undercrossings

Permanent CSS @ 2:1 offsite

Temporary CSS @ 1:1 offsite

and 1:1 onsite revegetation

(if revegetation fails w/in 2 yrs, 

add'l 1:1 offsite mitigation req'd)

Project footprint reduced by 24 acres. 2.7:1 onsite (174/64)

74 ac habitat no longer isolated by levees 0.4:1 revegetation ([56/2]/64)

Preserve area augmented by 42 acres

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Table C-1

Selected Section 7 Formal Consultations 

No. Project 

Name

17 Las Flores Estancia

Camp Pendleton

18 Parking Construction

for Bachelor Enlisted

Quarters

19 Fallbrook Fire

Management Plan

20 Improvement/Use

of Roads, Lots, and

Loading Docks

Voluntary/Recommended

Project Modifications Mitigation

Ratio(s))

Effective 

USMC should restore/enhance CSS in the CSS @ 2:1 offsite

vicinity of the historic bldg.

USMC should eradicate sweet fennel plants

CSS @ 2:1 offsite

Impacts unknown, so no mit. ratio

USMC continues to develop INRMP addressing Occupied = 2:1 restoration

CAGN. Unoccupied = 1:1 restoration

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APPENDIX D

REAL ESTATE MARKET DATA AND LAND VALUE

CALCULATIONS
Table D-1

Residential Land Value Calculations by County

Measure Los Angeles Orange Riverside San Bernardino San Diego Ventura

Average Home Sales Price (1) $394,230 $464,304 $250,923 $202,240 $410,435 $415,458

Housing Acreage Distribution (2)

Single Family, Detached $226,994 $69,413 $50,822 $59,850 $75,135 $22,714

Single Family, Attached $21,195 $10,918 $3,989 $2,296 $8,840 $2,683

Multi-Family, 2-4 Units $19,126 $5,835 $1,832 $2,674 $5,036 $1,011

Multi-Family, 5+ Units $56,430 $12,584 $4,070 $4,173 $15,106 $1,939

Total $323,744 $98,750 $60,713 $68,994 $104,117 $28,348

Units / Gross Ac. (Weighted Avg.)[3] $9.93 $9.46 $8.31 $8.20 $9.53 $8.46

Market Value per Gross Acre $3,916,654 $4,392,812 $2,085,156 $1,657,608 $3,910,551 $3,514,263

Residual Value per Vacant Gross Ac.(4) $391,665 $439,281 $208,516 $165,761 $391,055 $351,426

Residual Value per Vacant GSF $8.99 $10.08 $4.79 $3.81 $8.98 $8.07

(1) From Table 10

(2) Calculated by multiplying the number of housing units of each type in 2000 (DOF Table E-5a) 

 by the following assumed unit-per-acre estimates: single family detached: 7

single family attached: 10

multi-family (2-4 units): 15

multi-family (5+ units): 20

(3) Average of unit-per-acre assumptions in footnote (2), weighted by housing acreage distribution.

(4) Assumes value of vacant land zoned for development (but otherwise unentitled) is 10% percent of total market value.

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Table D-2

Office and Industrial Land Value Calculations by County

Measure Los Angeles Orange Riverside San Bernardino San Diego Ventura

Office 

Sales Price ($/Leasable SqFt) (1) $193 $220 $125 $125 $195 $175

Parcel Price per Net SqFt (2) $68 $77 $44 $44 $68 $61

Parcel Price per Gross SqFt (3) $54 $62 $35 $35 $54 $49

Market Value per Gross Acre $2,356,079 $2,683,296 $1,524,600 $1,524,600 $2,373,741 $2,134,440

Residual Value per Vacant Gross Ac.(4) $235,608 $268,330 $152,460 $152,460 $237,374 $213,444

Residual Value per Vacant GSF $5.41 $6.16 $3.50 $3.50 $5.45 $4.90

Industrial 

Sales Price ($/Leasable SqFt) (1) $43 $59 $41 $41 $65 $69

Parcel Price per Net SqFt (5) $10.86 $14.70 $10.25 $10.25 $16.25 $17.18

Parcel Price per Gross SqFt (3) $8.69 $11.76 $8.20 $8.20 $13.00 $13.74

Market Value per Gross Acre $378,381 $512,266 $357,192 $357,192 $566,280 $598,689

Residual Value per Vacant Gross Ac.(4) $37,838 $51,227 $35,719 $35,719 $56,628 $59,869

Residual Value per Vacant GSF $0.87 $1.18 $0.82 $0.82 $1.30 $1.37

Reported Unimproved Land Value (1) $5.00 -- $4.00 $4.00 $4.00 --

(1) From Table 1

(2) Assumes floor area ratio (FAR) of 0.35 for office space.

(3) Assumes net-to-gross ratio of 0.80 to account for associated infrastructure (roads, sidewalks, etc.).

(4) Assumes value of vacant land zoned for development (but otherwise unentitled) is 10% of total market value.

(5) Assumes floor area ratio (FAR) of 0.25 for industrial space.

Source: Economic & Planning Systems, Inc.

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Table D-3

Retail Land Value Calculations by County

Measure Los Angeles Orange Riverside San Bernardino San Diego Ventura

Sales Price ($/Leasable SqFt) (1) $144 $142 $108 $108 $124 $144

Parcel Price per Net SqFt (2) $43 $43 $32 $32 $37 $43

Parcel Price per Gross SqFt (3) $35 $34 $26 $26 $30 $35

Market Value per Gross Acre $1,505,434 $1,484,525 $1,129,075 $1,129,075 $1,296,346 $1,505,434

Residual Value per Vacant Gross Ac.(4) $150,543 $148,452 $112,908 $112,908 $129,635 $150,543

Residual Value per Vacant GSF $3.46 $3.41 $2.59 $2.59 $2.98 $3.46

(1) From Table 10

(2) Assumes floor area ratio (FAR) of 0.3 for office space.

(3) Assumes net-to-gross ratio of 0.80 to account for associated infrastructure (roads, sidewalks, etc.).

(4) Assumes value of vacant land zoned for development (but otherwise unentitled) is 10% of total market value.

Source: Economic & Planning Systems, Inc.

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
APPENDIX E

PROJECT MODIFICATION COST CALCULATIONS FOR

PRIVATE LAND DEVELOPMENT
Table E-1

Projected Development in Proposed Critical Habitat Regulated Under Section 7 (1)

Proposed 

Critical Single Family Multi-Family Mobile Home Total

Habitat Unit Residential Residential Residential

Critical Habitat Unit 1 (5)

San Diego -- -- -- 64

Critical Habitat Unit 2

San Diego 58 0 0 58

Critical Habitat Unit 3

San Diego 183 6 0 189

Critical Habitat Unit 4

San Diego 0 0 0 0

Critical Habitat Unit 5

San Diego -- -- -- 286

Critical Habitat Unit 6

Orange 373 50 3 426

San Diego 0 0 0 0

Critical Habitat Unit 7

Orange (6) -- -- -- 32

Residential Growth Acres Regulated by Section 7 (1)

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Table E-1

Projected Development in Proposed Critical Habitat Regulated Under Section 7 (1)

Proposed 

Critical Single Family Multi-Family Mobile Home Total

Habitat Unit Residential Residential Residential

Residential Growth Acres Regulated by Section 7 (1)

Critical Habitat Unit 8

Los Angeles 0 0 0 0

Critical Habitat Unit 9

Los Angeles 58 16 5 80

Orange 71 9 3 83

Riverside 0 0 0 0

San Bernardino 6 1 0 7

Critical Habitat Unit 10

Orange 0 0 0 0

Riverside 2,039 106 401 2,546

San Bernardino 293 32 19 344

San Diego 0 0 0 0

Critical Habitat Unit 11

San Bernardino 390 12 16 417

Critical Habitat Unit 12

Los Angeles 8 3 1 11

Critical Habitat Unit 13

Los Angeles 835 155 81 1,071

Ventura 136 17 6 159

Total Acres 4,451 406 535 5,774

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Table E-1

Projected Development in Proposed Critical Habitat Regulated Under Section 7 (1)

Proposed 

Critical 

Habitat Unit

Critical Habitat Unit 1 (5)

San Diego

Critical Habitat Unit 2

San Diego

Critical Habitat Unit 3

San Diego

Critical Habitat Unit 4

San Diego

Critical Habitat Unit 5

San Diego

Critical Habitat Unit 6

Orange

San Diego

Critical Habitat Unit 7

Orange (6)

Office Commercial Industrial Retail Services Other Total Total Total

"Office" (2) "Industrial" (3) "Retail" (4)

-- -- -- -- -- -- 0 5 2

0 0 0 -- -- 0 0 0 0

1 9 15 -- -- 0 1 15 9

0 0 0 -- -- 0 0 0 0

-- -- -- -- -- -- 0 2 4

-- -- 0 0 0 0 0 0 0

0 0 0 -- -- 0 0 0 0

-- -- -- -- -- -- 16 48 5

Commercial Growth Acres Regulated by Section 7 (1)

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Table E-1

Projected Development in Proposed Critical Habitat Regulated Under Section 7 (1)

Proposed 

Critical 

Habitat Unit

Critical Habitat Unit 8

Los Angeles

Critical Habitat Unit 9

Los Angeles

Orange

Riverside

San Bernardino

Critical Habitat Unit 10

Orange

Riverside

San Bernardino

San Diego

Critical Habitat Unit 11

San Bernardino

Critical Habitat Unit 12

Los Angeles

Critical Habitat Unit 13

Los Angeles

Ventura

Total Acres

Office Commercial Industrial Retail Services Other Total Total Total

"Office" (2) "Industrial" (3) "Retail" (4)

Commercial Growth Acres Regulated by Section 7 (1)

-- -- 0 0 0 0 0 0 0

-- -- 93 46 171 11 171 104 46

-- -- 115 65 206 24 206 139 65

-- -- 0 0 0 0 0 0 0

-- -- 13 9 24 3 24 16 9

-- -- 0 0 1 0 1 0 0

-- -- 2,184 2,218 5,754 1,283 5,754 3,467 2,218

-- -- 22 4 19 -1 19 21 4

0 0 0 -- -- 0 0 0 0

-- -- 640 448 1,195 158 1,195 797 448

-- -- 35 18 66 4 66 40 18

-- -- 666 338 1,260 82 1,260 748 338

-- -- 524 381 1,134 134 1,134 658 381

1 9 4,309 3,528 9,830 1,699 9,847 6,063 3,549

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual 2003 2004 2005 2006 2007

Growth Acres (2) Set-aside Land Value (3) 1 2 3 4 5

Critical Habitat Unit 1

Acres San Diego 0.06 :1 64 4 $391,055 Acres 0.15 0.15 0.15 0.15 0.15

Units Annual Cost $59,730 $59,730 $59,730 $59,730 $59,730

NPV $461,019

Critical Habitat Unit 2

Acres San Diego 0.06 :1 58 3 $391,055 Acres 0.14 0.14 0.14 0.14 0.14

Units Annual Cost $53,617 $53,617 $53,617 $53,617 $53,617

NPV $413,838

Critical Habitat Unit 3

Acres San Diego 0.06 :1 189 10 $391,055 Acres 0.45 0.45 0.45 0.45 0.45

Units Annual Cost $176,269 $176,269 $176,269 $176,269 $176,269

NPV $1,360,519

Critical Habitat Unit 4

Acres San Diego 0.06 :1 0 0 $391,055 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $150 $150 $150 $150 $150

NPV $1,160

Critical Habitat Unit 5

Acres San Diego 0.06 :1 286 16 $391,055 Acres 0.68 0.68 0.68 0.68 0.68

Units Annual Cost $266,790 $266,790 $266,790 $266,790 $266,790

NPV $2,059,198

Critical Habitat Unit 6

Acres Orange 1.82 :1 426 275 $439,281 Acres 11.96 11.96 11.96 11.96 11.96

Units Annual Cost $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546

Acres San Diego 0.06 :1 0 0 $391,055 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $12 $12 $12 $12 $12

Total NPV $40,541,515

Critical Habitat Unit 7

Acres Orange 1.82 :1 32 20 $439,281 Acres 0.89 0.89 0.89 0.89 0.89

Units Annual Cost $388,987 $388,987 $388,987 $388,987 $388,987

NPV $3,002,368

Critical Habitat Unit 8

Acres Los Angeles 0.44 :1 0 0 $391,665 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.44 :1 80 24 $391,665 Acres 1.06 1.06 1.06 1.06 1.06

Units Annual Cost $414,360 $414,360 $414,360 $414,360 $414,360

Acres Orange 1.82 :1 83 54 $439,281 Acres 2.33 2.33 2.33 2.33 2.33

Units Annual Cost $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166

Acres Riverside 1.14 :1 0.1 0.1 $208,516 Acres 0.003 0.003 0.003 0.003 0.003

Units Annual Cost $529 $529 $529 $529 $529

Acres San Bernardino 2.70 :1 7 5 $165,761 Acres 0.23 0.23 0.23 0.23 0.23

Units Annual Cost $38,021 $38,021 $38,021 $38,021 $38,021

Total NPV $11,385,286

Critical Habitat Unit 10

Effective

On-site 

Mitigation 

Projected Residential Development

Ratio (1)

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual 2003 2004 2005 2006 2007

Growth Acres (2) Set-aside Land Value (3) 1 2 3 4 5

Effective

On-site 

Mitigation 

Projected Residential Development

Ratio (1)

Acres Orange 1.82 :1 0.4 0.2 $439,281 Acres 0.01 0.01 0.01 0.01 0.01

Units Annual Cost $4,592 $4,592 $4,592 $4,592 $4,592

Acres Riverside 1.14 :1 2,546 1,358 $208,516 Acres 59.04 59.04 59.04 59.04 59.04

Units Annual Cost $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202

Acres San Bernardino 2.70 :1 344 251 $165,761 Acres 10.91 10.91 10.91 10.91 10.91

Units Annual Cost $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836

Acres San Diego 0.06 :1 0 0 $391,055 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $111 $111 $111 $111 $111

Total NPV $109,020,874

Critical Habitat Unit 11

Acres San Bernardino 2.70 :1 417 305 $165,761 Acres 13.24 13.24 13.24 13.24 13.24

Units Annual Cost $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559

NPV $16,938,559

Critical Habitat Unit 12

Acres Los Angeles 0.44 :1 11 3 $391,665 Acres 0.15 0.15 0.15 0.15 0.15

Units Annual Cost $59,600 $59,600 $59,600 $59,600 $59,600

NPV $460,019

Critical Habitat Unit 13

Acres Los Angeles 0.44 :1 1,071 327 $391,665 Acres 14.23 14.23 14.23 14.23 14.23

Units Annual Cost $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503

Acres Ventura 0.44 :1 159 49 $351,426 Acres 2.11 2.11 2.11 2.11 2.11

Units Annual Cost $742,146 $742,146 $742,146 $742,146 $742,146

Total NPV $48,754,636

Total NPV, All Units:

(1) For San Diego and Orange counties, the Effective Mitigation Ratio is the County-specific on-site mitigation ratio summarized in Table 11 minus an assumed CEQA 

 mitigation ratio of 2-to-1. For all other counties, the Effective Mitigation Ratio is the ratio reported in Table 11.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura involving the CAGN.

(2) Table E-1

(3) Table D-1

(4) Assumes projected development is distributed evenly throughout 2025.

$234,398,990

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Set-Aside Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15

$59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730

0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14

$53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617

0.45 0.45 0.45 0.45 0.45 0.45 0.45 0.45 0.45 0.45

$176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$150 $150 $150 $150 $150 $150 $150 $150 $150 $150

0.68 0.68 0.68 0.68 0.68 0.68 0.68 0.68 0.68 0.68

$266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790

11.96 11.96 11.96 11.96 11.96 11.96 11.96 11.96 11.96 11.96

$5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$12 $12 $12 $12 $12 $12 $12 $12 $12 $12

0.89 0.89 0.89 0.89 0.89 0.89 0.89 0.89 0.89 0.89

$388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06

$414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360

2.33 2.33 2.33 2.33 2.33 2.33 2.33 2.33 2.33 2.33

$1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166

0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003

$529 $529 $529 $529 $529 $529 $529 $529 $529 $529

0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23

$38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Set-Aside Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592

59.04 59.04 59.04 59.04 59.04 59.04 59.04 59.04 59.04 59.04

$12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202

10.91 10.91 10.91 10.91 10.91 10.91 10.91 10.91 10.91 10.91

$1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$111 $111 $111 $111 $111 $111 $111 $111 $111 $111

13.24 13.24 13.24 13.24 13.24 13.24 13.24 13.24 13.24 13.24

$2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559

0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15

$59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600

14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23

$5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503

2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11

$742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Set-Aside Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15

$59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730 $59,730

0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14

$53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617 $53,617

0.45 0.45 0.45 0.45 0.45 0.45 0.45 0.45

$176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269 $176,269

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$150 $150 $150 $150 $150 $150 $150 $150

0.68 0.68 0.68 0.68 0.68 0.68 0.68 0.68

$266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790 $266,790

11.96 11.96 11.96 11.96 11.96 11.96 11.96 11.96

$5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546 $5,252,546

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$12 $12 $12 $12 $12 $12 $12 $12

0.89 0.89 0.89 0.89 0.89 0.89 0.89 0.89

$388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987 $388,987

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06

$414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360 $414,360

2.33 2.33 2.33 2.33 2.33 2.33 2.33 2.33

$1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166 $1,022,166

0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003

$529 $529 $529 $529 $529 $529 $529 $529

0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23

$38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021 $38,021

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Table E-2

On-site Set-aside Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Set-Aside Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592 $4,592

59.04 59.04 59.04 59.04 59.04 59.04 59.04 59.04

$12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202 $12,311,202

10.91 10.91 10.91 10.91 10.91 10.91 10.91 10.91

$1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836 $1,808,836

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$111 $111 $111 $111 $111 $111 $111 $111

13.24 13.24 13.24 13.24 13.24 13.24 13.24 13.24

$2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559 $2,194,559

0.15 0.15 0.15 0.15 0.15 0.15 0.15 0.15

$59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600 $59,600

14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23

$5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503 $5,574,503

2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11

$742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146 $742,146

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per 2003 2004 2005 2006 2007

Developed (2) Preserved Mitigation Acre (3) 1 2 3 4 5

Critical Habitat Unit 1

Acres San Diego 0.00 :1 61 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 54 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 179 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 271 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 151 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 11 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.00 :1 0 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.00 :1 55 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Orange 0.00 :1 29 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 1.22 :1 0 0 $9,500 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Bernardino 0.00 :1 2 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 10

Off-site 

Mitigation 

Ratio (1)

Projected Residential Development

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Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per 2003 2004 2005 2006 2007

Developed (2) Preserved Mitigation Acre (3) 1 2 3 4 5

Off-site 

Mitigation 

Ratio (1)

Projected Residential Development

Acres Orange 0.00 :1 0 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 1.22 :1 1,188 1,453 $9,500 Acres 63.17 63.17 63.17 63.17 63.17

Units Annual Cost $600,147 $600,147 $600,147 $600,147 $600,147

Acres San Bernardino 0.00 :1 93 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $4,632,192

Critical Habitat Unit 11

Acres San Bernardino 0.00 :1 113 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 12

Acres Los Angeles 0.00 :1 8 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 13

Acres Los Angeles 0.00 :1 744 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Ventura 0.00 :1 110 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Total NPV, All Units:

(1) For San Diego and Orange counties, all mitigation above CEQA baseline is assumed to be on-site. The off-site mitigation ratio is therefore assumed to be zero. 

For the remaining counties, the mitigation ratio is from a review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios in Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura 

involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$4,632,192

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Preservation Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

6 7 8 9 10 11 12 13 14 15 16

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

6 7 8 9 10 11 12 13 14 15 16

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

63.17 63.17 63.17 63.17 63.17 63.17 63.17 63.17 63.17 63.17 63.17

$600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Preservation Calculations by Year (4)

2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-3

Off-site Preservation Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

63.17 63.17 63.17 63.17 63.17 63.17 63.17

$600,147 $600,147 $600,147 $600,147 $600,147 $600,147 $600,147

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration 2003 2004 2005 2006

Developed (2) Restored Cost per Acre (3) 1 2 3 4

Critical Habitat Unit 1

Acres San Diego 0.00 :1 61 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 54 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 179 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 271 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 151 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 11 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.93 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.93 :1 55 51.43 $30,000 Acres 2.24 2.24 2.24 2.24

Units Annual Cost $67,083 $67,083 $67,083 $67,083

Acres Orange 0.00 :1 29 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Acres Riverside 0.00 :1 2 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Acres San Bernardino 0.40 :1 2 0.78 $30,000 Acres 0.03 0.03 0.03 0.03

Units Annual Cost $1,019 $1,019 $1,019 $1,019

Restoration

Mitigation 

Ratio (1)

Projected Residential Development

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration 2003 2004 2005 2006

Developed (2) Restored Cost per Acre (3) 1 2 3 4

Restoration

Mitigation 

Ratio (1)

Projected Residential Development

Total NPV $525,647

Critical Habitat Unit 10

Acres Orange 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Acres Riverside 0.00 :1 1,188 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Acres San Bernardino 0.40 :1 93 37.18 $30,000 Acres 1.62 1.62 1.62 1.62

Units Annual Cost $48,499 $48,499 $48,499 $48,499

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0

Total NPV $374,338

Critical Habitat Unit 11

Acres San Bernardino 0.40 :1 113 45.11 $30,000 Acres 1.96 1.96 1.96 1.96

Units Annual Cost $58,841 $58,841 $58,841 $58,841

NPV $454,163

Critical Habitat Unit 12

Acres Los Angeles 0.93 :1 8 7.40 $30,000 Acres 0.32 0.32 0.32 0.32

Units Annual Cost $9,649 $9,649 $9,649 $9,649

NPV $74,475

Critical Habitat Unit 13

Acres Los Angeles 0.93 :1 744 691.91 $30,000 Acres 30.08 30.08 30.08 30.08

Units Annual Cost $902,490 $902,490 $902,490 $902,490

Acres Ventura 0.93 :1 110 102.66 $30,000 Acres 4.46 4.46 4.46 4.46

Units Annual Cost $133,908 $133,908 $133,908 $133,908

Total NPV $7,999,371

Total NPV, All Units:

(1) Based on review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for 

projects in Ventura involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$9,427,994

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

2.24 2.24 2.24 2.24 2.24 2.24 2.24 2.24 2.24 2.24

$67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

$1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

1.62 1.62 1.62 1.62 1.62 1.62 1.62 1.62 1.62 1.62

$48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

1.96 1.96 1.96 1.96 1.96 1.96 1.96 1.96 1.96 1.96

$58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841

0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32

$9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649

30.08 30.08 30.08 30.08 30.08 30.08 30.08 30.08 30.08 30.08

$902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490

4.46 4.46 4.46 4.46 4.46 4.46 4.46 4.46 4.46 4.46

$133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

2.24 2.24 2.24 2.24 2.24 2.24 2.24 2.24 2.24

$67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083 $67,083

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

$1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019 $1,019

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-4

CSS Restoration Calculations for Projected Residential Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

1.62 1.62 1.62 1.62 1.62 1.62 1.62 1.62 1.62

$48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499 $48,499

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

1.96 1.96 1.96 1.96 1.96 1.96 1.96 1.96 1.96

$58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841 $58,841

0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32 0.32

$9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649 $9,649

30.08 30.08 30.08 30.08 30.08 30.08 30.08 30.08 30.08

$902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490 $902,490

4.46 4.46 4.46 4.46 4.46 4.46 4.46 4.46 4.46

$133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908 $133,908

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual Acres Acres Per-acre Residual 2003 2004

Growth Acres (2) Set-aside Land Value (3) Impacted (2) Set-aside Land Value (3) 1 2

Critical Habitat Unit 1

Acres San Diego 0.06 :1 0 0 $237,374 5 0 $56,628 Acres 0.01 0.01

Units Annual Cost $774 $774

NPV $5,970

Critical Habitat Unit 2

Acres San Diego 0.06 :1 0 0 $237,374 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $17 $17

NPV $131

Critical Habitat Unit 3

Acres San Diego 0.06 :1 1 0 $237,374 15 1 $56,628 Acres 0.04 0.04

Units Annual Cost $2,771 $2,771

NPV $21,389

Critical Habitat Unit 4

Acres San Diego 0.06 :1 0 0 $237,374 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $2 $2

NPV $19

Critical Habitat Unit 5

Acres San Diego 0.06 :1 0 0 $237,374 2 0 $56,628 Acres 0.01 0.01

Units Annual Cost $292 $292

NPV $2,254

Critical Habitat Unit 6

Acres Orange 1.82 :1 0 0 $268,330 0 0 $51,227 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Diego 0.06 :1 0 0 $237,374 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 1.82 :1 16 10 $268,330 48 31 $51,227 Acres 1.77 1.77

Units Annual Cost $185,758 $185,758

NPV $1,433,758

Critical Habitat Unit 8

Acres Los Angeles 0.44 :1 0 0 $235,608 0 0 $37,838 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.44 :1 171 52 $235,608 104 32 $37,838 Acres 3.66 3.66

Units Annual Cost $588,268 $588,268

Acres Orange 1.82 :1 206 133 $268,330 139 90 $51,227 Acres 9.68 9.68

Units Annual Cost $1,748,819 $1,748,819

Acres Riverside 1.14 :1 0 0 $152,460 0 0 $35,719 Acres 0.01 0.01

Units Annual Cost $1,369 $1,369

Acres San Bernardino 2.70 :1 24 17 $152,460 16 12 $35,719 Acres 1.26 1.26

Units Annual Cost $133,278 $133,278

Total NPV $19,077,909

Projected Industrial Development

Ratio (1)

On-site 

Mitigation 

Projected Office Development

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual Acres Acres Per-acre Residual 2003 2004

Growth Acres (2) Set-aside Land Value (3) Impacted (2) Set-aside Land Value (3) 1 2

Projected Industrial Development

Ratio (1)

On-site 

Mitigation 

Projected Office Development

Critical Habitat Unit 10

Acres Orange 1.82 :1 1 0 $268,330 0 0 $51,227 Acres 0.03 0.03

Units Annual Cost $5,808 $5,808

Acres Riverside 1.14 :1 5,754 3,069 $152,460 3,467 1,850 $35,719 Acres 213.88 213.88

Units Annual Cost $23,219,256 $23,219,256

Acres San Bernardino 2.70 :1 19 14 $152,460 21 16 $35,719 Acres 1.29 1.29

Units Annual Cost $117,515 $117,515

Acres San Diego 0.06 :1 0 0 $237,374 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $180,168,151

Critical Habitat Unit 11

Acres San Bernardino 2.70 :1 1,195 872 $152,460 797 582 $35,719 Acres 63.21 63.21

Units Annual Cost $6,682,889 $6,682,889

NPV $51,581,437

Critical Habitat Unit 12

Acres Los Angeles 0.44 :1 66 20 $235,608 40 12 $37,838 Acres 1.41 1.41

Units Annual Cost $227,597 $227,597

NPV $1,756,691

Critical Habitat Unit 13

Acres Los Angeles 0.44 :1 1,260 385 $235,608 748 229 $37,838 Acres 26.68 26.68

Units Annual Cost $4,320,610 $4,320,610

Acres Ventura 0.44 :1 1,134 346 $213,444 658 201 $59,869 Acres 23.81 23.81

Units Annual Cost $3,738,432 $3,738,432

Total NPV $62,203,177

Total NPV, All Units $316,250,887

(1) For San Diego and Orange counties, the Effective Mitigation Ratio is the County-specific on-site mitigation ratio summarized in Table 11 minus an assumed CEQA 

 mitigation ratio of 2-to-1. For all other counties, the Effective Mitigation Ratio is the ratio reported in Table 11.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura involving the CAGN. Ventura involving the CAGN.

(2) Table E-1

(3) Table D-1

(4) Assumes projected development is distributed evenly throughout 2025.

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Set-Aside Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$774 $774 $774 $774 $774 $774 $774 $774 $774 $774 $774 $774

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$17 $17 $17 $17 $17 $17 $17 $17 $17 $17 $17 $17

0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04

$2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$2 $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 $2

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$292 $292 $292 $292 $292 $292 $292 $292 $292 $292 $292 $292

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77

$185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66

$588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268

9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68

$1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369

1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26

$133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units $316,250,887

Set-Aside Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

$5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808

213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88

$23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256

1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29

$117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21

$6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889

1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41

$227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597

26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68

$4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610

23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81

$3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Set-Aside Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$774 $774 $774 $774 $774 $774 $774 $774 $774

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$17 $17 $17 $17 $17 $17 $17 $17 $17

0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04

$2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771 $2,771

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$2 $2 $2 $2 $2 $2 $2 $2 $2

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$292 $292 $292 $292 $292 $292 $292 $292 $292

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77 1.77

$185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758 $185,758

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66 3.66

$588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268 $588,268

9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68 9.68

$1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819 $1,748,819

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369 $1,369

1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26

$133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278 $133,278

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-5

On-site Set-aside Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units $316,250,887

Set-Aside Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

$5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808 $5,808

213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88 213.88

$23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256 $23,219,256

1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29

$117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515 $117,515

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21 63.21

$6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889 $6,682,889

1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41 1.41

$227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597 $227,597

26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68 26.68

$4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610 $4,320,610

23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81 23.81

$3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432 $3,738,432

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per Projected Acres Acres Per-acre Residual 2003 2004

Developed (2) Preserved Mitigation Acre (3) Developed (2) Preserved Land Value (3) 1 2

Critical Habitat Unit 1

Acres San Diego 0.00 :1 0 0 $19,750 5 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 0 0 $19,750 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 1 0 $19,750 14 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0 $19,750 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 0 0 $19,750 2 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 0 0 $78,333 0 0 $51,227 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 6 0 $78,333 17 0 $51,227 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.00 :1 0 0 $0 0 0 $37,838 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.00 :1 119 0 $0 72 0 $37,838 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Orange 0.00 :1 73 0 $78,333 49 0 $51,227 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Riverside 1.22 :1 0 0 $9,500 0 0 $35,719 Acres 0.01 0.01

Units Annual Cost $261 $261

Acres San Bernardino 0.00 :1 6 0 $0 4 0 $35,719 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $2,016

Projected Office Development Projected Industrial Development

Ratio (1)

Off-site 

Mitigation 

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Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per Projected Acres Acres Per-acre Residual 2003 2004

Developed (2) Preserved Mitigation Acre (3) Developed (2) Preserved Land Value (3) 1 2

Projected Office Development Projected Industrial Development

Ratio (1)

Off-site 

Mitigation 

Critical Habitat Unit 10

Acres Orange 0.00 :1 0 0 $78,333 0 0 $51,227 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Riverside 1.22 :1 2,685 3,284 $9,500 1,618 1,979 $35,719 Acres 228.84 228.84

Units Annual Cost $4,430,084 $4,430,084

Acres San Bernardino 0.00 :1 5 0 $0 6 0 $35,719 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 0 0 $56,628 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $34,193,311

Critical Habitat Unit 11

Acres San Bernardino 0.00 :1 323 0 $0 216 0 $35,719 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 12

Acres Los Angeles 0.00 :1 46 0 $0 27 0 $37,838 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 13

Acres Los Angeles 0.00 :1 875 0 $0 520 0 $37,838 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Ventura 0.00 :1 787 0 $0 457 0 $59,869 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $0

Total NPV, All Units:

(1) For San Diego and Orange counties, all mitigation above CEQA baseline is assumed to be on-site. The off-site mitigation ratio is therefore assumed to be zero. 

For the remaining counties, the mitigation ratio is from a review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios in Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura 

involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$34,195,327

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Preservation Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$261 $261 $261 $261 $261 $261 $261 $261 $261 $261 $261 $261

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84

$4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Preservation Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$261 $261 $261 $261 $261 $261 $261 $261 $261

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-6

Off-site Preservation Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84 228.84

$4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084 $4,430,084

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration Projected Acres Acres Avg. Restoration 2003 2004

Developed (2) Restored Cost per Acre (3) Developed (2) Restored Cost per Acre (3) 1 2

Critical Habitat Unit 1

Acres San Diego 0.00 :1 0 0.00 $30,000 5 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 1 0.00 $30,000 14 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 0 0.00 $30,000 2 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Diego 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 6 0.00 $30,000 17 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.93 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.93 :1 119 110.55 $30,000 72 67.42 $30,000 Acres 7.74 7.74

Units Annual Cost $232,140 $232,140

Acres Orange 0.00 :1 73 0.00 $30,000 49 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Riverside 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Bernardino 0.40 :1 6 2.58 $30,000 4 1.72 $30,000 Acres 0.19 0.19

Units Annual Cost $5,602 $5,602

Total NPV $1,835,000

Projected Office Development Projected Industrial Development

Ratio (1)

Restoration

Mitigation 

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration Projected Acres Acres Avg. Restoration 2003 2004

Developed (2) Restored Cost per Acre (3) Developed (2) Restored Cost per Acre (3) 1 2

Projected Office Development Projected Industrial Development

Ratio (1)

Restoration

Mitigation 

Critical Habitat Unit 10

Acres Orange 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres Riverside 0.00 :1 2,685 0.00 $30,000 1,618 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Acres San Bernardino 0.40 :1 5 2.09 $30,000 6 2.30 $30,000 Acres 0.19 0.19

Units Annual Cost $5,720 $5,720

Acres San Diego 0.00 :1 0 0.00 $30,000 0 0.00 $30,000 Acres 0.00 0.00

Units Annual Cost $0 $0

Total NPV $44,151

Critical Habitat Unit 11

Acres San Bernardino 0.40 :1 323 129.16 $30,000 216 86.21 $30,000 Acres 9.36 9.36

Units Annual Cost $280,922 $280,922

NPV $2,168,281

Critical Habitat Unit 12

Acres Los Angeles 0.93 :1 46 42.86 $30,000 27 25.52 $30,000 Acres 2.97 2.97

Units Annual Cost $89,192 $89,192

NPV $688,423

Critical Habitat Unit 13

Acres Los Angeles 0.93 :1 875 813.89 $30,000 520 483.16 $30,000 Acres 56.39 56.39

Units Annual Cost $1,691,807 $1,691,807

Acres Ventura 0.93 :1 787 732.23 $30,000 457 425.08 $30,000 Acres 50.32 50.32

Units Annual Cost $1,509,534 $1,509,534

Total NPV $24,709,337

Total NPV, All Units:

(1) Based on review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for 

projects in Ventura involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$29,445,192

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74

$232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19

$5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

3 4 5 6 7 8 9 10 11 12 13 14

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19

$5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36

$280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922

2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97

$89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192

56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39

$1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807

50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32

$1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74 7.74

$232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140 $232,140

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19

$5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602 $5,602

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-7

CSS Restoration Calculations for Projected Commercial Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2017 2018 2019 2020 2021 2022 2023 2024 2025

15 16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19 0.19

$5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720 $5,720

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0

9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36 9.36

$280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922 $280,922

2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97 2.97

$89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192 $89,192

56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39 56.39

$1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807 $1,691,807

50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32 50.32

$1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534 $1,509,534

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual 2003 2004 2005 2006 2007

Growth Acres (2) Set-aside Land Value (3) 1 2 3 4 5

Critical Habitat Unit 1

Acres San Diego 0.06 :1 2 0 $129,635 Acres 0.01 0.01 0.01 0.01 0.01

Units Annual Cost $729 $729 $729 $729 $729

NPV $5,626

Critical Habitat Unit 2

Acres San Diego 0.06 :1 0 0 $129,635 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $43 $43 $43 $43 $43

NPV $332

Critical Habitat Unit 3

Acres San Diego 0.06 :1 9 1 $129,635 Acres 0.02 0.02 0.02 0.02 0.02

Units Annual Cost $2,827 $2,827 $2,827 $2,827 $2,827

NPV $21,822

Critical Habitat Unit 4

Acres San Diego 0.06 :1 0 0 $129,635 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $1

Critical Habitat Unit 5

Acres San Diego 0.06 :1 4 0 $129,635 Acres 0.01 0.01 0.01 0.01 0.01

Units Annual Cost $1,258 $1,258 $1,258 $1,258 $1,258

NPV $9,713

Critical Habitat Unit 6

Acres Orange 1.82 :1 0 0 $148,452 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.06 :1 0 0 $129,635 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $3

Critical Habitat Unit 7

Acres Orange 1.82 :1 5 3 $148,452 Acres 0.14 0.14 0.14 0.14 0.14

Units Annual Cost $21,263 $21,263 $21,263 $21,263 $21,263

NPV $164,115

Critical Habitat Unit 8

Acres Los Angeles 0.44 :1 0 0 $150,543 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.44 :1 46 14 $150,543 Acres 0.61 0.61 0.61 0.61 0.61

Units Annual Cost $91,850 $91,850 $91,850 $91,850 $91,850

Acres Orange 1.82 :1 65 42 $148,452 Acres 1.83 1.83 1.83 1.83 1.83

Units Annual Cost $271,751 $271,751 $271,751 $271,751 $271,751

Acres Riverside 1.14 :1 0.1 0.1 $112,908 Acres 0.003 0.003 0.003 0.003 0.003

Units Annual Cost $343 $343 $343 $343 $343

Acres San Bernardino 2.70 :1 9 7 $112,908 Acres 0.28 0.28 0.28 0.28 0.28

Units Annual Cost $32,039 $32,039 $32,039 $32,039 $32,039

Total NPV $3,056,371

Critical Habitat Unit 10

Acres Orange 1.82 :1 0.2 0.1 $148,452 Acres 0.01 0.01 0.01 0.01 0.01

On-site 

Mitigation 

Ratio (1)

Projected Residential Development

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County Set-Aside Calculations by Year (4)

Habitat Unit Projected Acres Per-acre Residual 2003 2004 2005 2006 2007

Growth Acres (2) Set-aside Land Value (3) 1 2 3 4 5

On-site 

Mitigation 

Ratio (1)

Projected Residential Development

Units Annual Cost $901 $901 $901 $901 $901

Acres Riverside 1.14 :1 2,218 1,183 $112,908 Acres 51.44 51.44 51.44 51.44 51.44

Units Annual Cost $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223

Acres San Bernardino 2.70 :1 4 3 $112,908 Acres 0.13 0.13 0.13 0.13 0.13

Units Annual Cost $14,543 $14,543 $14,543 $14,543 $14,543

Acres San Diego 0.06 :1 0 0 $129,635 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $1 $1 $1 $1 $1

Total NPV $44,949,597

Critical Habitat Unit 11

Acres San Bernardino 2.70 :1 448 327 $112,908 Acres 14.23 14.23 14.23 14.23 14.23

Units Annual Cost $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451

NPV $12,399,283

Critical Habitat Unit 12

Acres Los Angeles 0.44 :1 18 5 $150,543 Acres 0.24 0.24 0.24 0.24 0.24

Units Annual Cost $35,563 $35,563 $35,563 $35,563 $35,563

NPV $274,487

Critical Habitat Unit 13

Acres Los Angeles 0.44 :1 338 103 $150,543 Acres 4.49 4.49 4.49 4.49 4.49

Units Annual Cost $675,201 $675,201 $675,201 $675,201 $675,201

Acres Ventura 0.44 :1 381 117 $150,543 Acres 5.07 5.07 5.07 5.07 5.07

Units Annual Cost $762,704 $762,704 $762,704 $762,704 $762,704

Total NPV $11,098,372

Total NPV, All Units:

(1) For San Diego and Orange counties, the Effective Mitigation Ratio is the County-specific on-site mitigation ratio summarized in Table 11 minus an assumed CEQA 

 mitigation ratio of 2-to-1. For all other counties, the Effective Mitigation Ratio is the ratio reported in Table 11.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura involving the CAGN.

(2) Table E-1

(3) Table D-1

(4) Assumes projected development is distributed evenly throughout 2025.

$71,979,721

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Acres Orange

Set-Aside Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$729 $729 $729 $729 $729 $729 $729 $729 $729 $729

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$43 $43 $43 $43 $43 $43 $43 $43 $43 $43

0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

$2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14

$21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.61 0.61 0.61 0.61 0.61 0.61 0.61 0.61 0.61 0.61

$91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850

1.83 1.83 1.83 1.83 1.83 1.83 1.83 1.83 1.83 1.83

$271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751

0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003

$343 $343 $343 $343 $343 $343 $343 $343 $343 $343

0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28

$32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Set-Aside Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

$901 $901 $901 $901 $901 $901 $901 $901 $901 $901

51.44 51.44 51.44 51.44 51.44 51.44 51.44 51.44 51.44 51.44

$5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223

0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13

$14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$1 $1 $1 $1 $1 $1 $1 $1 $1 $1

14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23

$1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451

0.24 0.24 0.24 0.24 0.24 0.24 0.24 0.24 0.24 0.24

$35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563

4.49 4.49 4.49 4.49 4.49 4.49 4.49 4.49 4.49 4.49

$675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201

5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07

$762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Acres Orange

Set-Aside Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$729 $729 $729 $729 $729 $729 $729 $729

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$43 $43 $43 $43 $43 $43 $43 $43

0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

$2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827 $2,827

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

$1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258 $1,258

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.14 0.14 0.14 0.14 0.14 0.14 0.14 0.14

$21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263 $21,263

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.61 0.61 0.61 0.61 0.61 0.61 0.61 0.61

$91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850 $91,850

1.83 1.83 1.83 1.83 1.83 1.83 1.83 1.83

$271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751 $271,751

0.003 0.003 0.003 0.003 0.003 0.003 0.003 0.003

$343 $343 $343 $343 $343 $343 $343 $343

0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28

$32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039 $32,039

0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-8

On-site Set-aside Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Set-Aside Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

$901 $901 $901 $901 $901 $901 $901 $901

51.44 51.44 51.44 51.44 51.44 51.44 51.44 51.44

$5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223 $5,808,223

0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13

$14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543 $14,543

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$1 $1 $1 $1 $1 $1 $1 $1

14.23 14.23 14.23 14.23 14.23 14.23 14.23 14.23

$1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451 $1,606,451

0.24 0.24 0.24 0.24 0.24 0.24 0.24 0.24

$35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563 $35,563

4.49 4.49 4.49 4.49 4.49 4.49 4.49 4.49

$675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201 $675,201

5.07 5.07 5.07 5.07 5.07 5.07 5.07 5.07

$762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704 $762,704

Economic & Planning Systems, Inc. 2/26/2004 H:\12594gnatcatcher\Report\DEA_Feb2004\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per 2003 2004 2005 2006 2007

Developed (2) Preserved Mitigation Acre (3) 1 2 3 4 5

Critical Habitat Unit 1

Acres San Diego 0.00 :1 2 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 9 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 4 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 0 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 2 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.00 :1 0 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.00 :1 32 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Orange 0.00 :1 23 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 1.22 :1 0 0 $9,500 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Bernardino 0.00 :1 2 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 10

Acres Orange 0.00 :1 0 0 $78,333 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 1.22 :1 1,035 1,266 $9,500 Acres 55.04 55.04 55.04 55.04 55.04

Units Annual Cost $522,897 $522,897 $522,897 $522,897 $522,897

Acres San Bernardino 0.00 :1 1 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0 $19,750 Acres 0.00 0.00 0.00 0.00 0.00

Off-site 

Mitigation 

Ratio (1)

Projected Retail Development

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County Preservation Calculations by Year (4)

Habitat Unit Projected Acres Acres Average Price per 2003 2004 2005 2006 2007

Developed (2) Preserved Mitigation Acre (3) 1 2 3 4 5

Off-site 

Mitigation 

Ratio (1)

Projected Retail Development

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $4,035,944

Critical Habitat Unit 11

Acres San Bernardino 0.00 :1 121 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 12

Acres Los Angeles 0.00 :1 12 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 13

Acres Los Angeles 0.00 :1 234 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Ventura 0.00 :1 265 0 $0 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Total NPV, All Units:

(1) For San Diego and Orange counties, all mitigation above CEQA baseline is assumed to be on-site. The off-site mitigation ratio is therefore assumed to be zero. 

For the remaining counties, the mitigation ratio is from a review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios in Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for projects in Ventura 

involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$4,035,944

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Preservation Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

6 7 8 9 10 11 12 13 14 15 16

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

55.04 55.04 55.04 55.04 55.04 55.04 55.04 55.04 55.04 55.04 55.04

$522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

6 7 8 9 10 11 12 13 14 15 16

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Preservation Calculations by Year (4)

2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

55.04 55.04 55.04 55.04 55.04 55.04 55.04

$522,897 $522,897 $522,897 $522,897 $522,897 $522,897 $522,897

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-9

Off-site Preservation Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Preservation Calculations by Year (4)

2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration 2003 2004 2005 2006 2007

Developed (2) Restored Cost per Acre (3) 1 2 3 4 5

Critical Habitat Unit 1

Acres San Diego 0.00 :1 2 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 2

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 3

Acres San Diego 0.00 :1 9 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 4

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 5

Acres San Diego 0.00 :1 4 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 6

Acres Orange 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $0

Critical Habitat Unit 7

Acres Orange 0.00 :1 2 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 8

Acres Los Angeles 0.93 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

NPV $0

Critical Habitat Unit 9

Acres Los Angeles 0.93 :1 32 29.66 $30,000 Acres 1.29 1.29 1.29 1.29 1.29

Units Annual Cost $38,687 $38,687 $38,687 $38,687 $38,687

Acres Orange 0.00 :1 23 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 0.00 :1 2 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Bernardino 0.40 :1 2 0.97 $30,000 Acres 0.04 0.04 0.04 0.04 0.04

Units Annual Cost $1,261 $1,261 $1,261 $1,261 $1,261

Restoration

Mitigation 

Ratio (1)

Projected Retail Development

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County Restoration Calculations by Year (4)

Habitat Unit Projected Acres Acres Avg. Restoration 2003 2004 2005 2006 2007

Developed (2) Restored Cost per Acre (3) 1 2 3 4 5

Restoration

Mitigation 

Ratio (1)

Projected Retail Development

Total NPV $308,340

Critical Habitat Unit 10

Acres Orange 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres Riverside 0.00 :1 1,035 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Acres San Bernardino 0.40 :1 1 0.44 $30,000 Acres 0.02 0.02 0.02 0.02 0.02

Units Annual Cost $572 $572 $572 $572 $572

Acres San Diego 0.00 :1 0 0.00 $30,000 Acres 0.00 0.00 0.00 0.00 0.00

Units Annual Cost $0 $0 $0 $0 $0

Total NPV $4,419

Critical Habitat Unit 11

Acres San Bernardino 0.40 :1 121 48.48 $30,000 Acres 2.11 2.11 2.11 2.11 2.11

Units Annual Cost $63,236 $63,236 $63,236 $63,236 $63,236

NPV $488,080

Critical Habitat Unit 12

Acres Los Angeles 0.93 :1 12 11.48 $30,000 Acres 0.50 0.50 0.50 0.50 0.50

Units Annual Cost $14,979 $14,979 $14,979 $14,979 $14,979

NPV $115,614

Critical Habitat Unit 13

Acres Los Angeles 0.93 :1 234 218.04 $30,000 Acres 9.48 9.48 9.48 9.48 9.48

Units Annual Cost $284,395 $284,395 $284,395 $284,395 $284,395

Acres Ventura 0.93 :1 265 246.29 $30,000 Acres 10.71 10.71 10.71 10.71 10.71

Units Annual Cost $321,252 $321,252 $321,252 $321,252 $321,252

Total NPV $4,674,651

Total NPV, All Units:

(1) Based on review of selected Biological Opinions, as summarized in Table 11 and detailed in Appendix C.

 Mitigation ratios is Ventura County were assumed to be the same as in Los Angeles, because no Biological Opinions were provided for 

projects in Ventura involving the CAGN.

(2) Equal to Projected Growth Acres minus Acres Set-aside (Table E-1)

(3) Table 15

(4) Assumes projected development is distributed evenly throughout 2025.

$5,591,104

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29

$38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04

$1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261

Economic & Planning Systems, Inc. 2/26/2004 H:\12594\Model\\EmailTables_Feb2004.xls
Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6 7 8 9 10 11 12 13 14 15

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

$572 $572 $572 $572 $572 $572 $572 $572 $572 $572

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0 $0 $0

2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11

$63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236

0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50

$14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979

9.48 9.48 9.48 9.48 9.48 9.48 9.48 9.48 9.48 9.48

$284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395

10.71 10.71 10.71 10.71 10.71 10.71 10.71 10.71 10.71 10.71

$321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252

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Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 1

Acres San Diego

Units

Critical Habitat Unit 2

Acres San Diego

Units

Critical Habitat Unit 3

Acres San Diego

Units

Critical Habitat Unit 4

Acres San Diego

Units

Critical Habitat Unit 5

Acres San Diego

Units

Critical Habitat Unit 6

Acres Orange

Units

Acres San Diego

Units

Critical Habitat Unit 7

Acres Orange

Units

Critical Habitat Unit 8

Acres Los Angeles

Units

Critical Habitat Unit 9

Acres Los Angeles

Units

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Restoration Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

1.29 1.29 1.29 1.29 1.29 1.29 1.29 1.29

$38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687 $38,687

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04

$1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261 $1,261

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Table E-10

CSS Restoration Calculations for Projected Retail Development

Proposed Critical County

Habitat Unit

Critical Habitat Unit 10

Acres Orange

Units

Acres Riverside

Units

Acres San Bernardino

Units

Acres San Diego

Units

Critical Habitat Unit 11

Acres San Bernardino

Units

Critical Habitat Unit 12

Acres Los Angeles

Units

Critical Habitat Unit 13

Acres Los Angeles

Units

Acres Ventura

Units

Total NPV, All Units:

Restoration Calculations by Year (4)

2018 2019 2020 2021 2022 2023 2024 2025

16 17 18 19 20 21 22 23

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

$572 $572 $572 $572 $572 $572 $572 $572

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

$0 $0 $0 $0 $0 $0 $0 $0

2.11 2.11 2.11 2.11 2.11 2.11 2.11 2.11

$63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236 $63,236

0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50

$14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979 $14,979

9.48 9.48 9.48 9.48 9.48 9.48 9.48 9.48

$284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395 $284,395

10.71 10.71 10.71 10.71 10.71 10.71 10.71 10.71

$321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252 $321,252

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APPENDIX F

CONSULTATION COST MODEL
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

1

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Estimates of the cost of an individual consultation were developed from a review and

analysis of historical section 7 files from a number of Service field offices around the

country. These files addressed consultations conducted for both listings and CH

designations. Cost figures were based on an average level of effort for consultations of

4736 low, medium, or high complexity, multiplied by the appropriate labor rates for staff

from the Service and other Federal agencies. Estimates take into consideration the level

of effort of the Service, the Action agency, and the applicant during both formal and

informal consultations, as well as the varying complexity of consultations. Informal

consultations are assumed to involve a low to medium level of complexity. Formal

4741 consultations are assumed to involve a medium to high level of complexity. The cost of

a formal consultation includes the cost of the informal consultation that likely began the

section 7 consultation process. 

Section 7 consultation costs include the administrative costs associated with conducting

4746 the consultation, such as the cost of time spent in meetings, preparing letters, and in

some cases, developing a biological assessment and biological opinion. The costs of

reinitiating a consultation are assumed to be similar to conducting the original

consultation, because the re-initiation generally involves time spent in meetings and

preparing letters. This analysis assumes that the economic impact associated with a

4751 non-substantive reinitiation is similar to the cost of an informal consultation and the

economic impact associated with a substantive re-initiation is similar to the cost of a

formal consultation. The cost of internal consultation, where the Service is the Action

agency, depends on the activity under consideration and may be similar to the costs of

either informal or formal consultations. 

4756

Cost estimates for technical assistance are based on an analysis of past technical

assistance efforts by the Service in southern California. Technical assistance costs

represent the estimated economic costs of informational conversations, letters, and

meetings between landowners or developers and the Service regarding the designation

4761 of CH. Most likely, such communication will occur between municipal or private

property owners and the Service regarding areas designated as CH or lands adjacent to

CH.
Final Draft Report

Economic Analysis of Critical Habitat Designation for California Gnatcatcher

105Scenario A assumes discount rates of 12 percent and 7 percent for private and public development,

respectively. Scenario B assumes a discount rate of 3 percent for both private and public

development. 

2

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Estimated administrative costs associated with section 7 consultations, reinitiations, and

4766 technical assistance efforts are presented in Table F-1 (these are per effort estimates). 

The low and the high scenarios represent a reasonable range of costs for each type of

interaction. For example, when the Service participates in technical assistance with a

third party regarding a particular activity, the cost of the Service's effort is expected to

be approximately $260 to $680. The cost of the third party's effort is expected to be

4771 approximately $600 to $1,500. A summary of total costs by agency and consultation

type is shown in Table F-2, for both Scenario A and Scenario B.105 A description of the

number of anticipated consultations by project is shown in Table F-3. Project-level cost

summaries by agency are shown in Tables F-4A and F-4B (for Scenario A and B,

respectively). Project-level cost summaries by consultation type are shown in Tables F4776 5A and F-5B (for Scenario A and B, respectively).

Project modifications may be agreed upon during both informal and formal

consultations. The costs of modifications are estimated on a case-specific basis, relying

on information provided by the Service, action agencies, and private parties involved in

4781 the consultations. Likely project modifications and associated costs are addressed in the

main report text, for each relevant activity.
Table F-1

Individual Consultation and Technical Assistance Costs [1]

Economic Analysis of Critical Habitat Designation for the California Gnatcatcher

Category

Low High Low High Low High

USFWS $260 $680 $1,000 $3,100 $3,100 $6,100 

Action Agency $0 $0 $1,300 $3,900 $3,900 $6,500 

Third Party $600 $1,500 $1,200 $2,900 $2,900 $4,100 

Biological Assessment $0 $0 $0 $4,000 $4,000 $5,600 

Notes:

[1] A low to high cost range is specified for each action.

Technical Assistance Informal Consultations Formal Consultations

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Table F-2

Consultation and Technical Assistance Administrative Cost Summary

Economic Analysis of Critical Habitat Designation for the California Gnatcatcher

Category

Low High Low High Low High Low High

USFWS $848 $2,218 $184,916 $573,240 $3,760,317 $7,399,333 $3,946,081 $7,974,791

Action Agency $0 $0 $240,391 $721,172 $4,730,721 $7,884,536 $4,971,112 $8,605,708

Third Party $1,957 $4,892 $14,872 $35,942 $3,755,230 $5,309,118 $3,772,059 $5,349,952

Biological Assessments $0 $0 $0 $0 $4,621,793 $6,470,510 $4,621,793 $6,470,510

TOTAL $2,805 $7,110 $440,179 $1,330,353 $16,868,061 $27,063,497 $17,311,045 $28,400,961

Notes:

[1] Formal Consultation cost totals include Biological Assessment costs.

Technical Assistance Informal Consultation Formal Consultation [1] TOTAL

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Table F-3

Consultation Descriptions for Future Activities

Economic Analysis of Proposed Critical Habitat Designation for the California Gnatcatcher 

Consultation Nexus

Project Owner/Activity Action Agency

Technical 

Assistance

Informal 

3rd Party

Private Land Development USACE - - - 866 1259 866

Transportation and Road Construction

Caltrans USACE/FHWA - - - 191 191 191

Transportation Corridor Agency USACE - - - 1 1 1

Municipal Water Supply

Regional Infrastructure USACE - - - 13 13 13

Flood Control BOR - 12 12 3 3 3

Municipal Power Supply USACE/FERC/BLM - - - 6 6 6

Federal Land Management

Angeles National Forest USFS - 23 - - - -

Cleveland National Forest USFS - 41 - 41 - 21

San Bernardino National Forest USFS - 5 - 5 - 5

Bureau of Land Management BLM 3 12 - 4 - 4

Federal Emergency Management Activities FEMA - 75 - 30 - 30

Military Operations

Camp Pendleton (non-training areas) USMC - - - 37 - 0

Fallbrook US Navy - - - 16 - 16

El Toro US Navy - - - 1 - 1

Existing Habitat Conservation Plans (HCPs) USFWS - 28 28 8 8 8

Future Habitat Conservation Plans (HCPs) USFWS - - - 16 16 -

Reinitiated Section 7 Consultations USFWS - - - - - -

Total (2) 3 197 40 1,237 1,496 1,163

[1] The number reported in this column reflects the total number of third parties participating in formal consultations (for example, if there are three formal 

 consultations and one third party listed, only one consultation includes a third party participant).

(2) Because training areas in Marine Corps Base Camp Pendleton have not been proposed for critical habitat designation, estimated consultation costs for these areas are not included in the total.

Consultation Descriptions

Informal 

Consultations

Formal 

Consultations

Formal 3rd 

Party [1]

Biological 

Assessments [2]

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Table F-4 (1)

Consultation Costs by Agency and Party

Economic Analysis of Proposed Critical Habitat Designation for the California Gnatcatcher 

Consultation Nexus

Project Owner/Activity Action Agency

Low High Low High Low High Low High

Private Land Development (2) USACE $2,062,942 $3,399,496 $1,133,165 $1,888,609 $1,052,757 $1,488,381 $4,248,864 $6,776,485

Transportation and Road Construction

Caltrans USACE/FHWA $663,318 $1,093,073 $364,358 $607,263 $270,933 $383,043 $1,298,608 $2,083,379

Transportation Corridor Agency (3) USACE $7,100 $11,700 $3,900 $6,500 $2,900 $4,100 $13,900 $22,300

Municipal Water Supply

Regional Infrastructure USACE $45,396 $74,807 $24,936 $41,559 $18,542 $26,214 $88,873 $142,581

Flood Control BOR $15,153 $33,791 $12,883 $32,001 $10,997 $28,932 $39,034 $94,723

Municipal Power Supply USACE/FERC/BLM $20,428 $33,663 $11,221 $18,702 $8,344 $11,796 $39,993 $64,161

Federal Land Management

Angeles National Forest USFS $11,272 $34,944 $14,654 $43,962 $0 $0 $25,926 $78,905

Cleveland National Forest USFS $122,915 $241,800 $104,780 $209,560 $0 $0 $227,695 $451,360

San Bernardino National Forest USFS $19,849 $36,267 $12,742 $25,485 $0 $0 $32,591 $61,752

Bureau of Land Management BLM $20,108 $42,359 $15,377 $36,157 $959 $2,398 $36,444 $80,913

Federal Emergency Management Activities FEMA $141,174 $286,025 $105,145 $238,967 $0 $0 $246,319 $524,991

Military Operations

Camp Pendleton (non-training areas) USMC $56,214 $110,614 $70,721 $117,868 $0 $0 $126,935 $228,482

Fallbrook US Navy $55,675 $91,746 $30,582 $50,970 $0 $0 $86,257 $142,716

El Toro (3) US Navy $7,100 $11,700 $3,900 $6,500 $0 $0 $11,000 $18,200

Existing Habitat Conservation Plans (HCPs) USFWS $0 $0 $0 $0 $0 $0 $0 $0

Future Habitat Conservation Plans (HCPs) USFWS $7,842 $24,309 $10,194 $30,582 $0 $0 $18,035 $54,891

Reinitiated Section 7 Consultations USFWS $0 $0 $0 $0 $0 $0 $0 $0

Total (4) $3,256,485 $5,526,293 $1,918,558 $3,354,683 $1,365,432 $1,944,864 $6,540,475 $10,825,839

(1) Unless otherwise noted, the reported values are the net present value of future costs, assuming that all future costs are distributed evenly through 2025, and using a discount rate of 7 percent.

(2) The reported values are the net present value of future costs, assuming that all future costs are distributed evenly through 2025, and using a discount rate of 12 percent.

(3) The reported values are consultation costs expressed in constant dollars, assuming all costs are incurred in year 1 (2003).

(4) Because training areas in Marine Corps Base Camp Pendleton have not been proposed for critical habitat designation, estimated consultation costs for these areas are not included in the total.

Fish and Wildlife Service Third Party Total 

Consultation Costs (1)

Action Agency

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Table F-5 (1)

Consultation Costs by Consultation Type

Economic Analysis of Proposed Critical Habitat Designation for the California Gnatcatcher 

Consultation Nexus

Project Owner/Activity Action Agency

Low High Low High Low High Low High

Private Land Development (2) USACE - - - - $3,086,643 $5,149,376 $1,162,221 $1,627,109

Transportation and Road Construction

Caltrans USACE/FHWA - - - - $924,908 $1,560,198 $373,700 $523,180

Transportation Corridor Agency (3) USACE - - - - $9,900 $16,700 $4,000 $5,600

Municipal Water Supply

Regional Infrastructure USACE - - - - $63,298 $106,776 $25,575 $35,805

Flood Control BOR - - $21,259 $60,133 $12,660 $21,355 $5,115 $7,161

Municipal Power Supply USACE/FERC/BLM - - - - $28,484 $48,049 $11,509 $16,112

Federal Land Management

Angeles National Forest USFS - - $25,926 $78,905 - - $0 $0

Cleveland National Forest USFS - - $46,345 $141,050 $141,050 $253,890 $40,300 $56,420

San Bernardino National Forest USFS - - $5,636 $17,153 $17,153 $30,876 $9,802 $13,723

Bureau of Land Management BLM 1,375 3,485 $13,970 $42,518 $13,427 $24,168 $7,673 $10,742

Federal Emergency Management Activities FEMA - - $84,557 $257,349 $102,939 $185,291 $58,823 $82,352

Military Operations

Camp Pendleton (non-training areas) USMC - - - - $126,935 $228,482 $0 $0

Fallbrook US Navy - - - - $54,891 $98,803 $31,366 $43,913

El Toro (3) US Navy - - - - $7,000 $12,600 $4,000 $5,600

Existing Habitat Conservation Plans (HCPs) USFWS - - - - $0 $0 $0 $0

Future Habitat Conservation Plans (HCPs) USFWS - - - - $158,400 $267,200 $0 $0

Reinitiated Section 7 Consultations USFWS - - - - - - $0 $0

Total (4) $1,375 $3,485 $197,694 $597,109 $4,747,688 $8,003,765 $1,734,083 $2,427,716

(1) Unless otherwise noted, the reported values are the net present value of future costs, assuming that all future costs are distributed evenly through 2025, and using a discount rate of 7 percent.

(2) The reported values are the net present value of future costs, assuming that all future costs are distributed evenly through 2025, and using a discount rate of 12 percent.

(3) The reported values are consultation costs expressed in constant dollars, assuming all costs are incurred in year 1 (2003).

(4) Because training areas in Marine Corps Base Camp Pendleton have not been proposed for critical habitat designation, estimated consultation costs for these areas are not included in the total.

Informal Consultations Formal Consultations Biological Assessments

Consultation Costs (1)

Technical Assistance

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APPENDIX G

PROJECT MODIFICATION COST CALCULATIONS FOR

PUBLIC LAND DEVELOPMENT
Appendix Table G-1

Project Modification Costs for Caltrans District 7

Year 2003 2004 2005 2006 2007 2008 2009 2010

Project Modification Costs 1 2 3 4 5 6 7 8

Total Impact (ac) 6 Annual Acres Impacted 1.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0

Mitigation Ratio 1 :1 Annual Acres Mitigated 1.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0

Cost/Ac $ 116,667 Annual Mitigation Cost $ 116,667 $ - $ - $ - $ 116,667 $ - $ - $ -

Discount Rate 7.0%

NPV $ 369,198 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Acre Adj. 100%

Adj. NPV $ 369,198 Annual Acres Impacted 1.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0

Annual Acres Mitigated 1.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0

Annual Mitigation Cost $ 116,667 $ - $ - $ - $ 116,667 $ - $ - $ -

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual Acres Impacted 1.0 0.0 0.0 0.0 1.0 0.0 0.0 6.0

Annual Acres Mitigated 1.0 0.0 0.0 0.0 1.0 0.0 0.0 6.0

Annual Mitigation Cost $ 116,667 $ - $ - $ - $ 116,667 $ - $ - $ 700,000

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Appendix Table G-2

Project Modification Costs for Caltrans District 8

Year 2003 2004 2005 2006 2007 2008 2009 2010

Project Modification Costs 1 2 3 4 5 6 7 8

Unit 10 Impact 750 acres Annual Acres Impacted 39.1 39.1 39.1 39.1 39.1 39.1 39.1 39.1

Riverside growth 22,648 acres Annual Acres Mitigated 117.3 117.3 117.3 117.3 117.3 117.3 117.3 117.3

Impact/1,000 ac 33.1 Annual Mitigation Cost $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724

Unit 11 Growth 4,502 acres

Unit 11 Impact 149

Total Impact 899 acres Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Mitigation Ratio 3 :1

Cost/Ac $ 32,000 Annual Acres Impacted 39.1 39.1 39.1 39.1 39.1 39.1 39.1 39.1

Annual Acres Mitigated 117.3 117.3 117.3 117.3 117.3 117.3 117.3 117.3

Discount Rate 7.0% Annual Mitigation Cost $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724

NPV $ 42,301,405

Acre Adj. 100% Year 2019 2020 2021 2022 2023 2024 2025

Adj. NPV $ 42,301,405 17 18 19 20 21 22 23 TOTAL

Annual Acres Impacted 39.1 39.1 39.1 39.1 39.1 39.1 39.1 899.1

Annual Acres Mitigated 117.3 117.3 117.3 117.3 117.3 117.3 117.3 2697.3

Annual Mitigation Cost $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 3,752,724 $ 86,312,646

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Appendix Table G-3

Project Modification Costs for Caltrans District 11

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Total Impact (ac) 71.5

Annual Acres Impacted 3.1 3.1 3.1 3.1 3.1 3.1 3.1 3.1

SD Mitigation Ratio 2.06 :1 Annual Acres Mitigated 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

CEQA baseline 2.00 :1 Annual Mitigation Cost $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770

"Net" mitigation ratio 0.06 :1

Cost/Ac $ 32,000 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Discount Rate 7.0%

NPV $ 65,038 Annual Acres Impacted 3.1 3.1 3.1 3.1 3.1 3.1 3.1 3.1

Annual Acres Mitigated 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

Acre Adj. 36% Annual Mitigation Cost $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770

Adj. NPV $ 23,480

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual Acres Impacted 3.1 3.1 3.1 3.1 3.1 3.1 3.1 71.5

Annual Acres Mitigated 0.2 0.2 0.2 0.2 0.2 0.2 0.2 4.1

Annual Mitigation Cost $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 5,770 $ 132,704

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Appendix Table G-4

Project Modification Costs for Caltrans District 12

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Units 1-5 Impact 72 acres

San Diego growth 35,065 acres Annual Acres Impacted 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

Impact/1,000 ac 2.1 Annual Acres Mitigated 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9

Unit 11 Growth 11,486 acres Annual Mitigation Cost $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148

Unit 11 Impact 24 acres

Orange Mitigation Ratio 3.82 :1 Year 2011 2012 2013 2014 2015 2016 2017 2018

CEQA baseline 2.00 :1 9 10 11 12 13 14 15 16

"Net" mitigation ratio 1.82 :1

Annual Acres Impacted 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

Cost/Ac $ 31,692 Annual Acres Mitigated 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9

Annual Mitigation Cost $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148

Discount Rate 7.0%

NPV $ 666,723

Year 2019 2020 2021 2022 2023 2024 2025

Acre Adj. 67% 17 18 19 20 21 22 23 TOTAL

Adj. NPV $ 443,790

Annual Acres Impacted 1.0 1.0 1.0 1.0 1.0 1.0 1.0 23.6

Annual Acres Mitigated 1.9 1.9 1.9 1.9 1.9 1.9 1.9 42.9

Annual Mitigation Cost $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 59,148 $ 1,360,395

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Appendix Table G-5

Project Modification Costs for TCA Construction of Foothill-South Toll Road -- Far East Alignment

Toll Road Construction Assumptions:

Year 2003 2004 2005 2006 2007 2008 2009 2010

16 Rd miles 1 2 3 4 5 6 7 8

5280 ft/mile

84,480 Linear Feet Annual CSS Acres Impacted 0 0 145 145 145 145 0 0

300 ROW width (ft) Annual mitigation acres 0 0 265 265 265 265 0 0

25,344,000 footprint (sq ft) Annual Proj. Mod. Cost $0 $0 $20,736,970 $20,736,970 $20,736,970 $20,736,970 $0 $0

581.8 footprint (ac)

100% Assumed CSS coverage

581.8 Est. impacts to CSS Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

CSS Mitigation Assumptions:

CSS Acres Impacted 581.8 Annual mitigation acres 0 0 0 0 0 0 0 0

Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $0

Section 7 mitigation ratio 3.8 :1

CEQA baseline CSS mitigation 2.0 :1

Effective CSS baseline 1.8 :1 Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Cost per acre mitigated $78,333

Annual CSS Acres Impacted 0 0 0 0 0 0 0 582

Discount Rate 7.0% Annual mitigation acres 0 0 0 0 0 0 0

NPV $61,350,771 Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $82,947,879

Acre Adj. 100%

Adj. NPV $ 61,350,771

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Appendix Table G-6

Project Modification Costs for TCA Construction of Foothill-South Toll Road -- Arterial Improvement Alternative

Toll Road Construction Assumptions:

I-5 Widening: Arterial Widening (Ant.Pkwy & Av. La Pata): Smart Streets (Ortega Hwy, Camino Las Ramblas, & Av. Pico):

4.5 Road miles w/ CSS 10.4 Road miles 9.4 Road miles

23,760 Linear Feet 54,912 Linear Feet 49,632 Linear Feet

40 expansion width (ft) 40 ROW width (ft) 10 expansion width (ft)

950,400 footprint (sq ft) 2,196,480 footprint (sq ft) 496320 footprint (sq ft)

21.8 footprint (ac) 50.4 footprint (ac) 11.4 footprint (ac)

100% Assumed CSS coverage 100% Assumed CSS coverage 100% Assumed CSS coverage

21.8 Est. impacts to CSS 50.4 Est. impacts to CSS 11.4 Est. impacts to CSS

Widening Assumptions: 

83.6 Total Acres CSS Affected 2 Total Lanes (one each dir.)

10 Lane Width (ft)

10 Shoulder width (ft)

40 Total Width (ft)

CSS Mitigation Assumptions:

Year 2003 2004 2005 2006 2007 2008 2009 2010

CSS Acres Impacted 83.6 acres 1 2 3 4 5 6 7 8

Section 7 mitigation ratio 3.8 :1 Annual CSS Acres Impacted 0 0 21 21 21 21 0 0

CEQA baseline CSS mitigation 2.0 :1 Annual mitigation acres 0 0 38 38 38 38 0 0

Effective CSS baseline 1.8 :1 Annual Proj. Mod. Cost $0 $0 $2,980,939 $2,980,939 $2,980,939 $2,980,939 $0 $0

Cost per acre mitigated $78,333

Year 2011 2012 2013 2014 2015 2016 2017 2018

Discount Rate 7.0% 9 10 11 12 13 14 15 16

NPV $8,819,173

Annual CSS Acres Impacted 0 0 0 0 0 0 0 0

Acre Adj. 100% Annual mitigation acres 0 0 0 0 0 0 0 0

Adj. NPV $ 8,819,173 Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $0

Average, Scenario 1 & 2 (7%) $35,084,972 Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual CSS Acres Impacted 0 0 0 0 0 0 0 84

Annual mitigation acres 0 0 0 0 0 0 0

Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $11,923,758

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Appendix Table G-7

Project Modification Costs for the San Diego County Water Authority

Project Modification Assumptions

Annual CSS Acres Impacted (Temporary)

Annual mitigation acres acquired Year 2003 2004 2005 2006 2007 2008 2009 2010

Annual Proj. Mod. Cost 1 2 3 4 5 6 7 8

Permanent

CSS Impact Acres Impacted Temp/Perm Year Annual CSS Acres Impacted 0.29 0.29 0.29 27 27 27 27 27

Project 1 0.86 P 2000-'05 Annual mitigation acres 0 0 0 14 14 14 14 14

Project 2 0.5 P 2005-'10 Annual Proj. Mod. Cost $2,150 $2,150 $2,150 $206,175 $206,175 $206,175 $206,175 $206,175

Project 3 136.95 P 2005-'10

Project 4 8.24 T 2005-'10 Temporary

Project 5 4 P 2010-'15 Annual CSS Acres Impacted 0 0 0 2 2 2 2 2

Project 6 0.8 P 2010-'15 Annual mitigation acres 0 0 0 0 0 0 0 0

Project 7 2.6 P 2010-'15 Annual Proj. Mod. Cost $0 $0 $0 $7,416 $7,416 $7,416 $7,416 $7,416

Project 8 20.72 T 2010-'15

Assumed mitigation ratio (Permanent) 0.5 :1

Year 2011 2012 2013 2014 2015 2016 2017 2018

Reported mitigation ratio (Temporary) 1.5 :1 9 10 11 12 13 14 15 16

Assumed CEQA baseline ratio 1.2 :1 Permanent

Assumed mitigation ratio (Temporary) 0.3 :1 Annual CSS Acres Impacted 1.5 1.5 1.5 1.5 1.5 0 0 0

Annual mitigation acres 1 1 1 1 1 0 0 0

Cost per acre mitigated (Permanent) $15,000 Annual Proj. Mod. Cost $11,100 $11,100 $11,100 $11,100 $11,100 $0 $0 $0

Cost per acre mitigated (Temporary) $15,000

Temporary

Discount Rate 7.0% Annual CSS Acres Impacted 4 4 4 4 4 0 0 0

NPV $791,517 Annual mitigation acres 1 1 1 1 1 0 0 0

Annual Proj. Mod. Cost $18,648 $18,648 $18,648 $18,648 $18,648 $0 $0 $0

Acre Adj. 68%

Adj. NPV $ 538,216

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Permanent

Annual CSS Acres Impacted 0 0 0 0 0 0 0 146

Annual mitigation acres 0 0 0 0 0 0 0

Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $1,092,825

Temporary

Annual CSS Acres Impacted 0 0 0 0 0 0 0

Annual mitigation acres 0 0 0 0 0 0 0

Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $130,320

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Appendix Table G-8

Project Modification Costs for the Metropolitan Water District

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Annual Acres Impacted

Annual Acres Mitigated Annual Acres Impacted 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7

Annual Mitigation Cost Annual Acres Mitigated 18.1 18.1 18.1 18.1 18.1 18.1 18.1 18.1

Annual Mitigation Cost $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580

SDCWA impact 146 acres

San Diego growth 35,065 acres

Impact/1,000 ac 4.2 Year 2011 2012 2013 2014 2015 2016 2017 2018

Growth outside SD 47,987 acres 9 10 11 12 13 14 15 16

MWD Impact 199 acres

Annual Acres Impacted 8.7 8.7 8.7 8.7 8.7 8.7 8.7 8.7

Average mitigation ratio 2.63 :1 Annual Acres Mitigated 18.1 18.1 18.1 18.1 18.1 18.1 18.1 18.1

Est. CEQA baseline 0.54 :1 (1) Annual Mitigation Cost $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580

"Net" Mitigation Ratio 2.09 :1 (2)

(3)

Cost/Ac $ 43,917 Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Discount Rate 7.0%

NPV $ 8,956,652 Annual Acres Impacted 8.7 8.7 8.7 8.7 8.7 8.7 8.7 199.4

Annual Acres Mitigated 18.1 18.1 18.1 18.1 18.1 18.1 18.1 416.1

Acre Adj. 68% Annual Mitigation Cost $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 794,580 $ 18,275,335

Adj. NPV $ 6,090,353

(1) (All counties other than San Diego)

(2) (2:1 baseline, weighted by relative acreage of Orange County units 

(3) to all counties other than San Diego)

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Appendix Table G-9

Project Modification Costs for the Bureau of Reclamation

Project Modification Assumptions

Year 2003 2004 2005 2006 2007 2008 2009 2010

"Small" Water Reuse Projects 1 2 3 4 5 6 7 8

Frequency: 4 projects every 5 years

* 3 informal consultations; 1 formal consultation Annual CSS Acres Impacted 0.5 0.5 0.5 0.5 64 0.5 0.5 0.5

CSS Impact per Project 0.5 acres Annual mitigation acres ("net") 0 0 0 0 4 0 0 0

Annual Proj. Mod. Cost $919 $919 $919 $919 $117,642 $919 $919 $919

"Large" Regional Water Infrastructure Projects

Frequency: One every 5 years Year 2011 2012 2013 2014 2015 2016 2017 2018

CSS Impacts per Project 64 acres 9 10 11 12 13 14 15 16

Annual CSS Acres Impacted 0.5 64 0.5 0.5 0.5 0.5 64 0.5

Mitigation Assumptions Annual mitigation acres ("net") 0 4 0 0 0 0 4 0

CSS Mitigation Ratio: 2.06 Annual Proj. Mod. Cost $919 $117,642 $919 $919 $919 $919 $117,642 $919

Baseline mitigation (CEQA): 2.00

"Net" section 7 mitigation: 0.06

Year 2019 2020 2021 2022 2023 2024 2025

Cost per acre mitigated $31,692 17 18 19 20 21 22 23 TOTAL

Discount Rate 7.0% Annual CSS Acres Impacted 0.5 0.5 0.5 64 0.5 0.5 0.5 266

NPV $225,387 Annual mitigation acres ("net") 0 0 0 4 0 0 0 15

Annual Proj. Mod. Cost $919 $919 $919 $117,642 $919 $919 $919 $488,030

Acre Adj. 68%

Adj. NPV $ 153,259

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Appendix Table G-10

Project Modification Costs for Southern California Edison

Project Modification Costs

Year 2003 2004 2005 2006 2007 2008 2009 2010

Projects with Modifications 4 1 2 3 4 5 6 7 8

Total Acres Impacted 250

Acres Impacted per project 63 Annual CSS Acres Impacted 63 63

Annual mitigation acres 0 0 91 0 0 91 0 0

Reported mitigation ratio 2.00 :1 Annual Proj. Mod. Cost $0 $0 $4,331,335 $0 $0 $4,331,335 $0 $0

Est. CEQA baseline 0.54 :1 (1)

Est. "net" mitigation ratio 1.46 :1

Year 2011 2012 2013 2014 2015 2016 2017 2018

Cost per acre mitigated $47,600 9 10 11 12 13 14 15 16

SCE Service Territory 50,000 square miles

Annual CSS Acres Impacted 63 63

Discount Rate 7.0% Annual mitigation acres 91 0 0 0 0 0 91 0

NPV $10,347,646 Annual Proj. Mod. Cost $4,331,335 $0 $0 $0 $0 $0 $4,331,335 $0

Acre Adj. 68%

Adj. NPV $ 7,036,202 Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual CSS Acres Impacted 250

Annual mitigation acres 0 0 0 0 0 0 0

Annual Proj. Mod. Cost $0 $0 $0 $0 $0 $0 $0 $17,325,340

(1) (2:1 baseline, weighted by relative acreage of Orange County units to all 

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Appendix Table G-11

Project Modification Costs for San Diego Gas & Electric

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

SCE impact 250 acres

Growth outside SD 47,987 acres Annual Acres Impacted 7.9 7.9 7.9 7.9 7.9 7.9 7.9 7.9

Impact/1,000 ac 5.2 Annual Acres Mitigated 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

San Diego growth 35,065 acres Annual Mitigation Cost $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098

SDG&E Impact 183 acres

Mitigation Ratio 2.06 :1 Year 2011 2012 2013 2014 2015 2016 2017 2018

SD CEQA baseline 2.00 :1 9 10 11 12 13 14 15 16

"Net" ratio 0.06 :1

Annual Acres Impacted 7.9 7.9 7.9 7.9 7.9 7.9 7.9 7.9

Cost/Ac $ 19,750 Annual Acres Mitigated 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

Annual Mitigation Cost $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098

Discount Rate 7.0%

NPV $ 102,559

Year 2019 2020 2021 2022 2023 2024 2025

Acre Adj. 68% 17 18 19 20 21 22 23 TOTAL

Adj. NPV $ 69,738

Annual Acres Impacted 7.9 7.9 7.9 7.9 7.9 7.9 7.9 182.7

Annual Acres Mitigated 0.5 0.5 0.5 0.5 0.5 0.5 0.5 10.6

Annual Mitigation Cost $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 9,098 $ 209,263

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Appendix Table G-12

Project Modification Costs for the Southern California Gas Company

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Annual Acres Impacted

Annual Acres Mitigated Annual Acres Impacted 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0

Annual Mitigation Cost Annual Acres Mitigated 10.4 10.4 10.4 10.4 10.4 10.4 10.4 10.4

Annual Mitigation Cost $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958

SCGC Service Territory 23,000 square miles

SCE service territory 50,000 square miles

Scaling factor: 0.46 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

SCE impact 250 acres

Imputed SDG&E impact 115 acres Annual Acres Impacted 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0

Estimated Consultations 2 Annual Acres Mitigated 10.4 10.4 10.4 10.4 10.4 10.4 10.4 10.4

Annual Mitigation Cost $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958

Average mitigation ratio 2.63 :1 (1)

Est. CEQA baseline 0.54 :1 (2)

Est. "net" mitigation ratio 2.09 :1 Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Cost/Ac $ 55,389

Annual Acres Impacted 5.0 5.0 5.0 5.0 5.0 5.0 5.0 115.0

Discount Rate 7.0% Annual Acres Mitigated 10.4 10.4 10.4 10.4 10.4 10.4 10.4 240.0

NPV $ 6,514,855 Annual Mitigation Cost $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 577,958 $ 13,293,043

Acre Adj. 68%

Adj. NPV $ 4,429,978

(1) (All counties other than San Diego)

(2) (2:1 baseline, weighted by relative acreage of Orange County units to 

all counties other than San Diego)

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Appendix Table G-13

Project Modification Costs for Angeles National Forest

Project Modification Assumptions

Year 2003 2004 2005 2006 2007 2008 2009 2010

Total Acres Protected 4,000 1 2 3 4 5 6 7 8

Total Prescribed Burns 23

Ac. Protected / Burn 174 Annual Acres Protected 174 174 174 174 174 174 174 174

Per-Acre Protection Cost $100 Annual Proj. Mod. Cost $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $17,391

Discount Rate 7.0%

NPV $196,038 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Acre Adj. 100%

Adj. NPV $ 196,038 Annual Acres Protected 174 174 174 174 174 174 174 174

Annual Proj. Mod. Cost $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $17,391

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual Acres Protected 174 174 174 174 174 174 174 4000

Annual Proj. Mod. Cost $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $17,391 $400,000

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Appendix Table G-14

Project Modification Costs for Cleveland National Forest

Project Modification Costs

Year 2003 2004 2005 2006 2007 2008 2009 2010

Annual Acres Protected 1 2 3 4 5 6 7 8

Annual Proj. Mod. Cost

Annual Acres Protected 290 290 290 290 290 290 290 290

Total Acres Protected 20,000 Annual Proj. Mod. Cost $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $28,986

Total Prescribed Burns 69

Ac. Protected / Burn 290

Per-Acre Protection Cost $100 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Discount Rate 7.0%

NPV $326,730 Annual Acres Protected 290 290 290 290 290 290 290 290

Annual Proj. Mod. Cost $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $28,986

Acre Adj. 62%

Adj. NPV $ 203,838

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual Acres Protected 290 290 290 290 290 290 290 6667

Annual Proj. Mod. Cost $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $28,986 $666,667

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Appendix Table G-15

Project Modification Costs for San Bernardino National Forest

Project Modification Costs

Year 2003 2004 2005 2006 2007 2008 2009 2010

Annual Acres Protected 1 2 3 4 5 6 7 8

Annual Proj. Mod. Cost

Annual Acres Protected 43 43 43 43 43 43 43 43

Total Acres Protected 1,000 Annual Proj. Mod. Cost $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $4,348

Per-Acre Protection Cost $100

Discount Rate 7.0% Year 2011 2012 2013 2014 2015 2016 2017 2018

NPV $49,010 9 10 11 12 13 14 15 16

Acre Adj. 100% Annual Acres Protected 43 43 43 43 43 43 43 43

Adj. NPV $ 49,010 Annual Proj. Mod. Cost $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $4,348

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual Acres Protected 43 43 43 43 43 43 43 1000

Annual Proj. Mod. Cost $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $4,348 $100,000

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Appendix Table G-16

Project Modification Costs for the Bureau of Land Management

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Projects with Modifications 6

Acres Impacted per project 4 Annual CSS Acres Impacted 4 0 0 0 4 0 0 0

Assumed mitigation ratio 2 :1 Annual mitigation acres 8 0 0 0 8 0 0 0

Cost per acre mitigated $1,500 Annual Proj. Mod. Cost $12,000 $0 $0 $0 $12,000 $0 $0 $0

Discount Rate 7.0%

NPV $37,975 Year 2011 2012 2013 2014 2015 2016 2017 2018

9 10 11 12 13 14 15 16

Acre Adj. 68%

Adj. NPV $ 25,822 Annual CSS Acres Impacted 4 0 0 0 4 0 0 0

Annual mitigation acres 8 0 0 0 8 0 0 0

Annual Proj. Mod. Cost $12,000 $0 $0 $0 $12,000 $0 $0 $0

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual CSS Acres Impacted 4 0 0 0 4 0 0 24

Annual mitigation acres 8 0 0 0 8 0 0

Annual Proj. Mod. Cost $12,000 $0 $0 $0 $12,000 $0 $0 $72,000

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Table G-17

Project Modification Calculations -- Camp Pendleton

Service Date of Estimated

Location / Project Name Project # BO Permanent Temporary Cost (1)

Non-Training Areas

San Onofre Sewage Effluent 1-6-95-F-25 3/30/1995 0 0.3 $11,400

Bridge Retrofit - Interstate 5 1-6-96-F-31 8/15/1996 0 1.08 $41,040

Santa Margarita Sewage Effluent 1-6-96-F-36 10/21/1996 26.3 0.8 $2,029,200

Slope Stabilization at SDGE Talega Substation1-6-98-F-27 9/8/1998 0 3.5 $133,000

DeLuz Housing 1-6-98-F-38 11/23/1998 3.93 0 $298,680

Ammunition Handling Facility 1-6-99-F-30 4/19/1999 2.57 1.07 $235,980

Santa Margarita River Levee 1-6-95-F-02-R10 7/19/1999 1.65 0 $125,400

PPM Burn at San Mateo 1-6-00-F-34 5/12/2000 5.0 0 $380,000

Las Flores Estancia 1-6-01-F-910.2 2/2/2001 0.74 0 $56,240

SDGE Talega Substation Expansion 1-6-02-F-1988.2 12/10/2001 0 0 $0

SDGE Access Road 1-6-02-F-2464.2 1/31/2002 0 0 $0

San Onofre Housing Firebreak 1-6-02-F-2869.1 5/23/2002 0.77 0 $58,520

San Mateo BEQ Parking 1-6-02-F-2729.3 5/30/2002 2.21 0 $167,960

Subtotal 13 43.17 6.75 $3,537,420

Amount Per Year 1.58 5.23 0.82 $428,778

Training Areas

Northern Power Line 1-6-99-F-45 6/28/1999 0.0013 0.148 $5,723

SFPP Petroleum Pipeline 1-6-99-F-54 8/23/1999 0 0 $0

Electrical Towers M3-T3 1-6-99-F-76 10/28/1999 0.17 0.12 $17,480

Range 314 Road Upgrade 1-6-03-F-3001.3 1/10/2003 3.5 0 $266,000

Biological Assessment of Upland Habitat on-going - - -

Subtotal 5 3.6713 0.268 $289,203

Amount Per Year 0.61 0.45 0.03 $35,055

(1) Assumes a 2:1 total mitigation requirement for permanent impacts, 1:1 restoration for temporary impacts, 

and a cost of $38,000 per mitigated or restored acre. Does not represent actual amount paid.

Source: US Fish & Wildlife Service; Fallbrook Naval Weapons Station; Economic & Planning Systems, Inc.

Acres of CSS Impact

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Table G-17

Project Modification Calculations -- Camp Pendleton

Non-training NPV 7% $4,833,268 Year 2003 2004 2005 2006 2007 2008 2009 2010

Training NPV: 7% $395,145 Non-Training $428,778 $428,778 $428,778 $428,778 $428,778 $428,778 $428,778 $428,778

Training $35,055 $35,055 $35,055 $35,055 $35,055 $35,055 $35,055 $35,055

Year 2011 2012 2013 2014 2015 2016 2017 2018

Non-Training $428,778 $428,778 $428,778 $428,778 $428,778 $428,778 $428,778 $428,778

Training $35,055 $35,055 $35,055 $35,055 $35,055 $35,055 $35,055 $35,055

Year 2019 2020 2021 2022 2023 2024 2025

Non-Training $428,778 $428,778 $428,778 $428,778 $428,778 $428,778 $428,778

Training $35,055 $35,055 $35,055 $35,055 $35,055 $35,055 $35,055

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Appendix Table G-18

Project Modification Costs for Fallbrook Naval Weapons Station

Project Modification Assumptions Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Projects with Modifications 16 Proj. 1 Ammunition Rd. 0 20 0 0 0 0 0 0

Assumed mitigation ratio 1 :1 Proj. 2 Ten Mags over 20 years 0 5 0 5 0 5 0 5

Cost per acre mitigated $38,000 Proj. 3 Five year Cycles for Roads 0 0 3.3 0 0 0 0 3

Proj. 4 Building 0 0 0 0 0 0 0 0

Discount Rate 7.0%

NPV $2,109,962 Annual CSS Acres Impacted 0 25 3 5 0 5 0 8

Annual Project Modification Cost $0 $950,000 $126,667 $190,000 $0 $190,000 $0 $316,667

Acre Adj. 100% 13500 13500 13500 13500 13500 13500 13500 13500

Year 2011 2012 2013 2014 2015 2016 2017 2018

For Fallbrook 9 10 11 12 13 14 15 16

0.25 mi Proj. 1 Ammunition Rd. 0 0 0 0 0 0 0 0

5280 Proj. 2 Ten Mags over 20 years 0 5 0 5 0 5 0 5

1320 LF Proj. 3 Five year Cycles for Roads 0 0 0 0 3 0 0 0

22 ft width Proj. 4 Building 0 0 0 0 0 0 15 0

29040 sq ft

0.666666667 acres/yr Annual CSS Acres Impacted 0 5 0 5 3 5 15 5

3.333333333 Every Five Years Annual Project Modification Cost $0 $190,000 $0 $190,000 $126,667 $190,000 $570,000 $190,000

13500

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Proj. 1 Ammunition Rd. 0 0 0 0 0 0 0

Proj. 2 Ten Mags over 20 years 0 5 0 5 0 0 0

Proj. 3 Five year Cycles for Roads 0 3 0 0 0 0 0

Proj. 4 Building 0 0 0 0 0 0 0

Annual CSS Acres Impacted 0 8 0 5 0 0 0 98

Annual Project Modification Cost $0 $316,667 $0 $190,000 $0 $0 $0 $3,736,667

13500 13500 13500 13500 13500 13500 13500

14519 14519 14519 14519 14519 14519 14519

28019 28019 28019 28019 28019 28019 28019

0 8 0 5 0 0 0

$28,019 $344,685 $28,019 $218,019 $28,019 $28,019 $28,019 $4,381,099

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Appendix Table G-19

Project Modification Costs for the Pala Band of Mission Indians

Project Modification Costs Year 2003 2004 2005 2006 2007 2008 2009 2010

1 2 3 4 5 6 7 8

Housing projects 60

Acres Impacted per project 1.0 Annual CSS Acres Impacted 2.0 0.7 0.7 0.7 0.7 2.0 0.7 0.7

Annual mitigation acres 3.9 1.3 1.3 1.3 1.3 3.9 1.3 1.3

Community projects 5 (in 2005, '10, '15, & '20)Annual Proj. Mod. Cost $77,127 $26,444 $26,444 $26,444 $26,444 $77,127 $26,444 $26,444

Acres Impacted per project 5.0

Percent CSS on Reservation 26% Year 2011 2012 2013 2014 2015 2016 2017 2018

Assumed mitigation ratio 2 :1 9 10 11 12 13 14 15 16

Cost per acre mitigated $19,750

Annual CSS Acres Impacted 0.7 0.7 2.0 0.7 0.7 0.7 0.7 2.0

Discount Rate 7.0% Annual mitigation acres 1.3 1.3 3.9 1.3 1.3 1.3 1.3 3.9

NPV $432,705 Annual Proj. Mod. Cost $26,444 $26,444 $77,127 $26,444 $26,444 $26,444 $26,444 $77,127

Year 2019 2020 2021 2022 2023 2024 2025

17 18 19 20 21 22 23 TOTAL

Annual CSS Acres Impacted 0.7 0.7 0.7 0.7 2.0 0.7 0.7 22

Annual mitigation acres 1.3 1.3 1.3 1.3 3.9 1.3 1.3

Annual Proj. Mod. Cost $26,444 $26,444 $26,444 $26,444 $77,127 $26,444 $26,444 $861,619

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APPENDIX H

SUMMARY OF ECONOMIC ANALYSIS FOR

AREAS PROPOSED FOR CRITICAL HABITAT DESIGNATION

AND EXCLUSION (COMBINED)
Table H-1

Summary of Economic Impacts by Unit -- CH Proposed for Designation and Exclusion

Proposed

CH Unit

Unit 1 $34,256,806 $3,605,251 $1,671,146 $35,168,661 $74,701,863

Unit 2 $2,027,499 $281,550 $55,528 $1,168,556 $3,533,132

Unit 3 $6,329,275 $532,510 $188,139 $3,959,294 $11,009,218

Unit 4 $2,448,883 $266,690 $158 $3,326 $2,719,057

Unit 5 $9,807,316 $999,226 $302,572 $6,367,508 $17,476,623

Unit 6 $85,506,924 $966,067 $173,173 $2,817,874 $89,464,038

Unit 7 $10,991,170 $683,677 $27,397 $445,779 $12,148,023

Unit 8 $332,697 $116,418 $0 $0 $449,115

Unit 9 $38,074,247 $392,512 $254,193 $3,950,050 $42,671,002

Unit 10 $435,551,729 $3,069,916 $2,212,996 $19,072,846 $459,907,488

Unit 11 $90,433,234 $297,332 $232,976 $2,400,835 $93,364,377

Unit 12 $3,649,153 $64,918 $44,013 $271,750 $4,029,834

Unit 13 $168,719,062 $1,723,757 $2,156,399 $12,857,995 $185,457,213

Project-specific HCPs (4) N/A $141,539 N/A N/A $141,539

Total Cost $888,127,996 $13,141,364 $7,318,690 $88,484,473 $997,072,523

Annualized Cost (5) $110,347,057 $1,508,355 $948,209 $11,464,045 $124,267,667

(1) Assumes discount rate of 12% for private development projects and 7% for public development projects. 

(2) Average administrative consultation costs (low and high) were allocated among units in proportion 

to the number of projected growth acres in each unit with a Federal nexus. 

(3) This value is one-half the difference between the total Upper End Mitigation Scenario cost and total estimated project modification costs.

(4) Because the location of all existing project-specific HCPs was not known, this item is reported individually.

(5) Represents the annual amount that is equivalent to the Total Costs, when distributed over a 23-year period. Assumes a discount rate of 12 percent for Scenario A

 (private/public costs could not be separated in the Unit Summary table), and 3 percent for Scenario B.

Total Estimated Cost

Estimated Project Modification 

Costs (1)

Estimated Administrative Costs 

(2) Estimated Delay Costs

Estimated Uncertainty Costs 

(3)

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APPENDIX I

TIME DELAY SUMMARY
Table I-1

Summary of Section 7 Time Delay Calculations

Developable Acres 

with nexus in CH Acres Land Value of Value Impact

Unit through 2025 Delayed Delayed Acres of Delay

(1) (2) (3) (4)

Unit 1 68 3 $1,055,723 $63,343

Unit 2 55 2 $925,461 $55,528

Unit 3 203 9 $3,135,642 $188,139

Unit 4 0 0 $2,634 $158

Unit 5 276 12 $4,626,554 $277,593

Unit 6 151 7 $2,886,221 $173,173

Unit 7 35 2 $327,476 $19,649

Unit 8 0 0 $0 $0

Unit 9 469 20 $4,236,554 $254,193

Unit 10 6,631 288 $36,883,272 $2,212,996

Unit 11 772 34 $3,882,926 $232,976

Unit 12 94 4 $733,544 $44,013

Unit 13 3,993 174 $35,939,988 $2,156,399

Totals 12,747 554 $94,635,996 $5,678,160

(1) See Table 10. Equals projected growth acres through 2025 affected by section 7 minus on-site set-aside requirements.

(2) First year of land development after CHD is conservatively assumed to be delayed by six months due to lack of time to plan 

 to avoid breeding season. Acres delay represents developed acres divided by 23, the number of years of the projection.

(3) Represents value of raw, entitled land ready for development. Based on land values presented in Appendix D.

(4) Based on 6 percent discount rate, as delay lasts six months (i.e., one-half of 12% annual discount rate).

(5) Based on 1.5 percent discount rate, as delay lasts six months.

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