Both the natural environment and the socio-economic context in central California are very different from those of the Northwest. The climate in Central California is Mediterranean, in sharp contrast to the NW, as is the underlying rock substrate.
Mediterranean climate yields highly variable stream flows.
It should be expected that, as we become more familiar with facts and issues on the ground, we might find that some variations on rules and guidelines developed for the NW may work more effectively and efficiently in our locale. Some aspects of guidelines and rules developed for a very different natural and socio-economic environment in the NW could prove to be counterproductive in this area. For that reason, we urge that the 4D rules explicitly provide clear opportunity for learning from experience on the ground in this very different environment and that the rules provide for amendment at local and state level as experience is acquired. NMFS has indicated that approval of HCP applications can take up to 3 years. In the meantime the process of restoration is delayed, to the detriment of the threatened species.