APPENDIX D.2 Plant Survey Memorandum Athos Memo Report To: Aspen Environmental Group From: Lehong Chow, Ironwood Consulting, Inc. Date: April 3, 2019 Re: Athos Supplemental Spring 2019 Botanical Surveys This memo report presents the methods and results for supplemental botanical surveys conducted for the Athos Solar Energy Project in March 2019 and supplements the Biological Resources Technical Report (BRTR; Ironwood 2019) which reported on field surveys conducted in 2018. BACKGROUND Botanical surveys were previously conducted in the spring and fall of 2018 for the entirety of the project site for the Athos Solar Energy Project (Athos). However, due to insufficient rain, many plant species did not germinate for proper identification during 2018 spring surveys. Fall surveys in 2018 were conducted only on a reconnaissance-level due to low levels of rain. Regional winter rainfall from the two nearest weather stations showed rainfall averaging at 0.1 inches during botanical surveys conducted in 2018 (Ironwood, 2019). In addition, gen-tie alignments have changed slightly and alternatives, access roads and spur roads have been added. PURPOSE The purpose of this survey was to survey all new additions and re-survey areas of interest including public lands (limited to portions of the gen-tie segments), parcels supporting native vegetation and habitat, and windblown sandy areas where sensitive plant species may occur. The private land parcels in current or former agricultural use were not surveyed (parcel groups A, B, C, E, and part of G). METHODS Survey Areas: The area surveyed for biological resources included the entirety of gen-tie routes (including alternates), spur roads, access roads on public land, parcels supporting native vegetation (parcel groups D and F), and areas covered by windblown sand where sensitive species may occur (portion of parcel group G). See Figures 1 and 2 for survey areas. Athos Supplemental 2019 Botanical Survey Memo Report Survey Preparation Botanist Michelle Cloud-Hughes, along with Dave Kesonie and Emily Thorn, visited reference populations on January 29, 2019 at two locations: Highway 62 and Ironage Road and the Desert Lily Sanctuary, near Hwy 177, just north of Desert Center. Eriastrum harwoodii (CRPR 1B and BLM Sensitive; was identified at both localities. Individuals of Astragalus species and Cryptantha species were observed but needed an additional 2-3 weeks to distinguish whether they were indeed the special-status species Astragalus insularis var. harwoodii (CRPR 2B.2, no BLM status) and Cryptantha costata (CRPR 4.3, no BLM status). Ditaxis serrata var. californica (CRPR 3.2, no BLM status) has been reported to occur within the area but was not located even after contacting the botanist who originally collected from that local population. Please refer to the Biological Resources Technical Report (BRTR; Ironwood, 2019) for additional details. The results of the 2018 botanical inventories and sensitive species previously observed on the project site were reviewed prior to beginning surveys. Survey Method Botanical surveys began on March 4, 2019 and concluded on March 9, 2019. Field surveys were conducted according to the methods described in the BRTR (Ironwood, 2019). Along the gen-tie line and access roads, botanists walked along parallel linear belt transects spaced at 10-meter intervals within the first 30 meters on each side of the centerline, and covered an additional 50-meter buffer at 20-meter intervals on each side. A total width of 80 meters on each side of the gen-tie centerline was covered resulting in a 160-meter wide survey corridor. Gen-tie segments 3 and 4 have additional spur roads 1 and 2, resulting in a wider 60 meters of coverage on each side of the centerline at 10-meter intervals with an additional 50-meter buffer at 20-meter intervals on each side of the gen-tie. These survey areas have a survey corridor of 220-meters. Native parcels (D, F, and G) were surveyed at 10-meter intervals (Figure 2). An inventory of all plant species observed was recorded. Any California Rare Plant Rank (CRPR) plants were noted and their locations were recorded. Locations of any cacti (excluding cholla species, genus Cylindropuntia) on BLM lands were also recorded. The field team also searched for creosote bush rings on BLM lands. All locational information for special status species observed were recorded using a Global Positioning System (GPS). In addition to recording sign with the GPS unit, standardized paper datasheets were also completed. Surveyors included: Michelle Cloud-Hughes, Marc Baker, Dave Kesonie, Emily Thorn, and Lehong Chow. Page | 2 Athos Supplemental 2019 Botanical Survey Memo Report RESULTS Sensitive Species One special-status plant species not previously reported was detected during spring 2019 botanical surveys: Astragalus insularis var. harwoodii (CRPR 2B.2). Individuals of this plant were observed on gen- tie segment 2A and parcel group G (see Figure 3). No additional occurrences of special-status species reported previously were observed during the Spring 2019 survey. Locations of all special-status species detected on the Project site, including 2018 and 2019 field surveys, are shown in Figure 3. Cacti Counts Two species of cacti (excluding Cylindropuntia species) were observed during spring 2019 botanical surveys. Table 1 lists the cacti observations. Table 1. Cacti Count Results Cactus Species Location # Individuals Fishook cactus (Mammalaria tetrancistra) gen-tie 3 1 Barrel cactus (Ferocactus parcel group cylindraceus) F 2 Creosote Rings No creosote rings were observed. Plant list Several plant species were observed during the 2019 botanical surveys that were not previously detected due to poor germination. The full list of all plants observed since 2018 is included in Table 2 below. Table 2. Athos 2018-2019 Plants Observed SOLAR SCIENTIFIC NAME COMMON NAME GENUS GEN-TIE FARM Abronia villosa sand verbena Nyctaginaceae X Abronia villosa var villosa hairy sand verbena Nyctaginaceae X X Achyronychia cooperi onyx flower Caryophyllaceae X X Acmispon strigosus strigose lotus Fabaceae X X Aliciella latifolia broad leaf gilia Polemoniaceae X X Allionia incarnata windmills Nyctaginaceae X Page | 3 Athos Supplemental 2019 Botanical Survey Memo Report SOLAR SCIENTIFIC NAME COMMON NAME GENUS GEN-TIE FARM Ambrosia acanthicarpa annual burweed Asteraceae X Ambrosia dumosa white bursage Asteraceae X X Ambrosia ilicifolia holly leaf bursage Asteraceae X Ambrosia salsola cheesebush Asteraceae X X Amaranthus fimbriatus fringed amaranth Amaranthaceae X Amsinckia tessellata devil's lettuce Boraginaceae X X Antirrhinum filipes tangled snapdragon Plantaginaceae X Aristida sp. three-awn Poaceae X Aristida adscensionis three-awn Poaceae X *Antennaria sp. pussy toes Asteraceae X Asclepias erosa desert milkweed Apocynaceae X X Asclepias subulata skeleton milkweed Apocynaceae X Astragalus insularis var. Harwood's milkvetch Fabaceae X X harwoodii dwarf white Astragalus didymocarpus Fabaceae X milkvetch Astragalus lentiginosus freckled milkvetch Fabaceae X X var. variabilis Atriplex canescens hoary saltbush Chenopodiaceae X X Atriplex polycarpa allscale saltbush Chenopodiaceae X X Atrichoceris platyphylla gravel ghost Asteraceae X X Baileya pauciradiata laxflower Asteraceae X X Baileya pleniradiata wooly marigold Asteraceae X Baileya sp. desert marigold Asteraceae X Bebbia juncea sweetbush Asteraceae X Bebbia juncea var. aspera rush sweetbush Asteraceae X Boerhavia sp. slender spiderling Nyctaginaceae X Bouteloua sp. six-weeks gramma Poaceae X Bouteloua aristidoides var. needle grama Poaceae X X aristidoides Brandegea bigelovii desert starvine Cucurbitaceae X *Brassica tournefortii Sahara mustard Brassicaceae X X Calycoseris wrightii white tackstem Asteraceae X X Camissonia campestris Mojave suncup Onagraceae X *Carpobotus edulis highway ice plant Aizoaceae X Castela emoryi crucifixion thorn Simaroubaceae X Caulanthus lasiophyllus California mustard Brassicaceae X X Chaenactis carphoclinia pebble pincushion Asteraceae X X Chaenactis fremontii Fremont's pincushion Asteraceae X X Page | 4 Athos Supplemental 2019 Botanical Survey Memo Report SOLAR SCIENTIFIC NAME COMMON NAME GENUS GEN-TIE FARM Chaenactis stevioides desert pincushion Asteraceae X X Chaenactis xantiana fleshcolor pincushion Asteraceae X Chaenactis sp. pincushion Asteraceae X X *Chenopodium murale nettle leaf goosefoot Chenopodiaceae X X Condea emoryi desert lavender Lamiaceae X X Chorizanthe brevicornu brittle spineflower Polygonaceae X X Chorizanthe rigida spiny herb Polygonaceae X Chorizanthe corrugata wrinkled spineflower Polygonaceae X Chylismia brevipes ssp. golden suncup Onagraceae X X brevipes Chylismia claviformis browneyes Onagraceae X Croton californicus California croton Euphorbaceae X narrow leaved Cryptantha angustifolia Boraginaceae X X cryptantha bush-loving Cryptantha dumetorum Boraginaceae X cryptantha Guadalupe Cryptantha maritima Boraginaceae X cryptantha Cryptantha micrantha redroot cryptantha Boraginaceae X Nevada forget me Cryptantha nevadensis Boraginaceae X X not winged nut forget me Cryptantha pterocarya Boraginaceae X not Cryptantha sp. cryptantha Boraginaceae X Cucurbita palmata coyote melon Cucurbitaceae X Cylindropuntia silver cholla Cactaceae X X echinocarpa Cylindropuntia pencil cholla Cactaceae X X ramosissima Dalea mollis hairy prairie clover Fabaceae X X Dalea mollissima silky dalea Fabaceae X X Datura discolor small datura Solanaceae X X Datura wrightii jimson weed Solanaceae X X western tansy Descurainia