Ron Vanderhoff wrote this public comment in May to federal officials in response to proposed changes to weaken the Endangered Species Act.

“As a California botanist studying the region’s native plants, I have spent many years documenting and monitoring the status, distribution, ecology, and conservation of native plants in California. I have assisted U.S. Fish and Wildlife with Species Status Assessments and Recovery Plans.

Southern California is one of the world’s 36 Biodiversity Hotspots, comprising astonishing and diverse biological diversity. Native plants depend upon habitat, perhaps as much or more than any other biological organism. They depend upon this habitat very directly, since they are generally anchored to it. Protections of a native plant without associated protections of its essential habitat is of little value. I am concerned about the loss of these critical native plant habitats, especially for the nation’s endangered and threatened plant species.

Almost all of our listed plant species are restricted by very specific habitat requirements. These may be abiotic, such as soil types, precipitation, land aspects, temperature, nutrient availability, etc. Or they may be biotic, such as soil fungal associations, plant associates, pollinator presence, and much more. Usually, habitat is a specific combination of many of these ecological components. Our rare and threatened plants cannot persist without these very specific ecological requirements, more generally called habitats.

Native plants rely on specific, appropriate habitat for their continuation. The loss of these specific habitats does not mean that the plants can simply grow elsewhere. Orange County, California, the county I am centered in, has two endemic native plant species: the Laguna Beach Live-Forever (Dudleya stolonifera) and the Santiago Canyon Live-Forever (Dudleya chasmophyta).

The first was described as a species in 1949 and has been protected under the Federal Endangered Species Act since 1998. The latter was just declared a species last year and is awaiting possible petition as a protected species. It has been given a California Rare Plant Rank of 1B.1 by the CA Native Plant Society, its highest ranking. I am involved in the science and conservation of each of these species, both of which have very specific habitat requirements.

The limited habitat needed by the Laguna Beach Live-Forever is under pressure from development, invasive species, pollinator loss, and climate change.

Without habitat protections, this species would likely be headed to extinction. The Santiago Canyon Live-Forever, although not yet thoroughly assessed and listed, is only known to occur on a few thousand square meters of north-facing conglomerate rock cliff in a local canyon. In both cases, these rare native plants persist because their specific habitats persist. To protect species like these the U.S. Endangered Species Act must continue to protect critical habitat and strongly regulate the “take” of this habitat.

Plants, and especially native plants, are the foundation of biodiversity on earth. Plants quite literally feed the planet by feeding every other living organisms on the planet. The stewardship, conservation, restoration and recovery of our endangered species can only be effective if their associated habitats are also conserved, restored, and protected. I urge continuation of the U.S. Endangered Species Act with no changes.”

Ron Vanderhoff

Botanist

California Native Plant Society, California Invasive Plant Council, Calflora