Those rebuilding in the Palisades need a biologist to verify it is not a Monarch Butterfly potential area.
People rebuilding in Pacific Palisades lost their homes/possessions, their yards, everything. The Army Corps of Engineers came to town and within five months had scrapped most lots clean. Then it’s been more than a year with insurance not paying and city requirements fluctuating.
Just when a Highlands resident had worked through those roadblocks and thought he was reaching the finish line and a final plan check, he was told he needed a biologist’s statement.
This four-page “Biologist’s Statement of Biological Resources,” through the City of L.A. Planning Department (CP-3613 [4.24.2025]) is required.
The biologist’s application statement notes “The California Environmental Quality Act directs public agencies to assess and disclose the environmental effects of the projects it approves. . . .failure by a project applicant to disclose known biological resources on the project site may results in a violation of CEQA.”
The form requires protected trees/shrubs to be addressed, to find out if the project is in the Monarch Butterfly Potential area and if there any other special status species within a 0.25-mile radius of the site.
Most of the builders, inspectors and architects the resident spoke with had never heard of this new requirement, so the resident reached out to a company Envicom, located in Westlake Village, for guidance.
The resident learned that Envicom will come to the site, fill out the report and the resident pays $2,200.
To recap. The entire lot burns. The resident rebuilds, but can’t get a final plan check until a biologist okays it.
The form specifies it has to be a qualified biologist, with a bachelor’s degree in biology or ecology and five years of professional experience . . .and knows the relevant local, state and federal laws and regulations governing the protection of biological resources and meets the CDFW qualifications for botanical field surveyors.
The form requires PUBLIC AGENCIES, not individuals, to complete the form, for projects they approve.
Just when you think it can’t get any worse … it does
Another GOVERNMENT imposed barrier to rebuilding. Another unnecessary cost. Another new “cottage industry” in the making. LA,’s rationale for growing the number of high-paid city staff workers. Individual and class action lawsuits will follow. The “buck” stops with callous Mayor Bass and Supervisor Lindsey Horvath. Fire them both in the coming election several months from now.
If it was okay before, why isn’t it okay now? Ridiculous!
First: A date correction. The form is CP-3613 [4.24.2025] — April 24, 2025, not 2005. This is a new form, created after the fires and after Newsom suspended CEQA.
Second: Yes, it is being required. This four-page “Biologist’s Statement of Biological Resources” through the City of LA Planning Department is being required of fire rebuild applicants. Most builders, inspectors, and architects had never heard of this new requirement.
Third: The form explicitly invokes CEQA as its basis. The biologist’s application statement itself reads: “The California Environmental Quality Act directs public agencies to assess and disclose the environmental effects of the projects it approves… failure by a project applicant to disclose known biological resources on the project site may result in a violation of CEQA.” The form requires identifying protected trees and shrubs, whether the project is in the Monarch Butterfly Potential area, and any special status species within a 0.25-mile radius of the site.
The core contradiction: Newsom suspended CEQA on January 12, 2025 for eligible rebuild projects. The City of LA, through its Planning Department, then created a brand new form in April 2025 — dated four months after the CEQA suspension — that requires a certified biologist to conduct a site survey and explicitly grounds its authority in CEQA. Eligible Projects are supposed to be waived from CEQA requirements thanks to state and local actions.
This looks like exactly the kind of administrative end-run you’ve been documenting — the city recreating CEQA compliance requirements under a different label, imposed after the governor suspended the law those requirements derive from. The form didn’t exist before the fires. It was created during the rebuilding process. And it requires hiring a specialist — Sounds like a boondogle the Circling the News piece notes residents were being referred to Envicom for guidance.
So here is what the City has done, in plain terms: Newsom suspended CEQA on January 12, 2025. The City of LA Planning Department then created a brand-new CEQA-grounded biological survey form in April 2025 — CP-3613 dated 4.24.2025 — and is requiring fire rebuild applicants to submit it. To complete that form, residents must hire from the city’s pre-approved contractor list. Envicom is on that list, was referred to residents by name in at least one case, and holds a city contract running through 2027. The applicant pays Envicom directly. Envicom works at the direction of the City.
The governor suspended the law. The city created a new form invoking the suspended law. The city then directs residents to pay city-contracted firms to satisfy the form the city created under the law the governor suspended.
This is a toll booth. The question: who authorized the creation of CP-3613 in April 2025, and did that person have authority to impose CEQA-based requirements after the governor’s suspension order?
“The “buck” stops with callous Mayor Bass and Supervisor Lindsey Horvath. Fire them both in the coming election several months from now.”
Who should we ‘hire’ with Austin out of the race?
Are any of you familiar with the “ghost neighborhood” that exists just to the west of the south runways at LAX? This neighborhood has been off limits for development for decades due to the area being a habitat for the El Segundo Blue Butterfly. The butterfly has endangered status and that prevents development from happening. It’s not far fetched to imagine that the “Biologist’s Statement of Biological Resources” is an attempt to officially label the Palisades as a Monarch butterfly “potential area”. This would halt rebuilding in the area. It’s also not far fetched to believe that at some point, after residents have given up plans to rebuild, that the requirement would be rescinded thus opening the door to what the government really wants which is a “20 minute city”.
Does this require a lawsuit directed towards LACP/Mayor Bass and Horvath et al to rescind this edict which flies in the face of the Governors suspension of CEQA? Where is his voice in all this? There needs to be a check on this rampant inter/intra agency power tussle. We have to insist that All of our Leaders take the lead to solve this unnecessary to the point of spiteful conundrum.
That area west of the airport was actually “put out of use” because of the increasing air traffic noise –and then no one wanted to live under the runways–and it because an area of concern, too for lasers. The streets are still there and photos of the development before the airport expanded are fascinating.
The Governor suspended CEQA so the City needs to STOP requiring this for rebuilds – end of story.
This form allows the applicant to make the declaration of biological resources provided it is signed with an original signature from the property owner and notarized.
https://planning.lacity.gov/odocument/f743e937-e944-4783-b163-543073d6a119/Owners_Declaration_of_Biological_Resources.pdf
For a desktop review and filing of the form, I was quoted $1,146 by a firm in Pasadena
glad to see that there is a requirement to protect butterfly habitat. It may be an onerous step but it is a necessary step, particularly since the fire destroyed so much butterfly habitat. Before the fire, I had extensive butterfly flowers planted and after the house burned down, I was concerned that we had lost all of the habitat. To my joy, when I returned to the property after the fire, I was greeted by aw Monarch butterfly and much of the habit survived the fire.