SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN ENVIRONMENTAL IMPACT REPORT/ ENVIRONMENTAL ASSESSMENT ADDENDUM

Transcription

1 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN ENVIRONMENTAL IMPACT REPORT/ ENVIRONMENTAL ASSESSMENT ADDENDUM December 2009

2 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN ENVIRONMENTAL IMPACT REPORT/ ENVIRONMENTAL ASSESSMENT ADDENDUM Submitted to the: City of Brisbane Planning Department 50 Park Place Brisbane, CA Prepared by: LSA Associates, Inc Fifth Street Berkeley, CA December 2009

3 TABLE OF CONTENTS I. INTRODUCTION AND PROJECT DESCRIPTION... 1 A. ENVIRONMENTAL REVIEW UNDER CEQA...1 B. USE OF THE ENVIRONMENTAL CHECKLIST TO DETERMINE APPROPRIATE DOCUMENT...2 C. PROJECT DESCRIPTION...3 D. OTHER APPROVALS...16 E. ENVIRONMENTAL DOCUMENTS TO BE INCORPORATED BY REFERENCE..16 F. SUMMARY...18 II. PROJECT ANALYSIS A. TECHNICAL ANALYSIS...19 B. SUMMARY...27 III. REPORT PREPARATION A. REPORT PREPARERS...29 B. PRIMARY CONTACTS...29 C. REFERENCES...29 APPENDICES Appendix A: Environmental Checklist San Bruno Mountain HCP EIR/EA Addendum Appendix B: Amended Text of San Bruno Mountain HCP as Amended to Support ITP P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\00-TOC.doc (12/15/2009) i

4 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM TABLE OF CONTENTS FIGURES Figure I-1: Regional Location...4 Figure I-2: Habitat Conservation Plan Boundary...5 Figure I-3: Habitat Conservation Plan Acreage Distribution...6 Figure I-4: Northeast Ridge Parcel...7 Figure I-5: 1983 HCP Approved Northeast Ridge Project - Grading Limit in Open Space...10 Figure I Northeast Ridge Project - Grading Limit and Open Space...11 Figure I Northeast Ridge Project Construction Phases...13 P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\00-TOC.doc (12/15/2009) ii

5 I. INTRODUCTION AND PROJECT DESCRIPTION This document is the second Addendum to the Final Environmental Report and Environmental Assessment (the "HCP EIR/EA") that was prepared in 1982 for the adoption of the San Bruno Mountain Habitat Conservation Plan (the "HCP") and the issuance of an incidental take permit (an "ITP") for the HCP under section 10(a) of the federal Endangered Species Act. This Addendum, prepared by the City of Brisbane, describes amendments to the HCP proposed in 2007 (collectively, "HCP Amendment No. 5") and evaluates the effects of those amendments. The proposed HCP amendments require the approval of the City of Brisbane ("City"). The purpose of this Addendum ( 2009 HCP EIR/EA Addendum") is to inform City decision makers and the general public of the potential environmental effects that could result from approval of HCP Amendment No. 5. This Addendum, together with the HCP EIR/EA and the 1989 Addendum to the HCP EIR/EA ("1989 HCP EIR/EA Addendum"), will be used by the City Council and the public in their review of the proposed amendments. The City of Brisbane serves as the lead agency pursuant to CEQA in its consideration and use of this Addendum. The Brisbane City Council, the decision-making body, will consider this Addendum along with the previously-certified HCP EIR/EA and 1989 Addendum to the HCP EIR/EA prior to granting final approval and certifying this Addendum. As explained below, the amendment of the HCP also required an amendment to the incidental take permit ("ITP") issued for the HCP under the federal Endangered Species Act. The issuance of the ITP is a federal action and is outside the scope of the proposed project evaluated in this Addendum. However, the reader should note that the U.S. Fish and Wildlife Service ("Service") issued an amended Section 10(a)(1)(B) Incidental Take Permit (TE ) in May 2009 after preparation of Findings and Recommendations pursuant to the Endangered Species Act and Finding of No (the "FONSI") pursuant to the National Environmental Policy Act ("NEPA") for the Issuance of the amended ITP associated with Implementation of the amended HCP for San Bruno Mountain, which was supported by an Environmental Assessment in compliance with the National Environmental Policy Act, prepared in A. ENVIRONMENTAL REVIEW UNDER CEQA An addendum to a previously certified EIR is appropriate where some changes or additions to the EIR are necessary but the lead agency (here, the City) determines that none of the events described in section of the CEQA Guidelines (describing the conditions that require preparation of a subsequent EIR) has occurred (CEQA Guidelines 15164(a)). A brief explanation of the decision not to prepare a subsequent EIR should be included in the lead agency's findings on the project, or elsewhere in the record (CEQA Guidelines 15164(e)). Consistent with Guidelines sections and 15164, the City has determined that an addendum is appropriate to address the amendments to the HCP because: P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 1

6 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION The proposed amendments do not constitute substantial changes to the HCP that involve new or substantially increased significant impacts. The HCP as amended will reduce the overall area subject to development within the Northeast Ridge and conserve high value hilltop habitat for endangered butterfly species, thereby reducing the impacts associated with development. The amendments do not propose any change in the HCP management program for conserved habitat and will not result in a substantial change in the impacts associated with management activities. The circumstances under which the HCP is undertaken have not changed substantially in a way that creates new or substantially increased significant impacts, because (i) the callippe silverspot and bay checkerspot butterflies have always been designated as species of concern under the HCP, 1 and potential impacts to these species were analyzed in the HCP EIR/EA, (ii) their possible listing under the ESA was foreseen at the time the HCP was adopted; and (iii) current environmental conditions and identified threats to covered species and their habitats fall within the range of conditions that the HCP was designed to address. New information does not reveal that the proposed HCP amendments would result in new or more severe significant effects than those disclosed in the 1982 HCP EIR/EA and the 1989 HCP EIR/EA Addendum, as demonstrated by the technical analysis included in this Addendum and other supporting documents. New information does not reveal that any new mitigation measures or alternatives are now feasible or available that would substantially reduce impacts but that have not been adopted. Although members of the public have suggested alternative amendments, such as a "nodevelopment" configuration for the Northeast Ridge, these alternatives are not considered feasible inasmuch as they would not be consistent with land use designations under the HCP or with existing development entitlements associated with the Northeast Ridge project. The analysis and reasoning that support the City's determination are set forth in greater detail throughout this Addendum and in the supporting documents incorporated herein by reference. B. USE OF THE ENVIRONMENTAL CHECKLIST TO DETERMINE APPROPRIATE DOCUMENT Prior to the preparation of this Addendum, the City of Brisbane prepared a CEQA environmental checklist to determine whether the approval of HCP Amendment No. 5 would result in new or more severe significant effects than those found in the 1982 EIR/EA and 1989 HCP EIR/EA Addendum. The resulting checklist (attached to this document as Appendix A) examines each of the 16 environmental topics included in the checklist. Based on the environmental analysis conducted as part of the checklist preparation, the analysis contained in this Addendum, and the analysis contained in other documents (discussed below) prepared by the City, Service, and San Mateo County, the City has concluded that the proposed changes would not result in new significant environmental effects or substantially more severe environmental effects. For all topics, the environmental effects of the HCP amendments would be comparable to or less severe than those previously identified in the EIR/EA and subsequent amendments due to the revised operating program for the Northeast Ridge (Chapter 1 County of San Mateo San Bruno Mountain Area Habitat Conservation Plan. November. See pages III-4 through III-6. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 2

7 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION VII of the HCP), which would allow for reductions in the intensity and the physical extent of the Northeast Ridge project, as well as for supplemental funding. C. PROJECT DESCRIPTION The following section provides a project description for the HCP amendments that are the subject of this Addendum, including the project location, project background, and project description. 1. Project Location San Bruno Mountain is located on the northern San Francisco Peninsula, just south of the San Mateo- San Francisco County boundary. The Mountain is surrounded on all sides by the cities of Colma to the west, Daly City to the north, Brisbane to the east, and South San Francisco to the south. Figure I-1 shows the regional location. The San Bruno Mountain HCP study area consists of 3,537 acres, of which 2,326 acres are presently Conserved Habitat. Figure I-2 shows the HCP boundaries, and Figure I-3 shows the HCP acreage distribution. The acreage of the Northeast Ridge residential project area is located in the City of Brisbane, south of the San Mateo-San Francisco County boundary. Figure I-4 identifies the location of the Northeast Ridge parcel within the HCP boundaries. The Northeast Ridge project area is west of North Hill Drive, between Valley Drive to the south and Guadalupe Canyon Parkway to the north. Brisbane s central business district is located to the southeast, and the Crocker Industrial Park is located to the south. Guadalupe Canyon Parkway bounds the Northeast Ridge area to the north and west. Existing land uses surrounding the Northeast Ridge area include: residential development to the north; undeveloped open space directly to the east; multi-family residential development to the south; and San Bruno Mountain State Park to the west. 2. Project Background a. Adoption of the HCP and Issuance of the ITP. The HCP was designed as a long-term program for conserving the ecology of San Bruno Mountain. It provides comprehensive planning of development activities and conservation efforts on San Bruno Mountain, so as to allow public and private development projects while minimizing effects to sensitive biological resources on the mountain. As adopted, the HCP designated approximately 370 acres of the mountain for development and approximately 2,750 acres to be conserved and managed as habitat for HCP "species of concern," including the callippe and mission blue butterfly species, per the HCP Section VI-7. 2, 3 The HCP also imposed fees on authorized development activities, to be used to fund management and monitoring activities within conserved habitat. 2 Approximately 260 acres were left as "unplanned parcels," meaning that no development of these parcels could occur until a plan of development and conservation was prepared, consistent with the HCP. 3 To date, approximately 308 acres have been developed, and more than 2,800 acres are currently protected as Conserved Habitat. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 3

8 FIGURE I miles 20 San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum Regional Location SOURCE: DELORME, STREET ATLAS, I:\BRI0901 NE Ridge Addendum\figures\Fig_I1.ai (11/09/09)

9 FIGURE I-2 San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum Habitat Conservation Plan Boundary SOURCE: JONES & STOKES; TRA ENVIRONMENTAL SCIENCES, 2007 I:\BRI090 NE Ridge Addendum\figures\Fig_I2.ai (11/9/09)

10 FIGURE I-3 San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum Habitat Conservation Plan Acreage Distribution SOURCE: JONES & STOKES; TRA ENVIRONMENTAL SCIENCES, 2007 I:\BRI090 NE Ridge Addendum\figures\Fig_I3.ai (11/9/09)

11 Northeast Ridge FIGURE I feet San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum Northeast Ridge Parcel SOURCE: 1983 SAN BRUNO MOUNTAIN HCP EA; JONES & STOKES. 2007; I:\BRI090 NE Ridge Addendum\figures\Fig_I4.ai (11/10/09)

12 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION In 1982, when the HCP was adopted, the mission blue and callippe silverspot butterflies were the primary species of concern. These butterflies faced the possibility of extinction due to a variety of forces, the most significant of which was identified as the ongoing loss of habitat due to human and natural forces. 4 The mission blue was already listed as endangered under the federal Endangered Species Act ("ESA") at this time. The callippe had not been listed under the ESA but was regarded as imperiled, and its population biology and ecology on the mountain were studied in detail in preparing the HCP. 5 Additional HCP species of concern include the San Bruno elfin butterfly and San Francisco garter snake (already endangered in 1982), and the bay checkerspot butterfly (not yet listed in 1982). 6 Before adoption of the HCP, the County (as the lead agency under CEQA) and the Service (as the lead agency under NEPA) prepared the HCP EIR/EA in 1982 to analyze the effects of adopting the HCP. The HCP EIR/EA concluded that the adoption of the HCP would have significant unavoidable impacts, including the taking of endangered species, air quality degradation, traffic impacts and visual impacts. The County found that the HCP conservation measures, including the dedication and management of conserved habitat for the benefit of the callippe and mission blue butterflies and other species of concern, reduced the unavoidable impacts to an acceptable level when balanced against the social benefits of the proposed residential development within the Northeast Ridge, and that overriding considerations therefore warranted approval of the HCP. Based on the HCP EIR/EA, the Service found that the effects of the HCP on endangered species would be minimized and mitigated by the requirements set forth in the HCP, including the dedication of prime habitat to the public to be preserved in perpetuity for species of concern, and the enhancement and management of that habitat for the benefit of the species. Pursuant to section 10(a) of the ESA, the Service issued an ITP that authorized limited "take" of the mission blue butterfly, San Bruno elfin butterfly and San Francisco garter snake in connection with development and habitat management activities under the HCP. Because the callippe and bay checkerspot were not listed under the ESA when the HCP was adopted, no take authorization for these species was needed or granted at that time. As discussed below, the Service did not list the callippe as endangered until b. The Northeast Ridge Parcel. The HCP divided San Bruno Mountain into 36 "administrative parcels." Each parcel has an "operating program," which delimits the conserved habitat and developable area within that parcel and defines the rights and obligations of private landowners within the parcel who wish to develop their property consistent with the HCP, including the HCP fees applicable to development within the parcel. 4 The primary natural causes of habitat loss identified in the HCP are succession of grasslands to brush/scrub habitat, and the spread of exotic plant species. Human causes of habitat loss include trespassing by off-road vehicles and development activities. See HCP at S-1, S-8. 5 The Service proposed to list the callippe under the ESA in In 1980, however, all areas available for development within San Bruno Mountain were designated as critical habitat for the endangered mission blue butterfly. The Service therefore allowed the listing proposal for the callippe to expire, on the basis that the designation of mission blue habitat also protected the callippe, which used essentially the same habitat. HCP at II-3. The fact that the callippe was not listed under the ESA when the HCP was adopted therefore does not indicate that the callippe and its habitat had not been the object of extensive study and consideration by the Service in adopting the HCP. 6 The bay checkerspot has never been seen on the Northeast Ridge HCP Addendum, infra, at III-7. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 8

13 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION The Northeast Ridge lies within the Guadalupe Hills planning area and is designated administrative parcel The original operating program for the Northeast Ridge, when the HCP was adopted in 1982, allowed development of 92 acres and required the dedication of 138 acres as conserved habitat, as shown on Figure I-5. 7 The operating program allowed the development of a 1,250-unit residential project on the parcel, and the City approved a specific plan for such a project in c. HCP Amendments No In June 1985 the County applied for three amendments to the HCP, none of which involved the Northeast Ridge parcel, HCP funding provisions or incidental take coverage that are the subject of the proposed HCP Amendment No. 5. The three amendments were the South Slope Geotechnical Amendment ("HCP Amendment No. 1 ), the Rio Verde Heights Amendment ("HCP Amendment No. 2 ), and the County Park (Colma Dump) Amendment ("HCP Amendment No. 3"). The Service approved HCP Amendments No. 1 and No. 2 in 1985 and Amendment No. 3 in d. HCP Amendment No. 4. In February 1990, the City applied for the Northeast Ridge Project Equivalent Exchange Amendment ("HCP Amendment No. 4"), which revised the Northeast Ridge operating program in order to exchange some conserved habitat for development area within the parcel as shown on Figure I-6. The overall area of conserved habitat and development remained the same as under the original 1982 Operating Program, at 138 acres and 92 acres, respectively. 8 The revised operating program, however, allowed development of only 578 units, resulting in lower density of development. HCP Amendment No. 4 also increased the HCP charge assessed on development within the Northeast Ridge. The 1989 HCP EIR/EA Addendum was prepared to address the effects of the 1990 amendment. 9 The City (now acting as the lead agency under CEQA because it had obtained land use jurisdiction over the Northeast Ridge parcel) and the Service (for NEPA purposes) concluded that HCP Amendment No. 4 would not result in any new or substantially more severe significant environmental impacts. The 1989 HCP EIR/EA Addendum was approved in August Separately, the City of Brisbane granted land use approvals and entitlements (the "1989 VTM") authorizing the landowner to construct a revised residential development project on the Northeast Ridge consistent with the amended operating program. 7 The operating program permitted 35 acres of the conserved habitat to be disturbed during development and then restored before dedication to the public. 8 The revised operating program permitted 44 acres of the conserved habitat to be disturbed during development and then restored before dedication to the public. 9 Addendum to the Final Environmental Report and Supplement to the Environmental Assessment on Implementation of the San Bruno Mountain Conservation Plan and Endangered Species Act Section 10(a) Permit PRT , November P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 9

14 FIGURE I feet San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum 1983 HCP Approved Northeast Ridge Project - Grading Limit in Open Space SOURCE: CADILLAC-FAIRVIEW HOMES WEST; THOMAS REID ASSOCIATES, 12/15/89. I:\BRI090 NE Ridge Addendum\figures\Fig_I5.ai (11/9/09)

15 FIGURE I-6 not to scale San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum 1989 Northeast Ridge Project - Grading Limit and Open Space SOURCE: NORTHEAST RIDGE SOUTHWEST DIVERSIFIED; NOVEMBER 28, I:\BRI090 NE Ridge Addendum\figures\Fig_I6.ai (11/9/09)

16 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION e. Listing of the Callippe and Further Avoidance of s. Consistent with the revised operating program for the 1989 VTM, build out of the approved development on the Northeast Ridge proceeded in phases, in order to minimize adverse effects on species of concern. The first phase involved "Unit I," consisting of the southern portions of development area within the parcel. Later phases involved "Unit II," consisting of the northern portions of the development area. Unit II included two neighborhoods: the Hillcrest neighborhood in the northeast portion of the parcel ("Unit II Neighborhood I") and the Landmark neighborhood in the northwest portion of the parcel ("Unit II Neighborhood II"). In 1997, before the development of Unit II was complete, the Service listed the callippe as endangered under the ESA. Because the HCP already was designed and managed to benefit and conserve the callippe and its habitat, the listing did not require substantial changes to the HCP's land use designations or management provisions. However, the listing necessitated incidental take authorization before approved development or habitat management activities that might result in "take" of callippe could continue. Pursuant to section IX.a.4 of the HCP Agreement, the Service requested that the parties to the HCP meet and confer to determine whether there was further opportunity to reduce impacts to the callippe, prior to the issuance of incidental take authorization. After extensive study and deliberation, the parties agreed to further reduce the developable acreage within the Northeast Ridge parcel and dedicate additional land, previously planned for development, as conserved habitat. Specifically, the Service proposed that the development area planned for the Hillcrest neighborhood in Unit II, where development had not yet begun, be dedicated as conserved habitat. The Service proposed that the Landmark neighborhood of Unit II, where some development already had occurred, be slightly enlarged in order to compensate somewhat for the loss of the Hillcrest neighborhood. This had the effect of converting a small area at the northern fringe of the Landmark neighborhood, formerly designated as conserved habitat, to development. However, the overall net effect was to reduce developable acreage and increase conserved habitat by 8.93 acres, compared to the Northeast Ridge operating program as adopted in 1982 and amended in In addition, the Service considered the Hillcrest neighborhood to be of high value for the callippe, in part because it included hilltop areas used by the callippe for movement and mating. In contrast, the area newly proposed for development was considered by the Service as having low habitat value, in part because it included a eucalyptus grove and areas previously designated for temporary disturbance and restoration. Figure I-7 shows the 2007 Northeast Ridge proposed development and open space. The parties agreed in principle to the Service's proposed reconfiguration of the Northeast Ridge parcel. In addition, they agreed that the funding provisions found in the Northeast Ridge operating program would be revised to increase the HCP fees imposed on new development, providing additional funding for HCP habitat management. The landowner, Brookfield Northeast Ridge II LLC ("Brookfield"), also agreed to provide supplemental funding for habitat management in the form of a $4 million non-wasting endowment that would be managed by the HCP Trustees, providing additional assurance that adequate funds would be available in perpetuity to manage the conserved habitat for the benefit of the callippe and other species of concern. 10 In addition, the 2007 Modified Project would reduce the amount of conserved habitat to be temporarily disturbed by acres, compared to the project as approved under the 1989 VTM and operating program. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 12

17 FIGURE I feet San Bruno Mountain Habitat Conservation Plan EIR/EA Addendum 2007 Northeast Ridge Project - Construction Phases SOURCE: CARLSON, BARBEE & GIBSON, INC., OCTOBER, I:\BRI090 NE Ridge Addendum\figures\Fig_I7.ai (11/9/09)

18 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION In 2007, the City and the County formally applied to the Service to amend the ITP in order to authorize incidental take of the callippe and bay checkerspot butterflies in connection with HCP activities. For the City, as the entity with land use authority over the Northeast Ridge, this would allow it to grant approvals and permits to Brookfield for continued development within the Northeast Ridge parcel. The incidental take authorization would also allow Brookfield to conduct interim habitat management activities that Brookfield is required to undertake in temporarily disturbed areas of the Northeast Ridge before their dedication as conserved habitat (at which point the County, as HCP Operator and Habitat Manager, would become responsible for their management). For the County, which has no land use authority over the Northeast Ridge, incidental take authorization would allow it to resume certain management activities within potential callippe habitat, without fear of liability for incidental take of the callippe. At the same time, the City and County formally applied to the Service for approval of HCP Amendment No. 5, which would effect the reconfiguration of the Northeast Ridge and the revision of the funding provisions as described above. 11 The Service performed a biological study on the proposed HCP Amendment No. 5 and the proposed amendment to the ITP and concluded they would not jeopardize the survival or recovery of the callippe or bay checkerspot. It then prepared an Environmental Assessment of the proposed amendments pursuant to NEPA and determined they would not have significant environmental effects. The Service therefore granted approval of HCP Amendment No. 5, prepared a biological opinion and, on May 20, 2009, issued an amended ITP authorizing incidental take of the callippe silverspot and bay checkerspot butterflies. The amended ITP does not require approval by the City; therefore the proposed action is limited to the City's approval of HCP Amendment No. 5. f. Ongoing Activities Not Part of the Proposed Project. Most activities on the Northeast Ridge were delayed by the need to obtain incidental take authorization for the callippe silverspot and the lengthy deliberations over the reconfiguration of the Unit II development, as described above. But some activities that were already authorized by previous approvals have continued and are not part of the current proposed project. First, 17 new homes within the Northeast Ridge Unit I Landmark Village neighborhood have been constructed, pursuant to existing approvals issued under the 1989 VTM. These homes were completed in 2007 and Second, thinning and removal of eucalyptus trees have occurred, as required under the 1989 operating program for the Northeast Ridge. The tree removal occurred between December 2007 and June 2008 in order to remove obstacles to movement by callippe and other species of concern. The tree removal was not part of the 2007 Modified Project 13 and did not require incidental take authorization because it did not occur in callippe 11 The Service's approval is required for all amendments to the HCP; see "Other Approvals," below. 12 Although these 17 homes are not part of the proposed HCP Amendment No. 5, the Service's 2007 Environmental Assessment and FONSI considered the impacts of this construction in order to ensure that its analysis included all remaining impacts related to development of the Northeast Ridge, including potential cumulative impacts. 13 The 1989 revised operating program for the Northeast Ridge required removal of eucalyptus from developable areas and thinning of eucalyptus in conserved habitat. This required activity was delayed for some time by the listing of the callippe, but in November 2007 the HCP Habitat Manager (TRA) determined, and the USFWS concurred, that tree removal would not cause impacts to butterfly habitat. Thereafter, Brookfield removed the eucalyptus trees within the area currently designated for development (i.e., under the 1989 operating program) and thinned the trees within the area currently designated as conserved habitat. Under the HCP Amendment No. 5, the revised Northeast Ridge operating program would not require eucalyptus removal; the only additional tree removal activities to occur would be the removal of any remaining eucalyptus trees within areas newly designated for development (i.e., the trees that were formerly located in conserved habitat and thus were only thinned, and not removed completely). P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 14

19 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION habitat. 14 In connection with the eucalyptus removal and construction of the 17 homes described above, routine erosion control measures have been applied to disturbed areas. 3. Proposed Project HCP Amendment No. 5 would: (i) modify the HCP's existing operating program for the Northeast Ridge parcel, per amended Chapter VII of the HCP; (ii) amend the funding provisions contained in the HCP per amended section V(B); and (iii) amend section V.G. of the HCP to add the callippe silverspot butterfly and bay checkerspot butterfly to the list of species covered by the incidental take permit for the HCP. a. Northeast Ridge Operating Program Amendment. The amendment to the Northeast Ridge operating program (conserved habitat boundaries and funding provisions) would revise the area that is subject to development within the Northeast Ridge parcel, consistent with a revised vesting tentative map that Brookfield has submitted to the City (the "2007 Modified Project"). 15 As amended, the parcel would include acres of conserved habitat and approximately 84 acres of development. This represents a net increase in conserved habitat of 8.93 acres compared to the operating program as amended in Consistent with the 2007 Modified Project, the revised operating program would allow development of 71 residential units in Unit II as the last phase of development in this parcel, compared to 168 units previously approved. This represents a reduction of 80 units for the Northeast Ridge overall, because an additional 17 units were transferred from Unit II to Unit I and have already been constructed. The revised operating program also includes new funding provisions that would increase the HCP charge assessed on new homes constructed within the Northeast Ridge parcel, and provisions for supplemental funding in the form of an HCP Endowment funded by Brookfield. These funds would be used to support ongoing habitat management activities consistent with the HCP and would not change the habitat management program. The HCP charge on new homes would be approximately $850 (in 2007 dollars), adjusted annually for inflation, compared to $88.56 (in 2007 dollars) under the existing operating program. In addition, Brookfield would fund a $4 million HCP Endowment to be managed by the HCP Trustees for the ongoing habitat management and restoration activities of the HCP. b. Amendment to HCP Section V.B Funding Provisions. The amendments to the HCP funding provisions, per amended section V.B, are intended primarily to maintain consistency with the funding provisions in the revised operating program described above. 14 U.S. Fish and Wildlife Service Environmental Assessment for the San Bruno Mountain Habitat Conservation Plan Amendment, October. See Appendices containing the Biological Study and Analysis of Conserved Habitat for Amendments to the Habitat Conservation Plan for San Bruno Mountain and Incidental Take Permit PRT , prepared by TRA Environmental Sciences, p. 7 (October 2007). 15 The approval of the 2007 Modified Project and related development entitlements is not within the scope of the proposed project. The City of Brisbane is conducting separate environmental review in connection with the proposed modifications to the Northeast Ridge development entitlements. The consequences of those modifications, and the effects of building out the project as modified, are addressed in the 2007 NER EIR Addendum, which is incorporated herein by reference. See Addendum to the Final Environmental Report on the Northeast Ridge Residential Development, May 2007 (the "2007 NER EIR Addendum"). P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 15

20 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION c. Amendment to HCP Section V.G Incidental Take Provisions. The amendment to the HCP provisions, per amended section V.G., is intended to maintain consistency with the U.S. Fish and Wildlife Service's May 28, 2009, amendment of the ITP, which added take authorization for the callippe silverspot and bay checkerspot butterflies. The amendment to section V.G. simply updates the list of species for which incidental take authorization is provided under the HCP and does not, in itself, have any legal effect, because the Service has already issued the amended incidental take permit. The complete text of the proposed HCP amendments is attached as Appendix B. D. OTHER APPROVALS The amendment to the Northeast Ridge operating program has been processed as an "equivalent exchange amendment" pursuant to section IX.A.3 of the Agreement With Respect to the San Bruno Mountain Habitat Conservation Plan (the "Implementing Agreement"), to which the City is a party. The Implementing Agreement requires that such amendments be approved by the entity with local land use authority (the City) and by the Service. The amendment of the funding provisions at HCP section V.B and the amendment to the list of covered species at HCP section V.G. have been processed under the provisions for "all other amendments" per section IX.B of the Implementing Agreement. The Implementing Agreement requires that the local land use authority (the City), the Service and the County approve such amendments, although the County's approval is required only "with respect to impacts on conserved habitat," per HCP Implementing Agreement IX.B. In 2009, the Service completed its environmental review under NEPA; approved HCP Amendment No 5; and issued the amended ITP. 16 In addition, the County Board of Supervisors approved HCP Amendment No. 5 on September 22, E. ENVIRONMENTAL DOCUMENTS TO BE INCORPORATED BY REFERENCE The determinations set forth in this Addendum are supported by the following documents, all of which have been provided to the City Council, constitute a part of the administrative record for this Addendum, and all of which are incorporated herein by reference: (a) (b) Final Environmental Report and Environmental Assessment for the Adoption of the San Bruno Mountain Habitat Conservation plan and Endangered Species Act 10(a) Permit, November Final Environmental Report for the Northeast Ridge Development of San Bruno Mountain, December U.S. Fish and Wildlife Service, Amended Incidental Take Permit Number TE (May 28, 2009). 17 The County's approval primarily affects the management of conserved habitat where callippe or its host plant may be present. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 16

21 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION (c) (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) (n) Addendum to the Final Environmental Report and Response to Comments for the Northeast Ridge Project, Brisbane, California, September Addendum to the Final Environmental Report and Supplement to the Environmental Assessment on Implementation of the San Bruno Mountain Conservation Plan and Endangered Species Act Section 10(a) Permit PRT , November United States Fish and Wildlife Service final rule designating the callippe silverspot butterfly as an endangered species pursuant to the Endangered Species Act. 62 Fed. Reg (Dec. 5, 1997). Biological Opinion on the effects of the proposed continued implementation and amendment of the San Bruno Mountain Habitat Conservation Plan, U.S. Fish and Wildlife Service, Environmental Assessment for the San Bruno Mountain Habitat Conservation Plan Amendment, U.S. Fish and Wildlife Service, October The Environmental Assessment includes, as appendices, the Biological Study and Analysis of Conserved Habitat for Amendments to the Habitat Conservation Plan for San Bruno Mountain and Incidental Take Permit PRT , prepared by TRA Environmental Sciences (October 2007), and the San Bruno Mountain Habitat Management Plan 2007, prepared by TRA Environmental Sciences (September 2007). Addendum to the Final Environmental Report on the Northeast Ridge Residential Development, City of Brisbane, May Landmark at the Ridge Application for Vesting Tentative Map and Associated Permits submitted by Brookfield Homes Bay Area Inc., dated May 2007 (the 2007 Modified Project). San Mateo County Staff and Technical Advisory Committee Report regarding Habitat Management Plan with attachments, dated Minutes of February 11, 2008 and March 10, 2008 Brisbane City Council Meetings. At these meetings, the City Council conducted public hearings on the Northeast Ridge project and considered the environmental effects of the project and the proposed amendments to the HCP. Record of public notice for November 16, 2009 Brisbane City Council public hearing on approval of HCP Amendment No. 5 and modifications to Northeast Ridge project, dated November 6, 2009 (at its meeting on November 16, 2009, the City Council continued the public hearing to January 19, 2010). San Bruno Mountain Habitat Conservation Plan Year 2008 Activities Report for Special Status Species, Endangered Species Permit PRT , TRA Environmental Sciences, January Biological Opinion on the Amendment of the San Bruno Mountain Habitat Conservation Plan, U.S. Fish and Wildlife Service May 20, P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 17

22 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM I. INTRODUCTION AND PROJECT DESCRIPTION (o) (p) (q) Amended Section 10(a)(1)(B) Incidental Take Permit for the San Bruno Mountain Habitat Conservation Plan, San Mateo County, California, U.S. Fish and Wildlife Service, May 20, Findings and Recommendations Pursuant to the Endangered Species Act and Finding of No pursuant to the National Environmental Policy Act for the Issuance of a Section 10(a)(1)(B) Incidental Take Permit (TE ), U.S. Fish and Wildlife Service, May 28, Response to Issues Raised During the Review of Status Reports on San Bruno Mountain Habitat Management and Biological Monitoring, San Bruno Mountain HCP Technical Advisory Committee, August F. SUMMARY Based on the environmental analysis conducted as part of the preparation of the environmental checklist (see Appendix A), the analysis contained in this Addendum as Chapter II, Project Analysis, and the analysis contained in other documents identified above and incorporated by reference that were prepared by the City and the Service, the City has concluded that the HCP Amendment No. 5 would not result in new significant environmental effects or substantially more severe environmental effects than those that were identified in the 1982 HCP EIR/EA or 1989 HCP EIR/EA Addendum. Additionally, the circumstances under which the HCP is undertaken have not changed substantially in a way that creates new or substantially increased significant impacts, and new information does not reveal that the proposed HCP Amendment No. 5 would result in new or more severe significant effects than those disclosed in the 1982 HCP EIR/EA and the 1989 HCP EIR/EA Addendum, or that any new mitigation measures or alternatives are now feasible or available that would substantially reduce impacts but that have not been adopted. For all topics, the environmental effects of HCP Amendment No. 5 would be less severe than those previously identified in the HCP EIR/EA and subsequent amendments due to the revised operating program for the Northeast Ridge (Chapter VII of the HCP), which would allow for reductions in the intensity and the physical extent of the Northeast Ridge project, and for supplemental funding. Therefore, an EIR addendum is the appropriate CEQA document to inform the City Council of the potential effects related to the HCP as amended. No further environmental analysis under CEQA is required. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\1-IntroProjDesc.DOC (12/15/2009) 18

23 II. PROJECT ANALYSIS This section updates the HCP EIR/EA to address the potential environmental effects of the HCP as it would be amended by HCP Amendment No. 5. Because the HCP is concerned primarily with the conservation of the San Bruno Mountain ecosystem, this Addendum focuses primarily on potential biological impacts - especially the potential biological impacts of the proposed Amendment on the callippe and mission blue butterflies, which share much of the same habitat. As summarized in the Environmental Checklist included as Appendix A to this Addendum, other types of potential effects have been fully evaluated in the technical analysis performed for the Amendment, including the 2007 Environmental Assessment ("2007 EA") prepared by the Service to support its Finding of No under NEPA (the "2009 FONSI") 1. A. TECHNICAL ANALYSIS The following technical analysis addresses the following issues: Effects Resulting from the Development of the Northeast Ridge Parcel Habitat Fragmentation and Butterfly Movement Corridors Potential Cumulative s Effects of Management and Monitoring of Conserved Habitat Effects of Supplemental HCP Funding Natural Events Affecting Conserved Habitat 1. Effects Resulting from the Development of the Northeast Ridge Parcel The development of Unit II of the Northeast Ridge under the revised operating program per HCP Amendment No. 5 would require grading of acres of undisturbed land, including acres that would be permanently disturbed and 2.97 acres that would be restored pursuant to the restoration guidelines in the Habitat Management Plan. Of this disturbed acreage, approximately 11 acres would be grassland habitat. By comparison, development of Unit II under the 1989 VTM and existing Northeast Ridge operating program would require grading of 40 acres, including 25.6 acres that would be permanently disturbed and 14.4 acres that would be restored. Overall, the proposed amendment would result in a net increase in conserved habitat of 8.93 acres compared to the 1989 VTM and existing operating program. The amendment would designate new conserved habitat on the Northeast Ridge that is larger in size and higher in biological value than either the habitat that would be preserved under the existing operating program or the habitat lost as a result of the reconfiguration. New impacts to previously designated (but not dedicated) conserved habitat 1 USFWS, Findings and Recommendations pursuant to the Endangered Species Act and Finding of No pursuant to the National Environmental Policy Act (May 28, 2009). P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 19

24 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS would be limited to approximately 0.84 acre that consists primarily of a eucalyptus grove, which does not provide habitat for the callippe silverspot or mission blue butterflies. Regarding the effects of temporary and permanent habitat disturbance, the Service determined that the callippe silverspot butterfly and the mission blue butterfly may be harassed, injured, or killed as a result of construction activities, and young and eggs may be injured or killed as a result of being crushed or buried by earth moving activities. Increased levels of dust caused by construction or other earth moving activities also may clog butterfly spiracles (breathing tubes) and asphyxiate the early stages of the two species, although the inclusion of dust control measures during construction activities should minimize these potential effects. s to callippe silverspot and mission blue butterflies would also result from the loss of larval host plants (Johnny jump-up (viola pedunculata) and lupine (Lupinus albifrons, L. formosus, and L. variicolor) respectively) and nectar plants. However, the Service found that the proposed HCP Amendment No. 5 would not substantially alter the severity of these impacts, which are deemed to be less than significant, because the activities performed under the proposed HCP Amendment would be similar in kind and substantially reduced in extent compared to those approved under the existing HCP (i.e., under the 1989 VTM). 2 More specifically, the Service found that the proposed revised operating program for the Northeast Ridge parcel would reduce impacts to the callippe silverspot and the mission blue butterflies compared to the HCP's existing operating program for the Northeast Ridge because: (1) it would have a smaller development footprint than the parcel as configured under the existing Northeast Ridge operating program, due to the elimination of Unit-II Neighborhood-I (Hillcrest) (UII-NI); and (2) the proposed configuration would conserve more hilltopping habitat than would have been conserved under the existing operating program. Hilltopping habitat is important for the callippe silverspot butterfly because the adult males patrol for females on summits and ridgetops, while females fly uphill to mate and downhill to oviposit within areas containing Johnny jumpup. The grassland also supports lupines and nectar plants utilized by the mission blue butterfly. The 2007 Modified Project significantly reduces impacts to hilltop and downslope ovipositing habitat for both of these endangered species by eliminating the development of UII-NI. The site of UII-NI has been described as "...prime habitat for both butterfly species, particularly the [callippe]". 3 Murphy stated that UII-NI "...has greater negative impacts than development in other Northeast Ridge areas." 4 The Service also found that reconfiguration of the Northeast Ridge development and conserved habitat is not likely to result in take of the San Bruno elfin butterfly, Bay checkerspot butterfly or San Francisco garter snake, or to have adverse effects on the San Francisco lessingia, because these species or their host plants are not found within the Northeast Ridge. 5 2 USFWS, Intra-Service Biological Opinion on the Amendment to the San Bruno Mountain Habitat Conservation Plan p (May 20, 2009). 3 Murphy, D.D. and P.R. Ehrlich, Conservation biology of California remnant native grasslands. Pages in L.F. Huenneke and H.A. Mooney, editors. Grassland structure and function: California annual grassland. Kluwer Academic Publishers, Dordrecht, Netherlands. 4 USFWS, Intra-Service Biological Opinion on the Amendment to the San Bruno Mountain Habitat Conservation Plan p (May 20, 2009). 5 USFWS FONSI, supra, at p. 33. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 20

25 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS 2. Habitat Fragmentation and Butterfly Movement Corridors The proposed development under the 2007 Modified Project includes the construction of 71 homes. These homes will be two stories high, and the permanent footprint of the development ranges from approximately 50 to 1,300 feet across. Temporary disturbance will add 100 to 200 feet to the width of the project footprint, although these areas will not contain structures that could serve as a barrier to butterfly movement and will be restored. a. Preservation of Contiguous Habitat. In its 2009 Biological Opinion, the Service found that the 2007 Modified Project results in less fragmentation than the 1989 VTM due to clustering of the development in Unit-II Neighborhood-II (Landmark) ("UII-NII"). Development under the 2007 Modified Project would be located in an area dominated by grassland and blue gum eucalyptus. The deletion of UII-NI (Hillcrest) would result in preservation of a larger, contiguous grassland habitat block that includes the two primary hilltop areas on the Northeast Ridge: Callippe Hill and an unnamed hill to the east. While Callippe Hill has been conserved as habitat through the existing HCP, the 1989 VTM would have severely impacted the unnamed hill to the east. These changes will benefit the callippe and mission blue because they allow the preservation of larger, more contiguous habitat areas one of the key recommendations in the design guidelines included in the HCP. 6 Temporary disturbance associated with the 2007 Modified Project would include an area that is approximately 880 feet long and 100 to 200 feet wide, located on the south side of a ridgeline, approximately 100 feet south of Guadalupe Canyon Parkway. The ridgeline has consistently been utilized by the callippe silverspot butterfly, as have hilltops and ridgeline areas to the north and east. 7 However, the impact from grading on the south side of the ridgeline is anticipated to be temporary because the topographic high point of the ridgeline would remain and continue to provide hilltopping habitat for the callippe silverspot butterfly. After grading, the disturbed area would be restored to grassland habitat. b. Movement Corridors. The existing four-lane Guadalupe Canyon Parkway located directly to the north of the Northeast Ridge is not a permanent barrier to mission blue and callippe silverspot butterflies. Several studies have found that roads do not appear to substantially restrict the movement of butterflies. 8 In these studies, butterflies with different dispersal tendencies also differed in their behavioral response to road edges. The more vagile, strong flying species were less sensitive to road 6 See HCP Design Guidelines at HCP p. III For documented callippe observations within survey Transects 3, 4, 5, 13 and 14, see, e.g., San Bruno Mountain Habitat Conservation Plan Year 2008 Activities Report for Special Status Species, Endangered Species Permit PRT (TRA Environmental Sciences January 2009); San Bruno Mountain Habitat Conservation Plan Year 2006 Activities Report for Special Status Species, Endangered Species Permit PRT , (TRA Environmental Sciences February 2007); San Bruno Mountain Habitat Conservation Plan Year 2005 Activities Report for Special Status Species, Endangered Species Permit PRT (TRA Environmental Sciences February 2006); San Bruno Mountain Habitat Conservation Plan Year 2004 Activities Report for Special Status Species, Endangered Species Permit PRT (TRA Environmental Sciences August 2005). 8 Mungira, M.L. and J.A. Thomas Use of road verges by butterfly and burnet populations, and the effect of roads on adult dispersal and mortality. Journal of Applied Ecology 29: Ries, L., D.M. USFWS FONSI, supra, at pp Ries and Debinski 2001; Ries et al. 2001; Saarinen et al. 2005, cited. Valtonen, A. and K. Saarinen A highway intersection as an alternative habitat for a meadow butterfly: effect of mowing, habitat geometry, and roads on the ringlet (Aphantopus hyperantus). A1mals Zoologica Fennici 42: P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 21

26 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS barriers 9 than species that were either habitat specialists 10 or those that were not efficient dispersers. 11 Callippe silverspot butterflies are strong fliers, as are members of the genus Speyeria as a whole. 12 In addition, the callippe has been observed flying across Guadalupe Canyon Parkway during annual monitoring over the past 25 years. The mission blue was observed on two occasions crossing Guadalupe Canyon Parkway, and once crossing a 40-foot wide road at Twin Peaks. 13 While roadways may not be a significant barrier to butterflies, the vehicles that travel on them can result in significant levels of mortality. 14 When measured, usually less than 10 percent of butterflies from study populations experienced direct vehicle mortality due to road crossing, 15 although McKenna et al. suggested a higher proportion of mortality was possible. The number of butterflies that are able to move across Guadalupe Canyon Parkway is dependent on various factors, including the amount of traffic and the speeds of the vehicles. But the majority of traffic on Guadalupe Canyon Parkway is during the early morning and early evening "rush hour," periods when the two listed butterflies have not yet begun flying or are less likely to be active. Currently there is conserved habitat on both sides of Guadalupe Canyon Parkway - the Saddle and Rio Verde parcels on the north, and the Northeast Ridge Water Tank Parcel and the Northeast Ridge on the south. The habitat on the north side of the Parkway is approximately 250 to 400 feet in width and would not be affected by the Northeast Ridge development. The Water Tank Parcel would also not be affected by development within the Northeast Ridge. After development of the 2007 Modified Project, the conserved habitat within the Northeast Ridge parcel along the south side of Guadalupe Canyon Parkway would vary in width from approximately 87 feet to 250 feet. Thus the total corridor width, including the habitat on the north and south sides of the Parkway, would range from approximately 350 feet to 600 feet. As noted before, butterflies have been observed on both sides of Guadalupe Canyon Parkway and crossing the road. The area to be conserved on the south side of the Parkway, within the Northeast Ridge parcel, includes a steep hilltop that currently provides important habitat for callippe, as well as a portion of the north-facing slope along the Parkway that contains one of the densest colonies of Lupinus albifrons (host plant for the Mission blue butterfly) on the entire Mountain. If managed effectively over time, this area would continue to provide important habitat for these species. Management would be provided for under the revised Northeast Ridge operating program, which would require the HCP Operator to manage habitat strips along both sides of the Parkway, and the area around the 9 Mungira and Thomas 1992; USFWS FONSI, supra, at pp , Ries and Debinski 2001, op. cit. 10 USFWS FONSI, supra, at pp , Ries and Debinski 2001, op. cit. 11 Mungira and Thomas 1992; op. cit. Valtonen, A. and K. Saarinen. 2005, op. cit. 12 Howe, W.H., The Butterflies of North America. Doubleday and Company, Garden City, New York. 13 San Bruno Mountain Habitat Conservation Plan Steering Committee San Bruno Mountain Habitat Conservation Plan (Final). The County of San Mateo, South San Francisco, California. 14 Mungira and Thomas 1992, op. cit. USFWS FONSI, supra, at pp , cited McKenna et al. 2001; Ries et al Mungira and Thomas 1992; Ries et al. 2001; Valtonen and Saarinen 2005, op. cit. USFWS FONSI, supra, at pp , cited Ries et al P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 22

27 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS water tank, as butterfly movement corridors to facilitate exchange of butterflies between the Northeast Ridge and Saddle areas. This also would include restoration of existing coastal scrub areas north of the Parkway and near the water tank to grassland habitat. 16 In addition, the 2007 Modified Project would replace a public roadway, planned under the 1989 VTM to connect the development to Guadalupe Canyon Parkway, with an emergency vehicle access that would have a smaller footprint and be less trafficked than the planned public roadway. The 2007 EA analysis addressed the fact that the proposed HCP amendments allow the Northeast Ridge development area to be slightly enlarged at the northwest corner of the site, encroaching slightly on what was formerly conserved habitat and slightly narrowing the "corridor" between the Northeast Ridge development and Guadalupe Parkway to the north. The Service analyzed the effects of this change in the 2007 EA, and concluded it would not have significant adverse effects. The Service found that implementation of the 2007 Modified Project would not result in a complete barrier to east-west movement of the callippe or mission blue butterflies, because the butterflies would be able to fly through the cut and thinned eucalyptus grove, open areas, spaces between the homes, and around the north side of the development. In addition, the Service specifically found that the change would not prevent butterfly movement along the north side of proposed residential units 39-50, which are directly south of Guadalupe Canyon Parkway, or prevent movement back and forth over Guadalupe Canyon Parkway. This change is also addressed in Service's response to comments on the EA and its Finding of No under NEPA. Taking all these factors into account, the proposed HCP amendment would not result in new significant impacts, or a substantial increase in the severity of previously identified significant effects, from habitat fragmentation and isolation. 3. Potential Cumulative s It should be noted that the Northeast Ridge parcel is part of the HCP as a whole, which inherently minimizes potential cumulative effects by planning for comprehensive conservation and limited development within the HCP area. The proposed HCP amendment would allow the completion of development in the HCP's final remaining Planned Parcel but would not allow "new" development not already taken into account in the HCP planning process. All prior development activities have been accounted for in the environmental review undertaken in the HCP EIR/EA, First HCP Addendum, and in the Service s 2007 EA, and no further development is anticipated under the HCP. Therefore, the proposed HCP Amendment No. 5 would not have the potential to create new or substantially more severe cumulative effects, especially given that it would actually reduce planned development within the HCP. 4. Effects of Management and Monitoring of Conserved Habitat The proposed HCP amendments would provide additional funding for the continued implementation of management activities that were anticipated in the HCP EIR/EA. Furthermore, the addition of incidental take authorization for the callippe silverspot and bay checkerspot butterflies would allow habitat management activities to resume in areas where the callippe or bay checkerspot, or their host 16 Revised Northeast Ridge Operating Program, 2(g)(4). P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 23

28 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS plants, may be present. The potential effects of the proposed funding changes and incidental take authorization on management activities were fully evaluated in the 2007 EA. The Service determined that the increased funding would not substantially adversely affect HCP species of concern, including the callippe and mission blue, and instead would provide a net benefit to the species. Please refer to the 2007 EA and 2009 FONSI, which are available at the City of Brisbane Planning Department, for additional detail. It should be noted that the Service's 2007 EA for HCP Amendment No. 5 contains some discussion of measures that the County will incorporate in order to minimize any take associated with management activities. However, because the amendments do not propose to revise the habitat management program, and because the City is not responsible for habitat management activities, the potential environmental effects of HCP habitat management activities are only briefly reviewed in this Addendum. They will not result in new, significant impacts or a substantial increase in the severity of previously identified significant effects to covered species of concern as analyzed in the 1982 HCP EIR/EA. The Service has found that implementation of HCP management actions may result in the death, injury, harassment, or harm of the mission blue butterfly, San Bruno elfin butterfly, callippe silverspot butterfly, Bay checkerspot butterfly, and the San Francisco garter snake, and adverse effects to the San Francisco lessingia due to clearing of vegetation and other activities associated with hand clearing, flaming, herbicides, livestock grazing, prescribed burning, pile burning, mowing, mechanical clearing, replanting/restoration, suppression, and mechanical treatment. However, adverse affects to the San Bruno elfin, mission blue butterfly, and San Francisco garter snake were analyzed in the 1982 HCP EIR/EA and Service's subsequent environmental review documents and the proposed HCP amendment does not alter the analysis. 17 Activities associated with vegetation management are necessary to eliminate or control invasive plants that compete with the plants utilized by the listed butterflies, degrade or eliminate habitat for the San Francisco garter snake, or degrade the habitat of or outcompete the San Francisco lessingia, and thus result in significant long-term benefits to the survival and recovery of these species in the wild. Without implementation of the management activities, the San Bruno elfin butterfly likely will decline in status, and the callippe silverspot butterfly and the mission blue butterfly are highly likely to be extirpated in the foreseeable future from San Bruno Mountain. The existing HCP implements several actions described in the recovery plan for the San Bruno elfin butterfly and mission blue butterfly, 18 and the proposed HCP amendment does not change this. Regarding the general effectiveness of HCP management activities, it should be noted that the HCP was adopted against a backdrop of rapid loss of grassland habitat to invasive plant species. HCP habitat management activities have reduced the aerial extent of the primary invasive species threats to the HCP species of concern and protected the core habitat areas of the species of concern through consistent management activities since the issuance of the original ITP. 19 Protecting existing grasslands within conserved habitat is particularly important for the callippe, because efforts to create or restore callippe habitat by artificially propagating the callippe host plant, viola, have met with limited success to date. 17 USFWS, FONSI at USFWS Recovery plan for the San Bruno elfin and mission blue butterflies. Portland, Oregon. 81 pages. 19 See, e.g., Year 2006 Activities Report, supra, at p. 10. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 24

29 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS Between 1982 and 2004, grasslands in conserved habitat decreased by approximately 122 acres - a substantially slower rate of loss than that experienced before the adoption of the HCP. This indicates that the HCP mitigation measures are beneficial and effective in combating loss of habitat to invasive species. With expanded management activities to also address coastal scrub succession, it should be possible to further slow and ultimately reverse the loss of grassland habitat. In addition, butterfly populations have been relatively stable during the period of the HCP (within the limits of natural variation), 20 again indicating that the mitigation measures do not have significant adverse effects on the species of concern and are effective in protecting the native San Bruno Mountain ecosystem on which the species depend. 5. Effects of Supplemental HCP Funding The existing annual revenue for management of the HCP area is approximately $140,000 (in 2005 dollars). Over the course of the HCP's history, annual spending has varied widely from year to year, from $60,000 to more than $200,000, while focusing on a "core program" of management aimed at controlling exotic species. At present, the habitat management program also includes biannual monitoring of species of concern. The Draft San Bruno Mountain 5-Year Plan identifies a range of scenarios for "enhanced" management of conserved habitat, the cost of which runs from approximately $140,000 per year (for the existing core program plus controlled burning and grazing) to approximately $383,000 per year (for comprehensive management of all Priority One areas), to a maximum of approximately $425,000 per year (for comprehensive management of all Priority One areas plus extensive monitoring every year and a $10,000 annual contribution to a contingency fund) (TRA Draft San Bruno Mountain HCP 5 Year Plan 2004). 21 Under the proposed HCP Amendment No. 5, Brookfield would fund a non-wasting HCP Endowment in the amount of $4 million, to be managed by the HCP Trustees. The Service has estimated that this endowment would yield an annual return of approximately $200,000, based on the performance of numerous endowment funds established for species conservation banks over the last 20 years within the jurisdiction of the Service s Sacramento district office. The 5 percent annual rate of return is also within the range used by various conservancy organizations and accepted by other government agencies. Actual returns will vary from year to year, but the Service concluded that this was a reasonable rate of return to expect over time. In addition, new homes constructed within the Northeast Ridge would pay both the existing inflation-adjusted HCP charge, which was set at $20.00 in 1982 and was approximately $83 in 2005 dollars; and (2) a new, fixed charge of $ per home (not adjusted for inflation). This supplemental funding, when combined with the existing funding and the proposed HCP Endowment, would generate approximately $400,000 per year for habitat management and monitoring activities. Accordingly, the Service has found that the supplemental funding provided by the proposed HCP amendment would allow for the expansion of management activities under the existing habitat 20 See, e.g., Year 2008 Activities Report, supra, at p. 8 (finding that no long-term changes in callippe population sizes are occurring); Year 2006 Activities Report, supra, at p. 10 (explaining that, to date, no statistically significant longterm trends in mission blue population have been detected). 21 Thomas Reid Associates, Administrative Draft San Bruno Mountain, Habitat Conservation Plan, Volume 1, Amended 2004, For Endangered Species Permit Prt San Mateo County Department of Environmental Management. See also Draft Special Report on San Bruno Mountain Habitat Conservation Plan Management Budget, Thomas Reid Associates (August 2006). P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 25

30 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS management program. 22 As noted above, the success of the existing core program at protecting habitat against invasive plant species and slowing the rate of grassland habitat loss indicates that the mitigation measures are effective. An expanded management program that also addresses coastal scrub succession would have the potential to further slow and ultimately reverse habitat loss, providing additional benefits to HCP species of concern and the ecosystem as a whole. Conversely, although the adequacy of overall funding for HCP management is not within the scope of the proposed HCP Amendment, the Service concluded in its 2009 Biological Opinion on the HCP Amendment that, without the supplemental funding, the habitats utilized by the callippe silverspot butterfly and the other listed butterfly species would continue to decline to such a point that those species are highly likely to become extirpated from the HCP site in the foreseeable future. Because the Northeast Ridge site is among the last planned parcels to be developed within the HCP area, and because no other viable source of additional funding has been identified, the proposed HCP Amendment No. 5 offers the only available source of supplemental funding at present. 6. Natural Events Affecting Conserved Habitat The San Bruno Mountain ecosystem has developed as a result of both human-caused and natural events, including wildfires. Fire is a fairly common event on the Mountain; typically more than one large fire (several tens of acres to hundreds of acres in size) occurs on San Bruno Mountain every year. 23 These fires have routinely occurred within prime callippe silverspot habitat in Brisbane Acres, Southeast Ridge, Northeast Ridge and other areas. In each case, the callippe has recovered well and monitoring data over the span of the HCP have indicated the population has remained stable. No long term negative impacts to callippe silverspot from fires have been documented. Although fire has the potential to kill butterflies and their host plants, the process is considered to be beneficial because fire efficiently removes brush and thatch, which have been documented to negatively impact the callippe's host plant, viola pedunculata. In 2008, two fires occurred on San Bruno Mountain one on the Southeast Ridge and one in Owl and Buckeye canyons. The typical HCP management response to wildfire is to monitor the recovery of habitat in these areas and undertake restoration efforts as needed. This will be the case with the habitat affected by the 2008 fires. 24 Because regular fires are a routine occurrence within the HCP area and have potentially beneficial effects, and because they have not been documented to cause long term negative impacts to HCP species of concern, these events do not necessarily represent cause for concern or require reassessment of the basic approach underlying the HCP. 22 U.S. Fish and Wildlife Service, Findings and Recommendations Pursuant to the Endangered Species Act and Finding of No pursuant to the National Environmental Policy Act for the Issuance of a Section 10(a)(1)(B) Incidental Take Permit (TE ), U.S. Fish and Wildlife Service, May 28, 2009, at See, e.g., Year 2006 Activities Report, supra, at p. 8; Year 2008 Activities Report, supra, at p See Response to Issues Raised During the Review of Status Reports on San Bruno Mountain Habitat Management and Biological Monitoring, San Bruno Mountain HCP Technical Advisory Committee, August 2009; Year 2008 Activities Report, supra, at p. 8. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 26

31 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS B. SUMMARY Based on the environmental analysis conducted as part of the preparation of the environmental checklist (see Appendix A) and the project analysis contained in this chapter, as well as the analysis contained in other documents identified above and incorporated by reference that were prepared by the City and Service, the City of Brisbane has concluded that the HCP Amendment No. 5 would not result in new significant environmental effects or substantially more severe environmental effects than those that were identified in the 1982 HCP EIR/EA or 1989 HCP EIR/EA Addendum. Additionally, the circumstances under which the HCP is undertaken have not changed substantially in a way that creates new or substantially increased significant impacts, and new information does not reveal that the proposed HCP Amendment No. 5 would result in new or more severe significant effects than those disclosed in the 1982 HCP EIR/EA and the 1989 HCP EIR/EA Addendum, or that any new mitigation measures or alternatives are now feasible or available that would substantially reduce impacts but that have not been adopted. For all topics, the environmental effects of the HCP Amendment No. 5 would be less severe than those previously identified in the HCP EIR/EA and subsequent amendments due to the revised operating program for the Northeast Ridge (Chapter VII of the HCP), which would allow for reductions in the intensity and the physical extent of the Northeast Ridge project, and for supplemental funding. Therefore, an EIR addendum is the appropriate CEQA document to inform the City Council of the potential effects related to the HCP as amended. No further environmental analysis under CEQA is required. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 27

32 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM II. PROJET ANALYSIS P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\2-ProjectAnalysis.DOC (12/15/2009) 28

33 III. REPORT PREPARATION A. REPORT PREPARERS LSA Associates, Inc Fifth Street Berkeley, California Judith H. Malamut, AICP, Principal-in-Charge and Project Manager Adam Weinstein, AICP, Associate Patty Linder, Graphics Manager Jennifer Morris, Word Processing B. PRIMARY CONTACTS City of Brisbane William Prince, Community Development Director Harold Toppel, City Attorney Robin Leiter, Special Legal Counsel C. REFERENCES Debinski, and M.L. Wieland Conservation Value of Roadside Prairie Restoration to Butterfly Communities. Conservation Biology 15: Howe, W.H., The Butterflies of North America. Doubleday and Company, Garden City, New York. Mungira, M.L. and J.A. Thomas Use of road verges by butterfly and burnet populations, and the effect of roads on adult dispersal and mortality. Journal of Applied Ecology 29: Ries, L., D.M. Murphy, D.D. and P.R. Ehrlich, Conservation biology of California remnant native grasslands. Pages in L.F. Huenneke and H.A. Mooney, editors. Grassland structure and function: California annual grassland. Kluwer Academic Publishers, Dordrecht, Netherlands. San Bruno Mountain Habitat Conservation Plan Steering Committee San Bruno Mountain Habitat Conservation Plan (Final). The County of San Mateo, South San Francisco, California. Thomas Reid Associates, Administrative Draft San Bruno Mountain, Habitat Conservation Plan, Volume 1, Amended 2004, For Endangered Species Permit Prt San Mateo County Department of Environmental Management. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\3-repprep.doc (12/15/2009) 29

34 DECEMBER 2009 SAN BRUNO MOUNTAIN HABITAT CONSERVATION PLAN EIR/EA ADDENDUM III. REPORT PREPARATION United States Fish and Wildlife Service, Recovery plan for the San Bruno elfin and mission blue butterflies. Portland, Oregon. 81 pages. United States Fish and Wildlife Service, Findings and Recommendations Pursuant to the Endangered Species Act and Finding of No pursuant to the National Environmental Policy Act for the Issuance of a Section 10(a)(1)(B) Incidental Take Permit (TE ), U.S. Fish and Wildlife Service, May 28, 2009, at 25. Valtonen, A. and K. Saarinen A highway intersection as an alternative habitat for a meadow butterfly: effect of mowing, habitat geometry, and roads on the ringlet (Aphantopus hyperantus). A1mals Zoologica Fennici 42: P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\3-repprep.doc (12/15/2009) 30

35 APPENDIX A ENVIRONMENTAL CHECKLIST SAN BRUNO MOUNTAIN HCP EIR/EA ADDENDUM

36 ENVIRONMENTAL CHECKLIST The following environmental checklist provides an evaluation of the amendments to the San Bruno Mountain Habitat Conservation Plan (HCP), which was adopted in 1982 and is considered the project for purposes of this environmental review ( HCP Amendments ). This checklist has been prepared to show that an Addendum to the 1982 Final Environmental Report and Environmental Assessment for the HCP (HCP EIR/EA) is the appropriate document in which to evaluate the amendments to the project. For the purpose of this environmental checklist, the HCP EIR/EA refers to the original 1982 EIR/EA and all subsequent Addenda. Based on the evaluation in this environmental checklist, and pursuant to CEQA Guidelines Section 15162, the changes to the project would not be considered substantial; nor would substantial changes occur with respect to the circumstances under which the project would be undertaken; nor would new information of substantial importance be introduced to the environmental review record. This environmental checklist focuses on the following components of changes to the proposed project: 1) amendments to the Northeast Ridge operating program (see revised HCP Chapter VII); 2) amendments to the Northeast Ridge funding provisions (see revised HCP section V(B); and 3) amendments to the HCP incidental take provisions (see revised HCP section V.G and amended Section 10(a)(1)(B) Incidental Take Permit, May 20, 2009). Please note that the proposed HCP amendments would provide additional funding for the continued implementation of management activities that were anticipated in the HCP EIR/EA. Furthermore, the addition of incidental take authorization for the callippe silverspot butterfly would allow habitat management activities to resume in areas where the callippe, or its host plants, may be present. The potential effects of the proposed funding changes and incidental take authorization on management activities were fully evaluated in the 2007 Environmental Assessment for the San Bruno Mountain HCP Amendment (the "2007 EA"). The U.S. Fish and Wildlife Service (USFWS) determined that the increased funding would not substantially adversely affect HCP species of concern, including the callippe and mission blue, and instead would provide a net benefit to the species. Please refer to the 2007 EA and 2009 Finding of No (FONSI), which is available at the City of Brisbane Planning Department, for additional detail. Because the amendments do not propose to revise the habitat management program, and because the City is not responsible for habitat management activities, the potential environmental effects of HCP habitat management activities are not evaluated further in this environmental checklist. 1. Project Title: Amendments to the San Bruno Mountain Habitat Conservation Plan (HCP) 2. Lead Agency Name and Address: City of Brisbane Planning and Community Development Department 50 Park Place Brisbane, California P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-1

37 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A 3. Contact Person and Phone Number: William Prince, Director of Community Development, (415) Project Location: The San Bruno Mountain HCP comprises 3,537 acres of San Bruno Mountain. The changes to the proposed project are located entirely within the Northeast Ridge administrative parcel (HCP administrative parcel No. 1-07), one of 36 administrative parcels within the San Bruno Mountain HCP and part of the HCP's Guadalupe Hills planning area. The project location can be seen in Figure I-1 of the Addendum. The acre Northeast Ridge parcel is located within the City of Brisbane on San Bruno Mountain, just south of the San Mateo-San Francisco County boundary. The site is located northwest of Brisbane s central business district and north of the Crocker Industrial Park. The Northeast Ridge parcel is bounded on the north and east by Guadalupe Canyon Parkway; on the south by Crocker Industrial Park; and on the west by a Pacific Gas and Electric (PG&E) transmission line. 5. Project Sponsor's Name and Address: City of Brisbane Planning and Community Development Department 50 Park Place Contact Person and Phone Number: William Prince, Director of Community Development, (415) General Plan Designation: Residential Development (6.23 dwelling units per acre) 1 7. Zoning: Planned Development, P-D; Open Space, O-S 8. Description of Project: Please see attached Project Description. 9. Surrounding Land Uses and Setting: The Northeast Ridge administrative parcel is located just north of the Crocker Industrial Park and City of Brisbane s central business district. The Northeast Ridge parcel is bounded on the north and east by Guadalupe Canyon Parkway; on the south by Crocker Industrial Park; and on the west by a PG&E transmission line. Existing land uses surrounding the Northeast Ridge parcel include residential development to the north; undeveloped open space to the east; multi-family residential development to the south; and San Bruno Mountain State Park to the west. The Northeast Ridge parcel comprises hilly terrain that supports four vegetation types: annual grassland, coastal scrub, riparian/wetland, and introduced exotics. Approximately 90 percent of the site is annual grassland. 10. Other agencies whose approval is required (e.g., permits, financing approval, or participation agreement.) U.S. Fish and Wildlife Service San Mateo County 2 1 Applies to Northeast Ridge parcel only. 2 The County's approval is required only as to the proposed amendments to the section V.B funding provisions and the section V.G incidental take provisions, and only to the extent that they affect conserved habitat. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-2

38 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A ENVIRONMENTAL CHECKLIST Unless Mitigation Incorporated Less Than No I. AESTHETICS. Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? a) Have a substantial adverse effect on a scenic vista? (Less-Than- ) The changes to the proposed project would reduce the overall area subject to development within the Northeast Ridge administrative parcel and would provide additional protection to hilltop areas, which are key elements of scenic vistas in the project site. Therefore, the changes to the proposed project would better conserve scenic vistas compared to the previously proposed project. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? (No ) The changes to the proposed project would not affect any State scenic highway or substantially damage scenic resources within a State scenic highway. Highway 1 and Interstate 280 (I-280) are the closest scenic routes to the project site (approximately 2.5 miles from the project site), and neither highway is visible from the project site. c) Substantially degrade the existing visual character or quality of the site and its surroundings? (Less-Than- ) The changes to the proposed project would not result in an adverse change to the visual character of the project site because the total number of dwelling units in the Northeast Ridge administrative parcel would be reduced and the overall acreage of developed land would be reduced. The development specifications for new development in the area would not change as a result of changes to the project. Because the total amount of development in the Northeast Ridge parcel would be reduced and would P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-3

39 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A occur in a more compact configuration, impacts to the visual character and quality of the site would also be reduced. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? (Less-Than- ) The proposed changes to the project would reduce the total footprint of development in the Northeast Ridge parcel, and the total number of individual residences that would be constructed on the site would also be reduced. This reduction in dwelling units would result in a decrease in light and glare compared to the level of development anticipated in the HCP EIR/EA. Unless Mitigation Incorporated Less Than No II. AGRICULTURAL RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to a non-agricultural use? b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to a non-agricultural use? (No ) No agricultural resources are located on or near the project site. The site has not historically contained agricultural uses, and there would be no agricultural land converted to non-agricultural uses. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? (No ) Please see Section II.a, above. Neither the project site nor the surrounding area is zoned for agricultural use. Additionally, the project site is not currently under a Williamson Act contract. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-4

40 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? (No ) Please see Section II.a, above. Implementation of the proposed project would not result in the conversion of farmland to non-agricultural uses. Unless Mitigation Incorporated Less Than No III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? e) Create objectionable odors affecting a substantial number of people? a) Conflict with or obstruct implementation of the applicable air quality plan? (Less-Than- ) An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a nonattainment area. The main purpose of an air quality plan is to bring the area into compliance with the requirements of federal and State air quality standards. The air quality plans use the assumptions and projects of local planning agencies to determine control strategies for regional compliance status. Since the plans are based on local General Plans, projects that are deemed consistent with the applicable General Plan are usually found to be consistent with the air quality plans. The changes to the proposed project are consistent with growth anticipated under the City s General Plan and fall within the population projections prepared by the Association of Bay Area P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-5

41 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Governments (ABAG). The changes to the project would not conflict with implementation of an applicable air quality plan. b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? (Less-Than- ) As of 2009, the Bay Area is under nonattainment status for ozone and particulate matter per State and federal standards. Vehicular traffic, construction activity, and secondary sources (such as the operation of landscaping elements, pesticide spraying, paints, solvents, power generation, and painting) are contributing factors to these air pollutants, especially ozone and particulate matter. Compared to the previously proposed project, the currently proposed project would result in the construction of fewer residences. Therefore, the total volume of emissions from vehicle activity, construction activity, and secondary sources would be reduced compared to the emissions identified in the HCP EIR/EA. Therefore, the changes to the project would not worsen the project s contribution to the violation of an air quality standard. c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? (Less-Than- ) Please see Section III.b, above. d) Expose sensitive receptors to substantial pollutant concentrations? (Less-Than- ) Sensitive receptors to air pollutants typically include hospitals, nursing facilities, schools, and elderly care facilities. Although the project site is located approximately 0.3 miles from a school, it is unlikely that the proposed project would expose any sensitive receptors to substantial pollutant concentrations once the required mitigations are implemented. Because total development would be reduced as part of changes to the project (in terms of both developable acreage and number of housing units), impacts to sensitive receptors would be reduced compared to the previously identified impacts. e) Create objectionable odors affecting a substantial number of people? (Less-Than- ) The proposed project would involve the construction of new residences, but the number of residences would be reduced compared to the previous project. While there may be temporary objectionable odors associated with construction activities, these odors would be temporary in duration and occur infrequently. The project would not involve permanent land uses or activities that would generate objectionable odors. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-6

42 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No IV. BIOLOGICAL RESOURCES. Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) Through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan or other approved local, regional, or State habitat conservation plan? a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? (Less-than- ) The potential for substantial adverse effects on special-status species related to changes to the proposed project is addressed in the 2007 Environmental Assessment for the San Bruno Mountain HCP P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-7

43 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Amendment (2007 EA). In summary, the changes to the proposed project would preserve additional hilltop habitat for protected butterfly species compared to the previously proposed project. Therefore, the impact on protected butterfly species would be reduced. The following discussion, which is adapted from the 2007 EA, summarizes the potential impacts of project changes on protected plant and animal species. s to Special Status Plant Species. No special status plant species have been documented in the portion of the Northeast Ridge parcel that would be subject to development activities. Nevertheless, ground disturbing activities could affect unidentified special status plant species on the site. However, the changes to the proposed project would reduce the development footprint on the site, and would therefore have a lower potential to disturb unidentified special status plant species. s to Callippe Silverspot. The callippe silverspot butterfly potentially occurs in areas where the butterfly s host plant is located, where adult nectar plants are present, and on ridges and hilltops where courtship and mating take place. The viola is the host plant for the callippe silverspot. Depending on annual fluctuations, the estimated viola habitat that would be affected by the reconfigured development footprint associated with changes to the proposed project would range from 3.0 to 4.4 acres. This acreage is within the normal variability of viola coverage on the site from year to year. Compared to the earlier project, the proposed reconfiguration represents a reduction in the total area of development and an overall reduction in the loss of viola habitat. Therefore, the changes to the proposed project would benefit the callippe silverspot s host plant (however, all applicable callippe silverspot mitigation measures from the HCP EIR/EA would continue to apply). The changes to the proposed project would also result in temporary disturbance to an area that is approximately 880 feet long and 100 to 200 feet wide, located on the south side of a ridgeline. This area is located approximately 100 feet south of Guadalupe Canyon Parkway. This ridgeline has been shown to consistently support the callippe silverspot, as do hilltops and ridgeline areas to the north and east. The impact from grading on the south side of the ridgeline is anticipated to have a temporary impact because the topographic high point of the ridgeline would remain, and therefore continue to provide hilltop habitat for the callippe silverspot in the future. After grading, the area would be restored to grassland habitat. Existing protected hilltop and ridgeline habitat is present on the north side of Guadalupe Canyon Parkway, approximately 200 feet north of the site, and on Callippe Hill on the Northeast Ridge, approximately 100 feet east of the site. Both of these sites provide important hilltop habitat for the callippe silverspot and would provide suitable hilltops for callippe silverspot butterflies that would be temporarily displaced by project grading activities. In addition, an area that supports a high-density habitat area would be protected as open space. Therefore, temporary disturbance to the south side of the ridgeline would not substantially adversely affect the callippe silverspot. Development anticipated within the Northeast Ridge parcel as part of the revised project would likely constitute a barrier to the movement of the callippe silverspot, although this impact would be considered less than significant. Temporary disturbances would not constitute a barrier to movement, as areas subject to temporary disturbance would be revegetated following construction per the HCP operating program. Past studies have shown that an estimated 99 percent of callippe silverspot fly in an area 4,000 feet across, so they are capable of crossing the maximum estimated 1,300-foot distance of the residential development that would occur within the site. Because contiguous habitat would be P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-8

44 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A preserved along both sides of Guadalupe Parkway, and host plants would be located in close proximity to developed areas, the development area would not constitute a significant barrier to movement of the callippe silverspot. The changes to the project would not fragment callippe silverspot habitat to the point where portions of the population are isolated from one another. Disturbance associated with construction activities and the long-term use of open space by residential occupants of the Northeast Ridge parcel could adversely affect callippe silverspot individuals. However, the additional open space and reduced number of residential units that would result from changes to the project would reduce impacts on callippe silverspot individuals compared to the earlier project. s to Other Species. Effects to the Mission blue, bay checkerspot, and San Bruno elfin butterflies that could result from changes to the proposed project would be similar to or less than the impacts on the callippe silverspot described above. Similarly, impacts to special status birds and amphibians would also be reduced under the revised project, compared to the project as analyzed in the HCP EIR/EA. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? (Less-than- ) The USFWS has analyzed the project's potential for adverse effects to the grassland habitat of the callippe silverspot and mission blue butterflies and determined that the proposed project would not have substantial adverse effects on these species or their habitat. The proposed amendments would not have the potential to result in new or more severe adverse effects on other sensitive natural communities, because the modified Northeast Ridge configuration would reduce the development footprint and intensity. c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) Through direct removal, filling, hydrological interruption, or other means? (No ) There are no federally-protected wetlands as defined by Section 404 of the Clean Water Act on the project site. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? (Less-than- ) The potential for substantial interference with the movement of the callippe silverspot, mission blue, bay checkerspot and San Bruno elfin butterflies is addressed in Section IV.a, above, and is found not to be significant under the proposed amendments to the HCP. With respect to the movement of any other species or interfere with use of wildlife corridors or nursery sites, the proposed project would be expected to have comparable or reduced impacts compared to the previously approved Northeast P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-9

45 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Ridge configuration, given the reduction in developed area and the preservation of hilltop habitat and movement corridors. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? (Less-Than- ) The changes to the proposed project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. The changes to the project would result in the removal of several eucalyptus trees, but these trees are not protected or required to maintain habitat value. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan or other approved local, regional, or State habitat conservation plan? (Lessthan- ) The changes to the project involve amendments to an existing HCP. These amendments are designed to better protect endangered species on the site while allowing for development that is protective of ecological values. Therefore, the changes to the project would not conflict with a conservation plan. Unless Mitigation Incorporated Less Than No V. CULTURAL RESOURCES. Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in ' ? b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to ' ? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside of formal cemeteries? a) Cause a substantial adverse change in the significance of a historical resource as defined in ' ? (Less-Than- ) The San Bruno Mountain area, including the Northeast Ridge parcel, remained largely undeveloped up to the time of the HCP's adoption. A records search with the Northwest Information Center of the California Historical Resources Information System (NWIC), Sonoma State University concluded that there are no historical resources recorded at the site. Thus, the changes to the proposed project (which would reconfigure development on the site but would reduce the total acreage of developed area) would not result in any substantial adverse changes in the significance of historical resources. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-10

46 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to ' ? (Less-Than- ) Implementation of the changes to the proposed project would not result in any substantial adverse changes in the significance of archaeological resources. All applicable mitigation measures for cultural resources would remain in effect for the development-related changes to the proposed project. c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? (Less-Than- ) Please see Section V.b above. Implementation of the changes to the proposed project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. All applicable mitigation measures for cultural resources would remain in effect for development activities that would be affected by changes to the proposed project. d) Disturb any human remains, including those interred outside of formal cemeteries? (Less- Than- ) Please see Section V.b above. Implementation of the changes to the proposed project is not expected to result in the disturbance of any known human remains. All mitigation measures for cultural resources (including human remains) would remain in effect for the changes to the proposed project in the unlikely event that human remains are identified. Unless Mitigation Incorporated Less Than No VI. GEOLOGY AND SOILS. Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii) Strong seismic ground shaking? iii) Seismic-related ground failure, including liquefaction? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-11

47 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than iv) Landslides? b) Result in substantial soil erosion or the loss of topsoil? No c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? d) Be located on expansive soil, as defined in Table B of the Uniform Building Code (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42; ii)strong seismic ground shaking; iii)seismic-related ground failure, including liquefaction; iv)landslides? The development plans for the Northeast Ridge parcel and associated grading plans were reviewed by Ted Sayre and David T. Schrier of Cotton, Shires & Associates, Inc., the City of Brisbane s Geotechnical Consultant. In a letter dated June 12, 2007, Ted Sayre and David T. Schrier concluded that adequate identification and investigation of potential site geotechnical constraints have been completed and satisfactory measures have been proposed to address the identified site constraints. To ensure that the final proposed subdrain system access port design, drainage control, debris flow mitigation, and possible rockfall mitigation designs (if necessary) are appropriate for identified site conditions, design-level detailing of final grading, drainage, and improvement plans would be submitted and reviewed by the City Engineer and City Geotechnical Consultant to confirm that final design details are satisfactorily completed prior to final project approval. 3 Because the development footprint of the site would shrink as a result of the proposed changes to the project, these changes are not expected to result in new geotechnical impacts beyond those previously identified. i) Rupture of a known earthquake fault. (Less-than- ) 3 Sayre, Ted and David T. Schrier, Associate Engineering Geologist and Associate Geotechnical Engineer, Cotton, Shires and Associates, Inc. Letter to Randy Breault, City Engineer, City of Brisbane. June 12. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-12

48 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A The site of the proposed changes to the project is likely to be affected by very strong seismic ground shaking. However, no active faults traverse the site; the controlling seismic source within the vicinity of the project site is the San Andreas fault, located approximately 4 miles to the west. ii) Strong seismic ground shaking. (Less-Than- ) Compared to the original project, the modified project would expose fewer people and structures to seismic hazards. New structures developed on the project site would be designed and constructed in accordance with local building codes, which require the implementation of measures to reduce potential seismic ground-shaking impacts. Applicable geotechnical mitigation measures would apply to development anticipated as part of the modified project. iii) Seismic-related ground failure, including liquefaction. (Less-Than- ) ABAG liquefaction susceptibility maps indicate the project site has a very low susceptibility to liquefaction. 4 iv) Landslides. (Less-than- ) The changes to the proposed project would reduce the footprint of development on the site compared to the earlier project. The Northeast Ridge parcel is subject to potential landslides (including debris flows) and very strong seismic ground shaking. However, because the spatial extent of development would be reduced as part of the changes to the project (and fewer residences would be constructed), landslide hazards would also be reduced. b) Result in substantial soil erosion or the loss of topsoil? (Less-Than- ) The proposed changes to the project would not result in a significant increase in the potential for soil erosion or topsoil loss as the total area of development under the proposed project would be reduced. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? (Less-than- ) Development patterns that would result from the proposed project would not be more susceptible to soil instabilities, including on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse, compared to the earlier project. d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? (Less-Than- ) Existing geological conditions at the site include colluvial soils located within several site swales and mantling Franciscan Complex sandstone bedrock on the local hillsides. Expansive soils, usually clay 4 Association of Bay Area Governments, Liquefaction Susceptibility Map. Website: P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-13

49 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A soils that have the ability to change in volume when the water content of the soil changes, are not known to be found at the project site. Because the development footprint of residential uses in the Northeast Ridge parcel would be reduced as a result of changes to the proposed project, risks associated with expansive soils would also diminish incrementally. e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? (No ) No septic tanks or alternative wastewater disposal systems are required to serve development anticipated as part of the revised project. Unless Mitigation Incorporated Less Than No VII. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project located within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere with an P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-14

50 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? (Less-Than- ) Land uses at the site (residential uses and open space) would not change as a result of changes to the project. Therefore, hazardous materials associated with business and industry are not anticipated to be used during the operational period of the project. Development activities on the site would involve the use and disposal of chemical agents, solvents, paints, and other hazardous materials that are commonly associated with construction activities. The amount of these chemicals present during construction would be limited, would be in compliance with existing government regulations, and would not be considered a significant hazard. The proposed changes to the project would not substantially affect the volume or type of hazardous materials used on the site during the construction period. Similar to the earlier project, the changes to the proposed project are unlikely to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? (Less-Than- ) Please see Section VII.a, above. c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? (Less-Than- ) The changes to the proposed project would reduce the spatial coverage of development on the site and are not expected to result in hazardous emissions. The project site is not located within ¼-mile of an existing or proposed school, nor would anticipated development on the site emit or handle hazardous materials after construction. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-15

51 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section and, as a result, would it create a significant hazard to the public or the environment? (Less-Than- ) The project site is undeveloped and no known hazardous materials have been identified on the site. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? (No ) The project site is not located within an airport land use plan nor is it within 2 miles of an airport. At its nearest point, San Francisco International Airport is approximately 4.5 miles southwest of the project site. The changes to the project would not result in an airport-related safety hazard for people residing or working in the project area. f) For a project located within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? (No ) The project site is not located within the vicinity of a private airstrip and would not result in an airstriprelated safety hazard for people residing or working in the project area. g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? (Less-Than- ) The changes to the project would not modify an emergency route or otherwise interfere with an adopted emergency response plan or emergency evacuation plan because the changes would not result in physical changes to escape routes or increase the number of site occupants who could require evacuation in the event of an emergency. The changes to the proposed project would reduce the number of residents on the site and would allow for continued funding of vegetation maintenance activities, which would reduce the wildfire risk at the site. h) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? (Less-Than- ) The project site is adjacent to existing and proposed open space land uses. However, the proposed changes to the project would not result in an increase of exposure or risk of wildland fires over that evaluated in the 1982 EIR/EA. The proposed changes to the project would reduce the amount of development exposed to potential wildfire risks and would ensure that adequate funding is provided to manage vegetation in a way that reduces wildfire risks without compromising ecological values. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-16

52 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No VIII. HYDROLOGY AND WATER QUALITY. Would the project: a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding of as a result of the failure of a levee or dam? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-17

53 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than j) Inundation by seiche, tsunami, or mudflow? No a) Violate any water quality standards or waste discharge requirements? (Less-Than- ) The proposed changes to the project would not increase the potential for violating any water quality standards or waste discharge requirements because they would reduce the spatial extent of development on the site (thus incrementally reducing the volume of polluted runoff from impervious surfaces). b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? (Less-Than- ) As the City does not rely on groundwater for water supply, the proposed project would not deplete groundwater supplies. Similarly, the changes to the proposed project would also not deplete groundwater supply or otherwise change groundwater patterns. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? (Less-Than- ) Surface runoff from the revised project would be less than that from development anticipated under the previous project because there would be additional open space (and less developed land) in the Northeast Ridge parcel. Therefore, changes to the drainage pattern of the area would be incrementally moderated under the revised project. d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? (Less-Than- ) Similar to the earlier project, the revised project would involve substantial grading which would alter the existing on-site drainage pattern. However the total amount of grading would be reduced compared to the original project, namely because the development footprint would be reduced. Similar to the original project, the changes to the proposed project would not result in the alteration of a stream or river. Surface runoff under the current project would be less than that of the original project because there would be more open space and less impervious surfaces. Therefore, flood-related impacts would be incrementally reduced under the revised project. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-18

54 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? (Less-Than- ) Please see Sections VIII.d and VIII.e, above. f) Otherwise substantially degrade water quality? (Less-Than- ) Similar to the original project, under the revised project water quality could be adversely affected during and after the development phase. During construction, sedimentation may increase due to disturbance of soils and subsequent erosion. However, the current project would disturb less area than was proposed in the earlier project, and adverse effects to water quality (due to the generation of polluted runoff) would be reduced. g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?(no ) The project site is not located within a 100-year flood area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. The hydrological conditions at the site have not substantially changed since the preparation of the 1982 EIR/EA. h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? (No ) Please see Section VIII.g, above. i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? (No ) Because the project site is not located within a flood hazard zone or in the vicinity of a levee or dam, the changes to the project would not expose people or structures to a significant risk of loss, injury, or death involving flooding. j) Inundation by seiche, tsunami, or mudflow? (No ) At a minimum elevation of approximately 300 feet above mean sea level (amsl), the project site is not subject to inundation by seiche, tsunami, or mudflow. Therefore, the changes to the project would not expose persons to such hazards. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-19

55 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No IX. LAND USE AND PLANNING. Would the project: a) Physically divide an established community? b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation plan or natural community conservation plan? a) Physically divide an established community? (Less-Than- ) The changes to the proposed project would reconfigure residential uses in the Northeast Ridge parcel and would reduce the overall development footprint. Implementation of the changes, similar to implementation of the proposed project, would not physically divide an established community. The development that would occur as part of the project is part of a larger residential development on the northeast ridge of the San Bruno Mountain, and would not divide existing residential areas. b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? (Less-Than- ) The project site is located within the City of Brisbane. The changes to the proposed project would not change the type of land uses anticipated on the project site and would reduce development compared to the original project. The changes to the project are consistent with growth anticipated under the City s 1994 General Plan and fall within the population projections of ABAG. Therefore, the changes to the project would not conflict with any applicable land use plan, policy or regulation. c) Conflict with any applicable habitat conservation plan or natural community conservation plan? (Less-Than- ) The changes to the proposed project are changes to an existing HCP and are designed to make the HCP more effective at preserving and restoring the ecological integrity of the San Bruno Mountain area while allowing for development that is sensitive to natural communities. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-20

56 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No X. MINERAL RESOURCES. Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? (No ) There are no known mineral resources of value to the region and the State at the project site. Implementation of the changes to the proposed project would not result in the loss of availability of a known mineral resource of value to the region and the State. b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? (No ) The City s General Plan and HCP do not delineate any locally-important mineral resource recovery site within the project area. Thus, implementation of the changes to the proposed project would not result in the loss of availability of a locally-important mineral resource recovery site. Unless Mitigation Incorporated Less Than No XI. NOISE. Would the project result in: a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels? c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-21

57 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? Unless Mitigation Incorporated Less Than No a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? (Less-Than- ) Because the amount of development on the project site would be reduced, the changes to the proposed project would not be expected to increase noise levels in the area during the construction period compared to the original project. Construction activities anticipated under the revised project would continue to be subject to the City s Municipal Code , as well as applicable mitigation measures. These measures would reduce any noise impacts to a less-than-significant level. b) Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels? (Less-Than- ) Similar to the original project, the revised project would require the use of earth-moving and other construction equipment, and could result in temporary exposure to groundborne vibration or groundborne noise levels. This groundborne vibration and noise is not expected to be excessive and would be short-term in its duration. Adherence to applicable mitigation measures would reduce this impact to a less-than-significant level. c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? (Less-Than- ) The revised project would not change the type of land uses proposed for the site. These uses residential and open space uses would not substantially increase ambient noise levels in the project vicinity above levels existing without the project. The changes to the project would not generate enough traffic to create a perceptible change in traffic noise in the vicinity of the project site. No substantial long-term increase in ambient noise levels is expected to result with implementation of the changes to the project. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-22

58 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? (Less-Than- ) Similar to the original project, the revised project would require construction activities that would substantially increase noise levels in the project vicinity above existing levels. However, the implementation of applicable mitigation measures would reduce construction-related noise impacts to a less-than-significant level. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? (Less-Than- ) Although the project site is not located within an airport land use plan or within 2 miles of the San Francisco International Airport, aircraft overflight may cause the Community Noise Equivalent Level (CNEL) to reach 65 A-weighted decibels (dba). The changes to the proposed project would reduce the number of residents on the project site who would be exposed to high noise levels. Although this exposure to high noise levels would remain an impact, implementation of applicable mitigation measures would reduce this impact to a less-than-significant level. f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels?(no ) The project site is not within the vicinity of a private airstrip, and, thus changes to the proposed project would not expose people residing or working in the project area to excessive noise levels from such a source. Unless Mitigation Incorporated Less Than No XII. POPULATION AND HOUSING. Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-23

59 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? (Less-Than- ) The changes to the proposed project would reduce the number of dwelling units constructed on the site. Therefore, the changes to the proposed project would not result in unanticipated substantial population growth. b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? (No ) The changes to the proposed project would involve the reconfiguration of developed uses and open space in a currently undeveloped area and would not result in the displacement of existing housing. c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? (No ) The changes to the proposed project would not result in the displacement of people. Unless Mitigation Incorporated Less Than No XIII. PUBLIC SERVICES. a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection? Police protection? Schools? Parks? Other public facilities? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-24

60 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection, police protection, schools, parks, other public facilities?(less-than- ) The changes to the proposed project would reduce the number of residences on the project site compared to the previous project and would thus incrementally reduce demand for fire, police, school, and park/recreation services. Therefore, the impacts of the current project on these services would be less than those associated with the original project. The changes to the proposed project would increase the amount of open space on the site, thereby providing more passive recreation opportunities to residents. This increased provision of open space would be considered a beneficial impact of changes to the project. XIV. RECREATION. a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Unless Mitigation Incorporated Less Than No a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? (Less-Than- ) The changes to the proposed project would reduce the number of residential units on the project site and would thus reduce demand for parks and other recreational facilities compared to the earlier project. Therefore, the changes to the project would not substantially increase the use of existing neighborhood parks or other recreational facilities such that substantial physical deterioration of recreational facilities would occur or be accelerated. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? (Less- Than- ) The proposed project does not include recreational facilities or require the expansion of recreational facilities which might have an adverse physical effect on the environment. The changes to the P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-25

61 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A proposed project would provide additional open space on the site compared to the earlier project, but this open space would be managed to enhance its ecological integrity and would not result in adverse environmental effects. Unless Mitigation Incorporated Less Than No XV. TRANSPORTATION/TRAFFIC. Would the project: a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency or designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? f) Result in inadequate parking capacity? g) Conflict with adopted polices, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? (Less-Than- ) In 2003, the City commissioned a Traffic and Circulation Technical Analysis to determine circulation system performance with the addition of traffic from development proposed in the Northeast Ridge parcel in The current changes to the project would reduce development from the level analyzed in the 2003 study. Based on the 2003 study, all study area intersections are projected to operate at satisfactory levels of service under Existing plus Project conditions. Since traffic volumes would be P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-26

62 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A reduced as part of the proposed changes to the project (compared to levels analyzed in the 2003 study) no new traffic impacts would be expected. b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency or designated roads or highways? (Less-Than- ) Because the proposed changes to the project would reduce the number of residential units constructed on the project site (and associated vehicle trips), impacts to designated Congestion Management Program (CMP) would also be reduced. c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? (No ) Implementation of the changes to the proposed project would not result in changes to air traffic patterns. d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? (Less-Than- ) The changes to the proposed project would not result in changes to roadways in or around the project site such that design hazards would be exacerbated. e) Result in inadequate emergency access? (Less-Than- ) Please see Section VII.g. f) Result in inadequate parking capacity? (Less-Than- ) The changes to the proposed project would not result in effects to parking supply or demand such that environmental impacts would result. g) Conflict with adopted polices, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? (Less-Than- ) The changes to the proposed project would not conflict with adopted policies, plans, or programs supporting alternative transportation. Unless Mitigation Incorporated Less Than No XVI. UTILITIES AND SERVICE SYSTEMS. Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-27

63 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A Unless Mitigation Incorporated Less Than No b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project=s projected demand in addition to the provider=s existing commitments? f) Be served by a landfill with sufficient permitted capacity to accommodate the project=s solid waste disposal needs? g) Comply with federal, State, and local statutes and regulations related to solid waste? a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? (Less-Than- ) Similar to the previously proposed project, the revised project would not result in exceedance of wastewater treatment standards of the San Francisco Bay Regional Water Quality Control Board. The changes to the project include a reduction in the number of residential units that would be developed on the project site. Therefore, wastewater generation on the site would be reduced, and all wastewater would be appropriately processed in a wastewater treatment plant. b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? (Less-Than- ) Similar to the previously proposed project, the revised project would not require or result in the construction of new water or wastewater treatment facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects. Because the revised project would P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-28

64 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A include fewer residential units, demand for water and wastewater treatment would be reduced compared to the previous project. c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? (Less-Than- ) The changes to the proposed project include a reconfiguration of developed uses, a reduced development footprint, and the provision of additional open space. These changes would not require or result in the construction of new stormwater drainage facilities or expansion of existing facilities resulting in significant environmental effects. The amount of impervious surface area in the current project is expected to be less than that of the earlier project, resulting in a reduction in overall and peak runoff volumes. d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? (Less-Than- ) Because the revised project would include fewer residential units, water demand on the site would also be reduced. No new or expanded water entitlements would be required, and there would be sufficient water supplies available to serve the anticipated development from existing entitlements and resources. e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project s projected demand in addition to the provider s existing commitments? (Less-Than- ) Because the revised project would include fewer residential units, it would generate less wastewater than the previous project. All wastewater would flow to the Southeast Treatment Plant, which has adequate capacity to treat wastewater generated by the revised project. f) Be served by a landfill with sufficient permitted capacity to accommodate the project s solid waste disposal needs? (Less-Than- ) Because the revised project would include fewer residential units, it would generate less solid waste than the earlier project. All waste would be transported to the Ox Mountain Sanitary Landfill, located near Half Moon Bay, which has adequate near-term capacity to accommodate waste generated by development within the project site. g) Comply with federal, State, and local statutes and regulations related to solid waste? (Less- Than- ) Implementation of the revised project, which involves a reduced development footprint and the provision of additional open space, would not result in non-compliance with federal, State, and local statutes and regulations related to solid waste. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-29

65 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? (Less-Than- ) The changes to the proposed project, which would reduce the development footprint in the Northeast Ridge parcel and provide more open space than the earlier project, would benefit the ecological integrity of the area and would not cause substantial adverse effects on human beings, either directly or indirectly. P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-30

66 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A REPORT PREPARATION A. REPORT PREPARERS LSA Associates, Inc Fifth Street Berkeley, California Judith H. Malamut, AICP, Principal-in-Charge and Project Manager Adam Weinstein, AICP, Associate Patty Linder, Graphics Manager Jennifer Morris, Word Processing B. PRIMARY CONTACTS City of Brisbane William Prince, Community Development Director Harold Toppel, City Attorney Robin Leiter, Special Legal Counsel P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-31

67 NOVEMBER 2009 SAN BRUNO MOUNTAIN HCP 1982 EIR/EA ADDENDUM ENVIRONMENTAL CHECKLIST APPENDIX A P:\BRI0901 NE Ridge\PRODUCTS\HCP EIR EA Addendum\Final Addendum\Appendix A HCP Addendum Checklist-Rev.doc A-32

68 APPENDIX B AMENDED TEXT OF SAN BRUNO MOUNTAIN HCP AS AMENDED TO SUPPORT ITP

69 Amended Text of San Bruno Mountain HCP As Amended to Support ITP Section V.B of the HCP would be replaced with the following text: B. FUNDING PROGRAM A basic element of the HCP is creation of a funding mechanism which is able to support the monitoring, research, enhancement and other conservation techniques provided for in this HCP for permanent habitat conservation. The amount of funding must be adequate and protected against inflation. It does not seem possible to provide permanent, inflation free funding solely by reliance on discretionary appropriations from public entities. As a result, the HCP proposes to rely on private funding for habitat maintenance. Funds for habitat maintenance would be deposited in four distinct but overlapping phases: initial funding, service contract funding, permanent funding, and supplemental funding. 1) Interim funding will begin upon the execution of this Agreement, and will be paid by the Landowners. Upon full implementation of the program, it is anticipated that the total amount of interim funding paid by the Landowners will be approximately $50, per year. 2) Funds will also be raised through fees charged to the developers for monitoring of development, and for consultation provided to the developers, by the Plan Operator. The fees charged will cover the Plan Operatorʹs costs and expenses and will also provide some extra money for operation and enhancement of the Conserved Habitat. 3) (a) Except as provided herein, permanent and ongoing funding for habitat operation, maintenance and enhancement will be provided by a $20.00 annual charge per dwelling unit within the Development Areas and a $10.00 annual charge per 1,000 square feet of floor area of private non residential development on the mountain, adjusted annually for inflation as described in Section VI(A)(2) of the Agreement With Respect To The San Bruno Mountain Area Habitat Conservation Plan. As the construction is completed and permanent funding is imposed, interim funding will be phased out. (b) In addition to the annual charges described above, development within the City of Brisbane approved after May 28, 2009, including development of the Northeast Ridge, as described in the Operating Program (Chapter 7), will provide the following additional funding for habitat operation, maintenance and enhancement: (i) residential development will provide an annual charge in the amount of $ per dwelling unit; and (ii) for private nonresidential development, annual charges according to the following schedule: $35.76 per 1,000 square feet for the first 100,000 square feet, $18.26 per 1,000 square feet for the -1-

70 Amended Text of San Bruno Mountain HCP As Amended to Support ITP next 100,000 square feet, and $9.26 per 1,000 square feet for any area in excess of 200,000 square feet. For purposes of application of the private non residential fee, the area of multiple buildings covered under a single project approval will be combined. The additional annual charges described in this Section V(B)(3)(b) will not be adjusted annually for inflation. 4) Supplemental funding in the amount of $4,000, will be provided by Brookfield Northeast Ridge II LLC pursuant to an agreement with the City of Brisbane. This supplemental funding will be used to establish a non wasting endowment to be managed by the Trustees that will fund habitat operations, maintenance, monitoring and enhancement activities on the mountain to provide for the conservation of the Mission Blue, Callippe Silverspot and other Species of Concern and the San Bruno Mountain Area Ecological Community. Concurrently with the execution of this Agreement, the County and the Cities shall either enter into a trust agreement and thereby and thereupon establish the ʺSan Bruno Mountain Area Habitat Conservation Trust Fundʺ (hereinafter ʺTrust Fundʺ) or form an Assessment District or provide for other appropriate funding sources as provided below. The funding source shall have the duty to use the funds for habitat conservation on San Bruno Mountain so as to provide for the conservation of the Mission Blue, Callippe Silverspot and other Species of Concern and the San Bruno Mountain Area Ecological Community. The trustees of the Trust Fund shall be the Managers for the County and the Cities who shall act and administer the Trust Fund solely for the purpose of providing the County with funds for the protection and enhancement of the Species of Concern by the operation, maintenance and enhancement of the Conserved Habitat for such purposes, all as set forth in greater detail in said Trust Agreement. The funds will be paid annually to the funding source, as appropriate, and dedicated solely to habitat conservation activity. Upon full implementation of the program, it is anticipated that the amount of annual funding will be in excess of $400,000.00, which has been determined to be sufficient for habitat conservation. The exact amount of annual funding cannot be calculated because Landowners will begin participation in the funding program at different times. The Trust will consist of one representative each from San Mateo County, Brisbane, Daly City and South San Francisco. The Trustees of the Trust shall have the duty to use the funds for habitat conservation on San Bruno Mountain so as to provide for the conservation of the Mission Blue, Callippe Silverspot and other Species of Concern and the San Bruno Mountain Area Ecological Community. In connection with the subdivision, development and use of the Developable Administrative Parcels, the respective local agency having jurisdiction shall require, and in any event (except as provided in the Agreement) each Landowner with respect to each Development Area, or portion thereof, shall record, a covenant with respect to such Developable Administrative Parcels, or portion thereof. -2-

71 Amended Text of San Bruno Mountain HCP As Amended to Support ITP Prior to the time when the funding from covenants and restrictions assessments provided for above becomes available, the parties shall establish an Interim Funding (Interim Fund) in the amount of at least $50, per year for preliminary habitat restoration activities, native plant seeding and species population monitoring, and other habitat enhancing and monitoring activities. It is anticipated that additional interim funding will come from new projects, contributions from public agencies and from fees for monitoring and consultation, so that the interim funding will probably be in excess of $50, per year. As a contribution to the Interim Fund, each of the following Landowners shall pay to the Plan Operator the amount of money set forth below opposite its name monthly in advance, commencing with the later of (i) the approval of a specific plan, rezoning for residential or commercial purposes, PUD, or tentative subdivision map for any portion of the Developable Administrative Parcel set forth opposite the respective Landownerʹs name below; or (ii) the execution of this Agreement by each Landowner. Landowner/Developable Administrative Parcel Monthly Payment Pro Rata Limit Cadillac Fairview Homes West: Northeast Ridge Project $ 1, $ 23, W.W. Dean & Associates: South Slope Project , Presley: Reservoir Hill , Foxhall Investment, Ltd: Rio Verde Estates and Rio Verde Heights , With respect to all other Developable Administrative Parcels, the Landowner with respect thereto, upon the approval of any PUD, tentative subdivision tract map, building permit, grading permit, conditional use permit or special use permit shall be required to commence and continue paying to the Plan Operator for the Interim Fund, in the same manner and to the same extent provided above with respect to the Landowners specified in this subsection, a charge in the amount of $20.00 per year for every residential unit and $10.00 per year per 1,000 square feet of non residential floor area proposed to be developed under the approval sought. In the event that any of the Landowners above fails to meet its interim habitat funding obligation, the obligation to make payments shall terminate and the respective Landowner shall thereafter have no obligation to make further payments and the Landowner shall lose its rights and benefits under the Section 10(a) Permit. As the permanent funding provided becomes available, the Interim Funding shall be phased out. The parties to this Agreement recognize and agree that the permanent charge/assessment may be satisfied through collection on the annual County property -3-

72 Amended Text of San Bruno Mountain HCP As Amended to Support ITP tax bill of an equivalent amount. Such collection may be through an assessment levied by a public entity or district such as a landscape and lighting district pursuant to Streets and Highways Code , an open space maintenance district pursuant to Government Code , or some other mutually agreed upon funding source. All parties agree to cooperate in good faith in the formation of such a funding source as is selected by the Cities and the County and the Landowners shall consent to the formation of any such funding source so selected. -4-

73 Amended Text of San Bruno Mountain HCP As Amended to Support ITP Section V.G of the HCP would be replaced with the following text: G. INCIDENTAL TAKE PERMIT The County of San Mateo and the cities of Brisbane, Daly City and South San Francisco received a permit for taking of the Mission blue and other listed species under Section 10(a) of the Endangered Species Act. Each of the four local governments are named as a permittee. The permit application sets forth proposed conditions under which the local governments will operate. The conditions include the following: 1. No taking of Mission blue on San Bruno Mountain shall occur except in compliance with procedural and substantive requirements of the Agreement. 2. The conserved habitat shall be held, used and administered in accordance with the HCP and Agreement. 3. The development areas shall be used and administered in accordance with the conditions in Chapter VII of the HCP. 4. A permanent institutional structure and funding mechanism shall be established in accordance with Chapter V of the HCP and compliance with the applicable funding requirements shall be demonstrated by each developer prior to the issuance of any grading permit or building permit. 5. The permit shall be valid for an initial thirty year term, from 1983 to The Agreement, as required by Chapter V of the HCP, shall be executed concurrently with the issuance of the Section 10(a) permit. Furthermore, the City of Brisbane and the County of San Mateo have applied to amend the permit to provide for take of the callippe silverspot and the bay checkerspot butterfly under Section 10(a) of the Endangered Species Act. The amended permit will set forth the following additional condition under which the City of Brisbane and San Mateo County will operate. 1. No taking of callippe silverspot or bay checkerspot butterfly on San Bruno Mountain shall occur except in compliance with procedural and substantive requirements of the HCP. -5-

74 Amended Text of San Bruno Mountain HCP As Amended to Support ITP The Operating Program for the Northeast Ridge in Chapter VII of the HCP would be replaced with the following text and exhibits (exhibits not included below are not affected by the amendment): REVISED OPERATING PROGRAM Planning Area: Northeast Ridge (1) Administrative Parcel: Northeast Ridge Project (07) Location and description: The Northeast Ridge is located in the northeast corner of San Bruno Mountain. It is bounded on the south by the Crocker Industrial Park, on the north and east by Guadalupe Canyon Parkway and on the west by a P G & E transmission line (Figure 1 07 A). It has a hilly terrain which supports four vegetation types: annual grassland, coastal scrub, riparian/wetland, and introduced exotics (eucalyptus, gorse). Approximately 90% of the site is annual grassland. Ownership: The undeveloped Unit II portions of the site are owned by Brookfield Northeast Ridge LLC (Landowner), and future development of the Unit II project is under the supervision of Brookfield Bay Area Builders Inc. Project: The development of 71 single family homes in the Unit II, Neighborhood II. Status: This is a planned parcel. The original Concept Plan was submitted and approved by the Task Force and Local Agency at Public Forums in March and April A Specific Plan was submitted to the City of Brisbane and County of San Mateo in Sept An EIR was prepared on the Specific Plan. In November 1989, the Brisbane City Council approved a vesting tentative subdivision map and related applications for a project of 579 dwelling units. In August 1990 the U. S. Fish and Wildlife Service approved the Northeast Ridge Equivalent Exchange Amendment to the HCP. In 2007, Brookfield Homes submitted a revised development plan for Unit II in coordination with the City and County, and the U. S. Fish and Wildlife Service subsequently approved an Amendment to the HCP and Section 10(a) permit that incorporates the revised plan and that includes take authorization for the callippe silverspot in the Landmark II development area. Biological Issues: The Northeast Ridge includes rolling hillsides, terraces and slopes and residential development on the lower slopes. Even with the development, it remains an important habitat area for the callippe silverspot and the mission blue butterfly. Within undeveloped areas of the Northeast Ridge, grasslands are the dominant community and abundant host plants for both the callippe silverspot and mission blue are present. The area is mostly grassland with some areas converting to coastal scrub. A large eucalyptus grove that was present on the site has been thinned and removed in accordance with the Operating Program approved in The grasslands are dominated by nonnative annual grasses and herbaceous weeds in many areas, yet the area still supports the butterfly host plants and the rare butterflies in high numbers. -6-

75 Amended Text of San Bruno Mountain HCP As Amended to Support ITP Control work on French broom, eucalyptus and fennel has been successful, however non native annual grasses and weeds such as Italian thistle and wild radish still pose potential threats to the fragile grassland. : The development of the Unit II, Neighborhood II phase of the Northeast Ridge development will disturb approximately acres of land, acres will be permanently converted to urban uses, while 2.97 acres will be subject to habitat restoration. Approximately 12 acres of the total area disturbed by the Unit II project is grassland. Of that, approximately 2.27 acres of the total area disturbed is occupied by Johnny jump up (Viola pedunculata), which is the callippe silverspot butterflyʹs larvae food plant. The loss of grassland represents roughly 1% of the remaining grassland on San Bruno Mountain as mapped in The loss of viola represents roughly 1.7% of the remaining viola on San Bruno Mountain. Habitat that supports the mission blue butterfly will also be removed as a result of the development of Unit II, Neighborhood II. HCP Objectives Specific Conservation Needs: Since the Northeast Ridge parcel comprises a major portion of the San Bruno Mountain butterfly population, intensive mitigation and enhancement activities are warranted. However, because development planning was sensitive to the needs of the butterfly populations and the findings of the Biological Study, no specific habitat manipulation is required within the development boundaries (permanently and temporarily disturbed areas), with the exception of reclamation of cut and fill slopes. The enhancement activities will focus on expanding and improving habitat in the Conserved Habitat areas which will eventually be dedicated to the County. Habitat conservation measures include: retention of large, contiguous, and diverse areas of Conserved Habitat around the development sites; reclamation of cut and fill slopes with host plant species; phasing of development so that lower grade habitat areas are disturbed first; coordination with other developments in the planning area through the Plan Operator so that the total impact on the species of concern is minimized; both temporary and permanent protection of the Conserved habitat, initially from construction activities and finally from human encroachment; the use of habitat enhancement techniques to improve and expand the Conserved Habitat; and dedication of the Conserved Habitat once development has been assured. Finally, monitoring should take place to assess the effect of the above measures. The ultimate Conserved Habitat area, which is shown as Management Unit in Figure 1 07 C, will consist of everything but the permanently disturbed areas, shown as Management Units to in the same Figure. The developer will be financially responsible for reclaiming all of the temporarily disturbed areas within the Conserved Habitat area for a 5 year period. Operating Program Obligations: The landowner/developer has the following obligations: 1. No construction or conversion to urban uses shall be permitted beyond the temporarily disturbed habitat area within the on Figure 1 07 C. The boundary of area may be adjusted by the Landowner by not more than thirty (30) feet from the line shown on Figure 1 07 C, provided, however, that the -7-

76 Amended Text of San Bruno Mountain HCP As Amended to Support ITP total area increased as a result of such adjustment does not exceed five (5%) percent of the total Conserved Habitat in this Administrative Parcel. Outside area or within the temporarily disturbed habitat area within the , construction and conversion to urban uses may occur subject only to the conditions set forth in Paragraph 2 below. 2. Prior to any construction within Administrative Parcel 1 07, the Landowner shall provide for the following: a. Dedication of Conserved Habitat. The Landowner shall agree to dedicate to the County all lands within Administrative Parcel 1 07 within the Phase II dedication area shown in Figure 1 07 I and as adjusted by the Landowner pursuant to Paragraph 1. Such dedication shall be offered by the Landowner at the time of recordation of the final map for Unit II, Neighborhood II, as shown on Figure 1 07 I. b. HCP Funding Program. During the project development phase, the Landowner will enter into a contract with the Plan Operator to pay the reasonable cost of supervising the HCP restrictions on grading and supervising the reclamation of habitat. The monitoring and consultation funding shall be paid in accordance with Chapter VI. A. 5 of the Implementation Agreement (Agreement with respect to the San Bruno Mountain Area Habitat Conservation Plan). Pursuant to an agreement with the City of Brisbane, the Landowner shall fund the HCP Endowment by $4,000,000, subject to reimbursement from other future developments, if there are any, within the area covered by the HCP. This Endowment would be incrementally funded from the sale of each home within Unit II, Neighborhood II and 17 homes that were incorporated into Unit I. It is expected that this endowment would generate over $200,000 per year in interest, available to the HCP Trustees. If any future developments are approved within the HCP area, 75% of the future developmentʹs HCP Endowment contribution be used to reimburse Landowner for its HCP Endowment contribution. The remaining 25% would be contributed to the HCP for additional management funding. Owners of each home in the developed portions of the Northeast Ridge pay the annual HCP charge, which is adjusted annually for inflation as described in Section V(B)(3)(a). Owners of each of the homes within the Unit II, Neighborhood II will be required to pay the annual HCP charge and the additional charge of $ per year, as described in Section V(B)(3)(b). The HCP charges commence when the City issues the Certificate of Occupancy and when title is transferred from the Landowner. These HCP charges would be paid through the Homeowners Association and transferred to the County for use by the Trustees for ongoing habitat operation, maintenance and enhancement. c. Salvage Provisions. Prior to grading, transplant Viola from grading footprint to areas where CS habitat is being restored (areas where scrub or nonnatives have been removed). As much as possible, the ground around the Viola should be moved with it in an effort to transport any larvae that may be around the base of the plant. -8-

77 Amended Text of San Bruno Mountain HCP As Amended to Support ITP d. Reclamation Provisions. With respect to any areas which are to be graded or disturbed and thereafter dedicated as Conserved Habitat, the Landowner shall prepare a Reclamation Plan for approval by the City (or County, as the case may be) in accordance with its normal standards and procedures for grading permits. These provide for grading to be accomplished, erosion and run off controls, and revegetation with native grassland species approved by the Plan Operator. In addition, the Landowner shall clearly define on the ground (by snow or two strand wire fencing or other methods) the limits of disturbance anticipated and shall limit the construction disturbance to said limits as provided in fencing and signing provisions of the MOU and Chapter 5. The fencing shall be constructed at the boundary between temporarily disturbed areas and undisturbed areas as shown in Figure 1 07 H. At the time of approval of the reclamation plan(s), those plans shall substitute for the more generalized maps referenced in this section. A performance bond shall be secured through the City of Brisbane or Plan Operator for all restoration/reclamation activities prior to disturbance of the site. The performance bond requirement does not apply to the salvage operations described in Section 2(c) of this Operating Program. The amount of the performance bond shall be the amount determined by the Plan Operator to be adequate to ensure proper performance of the restoration/reclamation activities based. The bond shall be released to the Landowner within 30 days after the Plan Operator has determined the restoration/reclamation activities have been successfully completed. The funds will not be obtained from the HCP fund to meet the restoration/reclamation obligations. If restoration/reclamation is not completed by the Landowner, the bond will be used to fund completion of the activities. The Landowner shall maintain temporarily disturbed open space areas Management Unit for a period of five years from completion of grading and revegetation. The dedication of temporarily disturbed open space areas subject to maintenance and turnover criteria that defer the timing of the HCP Trusteesʹ obligation to commence maintenance allows the HCP Trustees to collect the HCP charges from occupied residences within Unit II, Neighborhood II and to build up a reserve before the HCP Trustees assume management responsibilities for these areas. All undisturbed areas will be maintained by the HCP Operator. e. Pesticide Control. The Landowner shall establish covenants and restrictions encumbering Development Areas in favor of the County and/or City prohibiting the use of aerial or large scale spraying of pesticides without the approval of the Plan Operator. f. Buffer Areas. The Landowner shall covenant in favor of the City of Brisbane and the County to establish and maintain a buffer area of up to thirty (30) feet in width to protect urban uses within the Development Areas from fire. Native plants, which will not present an invasion threat to grasslands within the Conserved Habitat, are preferred. These buffer areas will be maintained by the Homeowners Association. g. Inspection. The Landowner shall, in carrying out Reclamation Plans for Administrative Parcel 1 07, contract for an inspector acting for the County as -9-

78 Amended Text of San Bruno Mountain HCP As Amended to Support ITP Plan Operator to monitor grading and revegetation activities through completion of the reclamation activities and acceptance of the offer of dedication. The Plan Operator has the following obligations: 1. Prepare and execute an annual operating program for the Conserved Habitat within Administrative Parcel 1 07 and comply with mitigation measures set forth for Management Unit ; 2. Monitor the effect of all activities within Development Areas on adjacent Conserved Habitat and provide advice and direction to the Landowner to assist its compliance with the obligations described above with respect to Administrative Parcel 1 07; 3. Designate vegetation materials for use in Reclamation Plans and review such Reclamation Plans submitted by the Landowner with respect to Administrative Parcel 1 07 in a timely fashion to avoid delays in the implementation of such Plans; 4. Manage habitat strips along both sides of GCP and the area around the water tank as butterfly movement corridors to facilitate exchange of butterflies from NER to Saddle areas. To achieve this, the coastal scrub areas north of GCP and near the water tank will need to be opened up and restored to grassland habitat. 5. Accept dedications of Conserved Habitat within Administrative Parcel Notify the U. S. Fish and Wildlife Service immediately of the finding of any endangered species found dead or injured as a result of activities authorized under the Section 10(a) permit. Notification must include the date, time, and location of the specimen and any other pertinent information. The Service contact person for this information is Ms. Lori Rinek at (916) Any mission blue butterflies found dead or injured shall be deposited with the California Department of Fish and Game. Management Units: and These units contain the permanently disturbed areas of the Unit I development This unit contains the permanently disturbed areas of the Unit II development This unit contains all of the ultimate Conserved Habitat in the parcel. -10-

79 Exhibit 1-07-C -11-