ENVIRONMENTAL ASSESSMENT 51 AREA RESERVOIR REPAIR

Transcription

1 ENVIRONMENTAL ASSESSMENT 51 AREA RESERVOIR REPAIR MCB CAMP PENDLETON San Diego County, California May 2017

2 Environmental Assessment for the 51 Area Reservoir Repair, MCB Camp Pendleton Lead Agency for the EA: Title of Proposed Action: Affected Region: Designation: United States Marine Corps 51 Area Reservoir Repair San Diego County, California Environmental Assessment Abstract The United States Marine Corps has prepared this Environmental Assessment (EA) in accordance with the National Environmental Policy Act (NEPA) of 1969, 42 United States Code h, as implemented by the Council on Environmental Quality regulations, 40 Code of Federal Regulations Parts , and Marine Corps Order P5090.2A, Change 3, Chapter 12, dated 26 August 2013, Environmental Compliance and Protection Manual, which establishes procedures for implementing NEPA. The proposed action consists of the repair and maintenance of concrete drainage channels, cleaning existing drainage lines, repairing and clearing drainage pipes and culverts in the San Onofre housing area, repairing the Reservoir drain line, constructing a retaining wall, constructing a temporary access road, restoring the project site, and restoration and enhancement for Pacific Pocket Mouse (PPM) within the 51 Area (San Onofre) located on Marine Corps Base (MCB) Camp Pendleton, San Diego County, California. This EA describes the potential environmental consequences resulting from the Preferred Alternative and the No-Action Alternative on Biological Resources and Air Quality/Greenhouse Gases. Prepared by: Point of Contact: United States Marine Corps United States Marine Corps MCB Camp Pendleton Attn: Kristin Thomas, Project Manager Bldg Camp Pendleton, CA kristin.thomas@usmc.mil Telephone: (760) May 2017

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5 Table of Contents Abstract Table of Contents Acronyms... v Executive Summary Purpose and Need Introduction Background Project Location Purpose of and Need for the Proposed Action Regulatory Setting Proposed Action and Alternatives Alternative 1: Proposed Action Construction Maintenance of Drainage Channels Restoration and Enhancement Special Conservation Measures No-Action Alternative Alternatives Considered But Eliminated Install a 10-foot Wide Road from the Reservoir Install a 10-foot Wide Road from the San Diego Gas and Electric Access Road Extend the Emergency Repairs Access Road Resource Areas Eliminated From Detailed Consideration Summary of Impacts Preferred Alternative Affected Environment and Environmental Consequences Biological Resources Affected Environment Environmental Consequences from the Proposed Action Air Quality and Greenhouse Gases Affected Environment Environmental Consequences Cumulative Impacts Introduction Projects Considered in the Cumulative Analysis Methodology Geographic Scope of the Cumulative Effects Time Frame of the Cumulative Effects Analysis Cumulative Impact Analysis Air Quality and Greenhouse Gases Biological Resources Cumulative Effects Other NEPA Considerations Area Reservoir Repair, MCB Camp Pendleton Draft EA iii

6 1 Purpose and Need 5.1 Possible Conflicts Between the Action and the Objectives of Federal, Regional, State, and Local Plans, Policies, and Controls Irreversible and Irretrievable Commitment of Resources Relationship Between Short Term Environmental Impacts and Long Term Productivity Any Probable Adverse Environmental Effects that Cannot be Avoided and are Not Amenable to Mitigation List of Preparers Persons and Agencies Contacted or Consulted References Appendices A B C Public Involvement Record of Non-Applicability and Air Quality Technical Data USFWS Biological Opinion List of Tables Table ES-1. Summary of Potential Environmental Consequences by Resource... 8 Table Applicable Federal Regulations, Instructions, and Public Law Table Summary of Impacts Table Federally Listed Threatened and Endangered Plant and Animal Species Known to Occur or Potentially Occurring in the Project Vicinity Table Summary of Potential Impacts on Listed Species with Implementation of Alternative Table National and California Ambient Air Quality Standards Table Annual and Total Emissions Due to Construction of Alternative Table Cumulative Projects Table Summary of Cumulative Projects and Impacts to Coastal California Gnatcatcher and Pacific Pocket Mouse List of Figures Figure Regional Map Figure Project Site Figure Drainage Channels Figure Threatened and Endangered Species Known to Occur in the Project Site and Vicinity iv 51 Area Reservoir Repair, MCB Camp Pendleton EA

7 Acronyms Acronyms ARB California Air Resources Board BA Biological Assessment BMP Best Management Practice BO Biological Opinion BWI Basewide Water Infrastructure CAA Federal Clean Air Act CAAQS California Ambient Air Quality Standards CAGN Coastal California Gnatcatcher CEQ Council on Environmental Quality CFR Code of Federal Regulations CH 4 methane CO carbon monoxide CO 2 carbon dioxide CO 2e CO 2 equivalent CWA Clean Water Act of 1972 DoD Department of Defense DoPAA Description of Proposed Action and Alternatives EA Environmental Assessment ES Environmental Security ESA Endangered Species Act of 1973 FEAD Facilities Engineering and Acquisition Division GHG greenhouse gases gpm gallon per minute GWP global warming potential MCB Marine Corps Base MCO Marine Corps Order mph mile per hour NAAQS National Ambient Air Quality Standards NAVFAC SW Naval Facilities Engineering Command Southwest NEPA National Environmental Policy Act of 1969 NO nitrogen oxide NO 2 nitrogen dioxide N 2O nitrous oxide NPDES National Pollution Discharge Elimination System O 3 ozone PM 2.5 particulate matter less than 2.5 microns in diameter PM 10 particulate matter less than 10 microns in diameter PPM Pacific Pocket Mouse ppm parts per million PSD Prevention of Significant Deterioration ROI Region of Influence SDAB SDCAPCD SIP SO 2 SSC San Diego Air Basin San Diego County Air Pollution Control District State Implementation Plan sulfur dioxide Species of Special Concern 51 Area Reservoir Repair, MCB Camp Pendleton Draft EA v

8 1 Purpose and Need SWPPP SWRCB TAC µg/m³ USC USEPA USFWS USMC VOC Storm Water Pollution Prevention Plan State Water Resources Control Board toxic air contaminant micrograms per cubic meter United States Code United States Environmental Protection Agency United States Fish and Wildlife Service United States Marine Corps volatile organic compound vi 51 Area Reservoir Repair, MCB Camp Pendleton EA

9 Executive Summary Executive Summary This EA describes the potential environmental consequences resulting from the repair and maintenance of concrete drainage channels, repairing and cleaning the existing drainage pipes and culverts in the San Onofre housing area, repairing the Reservoir drain line, constructing a retaining wall, constructing a temporary access road, and restoring the project site, and restoration and enhancement for Pacific Pocket Mouse (PPM) within the 51 Area (San Onofre) located on Marine Corps Base Camp Pendleton, California. The USMC has developed one action alternative to implement the proposed action. The purpose of the proposed action is to repair and restore the damage caused to the facilities and environment when water was accidentally released from Reservoir 51772, and provide regular maintenance to this facility. Based on the analysis presented in this EA the USMC has developed and analyzed a No-Action Alternative and the Preferred Alternative. Biological resources and air quality/greenhouse gases were evaluated for potential environmental consequences in this EA. The potential environmental consequences associated with implementation of Alternative 1 and the No-Action Alternative are summarized in Table ES-1. As shown in Table ES-1, no significant impacts to any resource area would occur with implementation of the proposed action with the inclusion of Special Conservation Measures. ES-7 51 Area Reservoir Repair, MCB Camp Pendleton EA

10 1 Purpose and Need All other NEPA resource areas were eliminated from detailed analysis because they were determined to result in either negligible or less than significant impacts, as discussed in Section Table ES-1. Summary of Potential Environmental Consequences by Resource Resource Alternative 1 No-Action Alternative California gnatcatcher: With the proposed conservation measures, the project is not expected to appreciably reduce the numbers, reproduction, or distribution of the species on MCBCP or rangewide and is not anticipated to impact recovery of the species. Biological Resources Pacific Pocket Mouse: With the proposed conservation measures, including measures to minimize impacts to the South San Mateo population and implement recovery actions identified in the PPM Recovery Plan (Service 1998), the project will not impede and should contribute to recovery of PPM. Under the No-Action Alternative, the repairs and restoration would not take place. The existing mudslide area will continue to erode with each additional rainfall and reservoir release sending sand and sediment down the storm channel while removing more of this hillside. This will also prevent the four housing units from being reoccupied and could cause other units to be relocated. Air Quality/Greenhouse Gases Under Alternative 1 the proposed construction equipment would emit toxic air contaminants (TAC) that could potentially impact public health. The main source of TACs would occur in the form of particulates from the combustion of diesel fuel, due to the mobile and intermittent operation of proposed diesel-powered construction equipment. There would be minimal ambient impacts of TACs in a localized area. As a result, Alternative 1 would produce less than significant impacts to public health and no mitigation is required. Under the No-Action Alternative, the repairs and restoration would not take place, no construction equipment would be used; therefore, there would be no impacts to air quality Area Reservoir Repair, MCB Camp Pendleton EA

11 1 Purpose and Need 1.1 Introduction This Environmental Assessment (EA) has been prepared by the United States Marine Corps (USMC or Marine Corps) in accordance with the National Environmental Policy Act (NEPA) of 1969 (42 United States Code [USC] h, as amended), the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA (40 Code of Federal Regulations [CFR] Parts ), and Marine Corps Order (MCO) P5090.2A, Change 3, Chapter 12, dated 26 August 2013, Environmental Compliance and Protection Manual. NEPA encourages public involvement in the environmental review process. The development of this EA includes the publication of a notice to prepare an EA, and informing interested parties or agencies of the USMC s intent. Please refer to Appendix A, Public Involvement, for additional information on the public participation process. This EA describes the potential environmental consequences resulting from the proposed action located within the 51 Area (San Onofre) in the northwestern portion of the Base (Figure 1.1-1). The proposed action includes the following: Construction Geotech investigation; Repairing multiple sections of concrete drainage channels; Cleaning existing storm drains to include clearing and grubbing near the drains; Repairing the Reservoir drain line; Constructing a retaining wall and backfilling the hillside to prevent further erosion; and Site access and laydown during construction. Maintenance Cleaning sand and silt out of the drainage channels and trimming vegetation growth over the channels. Restoration and Enhancement Restore 0.48 acres of temporary direct project impacts to Pacific Pocket Mouse (PPM) habitat; Restore 0.70 acres of previous impacts to PPM habitat; and Enhance acres of PPM habitat in the vicinity of the 51 area. 1.2 Background Reservoir has a 1 million gallon capacity, is 35 years old, and supplies water to the North Water System, including San Onofre housing. During the week of 20 April 2012, the reservoir overfilled causing water to enter the Marine Corps Base (MCB) Camp Pendleton San Onofre housing area below. The alarms were not seen by the operator, allowing an 1,100 gallon per minute (gpm) pump to run and the reservoir to overflow for 3.5 hours. This overflow caused the hillside to erode filling the storm drain system with silt and causing it to back up (due to the silt from the hillside and the brush overgrowth in the 51 Area Reservoir Repair, MCB Camp Pendleton 1-1

12 1 Purpose and Need storm drain). This backup in the storm drains caused flooding in the San Onofre housing, displacing Marines and their families from four housing units, and burying the front of a car in mud Area Reservoir Repair, MCB Camp Pendleton EA

13 1 Purpose and Need Figure Regional Map 51 Area Reservoir Repair, MCB Camp Pendleton 1-3 EA

14 1 Purpose and Need 1.3 Project Location The proposed action would be implemented at Marine Corps Base (MCB) Camp Pendleton, the USMC s major amphibious training center for the West Coast (Figure 1.1-1). The project site is located in the 51 Area in the northwestern portion of the Base. MCB Camp Pendleton is a 200-square mile area located primarily within the northern portion of San Diego County, California, 40 miles north of downtown San Diego. The Orange County line is contiguous with the northwest boundary of MCB Camp Pendleton; Riverside County is to the north, but not directly adjacent to the boundary of MCB Camp Pendleton. The City of San Clemente and the Cleveland National Forest border MCB Camp Pendleton to the north and east, with the community of Fallbrook and the Naval Weapons Station Seal Beach/Fallbrook Annex to the east, and the City of Oceanside to the south. The Base is primarily accessed by Interstate 5 and State Route Purpose of and Need for the Proposed Action The purpose of the proposed action is to repair and restore the damage caused to the facilities and environment when water was accidentally released from Reservoir 51772, and provide regular maintenance to this facility. The proposed action is needed to prevent another mudslide and further erosion of the hillside. 1.5 Regulatory Setting This EA discusses reasonable alternatives for meeting the purpose and need for the proposed action; existing environmental conditions in the vicinity of the proposed action; direct, indirect, and cumulative impacts that might result from the proposed action; and measures to avoid or minimize potential adverse impacts. Important considerations for identification and analysis of alternatives were the avoidance or minimization of environmental impacts. This EA has been prepared in accordance with applicable federal regulations, instructions, and public law including, but not limited to, those identified in Table Table Applicable Federal Regulations, Instructions, and Public Law Name Regulation Public Law Migratory Bird Treaty Act of USC Endangered Species Act of USC Native Americans Graves Protection and Repatriation Act of USC & 40 CFR Part 10 Clean Water Act of USC National Environmental Policy Act of USC h Resource Conservation and Recovery Act of USC k Clean Air Act of 1970, as amended, including 1990 General Conformity Rule 42 USC q Comprehensive Environmental Response, Compensation, and Liability Act of USC National Historic Preservation Act of USC Federal Regulations Department of the Navy Procedures for Implementing National Environmental Policy Act 32 CFR Part 775 Council on Environmental Quality Regulations for Implementing the Procedural Provisions of National Environmental Policy Act 40 CFR Parts Area Reservoir Repair, MCB Camp Pendleton EA

15 1 Purpose and Need Table Applicable Federal Regulations, Instructions, and Public Law (continued) Name Regulation Executive Orders Protection of Wetlands, 24 May, 1977 Executive Order Federal Compliance with Pollution Control Standards Executive Order Federal Actions to Address Environmental Justice in Minority Populations and Low-income Populations, 11 February,1994 Executive Order Protection of Children from Environmental Health Risks and Safety Risks, 23 April, 1997 Executive Order Greening the Government through Waste Prevention, Recycling, and Federal Acquisition Executive Order Invasive Species Executive Order Greening the Government through Efficient Energy Management Executive Order Greening the Government through Leadership in Environmental Management Executive Order Responsibility of Federal Agencies to Protect Migratory Birds, 11 January, 2001 Executive Order Strengthening Federal Environmental, Energy, and Transportation Management Executive Order Preparing the United States for the Impacts of Climate Change Executive Order Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input Executive Order Planning for Federal Sustainability in the Next Decade Executive Order Marine Corps Orders Environmental Compliance and Protection Manual Chapter 12 Marine Corps Order P5090.2A, Change 3 United Facilities Criteria United Facilities Criteria for Low-Impact Development United Facilities Criteria Notes: CFR = Code of Federal Regulations; USC = United States Code NEPA requires consideration of potential impacts to the environment in the decision-making process for federal actions. CEQ regulations implement the action forcing provisions of NEPA to ensure that federal agencies comply with the letter and spirit of NEPA. MCO P5090.2A provides specific guidance for the USMC in preparing environmental documentation for proposed actions subject to NEPA. The proposed action may require the following permits, certifications, and/or determinations: Endangered Species Act (ESA) of 1973 Biological Opinion (BO) from the United States Fish and Wildlife Service (USFWS); and Storm Water Pollution Prevention Plan (SWPPP) pursuant to the general permit for constructionrelated discharge as regulated by the State Water Resources Control Board (SWRCB). 51 Area Reservoir Repair, MCB Camp Pendleton 1-5 EA

16 1 Purpose and Need. 2 Proposed Action and Alternatives The proposed action addressed in this EA is the repair and restoration of the damage caused to the facilities and environment when water was accidentally released from Reservoir 51772, along with the regular maintenance to this facility. This chapter describes the reasonable alternative for accomplishing the proposed action. This EA only addresses those alternatives that could reasonably meet the purpose and need for the proposed action. Final construction plans would be developed under a design-bid-build contract; therefore, minor deviations from the current conceptual site plan may be required during the final design phase. The conceptual project layout was designed to represent the maximum level of disturbance and all areas potentially disturbed are included within the project boundaries. Any design modifications or different configurations that may be developed would occur within the project site (Figure 2.1-1). The contractor would plan project development to avoid the direct loss of native vegetation and Pacific Pocket Mouse (PPM) habitat, to the maximum extent practicable, by reducing disturbance footprints. During this process, any design modifications would be reviewed and authorized by MCB Camp Pendleton Environmental Security (ES). 2.1 Alternative 1: Proposed Action The 51 Area reservoir repair would be located within the project site (Figure 2.1-1). The project components associated with this project include construction, maintenance, restoration, and enhancement Construction During design of the 51 Area reservoir repair project, geotechnical investigation may be necessary. If geotechnical investigation is conducted, it will likely occur 1 to 6 months before construction and would consist of one geotechnical boring within the erosion repair footprint. Vegetation removal within the investigation footprint may be needed to accommodate the activity. The investigation would be performed using a truck-mounted drill rig or a modified investigative vehicle and would take about 1 day. Construction would occur over a 4-month period and would require up to 10 workers per day. Construction would involve excavation for and installation of a retaining wall(s), clearing/grubbing and removing sand/silt and plant overgrowth, backfilling behind the retaining wall(s) to rebuild the drain culvert that was damaged, repairing the concrete culvert in three sections, replacing drain pipe, revegetation around the outer perimeter of the storm culverts, restoration for all temporary impacts due to construction, restoration for impacts to PPM habitat in the 51 Area, and enhancement for permanent impacts due to construction as well as previous impacts to PPM habitat. In general, the following equipment would be used during construction: dump trucks, concrete pumper trucks, backhoe/excavators, bobcats, pickup Area Reservoir Repair, MCB Camp Pendleton EA

17 2 Alternatives Including the Proposed Action Figure Project Site Area Reservoir Repair, MCB Camp Pendleton EA

18 2 Alternatives Including the Proposed Action trucks, crane, compactors, generators, air compressors, and miscellaneous smaller equipment (e.g., pumps) Drainage Channel Repair and Cleaning and Repair of Drain Line The project site consists of numerous drainage channels that would require repair and cleaning during the construction phase (Figure 2.1-2). Channels #1 and #2, Eastern Channel. Work would include removing debris/sand/silt from the 4 feet wide by 1.5 feet deep drainage channels. Access to Channels #1 and #2 would be from the top of the project site adjacent to the reservoir. The channels can be accessed to clean by hand and with a bobcat (within the drainage channels) from the proposed laydown area. A truck/bobcat would be located at the top of the project site in the proposed construction laydown area. Channel #3. Work would include removing debris/sand/silt from the 4 feet wide by 1.5 feet deep drainage channel. This channel has a pipe installed with a duckbill valve that is the discharge for the overflow and drain lines of Reservoir The remaining vegetation within the channel that was not removed by the emergency repairs would be removed by the proposed action. Access to Channel #3 would be by foot and the vegetation would be removed by foot or crane located above the channel. Channel #4. Work would include repair and removal of debris/sand/silt from the 4 feet wide by 1.5 feet deep drainage channel. Construction would include the repair of the culvert that was damaged when the hillside eroded. A section of concrete drain channel approximately 30 feet long would be repaired to connect all parts of this channel back to the main drainage channel. The remaining vegetation within the channel that was not removed by the emergency repairs would be removed by the proposed action. Access to Channel #4 would be by foot, and the debris would be removed through the foot access road developed to make repairs or by crane located at the top of the channels. Main Channel. Work would include repair and removal of debris/sand/silt from the channel; the channel varies in width from 4 to 7 feet and is 1.5 feet deep. The drain/overflow line from Reservoir would be repaired to connect to this channel. A 12-inch high-density polyethylene pipeline would be connected to the existing, corrugated metal pipe with a mechanical restraint joint. The pipe would connect to the channel through a headwall. Access to the lower portion of the main channel would be from the road that was installed to make the emergency repairs. Trench plates would be used to cover the main channel to allow construction access to the erosion site from below. Trench plates vary in width from 4 to 8 feet and would require trimming of the vegetation around the channel by approximately 2 feet on either side to allow temporary construction access from the bottom. Two drain channel sections require repair where the concrete channel was removed. An approximately 50-foot concrete channel would be replaced and a new 50-foot concrete channel near the existing manhole at the bottom of this channel would be constructed Retaining Wall The retaining wall would be installed using one of two approaches: 1) a single bin wall; or 2) two bin walls. The single wall construction method would be approximately 40 to 50 feet long and vary from 11 to 22 feet tall. The two-wall approach would consist of one wall that is approximately 40 to 50 feet long and a second that is 30 feet long (the walls vary from 7.5 to 14 feet tall), which step up on the hillside to have a more uniform slope. The bin walls would act as a gravity retaining wall and minimize the construction time allowed for installation in a difficult site access location. The bin wall would consist of 51 Area Reservoir Repair, MCB Camp Pendleton 2-3 EA

19 2 Alternatives Including the Proposed Action Figure Drainage Channels Area Reservoir Repair, MCB Camp Pendleton EA

20 2 Alternatives Including the Proposed Action thin metal structures (0.109-inch thickness) in approximately 10-foot-wide sections filled with granular pervious material or soil. Excavation and removal of dirt/debris would be required in this area. The backfill for the retaining wall would be compacted to 95 percent and be placed in 4- to 8-inch layers, with the top 12 inches consisting of native soil. A drain line would be required at the top of the wall(s) as well as a perforated pipe drain surrounded by pervious backfill below the wall. The fill required for the retaining wall would be approximately 800 cubic yards, with a surface area of 3,784 square feet (0.09 acre). The soil above the wall would be restored and protected with native vegetation ( restoration ). Any unvegetated area on a slope greater than 10 percent would require hydromulching and jute netting with straw wattles; the straw wattles would be removed within 5 years. The estimated construction time for this repair is 45 to 60 days. The Erosion Repair Footprint may be fenced off and excluded for PPM, as needed per the Biological Opinion and project biologist Construction Site Access and Laydown Areas Two laydown areas would be used for construction of the proposed action. The top construction site laydown would be located east of/adjacent to Reservoirs and 51771, and would include the road to the valve vault. The road to the valve vault would allow a crane to access the project site to remove debris and allow delivery of the retaining wall supplies to the project site. This road was initially graded in 2010 and would remain as a permanent impact for future access for laydown use and maintenance of the drain channels. The bottom access road created to conduct emergency repairs (graded in October 2012) would be used to access the project site and would also be used as a laydown area for the removal of debris and repair of the concrete culverts. A portion of the access road (10-foot-wide section of road parallel to housing) that was originally installed to conduct emergency repairs at the bottom of the project site (currently ranges from 11 to 30 feet wide) would provide access for maintenance. The remainder of the area would be restored back to PPM-suitable habitat. The 10-foot-wide road would allow a truck/skip-loader/excavator to access the project site to remove debris generated from runoff into the main drain channel. In addition, during construction, vehicles would be parked temporarily during the day at the top of the Temporary Access Road which would be restored after construction completion Maintenance of Drainage Channels The project site consists of numerous drainage channels that need maintenance on a yearly basis to minimize drainage issues from the main reservoir (Figure 2.1-2). Channels #1 and #2, Eastern Channel. Maintenance would include removing debris/sand/silt from and trimming any vegetative growth over the 4-feet-wide by 1.5-feet-deep drainage channels. Access to Channels #1 and #2 would be from the top of the channel adjacent to the reservoir. A truck/bobcat would be located at the top of the channel in the proposed construction laydown area and mechanized equipment would not be placed in the channel. Channel #3 and Channel #4. Maintenance would include removing debris/sand/silt from and trimming any vegetative growth over the 4-feet-wide by 1.5-feet-deep drainage channels. Access to Channels #3 and #4 would be by foot, with no mechanized equipment within the channel. To assist with vegetation removal, a crane would be located above the channel within the laydown area. Main Channel. Maintenance would include removing debris/sand/silt from and trimming any vegetative growth over the 4- to 7-feet-wide by 1.5-feet-deep drainage channel. Access to the 51 Area Reservoir Repair, MCB Camp Pendleton 2-5 EA

21 2 Alternatives Including the Proposed Action lower portion of the main channel would be from the access road that was installed to make the emergency repairs; a bobcat/truck would have access to the manhole location to remove any large debris collected at the bottom of the channels. Access to the remainder of the main channel to trim vegetation would be by foot, with no mechanized equipment within the channel Restoration and Enhancement Restoration for Impacts to PPM Habitat and Temporary Impacts due to Construction MCB Camp Pendleton would develop and implement a plan to restore a total of 1.18 acres of PPMoccupied habitat impacted by the proposed project (0.48 acres) and by past activities (0.7 acres (Figure The Habitat Restoration Plan would be reviewed and approved per the Biological Opinion (BO) from the United States Fish and Wildlife Service (USFWS 2017) before any impacts to PPM- occupied habitat and would address the following: Habitat restoration would be performed in areas that would be impacted from making repairs to the reservoir drainage system (i.e., Restoration Sites 02 and 03) and that have been subject to prior habitat disturbances (i.e. Restoration Sites 01, 04 and 05). The restoration plan would include quantitative performance criteria for assessing success of the restoration effort and to ensure the vegetation community targeted has the appropriate attributes to support PPM. Considerations to be included in the Restoration Plan include topsoil salvage in areas that would be subject to soil disturbance; the maintenance of friable soils preferred by PPM; planting of species, such as native grasses and forbs, that are prevalent within PPM-occupied habitat; the spatial design of planting; incorporation of erosion control measures to minimize degradation of temporarily impacted habitat; and maintenance and monitoring of the site to ensure that performance criteria are met. Plant species used would be derived from local source populations on Camp Pendleton, south coastal Orange County, or north coastal San Diego County. The use of plant stock from outside these geographic areas must be reviewed and approved by the MCB Camp Pendleton. Noxious weeds (as listed by the California Invasive Plant Council) may be controlled by hand weeding or herbicide application in disturbed areas as necessary to prevent their establishment. Restored areas would be planted and maintained to provide PPM habitat (e.g., percent shrub cover) and not necessarily to match the surrounding vegetation cover. Implementation of restoration would occur as soon as practicable following project construction Habitat Enhancement MCB Camp Pendleton would develop and implement a plan to enhance acres of PPM habitat in the vicinity of the 51 Area PPM South San Mateo population Figure and adjacent to and in conjunction with previous enhancement associated with the P-1044 Enhancement site. The Habitat Enhancement plan would be reviewed and approved per the BO from the USFWS before any impacts to PPM occupied habitat and would address the following: Habitat enhancement would be performed in areas outside the construction footprint that the MCB Camp Pendleton PPM monitoring program suggests are unoccupied or are only lightly occupied by PPM and where vegetation manipulation is likely to have only minor or negligible short term adverse effects to the species. Habitat enhancement is intended to provide an overall Area Reservoir Repair, MCB Camp Pendleton EA

22 2 Alternatives Including the Proposed Action long term net benefit to the South San Mateo PPM population by increasing the area of habitat suitable for PPM use in this vicinity. The Enhancement Plan would identify the exact location of the area(s) to be enhanced and specify the timing of enhancement actions. For areas that would be enhanced, the plan would include quantitative performance criteria, and enhancement measures would be performed using an adaptive management framework that involves application of two or more management treatments (e.g. vegetation thinning alone and vegetation thinning with the removal of leaf litter and debris from the soil surface) and pre- and post-enhancement PPM monitoring that would provide information about the relative efficacy of the different habitat enhancement methods Special Conservation Measures The Biological Opinion for the 51 Area Reservoir Repair Project (USFWS 2017) is provided as Appendix C and constitutes part of this EA. The special conservation measures in that BO would be included in the proposed action and these measures would be included as contract requirements on all relevant project scoping, scheduling, and planning documents. 2.2 No-Action Alternative Under the No-Action Alternative, the repairs and restoration would not take place. Under the No-Action Alternative, the existing mudslide area would continue to erode with each additional rainfall sending sand and sediment down the storm channel while removing more of the hillside. This would also prevent the four housing units from being reoccupied and could cause other units to be relocated. The No-Action Alternative is not considered a reasonable alternative because it does not meet the purpose and need for the proposed action. However, it does provide a measure of the baseline conditions against which the impacts of the proposed action can be compared. In this EA, the No-Action Alternative represents the baseline conditions described in Chapter 3, Affected Environment and Environmental Consequences. 2.3 Alternatives Considered But Eliminated As part of the USMC s decision-making process, three alternatives were considered but eliminated as infeasible, as described below Install a 10-foot Wide Road from the Reservoir This alternative is the same as Alternative 1 in terms of repair of the system except it involves a 10-foot wide road addition. This alternative would install an additional 10-foot wide road from the top of the hill following the third drain channel to the retaining wall location. This addition would make construction access easier, but would involve greater impacts to the PPM habitat than what has already been done (due to the erosion and construction of the emergency repairs access road). Therefore, this alternative was not carried forward for analysis due to the increased environmental consequences. 51 Area Reservoir Repair, MCB Camp Pendleton 2-7 EA

23 2 Alternatives Including the Proposed Action Install a 10-foot Wide Road from the San Diego Gas and Electric Access Road This alternative is the same as Alternative 1 in terms of repair of the system except it would install an additional 10-foot wide road from the current San Diego Gas and Electric access road and run perpendicular to the main drain channel. This addition would make construction access easier, but would involve greater impacts to the PPM habitat than what has already been done (due to the erosion and construction of the emergency repairs access road). Therefore, this alternative was not carried forward for analysis due to the increased environmental consequences Extend the Emergency Repairs Access Road This alternative would extend the existing emergency repairs access road to the retaining wall location. This alternative was not carried forward for analysis because it would result in greater impacts to PPM habitat than what has already been done (due to the erosion and construction of the emergency repairs access road). In addition, these impacts would not be required for proposed repairs but rather would only provide convenience during construction activities. 2.4 Resource Areas Eliminated From Detailed Consideration This section identifies resources excluded from further discussion and provides the rationale for its elimination. Reasons for elimination include: The resource does not exist at the project site; The resource would not be impacted by the proposed action or impacts, The resource would not be impacted by the proposed action with use of mitigation and conservations measures. The proposed action is to repair facilities and the environment, the activities associated with maintaining the facilities would be limited; therefore, the USMC has determined that several resource areas did not require detailed analysis in this EA; potential impacts were determined to be non-existent or negligible. Resources not addressed further in this EA include: topography, geology and soils; cultural resources; noise; transportation; land use; public health and safety; aesthetics; public services; socioeconomics; environmental justice; hydrology and water quality, and utilities. Topography, Geology, and Soils: The proposed action is not located near a fault line. The nearest fault line is over 60 miles away; however, the proposed action would be built to comply with applicable seismic design standards. In addition, the proposed action would comply with National Pollution Discharge Elimination System (NPDES) General Construction Permit requirements, Department of Defense (DoD) Unified Facilities Code guidance for Low-Impact Development (Unified Facilities Code ), and 438 of the Energy Independence and Security Act of 2007 (42 USC 17094) regulations to prevent erosion at the project site. Therefore, no impacts on topography, geology, and soils would occur. Cultural Resources: The area of potential effects for the proposed action was surveyed by SAIC (2013) and a supplemental survey by Byrd (2014). No archeological sites or isolates were identified within or in close proximity to the project area of potential effects (SAIC 2013 and Byrd 2014). There are also no historic buildings or structures and no known traditional cultural resources within the area of potential effects. Previous archeological survey investigations indicate that there are no archeological sites located Area Reservoir Repair, MCB Camp Pendleton EA

24 2 Alternatives Including the Proposed Action within the area of potential effects. In addition, no existing buildings or structures would be modified or demolished as part of the proposed action. Therefore, no impacts on cultural resources would occur. Noise: Operation of the proposed action would not be expected to generate noise above the community noise standard. In addition, construction of the proposed action would be temporary (approximately 2 months) and occur between the hours of 0700 and The increase in noise at the construction site would be representative of a typical construction site and would not exceed 85 decibels. Therefore, no noise impacts would occur. Transportation: The proposed action would not be expected to produce an increase in traffic at MCB Camp Pendleton during proposed operations. However, a temporary increase in traffic during construction of up to 40 trips per day would be expected. This represents less than 0.01 percent of the traffic at MCB Camp Pendleton (USMC 2012) and would be within the normal flux of vehicles on the Base. Furthermore, the proposed action would include the preparation of a Construction Traffic Management and Detour Plan that would specify necessary lane closures, detours, signage/lighting, flaggers, and other traffic control measures needed to avoid accidents and provide access and continued traffic movement along Basilone Road during construction. Therefore, no impacts on transportation would occur. Land Use: The proposed action would not change the existing land use; it would repair existing facilities that already meet the land use criteria for the project site, or provide additional earth stabilization to prevent further erosion and destabilization of the soils. Therefore, the proposed action would be compatible with existing and planned land uses in the project vicinity and no impacts on land use would occur. Public Health and Safety: No Installation Restoration sites or Underground Storage Tanks are located within the project site. In the event contamination is discovered during construction activities, MCB Camp Pendleton ES would be contacted immediately for necessary remedial requirements. If any contaminated soil or debris is discovered, it would be disposed in accordance with applicable federal, state and local laws and regulations. Therefore, no impacts to public health and safety would occur. Aesthetics: The proposed action would not affect a site that is visible to the public, or impact areas visible to the public. In addition, the proposed facilities would be designed and constructed consistent with the Base Exterior Architecture Plan guidelines. Therefore, no impacts on aesthetics would occur. Public Services: There would be no additional military, government/civilian, or contractor support personnel stationed at MCB Camp Pendleton as a result of the proposed action. Consequently, the proposed action would not result in a substantial increase in public services. Therefore, no impacts on public services would occur. Socioeconomics: There would be no additional military, government/civilian, and/or contractor support personnel stationed at MCB Camp Pendleton with implementation of the proposed action. Therefore, impacts on socioeconomics would not occur. Environmental Justice: The proposed action would not result in disproportionate impacts to minority and low-income populations and would not result in environmental health or safety risks to children. Therefore, impacts on environmental justice would not occur. Hydrology and Water Quality: The proposed action would not have an effect on the hydrology or water quality in the area. This proposed action would repair existing facilities, or provide additional earth stabilization to prevent further erosion and destabilization of the soils, and would not involve any 51 Area Reservoir Repair, MCB Camp Pendleton 2-9 EA

25 2 Alternatives Including the Proposed Action discharge into Waters of the United States. BMPs would be implemented during construction to ensure that water hydrology and quality are not affected. Therefore, the proposed action would have no impacts on hydrology and water quality. Utilities: This proposed action would not change the existing utilities or add any additional utilities; it would repair existing facilities that already have the utilities needed to support their operation. Therefore, the proposed action would have no impacts on utilities. 2.5 Summary of Impacts Resource areas analyzed in this EA include biological resources and air quality/greenhouse gases (GHGs). The environmental consequences associated with implementation of Alternative 1 and the No-Action Alternative are presented and compared in Table A detailed description of the affected environment and analysis of the environmental consequences is presented in Chapter 3. Table Summary of Impacts Resource Area Preferred Alternative No-Action Alternative Biological Resources NSI NSI Air Quality and Greenhouse Gases NSI NI Notes: NSI = No Significant Impact; NI = No impact 2.6 Preferred Alternative Alternative 1 is the preferred alternative because it fulfills the purpose and need for the proposed action while minimizing environmental impacts Area Reservoir Repair, MCB Camp Pendleton EA

26

27 3 Affected Environment and Environmental Consequences 3 Affected Environment and Environmental Consequences This chapter describes the affected environment (existing environment) and analyzes the potential environmental consequences that would occur as a result of implementing Alternative 1 and the No- Action Alternative. The resources evaluated in detail in this chapter include biological resources (Section 3.1) and air quality and greenhouse gases (Section 3.2). 3.1 Biological Resources This section describes existing habitat on MCB Camp Pendleton that would be directly impacted by the proposed action, additional information related to biological resources can be found in the Biological Opinion on the 51 Area Reservoir Repair Project located at Appendix C. The vegetation community that occurs within the project vicinity is limited to Diegan coastal sage scrub and Figure shows the threatened and endangered species in the project area Affected Environment Wildlife In addition to common species, the project site may host a handful of species of special concern (SSC) named by the California Department of Fish and Wildlife (CDFW) (CDFW 2011). Potential SSC inhabitants include the Coastal cactus wren (Campylorhynchus brunneicapillus sandiegoense), orangethroated whiptail (Aspidoscelis hyperythrus), and red diamond rattlesnake (Crotalus ruber ruber). Most of the bird species both resident and migrant are protected under the Migratory Bird Treaty Act and are given special consideration under Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds Threatened and Endangered Species The Pacific pocket mouse (Perognathus longimembris pacificus) and the Coastal California Gnatcatcher (Polioptila californica californica) are two species federally listed under the ESA as threatened or endangered identified as having the potential to occur within the project vicinity based on historical records, recent surveys, and/or the presence of similar suitable habitat (Table 3.1-1, Figure 3.1-1). Based on reviews of MCB Camp Pendleton s current monitoring and surveys, Geographic Information System information, and site conditions the potential occurrence of federally listed threatened and endangered species in the project site is summarized in Table A description of the species background, and regional and local context of distribution of the species, is provided in the 51 Area Reservoir Repair BO (Appendix C) USFWS 2017)). 51 Area Reservoir Repair, MCB Camp Pendleton 3-1

28 3 Affected Environment and Environmental Consequences Figure Threatened and Endangered Species Known to Occur in the Project Site and Vicinity Area Reservoir Repair, MCB Camp Pendleton EA

29 3 Affected Environment and Environmental Consequences Table Federally Listed Threatened and Endangered Plant and Animal Species Known to Occur in the Project Vicinity Species Status Habitat/Occurrence in Project Site Pacific Pocket Mouse (Perognathus longimembris pacificus) Coastal California Gnatcatcher (Polioptila californica californica) Status: FE FT, CSC This species is known to occur on MCB Camp Pendleton within plant communities suitable for the PPM consisting of shrublands with firm, finegrain, sandy substrates in the immediate vicinity of the ocean. These communities include coastal strand, coastal dunes, river alluvium, and coastal sage scrub growing on marine terraces. There is PPM-occupied habitat in the majority of the project site. Occupied CAGN habitat (as defined as 150-meter buffer encompassing all CAGN points within the last 25 years) occurs within the majority of the project site, with all permanent and temporary project impacts from construction being assumed occupied by CAGN. Federal Status (determined by USFWS): FE Federally Listed Endangered FT Federally Listed Threatened Notes: PPM = pacific pocket mouse; MCB = Marine Corps Base; USFWS = United States Fish and Wildlife Service; USMC = Unites States Marine Corps Environmental Consequences from the Proposed Action This section presents an analysis of potential direct, indirect, temporary, and permanent impacts on listed species that would result from the proposed action. The following analysis assumes the incorporation of Special Conservation Measures, as listed in Appendix C. Direct impacts are the immediate result of project-related activities (e.g., direct mortality of species, noise effects). Direct impacts may be either temporary (reversible) or permanent (irreversible). Most direct impacts are confined to the project site, but some (e.g., noise, siltation) may extend beyond the project site. Indirect impacts are caused by or result from project-related activities, but occur later in time or are spatially removed from the activities. Indirect impacts are diffuse, resource-specific, and less amenable to quantification or mapping than direct impacts, but still need to be considered. Indirect impacts typically extend beyond the immediate project site Alternative 1: Proposed Action Federally Listed Species Impacts to federally listed species and their native plant communities would occur with vegetation removal and soil disturbance during construction, with minimal disturbance during maintenance, restoration, and enhancement. Table summarizes potential effects on listed species from Alternative Area Reservoir Repair, MCB Camp Pendleton 3-3 EA

30 3 Affected Environment and Environmental Consequences Table Summary of Potential Impacts on Listed Species with Implementation of Alternative 1 Species Effects on Habitat Effects on Individuals Pacific Pocket Mouse (PPM) Temporary impact to habitat. Restoration and Enhancement should provide permanent improvement over existing habitat opportunities. Direct: Displacement of PPM from impacted habitat during construction, including the moving of individuals via a biological monitor. Noise and vibration impacts within 100 feet of project impact areas (both construction and restoration). Indirect: Potential increase in competition in surrounding habitat due to displacement of individuals within the project footprint. Coastal California Gnatcatcher (CAGN) This impact is likely to be temporary as the overall carrying capacity of the action area for the gnatcatcher is likely to return to pre-project levels as the shrub community recovers from the proposed thinning, and the project would not result in a longterm reduction in habitat for the gnatcatcher. Direct: Displacement of CAGN from impacted habitat during construction and restoration. Indirect: Potential increase in competition in surrounding habitat due to displacement of individuals within the project site. Minimal potential for disruption of nesting behavior to pairs adjacent to the project footprint Coastal California Gnatcatcher The action area consists primarily of gnatcatcher-occupied CSS, with smaller areas of non-native forbs/grassland, and unvegetated areas that were impacted by past activities. For the purpose of this project, gnatcatcher-occupied CSS is defined as CSS that occurs within 500 feet of any historically documented gnatcatcher locations within the past 25 years. Gnatcatcher presence was determined using basewide data. Basewide gnatcatcher surveys have been conducted once every 3 to 5 years on MCBCP dating back to To estimate the number of gnatcatcher pairs that overlap with the current project footprint GIS was used to map an area of 5.7 acres around each of the gnatcatcher territory locations documented in Although gnatcatcher territory size is known to vary with habitat conditions and other variables such as distance from the coast (Preston et al. 1998), this analysis uses the average estimated gnatcatcher territory size in Rancho Palos Verdes (Atwood et al. 1998a) as the basis for this analysis based on the similarity of habitat conditions and distance from the coast for the two areas. Using this methodology, an estimated total of 12 gnatcatcher territories overlap the project footprint, which includes proposed grading impacts, construction laydown and staging areas, drainage channels proposed for repair, and proposed restoration and enhancement areas. Locations of gnatcatchers within the vicinity of the project site are provided in Figure Occupied CAGN habitat occurs within the majority of the project site, with all permanent and temporary project impacts from construction being assumed occupied by CAGN Area Reservoir Repair, MCB Camp Pendleton EA

31 3 Affected Environment and Environmental Consequences Direct Effects This impact is likely to be temporary as the overall carrying capacity of the action area for the gnatcatcher is likely to return to pre-project levels as the shrub community recovers from the proposed thinning, and the project would not result in a long-term reduction in habitat for the gnatcatcher. Because there is a large gnatcatcher population (estimated to be 436 territories in 2014) on MCBCP, the project would impact a small percentage (about 1.1 percent) of the total population. The gnatcatcher population on MCBCP can likely tolerate this level of temporary impact without increased risk of extirpation. Thus, the project would not result in an appreciable reduction in the numbers, reproduction, or distribution of the gnatcatcher population on MCBCP or range-wide (USFWS 2017). Indirect Effects Additional indirect effects to gnatcatchers from the project include the potential for habitat degradation associated with an increase of erosion and sedimentation, introduction of invasive species, wildfire, and human encroachment. MCBCP already has extensive infrastructure, so with the proposed conservation measures, the increase in habitat degradation associated with these factors is likely to be insignificant (USFWS 2017). Conclusion 1. The project would temporarily remove habitat supporting up to four gnatcatcher pairs and would impact one additional pair as a result of impacts from construction noise. The affected pairs represent a small fraction of the estimated 439 gnatcatcher territories on MCBCP as of 2014 (Tetra Tech 2014). 2. The project would result in negligible permanent impacts to gnatcatcher habitat and would result in restoration of 1.18 acres of CSS. Thus, the project would result in no net loss of gnatcatcher habitat over the long term. 3. With the proposed conservation measures, the project is not expected to appreciably reduce the numbers, reproduction, or distribution of the species on MCBCP or rangewide and is not anticipated to impact recovery of the species Pacific Pocket Mouse The 51 Area reservoir repair project occurs within the South San Mateo PPM population. Specific trapping surveys were not performed in support of this action. To characterize the amount of this population s habitat that falls within the action area the Marine Corps has defined PPM occupied habitat to include the area within 492 feet (150 meters) of all historically documented PPM capture locations. However, not all PPM habitat within and adjacent to the project footprint may be occupied each year. Results from the MCBCP PPM monitoring program indicate that on average 26 percent or about acres (range acres) of the 260-acre South San Mateo PPM monitoring area were occupied/used by PPM between 2012 and 2015 (Brehme 2016, pers. comm.). This suggests that occupancy within suitable habitat varies over time and that PPM are unlikely to occupy all of the suitable habitat (i.e., CSS and disturbed habitat) within 492 feet of historic capture locations at any given point in time. Direct Effects While a majority of the area that is subject to soil disturbance from restoration and project construction was recently disturbed (between 2010 and 2014), impact monitoring grids established within a Area Reservoir Repair, MCB Camp Pendleton 3-5 EA

32 3 Affected Environment and Environmental Consequences emergency reservoir repair access road and the 2014 Basilone housing area firebreak indicate that PPM have recolonized at least some of the disturbed areas. Therefore, proposed soil disturbance from the restoration of habitat and construction to repair the reservoir drainage system could excavate or crush animals in their burrows. Animals subject to direct disturbance would either not be expected to survive or, through displacement, would be harmed from increased competition, increased risk of predation and stress, and reduced reproduction. Project construction would directly impact 0.84 acre of suitable PPM habitat within the soil disturbance footprint, and restoration would be conducted within another 0.70 acre of habitat that was previously impacted from the construction of fire breaks. Cumulatively this represents about 0.6 percent of the available habitat within the 260-acre South San Mateo PPM Monitoring Area. However, because monitoring grids in the vicinity of the construction and restoration footprints have consistently been occupied by PPM, the higher average monitoring grid occupancy rate in this area (0.76 *1.54 acres = 1.17 acres) was used to estimate that about 1.7 percent of the South San Mateo PPM population (1.17 acres/67.77 acres) would be impacted within the construction and restoration soil disturbance footprint. Based on average densities of PPM within the South San Mateo monitoring program grids from ( PPM/ ac.) in absolute terms this could result in death or injury to 6 to 30 PPM, with the overall proportional impact to the population likely to remain the same over this range because the higher impact estimate is associated with higher animal densities at times of population abundance in the action area. Pursuant to conservation measures that have been developed as part of the project, the Marine Corps proposes to erect exclusionary fencing around a small portion of the construction area and perform salvage trapping of PPM from that area. Due to the linear nature of the project and site topography, this is only feasible within about a 0.10 acre area where there has been severe erosion and construction of a retaining wall and backfilling with soil is proposed. The salvage trapping involves enclosing the construction footprint with a barrier that rodents cannot circumvent (e.g., silt fencing, flashing) and livetrapping and removing PPM from the enclosed area before the initiation of construction. Any captured animals would be removed and incorporated into a captive population that is being managed by the San Diego Zoological Society to assist in the recovery of PPM (Shier and Swaisgood 2013) or released outside of the exclusion fencing. Removal of animals from the construction footprint saves them from direct injury from construction but does not ensure they would be unharmed, as any salvaged animals that are released away from their burrows would suffer the same harm described for displaced animals (see below). Alternatively, PPM transferred to the breeding facility at the San Diego Zoo could contribute to future generations of captive mice. Consistent with the tasks identified in the PPM Recovery Plan (Service 1998), mice in this facility are being bred as a source of animals for creation of additional wild populations within the species historic range. Given the size of the removal trapping area and based on the number of proposed trap nights and observed nightly individual capture probabilities, most, if not all, of the PPM in this portion of the project footprint (likely just one or two individuals) would be removed from the project footprint before construction. PPM that enter traps could be killed or injured by the trapping activity itself from impingement in trap doors, elevated stress from confinement, exposure to heat or cold temperatures, or from aggression with hetero or con-specific animals confined in the same trap. Based on past experience, the qualification of individuals that would be performing the trapping, and the small number of individuals that may be captured, this risk is likely to be very low but is not absent. Therefore, a conservative estimate is that one of the captured animals could be killed or injured during the trapping activity, which includes transport of any salvaged animals to the San Diego Zoo. Any of the remaining animals within the project footprint following trapping and removal efforts would be crushed or displaced by the project. Because the surrounding habitat is already occupied by PPM and other small mammals that likely compete with PPM for resources (i.e., food and space), any PPM that are Area Reservoir Repair, MCB Camp Pendleton EA

33 3 Affected Environment and Environmental Consequences displaced from their burrows or are captured and deposited outside the project footprint would be subject to harm from the loss of their burrows, an increased risk of predation, increased competition with heteroand conspecifics, and decreased reproduction. Because only a small portion of the project footprint can be trapped and PPM remaining in the project footprint would likely be crushed in their burrows and difficult to observe, likely no more than 1 individual would be observed dead or injured as a result of construction activities. Following project completion, about 0.48 acre within the construction footprint and 0.70 acre impacted by past activities would be restored with native vegetation to recreate suitable habitat for PPM, and 0.46 acre would be permanently converted to non-habitat use. Habitat that is subject to temporary direct impacts would likely be successfully restored to support PPM and PPM should begin colonizing and using the areas subject to direct impacts within 2 to 4 years following initiation of restoration. While higher habitat occupancy rates adjoining the project footprint relative to the average occupancy rate at South San Mateo as a whole suggest up to 1.7 percent of the South San Mateo population could be injured or killed within the direct impact footprint, just 0.5 percent of the 260 acres of habitat thought to be suitable for PPM occupancy at South San Mateo would be temporarily lost, and 0.2 percent would be permanently converted to a non-habitat use. Given the small temporary proportional loss to the population and small permanent loss of suitable habitat, direct habitat losses would not appreciably reduce the survival of the South San Mateo PPM population. Noise and Vibration The use of large vehicles and heavy construction equipment during project grading and construction would generate noise and vibration that is likely to detrimentally affect PPM in adjoining habitat. Vibrations created by such equipment attenuate through the soil at various frequencies and can be transferred to the bodies of animals that reside underground. Laboratory studies show that the effects of low frequency vibrations on small mammals can include effects such as increased stress and ulcer formation in adult rodents, and increased congenital malformation and reduced birth weight of pups (Sackler and Weltman 1966, Bantle 1971, Toraason et al. 1980, Seidel and Griffin 1998, Rubin et al. 2007). The potential effects and likely zone of construction-related vibrational impacts on rodents in natural systems, though, is not fully understood. PPM within acres of suitable habitat in the area adjoining the soil disturbance footprint would likely be subject to harm from noise and vibration. This represents about 4 percent of the available habitat within the 260-acre South San Mateo PPM Monitoring Area. Because the monitoring program has consistently documented PPM occupancy in this vicinity, the average occupancy rate of monitoring grids in this vicinity (76 percent) is used to estimate that about 12 percent (7.91 acres/67.77 acres) of the South San Mateo PPM population could be directly impacted from construction-related noise and vibration. Based on average densities of PPM within the SSM monitoring program grids from ( PPM/ ac.), in absolute terms this could result in death or injury to 38 to 203 PPM, with the overall proportional impact to the population likely to remain the same over this range because the higher impact estimate is associated with higher animal densities at times of population abundance in the action area. PPM within the area subject to noise and vibration may be killed or injured from burrow collapse, or animals may flee in response to noise and vibration and be displaced into adjoining occupied habitat. Animals that flee or are displaced would be harmed from the loss of their burrows, and would likely suffer from increased risk of predation, increased competition with hetero- and conspecifics, and decreased reproduction. Because these impacts are not certain to be fatal, and animals that survive have the potential to breed and contribute to future generations, no attempt would be made to trap and remove animals from the area subject to noise and vibrational impacts. Furthermore, it is unlikely that any PPM within the area subject to noise and vibration would be observed dead or injured during or following 51 Area Reservoir Repair, MCB Camp Pendleton 3-7 EA

34 3 Affected Environment and Environmental Consequences project implementation because PPM is a nocturnal burrowing rodent and any direct injury to PPM is likely to occur belowground where the likelihood of observing injured animals is remote. Overall, the harm to up to 12 percent of the South San Mateo PPM population from construction associated noise and vibration when combined with direct habitat losses would increase the vulnerability of the South San Mateo population to the effects of environmental and demographic stochasticity, loss of genetic diversity, inbreeding depression, and catastrophes. However, based on PPM observations following the 2014 grading incident, this impact would likely be temporary and would not alter the suitability of PPM habitat in the area subject to noise and vibration impacts. Under favorable environmental conditions PPM would likely begin to utilize the acres of impacted habitat within 1 to 2 years of project construction, with re-colonization of this habitat likely to extend over a longer time interval (e.g. 3-5 years) under less favorable environmental conditions. Thus, impacts from noise and vibration would not appreciably reduce the survival of the South San Mateo PPM population over the long term. Habitat Restoration and Enhancement As a conservation measure, the Marine Corps proposes to perform a total of 1.18 acres of restoration within the past and proposed soil disturbance footprint and acres of enhancement at South San Mateo to help offset impacts to the PPM population from implementation of the project. The goal of restoration within the construction footprint and areas of prior grading impacts would be to return these areas to suitability for PPM. The goal of enhancement is to improve the suitability of and expand the amount of occupied habitat within the 260-acre area that supports the South San Mateo PPM population. The enhancement would be performed by thinning the shrub canopy and removal of duff and thatch in areas that the PPM monitoring program has found to be unoccupied or only lightly occupied by PPM. If successful, this would compensate for the short term increase in vulnerability of the South San Mateo PPM population to extirpation by increasing the average amount of PPM occupied habitat at San Mateo South by 133 percent (i.e. average occupied habitat would increase from to acres), increasing the carrying capacity of the South San Mateo population, and reducing its vulnerability to the effects of small population size (e.g., loss of genetic diversity, inbreeding depression, vulnerability to catastrophe) for a number of years until the vegetation re-grows and returns to its pre-project condition. At the Dana Point PPM population location, where similar vegetation thinning and duff removal enhancements have been performed within senescent sage scrub, monitoring has found increased occupancy and continued use of thinned areas by PPM over time (Brylski et al. 2010, Carranza 2014). Habitat restoration and enhancement activities such as weeding, planting, vegetation thinning, and duff removal have the potential to impact PPM from landscape workers trampling or disturbing active burrows. A study of burrow-depth in the closely-related little pocket mouse (Perognathus longimembris longimembris) documented that individuals selected resting sites in their burrows at depths ranging from 3.3 feet to as little as 0.4 inches (Kenagy 1973). Thus, workers could crush PPM in their burrows as they walk through habitat and perform restoration and enhancement activities, though the initial likelihood of workers crushing animals in burrows where there was recent soil disturbance should be low due to the immediately preceding construction impacts. As habitat conditions improve over time, both the restoration areas and the enhancement site(s) are likely to become occupied more densely by PPM. To minimize harm to animals within proposed restoration or enhancement areas, a PPM biologist would survey for and flag active small mammal burrows to be avoided by soil disturbing planting activities; would flag access paths to the restoration and enhancement areas to avoid trampling of areas with the highest potential to support PPM; and would, in coordination with CFWO, select the final boundaries of proposed habitat enhancement area(s). Monitoring of vegetation response and habitat use by PPM would also be performed as a component of restoration and enhancement plan implementation so that habitat Area Reservoir Repair, MCB Camp Pendleton EA

35 3 Affected Environment and Environmental Consequences management efforts can be adapted to minimize impacts to an increased presence of mice, if this is observed. Overall, with implementation of these minimization measures, the restoration and enhancement activities may kill or injure a few PPM (e.g. up to 2 to 3 individuals) over the life of the project, but any PPM killed or injured in this manner are likely to remain belowground in their burrows where they are unlikely to be observed. Because these individuals would be harmed from implementation of habitat restoration and enhancement that is being performed specifically to increase the extent of habitat occupancy at South San Mateo, the benefits of restoration and enhancement outweigh the loss of these individuals and their loss is not anticipated to appreciably reduce the prospects of survival of the South San Mateo PPM population. Indirect Effects Maintenance Activities Yearly maintenance of the drainage channels is proposed to keep the drainage channels free from vegetation, sand, silt, and debris. To minimize impacts to PPM, maintenance of the drainage channels would be scheduled to occur when PPM are dormant (i.e., from October 16 February 28/29), and access to the drainage channels would be by foot. Maintenance activities would involve no ground disturbance outside of the lined drainage channels, and all vehicles and mechanized equipment would remain within the permanent crane laydown area and permanent access road shown on Figure While accumulation of sand, debris, and vegetation in the drainage channels has potential to create suitable habitat conditions that could be colonized by PPM, routine maintenance of the drainage channels would prevent suitable habitat conditions from forming for a long enough time for PPM to colonize the concrete drainage channels. Restriction of vehicles and mechanized equipment to established staging areas should also help to minimize potential impacts to PPM. With continued faithful and routine maintenance of the drainage channels, it is unlikely that any PPM would be killed, injured, or harmed from yearly maintenance activities. Conclusion Up to 1.7 percent of the South San Mateo PPM population is anticipated to be impacted within the project footprint, and up to 12 percent of the South San Mateo PPM population would be impacted due to noise and vibration from construction activities. However, permanent impacts from construction would be restricted to 0.46 acre, and habitat that is temporarily impacted from construction and noise and vibration is anticipated to be re-occupied by PPM following project completion. 1. To minimize impacts from project construction, efforts would be made to salvage all PPM residing within the 0.10 acre erosion repair footprint so that those animals can be incorporated into a captive population that is being bred for the purposes of species recovery or released outside the project footprint. 2. To minimize impacts from proposed habitat restoration and enhancement measures, advanced surveys would be performed to flag and avoid burrow systems during planting efforts and to direct habitat enhancement to areas within 51 Area that are not occupied or only lightly occupied by PPM. 3. Impacts to PPM habitat would be offset by restoration of 1.18 acres that was previously impacted or would be impacted by the project, and through enhancement of an additional acres of suitable PPM habitat at South San Mateo using an adaptive management framework that would be designed to improve our knowledge and ability to effectively manage PPM habitat over the long term. 51 Area Reservoir Repair, MCB Camp Pendleton 3-9 EA

36 3 Affected Environment and Environmental Consequences 4. With the proposed conservation measures, including measures to minimize impacts to the South San Mateo population and implement recovery actions identified in the PPM Recovery Plan (Service 1998), the project would not impede and should contribute to recovery of PPM No-Action Alternative Under the No-Action Alternative the USMC would not implement the repairs and restoration proposed under Alternative 1. The existing disturbed conditions would remain unchanged Area Reservoir Repair, MCB Camp Pendleton EA

37 3 Affected Environment and Environmental Consequences 3.2 Air Quality and Greenhouse Gases Affected Environment Ambient air quality refers to the atmospheric concentration of a specific pollutant compound (i.e., amount of a pollutant in a specified volume of air) at a particular geographic location. Ambient air quality levels are determined by pollutant emissions (e.g., type and amount of pollutant emitted into the atmosphere), meteorology (e.g., weather patterns affecting pollutant emissions), and chemistry (e.g., chemical reactions that transform emitted compounds into other pollutants). Air quality in a given location is generally expressed in units of parts per million (ppm) or micrograms per cubic meter (μg/m 3 ) of the pollutant. MCB Camp Pendleton is located within San Diego County, which is in the San Diego Air Basin (SDAB). A measure of significance is a pollutant s concentration in comparison to a national and/or state ambient air quality standard. These standards represent the maximum atmospheric concentrations that may occur and still protect public health and welfare with a reasonable margin of safety. The national standards for seven major pollutants of concern (i.e., criteria pollutants), established by the USEPA, are termed the National Ambient Air Quality Standards (NAAQS). California standards, which differ from NAAQS, are established by the California Air Resources Board (ARB) and are termed the California Ambient Air Quality Standards (CAAQS). The main pollutants of concern for the project region include volatile organic compounds (VOCs), ozone (O 3), carbon monoxide (CO), nitrogen oxides (NO x), particulate matter less than 10 microns in diameter (PM 10), and particulate matter less than 2.5 microns in diameter (PM 2.5). Although VOCs or NO x (other than nitrogen dioxide [NO 2]) have no established ambient standards, they are important as precursors to O 3 formation. O 3 is a secondary pollutant formed in the atmosphere by photochemical reactions of previously emitted pollutants, or precursors. O 3 concentrations are the highest during the warmer months of the year and coincide with the period of maximum insolation (i.e., direct solar radiation). Ambient air quality standards are based on both concentration and averaging time Existing Air Quality The USEPA designates all areas of the U.S. in terms of having air quality better (attainment) or worse than (nonattainment) the NAAQS. Former nonattainment areas that have attained the NAAQS are designated as maintenance areas. Presently, the SDAB is in attainment of the NAAQS for all pollutants except O3. Additionally, the western portion of the SDAB (the portion of the County generally west of the interior desert region) is also a maintenance area for CO. CAAQS are at least as restrictive as the NAAQS and include pollutants for which national standards do not exist. In addition to the federal criteria pollutants, California has identified four combinations of pollutants and averaging times for CAAQS that differ from NAAQS. Presently, the SDAB is in attainment of the CAAQS for all air pollutants except O 3, PM 10, and PM 2.5. The county is considered a severe ozone nonattainment area by the ARB. Table summarizes the national and state ambient air quality standards for regulated pollutants. Toxic air contaminants (TAC) include air pollutants that can cause serious illnesses or increased mortality, even in low concentrations. TACs are compounds that generally have no established ambient standards, but are known or suspected to cause short-term (acute) and/or long-term (chronic noncarcinogenic or carcinogenic) adverse health effects. The ARB designates diesel particulate matter from the combustion of diesel fuel as a TAC. 51 Area Reservoir Repair, MCB Camp Pendleton 3-11 EA

38 3 Affected Environment and Environmental Consequences Pollutant Ozone (O 3) Carbon monoxide (CO) Nitrogen dioxide (NO 2) Sulfur dioxide (SO 2) PM 10 PM 2.5 Lead Table National and California Ambient Air Quality Standards Averaging Time 8-hour 1-hour 8-hour 1-hour Annual 1-hour 24-hour California Standards 0.07 ppm (137 µg/m 3 ) 0.09 ppm (180 µg/m 3 ) 9 ppm (10 mg/m 3 ) 20 ppm (23 mg/m 3 ) 0.03 ppm (57 µg/m 3 ) 0.18 ppm (339 µg/m 3 ) 0.04 ppm (105 µg/m 3 ) National Standards (a) Primary (b,c) Secondary (b,d) ppm (147 µg/m 3 ) Same as primary ppm (10 mg/m 3 ) 35 ppm (40 mg/m 3 ) ppm (100 µg/m 3 ) 0.10 ppm (188 µg/m 3 ) 3-hour Same as primary ppm (1,300 µg/m 3 ) 1-hour 0.25 ppm ppm (655 µg/m 3 ) (196 µg/m 3 ) --- Annual 20 µg/m hour 50 µg/m µg/m 3 Same as primary Annual 12 µg/m 3 15 µg/m hour µg/m Rolling 3-month average 0.15 µg/m 3 Same as primary 30-day average 1.5 µg/m 3 Source: ARB 2013a Notes: ppm = parts per million; μg/m 3 = micrograms per cubic meters a Standards other than the 1-hour ozone, 24-hour PM10, 24-hour PM2.5, and those based on annual averages are not to be exceeded generally more than once a year. b Concentrations are expressed first in units in which they were promulgated. Equivalent units are given in parenthesis. c Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. Each state must attain the primary standards no later than 3 years after that state s implementation plan is approved by the United States Environmental Protection Agency. d Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant Greenhouse Gas Emissions GHGs are gases that trap heat in the atmosphere. These emissions occur from natural processes and human activities. The accumulation of GHGs in the atmosphere influences the long-term range of average atmospheric temperatures. Scientific evidence indicates a trend of increasing global temperature over the past century due to an increase in GHG emissions from human activities. The climate change associated with this global warming is predicted to produce negative economic and social consequences across the globe. Recent observed changes due to global warming include shrinking glaciers, thawing permafrost, a lengthened growing season, and shifts in plant and animal ranges (Intergovernmental Panel on Climate Change 2014; United States Global Change Research Program 2014; and California Energy Commission 2012). Predictions of long-term environmental impacts due to global warming include sea level rise, changing weather patterns with increases in the severity of storms and droughts, changes to local and regional ecosystems including the potential loss of species, and a significant reduction in winter snow pack. In California, global warming effects are predicted to include exacerbation of air quality problems, a Area Reservoir Repair, MCB Camp Pendleton EA

39 3 Affected Environment and Environmental Consequences reduction in municipal water supply from the Sierra snowpack, a rise in sea level that would displace coastal businesses and residences, damage to marine and terrestrial ecosystems, and an increase in the incidence of infectious diseases, asthma, and other human health problems (California Energy Commission 2012). The most common GHGs emitted from natural processes and human activities include carbon dioxide (CO 2), methane (CH 4), and nitrous oxide (N 2O). Examples of GHGs created and emitted primarily through human activities include fluorinated gases (hydrofluorocarbons and perfluorocarbons used in refrigerants and propellants, among other products) and sulfur hexafluoride. Each GHG is assigned a global warming potential (GWP), which equates to the ability of a gas or aerosol to trap heat in the atmosphere. The GWP rating system is standardized to CO 2, which has a value of one. For example, CH 4 has a GWP of 21, which means that it has a global warming effect 21 times greater than CO 2 on an equal-mass basis. Total GHG emissions from a source are often reported as a CO 2 equivalent (CO 2e). The CO 2e is calculated by multiplying the emission of each GHG by its GWP and adding the products together to produce a single, combined emission rate representing all GHGs. Federal agencies, on a national scale, address emissions of GHGs by reporting and meeting reductions mandated in federal laws, Executive Orders, and agency policies. The most recent of these are Executive Orders and and the USEPA Final Mandatory Reporting of Greenhouse Gases Rule. Several states have promulgated laws as a means of reducing statewide levels of GHG emissions. In particular, the California Global Warming Solutions Act of 2006 (Assembly Bill 32) directs the State of California to reduce statewide GHG emissions to 1990 levels by the year Groups of states also have formed regionally based collectives (such as the Western Climate Initiative) to jointly address GHG pollutants. In an effort to reduce energy consumption, reduce dependence on petroleum, and increase the use of renewable energy resources in accordance with the goals set by Executive Orders and the Energy Policy Act of 2005, the Marine Corps and DoD have implemented a number of renewable energy projects (NAVFAC SW 2006). The types of projects currently in operation within the southwest region include thermal and photovoltaic solar systems, geothermal power plants, and wind generators. The military also purchases one-half of the biodiesel fuel sold in California and continues to promote and install new renewable energy projects within the southwest region. On 1 August 2016, the Council on Environmental Quality (CEQ) finalized guidance on how federal agencies should evaluate the effects of climate change and GHG emissions for NEPA documentation (CEQ 2016). The CEQ does not propose a reference point as an indicator of a level of GHG emissions that may significantly affect the quality of the human environment. In the analysis of the direct effects of an action alternative, the CEQ proposes that it would be appropriate to (1) quantify cumulative emissions over the life of the project; (2) discuss measures to reduce GHG emissions, including consideration of reasonable alternatives; and (3) qualitatively discuss the link between such GHG emissions and climate change. The potential effects of proposed GHG emissions are by nature global and cumulative impacts because individual sources of GHG emissions are not large enough to have an appreciable effect on climate change. Therefore, the impact of proposed GHG emissions to climate change is discussed in the context of cumulative impacts in Chapter 4. Appendix B.1 presents estimates of GHG emissions generated by each project alternative Applicable Regulations and Standards The federal Clean Air Act (CAA) of 1970, and its subsequent amendments, establish air quality regulations and the NAAQS, and delegate the enforcement of these standards to the states. In California, 51 Area Reservoir Repair, MCB Camp Pendleton 3-13 EA

40 3 Affected Environment and Environmental Consequences the ARB is responsible for enforcing air pollution regulations. In San Diego County, the SDCAPCD has this responsibility. Basic elements of the CAA include the NAAQS for criteria air pollutants, hazardous air pollutant standards, attainment plans, motor vehicle emission standards, stationary source emission standards and permits, and enforcement provisions. The CAA establishes air quality planning processes and requires areas in nonattainment of an NAAQS to develop a State Implementation Plan (SIP) that details how the state will attain the standard within mandated time frames. The requirements and compliance dates for attainment are based on the severity of the nonattainment classification of the area. The following section provides a summary of the federal, state, and local air quality rules and regulations that apply to the project alternatives Federal Regulations Clean Air Act Section 176(c) of the CAA, as articulated in the USEPA General Conformity Rule, states that a federal agency cannot issue a permit or support an activity unless the agency determines that it will conform to the most recent USEPA-approved SIP. This means that projects using federal funds or requiring federal approval in nonattainment or maintenance areas must not: 1) cause or contribute to any new violation of an NAAQS; 2) increase the frequency or severity of any existing violation; or 3) delay the timely attainment of any standard, interim emission reduction, or other milestone. Emissions of attainment pollutants are exempt from the conformity rule. Actions would conform to a SIP if their annual emissions remain less than applicable de minimis thresholds. Formal conformity determinations are required for any actions that exceed these thresholds. Based on the present attainment status of the SDAB, the proposed action would conform to the most recent USEPA-approved SIP if its annual construction or operational emissions do not exceed 100 tons of VOCs, CO, or NO x. The conformity evaluation for Alternative 1 is summarized in Section and presented in complete form in Appendix B.1 of this EA. Executive Orders The following Executive Orders regulate air quality. Executive Order 12088, Federal Compliance with Pollution Control Standards, requires federal agencies to comply with applicable pollution control standards and cooperate with USEPA, state, and local regulatory agencies. Executive Order 13423, Strengthening Federal Environmental, Energy, and Transportation Management, sets goals to reduce GHG emissions by reducing energy intensity by 3 percent annually or 30 percent by State Regulations The California CAA, as amended, outlines a program to attain the CAAQS for O 3, NO 2, sulfur dioxide (SO 2), and CO by the earliest practical date. Since the CAAQS are more stringent than the NAAQS, attainment of the CAAQS will require more emission reductions than what will be required to show attainment of the NAAQS. The ARB delegates the authority to regulate stationary source emissions to local air quality management districts. The ARB requires these agencies to develop their own strategies for achieving compliance with the NAAQS and CAAQS, but maintains regulatory authority over those strategies Area Reservoir Repair, MCB Camp Pendleton EA

41 3 Affected Environment and Environmental Consequences Local Regulations The SDCAPCD is the local agency responsible for enforcement of air quality regulations in the project region. The SDCAPCD has developed air quality plans to reduce emissions to a level that will bring the SDAB into attainment of the ambient air quality standards (SDCAPCD 2013a). Control measures for stationary sources proposed in the air quality plans and adopted by the SDCAPCD are incorporated into the SDCAPCD Rules and Regulations (SDCAPCD 2013b). SDCAPCD Rule 1501 implements the USEPA General Conformity Rule. If proposed emissions of VOCs, CO, or NO x increase by more than 100 tons per year within the SDAB, the USMC must demonstrate project conformity under one of the methods prescribed by SDCAPCD Rule Environmental Consequences For the purposes of this air quality analysis and for air pollutants designated as in nonattainment or maintenance of an NAAQS and, therefore, subject to general conformity requirements, if the total emissions estimated for a project alternative exceed a conformity de minimis threshold that triggers a conformity determination in the SDAB project region (100 tons per year of VOCs, CO, or NO x), further analysis is conducted to determine whether impacts were significant. In such cases, if emissions conform to the approved SIP, then proposed impacts would be less than significant. In the case of a criteria pollutant for which the SDAB is in attainment of its NAAQS (SO 2, PM 10, and PM 2.5), the analysis uses the USEPA Prevention of Significant Deterioration (PSD) threshold for new major sources of 250 tons per year as an indicator of significance of proposed air quality impacts. Although the PSD permitting program is not applicable to mobile sources, PSD thresholds are used as criteria for measuring air quality impacts under NEPA Alternative 1: Proposed Action Air quality impacts from construction of Alternative 1 would occur from: 1) combustive emissions due to the use of fossil fuel-powered equipment; and 2) fugitive dust emissions (PM 10 and PM 2.5) during site clearing and the operation of equipment on exposed soils. Construction activity data associated with Alternative 1 were used to estimate project combustive and fugitive dust emissions. Factors needed to derive proposed construction source emission rates were obtained from the Compilation of Air Pollution Emission Factors, AP-42, Volume I (USEPA 1995), the EMFAC2011 Model for on-road vehicles (ARB 2013b), and the In-Use Off-Road Equipment 2011 Inventory Model for off-road construction equipment (ARB 2013c). Appendix B.1 includes data and assumptions used to calculate proposed construction emissions. Construction would occur over a period of 2 months and the analysis assumed that it would occur within one calendar year. Table summarizes the annual and total emissions associated with construction of Alternative 1. These data show that annual VOC, CO, and NO x emissions generated by this alternative are well below the SDAB conformity de minimis levels. The SDAB is in attainment for SO 2, PM 10, and PM 2.5 and proposed construction emissions of these criteria pollutants are only a small fraction of the PSD threshold of 250 tons per year. As a result, construction of Alternative 1 would produce less than significant air quality impacts and no mitigation is required. Implementation of the SCMs from the BO in Appendix C and standard fugitive dust and construction equipment emission control special conservation measures would minimize emissions from proposed construction. Proposed construction equipment would emit TACs that could potentially impact public health. The main source of TACs would occur in the form of particulates from the combustion of diesel fuel. Due to the mobile and intermittent operation of proposed diesel-powered construction equipment over a large 51 Area Reservoir Repair, MCB Camp Pendleton 3-15 EA

42 3 Affected Environment and Environmental Consequences construction area, there would be minimal ambient impacts of TACs in a localized area. As a result, Alternative 1 would produce less than significant impacts to public health and no mitigation is required. The results of air quality analysis indicate that air pollutant emissions from Alternative 1 (Proposed Action) would not exceed their applicable conformity de minimis thresholds. Appendix B.2 of this EA includes a CAA Record of Non-Applicability documentation for Alternative 1. Table Annual and Total Emissions Due to Construction of Alternative 1 Activity VOC Total Air Pollutant Emissions (Tons) CO NOx SO2 PM10 PM2.5 CO2e Excavation & Retaining Wall Clearing and Grubbing Culvert Repairs Total Emissions (Tons/Year) (1) NEPA Significance Thresholds (2) NA Notes: CO = carbon monoxide; CO2e = CO2 equivalent; NEPA = National Environmental Policy Act; NOx = nitrogen (di)oxide; PM10 = particulate matter less than 10 microns in diameter; PM2.5 = particulate matter less than 2.5 microns in diameter; SO2 = sulfur dioxide; VOC = volatile organic compound 1. Assumes all emissions would occur within one annual period. 2. Conformity de minimis/united States Environmental Protection Agency Prevention of Significant Deterioration thresholds are 100/250 tons per year. As no significant air quality impacts would occur from Alternative 1, no mitigation is required. However, to minimize proposed emissions, the construction contractor would implement the SCMs from the BO in Appendix C and standard fugitive dust and construction equipment emission control measures, No-Action Alternative Under the No-Action Alternative, construction activities would not occur and operations would continue under current conditions. Therefore, no impacts on air quality would occur Area Reservoir Repair, MCB Camp Pendleton EA

43 4 Cumulative Impacts 4 Cumulative Impacts 4.1 Introduction The analysis of cumulative impacts (or cumulative effects) follows the objectives of NEPA and CEQ regulations (40 CFR Parts ) that provide the implementing procedures for NEPA. The CEQ regulations define cumulative impacts as: the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. (40 CFR ) The CEQ also provides guidance on cumulative impacts analysis in Considering Cumulative Effects under NEPA (CEQ 1997). Noting that environmental impacts result from a diversity of sources and processes, the CEQ guidance observes that no universally accepted framework for cumulative effects analysis exists, while noting that certain general principles have gained acceptance. One such principle provides that cumulative effects analysis should be conducted within the context of resource, ecosystem, and community thresholds levels of stress beyond which the desired condition degrades. Thus, each resource, ecosystem, and human community must be analyzed in terms of its ability to accommodate additional effects, based on its own time and space parameters. Therefore, cumulative effects analysis normally would encompass geographic boundaries beyond the immediate area of the proposed action, and a time frame including past actions and foreseeable actions, to capture these additional effects. Bounding the cumulative effects analysis is a complex undertaking, appropriately limited by practical considerations. Thus, CEQ guidelines observe, [i]t is not practical to analyze cumulative effects of an action on the universe; the list of environmental effects must focus on those that are truly meaningful. 4.2 Projects Considered in the Cumulative Analysis Identifiable effects of other past, present, and reasonably foreseeable future actions are analyzed and evaluated to the extent they may be additive to impacts of the proposed action. As part of the evaluation of cumulative impacts, a review of other projects in the vicinity of the action alternatives was conducted. Projects that were older than 5 years have been considered within the baseline of this analysis. Projects that are considered reasonably foreseeable future actions are projects that may not occur until Projects that would occur past 2020 are highly uncertain and, thus, do not meet the criteria of being reasonably foreseeable. However, resource areas for which the proposed action is not anticipated to have any direct or indirect impacts are not included, as there is no potential for cumulative impacts. 51 Area Reservoir Repair, MCB Camp Pendleton 4-1

44 4 Cumulative Impacts Table Cumulative Projects Project Name Timeframe Project Location Repair San Onofre Exchange Building Reasonably Foreseeable Building Relevant Areas of Potential Cumulative Impact Air Quality/GHGs Replace Roof Reservoirs Reasonably Foreseeable Buildings 51770, 51771, and Air Quality/GHGs Improve Beach Road Pedestrian Access Reasonably Foreseeable Beach Club Road Biological Resources, Air Quality/GHGs Improve RV Lots 1-5 Reasonably Foreseeable Beach Parking Areas Air Quality/GHGs Repair Bathrooms Reasonably Foreseeable Building Air Quality/GHGs Construct Boardwalk Reasonably Foreseeable Southwest of Building Biological Resources, Air Quality/GHGs Future Retail Site Reasonably Foreseeable South of Building Biological Resources, Air Quality/GHGs Maintenance Yard Screening Reasonably Foreseeable East of Building Biological Resources, Air Quality/GHGs Pacific Marine Credit Union Reasonably Foreseeable Building Air Quality/GHGs Transient Lodging Facility Reasonably Foreseeable South of Building Air Quality/GHGs Basewide Utilities Infrastructure Present Multiple Locations Biological Resources, Air Quality/GHGs Basewide Water Infrastructure Present/ Reasonably Foreseeable Multiple Locations Biological Resources, Air Quality/GHGs San Onofre Nuclear Generating Station Decommissioning Reasonably Foreseeable San Onofre Nuclear Generating Station Biological Resources, Air Quality/GHGs Large-Scale Exercise Reasonably Foreseeable Multiple Locations Biological Resources, Air Quality/GHGs Joint Logistics Over the Shore Reasonably Foreseeable Multiple Locations Biological Resources, Air Quality/GHGs California State Park Waterline Installation Present San Onofre State Park Mesa Air Quality/GHGs San Onofre Mitigation Area Vernal Pool Restoration Present San Onofre State Park Mesa Air Quality/GHGs Range and Training Areas Maintenance Activities Reasonably Foreseeable Multiple Locations Biological Resources, Air Quality/GHGs Note: GHG = Greenhouse gases Area Reservoir Repair, MCB Camp Pendleton EA

45 4 Cumulative Impacts 4.3 Methodology Geographic Scope of the Cumulative Effects Boundaries or the Region of Influence (ROI) for analyses of cumulative impacts in this EA vary. Delineation of the ROI is based upon proximity to the proposed action and the resources affected. For example, for air quality the potentially affected air basin is the appropriate boundary for assessment of cumulative impacts from releases of pollutants into the atmosphere. The cumulative impacts analysis focuses on projects that directly overlap with the proposed action (i.e., occur in similar locations and potentially impact similar resources) Time Frame of the Cumulative Effects Analysis The projects listed in Table consist of construction, repair, demolition, and training projects. Facility improvements would be permanent once constructed, but they are consistent with existing development, and would not result in new or different long-term operational impacts. Therefore, the time frame for the cumulative impacts analysis is limited to the duration of construction for those projects. The San Onofre Nuclear Generating Station Decommissioning project, while reasonably foreseeable, would not begin ground-disturbing activities within the next 5 years. The training projects would be consistent with activities currently occurring at MCB Camp Pendleton. The projects included in the cumulative impacts analysis have been identified as needs by the installation, but have not been programmed for a specific time frame. To be conservative, the analysis assumes that all projects and impacts would be constructed concurrent with the proposed action. 4.4 Cumulative Impact Analysis This section addresses the potential for cumulative impacts from the proposed action, in combination with the past, present, and reasonably foreseeable actions listed above. Resource areas with no potential for direct or indirect impacts from the proposed action also have no potential for cumulative impacts, and therefore are not considered further in this analysis. The resource areas retained for cumulative impact analysis are air quality and GHGs and biological resources Air Quality and Greenhouse Gases Given the temporary nature of the proposed action, the ROI of this analysis was established to include the residential, recreational, and commercial developments within the 51 Area of MCB Camp Pendleton, around San Onofre Creek and San Onofre State Beach. Potential impacts to air quality from the actions listed in Table are similar to those evaluated in Section for Alternative 1. Specifically, ground disturbance, demolition, and renovation could generate fugitive dust, and operation of fossil fuel-powered construction equipment would produce various criteria pollutants. It is expected that these actions would include measures similar to those adopted into Alternative 1 (Section ), such as dust control and proper equipment maintenance. With incorporation of these measures, cumulative impacts are not anticipated to be significant. The Large-Scale Exercise, and the Joint Logistics Over the Shore training projects, are consistent with activities currently occurring on MCB Camp Pendleton and would adhere to all necessary air permitting requirements. 51 Area Reservoir Repair, MCB Camp Pendleton 4-3 EA

46 4 Cumulative Impacts In addition, although GHG effects are inherently cumulative and global in nature, the proposed action and the other foreseeable actions are most likely de minimis in nature. In the context of global GHG emissions, the amount contributed by the actions, individually or in combination, is expected to be far below any threshold of concern for climate change. Therefore, significant cumulative impacts are not expected Biological Resources The ROI for biological resources is the project site and immediately surrounding areas. This ROI encompasses the combined effects of the past, present, and reasonably foreseeable projects on special-status plant and animal species on a regional scale. Reasonably foreseeable future projects that have not yet undergone environmental reviews under NEPA and ESA Section 7 would ensure that biological resource impacts are avoided, minimized, and/or compensated to the extent practicable. Table Summary of Cumulative Projects and Impacts to Coastal California Gnatcatcher and Pacific Pocket Mouse Species Project Effect Improve Beach Road Pedestrian Access Construct Boardwalk Future Retail Site Coastal California Gnatcatcher (CAGN) Maintenance Yard Screening Basewide Utilities Instructure San Onofre Nuclear Generating Station Decommissioning Large-Scale Exercise Joint Logistics Over the Shore No effects Pacific Pocket Mouse (PPM) Maintenance Yard Screening Basewide Utilities Instructure Large-Scale Exercise Joint Logistics Over the Shore No effects Area Reservoir Repair, MCB Camp Pendleton EA

47 4 Cumulative Impacts 4.5 Cumulative Effects Biological Resources All federal activities within MCB Camp Pendleton potentially affecting federally protected species and habitats would be subject to Endangered Species Act (ESA) Section 7 consultation. Under the ESA, these future federal activities are not considered in this cumulative effects analysis. Similarly, U.S. Forest Service lands occur east of MCB Camp Pendleton, upstream within a watershed that extends onto the Base. As any future activity within these federal lands that would potentially affect a federally protected species and its habitat would also be subject to ESA Section 7 consultation, these activities are not considered in this cumulative effects analysis. Cumulative effects to be considered under the ESA are those effects of future nonfederal (state, local agency, or private) activities on federally listed species that are reasonably certain to occur within the area affected by the Proposed Action. For this Environmental Assessment, this is limited to nonfederal activities implemented adjacent to MCB Camp Pendleton that may indirectly affect the Action Area. Adjacent nonfederal activities are subject to individual project reviews under the California Environmental Quality Act and, as relevant, federal permitting actions (e.g., CWA). Moreover, the adjacent nonfederal lands are under the jurisdiction of entities that participate in regional planning efforts that include state-mandated Natural Communities Conservation Plans. These approved plans serve as multiple-species Habitat Conservation Plans pursuant to Section 10(a)(1)(B) of the ESA. As such, any potential cumulative effect from neighboring activities on nonfederal lands on federally protected species and their habitats is expected to have a federal nexus and therefore be subject to reasonable and prudent measures, terms, conditions, and conservation recommendations pursuant to enforcement of the federal ESA by USFWS. Therefore, by definition, no current or foreseeable future action within the region is anticipated to result in cumulative effects to federally listed plant or animal species. 51 Area Reservoir Repair, MCB Camp Pendleton 4-5 EA

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49 5 Other NEPA Considerations 5 Other NEPA Considerations 5.1 Possible Conflicts Between the Action and the Objectives of Federal, Regional, State, and Local Plans, Policies, and Controls An assessment of the Proposed Action indicates that the action alternatives would not conflict with the objectives of other regulations. 5.2 Irreversible and Irretrievable Commitment of Resources Implementation of the Proposed Action would involve human labor; the consumption of fuel, oil, and lubricants for construction vehicles; and loss of natural resources (temporary). Implementing the Proposed Action would not result in significant irreversible or irretrievable commitment of resources 5.3 Relationship Between Short Term Environmental Impacts and Long Term Productivity In the short-term, effects to the human environment with implementation of the Proposed Action would primarily relate to the construction activity itself. Biological resources, air quality, and noise would be impacted in the short-term. The construction of the facility and operation would not significantly impact the long-term natural resource productivity of the area. The Proposed Action would not result in any impacts that would significantly reduce environmental productivity or permanently narrow the range of beneficial uses of the environment. 5.4 Any Probable Adverse Environmental Effects that Cannot be Avoided and are Not Amenable to Mitigation This EA has determined that the alternatives considered would not result in any significant impacts. With the implementation of special conservation measures as presented in the USFWS BO in Appendix C, no resource area would be subject to significant adverse impacts that would not be amenable to mitigation. 51 Area Reservoir Repair, MCB Camp Pendleton 5-1 EA

50

51 6 List of Preparers Marine Corps MCB Camp Pendleton Camp Pendleton, California Kristin Thomas, Project Manager 6 List of Preparers 51 Area Reservoir Repair, MCB Camp Pendleton 6-1 EA

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53 7 Persons and Agencies Contacted or Consulted 7 Persons and Agencies Contacted or Consulted Will Miller, USFWS, Carlsbad, CA Jonathon Snyder, USFWS, Carlsbad, CA 51 Area Reservoir Repair, MCB Camp Pendleton 7-1 EA

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55 8 References 8 References Anderson, E.R Habitat preferences of the California gnatcatcher in San Diego County. Master's thesis, San Diego State University, CA. Beyers, J.L. and W.O Wirtz II Proceedings-Fire Effects on Rare and Endangered Species and Habitats Conference, Nov , Bontrager, D.R Habitat requirements, home range, and breeding biology of the California gnatcatcher (Polioptila californica) in south Orange County, California. Prepared for Santa Margarita Co., Rancho Santa Margarita, CA. Braden, G. and S. Powell DRAFT REPORT. Breeding habitat used by Polioptila californica in western Riverside County. Prepared for The Metropolitan Water District. Prepared by the United States Fish and Wildlife Service, Carlsbad, CA. Braden, G.T., R.L. McKernan, and S.M. Powell Association of within-territory vegetation characteristics and fitness components of California Gnatcatchers. Auk 114: Brehme, C., and R. Fisher Survey Results for the Pacific Pocket Mouse: North and South San Mateo, Marine Corps Base, Camp Pendleton; with additional analyses to inform long-term monitoring design. Prepared for MCB Camp Pendleton. Prepared by U.S. Geological Survey. Brehme, C., and R. Fisher USGS Comments with regard to impacts to the Pacific Pocket Mouse. Prepared for U.S. Fish and Wildlife Service and MCB Camp Pendleton. Prepared by U.S. Geological Survey. California Air Resources Board (ARB). 2013a. Ambient Air quality Standards. Available at: Accessed: 03 May b. Mobile Source Emission Inventory -- Current Methods and Data - EMFAC Updated: January Available at: Accessed on: 06 May c. Mobile Source Emission Inventory -- Categories - Off-Road Diesel Equipment: In-Use Off-Road Equipment (Construction, Industrial, Ground Support and Oil Drilling). Available at: Accessed on: 06 May CDFW California Department of Fish and Wildlife. California Natural Diversity Database. Plants and Animals. Online at: Accessed on 27 March California Energy Commission Our Changing Climate 2012 Vulnerability & Adaptation to the Increasing Risks from Climate Change in California: A Summary Report on the third Assessment from the California Climate Center. Publication number CEC Available at: Accessed on: 03 May Area Reservoir Repair, MCB Camp Pendleton 8-1 EA

56 8 References Council on Environmental Quality (CEQ) Draft Guidance for Greenhouse Gas Emissions and Climate Change Impacts. Available at: Accessed: 21 February ERCE Phase 1: Amber Ridge California Gnatcatcher Study. Prepared for Weingarten, Siegel, Fletcher Group, Inc., San Diego, CA. Holland, R.F Preliminary Descriptions of the Terrestrial Natural Communities of California. State of California Resources Agency, Department of Fish and Game. October. Intergovernmental Panel on Climate Change Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II, and III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pacauri, R.K., and Reisinger, A]. IPCC, Geneva, Switzerland, 104 pp. MCBCP Integrated Natural Resource Management Plan Marine Corps Base and Marine Corps Air Station Camp Pendleton. MCB Camp Pendleton, Environmental Security. Marine Corps Expeditionary Energy Office Headquarters USMC Marine Corps Expeditionary Energy Strategy and Implementation Plan. Naval Facilities Engineering Command (NAVFAC) Southwest Renewable Energy and Distributed Generation Projects. San Diego County Air Pollution Control District (SDCAPCD). 2013a. Air Quality Planning. Available at: Accessed on: 03 May b. Rules and Regulations. Available at: Accessed on 06 May USDA Natural Resources Conservation Service, United States Department of Agriculture. Soil Survey Manual. Prepared by United States Department of Agriculture. U. S. Government Printing Office, Washington, D. C. USDA Natural Resources Conservation Service, United States Department of Agriculture. Official Soil Series Descriptions. Online at: Accessed on 28 March United States Environmental Protection Agency (USEPA) National Greenhouse Gas Emissions Data - Inventory of U.S. Greenhouse Gas Emissions and Sinks: (April 2013). Available at: Accessed on: 15 May Compilation of Air Pollutant Emission Factors, AP-42, Volume I. Section , Heavy Construction Operations. Available at: Accessed on: 03 May USFWS Biological Opinion ( F-02). Programmatic Activities and Conservation Plans in Riparian and Estuarine/Beach Ecosystems on Marine Corps Base Camp Pendleton. Prepared by Carlsbad Fish and Wildlife Office. 30 October Area Reservoir Repair, MCB Camp Pendleton EA

57 8 References USFWS Biological Opinion (FWS-MCBCP-15B F0796). Formal Section 7 Consultation on the 51 Area Reservoir Repair project, Marine Corps Base Camp Pendleton, San Diego County, California. Prepared by Carlsbad Fish and Wildlife Office. 17 January. United States Global Change Research Program Global Climate Change Impacts in the United States. Thomas, R. Karl, Jerry M. Melillo, and Thomas C. Peterson (eds.). Cambridge University Press. 51 Area Reservoir Repair, MCB Camp Pendleton 8-3 EA

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60 Appendix A Public Involvement

61 Appendix A Public Involvement Public Involvement The United States Marine Corps (USMC) published a Notice of Intent to Prepare in two local newspapers. The USMC will announce the completion of the Final Environmental Assessment (EA) by publishing a Notice of Availability in the newspapers. The Final EA will be available by contacting Environmental Security (ES), Camp Pendleton, CA , and telephone (760)

62 Appendix B Record of Non-Applicability and Air Quality Technical Data

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70 A B C D E F G Table B.1-1. Emission Source Data for the Area 51 Reservoir Repair Project at MCB Camp Pendleton - Alternative 1 Hp Average Daily Number Hours/ Total Total Activity/Equipment Type Rating Load Factor (1) Active Day Work Days Hp-Hrs Off-Road Equipment Excavation & Retaining Wall Backhoe/Excavator ,782 Bobcat ,894 Crane ,176 Compactor Generator ,512 Air Compressor ,680 Fugitive Dust (2) NA NA 0.25 NA 20 5 Clearing and Grubbing Backhoe/Excavator ,837 Bobcat ,421 Crane ,566 Generator ,134 Air Compressor ,260 Fugitive Dust (2) NA NA 0.5 NA Culvert Repairs Backhoe/Excavator ,946 Bobcat Crane Compactor Generator Air Compressor Fugitive Dust (2) NA NA 0.25 NA 20 5 Heavy Duty On-Road Trucks for Material Deliveries Total CY per Total Miles per Total Total Activity/Equipment Type Cubic Yards Truck Trip Trips (3) Round Trip Miles Work Days Excavation & Retaining Wall Dump Truck Concrete Pumper Truck ,896 5 Clearing and Grubbing Dump Truck , Culvert Repairs Dump Truck Concrete Pumper Truck Notes: (1) From ARB In-Use Off-Road Equipment Inventory Model, where applicable (ARB 2011). (2) Number Active is the average daily acres disturbed on a continuous basis and Total Hp-Hrs are total acre-days for the entire activity. (3) Equal to Total Cubic Yards divided by CY per Truck Trip. Attachment (1)

71 I J K L M N O P Q R Table B.1-2. Air Emission Factors for Sources Associated with the Area 51 Reservoir Repair Project at MCB Camp Pendleton. Fuel Emission Factors (Grams/Horsepower-Hour) Project Year/Source Type Type VOC CO NOx SO2 PM10 PM2.5 CO2 Reference Year 2014 Off-Road Equipment Hp D (1) Off-Road Equipment Hp D (1) Off-Road Equipment Hp D (1) Off-Road Equipment Hp D (1) Off-Road Equipment Hp D (1) On-road Truck - Idle (Gms/Hr) D ,472 (2) On-road Truck - 5 mph (Gms/Mi) D ,040 (3) On-road Truck - 25 mph (Gms/Mi) D ,017 (3) On-road Truck - 55 mph (Gms/Mi) D ,590 (3) On-Road Trucks - Composite (Gms/Mi) D ,841 (4) Fugitive Dust (Lbs/acre-day) (5) Notes: (1) Emissions factors developed for calendar year 2014 off-road composite equipment fleet with the use of the ARB In-Use Off-Road Equipment Inventory Model (ARB 2013), except CO emissions factors obtained from the Urbemis 2007 model and based on tractors/loaders/backhoes (Jones&Stokes Ass. 2007). (2) Idling emission factors developed from EMFAC2007 (ARB 2006). Units in grams/hour. (3) Generated by the EMFAC2011 model for diesel truck fleet (T7 tractor construction) in San Diego County, project year 2014 (ARB 2013). Assumes annual average temperatures. Units in grams/mile. (4) Composite factors based on a round trip of 5% at 5 mph, 30% at 25 mph, and 65% at 55 mph. Units in grams/mile. Although not shown in these calculations, emissions from 5 minutes of idling mode included for each truck round trip. (5) Units in lbs/acre-day from section of AP-42 (USEPA 1995). Emissions reduced by 50% from uncontrolled levels to simulate implementation of best management practices (BMPs) for fugitive dust control. Attachment (1)

72 T U V W X Y Z AA Table B.1-3. Annual Emissions associated with the Area 51 Reservoir Repair Project at MCB Camp Pendleton - Alternative 1 Total Emissions (Tons) Construction Activity/Equipment Type VOC CO NOx SO2 PM10 PM2.5 CO2 Excavation & Retaining Wall Backhoe/Excavator Bobcat Crane Compactor Generator Air Compressor Fugitive Dust Dump Truck Concrete Pumper Truck Subtotal Clearing and Grubbing Backhoe/Excavator Bobcat Crane Generator Air Compressor Fugitive Dust Dump Truck Subtotal Culvert Repairs Backhoe/Excavator Bobcat Crane Compactor Generator Air Compressor Fugitive Dust Dump Truck Concrete Pumper Truck Subtotal Total Emissions Attachment (1)

73 Table B.1-4. Summary of Annual Emissions for the Area 51 Reservoir Repair Project at MCB Camp Pendleton - Alternative 1 Tons Construction Activity VOC CO NOx SOx PM 10 PM 2.5 CO 2 e Excavation & Retaining Wall Clearing and Grubbing Culvert Repairs Total Tons Metric Tons US 2011 Annual CO2 Inventory - Metric Tons 5,797,300,000 Project % of US Inventory Attachment (1)

74 Appendix C USFWS Biological Opinion

75 In Reply Refer To: FWS-MCBCP-15B F0796 United States Department of the Interior Bart Battista Head, Environmental Planning Environmental Security MCIWEST-Marine Corps Base Camp Pendleton P.O. Box Camp Pendleton, California FISH AND WILDLIFE SERVICE Ecological Services Carlsbad Fish and Wildlife Office 2177 Salk Avenue, Suite 250 Carlsbad, California January 17, 2017 Sent by Subject: Formal Section 7 Consultation on the 51 Area Reservoir Repair at Marine Corps Base Camp Pendleton, San Diego County, California Dear Mr. Battista: This document transmits the U.S. Fish and Wildlife Service s (Service) biological opinion on the 51 Area Reservoir repair project at Marine Corps Base Camp Pendleton (MCBCP) and its effects on the federally endangered Pacific pocket mouse (Perognathus longimembris pacificus; PPM) and threatened coastal California gnatcatcher (Polioptila californica californica; gnatcatcher), in accordance with section 7 of the Endangered Species Act of 1973 (Act), as amended (16 U.S.C et seq.). Formal consultation was initiated on June 23, This biological opinion is based on information provided in the: 1) Biological Assessment for the 51 Area Reservoir Repair at Marine Corps Base Camp Pendleton [May 15, 2014 (BA)]; 2) Biological Assessment Supplemental Information for the 51 Area Reservoir Repair at Marine Corps Base Camp Pendleton [June 23, 2015 (Supplemental BA)]; and 3) correspondence, notes, maps, and other information compiled during discussions with the U.S. Marine Corps (Marine Corps) on the subject project. The complete project file addressing this consultation is maintained at the Carlsbad Fish and Wildlife Office (CFWO). CONSULTATION HISTORY On May 15, 2014, we received your request for formal section 7 consultation on the proposed action. On June 27, 2014, we responded to your request and identified additional information necessary to complete the biological opinion for this action. On July 2, 2014, we toured the reservoir site with the Marine Corps. During this site visit, we discussed the need for restoration of PPM habitat in the project vicinity that was impacted by past emergency reservoir repairs and other recent grading incidents implemented without prior consultation with the Service. We requested that the Marine Corps include such restoration activities as part of the proposed action for this consultation.

76 Mr. Bart Battista (FWS-MCBCP-15B F0796) 2 Between July of 2014 and December of 2015, the Marine Corps modified the project, gathered information to respond to our requests and recommendations, and worked with us to develop conservation measures to reduce impacts to PPM. On June 23, 2015, the Marine Corps submitted a Supplemental BA, which included four components of the proposed action: 1) repair and restore damage caused to facilities and the environment from the accidental release of water from Reservoir 51772; 2) repair impacts to PPM habitat in the 51 Area of MCBCP; 3) thin and manage dense coastal sage scrub (CSS) vegetation in the 51 Area; and 4) maintain roads throughout Area 51. On December 30, 2015, the Marine Corps withdrew the proposal to maintain roads throughout Area 51 as depicted in Figure S-4 of the Supplemental BA. On September 13, 2016, we provided a draft version of this biological opinion to the Marine Corps for review and received comments back from the Marine Corps on November 18, DESCRIPTION OF THE PROPOSED ACTION BIOLOGICAL OPINION The Proposed Action is to repair and restore damage caused to facilities and the environment from the accidental release of water from Reservoir in April of 2012; to repair impacts to PPM habitat in the 51 Area of MCBCP from a number of grading and earth disturbing incidents implemented between 2010 and 2014; and to thin and manage dense CSS vegetation in the 51 Area of MCBCP as a conservation measure designed to enhance habitat for PPM. To address impacts from the accidental release of water from Reservoir 51772, the action includes: the repair of the Reservoir drainage line; construction of a retaining wall and backfilling earth behind it to correct and prevent future erosion; and cleaning sand, silt, and debris out of and repairing multiple sections of concrete drainage channels that are downslope from Reservoir Advance geotechnical investigations and the creation of construction staging and laydown areas are needed to implement the facility repairs. The Marine Corps also proposes to implement ongoing maintenance of the drainage channels in the future, which will involve maintaining access to the drainage channels to allow for periodic trimming of vegetation overgrowing the channels and removal of sand, silt, and debris that accumulates within the drainage channels. The combined project footprint is depicted in Figure 1 and does not include areas that will be revegetated to address past impacts to PPM habitat. Between 2010 and 2014 a number of grading and other earth disturbing incidents occurred within occupied gnatcatcher and PPM habitat in the vicinity of the proposed project without prior consultation with the Service as required by section 7 of the Act. These incidents included disking a fire road along the ridgeline above San Onofre housing, creation of an access and staging area for Reservoir valve repairs, creation of an access road for emergency repairs to the Reservoir drainage channels, and creation of a fire break immediately adjoining the Basilone Road housing (Figure 2). This consultation does not address impacts to PPM and gnatcatchers from the past grading and other earth disturbing incidents implemented between 2010 and However, these past impacts are

77 Mr. Bart Battista (FWS-MCBCP-15B F0796) 3 reflected in the current baseline condition and overall status of PPM and gnatcatcher on MCBCP and rangewide. Permanent impacts from construction activities identified as part of the proposed action will occur primarily within areas that were disturbed during the 2010 and 2014 incidents. In addition, this consultation addresses potential effects to gnatcatchers and PPM from proposed restoration of areas temporarily impacted by construction activities and enhancement of habitat for PPM that will be implemented to offset past impacts in the action area. The following information includes specific details associated with project construction, maintenance, and habitat restoration and enhancement. Geotechnical Investigation During design of the 51 Area reservoir repair project, geotechnical investigation may be necessary. If geotechnical investigation is conducted, it will likely occur 1 to 6 months prior to construction and will consist of one geotechnical boring within the erosion repair footprint depicted in Figure 2-3 of the BA. Vegetation removal within the investigation footprint may be needed to accommodate the activity. The investigation will be performed using a truck-mounted drill rig or a modified investigative vehicle and will take about 1 day. Construction Construction will occur over a 4-month period and will require up to 10 workers per day. Construction will involve excavation and installation of the retaining wall(s); clearing/grubbing vegetation; removing sand, silt, and debris; backfilling behind the retaining wall to rebuild the drain culvert that was damaged; repairing a concrete culvert in three sections; replacing drain pipe; and revegetating the area around the outer perimeter of the storm culverts. The following construction equipment is anticipated to be used: dump trucks, concrete pumper trucks, excavators, bobcats, pickup trucks, crane, compactors, generators, air compressors, and miscellaneous smaller equipment (e.g., pumps). Construction staging and laydown areas will be located within the project footprint depicted in Figures 2-1, 2-2, and 2-3 of the BA. The top construction laydown area is located east of Reservoirs and and includes the road to the valve vault (the top access road). A crane will be deployed along the top access road to remove debris and supply the retaining wall supplies to the site. The bottom access road, which was created for emergency repairs in October 2012, will be used to access the site and to serve as a laydown area for the removal of debris and repair of the concrete culverts. A 10-foot wide portion of the bottom access road, which currently ranges from 11 to 30 feet wide, will remain to provide permanent access to the site by a truck/skip-loader/excavator for maintenance. These vehicles will periodically need to access the site to remove debris generated from runoff into the main drain channel. The remainder of the bottom access road will be used during project construction for parking construction vehicles and will be re-vegetated to return it to suitable habitat for PPM following project completion. Retaining Wall Two alternative approaches for retaining wall installation may be used for this project: construction of a single bin wall or construction of two bin walls. The single wall construction method would

78 Mr. Bart Battista (FWS-MCBCP-15B F0796) 4 involve construction of a single wall about 40 to 50 feet long and 11 to 22 feet high. The two wall approach would involve construction of two parallel walls 7.5 to 14 feet high, with one wall about 40 to 50 feet in length and the second wall about 30 feet in length. The bin wall(s) are thin metal walls installed in about 10-foot wide sections and back-filled with granular pervious material or soil. To construct the bin wall(s), dirt and debris will be excavated from an area of about 4,172 square feet. Backfill behind the wall(s) will be placed in 4-8 inch layers that are compacted to 95 percent. A drain line will be installed at the top of the wall(s), and a perforated pipe drain surrounded by pervious backfill will be placed below the wall. The approximate fill required for construction of the bin wall(s) is 800 cubic yards. The soil above the wall will be restored and planted with native vegetation. Any un-vegetated area on a slope greater than 10 percent will require hydro-mulching and jute netting with straw wattles, which will be removed within 5 years. The estimated construction time for installing the retaining wall is 45 to 60 days. Drainage Channels Channels 1 and 2, Eastern Channel. Sand, silt, and debris will be removed from the 4-foot wide by 1.5-foot deep drainage channels by hand or with a bobcat. Clean-out activities, including use of a bobcat, will be restricted to the width of the channels. Access to these channels will be from the proposed laydown area at the top of the site adjacent to the reservoirs. Channel 3. Vegetation, sand, silt, and debris will be removed from the 4-foot wide by 1.5-foot deep drainage channel. Access to this channel will be by foot, and the vegetation will be removed by hand or with a crane located above the channel. Channel 4. Vegetation, sand, silt, and debris will be removed from the 4-foot wide by 1.5-foot deep drainage channel. An approximately 30-foot long section of this damaged drainage channel will be repaired to connect it back to the main drainage channel. Access to this channel will be by foot, and vegetation and debris will be removed by hand or with a crane located above the channel. Main Channel. Sand, silt, debris, and vegetation will be removed from within the channel and 2 feet on either side of the channel; two 50-foot sections of the drainage channel will be repaired; and the drain/overflow line from Reservoir to the main channel will be repaired. Access to the lower portion of the main channel will be from the bottom access road. Trench plates will be used to cover the main channel and allow access to the erosion site. To connect the drain/overflow line to the main channel, a 12-inch high density polyethylene pipe will be connected to the existing corrugated metal pipe through a headwall. Maintenance of Drainage Channels The drainage channels referenced above will be maintained on a yearly basis to prevent drainage problems arising from water releases from the main reservoirs. Access to the drainage channels and maintenance activities will be implemented as follows: Channels 1 and 2, Eastern Channel. Maintenance will include removing sand, silt, and debris from the channels and trimming of any vegetation growth over the channels. Access to the site will be from the top of the site adjacent to the reservoir. A truck/bobcat will be located at the top of the

79 Mr. Bart Battista (FWS-MCBCP-15B F0796) 5 site in the proposed construction laydown area. Mechanized equipment will not be deployed within the channels. Channels 3 and 4. Maintenance will include removing sand, silt, and debris from the channels and trimming of any vegetation growth over the channels. Access to the site will be by foot, with no mechanized equipment in the channel. To assist with vegetation removal, a crane will be located above the channel within the laydown area. Main Channel. Maintenance will include removing sand, silt, and debris from the channels and trimming of any vegetation growth over the channels. Access to the lower portion of the main channel will be from the permanent access road identified in Figure 2-1 of the BA. A bobcat/truck will have access to the manhole location to remove any large debris collected at the bottom of the channels. Access to the remainder of the main channel to trim vegetation will be by foot, with no mechanized equipment in the remainder of the channel. Restoration A total of 1.18 acres of PPM-occupied habitat (Supplemental BA, Table S-1) impacted by the proposed project and by past activities will be restored to 5-25 percent vegetative cover. Enhancement The Marine Corps will enhance acres of habitat adjacent to current PPM-occupied areas to offset permanent and temporary loss of PPM habitat from construction and other past impacts between 2010 and 2014 (See Conservation Measure 15 below). Conservation Measures Implementation of the Proposed Action including construction, maintenance, and restoration and enhancement of habitat will incorporate the Conservation Measures (CMs) below to avoid or minimize any potential effects to listed species within the project action area. These Conservation Measures will be implemented in association with those activities named in the BA and Supplemental BA. General Conservation Measures CM 1. CM 2. All activities will take place within the footprints defined in the BA and Supplemental BA. Construction and restoration and enhancement site boundaries will be clearly delineated by flagging, stakes, survey lath, or snow fencing, as practical. Prior to project initiation, the design contractor will provide the 100 percent final project design footprint on aerial overlays and geographic information system (GIS) shapefiles, including the project footprint and amount/type of vegetation impacted (including both temporary and permanent), to MCBCP Environmental Security (MCBCP ES), who will in turn submit to the CFWO. Construction may not commence until review and approval has been granted by MCBCP ES. Any work that is proposed outside those construction footprints will be subject to review by MCBCP ES to

80 Mr. Bart Battista (FWS-MCBCP-15B F0796) 6 determine if potential impacts will occur to environmental resources and further environmental documentation will be required. Prior to the project being implemented, MCBCP ES will consult with the CFWO regarding any changes to the project that may affect federally listed species in a manner not addressed by this consultation. CM 3. CM 4. CM 5. CM 6. CM 7. CM 8. Contractors for construction, restoration, and enhancement and associated MCBCP departments conducting maintenance will be provided with digital files and hardcopy maps showing the project limits that were used for the environmental analyses in the BA and this biological opinion and will be informed that activities must be confined within those limits. Digital files and hardcopy maps will also include the distribution of federally listed species and sensitive habitats. Heavy equipment and staging areas will be restricted to existing roads and disturbed areas (see Figure 2-1 of the BA) and will be delineated on the grading plans. Vehicle operation and laydown areas will be delineated by staking and flagging between stakes to prevent habitat impacts outside of these areas. Construction, maintenance, restoration and enhancement will not be performed between dusk and dawn. To control the spread of weeds that may degrade native plant communities on MCBCP, all equipment and vehicles will be thoroughly power-washed before entering MCBCP. All project biologist(s) 1 will be told to identify and report any new weed invasions to MCBCP ES. In conjunction with final design and as required for construction, a Stormwater Pollution Prevention Plan (SWPPP) will be prepared for the project and submitted to the Regional Water Quality Control Board (RWQCB). The SWPPP will incorporate Best Management Practices (BMPs) for erosion and sedimentation controls, including techniques to diffuse and slow the velocity of storm water runoff. All construction activities with the potential to impact water quality due to runoff from the site will be conducted in accordance with SWPPP requirements. The SWPPP will be designed to avoid potential impacts to listed species and their habitat. In conjunction with the SWPPP, construction-related dust will be minimized by reducing vehicle speeds and traffic in newly cleared areas and covering or lightly spraying exposed soil piles with water when weather conditions warrant. Concrete 1 This project will be implemented over 5 years and may require the expertise of one or more biologists with experience surveying for birds and small mammals and expertise performing CSS restoration. An avian biologist with at least 40 hours of observation of the coastal California gnatcatcher in the field will oversee avoidance and documentation of impacts to that species. A PPM biologist that has completed at least 40 small mammal trapping sessions (i.e., calendar nights), has handled at least 40 PPM individuals, has experience with small mammal husbandry, and has successfully translocated small mammals in the wild will oversee avoidance and documentation of impacts to PPM. A restoration ecologist with experience performing at least three CSS restoration projects will oversee habitat restoration and enhancement measures.

81 Mr. Bart Battista (FWS-MCBCP-15B F0796) 7 discharge will not reach surrounding water bodies or pools unless specifically authorized in a Clean Water Act (CWA) discharge permit. CM 9. CM 10. CM 11. CM 12. CM 13. Erosion and sedimentation controls will be monitored and maintained during construction and until disturbed areas are stabilized and not susceptible to further erosion, as approved by MCBCP ES. Contractors will be prohibited from bringing domestic pets to construction sites to ensure that domestic pets do not disturb or depredate wildlife in adjacent habitats. The project sites will be kept as clean as possible to avoid attracting predators and protected species. All food-related trash will be placed in sealed bins and removed from the site on a daily basis. All project-related debris will be disposed of properly and will not be discarded on site. The site will be restored to as near the original biological condition as possible once activities are completed. All vegetation clearing for construction, maintenance, restoration and enhancement will occur outside of the nesting season for avian species (February 15 to August 31), including the gnatcatcher. If nesting season avoidance is not possible, then the following additional measures will be employed: a. An avian biologist 2, approved by MCBCP ES, will conduct pre-clearing surveys for active bird nests in and within 250 feet of the area proposed for clearing for both construction and maintenance activities. Pre-clearing surveys for restoration and enhancement will be under the discretion of the avian biologist. b. For active bird nests found within the survey area, the avian biologist will use the distance to the project limits and local topography to determine if clearing activities are likely to directly damage a nest or significantly disturb nesting activities. c. Where damage or disturbance of any nest is likely, the Marine Corps will implement further measures to avoid the likelihood of nest destruction or disturbance, including temporarily halting clearing activities until nesting is completed or directing construction/maintenance 250 feet or more away from active nests if warranted. Pacific Pocket Mouse Restoration, Enhancement, and Compensation for Temporary and Permanent Impacts. CM 14. The Marine Corps will offset direct and indirect impacts to PPM occupied habitat through a combination of restoration and enhancement of habitat within or adjoining the South San Mateo PPM population. Direct impacts (both permanent and temporary) 2 The avian biologist will have experience surveying for the coastal California gnatcatcher and at least 40 hours of observation of the species in the wild.

82 Mr. Bart Battista (FWS-MCBCP-15B F0796) 8 and indirect impacts from the proposed project and past impacts at South San Mateo between 2010 and 2014 will be offset through restoration of 1.18 acres within the construction footprint; an additional acres of enhancement will be performed within the boundaries of the South San Mateo PPM Monitoring Program boundary. CM 15. The Marine Corps will develop and implement a plan to restore 0.48 acres of habitat that will be temporarily directly impacted from construction of the 51 Area reservoir repair project. The Habitat Restoration Plan will be reviewed and approved by the CFWO prior to any impacts to PPM-occupied habitat and will address the following: a. Habitat restoration will be performed in areas identified in Figure S-1 and S-2 of the Supplemental Biological Assessment that will be impacted from making repairs to the reservoir drainage system (i.e., Restoration Sites 02 and 03). The restoration plan will include quantitative performance criteria for assessing success of the restoration effort and to ensure the vegetation community targeted has the appropriate attributes to support PPM. Considerations to be included in the Restoration Plan include topsoil salvage in areas that will be subject to soil disturbance; the maintenance of friable soils preferred by PPM; planting of species, such as native grasses and forbs, that are prevalent within PPM-occupied habitat at South San Mateo; the spatial design of planting; incorporation of erosion control measures to minimize degradation of temporarily impacted habitat; and maintenance and monitoring of the site to ensure that performance criteria are met. i. Plant species used will be derived from local source populations on Camp Pendleton, south coastal Orange County, or north coastal San Diego County. The use of plant stock from outside these geographic areas must be reviewed and approved by the CFWO. Noxious weeds (as listed by the California Invasive Plant Council) may be controlled by hand weeding or herbicide application in disturbed areas as necessary to prevent their establishment. ii. Restored areas will be planted and maintained to provide PPM habitat (e.g., percent shrub cover) and not necessarily to match the surrounding vegetation cover. iii. Implementation of restoration will occur as soon as practicable following project construction. CM 16. The Marine Corps will develop and implement a plan to restore 0.70 acres and enhance acres of habitat in the vicinity of the South San Mateo PPM population. The Habitat Restoration and Enhancement plan will be reviewed and approved by the CFWO prior to any impacts to PPM- occupied habitat and will address the following: a. Habitat restoration will be performed in areas identified in Figure S-1 of the Supplemental Biological Assessment that have been subject to prior habitat

83 Mr. Bart Battista (FWS-MCBCP-15B F0796) 9 disturbances (i.e. Restoration Sites 01, 04 and 05). The restoration plan will include quantitative performance criteria for assessing success of the restoration effort and to ensure the vegetation community targeted has the appropriate attributes to support PPM. Considerations to be included in the Restoration Plan include topsoil salvage in areas that will be subject to soil disturbance; the maintenance of friable soils preferred by PPM; planting of species, such as native grasses and forbs, that are prevalent within PPM-occupied habitat at South San Mateo; the spatial design of planting; incorporation of erosion control measures to minimize degradation of temporarily impacted habitat; and maintenance and monitoring of the site to ensure that performance criteria are met. i. Plant species used will be derived from local source populations on Camp Pendleton, south coastal Orange County, or north coastal San Diego County. The use of plant stock from outside these geographic areas must be reviewed and approved by the CFWO. Noxious weeds (as listed by the California Invasive Plant Council) may be controlled by hand weeding or herbicide application in disturbed areas as necessary to prevent their establishment. ii. iii. Restored areas will be planted and maintained to provide PPM habitat (e.g., percent shrub cover) and not necessarily to match the surrounding vegetation cover. Implementation of restoration will occur as soon as practicable following project construction. b. Habitat enhancement will be performed in areas outside the construction footprint that the MCBCP PPM monitoring program suggests are unoccupied or are only lightly occupied by PPM and where vegetation manipulation is likely to have only minor or negligible short term adverse effects to the species. Habitat enhancement is intended to provide an overall long term net benefit to the South San Mateo PPM population by increasing the area of habitat suitable for PPM use in this vicinity. The Restoration and Enhancement Plan will identify the exact location of the area(s) to be enhanced and specify the timing of enhancement actions. i. For areas that will be enhanced, the plan will include quantitative performance criteria, and enhancement measures will be performed using an adaptive management framework that involves application of two or more management treatments (e.g. vegetation thinning alone and vegetation thinning with the removal of leaf litter and debris from the soil surface) and pre- and post-enhancement PPM monitoring that will provide information about the relative efficacy of the different habitat enhancement methods.

84 Mr. Bart Battista (FWS-MCBCP-15B F0796) 10 Pacific Pocket Mouse Conservation Measures - Construction CM 17. Construction activities will be initiated when PPM are active (i.e., between April 1 and August 31) so PPM can be trapped and removed from the construction footprint or otherwise are behaviorally capable of fleeing the construction area. a. Equipment and materials may be delivered to the site, specifically to the Laydown/Stockpile area as defined in Figure 2-3 of the BA at any time of year. CM 18. CM 19. CM 20. CM 21. CM 22. A PPM biologist 3 approved by MCBCP ES at least 60 days prior to initiation of project construction or 30 days in advance of the geotechnical investigation, as applicable, will monitor all phases of construction and coordinate closely with MCBCP ES, who will in turn coordinate with the CFWO, to implement the avoidance and minimization measures named in the CMs. The PPM biologist through MCBCP ES will submit to the CFWO for review and approval a detailed PPM trap and release plan prior to any impacts to PPM occupied habitat. For construction, a contractor education program will be conducted by the PPM biologist with oversight by MCBCP ES personnel. Contractor education will be conducted during all project phases and cover the potential presence of listed species (including both PPM and gnatcatcher); the requirements and boundaries of the project; the importance of complying with avoidance, minimization, and compensation measures; and problem reporting and resolution methods. The PPM biologist will monitor all construction activities to ensure compliance with compensation measures and will keep the project construction manager and MCBCP ES informed of construction activities that may threaten significant biological resources, particularly sensitive species and their habitats. Silt (exclusion) fencing will be erected around the Erosion Repair Footprint as named in Figure 2-3 of the BA prior to performance of the geotechnical investigation and construction activities. Because the geotechnical investigation may occur several months in advance of project construction and the exclusion fencing is likely to only be effective over the short term, fencing shall be re-erected around the Erosion Repair Footprint at the time of project construction. The fencing design and location will be reviewed and approved by MCBCP ES to ensure that fencing is appropriately placed and that PPM cannot dig, crawl, or hop under or over the fence; the bottom lip of the fence will be buried in the ground. Such fencing may consist of woven nylon netting approximately 3 feet in height attached to wooden stakes. All fencing material will remain in place prior to PPM trapping until the geotechnical boring is complete and 3 The PPM biologist s qualifications shall include experience performing at least 40 small mammal trapping sessions (i.e., calendar nights,) experience handling at least 40 PPM individuals, experience with small mammal husbandry, and experience performing a translocation of a small mammal species.

85 Mr. Bart Battista (FWS-MCBCP-15B F0796) 11 will then be re-erected at the time of project construction. Following construction, the exclusion fencing will be removed under the guidance of the PPM biologist. CM 23. CM 24. CM 25. CM 26. CM 27. CM 28. CM 29. Within areas not enclosed by silt fencing (e.g., laydown areas), dirt/sand piles left overnight will be covered with tarps or plastic with the edges sealed with sandbags, bricks, or 2 x 4 s to prevent wildlife from burrowing into the dirt. Holes or trenches will be covered with material such as plywood or solid metal grates with the edges sealed with sandbags, bricks, or 2 x 4 s sufficient to prevent wildlife from falling into holes or trenches. The PPM biologist will check the integrity of the fence, excavation unit covers, soil stockpile tarps, and any additional measures meant to exclude PPM each morning and evening during the PPM trapping and approximately 60-day construction phase of the project. After installing the silt fencing, but before the geotechnical investigation or construction activities are implemented, the PPM biologist will conduct trapping to remove PPM from the erosion repair footprint. Trapping of PPM will be conducted immediately preceding the geotechnical investigation or construction activities, as applicable, so as to minimize the likelihood that PPM have an opportunity to re-inhabit the disturbance footprint. Trapping will be conducted for at least 5 nights, with at least 2 consecutive nights of negative results at the end of the trapping session before the geotechnical investigation or construction begins. The soils from all construction will be stockpiled at a location determined by MCBCP ES. Topsoil (the top 12 inches of substrate) will be removed and reserved separately from soil at lower horizons. All stockpiled soils will be completely covered until they are used. The topsoil will be placed on the top of temporarily impacted PPM-occupied habitat and PPM-suitable habitat as part of the restoration effort of these locations. All PPM that are removed from the project footprint will either be donated to the San Diego Zoological Society s PPM captive breeding program and/or released into adjacent habitat, as deemed appropriate by the PPM biologist, in consultation with MCBCP ES and the CFWO. The PPM biologist will provide bi-weekly (every 2 weeks) biological monitoring reports (electronic versions only), and one final biological monitoring report, to MCBCP ES, with correspondence copies provided to the CFWO. All take of federally-listed species will be reported electronically to MCBCP ES within 24 hours of the action. The PPM biologist will have the ability to halt construction activities, if necessary, to avoid unanticipated impacts to sensitive resources. If it is necessary to halt construction activities, the project biologist will contact MCBCP ES immediately to discuss appropriate actions. As needed, MCBCP ES staff will confer with the CFWO to ensure proper implementation of species and habitat protection measures. The

86 Mr. Bart Battista (FWS-MCBCP-15B F0796) 12 PPM biologist will provide a brief written report of the incident within 24 hours of the action to MCBCP ES. Gnatcatcher Conservation Measures Construction CM 30. If construction must take place during the bird breeding season (February 15 - August 31), then an avian biologist approved by MCBCP ES will be contracted by MCBCP to ensure Endangered Species Act (ESA) and Migratory Bird Treaty Act (MBTA) compliance. a. The avian biologist must be approved by MCBCP ES 2 weeks prior to construction start. b. The avian biologist will conduct pre-construction surveys for active gnatcatcher nests in and within 250 feet of the construction footprint. c. For active gnatcatcher nests found within the survey area, the avian biologist will use the distance to the project limits and local topography to determine if construction activities are likely to directly damage a nest or significantly disturb nesting activities. d. Where damage or disturbance of any gnatcatcher nest(s) is likely, MCBCP ES will implement further measures to avoid the likelihood of nest destruction or disturbance, including directing construction to areas further away from the active nest(s), if possible. e. Where mutually agreed by MCBCP ES and the CFWO, weed-free straw bale walls (or other sound minimization devices) may be constructed along the project perimeter to block visibility and sound from adjacent construction/maintenance, thereby reducing potential disturbance to active gnatcatcher nests. Also, signage will be installed to deter people from entering the area with an active nest(s). CM 31. The avian biologist will provide an electronic report of nest survey results to MCBCP ES within 7 days of survey completion. The avian biologist will provide bi-weekly (every 2 weeks) biological monitoring reports (electronic versions only), and one final biological monitoring report, to MCBCP ES and the CFWO. All take of federally-listed species will be reported electronically to MCBCP ES within 24 hours of the action. Pacific Pocket Mouse Conservation Measures - Geotechnical Investigation CM 32. At least 30 days in advance of geotechnical investigation activities, MCBCP ES will provide, for the review and approval of the CFWO, a plan for implementing the geotechnical investigation that identifies the location of all staging and access areas, the type of vehicles/machinery that will be used to perform the investigation, the need for any vegetation clearing, and the amount and type of earth disturbance anticipated. Based on the type and extent of anticipated habitat impacts from the investigation,

87 Mr. Bart Battista (FWS-MCBCP-15B F0796) 13 impacts to PPM will be minimized by using silt fencing and advance trapping to exclude PPM from the geotechnical investigation area as described in the PPM construction CMs. Should advance trapping to minimize impacts to PPM from the geotechnical investigation be performed, the PPM biologist will prepare a report summarizing findings from the advance trapping effort. This report will address whether additional pre-project trapping prior to the construction phase will be useful for minimizing impacts to PPM given site topography. CM 33. CM 34. CM 35. CM 36. CM 37. A PPM biologist will monitor investigative activities to ensure compliance with impact minimization measures and coordinate closely with MCBCP ES, who will in turn coordinate with the CFWO, to implement the avoidance and minimization measures named in the CMs. The PPM biologist will be approved by MCBCP ES at least 30 days before investigative activities. The PPM biologist will have the requirements named in CM-18. For investigative activities, a contractor education program will be conducted by the PPM biologist with oversight by MCBCP ES personnel. It will cover the potential presence of listed species (including PPM and gnatcatcher); the requirements and boundaries of the project; the importance of complying with avoidance, minimization, and compensation measures; and problem reporting and resolution methods. PPM that are removed from the project footprint will either be donated to the San Diego Zoological Society s PPM captive breeding program and/or released into adjacent habitat, as deemed appropriate by the PPM biologist, in consultation with MCBCP ES and the CFWO. The PPM biologist will provide one brief biological monitoring report (electronic version only) to MCBCP ES for investigative activity monitoring with a correspondence copy provided to the CFWO. All take of federally-listed species will be reported electronically to MCBCP ES within 24 hours of the action. The PPM biologist will have the ability to halt geotechnical investigation activities, if necessary, to avoid unanticipated impacts to sensitive resources. If it is necessary to halt investigative activities, the PPM biologist will contact MCBCP ES immediately to discuss appropriate actions. As needed, MCBCP ES staff will confer with the CFWO to ensure the proper implementation of species and habitat protection measures. The PPM biologist will provide a brief written report of the incident within 24 hours of the action to MCBCP ES. Pacific Pocket Mouse and Gnatcatcher Conservation Measures - Maintenance of Drainage Channels CM 38. Maintenance Activities a. Yearly maintenance activities (cleaning the sand/silt, vegetation trimming) of all drainage channels (Figure 2-3 of the BA) must occur from October 16 February 28/29, which is outside the PPM breeding season. Prior to commencement of maintenance activities MCBCP ES staff will inspect the

88 Mr. Bart Battista (FWS-MCBCP-15B F0796) 14 channels and recommend measures to avoid impacts to PPM during maintenance. Access to the drainage channels will be by foot, and all vehicles and mechanized equipment will remain within the permanent crane laydown area and permanent access road shown on Figure 2-1 in the BA. b. Vegetation removal for maintenance activities that overlap with the gnatcatcher breeding season (i.e., for maintenance activities occurring between February 15 and August 31) will be overseen by an avian biologist approved by MCBCP ES or by a MCBCP ES staff member with knowledge of avian biology and experience surveying for the gnatcatcher who will be present during performance of the maintenance activities to ensure that gnatcatcher or other migratory bird nests will not be disturbed. c. No ground disturbance outside of the lined drainage channels is authorized for the removal of sand, silt, debris, and vegetation. d. Oversight by MCBCP ES will ensure that maintenance activities are limited to existing access paths and the drainage channels. Pacific Pocket Mouse Conservation Measures Restoration/Enhancement CM 39. CM 40. CM 41. CM 42. During habitat restoration and enhancement, ripping, or any other heavy ground disturbance, access to the sites will only occur from designated roads (e.g., the permanent access road shown in Figure 2-1 of the BA), and all vehicles and equipment will remain within previously disturbed areas. The PPM biologist will be responsible for overseeing project implementation to ensure compliance with all restoration and enhancement related conservation measures and for preventing unanticipated impacts to PPM. The PPM biologist will be on site during pre-project flagging, ground disturbing activities, and other project and maintenance activities with the potential to impact PPM. The PPM biologist will have the requirements named in CM 18. At least 7 days before initiation of restoration or enhancement activities, the project boundary of the restoration and enhancement areas will be clearly marked with flagging, signposts, or other markers that are easily visible but will not prevent small mammals from freely entering or leaving the enhancement area. PPM fencing will not be placed around the restoration and enhancement boundaries but, where appropriate, the PPM biologist will flag and identify trails and access routes to the habitat restoration and enhancement areas that will be used by the restoration contractor. A contractor education program will be conducted by MCBCP ES. The program will be conducted during all project phases and will cover the potential presence of listed species; the requirements and boundaries of the project; the importance of complying with avoidance and minimization measures; and problem reporting and resolution methods.

89 Mr. Bart Battista (FWS-MCBCP-15B F0796) 15 CM 43. CM 44. Any planting stock to be brought onto the project site will first be inspected by the restoration contractor and proof provided to MCBCP ES to ensure it is free of pest species that could invade natural areas, including but not limited to Argentine ants (Linepithema humile), fire ants (Solenopsis invicta), and other insect pests. Any planting stock found to contain such pests will not be allowed on the project site or within 300 feet of natural habitats. The stock will be quarantined, treated, or disposed of according to best management principles by qualified experts in a manner that precludes invasive species invasions into natural habitats. Restoration and Enhancement Activities a. Ground-disturbing activities (e.g., soil recontouring, soil imprinting, seed drilling, driving with heavy vehicles, and installation of temporary irrigation) will be conducted only within the defined Restoration Area. b. Within 2 weeks prior to initiation of restoration or enhancement activities that involve the potential for ground disturbance, the PPM biologist will conduct a preliminary survey for PPM burrows and other sign within areas that will be disturbed from restoration or enhancement activities. The PPM biologist will mark all active potential PPM burrows within or adjacent to the area that will be affected by project activities and create a 10 to 15-foot buffer around the burrow to encompass the entire underground portion of the burrow. Burrow locations and other PPM sign will be mapped and provided to MCBCP ES and the CFWO prior to initiation of restoration/enhancement activities. c. At least 4 weeks in advance of implementing habitat enhancement activities, the PPM biologist will prepare a PPM monitoring plan and initiate monitoring within the habitat enhancement area to verify the absence or low density of PPM prior to vegetation manipulation and to modify the enhancement boundaries, if necessary, to include the areas of the lowest PPM occupancy. Results from the PPM monitoring in the habitat enhancement area will be provided to the CFWO prior to initiation of enhancement activities. d. Following the initial implementation of vegetation thinning and habitat enhancement activities, the PPM biologist will perform monitoring for up to 5 years within this area to monitor the success of thinning and duff removal treatments at enhancing the suitability of this area for PPM, and to recommend measures that will be implemented to avoid impacts to PPM during maintenance activities. Action Area According to 50 CFR pursuant to section 7 of the Act, the action area means all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action. Subsequent analyses of the environmental baseline, effects of the action, and levels of incidental take are based upon the action area. For this project, we have defined the action area to include the construction footprint for the proposed project, the footprint of all drainage channels

90 Mr. Bart Battista (FWS-MCBCP-15B F0796) 16 proposed to be repaired and maintained, the area of proposed habitat restoration and enhancement, and the surrounding habitat within about 500 feet, which may be exposed to project-related effects such as increased noise, light, and dust levels and human activity during project construction and operation of the facilities (Figure 1). STATUS OF THE SPECIES The status of the gnatcatcher is described in detail in a 5-year review of its status (Service 2010a) ( and the status of PPM has been described in detail in its recovery plan (Service 1998) and 5-year review (Service 2010b) ( Please refer to these documents for information on the listing status, life history, threats, and conservation needs of these species. We have included a brief a summary of the status and distribution of these species range-wide and on MCBCP. Coastal California Gnatcatcher The gnatcatcher is a small, non-migratory songbird that is found along the Pacific coastal regions of southern California and northern Baja California, Mexico (Atwood 1991) where it occurs in or near CSS vegetation communities (Atwood 1980). In 1993, the Service estimated that about 2,562 gnatcatcher pairs remained in the United States, with the highest densities occurring in Orange and San Diego counties (Service 1993). In a study using more rigorous sampling techniques, Winchell and Doherty (2008) estimated there were 1,324 (95 percent confidence interval: 976 1,673) gnatcatcher pairs over an 111,006-acre area on public and quasi-public lands in Orange and San Diego counties. Their sampling frame covered only a portion of the U.S. range that did not capture the northern and eastern extent of the species distribution. Although it is not valid to extrapolate beyond the sampling frame, especially in light of known differences in population densities across the range of the gnatcatcher (Atwood 1992), it is likely that more gnatcatchers occur in the U.S. portion of the range than was suggested by the 1993 population estimate. We are not aware of any recent estimates of the number of gnatcatchers in Baja California. Basewide surveys for gnatcatchers conducted about every 3 to 4 years since 1994 have documented between 268 and 668 gnatcatcher territories on MCBCP (Atwood et al. 1999; Griffiths Wildlife Biology 1997, 2004, 2008; Tetra Tech 2011, 2014). Surveys in 2014 detected 436 gnatcatcher territories on MCBCP (Tetra Tech 2014). The Marine Corps had previously estimated that 47,211 acres of CSS are suitable for gnatcatchers on MCBCP (Marine Corps 2004). An updated GIS analysis in 2009 conducted by Tetra Tech estimated 44,841 acres of CSS on MCBCP, but they determined only about half of that (21,257 acres) was actually suitable for occupation by gnatcatchers due to elevation considerations (gnatcatchers generally occur below 500 feet elevation on MCBCP) or a lack of necessary habitat structure as determined during field surveys (Tetra Tech 2011). Using the same methods, Tetra Tech (2014) estimated 19,580 acres of suitable gnatcatcher habitat occurred on MCBCP in 2013, but after extensive wildfire in May 2014, only 15,725 acres of suitable habitat remained.

91 Mr. Bart Battista (FWS-MCBCP-15B F0796) 17 Pacific Pocket Mouse The PPM is endemic to the immediate coast of southern California from Marina del Rey and El Segundo in Los Angeles County, south to the vicinity of the Mexican border in San Diego County (Hall 1981, Williams 1986, Erickson 1993). At the time of its listing in 1994 (59 FR 49752), only one small population of PPM was known to remain extant at the Dana Point Headlands in Orange County. Shortly thereafter, PPM was discovered at three additional locations (North San Mateo, South San Mateo, Santa Margarita), all within the boundaries of MCBCP in San Diego County (MBA and LSA 1997, Ogden 1997, Service 1999a). Despite extensive survey efforts that have been performed throughout its historical range since listing (2015 CFWO Survey Report Data Base), no additional occurrences of PPM have been found, and monitoring suggests the North San Mateo PPM population has become extirpated (Brehme and Fisher 2009, Brehme et al. 2012, Brehme et al. 2013). Monitoring of the Dana Point PPM population suggests that in recent years PPM have been using from 74 to 81 percent annually of the 17.9 acres of suitable habitat that are monitored 4, and the population likely varies in size from around 50 to 200 individuals (Brylski et al. 2008, 2009; Carranza 2014). Starting in 2012, the Marine Corps initiated a comprehensive annual basewide monitoring program that focuses on estimating the extent of PPM habitat occupancy/use within the three historically known occurrences on MCBCP (Brehme et al. 2011, Brehme et al. 2012). Because the PPM populations are patchily distributed over areas that are too big to practically monitor at once, this program uses 2.47-acre (1 hectare) randomly placed monitoring grids to statistically sample for PPM presence within habitat that falls within boundaries delineated for each population based on historic PPM capture locations. The proportion of sampled locations where PPM is detected is then used to estimate the amount of habitat that is occupied/used by PPM each year within those boundaries. Although a acre area has been delineated for monitoring the North San Mateo population, PPM have not been detected at this location since 2003, suggesting this site is no longer occupied by PPM (Natural Resource Assessment Inc. 2003, Service 2010, Brehme et al. 2014). At South San Mateo, between 2012 and 2015 the amount of PPM occupied habitat within the monitoring boundaries has averaged acres (range acres), which represents about 26 percent of the acre area that is monitored (Table 1) (Brehme et al. 2014, Brehme 2016, pers. comm.). The Santa Margarita population spans two troop training areas with different training regimes and operational restrictions, so the monitoring program estimates habitat occupancy/use separately within the Edson Range and Oscar One training area portions of the Santa Margarita population. Within the 1,171-acre area delineated as potentially occupied by PPM within Edson Range, habitat occupancy/use has averaged acres (range acres), which represents 39 percent of the monitored area. Within the 1, acre area delineated for PPM monitoring within Oscar One, estimated habitat occupancy/use has averaged acres (range acres) representing about 11 percent of the monitored area. Thus, from 2012 to 2015, total estimated PPM habitat occupancy/use on MCBCP has averaged acres (range to acres). 4 Although the Dana Point Preserve is 29.4 acres in size, most of the 11.5 acres that is not monitored is steep cliff face that is unsafe to access and likely does not provide suitable habitat for PPM.

92 Mr. Bart Battista (FWS-MCBCP-15B F0796) 18 Table 1: Estimated area occupied in acres (SE) within MCBCP population monitoring boundaries (Source: Brehme et al. 2014, Brehme pers. comm. 2016) Location Average (SD) South San Mateo (3.79) (3.79) (3.79) (4.61) (24.24) Edson (21.68) (23.58) (24.93) (25.47) (128.30) Oscar One (13.82) (14.63) (17.62) (11.92) (41.13) It is difficult to estimate the size of the PPM populations on MCBCP from the habitat occupancy/use data because the MCBCP PPM monitoring program relies upon data collected using tracking tubes to infer levels of PPM habitat occupancy/use within each population or subpopulation. This methodology involves reading track cards placed inside track tubes that are distributed throughout the monitoring grids. Because it is possible for an individual PPM to leave tracks in multiple tracking tubes, and tracks within a single tube could be generated by more than one PPM, this data is not reliable for estimating population size. However, some complementary information on PPM activity patterns and reproduction is collected using conventional live-trapping that is performed within portions of a few of the PPM monitoring grids (i.e., core grids) at each occurrence. Because PPM are individually marked during this trapping, the raw counts of unique individuals captured over an entire season within the core grids (Table 2) can be used to extrapolate crude population size estimates from the occupancy estimates. These extrapolations provide an indication of the potential range of population sizes, but they are not robust estimates with associated confidence intervals because they are calculated from raw data that is unadjusted for detection probabilities and that is collected over an entire season during which the populations are subject to fluctuations from births, deaths, immigration, and emigration. The core grid densities also are not likely to be representative for the populations as a whole since these locations are specifically chosen for reproductive monitoring based on high and consistent PPM encounter rates that provide the opportunity to observe enough animals to track reproduction in the populations. TABLE 2: Number of Individuals Captured on Core Monitoring Grids within MCBCP PPM Populations with raw counts converted to animal densities (Individuals/acre). Location South San Mateo South San Mateo South San Grid/Avg (Raw Count) 2012 (Density/ Acre) 2013 (Raw Count) 2013 (Density/ Acre) 2014 (Raw Count) 2014 (Density/ Acre) 2015 (Raw Count) 2015 (Density/ Acre) 1433 na na na na na na na na Avg. (Density/ Acre)

93 Mr. Bart Battista (FWS-MCBCP-15B F0796) 19 Location Grid/Avg (Raw Count) 2012 (Density/ Acre) 2013 (Raw Count) 2013 (Density/ Acre) 2014 (Raw Count) 2014 (Density/ Acre) 2015 (Raw Count) 2015 (Density/ Acre) Avg. (Density/ Acre) Mateo South 1468 na na na na na na San Mateo South na na na na San Mateo South Avg San Mateo Edson Edson Edson Avg Oscar One Oscar One Oscar One Avg Using density and occupancy estimates from 2012 through 2015, these extrapolations suggest that the South San Mateo population may have varied over this time period from a low of 64 individuals to a high of 4,450 individuals, with the highest densities observed in Over the same time frame these extrapolations for Edson Range suggest the population ranged from 6,026 to as many as 23,359 individuals and at Oscar One, these extrapolations range from 113 to 3,616 individuals. 5 Overall, the MCBCP and Dana Point PPM monitoring programs have focused on monitoring habitat occupancy/use due to the dramatic population fluctuations that have been observed for PPM (Service 2008) and other subspecies of Perognathus longimembris (French et al. 1974, Flake and Jorgensen 1969) and the difficulty these fluctuations present for estimating the sizes of the populations at low animal densities. While extrapolations that suggest the individual MCBCP populations can sometimes number in the thousands of individuals are consistent with results from fine scale demographic monitoring within Oscar One (Service 2008), difficulty locating/capturing PPM during numerous live-trapping surveys (Service 2010), including efforts performed specifically to bring animals into captivity for a captive breeding program (Shier 2014), suggest these populations are more likely to persist towards the lower range of extrapolated abundance during most years, with rapid expansion in population sizes and distribution observed on occasion. Given the large variability 5 Because no animals were detected on one of the two core grids at Oscar One during 2 years, this extrapolation is based on the average animal density and occupancy estimate for 2015, which provided the lowest population estimate among years.

94 Mr. Bart Battista (FWS-MCBCP-15B F0796) 20 in population size among years and our low confidence and inability to assess the accuracy of the population size extrapolations, we have assessed impacts to PPM based on the assumption that the proportional impact to occupied habitat equates to a similar proportional impact to the populations. ENVIRONMENTAL BASELINE Regulations implementing the Act (50 CFR ) define the environmental baseline as the past and present impacts of all Federal, State, or private actions and other human activities in the action area. Also included in the environmental baseline are the anticipated impacts of all proposed Federal projects in the action area that have undergone section 7 consultation, and the impacts of State and private actions that are contemporaneous with the consultation in progress. The action area is primarily within undeveloped open space that is bordered by two adjoining residential neighborhoods to the south and northwest. It is vegetated primarily with CSS, with small amounts of grass/forbland, and areas that are unvegetated due to past disturbance or have an urban/developed land use. Dirt access roads, fire breaks, and electrical transmission towers, poles, and transmission lines traverse the action area. The action area includes the Area 51 water reservoirs, drainage line, drainage channels, and appurtenant facilities that are the subject of the proposed action. Land use practices include operation of the reservoir facility, periodic maintenance of the fire breaks by the MCBCP facilities maintenance division, and daily use of the dirt roads by adjoining residents for hiking, mountain biking, and pet-walking. The site is not typically used for military training activities. The Marine Corps has not consulted on the effect of maintaining its fire breaks in this vicinity on threatened and endangered species. The electrical transmission lines that traverse the area are operated by San Diego Gas and Electric (SDGE) and Southern California Edison. In 1995, the Service issued SDGE a section 10(a)(1)(B) permit under the Act to implement a Natural Community Conservation Plan/Habitat Conservation Plan that exempts the company from take prohibitions under the Act for PPM and the gnatcatcher in association with emergencies and unavoidable impacts from repairs to existing facilities within its NCCP/HCP subregional boundaries, including MCBCP. SDGE performs ongoing repair and maintenance of its power lines and transmission towers within the action area that involves washing power lines and insulators, periodic grading of access roads and staging areas, trimming vegetation around its facilities, and occasional repair of its powerlines and transmission towers. This activity is overseen by a biological monitor who, to the extent possible, directs road grading away from active burrows and in the occasional instance where soil excavation for facility repair is needed, erects an exclusion fence around the project footprint in advance and performs removal trapping to avoid direct injury to PPM. While the precise number of PPM that may be harmed on an annual basis from SDGE s activities in the action area is unknown, it is likely that implementation of these take avoidance and minimization measures limits the harm to PPM from facilities maintenance to just a few individuals (e.g., about 1-3) each year. Southern California Edison (SCE) also maintains electric facilities within the action area, though much less frequently. SCE has not applied for or received a section 10(a)(1)(B) permit for its activities on MCBCP. Most of the project footprint lies within the 260-acre area surrounding the South San Mateo PPM population, which the Marine Corps monitors annually as part of its PPM monitoring program (Brehme et al. 2011). This monitoring program uses a combination of track tube and live-trapping grids to statistically sample for PPM within about 44.5 acres of the 260-acre area each year. Monitoring of the PPM population occurs on a biweekly basis from around April to September,

95 Mr. Bart Battista (FWS-MCBCP-15B F0796) 21 which causes some ongoing minor habitat disturbance (e.g., creation of trails, inadvertent trampling of burrows and vegetation) in the action area. Activities implemented between 2010 and 2014 impacted occupied gnatcatcher and PPM habitat (Figure 2) without the benefit of section 7 consultation; the effect of these activities on baseline conditions for gnatcatcher and PPM are discussed in greater detail below. In addition to these impacts, we completed consultation on the MILCON P-1044 CERS 2 Amendments to the Basewide Water Infrastructure (BWI) Project (FWS-MCBCP-12B F0058-R004; P-1044 CERS 2 project), which addresses potential impacts to gnatcatchers and PPM from construction of a water pipeline and valve facility adjacent to the proposed project (Figure 2). Coastal California gnatcatcher The action area consists primarily of gnatcatcher-occupied CSS, with smaller areas of non-native forbs/grassland, and unvegetated areas that were impacted by past activities. For the purpose of this consultation, gnatcatcher-occupied CSS is defined as CSS that occurs within 500 feet of any historically documented gnatcatcher locations within the past 25 years. Gnatcatcher presence was determined using basewide data. Basewide gnatcatcher surveys have been conducted once every 3 to 5 years on MCBCP dating back to We estimate that past grading and other earth disturbing incidents between 2010 and 2014 resulted in 1.23 acres of direct impact (e.g., grading and vegetation removal) to gnatcatcher habitat (Figure 2). In addition, the P-1044 CERS 2 project, which was constructed in 2015, involved temporary direct impacts to about 0.52 acre of gnatcatcher-occupied CSS; remaining project activities will result in thinning of shrub cover within another 3.61 acres of gnatcatcher-occupied CSS (Figure 2). Implementation of the habitat restoration component of the project has not yet been initiated but is proposed to occur as soon as practicable following construction of the pipeline and should return the temporarily impacted habitat to suitability for the gnatcatcher within the next 5 years. The 3.61 acres of CSS thinning associated with the P-1044 CERS 2 project will occur as a conservation measure to enhance habitat for the PPM. Based on 2014 gnatcatcher survey data, portions of five gnatcatcher pair territories appear to overlap the 3.61-acre thinning area. This may alter the suitability or quality of this area for the gnatcatcher over the short term by reducing perching and sheltering opportunities and possibly the availability of insect prey, but the amount of thinning should not result in a permanent loss of habitat suitability or ability of the habitat to support gnatcatchers over the long term. To estimate the number of gnatcatcher pairs that overlap with the current project footprint we used GIS to map an area of 5.7 acres around each of the gnatcatcher territory locations documented in Although gnatcatcher territory size is known to vary with habitat conditions and other variables such as distance from the coast (Preston et al. 1998), this analysis uses the average estimated gnatcatcher territory size in Rancho Palos Verdes (Atwood et al. 1998a) as the basis for this analysis based on the similarity of habitat conditions and distance from the coast for the two areas. Using this methodology, we estimate a total of 12 gnatcatcher territories overlap the project footprint, which includes proposed grading impacts, construction laydown and staging areas, drainage channels proposed for repair, and proposed restoration and enhancement areas.

96 Mr. Bart Battista (FWS-MCBCP-15B F0796) 22 Pacific pocket mouse The Area 51 reservoir repair and road maintenance project occurs within the South San Mateo PPM population. Because specific trapping surveys were not performed in support of this action, to characterize the amount of this population s habitat that falls within the action area the Marine Corps has defined PPM occupied habitat to include the area within 492 feet (150 meters) of all historically documented PPM capture locations. However, not all PPM habitat within and adjacent to the project footprint may be occupied each year. Results from the MCBCP PPM monitoring program indicate that on average 26 percent or about acres (range acres) of the 260-acre South San Mateo PPM monitoring area were occupied/used by PPM between 2012 and 2015 (Brehme 2016, pers. comm.). This suggests that occupancy within suitable habitat varies over time and that PPM are unlikely to occupy all of the suitable habitat (i.e., CSS and disturbed habitat) within 492 feet of historic capture locations at any given point in time. We estimate that past grading and other earth disturbing incidents between 2010 and 2014 resulted in 1.55 acres 6 of direct impact (e.g., grading and vegetation removal) and impacts from noise and vibration generated during grading likely extended into another acres of adjoining PPM habitat. For the purpose of this consultation, we assume that detrimental impacts to PPM from noise and vibration extend 98 feet (30 meters) from the earth disturbance footprint (Figure 2). Additional information regarding the effects of noise and vibration from construction activities on PPM is included in the Effects of the Action analysis for PPM below. In addition to the above discussed impacts to PPM, a portion of the PPM habitat within the action area was subject to impacts from the P-1044 CERS 2 project. In our biological opinion we estimated that 0.52 acres of PPM occupied habitat would be impacted from earth disturbance, and another 1.53 acres of occupied habitat would be impacted from noise and vibration during construction of the P-1044 CERS 2 project. The area of soil disturbance is proposed to be restored to CSS following project implementation. Shrub cover within another 3.61 acres of CSS within the action area is proposed to be thinned as a measure to enhance habitat for PPM. Analysis of the BWI project suggests construction of the P-1044 CERS 2 amendments could kill 7 to 34 PPM over the short term and another 3 PPM could be killed during habitat restoration and associated monitoring. Over the long term, the project s habitat restoration and enhancement measures are anticipated to restore habitat suitability for PPM to temporarily impacted areas and to improve and expand the amount of suitable habitat for PPM within the action area. In 2012, we also authorized the collection of PPM from the South San Mateo population to serve as founders for a captive population that has been established to help recover the species (FWS- OR/MCBCP-11B F0091). Our biological opinion authorized the removal of up to 60 individuals combined from the three extant PPM populations during implementation of the multiyear captive breeding program. Initially this program targeted the collection of 30 animals, 10 from each of the extant populations, to serve as captive population founders. However, between 2012 and 2014, just six PPM were collected from South San Mateo and used as founders for the captive 6 Under the Environmental Baseline for the gnatcatcher we estimate that these same grading and earth disturbing incidents resulted in 1.23 acres of direct impacts to gnatcatcher habitat. The disparity among these impact estimates results from our use of the disturbance to coastal sage scrub vegetation for estimating impacts to the gnatcatcher and use of the entire soil disturbance footprint for estimating impacts to PPM.

97 Mr. Bart Battista (FWS-MCBCP-15B F0796) 23 population. Based on breeding outcomes and the genetic make-up of the captive population, an additional four PPM were collected from South San Mateo in the fall of 2016 and added to the captive population. Although authorized, the decision to pursue the collection of more animals from South San Mateo will be determined in the future (e.g., in 2 or more years) based on the genetic diversity of the captive population and whether the newly collected animals successfully breed. Despite animal collections and repeated impacts to the PPM population at South San Mateo in recent years, this population increased substantially in distribution in 2015, likely due to mild weather conditions that allowed for an extended PPM breeding season. Monitoring has also documented that the area impacted by the creation of access roads and the fire break near Basilone Road housing have been re-occupied by PPM (Brehme 2016, pers. comm.). EFFECTS OF THE ACTION Effects of the action refer to the direct and indirect effects of an action on the species or critical habitat that will be added to the environmental baseline, along with the effects of other activities that are interrelated and interdependent with that action. Interrelated actions are those that are part of a larger action and depend on the larger action for their justification. Interdependent actions are those that have no independent utility apart from the action under consideration. Indirect effects are those that are caused by the proposed action and are later in time, but are still reasonably certain to occur. In addition to the proposed repair of the Area 51 reservoir drainage system, the proposed action involves restoration of PPM habitat to offset impacts that occurred during the creation or maintenance of fire breaks in Area 51 and during emergency repairs to the reservoir drainage system (i.e., the direct impacts from the past activities depicted in Figure 2). In areas that were impacted by the creation of fire breaks, the proposed action principally involves restoration of the impacted habitat, while habitat areas impacted from emergency reservoir repairs may be restored, be used for staging and access during reservoir repairs and then restored, or be permanently converted to a nonhabitat use in association with repair of the drainage system and creation of access and staging areas required for future maintenance. Most of the impacts for construction and site access will occur within areas that were impacted between 2010 and 2014 (Figure 2). Vegetation has started to regrow in some of these areas, but vegetative cover, particularly of shrubs, is very sparse. Therefore, it is unlikely that these areas currently support meaningful feeding, breeding or sheltering activities of gnatcatchers. Conversely, PPM monitoring has documented PPM re-colonizing areas that were previously impacted (Brehme 2016, pers. comm.). Therefore, all previously impacted portions of the project are considered occupied by PPM for this analysis. Coastal California gnatcatcher The reservoir repair project involves a) making permanent engineered corrections to the reservoir drainage system around which much of the habitat has already been impacted, b) maintaining the reservoir system drainage channels on a periodic basis so they are free of silt, debris, and vegetation, c) thinning CSS as a conservation measure to enhance habitat for PPM, and d) the restoration of habitat previously cleared during the creation of fire breaks and access roads (Figure 2). The restoration component of the project is not anticipated to affect gnatcatchers and is not discussed further.

98 Mr. Bart Battista (FWS-MCBCP-15B F0796) 24 Direct Effects Habitat Loss and Construction-Related Death and Injury Based on 2014 basewide surveys, we estimate four gnatcatcher territories overlap with the construction footprint. However, because construction activities will occur primarily within areas that were previously impacted, construction will only result in the loss of about an additional 0.1 acre of CSS. Because the project will only impact a small amount of vegetation and will be monitored by an avian biologist familiar with the gnatcatcher, we do not anticipate that gnatcatchers will be killed or injured during construction or that any active nests will be destroyed. In addition, because habitat removal from construction will affect only a fraction of any gnatcatcher territory in the area, construction-related habitat loss is anticipated to have an insignificant effect (i.e., unable to be meaningfully measured, detected, or evaluated) on gnatcatcher survival or reproduction. In the future, any silt, debris or vegetation that colonizes or re-establishes within the drainage channels will be removed on a periodic basis as a maintenance activity to keep the drainage channels free of obstructions. Similar to vegetation removal at the time of construction, this is anticipated to involve a nominal amount of habitat disturbance and loss at any one time (e.g., less than 0.25 acre), will affect only a fraction of any gnatcatcher territory and will be timed to occur outside of the breeding season or will be performed under the supervision of a biological monitor who will direct the maintenance activities to avoid impacts to breeding birds. Thus, maintenance of the drainage channels is also anticipated to have an insignificant effect on gnatcatcher survival or reproduction. The proposed thinning of acres of CSS to enhance habitat for PPM will affect habitat used by an estimated eight gnatcatcher pairs. While manipulation of the acres of CSS is not anticipated to result in permanent type conversion of the vegetation community, thinning of native shrub cover to an anticipated target of 5-30 percent could temporarily alter the suitability of this area for gnatcatchers by altering sheltering opportunities and the availability of insect prey. A study of post fire recovery of CSS suggests that gnatcatchers start using post burn areas when the cover of climax shrubs reaches percent (Harmsworth Associates 1999). Thus, thinning of the acres of CSS to below that level as a conservation measure for PPM could displace resident gnatcatchers or reduce the carrying capacity of the area for gnatcatchers. Because gnatcatchers are non-migratory territorial birds, removal or alteration of a substantial portion of a gnatcatcher pair s territory will force the pair to expand its existing territory or establish a new territory, particularly during the breeding season when territorial boundaries are better defined (Preston et al. 1998). Because gnatcatchers are distributed throughout much of the suitable habitat within the action area, it is likely that displaced gnatcatchers will be forced to compete with gnatcatchers in adjoining habitat when attempting to expand an existing territory or establish a new territory. If displaced birds cannot find suitable habitat to forage and shelter in, we anticipate they will be more vulnerable to predation and otherwise may die or be injured. Gnatcatchers that successfully establish territories in the altered or adjacent habitat are expected to experience reduced productivity (e.g., delayed initiation or prevention of nest building, fewer nesting attempts per season, and/or overall reduction in reproductive output) due to reduced availability of foraging and breeding habitat and increased territorial interactions.

99 Mr. Bart Battista (FWS-MCBCP-15B F0796) 25 Projection of a 5.7-acre estimated territory around each of the eight documented gnatcatcher locations in the PPM habitat enhancement area suggests that 20 percent or more of the habitat within four of the eight gnatcatcher territories will be altered by the proposed shrub thinning; we estimate that loss of more than 20 percent of a territory is significant enough to cause harm to each of these gnatcatcher pairs through displacement and decreased resource availability. Three of these territories overlap an adjoining 3.61-acre area within which CSS is already proposed to be thinned as a conservation measure associated with the P1044 CERS 2 project. Because the cumulative extent of habitat thinning within each of these three gnatcatcher territories will be increased, the significance of this habitat alteration is more appreciable and more likely to result in harm to these pairs. This impact is likely to be temporary as the overall carrying capacity of the action area for the gnatcatcher is likely to return to pre-project levels as the shrub community recovers from the proposed thinning, and the project will not result in a long-term reduction in habitat for the gnatcatcher. Because there is a large gnatcatcher population (estimated to be 436 territories in 2014) on MCBCP, the project will impact a small percentage (about 1.1 percent) of the total population. We anticipate that the gnatcatcher population on MCBCP can tolerate this level of temporary impact without increased risk of extirpation. Thus, it is our determination that the project will not result in an appreciable reduction in the numbers, reproduction, or distribution of the gnatcatcher population on MCBCP or range-wide. Noise and Vibration Noise and vibrations associated with the use of heavy equipment during construction have the potential to disrupt gnatcatcher behaviors in adjacent habitat by masking intraspecific communication and startling birds (e.g., see Dooling and Popper 2007 for a discussion of observed effects of highway noise on birds). Construction activities associated with repairs to the reservoir drainage system will occur during the gnatcatcher breeding season to minimize impacts to PPM. Therefore, construction could significantly disturb nesting activities of gnatcatcher pairs adjacent to the project site. To minimize disturbance to gnatcatchers in adjoining habitat during the breeding season, an avian biologist will conduct pre-construction surveys for active gnatcatcher nests in and within 250 feet of the construction footprint and will use the project limits and local topography to determine if construction activities are likely to directly damage a nest or significantly disturb nesting activities. Where damage or disturbance of any gnatcatcher nest(s) is likely, the avian biologist will recommend the construction contractor implement measures to minimize the likelihood of nest destruction or disturbance, including directing and phasing construction to occur in areas further away from the active nest(s), if possible; erecting straw bale sound minimization barriers; and erecting flagging or signage to deter people from entering nesting areas. Based on 2014 surveys, we estimate that four gnatcatcher territories overlap the reservoir repair construction footprint. The habitat supporting these territories generally experiences a low level of human activity; therefore, the gnatcatchers at this location are unlikely to be acclimated to high levels of noise and disturbance. However, gnatcatchers are often found along the urban edge (Atwood et al. 1998b) and appear to be relatively tolerant of noise and disturbance. We estimate, based on our best professional judgment, that only one of the four gnatcatcher pairs will be close enough to the construction activity to cause a delay in, or to forego, reproduction for 1 year. Loss of reproduction for one gnatcatcher pair over the course of only 1 breeding season will affect recruitment of the

100 Mr. Bart Battista (FWS-MCBCP-15B F0796) 26 gnatcatcher population in the action area over the short term but will not result in an appreciable reduction in the numbers, reproduction, or distribution of gnatcatchers on MCBCP or range-wide. Vegetation thinning for the purpose of habitat enhancement will occur outside of the breeding season for the gnatcatcher (i.e., vegetation manipulation will be implemented between August 31 and February 15). Based on 2014 surveys, we estimate that eight gnatcatcher territories overlap the habitat enhancement area. The specific tools and methods for shrub thinning in the acre habitat enhancement area will be specified and approved as a component of the Habitat Restoration and Enhancement Plan that will be prepared prior to initiation of construction activities. Based on similar habitat thinning projects performed to enhance habitat for PPM at the Dana Point Headlands and North San Mateo, this work will not involve soil disturbance and will primarily involve removal of shrubs that will be cut at their base using a combination of chain saws and hand tools and removal of plant debris on the soil surface with hand rakes. The timing of shrub thinning will be performed outside of the bird breeding season, and plant material will likely be removed by hand to vehicle staging areas along access paths identified by the restoration contractor in consultation with the avian biologist; thus, we anticipate that effects to gnatcatcher survival and reproduction from noise and vibration from restoration activities will be insignificant. Indirect Effects Additional indirect effects to gnatcatchers from the project include the potential for habitat degradation associated with an increase of erosion and sedimentation, introduction of invasive species, wildfire, and human encroachment. MCBCP already has extensive infrastructure, so with the proposed conservation measures, the increase in habitat degradation associated with these factors is likely to be insignificant. Effect on Recovery There is no recovery plan for the gnatcatcher, but MCBCP supports one of the most significant gnatcatcher populations in the region. The habitat enhancement for PPM will impact survival and reproduction for four gnatcatcher pairs, and one additional pair is anticipated to experience reduced reproduction as a result of construction-related noise and activity. However, the project proposes to restore 1.18 acres of CSS within the construction footprint and areas of prior habitat impacts, and the habitat within the PPM enhancement area should eventually recover and be re-occupied by gnatcatchers. Thus, the proposed project will not impede gnatcatcher recovery. Pacific pocket mouse The reservoir repair project involves cleaning silt, debris, and vegetation from the reservoir system drainage channels, making permanent engineered corrections to prevent erosion of the reservoir drainage system, restoring habitat previously cleared during the creation of fire breaks and access roads, and thinning CSS cover as a conservation measure to enhance habitat for PPM (discussed below). Repairs to the reservoir drainage system will be preceded by a geotechnical investigation that could involve drilling soil cores within the footprint of reservoir repairs. Repairs in this area will also involve the creation of permanent access roads and staging areas for future proposed maintenance (Figure 2-1 of the BA).

101 Mr. Bart Battista (FWS-MCBCP-15B F0796) 27 While a majority of the area that is subject to soil disturbance from restoration and project construction was recently disturbed (between 2010 and 2014), impact monitoring grids established within a 2012 emergency reservoir repair access road and the 2014 Basilone housing area firebreak indicate that PPM have recolonized at least some of the disturbed areas. Therefore, proposed soil disturbance from the restoration of habitat and construction to repair the reservoir drainage system could excavate or crush animals in their burrows. Animals subject to direct disturbance would either not be expected to survive or, through displacement, would be harmed from increased competition with hetero- and con-specifics, increased risk of predation and stress, and reduced reproduction. Habitat Loss and Construction Related Death and Injury We estimate that project construction will directly impact 0.84 acre of suitable PPM habitat within the soil disturbance footprint, and restoration will be conducted within another 0.70 acre of habitat that was previously impacted from the construction of fire breaks. Cumulatively this represents about 0.6 percent of the available habitat within the 260-acre South San Mateo PPM Monitoring Area. However, because monitoring grids in the vicinity of the construction and restoration footprints have consistently been occupied by PPM, we have applied the higher average monitoring grid occupancy rate in this area (0.76 *1.54 acres = 1.17 acres) to estimate that about 1.7 percent of the South San Mateo PPM population (1.17 acres/67.77 acres) will be impacted within the construction and restoration soil disturbance footprint. Based on average densities of PPM within the South San Mateo monitoring program grids from ( PPM/ ac.) in absolute terms this could result in death or injury to 6 to 30 PPM, with the overall proportional impact to the population likely to remain the same over this range because the higher impact estimate is associated with higher animal densities at times of population abundance in the action area. Pursuant to conservation measures that have been developed as part of the project, the Marine Corps proposes to erect exclusionary fencing around a small portion of the construction area and perform salvage trapping of PPM from that area. Due to the linear nature of the project and site topography, this is only feasible within about a 0.10 acre area where there has been severe erosion and construction of a retaining wall and backfilling with soil is proposed. The salvage trapping involves enclosing the construction footprint with a barrier that rodents cannot circumvent (e.g., silt fencing, flashing) and live-trapping and removing PPM from the enclosed area prior to the initiation of construction. Any captured animals will be removed and incorporated into a captive population that is being managed by the San Diego Zoological Society to assist in the recovery of PPM (Shier and Swaisgood 2013) or released outside of the exclusion fencing. Removal of animals from the construction footprint saves them from direct injury from construction but does not ensure they will be unharmed, as any salvaged animals that are released away from their burrows will suffer the same harm described for displaced animals (see below). Alternatively, PPM transferred to the breeding facility at the San Diego Zoo could contribute to future generations of captive mice. Consistent with the tasks identified in the PPM Recovery Plan (Service 1998), mice in this facility are being bred as a source of animals for creation of additional wild populations within the species historic range. Given the size of the removal trapping area and based on the number of proposed trap nights and observed nightly individual capture probabilities, we anticipate that most, if not all, of the PPM in this portion of the project footprint (likely just one or two individuals) will be removed from the project footprint prior to construction.

102 Mr. Bart Battista (FWS-MCBCP-15B F0796) 28 PPM that enter traps could be killed or injured by the trapping activity itself from impingement in trap doors, elevated stress from confinement, exposure to heat or cold temperatures, or from aggression with hetero or con-specific animals confined in the same trap. Based on past experience, the qualification of individuals that will be performing the trapping, and the small number of individuals that may be captured, this risk is likely to be very low but is not absent. Therefore, we conservatively estimate that one of the captured animals could be killed or injured during the trapping activity, which includes transport of any salvaged animals to the San Diego Zoo. Any of the remaining animals within the project footprint following trapping and removal efforts will be crushed or displaced by the project. Because the surrounding habitat is already occupied by PPM and other small mammals that likely compete with PPM for resources (i.e., food and space), we anticipate that any PPM that are displaced from their burrows or are captured and deposited outside the project footprint will be subject to harm from the loss of their burrows, an increased risk of predation, increased competition with hetero- and conspecifics, and decreased reproduction. Because only a small portion of the project footprint can be trapped and PPM remaining in the project footprint will likely be crushed in their burrows and difficult to observe, we estimate that no more than 1 individual will be observed dead or injured as a result of construction activities. Following project completion, about 0.48 acre within the construction footprint and 0.70 acre impacted by past activities will be restored with native vegetation to recreate suitable habitat for PPM, and 0.46 acre will be permanently converted to non-habitat use. We anticipate that the habitat that is subject to temporary direct impacts will be successfully restored to support PPM and PPM should begin colonizing and using the areas subject to direct impacts within 2 to 4 years following initiation of restoration. While higher habitat occupancy rates adjoining the project footprint relative to the average occupancy rate at South San Mateo as a whole suggest up to 1.7 percent of the South San Mateo population could be injured or killed within the direct impact footprint, just 0.5 percent of the 260 acres of habitat thought to be suitable for PPM occupancy at South San Mateo will be temporarily lost, and 0.2 percent will be permanently converted to a non-habitat use. Given the small temporary proportional loss to the population and small permanent loss of suitable habitat, we do not anticipate that direct habitat losses will appreciably reduce the survival of the South San Mateo PPM population. Noise and Vibration The use of large vehicles and heavy construction equipment during project grading and construction will generate noise and vibration that is likely to detrimentally affect PPM in adjoining habitat. Vibrations created by such equipment attenuate through the soil at various frequencies and can be transferred to the bodies of animals that reside underground. Laboratory studies show that the effects of low frequency vibrations on small mammals can include effects such as increased stress and ulcer formation in adult rodents, and increased congenital malformation and reduced birth weight of pups (Sackler and Weltman 1966, Bantle 1971, Toraason et al. 1980, Seidel and Griffin 1998, Rubin et al. 2007). However, we do not have a detailed understanding of the potential effects and likely zone of construction-related vibrational impacts on rodents in natural systems. Our best information regarding potential effects to PPM from construction related noise and vibration comes from observations made during implementation of the MCBCP PPM monitoring program. One such observation was made at South San Mateo during 2012 when a large bulldozer graded a

103 Mr. Bart Battista (FWS-MCBCP-15B F0796) 29 fire break through habitat that was being monitored for PPM occupancy at the time of grading. Immediately prior to this incident, monitoring documented PPM at 30 locations within 197 feet (60 meters) of the grading footprint, but intensive monitoring immediately and for several years following that impact failed to detect the continued use of the fire break and surrounding area by PPM (Brehme and Fisher 2012, pers. comm.; Brehme et al. 2014). Thus, although the manner that PPM were harmed by noise and vibration from the grading incident is unclear (e.g., possible burrow collapse and immediate death or injury, or flight and displacement from the area), loss of PPM activity in this area strongly suggests that PPM were directly harmed within an area that extended well beyond the immediate soil disturbance footprint. Another observation (Brehme 2015, pers. comm.) following a second firebreak grading incident near the Basilone road housing area at South San Mateo in 2014 suggests the severity and duration of these impacts varies, possibly in association with the type of equipment used, duration of the activity, activity of PPM at the time of impact, character of the surrounding terrain and/or soil type. At the time of this grading incident, there was no concurrent monitoring of PPM in the impact area, but track tubes placed in this area following the grading detected PPM in the cleared and adjoining area the season following the grading disturbance (Brehme 2015, pers. comm.). This suggests that while the detrimental impacts to mice from noise and vibration are likely to be significant and immediate, they may not always include alteration of PPM habitat suitability or extend over multiple years. Taking a conservative approach, because most of the 30 locations where PPM was detected prior to the 2012 incident were within 98 feet (30 meters) of the grading footprint, Brehme and Fisher (2012, pers. comm.) recommend calculating the area of likely adverse impacts to PPM from grading and ground disturbing construction activities to include all suitable habitat within 98 feet of the soil disturbance footprint. For the purposes of this analysis, we have adopted this recommendation and buffered the immediate disturbance footprint from soil disturbing construction activities by 98 feet to calculate the likely impact to PPM in adjoining occupied habitat. We do not anticipate and have not projected impacts from noise and vibration occurring in areas surrounding in-tact drainage channels or around habitat restoration and enhancement areas where no mechanized soil disturbance is proposed. Accordingly, we estimate that PPM within acres of suitable habitat in the area adjoining the soil disturbance footprint will be subject to harm from noise and vibration. This represents about 4 percent of the available habitat within the 260-acre South San Mateo PPM Monitoring Area. Because the monitoring program has consistently documented PPM occupancy in this vicinity, we have applied the average occupancy rate of monitoring grids in this vicinity (76 percent) to estimate that about 12 percent (7.91 acres/67.77 acres) of the South San Mateo PPM population could be directly impacted from construction-related noise and vibration. Based on average densities of PPM within the SSM monitoring program grids from ( PPM/ ac.), in absolute terms this could result in death or injury to 38 to 203 PPM, with the overall proportional impact to the population likely to remain the same over this range because the higher impact estimate is associated with higher animal densities at times of population abundance in the action area. PPM within the area subject to noise and vibration may be killed or injured from burrow collapse, or animals may flee in response to noise and vibration and be displaced into adjoining occupied habitat. Animals that flee or are displaced will be harmed from the loss of their burrows, and will likely suffer from increased risk of predation, increased competition with hetero- and conspecifics, and decreased reproduction. Because these impacts are not certain to be fatal, and animals that survive

104 Mr. Bart Battista (FWS-MCBCP-15B F0796) 30 have the potential to breed and contribute to future generations, no attempt will be made to trap and remove animals from the area subject to noise and vibrational impacts. Furthermore, we do not anticipate that any PPM within the area subject to noise and vibration will be observed dead or injured during or following project implementation because PPM is a nocturnal burrowing rodent and any direct injury to PPM is likely to occur belowground where the likelihood of observing injured animals is remote. Overall, the harm to up to 12 percent of the South San Mateo PPM population from construction associated noise and vibration when combined with direct habitat losses will increase the vulnerability of the South San Mateo population to the effects of environmental and demographic stochasticity, loss of genetic diversity, inbreeding depression, and catastrophes. However, based on PPM observations following the 2014 grading incident, we anticipate that this impact will be temporary and will not alter the suitability of PPM habitat in the area subject to noise and vibration impacts. Under favorable environmental conditions we anticipate that PPM will begin to utilize the acres of impacted habitat within 1 to 2 years of project construction, with re-colonization of this habitat likely to extend over a longer time interval (e.g. 3-5 years) under less favorable environmental conditions. Thus, we do not anticipate that impacts from noise and vibration will appreciably reduce the survival of the South San Mateo PPM population over the long term. Habitat Restoration and Enhancement Among the identified potential threats to PPM is senescence of sage scrub vegetation where the extant populations are distributed (Service 1998). Senescence of vegetation results in a dense shrub canopy that suppresses germination of forbs used as a food resource by PPM and causes the loss of habitat openings and patches of bare ground that appear to serve as important microhabitat for foraging, dust bathing, and other essential behaviors (Shier 2009, 2010). Monitoring has also shown that PPM are less likely to occupy habitat invaded by dense non-native annual grasses (i.e. greater than 30 percent cover; Brehme et al. 2014), likely for the same reasons. As a conservation measure, the Marine Corps proposes to perform a total of 1.18 acres of restoration within the past and proposed soil disturbance footprint and acres of enhancement at South San Mateo to help offset impacts to the PPM population from implementation of the project. The goal of restoration within the construction footprint and areas of prior grading impacts will be to return these areas to suitability for PPM. The goal of enhancement is to improve the suitability of and expand the amount of occupied habitat within the 260-acre area that supports the South San Mateo PPM population. The enhancement will be performed by thinning the shrub canopy and removal of duff and thatch in areas that the PPM monitoring program has found to be unoccupied or only lightly occupied by PPM. If successful, this would compensate for the short term increase in vulnerability of the South San Mateo PPM population to extirpation by increasing the average amount of PPM occupied habitat at San Mateo South by 133 percent (i.e. average occupied habitat would increase from to acres), increasing the carrying capacity of the South San Mateo population, and reducing its vulnerability to the effects of small population size (e.g., loss of genetic diversity, inbreeding depression, vulnerability to catastrophe) for a number of years until the vegetation regrows and returns to its pre-project condition. At the Dana Point PPM population location, where similar vegetation thinning and duff removal enhancements have been performed within senescent sage scrub, monitoring has found increased occupancy and continued use of thinned areas by PPM over time (Brylski et al. 2010, Carranza 2014).

105 Mr. Bart Battista (FWS-MCBCP-15B F0796) 31 Habitat restoration and enhancement activities such as weeding, planting, vegetation thinning, and duff removal have the potential to impact PPM from landscape workers trampling or disturbing active burrows. A study of burrow-depth in the closely-related little pocket mouse (Perognathus longimembris longimembris) documented that individuals selected resting sites in their burrows at depths ranging from 3.3 feet to as little as 0.4 inches (Kenagy 1973). Thus, workers could crush PPM in their burrows as they walk through habitat and perform restoration and enhancement activities, though the initial likelihood of workers crushing animals in burrows where there was recent soil disturbance should be low due to the immediately preceding construction impacts. As habitat conditions improve over time, both the restoration areas and the enhancement site(s) are likely to become occupied more densely by PPM. To minimize harm to animals within proposed restoration or enhancement areas, a PPM biologist will survey for and flag active small mammal burrows to be avoided by soil disturbing planting activities; will flag access paths to the restoration and enhancement areas to avoid trampling of areas with the highest potential to support PPM; and will, in coordination with CFWO, select the final boundaries of proposed habitat enhancement area(s). Monitoring of vegetation response and habitat use by PPM will also be performed as a component of restoration and enhancement plan implementation so that habitat management efforts can be adapted to minimize impacts to an increased presence of mice, if this is observed. Overall, with implementation of these minimization measures, we anticipate that the restoration and enhancement activities may kill or injure a few PPM (e.g. up to 2 to 3 individuals) over the life of the project, but any PPM killed or injured in this manner are likely to remain belowground in their burrows where they are unlikely to be observed. Because these individuals will be harmed from implementation of habitat restoration and enhancement that is being performed specifically to increase the extent of habitat occupancy at South San Mateo, the benefits of restoration and enhancement outweigh the loss of these individuals and their loss is not anticipated to appreciably reduce the prospects of survival of the South San Mateo PPM population. Indirect Effects Maintenance Activities Yearly maintenance of the drainage channels is proposed to keep the drainage channels free from vegetation, sand, silt, and debris. To minimize impacts to PPM, maintenance of the drainage channels will be scheduled to occur when PPM are dormant (i.e., from October 16 February 28/29), and access to the drainage channels will be by foot. Maintenance activities will involve no ground disturbance outside of the lined drainage channels, and all vehicles and mechanized equipment will remain within the permanent crane laydown area and permanent access road shown on Figure 2-1 in the BA. While accumulation of sand, debris, and vegetation in the drainage channels has potential to create suitable habitat conditions that could be colonized by PPM, we anticipate that routine maintenance of the drainage channels will prevent suitable habitat conditions from forming for a long enough time for PPM to colonize the concrete drainage channels. Restriction of vehicles and mechanized equipment to established staging areas should also help to minimize potential impacts to PPM. With continued faithful and routine maintenance of the drainage channels, we do not anticipate any PPM will be killed, injured, or harmed from yearly maintenance activities.

106 Mr. Bart Battista (FWS-MCBCP-15B F0796) 32 Effect on Recovery Recovery Action 1.7 in the PPM Recovery Plan (Service 1998) is to protect essential habitats and sites for PPM. This project will result in impacts to 1 of the 3 remaining extant PPM populations, but long-term detrimental impacts to this population will be minimal, and will be offset by other measures identified in the PPM Recovery Plan. Conservation measures that will be implemented as a component of the project that are consistent with actions called for in the PPM recovery plan include salvaging PPM that might otherwise be lost due to project impacts, performing habitat restoration and enhancement, and using an adaptive management framework during habitat restoration and enhancement that increases our knowledge of how to manage the species. To help offset the loss of individual PPM from construction of the project, the Marine Corps will trap animals within a portion of the area subject to direct impacts and make them available to the PPM captive breeding program 7. The captive breeding program is currently being implemented by the San Diego Zoo to help fulfill Recovery Action 5.7 from the Recovery Plan (Service 1998), Identify and Implement Measures to Create Additional Populations. Thus, while the loss of individuals will have a short-term adverse impact on the South San Mateo PPM population, the addition of up to two individuals to the captive breeding program will help to contribute to this recovery effort by adding genetic diversity and the potential for captured mice to contribute offspring to a population that has specifically been established to create new, or sustain the extant, populations. In addition to restoring habitat impacted by the proposed project and from prior grading of fire breaks, the Marine Corps proposes to enhance acres of habitat within the 260-acre South San Mateo PPM Monitoring program boundary where monitoring suggests PPM are currently absent or only occur at trace levels. This enhancement helps to fulfill Recovery Action 3.2 (Service 1998) to enhance and expand Pacific pocket mouse habitat and, if successful, would increase the average amount of PPM occupied habitat at San Mateo South by 133 percent (i.e. average occupied habitat would increase from to acres). This effort contributes to the recovery of PPM by enhancing and expanding PPM habitat and reducing the vulnerability of the South San Mateo population to extirpation. Because only a few efforts to restore and enhance PPM habitat have been attempted and only one of these has been a clearly demonstrated success (Carranza 2013), the Marine Corps proposes to implement the restoration and enhancement components of the project using an adaptive management framework that involves monitoring the response of PPM to the restoration and enhancement treatments. This is consistent with Recovery Action to develop an adaptive management plan for Federal lands on Marine Corps Base, Camp Pendleton. Ideally implementation and monitoring of the enhancement effort will become a component of a MCBCP PPM Management Plan that is currently under development; but even if it is not or the restoration and enhancement efforts are unsuccessful at creating additional occupied PPM habitat, the information collected during this effort will contribute to recovery of PPM by adding to our knowledge of how to manage its habitat. 7 While we anticipate that any animals captured within the construction footprint will be added to the PPM captive breeding program being implemented by the San Diego Zoo, the conservation measure addressing PPM salvage provides the option of releasing animals outside the construction footprint, with the decision about the final disposition of animals to be made on a case by case basis by the PPM biologist in coordination with CFWO.

107 Mr. Bart Battista (FWS-MCBCP-15B F0796) 33 CONCLUSION After reviewing the current status of the gnatcatcher and PPM, the environmental baseline for the action area, the effects of the proposed action, and the cumulative effects, it is our biological opinion that the proposed action is not likely to jeopardize the continued existence of the gnatcatcher or PPM. We reach this conclusion by considering the following: Gnatcatcher PPM 1. The project will temporarily remove habitat supporting up to four gnatcatcher pairs and will impact one additional pair as a result of impacts from construction noise. The affected pairs represent a small fraction of the estimated 439 gnatcatcher territories on MCBCP as of 2014 (Tetra Tech 2014). 2. The project will result in negligible permanent impacts to gnatcatcher habitat and will result in restoration of 1.18 acres of CSS. Thus, the project will result in no net loss of gnatcatcher habitat over the long term. 3. With the proposed conservation measures, the project is not expected to appreciably reduce the numbers, reproduction, or distribution of the species on MCBCP or rangewide and is not anticipated to impact recovery of the species. Up to 1.7 percent of the South San Mateo PPM population is anticipated to be impacted within the project footprint, and up to 12 percent of the South San Mateo PPM population will be impacted due to noise and vibration from construction activities. However, permanent impacts from construction will be restricted to 0.46 acre, and habitat that is temporarily impacted from construction and noise and vibration is anticipated to be re-occupied by PPM following project completion. 1. To minimize impacts from project construction, efforts will be made to salvage all PPM residing within the 0.10 acre erosion repair footprint so that those animals can be incorporated into a captive population that is being bred for the purposes of species recovery or released outside the project footprint. 2. To minimize impacts from proposed habitat restoration and enhancement measures, advanced surveys will be performed to flag and avoid burrow systems during planting efforts and to direct habitat enhancement to areas within Area 51 that are not occupied or only lightly occupied by PPM. 3. Impacts to PPM habitat will be offset by restoration of 1.18 acres that was previously impacted or will be impacted by the project, and through enhancement of an additional acres of suitable PPM habitat at South San Mateo using an adaptive management framework that will be designed to improve our knowledge and ability to effectively manage PPM habitat over the long term.

108 Mr. Bart Battista (FWS-MCBCP-15B F0796) With the proposed conservation measures, including measures to minimize impacts to the South San Mateo population and implement recovery actions identified in the PPM Recovery Plan (Service 1998), the project will not impede and should contribute to recovery of PPM. INCIDENTAL TAKE STATEMENT Section 9 of the Act and Federal regulation pursuant to section 4(d) of the Act prohibit the take of endangered and threatened species, respectively, without special exemption. Take is defined as harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, collect, or attempt to engage in any such conduct. Harm is further defined by us to include significant habitat modification or degradation that actually kills or injures a listed species by significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering. Harass is defined by us as an action that creates the likelihood of injury to a listed species by annoying it to such an extent as to significantly disrupt normal behavioral patterns which include, but are not limited to, breeding, feeding, or sheltering. Incidental take is defined as take that is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity. Under the terms of section 7(b)(4) and 7(o)(2) of the Act, such incidental take is not considered a prohibited taking under the Act, provided that such taking is in compliance with this incidental take statement. The measures described below are non-discretionary and must be implemented by the Marine Corps and its contractors, as appropriate, in order for the exemption in section 7(o)(2) to apply. The Marine Corps has a continuing duty to regulate the activity that is covered by this incidental take statement. If the Marine Corps (1) fails to adhere to the terms and conditions of the incidental take statement through enforceable terms and/or (2) fails to retain oversight to ensure compliance with these terms and conditions, the protective coverage of section 7(o)(2) may lapse. AMOUNT OR EXTENT OF TAKE Coastal California Gnatcatcher The estimated level of take for gnatcatchers is based on the number of gnatcatcher pairs in the project vicinity and the amount of occupied habitat impacted. If the amount or extent of incidental take is exceeded, it will trigger reinitiation of consultation. Take of gnatcatcher is exempted as follows: IT 1. IT 2. Take in the form of harm of up to one of the four gnatcatcher pairs within or adjacent to the reservoir repair alignment due to a reduction in fitness and productivity for one breeding season as a result of construction-related noise and disturbance during the breeding season. Because the effects of construction activity on gnatcatcher breeding will not be measured, the amount or extent of incidental take will be exceeded if more than four gnatcatcher pairs are observed whose estimated territories overlap the project footprint prior to or during project construction. Take in the form of harm of up to four gnatcatcher pairs due to proposed vegetation thinning within acres of occupied gnatcatcher habitat for the purpose of

109 Mr. Bart Battista (FWS-MCBCP-15B F0796) 35 Pacific Pocket Mouse enhancing habitat for PPM and impacts to 0.1 acre of CSS from construction activity. The amount or extent of incidental take will be exceeded if more than the specified amount of habitat or more than four gnatcatcher territories are substantially impacted (i.e., more than 20 percent of the habitat within their estimated territories is removed). We estimate that up to 1.7 percent of the South San Mateo PPM population may reside within the 1.54 acres of habitat that will be directly impacted by ground disturbing construction and restoration activities, and up to 12 percent of the population may reside in the surrounding acres of suitable habitat that will be impacted from noise and vibration generated from construction and soil disturbing activities. An attempt will be made to capture all PPM that reside within the 0.10-acre erosion repair footprint and relocate them outside the project footprint or incorporate them into the captive breeding program, but no attempt will be made to capture animals within the remaining area that will be impacted by the project. It is acknowledged that not all captured PPM will survive, reproduce, or be released from captivity. Because PPM are likely to remain underground within their burrows during project implementation, it will not be possible to observe and quantify the number of animals residing within the soil disturbance footprint that escape capture and are killed, injured, or harmed, nor will it be possible to observe and quantify the number of animals harmed from noise and vibration within surrounding habitat. Therefore, we have established estimated levels of take and associated triggers for reinitiation based on the amount of habitat affected and the number of PPM that could be reasonably observed. If the amount or extent of incidental take is exceeded, it will trigger reinitiation of consultation. Take of PPM is exempted as follows: IT 3. IT 4. IT 5. IT 6. Capture and incorporate into the captive breeding facility or release outside the project footprint up to two PPM. The amount or extent of incidental take will be exceeded if more than two PPM are captured or observed within the boundaries of exclusionary fencing. Death or injury of one PPM as a result of pre-project trapping activities. The amount or extent of incidental take will be exceeded if more than one PPM is killed or injured as a result of these trapping activities. Harm, death, or injury of all PPM that escape capture within the 1.54 acres of PPM occupied habitat that will be impacted by construction and other soil disturbing activities. Because it is unlikely that individuals that escape trapping will be detected, the amount or extent of incidental take will be considered exceeded if more than one PPM is observed killed or injured within the soil disturbance footprint or if more than 1.54 acres of PPM-occupied habitat is impacted from soil disturbing construction and habitat restoration activities. Harm, death, or injury of PPM as a result of noise and vibration within an estimated acres of suitable habitat adjacent to the direct soil disturbance footprint.

110 Mr. Bart Battista (FWS-MCBCP-15B F0796) 36 Because effects to PPM within this area will not be assessed directly during project construction, the amount or extent of take will be considered exceeded if more than 0.84 acre is impacted from construction activities. IT 7. IT 8. Death or injury of two PPM as a result of monitoring of PPM (e.g., use of traps) within habitat that will be restored and/or enhanced as a component of the project over the 5-year project implementation time frame. Harm, death, or injury of a small number of PPM as a result of habitat restoration and enhancement activities that will be implemented over 5 years to offset temporary and permanent impacts to the South San Mateo PPM population. Because it is unlikely that these individuals will be detected, the amount or extent of incidental take will be exceeded if more than 1.18 acres of habitat are disturbed from restoration and/or more than acres are disturbed from enhancement measures. EFFECT OF TAKE In the accompanying biological opinion, we determined that these levels of anticipated take are not likely to result in jeopardy to the gnatcatcher and PPM. REASONABLE AND PRUDENT MEASURES The Marine Corps will implement conservation measures as part of the proposed action to minimize the incidental take of gnatcatcher and PPM. In addition to these conservation measures, the following reasonable and prudent measures are necessary to monitor and report the effects of the incidental take on gnatcatcher and PPM: 1. The Marine Corps will monitor and report on consistency with the exempted amount or extent of take for gnatcatcher associated with the proposed action. 2. Because the design and construction method for the erosion repair retaining wall has not been finalized, we have assumed that the wall can be put in without pile driving or use of more than a hand held soil compacter. Greater vibrational impacts from more intensive construction methods could result in more harm than we have analyzed and should be avoided. Prior to initiation of work the Marine Corps will submit final project designs and construction methods to the Service to demonstrate that impacts from construction of the retaining wall have been minimized to the maximum extent practicable and that anticipated impacts will be consistent with those analyzed in this biological opinion. 3. The Marine Corps will monitor and report on consistency with the exempted amount or extent of take for PPM associated with the proposed action 4. The Marine Corps will implement measures to further minimize the impacts of the proposed action on PPM.

111 Mr. Bart Battista (FWS-MCBCP-15B F0796) 37 TERMS AND CONDITIONS To be exempt from the prohibitions of section 9 of the Act, the Marine Corps must comply with the following terms and conditions, which implement the reasonable and prudent measures described above. TC 1.1 TC 2.1 TC 3.1 TC 3.2 TC 4.1 Prior to initiating vegetation thinning to enhance habitat for PPM, the avian biologist will conduct a survey of the habitat enhancement area to verify that no more than four gnatcatcher territories (total) will be substantially impacted (i.e., more than 20 percent of a pairs territory will be impacted) by the enhancement activities. Surveys will be conducted within all suitable gnatcatcher habitat within the footprint of the enhancement area, and the survey will be conducted at least 60 days prior to initiation of the vegetation thinning. Prior to initiating the vegetation thinning, the Marine Corps will provide to the CFWO a map showing the distribution of gnatcatchers relative to the project footprint, and an estimate of the number of gnatcatchers territories that will be impacted by vegetation thinning. At least 14 days prior to initiation of repairs to the reservoir drainage system, the Marine Corps will submit to the CFWO the construction plans for the erosion repair retaining wall that identifies whether the erosion repair will be achieved with the construction of one or two retaining walls and the proposed method of wall installation. The plans should identify the proposed location of exclusion fencing surrounding the erosion repair footprint and identify best management practices that will be put in place to keep PPM outside the zone of construction impacts. The Marine Corps will develop a monitoring plan in coordination with the CFWO to verify that the area proposed for PPM habitat enhancement is unoccupied or only lightly occupied by PPM prior to implementation of enhancement measures. Should monitoring reveal otherwise, the Marine Corps will work with the PPM monitoring biologist and CFWO to identify an alternative habitat enhancement area that is unoccupied or only lightly occupied by PPM. The Marine Corps will submit reports to the CFWO documenting the observed success of restoration and enhancement activities within the project area and results from associated PPM monitoring. The frequency of these reports and specific information to be included will be described in the final plans for these activities, which will be submitted to the CFWO for review and approval at least 60 days prior to initiating activities that could affect PPM or PPM occupied habitat. To minimize the amount of habitat disturbance associated with reservoir repairs and stockpiling of soils at South San Mateo, the Marine Corps will have the construction contractor prepare a plan that identifies all vehicle access routes, equipment staging areas, and soil stockpile locations that will be used in the vicinity of the project. The purpose of this plan will be to reduce the project footprint as much as possible and to restrict equipment staging and soil stockpiling to existing roads and disturbed areas. The plan will be approved by MCBCP ES, in coordination with the CFWO, prior to project impacts at South San Mateo.

112 Mr. Bart Battista (FWS-MCBCP-15B F0796) 38 TC 4.2 The Marine Corps will coordinate with the CFWO and the San Diego Zoological Society prior to initiating salvage trapping for PPM in order to devise a strategy for the capture and transfer of PPM to the San Diego Zoological Society s captive breeding facility. DISPOSITION OF SICK, INJURED, OR DEAD SPECIMENS Upon locating dead, injured, or sick individuals of threatened or endangered species, initial notification must be made to our Division of Law Enforcement in either San Diego, California, at (619) or in Torrance, California, at (310) within 3 working days. Notification should also be sent by telephone and writing to this office in Carlsbad, California, at 2177 Salk Avenue, Suite 250, Carlsbad, California 92008, (760) Written notification must be made within 5 calendar days and include the collection date and time, the location of the animal, and any other pertinent information. Care must be taken in handling sick or injured animals to ensure effective treatment and care, and in handling dead specimens to preserve biological material in the best possible state. The remains of intact specimens will be placed with educational or research institutions holding the appropriate State and Federal permits. Remains will be placed with the San Diego Natural History Museum, San Diego. Arrangements regarding proper disposition of potential museum specimens will be made with the institution by the authorized biologist prior to implementation of the action. CONSERVATION RECOMMENDATIONS Section 7(a)(1) of the Act directs Federal agencies to utilize their authorities to further the purposes of the Act by carrying out conservation programs for the benefit of endangered and threatened species. Conservation recommendations are discretionary agency activities to minimize or avoid adverse effects of a proposed action on listed species or critical habitat, to help implement recovery plans, or to develop information. We appreciate the Marine Corps efforts to work with us to avoid and minimize impacts to the PPM from the reservoir repair project and your ongoing and comprehensive efforts to monitor PPM on Camp Pendleton. However, given PPM s limited distribution, small population sizes, and remaining questions about how to manage the habitat of this species, we are concerned about ongoing impacts to PPM on Camp Pendleton from maintenance of fire breaks, infrastructure development and maintenance, and troop training activities. Therefore, we recommend that the Marine Corps continue to work on improving coordination with facilities maintenance staff, its various tenants, and easement holders and consult with the Service to address any ongoing activities that may be affecting PPM. We also recommend that the Marine Corps work to finalize and implement the Draft Pacific Pocket Mouse Endangered Species Management Plan by February of 2017 to prevent further habitat degradation and safeguard this species from extinction. REINITIATION NOTICE This concludes formal consultation on the 51 Area Reservoir project as outlined in materials submitted to us. As provided in 50 CFR reinitiation of formal consultation is required where discretionary Federal agency involvement or control over the action has been retained (or is authorized by law) and if (1) the amount or extent of incidental take is exceeded; (2) new information

113 Mr. Bart Battista (FWS-MCBCP-15B F0796) 39 reveals effects of the agency action that may affect listed species or critical habitat in a manner or to an extent not considered in this opinion; and (3) the agency action is subsequently modified in a manner that causes an effect to the listed species or critical habitat not considered in this opinion; or (4) a new species is listed or critical habitat designated that may be affected by the action. In instances where the amount or extent of incidental take is exceeded, any operations causing such take must cease pending reinitiation. We appreciate your coordination on this project. If you have any questions regarding this consultation, please contact William Miller at , extension 206. Sincerely, G. Mendel Stewart Field Supervisor

114 Mr. Bart Battista (FWS-MCBCP-15B F0796) 40 LITERATURE CITED Atwood, J.L The United States distribution of the California black-tailed gnatcatcher. Western Birds 11: Atwood, J.L Subspecies limits and geographic patterns of morphological variation in California gnatcatchers (Polioptila californica). Bulletin of the Southern California Academy of Science 90: Atwood, J.L A maximum estimate of the California gnatcatcher s population size in the United States. Western Birds 23: 1 9. Atwood, J.L., S.H. Tsai, C.H. Reynolds, and M.R. Fugagli. 1998a. Distribution and population size of California gnatcatchers on the Palos Verde Peninsula, Western Birds 29: Atwood, J.L., S.H. Tsai, C.H. Reynolds, J.C. Luttrell, and M.R. Fugagli. 1998b. Factors affecting estimates of California Gnatcatcher territory size. Western Birds 29: Atwood, J.L., C.H. Reynolds, and S. Grove Distribution of California gnatcatchers on Camp Pendleton Marine Corps Base. Unpublished report, prepared for U.S. Marine Corps, Oceanside, California (Contract No. M C-0035); Manomet Center for Conservation Sciences, Massachusetts. June 30, pp. Bantle J.A Effects of mechanical vibrations on the growth and development of mouse embryos. Aerospace Med 42: Brehme, C.S. and R.N. Fisher survey results for the Pacific pocket mouse: North and South San Mateo, Marine Corps Base, Camp Pendleton; with additional analyses to inform long-term monitoring design. Report prepared for AC/S MCBCP ES, Marine Corps Base, Camp Pendleton. 40 pp. Brehme, C.S., T.A. Matsuda, L.R. Albert, B.H. Smith, and R.N. Fisher Pacific Pocket Mouse Studies 2010, MCB, Camp Pendleton; Discovery and Population Mapping-- with additional studies for scent effects on detectability and surveys for the Argentine ant at North and South San Mateo. Marine Corps Base, Camp Pendleton. Prepared for AC/S MCBCP ES, Marine Corps Base, Camp Pendleton. 40p. Brehme, C.S., J. Sebes, T.A. Matsuda, D. Clark, and R.N. Fisher DRAFT: MCBCP Pacific Pocket Mouse Monitoring Results for 2013 and Multi-year Trend Analysis from 2012 to Prepared for AC/S MCBCP ES, Marine Corps Base, Camp Pendleton. 69p. Brehme, C.S., J.A. Tracey, and R.N. Fisher in collaboration with Burnham, K., P. Meserve, W. Spencer, D. Deutschman, W.B. Miller, and M. Pavelka Pacific Pocket Mouse Monitoring Protocol for Marine Corps Base Camp Pendleton. Prepared for Wildlife Management Branch, AC/S MCBCP ES, Marine Corps Base Camp Pendleton. 52pp.

115 Mr. Bart Battista (FWS-MCBCP-15B F0796) 41 Brehme, C.S., J.A. Tracey, J. Sebes, T.A. Matsuda, D. Clark, and R.N. Fisher Pacific Pocket Mouse Monitoring 2012, MCB, Camp Pendleton. Prepared for AC/S MCBCP ES, Marine Corps Base, Camp Pendleton. 43p. DRAFT Brylski, P., W.B. Miller, S. Dodd, and S. Montgomery Pilot Monitoring Project for the Pacific Pocket Mouse, 2008, CNLM Dana Point Preserve, Orange County, California. Unpublished Report. Prepared for the Center of Natural Lands Management, Capistrano Beach, California. 35pp. Brylski, P., W.B. Miller, S. Dodd, and S. Montgomery Addendum to the pilot monitoring project for the Pacific Pocket Mouse, 2009, 2008, CNLM Dana Point Preserve, Orange County, California. Unpublished Report. Prepared for the Center of Natural Lands Management, Capistrano Beach, California. 38 pp. Carranza, L.A CNLM Annual Report of Management Activities for the Fiscal Year on the Dana Point Preserve Owned and Managed by CNLM (CNLM No. S033). Unpublished report prepared for the U.S. Fish and Wildlife Carlsbad Fish and Wildlife Office, Carlsbad, California. Dooling, R.J. and A.N. Popper The effects of highway noise on birds. Prepared by Environmental BioAcoustics LLC for the California Department of Transportation, Sacramento, California. Erickson, R Pacific pocket mouse (Perognathus longimembris pacificus). Draft manuscript to be included in Endangered Rodents of the World, to be published by the Species Survival Commission of the International Union for the Conservation of Nature and Natural Resources (IUCN). Flake, L.D. and C.D. Jorgensen Invasion of a trapped-out southern Nevada habitat by Perognathus longimembris. The Great Basin Naturalist 29(3): French, N., B. Maza, H.O. Hill, A.P. Aschwanden, and H.W. Kaaz A population study of irradiated desert rodents. Ecological Monographs 44: Griffiths Wildlife Biology Survey and breeding study of the California gnatcatcher and coastal cactus wren at Marine Corps Base Camp Pendleton in 1993 and Unpublished report, prepared for U.S. Marine Corps Camp Pendleton, California (Contract No. M C- 0079). September 25, pp. Griffiths Wildlife Biology The status of the California gnatcatcher at Marine Corps Base Camp Pendleton in Unpublished report prepared for U.S. Marine Corps Base, Camp Pendleton, AC/S MCBCP ES (Contract No. M C-0024). June 8, Griffiths Wildlife Biology The status of the California gnatcatcher at Marine Corps Base Camp Pendleton in Unpublished report prepared for U.S. Marine Corps Base, Camp Pendleton, AC/S MCBCP ES (Contract No. M T-0112). March 15, 2008.

116 Mr. Bart Battista (FWS-MCBCP-15B F0796) 42 Hall, E The Mammals of North America. Second edition. John Wiley and Sons, New York. Harmsworth Associates California Gnatcatcher and Coastal Cactus Wren Monitoring Report for the San Joaquin Hills Burn Area Unpublished report prepared for the Transportation Corridor Agencies, Santa Ana, California. Kenagy, G Daily and seasonal patterns of activity and energetics in a heteromyid rodent community. Ecology 54: [MBA and LSA] Michael Brandman Associates and LSA Associates Results of focused surveys for the Pacific pocket mouse Foothill Transportation Corridor-South. Unpublished report prepared for Foothill/Eastern Transportation Corridor Agency, Santa Ana, California, February pp. + Appendices. Natural Resources Assessment, Inc Presence/absence trapping studies for the Pacific pocket mouse on the Foothill/Eastern Transportation Corridor South. Unpublished report prepared for PandD Consultants, San Diego, California. November pp. + appendix. [Ogden] Ogden Environmental and Energy Services Pacific pocket mouse survey, Phase III, Marine Corps Base, Camp Pendleton. Unpublished report. Prepared for Assistant Chief of Staff, MCBCP ES. November. 46 pp. Preston, K.L., P.J. Mock, M.A. Grishaver, E.A. Bailey and D.F. King California gnatcatcher territorial behavior. Western Birds 29: Rubin C.T., E. Capilla, Y.K. Luu, B. Busa, H. Crawford, D.J. Nolan, V. Mittal, C.J. Rosen, J.E. Pessin, S. Judex Adipogenesis is inhibited by brief, daily exposure to highfrequency, extremely low-magnitude mechanical signals. Proc Natl Acad Sci USA 104: Sackler A.M. and A.S. Weltman Effects of vibration on the endocrine system of male and female rats. Aerosp Med 37: Seidel H. and M.J. Griffin Whole-body vibration, Stellman J. M., editor. Encyclopedia of occupational health and safety, vol 2. Switzerland (Geneva): International Labor Office. p Shier, D. M Behavioral ecology and translocation of the endangered Pacific little pocket mouse (Perognathus longimembris pacificus). Interagency Agreement between U.S. Fish and Wildlife Service.and CRES, Zoological Society of San Diego. Shier, D.M Behavioral ecology and translocation of the endangered Pacific little pocket mouse (Perognathus longimembris pacificus): Draft Annual Report for January 2009-December Unpublished report prepared for the U.S. Fish and Wildlife Service, Carlsbad, California.

117 Mr. Bart Battista (FWS-MCBCP-15B F0796) 43 Shier, D.M Captive Breeding, Anti-Predator Behavior and Reintroduction of the Pacific Pocket Mouse (Perognathus longimembris pacificus): Annual Report for the Period January 2013-December Unpublished report prepared for the California Department of Fish and Wildlife(San Diego) and U. S. Fish and Wildlife Service, (Carlsbad), California. Shier, D.M. and R. Swaisgood Section 6 Project Statement, Federal Endangered Species Act Traditional Section 6 Grant, California Department of Fish and Wildlife. Prepared for California Department of Fish and Wildlife, Sacramento, California. [Tetra Tech] Tetra Tech, Inc Coastal California gnatcatcher (Polioptila californica californica) general inventory and breeding status assessment study on Marine Corps Base Camp Pendleton, California. Unpublished report prepared for Assistant Chief of Staff, MCBCP ES, Marine Corps Base Camp Pendleton, California. [Tetra Tech] Tetra Tech, Inc Coastal California gnatcatcher general inventory and breeding status assessment study on Marine Corps Base Camp Pendleton, California. Unpublished report prepared for United States Marine Corps Wildlife Branch, Assistant Chief of Staff MCBCP ES, Marine Corps Base Camp Pendleton, California. Toraason M.A., D.W. Badger, and G.L. Wright Gastrointestinal response in rats to vibration and restraint. Environ Res 23: doi: / (80) [Service] U.S. Fish and Wildlife Service Endangered and threatened wildlife and plants; Determination of threatened status for the Coastal California Gnatcatcher; Final Rule. Federal Register 58: [Service] U.S. Fish and Wildlife Service Recovery Plan for the Pacific Pocket Mouse (Perognathus logimembris pacificus). U.S. Fish and Wildlife Service, Portland, Oregon. 112 pp Service 2010a gnatcatcher 5-year review [Service] U.S. Fish and Wildlife Service. 1999a. Surveys for the Pacific pocket mouse (Perognathus longimembris pacificus) on Marine Corps Base Camp Pendleton, California, Unpublished report prepared by the U. S. Fish and Wildlife Service for the Marine Corps Base Camp Pendleton, AC/S MCBCP ES under contract M MP pp. plus addendum. [Service] U.S. Fish and Wildlife Service Monitoring of the Pacific pocket mouse (Perognathus longimembris pacificus) population in the Oscar One Training Area on Marine Corps Base Camp Pendleton: Unpublished report prepared by the U.S. Fish and Wildlife Service for the Marine Corps Base Camp Pendleton, AC/S MCBCP ES under contract M MP pp. [Service] U.S. Fish and Wildlife Service Pacific pocket mouse (Perognathus longimembris pacificus) 5-Year Review: Summary and evaluation. 86 pp. [Service] U.S. Fish and Wildlife Service Reinitiation of Formal Section 7 Consultation on the Basewide Water Infrastructure Project for the MILCON P-1044 CERS 2 Amendments,

118 Mr. Bart Battista (FWS-MCBCP-15B F0796) 44 Marine Corps Base Camp Pendleton, San Diego County, California (FWS-MCBCP- 12B F0058-R004), May 7, Williams, D.F Wildlife Management Division Administrative Report 86-1:Mammalian species of special concern in California. State of California, The Resources Agency, Department of Fish and Game, Sacramento, California. PP. i-112. Winchell, C.S. and P.F. Doherty Using California gnatcatcher to test underlying models of habitat conservation plans. Journal of Wildlife Management 72: Personal Communications: Brehme, C. and R. Fisher U.S. Geological Survey Biological Resources Discipline, Western Ecological Research Center. Memorandum attached to correspondence sent to Sherri Sullivan, U. S. Marine Corps MCBCP ES Consultation Section, Marine Corps Base Camp Pendleton, Camp Pendleton, California. Subject: SSM Pipeline project and PPM; USGS comments with regard to impacts to the Pacific pocket mouse. Brehme, C U.S. Geological Survey, electronic mail with attachments to W. B. Miller, U.S. Fish and Wildlife Service. December 28, Brehme, C U.S. Geological Survey, electronic mail with attachment to W. B. Miller, U.S. Fish and Wildlife Service. January 23, 2016.

119 Mr. Bart Battista (FWS-MCBCP-15B F0796) 45 Figure 1. Present impacts to Area 51.

120 Mr. Bart Battista (FWS-MCBCP-15B F0796) 46 Figure 2. Past impacts to Area 51.