NOTICE OF INTENT TO ADOPT A (MITIGATED) NEGATIVE DECLARATION California Environmental Quality Act

NOTCE OF NTENT TO ADOPT A (MTGATED) NEGATVE DECLARATON Calforna Envronmental Qualty Act Pursuant to the State of Calforna Publc Resources Code and the "Gudelnes for mplementaton of the Calforna Envronmental Qualty Ad. of 1970 as amended to date, ths s to advse you that the Cty of Laguna Beach has prepared an ntal Study for the followng project. ROJECT rch Beach Heghts Fuel Modfcaton Plan (Oro Canyon area) CTY OF LAGUNA BEACH 505 Forest Avenue Laguna beach, CA 92651 PHONE: (949) 497 0700 FA: (949) 497 0771 OCATON/ADDRESS rch Beach Heghts area south ofdel Mar A venue, west of Santa Ana Street and east of Oro Street, extendng south to Cortez venue. PPLCATON NUMBERS esgn Revew, DR 11-017 and Coastal Development Permt, CDP 11-07 ENERAL PLAN DESGNATON AND ZONNG eneral Plan Desgnatons are VLD, Very Low Densty and POS, Permanent Open Space; Zonng s RABHSP (R-, Resdental ow Densty, Arch Beach Heghts Specfc Plan) and OSC, Open Space Conservaton. ROJECT APPLCANT ty of Laguna Beach Fre Department ESCRPTON OF PROJECT 'he proposed fuel modfcaton would be conducted on an approxmately 6.9 acre ste that s located n an unmproved "paper street rea" of the Arch Beach Heghts Specfc Plan area, and would extend from the edge of exstng resdences approxmately 150 feet to the undeveloped canyon. Fuel modfcaton would be done by hand and would requre approxmately 50% thnnng to acheve the esred level offrre safety. To mnmze mpacts to natve vegetaton, hand thnnng would follow a thnnng herarchy recommended 1 the September 2010 Bologcal Techncal Report prepared by Glenn Lukos Assocates. Thnnng would focus on the removal of on-natve speces and dead or dyng materal; thnnng of woody natve speces would only occur f the 50% threshold s not :heved through removal ofthe dead and non-natve vegetaton. Hand removal of pampas grass and other ornamental vegetaton that,not consdered frre retardant would also occur. NVRONMENTAL SETTNG roject ste s located n an unmproved, steeply sloped canyon surrounded on three sdes by densely developed resdental ;:ghborhoods. Sngle-famly homes are located to the north, east, and west. The Arch Beach Heghts Specfc Plan area has been eveloped wth sngle-famly homes on small lots (25'xl00') and only has two routes for access andlor evacuaton; t s an area where re hazards are a crtcal concern as dscussed n the Cty's Safety Element. A watercourse, located at the bottom of the canyon, has een colonzed by the nvasve, non-natve pampas grass. Throughout portons of the ste, an exstng fuel modfcaton area consstng f a band of prmarly non-natve and ornamental vegetaton separates the resdences from the natve habtat. Natve habtat on the :oject ste s composed of chaparral, coastal sage scrub, and a transtonal state between the two as the domnant vegetaton )mmunty. ECLARATON ased on the ntal Study dated, stafhas determned: [gj Ths project does not have the potental to substantally degrade the qualty of the envronment; substantally reduce the habtat of a fsh or wldlfe speces; cause a fsh or wldlfe populaton to drop below self-sustanng levels; threaten to elmnate a plant or anmal communty; substantally reduce the number or restrct the range of an endangered rare or threatened speces; or elmnate mportant examples of major perods ofcalforna hstory or prehstory. 'N.2 HJ7) Page 1 of4

::mce OF NTENT TO ADOPT A (MTGATED) NEGATVE DECLARATON "ch Beach Heghts Fuel Modfcaton Plan (Oro Canyon area) muary 21,2011 [8J Ths project does not have the potental to acheve short-term envronmental goals to the dsadvantage of long-term envronmental goals. [8J Ths project does not have possble envronmental effects that are ndvdually lmted but cumulatvely consderable. ("Cumulatvely consderable" means that the ncremental effects of the ndvdual project are sgnfcant when vewed n connecton wth the effects ofpast projects, the effects ofcurrent projects and the effects of probable future projects.) [8J Ths project wll not have envronmental effects that wll cause substantal adverse effect on human bengs, ether drectly or ndrectly. The aforementoned fndngs are contngent upon the followng mtgaton measures (f ndcated) whch have been ncorporated nto ths project: [8J See attached mtgaton measures. D None requred. UBLC COMMENT PEROD muary 26, 2011 to February 24, 2011, the publc and all affected agences are hereby nvted to revew the Negatve eclaraton and ntal Study wth mtgaton measures and submt wrtten comments. Such comments may be submtted ror to or durng the Desgn Revew Board hearng(s). UBLC HEARNG DATE: ESGN REVEW BOARD MEETNG 00 p.m. - February 24,2011 5 Forest Avenue, Laguna Beach, CA ouncl Chamber CUMENT AVALABLTY he Negatve Declaraton and ntal Study and other supportng envronmental documents are avalable for publc revew at e Cty of Laguna Beach, Communty Development Department, located at 505 Forest Avenue, Cty Hall, between the hours 8:00 a.m. and 5:00 p.m., Monday through Frday. TGATED NEGATVE DECLARATON PREPARED BY ty of Laguna Beach Contact: Kathy Lottes 5 Forest Avenue Ttle: Project Planner aguna Beach, CA 92651 Telephone: (949) 497-0700 Fax: (949) 497-0771 Date (:...-...;;;.-=---{_-"--'11=--- ~OMMENTS DUE BY February 24, 2011 e attached Mtgated Negatve Declaraton dated 1-21-2011 s beng referred to your agency/cty department for revew and mment. Your wrtten comments should be receved pror to, or be submtted verbally durng the Publc Hearng. fyou have any estons, please contact the Contact Person above. ev, 2 1-{)7) Page 2 of4

>TCE OF NTENT TO ADOPT A (MTGATED) NEGATVE DECLARATON ch Beach Heghts Fuel Modfcaton Plan (Oro Canyon area) uary 21,2011 TTACHMENTS egatve Declaraton and ntal Study PPORTNG ENVRONMENTAL DOCUMENTS 1 Cty of Laguna Beach Land Use Element 2 Cty of Laguna Beach Open Space and Conservaton Element 3 Cty of Laguna Beach Safety Element 4 Cty oflaguna Beach Zonng Map 5 Cty of Laguna Beach Muncpal Code (Ttle 7, Ttle 16, and Ttle 25) 6 September 2010, Bologcal Techncal Report for Proposed Fuel Modfcaton Zone n the Arch Beach Heghts Area of Laguna Beach, Orange County, Calforna.; Glenn Lukos Assocates. December 9,2010 Memorandum, Supplemental nformaton pertanng to bologcal resources wthn the proposed Arch Beach Heghts Fuel Modfcaton Zone; Glenn Lukos Assocates. 7 July 22, 2010, Submttal Requrements of Coastal Calforna Gnatcatcher Surveys for the Proposed Fuel Modfcaton Zones Between Nyes Place and Damond Street n Laguna Beach, Orange County, Calforna; Glenn Lukos Assocates. 8 May 28,2009, Geotechncal Evaluaton of Potental Slope Stablty mpacts, Proposed Arch Beach Heghts Fuel Modfcaton Areas 1 and 2, Laguna Beach, Calforna; Geofrrm. December 15,2010 Letter, Supplemental Geotechncal Comments Regardng Proposed Arch Beach Heghts Fuel Modfcaton Areas 1 and 2; Geofrrm. 9 Cal-WC, Calforna nvasve Plant Councl, Weed Workers Handbook, Pampas Grass and Jubata Grass, accessed onlne November 2010. 10 FEMA, FRM Maps 11 Drect communcaton wth Dr. Steven D. Colome, envronmental health scentst, 2010. 12 Washngton State Department oftransportaton, Glyphosate, Roadsde Vegetaton Management Herbcde Fact Sheet, accessed onlne December 2010. Patrck R. Durkn, Glyphosate - Human Health and Ecologcal Rsk Assessment, Fnal Report prepared for USDA Forest Servce, 2003. 13 Cty of Laguna Beach Transportaton Element 14 January, 2011 Fuel Modfcaton Plan 15 1997 State ofcalforna Sesmc Hazard Zones Map, Laguna Beach Quadrangle 16 State of Calforna, Department oftoxc Substances Control, EnvroStor, accessed onlne December 2010 17 Cty of Laguna Beach Nose Element 18 19 Cty oflaguna Beach Landscape and Scenc Hghways Resource Document 2010 Recommended Draft, Orange County Fre Hazard Severty Zones n LRA (Local Responsblty Area), State of Calforna Department of Forestry and Fre Protecton; http://www.fre.ca.gov/fre preventonlfhsz maps/fllsz maps orange.phd V. 2-1-07) Page 3 of4

'TCE OF NTENT TO ADOPT A (MTGATED) NEGATVE DECLARATON ch Beach Heghts Fuel Modfcaton Plan (Oro Canyon area) nuary21,2011 STRBUTON LST TV DEPARTMENTS 181 Communty Development 181 Fre o Marne Safety o Polce 181 Publc Works o Recreaton 181 Water Qualty :DERAL o Occupatonal Safety and Health Admnstraton rate o Ar Resources Board 181 Calforna Coastal Commsson Calforna Coastal Conservancy Department of Conservaton o Department of Fsh and Game - Regon 5 o Department of Forestry and Fre Protecton o Department of Health and Drnkng Water EGONAL o San Dego Regonal Water Qualty Control Board UNTY ~ Orange County Clerk-Recorder o Orange County Envronmental Health Department 181 Orange County Fre Department o Orange County Flood Control Dstrct CAL Also Water Management Agency Cty of Also Vejo Cty of Dana Pont o Cty of rvne o Cty of Laguna Hlls ~ Cty of Laguna Nguel o Cty of Laguna Woods llltes Cox Dgtal Cable San Dego Gas & Electrc Southern Calforna Edson Southern Calforna Gas Company o Verzon o US Anny Corps of Engneers o US Envronmental Protecton Agency o Department of Housng and Communty Development o Department of Parks and Recreaton o Department of Transportaton Dstrct 12 (Caltrans) Department of Toxc Substances Control o Department of Water Resources o Governor's Offce of Plannng and Research o South Coast Ar Qualty Management Dstrct o Orange County ntegrated Waste Management Department o Orange County Local Agency Fonnaton Commsson o Orange County Harbors Beaches and Parks Cty of Newport Beach Laguna Beach Chamber of Commerce Laguna Beach County Water Dstrct Laguna Beach ndependent Laguna Beach Unfed School Dstrct o Laguna Beach Vstor's Bureau ~ Laguna Beach Coastlne Plot 181 US Fsh and Wldlfe Servce ntegrated Waste Management Board Natve Amercan Hertage Commsson Offce of Emergency Servces Offce of Hstorc Preservaton o Resources Agency o Sesmc Safety Commsson ~ State Clearnghouse o State Lands Commsson o State Water Resources Control Board o Southern Calfoma Assocaton of Governments ~ Orange County Communty Development o Orange County Publc Facltes & Resources Department Laguna News-Post Moulton Nguel Water Dstrct South Coast Water Dstrct o South Orange County Wastewater Authorty EPEDTE SUBMTTAL OF YOUR COMMENTS, YOU MAY RESPOND BY FACSMLE TO (949) 497-0771 Ths Agency/Cty Department has comments, see attached. o Ths Agency/Cty Department has no comments. AME OF AGENCY/CTY DEPARTMENT GNATURE OF REPRESENTATVE DATE v.2-j.(l7) Page 4 of4

NTAL ENVRONMENTAL STUDY CHECKLST CTY OF LAGUNA BEACH, CALFORNA 1. Project Ttle: Fuel Modfcaton Plan for Arch Beach Heghts (Oro Canyon area) 2. Lead Agency Name and Address: Cty oflaguna Beach Fre Department 505 Forest Avenue Laguna Beach, Calforna 92651 3. Contact Person and Phone Number: Kathy Lottes at (949) 497-0700. 4. Project Locaton: Arch Beach Heghts area south of Del Mar Avenue, west of Santa Ana Street and east of Oro Street, extendng south to Cortez Avenue. See attached Regonal Map, Vcnty Map and Ste Plan (Exhbts 1-3). 5. Project Sponsor's Name and Address: Cty of Laguna Beach Fre Department, 505 Forest A venue, Laguna Beach, CA 92651 6. General Plan Desgnaton: The General Plan desgnaton for most parcels wthn the project ste s VLD, Very Low Densty; however, a handful of cty-owned parcels are desgnated as POS, Permanent Open Space. 7. Zonng: Most parcels wthn the project ste are zoned RABHSP (R-l, Resdental Low Densty, Arch Beach Heghts Specfc Plan); however, a handful of cty-owned parcels are zoned OSC, Open Space Conservaton. 8. Descrpton ofthe Project: The Cty of Laguna Beach s proposng to establsh a fuel modfcaton area n an unmproved, steeply sloped canyon (Oro Canyon) that s adjacent to a densely developed resdental neghborhood; the proposed fuel modfcaton and adjacent resdental areas are all located wthn the Arch Beach Heghts Specfc Plan Area. The fuel modfcaton area s located n an unmproved "paper street area" that s not easly accessed from exstng streets; t s drectly north of, and abuts, the newly establshed neghborhood vew and nature tral park located just south of Cortez and Quvera (Arch Beach Heghts Vew Park) where fuel modfcaton was recently conducted. Access/stagng for fuel modfcaton crews would be taken from the sewer pump-staton access road located to the south of the new vew park. The project ste contans 6.9 acres wth steep slopes typcally near a 2: 1 (horzontal:vertcal) rato wth small solated areas near a 1: 1 rato. A pump staton, paved access drve, and bured nfrastructure lnes are adjacent to, and may encroach nto, the project ste. A mapped watercourse, located at the bottom of the canyon, has been colonzed by the nvasve, non-natve pampas grass whch covers an area approxmately 18 feet wde by 735 long for a total of 0.30 acre. Throughout portons of the ste, an exstng fuel modfcaton area consstng of a band of prmarly non-natve and ornamental vegetaton separates the resdences from the natve habtat. Natve habtat wthn PAGE 1

the project ste s composed of chaparral, coastal sage scrub, and a transtonal state between the two as the domnant vegetaton communty. The goal of the proposed fuel reducton s to provde a defensble space adjacent to homes n an effort to enhance resdents' ablty to evacuate and survve a severe fre event. As proposed, the fuel reducton area would extend from the edge of exstng resdences approxmately 150 feet nto the undeveloped canyon. Reducton of the exstng vegetaton would be done by hand, and would requre approxmately 50% thnnng to acheve the desred level of fre safety. Hand thnnng would nvolve the removal of all dead materal and non-natve speces; possble trmmng of woody natve speces would occur only f the 50% thnnng s not acheved through removal ofthe dead and non-natve vegetaton. ntally, the fuel modfcaton could take up to fve months (from September through January) of hand crew work due to the heavy vegetaton cover that ncludes substantal dead and dyng vegetatve materal Mantenance of the fuel modfcaton would lkely requre a return wth hand crews once every 1-2 years, but would be a much less ntensve effort (estmated to nvolve 1-3 weeks ofwork). The Cty would also conduct hand removal of the nvasve pampas grass n accordance wth treatment optons (ncludng the use of Glyphosate) accepted by the Calforna nvasve Plant Councl and Calforna Natve Plant Socety. n addton, ornamental vegetaton located n the exstng fuel modfcaton area (between the resdences and natve vegetaton) that s not fre retardant would also be removed. No gradng would be conducted, and no nfrastructure, hardscape or other mprovements are proposed. The project would not result n the creaton of new buldng stes nor ncrease the opportunty for expanson ofexstng development. As dscussed n the General Plan Safety Element, the entre Cty s desgnated as a Very Hgh Fre Hazard Severty Zone. Ths State of Calforna desgnaton, whch s based on fuel load, weather, slopes and housng densty, has been appled to the 15 countes n Calforna that are most vulnerable to wldland fre rsk. The need to balance fre safety wth protecton of natve vegetaton s thoroughly dscussed n Topc 4 (Fre Hazards) of the Safety Element. See also the 2010 Recommended Draft Fre Hazard Severty Zones Map produced by the State of Calforna. The Arch Beach Heghts Area, although developed wth sngle-famly homes, s denser than other sngle-famly resdental neghborhoods n Laguna Beach due to the number of homes developed on very narrow lots (25' x 100'), and has lmted access and evacuaton routes. The Arch Beach Heghts area s dentfed as havng a crtcal development pattern wth respect to fre by the General Plan Safety Element (Topc 4: Fre Hazards). Accordng to the Bologcal Resource Values Map n the General Plan Open Space/Conservaton Element, a "Hgh Value" habtat area s dentfed wthn the project ste, and therefore, an onste bologcal assessment was prepared by Glenn Lukos Assocates. Ths bologcal assessment The bologcal assessment results n classfcaton of the Arch Beach Heghts project ste as "Moderate Value" habtat because the ste s bascally a habtat pennsula surrounded by urban development on three sdes; the southwestern extent s bsected by an access road resultng n margnal fragmentaton, and the entre area s surrounded by ether ornamental or dsturbed natve vegetaton. As noted on the Map, the pampas grass colony does not currently meet the crtera for PAGE 2

"Moderate Value" habtat; however, removal of the pampas grass would allow regrowth of natve vegetaton that, n turn, would meet those crtera. A small porton of the ste s located wthn the Calforna Coastal Commsson appeal jursdcton based on the presence of "lands wthn 100 feet of streams and wetlands... " and, the bologst concludes that the appeal jursdcton area would be desgnated by the Coastal commsson as ESHA solely based on ts geographc locaton and not the qualty ofhabtat contaned n the area. Because the project ste s located n an area wth steep slopes and s n proxmty to a sesmc hazard landslde area (as ndcated n the Cty'S Safety Element), a geotechncal report was prepared by Geofrm. Ths report evaluated slope stablty ssues wthn the fuel modfcaton area and provded mtgatng gudelnes. mplementaton of the mtgatng gudelnes would nclude: lmtng fuel modfcaton work to canopy thnnng (n order to mnmze damage to exstng root systems), and applyng surfcal amendments to the sol to mnmze sol eroson. These measures. would reduce potental for shallow slppage, and debrs and/or mudflows n slopng envronment. 9. Surroundng Land Uses and Settng: The surroundng land use s sngle-famly resdental to the north, east, and west; the undeveloped area of Oro Canyon extends to the south. The rdge overlookng Also Canyon (concdent wth the Cty boundary) s located just easterly of Balboa Avenue approxmately 600 feet from the project ste. 10. Other publc agences whose approval s requred (e.g. permts, fnancng approval, or partcpaton agreement): The proposed project requres Desgn Revew approval and a Coastal Development Permt, both of whch wll be consdered at a Cty Desgn Revew Board Hearng. Snce a small porton of the project ste occurs wthn the appeal jursdcton of the Calforna Coastal Commsson, the Coastal Development Permt s appealable to the Coastal Commsson upon exhauston of cty revew procedures. ATTACHMENTS: Regonal Map Vcnty Map Ste Plan PAGE 3

ENVRONMENTAL FACTORS POTENTALLY AFFECTED: The envronmental factors checked below would be potentally affected by ths project, nvolvng at least one mpact that s a "Potentally mpact" as ndcated by the checklst on the followng pages. Aesthetcs Ar Qualty Bologcal Resources Cultural Resources Geology / Sols Greenhouse Gas Emssons Hazards & Hazardous Materals Hydrology Water Qualty Land Use / Plannng Mneral Resources Nose Populaton / Housng! Publc Servces Utltes / Servce Systems Recreaton. Mandatory Fndngs of Sgnfcance Transportaton / Traffc DETERMNATON: On the bass ofths ntal evaluaton: fmd that the proposed project COULD NOT have a sgnfcant effect on the envronment, and a NEGATVE DECLARATON wll be prepared. fnd that although the proposed project could have a sgnfcant effect on the envronment, there wll not be a sgnfcant effect n ths case because revsons n the project have been made by or agreed to by the project proponent. A MTGATED NEGATVE DECLARATON wll be prepared. fmd that the proposed project MA Y have a sgnfcant effect on the envronment, and an ENVRONMENTAL MPACT REPORT s requred.! fnd that the proposed project MAY have a "potentally sgnfcant mpact" or "potentally sgnfcant unless mtgated" mpact on the envronment, but at least one effect (1) has been adequately analyzed n an earler document pursuant to applcable legal standards, and (2) has been addressed by mtgaton measures based on the earler analyss as descrbed on attached sheets. An ENVRONMENTAL MPACT REPORT s requred, but t must analyze only the effects that reman to be addressed. fnd that although the proposed project could have a sgnfcant effect on the envronment, because all potentally sgnfcant effects (a) have been analyzed n an earler ER or NEGATVE DECLARATON pursuant to applcable standards, and (b) have been avoded or mtgated pursuant to that earler ER or NEGATVE DECLARATON, ncludng revsons or mtgaton measures that are mposed upon the proposed project, nothng further s requred. S~ Date Kathryn Lottes Name PAGE 4

Adapted from USGS Laguna Beach quadrangle = o 2 4 6 NORTH MLES

Cf) UJ < U o ~ «Cf) o ~ ~ -- Z Z UJ -- (J) Adapted from USGS Laguna Beach, CA quadrangle : NORTH o 1,000 2,000 3,000 FEET

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact 1. AESTHETCS Would the project: a) Have a substantal adverse effect on a scenc vsta? 2 Publc vews of the canyon and hllsdes n the project ste wll reman avalable; no encroachment or reducton of the exstng vewshed would occur. Publc vews from the new Arch Beach Heghts Vew Park would reman avalable wth no encroachments. Thnnng of the exstng vegetaton would modfy the overall appearance of the project ste; : however, thnnng would be lmted to 50% reducton of the vegetaton cover and would focus on removal of nonnatve speces and dead plant materal whle retanng as much of the lvng, natve vegetaton as possble. Therefore, vsual mpacts to publc vews are mnmzed to less than sgnfcant. See l(c), and also 3(a). b) Substantally damage scenc resources, ncludng, but not lmted to, trees, rock outcroppngs or 2 hstorc buldngs wthn a scenc hghway? The project ste s not vsble from a scenc hghway. No mpacts to scenc hghway resources are antcpated as a result of the project. PAGES

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less.Than mpact No mpact c) Substantally degrade the exstng vsual character or qualty ofthe ste and ts surroundngs? 3,6,18 x As noted n the Bologcal Techncal Report, portons of the ste consst of prmarly non-natve and ornamental vegetaton whch separate exstng resdences from the natve habtat. The largest area of non-natves and ornamentals s found on the western sde of tbe project ste, prmarly located down slope from the homes on Oro Street. The proposed fuel modfcaton would nclude those areas of ornamental vegetaton, some or all of whch were presumably planted by a homeowner, and these ornamentals may provde aesthetc screenng and prvacy for those homeowners. Due to the sgnfcant fre rsk and the need to create defensble space adjacent to bomes, fuel modfcaton n the areas of non-natves and ornamentals would result n the removal of plants that are ll!! on the Cty's recommended plant lst for fuel modfcaton zones. Only plants dentfed as fre resstant per the Cty's Landscape and Scenc Hghways Resource Element would reman, and non-fre retardant plants such confers (pnes, cypress, cedar, junpers), eucalyptus, acaca, bouganvllea and ornamental 'grasses would be removed. The December 2010 Memorandum from Glenn Lukos Assocates dentfes a number of areas that are contan ornamental vegetaton, and estmates the amount of ornamental coverage n those areas. Although removal of these ornamentals could potentally mpact the exstng vsual screenng condton, such mpact s determned to be less than sgnfcant due to the followng factors: Area la (behnd homes on Oro Street) conta'ns approxmately 75% ornamental cover; therefore removal of these ornamentals would result n a substantal reducton of exstng vegetaton. Although ths ornamental coverage conssts of shrubs and trees whch provde a vsual barrer for several homes, the (prvate) landscapng whch s not subject to the proposed fuel modfcaton s also tall and dense and would contnue to provde vsual screenng. Area b (behnd. homes on Oro Street, south of la) contans ornamental cover that s not as tall or as dense as compared to 1a; ths ornamental cover s also located downhll at a greater dstance from resdental structures than la, and therefore provdes a lesser degree ofvsual screenng for the adjacent homes. Area 2 (adjacent to sewer pump staton) ncludes approxmately 25% ornamentals consstng prmarly of shrubs growng below a sycamore canopy. Ths area s located near the pump staton at the bottom of the canyon; removal of these ornamentals would not mpact vsual screenng. Area 3 (adjacent to home on Del Mar) ncludes approxmately 25% ornamentals whch are mostly shrubs. n addton, tall prvate landscapng that s not subject to fuel modfcaton would contnue to provde vsual screenng. Area 4 (adjacent to Del Mar) contans approxmately 75% ornamental cover that ncludes both Eucalyptus trees and medum-szed shrubs (approxmately 4-6 feet tall). Ths area s qute small and drectly abuts Del Mar Avenue, and therefore, vsual screenng benefts are mnmal. n addton, Area 5 whch S located downhll of homes on QUlvera Street conssts of dsturbed natve habtat composed of low-growng natve vegetaton mxed wth non-natve shrubs and grasses, and provdes lttle vsual screenng for the adjacent homes. d) Create a new source ofsubstantal lght or glare, whch would adversely affect day or nghttme vews n the area? 14 x The project does not nclude lghtng and/or renectve materals; fuel modfcaton actvtes would be conducted durng the day. No lghtng or glare mpacts are antcpated. PAGE 6

ssues and Supportng nformaton Potentally Less than Less Than No mpact mpact Wth mpact ncorporated 2. AR QUALTY (Where avalable, the sgnfcance crtera establshed by the applcable ar qualty management or ar polluton control dstrct may be reled upon to make the followng determnatons.) Would the project: a) Conflct wth or obstruct mplementaton ofthe applcable ar qualty plan? 13,14 x The proposed fuel modfcaton does not change any land use or growth assumpton as forecasted by the South Coast Ar Qualty Management Dstrct (SCAQMD) n ts Ar Qualty Management Plan (AQMP). SCAQMD's growth forecast s based on the land uses descrbed n the approved General Plans throughout the ar qualty basn. To the extent that a proposed project s consstent wth land use/growth assumptons n the local jursdcton's General Plan, t s also consdered consstent wth the SCAQMD's AQMP. Such consstency mples that a project would not create any sgnfcant regonal ar qualty mpacts because those mpacts have already been antcpated wthn the framework of the regonal ar qualty plannng process. b) Volate any ar qualty standard or contrbute substantally to an exstng or projected ar qualty volaton? 11, 12, 13, 14 x The project nvolves hand-cuttng and clearng of vegetaton n a defned area. n addton to hand-cuttng tools, the crews would typcally use chan saws (powered by a 2-stroke gas engne); a gas- or desel-powered onste chpper s also proposed. Operaton ofthe chan saws and chpper would produce ar pollutants ncludng hydrocarbons, carbon monoxde, ntrogen oxde, and partculate matter. Duraton of fuel modfcaton actvty would occur over a 5-month perod, but would be lmted to daytme hours durng weekdays as dscussed n ned), and to the wnter months when ar qualty tends to be better (wth the excepton of carbon monoxde emsson levels); however, addtonal steps can be taken to reduce potental mpacts relatng to the operaton of gas- and desel-powered equpment. n addton, sprayng of an herbcde (Glyphosate) to remove the nvasve pampas grass should not occur durng weather condtons that favor spray drft nto non-targeted areas. No gradng or earth-movng s proposed, and therefore dust emssons would be less than sgnfcant. To reduce project-generated mpacts to a level of nsgnfcance, mtgaton ncludes: The use of chansaws and onste chpper shall be avoded when ground-level ozone (the man component of smog) or carbon monoxde emssons reach an unhealthy level for senstve groups (Level Orange, Ar Qualty ndex). All chansaws shall comply wth the Calforna Ar Resources Board (ARB) Ter emssons control; demonstraton of such complance shall be provded by the Cty selected contractor pror to commencement of fuel modfcaton operatons No boom sprayer applcaton of herbcde shall be permtted when wnds are greater than 5 mph; no backpack sprayer applcaton usng a wand and nozzle hood shall occur when wnds are greater than 10 mph; no wck and dauber applcatons shall occur when wnds are greater than 15 mph. c) Result n a cumulatvely consderable net ncrease ofany crtera pollutant for whch the project regon s non-attanment under an applcable federal or state ambent ar qualty standard (ncludng releasng emssons whch exceed quanttatve thresholds for ozone precursors)? See dscusson under 2(a) and 2(b). 11,13,14 x PAGE 7

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact d) Expose senstve receptors to substantal pollutant concentratons? 11,13,14 Tbe project ste s adjacent to resdental neghborhoods, however, exposure of resdents to substantal 'pollutant concentratons s not expected. As dscussed n 2(b), tbe cbansaws and chpper would not operate f the Ar Qualty ndex reacbes an unhealthy level for senstve groups. n addton, the work crew would be utlzng a small number of chansaws (estmated at 2 per hand crew) that comply wtb the ARB Ter Emssons Control; and the chpper would operate near the sewer pump staton whcb s located more tban 100-feet away fromthe closest resdence. e) Create objectonable odors affectng a substantal number ofpeople? 11,13,14 See dscusson under 2(a), 2(b) and 2(d). Although the use of chan saws and the on ste chpper mght generate some objectonable odors, mpacts are expected to be less than sgnfcant because the chan saws would comply wth ARB Ter Emssons Control, and the cbpper would operate away from resdences. PAGE 8

ssues and Supportng nformaton Potentally less than less Than No mpact mpact Wth mpact ncorporated 3. BOLOGCAL RESOURCES Would the project: a) Have a substantal adverse effect, ether drectly or through habtat modfcatons, on any speces dentfed as a canddate, senstve or specal status speces n local or regonal plans, polces, regulatons, or by the Calforna Department of Fsh and Game or U.S. Fsh and Wldlfe Servce? 2,6,7,9, 12,14 A Bologcal Techncal Report was prepared by Glenn Lukos Assocates (GLA) for the proposed project. Ths bologcal assessment was conducted to determne f any specal-status speces occur wthn the project area. Reconnassance was conducted n such a manner as to allow nspecton of the entre ste by drect observaton, ncludng the use of bnoculars for avan surveys. n addton to ste reconnassance, the assessment ncluded revew of the Calforna Natural Dversty Database (CNDDB) for the Laguna Beach Quadrangle, the 2010 Calforna Natve Plant Socety (CNPS) rare plant nventory, and the Natural Resources Conservaton Servce (NRCS) sol survey for Laguna Beach. Whle none of the federally- or state-lsted anmal speces were observed, the Calforna gnatcatcher does have the potental to occur on the project ste due to the presence of coastal sage scrub. Protocol surveys for the Calforna gnatcatcher were conducted on May 14, May 21, May 28, June 4, June 11, and June 18, 2010; all surveys were conducted by GLA bologst Kevn Lvergood (TE-72638-0) durng the mornng hours and completed before 12:00 P.M. Temperatures ranged from 58 degrees Fahrenhet to 72 degrees Fahrenhet and wnd speed ranged from 0-7 mles per hour durng the surveys. All areas of sutable habtat were surveyed on foot by walkng slowly and methodcally. Taped vocalzatons and "pshng" sounds were utlzed to elct a response from gnatcatchers. However, no gnatcatchers were observed wthn or adjacent to the study area durng the surveys. No specal-status speces were dentfed wthn the proposed fuel modfcaton area; however, two specal-status habtats are supported wthn the project ste: coastal sage scrub and southern martme scrub. The Bologcal Techncal Report recommends mtgaton to mnmze potental mpacts wthn specal-status habtats. To mtgate potental project mpacts to a level of nsgnfcance, the project would be requred to mplement the followng mtgaton measures: To the extent practcable, vegetaton thnnng wthn coastal sage scrub and chaparral habtats should be lmted to the wnter months (September 1 - January 30) outsde of the grownglbloomng season n order to avod mpacts to specal-status plants. However, f seasonal fre condtons warrant and fuel modfcaton actvtes are requred durng the grownglbloomng season (February 1 - August 30), areas known to support or have potental to support bg- leaved crown beard, ntermedate marposa lly or other specal-status speces should be dentfed n the feld by a bologst pror to commencement of fuel modfcaton actvtes. x PAGE 9

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact n order to mnmze mpacts to natve vegetaton, thnnng wll focus on the removal of non-natve speces and dead or dyng materal to acheve a threshold of no more than 50% vegetatve cover. n areas domnated by non-natve speces or dead and dyng materal, cover may be reduced to less than 50 / Where t s not possble to reduce cover to at least 500/. through removal of only non-natves, and dead or dyng materal, woody natve speces wll be removed n accordance wth the followng thnnng herarchy: o ntal vegetaton removals wll nclude all non-natve speces as well as dead and dyng vegetaton. " f cover s not reduced to at least 50% after removng non-natve speces and dead plant materal, then nonspecal-status speces such as coastal goldenbush may be removed. f50% cover s not obtaned after removng coastal golden bush, then Calforna buckwheat wll be removed followed by black sage and Calforna sagebrush untl 50% cover s attaned. o All specal-status speces must be retaned, ncludng western dchondra, bg-leaved crownbeard, and natve shrubs that provde shadng/overstory for such speces. " Also to be retaned are all dagnostc southern martme chaparral speces, ncludng but not lmted to bg pod ceanothus (Ceanothus megacarpus), bush rue (Cneordum dumosum), lttle-leaved redberry (Rhamnus crocea), and bg-leaved crownbeard. As noted above, coastal sage scrub elements wll be avoded to the extent feasble and wll only be removed where t s not otherwse possble to acheve the 50% cover requrement. To avod mpacts to nestng and mgratory brds, t s recommended that any removal or clearng of vegetaton be conducted outsde of the breedng season, whch extends from February 1 to August 31. n the event that seasonal condtons promote a hgh rsk for wldfres, work may occur durng the breedng season f a qualfed bologst conducts a survey for nestng brds wthn 48 hours pror to the commencement of fuel modfcaton actvtes n the area, and ensures that no actve nests are affected. Conduct nvasve plant removal of the pampas grass as an offset to the temporary mpacts wthn the study areas a result of the fuel modfcaton actvtes. Also see dscusson/mtgaton n 2(b), 3(b), and 8(1). o All herbcde applcaton sball be n accordance wth product labels. o No herbcde applcaton shall occur durng tmes of precptaton or when precptaton s forecasted durng the subsequent 48-bour perod. o The contractor responsble for berbcde applcaton shall hold a vald Pest Control Busness Lcense ssued by the Calforna Department of Pestcde Regulaton. A qualfed bologst shall be retaned to provde onste montorng as follows: o o o Onste montorng of vegetaton thnnng operatons as necessary to ensure complance wtb the 50% thnnng protocol. dentfcaton and markng ofspecal-status speces pror to commencement of fuel modfcaton actvtes. Conduct worker awareness tranng for all contractors, band crews, and herbcde applcaton crews that wll be accessng the ste; the educaton wll be conducted pror to startng work on the project and upon the arrval of any new worker. o Onste montorng as necessary durng nvasve plant removal and precedng herbcde applcaton for the purpose of dentfyng and markng specal-status plants. o Effcacy montorng shall be conducted wthn 1-3 weeks after eacb berbcde treatment. PAGE 10

ssues and Supportng nformaton Potentally mpact Less than Wth [ncorporated Less Than mpact No mpact b) Have a substantal adverse effect on any rparan habtat or other senstve natural communty 2,5,14 dentfed n local or regonal plans, polces, regulatons or by the Calforna Department of x Fsh and Game or U.S. Fsh and Wldlfe Servce? A mapped watercourse ntersects the project ste; t s located at the base of the man canyon n whch the proposed fuel modfcaton would occur. As shown on Exhbt 3 of the Bologcal Techncal Report, the entre length of the watercourse s prmarly colonzed by pampas grass and non-natve ornamental vegetaton. The project ncludes hand removal of the nvasve pampas grass to offset the temporary mpacts wthn the study area as a result of fuel modfcaton actvtes. The pampas grass covers an area approxmately 18 feet wde by 735 feet long for a total of 0.30 acre. The Bologcal Techncal Report concludes that no jursdctonal waters subject to U.S. Army Corps of Engneers or Calforna Department of Fsb and Game would be mpacted by the proposed fuel modfcaton plan. Secton 25.50.030 ( watercourses) of the Cty's Zonng Code specfes that no dsturbance of the natve vegetaton wthn an establshed watercourse setback area (25' from both sdes of tbe centerflow lne) s permtted at any tme, except as part of a fuel modfcaton program approved by tbe drector of communty development. Further, the desgn revew board may approve landscape programs wthn establshed setbacks desgned to enhance or restore natve rparan vegetaton or tbe aestbetc character of the watercourse. Alteratons to a sgnfcant natural watercourse are prohbted except as necessary to enhance ts natural characterstcs or ts functonal or ecologcal purpose, or n tbe nterest of publc safety as determned and approved by tbe cty engneer. Eradcaton of the pampas grass would comply wtb the Cty's sgnfcant watercourse regulatons because: (1) t would allow for regrowtb of natve vegetaton thus resultng n an enhancement of tbe watercourse, and (2) pampas grass s hghly flammable and ts removal would mprove fre (publc) safety for Arch Beach Heghts resdents. c) Have a substantal adverse effect on federally protected wetlands as defmed by Secton 404 of 6 the Clean Water Act (ncludng, but not lmted to, marsh, vernal pool, coastal, etc.) through drect removal, fllng, hydrologcal nterrupton or other means? x The Bologcal Tecbncal Report evaluated the project ste for tbe presence of aquatc features potentally subject to the jursdcton of tbe U.S. Army Corps of Engneers (Corps) pursuant to Secton 404 of the Clean Water Act and tbe Calforna Department of Fsb and Game (CDFG) pursuant to Secton 1602 of the Calforna Fsh and Game Code. The Report found that no jursdctonal waters subject to Corps and/or CDFG wll be mpacted by the proposed fuel modfcaton plan. d) nterfere substantally wth the movement of any natve resdent or mgratory fsh or wldlfe speces or wth establshed natve resdent or 2,6,7, 14 x mgratory wldlfe corrdors or mpede the use of natve wldlfe nursery stes? The proposed fuel modfcaton actvtes are short-term, and would not take place durng the breedng (nestng) season except when seasonal condtons promote a hgh rsk for fre, and n that case, a qualfed bologst would conduct a survey for nestng brds. See mtgaton dentfed under 3(a). Therefore, the project would not substantally. nterfere wth the movement of any natve resdent or mgratory fsh or wldlfe speces or wth establshed natve resdent or mgratory wldlfe corrdors. PAGE 11

ssues and Supportng nformaton Potentally mpact Less than Wth, ncorporated Less Than mpact No mpact e) Conflct wth any local polces or ordnances protectng bologcal resources, such as a tree preservaton polcy or ordnance? 2,3,6,7,14 The project s not consstent wth Polcy 8N of the Open Space/Conservaton Element whch states, "Prohbt ntruson of fuel modfcaton programs nto envronmentally senstve areas, ncludng chaparral and coastal sage scrub." However, the project proposes fuel modfcaton usng only hand crews (not goats) and ncorporates a thnnng protocol that lmts lve vegetaton removal to 50% and gves frst prorty to removal of all dead and dyng vegetaton. As concluded n the Bologcal Techncal Report, tbe proposed fuel modfcaton would not result n mpacts because no specal-status speces (plants or anmals) were observed n tbe study area; although two specal-status habtats occur wthn the study area, fuel modfcaton would result n a tbnnng of the vegetaton canopy only and not a permanent removal of any plants or loss of the habtat type. Further, accordng to the Bologcal Techncal Report, the habtat qualty s "Moderate Value" because tbe project ste s a habtat pennsula surrounded by urban development on three sdes; the southwestern extent s bsected by an access road resultng n margnal fragmentaton and the entre area s surrounded by ether ornamental or dsturbed natve vegetaton. Further, as dscussed n the Safety Element (Topc 4: Fre Hazards), the protecton of natve vegetaton must be balanced wth fre safety. Arch Beach Heghts s dentfed as an area where fre hazards have reached a crtcal concern due to development patterns that nclude hgh-densty development, small setbacks, narrow roads, long culde-sacs and crcutous crculaton. n addton, small setbacks and flammable buldng materals, especally wthn proxmty to wldlands, tend to ncrease the propensty for fre and accelerate ts spread. The December 2010 Memorandum from GLA notes that the area at the bottom of the canyon s wthn the Coastal Commsson Appeal Jursdcton (based on the presence of "lands wthn 100 feet ofstreams and wetlands... ") and that ths area would be consdered by the Coastal Commsson as ESHA. However, the habtat occurrng wthn ths ESHA zone should be classfed as "Moderate Value" habtat based on the defntons provded n the Open Space/Conservaton Element, and the Coastal Commsson ESHA desgnaton s based strctly on the geographc locaton ofthe habtat and not the qualty of habtat contaned n the area. More aggressve wldland management technques that nvolve expanson of the Cty's fuel break program nto the nteror canyon areas (ncludng the project ste, Oro Canyon) and cooperaton wth other local jursdctons, neghborhood assocatons, and agences s a hgh prorty for the Cty. Ths prorty s reflected n the polces related to Fre Hazards, ncludng: Polcy 4B whch states, "Revew and contnually mantan each year the Cty's fuel modfcaton program," Polces 4C and 4D whch respectvely state, "Work wth adjacent local jursdctons and agences on the ongong mplementaton of the Cty's fuel modfcaton program," and "Coordnate the Cty's fuel modfcaton program wth neghborhood assocatons," and Polcy 4E whch states, "Work wth governmental jursdctons and agences on the cooperatve, ntegrated mplementaton of the Orange County Report of the WldlandlUrban nterface Task Force's recommendatons." n addton, removal of the pampas grass would allow regrowth of natve vegetaton thereby enhancng the natural condton of the watercourse whch s consstent wth polces related to watersheds and watercourses. See 8(0).. Whle the project as proposed s not fully consstent wth Polcy 8N nsofar as t does not prohbt fuel modfcaton nto areas of chaparral and coastal sage scrnb, t would not permanently remove chaparral or coastal sage scrub plants or cause loss of habtat type, or otherwse cause a sgnfcant physcal mpact to natve vegetaton, and t s fully consstent wth other vegetaton and wldlfe resource polces n the Cty's Open Space/Conservaton Element. The project furthers other objectves of the Cty ncludng Safety Element objectves to mprove fre safety, partcularly n areas where fre hazards have reached a crtcal concern. n consderng all aspects of the General Plan, perfect conformty s not requred because the proposed project would further the General Plan objectves and polces and would not obstruct ther attanment. n concluson, nconsstency wth a polcy may ndcate a physcal mpact (whch has been evaluated heren as less than sgnfcant), but the nconsstency s not by tself an mpact x PAGE 12

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact f) Conflct wth the provsons of an adopted Habtat Conservaton Plan, Natural Communty 2,6 Conservaton Plan or other local, regonal or state habtat conservaton plan?. No Habtat Conservaton Plan, Natural CommuDty ConservatOn Plan or other Smlar plans have been adopted that nclude the project ste or the Arch Beach Heghts Specfc Plan Area and no project mpact s expected 4. CULTURAL RESOURCES Would the project:,. a) Cause a substantal adverse change n the sgnfcance of a hstorcal resource as defned n Secton 15064.5? 2,14 There are no known cultural resources on the project ste. b) Cause a substantal adverse change n the, sgnfcance ofan archaeologcal resource 2,14 pursuant to Secton 15064.5? There are no known archeologcal resources on the project ste; furthermore, no earth-movng, dggng or excavatng actvtes are proposed that mght have the potental to drectly or ndrectly destroy such resources. c) Drectly or ndrectly destroy a unque paleontologcal resource or ste or unque 2,14 geologc feature? The project ste does not contan unque paleontologcal or geologc features; furthermore, no earth-movng, dggng or excavatng actvtes are proposed that mght have the potental to drectly or ndrectly destroy such resources. d) Dsturb any human remans, ncludng those nterred outsde of formal cemeteres? There are no known human remans on the project ste. 15. GEOLOGY AND SOLS Would the project: 2,14 a) Expose people or structures to potental substantal adverse effects, ncludng the rsk of loss, njury or death nvolvng: ) Rupture ofa known earthquake fault, as delneated on the most recent Alqust-Prolo Earthquake Fault Zonng Map ssued by the State Geologst for the area or based on other substantal evdence of a known fault? (Refer to Dvson of Mnes and Geology Specal Publcaton 42.) 3,8,15 The May 2009 Geotechncal Evaluaton prepared by Geofrm evaluated the potental slope stablty mpacts related to the proposed fuel modfcaton n order to dentfy slope stablty ssues and provde mtgatng gudelnes where possble. Because no structures or mprovements are proposed, the Geotechncal Evaluaton dd not need to assess rsk assocated wth rupture of an earthquake fault. The Safety Element of the General Plan ndcates that because no actve faults cross the Cty, the overall constrant or hazard from fault rupture s consdered low. PAGE 13

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact ) Strong sesmc ground shakng? 3,8,15 See 5(a)() ) Sesmc-related ground falure, ncludng lquefacton? 3,8,15 Lquefacton potental n Laguna Beach s based prmarly upon the assocaton. wth alluval areas wth shallow or potentally shallow groundwater depths. The project ste s not consdered to have potental for rsk of lquefacton. v) Landsldes? 3,8 The Geotechncal Evaluaton assessed the rsk ofandsde. Whle the cbaracter oftbe beddng. n tbe project vcnty s not generally prone to gross nstablty, tbe study determned that there are solated locatons potentally underlan by landsldes and the potental for reactvaton of exstng landsldes due to ncreased water fltraton (assocated wtb reducton of the vegetaton canopy) cannot be precluded. Also, the potental for debrs and/or mudflows from sgnfcant fuel modfcaton s low for slopes shallower than a 3:1 rato; moderate on terran slopng from a 3:1 to a 2:1 rato; and hgh on slopes between a 2:1 to 1:1 rato. However, fuel modfcaton mpacts can be mtgated f conducted n a manner that consders tbe potental mpacts to gross and surfcal slope nstablty. To mtgate potental mpacts to a level of nsgnfcance, tbe project would be requred to mplement tbe followng mtgaton measures: Fuel modfcaton efforts should be lmted to tbe canopy, and should mnmze damage to the exstng root systems. Fuel modfcaton areas wth a thck accumulaton of sol on terran slopng between a 3: 1 to 1:1 (horzontal:vertcal) rato should consder surfcal amendments, such as spray adhesves, fber rolls, jute mattng or Caltrans #2 Mulch. after the modfcaton s complete. b) Result n substantal sol eroson or loss of topsol? See 5(a)(v), and 8(1). c) Be located on a geologc unt or sol that s unstable, or that would become unstable as a result ofthe project, and potentally result n onor off-ste landslde, lateral spreadng, subsdence, lquefacton or collapse? See 5(a)() and 5(a)(v). d) Be located on expansve sol, as defned n Table 18-1-B of the Unform Buldng Code (1994), creatng substantal rsks to lfe or property? 3,8 3,8 3,8 No structures or mprovements are proposed; the project ste wll reman undeveloped. See also 5(a)() and 5(a)(v). e) Have sols ncapable of adequately supportng the use of septc tanks or alternatve wastewater dsposal systems where sewers are not avalable 15 for the dsposal ofwaste water? Tbe project does not nclude use of septc tanks or alternatve wastewater dsposal systems, and does not serve as a absorpton feld for sucb uses. 6. GREENHOUSE GAS EMSSONS Would tbe project: PAGE 14

ssues and Supportng nformaton Potentally Less than Less Than No mpact mpact Wth mpact ncorporated a) Generate greenhouse gas emssons, ether drectly or ndrectly, that may have a sgnfcant mpact on the envronment? 15 The proposed fuel modfcaton actvtes nvolves the use of chansaws (wth a 2-stroke gas engne), and therefore some C02 would be generated. However, the clearng and cuttng actvtes would nvolve the use of a sma)) number of chansaws handled by a small crew, and the fuel modfcaton would occur for a lmted perod of tme (approxmately 5 months ntally and 1-3 weeks durng subsequent annual or bannual mantenance). Therefore, the greenhouse gas emssons generated as a result ofthe project are consdered to be less than sgnfcant. b) Conflct wth an applcable plan, polcy or regulaton adopted for the purposes of reducng the emssons ofgreenhouse gases? 1,2,5,15 The proposed project does not conflct wth any applcable plan, polcy or regulaton for purposes of reducng. greenhouse gas emssons. 7. HAZARDS AND HAZARDOUS MATERALS Would the project: a) Create a sgnfcant hazard to the publc or the envronment through the routne transport, use or 9,12,15 dsposal of hazardous materals? t s lkely that the removal of pampas grass would requre the use of an herbcde (Glyphosate) n accordance wth accepted treatment optons. Transportaton, use and dsposal of the herbcde must be n complance wth all applcable Envronmental Laws, rules, regulatons, restrctons, and ordnances relatng to Hazardous Materals. The herbcde would be appled by a lcensed, qualfed contractor, selected by the Cty, n accordance wth product labels. The contractor s responsble for fojlowng all applcable regulatons nvolved n the transportaton, use and storage of. hazardous materals. No publc access would be allowed to the project ste durng herbcde applcaton. Because the pampas grass s located at the bottom of the canyon, adjacent homeowners would not be affected by hazardous materals nvolved wth the project due to the ntervenng dstance. See mtgaton dentfed n 2(b} and 3(a}.. b) Create a sgnfcant hazard to the publc or the envronment through reasonably foreseeable upset and accdent condtons nvolvng the 9,12,15 release of hazardous materals nto the envronment? See 7(a}. c) Emt hazardous emssons or handle hazardous or acutely hazardous materals, substances or waste wthn one-quarter mle ofan exstng or proposed school? 1,15 The project ste s not located wthn one-quarter mle of an exstng or proposed school. d) Be located on a ste whch s ncluded on a lst of hazardous materals stes compled pursuant to 16 Government Code Secton 65962.5 and, as a result, would create a sgnfcant hazard to the publc or the envronment? The project ste s not lsted as a hazardous materals ste. PAGE 15!

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact e) mpar mplementaton of or physcally nterfere wth an adopted emergency response plan or emergency evacuaton plan? 3,15,19 The proposed project wll not mpar or nterfere wth any emergency response or evacuaton plan. Reducton of the vegetaton cover n Oro Canyon (on the project ste) would provde addtonal tme for Arch Beach Heghts resdents to evacuate and survve the rsk of a severe wldland fre. Therefore, the project would have a postve mpact on emergency response and evacuaton. f) Expose people or structures to a sgnfcant rsk of loss, njury or death nvolvng wldland fres, ncludng where wldlands are adjacent to urbanzed areas or where resdences are ntermxed wth wldlands? 3,14,19 The proposed fuel modfcaton plan to reduce the vegetaton cover n Oro Canyon by 50% would gve Arch Beach Heghts resdents more tme to.evacuate and survve a wldland fre. The project mproves fre safety. 8. HYDROLOGY AND WATER QUALTY Would the project: a) Volate any water qualty standards or waste dscharge requrements? 5,14 The project would comply wth all applcable water qualty standards and waste dscharge requrements n accordance wth the Cty's Muncpal Code (Ttle 16, Water Qualty Control). b) Substantally deplete groundwater supples or nterfere substantally wth groundwater recharge such that there would be a net defct n aqufer volume or a lowerng ofthe local groundwater table level (e.g., the producton rate ofpreexstng nearby wells would drop to a level whch would not support exstng land uses or planned uses for whch permts have been granted)? The project would not utlze any groundwater supples. c) Substantally alter the exstng dranage pattern of the ste or area, ncludng through the alteraton of the course ofa stream or rver, n a manner whch would result n substantal eroson or sltaton onor off-ste? 5,14 14 :The project nvolves hand-cuttng of exstng vegetaton only, and no gradng or other earth-movng actvtes are proposed. PAGE 16

ssues and Supportng nformaton Potentally Less than Less Than No mpact mpact Wth mpact ncorporated d) Substantally alter the exstng dranage pattern of the ste or area, ncludng through the alteraton of the course ofa stream or rver, or substantally ncrease the rate or amount ofsurface runoff n a manner whch would result n floodng on- or offste? 8,14 The project ste s unmproved wth respect to dranage. The natve sol and rock slopes sheet flow to trbutary dranages whch ultmately collect n the canyon bottom. Potental reductons n vegetaton wll ncrease the volume of runoff and surface sedment losses from the steeper hllsdes, partcularly when the vegetaton reductons are made at the top of the slope. However, the proposed fuel modfcaton would be lmted to tbnnng tbe canopy and would not damage exstng root systems, and, n the steeper areas a surfcal amendment would be appled after fuel modfcaton to provde eroson control. Tbe pampas grass removal would result n the removal of the total plant system, but tbe pampas grass s located at tbe bottom of the canyon (ratber tban at the top oftbe slope); and further, any exposed sols resultng from herbcde applcaton would be covered wth Caltrans#2 Mulch to reduce the potental for eroson and runoff. See 5(a)(v) and 8(f). e) Create or contnbute runoff water whch would exceed the capacty ofexstng or planned stormwater dranage systems or provde 5,14 substantal addtonal sources ofpolluted runoff? The project ste s undeveloped, and no new development of structures, buldngs or hardscape s proposed whch could create or contrbute runoff water exceedng tbe capacty ofexstng or planned stormwater dranage systems. t) Result n an ncrease n pollutant dscharges to recevng waters? (Consder water qualty parameters such as temperature, dssolved oxygen, turbdty and other typcal storm water pollutants [e.g., heavy metals, pathogens, 8,12,14 petroleum dervatves, synthetc organcs, sedment, nutrents, oxygen-demandng substances and trash].) To mnmze the potental for polluted runoff from the project ste, berbcde applcaton should not occur durng rany days or when precptaton s forecasted wtbn the next 48 hours. Glyphosate s broken down by ether sunlght or sol mcrobes (0)" both); tmng ofthe applcaton to avod precptaton wll mnmze the potental for polluted runoff to occur. See mtgaton requred under S(a)(v). n addton, the followng mtgaton s requred: Herbcde applcaton shall not occur durng rany days or when precptaton s forecasted wthn the next 48 hours Any exposed sols resultng from herbcde applcaton shall be covered wth Caltrans #2 Mulch pror to the rany season each year to reduce the potental for sedment transport and runoff to enter waterways. g) Result n sgnfcant alteraton ofrecevng water qualty durng or followng constructon? No constructon s proposed. h) Result n ncreased mpervous surfaces and assocated ncreased runoff? 14 8,14 PAGE 17

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact See 8(d). ) Create a sgnfcant adverse envronmental mpact to dranage patterns due to changes n runoff flow 8,14 rates or volumes? See8(d). j) Result n ncreased eroson downstream? 8,14 See8(d). : k) Result n an ncrease n any pollutant for whch a downstream water body s already mpared, as lsted on the Clean Water Act Secton 303(d) lst? See 8(0. 12,14 ) Exacerbate already exstng senstve condtons to downstream envronmentally senstve area? See 8(0. 2,6,12, 14 m) Have a potentally sgnfcant adverse mpact on the surface water qualty ofether marne, fresh or 12 wetland waters? See 8(0. n) Have a potentally sgnfcant adverse mpact on ground water qualty? 12 The use of Glyphosate has very low potental to mpact ground water qualty due to ts lmted balf-lfe of 47 days and ts nablty to transport n sols. 0) Cause or contrbute to an exceedance of applcable surface or groundwater recevng water 2,5,12, 14 qualty objectves, polces or degradaton of benefcal uses? The project proposes removal of the nvasve pampas grass that has colonzed wthn a Cty-desgnated sgnfcant watercourse; alteratons or dsturbance of vegetaton n a sgnfcant watercourse s permtted n the nterest of publc safety and/or for the purpose of fuel modfcaton under Zonng Code Secton 25.50.030 ( Watercourse). Removal of the pampas grass would allow regrowth of natve vegetaton thereby enhancng the natural condton of the watercourse whch s consstent wth Polces 9A and 9K dentfed n Topc 9 (Watersheds and Watercourses) of the Cty's General Plan Open Space/Conservaton Element. Also, as dscussed n 8(a), 8(0 and 8(n), the use of Glyphosate to remove the pampas grass would not adversely mpact surface water or groundwater qualty, and s therefore not n conflct wth polces or regulatons pertanng to water qualty. p) mpact aquatc, wetland or rparan habtat 6 No aquatc resources have been dentfed on the project ste. q) Otherwse substantally degrade water qualty? 2,5, 12, 14 See 8(0). PAGE 18

ssues and Supportng nformaton Potentally Less than Less Than No mpact mpact Wth mpact ncorporated r) Place housng wthn loo-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood nsurance Rate Map or other flood 10 hazard delneaton map? The project does not propose any housng. s) Place wthn a loo-year flood hazard area structures whch would mpede or redrect flood flows? 10 The project ste s desgnated as beng located n a Federal Emergency Management Agency (FEMA) Flood Zone, whch s an area desgnated as havng a 0.2% chance of annual floodng. The project ste s not located wthn the l00-year flood hazard area. t) Expose people or structures to a sgnfcant rsk ofloss, njury or death nvolvng floodng, ncludng floodng as a result ofthe falure of a 3 levee or dam? The project ste s not located below a levee or dam, and there s no potental mpact due to falure of a levee or dam. u) nundaton by seche, tsunam or mudflow? 3 The project ste s not consdered to be at rsk of nundaton by seche, tsunam or mudflow.. 9. LAND USE AND PLANNNG Would the project a) Physcally dvde an establshed communty? 1,4, 14 No new development s proposed. b) Conflct wth any applcable land use plan, polcy or regulaton of an agency wth jursdcton over the project (ncludng, but not lmted to a general plan, specfc plan, local coastal program or zonng ordnance) adopted for the purpose of avodng or mtgatng an envronmental effect? 1,2,3,5,6, 14 As shown on the Cty's LCP post-certfcaton map, the project ste ncludes an area located at the bottom of the canyon that s wthn the Calforna Coastal Commsson appeal jursdcton. Ths appeal area s 100 feet wde (measurng 50 feet from eacb sde of the stream) and ncludes a sgnfcant watercourse as desgnated by the Cty. Consequently, tbe acton taken by the Cty on the requred Coastal Development Permt (CDP) would be subject to appeal by the Coastal Commsson. To ensure complance wth the Cty's certfed LCP, revew crtera as specfed n Chapter 25.07 (Coastal Development Permts) must be ncorporated nto the revew of the CDP applcaton, and tbe requred fndngs must be made n the case of CDP approval. Tbe bologcal assessment determned that tbe project ste contans only "Moderate Value" habtat; and that tbe 100-foot wde appeal area, consstng prmarly of chaparral and pampas grass wtb a sma)) amount of coastal sage scrub and ornamental vegetaton, would also qualfy as "Moderate Value" habtat after removal of the pampas grass. The fuel modfcaton program would follow a 50% thnnng protocol that would result n a thnnng of tbe vegetaton canopy only and not a permanent removal of any plants or loss of babtat type. Regrowtb of natve vegetaton would be expected n the areas wbere pampas grass s removed. See 3(a), 3(b) and 3(e) whch dscuss potental project mpacts and possble polcy conflct. nconsstency wth a polcy may ndcated a pbyscal mpact (wbch has been evaluated as less tban sgnfcant), but tbe nconsstency s not by tself an mpact. PAGE 19

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact c) Conflct wth any applcable habtat conservaton plan or natural communty conservaton plan? 2 The project would not conflct wth any habtat conservaton plan or natural communty conservaton plan. 10. MNERAL RESOURCES Would the project: a) Result n the loss ofavalablty of a known mneral resource that would be ofvalue to the regon and the resdents of the state? 1,4 No known mneral resources are located on the project ste. b) Result n the loss of avalablty ofa locallymportant mneral resource recovery ste delneated on a local general plan, specfc plan or 1,4 other land use plan?. No mneral resource recovery ste s planned or dentfed n the Cty of Laguna Beach General Plan or otber, applcable land use plan or specfc plan. 11. NOSE Would the project result n: a) Exposure of persons to or generaton ofnose levels n excess ofstandards establshed n the local general plan or nose ordnance, or 5,17 applcable standards of other agences? The project does not propose new development or land uses that would generate excessve nose levels. b) Exposure of persons to or generaton ofexcessve groundborne vbraton or groundborne nose levels? 14,17 The project does not nvolve the use of heavy machnery or other equpment that mght generate excessve ground borne vbraton or nose levels. c) A substantal permanent ncrease n ambent nose levels n the project vcnty above levels exstng wthout the project? 5,14,17 The proposed fuel modfcaton s short-term n duraton and would not produce a substantal permanent ncrease n ambent nose levels. PAGE 20

ssues and Supportng nformaton Potentally Less than Less Than No mpact mpact Wth mpact ncorporated d) A substantal temporary or perodc ncrease n ambent nose levels n the project vcnty above levels exstng wthout the project? 5,14 The project could generate nose mpacts related to the use of chansaws for vegetaton thnnng and an onste chpper. However, the fuel modfcaton actvtes could only operate on non-holday weekdays from 7:30 a.m. to 6 p.m. n accordance wth the Cty's nose regulatons for constructon actvty, and would occur over a lmted perod of tme (approxmately 5 months). n addton, the use of mufflers on the chansaws would further reduce potental nose mpacts. Most chansaws generate a far amount of engne nose snce they operate wth a 2-stroke engne usually runnng at a hgh rpm; chan saw mufflers also serve as a spark arrester, and can be acqured at a cost of $25 $30 each. The followng mtgaton s requred: All chansaws shall only be operated wth a muffler (unmodfed, wth the spark arrestor screen ncluded) and mantaned n good condton. 12. POPULATON AND HOUSNG Would the project: a) nduce substantal populaton growth n an area, ether drectly (for example, by proposng new homes and busnesses) or ndrectly (for example, through extenson ofroads or other nfrastructure)? The project does not propose any new homes or busnesses, road extensons, or any new nfrastructure. b) Dsplace substantal numbers of exstng housng, necesstatng the constructon of replacement housng elsewhere? The project does not nvolve housng dsplacement. c) Dsplace substantal numbers ofpeople, necesstatng the constructon of replacement housng elsewhere? 1,14 The p ro ect ~ does not elmnate any housn g or dsplace substantal numbers of people. The project ste s undeveloped.! 13. PUBLC SERVCES a) Would the project result n substantal adverse physcal mpacts assocated wth the provson of new or physcally altered governmental facltes, need for new or physcally altered governmental.facltes, the constructon of whch could cause sgnfcant envronmental mpacts, n order to mantan acceptable servce ratos, response tmes or other performance objectves for any of the publc servces: 1,4, 14 14 ) Fre protecton? 3,14,19 The proposed fuel modfcaton would mprove fre safety n the event of a wldland fre for Arch Beach Heghts resdents. PAGE 21

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact ) Polce protecton? 3,14 n the case of a wldland fre threatenng the Arch Beach Heghts area, polce servces would be called upon to assst n the emergency response; snce the project would mprove fre safety and gve resdents addtonal tme to evacuate, the project s consdered to have a postve mpact on polce servces. ) Schools? 14 The project would have no mpact v) Parks? 14 The project would have no mpact v) Other publc facltes? 14 The project would have no mpact; the ste s undeveloped and would reman n that condton. 14. RECREATON a) Would the project ncrease the use ofexstng neghborhood and regonal parks or other 14 recreatonal facltes such that substantal physcal deteroraton ofthe faclty would occur or be accelerated? The project s not growth-nducng and does not nvolve the constructon of any new homes that mght result n an ncrease n the use of parks or other recreatonal facltes. b) Does the project nclude recreatonal facltes or requre the constructon or expanson of recreatonal fachtes whch mght have an 14 adverse physcal effect on the envronment?....... The project ste S undeveloped and wll remam D that condton; no recreatonal facltes are proposed PAGE 22

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact 15. TRANSPORTATON TRAme Would tbe project: a) Conflct wth an applcable plan, ordnance or polcy establshng measures of effectveness for the perfonnance ofthe crculaton system, takng nto account all modes oftransportaton ncludng mass transt and non-motorzed travel and 13,14 relevant components of the crculaton system, ncludng but not lmted to ntersectons, streets, hghways and freeways, pedestran and bcycle paths, and mass transt? Tbe project would not create any long-term traffc mpacts. Altbougb no development s proposed, traffc related to tbe fuel modfcaton actvtes would nclude contractor vebcles carryng crews and equpment tbat would use local streets. Access to tbe ste would be va tbe paved sewer pump access road wbch connects to Alsos Avenue; contractor vebcles would be able to park on tbe sewer pump access road tbat s not avalable for publc use. Removal of debrs from the ste and vegetaton from tbe ste s expected to requre 2-4 daly truck trps. Some vegetaton wll be chpped onste to mnmze tbe need for removng t from tbe ste. No gradng s proposed and tbere would be no baulng of drt to or from tbe ste. See 16(1). Traffc mpacts are generally less than sgnfcant due to tbe lmted number of contractor vebcles accessng tbe ste, tbe 10catoD of a stagng area away from publc roads, and tbe lmted duraton (approxmately 5 months) oftbe fuel modfcaton actvtes. b) Conflct wth an applcable congeston management program, ncludng, but lmted to level of servce standards and travel demand measures, or other standards establshed by the county congeston management agency for desgnated roads or hghways? 13,14 Tbe proposed fuel modfcaton actvtes would generate approxmately 8-10 trps per day whcb would not conflct wtb exstng level of servce standards; tbs estmate ncludes 2-3 contractor vehcles (delverng band crews) and 1-2 trucks haulng debrs from the ste. c) Substantally ncrease hazards due to a desgn feature (e.g., sharp curves or dangerous ntersectons) or ncompatble uses (e.g., fann 14 equpment)? : The project does not nclude desgn changes to any roadways or propose ncompatble uses tbat would create road hazards. d) Result n nadequate emergency access? 3, 13, 14. Access and evacuaton routes are lmted to two routes (Nyes Place and Summt Drve); the p~~ject would allow addtonal tme for resdents to evacuate and therefore mprove the exstng emergency access condton. e) Conflct wth adopted polces, plans or programs regardng publc transt, bcycle, or pedestran 13, 14 facltes, or otherwse decrease the perfonnance or safety of such facltes?. The project does not mpact any publc transt, bcycle or pedestran facltes as no new development s proposed. PAGE 23

ssues and Supportng nformaton Potentally mpact Less than Wth ncorporated Less Than mpact No mpact 16. UTLTES AND SERVCE SYSTEMS Would the project: a) Exceed wastewater treatment requrements ofthe applcable Regonal Water Qualty Control 5,14 Board? The project ste would reman undeveloped and would not ncrease wastewater treatment demand. b) Requre or result n the constructon ofnew water or wastewater treatment facltes or expanson of 14 exstng facltes, the constructon ofwhch could cause sgnfcant envronmental effects? The project would generate no demand for water or wastewater treatment. c) Requre or result n the constructon ofnew storm water dranage facltes or expanson of exstng facltes, the constructon ofwhch could cause sgnfcant envronmental effects? 14 The project ste would reman n an undeveloped condton, and would not generate addtonal demand for storm water dranage facltes. d) Have suffcent water supples avalable to serve the project from exstng enttlements and 14 resources, or are new or expanded enttlements needed? The project does not propose new development that would generate new/addtonal water demand. e) Result n a determnaton by the wastewater treatment provder whch serves or may serve the project that t has adequate capacty to serve the project's projected demand n addton to the provder's exstng commtments? The project does not propose new development that would requre addtonal wastewater treatment capacty. 14 f) Be served by a landfll wth suffcent permtted capacty to accommodate the project's sold waste 14 dsposal needs? The proposed fuel modfcaton wll generate waste vegetatve matter; however, approxmately 25% of vegetatve waste would be reduced to mulch by an onste chpper and left n place, and the remanng vegetatve waste would be. transported to a green waste recycler. Waste materals such as cans, bottles, and mscellaneous dscarded tems that are found onste, would be collected and hauled to a landfll; the amount of ths waste materal s expected to be relatvely small and easly served by the exstng landfll. Any mpact to the landfll would be consdered temporary and nsgnfcant. g) Comply wth federal, state and local statutes and regulatons related to sold waste? See 16(1)., 14 PAGE 24

MANDATORY FNDNGS OF SGNFCANCE Does the project have the potental to degrade the qualty of the envronment, substantally reduce the habtat of a fsh or wldlfe speces, cause a fsh or wldlfe populaton to drop below self-sustanng levels, threaten to elmnate a plant or anmal communty, reduce the number or restrct the range of a rare or endangered plant or anmal or elmnate mportant examples of the major perods of Calforna hstory or prehstory? e proposed fuel modfcaton project, wth proposed mtgaton, s not antcpated to degrade the qualty of the vronment, substantally mpact fsh or wldlfe habtat, threaten plant or anmal communtes, reduce or restrct the range rare or endangered plants or anmals, or elmnate mportant examples of the major perods of Calforna hstory or ehstory. Does the project have mpacts that are ndvdually lmted, but cumulatvely consderable? ("Cumulatvely consderable" means that the ncremental effects of a project are consderable when vewed n connecton wth the effects of the past projects, the effects ofother current projects, and the effects ofprobable future projects.) tental project mpacts are reduced to a level of nsgnfcance through mtgaton; there are no cumulatvely consderable pacts as no specal-status speces were observed n the study area, and although two specal-status habtats occur wthn ~ study area, fuel modfcaton (thnnng of the vegetaton canopy only) would not result n the permanent removal of any lots or a loss of habtat type. Glyphosate, used for nvasve plant removal, does not boaccumulate through the food chan, ts presence on the landscape and n the sol over tme s not expected to have cumulatve adverse effects, and further, yphosate s not moble and has a very low potental to contamnate groundwater. Does the project have envronmental effects whch wll cause substantal adverse effects on human bengs, ether drectly or ndrectly? e project, wth mtgaton, wll not result n drect or ndrect substantal adverse mpacts to human bengs. EARLER ANALYSES. ler analyss may be used where, pursuant to the terng, program ER, or other CEQA process, one or more effects have been quately analyzed n an earler ER or Negatve Declaraton. Secton 15063 (c) (3) (D). n ths case a dscusson should dentfy followng tems: Earler analyss used. dentfy earler analyses and state where they are avalable for revew. t applcable, no other earler analyss has been dentfed. mpacts adequately addressed. dentfy whch effects from the above checklst were wthn the scope of and adequately analyzed n an earler document pursuant to applcable legal standards, and state whether such effects were addressed by mtgaton measures based on the earler analyss. t applcable, no other earler analyss has been dentfed. measures. For effects that are "Less than wth ncorporated," descrbe the mtgaton measures whch were ncorporated or refned from the earler document and the extent to whch they address ste-specfc condtons ofthe project. t applcable, no other earler analyss has been dentfed. PAGE 25

. SOURCE REFERENCES 1 2 Cty oflaguna Beach Land Use Element Cty oflaguna Beach Open Space and Conservaton Element! 3 Cty oflaguna Beach Safety Element 4 Cty oflaguna Beach Zonng Map 5 Cty of Laguna Beach Muncpal Code (Ttle 7, Ttle 16, and Ttle 25) 6 September 2010, Bologcal Techncal Report for Proposed Fuel Modfcaton Zone n the Arch Beach Heghts Area of Laguna Beach, Orange County, Calforna.; Glenn Lukos Assocates. 7 8 December 9,2010 Memorandum, Supplemental nformaton pertanng to bologcal resources wthn the proposed Arch Beach Heghts Fuel Modfcaton Zone; Glenn Lukos Assocates. July 22,2010, Submttal Requrements of Coastal Calforna Gnatcatcher Surveys for the Proposed Fuel Modfcaton Zones Between Nyes Place and Damond Street n Laguna Beach, Orange County, Calforna; Glenn Lukos Assocates. May 28, 2009, Geotechncal Evaluaton ofpotental Slope Stablty mpacts, Proposed Arch Beach Heghts Fuel Modfcaton Areas 1 and 2, Laguna Beach, Calforna; Geofmn. December 15,2010 Letter, Supplemental Geotechncal Comments Regardng Proposed Arch Beach Heghts Fuel Modfcaton Areas 1 and 2; Geofrm.!! 9 Cal-PC, Calforna nvasve Plant Councl, Weed Workers Handbook, Pampas Grass and Jubata Grass, accessed onlne November 2010. 10 FEMA, FRM Maps 11 Drect communcaton wth Dr. Steven D. Colome, envronmental health scentst, 2010. 12 Washngton State Department oftransportaton, Glyphosate, Roadsde Vegetaton Management Herbcde Fact Sheet, accessed onlne December 2010. 13 14 15 Patrck R. Durkn, Glyphosate - Human Health and Ecologcal Rsk Assessment, Fnal Report prepared for USDA Forest Servce, 2003. Cty oflaguna Beach Transportaton Element January, 2011 Fuel Modfcaton Plan 1997 State ofcalforna Sesmc Hazard Zones Map, Laguna Beach Quadrangle 16 State ofcalforna, Department oftoxc Substances Control, EnvroStor, accessed onlne December 2010 17 Cty oflaguna Beach Nose Element 18 Cty of Laguna Beach Landscape and Scenc Hghways Resource Document 19 2010 Recommended Draft, Orange County Fre Hazard Severty Zones n LRA (Local Responsblty Area), State of Calforna Department of Forestry and Fre Protecton; http://www.fre.ca.gov/fre preventonlfhsz mans/fhsz mans oran2:e.ohn PAGE 26

20. Measures. For effects that are "Less Than wth ncorporated," descrbe the mtgaton measure(s) whch were ncorporated and the extent to whch they address ste-specfc condtons of the project. The responsble person, Department, Agency, etc., that wll be responsble for verfcaton and the event or tme of verfcaton should also be specfed. See the followng Montorng Program Table. PAGE 27

MTGATON MONTORNG PROGRAM TABLE Envronmental Reference M". M Responsble tlgatlon easures P rt F acor_~y t #.. AR QUALTY 2(b) The use ofchansaws and onste chpper shall be avoded when ground-level ozone (the man component of smog) or carbon monoxde emssons reach an unhealthy level for senstve groups (Level Orange, Ar Fre Chef ~Qualty ndex). r-a1r QUALTY 2(b) All chansaws shall comply wth the Calforna Ar Resources Board (ARB) Ter emssons control; demonstraton of such complance shall be provded by the Cty selected contractor pror to Fre Chef commencement of fuel modfcaton operatons. AR QUALTY, 2(b),7(a) No boom sprayer applcaton of herbcde shall be permtted when wnds are greater than 5 mph; no HAZARDS AND backpack sprayer applcaton usng a wand and nozzle hood shall occur when wnds are greater than 10 Fre Chef HAZARDOUS mph; no wck and dauber applcatons shall occur when wnds are greater than 15 mph. MATERALS BOLOGCAL 3(a) To the extent practcable, vegetaton thnnng wthn coastal sage scrub and chaparral habtats should be RESOURCES lmted to the wnter months (September J January 30) outsde of the grownglbloomng season n order to avod mpacts to specal-status plants. However, f seasonal fre condtons warrant and fuel modfcaton actvtes are requred durng the grownglbloomng season (February 1-August 30), areas Fre Chef known to support or have potental to support bg-leaved crownbeard, ntermedate marposa lly or other specal-status speces should be dentfed n the feld by a bologst pror to commencement of fuel modfcaton actvtes. BOLOGCAL 3(a) n order to mnmze mpacts to natve vegetaton, thnnng wll focus on the removal of non-natve RESOURCES speces and dead or dyng materal to acheve a threshold of no more than 50% vegetatve cover. n areas domnated by non-natve speces or dead and dyng materal, cover may be reduced to less than 50%. Where t s not possble to reduce cover to at least 50% through removal of only non-natves, and dead or dyng materal, woody natve speces wll be removed n accordance wth the followng thnnng herarchy: o ntal vegetaton removals wll nclude all non-natve speces as well as dead and dyng vegetaton. o fcover s not reduced to at least 50% after removng non-natve speces and dead plant materal, then non-specal-status speces such as coastal goldenbush may be removed. f50% cover s not Fre Chef obtaned after removng coastal golden bush, then Calforna buckwheat wll be removed followed by black sage and Calforna sagebrush untl 50% cover s attaned. o All specal-status speces must be retaned, ncludng western dchondra, bg-leaved crownbeard, and natve shrubs that provde shadng/overstory for such speces. o Also to be retaned are all dagnostc southern martme chaparral speces, ncludng but not lmted to bg pod ceanothus (Ceanothus megacarpus), bush rue (Cneordum dumosum), lttle-leaved redberry (Rhamnus crocea), and bg-leaved crown beard. As noted above, coastal sage scrub elements wll be avoded to the extent feasble and wll only be removed where t s not otherwse to acheve the 50% cover requrement. PAGE 28

Envronmental Reference Factor # Measures BOLOGCAL 3(a) To avod mpacts to nestng and mgratory brds, t s recommended that any removal or clearng of RESOURCES vegetaton be conducted outsde of the breedng season, whch extends from February 1 to August 31. n the event that seasonal condtons promote a hgh rsk for wldfres, work may occur durng the breedng season f a qualfed bologst conducts a survey for nestng brds wthn 48 hours pror to the commencement of fuel modfcaton actvtes n the area, and ensures that no actve nests are affected. -- BOLOGCAL RESOURCES, HAZARDS AND HAZARDOUS MATERALS BOLOGCAL RESOURCES GEOTECHNCAL 3(a),7(a) 3(a) 5(a)(v),5(b), 5(c) Conduct nvasve plant removal of the pampas grass as an offset to the temporary mpacts wthn the study areas a result of the fuel modfcaton actvtes. Also see dscusson/mtgaton n 2(b), 3(b), and 8(1). o All herbcde applcaton shall be n accordance wth product labels. o No herbcde applcaton shall occur durng tmes of precptaton or when precptaton s forecasted durng the subsequent 48-hour perod. o The contractor responsble for herbcde applcaton shall hold a vald Pest Control Busness Lcense ssued by the Calforna Department of Pestcde Regulaton. KespOnSOJe Party Fre Chef Fre Chef A qualfed bologst shall be retaned to provde onste montorng as follows: o Onste montorng of vegetaton thnnng operatons as necessary to ensure complance wth the 50% thnnng protocol. 0 dentfcaton and markng of specal-status speces pror to commencement of fuel modfcaton actvtes. o Conduct worker awareness tranng for all contractors, hand crews, and herbcde applcaton crews Fre Chef that wll be accessng the ste; the educaton wll be conducted pror to startng work on the project and upon the arrval of any new worker. o Onste montorng as necessary durng nvasve plant removal and precedng herbcde applcaton for the purpose of dentfyng and markng specal-status plants. o Effcacy montorng shall be conducted wthn 1-3 weeks after each herbcde treatment. Fuel modfcaton efforts should be lmted to the canopy, and should mnmze damage to the exstng root systems. Fre Chef GEOTECHNCAL 5(a)(v),5(b), Fuel modfcaton areas wth a thck accumulaton of sol on terran slopng between a 3:1 to 1:1 5(c) (horzontal:vertcal) rato should consder surfcal amendments, such as spray adhesves, fber rolls, jute Fre Chef mattng or Caltrans #2 Mulch after the modfcaton s complete. -HYDROLOGY AND WATER QUALTY HYDROLOGY AND WATER QUALTY 8(t) 8(t) Herbcde applcaton shall not occur durng rany days or when precptaton s forecasted wthn the next 48 hours. FreChef Any exposed sols resultng from herbcde applcaton shall be covered wth Caltrans #2 Mulch pror to the rany season each year to reduce the potental for sedment transport and runoff to enter waterways. NOSE ll(d) All chansaws shall only be operated wth a mumer (unmodfed, wth the spark arrestor screen ncluded) and mantaned n 200d condton. Fre Chef Fre Chef PAGE 29