Comment Letter No. 4 California Department of Fish and Wildlife March 29, 2016

Similar documents
Conserving California s Wildlife Since 1870

Santa Barbara Audubon Society

3.6 Riparian Ecosystem Wildlife

A. Planning Background.

Chapter 13: Wildlife and Vegetation

GENERAL GUIDELINES FOR CONDUCTING THREATENED AND ENDANGERED SPECIES SURVEYS IN THE PINELANDS AREA. March 25, 2006 INTRODUCTION

SECTION 10: WETLANDS PROTECTION

FINAL FOCUSED TIERED ENVIRONMENTAL IMPACT REPORT D IGITAL A RTS F ACILITY UNIVERSITY OF CALIFORNIA, SANTA CRUZ

County of Sonoma Agenda Item Summary Report

PUBLIC NOTICE LOS ANGELES DISTRICT APPLICATION FOR PERMIT. University of California Santa Barbara North Campus Open Space (NCOS) Restoration Project

Appendix F. Response to Comments. North Coast System Rehabilitation Project 9/22/14 Phase 3 Coast Segment Draft Initial Study

Impact BIO-48: Periodic Effects of Inundation of California Tiger Salamander Habitat as a Result of Implementation of Alternative 4A

5.2 BIOLOGICAL RESOURCES AND WETLANDS

4.0 MITIGATION MONITORING AND REPORTING PLAN

Wildlife Management Intensity Standards

Wildlife Management Planning Guidelines for the South Texas Plains Ecoregion

Chapter 10 Natural Environment

Short-term (Construction) Impacts and Potential Mitigation

VEGETATIVE, WATER, FISH AND WILDLIFE RESOURCES POLICIES

EXECUTIVE SUMMARY ES.1 BACKGROUND ES.2 PURPOSE AND NEED FOR THE PROPOSED PROJECT

SR 161: Jovita Boulevard to South 360th St. Stage 2 / WSDOT Stream Buffer Mitigation (Agreement Y-9403) 2012 Final Monitoring Report

Carmel River Reroute & San Clemente Dam Removal Project (PLN110373) Monterey County Planning Commission Workshop July 25, 2012

Biotic Resources Group

Logan River at Rendezvous Park, Channel and Floodplain Restoration: Crack Willow (Salix fragilis) Issues and Management Strategies

Fitzgerald Marine Reserve Pilot Projects. Upland Vegetation Restoration in San Vicente Creek and the Monterey Cypress Grove

COUNTY OF SAN MATEO PLANNING AND BUILDING DEPARTMENT

Appendix E : Guidelines for Riparian Buffer Areas

Biological Resources and Development Permitting

California Regional Water Quality Control Board San Francisco Bay Region. Tentative Order No. R XXXX

Riparian Vegetation Protections. Heritage Tree Protection

COASTAL CONSERVANCY. December 2, 2004 SAN DIEGO NCCP PROGRAM IMPLEMENTATION: MONTE VISTA RANCH. File No Project Manager: Marc Beyeler

LOWER DRUM PLANNING UNIT Yuba-Bear River Watershed

Managing near Vernal Pools using Good Forestry in the Granite State

Santa Ana Hazardous Fuels Reduction Project Design Criteria

MITIGATED NEGATIVE DECLARATION & MITIGATION MONITORING PROGRAM CITY OF CHICO PLANNING DIVISION

In 2013, Gunnison sage-grouse was proposed for an "endangered" listing by the U.S. Fish and Wildlife Service under the Endangered Species Act.

Responses to Comments from State Agencies

Appendix E Habitat Vulnerability Summary Sheets

MANZANITA LAKE PLANNING UNIT Willow Creek Watershed

University of Florida Conservation Area Land Management Plan Bat House Woods

Monitoring Report #3 Kenston Lake Stream Restoration Bainbridge, Ohio

APPENDIX E AVOIDANCE AND MINIMIZATION PROTOCOL FOR VERNAL POOLS

Amphibian Protection Strategies. Presented by: Linda Dupuis, M.Sc., R.P.Bio Wildlife Habitat Ecologist

APPENDIX K LRDP EIR ADDENDUM #2

APPENDIX A CEQA Initial Study Checklist

ENVIRONMENTAL STEWARDSHIP AND THE 2020 PROJECT

Golf Course and Recreational Facilities Best Management Guidelines. Regional Official Plan Guidelines

[FWS R8 ES 2017 N107; FXES FF08ECAR00] Endangered and Threatened Wildlife and Plants; Incidental Take Permit

AVALONIA LAND CONSERVANCY FEE LAND STEWARDSHIP PRINCIPLES

PART 4 GOALS, POLICIES AND ACTIONS

What is an ecosystem?

DRAFT (July 2018) Butte County Oak Woodland Mitigation Ordinance

Wildlife Management Plan A1924, O. Mumme, Survey 344, Track 227, Acres

MONTEREY PENINSULA WATER MANAGEMENT DISTRICT PROJECT DESCRIPTION FOR SELECTIVE VEGETATION MANAGEMENT AND BANK RESTORATION (RANCHO SAN CARLOS AREA)

Strong site and year specific needs, particularly driven by annual systems Well drained, <1200 m, over diverse soil types

Wildlife Habitat as it relates to Forestry

-MENDOCINO COUNTY PLANNING AND BUILDING SERVICES- DIVISION II OF TITLE 20--COASTAL ZONING CODE

COON CREEK WATERSHED DISTRICT PERMIT REVIEW

APPENDIX P EL DORADO COUNTY GENERAL PLAN: APPLICABLE SECTIONS FROM CONSERVATION AND OPEN SPACE ELEMENT

U.S. ARMY CORPS OF ENGINEERS BUILDING STRONG LOS ANGELES DISTRICT

EA 04- Date: December 7, 2015 Project ID No

BIOLOGICAL ASSESSMENT/EVALUATION WILDLIFE AND BOTANY REPORTS

SANTA CLARA Protections in place:

Natural Resources KEY ISSUES SCENIC AREA ACT PROVISIONS CHAPTER 3. not adversely affect natural resources [Section 6(d)(3)].

Mitigation Monitoring and Reporting Program for the Concord Community Reuse Project

Napa County General Plan, June 23, 2009 Natural Resources Policies

EXHIBIT A FISH AND GAME CORRESPONDENCE

3.4 BIOLOGICAL RESOURCES

CHAPTER 4. IMPACT ASSESSMENT AND ESTIMATED LEVEL OF TAKE

CATEGORY a protection of the natural environment, its ecosystems and biodiversity.

3 PROJECT DESCRIPTION

A. Summary of Impacts and Mitigation Measures

Phase II: Proposed (regulated) Impervious in disturbed area (ac) Long Lake Existing Impervious in disturbed area (ac)

Appendix Q Conceptual Mitigation Plan for Impacts to Wetlands and Other Waters of the United States

KINGS RIVER PLANNING UNIT Kings River Watershed

6.0 ALTERNATIVES. The alternatives that are evaluated in this section include the following:

ENVIRONMENTAL REVIEW PROCESS AND ADOPTION OF MITIGATED NEGATIVE DECLARATION

August clarified 4.0 CONSERVATION PROGRAM

STAFF REPORT WASHINGTON STATE PARKS AND RECREATION COMMISSION COVERED SHELTERS AND BIKE RACKS

DECISION MEMO. West Fork Blacktail Deer Creek Hardened Crossing

WETLANDS AND OPEN WATERS Compensatory Mitigation Definitions of Factors

2.0 GOALS AND OBJECTIVES

(1) The proposed commercial solar energy generation facility is either

SECTION ENVIRONMENTAL SUB-INDEX TREE PROTECTION PRESERVATION AND HARVESTING

1.0 REQUEST. SANTA BARBARA COUNTY PLANNING COMMISSION Determination of Flood Control Easement in Carpinteria Marsh

Section 4.10 Ecosystems and Biological Resources

Sec ESH Environmentally Sensitive Habitat Area Overlay District.

Proposed Low-Effect Habitat Conservation Plan for the California Tiger. Salamander and California Red-Legged Frog, Sonoma County, California

COASTAL CONSERVANCY. Staff Recommendation March 25, 2004 NCCP PROGRAM IMPLEMENTATION: SAN DIEGO RIVER CALMAT PROPERTY PHASE 2

FINAL ENVIRONMENTAL IMPACT REPORT VERONICA MEADOWS SPECIFIC PLAN. January 2005

HAU FIELD INVENTORY PROCEDURES

University of Florida Conservation Areas Land Management Plan Trillium Slope (Golf Course Woods)

Information Sheet: Development within Wildlife Habitat Areas, including development within Gunnison Sage-grouse habitat

Illinois DNR Conservation Ecosystems Program Project Grant Application for FY 2008

4.1 Introduction and Approach

STAFF REPORT CHELAN COUNTY PUD DAROGA DOMESTIC WATER SYSTEM

The Wyoming Wildlife Advocates also value the Caribou-Targhee National

3.15 SNAG AND SNAG ASSOCIATED SPECIES

Wetland restoration and monitoring on the Chevelon Wildlife Area

SANTA CLARA VALLEY HABITAT PLAN DEVELOPMENT FEE NEXUS STUDY JUNE 30, 2012 WITH URBAN ECONOMICS

Transcription:

Comment Letter No. 4 California Department of Fish and Wildlife March 29, 2016 4-1. This comment provides a general description of the proposed NCOS Restoration Project and an introduction to comments provided below. No response is necessary. 4-2. Table 2.5-1 is part of the MND s Project Description and it is not the purpose of the Project Description to describe existing environmental conditions at the project site. MND Section 5.4.1 (Biological Resources Setting) provides a comprehensive description of the existing plant/habitat communities on the project site, and Figure 5.4-1 (Project Site Habitat Types) depicts the location of on-site plant communities. 4-3. The Total Acres with Project column of Table 2.5-1 only depicts habitat areas that would be created by the Project, and only 106 of the 136-acre project site would be disturbed by proposed grading activities for the purpose of creating restored wetland and upland habitat. Of the 106 acres that would be graded to accommodate proposed restoration activities, 39.5 acres are on the South Parcel, and 65.5 acres are on the former golf course and Whittier parcels. Weeding will be the main activities conducted on the undisturbed 30-acre portion of the project site (27.3 acres on the South Parcel and 2.2 acres on the Whittier parcel). Existing habitat on the South Parcel will not be entirely removed as indicated by this comment. Habitat types to be preserved on the South Parcel include: coastal sage scrub affiliates (3.53 ac); annual grass and herbs (12.33 ac); taller weeds (17.65 ac); perennial native grass (0.89 ac); bare ground (1.72 ac); trees (1.11 ac); non-native turf grass (0.11 ac); and the existing eucalyptus woodland. 4-4. The MND did evaluate the potential for proposed construction-related activities to impact on-site wildlife species that may be located in annual grassland. Section 5.4.2d states, in part: Project-related construction operations could temporarily reduce wildlife movement that does occur through the project site, however, construction would be conducted in phases, which would minimize the potential for short-term wildlife movement impacts. The proposed long-term habitat enhancements would increase habitat value and provide forage and cover that would enhance the potential for wildlife movement through the site. Since the removal of annual grassland from the South Parcel would not result in significant impacts to any known sensitive plant or animal species or their habitats (see MND Sections 5.4.2a and 5.4.2c) impacts to on-site species were considered to be short-term and less than significant, and no mitigation measures were required. In addition, as described in Response 4.3 above a substantial area (27.3 acres) of existing habitat would be preserved on the South Parcel, and that area would be enhanced by proposed weeding activities.

Page 2 In regard to wildlife species on the project site that birds may feed on, on-site wildlife resources are being assessed through a variety of on-going and previously completed studies including: an invertebrate study that is on-going; a winter and spring raptor and breeding bird survey that builds on two years (2012-2014) of previous bird surveys conducted on the project site; and a cover board survey that found very few organisms other than western fence lizards and argentine ants. For the cover board study (8/31/2012 9/1/ 2014) 26 cover boards were opened every other week over a two year period, resulting in 1,351 observations. The cover board study found that in 19% of observations (256 observation events) invasive argentine ants were found. 11% of time western fence lizards and 10% of the time juvenile western fence lizards were found. 4% of the time skink were observed, followed by silverfish (3.7%), pill bug (3%), spider (2.7%), centipede (2.6%), black beetle (2.4%), field cricket (2.23%), Jerusalem cricket (1.3%), slender salamander (1.6% - which is approximately 10 board flips out of the 1,350 done), alligator lizard (0.74%), cricket (0.59%), field mouse (0.59%). Observations of vole, ringneck snake, gopher snake and deer mouse were all less than 0.3%, or 4 observations or less over the 2 year study. The conclusion of the cover board study is that the project site does support some native wildlife, but at very low density. 4-5. Please refer to response 4-4 above regarding construction-related loss of foraging habitat. As indicated by that response, the Project would result in long-term habitat enhancements that would increase habitat value that would enhance the potential for wildlife foraging on the project site, and 27.3 acres of existing habitat would be preserved on the South Parcel. Therefore, the project would have a beneficial long-term cumulative impact related to raptor foraging. Based on the results of the cover board surveys described in Response 4-4 above, it does not appear the project would result in a substantial loss of vole habitat. In addition, there is more evidence for vole use in the remnant portion of native grassland on the Ellwood Mesa, west of the project site, which is being used as a reference site for the proposed Project. Further, CCBER has proposed (Stratton, April 16, 2016) to enhance portions of the project site for smaller organisms through constructing hybernaculums, which CCBER has been constructing on North Parcel by digging holes and filling them with a variety of rock and tile material to create holes and crevices for holding water, providing cover and multiple small entry/exit points with temperature control provided by soil cover over the feature. These features, along with the presence of more than 500 acres of open space adjacent that the project site to the west and south, will act as a refugia and a source for recolonization of the project site by species such as voles, mice and reptiles. 4-6. Section 5.4.1 (Biological Resources Setting) provides the following description of previous field surveys that have been conducted on the project site:

Page 3 The biological resources setting has been established by Sage Institute, Inc. (SII) biologist/ecologist field surveys conducted in the fall and winter 2015-2016 including a formal jurisdictional wetland delineation study, to document existing conditions and ground truth available background information from academic and professional studies conducted over the project site for UCSB as far back as 2000. Many detailed studies have been conducted over the project site as a part of UCSB academic research and for development under the LRDP. Studies included special-status plant and wildlife species surveys, wetland delineation mapping, general plant community and habitat mapping, and bird surveys conducted throughout the year (nesting, foraging, migrating, etc.). The biological resources analysis described below represents the accumulated data from the copious plant and wildlife resources studies based on existing conditions from current 2015-2016 field surveys. 4-7 In addition to the extensive field study efforts that have been completed, CCBER is conducting special status plant surveys on the project site this spring that follow CDFW protocols, and that build on a 2013 Keeler-Wolf study of habitat on South Parcel that was completed using modified habitat associations. The first of the three spring surveys for special status plants found only 1 species, Lonicera subspicata var. subspicata represented by a small number of plants in a proposed disturbance area, and more plants in areas that are to be preserved. CCBER has extensive experience growing and establishing populations of this plant. No seedlings of Centromadia parryi var australis have been found yet, although it is early in the year for this plant. This species is not common on the project site, however, CCBER has been working with this species for 8 years and successfully established populations on several sites on the UCSB Campus, including the San Clemente housing project and on the North Parcel. Any project-related disturbances to these or other sensitive plants located on the project site would be reduced to a less than significant level through compliance with UCSB Long Range Development Plan Policy ESH-30, which requires: New development shall avoid all special-status plant species, including Southern tarplant, to the greatest extent feasible. This policy applies to isolated individual plants that do not meet the definition of ESHA. Special-status species that are ESHA shall be afforded full protection under the ESHA provisions of the LRDP. Where the individual(s) do not meet the definition of ESHA and cannot be feasibly avoided, then it may be relocated provided that the impact to individual species shall be fully mitigated. As requested by this comment, CCBER will provide the Tarplant Restoration Plan required by mitigation measure BIO-1a to CDFW for review. 4-8. MND Section 5.4.2c evaluates potential project-related wetland habitat impacts to sensitive species, and states in part:

Page 4 Temporary construction-related actions such as tree removals, dewatering of creeks and drainages, excavation, and fill activities in waters of the U.S./State have the potential to result in the take (kill, harm, harass) of tidewater goby, western pond turtle, California red-legged frog (should it occur), and nesting birds including raptors. The tidewater goby can inhabit the on-site drainages and cannot survive outside of water and would need to be salvaged and relocated as part of the project implementation. The California red-legged frog and western pond turtle can survive out of water but would also need to be relocated to suitable habitat nearby during construction. Loss of habitat, capture and other take of a federally listed and other special-status wildlife species, and take of an active bird s nest including nest failure, would be a significant impact. This potentially significant but mitigable impact would be reduced to a less than significant level by implementing mitigation measures BIO-2a, BIO-2b, BIO-2c, BIO-3a, BIO-3b, BIO-4a and BIO-4b. In addition, the analysis also evaluated the potential for the project to result in long-term impacts to sensitive and common species associated with on-site wetland habitat and concluded: The Project would restore and return the highly modified former golf course and borrow areas to a mosaic of pre-disturbance conditions that provide tidally influenced habitats and surrounding uplands restored with native plants. For both special-status and common wildlife species, this would be an overall long-term beneficial impact as the habitat for the special-status species that currently exists on the project site would be substantially enhanced. Please also refer to Responses 4-4, 4-5 and 4-6 above regarding project-related impacts to common wildlife species on the project site, the project s long-term cumulative impacts, and previous and on-going surveys conducted on the project site. 4-9. The three sycamore trees located on the project site are dispersed throughout the site, with one tree located near the southern segment of Devereux Creek, one tree near the western segment of the Creek, and one tree located near the tributary on the eastern portion of the site. The two oak trees are located along the southern segment of Devereux Creek. Areas that support willows are located on the eastern portion of the South Parcel and are to be retained. In regard to salvaging both live and dead trees on the project site, MND Section 2.7.1 (Project Implementation) states: Prior to grading operations with a specified area the surface vegetation would be removed. Native vegetation would be salvaged to the extent possible. Herbaceous vegetation that is removed may be buried on the project site, and woody vegetation would be transported off-site. Except in situations where public safety or flood protection concerns prohibit, dead or dying trees may be retained in place as they serve important habitat functions in providing nesting and breeding habitat areas for wildlife. (emphasis added).

Page 5 In addition, trunks and big branches of large removed trees would be retained on-site and used to provide vertical and horizontal habitat elements such as perches, cover, habitat, graineries, and cavities (Stratton, April 21, 2016). In regard to tree removals from the project site and replanting requirements, it should be noted that more than 100 oak trees are being planted and another 100 have already been planted on Coal Oil Point Reserve adjacent to the project site. These trees will grow to support white-tailed kites and other raptors and song birds, which will be able to forage on the project site from an excellent vantage point. If soils are suitable on the north side of South Parcel, oaks will be planted there also. In addition, the proposed widening of the small ditch creek on the Whittier parcel will greatly enhance that habitat, and the area adjacent to the drainage would be planted with more than 40 riparian trees including willow, sycamore, cottonwood, alder and oaks (Stratton, April 16, 2016). The additional trees will substantially increase the habitat value of this area as the existing channel supports only a few willows. It should also be noted that the previous widening of Phelps creek north of the project site, which occurred in conjunction with the development of the UCSB Ocean Walk housing project, greatly expanded that riparian corridor and that area now includes oaks, cottonwoods and sycamore that are becoming well established. In regard to the potential for the project to adversely affect bats that use on-site trees, there is no record of sensitive bat species being observed on the project site. However, CCBER will consult with CDFW prior to conducting on-site bat surveys in conjunction with required pre-construction bird nest surveys required by MND mitigation measures BIO- 2a, 2b and 2c. 4-10. As described by responses 4-4 and 4-5 above, the MND determined that project-related grading and grubbing impacts such as those described by this comment would be less than significant. However, CCBER will continue to work with the CDFW to address the Department s concerns in conjunction with the preparation of a project-specific Habitat Restoration and Monitoring Plan. MND Section 2.7.3 (Maintenance) provides the following description of the Habitat Restoration and Monitoring Plan: A Habitat Restoration and Monitoring Plan to be prepared for the Project will include monitoring and adaptive management measures, and would be completed as part of final project design. The Plan would also include requirements specified by the Project s environmental review, conditions required by the Project s permitting and or grant funding agencies, and project-specific monitoring protocols and project performance/success criteria. On-going monitoring would be performed to evaluate vegetation establishment, wildlife utilization, physical processes, and site conditions related to potential development of hazards such as slope stability and flood capacity. The monitoring plan would include the following elements:

Page 6 Recording of as-built conditions Establishment of permanent monitoring stations (e.g. cross-sections, photo points, transects) Monitoring schedule Monitoring protocols (standardized for consistency in data collection and documentation) Reporting requirements Success criteria Corrective /adaptive management measures or process In addition, CCBER will implement mitigation measures and conditions of approval that may be included in the Streambed Alteration Agreement issued for the project as required by MND mitigation measure BIO-4b. 4-11. The proposed western snowy plover habitat would have characteristics that are very similar to the existing plover area located in the vicinity of the Devereux Slough, which is currently used by snowy plovers as a nesting site. 4-12. Please refer to response 4-10. 4-13. Please refer to response 4-10. 4-14. As requested by this comment, CCBER will provide the salvage and relocation plans for tidewater goby, California red-legged frog, and western pond turtle to CDFW for review. 4-15. The MND provides an analysis of the Project s consistency with applicable policies of the UCSB 2010 Long Range Development Plan (LRDP). LRDP Policy ESH-05 requires that: Nature trails, intended for the passive enjoyment of the open space/esha resource, shall be restricted to pedestrian use and sited to afford the user an experience of the resource, provided that such trails are designed to protect the resource. As indicated by the MND s analysis that is provided below, the Project would be consistent with the requirements of LRDP Policy ESH-05, which would minimize the potential for the proposed secondary and tertiary trails to result in impacts to on-site habitat. The Project has proposed to develop several types of trails on the project site. The proposed primary trail would be a multi-use (pedestrian and bicycles) trail that would provide nature viewing as well as a circulation connection between residences adjacent to the project site to the north and east and Storke Road. The proposed secondary and tertiary trails would be located on the South Parcel and are intended to be used primarily by pedestrians and to allow users the opportunity to experience the natural character of the restored project areas (refer to trail descriptions provided on IS/MND Figure 2.6-2). Should on-going monitoring of the project site indicate that indirect impacts to a sensitive habitat area is occurring, methods that would be implemented to minimize those effects

Page 7 may include but are not limited to the installation of additional landscape barriers, post and cable and/or split rail fencing, or other similar barriers that do not interfere with animal movement. It is possible that bicycles and off-leash dogs will be prohibited on trails that are to be constructed on the South Parcel. All trails on the project site will be designed to not erode or pond water. 4-16. As described in response 4-8 above, the MND has evaluated project-related impacts to wetland habitat and impacts to aquatic species. The analysis provided by the MND indicates that the project would have the potential to result in significant impacts, however, those impacts would be reduced to a less than significant level with the implementation of identified mitigation measures. CCBER will continue to work with the CDFW to implement mitigation measures and conditions of approval that may be included in the Streambed Alteration Agreement issued for the project as required by MND mitigation measure BIO-4b.