Agenda packet — Agoura Hills City Council, May 27, 2026 (part 5 of 7)

CDFW may also act as a Responsible Agency under CEQA. (Pub. Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law2 of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.) or the Native Plant Protection Act (NPPA; Fish & G. Code, §1900 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Agoura Hills (City)
Objective: The objective of the Project is to create a network of bike corridors, as well as support facilities and programs to link local and regional destinations and make biking more practical and desirable for a broader range of people. Components of the proposed Project include the Bicycle Master Plan, the Vehicle Miles Traveled Mitigation Exchange and Banking Program, and General Plan Amendments. The Bicycle Master Plan proposes 30.1 miles of new bikeways to build upon the City’s existing 1.3 miles of bicycle routes and 9.2 miles of bicycle lanes. The Medea Creek Path, a two-mile bicycle path along Medea Creek Channel, and the Agoura High School Connection, a 0.35-mile bicycle path connecting two intersections adjacent to Agoura High School, are prioritized for implementation.

Location: The Planning Area for the Project includes the existing City boundaries (approximately 7.86 square miles). The City is located in western Los Angeles County near the southeastern edge of Ventura County. It is bordered by the City of Westlake Village to the west, the City of Thousand Oaks to the northwest, the unincorporated community of Oak Park (Ventura County) to the north, the City of Calabasas and unincorporated areas of Los Angeles County to the east, and unincorporated areas of Los Angeles County to the south.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

2 “Take” is defined in Section 86 of the Fish and Game Code as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.”
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General Comments
1) Disclosure. The PEIR should provide an adequate, complete, and detailed disclosure about the effects which a proposed project is likely to have on the environment (Pub. Resources Code, § 20161; CEQA Guidelines, § 15151). Such disclosure is necessary so CDFW may provide comments on the adequacy of proposed avoidance, minimization, or mitigation measures, as well as assess the significance of the specific impact relative to plant and wildlife species impacted (e.g., current range, distribution, population trends, and connectivity). 2) Project Description and Alternatives. To enable adequate review and comment on the proposed Project from the standpoint of the protection of fish, wildlife, and plants, CDFW recommends the following information be included in the PEIR. a. A complete discussion of the purpose and need for, and description of the proposed Project.
b. A range of feasible alternatives to the Project location to avoid or otherwise minimize direct and indirect impacts on sensitive biological resources and wildlife movement areas. CDFW recommends the City select Project designs and alternatives that would avoid or otherwise minimize direct and indirect impacts on biological resources. CDFW also recommends the City consider establishing appropriate setbacks from sensitive and special status biological resources. Setbacks should not be impacted by ground disturbance or hydrological changes from any future Project-related construction, activities, maintenance, and development. As a general rule, CDFW recommends reducing or clustering a development footprint to retain unobstructed spaces for vegetation and wildlife and provide connections for wildlife between properties and minimize obstacles to open space.
c. Project alternatives should be thoroughly evaluated, even if an alternative would impede, to some degree, the attainment of the Project objectives or would be more costly (CEQA Guidelines, § 15126.6). The PEIR shall include sufficient information about each alternative to allow meaningful evaluation, public participation, analysis, and comparison with the proposed Project (CEQA Guidelines, § 15126.6).
d. Where the Project may impact aquatic and riparian resources, CDFW recommends the City select Project designs and alternatives that would fully avoid impacts to such resources. CDFW also recommends an alternative that would not impede, alter, or otherwise modify existing surface flow, watercourse and meander, and water-dependent ecosystems and natural communities.

Project designs should consider elevated crossings to avoid channelizing or narrowing of watercourses. Any modifications to a river, creek, or stream may Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B Charmaine Yambao
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cause or magnify upstream bank erosion, channel incision, and drop in water level, which may cause the watercourse to alter its course of flow. 3) Biological Baseline Assessment. An adequate biological resources assessment should provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the Project site and where the Project may result in ground disturbance. The assessment and analysis should place emphasis on identifying endangered, threatened, rare, and sensitive species; regionally and locally unique species; and sensitive habitats. An impact analysis will aid in determining the Project’s potential direct, indirect, and cumulative biological impacts, as well as specific mitigation or avoidance measures necessary to offset those impacts.

CDFW also considers impacts to Species of Special Concern (SSC) a significant direct and cumulative adverse effect without implementing appropriate avoidance and/or mitigation measures. The DEIR should include the following information. a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region (CEQA Guidelines, § 15125(c)). The DEIR should include measures to fully avoid and otherwise protect Sensitive Natural Communities.

CDFW considers Sensitive Natural Communities as threatened habitats having both regional and local significance. Natural communities, alliances, and associations with a State-wide rarity ranking of S1, S2, and S3 should be considered sensitive and declining at the local and regional level. These ranks can be obtained by visiting the Vegetation Classification and Mapping Program - Natural Communities webpage3.
b. A thorough, recent, floristic-based assessment of special status plants and natural communities following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities4. Botanical field surveys should be comprehensive over the entire Project site, including areas that will be directly or indirectly impacted by the Project. Adjoining properties should also be surveyed where direct or indirect Project effects could occur, such as those from fuel modification, herbicide application, invasive species, and altered hydrology. Botanical field surveys should be conducted in the field at the times of year when plants will be both evident and identifiable. Usually, this is during flowering or fruiting. Botanical field survey visits should be spaced throughout the growing season to accurately determine what plants exist in the Project site. This usually involves multiple visits to the Project site (e.g., in early, mid, and late season) to capture the floristic diversity at a level necessary to determine if special status plants are present.

3 https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities 4 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B Charmaine Yambao
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c. Floristic alliance- and/or association-based mapping and vegetation impact assessments conducted in the Project site and within adjacent areas. The Manual of California Vegetation5, second edition, (Sawyer, Keeler-Wolf, & Evens, 2009) should also be used to inform this mapping and assessment. Adjoining habitat areas should be included in this assessment where the Project’s construction and activities could lead to direct or indirect impacts offsite. d. A complete and recent assessment of the biological resources associated with each habitat type in the Project site and within adjacent areas. A full literature review includes but is not limited to CDFW’s California Natural Diversity Database
6 (CNDDB). The CNDDB should be accessed to obtain current information on any previously reported sensitive species and habitat. An assessment should include a minimum nine-quadrangle search of the CNDDB to determine a list of species potentially present in the Project site. A ninequadrangle search should be provided in the Project’s CEQA document for adequate disclosure of the Project’s potential impact on biological resources. e. A complete, recent, assessment of endangered, rare, or threatened species and other sensitive species within the Project site and adjacent areas, including SSC and California Fully Protected Species (Fish & G. Code, §§ 3511, 4700, 5050, and 5515). Species to be addressed should include all those which meet the CEQA definition of endangered, rare, or threatened species (CEQA Guidelines, § 15380). Seasonal variations in use of the Project site should also be addressed such as wintering, roosting, nesting, and foraging habitat. Focused speciesspecific surveys, conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable, may be required if suitable habitat is present. See CDFW’s Survey and Monitoring Protocols and Guidelines7for established survey protocol. Acceptable species-specific survey procedures may be developed in consultation with CDFW and U.S. Fish and Wildlife Service.
f. A recent wildlife and rare plant survey. A lack of records in the CNDDB does not mean that rare, threatened, or endangered plants and wildlife do not occur. Field verification for the presence or absence of sensitive species is necessary to provide a complete biological assessment for adequate CEQA review (CEQA Guidelines, § 15003(i)). CDFW generally considers biological field assessments for wildlife to be valid for a one-year period, and assessments for rare plants may be considered valid for a period of up to three years. Some aspects of the proposed Project may warrant periodic updated surveys for certain sensitive taxa, particularly if Project implementation build out could occur over a protracted time frame or in phases.

5 https://vegetation.cnps.org/
6 https://wildlife.ca.gov/Data/CNDDB
7 https://wildlife.ca.gov/conservation/survey-protocols Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B Charmaine Yambao
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4) Direct and Indirect Impacts on Biological Resources. The PEIR should provide a thorough discussion of direct and indirect impacts expected to affect biological resources with specific measures to offset such impacts. The PEIR should address the following.
a. A discussion of potential impacts from lighting, noise, temporary and permanent human activity, and exotic species, and identification of any mitigation measures. A discussion regarding Project-related indirect impacts on biological resources. These include resources in nearby public lands, open space, adjacent natural habitats, riparian ecosystems, and any designated and/or proposed or existing reserve lands (e.g., preserve lands associated with a Natural Community Conservation Plan (Fish & G. Code, § 2800 et. seq.)). b. A discussion of both the short-term and long-term effects of the Project on species population distribution and concentration, as well as alterations of the ecosystem supporting those species impacted (CEQA Guidelines, § 15126.2(a)).
c. Impacts on, and maintenance of, wildlife corridor/movement areas, including access to undisturbed habitats in areas adjacent to the Project, should be fully analyzed and discussed in the PEIR.
d. A discussion of post-Project fate of drainage patterns, surface flows, and soil erosion and/or sedimentation in streams and water bodies. The discussion should also address the potential water extraction activities and the potential resulting impacts on habitat supported by the groundwater. Measures to mitigate such impacts should be included.
e. An analysis of impacts from proposed changes to land use designations and zoning, and existing land use designation and zoning located nearby or adjacent to natural areas that may inadvertently contribute to wildlife-human interactions.

A discussion of possible conflicts and mitigation measures to reduce these conflicts should be included in the PEIR.
5) Cumulative Impact. Cumulative impacts on biological resources can result from collectively significant projects which are individually insignificant. The Project, when considered collectively with prior, concurrent, and probable future projects, may have a significant cumulative effect on biological resources. The Project may have the potential to substantially reduce the number or restrict the range of endangered, rare, or threatened species. Species that may be impacted by the Project include, but are not limited to, the biological resources described in this letter.

Accordingly, CDFW recommends the PEIR evaluate the Project’s potential cumulative impacts on biological resources. The Project may have a “significant effect on the environment” if the possible effects of the Project are individually Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B Charmaine Yambao
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limited but cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects (Pub. Resources Code, § 21083(b)). The City’s conclusions regarding the significance of the Project’s cumulative impact should be justified and supported by evidence to make those conclusions.

Specifically, if the City concludes that the Project would not result in cumulative impacts on biological resources, the City, “shall identify facts and analysis supporting the Lead Agency’s conclusion that the cumulative impact is less than significant” (CEQA Guidelines section § 15130(a)(2)).
6) Nesting Birds. To avoid impacts to nesting birds, CDFW recommends that clearing of vegetation occur outside of the peak avian breeding season, which general runs from February 1 through September 1 (as early as January 1 for some raptors). If Project construction is necessary during the bird breeding season, a qualified biologist with experience in conducting breeding bird surveys should conduct a nesting bird survey within three days prior to work in the area. If an active nest is identified, a buffer shall be established between the construction activities and the nest so that nesting activities are not interrupted. For the given Project site, CDFW generally recommends a 100-foot buffer from common avian species, 300 feet for listed or highly sensitive, and 500 feet for raptors. The buffer should be delineated by temporary fencing and remain in effect as long as construction is occurring. No Project construction shall occur within the fenced nest zone until the young have fledged, are no longer being fed by the parents, have left the nest, and will no longer be impacted by the Project. Reductions or expansions in the nest buffer distance may be appropriate depending on the avian species involved, ambient levels of human activity, screening vegetation, or possibly other factors. 7) Mitigation Measures. Public agencies have a duty under CEQA to prevent significant, avoidable damage to the environment by requiring changes in a project through the use of feasible alternatives or mitigation measures (CEQA Guidelines, §§ 15002(a)(3), 15021). Pursuant to CEQA Guidelines section 15126.4, an environmental document shall describe feasible measures which could mitigate impacts below a significant level under CEQA. Mitigation measures must be feasible, effective, implementable, and fully enforceable/imposed by the lead agency through permit conditions, agreements, or other legally binding instruments (Pub. Resources Code, § 21081.6(b); CEQA Guidelines, § 15126.4). a. The DEIR should provide mitigation measures that are specific and detailed (i.e., responsible party, timing, specific actions, location) in order for a mitigation measure to be fully enforceable and implemented successfully via a mitigation monitoring and/or reporting program (Pub. Resources Code, § 21081.6; CEQA Guidelines, § 15097).

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b. If a proposed mitigation measure would cause one or more significant effects, in addition to impacts caused by the proposed Project, the DEIR should include a discussion of the effects of proposed mitigation measures (CEQA Guidelines, § 15126.4(a)(1)). In that regard, the DEIR should provide an adequate, complete, and detailed disclosure about the Project’s proposed mitigation measure(s).

Adequate disclosure is necessary so CDFW may assess the potential impacts of proposed mitigation measures.
8) Compensatory Mitigation. The PEIR should include compensatory mitigation measures for the Project’s significant impacts (direct and/or through habitat modification) to sensitive and special status plants, animals, and habitats. Mitigation measures should emphasize avoidance and minimization of Project-related impacts. For unavoidable impacts, on-site habitat restoration or enhancement should be discussed in detail. If on-site mitigation is not feasible or would not be biologically viable and therefore inadequate to mitigate the loss of biological functions and values, off-site mitigation through habitat creation and/or acquisition and preservation in perpetuity should be addressed. Areas proposed as mitigation lands should be protected in perpetuity with a conservation easement and financial assurance and dedicated to a qualified entity for long-term management and monitoring.
9) Long-term Management of Mitigation Lands. For proposed mitigation lands, the PEIR should include measures to protect the targeted habitat values in perpetuity.

The mitigation should offset Project-induced qualitative and quantitative losses of biological resources. Issues that should be addressed include (but are not limited to) restrictions on access, proposed land dedications, monitoring and management programs, control of illegal dumping, water pollution, and increased human intrusion. An appropriate endowment should be set aside to provide for long-term management of mitigation lands.
10) CESA. CDFW considers adverse impacts to a species protected by CESA to be significant. Take of any endangered, threatened, candidate species, or NPPA-listed plant species that results from the Project is prohibited, except as authorized by state law (Fish & G. Code §§ 2080, 2085; Cal. Code Regs., tit. 14, §786.9).

Consequently, if the Project or any Project-related activity will result in take of a species designated as endangered or threatened, or a candidate for listing under CESA, CDFW recommends that the Project proponent seek appropriate take authorization under CESA prior to implementing the Project. Appropriate authorization from CDFW may include an Incidental Take Permit (ITP) or a consistency determination in certain circumstances, among other options (Fish & G.

Code, §§ 2080.1, 2081, subds. (b) and (c)). Early consultation is encouraged, as significant modification to a Project and mitigation measures may be required to obtain a CESA Permit.

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To ensure CDFW will be able to use the City’s CEQA document for the issuance of an ITP, the PEIR should address all Project impacts to CESA-listed species and specify a mitigation, monitoring, and reporting program that will meet the requirements of an ITP.
11) Translocation/Salvage of Plants and Animal Species. Translocation and transplantation is the process of removing plants and wildlife from one location and permanently moving it to a new location. CDFW generally does not support the use of translocation or transplantation as the primary mitigation strategy for unavoidable impacts to endangered, rare, or threatened plants and animals. These efforts are experimental, and the outcome is unreliable. CDFW has found that permanent preservation and management of habitat capable of supporting these species is often a more effective long-term strategy for conserving plants and animals and their habitats.
12) Scientific Collecting Permit. A Scientific Collecting Permit would be necessary if there is a plan to capture and relocate wildlife. Pursuant to the California Code of Regulations, title 14, section 650, qualified biologist(s) must obtain appropriate handling permits to capture, temporarily possess, and relocated wildlife to avoid harm or mortality in connection with Project-related activities. CDFW has the authority to issue permits for the take or possession of wildlife, including mammals; birds, nests, and eggs; reptiles, amphibians, fish, plants; and invertebrates (Fish & G. Code, §§ 1002, 1002.5, 1003). A Scientific Collecting Permit is required to monitor project impacts on wildlife resources, as required by environmental documents, permits, or other legal authorizations; and, to capture, temporarily possess, and relocate wildlife to avoid harm or mortality in connection with otherwise lawful activities (Cal. Code Regs., tit. 14, § 650). For more information, please see CDFW’s Scientific Collecting Permit webpage8. 13) Lake and Streambed Alteration. CDFW has regulatory authority over activities in streams that will divert or obstruct the natural flow, or change the bed, channel, or bank (which may include associated riparian resources) of any river, stream, or lake or use material from a river, stream, or lake. For any such activities, the Project applicant (or “entity”) must provide written notification to CDFW pursuant to section 1600 et seq. of the Fish and Game Code. Based on this notification and other information, CDFW determines whether a Lake and Streambed Alteration Agreement (LSAA) with the applicant is required prior to conducting the proposed activities. CDFW’s issuance of a LSAA for a project that is subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. CDFW recommends that the City assess whether notification is appropriate. A Notification

8 https://wildlife.ca.gov/Licensing/Scientific-Collecting Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B Charmaine Yambao
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package for a LSAA may be obtained by accessing CDFW’s Lake and Streambed Alteration Program website9.
14) Wetland Resources. CDFW, as described in Fish and Game Code section 703(a), is guided by the Fish and Game Commission’s (Commission) policies10. Through its Wetlands Resources policy, the Commission “…seek[s] to provide for the protection, preservation, restoration, enhancement, and expansion of wetland habitat in California” (California Fish and Game Commission, 2005). It is the policy of the Commission to strongly discourage development in or conversion of wetlands. It opposes, consistent with its legal authority, any development or conversion that would result in a reduction of wetland acreage or wetland habitat values. To that end, the Commission opposes wetland development proposals unless, at a minimum, project mitigation assures there will be ‘no net loss’ of either wetland habitat values or acreage. The Commission strongly prefers mitigation which would achieve expansion of wetland acreage and enhancement of wetland habitat values.”
a. The Wetlands Resources policy provides a framework for maintaining wetland resources and establishes mitigation guidance. CDFW encourages avoidance of wetland resources as a primary mitigation measure and discourages the development or type conversion of wetlands to uplands. CDFW encourages activities that would avoid the reduction of wetland acreage, function, or habitat values. Once avoidance and minimization measures have been exhausted, a project should include mitigation measures to assure a “no net loss” of either wetland habitat values, or acreage, for unavoidable impacts to wetland resources. Conversions include, but are not limited to, conversion to subsurface drains, placement of fill or building of structures within the wetland, and channelization or removal of materials from the streambed. All wetlands and watercourses, whether ephemeral, intermittent, or perennial, should be retained and provided with substantial setbacks, which preserve the riparian and aquatic values and functions benefiting local and transient wildlife populations. CDFW recommends mitigation measures to compensate for unavoidable impacts be included in the DEIR and these measures should compensate for the loss of function and value.
b. The Fish and Game Commission’s Water policy guides CDFW on the quantity and quality of the waters of this State that should be apportioned and maintained respectively so as to produce and sustain maximum numbers of fish and wildlife; to provide maximum protection and enhancement of fish and wildlife and their habitat; encourage and support programs to maintain or restore a high quality of the waters of this State; prevent the degradation thereof caused by pollution and contamination; and, endeavor to keep as much water as possible open and

9 http://www.wildlife.ca.gov/Conservation/LSA
10 https://fgc.ca.gov/About/Policies/Miscellaneous
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accessible to the public for the use and enjoyment of fish and wildlife. CDFW recommends avoidance of water practices and structures that use excessive amounts of water, and minimization of impacts that negatively affect water quality, to the extent feasible (Fish & G. Code, § 5650). 15) Use of Native Plants and Trees. CDFW recommends the City require the Project Applicant to provide a native plant palette for the Project. The Project’s landscaping plan should be disclosed and evaluated in the PEIR for potential impacts on biological resources such as natural communities adjacent to the Project site (e.g., introducing non-native, invasive species). CDFW supports the use of native plants for the Project especially considering the Project’s location adjacent to protected open space and natural areas. CDFW strongly recommends avoiding non-native, invasive species for landscaping and restoration, particularly any species listed as ‘Moderate’ or ‘High’ by the California Invasive Plant Council11 CDFW supports the use of native species found in naturally occurring plant communities within or adjacent to the Project site. In addition, CDFW supports planting species of trees, such as oaks (Quercus genus), and understory vegetation (e.g., ground cover, subshrubs, and shrubs) that create habitat and provide a food source for birds.

CDFW recommends retaining any standing, dead, or dying tree (snags) where possible because snags provide perching and nesting habitat for birds and raptors.

Finally, CDFW supports planting species of vegetation with high insect and pollinator value.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNDDB website12 provides direction regarding the types of information that should be reported and allows on-line submittal of field survey forms.

In addition, information on special status native plant populations and sensitive natural communities, should be submitted to CDFW’s Vegetation Classification and Mapping Program using the Combined Rapid Assessment and Relevé Form13.

The City should ensure data collected for the preparation of the PEIR is properly submitted.

11 https://www.cal-ipc.org/plants/inventory/
12 https://wildlife.ca.gov/Data/CNDDB
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FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)

CONCLUSION
CDFW appreciates the opportunity to comment on the NOP to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Kelly Fisher14, Environmental Scientist.

Sincerely,
Victoria Tang
Environmental Program Manager
South Coast Region
ec: California Department of Fish and Wildlife
Victoria Tang
Jennifer Turner
Kelly Fisher
Office of Planning and Research
[email protected]

REFERENCES
Sawyer, J. O., Keeler-Wolf, T., & Evens, J. M. (2009). A Manual of California Vegetation (Second ed.). Sacramento, CA: California Native Plant Society. Retrieved from https://vegetation.cnps.org/

14 Phone: 858-354-5083; Email: [email protected] Docusign Envelope ID: DA8041A1-39B5-410B-B16A-DB36B3875A1B [
DocuSigned by:
1)4~
5991E19EF8094C3 ..
100 Civic Center Way
Calabasas, CA 91302
(818) 224-1600
January 27, 2025
Charmaine Yambao, PE
Senior Civil Engineer, Public Works
30001 Ladyface Court
Agoura Hills, CA 91301
Subject: Notice of Preparation (NOP) of a Programmatic Environmental Impact Report for the Bicycle Master Plan.

Dear Ms. Yambao,
The City of Calabasas is in receipt of your Notice of Public Scoping Meeting regarding the City of Agoura Hills Bicycle Master Plan scheduled for February 6, 2025 at the City of Agoura Hills Council Chambers. The City would like to forward the following comments relative to the Programmatic Environmental Impact Report:
• The City of Calabasas is interested in the availability and connectivity of safe bicycle infrastructure across the Conejo Valley to provide alternative transportation choices and recreational opportunities. We would like to be invited to any public project meetings related to the project or the environmental document.
• Please provide copies of the draft Bicycle Master Plan and the draft environmental document for our review when available.

Thank you for the opportunity to comment on the PEIR. Please direct future correspondence, meeting invitations, and future plan coordination opportunities to Tra’a Bezdecny in the City’s Public Works Department. She may be contacted at (818) 224-1673 (direct line), or at [email protected] (email).

CITY of CALABASAS
Sincerely,
____________________________________
Michael Klein, AICP
Community Development Director
(818) 224-1701
[email protected]

VENTURA COUNTY

AIR POLLUTION CONTROL DISTRICT
Memorandum
TO: Charmaine Yambao, Public Works DATE: February 10, 2025 FROM: Nicole Collazo, Air Quality Specialist, Planning Division SUBJECT: Notice of Preparation of a Draf Environmental Impact Report for City of Agoura Hills Bicycle Master Plan (RMA 25-003)
Ventura County Air Pollution Control District (APCD) staff has reviewed the subject Notice of Preparation (NOP) for the draft environmental impact report (DEIR), which will analyze the environmental impacts of the construction of 30.1 miles of new bikeways and bikeway improvements to build upon the city’s existing 1.3 miles of bicycle routes and 9.2 miles of bicycle lanes. The BMP aims to create a network of diverse bike corridors, as well as support facilities and programs to link local and regional destinations and make biking more practical and desirable for a broader range of people. The Lead Agency is the City of Agoura Hills within Los Angeles County.

APCD has the following comments regarding the project’s NOP.

NOP Comments
1) Due to the proximity of the project to the City of Thousand Oaks residential neighborhoods and unincorporated Oak Park residential areas, please consider the potential for fugitive dust generated from grading/construction activities in constructing bike paths near these areas in the project DEIR’s Air Quality Section and what measures will be taken to ensure impacts remain low, including the potential for compliance-driven violations of VCAPCD Rules 50, Opacity, Rule 51, Nuisance, and Rule 55, Fugitive Dust.

Thank you for the opportunity to comment on the NOP. If you have any questions, you may contact me at [email protected].

VENTURA COUNTY

AIR POLLUTION

CONTROL DISTRICT

ALI REZA GHASEMI , PE
Air Pollution Control Officer
4567 Telephone Road, 2nd Floor I Ventura, CA 93003
Phone: 805.303.4005 I Fax: 805.456.7797
~. COUNTY c{- VENTURA
February 11, 2025
Charmaine Yambao
City of Agoura Hills
30001 Ladyface Court
Agoura Hills, CA 93101
Sent via email: [email protected]

RESOURCE MANAGEMENT AGENCY

DAVE WARD
Planning Director

SUSAN CURTIS
Assistant Planning Director
SUBJECT: Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) of a Bicycle Master Plan
Dear Charmaine,
Thank you for providing the County of Ventura Planning Division with the opportunity to comment on the Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) of a Bicycle Master Plan.

The Bicycle Master Plan includes:
• A Bicycle Master Plan that proposed 30.1 miles of new bikeways and bikeway improvements to create a network of diverse bike corridors and make biking more practical and desirable;
• Vehicle Miles Traveled (VMT) Mitigation Exchange and Banking Program that would establish a mitigation program for developers to purchase VMT reduction credits that would fund the bicycle plan improvements; and, • General Plan Amendments to the Infrastructure and Community Services Element for consistency with the Bicycle Master Plan.

Ventura County General Plan
The County's General Plan recognizes the importance of a circulation, transportation, and mobility (CTM) network that reduces greenhouse gas emissions, promotes active transportations, and increases roadway safety. The following General Plan Goals and Policies support a regional mobility plan that encourages alternative modes of transportation:

Goal: Regional Multimodal System (CTM-2): To facilitate the safe, efficient, and cost-effective movement of all users, including bicyclists, pedestrians, public transportation riders, children, older people, and disabled people, as well as motorists through the provision of an integrated multimodal system.

Policy: Countywide Bicycle Land and Trail System {CTM-2.12): The County shall coordinate with cities in the county and Ventura County Transportation Commission (VCTC) to plan and implement a system of bicycle lanes and multi-use trails that link the cities, unincorporated communities, schools including colleges and universities, HALL OF ADMINISTRATION #1740
(805) 654-2481 • FAX (805) 654-2509 • 800 South Victoria Avenue, Ventura, CA 93009 • vcrma.org Agoura Hills Master Bicycle Plan
NOP for a Draft EIR
February 11 , 2025

Page 2 of 2 ends

commercial/retail, employment centers, health care service facilities, public transportation, and other points of interest.

Goal: Regional Multimodal System (CTM-3): To develop an accessible and interconnected bicycle network that addresses resident and visitor needs for commuting, daily activities, and recreation.

Policy: lnterjurisdictional Bicycle Network Connectivity (CTM-3.4): The County shall promote bicycle network connectivity between Ventura County communities as well as Santa Barbara and Los Angeles Counties.

Policy: Bicycle Network Routes and Wayfinding (CTM-3.8): The County shall use clear and consistent message and placement for on- and off-street regional bikeways and to regional destinations.

For the complete 2040 General Plan, please visit the Planning Division website at https://vcrma.org/divisions/planning/ventura-county-general-plan/.

Recommendations
The County's Ventura Public Works Agency oversees the Active Transportation Plan (2024) that identified 80 miles of bicycle facilities and several wayfinding routes. The City's Bicycle Master Plan proposes that the bicycle route along Kanan Road be upgraded to a Class IV separated bikeway, with a protected bike lane separate from vehicular traffic.

Kanan Road connects to the unincorporated County community of Oak Park and the City's proposed improvements would benefit both City and County residents. The City's improvements along Kanan Road support the General Plan Policies CTM-2.12 and CTM3.4.

The County portion of Kanan Road is currently a Class II bike lane, marked by striping and signage, and the County's Active Transportation Plan recommends that Kanan Road be upgraded to a Class 118 buffered bikeway. When City's improvements along Kanan Road begin, please contact the County to coordinate striping, signage, and wayfinding for bicyclists when there is a transition from a Class II to a Class IV bikeway or vice versa in accordance with Policy CTM-3.8.

As stated in Policy CTM-2.12, the County coordinates with the Ventura County Transportation Commission (VCTC) on maintaining and expanding bike land infrastructure. VCTC hosts an online map (https://www.qoventura.org/gettingaround/bike-map/) of the existing bike lanes in Ventura County. Please notify VCTC when the improvements along Kanan Road are completed so the online map can be updated which helps inform both city and county residents of their bike route planning.

If you have any questions about this letter, please contact Brittany Webber at [email protected] or (805) 654-2469.

Sincerely,
Dave Ward, AICP
Planning Director
Appendix B
CalEEMod Modeling Outputs
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Medea Creek Bike Path Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

3. Construction Emissions Details

3.1. Linear, Grubbing & Land Clearing (2026) - Unmitigated

3.3. Linear, Grading & Excavation (2026) - Unmitigated

3.5. Linear, Drainage, Utilities, & Sub-Grade (2026) - Unmitigated

3.7. Linear, Paving (2026) - Unmitigated

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Medea Creek Bike Path Detailed Report, 2/3/2025
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4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.18. Vegetation

5.18.1. Land Use Change
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5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Medea Creek Bike Path
Construction Start Date 1/1/2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 9.80
Location Agoura Hills, CA 91301, USA
County Los Angeles-South Coast
City Agoura Hills
Air District South Coast AQMD
Air Basin South Coast
TAZ 3813
EDFZ 7
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Road Construction 2.00 Mile 3.40 0.00 — — — —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.69 3.11 25.4 31.7 0.06 1.09 1.77 2.86 1.00 0.26 1.26 — 7,069 7,069 0.29 0.08 1.92 7,101 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.69 3.11 25.4 31.3 0.06 1.09 1.77 2.86 1.00 0.26 1.26 — 7,041 7,041 0.29 0.08 0.05 7,071 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.89 1.59 13.1 16.3 0.03 0.54 0.91 1.45 0.50 0.14 0.63 — 3,667 3,667 0.15 0.04 0.47 3,683 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.34 0.29 2.39 2.98 0.01 0.10 0.17 0.26 0.09 0.02 0.12 — 607 607 0.02 0.01 0.08 610

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 3.69 3.11 25.4 31.7 0.06 1.09 1.77 2.86 1.00 0.26 1.26 — 7,069 7,069 0.29 0.08 1.92 7,101 -------------------
-------------------
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Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 3.69 3.11 25.4 31.3 0.06 1.09 1.77 2.86 1.00 0.26 1.26 — 7,041 7,041 0.29 0.08 0.05 7,071 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 1.89 1.59 13.1 16.3 0.03 0.54 0.91 1.45 0.50 0.14 0.63 — 3,667 3,667 0.15 0.04 0.47 3,683 Annual — — — — — — — — — — — — — — — — — —
2026 0.34 0.29 2.39 2.98 0.01 0.10 0.17 0.26 0.09 0.02 0.12 — 607 607 0.02 0.01 0.08 610

3. Construction Emissions Details

3.1. Linear, Grubbing & Land Clearing (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.44 0.37 3.22 3.48 < 0.005 0.19 — 0.19 0.17 — 0.17 — 490 490 0.02 < 0.005 — 492 Dust
From
Material
Movement
— — — — — — 0.21 0.21 — 0.02 0.02 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
-------------------
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Off-Roa
Equipment

0.03 0.03 0.22 0.24 < 0.005 0.01 — 0.01 0.01 — 0.01 — 33.6 33.6 < 0.005 < 0.005 — 33.7 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 < 0.005 0.04 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 5.56 5.56 < 0.005 < 0.005 — 5.58 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.07 0.83 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 193 193 0.01 0.01 0.02 195 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 13.4 13.4 < 0.005 < 0.005 0.02 13.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
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Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.22 2.22 < 0.005 < 0.005 < 0.005 2.25 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Linear, Grading & Excavation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.52 2.96 25.2 29.1 0.06 1.09 — 1.09 1.00 — 1.00 — 6,495 6,495 0.26 0.05 — 6,517 Dust
From
Material
Movement
— — — — — — 1.24 1.24 — 0.13 0.13 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 -------------------
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Average — — — — — — — — — — — — — — — — — —
Daily
Off-Roa
d
Equipm
ent

0.97 0.81 6.90 7.97 0.02 0.30 — 0.30 0.27 — 0.27 — 1,779 1,779 0.07 0.01 — 1,785 Dust
From
Material
Movement
— — — — — — 0.34 0.34 — 0.04 0.04 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.18 0.15 1.26 1.45 < 0.005 0.05 — 0.05 0.05 — 0.05 — 295 295 0.01 < 0.005 — 296 Dust
From
Material
Movement
— — — — — — 0.06 0.06 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.17 0.15 0.16 2.58 0.00 0.00 0.52 0.52 0.00 0.12 0.12 — 542 542 0.02 0.02 1.83 550 Vendor < 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 31.2 31.2 < 0.005 < 0.005 0.08 32.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.17 0.15 0.17 2.20 0.00 0.00 0.52 0.52 0.00 0.12 0.12 — 514 514 0.02 0.02 0.05 520 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 31.2 31.2 < 0.005 < 0.005 < 0.005 32.6 Medea Creek Bike Path Detailed Report, 2/3/2025
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.05 0.63 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 143 143 0.01 0.01 0.22 145 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 8.54 8.54 < 0.005 < 0.005 0.01 8.93 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 23.6 23.6 < 0.005 < 0.005 0.04 24.0 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.41 1.41 < 0.005 < 0.005 < 0.005 1.48 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Linear, Drainage, Utilities, & Sub-Grade (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.85 2.39 21.2 23.3 0.05 0.83 — 0.83 0.76 — 0.76 — 5,693 5,693 0.23 0.05 — 5,712 Dust
From
Material
Movement
— — — — — — 1.03 1.03 — 0.11 0.11 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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Off-Roa 2.85 2.39 21.2 23.3 0.05 0.83 — 0.83 0.76 — 0.76 — 5,693 5,693 0.23 0.05 — 5,712 d
Equipm
Dust
From
Material
Movement
— — — — — — 1.03 1.03 — 0.11 0.11 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.69 0.58 5.10 5.62 0.01 0.20 — 0.20 0.18 — 0.18 — 1,372 1,372 0.06 0.01 — 1,377 Dust
From
Material
Movement
— — — — — — 0.25 0.25 — 0.03 0.03 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.13 0.11 0.93 1.03 < 0.005 0.04 — 0.04 0.03 — 0.03 — 227 227 0.01 < 0.005 — 228 Dust
From
Material
Movement
— — — — — — 0.05 0.05 — < 0.005 < 0.005 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.15 0.13 0.14 2.26 0.00 0.00 0.46 0.46 0.00 0.11 0.11 — 474 474 0.02 0.02 1.60 481 Medea Creek Bike Path Detailed Report, 2/3/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.15 0.13 0.15 1.93 0.00 0.00 0.46 0.46 0.00 0.11 0.11 — 450 450 0.02 0.02 0.04 455 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.04 0.49 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 110 110 < 0.005 < 0.005 0.17 111 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 18.2 18.2 < 0.005 < 0.005 0.03 18.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Linear, Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.00 0.84 7.37 10.8 0.01 0.30 — 0.30 0.28 — 0.28 — 1,619 1,619 0.07 0.01 — 1,625 -------------------
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Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.10 0.09 0.77 1.12 < 0.005 0.03 — 0.03 0.03 — 0.03 — 169 169 0.01 < 0.005 — 169 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 0.14 0.20 < 0.005 0.01 — 0.01 0.01 — 0.01 — 27.9 27.9 < 0.005 < 0.005 — 28.0 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.11 0.10 0.12 1.52 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 353 353 0.02 0.01 0.03 358 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.17 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 37.3 37.3 < 0.005 < 0.005 0.06 37.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 6.18 6.18 < 0.005 < 0.005 0.01 6.26 Medea Creek Bike Path Detailed Report, 2/3/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
-------------------
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Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Linear, Grubbing & Land
Clearing
Linear, Grubbing & Land
Clearing
1/1/2026 2/5/2026 5.00 25.0 —
Linear, Grading &
Excavation
Linear, Grading &
Excavation
2/6/2026 6/26/2026 5.00 100 —
Linear, Drainage, Utilities,
& Sub-Grade
Linear, Drainage, Utilities,
& Sub-Grade
6/27/2026 10/28/2026 5.00 88.0 —
Linear, Paving Linear, Paving 10/29/2026 12/21/2026 5.00 38.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Medea Creek Bike Path Detailed Report, 2/3/2025
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Linear, Grubbing & Signal Boards Electric Average 4.00 8.00 6.00 0.82 Land Clearing
Linear, Grubbing &
Land Clearing
Crawler Tractors Diesel Average 1.00 8.00 87.0 0.43
Linear, Grubbing &
Land Clearing
Excavators Diesel Average 1.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Excavators Diesel Average 3.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Crawler Tractors Diesel Average 1.00 8.00 87.0 0.43
Linear, Grading &
Excavation
Graders Diesel Average 1.00 8.00 148 0.41
Linear, Grading &
Excavation
Rollers Diesel Average 2.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Linear, Grading &
Excavation
Signal Boards Electric Average 4.00 8.00 6.00 0.82
Linear, Grading &
Excavation
Rubber Tired Loaders Diesel Average 1.00 8.00 150 0.36
Linear, Grading &
Excavation
Scrapers Diesel Average 2.00 8.00 423 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Scrapers Diesel Average 2.00 8.00 423 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Rough Terrain Forklifts Diesel Average 1.00 8.00 96.0 0.40 Linear, Drainage,
Utilities, & Sub-Grade
Signal Boards Electric Average 4.00 8.00 6.00 0.82
Linear, Drainage,
Utilities, & Sub-Grade
Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Linear, Drainage,
Utilities, & Sub-Grade
Graders Diesel Average 1.00 8.00 148 0.41
Linear, Drainage,
Utilities, & Sub-Grade
Plate Compactors Diesel Average 1.00 8.00 8.00 0.43
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Linear, Drainage, Pumps Diesel Average 1.00 8.00 11.0 0.74 Utilities, & Sub-Grade
Linear, Drainage,
Utilities, & Sub-Grade
Air Compressors Diesel Average 1.00 8.00 37.0 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Linear, Paving Rollers Diesel Average 3.00 8.00 36.0 0.38 Linear, Paving Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Linear, Paving Pavers Diesel Average 1.00 8.00 81.0 0.42 Linear, Paving Signal Boards Electric Average 4.00 8.00 6.00 0.82 Linear, Paving Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Linear, Grubbing & Land Clearing — — — —
Linear, Grubbing & Land Clearing Worker 15.0 18.5 LDA,LDT1,LDT2 Linear, Grubbing & Land Clearing Vendor 0.00 10.2 HHDT,MHDT Linear, Grubbing & Land Clearing Hauling 0.00 20.0 HHDT Linear, Grubbing & Land Clearing Onsite truck — — HHDT
Linear, Grading & Excavation — — — —
Linear, Grading & Excavation Worker 40.0 18.5 LDA,LDT1,LDT2 Linear, Grading & Excavation Vendor 1.00 10.2 HHDT,MHDT Linear, Grading & Excavation Hauling 0.00 20.0 HHDT
Linear, Grading & Excavation Onsite truck — — HHDT
Linear, Drainage, Utilities, &
Sub-Grade
— — — —
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Linear, Drainage, Utilities, & Worker 35.0 18.5 LDA,LDT1,LDT2 Sub-Grade
Linear, Drainage, Utilities, &
Sub-Grade
Vendor 0.00 10.2 HHDT,MHDT
Linear, Drainage, Utilities, &
Sub-Grade
Hauling 0.00 20.0 HHDT
Linear, Drainage, Utilities, &
Sub-Grade
Onsite truck — — HHDT
Linear, Paving — — — —
Linear, Paving Worker 27.5 18.5 LDA,LDT1,LDT2
Linear, Paving Vendor 0.00 10.2 HHDT,MHDT
Linear, Paving Hauling 0.00 20.0 HHDT
Linear, Paving Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Linear, Grubbing & Land
Clearing
— — 3.40 0.00 —
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Linear, Grading & Excavation — — 3.40 0.00 —
Linear, Drainage, Utilities, &
Sub-Grade
— — 3.40 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Road Construction 3.40 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 470 532 0.03 < 0.005

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
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5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 18.3 annual days of extreme heat Extreme Precipitation 6.15 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 20.6 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 2 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
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Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 2 1 1 3
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details
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7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 64.7
AQ-PM 45.2
AQ-DPM 58.5
Drinking Water 30.4
Lead Risk Housing 7.39
Pesticides 15.3
Toxic Releases 31.3
Traffic 87.8
Effect Indicators —
CleanUp Sites 11.8
Groundwater 36.8
Haz Waste Facilities/Generators 80.2
Impaired Water Bodies 91.9
Solid Waste 11.6
Sensitive Population —
Asthma 6.99
Cardio-vascular 36.5
Low Birth Weights 19.8
Socioeconomic Factor Indicators —
Education 14.2
Housing 11.6
Linguistic 36.0
Poverty 8.98
Unemployment 45.8
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7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 94.54638778
Employed 79.81521879
Median HI 94.46939561
Education —
Bachelor's or higher 81.48338252
High school enrollment 100
Preschool enrollment 73.10406775
Transportation —
Auto Access 87.47593995
Active commuting 39.38149621
Social —
2-parent households 65.8026434
Voting 76.56871551
Neighborhood —
Alcohol availability 50.99448223
Park access 81.35506224
Retail density 40.67753112
Supermarket access 38.93237521
Tree canopy 66.66238932
Housing —
Homeownership 88.31002181
Housing habitability 89.33658411
Low-inc homeowner severe housing cost burden 58.29590658 Low-inc renter severe housing cost burden 69.75490825
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Uncrowded housing 96.93314513
Health Outcomes —
Insured adults 76.20941871
Arthritis 0.0
Asthma ER Admissions 92.4
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 82.5
Cognitively Disabled 70.6
Physically Disabled 68.4
Heart Attack ER Admissions 71.5
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 3.9
SLR Inundation Area 0.0
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Children 71.1
Elderly 55.1
English Speaking 98.1
Foreign-born 28.3
Outdoor Workers 90.3
Climate Change Adaptive Capacity —
Impervious Surface Cover 75.2
Traffic Density 83.5
Traffic Access 23.0
Other Indices —
Hardship 5.1
Other Decision Support —
2016 Voting 67.7

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 19.0 Healthy Places Index Score for Project Location (b) 91.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

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7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Appendix C
Comment Letters Received on the Draft Programmatic Environmental Impact Report State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
wildlife.ca.gov
Conserving California’s Wildlife Since 1870
December 26, 2025
Charmaine Yambao
City of Agoura Hills
30001 Ladyface Court
Agoura Hills, CA 93101
[email protected]
Subject: Draft Environmental Impact Report for the Agoura Hills Bicycle Master Plan, SCH No. 2025010338, Los Angeles County, CA
Dear Charmaine Yambao:

The California Department of Fish and Wildlife (CDFW) reviewed the Draft Environmental Impact Report (DEIR) from City of Agoura Hills for the Agoura Hills Bicycle Master Plan (Project) pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines1.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, CDFW appreciates the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Fish & G. Code, § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW may also act as a Responsible Agency under CEQA. (Pub. Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

S-1.1
DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 Letter S-1
Charmaine Yambao
City of Agoura Hills
December 26, 2025

Page 2 of 17 ends

example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law2 of any species protected under the California Endangered Species Act (CESA; Fish & G. Code, § 2050 et seq.) or the Native Plant Protection Act (NPPA; Fish & G. Code, §1900 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

Biological Setting: The Project area encompasses all of the City of Agoura Hills.

Topography of the Project area varies from gradual to rugged, steeply sloped terrain, with elevations ranging from approximately 800 feet above mean sea level in Lindero Canyon in the western portion of the Project area to 2,000 feet above mean sea level at Ladyface Mountain in the southern portion of the Project area. The Project area includes various vegetation communities including riparian woodlands, oak woodlands, grasslands, chaparral, scrub amongst developed areas.

The Project area is within the Malibu Creek Watershed and contains four main creeks, Medea, Lindero Canyon, Palo Comado, and Chesebro. Medea Creek flows through the middle of the city, passing through both natural and man-made channels and an open space area. Lindero Canyon Creek flows through a canyon in the northwest part of the 2 “Take” is defined in Section 86 of the Fish and Game Code as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.”
DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.1
(cont.)
Charmaine Yambao
City of Agoura Hills
December 26, 2025

Page 3 of 17 ends

city, empties into Lake Lindero, and then reappears just south of Agoura Road, west of Kanan Road. Lake Lindero is an artificial lake in the western portion of the city, primarily surrounded by residences and a public golf course. Palo Comado Creek crosses the northeast section of the city, while Chesebro Creek flows along the north side of Agoura Road between Lewis Road and Medea Creek. In addition to these creeks, many smaller streams are present throughout the City.

The Plan states “Due to the programmatic nature of the Project, a precise, project-level analysis of the specific impacts of individual projects is not possible at this time.” However, the Plan states that there is potential for Agoura Hills dudleya (Dudleya cymosa ssp. Agourensis; California Rare Plant Rank (CRPR) 1B.2), Lyon's pentachaeta (Pentachaeta lyonia; Endangered Species Act (ESA) – Endangered, California Endangered Species Act (CESA) – Endangered, CRPR 1B.1), Crotch’s bumble bee (Bombus crotchii; CESA – Candidate), monarch butterfly (Danaus plexippus; ESA – Candidate), and southwestern pond turtle (Actinemys pallida; ESA – Proposed Threatened, California Species of Special Concern (SSC)) to be present on site.

Additionally, recent observations of Santa Susana tarplant (Deinandra minthornii; CRPR 1B.2) and Ojai navarretia (Navarretia ojaiensis; CRPR 1B.1) have been recorded on California Natural Diversity Database(CNDDB). The Plan includes mitigation measures for pre-construction assessment, nesting birds, best management practices, delineation surveys, compensatory mitigation, and tree protection.

Project History: CDFW previously reviewed the NOP and submitted comments on January 27, 2025. Comments in the NOP addressed cumulative impacts, compensatory mitigation, nesting birds, lake and streambed alteration among other general comments.

Additional comments or other suggestions may also be included to improve the document.

COMMENT # 1: Impacts on Crotch’s Bumble Bee
Issue: The Project will impact on Crotch’s bumble bee and its associated habitat.

Specific impact: The Project may result in temporal or permanent loss of suitable nesting and foraging habitat. Project ground-disturbing activities may cause death or injury of adults, eggs, and larva; burrow collapse; nest abandonment; and reduced nest success.

Why impact would occur: The DEIR states the Project area has potential occurrence of Crotch’s bumble bee. Additionally, recent observations of Crotch’s bumble bee adjacent to the Project area (Medea Creek Path) have been recorded on DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.1
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CNDDB3.Crotch’s bumble bee primarily nest in late February through late October underground in abandoned small mammal burrows but may also nest under perennial bunch grasses or thatched annual grasses, under-brush piles, in old bird nests, and in dead trees or hollow logs (Williams et al. 2014; Hatfield et al. 2018). Overwintering sites utilized by Crotch’s bumble bee mated queens include soft, disturbed soil (Goulson 2010), or under leaf litter or other debris (Williams et al. 2014).

CDFW appreciates the incorporation of MM BIO-1a to include pre-construction surveys.

As currently written, the DEIR only contains a pre-construction survey to mitigate impacts to special status species. The DEIR states “the City shall retain the qualified biologist to identify the specific impacts to the biological resource…identify any state or federal listed species that would necessitate coordination with the appropriate regulatory agency (i.e., USFWS, CDFW, USACE) to obtain regulatory permits, develop project-specific avoidance and mitigation procedures prior to initiating construction activities, and implement project-specific avoidance and mitigation measures prior to and during any construction activities”. Because the DEIR states there is already potential for impacts to Crotch’s bumble bee, the document should include a mitigation measure specific to that species. Without sufficient avoidance, minimization, or mitigation measures, the development may result in undisclosed and unmitigated temporal or permanent loss of colonies, and suitable nesting and foraging habitat.

Evidence impact would be significant: The California Fish and Game Commission accepted a petition to list the Crotch’s bumble bee as endangered under CESA, determining the listing “may be warranted” and advancing the species to the candidacy stage of the CESA listing process. The Project may substantially reduce and adversely modify habitat as well as reduce and potentially impair the viability of populations of Crotch’s bumble bee. The Project may also reduce the number and range of the species without taking into account the likelihood that special status species on adjacent and nearby natural lands may rely upon the habitat that occurs on the proposed Project site. Crotch’s bumble bee is listed as an invertebrate of conservation priority under the California Terrestrial and Vernal Pool Invertebrates of Conservation Priority.

Recommended Potentially Feasible Mitigation Measure(s)
CDFW requests the following recommendations and mitigation measures are incorporated into the final CEQA document:

Recommendation #1: CEQA - CDFW’s issuance of an ITP for a Project is subject to CEQA. As a Responsible Agency, CDFW may consider the CEQA document from the lead agency/Project proponent for the Project. However, additional documentation may be required as part of an ITP application for the Project in order for CDFW to adequately develop an accurate take analysis and identify measures that would fully mitigate for take of CESA-listed species. To minimize additional requirements by CDFW pursuant to Fish and Game Code section 2081 and/or under CEQA, a project’s CEQA document 3 https://wildlife.ca.gov/Data/CNDDB
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should fully identify the potential impacts to Crotch’s bumble bee and provide adequate avoidance, mitigation, monitoring, and reporting commitments for issuance of the ITP.

Mitigation Measure #1: Crotch’s Bumble Bee Surveys - The Project proponent shall retain a qualified biologist with the appropriate handling permits to conduct updated focused surveys. Focused surveys shall follow CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species4 (CDFW 2023).

Focused surveys shall also be conducted throughout the entire Project site and during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the City prior to implementing Project ground-disturbing activities.

Mitigation Measure #2: Incidental Take Permit – The Project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a copy of a fully executed take authorization to the City prior to implementing Project ground-disturbing activities and vegetation removal.

COMMENT # 2: Impacts to Rare Plants
Issue: The Project will impact rare plants.

Specific impact: The proposed grading within the Project footprint will directly impact rare plants.

Why impact would occur: The DEIR states the Project area has potential occurrence of Agoura Hills dudleya, Lyon's pentachaeta, Santa Susana tarplant, and Ojai navarretia. Additionally, recent observations adjacent to the Project area (Medea Creek Path) have been recorded on CNDDB5. While CDFW appreciates that the City is proposing a pre-construction survey, this not sufficient to appropriately assess impacts to rare plants. Therefore, measures should be included to require new surveys and conditional measures to avoid, protect, and minimize any additional individuals found.

Rare plant impacts will be missed without appropriate protocol level surveys during the blooming period. Without compensatory mitigation to offset the permanent loss of rare plant individuals, the Project would contribute to the cumulative loss of rare plants on a local and regional scale.

Evidence impact would be significant: Impacts on rare flora could be considered a significant effect on the environment. Plants with a CRPR of 1B are rare throughout their range, endemic to California, and are seriously or fairly threatened. Most of the plants that are ranked 1B have declined significantly over the last century. The additional threat rank of 0.2 indicates a species with 20 to 80 percent of its occurrences 4 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline 5 https://wildlife.ca.gov/Data/CNDDB
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threatened. Impacts to CRPR 1B plant species and their habitat meet the definition of endangered, rare, or threatened species (CEQA Guidelines, § 15380).

Impacts to CRPR 1B plant species and their habitat may result in a mandatory finding of significance because the Project would potentially threaten to eliminate a plant community and substantially reduce the number or restrict the range of an endangered, rare, or threatened species (CEQA Guidelines, § 15065). Insufficient mitigation may result in unmitigated temporal or permanent impacts to a rare plant species.

Subsequently, the Project would continue to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on a species identified as a candidate, sensitive, or special status species by CDFW.

Recommended Potentially Feasible Mitigation Measure(s)
Mitigation Measure #3: Rare Plant Surveys - Prior to ground-disturbing activities, the Project proponent shall retain a qualified botanist to conduct focused surveys for Agoura Hills dudleya, Lyon's pentachaeta, Santa Susana tarplant, and Ojai navarretia during the appropriate bloom period. Methods during the surveys shall adhere to guidance provided in CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities6 . Findings from the surveys shall be provided to the City and CDFW prior to ground disturbing activities.

Mitigation Measure #4: Rare Plant Mitigation - The Project proponent shall provide compensatory mitigation through replacement habitat at no less than 2:1 of the total habitat acreage impacted. The Project proponent shall acquire CDFW approved mitigation land that has presence of the rare plant and is located in the same watershed as the Project area. The mitigation land shall also provide equivalent or greater habitat value than that of the Project area. The Project proponent shall protect replacement habitat in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage mitigation lands pursuant to Government Code, section 65967(c). Recordation of the conservation easement shall occur prior to commencement of Project activities. An appropriate endowment shall also be provided for the long-term monitoring and management of mitigation lands.

Mitigation Measure #5: Habitat Management and Monitoring Plan - The Project proponent shall retain a certified botanist to draft a Habitat Management and Monitoring Plan (HMMP) and submit it to the City and CDFW for review and approval prior to Project activities. The HMMP shall outline initial and long-term management and maintenance activities that would occur on mitigation lands. The HMMP shall provide measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Maintenance activities outlined in the HMMP shall 6 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.3
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include measures pertaining to control of exotic vegetation, irrigation schedule, and protection from future maintenance activities.

COMMENT # 3: Impacts to Southwestern Pond turtle
Issue: The Project will impact southwestern pond turtle and associated habitat within the Project area during Project activities.

Specific impact: Direct impacts to southwestern pond turtle will result from Project construction, ground disturbance, and trampling or crushing from construction equipment, vehicles, and foot or bicycle traffic. Indirect impacts could result from temporary or permanent loss of suitable habitat.

Why impact would occur: The DEIR notes that the Project area provides suitable habitat for southwestern pond turtle. CDFW appreciates that the City is proposing a preconstruction survey, but the DEIR does not provide any protocol level surveys or mitigation specific to southwestern pond turtle. Project ground-disturbing activities, such as vegetation removal and grading, would result in habitat destruction, causing the death or injury of adults, juveniles, eggs, or hatchlings. Given that habitat loss on a local and regional scale is a major cause of population decline for southwestern pond turtle, removal of confirmed southwestern pond turtle habitat would be considered a significant impact and should be mitigated appropriately.

Evidence impact would be significant: Southwestern pond turtle is a California SSC.

A California SSC is a species, subspecies, or distinct population of an animal native to California that currently satisfies one or more of the following (not necessarily mutually exclusive) criteria:
1) If the species is extirpated from the State or, in the case of birds, is extirpated in its primary season or breeding role;
2) If the species is listed as threatened or endangered under ESA-, but not CESA-, threatened, or endangered;
3) If the species meets the State definition of threatened or endangered but has not formally been listed;
4) If the species is experiencing, or formerly experienced, serious (noncyclical) population declines or range retractions (not reversed) that, if continued or resumed, could qualify it for State threatened or endangered status; and 5) If naturally small populations exhibiting high susceptibility to risk from any factor(s), that if realized, could lead to declines that would qualify it for CESA - threatened or -endangered status (CDFW 2025f).

CEQA provides protection not only for CESA-listed species, but for any species including, but not limited to, SSC that can be shown to meet the criteria for State listing.

These SSC meet the CEQA definition of rare, threatened, or endangered species (CEQA Guidelines, § 15380). The DEIR does not provide mitigation for potential impacts on southwestern pond turtle. Inadequate avoidance, minimization, and mitigation measures for impacts to sensitive or special status species will result in the DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.3
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S-1.4
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Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species by CDFW.

Recommended Potentially Feasible Mitigation Measure(s)
Mitigation Measure #6: Compensatory Mitigation - For SSC that have been confirmed and/or are expected to occur within the Project site, the Project proponent shall provide compensatory mitigation for temporary and permanent loss of any habitat supporting SSC. There shall be no net loss of habitat supporting SSC [CEQA Guidelines, § 15370(e)]. Compensatory mitigation in the form of preservation shall be provided at no less than 2:1 acreage. Mitigation shall provide appropriate habitat (depending on the species), refugia, and habitat structures that supports those species (e.g., woody material, rocks, brush piles, pools, burrows). Any proposed mitigation area/plan shall include a discussion on the territory size; nesting, breeding, foraging, and refuge locations; invasive, non-native plant and wildlife species present; food availability; and how all life cycle functions will be mitigated. Any mitigation plan for SSC shall be distributed and approved by CDFW prior to Project activities. The replacement habitat shall be protected in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity, which should include an appropriate endowment to provide for the long-term management of mitigation lands.

Mitigation Measure #7: Injured or Dead Wildlife - If any special status wildlife species are found, harmed during relocation, or a dead or injured animal is found, work in the immediate area shall stop immediately, the qualified biologist shall be notified, and dead or injured wildlife documented immediately. A formal report shall be sent to CDFW and the City within 3 calendar days of the incident or finding. The report shall include the date, time of the finding or incident (if known), and location of the carcass or injured animal and circumstances of its death or injury (if known). Work in the immediate area may only resume once the proper notifications have been made and additional mitigation measures have been identified to prevent additional injury or death.

ADDITIONAL COMMENTS
Recirculation. CDFW recommends that the DEIR be recirculated after a preferred alternative is selected and focused surveys have been completed to fully disclose the potential impacts to special-status species.

Focused Surveys. The Project proponent shall obtain a qualified biologist to conduct focused botanical and animal surveys. Focused protocol-level surveys shall be conducted at the appropriate time of year for maximum documentation of special-status species prior to finalizing the FEIR. Based on the survey results, the final CEQA document should propose specific avoidance, minimization, and mitigation for Project DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.4
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S-1.5
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impacts to special-status species. For established survey protocols, see CDFW’s Survey and Monitoring Protocols and Guidelines7.

CEQA Document Tiering. The Project is a programmatic plan that is intended to provide guidance for individual developments that will occur at a future time within the Project area. While CDFW appreciates that biological surveys and impact analysis in the Biological Resources section of the DEIR, more updated surveys and impact analysis may need to occur once individual projects are approved. Without disclosing any design or individual project specifics, CDFW recommends that, for individual projects nested under the proposed Project, findings of significance should be set aside when certifying the DEIR until those aspects can be fully studied in a subsequent or supplemental CEQA document (see CEQA Guidelines §§ 15162 and 15163). The DEIR should explicitly discuss what further CEQA actions are anticipated for these individual projects, whether further analysis will be provided, and whether it will be available for public review. In addition to this recommendation, CDFW would appreciate the opportunity to review and comment on subsequent CEQA actions (e.g., subsequent, supplemental, addendum, etc.) associated with this DEIR.

Landscaping. For individual projects that will incorporate landscaping, CDFW recommends that the project applicant should use only native species found in naturally occurring vegetation communities within or adjacent to the Project site. The Project proponent should not plant, seed, or otherwise introduce nonnative, invasive plant species to areas that are adjacent to and/or near native habitat areas. CDFW recommends the Project proponent restrict use of any species, particularly ‘moderate’ or ‘high’ listed by the California Invasive Plant Council. These species are documented to have substantial and severe ecological impacts on physical processes, plant and animal communities, and vegetation structure.

Mitigation and Monitoring Reporting Plan. CDFW recommends the Project’s environmental document include mitigation measures recommended in this letter.

CDFW has provided comments via a mitigation monitoring and reporting plan to assist in the development of feasible, specific, detailed (i.e., responsible party, timing, specific actions, location), and fully enforceable mitigation measures (CEQA Guidelines, § 15097; Pub. Resources Code, § 21081.6). The Lead Agency is welcome to coordinate with CDFW to further review and refine the Project’s mitigation measures. Per Public Resources Code section 21081.6(a)(1), CDFW has provided a summary of our suggested mitigation measures and recommendations in the form of an attached Draft Mitigation Monitoring and Reporting Plan (Attachment A).

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 7 https://wildlife.ca.gov/conservation/survey-protocols DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.6
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S-1.7
S-1.8
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21003, subd. (e).) Accordingly, please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNDDB website8 provides direction regarding the types of information that should be reported and allows on-line submittal of field survey forms.

City of Lancaster should ensure data collected for the preparation of the DEIR is properly submitted.

FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)

CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City in identifying and mitigating Project impacts on biological resources. CDFW requests an opportunity to review and comment on any response that the City has to our comments and to receive notification of any forthcoming hearing date(s) for the Project (CEQA Guidelines, § 15073(e)).

Questions regarding this letter or further coordination should be directed to Andrew Aitken10, Environmental Scientist.

Sincerely,
Steve Gibson, Senior Environmental Scientist Supervisor Acting for Victoria Tang, Environment Program Manager
South Coast Region
8 https://wildlife.ca.gov/Data/CNDDB
9 https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities/Submit 10 Phone: 562-525-9688; Email: [email protected] DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.11
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ATTACHMENTS
Attachment A: Draft Mitigation, Monitoring, and Reporting Program ec: California Department of Fish and Wildlife
Victoria Tang, Environment Program Manager
Steve Gibson, Senior Environmental Scientist Supervisor Andrew Aitken, Environmental Scientist
Office of Planning and Research
[email protected]

REFERENCES
Goulson, D. 2010. Bumblebees: behavior, ecology, and conservation. Oxford University Press, New York. 317pp.

Hatfield, R., Jepsen, S., Foltz Jordan, S., Blackburn, M., Code, Aimee. 2018. A Petition to the State of California Fish and Game Commission to List Four Species of Bumblebees as Endangered Species.

Williams, P.H., R.W. Thorp, L.L. Richardson, and S.R. Colla. 2014. Bumble bees of North America: An Identification guide. Princeton University Press, Princeton, New Jersey. 208pp.

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ATTACHMENT A: DRAFT MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) CDFW provides the following language to be incorporated into the MMRP for the Project.

Mitigation Measure Timing Responsible
Party
Mitigation Measure #1: Crotch’s Bumble Bee Surveys - The Project proponent shall retain a qualified biologist with the appropriate handling permits to conduct updated focused surveys. Focused surveys shall follow CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species11 (CDFW 2023). Focused surveys shall also be conducted throughout the entire Project site and during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the City prior to implementing Project ground-disturbing activities.

Prior to
ProjectImplementation
Project
Proponent
Mitigation Measure #2: Incidental Take Permit – The Project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a copy of a fully executed take authorization to the City prior to implementing Project ground-disturbing activities and vegetation removal.

Prior to
ProjectImplementation
Project
Proponent
Mitigation Measure #3: Rare Plant Surveys - Prior to ground-disturbing activities, the Project proponent shall retain a qualified botanist to conduct focused surveys for Agoura Hills dudleya, Lyon's pentachaeta, Santa Susana tarplant, and Ojai navarretia during the appropriate bloom period. Methods during the surveys shall adhere to guidance provided in CDFW’s Prior to
ProjectImplementation
Project
Proponent
11 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.2
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Mitigation Measure Timing Responsible
Party
Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities12 . Findings from the surveys shall be provided to the City and CDFW prior to ground disturbing activities.Mitigation Measure #4: Rare Plant Mitigation - The Project proponent shall provide compensatory mitigation through replacement habitat at no less than 2:1 of the total habitat acreage impacted. The Project proponent shall acquire CDFW approved mitigation land that has presence of the rare plant and is located in the same watershed as the Project area. The mitigation land shall also provide equivalent or greater habitat value than that of the Project area. The Project proponent shall protect replacement habitat in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage mitigation lands pursuant to Government Code, section 65967(c). Recordation of the conservation easement shall occur prior to commencement of Project activities. An appropriate endowment shall also be provided for the long-term monitoring and management of mitigation lands.

Prior to
ProjectImplementation
Project
Proponent
Mitigation Measure #5: Habitat Management and Monitoring Plan - The Project proponent shall retain a certified botanist to draft a Habitat Management and Monitoring Plan (HMMP) and submit it to the City and CDFW for review and approval prior to Project activities. The HMMP shall outline initial and long-term management and maintenance activities that would occur on mitigation lands. The HMMP shall provide measurable goals and success criteria for establishing self-sustaining populations (e.g., Prior to
ProjectImplementation
Project
Proponent
12 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.3
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Mitigation Measure Timing Responsible
Party
percent survival rate, absolute cover). Maintenance activities outlined in the HMMP shall include measures pertaining to control of exotic vegetation, irrigation schedule, and protection from future maintenance activities.Mitigation Measure #6: Compensatory Mitigation - For SSC that have been confirmed and/or are expected to occur within the Project site, the Project proponent shall provide compensatory mitigation for temporary and permanent loss of any habitat supporting SSC. There shall be no net loss of habitat supporting SSC [CEQA Guidelines, § 15370(e)]. Compensatory mitigation in the form of preservation shall be provided at no less than 2:1 acreage. Mitigation shall provide appropriate habitat (depending on the species), refugia, and habitat structures that supports those species (e.g., woody material, rocks, brush piles, pools, burrows). Any proposed mitigation area/plan shall include a discussion on the territory size; nesting, breeding, foraging, and refuge locations; invasive, non-native plant and wildlife species present; food availability; and how all life cycle functions will be mitigated. Any mitigation plan for SSC shall be distributed and approved by CDFW prior to Project activities. The replacement habitat shall be protected in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity, which should include an appropriate endowment to provide for the long-term management of mitigation lands.

Prior to
ProjectImplementation
Project
Proponent
Mitigation Measure #7: Injured or Dead Wildlife - If any special status wildlife species are found, harmed during relocation, or a dead or injured animal is found, work in the immediate area shall stop immediately, the qualified biologist shall be notified, and dead or injured wildlife documented immediately. A formal report shall be sent to CDFW and the City within 3 calendar days of the incident or finding. The report shall include the date, During
ProjectImplementation
Project
Proponent
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Mitigation Measure Timing Responsible
Party
time of the finding or incident (if known), and location of the carcass or injured animal and circumstances of its death or injury (if known). Work in the immediate area may only resume once the proper notifications have been made and additional mitigation measures have been identified to prevent additional injury or death.

Mitigation Measure #8: Focused Surveys - The Project proponent shall obtain a qualified biologist to conduct focused botanical and animal surveys. Focused protocol-level surveys shall be conducted at the appropriate time of year for maximum documentation of special-status species prior to finalizing the FEIR. Based on the survey results, the final CEQA document should propose specific avoidance, minimization, and mitigation for Project impacts to special-status species. For established survey protocols, see CDFW’s Survey and Monitoring Protocols and Guidelines13.

Prior to
ProjectImplementation
Project
Proponent
Recommendation #1: CEQA - CDFW’s issuance of an ITP for a Project is subject to CEQA. As a Responsible Agency, CDFW may consider the CEQA document from the lead agency/Project proponent for the Project. However, additional documentation may be required as part of an ITP application for the Project in order for CDFW to adequately develop an accurate take analysis and identify measures that would fully mitigate for take of CESAlisted species. To minimize additional requirements by CDFW pursuant to Fish and Game Code section 2081 and/or under CEQA, a project’s CEQA document should fully identify the potential impacts to Crotch’s bumble bee Prior to adoption of the
DEIR
Lead Agency
13 https://wildlife.ca.gov/conservation/survey-protocols DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.4
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Mitigation Measure Timing Responsible
Party
and provide adequate avoidance, mitigation, monitoring, and reporting commitments for issuance of the ITP.Recommendation #2: Recirculation - CDFW recommends that the DEIR be recirculated after a preferred alternative is selected and focused surveys have been completed to fully disclose the potential impacts to special-status species.

Prior to adoption of the
DEIR
Lead Agency
Recommendation #3: CEQA Document Tiering - The Project is a programmatic plan that is intended to provide guidance for individual developments that will occur at a future time within the Project area. While CDFW appreciates that biological surveys and impact analysis in the Biological Resources section of the DEIR, more updated surveys and impact analysis may need to occur once individual projects are approved. Without disclosing any design or individual project specifics, CDFW recommends that, for individual projects nested under the proposed Project, findings of significance should be set aside when certifying the DEIR until those aspects can be fully studied in a subsequent or supplemental CEQA document (see CEQA Guidelines §§ 15162 and 15163). The DEIR should explicitly discuss what further CEQA actions are anticipated for these individual projects, whether further analysis will be provided, and whether it will be available for public review. In addition to this recommendation, CDFW would appreciate the opportunity to review and comment on subsequent CEQA actions (e.g., subsequent, supplemental, addendum, etc.) associated with this DEIR.

Prior to adoption of the
DEIR
Lead Agency
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Mitigation Measure Timing Responsible
Party
Recommendation #4: Landscaping - For individual projects that will incorporate landscaping, CDFW recommends that the project proponent should use only native species found in naturally occurring vegetation communities within or adjacent to the Project site. The Project proponent should not plant, seed, or otherwise introduce nonnative, invasive plant species to areas that are adjacent to and/or near native habitat areas. CDFW recommends the Project proponent restrict use of any species, particularly ‘moderate’ or ‘high’ listed by the California Invasive Plant Council. These species are documented to have substantial and severe ecological impacts on physical processes, plant and animal communities, and vegetation structure.

Prior to
ProjectImplementation
Project
Proponent
DocusignEnvelopeID:6827929F-C0AF-4700-811D-1A0E9D134D48 S-1.8
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 7
100 SOUTH MAIN STREET, SUITE 100 | LOS ANGELES, CA 90012 PHONE (213) 897-0362 | FAX (213) 897-0360 TTY 711
www.dot.ca.gov
January 29, 2026
Charmaine Yambao, PE, Senior Civil Engineer
City of Agoura Hills, Public Works Division
30001 Ladyface Court,
Agoura Hills, CA 91301
RE: Agoura Hills Bicycle Master Plan
– Draft Programmatic Environmental Impact
Report (DPEIR)
SCH # 2025010338
GTS # LA-2025-04962
Vic. LA Multiple

Dear Charmaine Yambao:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above-referenced environmental document. The proposed project includes the following components:

1. Bicycle Master Plan (BMP). The BMP proposes 30.1 miles of new bikeways and bikeway improvements to build upon the city’s existing 1.3 miles of bicycle routes and 9.2 miles of bicycle lanes.

2. VMT Mitigation Exchange and Banking Program (Program). The Program would establish a mitigation opportunity for projects exceeding the vehicle miles traveled (VMT) threshold by allowing a developer or project proponent to purchase VMT reduction credits, which would in turn be used to fund the implementation of bicycle improvement projects identified within the BMP.

3. General Plan Amendments (Amendments). To ensure the city’s General Plan is consistent with the Bicycle Master Plan, the project would amend the existing General Plan Infrastructure and Community Services Element.

After reviewing the DPEIR, Caltrans has the following comments:

Letter S-2
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Charmaigne Yambao
January 29, 2026

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“Provide a safe and reliable transportation network that serves all people and respects the environment” Caltrans aims to provide a safe, reliable transportation network that serves all people and respects the environment. For this reason, Caltrans acknowledges and supports the stated goals of the Agoura Hills Master Bicycle Plan, VMT Mitigation Program, and associated General Plan amendments. These infrastructure investments will help California meet its climate, transportation, and livability goals. Caltrans planners and engineers are available to partner on implementing design elements that improve safety and mobility for people walking, riding bikes, or taking transit throughout the Plan area. By removing barriers and improving safety, this Plan can make transportation mode shift easier for Californians and help the State meet its policy goals to reduce the number of trips made by driving, Greenhouse Gas (GHG) emissions, and encourage active modes of travel.

While Caltrans does support the objectives of the proposed project, the comments below outline some of the aspects of the plan which can be improved upon or considered in future phases:
• The plan introduces itself as proposing “30.1 miles of new bikeways” however, this might be misrepresentative. As seen on page 43, a majority of the improvements recommend Class III routes in locations where people riding bicycles are already permitted to ride.

Without the Class III designations, the total proposed miles of new bikeways would be a substantially different, but more transparent, estimate. We are supportive of the designation and recognize Class III facilities may be the only possibility in some locations, but the distinction is important to illustrate within the report. • Per SB 1216, new sharrow markings are no longer permissible in zones above 30 mph.

Multiple proposed Class III routes were observed in violation of this (Canwood is 40 mph, and Lake Lindero is 50 mph) and may need to be reexamined. While we recognize there may still be applicability on local roads, Caltrans Districts Statewide do not recognize Class III facilities as metrics for performance with regards to bike and pedestrian features.

In many cases consideration for a Class II facility may likely fit within the footprint of the existing roadway. Otherwise, lower speed limits would be required to accommodate Class III’s.
• Regarding the Medea Creek Path
o Some of the crosswalks at Segment 3 on Kanan could be improved to high visibility. o The US 101 undercrossing is sizeable. This may be preliminary, but highlighting features like pedestrian lighting or other safety features would be valuable. o This undercrossing will require a Caltrans encroachment permit and all maintenance, safety, and statutory requirements will need to be addressed. • Bicycle Parking is mentioned as being deployed at “various locations”. We would recommend providing specific examples as mode shift is often reliant on the ability to safely secure your bicycle as you would a vehicle.

S-2.2
(cont.)
S-2.4
S-2.3
S-2.5
S-2.6
Charmaigne Yambao
January 29, 2026

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“Provide a safe and reliable transportation network that serves all people and respects the environment” • A wayfinding and signage plan would also greatly improve the visibility and access of the entire active transportation network.
• Community Engagement is mentioned; however, the DEIR only illustrates that it complied with the minimum CEQA notices. It is not apparent that community outreach outside of city council was conducted in the recommendation portion of this planning document, which may have been valuable. It is recommended to note what types of future engagement best practices will be implemented in the future as the project rolls out. • Further justification may be needed for the environmentally preferred alternative. It currently appears that Alternative 2 would be superior due to its much more expanded footprint while being less invasive than the separated path. While Caltrans is supportive of the development of the bike path, more needs to be stated as to why Alt 3 is preferable to Alt 2.

Please be aware that Caltrans encroachment permits will be required at all locations where Project work interacts with State ROW. This includes any grading, topography, or equipment work that will change the pattern or direction of water runoff in a way that will impact State facilities or ROW.

A condition of approval for issued entitlements shall include a requirement to work with Caltrans’ Office of Permits to obtain the appropriate encroachment permits. Final design requirements for any proposed changes to infrastructure within or along Caltrans Right-of-way will be determined by the Office of Permits. At the time of permit application there will be rounds of review and corrections to ensure all design, Right-of-way, access management, water runoff, environmental, and statutory requirements are being addressed.

Caltrans District 7 Office of Permits contact information:

Mailing Address: 100 S Main Street, Ste 100 Los Angeles, CA 90012 Office Hours: 8:00 a.m. to 5:00 p.m. Monday-Friday
Phone: 213-897-3631 | Fax: 213-897-0420 | E-mail: [email protected]

If you have any questions, please contact project coordinator Anthony Higgins, at [email protected] and refer to GTS# 07-LA-2025-04962.

Sincerely,
Anthony Higgins
Acting LDR Branch Chief
Cc: State Clearinghouse
S-2.7
S-2.8
S-2.9
S-2.11
S-2.10
Appendix D
Responses to Comments
Responses to Comments
Final Programmatic Environmental Impact Report D-1
Responses to Comments
Introduction
A Draft Programmatic Environmental Impact Report (PEIR) for the proposed Bicycle Master Plan (BMP), Vehicle Miles Traveled (VMT) Mitigation Exchange and Banking Program (Program), and General Plan Amendments (Amendments) (hereafter referred to as the “proposed Project” or “Project”) was circulated for a 68-day public review period from November 25, 2025 to January 31, 2026. In accordance with Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, the City of Agoura Hills (City) reviewed all written comments received on the Draft PEIR and prepared written responses to the written comments received during the public review period.

This chapter includes the responses to comments received on the Draft PEIR.

Public Comments Received
As summarized in Table 1, comment letters were submitted by two state agencies. The comment letters are provided in Appendix C and responses are provided below. The comment letters have been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response S-1.1, for example, indicates that the response is for the first issue raised in comment Letter S-1).

Table 1 Public Comments Received on the Draft PEIR
Letter No. and Commenter Date Received
State Agency
S-1 California Department of Fish and Wildlife December 26, 2025 S-2 California Department of Transportation January 29, 2026 Response to Comments
No changes to the Draft PEIR were made in response to public comments. Responses to public comments received were prepared to address the environmental concerns raised by the commenters and to indicate where and how the Draft PEIR explains pertinent environmental issues.

The focus of the responses to comments is the disposition of environmental issues that are raised in the comments, as specified by CEQA Guidelines Section 15088(c). Detailed responses are not provided to comments on the merits of the proposed Project. However, when a comment is not directed to an environmental issue, the response indicates that the comment has been noted and forwarded to the appropriate decision-makers for review and consideration.

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Letter S-1
COMMENTER: Steve Gibson, Senior Environmental Scientist Supervisor, California Department of Fish and Wildlife
DATE: December 26, 2025
Response S-1.1
The commenter provides a description of the California Department of Fish and Wildlife’s (CDFW) role as a trustee and/or responsible agency for the proposed Project, a summary of the proposed Project, and CDFW’s prior involvement with the proposed Project.

This comment is introductory and does not contain a substantive comment on the Draft PEIR. No further response is required.

Response S-1.2
The commenter states the Project could significantly impact Crotch’s bumble bee (Bombus crotchii), as the Project may cause temporary or permanent loss of suitable nesting and foraging habitat, and ground-disturbing activities could lead to direct mortality, nest abandonment, and reduced reproductive success. The commenter recommends additional mitigation measures, including focused surveys during the appropriate season consistent with CDFW’s published guidelines, submitting results to CDFW before any disturbance occurs, and obtaining an Incidental Take Permit (ITP) from CDFW with full compliance to permit conditions.

Pages 4.3-7, 4.3-27, and 4.3-29 in Section 4.3, Biological Resources, of the Draft PEIR identifies that Crotch’s bumble bee has potential to occur within the Project area. Specifically, the Draft PEIR discloses that construction of the Agoura High School Connection would have the potential to temporarily disturb or remove overwintering and nesting habitat, as Crotch’s bumble bee is known to occupy similarly situated non-native grassland habitat similar to that within the identified project boundary for the Connection. On Page 4.3-29, the Draft PEIR identifies this impact as potentially significant.

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project‑level analysis of the specific impacts of individual projects identified within the BMP…is not possible at this time,” and therefore the analysis and impact conclusions rely on performance‑based mitigation to be applied when and where ground disturbance is proposed during implementation of individual projects proposed within the BMP (Mitigation Measure BIO‑1a through BIO‑1c).

Specifically, Mitigation Measure (MM) BIO‑1a (pages 4.3-31 and 4.3-32) requires the City to retain a qualified biologist to conduct pre‑construction, site‑specific assessments of each future project footprint to identify special‑status species and habitats, develop project‑specific avoidance and mitigation procedures, and implement those measures prior to and during construction; the measure explicitly requires pre‑construction surveys for special‑status invertebrates where appropriate, establishment of avoidance buffers, relocation with permits as applicable, restoration, and compensatory mitigation at ratios scaled to the extent and quality of habitat affected (1:1 to 5:1). This approach is particularly important because most facilities would occur in previously developed or disturbed corridors with low potential for many special‑status species, whereas a subset of locations, such as the Agoura High School Connection in non‑native grassland, could present project‑specific potential for Crotch’s bumble bee. Site‑level conditions will be verified and Responses to Comments
Final Programmatic Environmental Impact Report D-3
addressed under MM BIO‑1a at the time of design and prior to ground disturbance when surveys can be properly timed to the species’ active period and tailored to the defined limits of work.

In short, committing to program‑wide focused Crotch’s bumble bee surveys now would be inefficient and potentially ineffective given the absence of finalized designs and construction windows. The PEIR’s mitigation framework ensures that any future project with a credible potential to affect Crotch’s bumble bee will undergo appropriate, site‑specific survey, avoidance, and compensatory measures before construction, reducing impacts to less than significant with mitigation.

For the above reasons, that the analysis considers impacts on Crotch’s bumble bee, that the Programmatic EIR does not contain the specificity that would reliably identify impacts to Crotch’s bumble bee, and that performance measures are included that will require future surveys where necessary, the commenter’s requested mitigation measure requiring City‑wide, focused surveys for Crotch’s bumble bee is not being adopted. The PEIR is a programmatic document that does not authorize construction and, by definition, lacks the site‑specific design, access, and timing information needed to implement defensible protocol surveys across the entire citywide program.

An ITP is an authorization under the California Endangered Species Act, separate from CEQA, that is obtained through a formal application to CDFW if take of a State-listed or candidate species is required. Crotch’s bumble bee has a low potential to occur within individual project areas and impacts are considered less than significant with mitigation. While an ITP may be required under the California Endangered Species Act if future project‑level activities cannot avoid take, the ITP authorization would be obtained by the City during subsequent implementation of individual projects if pre-construction surveys required under Mitigation Measure BIO-1a identify Crotch’s bumble bee and take is triggered. No changes to the Draft PEIR are required.

Response S-1.3
The commenter states that the Project could significantly impact rare plants because grading within the Project area may directly remove individuals and suitable habitat for several California Rare Plant Rank (CRPR) 1B species with potential to occur on or adjacent to the Project area. The commenter explains that general pre-construction surveys are not sufficient to detect these species and recommends protocol-level, blooming-season surveys consistent with CDFW guidance, followed by compensatory mitigation for any affected individuals, including habitat replacement at a minimum 2:1 ratio and long-term protection under a conservation easement. The commenter also recommends preparation of a Habitat Management and Monitoring Plan to ensure the long-term viability of replacement populations.

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species may occur within the Project area, and direct and indirect impacts may result in potentially significant impacts to special-status plant species. Page 4.3-27 further explains that “a precise, project‑level analysis of the specific impacts of individual projects identified within the BMP…is not possible at this time,” and therefore the analysis and impact conclusions rely on performance‑based mitigation to be applied when and where ground disturbance is proposed during implementation of individual projects proposed within the BMP (Mitigation Measure BIO‑1a through BIO‑1c).

For the above reasons, that the analysis considers impacts on rare plants, that the Programmatic EIR does not contain the specificity that would reliably identify impacts to rare plants, and that performance measures are included that will require future surveys where necessary, the commenter’s requested mitigation, including protocol-level rare plant surveys, fixed 2:1 City of Agoura Hills
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compensatory mitigation, or preparation of a Habitat Management and Monitoring Plan, is not being adopted. The PEIR is a programmatic document that does not authorize construction and, by definition, lacks the site‑specific design, access, and timing information needed to implement defensible blooming-season surveys across all potential improvement areas. As described in Section

4.3, Biological Resources, the PEIR employs a performance-based mitigation framework (e.g., MM BIO-1a [pages 4.3-31 and 4.3-32], BIO-1c [page 4.3-33], BIO-2a [pages 4.3-37 and 4.3-38], and BIO2c [pages 4.3-38 and 4.3-39]) that requires a qualified biologist to conduct site-specific pre-construction biological assessments, develop project-level avoidance and minimization measures, and implement appropriate survey protocols during the correct phenological window where suitable habitat is present at the time individual projects advance through design and permitting. This tiered approach is warranted because many future activities would occur in previously developed or disturbed corridors with low potential for CRPR 1B taxa, while a subset of individual project locations may warrant focused, blooming-season surveys and tailored measures that reflect the defined limits of disturbance, final design, and construction schedule.

Committing to uniform, program-wide survey and compensatory ratios at this stage would be premature under CEQA’s programmatic framework. Instead, the PEIR requires that any future project with a credible potential to affect rare plants conduct appropriate, site-specific surveys and apply avoidance, minimization, and compensatory mitigation (including habitat replacement where warranted) prior to ground disturbance, ensuring impacts associated with adoption of the BMP are reduced to less than significant with mitigation. No changes to the Draft PEIR are required.

Response S-1.4
The commenter states the Project could significantly impact southwestern pond turtle (Actinemys pallida) because construction activities could cause direct mortality as well as indirect impacts from the loss or degradation of suitable habitat. Although the Draft PEIR acknowledges that suitable habitat is present in the Project area and proposes a general pre-construction survey, the commenter explains that the Draft PEIR does not include protocol-level surveys or species-specific mitigation measures. Given that habitat loss is a major contributor to regional declines in the species, the commenter asserts that removal of confirmed habitat would constitute a significant impact under CEQA. To address these concerns, the commenter recommends compensatory mitigation at a minimum 2:1 ratio for habitat supporting the species, long-term protection of replacement habitat under a conservation easement, and implementation of procedures for reporting and responding to injured or deceased wildlife discovered during construction.

Pages 4.3-8 and 4.3-27 in Section 4.3, Biological Resources, of the Draft PEIR identify that southwestern pond turtle may occur within the Project area, specifically within the city’s open space areas and undeveloped hillsides at the wildland-urban interface. Page 4.3-27 further explains that “a precise, project‑level analysis of the specific impacts of individual projects identified within the BMP…is not possible at this time,” and therefore the analysis and impact conclusions rely on performance‑based mitigation to be applied when and where ground disturbance is proposed during implementation of individual projects proposed within the BMP (Mitigation Measure BIO‑1a through BIO‑1c).

For the above reasons, that the analysis considers impacts on southwestern pond turtle, that the Programmatic EIR does not contain the specificity that would reliably identify impacts to southwestern pond turtle, and that performance measures are included that will require future surveys where necessary, the commenter’s requested mitigation, including protocol-level surveys, fixed compensatory ratios, or species-specific plans for southwestern pond turtle, is not being Responses to Comments
Final Programmatic Environmental Impact Report D-5
adopted. The PEIR is a programmatic document that does not authorize construction and, by definition, lacks the site‑specific design, access, and timing information needed to implement defensible species protocols across all potential improvement areas. As outlined in Section 4.3, Biological Resources, the PEIR uses a performance-based, tiered mitigation framework (MM BIO-1a [pages 4.3-31 and 4.3-32] and BIO-1c [page 4.3-33]) that requires a qualified biologist to conduct site-specific pre-construction assessments once individual projects advance through design and permitting, identify presence of suitable aquatic/riparian and upland refugia, and develop project-level avoidance and minimization measures tailored to the confirmed conditions at each work area. Under this framework, measures may include seasonally appropriate clearance surveys where suitable habitat is present, exclusion fencing and environmentally sensitive area buffers, biological monitoring during ground disturbance near aquatic features, relocation only with appropriate approvals/authorizations, timing restrictions to avoid peak activity periods, and compensatory mitigation scaled to the extent and quality of affected habitat where avoidance is not feasible.

Given that many improvements would occur in developed or disturbed corridors with low potential for southwestern pond turtle, while a subset of locations may warrant focused measures, imposing uniform program-wide requirements (e.g., protocol surveys and a fixed 2:1 habitat replacement ratio) would be premature absent verified habitat and final limits of disturbance for individual projects. The PEIR instead commits the City to apply appropriate, site-specific surveys, avoidance, minimization, and compensatory mitigation at the time of future project-level approvals and prior to ground disturbance, ensuring that any future project with a credible potential to affect southwestern pond turtle reduces impacts to less than significant with mitigation. No changes to the Draft PEIR are required.

Response S-1.5
The commenter recommends that the City recirculate the Draft PEIR after selecting a preferred alternative and completing focused surveys for special-status species. According to the commenter, recirculation is necessary to fully disclose biological impacts and ensure that the public and responsible agencies can evaluate project-specific effects prior to approval.

Recirculation of the Draft PEIR is not required. As explained in Section 4.3, Biological Resources, this Draft PEIR is intentionally programmatic and does not authorize ground-disturbing activities or contain sufficient site-level detail to conduct defensible protocol surveys at this time. The Draft PEIR evaluates potential impacts at a broad program level and incorporates a tiered mitigation framework that requires project-specific biological assessments, appropriately timed focused surveys, and avoidance/minimization measures when individual projects advance to design and permitting and when site-specific conditions can be accurately verified. Pursuant to CEQA Guidelines Section 15088.5, a lead agency must recirculate an EIR only when “significant new information” becomes available that deprives the public of a meaningful opportunity to comment on substantial changes to the analysis or mitigation; here, no such information has been identified. The Draft PEIR provides adequate disclosure of potential impacts associated with the Project and commits to implementing all necessary focused surveys and mitigation measures at the project-level tiering stage. Therefore, recirculation of the Draft PEIR is not warranted.

As required by CEQA, the Agoura Hills City Council will identify and select the preferred alternative at the time the Project is considered for approval. Selection of a preferred alternative occurs during the decision‑making process after circulation of the Draft and Final PEIR and does not require City of Agoura Hills
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recirculation unless identifying the preferred alternative introduces new significant impacts or substantially increases the severity of previously identified impacts.

Response S-1.6
The commenter recommends that the City retain a qualified biologist to conduct focused, protocol-level botanical and wildlife surveys at the appropriate time of year to ensure maximum detectability of special-status species. The commenter states that these surveys should be completed prior to finalizing the Final PEIR and that the final CEQA document should include specific, survey-based avoidance, minimization, and mitigation measures.

Conducting focused, protocol-level surveys before certification of the Draft PEIR is not required for a programmatic document. Consistent with CEQA Guidelines Section 15168 and the requirements of Mitigation Measure BIO-1a, site‑specific biological surveys shall be conducted at the project‑level tiering stage when individual project designs, disturbance boundaries. As described in Section 4.3, Biological Resources, the Draft PEIR does not authorize construction and does not contain the site-specific design, access, or construction timing information necessary to implement defensible protocol surveys across all individual project locations. The Draft PEIR instead relies on a tiered, performance-based mitigation framework that requires a qualified biologist to conduct site-specific biological assessments and appropriately timed focused surveys when individual projects undergo project-level design and permitting and when site conditions, limits of disturbance, and construction windows are known. This tiering approach complies with CEQA for a programmatic document and ensures that avoidance, minimization, and mitigation measures (including any species-specific protocols) are developed based on verified, site-specific survey results.

Response S-1.7
The commenter acknowledges that the Draft PEIR is a programmatic document but recommends that findings of significance for biological resources be postponed until individual, site-specific projects are proposed and can be fully analyzed in subsequent or supplemental CEQA documents consistent with CEQA Guidelines Sections 15162 and 15163. The commenter requests that the Draft PEIR explicitly describe what additional CEQA documentation will be required for future projects, whether further biological analysis will be provided, and whether those documents will be available for public review. The commenter also requests the opportunity to review and comment on all subsequent CEQA actions associated with the Project.

This Draft PEIR is intended to provide a program-level evaluation of potential impacts associated with implementation of the overall Project and does not authorize construction of any individual project. Because detailed design, construction timing, and site conditions are not yet known, the Draft PEIR appropriately evaluates impacts at a broad, programmatic level and identifies performance-based mitigation to be implemented after project-specific analysis in future CEQA documents is prepared as required under CEQA Guidelines Sections 15162, 15163, and 15168.

Chapter 3, Environmental Setting, Section 3.2.2, Approach to Analysis, of the Draft PEIR explains that future activities covered by the Project will undergo additional environmental review depending on the nature of the project-level changes and whether new significant impacts or substantially more severe impacts may occur. This tiered approach ensures that all future projects receive the appropriate level of CEQA review, which may include biological surveys and impact analysis where warranted. The City will continue to coordinate with responsible agencies, including CDFW, and will make subsequent CEQA documents available for public review when required under CEQA.

Responses to Comments
Final Programmatic Environmental Impact Report D-7
Response S-1.8
The commenter recommends that individual projects incorporating landscaping use only native plant species from vegetation communities naturally occurring within or adjacent to the Project area. The commenter further advises that non-native or invasive species, including those ranked “moderate” or “high” by the California Invasive Plant Council, should not be planted, seeded, or introduced near native habitat because these species can substantially affect ecological processes, plant communities, and habitat structure.

Landscaping recommendations will be addressed at the project-level rather than in this programmatic document. The Draft PEIR does not authorize construction or establish final landscaping plans, and therefore does not include the site-specific design details necessary to determine planting palettes or evaluate proximity to sensitive habitats. The Draft PEIR’s tiered mitigation framework requires that each future project undergo site-specific biological review during project-level design, at which time a qualified biologist will identify appropriate avoidance and minimization measures, including landscaping requirements where necessary to protect adjacent native habitats. This approach ensures that landscaping palettes are tailored to actual site conditions and biological constraints once they are known and avoids imposing program-wide requirements that may not be applicable to all project locations. At the project-level CEQA tiering stage, the City will evaluate the need for native planting requirements and restrictions on invasive species and will incorporate such measures, as appropriate, into final design and mitigation.

Response S-1.9
The commenter recommends the Draft PEIR includes CDFW’s recommended mitigation measures (Attachment A of Letter S-1) and invites the City to coordinate with CDFW to further review and refine the Project’s mitigation measures.

Responses to specific mitigation recommendations have been provided in Responses S-1.2 through S-1.4 above. No changes to the proposed mitigation measures or the Draft PEIR are required. The Project’s Mitigation Monitoring and Reporting Program will be prepared and certified concurrently with the Final PEIR, as required by CEQA.

Response S-1.10
The commenter requests that special-status species and natural communities detected during Project surveys be submitted to CDFW's vegetation classification and mapping program and to the California Natural Diversity Database.

If special-status species or natural communities are observed during future implementation of individual projects (such as during pre-construction surveys that may occur for compliance with the mitigation measures identified in the Draft PEIR), information would be submitted to CDFW as required by state-issued permits (e.g., CDFW Lake and Streambed Alteration Agreement), rather than as a separate condition of the City’s permit, because these reporting obligations fall under CDFW’s jurisdiction and enforcement authority.

Response S-1.11
The commenter states that payment of CDFW fees is required.

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If the Final PEIR is certified and the Project is approved, the City would pay the required CDFW fees at the time the Notice of Determination for the Final PEIR is filed with the Los Angeles County Clerk.

Response S-1.12
The commenter concludes the letter and requests the opportunity to review the response to comments and receive notification of hearing dates.

The City will provide responses to comments to CDFW and notice of public hearings 10 days prior to the City hearings where certification of the Draft PEIR will be considered (CEQA Guidelines Section 15088). The comment does not contain a substantive comment on the Draft PEIR and no further response is required.

Response S-1.13
The commenter notes their inclusion of Attachment A: Draft Mitigation, Monitoring, and Reporting Program. The commenter also provides a list of references used to inform their comment letter.

The measures listed within Attachment A: Draft Mitigation, Monitoring, and Reporting Program correspond to individual comments S-1.2 through S-1.8, which are addressed in the above responses. As discussed in Responses S-1.2 through S-1.8, no changes to the Draft PEIR are required.

Responses to Comments
Final Programmatic Environmental Impact Report D-9
Letter S-2
COMMENTER: Anthony Higgins, Acting LDR Branch Chief, California Department of Transportation DATE: January 29, 2026
Response S-2.1
The commenter provides a summary of the proposed Project and acknowledges their appreciation for including the California Department of Transportation (Caltrans) in the environmental review process.

The comment is introductory and does not contain a substantive comment on the Draft PEIR. No further response is required.

Response S-2.2
The commenter expresses support for the Project’s goals because they align with State goals for safety, climate action, and sustainable transportation. The commenter also offers to collaborate on design elements that improve safety and promote walking, biking, and transit to help reduce driving and associated greenhouse gas emissions.

This comment does not contain a substantive comment on the Draft PEIR. No further response is required.

Response S-2.3
The commenter notes that the Bicycle Master Plan’s claim of proposing “30.1 miles of new bikeways” may be misleading because most of these miles are Class III routes where bicyclists are already permitted. They support including Class III facilities but recommend clarifying the distinction so that the reported miles of truly “new” bikeways are more transparent.

The City acknowledges that Class III bikeways typically occur on streets where bicycle travel is already permitted. The City will evaluate opportunities to more clearly differentiate between mileage associated with new Class I and II facilities versus Class III designations in the Plan. This distinction in facility designation does not alter or affect the impact analysis presented in the Draft PEIR, and no changes to the Draft PEIR are required.

Response S-2.4
The commenter explains that Senate Bill 1216 prohibits new sharrow markings on roads with speed limits above 30 miles per hour (mph), which conflicts with several proposed Class III routes in the Bicycle Master Plan (e.g., Canwood Street at 40 mph and Lake Lindero Drive at 50 mph). The commenter notes that Class III facilities are not used as performance metrics by Caltrans and suggests Class II facilities may fit within existing roadway widths, otherwise speed limits would need to be reduced for Class III feasibility.

Senate Bill 1216 and the associated prohibition on new sharrow markings on roadways with speed limits above 30 mph are acknowledged and discussed in the Final Bicycle Master Plan (pages 7 and 8). As noted, several streets included in the recommended Bike Network (Figure 4, page 23) have posted speed limits exceeding 30 mph yet are shown with proposed Class III designations. These City of Agoura Hills
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include segments of Canwood Street (35–40 mph), Roadside Drive (40 mph), and Kanan Road south of Agoura Road (45 mph). For these locations, the proposed Class III facilities would not include sharrows. The City will evaluate appropriate options for each segment, which may include installing Class III bike route signage without sharrows or considering speed limit reductions where feasible.

Additionally, the City notes that the speed limit on Lake Lindero is 25 mph, not 50 mph; the higher‑speed Lindero Canyon Road is outside the City limits and not part of the Project area.

The City will continue assessing facility types and operational conditions to ensure consistency with State requirements and best practices for bicycle safety. No changes to the Draft PEIR are required.

Response S-2.5
The commenter recommends improving certain crosswalks on Kanan Road near the Medea Creek Path to high-visibility markings, suggests incorporating pedestrian lighting or other safety features in the large United States 101 undercrossing, and notes that the undercrossing would require a Caltrans encroachment permit and adherence to all maintenance and safety requirements.

The City will evaluate opportunities to upgrade crosswalks on Kanan Road to high-visibility markings as part of future design advancement. The City also acknowledges the commenter’s recommendation to incorporate pedestrian lighting or other safety enhancements within the United States 101 undercrossing and will assess appropriate treatments during future project development.

The City further recognizes that any improvements within the State right-of-way, including the United States 101 undercrossing, would require a Caltrans encroachment permit. Acquisition of the encroachment permit and all associated maintenance, safety, and statutory requirements would be addressed in coordination with Caltrans during future implementation of the Medea Creek Path. No changes to the Draft PEIR are required.

Response S-2.6
The commenter notes that the Draft PEIR references bicycle parking at “various locations” but does not specify where these facilities would be provided. The commenter recommends identifying specific example locations because secure bicycle parking is essential to supporting mode shift.

The City recognizes that secure, well‑located bicycle parking is critical to enabling mode shift and supporting riders at the end of their trip. As described in Section 4.1.3 of the Bicycle Master Plan (page 21), end‑trip facilities such as bike racks, lockers, and repair stations are a core component of the City’s bicycle infrastructure network. While the Bicycle Master Plan provides a citywide framework, specific bicycle parking locations would be identified during future project‑level design and through coordination with property owners, schools, and transit agencies. No changes to the Draft PEIR are required.

Response S-2.7
The commenter states that a dedicated wayfinding and signage plan would significantly improve visibility and accessibility across the City’s active transportation network.

As described in Section 4.1.2 of the Bicycle Master Plan (page 20), signage and wayfinding are identified as recommended treatments intended to help bicyclists and drivers identify designated routes, understand corridor transitions, and navigate more comfortably throughout the system. The Bicycle Master Plan includes wayfinding as part of the broader suite of corridor enhancements, and Responses to Comments
Final Programmatic Environmental Impact Report D-11
future project-level design would refine the specific locations, sign types, and branding elements for the Citywide network. No changes to the Draft PEIR are required.

Response S-2.8
The commenter notes that, while the Draft PEIR shows CEQA‑required noticing was completed, it is unclear whether broader community outreach informed the recommendations in the Bicycle Master Plan. The commenter suggests clarifying what community engagement was conducted and identifying best practices for future engagement as the Project is implemented.

As described in Chapter 3 of the Bicycle Master Plan (starting on page 13), the City conducted a robust outreach process that included two public workshops (March 22, 2022 and July 12, 2022), an online survey, social media announcements, Strava challenge participation, and collaboration with residents, local bicycling advocacy groups, Las Virgenes Unified School District, the Los Angeles Sheriff’s Department, and local businesses. These activities provided direct input that helped shape the recommended projects and priorities.

The Draft PEIR focuses on CEQA noticing requirements and complies with applicable CEQA noticing provisions stipulated by CEQA Guidelines Sections 15802, 15805, 15806, and 15807. No changes to the Draft PEIR are required.

Response S-2.9
The commenter questions why Alternative 3 (Only Class II/III facilities) is identified as environmentally preferable over Alternative 2 (Project minus the Medea Creek Path and Agoura High School Connection), noting that Alternative 2 appears to provide a broader footprint with fewer intrusions than a separated path. The commenter requests clearer justification for selecting Alternative 3 as the environmentally superior alternative.

As discussed in Draft PEIR Section 6.5 (starting on page 6-31), Alternative 3 is identified as the environmentally superior build alternative because it has the smallest overall construction footprint, eliminating all Class I and Class IV facilities and substantially reducing earthwork and disturbance compared to both the Project and Alternative 2. This reduction results in lower impacts across multiple environmental resource areas, including air quality, biological resources, cultural resources, geology/soils, hazards, hydrology/water quality, noise, and transportation.

While Alternative 2 would still reduce impacts relative to the Project, it retains several off‑road Class I facilities and all Class IV corridors, which continue to introduce disturbance in sensitive or previously undisturbed areas. Alternative 3 avoids these areas entirely, which is why it performs better environmentally, even though it does not meet all Project objectives to the same extent. As required by CEQA, the Agoura Hills City Council will identify and select a preferred alternative at the time the Project is considered for approval. No changes to the Draft PEIR are required.

Response S-2.10
The commenter advises that Caltrans encroachment permits would be required wherever Project elements interact with State right-of-way, including any grading or drainage modifications affecting State facilities. The commenter requests that conditions of approval for issued entitlements explicitly require coordination with Caltrans District 7’s Office of Permits, and provides contact information for permitting.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
D-12
The City acknowledges that any individual Project components occurring within or affecting Caltrans right‑of‑way would require an encroachment permit from Caltrans. As individual projects advance through design and into implementation, the City will coordinate with the Caltrans Office of Permits to obtain the appropriate encroachment permits, as stated in Chapter 2, Project Description, Section

2.7, Required Permits and Approvals. No changes to the Draft PEIR are required.

Response S-2.11
The commenter provides their contact information.

The comment is conclusory and does not contain a substantive comment on the Draft PEIR. No further response is required.

Appendix E
Mitigation Monitoring and Reporting Program
Agoura Hills Bicycle Master Plan
Mitigation Monitoring and Reporting Program
SCH#2025010338
prepared by
City of Agoura Hills
Public Works Department
30001 Ladyface Court
Agoura Hills, California 91301
Contact: Charmaine Yambao, Public Works Director
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
March 2026
Mitigation Monitoring and Reporting Program
SCH#2025010338 1
Mitigation Monitoring and Reporting Program
The Programmatic Environmental Impact Report (PEIR) for the proposed Bicycle Master Plan (BMP), VMT Mitigation Exchange and Banking Program (Program), and General Plan Amendments (Amendments) in the City of Agoura Hills identifies the mitigation measures required to reduce environmental impacts associated with the Project. The California Environmental Quality Act (CEQA) requires a public agency to adopt a mitigation monitoring and reporting program (MMRP) for assessing and ensuring compliance with required mitigation measures that are necessary to reduce or avoid significant effects on the environment (Public Resources Code 21081.6). CEQA Guidelines Section 21081.6 provides general guidelines for implementing mitigation monitoring programs and indicates that specific reporting and/or monitoring requirements, to be enforced during project implementation, shall be defined as part of making findings or adopting a mitigated negative declaration.

This MMRP is intended to track and ensure compliance with adopted mitigation measures in the Agoura Hills Bicycle Master Plan Draft PEIR (State Clearinghouse Number 2025010338). The first column, entitled “Mitigation Measure,” identifies mitigation measures that were identified in the Final PEIR. The second column, entitled “Implementing Action,” refers to the action that must be taken to ensure the mitigation measure’s implementation. The third column, entitled “Implementation Monitoring and Reporting Responsibility,” refers to the agency responsible for oversight or ensuring that the mitigation measure is implemented. The fourth column, entitled “Implementation Timing Requirements,” refers to how often the monitoring will occur to ensure that the mitigation action is complete. The “Compliance Verification” columns are where the agency responsible for oversight verifies that the measures have been implemented.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
2 This page intentionally left blank.

Mitigation Monitoring and Reporting Program
SCH#2025010338 3
Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
Biological Resources
BIO-1(a): Pre-Construction Biological Resources Assessment and Reporting Prior to approval of final design for individual projects identified within the BMP that involve ground disturbance and/or vegetation trimming or removal, the City shall retain a qualified biologist to conduct a focused assessment of the environmental limits of the individual project boundary to identify sensitive biological resources that may be impacted by implementation of the project, including special-status plants, animals, and their habitats, as well as sensitive natural communities, regulated waters, and protected trees.

If the biologist identifies protected biological resources that may be affected by implementation of the project, the City shall first prepare alternative designs that seek to avoid and/or minimize impacts to the biological resources. If the project cannot be redesigned without complete avoidance, the City shall retain the qualified biologist to identify the specific impacts to the biological resource (i.e., special-status species, sensitive natural communities, regulated waters, and/or protected trees), identify any state or federal listed species that would necessitate coordination with the appropriate regulatory agency (i.e., USFWS, CDFW, USACE) to obtain regulatory permits, develop project-specific avoidance and mitigation procedures prior to initiating construction activities, and implement project-specific avoidance and mitigation measures prior to and during any construction activities.

Mitigation actions that may be required if impacts to sensitive biological resources be identified during implementation of individual projects include:
 Pre-construction surveys to identify the presence of special-status species, nesting birds, and roosting bats, within and adjacent to work areas;
 Worker Environmental Awareness Program training for all construction personnel;  Complete avoidance of special-status species where and if possible. Avoidance measures may include:
 Delimiting and flagging of special-status species avoidance buffer areas (Environmentally Sensitive Areas),  Monitoring of construction activity near Environmentally Sensitive Areas, and  Installation of special-status species exclusion fencing;  Relocation of special-status species out of work areas (with applicable permits and authorizations as necessary);  Restoration of temporarily disturbed special-status species’ habitat; and,  Compensatory mitigation for impacts to special-status species habitat at a minimum ratio appropriate for extent and quality of permanently disturbed habitat. Mitigation ratios may vary from 1:1 to 5:1.

The City will retain a qualified
biologist to conduct a focused
biological assessment prior to
approval of final design for any
project involving ground
disturbance or vegetation
removal. If sensitive biological
resources are identified, the
City will develop alternative
designs to avoid or minimize
impacts. If avoidance is not
feasible, the qualified biologist
will identify specific impacts,
determine permitting needs,
prepare project-specific
avoidance and mitigation
procedures, and oversee
implementation during
construction.

The City of Agoura Hills is responsible for:
 Hiring a qualified biologist.
 Ensuring the focused biological
assessment is completed.
 Ensuring mitigation measures are
incorporated into construction plans for
individual projects.

The qualified biologist is responsible for:
 Conducting the focused biological
assessment for sensitive resources prior
to final design approval.
 Identifying sensitive biological
resources and recommending
avoidance or minimization measures.
 Preparing project-specific mitigation
procedures when full avoidance is not
feasible.

The construction contractor is responsible
for:
 Adhering to mitigation measures.

Prior to approval of
final design for
individual projects
BIO-1(b): Pre-Construction Nesting Bird Surveys, Avoidance, and Reporting Future construction activities initiated during the raptor and passerine bird nesting season (January 1 – August 31) involving removal of vegetation or other nesting bird habitat, including abandoned structures and other manmade features, shall be preceded by a pre-construction nesting bird survey conducted no more than one week prior to initiation of ground disturbance and vegetation removal activities. The nesting bird preconstruction survey shall be conducted on foot and shall include up to a 200-foot buffer around the construction site depending on the specific area being surveyed, where publicly accessible. The survey shall be conducted by a qualified biologist familiar with the identification of avian species known to occur in southern California. If nests are found, an avoidance buffer shall be determined by a qualified biologist dependent upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site, which shall be demarcated by the biologist with bright orange construction fencing, flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified as to the existence of the buffer zone and to check with the qualified Biologist before entering the buffer zone during the nesting season. Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the encroachment will not be detrimental to an active nest.

No ground or vegetation disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/ nesting is completed, and the young have fledged the nest. An email summarizing the preconstruction survey(s) shall be prepared by a qualified biologist and shall be submitted to the city prior to the commencement of construction activities.

Individual project plans shall include a statement acknowledging compliance with the MBTA and CFGC that includes avoidance of active bird nests and identification of BMPs to avoid impacts to active nests, including checking for nests prior to construction activities during the nesting bird season and what to do if an active nest is found so that the nest is not inadvertently impacted during grading or construction activities.

If construction occurs between
January 1 and August 31 and
involves vegetation removal or
disturbance of nesting habitats,
the City will retain a qualified
biologist to conduct a nesting
bird survey no more than seven
days before ground disturbance.

If active nests are found, the
biologist will establish
species-specific buffers. No
encroachment may occur within
the buffer unless determined by
the biologist that the
encroachment will not be
detrimental to an active nest,
and no ground disturbance may
occur within the buffer until the
biologist confirms nesting is
complete and the young have
fledged. All individual project
plans will acknowledge
The City of Agoura Hills is responsible for:
 Hiring a qualified biologist
 Reviewing and approving the survey
results.
 Verifying construction workers are
working outside of established buffers.
 Ensuring individual project plans
acknowledge compliance with the
MBTA and CFGC.

The qualified biologist is responsible for:
 Conducting a nesting bird survey within
seven days prior to the start of
construction when work occurs
between January 1 and August 31.
 Summarizing survey results in an email
submitted to the City.
 Establishing a buffer around any
nesting birds or active nests, if
identified.

Prior to construction;
during construction
City of Agoura Hills
Agoura Hills Bicycle Master Plan
4 Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
compliance with the MBTA and
CFGC.
 Monitoring active nests once per week
until nesting is complete and young
have fledged.

The construction contractor is responsible
for:
 Avoiding work within the buffer
established by the qualified biologist.

BIO-1(c): Construction Best Management Practices
The following construction BMPs shall be incorporated into all grading and construction plans for individual projects:
 A 20 mile-per-hour speed limit shall be designated in all construction areas where applicable.  All vehicles and equipment shall be parked on pavement, existing roads, and previously disturbed areas, and clearing of vegetation for vehicle access shall be avoided to the greatest extent feasible.  The number of access routes, number, and size of staging areas, and the total area of the activity shall be limited to the minimum necessary to achieve the goal of the Project.  Equipment washout and fueling areas shall be located within the limits of grading at a minimum of 100 feet from waters, wetlands, or other sensitive resources as identified by a qualified biologist to the greatest extent feasible.

Washout areas shall be designed to fully contain polluted water and materials for subsequent removal from the site.
 Daily construction work schedules shall be limited to daylight hours where adjacent to natural areas capable of supporting wildlife, and shall be consistent with local noise ordinances.  Mufflers shall be used on all construction equipment where work will be conducted within or adjacent to natural areas capable of supporting wildlife, and vehicles shall be in good operating condition.  Drip pans shall be placed under all stationary vehicles and mechanical equipment within 100 feet of a drainage, creek, or stream.
 All trash shall be placed in sealed containers and shall be removed from project sites a minimum of once per week.
 No pets are permitted on Project sites during construction.

Construction BMPs will be
incorporated into all grading
and construction plans for each
individual project.

The City of Agoura Hills is responsible for:
 Ensuring all required BMPs are included
in grading and construction plans.
 Verifying that contractors implement
BMPs throughout construction.

The construction contractor is responsible
for:
 Implementing all BMPs and maintaining
BMP throughout the duration of
construction.

Prior to approval of
grading and
construction plans
for individual
projects
BIO-2(a): Riparian Habitat and Sensitive Natural Communities Protection If sensitive natural communities, wetlands, or riparian habitats are identified within individual project limits, the City shall design or modify the project to avoid direct and indirect impacts on these habitats, if feasible. At a minimum, the City shall implement the following measures to minimize the loss of riparian vegetation, where feasible.  Protect sensitive habitat areas from harmful exposure to light. If an individual project identified within the BMP is located within or adjacent to sensitive habitat areas or habitat for sensitive species, and lighting is proposed, then the facility will be designed to protect such areas from harmful exposure to light by shielding light sources, redirecting light sources, or using low intensity lighting.  Delineate sensitive habitat areas. Sensitive habitat areas to be avoided, including appropriate buffers (determined by a qualified biologist), will be flagged by a qualified biologist prior to the onset of construction activities. Where indicated by the biologist, these areas will be fenced or otherwise protected from direct and indirect impacts. All such areas to be avoided with be clearly marked on construction plans and designated as “no construction” zones.
 Slope stabilization. Where construction will occur on bare soil or on slopes, the contractor shall stabilize exposed soil/slopes immediately upon completion of construction activities. On highly erodible soils/slopes, the contractor shall use a non-vegetative material that binds the soil initially and breaks down within a few years. If more intensive erosion control treatments are needed, geotextile mats, excelsior blankets, or other soil stabilization products shall be used.
 Install signage and fencing, vegetation, or other natural barriers to prevent impacts on adjacent areas during operation. Fencing, vegetation, or other natural barriers will be constructed to prevent impacts on sensitive habitat areas adjacent to the Facilities during operation. Signs will be erected in appropriate locations to inform users of the need to stay within designated bike paths, lanes, routes, or boulevards.

If sensitive natural
communities, wetlands, or
riparian habitats are identified,
the City will modify the design
of individual projects to avoid
impacts where feasible. When
avoidance is not fully feasible,
measures to minimize impacts
will be implemented. Measures
will include lighting controls,
delineation of sensitive habitats
and avoidance areas, slope
stabilization, and installation of
signage and barriers.

The City of Agoura Hills is responsible for:
 Ensuring construction plans avoid
impacts or include lighting controls,
delineation of sensitive habitats and
avoidance areas, slope stabilization,
and installation of signage and barriers.
 Hiring a biologist to delineate sensitive
habitat areas.

The qualified biologist is responsible for:
 Identifying sensitive natural
communities, wetlands, and riparian
habitats within individual project limits.
 Establishing and flagging appropriate
buffers around sensitive habitat areas
The construction contractor is responsible
for:
 Implementing measures identified on
the construction plans.

Avoiding sensitive habitat areas and
buffers.

Prior to construction;
during construction
Mitigation Monitoring and Reporting Program
SCH#2025010338 5
Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
BIO-2(b): Jurisdictional Delineation Survey and Report
Before approving any individual project involving ground disturbance, the City shall retain a qualified biologist to conduct a site-specific assessment of the individual project area to identify sensitive natural communities, wetlands, or riparian habitats. The field delineation shall include a survey effort within the individual project area. During the field survey, sample points shall be established to document wetland and non-wetland aquatic resources, using the appropriate agency-approved methodology and data forms. The sample points shall focus on identifying indicators of an OHWM, wetland hydrology, hydric soils, and hydrophytic vegetation. Using this information, a “wetland edge” shall be discerned between the wetland and non-wetland points, and the boundary of the aquatic resources shall be mapped with a sub-meter global position system unit.

The survey shall be conducted in accordance with USACE Wetlands Delineation Manual (1987) and Arid West Regional Supplement to the manual, as well as the latest guidance from the CDFW and Los Angeles RWQCB. This methodology is the acceptable methodology for delineating the boundaries of federal and state jurisdictions.

The report shall include a discussion of methodologies and results that detail the background information; field observations and data collected; and a summary of findings. The report shall contain narrative descriptions of all aquatic features identified, including jurisdictional resources and their boundaries within the Project component’s work area. The report shall quantify lengths and acreages of each aquatic feature, provide high-quality figures, site photographs, and completed data forms, and geographic information system (GIS) data.

The report shall be used to support permitting requirements and shall be submitted to the City for review and approval prior to the issuance of grading permits.

Before approving any individual
project involving ground
disturbance, the City will retain
a qualified biologist to conduct
a site-specific delineation of
sensitive natural communities,
wetlands, and riparian habitats.

The biologist will prepare a
delineation report to support
permit applications.

The City of Agoura Hills is responsible for:
 Hiring a qualified biologist.
 Ensuring the delineation is completed.
 Reviewing and approving the
delineation report.

The qualified biologist is responsible for:
 Conducting the site-specific
jurisdictional delineation.
 Preparing a delineation report.

Prior to issuance of
grading permits for
individual projects
BIO-2(c): Compensatory Mitigation
If sensitive natural communities, state or federally protected wetlands, and/or riparian habitats are disturbed due to implementation of an individual project identified within the BMP, the City shall compensate for the disturbance to ensure no net loss of habitat functions and values. Compensation ratios shall be based on site-specific information and determined through coordination with state, federal, and/or local agencies as part of the permitting process for the individual project prior to the issuance of a grading permit and/or initiation of construction activities. Unless determined otherwise by the regulatory/permitting agency, the compensation shall be at a minimum ratio of two acres restored, created, and/or preserved for every one acre disturbed (2:1). Compensation may comprise on-site restoration/creation off-site restoration, preservation, or purchase of mitigation credits (or a combination of these elements). If compensatory mitigation involves restoration, the City shall develop and implement a Restoration and Monitoring Plan that describes how the habitat shall be created and monitored over a minimum period of time.

In broad terms, the Restoration and Monitoring Plan shall at a minimum include:
 Description of the project/impact and mitigation sites  Information related to riparian habitat impacts
 Specific objectives
 Success criteria
 Plant palettes for each vegetation community
 Implementation plan
 Maintenance activities
 Monitoring plan
 Contingency measures
The plant palette shall include a diversity of appropriate native species that occur in the communities in the surrounding area. The performance standards for the Restoration and Monitoring Plan shall be, at a minimum, the following:
 Within five years after introducing the native plants to the mitigation site, the acreage of restored native grassland habitat shall be no less than two times the acreage lost to project construction.  Within five years after introducing the native plants to the mitigation site, the absolute cover of the target species and other native species shall be no less than 50 percent within the restoration area.

If sensitive natural
communities, protected
wetlands, or riparian habitats
are disturbed by an individual
project, the City will provide
compensatory mitigation to
ensure no net loss of habitat
functions and values.

Compensation ratios will be
established in coordination with
state, federal, and local
agencies during permitting.

If compensatory mitigation
involves restoration, the City
will implement a Restoration
and Monitoring Plan.

Restoration will be monitored
annually for up to five years or
until success criteria are met.

Annual and final reports will be
submitted to the City.

If compensatory mitigation
involves in-lieu fees, the City
will pay the in-lieu fees.

The City of Agoura Hills is responsible for:
 Coordinating with regulatory agencies
to determine compensation ratios.
 Developing a Restoration and
Monitoring Plan if restoration is used as
compensatory mitigation.
 Ensuring monitoring and reporting
requirements are met if restoration is
used as compensatory mitigation.
 Providing evidence of payment if in-lieu
fees are paid as compensatory
mitigation.

Compensation ratios
will be determined
prior to issuance of
grading permits for
individual projects;
in-lieu fees will be
paid prior to
issuance of grading
permits for individual
projects; restoration
projects will occur
prior to construction;
restoration
monitoring and
reporting will occur
annually; final
restoration report
will be prepared five
years after the start
of the restoration
project
City of Agoura Hills
Agoura Hills Bicycle Master Plan
6 Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
 Restoration will be considered successful after the success criteria have been met for a period of at least 2 years without any maintenance or remediation activities other than invasive species control.

The restoration project shall be initiated prior to development of the individual project and shall be implemented at most over a five-year period, unless success criteria is met sooner. The restoration project shall incorporate an iterative process of annual monitoring and evaluation of progress, and allow for adjustments to the restoration plan, as necessary, to achieve desired outcomes and meet success criteria. Annual reports discussing the implementation, monitoring, and management of the restoration project shall be submitted to the City. Five years after start of the restoration project, a final report shall be submitted to the City, which shall at a minimum discuss the implementation, monitoring, and management of the restoration project over the five-year period and indicate whether the restoration project has been successful based on established success criteria. The annual reports and the final report shall include as-built plans submitted as an appendix to the report.

If the loss of the sensitive habitat types is to be mitigated by a contribution of an in-lieu fee, the City shall provide evidence of payment of the in-lieu fee prior to issuance of the grading permit. The fee shall be based on the cost per acre to restore or create in-kind habitat and the acreage of sensitive communities impacted. In-lieu fees shall be used for the restoration of in-kind habitat.

BIO-5(a): Tree Protection
The City shall procure all necessary tree removal permits prior to impacting a protected oak tree. A tree protection and replacement plan shall be developed by a certified arborist for any protected oak tree(s) or other naturally occurring native tree that has a trunk diameter (at 4.5 feet above grade; diameter at breast height [DBH]) that will be affected by implementation of an individual project identified within the BMP. The tree protection and replacement plan shall include, but would not be limited to, an inventory of protected oak trees and naturally occurring native trees with a DBH of four inches or more within the individual construction site, setbacks from trees and protective fencing, restrictions regarding grading and paving near trees, direction regarding pruning and digging within the root zone of trees, and requirements for replacement and maintenance of trees. If protected oak trees or other naturally occurring native trees with a DBH of four inches or more will be removed, replacement tree plantings of like species in accordance with the city standards, but at a minimum ratio of 4:1 (trees planted to trees impacted) for protected oak trees in accordance with the City of Agoura Hills Oak Tree Preservation Guidelines and Oak Tree Ordinance (Municipal Code Article IX, Chapter 6, Part 2., Division 7) and a minimum ratio of 1:1 replacement for other naturally occurring native trees with a DBH of four inches or more, and shall be installed on-site or at an approved off-site location and a restoration and monitoring program shall be developed and implemented for a minimum of seven years.

If the protective zone (as defined per the Agoura Hills Oak Tree Preservation Guidelines) of a protected oak tree is disturbed by more than 30 percent, the tree shall be retained and mitigated at a ratio of 4:1 as described above, because long-term impacts that may lead to decline or mortality may not be visible for several years. Any protected oak tree that will be encroached within its protective zone during construction shall have a certified arborist present to oversee the work activities. Any trimming of roots and branches shall be performed or directly supervised by a certified arborist and shall be done in accordance with the American National Standards Institute A300 Tree Care standards.

The City will procure tree
removal permits for impacts to
oak trees. The City will retain a
certified arborist to develop a
tree protection and
replacement plan for impacts to
protected oak trees or native
tree ≥4 inches DBH. If protected
oak trees, native trees ≥4 inches
DBH, or their protective zones
will be removed, the City will
implement required
replacement at the appropriate
ratio and carry out a seven-year
restoration and monitoring
program. The City will retain a
certified arborist to oversee
work activities if a protected
oak tree will be encroached
within its protective zone during
construction. The City will retain
a certified arborist to perform
or directly supervise trimming
of roots and branches.

The City of Agoura Hills is responsible for:
 Obtaining tree-removal permits.
 Hiring a certified arborist.
 Reviewing and approving the tree
protection and replacement plan.
 Ensuring protective zones and
tree-protection measures are
incorporated into project construction
plans.
 Verifying that construction workers
comply with protective zones and
tree-protection measures.
 Ensuring the restoration and
monitoring program is developed for
replacement plantings over the
required seven-year period.

The certified arborist is responsible for:
 Preparing the Tree protection and
replacement plan.
 Overseeing construction activities
within the protective zone of protected
oak trees.
 Performing or supervising all root and
branch trimming.

The construction contractor is responsible
for:
 Adhering to protective zones and
tree-protection measures.
 Complying with root and branch
trimming limitations.

Prior to construction;
during construction;
annual monitoring
Mitigation Monitoring and Reporting Program
SCH#2025010338 7
Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
Cultural Resources
CUL-1: Prepare Historical Resources Evaluation Prior to Approval of Project Involving Structures 45 Years or Older and Implement Mitigation Prior to and During Construction Prior to approval of individual Class I facilities, Class II facilities, Class IV facilities, and enhanced bicycle treatments that include construction activities which could result in direct/indirect impacts to historical resources, including those that could result in direct impacts to structures/objects and/or indirect impact to buildings 45 years or older, the City shall retain a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards (SOI PQS) in architectural history and/or history as defined in CFR Title 36, Part 61 to oversee the following steps:
 Prior to proceeding with the historical resources evaluation (HRE) described below, a qualified architectural historian or historian (who meets the Secretary of the Interior’s Professional Qualifications Standards (SOI PQS) in architectural history and/or history as defined in CFR Title 36, Part 61) shall conduct a review of the applicable registers of previously documented built environment resources qualifying as historical resources to determine the presence of such resources within or immediately adjacent to a Class I, II, or IV project footprint or enhanced bicycle facility, and to confirm its condition is consistent with that presented in associated designation documentation. This effort, which may include a field survey, shall be documented in a report (that may be combined with the report described in the third bullet below as necessary and appropriate) that shall be submitted to the City for review and approval prior to initiation of a project component.  Based on guidance provided by the California Office of Historic Preservation (OHP), not all built environment resources merit recordation. Therefore, the professional judgement of an architectural historian (that meets the SOI PQS in architectural history or history as defined in Code of Federal Regulations, Title 36, Part 61) shall be relied upon to determine if built environment resources with potential significance requiring recordation are present within a given project component site or its immediate surroundings. If a project component site or property in its immediate surroundings includes a building, structure, or other built environment feature that is 45 years of age or older that merits recordation and has the potential to be significantly impacted by the project, the City shall prepare a HRE for the property containing said building, structure, or other built environment feature. The evaluation shall consider the eligibility of the resource for listing in the National Register of Historic Places and California Register of Historical Resources, in addition to any applicable local register of historical resources.
 The HRE shall be prepared by a SOI PQS architectural historian or historian. The HRE shall include an intensivelevel evaluation prepared in accordance with the guidelines and best practices promulgated by the California OHP. The building, structure or other built environment feature shall be evaluated within an appropriate historic context and documented in a report that meets the California OHP guidelines. All evaluated resources shall be documented on California Department of Parks and Recreation Series 523 Forms (DPR forms) in accordance with the guidance included in the OHP’s Instruction for Recording Historical Resources. The report with attached DPR forms shall be submitted to the City for review and approval prior to proceeding with construction of the project component.
 If built environment resources qualifying as historical resources having the potential to be significantly impacted by a proposed project component are identified within a proposed project component site or its immediate surroundings, efforts shall be made to ensure that impacts are mitigated. In such instances, the above-noted HRE report shall be amended or supplemented with a report that identifies the resource’s character-defining features and recommends treatment methods for character-defining features. The report shall demonstrate how the proposed project component complies with the Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI Standards) and avoids impacts to historical resources pursuant to CEQA. The report shall be submitted to the City for review and approval prior to proceeding with construction the project.  If built environment historical resources are identified and compliance with the SOI Standards is not possible, appropriate site-specific mitigation measures that reduce impacts to historical resources to the greatest extent feasible shall be established and undertaken. Mitigation measures may include, but would not be limited to, documentation of the historical resource in the form of a Historic American Building Survey (HABS) or Historic American Engineering Record (HAER) report that complies with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation, or development of an interpretative display or educational opportunity that relates the history and significance of the resource to the public.

Prior to approving individual
projects that could directly or
indirectly impact structures,
objects or buildings 45 years or
older, the City will retain a
qualified architectural historian
to review existing registers of
previously documented built
environment historical
resources, determine the
presence of such resources
within or immediately adjacent
to individual project footprints,
and confirm conditions are
consistent with those presented
in designation documentation.

The historian will conduct a field
survey as needed to verify
current conditions. The
historian will present findings in
a report submitted to the City.

The City will retain a qualified
architectural historian to
prepare an HRE for any building,
structure, or other built
environment feature that is 45
years of age or older and has
the potential to be significantly
impacted by an individual
project. The historian will
document resources on DPR
forms.

The City will avoid or mitigate
for impacts to qualifying
historical resources.

The City of Agoura Hills is responsible for:
 Hiring a qualified architectural historian
meeting SOI PQS.
 Reviewing and approving HREs and DPR
forms.
 Ensuring recommended avoidance and
site-specific mitigation measures are
incorporated into construction plans for
individual projects.

The qualified architectural historian is
responsible for:
 Reviewing existing registers of
previously documented built
environment historical resources.
 Determining the presence of previously
documented built environment
historical resources within or
immediately adjacent to individual
project footprints.
 Confirming the current conditions of
previously documented built
environment historical resources are
consistent with conditions presented in
designation documentation, including
conducting as-needed field surveys.
 Determining whether built
environment resources ≥45 years old
require recordation and/or merit an
HRE.
 Preparing an HRE in accordance with
California OHP guidelines and
completing DPR 523 forms if
recordation is required.
 Recommending design treatments
demonstrating compliance with the SOI
Standards when historical resources
may be significantly impacted.
 Preparing additional mitigation
recommendations when compliance
with SOI Standards is not feasible.

The construction contractor is responsible
for:
 Adhering to design treatments and/or
site-specific mitigation measures.

Prior to construction;
during construction
City of Agoura Hills
Agoura Hills Bicycle Master Plan
8 Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
CUL-2: Prepare Archaeological Resources Assessment Prior to Project Approval and Implement Mitigation Prior to and During Construction.

Prior to approval of individual Class I facilities, Class II facilities, Class IV facilities, and enhanced bicycle treatments that involve ground disturbing activities, the City shall retain an archaeologist that meets the SOI PQS in either prehistoric or historic archaeology (qualified archaeologist as defined in CFR, Title 36, Part 61) to oversee the preparation of an archaeological resources assessment).  Archaeological Resources Assessments shall include a CHRIS records search at the SCCIC with a minimum 0.5-mile radius and a Sacred Lands File search through the California Native American Heritage Commission. The records searches will characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas. A Phase I pedestrian survey shall be undertaken at Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas and shall include the participation of a retained Tribal representative approved by local Tribes listed on the NAHC contact list culturally affiliated with the project area to locate any surface evidence of cultural materials. A geoarchaeological review (examination of CHRIS and ethnographic data, historical, geological, and soil maps, aerial imagery, geotechnical reports) shall be conducted to assess the potential for the project to encounter unknown archaeological resources during construction. A qualified archaeologist shall identify known archaeological resources and classify the Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas as having high, medium, or low sensitivity for unknown archaeological resources. The assessment shall also include recommendations for additional studies and/or mitigation, as necessary, such as archaeological and Tribal monitoring during construction-related ground disturbance. Construction monitoring shall be recommended when archaeological resources are present and/or the assessment identifies a moderate or high likelihood of archaeological resources being present.
 If the CHRIS search or Phase I archaeological survey identifies resources that may be impacted by Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas, the archaeological resources assessment shall also include Phase II testing and evaluation. Local Tribes listed on the NAHC contact list culturally affiliated with the area shall be notified of any prehistoric resources identified and retained, as requested, to advise on appropriate next steps. Local Tribes culturally affiliated with the project area shall be provided the opportunity to review and approve the Phase II Testing and Evaluation Plan prior to implementation. A Tribal representative shall be present to monitor all Phase II testing and evaluation activities. If resources are determined significant (i.e., eligible for the CRHR and/or NRHP or unique to the City) shall first consider whether avoidance and preservation in place is feasible. If resource avoidance and preservation in place is not feasible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation.  For archaeological resources found eligible under CRHR Criterion 4/NRHP Criterion D (data potential) that cannot be avoided and will be impacted by Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas, mitigation shall include, but would not be limited to, a Phase III data recovery program. The data recovery program shall make provisions for adequately recovering the scientifically consequential information from and about the resource.

The qualified archaeologist and City shall consult with appropriate Native American representatives regarding the data recovery program in determining treatment for prehistoric or Native American resources to ensure cultural values ascribed to the resource, beyond those that are scientifically important, are considered. For archaeological resources that are found eligible under CRHR Criteria 1/NRHP Criteria A (events), 2/B (persons), and/or 3/C (design/craftsmanship) that cannot be avoided and will be impacted by Class I facilities, Class II facilities involving road widening, Class IV facilities involving road widening, or enhanced bicycle treatments located in previously undisturbed areas, other appropriate mitigation shall be determined by a qualified archaeologist in consultation with the City and, if the resource is of indigenous origin, local interested Tribes. Mitigation may include, but would not be limited to, development of interpretive or educational materials or preservation of all or portions of the archaeological site.
 Final disposition of any recovered artifacts or samples, which could include but would not be limited to curation or onsite reburial, shall occur as specified by the qualified archaeologist in consultation with the City and, if the resource is of indigenous origin, local interested Tribes. Artifacts and samples include material recovered from all Prior to approving individual
projects involving
ground-disturbance, the City
will retain a qualified
archaeologist to conduct an
archaeological resources
assessment. The archaeologist
will review CHRIS records, the
Sacred Lands File, and previous
survey data to identify known
cultural resources within or
adjacent to individual project
sites. The archaeologist will also
conduct a Phase I pedestrian
survey in previously
undisturbed areas with
participation from a Tribal
representative and will prepare
a geoarchaeological review to
assess the potential for
encountering unknown
archaeological resources. The
archaeologist will present
findings in a report submitted to
the City.

If archaeological resources may
be impacted, the archaeological
resources assessment will
include Phase II testing and
evaluation. Local Tribes will be
notified of any identified
prehistoric resources, provided
an opportunity to review the
Phase II Testing and Evaluation
Plan, and invited to participate
in monitoring Phase II
investigations. The
archaeologist will recommend
avoidance measures whenever
feasible; if avoidance is not
feasible, the archaeologist will
identify appropriate site-specific
mitigation measures.

If significant archaeological
resources cannot be avoided,
the City will implement
additional mitigation, which
may include Phase III data
recovery or alternative
treatments for eligible
resources. Mitigation will be
developed in consultation with
The City of Agoura Hills is responsible for:
 Hiring a qualified archaeologist meeting
SOI PQS.
 Reviewing and approving
archaeological resources assessment
documents.
 Notifying and coordinating with local
Tribes when prehistoric resources are
identified, including facilitating Tribal
monitoring and review.
 Ensuring recommended avoidance and
site-specific mitigation measures are
incorporated into construction plans for
individual projects.
 Ensuring final disposition of recovered
artifacts or samples is completed.

The qualified archaeologist is responsible for:
 Preparing all archaeological resources
assessment documents.
 Classifying the sensitivity of each
project area for unknown
archaeological resources and
recommending monitoring where
appropriate.
 Conducting Phase II testing and
determining resource eligibility.
 Recommending avoidance measures
and preservation in place where
feasible.
 Recommending site-specific mitigation
when avoidance is not feasible,
including Phase III data recovery for
eligible resources.
 Specifying final disposition of recovered
artifacts or samples.

The construction contractor is responsible
for:
 Adhering to avoidance and/or sitespecific mitigation measures.

Prior to construction;
during construction
Mitigation Monitoring and Reporting Program
SCH#2025010338 9
Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
phases of work, including the Phase I survey, Phase II testing, Phase III data recovery, and construction monitoring.
appropriate Tribal
representatives when resources
are of indigenous origin.

The City will ensure that
recovered artifacts or samples
are curated or reburied in
consultation with the qualified
archaeologist, and in
consultation with Tribal
representatives when resources
are indigenous.

Geology and Soils
GEO-9: Paleontological Resources Assessment
Prior to approval of final design for individual projects identified within the BMP that involve ground disturbance, the City shall require preparation of a Paleontological Resources Assessment. This assessment may be prepared as a standalone report or incorporated into a larger environmental review document. The Paleontological Resources Assessment shall be prepared by an individual meeting the standards of a Qualified Professional Paleontologist as defined by the SVP. The assessment shall summarize the results of a records search of the Natural History Museum of Los Angeles County, summarize the results of a desktop review of available literature and geologic maps of the individual project site, characterize the paleontological sensitivity of the geologic unit(s) present within the project site using the SVP paleontological sensitivity scale, assess the potential for significant impacts to paleontological resources, and provide mitigation recommendations for avoiding or reducing impacts to paleontological resources from project construction, if necessary.

The City will retain a qualified
Professional Paleontologist to
prepare a Paleontological
Resources Assessment prior to
approval of final design for any
project involving ground
disturbance.

The City of Agoura Hills is responsible for:
 Retaining a qualified paleontologist.
 Reviewing and approving the
Paleontological Resources Assessment.
 Ensuring mitigation measures are
incorporated into construction plans for
individual projects.

The Paleontologist is responsible for:
 Preparing the Paleontological
Resources Assessment.

The construction contractor is responsible
for:
 Adhering to mitigation measures.

Prior to approval of
final design for
individual projects
Hazards and Hazardous Materials
HAZ-1: Soil Management Plan.

Prior to commencement of ground-disturbing activities for proposed facilities within 1,000 feet of a known hazardous release site, the City shall retain a qualified consultant (i.e., professional geologist or professional engineer) to prepare a Soil Management Plan (SMP) for the project. The SMP shall address:

On-site handling and management of unanticipated contaminated soils or other contaminated wastes (e.g., stained soil, soil with solvent or chemical odors) if encountered during ground disturbance, n-site handling and management of unanticipated contaminated soils or other contaminated wastes (e.g., stained soil, soil with solvent or chemical odors) if encountered during ground disturbance, and Specific actions to reduce hazards to construction workers and off-site receptors during construction (e.g., personal protective equipment, dust control, and/or air monitoring.

The SMP must establish remedial measures and soil management practices to ensure construction worker safety and prevent the off-site migration of contaminants from the project site to the satisfaction of the Director of Public Works. These measures and practices may include, but are not limited to:
 Proper transportation and disposal procedures for contaminated materials in accordance with applicable regulations, including CCR Title 22.
 A requirement to halt work in the immediate area and contact a qualified consultant (i.e., professional geologist or professional engineer) immediately to evaluate the project site conditions if odorous or visually stained soils, other indications of piping or equipment (including hydrocarbon piping or equipment), or debris are encountered during ground-disturbing activities.
 A health and safety plan for contractors working at the project site that addresses the safety and health hazards of each phase of project construction activities with the requirements and procedures for employee protection The City will retain a
professional geologist or
professional engineer to
prepare a Soil Management
Plan prior to ground
disturbance.

The City of Agoura Hills is responsible for:
 Hiring a professional geologist or
professional engineer.
 Reviewing and approving the Soil
Management Plan.
 Approving construction in impacted
areas.
 Ensuring measures are incorporated
into construction Specifications for
individual projects
 Verifying the Soil Management Plan is
implemented.

The professional geologist or professional
engineer is responsible for:
 Preparing the Soil Management Plan.
 Recommending specific actions to
reduce hazards during construction.
 Recommending testing, removal,
treatment, and/or disposal methods for
hazardous materials.

Prior to issuance of
grading permits for
individual projects;
prior to construction;
during construction
City of Agoura Hills
Agoura Hills Bicycle Master Plan
10 Mitigation Measure Implementing Action
Implementation Monitoring/ Reporting
Responsibility
Implementation
Timing Requirements
Compliance
Verification Initial
Compliance
Verification Date
Compliance
Verification Comments
and outlines proper soil handling procedures and health and safety requirements to minimize worker and public exposure to hazardous materials during construction.
 Reporting on monitoring activities.

The Director of Public Works shall review and approve the SMP prior to construction (grading/excavation) activities at and prior to issuing grading permits for proposed facilities within 1,000 feet of a known hazardous release site. The City shall implement the SMP during grading and construction activities.  Establishing remedial measures and soil
management practices to ensure safety
and prevent migration.

The construction contractor is responsible
for:
 Implementing the Soil Management
Plan and adhering to the measures and
actions identified therein.
 Halting work in the event unexpected
hazardous materials are encountered
during construction.

Noise
N-1: Construction Noise Reduction Measures
The following construction noise reduction measures shall be included as standard conditions of approval for projects involving construction within 125 feet of a sensitive receptor:
 Properly muffle and maintain all construction equipment powered by internal combustion engines;  Prohibit unnecessary idling of combustion engines;
 Locate all stationary noise-generating construction equipment (such as air compressors) as far as practical from existing nearby residences and other noise-sensitive land uses;  Select quiet construction equipment, particularly air compressors, whenever possible;  Fit motorized equipment with proper mufflers in good working order;  Residences, schools, libraries, hospitals or other medical care facilities adjacent to individual project sites shall be notified, in advance and by writing, of the proposed construction schedule before construction activities commence, including details for the noise disturbance coordinator; and,  Construction of each individual project identified within the BMP shall have a designated “noise disturbance coordinator” responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of noise complaints and shall require that reasonable measures be implemented to correct the problem. A telephone number for the disturbance coordinator shall be posted at the construction site.

Noise reduction measures will
be included as standard
conditions of approval for
individual projects involving
construction within 125 feet of
a sensitive receptor.

The City of Agoura Hills is responsible for:
 Ensuring construction noise reduction
measures are included in grading and
construction plans.
 Verifying that contractors implement
noise reduction measures throughout
construction.

The construction contractor is responsible
for:
 Implementing all noise reduction
measures and maintaining noise
reduction measures throughout the
duration of construction.

Prior to construction;
during construction
N-2: Construction Vibration Control Plan
Prior to the issuance of any grading permit, the Public Works Department shall verify that the Project plans and specifications include provisions that require that paving activities within 37 feet of off-site structures utilize a static roller in lieu of a vibratory roller.

Plans and specifications for
individual projects require a
static roller for paving activities
occurring within 37 feet of
off-site structures.

The City of Agoura Hills is responsible for:
 Ensuring the plans and specifications
for individual projects include the
requirement to use a static roller within
37 feet of off-site structures.

The construction contractor is responsible
for:
 Adhering to the plans and specifications
for individual projects.

Prior to issuance of
grading permits for
individual projects
Exhibit “B”
Findings of Fact and Statement of Overriding Considerations Agoura Hills Bicycle Master Plan
Findings of Fact and Statement of Overriding Considerations SCH# 2025010338
prepared by
City of Agoura Hills
Public Works Department
30001 Ladyface Court
Agoura Hills, California 91301
Contact: Charmaine Yambao, Director of Public Works/City Engineer prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
April 2026

Table of Contents
Findings of Fact and Statement of Overriding Considerations i Table of Contents
1 Introduction .................................................................................................................................1 2 Project Description.......................................................................................................................3 3 Project Objectives........................................................................................................................4 4 Findings of Fact ............................................................................................................................5

4.2.1 Biological Resources – Impact BIO-1....................................................................6

4.2.2 Biological Resources – Impact BIO-2....................................................................8

4.2.3 Biological Resources – Impact BIO-3..................................................................11

4.2.4 Biological Resources – Impact BIO-5..................................................................12

4.2.5 Geology and Soils – Impact GEO-9.....................................................................14

4.2.6 Hazards and Hazardous Materials – Impact HAZ-1............................................14

4.2.7 Hazards and Hazardous Materials – Impact HAZ-2............................................16

4.2.8 Noise – Impact NOI-1 .........................................................................................16

4.2.9 Noise – Impact NOI-2 .........................................................................................17

4.3.1 Cultural Resources – Impact CUL-1 ....................................................................18

4.3.2 Cultural Resources – Impact CUL-2 ....................................................................20

4.3.3 Recreation – Impact REC-2.................................................................................21 5 Project Alternatives....................................................................................................................24 6 Statement of Overriding Considerations...................................................................................28 7 Statement of Location and Custodian of Documents................................................................30 City of Agoura Hills
Agoura Hills Bicycle Master Plan
ii
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Introduction
Findings of Fact and Statement of Overriding Considerations 1 1 Introduction
A Draft Programmatic Environmental Impact Report (PEIR) was prepared for the proposed Bicycle Master Plan (BMP), Vehicle Miles Traveled (VMT) Mitigation Exchange and Banking Program (Program), and General Plan Amendments (Amendments) (hereafter referred to as the “proposed Project” or “Project”). The City of Agoura Hills (City) filed a notice of completion with the Governor’s Office of Land Use and Climate Innovation on November 25, 2025 to begin a 67-day public review period (Public Resources Code [PRC] Section 21161), which ended on January 31, 2026. The PEIR was made available on the City’s website.1In addition, the PEIR was made available for review at City Hall, located at 30001 Ladyface Court, between the hours of 7:00 AM and 5:00 PM, Monday through Thursday and 7:00 AM and 4:00 PM on Friday. As a result of these notification efforts, the City received two written comments on the content of the PEIR.

After close of the PEIR public review and comment period, a Final EIR consisting of responses to comments and minor revisions to the PEIR was prepared for Planning Commission and City Council.

On May 27, 2026, the City Council, at a public hearing, is expected to decide on the certification of the Final EIR and approval of the Project. The public hearing will be simultaneously held virtually and in person.

The Findings of Fact (Findings) and Statement of Overriding Considerations (SOC) presented herein address the environmental effects associated with the Project that are described and analyzed within the Final EIR, reflect the Council’s determinations about feasible mitigation measures, and the adequacy of the Final EIR. These Findings have been made pursuant to the California Environmental Quality Act (CEQA; California PRC 21000 et seq.), specifically Public Resources Code Sections 21081 and 21081.6, as well as the CEQA Guidelines (14 California Code of Regulations 15000 et seq.) Sections 15091 and 15093.

Public Resources Code Section 21081 and CEQA Guidelines Section 15091 require that the City, as the Lead Agency for this Project, prepare written findings for any identified significant environmental effects along with a brief explanation of the rationale for each finding. Specific findings under CEQA Guidelines Section 15091(a) are:
(1) Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final [P]EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or Project alternatives identified in the Final EIR.

Furthermore, in accordance with Public Resources Code Section 21081 and CEQA Guidelines Section 15093, whenever significant effects cannot be mitigated to below a level of significance, the City as the decision-making agency is required to balance, as applicable, the benefits of the Project against its unavoidable environmental risks when determining whether to approve the Project. If the 1 PEIR for the Project is available here: https://www.agourahillscity.gov/business_detail_T4_R74.php City of Agoura Hills
Agoura Hills Bicycle Master Plan
2 benefits of a Project outweigh the unavoidable adverse environmental effects, the adverse effects may be considered “acceptable,” in which case the lead agency must adopt a formal SOC.

The Final EIR identified potentially significant environmental effects that could result from the Project but could be reduced to a less than significant level through implementation of mitigation measures. Those effects were related to biological resources (impacts to special-status species, nesting birds, riparian habitats and sensitive natural communities, state or federally protected wetlands, and conflicts with local policies or ordinances protecting biological resources), geology and soils (impacts related to paleontological resources), hazards and hazardous materials (impacts related to the routine transport, use, or disposal of hazardous materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment), and noise (impacts related to generation of substantial temporary ambient noise levels and groundbourne vibration during construction ).

Significant and unavoidable impacts associated with cultural resources (impacts related to historical structures and archaeological resources) and recreation (due to construction or expansion of recreational facilities that could cause significant environmental effects) were identified because mitigation measures would not reduce impacts to a less than significant level, and thus a statement of overriding considerations is required.

Project Description
Findings of Fact and Statement of Overriding Considerations 3 2 Project Description
The following is a summary of the full Project description, which can be found in Chapter 2, Project Description, of the EIR.

The proposed Project covers the entirety of the city of Agoura Hills. Refer to Figure 2-1 and Figure 2- 2 in Chapter 2, Project Description, for a map of the Project location. The BMP proposes 30.1 miles of new bikeways and bikeway improvements, including Class I, Class II, Class III, and Class IV facilities, to build upon the city’s existing 1.3 miles of bicycle routes (Class III) and 9.2 miles of bicycle lanes (Class II). The BMP proposes a vision of a diverse network of interconnected bicycle corridors, support facilities, and programs that aim to link local and regional destinations and make biking more practical and desirable for a broader range of people. The City seeks to prioritize implementation of two projects within the BMP: the Medea Creek Path (Path), a two-mile bicycle path along the Medea Creek Channel, and the Agoura High School Connection (Connection), a 0.35- mile bicycle path connecting two intersections adjacent to Agoura High School. The proposed Project also includes the VMT Program, which would establish a mitigation opportunity for projects exceeding the VMT threshold by allowing a developer or project proponent to purchase VMT reduction credits, which would in turn be used to fund the implementation of bicycle improvement projects identified within the BMP. To ensure the city’s General Plan is consistent with the BMP, the Project would also amend the existing General Plan Infrastructure and Community Services Element.

Project Components
Bicycle Master Plan
The purpose of the BMP is to provide safer streets for city residents who are dependent on bicycling for everyday transportation. Recommended actions included within the BMP are meant to support and increase bicycling in the city, to enhance non-motorized travel infrastructure, and to create options to support the existing and future population. The BMP includes an inventory of existing bicycle infrastructure that identifies deficiencies, develops and prioritizes improvements, and provides a recommended path for implementation.

VMT Mitigation Exchange and Banking Program
The Program would establish a new mitigation opportunity for projects exceeding the VMT threshold by allowing a developer or project proponent to purchase VMT reduction credits, which would in turn be used to fund the implementation of bicycle improvement projects identified within the BMP. The exchange concept relies on the applicant of a discretionary project agreeing to implement a predetermined, unfunded, and planned VMT-reducing project or project component.

General Plan Amendments
The City must amend Chapter 3, Infrastructure and Community Services, of the existing City of Agoura Hills General Plan 2035 to ensure consistency with the proposed BMP. The General Plan Amendments primarily shift the focus from prioritizing automobile mobility to reducing VMT through alternative transportation modes like walking and biking, as guided by the BMP.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
4 3 Project Objectives
The objectives for the proposed BMP are as follows:
▪ Increase transportation choices by providing viable alternatives to driving and improved equity to include all bikers, those who choose not to drive and those who cannot drive. ▪ Improve accessibility through local and regional connectivity. Local connections include residential communities, schools, commercial centers, and parks whereas regional connections include the surrounding communities and recreational trail network. ▪ Improve safety by providing separate biking facilities, reducing bicycle collisions, creating greater visibility for bikers, and raising awareness to both bicyclists and road users. ▪ Improve the public health by creating facilities that allow for more biking. ▪ Enhance sustainability and environmental benefits by reducing air pollution, greenhouse gas emissions, and noise pollution.
▪ Enhance community character by constructing bicycle facilities near areas of high scenic value, such as along greenbelts or near surface waters.
▪ Provide a mechanism for developers to mitigate VMT impacts from development projects.

Findings of Fact
Findings of Fact and Statement of Overriding Considerations 5 4 Findings of Fact
Having received, reviewed, and considered the information in the Final Programmatic EIR for this Project, as well as the supporting administrative record, the City of Agoura Hills makes findings pursuant to, and in accordance with, Sections 21081, 21081.5, and 21081.6 of the Public Resources Code.

Environmental Effects Found Not to be Significant
Through Project scoping and the environmental analysis contained within the Final EIR, it was determined that the Project would not result in potentially significant effects on the environment for all CEQA Appendix G checklist questions related to aesthetics, air quality, agriculture and forestry resources, energy, greenhouse gas emissions, hydrology and water quality, land use and planning, population and housing, public services, transportation, tribal cultural resources, utilities and service systems, and wildfire. In addition, it was determined that the Project would not result in potentially significant effects on the environment for CEQA Appendix G checklist questions within the following issue areas:
▪ Biological resources (impacts to wildlife movement and nursery sites, and conflicts with an adopted habitat conservation plan)
▪ Cultural resources (impacts to related to the discovery of human remains) ▪ Geology and soils (impacts related to risk of loss injury or death involving rupture of a known earthquake fault, seismic ground shaking, seismic-related ground failure, or landslides; erosion or loss of top soil, soil stability, expansive soils, and soil capacity to support alternative wastewater disposal systems)
▪ Hazards and hazardous materials (impacts due to projects being located on a Cortese list site, proximity to an airport or airport land use plan, conflicts with an adopted emergency response plan, and wildland fires)
▪ Noise (impacts related to airport noise)
▪ Recreation (impacts related to increased use and deterioration of existing neighborhood and regional parks).

No further findings are required for these subject areas.

Findings for Significant but Mitigated Effects
The following findings are hereby made by the City of Agoura Hills for the significant but mitigable environmental effects identified in the EIR related to biological resources (impacts to special-status species, nesting birds, riparian habitats and sensitive natural communities, state or federally protected wetlands, and conflicts with local policies or ordinances protecting biological resources), geology and soils (impacts to paleontological resources), hazards and hazardous materials (impacts related to the routine transport, use, or disposal of hazardous materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment), and noise (impacts related to generation of substantial temporary ambient noise levels and groundbourne vibration during construction).

City of Agoura Hills
Agoura Hills Bicycle Master Plan
6 4.2.1 Biological Resources – Impact BIO-1
Implementation of the Project, particularly construction of the Medea Creek Path and associated facilities, could adversely impact special-status species, nesting birds, and sensitive biological resources during construction activities. Impacts would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measures BIO-1(a), BIO-1(b), and BIO-1(c) would reduce potential impacts related to special-status species, nesting birds, and sensitive biological resources to a less than significant level.

Explanation
Implementation of Mitigation Measure BIO-1(a) would require that a qualified biologist conduct a pre-construction biological resources assessment to identify sensitive biological resources and develop project-specific avoidance and mitigation procedures, and Mitigation Measure BIO-1(b) would require pre-construction nesting bird surveys and establishment of protective buffers during the nesting season. Mitigation Measure BIO-1(c) would require implementation of construction best management practices to avoid and minimize impacts to biological resources during grounddisturbing activities. With implementation of Mitigation Measures BIO-1(a), BIO-1(b), and BIO-1(c), impacts would be less than significant.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measures have been included in a Mitigation Monitoring and Reporting Program (MMRP) that is to be adopted concurrently with these findings.

BIO-1(a) Pre-Construction Biological Resources Assessment and Reporting Prior to approval of final design for individual projects identified within the BMP that involve ground disturbance and/or vegetation trimming or removal, the City shall retain a qualified biologist to conduct a focused assessment of the environmental limits of the individual project boundary to identify sensitive biological resources that may be impacted by implementation of the project, including special-status plants, animals, and their habitats, as well as sensitive natural communities, regulated waters, and protected trees.

If the biologist identifies protected biological resources that may be affected by implementation of the project, the City shall first prepare alternative designs that seek to avoid and/or minimize impacts to the biological resources. If the project cannot be redesigned without complete avoidance, the City shall retain the qualified biologist to identify the specific impacts to the biological resource (i.e., special-status species, sensitive natural communities, regulated waters, and/or protected trees), identify any state or federal listed species that would necessitate coordination with the appropriate regulatory agency, such as the U.S. Fish and Wildlife Service, California Department of Fish and Wildlife (CDFW), or U.S. Army Corps of Engineers (USACE), to obtain regulatory permits, develop project-specific avoidance and mitigation procedures prior to Findings of Fact
Findings of Fact and Statement of Overriding Considerations 7 initiating construction activities, and implement project-specific avoidance and mitigation measures prior to and during any construction activities.

Mitigation actions that may be required if impacts to sensitive biological resources be identified during implementation of individual projects include:
▪ Pre-construction surveys to identify the presence of special-status species, nesting birds, and roosting bats, within and adjacent to work areas;
▪ Worker Environmental Awareness Program training for all construction personnel; ▪ Complete avoidance of special-status species where and if possible. Avoidance measures may include:
 Delimiting and flagging of special-status species avoidance buffer areas (Environmentally Sensitive Areas),
 Monitoring of construction activity near Environmentally Sensitive Areas, and  Installation of special-status species exclusion fencing; ▪ Relocation of special-status species out of work areas (with applicable permits and authorizations as necessary);
▪ Restoration of temporarily disturbed special-status species’ habitat; and, ▪ Compensatory mitigation for impacts to special-status species habitat at a minimum ratio appropriate for extent and quality of permanently disturbed habitat. Mitigation ratios may vary from 1:1 to 5:1.

BIO-1(b) Pre-Construction Nesting Bird Surveys, Avoidance, and Reporting Future construction activities initiated during the raptor and passerine bird nesting season (January 1 – August 31) involving removal of vegetation or other nesting bird habitat, including abandoned structures and other manmade features, shall be preceded by a pre-construction nesting bird survey conducted no more than one week prior to initiation of ground disturbance and vegetation removal activities. The nesting bird preconstruction survey shall be conducted on foot and shall include up to a 200-foot buffer around the construction site depending on the specific area being surveyed, where publicly accessible. The survey shall be conducted by a qualified biologist familiar with the identification of avian species known to occur in southern California. If nests are found, an avoidance buffer shall be determined by a qualified biologist dependent upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site, which shall be demarcated by the biologist with bright orange construction fencing, flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified as to the existence of the buffer zone and to check with the qualified Biologist before entering the buffer zone during the nesting season. Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the encroachment will not be detrimental to an active nest. No ground or vegetation disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/ nesting is completed, and the young have fledged the nest.

An email summarizing the preconstruction survey(s) shall be prepared by a qualified biologist and shall be submitted to the city prior to the commencement of construction activities.

Individual project plans shall include a statement acknowledging compliance with the Migratory Bird Treaty Act and California Fish and Game Code that includes avoidance of active bird nests and identification of BMPs to avoid impacts to active nests, including checking for nests prior to City of Agoura Hills
Agoura Hills Bicycle Master Plan
8 construction activities during the nesting bird season and what to do if an active nest is found so that the nest is not inadvertently impacted during grading or construction activities.

BIO-1(c) Construction Best Management Practices
The following construction BMPs shall be incorporated into all grading and construction plans for individual projects:
▪ A 20-mile per hour speed limit shall be designated in all construction areas where applicable. ▪ All vehicles and equipment shall be parked on pavement, existing roads, and previously disturbed areas, and clearing of vegetation for vehicle access shall be avoided to the greatest extent feasible.
▪ The number of access routes, number, and size of staging areas, and the total area of the activity shall be limited to the minimum necessary to achieve the goal of the project. ▪ Equipment washout and fueling areas shall be located within the limits of grading at a minimum of 100 feet from waters, wetlands, or other sensitive resources as identified by a qualified biologist to the greatest extent feasible. Washout areas shall be designed to fully contain polluted water and materials for subsequent removal from the site. ▪ Daily construction work schedules shall be limited to daylight hours where adjacent to natural areas capable of supporting wildlife, and shall be consistent with local noise ordinances. ▪ Mufflers shall be used on all construction equipment where work will be conducted within or adjacent to natural areas capable of supporting wildlife, and vehicles shall be in good operating condition.
▪ Drip pans shall be placed under all stationary vehicles and mechanical equipment within 100 feet of a drainage, creek, or stream.
▪ All trash shall be placed in sealed containers and shall be removed from project sites a minimum of once per week.
▪ No pets are permitted on project sites during construction.

4.2.2 Biological Resources – Impact BIO-2
Future construction activities could adversely impact riparian habitat or other sensitive natural communities. Impacts would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measures BIO-1(a) through BIO-1(c) and BIO-2(a) through BIO-2(c) would reduce potential impacts related to riparian habitat and sensitive natural communities to a less than significant level.

Explanation
As described under Section 4.2.1, Biological Resources – Impact BIO-1, above, Mitigation Measures BIO-1(a), BIO-1(b), and BIO-1(c) would ensure identification, avoidance, and protection of sensitive biological resources during construction. Mitigation Measure BIO-2(a) would require avoidance and protection of riparian habitat or sensitive natural communities through design modifications, habitat delineation, and installation of protective measures. Mitigation Measure BIO-2(b) would Findings of Fact
Findings of Fact and Statement of Overriding Considerations 9 require jurisdictional delineation consistent with USACE, CDFW, and Regional Water Quality Control Board methodologies. Mitigation Measure BIO-2(c) would ensure compensatory mitigation to achieve no net loss of habitat functions and values.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measures have been included in a MMRP that is to be adopted concurrently with these findings.

BIO-1(a) Pre-Construction Biological Resources Assessment and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(b) Pre-Construction Nesting Bird Surveys, Avoidance, and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(c) Construction Best Management Practices
Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-2(a) Riparian Habitat and Sensitive Natural Communities Protection If sensitive natural communities, wetlands, or riparian habitats are identified within individual project limits, the City shall design or modify the project to avoid direct and indirect impacts on these habitats, if feasible. At a minimum, the City shall implement the following measures to minimize the loss of riparian vegetation, where feasible. ▪ Protect sensitive habitat areas from harmful exposure to light. If an individual project identified within the BMP is located within or adjacent to sensitive habitat areas or habitat for sensitive species, and lighting is proposed, then the facility will be designed to protect such areas from harmful exposure to light by shielding light sources, redirecting light sources, or using low intensity lighting.
▪ Delineate sensitive habitat areas. Sensitive habitat areas to be avoided, including appropriate buffers (determined by a qualified biologist), will be flagged by a qualified biologist prior to the onset of construction activities. Where indicated by the biologist, these areas will be fenced or otherwise protected from direct and indirect impacts. All such areas to be avoided with be clearly marked on construction plans and designated as “no construction” zones. ▪ Slope stabilization. Where construction will occur on bare soil or on slopes, the contractor shall stabilize exposed soil/slopes immediately upon completion of construction activities. On highly erodible soils/slopes, the contractor shall use a non-vegetative material that binds the soil initially and breaks down within a few years. If more intensive erosion control treatments are needed, geotextile mats, excelsior blankets, or other soil stabilization products shall be used. ▪ Install signage and fencing, vegetation, or other natural barriers to prevent impacts on adjacent areas during operation. Fencing, vegetation, or other natural barriers will be constructed to prevent impacts on sensitive habitat areas adjacent to the Facilities during operation. Signs will be erected in appropriate locations to inform users of the need to stay within designated bike paths, lanes, routes, or boulevards.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
10 BIO-2(b) Jurisdictional Delineation Survey and Report Before approving any individual project involving ground disturbance, the City shall retain a qualified biologist to conduct a site-specific assessment of the individual project area to identify sensitive natural communities, wetlands, or riparian habitats. The field delineation shall include a survey effort within the individual project area. During the field survey, sample points shall be established to document wetland and non-wetland aquatic resources, using the appropriate agencyapproved methodology and data forms. The sample points shall focus on identifying indicators of an OHWM, wetland hydrology, hydric soils, and hydrophytic vegetation. Using this information, a “wetland edge” shall be discerned between the wetland and non-wetland points, and the boundary of the aquatic resources shall be mapped with a sub-meter global position system unit.

The survey shall be conducted in accordance with USACE Wetlands Delineation Manual (1987) and Arid West Regional Supplement to the manual, as well as the latest guidance from the CDFW and Los Angeles Regional Water Quality Control Board. This methodology is the acceptable methodology for delineating the boundaries of federal and state jurisdictions.

A delineation report shall be prepared in accordance with the USACE Los Angeles District’s 2017 Minimum Standards for Acceptance of Aquatic Resources Delineation Reports and shall be used to support necessary permit applications. The report shall include a discussion of methodologies and results that detail the background information; field observations and data collected; and a summary of findings. The report shall contain narrative descriptions of all aquatic features identified, including jurisdictional resources and their boundaries within the Project component’s work area. The report shall quantify lengths and acreages of each aquatic feature, provide highquality figures, site photographs, and completed data forms, and geographic information system data.

The report shall be used to support permitting requirements and shall be submitted to the City for review and approval prior to the issuance of grading permits.

BIO-2(c) Compensatory Mitigation
If sensitive natural communities, state or federally protected wetlands, and/or riparian habitats are disturbed due to implementation of an individual project identified within the BMP, the City shall compensate for the disturbance to ensure no net loss of habitat functions and values.

Compensation ratios shall be based on site-specific information and determined through coordination with state, federal, and/or local agencies as part of the permitting process for the individual project prior to the issuance of a grading permit and/or initiation of construction activities. Unless determined otherwise by the regulatory/permitting agency, the compensation shall be at a minimum ratio of two acres restored, created, and/or preserved for every one acre disturbed (2:1). Compensation may comprise on-site restoration/creation off-site restoration, preservation, or purchase of mitigation credits (or a combination of these elements). If compensatory mitigation involves restoration, the City shall develop and implement a Restoration and Monitoring Plan that describes how the habitat shall be created and monitored over a minimum period of time. In broad terms, the Restoration and Monitoring Plan shall at a minimum include:
▪ Description of the project/impact and mitigation sites ▪ Information related to riparian habitat impacts
▪ Specific objectives
▪ Success criteria
Findings of Fact
Findings of Fact and Statement of Overriding Considerations 11 ▪ Plant palettes for each vegetation community
▪ Implementation plan
▪ Maintenance activities
▪ Monitoring plan
▪ Contingency measures
The plant palette shall include a diversity of appropriate native species that occur in the communities in the surrounding area. The performance standards for the Restoration and Monitoring Plan shall be, at a minimum, the following:
▪ Within five years after introducing the native plants to the mitigation site, the acreage of restored native grassland habitat shall be no less than two times the acreage lost to Project construction.
▪ Within five years after introducing the native plants to the mitigation site, the absolute cover of the target species and other native species shall be no less than 50 percent within the restoration area.
▪ Restoration will be considered successful after the success criteria have been met for a period of at least 2 years without any maintenance or remediation activities other than invasive species control.

The restoration project shall be initiated prior to development of the individual project and shall be implemented at most over a five-year period, unless success criteria is met sooner. The restoration project shall incorporate an iterative process of annual monitoring and evaluation of progress, and allow for adjustments to the restoration plan, as necessary, to achieve desired outcomes and meet success criteria. Annual reports discussing the implementation, monitoring, and management of the restoration Project shall be submitted to the City. Five years after start of the restoration project, a final report shall be submitted to the City, which shall at a minimum discuss the implementation, monitoring, and management of the restoration project over the five-year period and indicate whether the restoration project has been successful based on established success criteria. The annual reports and the final report shall include as-built plans submitted as an appendix to the report.

4.2.3 Biological Resources – Impact BIO-3
Future construction activities could adversely impact state or federally protected wetlands defined by Section 404 of the Clean Water Act. Impacts would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure BIO-1(a), BIO-1(c), and BIO2(a) through BIO-2(c) would reduce potential impacts related to wetlands to a less than significant level.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
12 Explanation
As described under Section 4.2.1, Biological Resources – Impact BIO-1, above, Mitigation Measure BIO-1(a) would ensure early identification of sensitive biological resources, such as wetland resources, and development of avoidance and minimization procedures, and Mitigation Measure BIO-1(c) would require BMPs to minimize ground disturbance and prevent indirect impacts. As described under Section 4.2.2, Biological Resources – Impact BIO-2, above, Mitigation Measures BIO-2(a), BIO-2(b), and BIO-2(c) would require avoidance where feasible, delineation of jurisdictional waters, and compensatory mitigation consistent with agency requirements.

Implementation of these measures would reduce impacts to less than significant.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measures have been included in a MMRP that is to be adopted concurrently with these findings.

BIO-1(a) Pre-Construction Biological Resources Assessment and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(c) Construction Best Management Practices
Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-2(a) Riparian Habitat and Sensitive Natural Communities Protection Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(b) Jurisdictional Delineation Survey and Report
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(c) Compensatory Mitigation
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

4.2.4 Biological Resources – Impact BIO-5
Future construction activities could conflict with local policies protecting biological resources. This impact would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measures BIO-1(a), BIO-1(c), BIO-2(a) through BIO-2(c), and BIO-5(a) would reduce potential impacts related to special-status species to a less than significant level.

Explanation
Mitigation Measures BIO-1(a) and BIO-1(c) require pre-construction biological assessment and BMPs that ensure compliance with applicable biological resource standards. Mitigation Measures BIO-2(a), BIO-2(b), and BIO-2(c) require avoidance, delineation, and compensatory mitigation for sensitive Findings of Fact
Findings of Fact and Statement of Overriding Considerations 13 natural communities. Mitigation Measure BIO-5(a) mandates protection and replacement of protected trees consistent with the City’s Oak Tree Preservation Guidelines and Ordinance. With implementation of these measures, impacts would be less than significant.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measures have been included in a MMRP that is to be adopted concurrently with these findings.

BIO-1(a) Pre-Construction Biological Resources Assessment and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(c) Construction Best Management Practices
Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-2(a) Riparian Habitat and Sensitive Natural Communities Protection Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(b) Jurisdictional Delineation Survey and Report
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(c) Compensatory Mitigation
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-5(a) Tree Protection
The City shall procure all necessary tree removal permits prior to impacting a protected oak tree. A tree protection and replacement plan shall be developed by a certified arborist for any protected oak tree(s) or other naturally occurring native tree that has a trunk diameter (at 4.5 feet above grade; diameter at breast height [DBH]) that will be affected by implementation of an individual project identified within the BMP. The tree protection and replacement plan shall include, but would not be limited to, an inventory of protected oak trees and naturally occurring native trees with a DBH of four inches or more within the individual construction site, setbacks from trees and protective fencing, restrictions regarding grading and paving near trees, direction regarding pruning and digging within the root zone of trees, and requirements for replacement and maintenance of trees. If protected oak trees or other naturally occurring native trees with a DBH of four inches or more will be removed, replacement tree plantings of like species in accordance with the city standards, but at a minimum ratio of 4:1 (trees planted to trees impacted) for protected oak trees in accordance with the City of Agoura Hills Oak Tree Preservation Guidelines and Oak Tree Ordinance (Municipal Code Article IX, Chapter 6, Part 2., Division 7) and a minimum ratio of 1:1 replacement for other naturally occurring native trees with a DBH of four inches or more, and shall be installed on-site or at an approved off-site location and a restoration and monitoring program shall be developed and implemented for a minimum of seven years.

If the protective zone (as defined per the Agoura Hills Oak Tree Preservation Guidelines) of a protected oak tree is disturbed by more than 30 percent, the tree shall be retained and mitigated at a ratio of 4:1 as described above, because long-term impacts that may lead to decline or mortality may not be visible for several years. Any protected oak tree that will be encroached within its City of Agoura Hills
Agoura Hills Bicycle Master Plan
14 protective zone during construction shall have a certified arborist present to oversee the work activities. Any trimming of roots and branches shall be performed or directly supervised by a certified arborist and shall be done in accordance with the American National Standards Institute A300 Tree Care standards.

4.2.5 Geology and Soils – Impact GEO-9
Ground disturbance during construction activities could encounter geologic units with high or undetermined paleontological sensitivity. Impacts to paleontological resources would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure GEO-9 would reduce potential impacts related to paleontological resources to a less than significant level.

Explanation
Implementation of Mitigation Measure GEO-9 would require preparation of a Paleontological Resources Assessment by a qualified paleontologist prior to approval of final design for individual projects involving ground disturbance. The assessment would include a records search, review of geologic mapping, evaluation of paleontological sensitivity, and recommendations for avoiding or minimizing impacts to paleontological resources to less than significant.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measure has been included in a MMRP that is to be adopted concurrently with these findings.

GEO-9 Paleontological Resources Assessment
Prior to approval of final design for individual projects identified within the BMP that involve ground disturbance, the City shall require preparation of a Paleontological Resources Assessment. This assessment may be prepared as a standalone report or incorporated into a larger environmental review document. The Paleontological Resources Assessment shall be prepared by an individual meeting the standards of a Qualified Professional Paleontologist as defined by the Society of Vertebrate Paleontology. The assessment shall summarize the results of a records search of the Natural History Museum of Los Angeles County, summarize the results of a desktop review of available literature and geologic maps of the individual project site, characterize the paleontological sensitivity of the geologic unit(s) present within the project site using the Society of Vertebrate Paleontology paleontological sensitivity scale, assess the potential for significant impacts to paleontological resources, and provide mitigation recommendations for avoiding or reducing impacts to paleontological resources from project construction, if necessary.

4.2.6 Hazards and Hazardous Materials – Impact HAZ-1
Construction of the Project has the potential to create a significant hazard to the public or the environment through the routine transport, use, and disposal of hazardous materials, as well as through reasonably foreseeable upset and accident conditions involving the release of hazardous Findings of Fact
Findings of Fact and Statement of Overriding Considerations 15 materials into the environment. Impacts would be less than significant through adherence to existing regulations and with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure HAZ-1 would reduce potential impacts related to hazardous materials risks to a less than significant level.

Explanation
Mitigation Measure HAZ-1 would reduce potential impacts to a less than significant level by requiring the preparation of a Soil Management Plan for projects located within 1,000 feet of known hazardous release sites, which would establish procedures for handling unanticipated contaminated soils, identify actions to minimize hazards to construction workers and off-site receptors, and ensure compliance with applicable hazardous materials regulations.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measure has been included in a MMRP that is to be adopted concurrently with these findings.

HAZ-1 Soil Management Plan
Prior to commencement of ground-disturbing activities for proposed facilities within 1,000 feet of a known hazardous release site, the City shall retain a qualified consultant (i.e., professional geologist or professional engineer) to prepare a Soil Management Plan (SMP) for the project. The SMP shall address:

1. On-site handling and management of unanticipated contaminated soils or other contaminated wastes (e.g., stained soil, soil with solvent or chemical odors) if encountered during ground disturbance, and

2. Specific actions to reduce hazards to construction workers and off-site receptors during construction (e.g., personal protective equipment, dust control, and/or air monitoring).

The SMP must establish remedial measures and soil management practices to ensure construction worker safety and prevent the off-site migration of contaminants from the project site. These measures and practices may include, but are not limited to:
▪ Proper transportation and disposal procedures for contaminated materials in accordance with applicable regulations, including California Code of Regulations Title 22. ▪ A requirement to halt work in the immediate area and contact a qualified consultant (i.e., professional geologist or professional engineer) immediately to evaluate the project site conditions if odorous or visually stained soils, other indications of piping or equipment (including hydrocarbon piping or equipment), or debris are encountered during grounddisturbing activities. ▪ A health and safety plan for contractors working at the project site that addresses the safety and health hazards of each phase of project construction activities with the requirements and procedures for employee protection and outlines proper soil handling procedures and health City of Agoura Hills
Agoura Hills Bicycle Master Plan
16 and safety requirements to minimize worker and public exposure to hazardous materials during construction.
▪ Reporting on monitoring activities.

4.2.7 Hazards and Hazardous Materials – Impact HAZ-2
Construction of the Project would involve handling hazardous materials within one-quarter mile of a school. Impacts would be less than significant through adherence to existing regulations and with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure HAZ-1 would reduce potential impacts related to the handling of hazardous materials within one-quarter mile of a school to a less than significant level.

Explanation
Mitigation Measure HAZ-1 would reduce potential impacts to a less than significant level by requiring the preparation of a SMP that outlines procedures for the safe handling, storage, and disposal of contaminated soils or hazardous materials, as well as measures to protect workers and off-site sensitive receptors, including schools. Compliance with existing hazardous materials regulations, combined with implementation of the SMP when required, would ensure that construction activities do not create significant hazards near schools.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measure has been included in an MMRP that is to be adopted concurrently with these findings.

HAZ-1 Soil Management Plan
Refer to Section 4.2.6, Hazards and Hazardous Materials – Impact HAZ-1, above.

4.2.8 Noise – Impact NOI-1
Construction of individual bicycle facilities identified in the BMP would temporarily produce high noise levels, potentially impacting nearby noise-sensitive land uses. Impacts would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure NOI-1 would reduce Findings of Fact
Findings of Fact and Statement of Overriding Considerations 17 potential impacts related to substantial temporary increases in noise levels to a less than significant level.

Explanation
Implementation of Mitigation Measure N-1 would reduce impacts to a less than significant level by requiring standard construction noise-reduction practices, including properly muffling equipment, prohibiting unnecessary idling, siting stationary equipment away from sensitive land uses, notifying adjacent receptors of construction schedules, and implementing enhanced communication through a designated noise disturbance coordinator.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measure has been included in a MMRP that is to be adopted concurrently with these findings.

N-1 Construction Noise Reduction Measures
The following construction noise reduction measures shall be included as standard conditions of approval for projects involving construction within 125 feet of a sensitive receptor:
▪ Properly muffle and maintain all construction equipment powered by internal combustion engines;
▪ Prohibit unnecessary idling of combustion engines;
▪ Locate all stationary noise-generating construction equipment (such as air compressors) as far as practical from existing nearby residences and other noise-sensitive land uses; ▪ Select quiet construction equipment, particularly air compressors, whenever possible; ▪ Fit motorized equipment with proper mufflers in good working order; ▪ Residences, schools, libraries, hospitals, or other medical care facilities adjacent to individual project sites shall be notified, in advance and by writing, of the proposed construction schedule before construction activities commence, including details for the noise disturbance coordinator; and,
▪ Construction of each individual project identified within the BMP shall have a designated “noise disturbance coordinator” responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of noise complaints and shall require that reasonable measures be implemented to correct the problem. A telephone number for the disturbance coordinator shall be posted at the construction site.

4.2.9 Noise – Impact NOI-2
Construction of individual bicycle facilities identified in BMP would temporarily generate groundborne vibration, potentially affecting adjacent sensitive land uses. Impacts would be less than significant with mitigation.

Finding
Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Final EIR (CEQA Guidelines Section 15091[a][1]). Implementation of Mitigation Measure N-2 would reduce potential impacts related to groundborne vibration to a less than significant level.

City of Agoura Hills
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18 Explanation
Implementation of Mitigation Measure N-2 would reduce impacts related to excessive groundborne vibration to a less than significant level by requiring paving activities occurring within 37-feet of offsite structures to use a static roller rather than a vibratory roller.

Mitigation Measures
Pursuant to CEQA Guidelines Section 15091, the following mitigation measure has been included in a MMRP that is to be adopted concurrently with these findings.

N-2 Construction Vibration Control Plan
Prior to the issuance of any Grading Permit, the Public Works Department shall verify that the Project plans and specifications include provisions that require that paving activities within 37 feet of off-site structures utilize a static roller in lieu of a vibratory roller.

Findings for Significant and Unavoidable Effects
Public Resources Code 21081 and 21081.5, and CEQA Guidelines Section 15093, require that the City of Agoura Hills balance the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental effects when determining to approve a project. If specific economic, legal, social, technological, or other benefits outweigh the unavoidable adverse environmental effects, the adverse effects may be considered “acceptable.” The Final EIR identifies the following significant and unavoidable impacts that would be caused by implementation of the Project: impacts associated with cultural resources (impacts to historical and archaeological resources), and recreational facilities (impacts related to the construction or expansion of recreational facilities that could adversely affect the environment). The following findings and statement of overriding considerations outline the specific reasons to support the City of Agoura Hills Public Works Department recommendation for approval.

4.3.1 Cultural Resources – Impact CUL-1
Development facilitated by the Project has the potential to result in significant impacts if development carried out under the Project would cause a substantial adverse change in the significance of a historical resource. This impact would be significant and unavoidable.

Mitigation Measures
CUL-1 Prepare Historical Resources Evaluation Prior to Approval of Project Involving Structures 45 Years or Older and Implement Mitigation Prior to and During Construction
Prior to approval of individual Class I facilities, Class II facilities, Class IV facilities, and enhanced bicycle treatments that include construction activities which could result in direct/indirect impacts to historical resources, including those that could result in direct impacts to structures/objects and/or indirect impact to buildings 45 years or older, the City shall retain a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards (SOI PQS) in architectural history and/or history as defined in Code of Federal Regulations (CFR) Title 36, Part 61 to oversee the following steps:

Findings of Fact
Findings of Fact and Statement of Overriding Considerations 19 ▪ Prior to proceeding with the historical resources evaluation (HRE) described below, a qualified architectural historian or historian(who meets the SOI PQS in architectural history and/or history as defined in CFR Title 36, Part 61) shall conduct a review of the applicable registers of previously documented built environment resources qualifying as historical resources to determine the presence of such resources within or immediately adjacent to a Class I, II, or IV project footprint or enhanced bicycle facility, and to confirm its condition is consistent with that presented in associated designation documentation. This effort, which may include a field survey, shall be documented in a report (that may be combined with the report described in the third bullet below as necessary and appropriate) that shall be submitted to the City for review and approval prior to initiation of a project component. ▪ Based on guidance provided by the California Office of Historic Preservation (OHP), not all built environment resources merit recordation. Therefore, the professional judgement of an architectural historian (that meets the SOI PQS in architectural history or history as defined in Code of Federal Regulations, Title 36, Part 61) shall be relied upon to determine if built environment resources with potential significance requiring recordation are present within a given project component site or its immediate surroundings. If a project component site or property in its immediate surroundings includes a building, structure, or other built environment feature that is 45 years of age or older that merits recordation and has the potential to be significantly impacted by the project, the City shall prepare a HRE for the property containing said building, structure, or other built environment feature. The evaluation shall consider the eligibility of the resource for listing in the National Register of Historic Places and California Register of Historical Resources, in addition to any applicable local register of historical resources.
▪ The HRE shall be prepared by a SOI PQS architectural historian or historian. The HRE shall include an intensive-level evaluation prepared in accordance with the guidelines and best practices promulgated by the California OHP. The building, structure or other built environment feature shall be evaluated within an appropriate historic context and documented in a report that meets the California OHP guidelines. All evaluated resources shall be documented on California Department of Parks and Recreation Series 523 Forms in accordance with the guidance included in the OHP’s Instruction for Recording Historical Resources. The report with attached California Department of Parks and Recreation Series 523 Forms shall be submitted to the City for review and approval prior to proceeding with construction of the project component.
▪ If built environment resources qualifying as historical resources having the potential to be significantly impacted by a proposed project component are identified within a proposed project component site or its immediate surroundings, efforts shall be made to ensure that impacts are mitigated. In such instances, the above-noted HRE report shall be amended or supplemented with a report that identifies the resource’s character-defining features and recommends treatment methods for character-defining features. The report shall demonstrate how the proposed project component complies with the Secretary of the Interior’s Standards for the Treatment of Historic Properties (SOI Standards) and avoids impacts to historical resources pursuant to CEQA. The report shall be submitted to the City for review and approval prior to proceeding with construction the project.
▪ If built environment historical resources are identified and compliance with the SOI Standards is not possible, appropriate site-specific mitigation measures that reduce impacts to historical resources to the greatest extent feasible shall be established and undertaken. Mitigation measures may include, but would not be limited to, documentation of the historical resource in City of Agoura Hills
Agoura Hills Bicycle Master Plan
20 the form of a Historic American Building Survey or Historic American Engineering Record report that complies with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation, or development of an interpretative display or educational opportunity that relates the history and significance of the resource to the public.

Finding and Rationale
Implementation of Mitigation Measure CUL-1 would ensure proper identification, documentation, and, where feasible, avoidance of historical resources. The measure requires evaluation of built environment resources by qualified professionals, preparation of historical resources evaluations in accordance with state and federal standards, and the development of treatment measures to avoid or minimize impacts. However, even with full implementation of Mitigation Measure CUL-1, it may not be feasible in all cases to avoid substantial adverse changes to historical resources or to fully reduce impacts to below the level of significance. Therefore, the Project’s impacts to historical resources would remain significant and unavoidable.

4.3.2 Cultural Resources – Impact CUL-2
The proposed Project has the potential to result in significant impacts if development carried out under the Project would cause a substantial adverse change in the significance of an archaeological resource. This impact would be significant and unavoidable.

Mitigation Measures
CUL-2 Prepare Archaeological Resources Assessment Prior to and During Construction
Prior to approval of individual Class I facilities, Class II facilities, Class IV facilities, and enhanced bicycle treatments that involve ground disturbing activities, the City shall retain an archaeologist that meets the SOI PQS in either prehistoric or historic archaeology (qualified archaeologist as defined in CFR, Title 36, Part 61) to oversee the preparation of an archaeological resources assessment).
▪ Archaeological Resources Assessments shall include a California Historical Resources Information System (CHRIS) records search at the South Central Coastal Information Center with a minimum 0.5-mile radius and a Sacred Lands File search through the California Native American Heritage Commission. The records searches will characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around a Class I facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments. A Phase I pedestrian survey shall be undertaken at Class I facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments to locate any surface evidence of cultural materials. A geoarchaeological review (examination of CHRIS and ethnographic data, historical, geological, and soil maps, aerial imagery, geotechnical reports) shall be conducted to assess the potential for the project to encounter unknown archaeological resources during construction. A qualified archaeologist shall identify known archaeological resources and classify the Class I facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments as having high, medium, or low sensitivity for unknown archaeological resources. The assessment shall also include recommendations for additional studies and/or mitigation, as necessary, such as monitoring during construction-related ground disturbance. Construction monitoring shall be Findings of Fact
Findings of Fact and Statement of Overriding Considerations 21 recommended when archaeological resources are present and/or the assessment identifies a moderate or high likelihood of archaeological resources being present. ▪ If the CHRIS search or Phase I archaeological survey identifies resources that may be impacted by Class I facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments, the archaeological resources assessment shall also include Phase II testing and evaluation. If resources are determined significant (i.e., eligible for the California Register of Historical Resources [CRHR] and/or National Register of Historic Places [NRHP]) or unique the City shall first consider whether avoidance and preservation in place is feasible. If resource avoidance and preservation in place is not feasible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation. ▪ For archaeological resources found eligible under CRHR Criterion 4/NRHP Criterion D (data potential) that cannot be avoided and will be impacted by Class I facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments, mitigation shall include, but would not be limited to, a Phase III data recovery program. The data recovery program shall make provisions for adequately recovering the scientifically consequential information from and about the resource. The qualified archaeologist and City shall consult with appropriate Native American representatives regarding the data recovery program in determining treatment for prehistoric or Native American resources to ensure cultural values ascribed to the resource, beyond those that are scientifically important, are considered. For archaeological resources that are found eligible under CRHR Criteria1/NRHP Criteria A (events), 2/B (persons), and/or 3/C (design/craftsmanship) that cannot be avoided and will be impacted by ClassI facilities, Class II facilities involving road widening, Class IV facilities, or enhanced bicycle treatments, other appropriate mitigation shall be determined by a qualified archaeologist in consultation with the City and, if the resource is of indigenous origin, local interested Tribes. Mitigation may include but would not be limited to development of interpretive or educational materials or preservation of all or portions of the archaeological site. ▪ Final disposition of any recovered artifacts or samples, which could include but would not be limited to curation or onsite reburial ,shall occur as specified by the qualified archaeologist in consultation with the City and, if the resource is of indigenous origin, local interested Tribes.

Artifacts and samples include material recovered from all phases of work, including the Phase I survey, Phase II testing, Phase III data recovery, and construction monitoring.

Finding and Rationale
Implementation of Mitigation Measure CUL-2 would ensure proper records searches, surveys, professional evaluations, and, where feasible, avoidance or data recovery for archaeological resources, including consultation with appropriate Native American representatives for prehistoric or Native American resources. However, even with full implementation of Mitigation Measure CUL-2, it may not be feasible in all cases to avoid substantial adverse changes to archaeological resources or to fully reduce impacts to below the level of significance. Therefore, the Project’s impact related to archaeological resources would remain significant and unavoidable.

4.3.3 Recreation – Impact REC-2
Implementation of the proposed Project would result in the construction or expansion of recreational facilities that could adversely affect the environment. Those impacts are identified throughout the Programmatic Environmental Impact Report. This impact would be significant and unavoidable.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
22 Mitigation Measures
BIO-1(a) Pre-Construction Biological Resources Assessment and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(b) Pre-Construction Nesting Bird Surveys, Avoidance, and Reporting Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-1(c) Construction Best Management Practices
Refer to Section 4.2.1, Biological Resources – Impact BIO-1, above.

BIO-2(a) Riparian Habitat and Sensitive Natural Communities Protection Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(b) Jurisdictional Delineation Survey and Report
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-2(c) Compensatory Mitigation
Refer to Section 4.2.2, Biological Resources – Impact BIO-2, above.

BIO-5(a) Tree Protection
Refer to Section 4.2.4, Biological Resources – Impact BIO-5, above.

CUL-1 Prepare Historical Resources Evaluation Prior to Approval of Project Involving Structures 45 Years or Older and Implement Mitigation Prior to and During Construction
Refer to Section 4.3.1, Cultural Resources – Impact CUL-1, above.

CUL-2 Prepare Archaeological Resources Assessment Prior to and During Construction
Refer to Section 4.3.2, Cultural Resources – Impact CUL-2, above.

GEO-9 Paleontological Resources Assessment
Refer to Section 4.2.5, Geology and Soils – Impact GEO-9, above.

HAZ-1 Soil Management Plan
Refer to Section 4.2.6, Hazards and Hazardous Materials – Impact HAZ-1, above.

N-1 Construction Noise Reduction Measures
Refer to Section 4.2.8, Noise – Impact NOI-1, above.

N-2 Construction Vibration Control Plan
Refer to Section 4.2.9, Noise – Impact NOI-2, above.

Findings of Fact
Findings of Fact and Statement of Overriding Considerations 23 Finding and Rationale
Implementation of Mitigation Measures BIO-1(a) through N-2 would reduce or avoid individual environmental impacts associated with the construction or expansion of recreational facilities, including impacts related to biological resources, cultural resources, hazardous materials, paleontological resources, noise, and vibration. However, as identified in the Final EIR, even with all feasible mitigation incorporated, construction or expansion of recreational facilities facilitated by the Project could still result in impacts to cultural resources which would remain significant and unavoidable. Therefore, although other impacts would be reduced to less than significant levels with mitigation, the Project’s impact related to REC-2 remains significant and unavoidable.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
24 5 Project Alternatives
Section 15126.6 of the CEQA Guidelines states the following:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.

Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

As described in Section 4.3, Findings for Significant and Unavoidable Effects, above, the City of Agoura Hills has determined that, even after the adoption of all feasible mitigation measures, the Project would still cause one or more significant environmental impacts that cannot be avoided or lessened to below a level of significance. Therefore, the City of Agoura Hills must determine if there is a Project alternative that is both environmentally superior and feasible. An alternative may be “infeasible” if it fails to achieve the most basic Project objectives identified within the EIR. Further, “feasibility” under CEQA encompasses the desirability of the Project “based on a reasonable balancing of the relevant economic, environmental, social, and technological factors” of a project (City of Del Mar v. City of San Diego [1982], 133 Cal.App.3d at p. 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland [1993], 23 Cal.App.4th at p. 715).

The Final EIR identifies the following significant and unavoidable impacts that would be caused by implementation of the Project: impacts associated with cultural resources (impacts to historical and archaeological resources), and recreational facilities (impacts related to the construction or expansion of recreational facilities that could adversely affect the environment). The alternatives analyzed in the Final EIR and described below are therefore discussed below in terms of their potential ability to avoid or reduce these impacts.

Alternative 1: No Project Alternative
The No Project Alternative is a scenario in which the BMP, including the Path and Connection, would not be implemented, the Program would not be established, and Amendments would not be adopted. As a result, no construction activities related to bicycle infrastructure would occur, and the city’s existing network of 1.3 miles of bicycle routes and 9.2 miles of bicycle lanes would remain unchanged. The General Plan would continue to prioritize auto mobility rather than reducing VMT.

As such, the No Project Alternative would not fulfill any Project Objectives, as the No Project Alternative would not improve transportation choices, accessibility, bicycle safety, public health, sustainability, or community character through the construction of bicycle facilities near areas of high scenic value, or the provision of a mechanism for developers to mitigate VMT impacts from development projects.

Project Alternatives
Findings of Fact and Statement of Overriding Considerations 25 Finding
The No Project Alternative would avoid the proposed Project’s significant and unavoidable impacts to cultural resources (Impacts CUL-1 and CUL-2) and recreation (Impact REC-2) because no construction activities would occur. For all other environmental topics analyzed, including aesthetics, air quality, biological resources, geology and soils, geology and soils (including paleontological resources), hazards and hazardous materials, hydrology and water quality, land use and planning, noise, transportation, and tribal cultural resources, the No Project Alternative would result in no impact or reduced impacts relative to the proposed Project, as no bicycle facilities would be constructed and no ground disturbance would occur.

The No Project Alternative would not accomplish any objectives of the Project, including increasing transportation choices, improving local and regional bike connectivity and safety, improving public health, enhancing sustainability and community character, and providing a mechanism to mitigate VMT impacts through the proposed VMT Mitigation Exchange and Banking Program. It would also forgo the proposed General Plan Amendments intended to shift the City’s focus from auto mobility to VMT reduction through expanded active transportation. Accordingly, the City rejects the No Project Alternative as infeasible because it would not achieve the Project objectives, even though it would reduce or avoid the proposed Project’s significant and unavoidable impacts.

The findings for the proposed Project set forth in this document and the overriding social, economic and other considerations set forth in the Statement of Overriding Considerations (Refer to Section 6, Statement of Overriding Considerations) provide support for selection of the proposed Project and the elimination of this alternative from further consideration.

Alternative 2: Project Minus Medea Creek Path and
Agoura High School Connection
Alternative 2 would implement the BMP, Program, and Amendments of the proposed Project.

However, the BMP implemented under Alternative 2 would remove the Path and the Connection from the list of bicycle facilities. All Class II, Class III, and Class IV facilities, and enhanced bicycle treatments would be included within the BMP under Alternative 2. The Program would be revised to only fund individual projects identified under this alternative, excluding the Path and Connection.

The Amendments would also be revised to exclude the Path and Connection from the City’s planned additions to its system of bikeways but would still shift the focus of Chapter 3 of the General Plan to prioritize VMT reduction through improved active transportation modes like walking and biking.

Under Alternative 2, approximately 29 miles of bicycle facilities would be implemented. Alternative 2 would fulfill the Project Objectives, but to a lesser extent given the reduced miles of bicycle facilities implemented and improved under this Alternative. Additionally, Alternative 2 would not fulfill the Project Objective that aims to enhance community character by constructing bicycle facilities near areas of high scenic value.

Finding
Alternative 2 would partially achieve the Project objectives, as it removes two priority facilities and therefore provides fewer miles of bicycled improvements and would result in diminished connectivity, access, and scenic-value improvements compared to the proposed Project, as well as implement fewer opportunities to fund improvements through the VMT Mitigation Exchange and Banking Program. Due to the reduced construction footprint associated with the exclusion of the City of Agoura Hills
Agoura Hills Bicycle Master Plan
26 Media Creek Path and Agoura High School Connection, Alternative 2 would reduce the severity of several construction-related impacts compared to the proposed Project, including to aesthetics, air quality, biological resources, geology and soils, hazards and hazardous materials, hydrology and water quality, noise, and transportation. Impacts to these resources would be reduced compared to the proposed Project, though not to the extent of a reduced significance level, as these impacts would remain less than significant or less than significant with mitigation under Alternative 2.

Even with the reduced footprint, Alternative 2 would not avoid significant and unavoidable impacts to cultural resources (Impacts CUL-1 and CUL-2), as ground-disturbing work would still occur in previously undisturbed areas where historical and archaeological resources could be affected despite implementation of Mitigation Measures CUL-1 and CUL-2. Accordingly, Impact REC-2 would also remain significant and unavoidable under Alternative 2, as Alternative 2 would still involve the development or expansion of recreational facilities which would result in significant impacts to cultural resources.

Although Alternative 2 would decrease environmental impacts associated with the proposed Project, Alternative 2 is less desirable than the proposed Project, as it would only partially fulfill the Project objectives. Therefore, the City rejects Alternative 2 as undesirable as it fulfills Project objectives to a lesser extent compared to the proposed Project.

Alternative 3: Only Class II and Class III Facilities
Alternative 3 would involve implementation of the BMP, Program, and Amendments; however, the BMP would only include Class II and Class III facilities. All Class I facilities, including the Path and Connection, and Class IV facilities would be removed from the BMP, while all Class II and Class III facilities would be included in the BMP under Alternative 3. The Program would be revised to reflect the ability to purchase VMT reduction credits only for the funding of individual projects identified within the BMP under this alternative, which would exclude Class I facilities, including the Path, Connection, and Class IV facilities . The Amendments would also be revised but would still shift the focus of Chapter 3 of the General Plan to prioritize VMT reduction through active transportation modes like walking and biking. Under Alternative 3, approximately 25.6 miles of bicycle facilities would be implemented. Similar to Alternative 2, Alternative 3 would fulfill Project Objectives, though to a lesser extent given the reduced miles of bicycle facilities implemented and improved, and the Project Objective that aims to enhance community character would not be fulfilled.

Finding
Alternative 3 would not avoid the proposed Project’s significant and unavoidable impact related to cultural resources, since ground disturbance could still affect historical and archaeological resources. Accordingly, Impact REC-2 would also remain significant and unavoidable under Alternative 3, as Alternative 3 would still involve the development or expansion of recreational facilities which would result in significant impacts to cultural resources. However, Alternative 3 omits proposed Class I and Class IV facilities, resulting in the smallest construction footprint of the build alternatives. Therefore, the potential for significant and unavoidable impacts would be reduced compared to the proposed Project due to less construction in previously undisturbed areas.

Project Alternatives
Findings of Fact and Statement of Overriding Considerations 27 Due to its reduced footprint relative to the proposed Project, Alternative 3 would further reduce the severity of most construction-related impacts, including those related to aesthetics, air quality, biological resources, geology and soils, hazards and hazardous materials, hydrology and water quality, noise, and transportation, all of which would remain less than significant or less than significant with mitigation.

Although Alternative 3 would reduce all construction-related impacts, it would not meet the Project objectives to the same extent as the proposed Project, given the exclusion of all Class I and Class IV facilities and the correspondingly reduced network, connectivity, safety improvements for cyclists, and opportunities to enhance community character near areas of high scenic value. It would also limit the scope of projects that can be funded via the VMT Mitigation Exchange and Banking Program. Accordingly, although identified as the environmentally superior alternative, the City rejects Alternative 3 as undesirable because it would not achieve Project objectives to the same extent as the proposed Project.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
28 6 Statement of Overriding Considerations
As described in the Final Programmatic EIR for the Agoura Hills BMP, the EIR finds that all potential impacts from adoption of the Project and from physical changes that could potentially occur due to adoption of the Project can be feasibly mitigated to a level that is less than significant, with the following exceptions: Impact CUL-1, substantial adverse change in the significance of a historical resource; Impact CUL-2, substantial adverse change in the significance of an archaeological resource; and Impact REC-2, construction or expansion of recreational facilities that could adversely affect the environment.

In accordance with CEQA Guidelines Section 15093, the City Council has, in determining whether to approve the Project, balanced the economic, legal, social, technological, and other benefits of the Project against the potentially unavoidable environmental impacts, and has found that the benefits of the Project outweigh the potentially unavoidable environmental effects, for the reasons set forth below. The following statements specify the reasons why, in the City Council’s judgement, the benefits of the Project outweigh any of the significant and unavoidable consequences described in the EIR. The City Council also finds that any one of the following reasons cited below is sufficient to justify approval of the Project. Thus, even if it were to be determined that not every reason cited below is supported by substantial evidence, the City Council determines that each individual reason is sufficient justification of approval of the Project. The substantial evidence supporting the City Council’s findings and the benefits described below can be found in the record of proceedings. ▪ The adoption of the Project would facilitate the development of approximately 30.1 miles of new bikeways and bikeway improvements (Class I-Class IV), providing a linked system of corridors that would make bicycling more practical and desirable for a broad range of users with differences in mobility capabilities, which would directly increase local and regional connectivity to neighborhoods, schools, parks, and commercial destinations. ▪ The adoption of the Project would improve safety for pedestrians and bicyclists by expanding and enhancing separated and designated facilities for active transportation with treatments such as signage and bicycle signals, which would reduce conflicts, increase visibility, and lower collision risk for vulnerable roadway users across Agoura Hills. ▪ The adoption of the Project would enhance public health and community well-being by encouraging physical activity and expanding equitable access to low-cost, non-motorized mobility, which would improve opportunities for daily exercise and reduce barriers for residents who rely on active transportation for essential trips.
▪ The adoption of the Project would be consistent with regional plans and guidance such as Connect SoCal 2024 objectives to reduce transportation emissions and expand active transportation, as the Project would integrate with the region’s multimodal network and programming.
▪ The adoption of the Project would involve scenic and community character benefits by constructing bicycle facilities near areas of high scenic value, thereby reinforcing community character and recreational access by enhancing viewing opportunities and access to open space.

The adoption of the Project would fulfill City objectives to increase transportation choices, improve accessibility and safety, enhance sustainability and public health, improve community character, Statement of Overriding Considerations
Findings of Fact and Statement of Overriding Considerations 29 and provide a mechanism for VMT mitigation, whereas alternatives would either forgo achievement of such goals or fulfill them to a substantially lesser extent.

Any one of these reasons is sufficient to support adoption of the Agoura Hills BMP, and to outweigh the identified significant and unavoidable environmental effects that might occur due to adoption of the Project. In light of the benefits to the City and the local community identified above, pursuant to CEQA Guidelines Section 15903, the City Council finds that these overriding considerations, as identified in conjunction with the environmental review of impacts stemming from adoption of the Agoura Hills BMP, outweigh the potentially significant and unavoidable environmental impacts identified in the Final EIR, rendering those impacts acceptable under the circumstances.

City of Agoura Hills
Agoura Hills Bicycle Master Plan
30 7 Statement of Location and Custodian of
Documents
Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e) require that the City of Agoura Hills, as the Lead Agency, specify the location and custodian of the documents of other materials that constitute the record of proceedings upon which the decision has been based.

The following location is where review of the record may be performed:

City of Agoura Hills
Public Works Department
30001 Ladyface Court
Agoura Hills, California 91301
The City of Agoura Hills has relied on all of the documents contained within the record of proceedings in reaching its decision on the Project.

RESOLUTION NO. 26-2131

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF AGOURA

HILLS, CALIFORNIA, APPROVING A GENERAL PLAN AMENDMENT
(CASE NO. PZ-2026-61-GPA), AMENDING CHAPTER 3:

INFRASTRUCTURE AND COMMUNITY SERVICES, WITH TEXTUAL

REVISIONS TO REFERENCE AND MAINTAIN CONSISTENCY WITH

THE BICYCLE MASTER PLAN, AND AMENDING THE GENERAL PLAN
BIKEWAYS EXHIBIT (FIGURE M-7) TO PROVIDE AN UPDATED
OVERVIEW OF THE BICYCLE NETWORK WITHIN THE CITY.

WHEREAS, in June 2020, the City Council adopted Resolution Number 20-1942, updating the transportation thresholds of significance for the purposes of analyzing transportation impacts under CEQA, pursuant to State law, including a Transportation Demand Mitigation program that developers can choose to implement to reduce VMT by strategies that include implementing bicycle infrastructure; and WHEREAS, in the Fall of 2021, the City of Agoura Hills began developing the draft Bicycle Master Plan (BMP) to build upon the City’s existing bicycle routes and bicycle lanes, developing a citywide network that ensures residents have access to safe bicycle facilities, meets both commuter and recreational needs, provides connectivity to regional bicycle facilities, and provides standard design details for typical bicycle facility types and treatments; and
WHEREAS, in August 2025, the final draft BMP was released. The BMP proposes a vision of a diverse network of interconnected bicycle corridors and support facilities that aim to link local and regional destinations and make biking more practical and desirable for a broader range of people. The BMP proposes 30.1 miles of new bikeways and bikeway improvements to build upon the City’s existing 1.3 miles of bicycle routes and

9.2 miles of bicycle lanes; and
WHEREAS, in connection with the adoption of the Bicycle Master Plan and Transportation Demand Mitigation program, the City of Agoura Hills also has initiated legislative actions to update the General Plan 2035 to amend Section A. Mobility (M), of Chapter 3: Infrastructure and Community Services and amend the General Plan Bikeways Exhibit (Figure M-7) to graphically depict an updated overview of the existing and planned bicycle network within the City of Agoura Hills (the Bicycle Master Plan, the VMT Mitigation Exchange and Banking Program, and the General Plan Amendments are collectively referred to as the “Project”); and
WHEREAS, on May 7, 2025, the Planning Commission adopted Resolution 26- 1320; A Resolution of the Planning Commission of the City of Agoura Hills recommending that the City Council of the City of Agoura Hills: 1) Pursuant to the California Environmental Quality Act, certify and adopt the Final Programmatic Environmental Impact Report for the Bicycle Master Plan, the Vehicle Miles Traveled Mitigation Exchange and Banking Program, and general plan amendments, and adopt the Findings of Fact, the Statement of Overriding Considerations, and the Mitigation Monitoring and Reporting Program; 2) Adopt the Bicycle Master Plan; and 3) Adopt a general plan amendment (Case No. PZ-2026-61-GPA) to amend Chapter 3: Infrastructure and

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Agoura Hills City CouncilMay 27, 2026

Agoura Hills City Council
May 27, 2026