Agenda packet — American Canyon City Council, November 19, 2024 (part 8 of 16)

1275
*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1542 ALL 564307.8 4227325 0.001234 9901 DieselExhPM 3.21E-07 25YrCancerDerived_InhSoilDerm * 3.21E-07 1543 ALL 564307.8 4227417 0.001208 9901 DieselExhPM 3.14E-07 25YrCancerDerived_InhSoilDerm * 3.14E-07 1544 ALL 564307.8 4227509 0.001169 9901 DieselExhPM 3.04E-07 25YrCancerDerived_InhSoilDerm * 3.04E-07 1545 ALL 564307.8 4227600 0.001126 9901 DieselExhPM 2.93E-07 25YrCancerDerived_InhSoilDerm * 2.93E-07 1546 ALL 564307.8 4227692 0.001081 9901 DieselExhPM 2.81E-07 25YrCancerDerived_InhSoilDerm * 2.81E-07 1547 ALL 564307.8 4227784 0.001031 9901 DieselExhPM 2.68E-07 25YrCancerDerived_InhSoilDerm * 2.68E-07 1548 ALL 564307.8 4227875 0.000972 9901 DieselExhPM 2.53E-07 25YrCancerDerived_InhSoilDerm * 2.53E-07 1549 ALL 564406.3 4227142 0.000906 9901 DieselExhPM 2.36E-07 25YrCancerDerived_InhSoilDerm * 2.36E-07 1550 ALL 564406.3 4227234 0.000918 9901 DieselExhPM 2.39E-07 25YrCancerDerived_InhSoilDerm * 2.39E-07 1551 ALL 564406.3 4227325 0.000964 9901 DieselExhPM 2.51E-07 25YrCancerDerived_InhSoilDerm * 2.51E-07 1552 ALL 564406.3 4227417 0.000954 9901 DieselExhPM 2.48E-07 25YrCancerDerived_InhSoilDerm * 2.48E-07 1553 ALL 564406.3 4227509 0.000928 9901 DieselExhPM 2.41E-07 25YrCancerDerived_InhSoilDerm * 2.41E-07 1554 ALL 564406.3 4227600 0.000902 9901 DieselExhPM 2.35E-07 25YrCancerDerived_InhSoilDerm * 2.35E-07 1555 ALL 564406.3 4227692 0.000876 9901 DieselExhPM 2.28E-07 25YrCancerDerived_InhSoilDerm * 2.28E-07 1556 ALL 564406.3 4227784 0.000848 9901 DieselExhPM 2.20E-07 25YrCancerDerived_InhSoilDerm * 2.20E-07 1557 ALL 564406.3 4227875 0.000822 9901 DieselExhPM 2.14E-07 25YrCancerDerived_InhSoilDerm * 2.14E-07 1558 ALL 564504.7 4227142 0.000714 9901 DieselExhPM 1.86E-07 25YrCancerDerived_InhSoilDerm * 1.86E-07 1559 ALL 564504.7 4227234 0.000736 9901 DieselExhPM 1.91E-07 25YrCancerDerived_InhSoilDerm * 1.91E-07 1560 ALL 564504.7 4227325 0.000757 9901 DieselExhPM 1.97E-07 25YrCancerDerived_InhSoilDerm * 1.97E-07 1561 ALL 564504.7 4227417 0.000768 9901 DieselExhPM 2.00E-07 25YrCancerDerived_InhSoilDerm * 2.00E-07 1562 ALL 564504.7 4227509 0.000757 9901 DieselExhPM 1.97E-07 25YrCancerDerived_InhSoilDerm * 1.97E-07 1563 ALL 564504.7 4227600 0.00074 9901 DieselExhPM 1.92E-07 25YrCancerDerived_InhSoilDerm * 1.92E-07 1564 ALL 564504.7 4227692 0.000721 9901 DieselExhPM 1.87E-07 25YrCancerDerived_InhSoilDerm * 1.87E-07 1565 ALL 564504.7 4227784 0.000706 9901 DieselExhPM 1.83E-07 25YrCancerDerived_InhSoilDerm * 1.83E-07 1566 ALL 564504.7 4227875 0.000691 9901 DieselExhPM 1.80E-07 25YrCancerDerived_InhSoilDerm * 1.80E-07 1567 ALL 564603.1 4227142 0.000588 9901 DieselExhPM 1.53E-07 25YrCancerDerived_InhSoilDerm * 1.53E-07 1568 ALL 564603.1 4227234 0.000612 9901 DieselExhPM 1.59E-07 25YrCancerDerived_InhSoilDerm * 1.59E-07 1569 ALL 564603.1 4227325 0.000639 9901 DieselExhPM 1.66E-07 25YrCancerDerived_InhSoilDerm * 1.66E-07 1570 ALL 564603.1 4227417 0.000636 9901 DieselExhPM 1.65E-07 25YrCancerDerived_InhSoilDerm * 1.65E-07 1571 ALL 564603.1 4227509 0.000625 9901 DieselExhPM 1.62E-07 25YrCancerDerived_InhSoilDerm * 1.62E-07 1572 ALL 564603.1 4227600 0.000618 9901 DieselExhPM 1.61E-07 25YrCancerDerived_InhSoilDerm * 1.61E-07 1573 ALL 564603.1 4227692 0.000606 9901 DieselExhPM 1.58E-07 25YrCancerDerived_InhSoilDerm * 1.58E-07 1574 ALL 564603.1 4227784 0.000594 9901 DieselExhPM 1.55E-07 25YrCancerDerived_InhSoilDerm * 1.55E-07 1575 ALL 564603.1 4227875 0.000581 9901 DieselExhPM 1.51E-07 25YrCancerDerived_InhSoilDerm * 1.51E-07 1576 ALL 564701.6 4227142 0.000493 9901 DieselExhPM 1.28E-07 25YrCancerDerived_InhSoilDerm * 1.28E-07 1577 ALL 564701.6 4227234 0.000511 9901 DieselExhPM 1.33E-07 25YrCancerDerived_InhSoilDerm * 1.33E-07 1578 ALL 564701.6 4227325 0.000532 9901 DieselExhPM 1.38E-07 25YrCancerDerived_InhSoilDerm * 1.38E-07 1579 ALL 564701.6 4227417 0.000537 9901 DieselExhPM 1.40E-07 25YrCancerDerived_InhSoilDerm * 1.40E-07 1580 ALL 564701.6 4227509 0.000531 9901 DieselExhPM 1.38E-07 25YrCancerDerived_InhSoilDerm * 1.38E-07 1581 ALL 564701.6 4227600 0.000526 9901 DieselExhPM 1.37E-07 25YrCancerDerived_InhSoilDerm * 1.37E-07 1582 ALL 564701.6 4227692 0.00052 9901 DieselExhPM 1.35E-07 25YrCancerDerived_InhSoilDerm * 1.35E-07 1583 ALL 564701.6 4227784 0.000512 9901 DieselExhPM 1.33E-07 25YrCancerDerived_InhSoilDerm * 1.33E-07 1584 ALL 564701.6 4227875 0.000502 9901 DieselExhPM 1.30E-07 25YrCancerDerived_InhSoilDerm * 1.30E-07 1585 ALL 564800 4227142 0.00043 9901 DieselExhPM 1.12E-07 25YrCancerDerived_InhSoilDerm * 1.12E-07 1586 ALL 564800 4227234 0.000429 9901 DieselExhPM 1.11E-07 25YrCancerDerived_InhSoilDerm * 1.11E-07 1587 ALL 564800 4227325 0.000444 9901 DieselExhPM 1.16E-07 25YrCancerDerived_InhSoilDerm * 1.16E-07 1588 ALL 564800 4227417 0.00046 9901 DieselExhPM 1.19E-07 25YrCancerDerived_InhSoilDerm * 1.19E-07 1589 ALL 564800 4227509 0.000464 9901 DieselExhPM 1.21E-07 25YrCancerDerived_InhSoilDerm * 1.21E-07 1590 ALL 564800 4227600 0.000458 9901 DieselExhPM 1.19E-07 25YrCancerDerived_InhSoilDerm * 1.19E-07 1591 ALL 564800 4227692 0.000451 9901 DieselExhPM 1.17E-07 25YrCancerDerived_InhSoilDerm * 1.17E-07 1592 ALL 564800 4227784 0.000447 9901 DieselExhPM 1.16E-07 25YrCancerDerived_InhSoilDerm * 1.16E-07 1593 ALL 564800 4227875 0.00044 9901 DieselExhPM 1.14E-07 25YrCancerDerived_InhSoilDerm * 1.14E-07 1594 ALL 564066.7 4227050 0.002727 9901 DieselExhPM 7.09E-07 25YrCancerDerived_InhSoilDerm * 7.09E-07 1595 ALL 564066.7 4226952 0.002674 9901 DieselExhPM 6.95E-07 25YrCancerDerived_InhSoilDerm * 6.95E-07 1596 ALL 564066.7 4226853 0.002728 9901 DieselExhPM 7.09E-07 25YrCancerDerived_InhSoilDerm * 7.09E-07 1597 ALL 564066.7 4226755 0.002998 9901 DieselExhPM 7.79E-07 25YrCancerDerived_InhSoilDerm * 7.79E-07 1598 ALL 564066.7 4226656 0.002562 9901 DieselExhPM 6.66E-07 25YrCancerDerived_InhSoilDerm * 6.66E-07 1599 ALL 564066.7 4226558 0.001641 9901 DieselExhPM 4.27E-07 25YrCancerDerived_InhSoilDerm * 4.27E-07 1600 ALL 564066.7 4226460 0.001024 9901 DieselExhPM 2.66E-07 25YrCancerDerived_InhSoilDerm * 2.66E-07 1601 ALL 564066.7 4226361 0.000758 9901 DieselExhPM 1.97E-07 25YrCancerDerived_InhSoilDerm * 1.97E-07 1602 ALL 564066.7 4226263 0.000722 9901 DieselExhPM 1.88E-07 25YrCancerDerived_InhSoilDerm * 1.88E-07 1603 ALL 564066.7 4226164 0.000682 9901 DieselExhPM 1.77E-07 25YrCancerDerived_InhSoilDerm * 1.77E-07 1604 ALL 564066.7 4226066 0.000596 9901 DieselExhPM 1.55E-07 25YrCancerDerived_InhSoilDerm * 1.55E-07 1605 ALL 564066.7 4225967 0.000533 9901 DieselExhPM 1.39E-07 25YrCancerDerived_InhSoilDerm * 1.39E-07 1606 ALL 564066.7 4225869 0.000499 9901 DieselExhPM 1.30E-07 25YrCancerDerived_InhSoilDerm * 1.30E-07 1607 ALL 564066.7 4225771 0.000461 9901 DieselExhPM 1.20E-07 25YrCancerDerived_InhSoilDerm * 1.20E-07 1608 ALL 564066.7 4225672 0.000428 9901 DieselExhPM 1.11E-07 25YrCancerDerived_InhSoilDerm * 1.11E-07

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1609 ALL 564066.7 4225574 0.000395 9901 DieselExhPM 1.03E-07 25YrCancerDerived_InhSoilDerm * 1.03E-07 1610 ALL 564066.7 4225475 0.000365 9901 DieselExhPM 9.49E-08 25YrCancerDerived_InhSoilDerm * 9.49E-08 1611 ALL 564158.3 4227050 0.001827 9901 DieselExhPM 4.75E-07 25YrCancerDerived_InhSoilDerm * 4.75E-07 1612 ALL 564158.3 4226952 0.001693 9901 DieselExhPM 4.40E-07 25YrCancerDerived_InhSoilDerm * 4.40E-07 1613 ALL 564158.3 4226853 0.00177 9901 DieselExhPM 4.60E-07 25YrCancerDerived_InhSoilDerm * 4.60E-07 1614 ALL 564158.3 4226755 0.002072 9901 DieselExhPM 5.39E-07 25YrCancerDerived_InhSoilDerm * 5.39E-07 1615 ALL 564158.3 4226656 0.001808 9901 DieselExhPM 4.70E-07 25YrCancerDerived_InhSoilDerm * 4.70E-07 1616 ALL 564158.3 4226558 0.00128 9901 DieselExhPM 3.33E-07 25YrCancerDerived_InhSoilDerm * 3.33E-07 1617 ALL 564158.3 4226460 0.000854 9901 DieselExhPM 2.22E-07 25YrCancerDerived_InhSoilDerm * 2.22E-07 1618 ALL 564158.3 4226361 0.000589 9901 DieselExhPM 1.53E-07 25YrCancerDerived_InhSoilDerm * 1.53E-07 1619 ALL 564158.3 4226263 0.000527 9901 DieselExhPM 1.37E-07 25YrCancerDerived_InhSoilDerm * 1.37E-07 1620 ALL 564158.3 4226164 0.000543 9901 DieselExhPM 1.41E-07 25YrCancerDerived_InhSoilDerm * 1.41E-07 1621 ALL 564158.3 4226066 0.000506 9901 DieselExhPM 1.31E-07 25YrCancerDerived_InhSoilDerm * 1.31E-07 1622 ALL 564158.3 4225967 0.000454 9901 DieselExhPM 1.18E-07 25YrCancerDerived_InhSoilDerm * 1.18E-07 1623 ALL 564158.3 4225869 0.000416 9901 DieselExhPM 1.08E-07 25YrCancerDerived_InhSoilDerm * 1.08E-07 1624 ALL 564158.3 4225771 0.000389 9901 DieselExhPM 1.01E-07 25YrCancerDerived_InhSoilDerm * 1.01E-07 1625 ALL 564158.3 4225672 0.000373 9901 DieselExhPM 9.69E-08 25YrCancerDerived_InhSoilDerm * 9.69E-08 1626 ALL 564158.3 4225574 0.000355 9901 DieselExhPM 9.22E-08 25YrCancerDerived_InhSoilDerm * 9.22E-08 1627 ALL 564158.3 4225475 0.000333 9901 DieselExhPM 8.65E-08 25YrCancerDerived_InhSoilDerm * 8.65E-08 1628 ALL 564250 4227050 0.001307 9901 DieselExhPM 3.40E-07 25YrCancerDerived_InhSoilDerm * 3.40E-07 1629 ALL 564250 4226952 0.001255 9901 DieselExhPM 3.26E-07 25YrCancerDerived_InhSoilDerm * 3.26E-07 1630 ALL 564250 4226853 0.001288 9901 DieselExhPM 3.35E-07 25YrCancerDerived_InhSoilDerm * 3.35E-07 1631 ALL 564250 4226755 0.00135 9901 DieselExhPM 3.51E-07 25YrCancerDerived_InhSoilDerm * 3.51E-07 1632 ALL 564250 4226656 0.001159 9901 DieselExhPM 3.01E-07 25YrCancerDerived_InhSoilDerm * 3.01E-07 1633 ALL 564250 4226558 0.000823 9901 DieselExhPM 2.14E-07 25YrCancerDerived_InhSoilDerm * 2.14E-07 1634 ALL 564250 4226460 0.000655 9901 DieselExhPM 1.70E-07 25YrCancerDerived_InhSoilDerm * 1.70E-07 1635 ALL 564250 4226361 0.000489 9901 DieselExhPM 1.27E-07 25YrCancerDerived_InhSoilDerm * 1.27E-07 1636 ALL 564250 4226263 0.000403 9901 DieselExhPM 1.05E-07 25YrCancerDerived_InhSoilDerm * 1.05E-07 1637 ALL 564250 4226164 0.000402 9901 DieselExhPM 1.05E-07 25YrCancerDerived_InhSoilDerm * 1.05E-07 1638 ALL 564250 4226066 0.000402 9901 DieselExhPM 1.05E-07 25YrCancerDerived_InhSoilDerm * 1.05E-07 1639 ALL 564250 4225967 0.0004 9901 DieselExhPM 1.04E-07 25YrCancerDerived_InhSoilDerm * 1.04E-07 1640 ALL 564250 4225869 0.000354 9901 DieselExhPM 9.21E-08 25YrCancerDerived_InhSoilDerm * 9.21E-08 1641 ALL 564250 4225771 0.000334 9901 DieselExhPM 8.67E-08 25YrCancerDerived_InhSoilDerm * 8.67E-08 1642 ALL 564250 4225672 0.000316 9901 DieselExhPM 8.22E-08 25YrCancerDerived_InhSoilDerm * 8.22E-08 1643 ALL 564250 4225574 0.000309 9901 DieselExhPM 8.02E-08 25YrCancerDerived_InhSoilDerm * 8.02E-08 1644 ALL 564250 4225475 0.000301 9901 DieselExhPM 7.82E-08 25YrCancerDerived_InhSoilDerm * 7.82E-08 1645 ALL 564341.7 4227050 0.001011 9901 DieselExhPM 2.63E-07 25YrCancerDerived_InhSoilDerm * 2.63E-07 1646 ALL 564341.7 4226952 0.000977 9901 DieselExhPM 2.54E-07 25YrCancerDerived_InhSoilDerm * 2.54E-07 1647 ALL 564341.7 4226853 0.000986 9901 DieselExhPM 2.56E-07 25YrCancerDerived_InhSoilDerm * 2.56E-07 1648 ALL 564341.7 4226755 0.000991 9901 DieselExhPM 2.57E-07 25YrCancerDerived_InhSoilDerm * 2.57E-07 1649 ALL 564341.7 4226656 0.000887 9901 DieselExhPM 2.31E-07 25YrCancerDerived_InhSoilDerm * 2.31E-07 1650 ALL 564341.7 4226558 0.000625 9901 DieselExhPM 1.63E-07 25YrCancerDerived_InhSoilDerm * 1.63E-07 1651 ALL 564341.7 4226460 0.00049 9901 DieselExhPM 1.27E-07 25YrCancerDerived_InhSoilDerm * 1.27E-07 1652 ALL 564341.7 4226361 0.000414 9901 DieselExhPM 1.08E-07 25YrCancerDerived_InhSoilDerm * 1.08E-07 1653 ALL 564341.7 4226263 0.000334 9901 DieselExhPM 8.67E-08 25YrCancerDerived_InhSoilDerm * 8.67E-08 1654 ALL 564341.7 4226164 0.000303 9901 DieselExhPM 7.86E-08 25YrCancerDerived_InhSoilDerm * 7.86E-08 1655 ALL 564341.7 4226066 0.000303 9901 DieselExhPM 7.87E-08 25YrCancerDerived_InhSoilDerm * 7.87E-08 1656 ALL 564341.7 4225967 0.000335 9901 DieselExhPM 8.71E-08 25YrCancerDerived_InhSoilDerm * 8.71E-08 1657 ALL 564341.7 4225869 0.000315 9901 DieselExhPM 8.18E-08 25YrCancerDerived_InhSoilDerm * 8.18E-08 1658 ALL 564341.7 4225771 0.000296 9901 DieselExhPM 7.70E-08 25YrCancerDerived_InhSoilDerm * 7.70E-08 1659 ALL 564341.7 4225672 0.000274 9901 DieselExhPM 7.13E-08 25YrCancerDerived_InhSoilDerm * 7.13E-08 1660 ALL 564341.7 4225574 0.000264 9901 DieselExhPM 6.87E-08 25YrCancerDerived_InhSoilDerm * 6.87E-08 1661 ALL 564341.7 4225475 0.000263 9901 DieselExhPM 6.85E-08 25YrCancerDerived_InhSoilDerm * 6.85E-08 1662 ALL 564433.3 4227050 0.000833 9901 DieselExhPM 2.16E-07 25YrCancerDerived_InhSoilDerm * 2.16E-07 1663 ALL 564433.3 4226952 0.00082 9901 DieselExhPM 2.13E-07 25YrCancerDerived_InhSoilDerm * 2.13E-07 1664 ALL 564433.3 4226853 0.00081 9901 DieselExhPM 2.11E-07 25YrCancerDerived_InhSoilDerm * 2.11E-07 1665 ALL 564433.3 4226755 0.000791 9901 DieselExhPM 2.06E-07 25YrCancerDerived_InhSoilDerm * 2.06E-07 1666 ALL 564433.3 4226656 0.000684 9901 DieselExhPM 1.78E-07 25YrCancerDerived_InhSoilDerm * 1.78E-07 1667 ALL 564433.3 4226558 0.000514 9901 DieselExhPM 1.34E-07 25YrCancerDerived_InhSoilDerm * 1.34E-07 1668 ALL 564433.3 4226460 0.000401 9901 DieselExhPM 1.04E-07 25YrCancerDerived_InhSoilDerm * 1.04E-07 1669 ALL 564433.3 4226361 0.000323 9901 DieselExhPM 8.39E-08 25YrCancerDerived_InhSoilDerm * 8.39E-08 1670 ALL 564433.3 4226263 0.000288 9901 DieselExhPM 7.49E-08 25YrCancerDerived_InhSoilDerm * 7.49E-08 1671 ALL 564433.3 4226164 0.000252 9901 DieselExhPM 6.55E-08 25YrCancerDerived_InhSoilDerm * 6.55E-08 1672 ALL 564433.3 4226066 0.000233 9901 DieselExhPM 6.05E-08 25YrCancerDerived_InhSoilDerm * 6.05E-08 1673 ALL 564433.3 4225967 0.000254 9901 DieselExhPM 6.61E-08 25YrCancerDerived_InhSoilDerm * 6.61E-08 1674 ALL 564433.3 4225869 0.000264 9901 DieselExhPM 6.86E-08 25YrCancerDerived_InhSoilDerm * 6.86E-08 1675 ALL 564433.3 4225771 0.000279 9901 DieselExhPM 7.24E-08 25YrCancerDerived_InhSoilDerm * 7.24E-08

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1676 ALL 564433.3 4225672 0.000257 9901 DieselExhPM 6.67E-08 25YrCancerDerived_InhSoilDerm * 6.67E-08 1677 ALL 564433.3 4225574 0.000236 9901 DieselExhPM 6.13E-08 25YrCancerDerived_InhSoilDerm * 6.13E-08 1678 ALL 564433.3 4225475 0.00023 9901 DieselExhPM 5.97E-08 25YrCancerDerived_InhSoilDerm * 5.97E-08 1679 ALL 564525 4227050 0.000682 9901 DieselExhPM 1.77E-07 25YrCancerDerived_InhSoilDerm * 1.77E-07 1680 ALL 564525 4226952 0.000706 9901 DieselExhPM 1.84E-07 25YrCancerDerived_InhSoilDerm * 1.84E-07 1681 ALL 564525 4226853 0.000711 9901 DieselExhPM 1.85E-07 25YrCancerDerived_InhSoilDerm * 1.85E-07 1682 ALL 564525 4226755 0.000668 9901 DieselExhPM 1.74E-07 25YrCancerDerived_InhSoilDerm * 1.74E-07 1683 ALL 564525 4226656 0.000584 9901 DieselExhPM 1.52E-07 25YrCancerDerived_InhSoilDerm * 1.52E-07 1684 ALL 564525 4226558 0.000452 9901 DieselExhPM 1.18E-07 25YrCancerDerived_InhSoilDerm * 1.18E-07 1685 ALL 564525 4226460 0.000341 9901 DieselExhPM 8.86E-08 25YrCancerDerived_InhSoilDerm * 8.86E-08 1686 ALL 564525 4226361 0.000287 9901 DieselExhPM 7.46E-08 25YrCancerDerived_InhSoilDerm * 7.46E-08 1687 ALL 564525 4226263 0.000255 9901 DieselExhPM 6.62E-08 25YrCancerDerived_InhSoilDerm * 6.62E-08 1688 ALL 564525 4226164 0.000224 9901 DieselExhPM 5.83E-08 25YrCancerDerived_InhSoilDerm * 5.83E-08 1689 ALL 564525 4226066 0.000198 9901 DieselExhPM 5.13E-08 25YrCancerDerived_InhSoilDerm * 5.13E-08 1690 ALL 564525 4225967 0.0002 9901 DieselExhPM 5.21E-08 25YrCancerDerived_InhSoilDerm * 5.21E-08 1691 ALL 564525 4225869 0.000216 9901 DieselExhPM 5.61E-08 25YrCancerDerived_InhSoilDerm * 5.61E-08 1692 ALL 564525 4225771 0.00025 9901 DieselExhPM 6.49E-08 25YrCancerDerived_InhSoilDerm * 6.49E-08 1693 ALL 564525 4225672 0.000254 9901 DieselExhPM 6.59E-08 25YrCancerDerived_InhSoilDerm * 6.59E-08 1694 ALL 564525 4225574 0.000227 9901 DieselExhPM 5.91E-08 25YrCancerDerived_InhSoilDerm * 5.91E-08 1695 ALL 564525 4225475 0.000206 9901 DieselExhPM 5.36E-08 25YrCancerDerived_InhSoilDerm * 5.36E-08 1696 ALL 564616.7 4227050 0.000577 9901 DieselExhPM 1.50E-07 25YrCancerDerived_InhSoilDerm * 1.50E-07 1697 ALL 564616.7 4226952 0.00061 9901 DieselExhPM 1.58E-07 25YrCancerDerived_InhSoilDerm * 1.58E-07 1698 ALL 564616.7 4226853 0.000641 9901 DieselExhPM 1.67E-07 25YrCancerDerived_InhSoilDerm * 1.67E-07 1699 ALL 564616.7 4226755 0.000602 9901 DieselExhPM 1.56E-07 25YrCancerDerived_InhSoilDerm * 1.56E-07 1700 ALL 564616.7 4226656 0.000516 9901 DieselExhPM 1.34E-07 25YrCancerDerived_InhSoilDerm * 1.34E-07 1701 ALL 564616.7 4226558 0.000404 9901 DieselExhPM 1.05E-07 25YrCancerDerived_InhSoilDerm * 1.05E-07 1702 ALL 564616.7 4226460 0.000307 9901 DieselExhPM 7.98E-08 25YrCancerDerived_InhSoilDerm * 7.98E-08 1703 ALL 564616.7 4226361 0.00025 9901 DieselExhPM 6.50E-08 25YrCancerDerived_InhSoilDerm * 6.50E-08 1704 ALL 564616.7 4226263 0.00022 9901 DieselExhPM 5.72E-08 25YrCancerDerived_InhSoilDerm * 5.72E-08 1705 ALL 564616.7 4226164 0.000198 9901 DieselExhPM 5.15E-08 25YrCancerDerived_InhSoilDerm * 5.15E-08 1706 ALL 564616.7 4226066 0.000178 9901 DieselExhPM 4.62E-08 25YrCancerDerived_InhSoilDerm * 4.62E-08 1707 ALL 564616.7 4225967 0.000172 9901 DieselExhPM 4.46E-08 25YrCancerDerived_InhSoilDerm * 4.46E-08 1708 ALL 564616.7 4225869 0.000183 9901 DieselExhPM 4.76E-08 25YrCancerDerived_InhSoilDerm * 4.76E-08 1709 ALL 564616.7 4225771 0.000204 9901 DieselExhPM 5.30E-08 25YrCancerDerived_InhSoilDerm * 5.30E-08 1710 ALL 564616.7 4225672 0.00024 9901 DieselExhPM 6.24E-08 25YrCancerDerived_InhSoilDerm * 6.24E-08 1711 ALL 564616.7 4225574 0.000226 9901 DieselExhPM 5.87E-08 25YrCancerDerived_InhSoilDerm * 5.87E-08 1712 ALL 564616.7 4225475 0.000202 9901 DieselExhPM 5.25E-08 25YrCancerDerived_InhSoilDerm * 5.25E-08 1713 ALL 564708.3 4227050 0.000499 9901 DieselExhPM 1.30E-07 25YrCancerDerived_InhSoilDerm * 1.30E-07 1714 ALL 564708.3 4226952 0.000527 9901 DieselExhPM 1.37E-07 25YrCancerDerived_InhSoilDerm * 1.37E-07 1715 ALL 564708.3 4226853 0.000561 9901 DieselExhPM 1.46E-07 25YrCancerDerived_InhSoilDerm * 1.46E-07 1716 ALL 564708.3 4226755 0.000556 9901 DieselExhPM 1.44E-07 25YrCancerDerived_InhSoilDerm * 1.44E-07 1717 ALL 564708.3 4226656 0.000495 9901 DieselExhPM 1.29E-07 25YrCancerDerived_InhSoilDerm * 1.29E-07 1718 ALL 564708.3 4226558 0.000374 9901 DieselExhPM 9.73E-08 25YrCancerDerived_InhSoilDerm * 9.73E-08 1719 ALL 564708.3 4226460 0.000289 9901 DieselExhPM 7.50E-08 25YrCancerDerived_InhSoilDerm * 7.50E-08 1720 ALL 564708.3 4226361 0.000234 9901 DieselExhPM 6.09E-08 25YrCancerDerived_InhSoilDerm * 6.09E-08 1721 ALL 564708.3 4226263 0.000206 9901 DieselExhPM 5.34E-08 25YrCancerDerived_InhSoilDerm * 5.34E-08 1722 ALL 564708.3 4226164 0.000188 9901 DieselExhPM 4.88E-08 25YrCancerDerived_InhSoilDerm * 4.88E-08 1723 ALL 564708.3 4226066 0.00017 9901 DieselExhPM 4.41E-08 25YrCancerDerived_InhSoilDerm * 4.41E-08 1724 ALL 564708.3 4225967 0.000154 9901 DieselExhPM 4.01E-08 25YrCancerDerived_InhSoilDerm * 4.01E-08 1725 ALL 564708.3 4225869 0.00016 9901 DieselExhPM 4.16E-08 25YrCancerDerived_InhSoilDerm * 4.16E-08 1726 ALL 564708.3 4225771 0.000185 9901 DieselExhPM 4.82E-08 25YrCancerDerived_InhSoilDerm * 4.82E-08 1727 ALL 564708.3 4225672 0.000215 9901 DieselExhPM 5.58E-08 25YrCancerDerived_InhSoilDerm * 5.58E-08 1728 ALL 564708.3 4225574 0.000218 9901 DieselExhPM 5.68E-08 25YrCancerDerived_InhSoilDerm * 5.68E-08 1729 ALL 564708.3 4225475 0.000202 9901 DieselExhPM 5.26E-08 25YrCancerDerived_InhSoilDerm * 5.26E-08 1730 ALL 564800 4227050 0.000446 9901 DieselExhPM 1.16E-07 25YrCancerDerived_InhSoilDerm * 1.16E-07 1731 ALL 564800 4226952 0.000472 9901 DieselExhPM 1.23E-07 25YrCancerDerived_InhSoilDerm * 1.23E-07 1732 ALL 564800 4226853 0.000495 9901 DieselExhPM 1.29E-07 25YrCancerDerived_InhSoilDerm * 1.29E-07 1733 ALL 564800 4226755 0.00051 9901 DieselExhPM 1.33E-07 25YrCancerDerived_InhSoilDerm * 1.33E-07 1734 ALL 564800 4226656 0.000461 9901 DieselExhPM 1.20E-07 25YrCancerDerived_InhSoilDerm * 1.20E-07 1735 ALL 564800 4226558 0.000354 9901 DieselExhPM 9.19E-08 25YrCancerDerived_InhSoilDerm * 9.19E-08 1736 ALL 564800 4226460 0.000282 9901 DieselExhPM 7.33E-08 25YrCancerDerived_InhSoilDerm * 7.33E-08 1737 ALL 564800 4226361 0.000233 9901 DieselExhPM 6.06E-08 25YrCancerDerived_InhSoilDerm * 6.06E-08 1738 ALL 564800 4226263 0.000201 9901 DieselExhPM 5.21E-08 25YrCancerDerived_InhSoilDerm * 5.21E-08 1739 ALL 564800 4226164 0.000183 9901 DieselExhPM 4.75E-08 25YrCancerDerived_InhSoilDerm * 4.75E-08 1740 ALL 564800 4226066 0.000163 9901 DieselExhPM 4.22E-08 25YrCancerDerived_InhSoilDerm * 4.22E-08 1741 ALL 564800 4225967 0.000145 9901 DieselExhPM 3.76E-08 25YrCancerDerived_InhSoilDerm * 3.76E-08 1742 ALL 564800 4225869 0.000139 9901 DieselExhPM 3.63E-08 25YrCancerDerived_InhSoilDerm * 3.63E-08

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1743 ALL 564800 4225771 0.000156 9901 DieselExhPM 4.04E-08 25YrCancerDerived_InhSoilDerm * 4.04E-08 1744 ALL 564800 4225672 0.000172 9901 DieselExhPM 4.48E-08 25YrCancerDerived_InhSoilDerm * 4.48E-08 1745 ALL 564800 4225574 0.000193 9901 DieselExhPM 5.03E-08 25YrCancerDerived_InhSoilDerm * 5.03E-08 1746 ALL 564800 4225475 0.000197 9901 DieselExhPM 5.11E-08 25YrCancerDerived_InhSoilDerm * 5.11E-08 1747 ALL 563975 4226209 0.000908 9901 DieselExhPM 2.36E-07 25YrCancerDerived_InhSoilDerm * 2.36E-07 1748 ALL 563975 4226117 0.000773 9901 DieselExhPM 2.01E-07 25YrCancerDerived_InhSoilDerm * 2.01E-07 1749 ALL 563975 4226025 0.000688 9901 DieselExhPM 1.79E-07 25YrCancerDerived_InhSoilDerm * 1.79E-07 1750 ALL 563975 4225934 0.000619 9901 DieselExhPM 1.61E-07 25YrCancerDerived_InhSoilDerm * 1.61E-07 1751 ALL 563975 4225842 0.000575 9901 DieselExhPM 1.49E-07 25YrCancerDerived_InhSoilDerm * 1.49E-07 1752 ALL 563975 4225750 0.000525 9901 DieselExhPM 1.37E-07 25YrCancerDerived_InhSoilDerm * 1.37E-07 1753 ALL 563975 4225659 0.000484 9901 DieselExhPM 1.26E-07 25YrCancerDerived_InhSoilDerm * 1.26E-07 1754 ALL 563975 4225567 0.000446 9901 DieselExhPM 1.16E-07 25YrCancerDerived_InhSoilDerm * 1.16E-07 1755 ALL 563975 4225475 0.000415 9901 DieselExhPM 1.08E-07 25YrCancerDerived_InhSoilDerm * 1.08E-07 1756 ALL 563876.6 4226209 0.001205 9901 DieselExhPM 3.13E-07 25YrCancerDerived_InhSoilDerm * 3.13E-07 1757 ALL 563876.6 4226117 0.000998 9901 DieselExhPM 2.59E-07 25YrCancerDerived_InhSoilDerm * 2.59E-07 1758 ALL 563876.6 4226025 0.000887 9901 DieselExhPM 2.31E-07 25YrCancerDerived_InhSoilDerm * 2.31E-07 1759 ALL 563876.6 4225934 0.000782 9901 DieselExhPM 2.03E-07 25YrCancerDerived_InhSoilDerm * 2.03E-07 1760 ALL 563876.6 4225842 0.000698 9901 DieselExhPM 1.81E-07 25YrCancerDerived_InhSoilDerm * 1.81E-07 1761 ALL 563876.6 4225750 0.000631 9901 DieselExhPM 1.64E-07 25YrCancerDerived_InhSoilDerm * 1.64E-07 1762 ALL 563876.6 4225659 0.000573 9901 DieselExhPM 1.49E-07 25YrCancerDerived_InhSoilDerm * 1.49E-07 1763 ALL 563876.6 4225567 0.000523 9901 DieselExhPM 1.36E-07 25YrCancerDerived_InhSoilDerm * 1.36E-07 1764 ALL 563876.6 4225475 0.000483 9901 DieselExhPM 1.25E-07 25YrCancerDerived_InhSoilDerm * 1.25E-07 1765 ALL 563778.1 4226209 0.001754 9901 DieselExhPM 4.56E-07 25YrCancerDerived_InhSoilDerm * 4.56E-07 1766 ALL 563778.1 4226117 0.001405 9901 DieselExhPM 3.65E-07 25YrCancerDerived_InhSoilDerm * 3.65E-07 1767 ALL 563778.1 4226025 0.001162 9901 DieselExhPM 3.02E-07 25YrCancerDerived_InhSoilDerm * 3.02E-07 1768 ALL 563778.1 4225934 0.000986 9901 DieselExhPM 2.56E-07 25YrCancerDerived_InhSoilDerm * 2.56E-07 1769 ALL 563778.1 4225842 0.000854 9901 DieselExhPM 2.22E-07 25YrCancerDerived_InhSoilDerm * 2.22E-07 1770 ALL 563778.1 4225750 0.00075 9901 DieselExhPM 1.95E-07 25YrCancerDerived_InhSoilDerm * 1.95E-07 1771 ALL 563778.1 4225659 0.000665 9901 DieselExhPM 1.73E-07 25YrCancerDerived_InhSoilDerm * 1.73E-07 1772 ALL 563778.1 4225567 0.000592 9901 DieselExhPM 1.54E-07 25YrCancerDerived_InhSoilDerm * 1.54E-07 1773 ALL 563778.1 4225475 0.000535 9901 DieselExhPM 1.39E-07 25YrCancerDerived_InhSoilDerm * 1.39E-07 1774 ALL 563679.7 4226209 0.002498 9901 DieselExhPM 6.49E-07 25YrCancerDerived_InhSoilDerm * 6.49E-07 1775 ALL 563679.7 4226117 0.001881 9901 DieselExhPM 4.89E-07 25YrCancerDerived_InhSoilDerm * 4.89E-07 1776 ALL 563679.7 4226025 0.001494 9901 DieselExhPM 3.88E-07 25YrCancerDerived_InhSoilDerm * 3.88E-07 1777 ALL 563679.7 4225934 0.001225 9901 DieselExhPM 3.18E-07 25YrCancerDerived_InhSoilDerm * 3.18E-07 1778 ALL 563679.7 4225842 0.001024 9901 DieselExhPM 2.66E-07 25YrCancerDerived_InhSoilDerm * 2.66E-07 1779 ALL 563679.7 4225750 0.000873 9901 DieselExhPM 2.27E-07 25YrCancerDerived_InhSoilDerm * 2.27E-07 1780 ALL 563679.7 4225659 0.000759 9901 DieselExhPM 1.97E-07 25YrCancerDerived_InhSoilDerm * 1.97E-07 1781 ALL 563679.7 4225567 0.000664 9901 DieselExhPM 1.73E-07 25YrCancerDerived_InhSoilDerm * 1.73E-07 1782 ALL 563679.7 4225475 0.00059 9901 DieselExhPM 1.53E-07 25YrCancerDerived_InhSoilDerm * 1.53E-07 1783 ALL 563581.3 4226209 0.003035 9901 DieselExhPM 7.89E-07 25YrCancerDerived_InhSoilDerm * 7.89E-07 1784 ALL 563581.3 4226117 0.002256 9901 DieselExhPM 5.86E-07 25YrCancerDerived_InhSoilDerm * 5.86E-07 1785 ALL 563581.3 4226025 0.001756 9901 DieselExhPM 4.56E-07 25YrCancerDerived_InhSoilDerm * 4.56E-07 1786 ALL 563581.3 4225934 0.00141 9901 DieselExhPM 3.66E-07 25YrCancerDerived_InhSoilDerm * 3.66E-07 1787 ALL 563581.3 4225842 0.001158 9901 DieselExhPM 3.01E-07 25YrCancerDerived_InhSoilDerm * 3.01E-07 1788 ALL 563581.3 4225750 0.000981 9901 DieselExhPM 2.55E-07 25YrCancerDerived_InhSoilDerm * 2.55E-07 1789 ALL 563581.3 4225659 0.000846 9901 DieselExhPM 2.20E-07 25YrCancerDerived_InhSoilDerm * 2.20E-07 1790 ALL 563581.3 4225567 0.00074 9901 DieselExhPM 1.92E-07 25YrCancerDerived_InhSoilDerm * 1.92E-07 1791 ALL 563581.3 4225475 0.000656 9901 DieselExhPM 1.71E-07 25YrCancerDerived_InhSoilDerm * 1.71E-07 1792 ALL 563482.8 4226209 0.002801 9901 DieselExhPM 7.28E-07 25YrCancerDerived_InhSoilDerm * 7.28E-07 1793 ALL 563482.8 4226117 0.002151 9901 DieselExhPM 5.59E-07 25YrCancerDerived_InhSoilDerm * 5.59E-07 1794 ALL 563482.8 4226025 0.001725 9901 DieselExhPM 4.48E-07 25YrCancerDerived_InhSoilDerm * 4.48E-07 1795 ALL 563482.8 4225934 0.001414 9901 DieselExhPM 3.68E-07 25YrCancerDerived_InhSoilDerm * 3.68E-07 1796 ALL 563482.8 4225842 0.001193 9901 DieselExhPM 3.10E-07 25YrCancerDerived_InhSoilDerm * 3.10E-07 1797 ALL 563482.8 4225750 0.001025 9901 DieselExhPM 2.66E-07 25YrCancerDerived_InhSoilDerm * 2.66E-07 1798 ALL 563482.8 4225659 0.000893 9901 DieselExhPM 2.32E-07 25YrCancerDerived_InhSoilDerm * 2.32E-07 1799 ALL 563482.8 4225567 0.000787 9901 DieselExhPM 2.05E-07 25YrCancerDerived_InhSoilDerm * 2.05E-07 1800 ALL 563482.8 4225475 0.000701 9901 DieselExhPM 1.82E-07 25YrCancerDerived_InhSoilDerm * 1.82E-07 1801 ALL 563384.4 4226209 0.001951 9901 DieselExhPM 5.07E-07 25YrCancerDerived_InhSoilDerm * 5.07E-07 1802 ALL 563384.4 4226117 0.001662 9901 DieselExhPM 4.32E-07 25YrCancerDerived_InhSoilDerm * 4.32E-07 1803 ALL 563384.4 4226025 0.00141 9901 DieselExhPM 3.67E-07 25YrCancerDerived_InhSoilDerm * 3.67E-07 1804 ALL 563384.4 4225934 0.001211 9901 DieselExhPM 3.15E-07 25YrCancerDerived_InhSoilDerm * 3.15E-07 1805 ALL 563384.4 4225842 0.001053 9901 DieselExhPM 2.74E-07 25YrCancerDerived_InhSoilDerm * 2.74E-07 1806 ALL 563384.4 4225750 0.000931 9901 DieselExhPM 2.42E-07 25YrCancerDerived_InhSoilDerm * 2.42E-07 1807 ALL 563384.4 4225659 0.000832 9901 DieselExhPM 2.16E-07 25YrCancerDerived_InhSoilDerm * 2.16E-07 1808 ALL 563384.4 4225567 0.000749 9901 DieselExhPM 1.95E-07 25YrCancerDerived_InhSoilDerm * 1.95E-07 1809 ALL 563384.4 4225475 0.00068 9901 DieselExhPM 1.77E-07 25YrCancerDerived_InhSoilDerm * 1.77E-07

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1810 ALL 563285.9 4226209 0.001107 9901 DieselExhPM 2.88E-07 25YrCancerDerived_InhSoilDerm * 2.88E-07 1811 ALL 563285.9 4226117 0.001069 9901 DieselExhPM 2.78E-07 25YrCancerDerived_InhSoilDerm * 2.78E-07 1812 ALL 563285.9 4226025 0.001007 9901 DieselExhPM 2.62E-07 25YrCancerDerived_InhSoilDerm * 2.62E-07 1813 ALL 563285.9 4225934 0.000931 9901 DieselExhPM 2.42E-07 25YrCancerDerived_InhSoilDerm * 2.42E-07 1814 ALL 563285.9 4225842 0.000845 9901 DieselExhPM 2.20E-07 25YrCancerDerived_InhSoilDerm * 2.20E-07 1815 ALL 563285.9 4225750 0.000764 9901 DieselExhPM 1.99E-07 25YrCancerDerived_InhSoilDerm * 1.99E-07 1816 ALL 563285.9 4225659 0.000696 9901 DieselExhPM 1.81E-07 25YrCancerDerived_InhSoilDerm * 1.81E-07 1817 ALL 563285.9 4225567 0.00064 9901 DieselExhPM 1.66E-07 25YrCancerDerived_InhSoilDerm * 1.66E-07 1818 ALL 563285.9 4225475 0.000593 9901 DieselExhPM 1.54E-07 25YrCancerDerived_InhSoilDerm * 1.54E-07 1819 ALL 563187.5 4226209 0.00063 9901 DieselExhPM 1.64E-07 25YrCancerDerived_InhSoilDerm * 1.64E-07 1820 ALL 563187.5 4226117 0.000671 9901 DieselExhPM 1.75E-07 25YrCancerDerived_InhSoilDerm * 1.75E-07 1821 ALL 563187.5 4226025 0.000684 9901 DieselExhPM 1.78E-07 25YrCancerDerived_InhSoilDerm * 1.78E-07 1822 ALL 563187.5 4225934 0.000676 9901 DieselExhPM 1.76E-07 25YrCancerDerived_InhSoilDerm * 1.76E-07 1823 ALL 563187.5 4225842 0.000654 9901 DieselExhPM 1.70E-07 25YrCancerDerived_InhSoilDerm * 1.70E-07 1824 ALL 563187.5 4225750 0.000617 9901 DieselExhPM 1.60E-07 25YrCancerDerived_InhSoilDerm * 1.60E-07 1825 ALL 563187.5 4225659 0.000573 9901 DieselExhPM 1.49E-07 25YrCancerDerived_InhSoilDerm * 1.49E-07 1826 ALL 563187.5 4225567 0.00053 9901 DieselExhPM 1.38E-07 25YrCancerDerived_InhSoilDerm * 1.38E-07 1827 ALL 563187.5 4225475 0.000493 9901 DieselExhPM 1.28E-07 25YrCancerDerived_InhSoilDerm * 1.28E-07 1828 ALL 563089.1 4226209 0.00042 9901 DieselExhPM 1.09E-07 25YrCancerDerived_InhSoilDerm * 1.09E-07 1829 ALL 563089.1 4226117 0.000423 9901 DieselExhPM 1.10E-07 25YrCancerDerived_InhSoilDerm * 1.10E-07 1830 ALL 563089.1 4226025 0.000384 9901 DieselExhPM 9.99E-08 25YrCancerDerived_InhSoilDerm * 9.99E-08 1831 ALL 563089.1 4225934 0.000423 9901 DieselExhPM 1.10E-07 25YrCancerDerived_InhSoilDerm * 1.10E-07 1832 ALL 563089.1 4225842 0.000462 9901 DieselExhPM 1.20E-07 25YrCancerDerived_InhSoilDerm * 1.20E-07 1833 ALL 563089.1 4225750 0.000477 9901 DieselExhPM 1.24E-07 25YrCancerDerived_InhSoilDerm * 1.24E-07 1834 ALL 563089.1 4225659 0.000477 9901 DieselExhPM 1.24E-07 25YrCancerDerived_InhSoilDerm * 1.24E-07 1835 ALL 563089.1 4225567 0.000449 9901 DieselExhPM 1.17E-07 25YrCancerDerived_InhSoilDerm * 1.17E-07 1836 ALL 563089.1 4225475 0.00042 9901 DieselExhPM 1.09E-07 25YrCancerDerived_InhSoilDerm * 1.09E-07 1837 ALL 562990.6 4226209 0.000315 9901 DieselExhPM 8.18E-08 25YrCancerDerived_InhSoilDerm * 8.18E-08 1838 ALL 562990.6 4226117 0.000321 9901 DieselExhPM 8.33E-08 25YrCancerDerived_InhSoilDerm * 8.33E-08 1839 ALL 562990.6 4226025 0.000282 9901 DieselExhPM 7.33E-08 25YrCancerDerived_InhSoilDerm * 7.33E-08 1840 ALL 562990.6 4225934 0.00027 9901 DieselExhPM 7.03E-08 25YrCancerDerived_InhSoilDerm * 7.03E-08 1841 ALL 562990.6 4225842 0.000286 9901 DieselExhPM 7.42E-08 25YrCancerDerived_InhSoilDerm * 7.42E-08 1842 ALL 562990.6 4225750 0.000327 9901 DieselExhPM 8.50E-08 25YrCancerDerived_InhSoilDerm * 8.50E-08 1843 ALL 562990.6 4225659 0.000356 9901 DieselExhPM 9.25E-08 25YrCancerDerived_InhSoilDerm * 9.25E-08 1844 ALL 562990.6 4225567 0.00037 9901 DieselExhPM 9.63E-08 25YrCancerDerived_InhSoilDerm * 9.63E-08 1845 ALL 562990.6 4225475 0.000366 9901 DieselExhPM 9.51E-08 25YrCancerDerived_InhSoilDerm * 9.51E-08 1846 ALL 562892.2 4226209 0.000238 9901 DieselExhPM 6.18E-08 25YrCancerDerived_InhSoilDerm * 6.18E-08 1847 ALL 562892.2 4226117 0.00025 9901 DieselExhPM 6.49E-08 25YrCancerDerived_InhSoilDerm * 6.49E-08 1848 ALL 562892.2 4226025 0.000247 9901 DieselExhPM 6.43E-08 25YrCancerDerived_InhSoilDerm * 6.43E-08 1849 ALL 562892.2 4225934 0.000236 9901 DieselExhPM 6.15E-08 25YrCancerDerived_InhSoilDerm * 6.15E-08 1850 ALL 562892.2 4225842 0.00022 9901 DieselExhPM 5.72E-08 25YrCancerDerived_InhSoilDerm * 5.72E-08 1851 ALL 562892.2 4225750 0.000215 9901 DieselExhPM 5.59E-08 25YrCancerDerived_InhSoilDerm * 5.59E-08 1852 ALL 562892.2 4225659 0.000231 9901 DieselExhPM 6.01E-08 25YrCancerDerived_InhSoilDerm * 6.01E-08 1853 ALL 562892.2 4225567 0.00026 9901 DieselExhPM 6.77E-08 25YrCancerDerived_InhSoilDerm * 6.77E-08 1854 ALL 562892.2 4225475 0.000291 9901 DieselExhPM 7.56E-08 25YrCancerDerived_InhSoilDerm * 7.56E-08 1855 ALL 562793.8 4226209 0.00019 9901 DieselExhPM 4.94E-08 25YrCancerDerived_InhSoilDerm * 4.94E-08 1856 ALL 562793.8 4226117 0.000193 9901 DieselExhPM 5.02E-08 25YrCancerDerived_InhSoilDerm * 5.02E-08 1857 ALL 562793.8 4226025 0.000207 9901 DieselExhPM 5.37E-08 25YrCancerDerived_InhSoilDerm * 5.37E-08 1858 ALL 562793.8 4225934 0.000215 9901 DieselExhPM 5.59E-08 25YrCancerDerived_InhSoilDerm * 5.59E-08 1859 ALL 562793.8 4225842 0.000209 9901 DieselExhPM 5.43E-08 25YrCancerDerived_InhSoilDerm * 5.43E-08 1860 ALL 562793.8 4225750 0.000198 9901 DieselExhPM 5.15E-08 25YrCancerDerived_InhSoilDerm * 5.15E-08 1861 ALL 562793.8 4225659 0.000178 9901 DieselExhPM 4.63E-08 25YrCancerDerived_InhSoilDerm * 4.63E-08 1862 ALL 562793.8 4225567 0.00018 9901 DieselExhPM 4.68E-08 25YrCancerDerived_InhSoilDerm * 4.68E-08 1863 ALL 562793.8 4225475 0.000204 9901 DieselExhPM 5.29E-08 25YrCancerDerived_InhSoilDerm * 5.29E-08 1864 ALL 562695.3 4226209 0.000161 9901 DieselExhPM 4.17E-08 25YrCancerDerived_InhSoilDerm * 4.17E-08 1865 ALL 562695.3 4226117 0.000156 9901 DieselExhPM 4.05E-08 25YrCancerDerived_InhSoilDerm * 4.05E-08 1866 ALL 562695.3 4226025 0.000163 9901 DieselExhPM 4.24E-08 25YrCancerDerived_InhSoilDerm * 4.24E-08 1867 ALL 562695.3 4225934 0.000175 9901 DieselExhPM 4.55E-08 25YrCancerDerived_InhSoilDerm * 4.55E-08 1868 ALL 562695.3 4225842 0.000183 9901 DieselExhPM 4.76E-08 25YrCancerDerived_InhSoilDerm * 4.76E-08 1869 ALL 562695.3 4225750 0.000181 9901 DieselExhPM 4.70E-08 25YrCancerDerived_InhSoilDerm * 4.70E-08 1870 ALL 562695.3 4225659 0.000172 9901 DieselExhPM 4.47E-08 25YrCancerDerived_InhSoilDerm * 4.47E-08 1871 ALL 562695.3 4225567 0.000163 9901 DieselExhPM 4.24E-08 25YrCancerDerived_InhSoilDerm * 4.24E-08 1872 ALL 562695.3 4225475 0.000165 9901 DieselExhPM 4.30E-08 25YrCancerDerived_InhSoilDerm * 4.30E-08 1873 ALL 562596.9 4226209 0.00014 9901 DieselExhPM 3.65E-08 25YrCancerDerived_InhSoilDerm * 3.65E-08 1874 ALL 562596.9 4226117 0.000133 9901 DieselExhPM 3.45E-08 25YrCancerDerived_InhSoilDerm * 3.45E-08 1875 ALL 562596.9 4226025 0.000132 9901 DieselExhPM 3.44E-08 25YrCancerDerived_InhSoilDerm * 3.44E-08 1876 ALL 562596.9 4225934 0.000141 9901 DieselExhPM 3.65E-08 25YrCancerDerived_InhSoilDerm * 3.65E-08

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1877 ALL 562596.9 4225842 0.000152 9901 DieselExhPM 3.96E-08 25YrCancerDerived_InhSoilDerm * 3.96E-08 1878 ALL 562596.9 4225750 0.00016 9901 DieselExhPM 4.16E-08 25YrCancerDerived_InhSoilDerm * 4.16E-08 1879 ALL 562596.9 4225659 0.00016 9901 DieselExhPM 4.15E-08 25YrCancerDerived_InhSoilDerm * 4.15E-08 1880 ALL 562596.9 4225567 0.000153 9901 DieselExhPM 3.97E-08 25YrCancerDerived_InhSoilDerm * 3.97E-08 1881 ALL 562596.9 4225475 0.000142 9901 DieselExhPM 3.70E-08 25YrCancerDerived_InhSoilDerm * 3.70E-08 1882 ALL 562498.4 4226209 0.000125 9901 DieselExhPM 3.25E-08 25YrCancerDerived_InhSoilDerm * 3.25E-08 1883 ALL 562498.4 4226117 0.000117 9901 DieselExhPM 3.05E-08 25YrCancerDerived_InhSoilDerm * 3.05E-08 1884 ALL 562498.4 4226025 0.000113 9901 DieselExhPM 2.94E-08 25YrCancerDerived_InhSoilDerm * 2.94E-08 1885 ALL 562498.4 4225934 0.000115 9901 DieselExhPM 3.00E-08 25YrCancerDerived_InhSoilDerm * 3.00E-08 1886 ALL 562498.4 4225842 0.000124 9901 DieselExhPM 3.23E-08 25YrCancerDerived_InhSoilDerm * 3.23E-08 1887 ALL 562498.4 4225750 0.000135 9901 DieselExhPM 3.51E-08 25YrCancerDerived_InhSoilDerm * 3.51E-08 1888 ALL 562498.4 4225659 0.000142 9901 DieselExhPM 3.68E-08 25YrCancerDerived_InhSoilDerm * 3.68E-08 1889 ALL 562498.4 4225567 0.000142 9901 DieselExhPM 3.69E-08 25YrCancerDerived_InhSoilDerm * 3.69E-08 1890 ALL 562498.4 4225475 0.000136 9901 DieselExhPM 3.52E-08 25YrCancerDerived_InhSoilDerm * 3.52E-08 1891 ALL 562400 4226209 0.000113 9901 DieselExhPM 2.93E-08 25YrCancerDerived_InhSoilDerm * 2.93E-08 1892 ALL 562400 4226117 0.000105 9901 DieselExhPM 2.74E-08 25YrCancerDerived_InhSoilDerm * 2.74E-08 1893 ALL 562400 4226025 0.000101 9901 DieselExhPM 2.63E-08 25YrCancerDerived_InhSoilDerm * 2.63E-08 1894 ALL 562400 4225934 9.88E-05 9901 DieselExhPM 2.57E-08 25YrCancerDerived_InhSoilDerm * 2.57E-08 1895 ALL 562400 4225842 0.000103 9901 DieselExhPM 2.68E-08 25YrCancerDerived_InhSoilDerm * 2.68E-08 1896 ALL 562400 4225750 0.000111 9901 DieselExhPM 2.89E-08 25YrCancerDerived_InhSoilDerm * 2.89E-08 1897 ALL 562400 4225659 0.00012 9901 DieselExhPM 3.13E-08 25YrCancerDerived_InhSoilDerm * 3.13E-08 1898 ALL 562400 4225567 0.000127 9901 DieselExhPM 3.30E-08 25YrCancerDerived_InhSoilDerm * 3.30E-08 1899 ALL 562400 4225475 0.000128 9901 DieselExhPM 3.34E-08 25YrCancerDerived_InhSoilDerm * 3.34E-08 1900 ALL 563133.3 4226300 0.000497 9901 DieselExhPM 1.29E-07 25YrCancerDerived_InhSoilDerm * 1.29E-07 1901 ALL 563133.3 4226399 0.000531 9901 DieselExhPM 1.38E-07 25YrCancerDerived_InhSoilDerm * 1.38E-07 1902 ALL 563133.3 4226497 0.000831 9901 DieselExhPM 2.16E-07 25YrCancerDerived_InhSoilDerm * 2.16E-07 1903 ALL 563133.3 4226596 0.002327 9901 DieselExhPM 6.05E-07 25YrCancerDerived_InhSoilDerm * 6.05E-07 1904 ALL 563133.3 4226694 0.003923 9901 DieselExhPM 1.02E-06 25YrCancerDerived_InhSoilDerm * 1.02E-06 1905 ALL 563133.3 4226792 0.002944 9901 DieselExhPM 7.65E-07 25YrCancerDerived_InhSoilDerm * 7.65E-07 1906 ALL 563133.3 4226891 0.0015 9901 DieselExhPM 3.90E-07 25YrCancerDerived_InhSoilDerm * 3.90E-07 1907 ALL 563133.3 4226989 0.000774 9901 DieselExhPM 2.01E-07 25YrCancerDerived_InhSoilDerm * 2.01E-07 1908 ALL 563133.3 4227088 0.000462 9901 DieselExhPM 1.20E-07 25YrCancerDerived_InhSoilDerm * 1.20E-07 1909 ALL 563133.3 4227186 0.000348 9901 DieselExhPM 9.04E-08 25YrCancerDerived_InhSoilDerm * 9.04E-08 1910 ALL 563133.3 4227285 0.000295 9901 DieselExhPM 7.66E-08 25YrCancerDerived_InhSoilDerm * 7.66E-08 1911 ALL 563133.3 4227383 0.000266 9901 DieselExhPM 6.90E-08 25YrCancerDerived_InhSoilDerm * 6.90E-08 1912 ALL 563133.3 4227481 0.000243 9901 DieselExhPM 6.31E-08 25YrCancerDerived_InhSoilDerm * 6.31E-08 1913 ALL 563133.3 4227580 0.000221 9901 DieselExhPM 5.75E-08 25YrCancerDerived_InhSoilDerm * 5.75E-08 1914 ALL 563133.3 4227678 0.0002 9901 DieselExhPM 5.21E-08 25YrCancerDerived_InhSoilDerm * 5.21E-08 1915 ALL 563133.3 4227777 0.00018 9901 DieselExhPM 4.69E-08 25YrCancerDerived_InhSoilDerm * 4.69E-08 1916 ALL 563133.3 4227875 0.000159 9901 DieselExhPM 4.15E-08 25YrCancerDerived_InhSoilDerm * 4.15E-08 1917 ALL 563041.7 4226300 0.000364 9901 DieselExhPM 9.46E-08 25YrCancerDerived_InhSoilDerm * 9.46E-08 1918 ALL 563041.7 4226399 0.000405 9901 DieselExhPM 1.05E-07 25YrCancerDerived_InhSoilDerm * 1.05E-07 1919 ALL 563041.7 4226497 0.000694 9901 DieselExhPM 1.80E-07 25YrCancerDerived_InhSoilDerm * 1.80E-07 1920 ALL 563041.7 4226596 0.001742 9901 DieselExhPM 4.53E-07 25YrCancerDerived_InhSoilDerm * 4.53E-07 1921 ALL 563041.7 4226694 0.002779 9901 DieselExhPM 7.22E-07 25YrCancerDerived_InhSoilDerm * 7.22E-07 1922 ALL 563041.7 4226792 0.002279 9901 DieselExhPM 5.92E-07 25YrCancerDerived_InhSoilDerm * 5.92E-07 1923 ALL 563041.7 4226891 0.001352 9901 DieselExhPM 3.51E-07 25YrCancerDerived_InhSoilDerm * 3.51E-07 1924 ALL 563041.7 4226989 0.000782 9901 DieselExhPM 2.03E-07 25YrCancerDerived_InhSoilDerm * 2.03E-07 1925 ALL 563041.7 4227088 0.000441 9901 DieselExhPM 1.15E-07 25YrCancerDerived_InhSoilDerm * 1.15E-07 1926 ALL 563041.7 4227186 0.000296 9901 DieselExhPM 7.70E-08 25YrCancerDerived_InhSoilDerm * 7.70E-08 1927 ALL 563041.7 4227285 0.00024 9901 DieselExhPM 6.24E-08 25YrCancerDerived_InhSoilDerm * 6.24E-08 1928 ALL 563041.7 4227383 0.000209 9901 DieselExhPM 5.43E-08 25YrCancerDerived_InhSoilDerm * 5.43E-08 1929 ALL 563041.7 4227481 0.000192 9901 DieselExhPM 5.00E-08 25YrCancerDerived_InhSoilDerm * 5.00E-08 1930 ALL 563041.7 4227580 0.000182 9901 DieselExhPM 4.73E-08 25YrCancerDerived_InhSoilDerm * 4.73E-08 1931 ALL 563041.7 4227678 0.000171 9901 DieselExhPM 4.44E-08 25YrCancerDerived_InhSoilDerm * 4.44E-08 1932 ALL 563041.7 4227777 0.000161 9901 DieselExhPM 4.18E-08 25YrCancerDerived_InhSoilDerm * 4.18E-08 1933 ALL 563041.7 4227875 0.000149 9901 DieselExhPM 3.88E-08 25YrCancerDerived_InhSoilDerm * 3.88E-08 1934 ALL 562950 4226300 0.000279 9901 DieselExhPM 7.26E-08 25YrCancerDerived_InhSoilDerm * 7.26E-08 1935 ALL 562950 4226399 0.000336 9901 DieselExhPM 8.74E-08 25YrCancerDerived_InhSoilDerm * 8.74E-08 1936 ALL 562950 4226497 0.000602 9901 DieselExhPM 1.56E-07 25YrCancerDerived_InhSoilDerm * 1.56E-07 1937 ALL 562950 4226596 0.001359 9901 DieselExhPM 3.53E-07 25YrCancerDerived_InhSoilDerm * 3.53E-07 1938 ALL 562950 4226694 0.002059 9901 DieselExhPM 5.35E-07 25YrCancerDerived_InhSoilDerm * 5.35E-07 1939 ALL 562950 4226792 0.001817 9901 DieselExhPM 4.72E-07 25YrCancerDerived_InhSoilDerm * 4.72E-07 1940 ALL 562950 4226891 0.001164 9901 DieselExhPM 3.03E-07 25YrCancerDerived_InhSoilDerm * 3.03E-07 1941 ALL 562950 4226989 0.000761 9901 DieselExhPM 1.98E-07 25YrCancerDerived_InhSoilDerm * 1.98E-07 1942 ALL 562950 4227088 0.000459 9901 DieselExhPM 1.19E-07 25YrCancerDerived_InhSoilDerm * 1.19E-07 1943 ALL 562950 4227186 0.000278 9901 DieselExhPM 7.23E-08 25YrCancerDerived_InhSoilDerm * 7.23E-08

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 1944 ALL 562950 4227285 0.000206 9901 DieselExhPM 5.35E-08 25YrCancerDerived_InhSoilDerm * 5.35E-08 1945 ALL 562950 4227383 0.000171 9901 DieselExhPM 4.45E-08 25YrCancerDerived_InhSoilDerm * 4.45E-08 1946 ALL 562950 4227481 0.000157 9901 DieselExhPM 4.08E-08 25YrCancerDerived_InhSoilDerm * 4.08E-08 1947 ALL 562950 4227580 0.000148 9901 DieselExhPM 3.85E-08 25YrCancerDerived_InhSoilDerm * 3.85E-08 1948 ALL 562950 4227678 0.00014 9901 DieselExhPM 3.65E-08 25YrCancerDerived_InhSoilDerm * 3.65E-08 1949 ALL 562950 4227777 0.000135 9901 DieselExhPM 3.51E-08 25YrCancerDerived_InhSoilDerm * 3.51E-08 1950 ALL 562950 4227875 0.000131 9901 DieselExhPM 3.40E-08 25YrCancerDerived_InhSoilDerm * 3.40E-08 1951 ALL 562858.3 4226300 0.00023 9901 DieselExhPM 5.97E-08 25YrCancerDerived_InhSoilDerm * 5.97E-08 1952 ALL 562858.3 4226399 0.000291 9901 DieselExhPM 7.57E-08 25YrCancerDerived_InhSoilDerm * 7.57E-08 1953 ALL 562858.3 4226497 0.00053 9901 DieselExhPM 1.38E-07 25YrCancerDerived_InhSoilDerm * 1.38E-07 1954 ALL 562858.3 4226596 0.001093 9901 DieselExhPM 2.84E-07 25YrCancerDerived_InhSoilDerm * 2.84E-07 1955 ALL 562858.3 4226694 0.001596 9901 DieselExhPM 4.15E-07 25YrCancerDerived_InhSoilDerm * 4.15E-07 1956 ALL 562858.3 4226792 0.001476 9901 DieselExhPM 3.84E-07 25YrCancerDerived_InhSoilDerm * 3.84E-07 1957 ALL 562858.3 4226891 0.001008 9901 DieselExhPM 2.62E-07 25YrCancerDerived_InhSoilDerm * 2.62E-07 1958 ALL 562858.3 4226989 0.000704 9901 DieselExhPM 1.83E-07 25YrCancerDerived_InhSoilDerm * 1.83E-07 1959 ALL 562858.3 4227088 0.000479 9901 DieselExhPM 1.24E-07 25YrCancerDerived_InhSoilDerm * 1.24E-07 1960 ALL 562858.3 4227186 0.000288 9901 DieselExhPM 7.47E-08 25YrCancerDerived_InhSoilDerm * 7.47E-08 1961 ALL 562858.3 4227285 0.000193 9901 DieselExhPM 5.01E-08 25YrCancerDerived_InhSoilDerm * 5.01E-08 1962 ALL 562858.3 4227383 0.000155 9901 DieselExhPM 4.04E-08 25YrCancerDerived_InhSoilDerm * 4.04E-08 1963 ALL 562858.3 4227481 0.000135 9901 DieselExhPM 3.52E-08 25YrCancerDerived_InhSoilDerm * 3.52E-08 1964 ALL 562858.3 4227580 0.000124 9901 DieselExhPM 3.23E-08 25YrCancerDerived_InhSoilDerm * 3.23E-08 1965 ALL 562858.3 4227678 0.000118 9901 DieselExhPM 3.06E-08 25YrCancerDerived_InhSoilDerm * 3.06E-08 1966 ALL 562858.3 4227777 0.000113 9901 DieselExhPM 2.95E-08 25YrCancerDerived_InhSoilDerm * 2.95E-08 1967 ALL 562858.3 4227875 0.000111 9901 DieselExhPM 2.87E-08 25YrCancerDerived_InhSoilDerm * 2.87E-08 1968 ALL 562766.7 4226300 0.000198 9901 DieselExhPM 5.15E-08 25YrCancerDerived_InhSoilDerm * 5.15E-08 1969 ALL 562766.7 4226399 0.00026 9901 DieselExhPM 6.75E-08 25YrCancerDerived_InhSoilDerm * 6.75E-08 1970 ALL 562766.7 4226497 0.000472 9901 DieselExhPM 1.23E-07 25YrCancerDerived_InhSoilDerm * 1.23E-07 1971 ALL 562766.7 4226596 0.0009 9901 DieselExhPM 2.34E-07 25YrCancerDerived_InhSoilDerm * 2.34E-07 1972 ALL 562766.7 4226694 0.001266 9901 DieselExhPM 3.29E-07 25YrCancerDerived_InhSoilDerm * 3.29E-07 1973 ALL 562766.7 4226792 0.001225 9901 DieselExhPM 3.18E-07 25YrCancerDerived_InhSoilDerm * 3.18E-07 1974 ALL 562766.7 4226891 0.000877 9901 DieselExhPM 2.28E-07 25YrCancerDerived_InhSoilDerm * 2.28E-07 1975 ALL 562766.7 4226989 0.00063 9901 DieselExhPM 1.64E-07 25YrCancerDerived_InhSoilDerm * 1.64E-07 1976 ALL 562766.7 4227088 0.00048 9901 DieselExhPM 1.25E-07 25YrCancerDerived_InhSoilDerm * 1.25E-07 1977 ALL 562766.7 4227186 0.000313 9901 DieselExhPM 8.12E-08 25YrCancerDerived_InhSoilDerm * 8.12E-08 1978 ALL 562766.7 4227285 0.000197 9901 DieselExhPM 5.11E-08 25YrCancerDerived_InhSoilDerm * 5.11E-08 1979 ALL 562766.7 4227383 0.000146 9901 DieselExhPM 3.80E-08 25YrCancerDerived_InhSoilDerm * 3.80E-08 1980 ALL 562766.7 4227481 0.000124 9901 DieselExhPM 3.23E-08 25YrCancerDerived_InhSoilDerm * 3.23E-08 1981 ALL 562766.7 4227580 0.00011 9901 DieselExhPM 2.87E-08 25YrCancerDerived_InhSoilDerm * 2.87E-08 1982 ALL 562766.7 4227678 0.000101 9901 DieselExhPM 2.63E-08 25YrCancerDerived_InhSoilDerm * 2.63E-08 1983 ALL 562766.7 4227777 9.67E-05 9901 DieselExhPM 2.51E-08 25YrCancerDerived_InhSoilDerm * 2.51E-08 1984 ALL 562766.7 4227875 9.49E-05 9901 DieselExhPM 2.47E-08 25YrCancerDerived_InhSoilDerm * 2.47E-08 1985 ALL 562675 4226300 0.000174 9901 DieselExhPM 4.52E-08 25YrCancerDerived_InhSoilDerm * 4.52E-08 1986 ALL 562675 4226399 0.000237 9901 DieselExhPM 6.15E-08 25YrCancerDerived_InhSoilDerm * 6.15E-08 1987 ALL 562675 4226497 0.000425 9901 DieselExhPM 1.10E-07 25YrCancerDerived_InhSoilDerm * 1.10E-07 1988 ALL 562675 4226596 0.000758 9901 DieselExhPM 1.97E-07 25YrCancerDerived_InhSoilDerm * 1.97E-07 1989 ALL 562675 4226694 0.001033 9901 DieselExhPM 2.68E-07 25YrCancerDerived_InhSoilDerm * 2.68E-07 1990 ALL 562675 4226792 0.001033 9901 DieselExhPM 2.68E-07 25YrCancerDerived_InhSoilDerm * 2.68E-07 1991 ALL 562675 4226891 0.000774 9901 DieselExhPM 2.01E-07 25YrCancerDerived_InhSoilDerm * 2.01E-07 1992 ALL 562675 4226989 0.000555 9901 DieselExhPM 1.44E-07 25YrCancerDerived_InhSoilDerm * 1.44E-07 1993 ALL 562675 4227088 0.000455 9901 DieselExhPM 1.18E-07 25YrCancerDerived_InhSoilDerm * 1.18E-07 1994 ALL 562675 4227186 0.000336 9901 DieselExhPM 8.72E-08 25YrCancerDerived_InhSoilDerm * 8.72E-08 1995 ALL 562675 4227285 0.000215 9901 DieselExhPM 5.58E-08 25YrCancerDerived_InhSoilDerm * 5.58E-08 1996 ALL 562675 4227383 0.000145 9901 DieselExhPM 3.78E-08 25YrCancerDerived_InhSoilDerm * 3.78E-08 1997 ALL 562675 4227481 0.000117 9901 DieselExhPM 3.04E-08 25YrCancerDerived_InhSoilDerm * 3.04E-08 1998 ALL 562675 4227580 0.000102 9901 DieselExhPM 2.66E-08 25YrCancerDerived_InhSoilDerm * 2.66E-08 1999 ALL 562675 4227678 9.03E-05 9901 DieselExhPM 2.35E-08 25YrCancerDerived_InhSoilDerm * 2.35E-08 2000 ALL 562675 4227777 8.21E-05 9901 DieselExhPM 2.13E-08 25YrCancerDerived_InhSoilDerm * 2.13E-08 2001 ALL 562675 4227875 7.99E-05 9901 DieselExhPM 2.08E-08 25YrCancerDerived_InhSoilDerm * 2.08E-08 2002 ALL 562583.3 4226300 0.000157 9901 DieselExhPM 4.07E-08 25YrCancerDerived_InhSoilDerm * 4.07E-08 2003 ALL 562583.3 4226399 0.000219 9901 DieselExhPM 5.69E-08 25YrCancerDerived_InhSoilDerm * 5.69E-08 2004 ALL 562583.3 4226497 0.000385 9901 DieselExhPM 1.00E-07 25YrCancerDerived_InhSoilDerm * 1.00E-07 2005 ALL 562583.3 4226596 0.000648 9901 DieselExhPM 1.69E-07 25YrCancerDerived_InhSoilDerm * 1.69E-07 2006 ALL 562583.3 4226694 0.00086 9901 DieselExhPM 2.23E-07 25YrCancerDerived_InhSoilDerm * 2.23E-07 2007 ALL 562583.3 4226792 0.000882 9901 DieselExhPM 2.29E-07 25YrCancerDerived_InhSoilDerm * 2.29E-07 2008 ALL 562583.3 4226891 0.000691 9901 DieselExhPM 1.80E-07 25YrCancerDerived_InhSoilDerm * 1.80E-07 2009 ALL 562583.3 4226989 0.000495 9901 DieselExhPM 1.29E-07 25YrCancerDerived_InhSoilDerm * 1.29E-07 2010 ALL 562583.3 4227088 0.000414 9901 DieselExhPM 1.08E-07 25YrCancerDerived_InhSoilDerm * 1.08E-07

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*HARP - HRACalc v22118 11/21/2023 4:17:32 AM - Cancer Risk - Input File: F:\Jobs\56390001\HARP\RESIDENT\hra\Commerce220WorkerHRAInput.hra REC GRP NETID X Y CONC POLID POLABBREV RISK_SUM SCENARIO DETAILS INH_RISK 2011 ALL 562583.3 4227186 0.000343 9901 DieselExhPM 8.90E-08 25YrCancerDerived_InhSoilDerm * 8.90E-08 2012 ALL 562583.3 4227285 0.000236 9901 DieselExhPM 6.14E-08 25YrCancerDerived_InhSoilDerm * 6.14E-08 2013 ALL 562583.3 4227383 0.000153 9901 DieselExhPM 3.97E-08 25YrCancerDerived_InhSoilDerm * 3.97E-08 2014 ALL 562583.3 4227481 0.000113 9901 DieselExhPM 2.93E-08 25YrCancerDerived_InhSoilDerm * 2.93E-08 2015 ALL 562583.3 4227580 9.62E-05 9901 DieselExhPM 2.50E-08 25YrCancerDerived_InhSoilDerm * 2.50E-08 2016 ALL 562583.3 4227678 8.58E-05 9901 DieselExhPM 2.23E-08 25YrCancerDerived_InhSoilDerm * 2.23E-08 2017 ALL 562583.3 4227777 7.73E-05 9901 DieselExhPM 2.01E-08 25YrCancerDerived_InhSoilDerm * 2.01E-08 2018 ALL 562583.3 4227875 7.17E-05 9901 DieselExhPM 1.86E-08 25YrCancerDerived_InhSoilDerm * 1.86E-08 2019 ALL 562491.7 4226300 0.000143 9901 DieselExhPM 3.73E-08 25YrCancerDerived_InhSoilDerm * 3.73E-08 2020 ALL 562491.7 4226399 0.000205 9901 DieselExhPM 5.32E-08 25YrCancerDerived_InhSoilDerm * 5.32E-08 2021 ALL 562491.7 4226497 0.000351 9901 DieselExhPM 9.12E-08 25YrCancerDerived_InhSoilDerm * 9.12E-08 2022 ALL 562491.7 4226596 0.000562 9901 DieselExhPM 1.46E-07 25YrCancerDerived_InhSoilDerm * 1.46E-07 2023 ALL 562491.7 4226694 0.000728 9901 DieselExhPM 1.89E-07 25YrCancerDerived_InhSoilDerm * 1.89E-07 2024 ALL 562491.7 4226792 0.000762 9901 DieselExhPM 1.98E-07 25YrCancerDerived_InhSoilDerm * 1.98E-07 2025 ALL 562491.7 4226891 0.000624 9901 DieselExhPM 1.62E-07 25YrCancerDerived_InhSoilDerm * 1.62E-07 2026 ALL 562491.7 4226989 0.000448 9901 DieselExhPM 1.16E-07 25YrCancerDerived_InhSoilDerm * 1.16E-07 2027 ALL 562491.7 4227088 0.000368 9901 DieselExhPM 9.58E-08 25YrCancerDerived_InhSoilDerm * 9.58E-08 2028 ALL 562491.7 4227186 0.000329 9901 DieselExhPM 8.55E-08 25YrCancerDerived_InhSoilDerm * 8.55E-08 2029 ALL 562491.7 4227285 0.000253 9901 DieselExhPM 6.57E-08 25YrCancerDerived_InhSoilDerm * 6.57E-08 2030 ALL 562491.7 4227383 0.000169 9901 DieselExhPM 4.40E-08 25YrCancerDerived_InhSoilDerm * 4.40E-08 2031 ALL 562491.7 4227481 0.000116 9901 DieselExhPM 3.01E-08 25YrCancerDerived_InhSoilDerm * 3.01E-08 2032 ALL 562491.7 4227580 9.17E-05 9901 DieselExhPM 2.38E-08 25YrCancerDerived_InhSoilDerm * 2.38E-08 2033 ALL 562491.7 4227678 8.14E-05 9901 DieselExhPM 2.12E-08 25YrCancerDerived_InhSoilDerm * 2.12E-08 2034 ALL 562491.7 4227777 7.38E-05 9901 DieselExhPM 1.92E-08 25YrCancerDerived_InhSoilDerm * 1.92E-08 2035 ALL 562491.7 4227875 6.68E-05 9901 DieselExhPM 1.74E-08 25YrCancerDerived_InhSoilDerm * 1.74E-08 2036 ALL 562400 4226300 0.000133 9901 DieselExhPM 3.46E-08 25YrCancerDerived_InhSoilDerm * 3.46E-08 2037 ALL 562400 4226399 0.000193 9901 DieselExhPM 5.01E-08 25YrCancerDerived_InhSoilDerm * 5.01E-08 2038 ALL 562400 4226497 0.000321 9901 DieselExhPM 8.35E-08 25YrCancerDerived_InhSoilDerm * 8.35E-08 2039 ALL 562400 4226596 0.000493 9901 DieselExhPM 1.28E-07 25YrCancerDerived_InhSoilDerm * 1.28E-07 2040 ALL 562400 4226694 0.000626 9901 DieselExhPM 1.63E-07 25YrCancerDerived_InhSoilDerm * 1.63E-07 2041 ALL 562400 4226792 0.000664 9901 DieselExhPM 1.73E-07 25YrCancerDerived_InhSoilDerm * 1.73E-07 2042 ALL 562400 4226891 0.000567 9901 DieselExhPM 1.47E-07 25YrCancerDerived_InhSoilDerm * 1.47E-07 2043 ALL 562400 4226989 0.000412 9901 DieselExhPM 1.07E-07 25YrCancerDerived_InhSoilDerm * 1.07E-07 2044 ALL 562400 4227088 0.000329 9901 DieselExhPM 8.54E-08 25YrCancerDerived_InhSoilDerm * 8.54E-08 2045 ALL 562400 4227186 0.000303 9901 DieselExhPM 7.89E-08 25YrCancerDerived_InhSoilDerm * 7.89E-08 2046 ALL 562400 4227285 0.00026 9901 DieselExhPM 6.77E-08 25YrCancerDerived_InhSoilDerm * 6.77E-08 2047 ALL 562400 4227383 0.000188 9901 DieselExhPM 4.88E-08 25YrCancerDerived_InhSoilDerm * 4.88E-08 2048 ALL 562400 4227481 0.000126 9901 DieselExhPM 3.28E-08 25YrCancerDerived_InhSoilDerm * 3.28E-08 2049 ALL 562400 4227580 9.18E-05 9901 DieselExhPM 2.39E-08 25YrCancerDerived_InhSoilDerm * 2.39E-08 2050 ALL 562400 4227678 7.72E-05 9901 DieselExhPM 2.01E-08 25YrCancerDerived_InhSoilDerm * 2.01E-08 2051 ALL 562400 4227777 7.05E-05 9901 DieselExhPM 1.83E-08 25YrCancerDerived_InhSoilDerm * 1.83E-08 2052 ALL 562400 4227875 6.45E-05 9901 DieselExhPM 1.68E-08 25YrCancerDerived_InhSoilDerm * 1.68E-08

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UTMX UTMY Road Cancer Risk Road Chronic HI Road PM2.5 Rail Cancer Risk Rail Chronic HI Rail PM2.5 563979 4226674 1.1926866 0.003058275 0.025068535 -3.40E+38 -3.40E+38 -3.40E+38 BAAQMD Stationary Source Screening Risk Output

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11/21/23, 2:35 AM about:blank
about:blank 1/2
Screening Report
Area of Interest (AOI) Information
Area : 6,010,163.38 ft²
Nov 21 2023 2:35:31 Pacific Standard Time

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about:blank 2/2
Summary
Name Count Area(ft²) Length(ft)
Permitted Stationary Sources 0 N/A N/A
NOTE: A larger buffer than 1000 feet may be warranted depending on proximity to significant sources.

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Commerce 220 Warehouse Distribution Project
Summary of Energy Use During Construction
Construction equipment fuel 32,838 gallons (diesel)
Construction vehicle fuel 29,325 gallons (gasoline, diesel) Total construction fuel 62,162 gallons (gasoline, diesel) Summary of Energy Use During Construction - Electicity
Year kWh per Year
2025 0
Summary of Annual Energy Use During Operations (2025)
Operation vehicle fuel 42,129 gallons Gasoline
249,798 gallons Diesel
13,980 gallons Natural Gas
35,233 kw-hours Electricity
Operational Building Energy
Operation natural gas 0 MMBtu
Operation electricity 659,500 kw-hours

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SDG Commerce 220 Warehouse Distribution Project
Phase Name Equipment Type Fuel Type
Number
per Day
Hours Per
Day Horsepower Load Factor PhaseDays Fuel Consumption
Site Preparation Rubber Tired Dozers Diesel 3 8 367 0.4 10 1903 Site Preparation Tractors/Loaders/Backhoes Diesel 4 8 84 0.37 10 537 Grading Excavators Diesel 2 8 158 0.38 20 1037
Grading Graders Diesel 1 8 148 0.41 20 524
Grading Rubber Tired Dozers Diesel 1 8 367 0.4 20 1268
Grading Scrapers Diesel 2 8 423 0.48 20 3509
Grading Tractors/Loaders/Backhoes Diesel 2 8 84 0.37 20 537 Building Construction Cranes Diesel 1 7 367 0.29 200 8046 Building Construction Forklifts Diesel 3 8 82 0.2 200 4251 Building Construction Generator Sets Diesel 1 8 14 0.74 200 895 Building Construction Tractors/Loaders/Backhoes Diesel 3 7 84 0.37 200 7049 Building Construction Welders Diesel 1 8 46 0.45 200 1788 Paving Pavers Diesel 2 8 81 0.42 20 588
Paving Paving Equipment Diesel 2 8 89 0.36 20 554
Paving Rollers Diesel 2 8 36 0.38 20 236
Architectural Coating Air Compressors Diesel 1 6 37 0.48 20 115 32,837.8
ARB 2021, Low Emission Diesel (LED) Study: Biodiesel and Renewable Diesel Emissions in Legacy and New Technology Diesel Engines, November 2021 Average Value for CARB Reference Fuel - Nonroad Transient Cycle - BSFC = 0.054 gal/bhp-hr

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SDG Commerce 220 Warehouse Distribution Project
`
Vehicle Type Total VMT (mi) mi/gal gal Vehicle Cat
Worker 347,011 26.30 13,194 LDA,LDT1,LDT2
Vendor 92,504 6.76 13,685 HHDT,MHDT
Hauling 14,100 5.76 2,446 HHDT
Onsite truck 0 5.76 0 HHDT
453,615 29,325 gallons
Combined VMT
Note: Fuel Economy Factors are from EMFAC2021 for: 2024 Napa Energy Calculations - Construction Vehicle Fuel

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SDG Commerce 220 Warehouse Distribution Project
Operational Year 2025
County Napa
Building Energy Fuel Electricity (kWh/yr) Natural Gas (MMBTU/yr) Refrigerated Warehouse-No Rail 659500 0
Total Building Energy 659,500 0
Energy Calculations - Building Electricity Consumption

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SDG Commerce 220 Warehouse Distribution Project
Energy Calculations
Onroad Mobile Sources `
Operational Year 2025
County Napa
Gasoline 42,129 gallons
Diesel 249,798 gallons
Natural Gas 13,980 gallons
Electricity 35,233 kw-hr

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SDG Commerce 220 Warehouse Distribution Project
`
Total Operational FUEL Consumption for ALL LAND USES (gallons for fuels, Kw-hr for electricity) Fuel All Vehicles HHDT LDA LDT1 LDT2 LHD1 LHD2 MCY MDV MH MHDT OBUS SBUS UBUS Gasoline 42,129 291 13762 1994 8965 0 0 0 7811 0 9307 0 0 0 Diesel 249,798 226317 27 0 28 0 0 0 121 0 23303 0 0 0
Natural Gas 13,980 13609 0 0 0 0 0 0 0 0 371 0 0 0
Electricity 35,233 16771 14646 78 809 0 0 0 801 0 2129 0 0 0 Trucks
Refrigerated Warehouse-No Rail Tota Consumption by Vehicle Category Fuel Units HHDT LDA LDT1 LDT2 LHD1 LHD2 MCY MDV MH MHDT OBUS SBUS UBUS Gasoline gal 291 0 0 0 0 0 0 0 0 9307 0 0 0
Diesel gal 226317 0 0 0 0 0 0 0 0 23303 0 0 0
Natural Gas gal 13609 0 0 0 0 0 0 0 0 371 0 0 0
Plug-in Hybrid gal 0 0 0 0 0 0 0 0 0 0 0 0 0
Electricity kwhr 16771 0 0 0 0 0 0 0 0 2129 0 0 0
Plug-in Hybrid kwhr 0 0 0 0 0 0 0 0 0 0 0 0 0
Passenger Vehicles
User Defined Industrial Total Consumption by Vehicle Category Fuel Units HHDT LDA LDT1 LDT2 LHD1 LHD2 MCY MDV MH MHDT OBUS SBUS UBUS Gasoline gal 0 13511 1993 8939 0 0 0 7794 0 0 0 0 0
Diesel gal 0 27 0 28 0 0 0 121 0 0 0 0 0
Natural Gas gal 0 0 0 0 0 0 0 0 0 0 0 0 0
Plug-in Hybrid gal 0 252 1 26 0 0 0 16 0 0 0 0 0
Electricity kwhr 0 12743 64 525 0 0 0 602 0 0 0 0 0
Plug-in Hybrid kwhr 0 1903 13 284 0 0 0 198 0 0 0 0 0
Land Use Type Season Annual VMT HHDT% LDA% LDT1% LDT2% LHD1% LHD2% MCY% MDV% MH% MHDT% OBUS% SBUS% UBUS% Refrigerated Warehouse-No Rail Annual 1,656,783 85.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 14.9% 0.0% 0.0% 0.0% User Defined Industrial Annual 911,332 0.0% 51.6% 5.6% 24.9% 0.0% 0.0% 0.0% 17.9% 0.0% 0.0% 0.0% 0.0% 0.0% Region Year County-Specific Fuel Economy (gal/mi)
Napa 2025 Fuel HHDT LDA LDT1 LDT2 LHDT1 LHDT2 MCY MDV MH MHDT OBUS SBUS UBUS Napa 2025 Gasoline 0.2882 0.0320 0.0393 0.0401 0.1065 0.1206 0.0242 0.0495 0.2263 0.2111 0.2083 0.0992 0.1490 Napa 2025 Diesel 0.1703 0.0231 0.0401 0.0307 0.0636 0.0771 0.0403 0.1065 0.1176 0.1376 0.1231 0.1167 Napa 2025 Natural Gas 0.1928 0.1384 0.1302 0.1833 0.1286 Napa 2025 Plug-in Hybrid 0.0334 0.0336 0.0338 0.0342
Region Year County-Specific Electric Car Economy (kw-hr/mi) Napa 2025 Fuel HHDT LDA LDT1 LDT2 LHD1 LHD2 MCY MDV MH MHDT OBUS SBUS UBUS Napa 2025 Electricity 1.8515 0.3861 0.3861 0.3861 0.3861 1.0947 1.1078 1.0535 Napa 2025 Plug-in Hybrid 0.3020 0.3020 0.3020 0.3020
Fossil Fuel Consumption - weighted by EMFAC Vehicle Type and Fuel Region Year Fuel HHDT LDA LDT1 LDT2 LHDT1 LHDT2 MCY MDV MH MHDT OBUS SBUS UBUS Napa 2025 CVMT Fraction 0.9936 0.9164 0.9959 0.9899 0.9947 0.9949 1.0000 0.9864 1.0000 0.9921 0.9983 0.9952 1.0000 Napa 2025 Gasoline 0.0007 0.9798 0.9991 0.9924 0.6488 0.3416 1.0000 0.9783 0.8110 0.1800 0.6095 0.1692 0.3846 Napa 2025 Diesel 0.9489 0.0027 0.0002 0.0041 0.3512 0.6584 0.0000 0.0187 0.1890 0.8090 0.3884 0.7705 0.5159 Napa 2025 Natural Gas 0.0504 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0109 0.0020 0.0603 0.0995 Napa 2025 Plug-in Hybrid 0.0000 0.0175 0.0007 0.0034 0.0000 0.0000 0.0000 0.0030 0.0000 0.0000 0.0000 0.0000 0.0000

1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 Electricity Factors (mi/kw-hr) - Weighted by EMFAC Vehicle Type and Fuel Type Region Year Fuel HHDT LDA LDT1 LDT2 LHDT1 LHDT2 MCY MDV MH MHDT OBUS SBUS UBUS Napa 2025 EVMT Fraction 0.0064 0.0836 0.0041 0.0101 0.0053 0.0051 0.0000 0.0136 0.0000 0.0079 0.0017 0.0048 0.0000 Napa 2025 Electricity 1.0000 0.8397 0.7930 0.5913 1.0000 1.0000 0.7038 1.0000 1.0000 1.0000 Napa 2025 Plug-in Hybrid 0.0000 0.1603 0.2070 0.4087 0.0000 0.0000 0.2962 0.0000 0.0000 0.0000 0 0 0 0 1 1 1 0
Energy Calculations - Operations Fuel Use from Mobile Sources

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Commerce 220 Warehouse Distribution Project
On-Site PV Solar GHG Calculations
Electricity GHG Emissions Intensity3 COe Emissions CO2e Emissions MWh/yr lb CO2e/MWhr kg/yr MT/yr
Consumption1
659.5 98 29378 29.4
Avoided Emissions from
Onsite Production2
235.204 98 10477 -10.5
Net Facility Consumption 18.9
Notes:
3) PG&E GHG Emissions Intensity Factor for 2021.
2) Energy production on-site based on applicant provided information. DC System Size: 144.72 kW , CEC AC System Size: 134.13 kW with estimated Annual System Production 235,204 kWh 1) Energy Consumption estimated from SDG Commerce 217 Warehouse energy consumption value of 3.0 (kw-hr/ft2).

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Commerce 220 Warehouse Distribution Project
Operational Mobile Sources
Future Project Energy Projections (2030 and 2040)

LDV HHDT MHDT LDV HHDT MHDT
Total VMT/year 911,332 1,409,923 246,861 Total VMT/year 911,332 1,409,923 246,861 % ZEV 28% 10% 5% VMT and Fuel % ZEV 28% 25% 42% VMT and Fuel CVMT - NG Annual 634,465 - CVMT - NG Annual 528,721 -
CVMT - Diesel 634,465 234,518 CVMT - Diesel 528,721 143,994 CVMT - Gasoline 656,159 CVMT - Gasoline 656,159
EVMT - Annual 255,173 140,992 12,343 EVMT - Annual 255,173 352,481 102,867 Gasoline (gal) 23,727 - - 23,727 Gasoline (gal) 23,727 - - 23,727 Diesel (gal) - 100,091 26,935 127,026 Diesel (gal) - 83,409 16,538 99,947 Natural Gas (gal) - 119,709 - 119,709 Natural Gas (gal) - 99,758 - 99,758 Electricity kw-hr 98,518 261,254 13,399 373,170 Electricity kw-hr 98,518 653,134 111,666 863,318 Assumes that LDV follow Statewide MSS Projections from Vision Model. Assumes that LDV follow Statewide MSS Projections from Vision Model.

Assumes that MHDT follow MSS Strategy Projections for (State, SC or SJV) Assumes that MHDT are box trucks and are Milestone Group 1.

Assumes that HHDT follow MSS Strategy Projections for (State, SC or SJV) Assumes that HHDT are day cab trucks complying with Milestone Group 2 Timeline.

LDV HHDT MHDT LDT1 HHDT MHDT
Gasoline (gal/mi) 0.0362 Gasoline (gal/mi) 0.0362
Diesel (gal/mi) 0.1578 0.1149 Diesel (gal/mi) 0.1578 0.1149 Natural Gas (gal/mi) 0.1887 Natural Gas (gal/mi) 0.1887 kw-hr /mi 0.3861 1.8530 1.0855 kw-hr /mi 0.3861 1.8530 1.0855 LDV HHDT MHDT LDT1 HHDT MHDT
Total VMT/year 911,332 1,409,923 246,861 Total VMT/year 911,332 1,409,923 246,861 % ZEV 85% 65% 65% VMT and Fuel % ZEV 85% 100% 100%
CVMT - NG Annual 246,736 - CVMT - NG Annual - -
CVMT - Diesel 246,736 86,401 CVMT - Diesel - -
CVMT - Gasoline 136,700 CVMT - Gasoline 136,700
EVMT - Annual 774,632 916,450 160,459 EVMT - Annual 774,632 1,409,923 246,861 Gasoline (gal) 4,943 - - 4,943 Gasoline (gal) 4,943 - - 4,943 Diesel (gal) - - - - Diesel (gal) - - - -
Natural Gas (gal) - 46,554 - 46,554 Natural Gas (gal) - - - - Electriity kw-hr 299,072 1,698,150 174,184 2,171,406 Electriity kw-hr 299,072 2,612,538 267,976 3,179,586 Assumes that LDV follow Statewide MSS Projections from Vision Model. Assumes that LDV follow Statewide MSS Projections from Vision Model.

Assumes that MHDT follow MSS Strategy Projections for (State, SC or SJV) Assumes that MHDT are box trucks and are Milestone Group 1.

Assumes that HHDT follow MSS Strategy Projections for (State, SC or SJV) Assumes that HHDT are day cab trucks complying with Milestone Group 2 Timeline.

LDT1 HHDT MHDT LDT1 HHDT MHDT
Gasoline (gal/mi) 0.0362 Gasoline (gal/mi) 0.0362 0.0000 0.0000 Diesel (gal/mi) 0.1578 0.1149 Diesel (gal/mi) 0.0000 0.1578 0.1149 Natural Gas (gal/mi) 0.1887 0.1372 Natural Gas (gal/mi) 0.0000 0.1887 0.1372 kw-hr /mi 0.3861 1.8530 1.0855 kw-hr /mi 0.3861 1.8530 1.0855 2030 - MSS 2030 - ACF
2,568,115 2,568,115
Fuel Consumption Factors Fuel Consumption Factors
2045 - MSS 2045 - ACF
2,568,115 2,568,115
Fuel Consumption Factors Fuel Consumption Factors

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Commerce 220 Warehouse Distribution Project
Operational Mobile Sources
GHG Projections (2030 and 2040)
Fuel Consumption1 MSS2 ACF3
Gasoline 23,727 23,727 8.78 kg/gal
Diesel 127,026 99,947 10.18 kg/gal
Natural Gas 119,709 99,758 6.89 kg/gal
Electricity 373,170 863,318 98.00 lb/MWHr
CO2e Emissions (Metric Tons) 2343.4 1952.0
Fuel Consumption1 MSS2 ACF3
Diesel 4,943 4,943 8.78 kg/gal
Natural Gas - - 10.18 kg/gal
Electricity 46,554 - 6.89 kg/gal
2,171,406 3,179,586 0.00 lb/MWHr
CO2e Emissions (Metric Tons) 364.4 43.4
CO2 Emission Factor
1 Fuel consumption is in gallons for gasoline and diesel, gallon equivalents for natural gas and kWh for electricity. 2 Based on fuel consumption estimates from project VMT and ZEV projections from the 2020 Mobile Source Strategy META and Vision Models.
3 Based on Fleet Projections assuming all trucks are subject to Advanced Clean Fleet Rule, following milestone compliance options.
3 Based on Fleet Projections assuming all trucks are subject to Advanced Clean Fleet Rule, following milestone compliance options.
2030 Projections
CO2 Emission Factor
1 Fuel consumption is in gallons for gasoline and diesel, gallon equivalents for natural gas and kWh for electricity. 2 Based on fuel consumption estimates from project VMT and ZEV projections from the 2020 Mobile Source Strategy META and Vision Models.
2045 Projections

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Appendix C:

Biological Resources Supporting Information
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C.1 - Biological Resources Assessment
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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
Biological Resources Assessment
SDG Commerce 220 Distribution Center Project
City of American Canyon, Napa County, California
Project Applicant:

SDG Commerce 220, LLC
413 West Yosemite Avenue, Suite 105
Madera, CA 93637
Prepared by:

FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
925.357.2562
Contact: Mary Bean, Project Director
Date: September 20, 2023
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Table of Contents
FirstCarbon Solutions iii Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx Table of Contents
Section 1: Introduction .................................................................................................................. 1

1.1 - Project Location................................................................................................................. 1

1.2 - Project Description............................................................................................................ 1

1.3 - Project History................................................................................................................... 1 Section 2: Regulatory Setting ......................................................................................................... 9

2.1 - Federal............................................................................................................................... 9

2.2 - State................................................................................................................................. 11

2.3 - Regional and Local........................................................................................................... 15

2.4 - City of American Canyon Ordinances.............................................................................. 16 Section 3: Methods...................................................................................................................... 17

3.1 - Literature Review............................................................................................................. 17

3.2 - Field Surveys and Focused Surveys................................................................................. 18

3.3 - Wildlife Movement Corridors.......................................................................................... 20 Section 4: Results ......................................................................................................................... 23

4.1 - Environmental Setting ..................................................................................................... 23

4.2 - Vegetation Communities and Land Cover Types............................................................. 27

4.3 - Wildlife ............................................................................................................................ 31

4.4 - Wildlife Movement Corridors and Nursey Sites.............................................................. 32

4.5 - Protected Trees................................................................................................................ 33

4.6 - Habitat Conservation Plans............................................................................................. 33 Section 5: Sensitive Biological Resources...................................................................................... 35

5.1 - Sensitive Natural Communities....................................................................................... 35

5.2 - Special-status Plant Species ............................................................................................ 35

5.3 - Special-status Wildlife Species ........................................................................................ 39

5.4 - State or Federally Protected Waters and Wetlands ........................................................ 44

5.5 - Wildlife Movement Corridors and Nursery Sites............................................................. 44 Section 6: Impact Analysis and Recommendations....................................................................... 45

6.1 - Impact Analysis for Sensitive Natural Communities........................................................ 45

6.2 - Impact Analysis for Special-status Species...................................................................... 45

6.3 - Impact Analysis for Wildlife Nursery Sites and Wildlife Movement Corridors................ 50

6.4 - Impact Analysis for State and Federally Protected Waters and Wetlands...................... 51

6.5- Protected Trees ................................................................................................................ 51

6.6- Conflict with Habitat Conservation Plans......................................................................... 51 Appendix A: Site Photographs
Appendix B: Special-status Species Tables
Appendix C: Database Searches
Appendix D: Supporting Documents
D.1 - SDG Commerce Site 217 Documents
D.2 - SDG Commerce Site 220 Documents
Appendix E: Plant and Wildlife List
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iv FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx List of Tables
Table 1: Soil Types Present within Project Site......................................................................................23 List of Exhibits
Exhibit 1: Regional Location.................................................................................................................... 3 Exhibit 2: Local Vicinity ........................................................................................................................... 5 Exhibit 3: Site Plan................................................................................................................................... 7 Exhibit 4: Soils.......................................................................................................................................25 Exhibit 5: Vegetation Communities and Land Cover Types...................................................................29 Exhibit 6: CNDDB Occurrences..............................................................................................................37 Exhibit 7: Impacts..................................................................................................................................53 1304
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Biological Resources Assessment Introduction
FirstCarbon Solutions 1 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx SECTION 1: INTRODUCTION
This Biological Resources Assessment (BRA) has been prepared by FirstCarbon Solutions (FCS) for the proposed SDG Commerce Court 220 Distribution Center Project (proposed project). The purpose of the BRA is to (1) document existing and potentially occurring biological resources on the project site and adjacent areas; (2) analyze potential project-related impacts on regulated biological resources; (3) summarize relevant local, State, and federal regulations; and (4) recommend appropriate measures to mitigate potential impacts on biological resources to less than significant levels.

1.1 - Project Location
The approximately 10.17-acre project site is located in the City of American Canyon, in Napa County, California (Exhibit 1 and Exhibit 2). The project site is located on the Cuttings Wharf, California United States Geological Survey (USGS) 7.5-minute Topographic Quadrangle Map. The project site is generally trapezoidal in shape, bordered by the Commerce Court extension and eucalyptus trees to the east, eucalyptus trees and North Slough to the west, the future SDG Commerce 217 project site to the north, and the constructed and operational SDG Commerce 330 Distribution Center to the south.

1.2 - Project Description
The project applicant, SDG Commerce 220, LLC, proposes to develop a 219,834-square-foot wine storage and distribution center on the 443,005-square-foot project site (Exhibit 3). The warehouse would provide 23 truck doors and up to provisions for 4,400 square feet of office space. The warehouse would have perimeter concrete tilt-up wall panels with varying parapet heights and accent spandrel glass/metal canopy features around offices and corners of the building. The average roof height would be approximately 35 feet high and portions of the building exterior walls would have various heights to provide architectural relief. The building would be insulated and refrigerated at approximately 58°F (degrees Fahrenheit), making it suitable for storage of wine and related products. The amount of refrigeration necessary would be reduced through the use of intake louvers and fans, which would allow cool night air to be utilized.

1.3 - Project History
The project site is part of what was previously a larger 35.85-acre site. The site was subdivided into three lots (SDG Commerce 217, SDG Commerce 220, and SDG Commerce 330) via a tentative parcel map in February 2019. The southern parcel (SDG Commerce 330) was developed in 2021. The northern parcel (SDG Commerce 217) was entitled in 2021 and at the time of this writing is currently being developed. The central parcel (SDG Commerce 220) is the project site evaluated in this BRA.

Exhibit 3 shows the relationship of the three parcels to each other. The following narrative provides background on the entire 35.85-acre project site.

Aerial photography dating back to 1937 indicates that the entire project site was occupied by planted ornamental trees; between then and the late 1950s, a eucalyptus grove was planted. From 1305
SDG Commerce 220, LLC–220 Distribution Center Project
Introduction Biological Resources Assessment
2 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx the 1950s until 2001 the site remained relatively unchanged. From 2001 until circa 2012, the northwest corner of the site was used as a paintball field (Sherwood Forest Paintball Area) with the eucalyptus trees remaining in place.

In 2004, a warehouse was built directly to the north of the greater 35.8-acre site (as shown in Exhibit 2), and its development also included construction of Commerce Court cul-de-sac road improvements that terminated at on the northeast corner of the site. Also in 2004, the City of American Canyon installed underground utilities and a rock-paved access road through the middle of the eucalyptus grove adjacent to the east side of the project site. This work also included installation of a sanitary sewer force main that crosses the northern portion of the site (i.e., the 217 SDG Commerce parcel). In 2012 the entire 35.85-acre site was cleared and grubbed of eucalyptus trees and shrubs.

It should be noted that as part of the SDG Commerce 217 development, much of the SDG Commerce 220 project site was graded between May 29 and July 2, 2023, to procure existing, stockpiled soil for use as clean fill material for the SDG Commerce 217 site (See Appendix A for photographs). A Monk & Associates (M&A) authored Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site in September 2020 analyzed grading impacts (Appendix D.1). Additionally, an approved grading plan was issued by the City of American Canyon in March 2023 (Appendix D.1). 1306
12 29
121
37 4
Napa County
Solano County
80 680
12 116
Contra Costa County
780
128
Montezuma Slou gh
Carquinez Strait
Sonoma County
Marin County
242
680
24 Napa River
Jack London
State Park
Vacaville
Napa
Fairfield
Suisun City
Vallejo
Novato Benicia
Bay Point
Hercules
Pinole Martinez
San Anselmo
San Rafael Concord
San Pablo
Pleasant Hill Richmond
Larkspur
El Cerrito
Mill Valley
Albany Walnut Creek
Lafayette
Orinda
Berkeley
Alamo
Sonoma
American
Canyon
Clayton
Exhibit 1
Re gional Location Map
5 2.5 0 5
Miles
Text
Project Site
Source : Ce n sus 2000 Data, T he Californ ia Spatial In form ation Library (CaSIL).

ST RAVINSKI DEVELOPMENT GROUP, LLC
SDG COMMERCE 220 DIST RIBUT ION CENT ER PROJECT

BIOLOGICAL RESOURCE ASSESSMENT
56390001 • 08/2023 | 1_re gional.m xd
Project Site
80 Legend
City of American Canyon
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56390001 • 08/2023 | 2_lo cal_vicinity.m xd
Exhibit 2
Lo cal Vicinity Map
So urce: Bing Aerial Im agery.

STRAVINSKI DEVELOPMENT GROU P, LLC
SDG COMMERCE 220 DISTRIBU TION CENTER PROJECT

BIOLOGICAL RESOU RCE ASSESSMENT
1,000 500 0 1,000
Feet
Legend
Project Site
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56390001• 09/2023 | 3_Site_Plan.cdr
Exhibit 3
Site Plan

STRAVINSKI DEVELOPMENT GROUP, LLC
SDG COMMERCE 220 DISTRIBUTION CENTER PROJECT

BIOLOGICAL RESOURCE ASSESSMENT
Source: RSA+ Consulting Civil Engineers + Surveyors. 07/21/2023.

PROJECT SITE BOUNDARY
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Regulatory Setting
FirstCarbon Solutions 9 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx SECTION 2: REGULATORY SETTING

2.1 - Federal

2.1.1 - Endangered Species Act of 1973
The United States Fish and Wildlife Service (USFWS) has jurisdiction over species listed as threatened or endangered under the federal Endangered Species Act of 1973. Section 9 of Endangered Species Act protects listed species from “take,” which is broadly defined as actions taken to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” The Endangered Species Act protects threatened and endangered plants and animals and their critical habitat. Candidate species are those proposed for listing; these species are usually treated by resource agencies as if they were actually listed during the environmental review process.

2.1.2 - Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) implements international treaties between the United States and other nations devised to protect migratory birds, their parts, eggs, and nests from activities such as hunting, pursuing, capturing, killing, selling, and shipping, unless expressly authorized in the regulations or by permit. All migratory birds and their nests are protected from take and other impacts under the MBTA (16 United States Code [USC] § 703, et seq.).

2.1.3 - Bald and Golden Eagle Protection Act
The golden eagle (Aquila chrysaetos) and bald eagle (Haliaeetus leucocephalus) are afforded additional protection under the Eagle Protection Act, amended in 1973 (16 USC § 669, et seq.) and the Bald and Golden Eagle Protection Act (16 USC §§ 668–668d).

2.1.4 - Clean Water Act
Section 404
The United States Army Corps of Engineers (USACE) administers Section 404 of the federal Clean Water Act (CWA), which regulates the discharge of dredge and fill material into waters of the United States.

As of the preparation of this report on August 28, 2023, the final “Revised Definition of Waters of the United States” rule was published in the Federal Register on January 18, 2023, and took effect on March 20, 2023. However, the final rule is not currently operative in certain states and for certain parties due to litigation. Moreover, the United States Environmental Protection Agency (EPA) and USACE (hereafter known as the agencies) are in receipt of the U.S. Supreme Court’s May 25, 2023, decision in the case of Sackett v. Environmental Protection Agency. In light of this decision, the agencies will interpret the phrase “waters of the United States” consistent with the Supreme Court’s decision in Sackett.
1 As a result of ongoing litigation, the agencies are interpreting “waters of the United States” consistent with the pre-2015 regulatory regime until further notice. 1 United States Environmental Protection Agency (EPA). 2023. Website: https://www.epa.gov/wotus/current-implementation-watersunited-states. Accessed July 12, 2023. 1313
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10 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx Therefore, since the agencies are interpreting “waters of the United States” consistent with the pre2015 regulatory regime until further notice, our analysis follows 40 Code of Federal Regulations 230.3(s) in effect under the pre-2015 regulatory regime, which defines “waters of the United States“ as follows:

1. All waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide.

2. All interstate waters including interstate wetlands.

3. All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters:
a) Which are or could be used by interstate or foreign travelers for recreational or other purposes; or
b) From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or
c) Which are used or could be used for industrial purposes by industries in interstate commerce.

4. All impoundments of waters otherwise defined as waters of the United States under this definition.

5. Tributaries of waters identified in paragraphs(s) (1) through (4) of this section.

6. The territorial sea.

7. Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs(s) (1) through (6) of this section; waste treatment systems, including treatment ponds or lagoons designed to meet the requirements of the CWA (other than cooling ponds as defined in 40 Code of Federal Regulations 423.11(m) which also meet the criteria of this definition) are not waters of the United States.

Waters of the United States do not include prior converted cropland. Notwithstanding the determination of an area’s status as prior converted cropland by any other federal agency, for the purposes of the CWA, the final authority regarding CWA jurisdiction remains with the EPA and/or USACE.
“Wetland” refers to areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and seasonal wetlands. Wetlands are considered jurisdictional if they fall under one of the categories of waters of the United States defined above. The USACE jurisdiction typically extends up to the ordinary high water mark (OHWM).
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FirstCarbon Solutions 11 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx In general, a USACE permit must be obtained before placing fill in wetlands or other waters of the United States. The type of permit depends on the impacted acreage, the purpose of the proposed fill, and other factors.

Section 401
As stated in Section 401 of the CWA, “any applicant for a federal permit for activities that involve a discharge to waters of the State, shall provide the federal permitting agency a certification from the State in which the discharge is proposed that states that the discharge will comply with the applicable provisions under the Federal Clean Water Act.” Therefore, before the USACE will issue a Section 404 permit, applicants must apply for and receive a Section 401 Water Quality Certification from the Regional Water Quality Control Board (RWQCB).

2.2 - State

2.2.1 - CEQA Guidelines
The California Environmental Quality Act (CEQA) requires public agencies to evaluate potential impacts to special-status species and their habitat. The following CEQA Guidelines Appendix G checklist questions serve as thresholds of significance when evaluating the potential impacts of a proposed project on biological resources. Impacts are considered significant if a project would:
• Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as being a Candidate, Sensitive, or Special-status in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or USFWS. • Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS. • Have a substantial adverse effect on federally and State-protected wetlands as defined by Section 404 of the CWA (including but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. • Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
• Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State Habitat Conservation Plan.

Oak Woodlands Conservation Act
California State Senate Bill (SB) 1334, the Oak Woodlands Conservation Act, became law on January 1, 2005, and was added to the CEQA statutes as 21083.4. This statute requires that a county must determine whether or not a project will result in a significant impact on oak woodlands and, if it is 1315
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12 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx determined that a project may result in a significant impact on oak woodlands then the County shall require one or more of the following mitigation measures:
• Conserve oak woodlands through the use of conservation easements. • Plant an appropriate number of trees, including maintenance of plantings and replacement of failed plantings.
• Contribute funds to the Oak Woodlands Conservation Fund for the purpose of purchasing oak woodlands conservation easements.
• Other mitigation measures developed by the county.

2.2.2 - California Endangered Species Act
The State of California enacted the California Endangered Species Act (CESA) in 1984. CESA pertains to State-listed endangered and threatened species. CESA requires State agencies to consult with the CDFW when preparing CEQA documents to ensure that the State lead agency actions do not jeopardize the continued existence of a listed species or result in the destruction or adverse modification of habitat essential to the continued existence of those species, if there are reasonable and prudent alternatives available (Fish and Game Code [FGC] § 2080). CESA directs agencies to consult with the CDFW on projects or actions that could affect listed species, directs the CDFW to determine whether jeopardy would occur, and allows the CDFW to identify “reasonable and prudent alternatives” to the project consistent with conserving the species. CESA allows the CDFW to authorize exceptions to the State’s prohibition against take of a listed species if the “take” of a listed species is incidental to carrying out an otherwise lawful project that has been approved under CEQA (FGC § 2081).

2.2.3 - California Fish and Game Code
Under CESA, the CDFW has the responsibility for maintaining a list of endangered and threatened species (FGC § 2070). Fish and Game Code Sections 2050 through 2098 outline the protection provided to California’s rare, endangered, and threatened species. Fish and Game Code Section 2080 prohibits the taking of plants and animals listed under the CESA. Fish and Game Code Section 2081 established an incidental take permit program for State-listed species. The CDFW maintains a list of “Candidate” species that it formally notices as being under review for addition to the list of endangered or threatened species.

In addition, the Native Plant Protection Act of 1977 (NPPA) (FGC § 1900, et seq.) prohibits the taking, possessing, or sale within the State of any plants with a State designation of rare, threatened, or endangered (as defined by the CDFW). An exception to this prohibition in the NPPA allows landowners, under specified circumstances, to take listed plant species, provided that the owners first notify the CDFW and give the agency at least 10 days to come and retrieve (and presumably replant) the plants before they are plowed under or otherwise destroyed. Fish and Game Code Section 1913 exempts from “take” prohibition “the removal of endangered or rare native plants from a canal, lateral ditch, building site, or road, or other right-of-way.” Project impacts to these species 1316
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FirstCarbon Solutions 13 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx are not considered significant unless the species are known to have a high potential to occur within the area of disturbance associated with construction of the proposed project.

In addition to formal listing under the Endangered Species Act and CESA, some species receive additional consideration by the CDFW and local lead agencies during the CEQA process. Species that may be considered for review are those listed as a Species of Special Concern. The CDFW maintains lists of Species of Special Concern that serve as species “watch lists.” Species with this status may have limited distributions or limited populations, and/or the extent of their habitats has been reduced substantially, such that their populations may be threatened. Thus, their populations are monitored, and they may receive special attention during environmental review. While they do not have statutory protection, they may be considered rare under CEQA and specific protection measures may be warranted. In addition to Species of Special Concern, the CDFW Special Animals List identifies animals that are tracked by the California Natural Diversity Database (CNDDB) and may be potentially vulnerable but warrant no federal interest and no legal protection.

Sensitive species that would qualify for listing but are not currently listed are afforded protection under CEQA. CEQA Guidelines Section 15065 (Mandatory Findings of Significance) requires that a substantial reduction in numbers of a rare or endangered species be considered a significant effect.

CEQA Guidelines Section 15380 (Rare or Endangered Species) provides for the assessment of unlisted species as rare or endangered under CEQA if the species can be shown to meet the criteria for listing. Unlisted plant species on the California Native Plant Society (CNPS) List ranked 1A, 1B, and 2 would typically require evaluation under CEQA.

Fish and Game Code Sections 3500 to 5500 outline protection for fully protected species of mammals, birds, reptiles, amphibians, and fish. Species that are fully protected by these sections may not be taken or possessed at any time. The CDFW cannot issue permits or licenses that authorize the take of any fully protected species, except under certain circumstances such as scientific research and live capture and relocation of such species pursuant to a permit for the protection of livestock.

Under Fish and Game Code Section 3503.5, it is unlawful to take, possess, or destroy any birds in the orders of Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto. To comply with the requirements of CESA, an agency reviewing a proposed project within its jurisdiction must determine whether any State-listed endangered or threatened species may be present in the project study area and determine whether the proposed project will have a potentially significant impact on such species. In addition, the CDFW encourages informal consultation on any proposed project that may impact a Candidate species.

Project-related impacts to species on the CESA endangered or threatened list would be considered significant. State-listed species are fully protected under the mandates of CESA. “Take” of protected species incidental to otherwise lawful management activities may be authorized under Fish and Game Code Section 206.591. Authorization from the CDFW would be in the form of an Incidental Take Permit.
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14 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx Fish and Game Code Section 1602 requires any entity to notify the CDFW before beginning any activity that “may substantially divert or obstruct the natural flow of, or substantially change or use any material from the bed, channel, or bank of any river, stream, or lake” or “deposit debris, waste, or other materials that could pass into any river, stream, or lake.” “River, stream, or lake” includes waters that are episodic and perennial and ephemeral streams, desert washes, and watercourses with a subsurface flow. A Lake or Streambed Alteration Agreement will be required if the CDFW determines that project activities may substantially adversely affect fish or wildlife resources through alterations to a covered body of water. CDFW jurisdiction typically extends to the edge or “drip line” of the riparian habitat or top of bank.

2.2.1 - California Porter-Cologne Water Quality Control Act The RWQCB regulates actions that would involve “discharging waste, or proposing to discharge waste, within any region that could affect the water of the State” (Water Code § 13260(a)), pursuant to provisions of the Porter-Cologne Water Quality Act. “Waters of the State” are defined as “any surface water or groundwater, including saline waters, within the boundaries of the State” (Water Code § 13050(e)). In 2019, the California State Water Resources Control Board (State Water Board) published the State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (Procedures) to guide wetland/waters of the State determinations and the permitting process.2

2.2.2 - California Native Plant Society
The CNPS maintains a rank of plant species that are native to California and that have low population numbers, limited distribution, or are otherwise threatened with extinction. This information is published in the Inventory of Rare and Endangered Vascular Plants of California. Following are the definitions of the CNPS ranks:
• Rank 1A: Plants presumed extirpated in California and either rare or extinct elsewhere • Rank 1B: Plants rare, threatened, or endangered in California and elsewhere • Rank 2A: Plants presumed extirpated in California but common elsewhere • Rank 2B: Plants rare, threatened, or endangered in California but more common elsewhere • Rank 3: Plants about which more information is needed • Rank 4: Watch List: Plants of limited distribution
Potential impacts to populations of CNPS ranked plants receive consideration under CEQA review. All plants appearing on the CNPS List ranked 1 or 2 are considered to meet the CEQA Guidelines Section 15380 criteria. Rank 3 and 4 plants do not automatically meet this definition. Rank 4 plants do not clearly meet CEQA standards and thresholds for impact considerations. Nevertheless, some level of CEQA review is justified for California Rare Plant Rank (CRPR) 4 taxa, and under some circumstances, a full impact analysis is warranted. Taxa that can be shown to meet the criteria for endangered, rare, or threatened status under CEQA Section 15380(d) or that can be shown to be regionally rare or unique as defined in CEQA Section 15125(c) must be fully analyzed in a CEQA document. Some 2 California State Water Resources Control Board (State Water Board). 2019. State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. April 2, 2019. 1318
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FirstCarbon Solutions 15 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx circumstances, such as local rarity, having occurrences peripheral to the taxon’s distribution, or having occurrences on unusual substrates or rare and declining habitats, provide justification for treating some CRPR 4 taxa occurrences as regionally rare or unique. One limitation to fully analyzing impacts on CRPR 4 taxa is the difficulty in obtaining current data on the number and condition of the occurrences.3

2.3 - Regional and Local

2.3.1 - City of American Canyon General Plan
The City of American Canyon General Plan sets forth the following goals, objectives, and policies relevant to biological resources on the project site. Only those applicable to the proposed project are discussed herein:

Goal 8 Protect and preserve the significant habitats, plants and wildlife that exist in the City and its Planning Area.

Objective 8.1 Maintain data and information regarding areas of significant biological value within the Planning Area to facilitate resource conservation and the appropriate management of development.

Policy 8.1.1 Acquire and maintain the most current information available regarding the status and location of sensitive biological elements (species and natural communities) within the City and, as appropriate, within the Sphere of Influence and Urban Limit Line.

Policy 8.1.4 Regularly monitor and review developments proposed within the City's Planning Area to assess their impacts on local biological resources and to recommend appropriate mitigation measures that the developer and/or government agency can implement.

Objective 8.2 Balance the preservation of natural habitat areas, including coastal saltmarsh, mixed hardwood forest, oak savanna, and wetland and riparian habitats, with new development in the City.

Policy 8.2.1 Land use applications for developments located within sensitive habitats, including coastal saltmarsh, mixed hardwood forest, oak savanna, and riparian habitats (see Figure 8-1) [General Plan], or with areas potentially occupied by vernal pools (see Figure 8-2) [General Plan] shall be accompanied by sufficient technical background data to enable an adequate assessment of the potential for impacts on these resources, and possible measures to reduce any identifiable impacts. In addition to examining Figure 8-1 [General Plan] for information on these sensitive habitats, an on-site assessment shall be conducted by a City approved qualified Biologist to determine whether sensitive habitats exist on-site. In instances where the potential 3 California Native Plant Society (CNPS). 2020. Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact Analysis. Sacramento, CA. January 21, 2020.
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Policy 8.3.1 b Development shall be designed and sited to preserve watercourses, riparian habitat, vernal pools, and wetlands in their natural condition, unless these actions result in an unfeasible project, in which case habitat shall be replaced in accord with subsection "g" (below).

Objective 8.3 Protect natural drainages and riparian corridors within the American Canyon Planning Area.

Policy 8.3.1 Review proposed developments in wetlands and riparian habitats to evaluate their conformance with the following policies and standards:
• The development plan shall fully consider the nature of existing biological resources and all reasonable measures shall be taken to avoid significant impacts, including retention of sufficient natural open space and undeveloped buffer zones.

Policy 8.3.1 e Development shall incorporate fences, walls, vegetative cover, or other measures to adequately buffer habitat areas, linkages or corridors from built environment.

Policy 8.3.1 f Roads and utilities shall be located and designed such that conflicts with biological resources, habitat areas, linkages or corridors are avoided where feasible.

Policy 8.3.1 g Future development shall utilize appropriate open space or conservation easements in order to protect sensitive species or their habitats.

Policy 8.3.5 Establish a network of open spaces along the City's natural drainages and riparian corridors and link significant biological habitats. Any recreational use of these areas shall be designed to avoid damaging sensitive habitat areas.

Policy 8.3.6 Preserve and integrate the City's natural drainages in new development, as opposed to their channelization or undergrounding, emphasizing opportunities for the development of pedestrian paths and greenbelts along their lengths throughout the City.

2.4 - City of American Canyon Ordinances
Municipal Code Chapter 18.40.110 sets forth the City’s Tree Ordinance. The ordinance states that existing trees shall be preserved on the site unless otherwise approved by the City Council as a part of the site development plans. Additionally, unless specifically approved by the City Council, any tree removed shall be replaced on the site. Replacement trees shall be a minimum size of a 24-inch box of the same species unless specifically approved by the City Council. 1320
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3.1 - Literature Review
Literature review was conducted to analyze existing documentation regarding biological resources and habitat conditions within the project site and is summarized below.

3.1.1 - Existing Documentation
As part of the literature review, an FCS Biologist compiled and analyzed existing environmental documentation for the project site and relevant areas in its vicinity. This documentation included literature pertaining to the habitat requirements of special-status species with the potential to occur in the project vicinity and federal register listings, protocols, and species data provided by the USFWS, CDFW, and CNPS. Additionally, FCS reviewed and evaluated all available supporting documentation provided by the applicant, including a pending USACE jurisdictional determination, and species-specific studies and habitat assessments. These documents are attached to this BRA (Appendix D), and include the following:

SDG Commerce 217 Documents
• Monk & Associates (M&A). 2020. Revised Biological Resource Analysis SDG Commerce 217 Distribution Center. City of American Canyon, California. March 2020. • Monk & Associates (M&A). 2020. Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site SDG Commerce 217 Distribution Center. September 2020. • FirstCarbon Solutions (FCS). 2023. Pre-Construction Surveys and Implementation of CEQA Mitigation Measures BIO-1, BIO-2, BIO-3, BIO-4, and BIO-5 per the Mitigation Monitoring and Reporting Program for the Commerce 217 Warehouse Project, American Canyon, California.

April 2023.
• RSA+. 2023. Commerce 217 Distribution Center Borrow Site Grading Plan. March 2023.

SDG Commerce 220 Documents
• Pinecrest Research Corp., Inc. 2023. Special-Status Animal Survey Report. August 2023. • Pinecrest Research Corp., Inc. 2023. Special-Status Plant Survey Report. July 2023. • Monk & Associates (M&A). 2023. Request for Reverification of Jurisdictional Determination and a PJD SDG Commerce 220 Project Site; USACE File Number: 2011-00322N American Canyon, California. May 2023.

3.1.2 - Topographic Maps and Aerial Photographs
An FCS Biologist reviewed current USGS 7.5-minute topographic quadrangle map(s)and aerial photographs as a preliminary analysis of the existing conditions within the project site and 1321
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photographs provided a perspective of the current site conditions relative to on-site and off-site land use, plant community locations, and potential locations of wildlife movement corridors.

3.1.3 - Soil Surveys
The United States Department of Agriculture (USDA) has published soil surveys that describe the soil series (i.e., group of soils with similar profiles) occurring within a particular area. 6 These profiles
include major horizons with similar thickness, arrangement, and other important characteristics.

These series are further subdivided into soil mapping units that provide specific information regarding soil characteristics. Many special-status plant species have a limited distribution based exclusively on soil type. Therefore, pertinent USDA soil survey maps were reviewed to determine the existing soil mapping units within the project site and to inform whether the soil conditions on-site are potentially suitable for any special-status plant species. However, Natural Resources Conservation Service (NRCS) soil maps utilize an approximately 1.4-acre minimum mapping unit, and line placement may not be accurate on a large (i.e., parcel-level) scale.

3.1.4 - Special-status Species Database Search
An FCS Biologist compiled a list of threatened, endangered, and otherwise special-status species previously recorded within the project vicinity based on a search of the USFWS Information for Planning and Consultation (IPaC) database,
7 the CNDDB, and the CNPS Electronic Inventory (CNPSEI) of Rare and Endangered Vascular Plants of California for the Cuttings Wharf, California USGS 7.5- minute Topographic Quadrangle Map, and the eight surrounding quadrangles. 8,9 The CNDDB
Biogeographic Information and Observation System (BIOS 6) was used to determine the distance between the known occurrences of special-status species and the project site.10

3.2 - Field Surveys and Focused Surveys
FCS Biologists familiar with the biological resources of the region conducted field surveys on December 2, 2022, and March 17, 2023. The objective of the field surveys was to ascertain general site conditions, wildlife use, and identify whether existing vegetation communities provide suitable 4 United States Geological Survey (USGS). 2022. National Geospatial Program. Website: https://www.usgs.gov/core-sciencesystems/national-geospatial-program/us-topo-maps-america?qt-science_support_page_related_con=4#qtscience_support_page_related_con. Accessed August 21, 2023. 5 United States Environmental Protection Agency (EPA). 2022. Watershed Assessment, Tracking and Environmental Results System (WATERS). Website: https://www.epa.gov/waterdata/waters-watershed-assessment-tracking-environmental-results-system.

Accessed August 21, 2023. 6 Natural Resources Conservation Service (NRCS). 2022. Web Soil Survey (WSS). United States Department of Agriculture (USDA).

Website: https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx. Accessed August 21, 2023. 7 United States Fish and Wildlife Service (USFWS). 2023. Information for Planning and Consultation (IPaC). Website:
https://ecos.fws.gov/ipac/. Accessed August 21, 2023. 8 California Department of Fish and Wildlife (CDFW). 2023. California Natural Diversity Database (CNDDB) RareFind 5 California Natural Diversity Database Query for Special-Status Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx.

Accessed August 21, 2023. 9 California Native Plant Society (CNPS). 2022. California Native Plant Society Rare and Endangered Plant Inventory. Website:
http://www.rareplants.cnps.org/. Accessed August 21, 2023. 10 California Department of Fish and Wildlife (CDFW). 2022. Biogeographic Information and Observation System (BIOS 6). Website:
https://map.dfg.ca.gov/bios/. Accessed August 21, 2023. 1322
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Wildlife species detected during the reconnaissance-level surveys by sight, calls, tracks, scat, or other signs were recorded. Notations were made regarding suitable habitat for those special-status species determined to have the potential to occur within the project site.11 Appropriate field guides were used to assist in species identification during surveys, such as Peterson, Reid, and Stebbins.12,13,14 Online resources such as eBird and California Herps were also consulted, as necessary. 15,16 M&A performed 10 field surveys on the greater 35-acre project site before the site was subdivided into three lots (SDG Commerce 217, SDG Commerce 220, and SDG Commerce 330). Consequently, the SDG Commerce 220 project site was included in these surveys which were conducted on March 1 and April 27, 2006; June 14, 2011; February 14, March 21, and June 12, 2012; May 18, 2017; March 30, 2018; December 19 and December 27, 2019. Additional details concerning these surveys can be found in Appendix D.1 of this document.

3.2.1 - Pre-construction Surveys for SDG Commerce 217
Seven pre-construction surveys were conducted by FCS between January 18 and April 7, 2023, for a total of approximately 30 survey hours. Surveys were conducted for the entirety of the Commerce 217 project site and relevant adjacent areas (which included the adjacent SDG Commerce 220 site).

Surveys were conducted pursuant to the January 2021 Mitigation, Monitoring, and Reporting Program (MMRP) for the Commerce 217 Warehouse Project. Surveys included nesting birds (including Swainson’s hawk) and burrowing owl detection. Surveys for western pond turtle adults and nests were also performed simultaneously while walking the site. Survey methods followed established procedures and applicable protocols, including the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (Protocol) and the Staff Report on Burrowing Owl Mitigation.
17,18 Survey equipment included high-quality binoculars and a high-quality spotting scope. Surveys were conducted during the appropriate times of day (including peak bird detection periods between sunrise and 10:00 a.m.). Additional details concerning these surveys can be found in Appendix D.1 of this document. 11 California Department of Fish and Wildlife (CDFW). 2022. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed August 21, 2023. 12 Peterson, T.R. 2010. A Field Guide to Birds of Western North America, 4th Edition. Boston: Houghton Mifflin Harcourt. 13 Reid, F. 2006. A Field Guide to Mammals of North America, 4th Edition. Boston: Houghton Mifflin Harcourt. 14 Stebbins, R.C. 2003. A Field Guide to Western Reptiles and Amphibians. Third Edition. Boston: Houghton Mifflin Harcourt. 15 eBird. 2022. Online bird occurrence database. Website: http://ebird.org/content/ebird/. Accessed August 21, 2023. 16 California Herps. 2022. A Guide to the Amphibians and Reptiles of California. Website: http://www.californiaherps.com/Accessed August 21, 2023. 17 Swainson’s Hawk Technical Advisory Committee. 2000. Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley. California Department of Fish and Wildlife, May 31, 2000. 18 California Department of Fish and Wildlife (CDFW). 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resource Agency Department of Fish and Game. March 7, 2012. 1323
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3.2.2 - Special-status Animal Surveys for SDG Commerce 220 Eleven special-status animal surveys were conducted between January 18 and July 2, 2023, by Pinecrest Research Corp (Pinecrest) for the entirety of the Commerce 220 project site. Surveys were conducted by Dr. Christopher DiVittorio to determine the pre-construction presence or absence of several special-status species, including burrowing owl, Swainson’s hawk, nesting raptors, nesting passerine birds, and western pond turtle. Survey methods followed established procedures and applicable protocols, including the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley, and the Staff Report on Burrowing Owl Mitigation. 19,20
Survey equipment included high-quality binoculars and a high-quality spotting scope. Surveys were conducted during the appropriate times of day (including peak bird detection periods between sunrise and 10:00 a.m.). Additional details concerning these surveys can be found in Appendix D.2 of this document.

3.2.3 - Protocol-level Rare Plant Surveys for SDG Commerce 220 Protocol-level rare plant surveys were conducted by Pinecrest during the growing season of 2023. An early-season site visit was performed on March 20. Mid-season site visits were performed on April 6, April 7, and May 29. A late-season site visit was also performed on July 2. Between the mid-season and late-season site visits the majority of the site was graded thus the late-season site visit focused on remaining vegetation surrounding the areas of disturbance. Rare plants recorded and mapped in the field, if present, include all plants that are federal or State-listed as Rare, Threatened, or Endangered, all federal and State candidates for listing, all plants included in Lists 1 through 4 of the CNPS Inventory, and plants that qualify under the definition of “rare” in CEQA Guidelines Section 15380.

Botanical surveys were performed by Dr. Christopher DiVittorio, with secondary identification on voucher and photograph specimens made by Dr. Zoya Akulova. During the site visit, Dr. DiVittorio surveyed the entirety of the project area using methods as specified in the CDFW publication titled Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities.
21 Surveys were conducted by walking the entire project area on foot in parallel lines approximately 15 feet apart, identifying every species that was flowering, and making note of any species that were past flowering or that had not yet flowered. Voucher specimens were taken of any species that required identification in the laboratory. All terminology follows currently accepted nomenclature as described in The Jepson Manual. Additional details concerning these surveys can be found in Appendix D.2 of this document.

3.3 - Wildlife Movement Corridors
Wildlife movement corridors link areas of suitable wildlife habitat that are otherwise separated by natural and anthropogenic dispersal barriers, including rugged terrain, changes in vegetation, 19 Swainson’s Hawk Technical Advisory Committee. 2000. Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley. California Department of Fish and Wildlife, May 31, 2000. 20 California Department of Fish and Wildlife (CDFW). 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resource Agency Department of Fish and Game. March 7, 2012. 21 California Department of Fish and Wildlife (CDFW). 2018. Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities. March 20, 2018. 1324
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The project site was evaluated for evidence of a wildlife movement corridor during the reconnaissance-level survey and review of aerial photographs, and CDFW’s BIOS6 information on Bay Area Linkages. The focus of this study was to determine whether a change in land use at the project site could have significant impacts on the regional movement of wildlife. Conclusions are based on the information compiled during the literature review, aerial photographs, USGS topographic maps and resource maps for the vicinity; the field survey; and professional experience with the desired topography, habitat, and resource requirements of the special-status species potentially utilizing the project site and vicinity.
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This section summarizes the results of the literature research, database analyses, and field surveys listed in Section 3 above. Sensitive biological resources including special-status species and the impact analysis are addressed separately in Section 5 and 6 of this document.

4.1 - Environmental Setting
The project site is generally located on the northern boundary of the City of American Canyon, where commercial use is dominant. The project site is bordered by the Commerce Court extension and eucalyptus trees to the east, eucalyptus trees and North Slough to the west (beyond which is the Napa River), future SDG Commerce 217 project site to the north, and the active SDG Commerce 330 Distribution Center to the south.

4.1.1 - Topography and Hydrology
The project site is relatively flat with elevations ranging from 8 to 20 feet above sea level. The ground is undulating due to past land use disturbances including eucalyptus tree removal in 2012. The site slopes gently to the west toward the North Slough and the Napa River.

There are four wetland features (three seasonal wetlands and one linear wetland) along the northern boundary of the project site. In 2023, M&A mapped 0.023-acre of seasonal wetlands and

0.042-acre of linear wetlands within the delineation survey area. These wetlands have surface hydrologic connectivity to North Slough, which flows to the Napa River to the west. The Napa River is a traditional navigable water.

4.1.2 - Soils
The NRCS Web Soil Survey (WSS) depicts one soil type within the project site; Haire clay loam (148).

This soil type and its primary characteristics are summarized in Table 1 and depicted in Exhibit 4.

Table 1: Soil Types Present within Project Site
Soil Name Symbol Slope Description Acreage
Haire Clay Loam 148 2-9% Alluvium derived from sedimentary rock, moderately well drained, non-saline to very slightly saline.

10.17 1327

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Exh ibit 4
S oils Map
S ource: Bing Aerial Im agery. US DA S oils Data Mart, County of Am erican Canyon.

S TRAVINS KI DEVELOPMENT GROUP, LLC
S DG COMMERCE 220 DIS TRIBUTION CENTER PROJECT

BIOLOGICAL RES OURCE AS S ES S MENT
140 70 0 140
Feet
Legend
Project Site 10.17 acres
Soil Classification
148 - Haire clay loam, 2 to 9 percent slopes 10.17 acres 1329

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4.2 - Vegetation Communities and Land Cover Types
The following section describes the vegetation communities and land cover types present on the project site. The location and extent of each vegetation community is shown on Exhibit 5. These results are generally consistent with the results presented in the M&A BRA.

4.2.1 - Non-native Annual Grassland–Avena spp.–Bromus spp. Herbaceous SemiNatural Alliance This vegetation type is typically described by being dominated by non-native annual grasses and annual or perennial forbs from dense to sparse cover with less than 10 percent tree or shrub cover.

With a few exceptions, the plants are dead through the summer and fall dry season, persisting as seeds. This community usually occurs below 3,000 feet and is the most common herbaceous vegetation type of the region. This vegetation type is classified by the Manual of California Vegetation (MCV) as Avena spp.–Bromus spp. Herbaceous Semi-Natural Alliance, which has broad membership rules, but is dominated by a non-native annual grass species. The herb layer in this alliance is generally less than 1.2 meter and cover ranges from open to continuous. Trees and shrubs may be present at low cover. This community is found on various substrates including foothills, waste spaces, rangelands, and openings in woods.

The vast majority of the project site is generally considered non-native annual grassland, with a species composition that trends strongly toward ruderal. Individual scattered shrubs (including coyote brush [Baccharis pilularis]) and eucalyptus saplings and resprouts are not considered their own vegetation type due to small patch size, but rather a component of the grassland matrix (see membership rules, above).

The most predominant grass species within the project site included wild oats (Avena sp), canarygrass (Phalaris aquatica), medusahead (Taeniatherum caput-medusae), wall barley (Hordeum murinum), but equally dominant are ruderal species including mustard (Hirschfeldia incana), stinkwort (Dittrichia graveolens), Italian rye grass (Festuca perennis), ripgut brome (Bromus diandrus), soft chess (Bromus hordeaceus), slender wild oat (Avena barbata), common vetch (Vicia sativa), red-stem filaree (Erodium cicutarium), bull thistle (Cirsium vulgare), Italian thistle (Carduus pycnocephalus), bristly ox-tongue (Helminthotheca echioides), California burclover (Medicago polymorpha), and cut-leaf geranium (Geranium dissectum).

Large areas of this vegetation type were graded between May 29 and July 2, 2023 (see Appendix A and D.1). The grading did not encroach into the wetlands features or associated wetland buffer areas. The grading effectively eliminated the non-native grassland throughout much of the site. 1331

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Exhibit 5
Vegetation Com m unities and
Land Cover T ypes
Source: Bing Aerial Im agery. Mon k & Associates En viron m ental Con sultants, 08/2023.

ST RAVINSKI DEVELOPMENT GROUP, LLC
SDG COMMERCE 220 DIST RIBUT ION CENT ER PROJECT

BIOLOGICAL RESOURCE ASSESSMENT
200 100 0 200
Feet
Legend
Project Site 10.17 acres
Vegetation Communities and Land Cover Types
Avena spp.-Bromus spp. Herbaceous Semi-Natural Stand 9.46 acres Developed 0.65 acre
Seasonal wetland 0.02 acre
Linear Wetland 0.04 acre
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4.2.2 - Seasonal Wetlands
Seasonal wetland habitat is present on the project site, as shown in Exhibit 5. In 2011, the USACE confirmed 0.049-acre of wetlands and 0.004-acre of “other waters” adjacent to the former gravel road on the eastern edge of the project site. On December 6, 2011, the USACE confirmed the extent of its jurisdiction on the project site (USACE File Number 2011-00322N). This determination expired on January 31, 2017, as a result, M&A conducted a reverification wetland delineation of the project site on November 16, 2016. The map was field confirmed by the USACE on May 18, 2017, and an approved jurisdictional determination (AJD) was issued on May 16, 2018. It should be noted that the 2018 AJD included one isolated wetland that is no longer part of the project site. In 2023, M&A mapped 0.023-acre of seasonal wetlands (W1-W3) and 0.042-acre of linear wetlands (LW1) within the project site. On August 30, 2023, the USACE issued a Preliminary Jurisdictional Determination (PJD) which can be found in Appendix D.2.

Vegetation observed within the seasonal wetlands included non-native and native species. Nonnative species included spiny-fruit buttercup (Ranunculus muricatus; facultative wetland [FACW]) and Italian ryegrass (Festuca perennis; facultative [FAC]). Native species included creeping spikerush (Eleocharis macrostachya; obligate wetland species [OBL]), brown-headed rush (Juncus phaeocephalus; FACW) and spreading rush (Juncus patens; FACW). Mapped wetlands on the project site remain inundated and/or saturated seasonally for sufficient duration to satisfy wetland hydrology criteria. Hydrological indicators in the mapped wetlands include the presence of oxidized rhizosphere (a “primary” hydrological indicator) as well as biotic crust. Soil matrix colors in the wetland area identified in the field were noted as 10YR 3/2 with redoximorphic features. Soil matrix colors in areas mapped as non-hydric soils were noted as 10YR 3/3 and 10YR 3/2, with insufficient redoximorphic features. These wetland features were not impacted during the grading that occurred within upland portions of the project site between May 29 and July 2, 2023.

4.2.3 - Developed
While not a natural habitat type, urban/developed areas typically consist of buildings, hardscape such as asphalt or concrete and other man-made structures. Such areas typically provide little habitat value to most wildlife species. On-site, this landcover type can be found within the southeastern corner in the form of a construction trailer, a staging area, and a paved road that allows access into the site via Commerce Boulevard. The paved road runs half the length of the southern border of the project site.

4.3 - Wildlife
The vegetation community and land cover types discussed above provide habitat for numerous wildlife species. Wildlife activity during the 2023 field surveys consisted primarily of avian species, including Say's phoebe (Sayornis saya), American crow (Corvus brachyrhynchos), western bluebird (Sialia mexicana), Anna’s hummingbird (Calypte anna), lesser goldfinch (Spinus psaltria), yellowrumped warbler (Setophaga coronate), turkey vulture (Cathartes aura), red-shouldered hawk (Buteo lineatus), and California towhee (Melozone crissalis). Additionally, Botta’s pocket gopher (Thomomys bottae) burrows, black-tailed jackrabbit (Lepus californicus), and Columbian black-tailed deer (Odocoileus hemionus ssp. columbianus) were observed. Noteworthy, no signs of current or past 1335
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In general, FCS field surveys found that the conditions related to wildlife habitat are consistent with the results presented in the March 2020 M&A BRA which lists the following common wildlife species as observed on or near the project site: wild turkey (Meleagris gallopavo), house finch (Haemorhous mexicanus), black phoebe (Sayornis nigricans), Say's phoebe, American crow, mourning dove (Zenaida macroura), black-tailed jackrabbit, California meadow vole (Microtus californicus), Botta’s pocket gopher, and Mule deer (Odocoileus hemionus ), among others, all of which have been observed on the project site. Red-shouldered hawk, tree swallows (Tachycineta bicolor), Nuttall’s woodpecker (Picoides nuttallii), and northern flicker (Colaptes auratus), among others, likely nest in the eucalyptus trees that surround the project site to the west, north and south. Chestnut-backed chickadee (Poecile rufescens), brown creeper (Certhia americana), American robin (Turdus migratorius), northern mockingbird (Mimus polyglottos), spotted towhee (Pipilo maculatus), California towhee (Pipilo crissalis), dark-eyed junco (Junco hyemalis), Bullock’s oriole (Icterus bullockii) and western gray squirrel (Sciurus griseus) were also observed in the immediate project vicinity.

Wildlife use is expected to have decreased since M&A’s surveys because these surveys were conducted prior the construction of the warehouse to the south (SDG Commerce 330) and before the current construction began on the warehouse to the north (SDG Commerce 217). A comprehensive list of wildlife and plant species observed by FCS and Pinecrest can be found in Appendix E.

4.4 - Wildlife Movement Corridors and Nursey Sites
A wildlife corridor is an area of habitat connecting wildlife populations that can be separated by natural and anthropogenic dispersal barriers, including rugged terrain, changes in vegetation, development, or human disturbance. Wildlife corridors allow an exchange of individuals between populations, which may help prevent the negative effects of inbreeding and reduced genetic diversity (via genetic drift) that often occur within isolated populations.

The project site has been subject to decades of varying degrees of anthropogenic disturbances.

More recently, adjacent developments include the construction of SDG Commerce 330 to the south and the current construction of SDG Commerce 217 to the north. Dense industrial developments are located north of the project site while a school and single-family residences are found to the south.

Therefore, non-volant wildlife movement through the site is limited, and the site does not connect habitats suitable for sustainable wildlife populations. Wildlife may utilize the off-site eucalyptus grove and aquatic habitats (e.g., North Slough and Napa River) to the west for dispersal; however, the proposed project would be set back from the eucalyptus grove and aquatic habitats. No direct impacts to the eucalyptus grove and marsh habitat would occur from project construction.

There are no native wildlife nursery sites present within the project site. 1336
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Biological Resources Assessment Results
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4.5 - Protected Trees
No tree removal is proposed, the project site does not contain any trees.

4.6 - Habitat Conservation Plans
No habitat conservation plans exist for the project site. 1337

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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Sensitive Biological Resources FirstCarbon Solutions 35 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx SECTION 5: SENSITIVE BIOLOGICAL RESOURCES
The following section discusses the extent to which sensitive biological resources are present or expected on-site. Sensitive biological resources are protected by laws and regulations, including CEQA (see Section 2 for details).

5.1 - Sensitive Natural Communities
The CDFW maintains a list of natural communities that classifies vegetation types found within the State of California and ranks them based on rarity. Communities ranked S1-S3 are considered sensitive natural communities.22 Wetlands and riparian habitats are also typically considered sensitive natural communities and are addressed in the environmental review process.

5.1.1 - Seasonal Wetland Communities
The vegetation communities of the four wetland features are dominated by both non-native, and native hydrophytic species as described in detail in Section 4.2.2. Naturally occurring seasonal wetland plant communities can be considered sensitive natural communities.

5.2 - Special-status Plant Species
The CNDDB and CNPS list 45 special-status or sensitive plant species that have been recorded within the Cuttings Wharf, California, USGS Topographic Quadrangle Map and the eight surrounding quadrangles (Appendix B).23,24,25 The CNDDB occurrences within the vicinity of the project site are shown on Exhibit 6. A list of all plant species recorded on-site during the protocol-level floristic surveys is included in Appendix E. No rare or special-status plant species were observed during the appropriately timed protocol-level floristic surveys (see Section 3.2.3) and are therefore determined to be absent from the site. This result is also supported by M&A’s March 2020 BRA, which additionally states that in the recent past, blue gum eucalyptus trees covered most of the project site dating back for several decades; these trees emit allelopathic (growth inhibiting) chemicals from their leaves, acorns and bark that prevent other plants from growing under them.26 22 California Department of Fish and Wildlife (CDFW). 2023. Natural Communities List, Sacramento: California Department of Fish and Wildlife. Website: https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities#sensitive%20natural%20communities. Accessed August 21, 2023. 23 United States Geological Survey (USGS). 2023. National Geospatial Program. Website: https://www.usgs.gov/core-sciencesystems/national-geospatial-program/us-topo-maps-america?qt-science_support_page_related_con=4#qtscience_support_page_related_con. Accessed August 21, 2023. 24 California Department of Fish and Wildlife (CDFW). 2023. CNDDB RareFind 5 California Natural Diversity Database Query for Specialstatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed August 21, 2023. 25 California Native Plant Society (CNPS). 2023. California Native Plant Society Rare and Endangered Plant Inventory. Website:
http://www.rareplants.cnps.org/. Accessed August 21, 2023. 26 Monk & Associates (M&A). 2020. Revised Biological Resource Analysis SDG Commerce 217 Distribution Center. March 2, 2020. 1339

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56390001 • 08/2023 | 6_CNDDB.m xd STR AVINSKI DEVELOPMENT GR OUP, LLC SDG COMMER CE 220 DISTR IBUTION CENTER PR OJECT

BIOLOGICAL R ESOUR CE ASSESSMENT
Exh ibit 6
CNDDB Spec ial-Status
Spec ies Oc c urrences
Source: Bing Street Im ag ery. California Natural Diversity Database (CNDDB), Aug ust 2023. 8 4 0 8
Miles
Legend
Project Site
CNDDB
Symbology
Plant (80m)
Plant (specific)
Plant (non-specific)
Plant (circular)
Animal (80m)
Animal (specific)
Animal (non-specific)
Animal (circular)
Terrestrial Comm. (80m)
Terrestrial Comm. (specific)
Terrestrial Comm. (non-specific)
Terrestrial Comm. (circular)
Aquatic Comm. (80m)
Aquatic Comm. (specific)
Aquatic Comm. (non-specific)
Aquatic Comm. (circular)
Multiple (80m)
Multiple (specific)
Multiple (non-specific)
Multiple (circular)
Sensitive EO's (Commercial only)
CNDDB version 08/2023. Please Note:

Th e oc c urrences sh ow n on th is m ap represent th e know n locations of th e spec ies listed h ere as of th e d ate of th is version. Th ere m ay be ad d itional oc c urrences or ad d itional species w ith in th is area w h ic h h ave not yet been surveyed and /or m apped . Lac k of inform ation in th e CNDDB about a species or an area can never be used as proof th at no special status species oc c ur in an area.
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5.3 - Special-status Wildlife Species
The CNDDB identifies 43 federal and State-listed threatened and/or endangered wildlife species and State Species of Special Concern that have been recorded within the Cuttings Wharf, California, USGS Topographic Quadrangle Map and the eight surrounding quadrangles (Appendix B).27,28 The CNDDB occurrences within the vicinity of the project site are shown on Exhibit 6. Thirty-five of these species are unlikely to occur on-site, as discussed in the Special-status Wildlife Species Habitat Value Evaluation Table (Appendix B, Table 2).

The remaining eight species (and functional groups like nesting birds and roosting bats that include special-status species) could have at least theoretical potential to occur on-site, perhaps as vagrant, dispersing, or foraging individuals, and are therefore discussed in more detail below.

5.3.1 - Swainson’s Hawk
The Swainson's hawk (Buteo swainsoni) is a State-listed threatened species protected pursuant to CESA and Title 14 of the California Code of Regulations. It is protected from direct take under the Federal MBTA of 1918 (16 USC 703-711). Swainson’s hawks, their active nests, eggs, and young are also protected under California Fish and Game Code (FGC §§ 3503, 3503.5, 3513, and 3800).

Swainson's hawk inhabits open to semi-open areas at low to middle elevations in valleys, dry meadows, foothills, and level uplands. It nests almost exclusively in trees and will nest in almost any tree species that is at least 10 feet tall.

Foraging habitats include grasslands, alfalfa fields, fallow fields, beet, tomato, and other low growing row or field crops, dry-land and irrigated pasture, and rice land when not flooded. Swainson's hawk generally forages in open habitats with short vegetation containing small mammals, reptiles, birds, and insects. Its primary prey in the Central Valley is California meadow vole. Agricultural areas are often preferred over more natural grassland habitats due to larger prey populations. During the nesting season Swainson’s hawk usually forage within 2 miles of the nest.

Swainson’s hawk does not require habitats that contain many perches because it most often searches for prey aerially, therefore it can occupy habitats with few or no perches except the nest tree. Swainson's hawks are regular summer visitors and breeders throughout the western states. In the fall months, most Swainson’s hawks migrate to Argentina before returning to the United States to breed in the late spring (typically April). For decades, Argentina farmers were spraying insecticides over habitats that included gregarious night roosts of the Swainson’s hawk, killing many thousands of these hawks. This practice was halted in the last 10 years and the Swainson’s hawk population appears to be dramatically responding in California. While in the 1970s through 1990s there were only two relatively small populations of Swainson’s hawks that remained resident in California yearround in the Davis area and in the Sacramento River Delta, resident and migrant populations of the 27 California Department of Fish and Wildlife (CDFW). 2023. CNDDB RareFind 5 California Natural Diversity Database Query for SpecialStatus Species. Website: https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed August 22, 2023. 28 California Department of Fish and Wildlife (CDFW). 2023. Biogeographic Information and Observation System (BIOS 6). Website:
https://map.dfg.ca.gov/bios/. Accessed August 22, 2023. 1343
SDG Commerce 220, LLC–220 Distribution Center Project
Sensitive Biological Resources Biological Resources Assessment 40 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx Swainson’s hawks are now dramatically expanding their nesting distribution in California since insecticide use over Argentinian wintering grounds was halted. For example, Swainson’s hawks were never recorded nesting in the Napa County area until relatively recently. 29 The closest known record for nesting Swainson’s hawk is 1.5 miles north of the project site (CNDDB Occurrence No. 2839). No individual Swainson’s hawk or nests have been observed on the site or in the vicinity of the project site during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site or seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. However, the eucalyptus trees growing adjacent to the project site could provide suitable nesting habitat. Therefore, there is the possibility that Swainson’s hawks could nest near this project site in future years.

5.3.2 - Western Burrowing Owl
The western burrowing owl (Athene cunicularia) is a California Species of Special Concern. Its nest, eggs, and young are also protected under California Fish and Game Code (FGC §§ 3503, 3503.5, and 3800). The burrowing owl is also protected from direct take under the MBTA (50 CFR 10.13).

Burrowing owl occurs in open, dry annual or perennial grasslands, deserts, and scrublands characterized by low growing vegetation. This species utilizes, modifies, and nests in burrows created by other species, most notably the California ground squirrel. They may also on occasion dig their own burrows or use man-made objects such as concrete culverts or rip-rap piles for cover.

The closest CNDDB record within the last 10 years was documented 2.7 miles north of the project site (CNDDB Occurrence No. 935). No evidence of burrowing owl activity was observed during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site or the seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. Furthermore, no California ground squirrel burrows were observed, and no other burrows or dens were observed that would provide suitable nesting habitat for burrowing owl.

However, it cannot be ruled out entirely that a vagrant burrowing owl may visit the site under unlikely circumstances before start of construction and could potentially be impacted by the proposed project.

5.3.3 - Northern Harrier
The northern harrier (Circus hudsonius) is a California Species of Special Concern. This raptor is protected under California Fish and Game Code Section 3503.5 that protects nesting raptors and their eggs/young and is also protected from direct take under the MBTA (50 CFR 10.13). Northern harriers build grass-lined nests on the ground within dense, low-lying vegetation in a variety of habitats, though they are typically found nesting in grassland or marsh habitats. They usually nest on level to near level ground. This species is particularly vulnerable to ground predators such as coyotes (Canis latrans), red fox (Vulpes vulpes), and various snake species.30 29 Monk & Associates (M&A). 2020. Revised Biological Resource Analysis SDG Commerce 217 Distribution Center. March 2, 2020. 30 Ibid. 1344
SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Sensitive Biological Resources FirstCarbon Solutions 41 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx The closest CNDDB record was documented 2.8 miles west of the project site (CNDDB Occurrence No. 29). No individual northern harriers or nests have been observed on the site or in the vicinity of the project site during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site or seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. However, northern harriers have the potential to nest in the open ruderal habitats on-site that provide marginal nesting habitat for this species. Therefore, there is the possibility that northern harriers could nest on or near this project site in the future.

5.3.4 - Golden Eagle
The golden eagle is a migratory California resident that resides in rolling foothills, mountain areas, sage-juniper flats, and deserts from sea level to 11,500 feet (3,833 meters). It feeds mostly on lagomorphs and rodents, and occasionally other mammals, birds, reptiles, and some carrion. The golden eagle hunts in open terrain including grasslands, deserts, savannas, and early successional stages of forest and shrub habitats. It is known to hunt in pairs and pirate food from other predators.

This species nests in large trees in open areas on cliffs. The breeding season for the golden eagle ranges from January through August, with a peak in March through July.

The closest CNDDB record was documented 4.5 miles southeast of the project site (CNDDB Occurrence No. 40). No individual golden eagles or nests have been observed on the site or in the vicinity of the project site during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site or seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. Regardless, the eucalyptus trees growing adjacent to the project site could provide suitable nesting habitat. Therefore, it cannot be ruled out that golden eagles could nest near this project site in the future.

5.3.5 - White-tailed Kite
The white-tailed kite (Elanus leucurus) is a whitish falcon-shaped raptor. This sensitive bird is designated by CDFW as a fully protected species (FGC § 3511). Fully protected animal species may not be taken or possessed at any time and no licenses or permits may be issued for their take except for collecting these species for necessary scientific research and relocation of the bird species for the protection of livestock.

Nesting white-tailed kite habitat consists mainly of oak and sycamore woodlands, but the birds also use mature willows. White-tailed kite nests have been documented in a variety of tree species, including oak (Quercus sp.), cottonwood (Populus sp.), willow (Salix sp.), California sycamore (Platanus racemosa), and elder (Acer sp.).
31 Nests are placed near the top of dense oak, willow, or other tree stand approximately 20-100 feet above ground. 32 Nest trees have a dense canopy or are
within a dense group of trees, such as riparian forest or oak woodland. Adjacent to their nesting woodland must be open foraging grasslands, where the birds can find their small mammal prey. 33 31 Science Applications International Corporation (SAIC). 2007. Draft Ecological Baseline Report for the Butte Regional Habitat Conservation Plan/Natural Community Conservation Plan. Prepared for the Butte County Association of Governments. May 2007. 32 California Department of Fish and Wildlife (CDFW). 1988. California’s Wildlife, Volume II: Birds. State of California Resources Agency.

Sacramento, California. 33 Gallagher, Sylvia. 1997. Atlas of Breeding Birds, Orange County, California. Sea and Sage Audubon Press, Irvine, CA. 1345
SDG Commerce 220, LLC–220 Distribution Center Project
Sensitive Biological Resources Biological Resources Assessment 42 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx White-tail kites forage in undisturbed, open grasslands, meadows, emergent wetlands, farmlands, crops, pastures, and other cultivated habitats. The white-tailed kite preys mostly on voles, but also takes other small, diurnal mammals, and occasionally birds, insects, reptiles, and amphibians.

The closest CNDDB record was documented 5.3 miles north of the project site (CNDDB Occurrence No. 181). Several white-tailed kite individuals were observed foraging over the site or in the vicinity of the project site during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site and seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. This species was observed on the following dates during 2023 surveys: March 20, April 4, April 5, April 6, April 7, April 24, April 28, and July 2. These individuals were observed to be continually harassed by several crows who were observed loitering around the eucalyptus grove. After continued interactions with the crows, white-tailed kite individuals flew off to the southwest out of sight and the location of their nest could not be determined.

The eucalyptus trees growing adjacent to the project site could provide suitable nesting habitat.

Therefore, it cannot be ruled out that white-tailed kite could nest within relevant disturbance distance.

5.3.6 - Protected Nesting Birds (Including All Special-status Bird Species) In addition to the specific special-status bird species discussed in more detail above, the active nests of most resident and migratory (game and non-game) birds (including the nests of additional specialstatus bird on-site) are protected by the MBTA and/or Fish and Game Code; and are therefore categorized as “special-status” wildlife functional group during this time. While a juvenile, redshouldered hawk was observed perched off-site within a large eucalyptus tree to the north of the SDG Commerce 217 site during the 2023 surveys, no active nests were observed.

The project site is adjacent to eucalyptus groves which provide nesting opportunities for different taxa of birds, and the site itself contains the potential for ground nesters. Although the site has been significantly disturbed in the past, the grassland on-site may provide marginal foraging opportunities to support nesting and rearing habitat. Therefore, it cannot be ruled out that protected bird nests are present on or within the disturbance distance of the project site during the nesting season (typically considered to last from February 1 to August 31 for most species).

5.3.7 - Bats (Including Special-status Bats)
The project site is adjacent to eucalyptus groves which offer potentially viable roosting habitat for bat species. A CNDDB recorded presence of bat species 5.2 miles northwest of the project site (CNDDB Occurrence No. 44). Bats could potentially use cavities in trees to roost and forage over the grassland and shrubland. Of the special-status bat species that has potential to occur in the region, the pallid bat (Antrozous pallidus) would be more likely to roost in natural features, such as the eucalyptus grove rather than artificial structures.

Roosts are used during the daytime to seek refuge; at night between foraging excursions to rest, digest prey, seek refuge from predators or poor weather conditions, or for social purposes; and in winter for hibernation. Adult females and their young use some particularly secure roosts as 1346
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At dusk, bats leave their roosts to forage for insects in nearby ponds or riparian habitats. Bats generally prey on insect species that are locally abundant near water bodies. Ecotone areas (areas of transition between habitats) are also used as foraging areas. The grassland habitat of the project site and eucalyptus grove adjacent has foraging and roosting potential for bat species. Therefore, it cannot be ruled out that bat roosts are within disturbance distance of the project site.

5.3.8 - Western Pond Turtle
The western pond turtle (Actinemys marmorata) is a California Species of Special Concern. This species feeds on aquatic plant material, including pond lilies, beetles, fishes, frogs, and a variety of invertebrate species. Pond turtles require basking sites such as partially submerged logs, rocks, mats of floating vegetation, or open mud banks. Turtles slip from basking sites to underwater retreats at the approach of humans or potential predators. In colder areas, this species hibernates underwater in bottom mud.

The closest CNDDB record was documented 0.4 mile northeast of the project site (CNDDB Occurrence No. 552). No western pond turtle individuals or nests have been observed on the site or in the vicinity of the project site during the 11 surveys conducted by Pinecrest on the SDG Commerce 220 site or seven surveys conducted by FCS on the adjacent SDG Commerce 217 site between January and July 2023. While there are seasonal wetland features present on-site there are no ponds or streams on-site that would be suitable for foraging or breeding. It cannot be ruled out entirely that a vagrant western pond turtle may be present on-site under unlikely circumstances before start of construction and could potentially be impacted by the project.

5.3.9 - Monarch Butterfly
The monarch butterfly (Danaus plexippus) is listed as Candidate under the Endangered Species Act, and wintering roosts are protected under the Fish and Game Code.

Preferred monarch habitat is filled with diverse nectar sources which support monarchs and native bees. Native milkweeds (Asclepias spp.) and other nectar sources provide monarchs with breeding habitat, resting, and refueling stops during migration, and food at overwintering sites.

Overwintering habitats consist of tree groves that typically occur within 1.5 miles of the Pacific coastline, or within the San Francisco Bay Area, where the proximity to large water bodies moderate temperature fluctuations. Overwintering begins in September or October. Suitable grove conditions include temperatures above freezing, high humidity, dappled sunlight, access to water and nectar, and protection from high winds and storms. Monarchs will select the native Monterey pine, Monterey cypress, western sycamore, and other native tree species when they are available, but will also utilize non-native eucalyptus species if other optimal habitat conditions are met. During breeding season in the late spring and summer, female monarch butterflies will lay their eggs on the underside of young leaves or flower buds of milkweeds, caterpillars then hatch within 3-5 days and begin to feed on milkweed leaves that provide energy and protective toxic compounds that protect 1347
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While no milkweed has been recorded on-site as confirmed through protocol-level rare plant surveys, the project site is bounded by dense stands of eucalyptus trees, potentially suitable for overwintering monarchs. Overwintering colonies have been documented on Mare Island, approximately 7 miles to the south. For these reasons, the presence of overwintering monarchs within disturbance distance cannot be ruled out.

5.4 - State or Federally Protected Waters and Wetlands
There are four wetlands features present within the project site as shown on Exhibit 5 and in Appendix D.2.34 The USACE issued a PJD on August 30, 2023 which includes 0.023-acre of seasonal wetlands and 0.042-acre of linear wetlands mapped within the project site. These wetlands have surface hydrologic connectivity to North Slough, which flows to the Napa River. The Napa River is a traditional navigable water. Consequently, the seasonal wetlands identified within the project site would likely be subject to USACE and RWQCB jurisdiction.

5.5 - Wildlife Movement Corridors and Nursery Sites
Field surveys and a query of CDFW’s BIOS6 information on wildlife linkages in the Bay Area confirm the that the proposed project will not interfere with the movement of native wildlife. The project site and adjacent areas are not identified by CDFW (The Critical Linkages: Bay Area and Beyond project; BIOS 6)35 as lands essential to maintain or restore functional connectivity among wildlands for all species or ecological processes of interest in the California Bay Area and as a vital adaptation strategy to conserve biodiversity during climate change.

The project site has a history of disturbance associated with eucalyptus tree removal in 2012, and continued disturbance associated with the paintball facility located immediately to the southeast.

Additionally, construction of the SDG Commerce 330 Distribution Center to the south recently occurred and construction of the SDG Commerce 217 site to the north is currently underway.

Wildlife may utilize the off-site eucalyptus grove and aquatic habitats (e.g., North Slough and Napa River) to the west for dispersal; however, the proposed project would not encroach into the off-site eucalyptus grove or aquatic habitats.

Wildlife nursery sites include nesting birds and maternity bat roosts, aquatic breeding habitat, and special-status and non-special-status wildlife breeding or nesting colonies. No significant breeding/nesting colonies were observed during the wildlife surveys. However, individual nesting birds and roosting bats have the potential of being present on-site and within disturbance distance seasonally.
34 Monk & Associates (M&A). 2023. Request for Reverification of Jurisdictional Determination and a PJD SDG Commerce 220 Project Site; USACE File Number: 2011-00322N American Canyon, California. May 31, 2023. 35 California Department of Fish and Wildlife (CDFW). 2022. Biogeographic Information and Observation System (BIOS 6): The Critical Linkages: Bay Area & Beyond project. Website: https://map.dfg.ca.gov/bios/. Accessed August 21, 2023. 1348
SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Impact Analysis and Recommendations FirstCarbon Solutions 45 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx SECTION 6: IMPACT ANALYSIS AND RECOMMENDATIONS
The following discussion addresses potential project impacts on sensitive biological resources, including special-status species, and recommends mitigation measures to avoid and/or mitigate impacts to a less than significant level under CEQA Guidelines.

6.1 - Impact Analysis for Sensitive Natural Communities Seasonal wetland communities are typically considered sensitive under CEQA. The wetland features on-site would be avoided by the proposed project through the implementation of 25-foot buffers (Exhibit 7). No other sensitive communities occur on-site. Therefore, no impacts on sensitive natural communities would occur.

6.2 - Impact Analysis for Special-status Species
The following section analyzes potential project-related impacts on special-status species potentially occurring on or within disturbance distance of the proposed project.

6.2.1 - Impact Analysis for Special-status Wildlife Species Swainson’s Hawk
Potentially suitable Swainson’s hawk nesting trees are located adjacent to the project site. If a Swainson’s hawk nest is active near the project site during construction, the proposed project could cause indirect harm to the species through the noise, light and other man-made disturbances resulting from project construction, which may result in this species abandoning its nests.

No Swainson hawks or nests were observed during the 18 field surveys conducted by FCS and Pinecrest in 2023. Out of an abundance of caution, FCS proposes that the project applicant implement the following mitigation measures (MM BIO-1a through MM BIO-1b) to avoid indirect impacts on Swainson’s hawk nesting habitat and to establish adequate nest protection zones to conform with CDFW Guidelines:36
MM BIO-1a Pre-construction Surveys for Swainson’s Hawk
Prior to ground disturbance that occurs during the nesting season for Swainson’s hawk (generally March 20 to July 20), a qualified Biologist shall conduct Swainson’s hawk nesting surveys within a 0.5-mile radius of the project site to determine whether nests are occupied. Occupancy shall be determined through observation of all accessible areas, including from public roads or other publicly accessible observation areas of Swainson’s hawk activity (e.g., foraging) on and near the project site.
36 California Department of Fish and Wildlife (CDFW). 2000. Recommended Timing and Methodology for Swainson's Hawk Nesting Surveys in California's Central Valley. Swainson’s Hawk Technical Advisory Committee. Sacramento, California. May 31, 2000. 1349
SDG Commerce 220, LLC–220 Distribution Center Project
Impact Analysis and Recommendations Biological Resources Assessment 46 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/5639/56390001/BRA/edit/56390001 Commerce Court 220 BRA.docx The qualified Biologist shall follow the survey protocol outlined in CDFW’s Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley, which recommends surveys according to the following survey periods:

I. January–March 20: Conduct one survey total.

II. March 20–April 5: Conduct three surveys total. Surveys shall be conducted between sunrise to 10:00 a.m. and/or 4:00 p.m. to sunset.

III. April 5–April 20: Conduct three surveys total. Surveys shall be conducted between sunrise to 12:00 p.m. and/or 4:30 p.m. to sunset.

IV. April 21–June 10: Initiating surveys are not recommended. Monitoring of known nest sites only.

V. June 10–July 30: (post-fledging) Conduct three surveys total. Surveys shall be conducted between sunrise to 12:00 p.m. and/or 4:00 p.m. to sunset.

Pre-construction surveys shall be completed for at least the two survey periods immediately prior to a project’s initiation.37
MM BIO-1b Swainson’s Hawk Avoidance and Minimization and Construction Monitoring If nests are located and determined to be occupied, minimization measures must be implemented, and construction monitoring conducted as follows:

1. Construction activities shall be prohibited within 600 feet of an active and occupied Swainson’s hawk nest, or within 600 feet of nests under construction, to prevent nest abandonment.

2. Notwithstanding the foregoing, if site-specific conditions or the nature of the construction activity (e.g., other nearby development, limited activities) indicate that a smaller buffer, or no buffer at all, could be used, the project applicant may seek approval from the qualified Biologist who in coordination with the California Department of Fish and Wildlife (CDFW) shall determine the appropriate buffer size, which, once approved, shall govern.

3. No tree containing an active Swainson’s hawk nest shall be removed.

Western Burrowing owl
No western burrowing owls have been observed on the project site during the 18 field surveys conducted by FCS and Pinecrest in 2023. Additionally, no suitable burrows or ground squirrels were observed on-site during the surveys. Therefore, the likelihood of presence on the project site is considered to be low. Since the western burrowing owl is a mobile species that could move onto the project site prior to development, pre-construction surveys are recommended out of an abundance of caution. If burrowing owl are present on-site before grading, the proposed project may result in impacts to the western burrowing owl, considered a potentially significant impact pursuant to CEQA. 37 California Department of Fish and Wildlife (CDFW). 2000. Recommended Timing and Methodology for Swainson's Hawk Nesting Surveys in California's Central Valley. Swainson’s Hawk Technical Advisory Committee. Sacramento, California. May 31, 2000. 1350
SDG Commerce 220, LLC–220 Distribution Center Project
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MM BIO-2 Pre-construction Surveys for Burrowing Owl (includes avoidance and passive relocation if found)
A qualified Biologist shall conduct a habitat assessment for wintering burrowing owl, and surveys if habitat is present. The qualified Biologist shall follow the California Department of Fish and Wildlife (CDFW) 2012 Staff Report on Burrowing Owl Mitigation habitat assessment and survey methodology prior to project activities occurring during the burrowing owl wintering season from September 1 to January

31. The habitat assessment and surveys shall encompass a sufficient buffer zone to detect owls nearby that may be impacted, which shall be a minimum of 1,640 feet unless otherwise approved in writing by the CDFW. Surveys shall include four nonbreeding season surveys spread evenly throughout the nonbreeding season pursuant to the CDFW 2012 Staff Report. Time lapses between surveys or project activities shall trigger subsequent surveys, as determined by a qualified Biologist, including but not limited to a final survey within 24 hours prior to ground disturbance and before construction equipment mobilizes to the project area. The qualified Biologist shall have a minimum of 2 years of experience implementing the CDFW 2012 Staff Report survey methodology resulting in detections.

Detected burrowing owls shall be avoided pursuant to the buffer zone prescribed in the CDFW 2012 Staff Report, unless otherwise approved in writing by CDFW, and any eviction plan shall be subject to CDFW review. Please be advised that CDFW does not consider eviction of burrowing owls (i.e., passive removal of an owl from its burrow or other shelter) as a “take” avoidance, minimization, or mitigation measure; therefore, off-site habitat compensation shall be included in the eviction plan.

Habitat compensation acreages shall be approved by CDFW, as the amount depends on-site-specific conditions, and must be completed before project construction unless otherwise approved in writing by CDFW. Habitat compensation shall also include placement of a conservation easement and preparation and implementation of a long-term management plan prior to project construction.

Other Protected Nesting Birds (including northern harrier, golden eagle, white-tailed kite and others)
The adjacent areas of the project site provide suitable nesting habitat for a variety of species of nesting birds, including potentially for special-status bird species including northern harrier, golden eagle, white-tailed kite, and others. Disturbed grassland and barren areas provide potential nesting opportunities for ground nesting birds. Construction activities that occur during the avian nesting season (generally February 1 to August 31) could disturb protected nesting sites within the construction footprint and within disturbance distance. Grading and the removal of vegetation during the nesting season could result in direct harm to nesting birds, while noise, light, and other 1351
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No active raptor nests were observed within the project site during the 2023 field surveys conducted by FCS and Pinecrest; however white-tail kite individuals were observed foraging over project site.

Additionally, a juvenile, red-shouldered hawk was observed perched off-site within a large eucalyptus tree to the north of the SDG Commerce 217 site. Although no active nests have been observed on-site, it cannot be ruled out that avian species may nest within disturbance distance of the project site. With implementation of MM BIO-3, requiring pre-construction nesting bird surveys and avoidance of direct and indirect impacts on nests, potential project-related impacts on protected bird nests can be reduced to a less than significant level under CEQA.

MM BIO-3 Protection of Active Bird Nests (includes pre-construction survey and implementation of avoidance buffer, if found).

1. If the proposed project requires vegetation to be removed during the nesting season (February 1 to August 31), pre-construction surveys shall be conducted no more than 7 days prior to the start of ground or vegetation disturbance (including tree removal) to determine whether or not active nests are present.

2. If an active nest is located during pre-construction surveys, a qualified Biologist shall determine an appropriately sized avoidance buffer based on the species and anticipated disturbance level. (The California Department of Fish and Wildlife [CDFW] recommends a minimum no-disturbance buffer of 250 feet around active nests of non-listed bird species and a 500-foot no-disturbance buffer around active nests of non-listed raptors.) A qualified Biologist shall delineate the avoidance buffer using Environmentally Sensitive Area (ESA) fencing, pin flags, and/or yellow caution tape. The buffer zone shall be maintained around the active nest site(s) until the young have fledged and are foraging independently.

No construction activities or construction foot traffic is allowed to occur within the avoidance buffer(s).

3. The qualified Biologist shall monitor the active nest during construction activities and modify the protection zone accordingly to prevent project-related nest disturbance, until the young have fledged.

Roosting Bats (including Pallid Bat)
The project site is adjacent to trees that could provide suitable bat roosting habitat, including for special-status bats such as pallid bat. Potential indirect impacts could occur to roosting bats due to the proximity to disturbance distance during project construction. These activities could potentially subject bats to risk of injury or disturbance, and they are likely to avoid using the area until such construction activities have dissipated or ceased. Relocation, in turn, could cause hunger or stress among individual bats by displacing them into adjacent territories belonging to other individuals. 1352
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MM BIO-4 Roosting Bat Pre-construction Survey and Avoidance A qualified Biologist with relevant roosting bat experience shall conduct a survey for special-status bats during the appropriate time of day to maximize detectability to determine whether bat species are roosting near the work area no less than 7 days and no more than 14 days prior to beginning ground disturbance and/or construction. Survey methodology may include visual surveys of bats (e.g., observation of bats during foraging period), inspection for suitable habitat, bat sign (e.g., guano), or use of ultrasonic detectors (Anabat, etc.) within 250 feet of project construction activities (where accessible).

If the Biologist determines or presumes bats are present, the Biologist shall exclude the bats from suitable spaces by installing one-way exclusion devices. After the bats vacate the space, the Biologist shall close off the space to prevent recolonization.

Grading shall only commence after the Biologist verifies 7 to 10 days later that the exclusion methods have successfully prevented bats from returning. To avoid impacts on non-volant (i.e., nonflying) bats, the Biologist shall only conduct bat exclusion and eviction from May 1 through October 1. Exclusion efforts may be restricted during periods of sensitive activity (e.g., during hibernation or while females in maternity colonies are nursing young).

Western Pond Turtle
No western pond turtles or nests were observed during the 2023 surveys conducted by FCS and Pinecrest. While the site appears to be unlikely to support western pond turtle, it cannot be ruled out entirely that a vagrant western pond turtle may be present on-site under unlikely circumstances before start of construction and could potentially be impacted by the project. Impacts to western pond turtle from the proposed project are considered potentially significant. MM BIO-5 would reduce this impact to a less than significant level through avoidance and minimization measures outlined below.

MM BIO-5 Protection of Western Pond Turtles
A qualified Biologist (i.e., a Biologist with at least 2 years of experience conducting surveys for western pond turtle detections) shall submit a wildlife exclusion fencing plan to the California Department of Fish and Wildlife (CDFW) for review and approval prior to starting construction. Exclusion fencing shall be installed along the western perimeter of the project site to prevent the species from traveling from North Slough onto the project site during construction. A qualified Biologist shall survey the project site and adjacent habitat within 72 hours of the start of project activities to determine whether western pond turtle or their nests are present and guide the installation of the exclusion fence. If western pond turtles are discovered, 1353
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Monarch Butterfly
There is a potential for monarch overwintering in the eucalyptus woodland adjacent to the site.

Construction activities, including dust, noise, and vibration adjacent to overwintering colonies could result in loss of overwintering monarch butterflies. Therefore, MM BIO-6 which includes a preconstruction survey and, if found, avoidance in coordination with USFWS and CDFW are recommended to reduce any potential impacts on monarch butterfly to less than significant.

MM BIO-6 Protection of Overwintering Monarch Butterfly
Activities such as vegetation removal, grading, or initial ground-disturbing activities shall be conducted between November 1 and July 31 (outside of the overwintering season) to the extent feasible. If such activities must be initiated during the overwintering season (August 1 through October 31), a pre-construction overwintering survey shall be conducted by a qualified Biologist no more than 7 days prior to vegetation removal, grading, or initial ground disturbance. The survey shall include the disturbance area and surrounding 250 feet to identify the location and status of any colonies that could potentially be affected either directly or indirectly by project activities. If no colonies are present, then project activities can commence as scheduled. If a colony is present, project construction shall cease immediately to avoid all direct and indirect impacts and report the presence of the colony to the United States Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) and follow all recommendations provided by USFWS and CDFW.

6.3 - Impact Analysis for Wildlife Nursery Sites and Wildlife Movement Corridors
The site does not function as a critical wildlife movement corridor, as discussed in Sections 4.4 and

5.5 above. This result is consistent with M&A’s March 2020 BRA (Appendix D.1). Certain common wildlife may move within or cross the site; however, it does not function to connect valuable habitats together, but rather it currently funnels wildlife east into a pocket of land generally surrounded with dense developments, including State Route (SR) 29 to the east, commercial and industrial areas to 1354
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Therefore, potential project-related impacts on wildlife movement are less than significant.

No substantial wildlife nursery sites, including breeding or nesting colonies, breeding ponds, or dens are present on-site. However, individual nesting birds and roosting bats have the potential of being present within disturbance distances seasonally. Potential impacts to individual nesting birds and roosting bats are addressed through the implementation of MM BIO-1 through MM BIO-4. As such, impacts to nursery sites would be less than significant.

6.4 - Impact Analysis for State and Federally Protected Waters and Wetlands The proposed project would avoid all impacts on potential jurisdictional wetland features through the implementation of a wetland buffer avoidance area (Exhibit 7). Additionally, the proposed project would be required to comply with applicable laws and regulations related to jurisdictional waters and wetlands (see Regulatory Background section). These generally applicable laws and regulations are designed to avoid any net loss of area and function, reducing any potential indirect or residual impacts to less than significant under CEQA.

6.5- Protected Trees
The proposed project would not remove any trees as there are no trees located within the project site. Therefore, the proposed project would not remove any City protected trees and no conflicts would occur.

6.6- Conflict with Habitat Conservation Plans
No adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State Habitat Conservation Plan is applicable to the project site. Therefore, the proposed project would not conflict with the provisions of such a document. 1355

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56390001 • 08/2023 | 7_im pacts.m xd
Exh ibit 7
Biological Im pacts
Source: Bing Aerial Im agery . Monk & Associates Environm ental Consultants, 08/2023.

STR AVINSKI DEVELOPMENT GR OUP, LLC
SDG COMMER CE 220 DISTR IBUTION CENTER PR OJECT

BIOLOGICAL R ESOUR CE ASSESSMENT
140 70 0 140
Feet
Legend
Project Site 10.17 acres
25' Wetland Buffer (No Project Impact) 0.65 acre
Permanent Impact 9.52 acres
Vegetation Communities and Land Cover Types Project Site Perm Impact No Impact Avena spp.-Bromus spp. Herbaceous Semi-Natural Stand 9.46 acres 8.87 acres 0.59 acre Developed 0.65 acre 0.65 acre 0.00 acre
Seasonal wetland 0.02 acre 0.00 acre 0.02 acre
Linear Wetland 0.04 acre 0.00 acre 0.04 acre
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Appendix A:

Site Photographs
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Photograph 1: 4.3.1–Non-na�ve annual grassland facing west Photograph 2: Eucalyptus saplings next to seasonal wetlands facing north 1361
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Photograph 3: Eucalyptus grove on the western periphery of the project site facing north.

Photograph 4: Grading within the project site and sectioned off seasonal wetland facing west. 1362
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Photograph 5: Grading throughout the south of the project site facing west. 1363

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Appendix B:

Special-status Species Tables
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Table 1: Special-status Plant Species Habitat Value Evaluation Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Agrostis hendersonii
Henderson's bent grass
— — 3.2 Valley and foothill grassland, vernal pools.

Moist places in grassland or vernal pool
habitat.

Elevation: 65-1030 m.

Blooming Period: April-June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Allium peninsulare var.
franciscanum
Franciscan onion
— — 1B.2 Cismontane woodland, valley, and foothill
grassland. Clay soils; often on serpentine;
sometimes on volcanics. Dry hillsides.

Elevation: 5-320 m.

Blooming Period: May-June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Amorpha californica var.
napensis
Napa false indigo
— — 1B.2 Dicot, perennial shrub found in broadleaf
upland forest or chaparral openings
Elevation: 30–590 m.

Blooming period: April–July.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Astragalus tener var. tener
alkali milk-vetch
— — 1B.2 Alkali playa, valley and foothill grassland,
vernal pools. Low ground, alkali flats, and
flooded lands; in annual grassland or in
playas or vernal pools.

Elevation: 0-170 m
Blooming Period: May-July

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Balsamorhiza macrolepis
big-scale balsamroot
— — 1B.2 Chaparral, cismontane woodland and
valley and foothill grassland. Sometimes
occurs in serpentinite soils.

Elevation: 45-1555 m.

Blooming period: March-June.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Blennosperma bakeri
Sonoma sunshine
FE SE 1B.1 Vernal pools, wet grasslands and swales.

Elevation: 10-290 m.

Blooming Period: March-May

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Blepharizonia plumosa
big tarplant
— — 1B.1 Valley and foothill grassland. Dry hills &
plains in annual grassland. Clay to clayloam soils; usually on slopes and often in burned areas.

Elevation: 60-505 m.

Blooming Period: July-October

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Brodiaea leptandra
narrow-anthered brodiaea
— — 1B.2 Monocot perennial herb found in open
mixed-evergreen forest, chaparral, and
gravelly soils.

Elevation: 70–610 m.

Blooming period: May–July.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Calochortus pulchellus
Mt. Diablo fairy-lantern
— — 1B.2 Chaparral, cismontane woodland, riparian
woodland, valley, and foothill grassland.

Elevation: 30–840 m.

Blooming period: April–June.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Carex lyngbyei
Lyngbye's sedge
— — 2B.2 Marshes and swamps (brackish or
freshwater).

Elevation: 0–200 m.

Blooming period: April–August

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Castilleja affinis var.
neglecta
Tiburon paintbrush
FE ST 1B.2 Valley and foothill grassland. Rocky
serpentine sites.

Elevation: 120–400 m.

Blooming period: April–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Ceanothus confusus
Rincon Ridge ceanothus
— — 1B.1 Volcanic slopes, chaparral, pine/oak
woodland.

Elevation: 75–1100 m.

Blooming period: February–April

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Ceanothus purpureus
holly-leaved ceanothus
— — 1B.2 Chaparral, cismontane woodland on
volcanic substrates or slopes.

Elevation: 140–720 m.

Blooming period: February–April

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Ceanothus sonomensis
Sonoma ceanothus
— — 1B.2 Chaparral, serpentine or volcanic
substrates.

Elevation: 140–795 m.

Blooming period: March–April

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Centromadia parryi ssp.
congdonii
Congdon's tarplant
— — 1B.1 Valley and foothill grassland. Alkaline soils
sometimes described as heavy white clay.

Elevation: 0–230 m.

Blooming Period: March–October

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Centromadia parryi ssp.
parryi
pappose tarplant
— — 1B.2 Chaparral, coastal prairie, meadows and
seeps, coastal salt marsh, valley and
foothill grassland. Vernally mesic, often
alkaline sites.

Elevation: 1-500 m.

Blooming period: March–November

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Chloropyron molle ssp. molle
soft salty bird's-beak
FE CR 1B.2 Coastal salt marsh. In coastal salt marsh
with Distichlis, Salicornia, Frankenia, etc.

Elevation: 0-5 m.

Blooming Period: July-November

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Cicuta maculata var.
bolanderi
Bolander's water-hemlock
— — 2B.1 Marshes and swamps. In fresh or brackish
water.

Elevation: 0-20 m.

Blooming Period: July-September

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Dirca occidentalis
western leatherwood
— — 1B.2 Broadleafed upland forest, chaparral,
closed-cone coniferous forest, cismontane
woodland, north coast coniferous forest,
riparian forest, riparian woodland. On
brushy slopes, mesic sites; mostly in mixed
evergreen and foothill woodland
communities.

Elevation: 20–640 m.

Blooming Period: November–March

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Downingia pusilla
dwarf downingia
— — 2B.2 Valley and foothill grassland (mesic sites),
vernal pools. Vernal lake and pool margins
with a variety of associates. In several
types of vernal pools.

Elevation: 1-490 m.

Blooming period: March-May

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Erigeron greenei
Greene's narrow-leaved
daisy
— — 1B.2 Perennial herb found in chaparral
(serpentinite or volcanic)
Elevation: 80 –1005 m
Blooming period: May–September

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Eryngium jepsonii
Jepson's coyote-thistle
— — 1B.2 Vernal pools, valley and foothill grassland.

In clay substrate.

Elevation: 3–305 m.

Blooming Period: May–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Extriplex joaquinana
San Joaquin spearscale
— — 1B.2 Chenopod scrub, meadows and seeps,
Playas, Valley and foothill grassland. In
seasonal alkali wetlands or alkali sink
scrub with Distichlis spicata, Frankenia,
etc.

Elevation: 0–800 m.

Blooming Period: April–September

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Fritillaria liliacea
fragrant fritillary
— — 1B.2 Coastal scrub, valley and foothill
grassland, coastal prairie, and cismontane
woodland. Often on serpentine; various
soils reported though usually on clay, in
grassland.

Elevation: 3–385 m.

Blooming Period: February–April

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Helianthella castanea
Diablo helianthella
— — 1B.2 Broadleafed upland forest, chaparral,
cismontane woodland, coastal scrub,
riparian woodland, valley and foothill
grassland. Usually in chaparral/oak
woodland interface in rocky, azonal soils.

Often in partial shade.

Elevation: 45-1070 m.

Blooming Period: April–September

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Hemizonia congesta ssp.
congesta
congested-headed hayfield
tarplant
— — 1B.2 Valley and foothill grassland. Grassy
valleys and hills, often in fallow fields;
sometimes along roadsides.

Elevation: 5-520 m.

Bloom period: April-November

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Hesperolinon breweri
Brewer's western flax
— — 1B.2 Chaparral, cismontane woodland, valley
and foothill grassland. Often in rocky
serpentine soil in serpentine chaparral and
serpentine grassland.

Elevation: 195-910 m.

Blooming Period: May-July

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Holocarpha macradenia
Santa Cruz tarplant
FT CE 1B.1 Coastal prairie, coastal scrub, valley and
foothill grassland. Light, sandy soil or
sandy clay; often with nonnatives.

Elevation: 10-275 m.

Blooming Period: June–October

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Horkelia tenuiloba
thin-lobed horkelia
— — 1B.2 Broad-leafed upland forest, chaparral,
valley and foothill grassland with sandy
soils. Often found in mesic habitats.

Elevation: 45-640 m.

Blooming period: May–July (August)

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Isocoma arguta
Carquinez goldenbush
— — 1B.1 Valley and foothill grassland. Alkaline soils, flats, lower hills. On low benches near
drainages and on tops and sides of
mounds in swale habitat.

Elevation: 1-50 m
Blooming Period: April–December

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Lasthenia conjugens
Contra Costa goldfields
FE — 1B.1 Valley and foothill grassland, vernal pools,
alkaline playas, cismontane woodland,
swales, low depressions, in open grassy
areas.

Elevation: 1–450 m.

Blooming Period: March–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Lathyrus jepsonii var.
jepsonii
Delta tule pea
— — 1B.2 Marshes and swamps. In freshwater and
brackish marshes. Often found with
Typha, Aster lentus, Rosa californica,
Juncus spp., Scirpus, etc. Usually on marsh
and slough edges.

Elevation: 0–5 m.

Blooming Period: May–July

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Legenere limosa
legenere
— — 1B.1 Vernal pools and in beds of vernal pools.

Elevation: 1–1005 m.

Blooming Period: April–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Leptosiphon jepsonii
Jepson's leptosiphon
— — 1B.2 Dicot annual herb found in open to
partially shaded grassy slopes. On volcanic
soils or the periphery of serpentine
substrates.

Elevation: 100–570 m.

Blooming period: March–May.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Lilaeopsis masonii
Mason's lilaeopsi
— CR 1B.1 Marshes and swamps, riparian scrub. Tidal
zones, in muddy or silty soil formed
through river deposition or river bank
erosion. In brackish or freshwater.

Elevation: 0-10 m
Blooming Period: April-November

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Lupinus sericatus
Cobb Mountain lupine
— — 1B.2 Perennial herb found in broadleafed
upland forest, chaparral. cismontane
woodland, lower montane coniferous
forest.

Elevation: 275–1525 m
Blooming period: March–June.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Polygonum marinense
Marin knotweed
— — 3.1 Marshes and swamps.

Elevation: 0-10 m.

Blooming period: May–August

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Rhynchospora californica
California beaked-rush
— — 1B.1 Bogs and fens, open marshes and swamps,
lower montane coniferous forest,
meadows and freshwater seeps.

Elevation: 45-270 m.

Blooming period: May–July

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Senecio aphanactis
chaparral ragwort
— — 1B.2 Dicot annual herb found in chaparral,
cismontane woodland, and coastal scrub
habitat. Prefers drying alkaline flats.

Elevation: 15-800m.

Blooming period: January–April.

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Sidalcea hickmanii ssp.
napensis
Napa checkerbloom
— — 1B.1 Chamise chaparral, rocky volcanic soil.

Elevation: 400-600 m.

Blooming period: April-June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Spergularia macrotheca var.
longistyla
long-styled sand-spurrey
— — 1B.2 Marshes and swamps, meadows and
seeps. Alkaline.

Elevation: 0-220 m.

Blooming Period: February–May

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Symphyotrichum lentum
Suisun Marsh aster
— — 1B.2 Marshes and swamps (brackish and
freshwater). Most often seen along
sloughs with Phragmites, Scirpus,
blackberry, Typha, etc.

Elevation: 0-15 m.

Blooming Period: May–November

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Trichostema ruygtii
Napa bluecurls
— — 1B.2 Cismontane woodland, chaparral, valley
and foothill grassland, vernal pools. Often
in sunny, open areas
Elevation: 30-600m.

Blooming period: June–October

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Trifolium amoenum
two-fork clover
FE — 1B.1 Coastal bluff scrub, valley and foothill
grassland (sometimes serpentinite).

Elevation: 5-415 m.

Blooming period: April–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Trifolium hydrophilum
saline clover
— — 1B.2 Marshes and swamps, valley and foothill
grassland in mesic or alkaline soils, and
vernal pools.

Elevation: 0-300 m.

Blooming period: April–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.

Viburnum ellipticum
oval-leaved viburnum
— — 2B.3 Chaparral, cismontane woodland, lower
montane coniferous forest.

Elevation: 215-1400 m.

Blooming Period: May–June

Absent: The project site does not contain habitat suitable for this species. Absence confirmed through appropriately timed protocol-level rare plant surveys, in 2023.
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Scientific Name
Common Name
Status
Habitat Description4 ESA Habitat Value and Rationale 1 CESA2 CRPR3 Code Designations
1 Federal Status: 2023 Endangered Species Act (ESA)
Listing
2 State Status: 2023 California Endangered Species Act (CESA) Listing 3 California Rare Plant Rank (CRPR): 2023 CRPR Listing ESU = Evolutionary Significant Unit is a distinctive
population.

FE = Listed as endangered under the Endangered
Species Act.

FT = Listed as threatened under the Endangered
Species Act.

FC = Candidate for listing (threatened or endangered)
under the Endangered Species Act.

FD = Delisted in accordance with the Endangered
Species Act.

FPD = Federally Proposed to be Delisted.

MBTA = Protected by the Migratory Bird Treaty Act
— = Not federally listed
SE = Listed as endangered under the California
Endangered Species Act.

ST = Listed as threatened under the CESA.

SSC = Species of Special Concern as identified by the CDFW.

FP = Listed as fully protected under FGC.

CFG = FGC =protected by FGC 3503.5
CR = Rare in California.
— = Not state listed
Rank 1A = Plants species that presumed extinct in
California.

Rank 1B = Plant species that are rare, threatened, or
endangered in California and elsewhere.

Rank 2 = Plant species that are rare, threatened, or
endangered in California, but more common
elsewhere.

Rank 3 = Plants about which we need more information—A
Review List
Rank 4 = Plants of limited distribution—A Watch List
Blooming period: Months in parentheses are uncommon.

Notes:
4 Habitat Description: Habitat description adapted from CNDDB and CNPS online inventory or other specified source. 5 Potential to Occur and Rationale: Location of recorded species occurrences determined by geospatial information from BIOS 6 or other specified source.

Sources:

California Department of Fish and Wildlife (CDFW). 2023. CNDDB RareFind 5 California Natural Diversity Database Query for Special-Status Species. Website:
https://map.dfg.ca.gov/rarefind/view/RareFind.aspx. Accessed July 18, 2023.

California Native Plant Society (CNPS). 2023. California Native Plant Society Rare and Endangered Plant Inventory. Website: http://www.rareplants.cnps.org/. Accessed July 18, 2023.

California Department of Fish and Wildlife (CDFW). 2023. Biogeographic Information and Observation System (BIOS 6). Website: https://map.dfg.ca.gov/bios/. Accessed July 18, 2023. 1375
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Table 2: Special-status Wildlife Species Habitat Value Evaluation Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Amphibians
Dicamptodon ensatus
California giant
salamander
— SSC Known from wet coastal forests near streams and
seeps from Mendocino County south to Monterey
County, and east to Napa County. Aquatic larvae
found in cold, clear streams, occasionally in lakes and ponds. Adults known from wet forests under rocks
and logs near streams and lakes.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Rana boylii pop. 1
foothill yellow-legged frognorth coast DPS
— SSC Partly-shaded, shallow streams and riffles with a rocky substrate in a variety of habitats. Needs at least some cobble-sized substrate for egg-laying. Needs at least
15 weeks to attain metamorphosis.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Rana draytonii
California red-legged frog
FT SSC Lowlands and foothills in or near permanent sources of deep water with dense, shrubby or emergent
riparian vegetation. Requires 11-20 weeks of
permanent water for larval development
Absent. The project site is adjacent to mapped critical habitat for this species, but the project site is significantly developed, and the site and surrounding area does not
provide suitable habitat. Absence confirmed through
surveys in 2023.

Taricha rivularis
red-bellied newt
— SSC Lives in terrestrial habitats, juveniles generally underground, adults active at surface in moist
environments. Will migrate over 1 km to breed,
typically in streams with moderate flow and clean,
rocky substrate.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Birds
Agelaius tricolor
Tricolored blackbird
— ST
SSC
Breeds near fresh water in dense emergent
vegetation.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Aquila chrysaetos
Golden eagle
— FP Typically frequents rolling foothills, mountain areas, sage-juniper flats and desert
Low: The species has been recorded 4.5 miles southeast of the project site and the site is adjacent to marginal nesting habitat for the species. This species was not observed
during the 2023 surveys.

Athene cunicularia
Burrowing owl
— SSC Open, dry annual or perennial grasslands, deserts, and scrublands characterized by low-growing vegetation.

Subterranean nester, dependent upon burrowing
mammals, most notably, the California ground
squirrel.

Low. The species has been recorded 2.7 miles north of the project site and the site provides marginal habitat for the species. This species was not observed during the 2023
surveys.

Buteo swainsoni
Swainson's hawk
— ST Breeds in stands with few trees in juniper-sage flats, riparian areas, and in oak savannah. Requires adjacent
suitable foraging areas such as grasslands or alfalfa
fields supporting rodent populations.

Low. Land adjacent to the project site provides suitable nesting habitat. The closest known record of the species is

1.5 miles north of the project site. This species was not observed during the 2023 surveys.

Charadrius nivosus nivosus
western snowy plover
FT SSC Sandy beaches, salt pond levees and shores of large alkali lakes. Needs sandy, gravelly or friable soils for nesting.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Circus hudsonius
northern harrier
— SSC Coastal salt and freshwater marsh. Nest and forage in grasslands, from salt grass in desert sink to mountain
cienagas. Nests on ground in shrubby vegetation,
usually at marsh edge; nest built of a large mound of
sticks in wet areas.

Low. The species has been recorded 1.8 miles west of the project site and the site provides marginal nesting habitat for the species. This species was not observed during the 2023 surveys.

Coturnicops
noveboracensis
yellow rail
— SSC Shallow marshes, and wet meadows; in winter, drier fresh-water and brackish marshes, as well as dense,
deep grass, and rice fields.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Cypseloides niger
black swift
— SSC Coastal belt of Santa Cruz and Monterey counties; central & southern Sierra Nevada; San Bernardino &
San Jacinto mountains. Breeds in small colonies on
cliffs behind or adjacent to waterfalls in deep canyons and sea-bluffs above the surf; forages widely.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Elanus leucurus
white-tailed kite
— FP Grasslands and open coastal scrub in coastal and
valley lowlands; rarely found away from agricultural
areas. Inhabits herbaceous, open stages of most
habitats mostly in cismontane California.

Low: The species has been recorded 5.3 miles north of the project site and the site provides marginal nesting habitat for the species. Individuals were observed foraging over the project site in 2023.

Falco peregrinus anatum
American peregrine falcon
FD FP Near wetlands, lakes, rivers, or other water; on cliffs, banks, dunes, mounds; also, human-made structures.

Nest consists of a scrape or a depression or ledge in
an open site.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Geothlypis trichas sinuosa
saltmarsh common
yellowthroat
— SSC Resident of the San Francisco Bay region, in fresh and saltwater marshes. Requires thick, continuous cover
down to water surface for foraging; tall grasses, tule
patches, willows for nesting.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Laterallus jamaicensis
coturniculus
California black rail
— FP Inhabits freshwater marshes, wet meadows and
shallow margins of saltwater marshes bordering
larger bays. Needs water depths of about 1 inch that
do not fluctuate during the year and dense vegetation
for nesting habitat.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Melospiza melodia
maxillaris
Suisun song sparrow
— SSC Resident of brackish-water marshes surrounding
Suisun Bay. Inhabits cattails, tules and other sedges,
and Salicornia; also known to frequent tangles
bordering sloughs.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Melospiza melodia
samuelis
San Pablo song sparrow
— SSC Resident of salt marshes along the north side of San Francisco and San Pablo bays. Inhabits tidal sloughs in the Salicornia marshes; nests in Grindelia bordering
slough channels.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Rallus obsoletus obsoletus
California Ridgway's rail
FE FP Salt water and brackish marshes traversed by tidal sloughs in the vicinity of San Francisco Bay. Associated with abundant growths of pickleweed, but feeds away
from cover on invertebrates from mud-bottomed
sloughs

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Riparia riparia
bank swallow
— ST Nests in riparian scrub and riparian woodland.

Requires vertical banks/cliffs with fine-textured/sandy soils near streams, rivers, lakes, ocean to dig nesting hole.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Xanthocephalus
xanthocephalus
yellow-headed blackbird
— SSC Nests in freshwater emergent wetlands with dense
vegetation and deep water. Often along borders of
lakes or ponds. Nests only where large insects such as
Odonata are abundant, nesting timed with maximum
emergence of aquatic insects.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Fish
Acipenser medirostris pop.
1 green sturgeon-southern
DPS
FT — Spawning occurs primarily in cool (11-15 C) sections of mainstem rivers in deep pools (8-9 meters) with
substrate containing small to medium sized sand,
gravel, cobble, or boulder.

Absent: The project site does not contain habitat suitable for this species.

Hypomesus transpacificus
Delta smelt
FT — Aquatic and estuary habitats. Populations in the
Sacramento-San Joaquin Delta.

Absent: The project site does not contain habitat suitable for this species.

Oncorhynchus mykiss
irideus pop. 11
steelhead-Central Valley
DPS
FT — Populations in the Sacramento and San Joaquin rivers and their tributaries.

Absent: The project site does not contain habitat suitable for this species.

Pogonichthys
macrolepidotus
Sacramento splittail
— SSC Endemic to the lakes and rivers of the Central Valley, but now confined to the Delta, Suisun Bay and
associated marshes. Slow moving river sections, dead
end sloughs. Requires flooded vegetation for
spawning and foraging for young.

Absent: The project site does not contain habitat suitable for this species.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Spirinchus thaleichthys
longfin smelt
FC — Longfin smelt spend their adult life in bays, estuaries, and nearshore coastal areas, and migrate into
freshwater rivers to spawn. Spawning occurs primarily
from January through March, after which most adults
die.

Absent: The project site does not contain habitat suitable for this species.

Thaleichthys pacificus
eulachon
FT — Found in Klamath River, Mad River, Redwood Creek,
and in small numbers in Smith River and Humboldt
Bay tributaries. Spawn in lower reaches of coastal
rivers with moderate water velocities and bottom of
pea-sized gravel, sand, and woody debris.

Absent: The project site does not contain habitat suitable for this species.

Invertebrates
Branchinecta lynchi
vernal pool fairy shrimp
FT — Small vernal pools with cool water (10ºC), moderate alkalinity and conductivity, and less than 1 m deep.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Bombus crotchii
Crotch bumble bee
— SC This species occurs primarily in California, including coastal habitats, western Mojave Desert, San Joaquin
Valley, and adjacent foothills through most of
southwestern California. It inhabits arid grasslands
and shrublands, and its food sources including
milkweeds, pincushions, lupines, clovers, phacelias,
sages, clarkias, poppies, and buckwheats.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Bombus occidentalis
western bumble bee
— SC Formerly found in large parts of California but has been reduced in abundance and is now mostly
restricted to high meadows or coastal environments.

Species requires floral resources, and undisturbed
nest and overwintering sites

Absent: Historic records from 1962 of this species were found 7 miles away from the project site, but no recent recorded occurrence exists. The site is site is heavily disturbed from years of anthropogenic disturbances. This species was not observed during the 2023 surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Danaus plexippus
Monarch Butterfly
— — Occurs in temperate climates, such as eastern and
western North America and undergoes long-distance
migration. Lays eggs on obligate milkweed host plant
(primarily Asclepias spp.). Inhabits a variety of open
habitats including fields, meadows, weedy areas,
marshes, and roadsides. Adults feed on variety of
flowers including dogbane, lilac, red clover, lantana,
thistles, goldenrods, blazing stars, ironweed, and
tickseed sunflower.

Low: The species has been recorded 7 miles south of the project site. The site is adjacent to eucalyptus groves which provides marginal overwintering habitat for the
species. This species was not observed during the 2023
surveys.

Desmocerus californicus
dimorphus
valley elderberry longhorn
beetle
FT — Occurs only in the Central Valley of California, in association with blue elderberry (Sambucus
mexicana). Prefers to lay eggs in elderberries 2-8
inches in diameter; some preference shown for
"stressed" elderberries. Common in riparian scrub.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Speyeria callippe callippe
callippe silverspot butterfly
FE — Restricted to the northern coastal scrub of the San Francisco peninsula. Hostplant is Viola pedunculata.

Most adults found on east facing slopes; males
congregate on hilltops in search of females.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Syncaris pacifica
California freshwater
shrimp
FE — Endemic to Marin, Napa, and Sonoma counties. Found in low elevation, low gradient streams where riparian
cover is moderate to heavy. Shallow pools away from
main streamflow. Winter: undercut banks with
exposed roots. Summer: leafy branches touching
water.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Mammals
Antrozous pallidus
Pallid bat
— SSC Found in deserts, grasslands, shrublands, woodlands, and forests. Most common in open, dry habitats with
rocky areas for roosting. Roosts must protect bats
from high temperatures and include trees and
buildings. Species is very sensitive to disturbance of
roosting sites.

Low: The project site is adjacent to a eucalyptus grove that has potential roosting habitat for this species. Record of this species was found 5.2 miles northwest of the project site. This species was not observed during the 2023
surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Microtus californicus
sanpabloensis
San Pablo vole
— SSC Saltmarshes of San Pablo Creek, on the south shore of San Pablo Bay. Constructs burrow in soft soil. Feeds
on grasses, sedges and herbs. Forms a network of
runways leading from the burrow.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Nyctinomops macrotis
big free-tailed bat
— SSC Migrant bats using elevations from 0-2600 meters.

Roosts in rock crevices cliffs as well as in buildings, caves, and tree cavities

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Reithrodontomys
raviventris
salt-marsh harvest mouse
— FP Only in the saline emergent wetlands of San Francisco Bay and its tributaries. Pickleweed is primary habitat
but may occur in other marsh vegetation types and in
adjacent upland areas. Does not burrow; builds
loosely organized nests. Requires higher areas for
flood escape.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Sorex ornatus sinuosus
Suisun shrew
— SSC Tidal marshes of the northern shores of San Pablo and Suisun bays. Require dense low-lying cover and
driftweed and other litter above the mean hightide
line for nesting and foraging.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Sorex vagrans halicoetes
salt-marsh wandering
shrew
— SSC Salt marshes of the southern portion of the San
Francisco Bay. Marsh, wetland, or swamps with
Salicornia and abundant driftwood

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Taxidea taxus
American badger
— SSC Found in drier open stages of most shrub, forest and herbaceous habitats with friable soils, specifically
grassland environments. Natal dens occur on slopes.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Reptiles
Emys marmorata
western pond turtle
— SSC A thoroughly aquatic turtle of ponds, marshes, rivers, streams and irrigation ditches, usually with aquatic
vegetation, below 6000 ft elevation.

Low: The species has been recorded 0.4 miles northeast of the project site. Adjacent aquatic habitat west of the site provides marginal habitat for this species. This species was not observed during the 2023 surveys.
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Scientific Name
Common Name
Status
Habitat Description3 Habitat Value and Rationale4 ESA1 CESA/FGC2 Masticophis lateralis
euryxanthus
Alameda whipsnake
FT — Typically found in chaparral and scrub habitats but will also use adjacent grassland, oak savanna and
woodland habitats. Specifically, mostly south-facing
slopes and ravines, with rock outcrops, deep crevices
or abundant rodent burrows, where shrubs form a
vegetative mosaic with oak trees and grasses.

Absent: The project site does not contain habitat suitable for this species. This species was not observed during the 2023 surveys.

Code Designations
1 Federal Status: 2023 Endangered Species Act (ESA) Listing 2 State Status: 2023 California Endangered Species Act (CESA) Listing ESU = Evolutionary Significant Unit is a distinctive population.

FE = Listed as endangered under the Endangered Species Act.

FT = Listed as threatened under the Endangered Species Act.

FC = Candidate for listing (threatened or endangered) under the Endangered Species Act.

FD = Delisted in accordance with the Endangered Species Act.

FPD = Federally Proposed to be Delisted.

MBTA = protected by the Migratory Bird Treaty Act
— = Not federally listed
SE = Listed as endangered under CESA.

ST = Listed as threatened under CESA.

SSC = Species of Special Concern as identified by the CDFW.

FP = Listed as fully protected under the Fish and Game Code.

CFG = FGC = protected by Fish and Game Code 3503.5
CR = Rare in California.
— = Not State-listed
Notes:
3 Habitat Description: Habitat description adapted from CNDDB or other specified source. 4 Potential to Occur and Rationale: Location of recorded species occurrences determined by geospatial information from BIOS 6 or other specified source.

Sources:

California Department of Fish and Wildlife (CDFW). 2023. Biogeographic Information and Observation System (BIOS 6). Website: https://map.dfg.ca.gov/bios/. Accessed July 18, 2023 1383

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Appendix C:

Database Searches
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Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Accipiter cooperii
Cooper's hawk
ABNKC12040 None None G5 S4 WL
Acipenser medirostris pop. 1
green sturgeon - southern DPS
AFCAA01031 Threatened None G2T1 S1
Adela oplerella
Opler's longhorn moth
IILEE0G040 None None G2 S2
Agelaius tricolor
tricolored blackbird
ABPBXB0020 None Threatened G1G2 S2 SSC
Agrostis hendersonii
Henderson's bent grass
PMPOA040K0 None None G2Q S2 3.2
Allium peninsulare var. franciscanum
Franciscan onion
PMLIL021R1 None None G4G5T2 S2 1B.2
Amorpha californica var. napensis
Napa false indigo
PDFAB08012 None None G4T2 S2 1B.2
Andrena blennospermatis
Blennosperma vernal pool andrenid bee
IIHYM35030 None None G2 S1
Antrozous pallidus
pallid bat
AMACC10010 None None G4 S3 SSC
Aquila chrysaetos
golden eagle
ABNKC22010 None None G5 S3 FP
Ardea herodias
great blue heron
ABNGA04010 None None G5 S4
Astragalus tener var. tener
alkali milk-vetch
PDFAB0F8R1 None None G2T1 S1 1B.2
Athene cunicularia
burrowing owl
ABNSB10010 None None G4 S2 SSC
Balsamorhiza macrolepis
big-scale balsamroot
PDAST11061 None None G2 S2 1B.2
Blennosperma bakeri
Sonoma sunshine
PDAST1A010 Endangered Endangered G1 S1 1B.1
Blepharizonia plumosa
big tarplant
PDAST1C011 None None G1G2 S1S2 1B.1
Bombus caliginosus
obscure bumble bee
IIHYM24380 None None G2G3 S1S2
Bombus occidentalis
western bumble bee
IIHYM24252 None Candidate
Endangered
G3 S1
Bombus pensylvanicus
American bumble bee
IIHYM24260 None None G3G4 S2
Quad IS (Cuttings Wharf (3812223) OR Napa (3812233) OR Mt. George (3812232) OR Sonoma (3812234) OR Sears Point (3812224) OR Cordelia (3812222) OR Petaluma Point (3812214) OR Mare Island (3812213) OR Benicia (3812212)) Query Criteria:

Report Printed on Thursday, August 03, 2023
Commercial Version -- Dated July, 30 2023 -- Biogeographic Data Branch Page 1 of 5 Information Expires 1/30/2024
Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1387
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Branchinecta lynchi
vernal pool fairy shrimp
ICBRA03030 Threatened None G3 S3
Brodiaea leptandra
narrow-anthered brodiaea
PMLIL0C022 None None G3? S3? 1B.2
Buteo regalis
ferruginous hawk
ABNKC19120 None None G4 S3S4 WL
Buteo swainsoni
Swainson's hawk
ABNKC19070 None Threatened G5 S4
Calasellus californicus
An isopod
ICMAL34010 None None G2 S3
Calochortus pulchellus
Mt. Diablo fairy-lantern
PMLIL0D160 None None G2 S2 1B.2
Carex lyngbyei
Lyngbye's sedge
PMCYP037Y0 None None G5 S3 2B.2
Castilleja affinis var. neglecta
Tiburon paintbrush
PDSCR0D013 Endangered Threatened G4G5T1T2 S1S2 1B.2
Ceanothus confusus
Rincon Ridge ceanothus
PDRHA04220 None None G1 S1 1B.1
Ceanothus purpureus
holly-leaved ceanothus
PDRHA04160 None None G2 S2 1B.2
Ceanothus sonomensis
Sonoma ceanothus
PDRHA04420 None None G2 S2 1B.2
Centromadia parryi ssp. congdonii
Congdon's tarplant
PDAST4R0P1 None None G3T2 S2 1B.1
Centromadia parryi ssp. parryi
pappose tarplant
PDAST4R0P2 None None G3T2 S2 1B.2
Charadrius nivosus nivosus
western snowy plover
ABNNB03031 Threatened None G3T3 S3 SSC
Chloropyron molle ssp. molle
soft salty bird's-beak
PDSCR0J0D2 Endangered Rare G2T1 S1 1B.2
Cicuta maculata var. bolanderi
Bolander's water-hemlock
PDAPI0M051 None None G5T4T5 S2? 2B.1
Circus hudsonius
northern harrier
ABNKC11011 None None G5 S3 SSC
Coastal Brackish Marsh
Coastal Brackish Marsh
CTT52200CA None None G2 S2.1
Coturnicops noveboracensis
yellow rail
ABNME01010 None None G4 S2 SSC
Cypseloides niger
black swift
ABNUA01010 None None G4 S3 SSC
Danaus plexippus plexippus pop. 1
monarch - California overwintering population
IILEPP2012 Candidate None G4T1T2Q S2
Report Printed on Thursday, August 03, 2023
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Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1388
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Desmocerus californicus dimorphus
valley elderberry longhorn beetle
IICOL48011 Threatened None G3T3 S3
Dicamptodon ensatus
California giant salamander
AAAAH01020 None None G2G3 S2S3 SSC
Dirca occidentalis
western leatherwood
PDTHY03010 None None G2 S2 1B.2
Downingia pusilla
dwarf downingia
PDCAM060C0 None None GU S2 2B.2
Elanus leucurus
white-tailed kite
ABNKC06010 None None G5 S3S4 FP
Emys marmorata
western pond turtle
ARAAD02030 None None G3G4 S3 SSC
Erigeron greenei
Greene's narrow-leaved daisy
PDAST3M5G0 None None G3 S3 1B.2
Eryngium jepsonii
Jepson's coyote-thistle
PDAPI0Z130 None None G2 S2 1B.2
Extriplex joaquinana
San Joaquin spearscale
PDCHE041F3 None None G2 S2 1B.2
Falco peregrinus anatum
American peregrine falcon
ABNKD06071 Delisted Delisted G4T4 S3S4
Fritillaria liliacea
fragrant fritillary
PMLIL0V0C0 None None G2 S2 1B.2
Geothlypis trichas sinuosa
saltmarsh common yellowthroat
ABPBX1201A None None G5T3 S3 SSC
Gonidea angulata
western ridged mussel
IMBIV19010 None None G3 S2
Helianthella castanea
Diablo helianthella
PDAST4M020 None None G2 S2 1B.2
Hemizonia congesta ssp. congesta
congested-headed hayfield tarplant
PDAST4R0W1 None None G5T2 S2 1B.2
Hesperolinon breweri
Brewer's western flax
PDLIN01030 None None G2 S2 1B.2
Horkelia tenuiloba
thin-lobed horkelia
PDROS0W0E0 None None G2 S2 1B.2
Hydroprogne caspia
Caspian tern
ABNNM08020 None None G5 S4
Hypomesus transpacificus
Delta smelt
AFCHB01040 Threatened Endangered G1 S1
Isocoma arguta
Carquinez goldenbush
PDAST57050 None None G1 S1 1B.1
Lasthenia conjugens
Contra Costa goldfields
PDAST5L040 Endangered None G1 S1 1B.1
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Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1389
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Laterallus jamaicensis coturniculus
California black rail
ABNME03041 None Threatened G3T1 S2 FP
Lathyrus jepsonii var. jepsonii
Delta tule pea
PDFAB250D2 None None G5T2 S2 1B.2
Legenere limosa
legenere
PDCAM0C010 None None G2 S2 1B.1
Leptosiphon jepsonii
Jepson's leptosiphon
PDPLM09140 None None G2G3 S2S3 1B.2
Lilaeopsis masonii
Mason's lilaeopsis
PDAPI19030 None Rare G2 S2 1B.1
Lupinus sericatus
Cobb Mountain lupine
PDFAB2B3J0 None None G2? S2? 1B.2
Masticophis lateralis euryxanthus
Alameda whipsnake
ARADB21031 Threatened Threatened G4T2 S2
Melospiza melodia maxillaris
Suisun song sparrow
ABPBXA301K None None G5T3 S2 SSC
Melospiza melodia samuelis
San Pablo song sparrow
ABPBXA301W None None G5T2 S2 SSC
Northern Coastal Salt Marsh
Northern Coastal Salt Marsh
CTT52110CA None None G3 S3.2
Northern Vernal Pool
Northern Vernal Pool
CTT44100CA None None G2 S2.1
Nycticorax nycticorax
black-crowned night heron
ABNGA11010 None None G5 S4
Nyctinomops macrotis
big free-tailed bat
AMACD04020 None None G5 S3 SSC
Oncorhynchus mykiss irideus pop. 8
steelhead - central California coast DPS
AFCHA0209G Threatened None G5T3Q S3
Pandion haliaetus
osprey
ABNKC01010 None None G5 S4 WL
Pogonichthys macrolepidotus
Sacramento splittail
AFCJB34020 None None G3 S3 SSC
Polygonum marinense
Marin knotweed
PDPGN0L1C0 None None G2Q S2 3.1
Rallus obsoletus obsoletus
California Ridgway's rail
ABNME05011 Endangered Endangered G3T1 S2 FP
Rana boylii pop. 1
foothill yellow-legged frog - north coast DPS
AAABH01051 None None G3T4 S4 SSC
Rana draytonii
California red-legged frog
AAABH01022 Threatened None G2G3 S2S3 SSC
Reithrodontomys raviventris
salt-marsh harvest mouse
AMAFF02040 Endangered Endangered G1G2 S3 FP
Report Printed on Thursday, August 03, 2023
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Selected Elements by Scientific Name
California Department of Fish and Wildlife
California Natural Diversity Database
1390
Species Element Code Federal Status State Status Global Rank State Rank Rare Plant
Rank/CDFW
SSC or FP
Rhynchospora californica
California beaked-rush
PMCYP0N060 None None G1 S1 1B.1
Riparia riparia
bank swallow
ABPAU08010 None Threatened G5 S3
Senecio aphanactis
chaparral ragwort
PDAST8H060 None None G3 S2 2B.2
Serpentine Bunchgrass
Serpentine Bunchgrass
CTT42130CA None None G2 S2.2
Sidalcea hickmanii ssp. napensis
Napa checkerbloom
PDMAL110A6 None None G3T1 S1 1B.1
Sorex ornatus sinuosus
Suisun shrew
AMABA01103 None None G5T1T2Q S1S2 SSC
Spergularia macrotheca var. longistyla
long-styled sand-spurrey
PDCAR0W062 None None G5T2 S2 1B.2
Speyeria callippe callippe
callippe silverspot butterfly
IILEPJ6091 Endangered None G5T1 S1
Speyeria zerene sonomensis
Sonoma zerene fritillary
IILEPJ6083 None None G5T1 S1
Spirinchus thaleichthys
longfin smelt
AFCHB03010 Candidate Threatened G5 S1
Symphyotrichum lentum
Suisun Marsh aster
PDASTE8470 None None G2 S2 1B.2
Syncaris pacifica
California freshwater shrimp
ICMAL27010 Endangered Endangered G2 S2
Taricha rivularis
red-bellied newt
AAAAF02020 None None G2 S2 SSC
Taxidea taxus
American badger
AMAJF04010 None None G5 S3 SSC
Trichostema ruygtii
Napa bluecurls
PDLAM220H0 None None G1G2 S1S2 1B.2
Trifolium amoenum
two-fork clover
PDFAB40040 Endangered None G1 S1 1B.1
Trifolium hydrophilum
saline clover
PDFAB400R5 None None G2 S2 1B.2
Viburnum ellipticum
oval-leaved viburnum
PDCPR07080 None None G4G5 S3? 2B.3
Xanthocephalus xanthocephalus
yellow-headed blackbird
ABPBXB3010 None None G5 S3 SSC
Record Count: 101
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California Natural Diversity Database
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment
FirstCarbon Solutions
Appendix D:

Supporting Documents
1413

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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment
FirstCarbon Solutions
D.1 - SDG Commerce Site 217 Documents
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UNITED STATES
T +1 888 826 5814
T +1 714 508 4100
F +1 714 508 4110
E [email protected]
Irvine
250 Commerce
Suite 210
Irvine, CA 92602
Bay Area
2999 Oak Road
Suite 250
Walnut Creek, CA 94597
Central Valley
7726 N. First Street
#413
Fresno, CA 93720
Inland Empire
967 Kendall Drive
#A-537
San Bernardino, CA 92407
Sacramento Valley
2351 Sunset Boulevard
Suite 170-301
Rocklin, CA 95765
Utah
2901 Bluegrass Boulevard
Suite 200-62
Lehi, UT 84043
Connecticut
2 Corporate Drive
Suite 450
Shelton, CT 06484
New York
10 Monument Street
Deposit, NY 13754
56 Broome Corporate Parkway
Conklin, NY 13748
CANADA

UNITED KINGDOM

PORTUGAL
FRANCE
KENYA

AUSTRALIA

PHILIPPINES
CHINA

MALAYSIA

SINGAPORE
1 Letter Report
April 20, 2023
John Wojtas
Industrial and Commercial Contractors, LP
413 W. Yosemite Avenue, Suite 105
Madera, CA 93637
Subject: Pre-construction Surveys and Implementation of CEQA Mitigation Measures BIO-1, BIO-2, BIO-3, BIO-4, and BIO-5 per the Mitigation Monitoring and Reporting Program for the Commerce 217 Warehouse Project, American Canyon, California
Dear John:

This letter summarizes results of pre-construction burrowing owl (Athene cunicularia), Swainson’s hawk (Buteo swainsoni), nesting raptor, nesting passerine bird, and western pond turtle (Actinemys marmorata) surveys conducted to-date by FirstCarbon Solutions (FCS) consulting Biologists Dr. Christopher DiVittorio and Bernhard Warzecha as they relate to compliance with CEQA Mitigation Measures (MM) BIO-1, MM BIO-2, MM BIO-3, MM BIO-4, and MM BIO-5 from the January 2021 Mitigation, Monitoring, and Reporting Program (MMRP) for the Commerce 217 Warehouse Project located in American Canyon, California.

The project site comprises a single parcel measuring 10.8 acres in size and consists of nonnative annual and perennial grassland with several small, mapped wetland features. The site is bounded by Commerce Court to the east, a developed warehouse to the north, an open field to the south beyond which is another developed warehouse, and a eucalyptus grove to the west.

Methods
Between January 18 and April 7, 2023, FCS conducted seven nesting bird and burrowing owl detection surveys (including for Swainson’s hawk) on the project site and relevant adjacent areas (where accessible), for a total of approximately 30 survey hours. Surveys for western pond turtle adults and nests were also performed simultaneously while walking the site.

Survey methods followed established procedures and applicable protocols, including the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (Protocol) and the Staff Report on Burrowing Owl Mitigation. 1,2
Survey
equipment included high-quality binoculars and a high-quality spotting scope. 1 Swainson’s Hawk Technical Advisory Committee. 2000. Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley. California Department of Fish and Wildlife, May 31, 2000. 2 California Department of Fish and Wildlife 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resource Agency Department of Fish and Game. March 7, 2012. 1417
2 Letter Report
Surveys were conducted during the appropriate times of day (including peak bird detection periods between sunrise and 10:00 a.m.). Surveys were conducted on foot. Survey dates conducted by FCS are shown below in Table 1.

Table 1: Survey Dates
Date Swainson’s Hawk Burrowing Owl Nesting Birds including Raptors 1/18/2023 Firstsurvey in Period I Burrowing owl breeding season survey
Nesting bird surveys–All Species
3/20/2023 First survey in Period II Burrowing owl breeding season survey
Nesting bird surveys–All Species
3/31/2023 Second survey in Period II Burrowing owl breeding season survey
Nesting bird surveys–All Species
4/4/2023 Third survey in Period II Burrowing owl breeding season survey
Nesting bird surveys–All Species
4/5/2023 First survey in Period III Burrowing owl breeding season survey
Nesting bird surveys–All Species
4/6/2023 Second survey in Period III Burrowing owl breeding season survey
Nesting bird surveys–All Species
4/7/2023 Third survey in Period III Burrowing owl breeding season survey
Nesting bird surveys–All Species
4/24/2023
(planned)
Swainson’s hawk
presence/absence survey
Burrowing owl breeding season
survey
Nesting bird surveys–All Species
Surveys were conducted by FCS consulting Biologists Dr. Christopher DiVittorio and Bernhard Warzecha, both of whom are experienced in conducting surveys for all of the aforementioned special-status species and have been previously approved by the California Department of Fish and Wildlife (CDFW).

Additionally Mr. Warzecha and Dr. DiVittorio have previous experience and training in the monitoring of Swainson’s hawk nesting, including Swainson’s hawk identification and behavioral patterns.

Results
A list of all species of birds observed at the different time points is provided below. No nesting birds were observed on the project site itself, and no nests of any protected species were observed off-site in the areas that could be accessed. White-tailed kites (Elanus leucurus) were observed foraging in the field, but they did not appear to be nesting nearby, as described below. No Swainson’s hawk or burrowing owl were observed during any of the avian surveys to-date. No adults or nests of western pond turtle were observed. All observed animal species are listed in Attachment A: Animal Species Observed. 1418
3 Letter Report
Swainson’s Hawk
No individuals of Swainson's hawk were observed during any of the surveys, and no raptor nests that could belong to Swainson's hawk were observed. The presence of other birds-of-prey utilizing territories on-site also indicates that Swainson's hawk are not utilizing this habitat currently. The negative survey results for Swainson’s hawk despite approximately 30 survey hours satisfies the requirements of the survey protocol for this species, therefore it is reasonable to conclude Swainson's hawk are absent from the project site.

Nesting Birds (Including Raptors)
FCS Biologists observed no active nests within the vicinity of the project site. Several American crow were loitering around the eucalyptus grove to the east of the parcel and harassing white-tail kites that approached the grove; however, their nest could not be located. Several white-tail kites were observed each day foraging over the grassland habitat; however, each time they flew off to the southwest out of sight and the location of their nest could not be determined. One juvenile red-tailed hawk was observed within the large eucalyptus tree along the north property line; however, this individual flew off-site after approximately 20 minutes. No other active nests were observed as of April 7.

Burrowing Owl
No evidence of burrowing owl activity was observed during any of the field surveys. No California ground squirrel burrows were observed on-site, and no other burrows or dens were observed that would provide suitable nesting habitat for burrowing owl. Therefore, it is reasonable to conclude burrowing owl is absent from the project site.

Western Pond Turtle
No evidence of western pond turtle activity was observed during any of the field surveys. There are some wetland features on-site, however no ponds or streams suitable for western pond turtle exist onsite and no signs of adults or nests were observed. Therefore, it is reasonable to conclude western pond turtle is absent from the project site.

Compliance
With implementation of the pre-construction surveys, and implementation of the recommendations for Swainson’s hawk, burrowing owl, nesting birds, and western pond turtle, the project is in compliance with MM BIO-1, MM BIO-2, MM BIO-3, MM BIO-4 and MM BIO-5. 1419
4 Letter Report
FCS appreciates the opportunity to assist you on this project. If you have any questions concerning this letter report, please contact me at [email protected].

Sincerely,
Janna Waligorski
Senior Project Manager
FirstCarbon Solutions
2999 Oak Road, Suite 250
Walnut Creek, CA 94597
530.519.9736
Attachment A: Animal Species Observed List
1420
Attachment A
Attachment A:

Animal Species Observed
1421
Attachment A
Commerce 217/220 Species List
Site Visit: 1/18/23
Birds: juvenile red-shouldered hawk (Buteo lineatus) sitting in eucalyptus tree on N fenceline, Western bluebird (Sialia mexicana), Anna's hummingbird (Calypte anna), turkey vulture (Cathartes aura), American pelican (Pelecanus erythrorhynchos), black phoebe (Sayornis nigricans), white-crowned sparrow (Zonotrichia leucophrys), Northern flicker (Colaptes auratus), crow (Corvus brachyrhynchos) Site Visit: 3/20/23
Start Time: 6:35 AM
Weather: no wind, 49 degF, 46% RH
Note: start at sunrise; park in SE corner
Bird Species: wild turkey (Meleagris gallopavo), turkey vulture (Cathartes aura), Canada goose (Branta canadensis), crow (Corvus brachyrhynchos), raven (Corvus corax), mourning dove (Zenaida macroura), lesser goldfinch (Spinus psaltria), dark-eyed junco (Junco hyemalis), Western bluebird (Sialia mexicana), red-shouldered blackbird (Agelaius phoeniceus), yellow-rumped warbler (Setophaga coronata), house finch (Haemorhous mexicanus), red-shouldered hawk (Buteo lineatus) two individuals soaring over the eucalyptus grove to the E of the site, house wren (Troglodytes aedon), American robin (Turdus migratorius), golden-crowned sparrow (Zonotrichia atricapilla), Nuttal's woodpecker (Picoides nuttallii), white-crowned sparrow (Zonotrichia leucophrys), American robin (Turdus migratorius), purple finch (Haemorhous purpureus), tree swallow (Tachycineta bicolor), American goldfinch (Spinus tristis), mallard ducks (Anas platyrhynchos), ruby-crowned kinglet (Regulus calendula), American pipit (Anthus rubescens), California gull (Larus californicus), brown-headed cowbird (Molothrus ater), Anna's hummingbird (Calypte anna), chestnut-backed chickadee (Poecile rufescens), White-tailed kite (Elanus leucurus)
Other Animals: black-tailed jackrabbit (Lepus californicus) Flowering Plants: California poppy (Eschscholzia californica), coastal heron’s bill (Erodium cicutarium), common groundsel (Senecio vulgaris), field marigold (Calendula arvensis) Site Visit: 3/31/23
Start time: 6:30 AM
Weather: clear, wind 0 mph, 44.5 degF, 76.5% RH
Notes: parked NE corner
Bird species: American robin (Turdus migratorius), house finch (Haemorhous mexicanus), crow (Corvus brachyrhynchos), red-shouldered blackbird (Agelaius phoeniceus), yellow-rumped warbler (Setophaga coronata), wild turkey (Meleagris gallopavo), mourning dove (Zenaida macroura), Western scrub jay (Aphelocoma californica), lesser goldfinch (Spinus psaltria), house wren (Troglodytes aedon), Canada goose (Branta canadensis), American goldfinch (Spinus tristis), house sparrow (Passer domesticus), 1422
Attachment A
Allen's hummingbird (Selasphorus sasin), kildeer (Charadrius vociferus), raven (Corvus corax), unknown gull likely Western or California, American coot (Fulica americana), European starling (Sturnus vulgaris), ruby-crowned kinglet (Regulus calendula), black phoebe (Sayornis nigricans) Other Animals: Mule deer (Odocoileus hemionus), domestic cat (Felis catus) Site Visit: 4/4/23
Start time: 6:35 AM
Weather: clear, 49 degF, no wind, 81% RH, 6:15 AM first light, 7:15 first direct sunlight Notes: parked SW corner
Bird Species: red-shouldered hawk (Buteo lineatus) perched on eucalyptus tree on N fenceline , wild turkey (Meleagris gallopavo) calling and all over parking area, White-tailed kite (Elanus leucurus) foraging and calling, house wren (Troglodytes aedon), house finch (Haemorhous mexicanus), mourning dove (Zenaida macroura), crow (Corvus brachyrhynchos), yellow-rumped warbler (Setophaga coronata), raven (Corvus corax), lesser goldfinch (Spinus psaltria), purple finch (Haemorhous purpureus), song sparrow (Melospiza melodia), mallard ducks (Anas platyrhynchos), red-shouldered blackbird (Agelaius phoeniceus), rock wren (Salpinctes obsoletus), black phoebe (Sayornis nigricans), European starling (Sturnus vulgaris), fox sparrow (Passerella iliaca), Northern mockingbird (Mimus polyglottos), tree swallow (Tachycineta bicolor), Canada goose (Branta canadensis), kildeer (Charadrius vociferus), Anna's hummingbird (Calypte anna), Western bluebird (Sialia mexicana) Other Animals: black-tailed jackrabbit (Lepus californicus) Site Visit: 4/5/23
Start time: 6:08 AM
Weather: 39 degF, 80% RH, no wind
Notes: met Jerry with Stravinsky on-site; parked SW corner Bird Species: red-shouldered hawk (Buteo lineatus) called from southwest corner of eucalyptus grove once, wild turkey (Meleagris gallopavo), house finch (Haemorhous mexicanus), crow (Corvus brachyrhynchos), yellow-rumped warbler (Setophaga coronata), California towhee (Melozone crissalis), raven (Corvus corax), mallard ducks (Anas platyrhynchos), red-shouldered blackbird (Agelaius phoeniceus), White-tailed kite (Elanus leucurus) 3 hovering various times over the field, Nuttal's woodpecker (Picoides nuttallii), European starling (Sturnus vulgaris), white-crowned sparrow (Zonotrichia leucophrys), black phoebe (Sayornis nigricans) Site Visit: 4/6/23
Start time: 6:17 AM
Weather: clear, 44 degF, 80% RH, no wind
Notes: fewer wildlife than yesterday; met Jerry with Stravinsky on-site; parked SW corner 1423
Attachment A
Bird Species: wild turkey (Meleagris gallopavo), house finch (Haemorhous mexicanus), crow (Corvus brachyrhynchos), yellow-rumped warbler (Setophaga coronata), California towhee (Melozone crissalis), brown creeper (Certhia americana), raven (Corvus corax), American robin (Turdus migratorius), Canada goose (Branta canadensis), red-shouldered hawk (Buteo lineatus) called from southwest corner of eucalyptus grove once similar to other mornings, White-tailed kite (Elanus leucurus) two individuals over east eucalyptus grove being chased by crows, song sparrow (Melospiza melodia), great blue heron (Ardea herodias) soaring overhead, unknown gulls soaring, lesser goldfinch (Spinus psaltria), Anna's hummingbird (Calypte anna), mallard ducks (Anas platyrhynchos), red-shouldered blackbird (Agelaius phoeniceus)
Other Animals: runways of black-tailed jackrabbit (Lepus californicus) and California vole (Microtus californicus)
Site Visit: 4/7/23
Start time: 6:30 AM
Weather: cloudy, 54.5 degF, 79% RH, wind 1-2 mph
Notes: fewer birds today, met Jerry on-site
Bird Species: Bewick's wren (Thryomanes bewickii), crow (Corvus brachyrhynchos), yellow-rumped warbler (Setophaga coronata), wild turkey (Meleagris gallopavo), hermit thrush (Catharus guttatus), Anna's hummingbird (Calypte anna), house wren (Troglodytes aedon), dark-eyed junco (Junco hyemalis), black phoebe (Sayornis nigricans), lesser goldfinch (Spinus psaltria), house finch (Haemorhous mexicanus), Nuttal's woodpecker (Picoides nuttallii), White-tailed kites (Elanus leucurus) being chased by crows then two foraging in field, cliff swallow (Petrochelidon pyrrhonota), cedar waxwing (Bombycilla cedrorum), American goldfinch (Spinus tristis), mallard ducks (Anas platyrhynchos), white-crowned sparrow (Zonotrichia leucophrys)
Other Animals: black-tailed jackrabbit (Lepus californicus) 1424

MONK & ASSOCIATES
Environmental Consultants
1136 Saranap Ave., Suite Q  Walnut Creek  California  94595 (925) 947-4867  FAX (925) 947-1165
September 3, 2020
Industrial and Commercial Contractors, LP
403 W. Yosemite Avenue, Suite 105
Madera, California 93637
Attention: Mr. Brian Doswald
RE: Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site SDG Commerce 217 Distribution Center, Napa, California
APN: 058-030-065-000
Dear Mr. Doswald:

1. INTRODUCTION
Monk & Associates, Inc., (M&A) has prepared this Addendum to our March 2, 2020, Revised Biological Resource Analysis (biology report) for the SDG Commerce 217 Distribution Center located in the City of American Canyon, California (the “project site”). Since the time M&A prepared our biology report for the project site, it has been determined that it will be necessary to acquire soil from the adjacent parcel to the south (the “borrow area parcel”) and transport this soil for use as clean fill on the project site. M&A has prepared this Addendum to our biology report to address the transportation of soil from the offsite borrow area parcel onto the project site and to analyze any affects this activity could have on mapped jurisdictional waters of the United States/State that lie inbetween the project site and the adjacent borrow area parcel.

Mapped waters of the United States are shown on the attached exhibits.

2. DESCRIPTION OF THE PROJECT SITE AND ADJACENT BORROW AREA PARCEL
The project site and the adjacent borrow area parcel were once part of a contiguous approximately 35-acre project site that M&A conducted surveys on over multiple years dating between 2006 and 2018. Both the project site and adjacent borrow area parcel are dominated by ruderal (weedy) vegetation including stinkwort (Dittrichia graveolens), Italian rye grass (Festuca perennis), ripgut brome (Bromus diandrus), soft chess (Bromus hordeaceus), slender wild oat (Avena barbata), common vetch (Vicia sativa), red-stem filaree (Erodium cicutarium), bull thistle (Cirsium vulgare), Italian thistle (Carduus pycnocephalus pycnocephalus), bristly oxtongue (Helminthotheca echioides), California burclover (Medicago polymorpha), and cut-leaf geranium (Geranium dissectum). These non-native, weedy species provide little habitat value to wildlife and they do not constitute a native plant community. Native, coyote brush (Baccharis pilularis subsp. consanguinea), a plant that responds to land disturbances, is also common on the 35 acres. Ruderal vegetation is the only vegetation community found on the project site. The adjacent borrow area parcel, however, in addition to supporting a ruderal herbaceous community also supports waters of the United States, as described below.

On May 16, 2018, the U.S. Army Corps of Engineers issued a jurisdictional determination confirming their jurisdiction over 0.043-acre of waters of the U.S. on the approximately 35-acre 1425
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parcel that comprises the project site, the adjacent borrow area parcel, and another property now known as 330 Commerce Center (see attached exhibits). The entire 0.043-acre of waters of the U.S. confirmed by the Corps is found on the adjacent borrow area parcel as shown on the attached exhibit “Borrow Site Rough Grading,” Sheet 1 prepared by RSA on August 21, 2020.

There are no waters of the United States or State on the project site.

3. DISCUSSION OF PROPOSED ACTIVITIES AND AVOIDANCE OF IMPACTS TO

MAPPED WATERS OF THE UNITED STATES
The project applicant intends to rough grade the borrow area parcel and transport soil from that parcel onto the project site for use in development of the project site. In order to protect the waters of the United States/State that occur in between the project site and the borrow area parcel, a 25-foot buffer area around the outside edge of the wetlands will be staked and protected with fiber roll, silt fencing and high visibility orange construction fencing to prevent equipment from driving into the wetlands during hauling activities. See the attached exhibit.

With these protection measures in place, as shown on the attached Borrow Site Rough Grading exhibit, Sheet 1, attached, there are no expected impacts to waters of the U.S./State from the transport of soil/materials from the borrow area parcel to the project site.

This concludes our addendum to our biology report. If you have any questions or require additional information, please do not hesitate to contact me at (925) 323-4850 or [email protected]. Thank you.

Sincerely,
Sarah Lynch
Senior Associate Biologist
Attachments: U.S. Army Corps of Engineers Confirmed Aquatic Resources Delineation Map; Sheet 1, Borrow Site Rough Grading prepared by RSA, August 21, 2020 1426
SDG COMMERCE 217 DISTRIBUTION CENTER

BORROW SITE ROUGH GRADING

AMERICAN CANYON CALIFORNIA
1 1

PRELIMINARY - NOT FOR CONSTRUCTION

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DATE
JOB NO.

SHEET NO.

OF SHEETSAPPD REVISIONS BY DATE NO.

Printed on Recycled Paper Please Continue the Cycle
RSA | CONSULTING CIVIL ENGINEERS + SURVEYORS + + 1980 est. 1515 FOURTH STREET
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MONK & ASSOCIATES
Environmental Consultants
1136 Saranap Ave., Suite Q  Walnut Creek  California  94595 (925) 947-4867  FAX (925) 947-1165
Revised

BIOLOGICAL RESOURCE ANALYSIS
SDG COMMERCE 217 DISTRIBUTION CENTER

CITY OF AMERICAN CANYON, CALIFORNIA
March 2, 2020
Prepared for
SDG Commerce 217, LLC
413 W. Yosemite Ave. Suite 105
Madera, California 93637
Prepared by
Monk & Associates, Inc.
1136 Saranap Avenue, Suite Q
Walnut Creek, California 94595
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TABLE OF CONTENTS

1. INTRODUCTION...........................................................................................................................4

2. PROPERTY LOCATION AND SETTING................................................................................4

3. PROPOSED PROJECT.................................................................................................................5

4. ANALYSIS METHODS.................................................................................................................5

5. RESULTS OF RESEARCH AND PROJECT SITE ANALYSES...........................................5

5.1 Topography..............................................................................................................................5

5.2 Hydrology ................................................................................................................................5

5.3 Plant Communities and Associated Wildlife Habitats ...........................................................6

5.3.1 RUDERAL HERBACEOUS VEGETATION ....................................................................................6

5.4 Wildlife Corridors....................................................................................................................6

6. SPECIAL-STATUS SPECIES DEFINITION ............................................................................7

6.1 Definitions................................................................................................................................7

6.2 Potential Special-Status Plants on the Project Site .................................................................9

6.3 Potential Special-Status Animals in the Project Site ............................................................10

6.3.1 CALIFORNIA RED-LEGGED FROG ...........................................................................................10

6.3.2 SWAINSON’S HAWK................................................................................................................12

6.3.3 WESTERN BURROWING OWL.................................................................................................13

6.3.4 NORTHERN HARRIER ..............................................................................................................14

7. REGULATORY FRAMEWORK FOR NATIVE WILDLIFE, FISH, AND PLANTS......14

7.1 Federal Endangered Species Act...........................................................................................14

7.1.1 RESPONSIBLE AGENCY ..........................................................................................................16

7.1.2 APPLICABILITY TO THE PROPOSED PROJECT .........................................................................16

7.2 Federal Migratory Bird Treaty Act .......................................................................................17

7.2.1 APPLICABILITY TO THE PROPOSED PROJECT........................................................................17

7.3 California Endangered Species Act ......................................................................................17

7.3.1 SECTION 2081 OF THE CALIFORNIA ENDANGERED SPECIES ACT ........................................17

7.3.2 APPLICABILITY TO THE PROPOSED PROJECT........................................................................19

7.4 California Fish and Game Code § 3503, 3503.5, 3511, and 3513.......................................19

7.4.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................19

7.5 City of American Canyon General Plan ...............................................................................20

7.5.1 GOAL 8, OBJECTIVE 8.1 AND POLICIES 8.1.1 AND 8.1.4 .......................................................20

7.5.2 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................20

7.5.3 OBJECTIVE 8.2 AND POLICY 8.2.1..........................................................................................20

7.5.4 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................21

7.5.5 OBJECTIVE 8.3 AND POLICY 8.3.1..........................................................................................21

7.5.6 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................21

7.5.7 POLICY 8.3.1 B........................................................................................................................21

7.5.8 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................21

7.5.9 POLICY 8.3.1 E........................................................................................................................21

7.5.10 APPLICABILITY TO THE PROPOSED PROJECT ......................................................................21

7.5.11 POLICY 8.3.1 F ......................................................................................................................21

7.5.12 APPLICABILITY TO THE PROPOSED PROJECT ......................................................................22

7.5.13 POLICY 8.3.1 G .....................................................................................................................22

7.5.14 POLICIES 8.3.5 AND 8.3.6.....................................................................................................22

7.5.15 APPLICABILITY TO THE PROPOSED PROJECT .......................................................................22

8. CITY OF AMERICAN CANYON –ORDINANCES...............................................................22 1430
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8.1 Trees (Ord. 18.40.110) ..........................................................................................................22

8.1.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................22

9. REGULATORY REQUIREMENTS PERTAINING TO WATERS OF THE UNITED STATES AND STATE .....................................................................................................................22

9.1 U.S. Army Corps of Engineers Jurisdiction and General Permitting ..................................23

9.1.1 SECTION 404 OF THE CLEAN WATER ACT ............................................................................23

9.1.2 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................26

9.2 State Water Resources Control Board (SWRCB) / California Regional Water Quality Control Board (RWQCB)............................................................................................................26

9.2.1 SECTION 401 OF THE CLEAN WATER ACT ............................................................................26

9.2.2 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................27

9.3 California Department of Fish and Wildlife Protections......................................................27

9.3.1 SECTION 1602 OF CALIFORNIA FISH AND GAME CODE........................................................27

9.3.2 APPLICABILITY TO THE PROPOSED PROJECT........................................................................28

10. STATE WATER RESOURCES CONTROL BOARD (SWRCB)/RWQCB – STORM WATER MANAGEMENT..............................................................................................................28

10.1 Construction General Permit...............................................................................................28

10.1.1 APPLICABILITY TO THE PROPOSED PROJECT......................................................................30

10.2 RWQCB Municipal Storm Water Permitting Programs....................................................30

10.2.1 NPDES C.3 REQUIREMENTS ...............................................................................................30

10.2.2 APPLICABILITY TO THE PROPOSED PROJECT ......................................................................31

11. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) REGULATIONS .........32

12. IMPACTS ANALYSIS...............................................................................................................33

12.1 Significance Criteria............................................................................................................33

12.1.1 THRESHOLDS OF SIGNIFICANCE ..........................................................................................33

13. IMPACT ASSESSMENT AND PROPOSED MITIGATION..............................................34

13.1 Impact BIO-1. Development of the Project Could Have a Potentially Significant Impact on Nesting Swainson’s hawks (Potentially Significant).............................................................35

13.2 Mitigation Measure BIO-1. Mitigation for Potential Impacts to Nesting Swainson’s Hawk ............................................................................................................................................36

13.3 Impact BIO-2. Development of the Project Could Have a Potentially Significant Impact on Western Burrowing Owl (Potentially Significant)................................................................36

13.4 Mitigation Measure BIO-2. Mitigation for Potential Impacts to Western Burrowing Owl ......................................................................................................................................................36

13.5 Impact BIO-3: Development of the Project Would Have a Potentially Significant Impact on Tree or Ground Nesting Raptors (Potentially Significant)....................................................37

13.6 Mitigation Measure BIO-3: Mitigation for Potential Impacts to Tree or Ground Nesting Raptors.........................................................................................................................................37

13.7 Impact BIO-4: Development of the Project Would Have a Potentially Significant Impact on Nesting Passerine Birds. (Potentially Significant).................................................................38

13.8 Mitigation Measure BIO-4: Mitigation for Potential Impacts to Nesting Passerine Birds. ......................................................................................................................................................39

14. LITERATURE CITED ..............................................................................................................40 1431
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FIGURES
(At Back of Report)
Figure 1. SDG Commerce 217 Distribution Center Project Site Regional Map.

Figure 2. SDG Commerce 217 Distribution Center Project Site Location Map.

Figure 3. SDG Commerce 217 Distribution Center Project Site Aerial Photograph.

Figure 4. Known Special-Status CNDDB Records Within 3 Miles of the SDG Commerce 217 Distribution Center Project Site.

Figure 5. USFWS Critical Habitat in the Vicinity of the SDG 217 Commerce Distribution Center Project Site.

TABLES
(At Back of Report)
Table 1. Plant Species Observed on the SDG Commerce 217 Distribution Center Project Site.

Table 2. Wildlife Species Observed on the SDG Commerce 217 Distribution Center Project Site.

Table 3. Special-Status Plant Species Known to Occur Within 3 Miles of the SDG Commerce 217 Distribution Center Project Site.

Table 4. Special-Status Wildlife Species Known to Occur Within 3 Miles of the SDG Commerce 217 Distribution Center Project Site.

ATTACHMENTS
(At Back of Report)
Sheet A1. Preliminary Site Plan for the SDG Commerce 217 Distribution Center, prepared by WAI (Ward Architects, Inc.) dated January 15, 2020.

Sheet 2. Confirmed Reverification Aquatic Resources Delineation Map, dated May 22, 2017.

Sheet UP4. Utility Plan for the SDG Commerce 217 Distribution Center, prepared by RSA, dated January 2020.

Storm Drain Level Spreader Detail, prepared by RSA, dated January 7, 2020. 1432
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1. INTRODUCTION
Monk & Associates, Inc. (M&A) has prepared this biological resource analysis for the proposed SDG Commerce 217 Distribution Center project site (herein referred to as the project site) located in the City of American Canyon, California (Figures 1 and 2). The purpose of our analysis is to provide a description of existing biological resources on the project site and to identify potentially significant impacts that could occur to sensitive biological resources from the construction of a distribution center and associated parking on the project site.

Biological resources include common plant and animal species, and special-status plants and animals as designated by the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), National Marine Fisheries Service (NMFS), and other resource organizations, including the California Native Plant Society (CNPS). Biological resources also include waters of the United States and State, as regulated by the U.S. Army Corps of Engineers (Corps), California Regional Water Quality Control Board (RWQCB), and CDFW. Our analysis includes a formal delineation of “waters of the U.S.” that was confirmed in 2012 and reverified by the Corps in 2017.

This biological resources analysis also provides mitigation measures for “potentially significant” impacts that could occur to biological resources. Whenever possible, upon implementation, the prescribed mitigation measures would reduce impacts to levels considered less than significant pursuant to the California Environmental Quality Act (CEQA) (Pub. Resources Code §§ 21000 et seq.; 14 Cal. Code Regs §§ 15000 et seq). Accordingly, this report is suitable for review and inclusion in any review being conducted by the City of American Canyon for the proposed project pursuant to the CEQA.

2. PROPERTY LOCATION AND SETTING
The approximately 10-acre project site is located at 1075 Commerce Court, American Canyon, Napa County, California (Figures 1 and 2). The project site is bordered to the southeast by Jungle Paintball, a 40-acre paintball park. To the east is located a large eucalyptus grove with scattered mobile homes. Further to the east is Oat Hill, a geographically prominent hill west of Highway

29. A mix of open space, large warehouses and distribution centers occurs north of the project site. The American Canyon Wastewater Treatment Plant and treatment ponds is located west of the project site. The Napa River and associated marshes occur greater than 300 feet west of the project site. A large distribution center, known as the SDG Commerce 330 Distribution Center, is currently under construction occurs immediately to the south of the project site. Clark Ranch, Wetlands Edge Park, and salt marsh and mudflat habitats associated with the Napa River, occur further to the south of the project site. The Napa Valley Unified School District is constructing the Napa Junction Elementary School to the southeast, along Eucalyptus Drive. Figure 3 provides an aerial photograph that shows the project site features and the surrounding land use.

The 10.39-acre project site is part of a larger 35.85-acre parcel (formerly known as Lot 3) that is comprised of a highly disturbed, ruderal (weedy) plant community, that was recently graded and leveled. This site formerly was occupied by a grove of blue gum eucalyptus (Eucalyptus globulus) trees that were removed in 2012.
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3. PROPOSED PROJECT
The applicant proposes to construct a 217,294-square foot distribution center with associated parking areas and a detention/bioretention pond on the 10.39-acre project site. Access to the distribution center will be provided by the Commerce Court extension, as illustrated on the Preliminary Site Plan (see attached Sheet A1).

4. ANALYSIS METHODS
Prior to preparing this biological resources analysis report, M&A researched the most recent version of CDFW’s Natural Diversity Database, RareFind 5 application (CNDDB 2018) for historic and recent records of special-status plant and animal species (that is, threatened, endangered, rare) known to occur in the region of the project site. All special-status species records were compiled in tables. M&A examined all known record locations for special-status species to determine if special-status species could occur on the project site or within an area of affect.

M&A biologists have a long history of field surveys associated with the approximately 35-acre parcel. M&A biologists conducted site surveys on the parcel on March 1 and April 27, 2006, June 14, 2011, February 14, March 21, and June 12, 2012, May 18, 2017, and on March 30, 2018, December 19 and December 27, 2019. In 2006, and again in 2011, M&A conducted a wetland delineation on the entire parcel. This delineation of “waters of the U.S.” was confirmed by the Corps in 2012 and reverified by this agency in 2017. The Corps Confirmed Reverification of Aquatic Resources Delineation Map is provided as Sheet 2.

During the site surveys and wetland delineations, M&A biologists recorded biological resources and assessed the likelihood of resource regulated areas on the project site. In addition to the wetland delineations, the survey involved searching all habitats on the site and recording all plant and wildlife species observed. M&A cross-referenced the habitats found on the project site against the habitat requirements of local or regionally known special-status species to determine if the proposed project could directly or indirectly impact such species. The results of our literature research and field reconnaissance are provided in the sections below.

5. RESULTS OF RESEARCH AND PROJECT SITE ANALYSES

5.1 Topography
The project site is relatively flat with elevations ranging from 8 to 20 feet above sea level. The ground is undulating due to past land use disturbances including eucalyptus tree removal in 2012. The site slopes gently to the west towards North Slough and the Napa River.

5.2 Hydrology
There are no drainages on the project site. There are no indicators of hydrology on the 10-acre project site (Sheet 2).
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5.3 Plant Communities and Associated Wildlife Habitats
A complete list of plant species observed on the project site is presented in Table 1.

Nomenclature used for plant names follows The Jepson Manual Second Edition (Baldwin 2012) and changes made to this manual as published on the Jepson Interchange Project website (http://ucjeps.berkeley.edu/interchange/index.html). Table 2 is a list of wildlife species observed on the project site during multiple years of surveys at the project site. Nomenclature for wildlife follows CDFW’s Complete list of amphibian, reptile, bird, and mammal species in California (CDFW 2016) and any changes made to species nomenclature as published in scientific journals since the publication of CDFW’s list.

5.3.1 RUDERAL HERBACEOUS VEGETATION
A complete list of plant species observed within the project site is presented in Table 1. The project site is dominated by ruderal vegetation including stinkwort (Dittrichia graveolens), Italian rye grass (Festuca perennis), ripgut brome (Bromus diandrus), soft chess (Bromus hordeaceus), slender wild oat (Avena barbata), common vetch (Vicia sativa), red-stem filaree (Erodium cicutarium), bull thistle (Cirsium vulgare), Italian thistle (Carduus pycnocephalus pycnocephalus), bristly ox-tongue (Helminthotheca echioides), California burclover (Medicago polymorpha), and cut-leaf geranium (Geranium dissectum). Native, coyote brush (Baccharis pilularis subsp. consanguinea), a plant that responds to land disturbances, such as is found on the project site, is also common on this parcel.

Typically, ruderal communities provide habitat for those animal species adapted to humans.

Examples of animals associated with these communities include wild turkey (Meleagris gallopavo), house finch (Haemorhous mexicanus), black phoebe (Sayornis nigricans), Say's phoebe (Sayornis saya), American crow (Corvus brachyrhynchos), mourning dove (Zenaida macroura), California ground squirrel (Otospermophilus beecheyi), black-tailed jackrabbit (Lepus californicus), California meadow vole (Microtus californicus), and Botta’s pocket gopher (Thomomys bottae), among others, all of which have been observed on the project site. Redshouldered hawk (Buteo lineatus), tree swallows (Tachycineta bicolor), Nuttall’s woodpecker (Picoides nuttallii), and northern flicker (Colaptes auratus), among others, likely nest in the eucalyptus trees that surround the project site to the west, north and south. Chestnut-backed chickadee (Poecile rufescens), brown creeper (Certhia americana), American robin (Turdus migratorius), northern mockingbird (Mimus polyglottos), spotted towhee (Pipilo maculatus), California towhee (Pipilo crissalis), dark-eyed junco (Junco hyemalis), Bullock’s oriole (Icterus bullockii) and western gray squirrel (Sciurus griseus) were also observed in the immediate project vicinity.

5.4 Wildlife Corridors
Wildlife corridors are linear and/or regional habitats that provide connectivity to other natural vegetation communities within a landscape fractured by urbanization and other development.

Wildlife corridors have several functions: 1) they provide avenues along which wide-ranging animals can travel, migrate, and breed, allowing genetic interchange to occur; 2) populations can move in response to environmental changes and natural disasters; and 3) individuals can recolonize habitats from which populations have been locally extirpated (Beier and Loe 1992).

All three of these functions can be met if both regional and local wildlife corridors are accessible 1435
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to wildlife. Regional wildlife corridors provide foraging, breeding, and retreat areas for migrating, dispersing, immigrating, and emigrating wildlife populations. Local wildlife corridors also provide access routes to food, cover, and water resources within restricted habitats.

The proposed project will not interfere with the movement of native wildlife. The project site has a history of disturbance associated with eucalyptus tree removal in 2012, and continued disturbance associated with the paintball facility located immediately to the southeast and construction of the SDG Commerce 330 Distribution Center distribution center to the south. The eucalyptus grove and the marshes associated with the Napa River to the west of the project site provide a more valuable wildlife corridor for terrestrial wildlife.

6. SPECIAL-STATUS SPECIES DEFINITION

6.1 Definitions
For purposes of this analysis, special-status species are plants and animals that are legally protected under the California and Federal Endangered Species Acts (CESA and FESA, respectively) or other regulations, and species that are considered rare by the scientific community (for example, the CNPS). Special-status species are defined as:
• plants and animals that are listed or proposed for listing as threatened or endangered under the CESA (Fish and Game Code §2050 et seq.; 14 CCR §670.1 et seq.) or the FESA (50 CFR 17.12 for plants; 50 CFR 17.11 for animals; various notices in the Federal Register [FR] for proposed species);
• plants and animals that are candidates for possible future listing as threatened or endangered under the FESA (50 CFR 17; FR Vol. 64, No. 205, pages 57533-57547, October 25, 1999); and under the CESA (California Fish and Game Code §2068); • plants and animals that meet the definition of endangered, rare, or threatened under the California Environmental Quality Act (CEQA) (14 CCR §15380) that may include species not found on either State or Federal Endangered Species lists; • Plants occurring on Ranks 1A, 1B, 2A, 2B, 3, and 4 of CNPS’ electronic Inventory (CNPS 2017). The California Department of Fish and Wildlife (CDFW) recognizes that Ranks 1A, 1B, 2A and 2B of the CNPS inventory contain plants that, in the majority of cases, would qualify for State listing, and CDFW requests their inclusion in EIRs. Plants occurring on CNPS Ranks 3 and 4 are "plants about which more information is necessary," and "plants of limited distribution," respectively (CNPS 2001) (CNPS 2017).

Such plants may be included as special-status species on a case by case basis due to local significance or recent biological information (more on CNPS Rank species below); • migratory nongame birds of management concern listed by U.S. Fish and Wildlife Service (Migratory Nongame Birds of Management Concern in the United States: The list 1995; Office of Migratory Bird Management; Washington D.C.; Sept. 1995); 1436
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• animals that are designated as "species of special concern" by CDFW (2018); • Animal species that are “fully protected” in California (Fish and Game Codes 3511, 4700, 5050, and 5515).
• Bat Species that are designated on the Western Bat Working Group’s (WBWG) Regional Bat Species Priority Matrix as: “RED OR HIGH.” This priority is justified by the WBWG as follows: “Based on available information on distribution, status, ecology, and known threats, this designation should result in these bat species being considered the highest priority for funding, planning, and conservation actions. Information about status and threats to most species could result in effective conservation actions being implemented should a commitment to management exist. These species are imperiled or are at high risk of imperilment.”
In the paragraphs below we provide further definitions of legal status as they pertain to the special-status species discussed in this report or in the attached tables.

Federal Endangered or Threatened Species. A species listed as Endangered or Threatened under the FESA is protected from unauthorized “take” (that is, harass, harm, pursue, hunt, shoot, trap) of that species. If it is necessary to take a Federal listed Endangered or Threatened species as part of an otherwise lawful activity, it would be necessary to receive permission from the USFWS prior to initiating the take.

State Threatened Species. A species listed as Threatened under the state Endangered Species Act (§2050 of California Fish and Game Code) is protected from unauthorized “take” (that is, harass, pursue, hunt, shoot, trap) of that species. If it is necessary to “take” a state listed Threatened species as part of an otherwise lawful activity, it would be necessary to receive permission from CDFW prior to initiating the “take.”
California Species of Special Concern. These are species in which their California breeding populations are seriously declining and extirpation from all or a portion of their range is possible.

This designation affords no legally mandated protection; however, pursuant to the CEQA Guidelines (14 CCR §15380), some species of special concern could be considered “rare.” Pursuant to its rarity status, any unmitigated impacts to rare species could be considered a “significant effect on the environment” (§15382). Thus, species of special concern must be considered in any project that will, or is currently, undergoing CEQA review, and/or that must obtain an environmental permit(s) from a public agency.

CNPS Rank Species. The CNPS maintains an “Inventory” of special status plant species. This inventory has four lists of plants with varying rarity. These lists are: Rank 1, Rank 2, Rank 3, and Rank 4. Although plants on these lists have no formal legal protection (unless they are also state or federal listed species), CDFW requests the inclusion of Rank 1 species in environmental documents. In addition, other state and local agencies may request the inclusion of species on other lists as well. The Rank 1 and 2 species are defined below:
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• Rank 1A: Presumed extinct in California;
• Rank 1B: Rare, threatened, or endangered in California and elsewhere; • Rank 2A: Plants presumed extirpated in California, but more common elsewhere; • Rank 2B: Rare, threatened, or endangered in California, but more common elsewhere.

All of the plants constituting Rank 1B meet the definitions of Section 1901, Chapter 10 (Native Plant Protection Act) or Sections 2062 and 2067 (California Endangered Species Act) of the Fish and Game Code, and are eligible for state listing (CNPS 2001). Rank 2 species are rare in California, but more common elsewhere. Ranks 3 and 4 contain species about which there is some concern, and are reviewed by CDFW and maintained on “watch lists.” Additionally, in 2006 CNPS updated their lists to include “threat code extensions” for each list.

For example, Rank 1B species would now be categorized as Rank 1B.1, Rank 1B.2, or Rank 1B.3. These threat codes are defined as follows:
• .1 is considered “seriously endangered in California (over 80% of occurrences threatened/high degree and immediacy of threat)”;
• .2 is “fairly endangered in California (20-80% of occurrences threatened)”; • .3 is “not very endangered in California (less than 20% of occurrences threatened or no current threats known).”
Under the CEQA review process only CNPS Rank 1 and 2 species are considered since these are the only CNPS species that meet CEQA’s definition of “rare” or “endangered.” Impacts to Rank 3 and 4 species are not regarded as significant pursuant to CEQA.

Fully Protected Birds. Fully protected birds, such as the white-tailed kite and golden eagle, are protected under California Fish and Game Code (§3511). Fully protected birds may not be “taken” or possessed (i.e., kept in captivity) at any time.

6.2 Potential Special-Status Plants on the Project Site Figure 4 provides a graphical illustration of the known records for special-status species within 3 miles of the project site and helps readers visually understand the number of sensitive species that occur in the vicinity of the project site. No special-status plants have been mapped on or adjacent to the project site. However, according to the CDFW’s CNDDB, a total of eight specialstatus plant species are known to occur in the region of the project site (Table 3). Most of these plants occur in specialized habitats such as marshes, foothill grasslands, and vernal pools, none of which occur onsite. In the recent past, blue gum eucalyptus trees covered the majority of the project site dating back for several decades; these trees emit allelopathic (growth inhibiting) chemicals from their leaves, acorns and bark that prevent other plants from growing under them.

Once bark and leaf debris accumulate on the ground beneath the trees, nearly nothing will grow there. Based on the negative findings during the multiple surveys conducted on this site in 2006, 2011, 2012, 2017, 2018 and 2019, special-status plants are not likely to be found onsite and mitigation for special-status plants should not be warranted. 1438
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6.3 Potential Special-Status Animals in the Project Site Figure 4 provides a graphical illustration of the known records for special-status species within three miles of the project site and helps readers visually understand the number of sensitive species that occur in the vicinity of the project site. No special-status animal records have ever been mapped on or adjacent to the project site. However, a total of 18 special-status animal species are known to occur in the region of the project site (Table 4). Due to the disturbed nature of the project site and its history as a eucalyptus grove, there is a very low likelihood of specialstatus species occurring onsite. Regardless, due to the sensitivity of four of the special-status wildlife species known to occur in the area, we further discuss these species below.

6.3.1 CALIFORNIA RED-LEGGED FROG
The California red-legged frog (Rana draytonii) was federally-listed as threatened on May 23, 1996 (Federal Register 61: 25813-25833) and as such is protected pursuant to the Federal Endangered Species Act. On March 16, 2010 the USFWS issued the final designation for California red-legged frog Critical Habitat (USFWS 2010). The project site does not fall within mapped critical habitat, although it is adjacent (see Figure 5).

The California red-legged frog is also a state “species of special concern.” While the state designation “species of special concern” does not provide any legally mandated protection, species of special concern must be considered in any project undergoing a CEQA review.

The California red-legged frog is typically found in ponds, slow-flowing portions of perennial and intermittent streams that maintain water in the summer months. This frog is also found in hillside seeps that maintain pool environments or saturated soils throughout the summer months.

Populations probably cannot be maintained if all surface water disappears (i.e., no available surface water for egg laying and larval development habitat). Larval California red-legged frogs require 11-20 weeks of permanent water to reach metamorphosis (i.e., to change from a tadpole into a frog), in water depths of 10 to 20 inches (USFWS 2002). Riparian vegetation such as willows and emergent vegetation such as cattails are preferred red-legged frog habitats, though not necessary for this species to be present. Populations of California red-legged frog will be reduced in size or eliminated from ponds supporting non-native species such as bullfrog, Centrarchid fish species (such as sunfish, bluegill, or large-mouth bass), and signal and red swamp crayfish (Pacifastacus leniusculus and Procambarus clarkii, respectively), all of which are known California red-legged frog predators. However, the presence of these non-native species does not preclude the presence of the California red-legged frog.

California red-legged frogs also use upland habitats for migration and dispersal. The USFWS Recovery Plan for the California Red-Legged Frog states that frog overland excursions via uplands can vary between 0.25-mile up to 3 miles during the wet season, and that frogs “have been observed to make long-distance movements that are straight-line, point to point migrations rather than using corridors for moving in between habitats” (USFWS 2002). The information presented in the USFWS’ Recovery Plan was taken from a publication by Bulger et al. (2003) that recounts a study in coastal redwoods in Santa Cruz area. M&A believes that such overland straight-line migrations are primarily limited to periods of heavy rainfall or during periods when ambient conditions exhibit high moisture levels such as in fog belts along the coast. Working in 1439
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Point Reyes National Seashore on the coast of California, Fellers and Kleeman (2007) found approximately 31 percent of California red-legged frogs moved more than 30 meters from their breeding sites and about 69 percent moved less than 30 meters from their breeding site during seasonal movement periods. Similarly, Bulger et al. (2003) found that 60 percent of their radio tagged frogs stayed within 30 meters of their breeding sites.

In locations that are characterized by hot and seasonally dry climates, the California red-legged frog is inclined to stay closer to its aquatic environments or will not migrate. Tatarian (2005) who studied an inland population of California red-legged frogs in eastern Contra Costa County where the climate is far drier than the coastal environment, found that all movements started after the first 0.5 cm of rain in the fall, with more terrestrial movements being made in the fall prebreeding season (57%) than in the winter breeding season (32%) or spring post-breeding season (11%). Tatarian (op. cit.) also found that California red-legged frogs moved greater average distances aquatically (84.6 m) than terrestrially (27.7 m). Greater terrestrial distances were moved in the pre-breeding season (35.2 m) than in the breeding season (15.5 m) or post-breeding season (16.3 m) with the majority of movements occurring for only one of the 3-4 day survey periods. The majority of frogs (57%) were position faithful within a pool, indicating they did not migrate at all. These data suggest that long forays across the landscape found in coastal populations are less likely in dry inland locations.

The USFWS Recovery Plan for the California Red-Legged Frog states that populations are “most likely to persist where multiple breeding areas are embedded within a matrix of habitats used for dispersal.” “The primary constituent elements for California red-legged frogs are aquatic and upland areas where suitable breeding and non-breeding habitat is interspersed throughout the landscape and is interconnected by unfragmented dispersal habitat” (USFWS 2002).

In the American Canyon/Napa area, there are no records for the California red-legged frog west of State Route 29 where the project site is located. The closest known California red-legged frog occurrence is 1.4 miles east of the project site (CNDDB Occurrence No. 896). The California red-legged frog at this location was found in a dry cement tank adjacent to a large quarry pond that supported bullfrogs (Lithobates catesbeiana). State Route 29 is located between this closest California red-legged frog record and the project site and constitutes an effective geographic barrier to overland California red-legged frog movements to/from the known record location and other extant California red-legged frog populations to the project site. There is no hydrologic connectivity over any undeveloped migration route between the known records for this species and the project site. Finally, the project site does not provide suitable habitat for the California red-legged frog. Based on all the available information, it can be concluded that the project site does not provide suitable habitat for the California red-legged frog. Similarly, the surrounding parcels with dense eucalyptus groves do not provide suitable habitat. Owing to the excessively disturbed conditions on the project site due to prior grading and tree removal activities, this species is not expected to occur on the project site. Therefore, the proposed project will not impact the California red-legged frog and mitigation should not be warranted. 1440
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6.3.2 SWAINSON’S HAWK
The Swainson's hawk (Buteo swainsoni) is a state-listed threatened species, protected pursuant to the California Endangered Species Act (CESA), and Title 14 of the California Code of Regulations. While it has no special federal status, it is protected from direct take under the Federal Migratory Bird Treaty Act of 1918 (16 U.S.C. 703-711). Swainson’s hawks, their active nests, eggs, and young are also protected under California Fish and Game Code (§3503, §3503.5, §3513, and §3800).

Swainson's hawk inhabits open to semi-open areas at low to middle elevations in valleys, dry meadows, foothills, and level uplands (Kochert 1986). It nests almost exclusively in trees and will nest in almost any tree species that is at least 10 feet tall (Schmutz et. al. 1984). Nests are constructed in isolated trees that are dead or alive along drainages and in wetlands, or in windbreaks in fields and around farmsteads (Palmer 1988). Swainson’s hawks occasionally nest in shrubs, on telephone poles, and on the ground. In the Central Valley of California, the majority of Swainson's hawk nests and territories are associated with riparian systems and nests are commonly found in cottonwoods and oaks (Schlorff et. al. 1984). They have also been documented nesting in eucalyptus (Eucalyptus spp.), black walnut (Juglans hindsii), black locust (Robinia pseudoacacia), almond (Prunus dulcis), Osage orange (Maclura pomifera), Arizona cypress (Cupressus arizonica), and pine (Pinus spp.).

Foraging habitats include grasslands, alfalfa fields, fallow fields, beet, tomato, and other lowgrowing row or field crops, dry-land and irrigated pasture, and rice land when not flooded (CDFG 1994). The Swainson's hawk generally forages in open habitats with short vegetation containing small mammals, reptiles, birds, and insects. Its primary prey in the Central Valley is California meadow vole (Microtus californicus). Agricultural areas are often preferred over more natural grassland habitats due to larger prey populations. In addition, agricultural practices (planting, maintenance, harvesting, disking) allow for access to prey, and very likely increase foraging success of Swainson’s hawks by flushing prey (personal observations of G. Monk).

During the nesting season Swainson’s hawks usually forage within two miles of the nest.

Swainson's hawks are regular summer visitors and breeders throughout the western states. In the fall months, most Swainson’s hawks migrate to Argentina before returning to the United States to breed in the late-spring (typically April). For decades, Argentina farmers were spraying insecticides over habitats that included gregarious night roosts of the Swainson’s hawk, killing many thousands of these hawks. This practice was halted in the last 10 years and the Swainson’s hawk population appears to be dramatically responding in California. While in the 1970s through 1990s there were only two relatively small populations of Swainson’s hawks that remained resident in California year-round in the Davis area and in the Sacramento River Delta, resident and migrant populations of the Swainson’s hawks are now dramatically expanding their nesting distribution in California since insecticide use over Argentinian wintering grounds was halted (G. Monk, personal observations). For example, Swainson’s hawks were never recorded nesting in the Napa County area until relatively recently.
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The closest known record for nesting Swainson’s hawk is 2.6 miles northeast of the project site (CNDDB Occurrence No. 2744). No Swainson’s hawk nests have been observed on the site or offsite in the vicinity of the project site during M&A’s project site surveys. However, the nesting population appears to be increasing throughout its nesting range in northern California (recent CNDDB records and G. Monk general observations) and the eucalyptus trees growing adjacent to the project site provide suitable nesting habitat. Therefore, there is the possibility that Swainson’s hawks could nest near this project site in future years. Hence, prior to earthdisturbance or construction, nesting surveys must be conducted that confirm or negate this species’ presence as a nesting bird on or adjacent to the project site. Accordingly, impacts to Swainson’s hawk are regarded as potentially significant pursuant to the CEQA. Mitigation could be implemented to reduce these impacts to levels regarded as less than significant pursuant to the CEQA. The Impacts and Mitigation Measures that follow in the sections below address these impacts.

6.3.3 WESTERN BURROWING OWL
The western burrowing owl (Athene cunicularia hypugaea) is a California “species of special concern.” Its nest, eggs, and young are also protected under California Fish and Game Code (§3503, §3503.5, and §3800). The burrowing owl is also protected from direct take under the Migratory Bird Treaty Act (50 CFR 10.13). Finally, based upon this species’ rarity status, any unmitigated impacts to rare species would be considered a “significant effect on the environment” pursuant to §21068 of the CEQA Statutes and §15382 of the CEQA Guidelines.

Thus, this owl species must be considered in any project that will, or is currently, undergoing CEQA review, and/or that must obtain an environmental permit(s) from a public agency. When these owls occur on project sites, typically, mitigation requirements are mandated in the conditions of project approval from the CEQA lead agency.

Burrowing owl habitat is usually found in annual and perennial grasslands, characterized by lowgrowing vegetation. Often, the burrowing owl utilizes rodent burrows, typically California ground squirrel (Otospermophilus beecheyi) burrows, for nesting and cover. They may also on occasion dig their own burrows or use man-made objects such as concrete culverts or rip-rap piles for cover. They exhibit high site fidelity, reusing burrows year after year. Occupancy of suitable burrowing owl habitat can be verified at a site by observation of these owls during the spring and summer months or, alternatively, its molted feathers, cast pellets, prey remains, eggshell fragments, or excrement (white wash) at or near a burrow. Burrowing owls typically are not observed in grasslands with tall vegetation or wooded areas because the vegetation obscures their ability to detect avian and terrestrial predators. Since burrowing owls spend the majority of their time sitting at the entrances of their burrows, grazed grasslands seem to be their preferred habitat because it allows them to view the world at 360 degrees without obstructions.

The closest CNDDB record was documented 2.6 miles southeast of the project site in an area that has since been developed (CNDDB Occurrence No. 109). The project site was severely disturbed during the eucalyptus removal in 2012; thus, ground squirrel burrows are few and of recent origin. The mobility of the western burrowing owl enables the species to colonize the recent burrows. M&A did not observe western burrowing owls or any indirect evidence that burrowing owls are using or residing on the project site during any of the site surveys. 1442
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Regardless, the project site provides marginal nesting habitat for the western burrowing owl. In order to confirm or negate the presence of western burrowing owls on site, surveys must be conducted prior to the commencement of earth-moving or construction. Accordingly, impacts to western burrowing owl are regarded as potentially significant pursuant to the CEQA. Mitigation could be implemented to reduce these impacts to levels regarded as less than significant pursuant to the CEQA. The Impacts and Mitigation Measures that follow in the sections below address these impacts.

6.3.4 NORTHERN HARRIER
The northern harrier (Circus cyaneus) is a California species of special concern. This raptor is protected under California Fish and Game Code §3503.5 that protects nesting raptors and their eggs/young and is also protected from direct take under the Migratory Bird Treaty Act (50 CFR

10.13). Northern harriers build grass-lined nests on the ground within dense, low-lying vegetation in a variety of habitats, though they are typically found nesting in grassland or marsh habitats. They usually nest on level to near level ground. This species is particularly vulnerable to ground predators such as coyotes (Canis latrans), red fox (Vulpes vulpes), and various snake species. Ground nesting birds in general are also subject to disturbance by agricultural practices. Northern harriers may forage over the project site and may nest in the open ruderal habitats onsite that provide suitable nesting habitat for this species. Hence, the proposed project could result in impacts to nesting northern harriers.

The closest CNDDB record was documented 2.8 miles west of the project site (CNDDB Occurrence No. 29). The project site was severely disturbed during the eucalyptus removal in 2012. Regardless, the project site provides marginal nesting habitat for the northern harrier. In order to confirm or negate the presence of northern harriers on site, surveys must be conducted prior to the commencement of earth-moving or construction. Accordingly, impacts to northern harrier are regarded as potentially significant pursuant to the CEQA. Mitigation could be implemented to reduce these impacts to levels regarded as less than significant pursuant to the CEQA. The Impacts and Mitigation Measures that follow in the sections below address these impacts.

7. REGULATORY FRAMEWORK FOR NATIVE WILDLIFE, FISH, AND PLANTS This section provides a discussion of those laws and regulations that are in place to protect native wildlife, fish, and plants. Under each law we discuss their pertinence to the proposed development.

7.1 Federal Endangered Species Act
The Federal Endangered Species Act (FESA) forms the basis for the federal protection of threatened or endangered plants, insects, fish and wildlife. FESA contains four main elements, they are as follows:

Section 4 (16 USCA §1533): Species listing, Critical Habitat Designation, and Recovery Planning: outlines the procedure for listing endangered plants and wildlife. 1443
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Section 7 (§1536): Federal Consultation Requirement: imposes limits on the actions of federal agencies that might impact listed species.

Section 9 (§1538): Prohibition on Take: prohibits the "taking" of a listed species by anyone, including private individuals, and State and local agencies.

Section 10: Exceptions to the Take Prohibition: non-federal agencies can obtain an incidental take permit through approval of a Habitat Conservation Plan.

In the case of salt water fish and other marine organisms, the requirements of FESA are enforced by the National Marine Fisheries Service (NMFS). The USFWS enforces all other cases. Below, Sections 9, 7, and 10 of FESA are discussed since they are the sections most relevant to the proposed project.

Section 9 of FESA as amended, prohibits the "take" of any fish or wildlife species listed under FESA as endangered. Under Federal regulation, "take" of fish or wildlife species listed as threatened is also prohibited unless otherwise specifically authorized by regulation. "Take," as defined by FESA, means "to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” "Harm" includes not only the direct taking of a species itself, but the destruction or modification of the species' habitat resulting in the potential injury of the species. As such, "harm" is further defined to mean "an act which actually kills or injures wildlife; such an act may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering" (50 CFR 17.3). A December 2001 decision by the 9th Circuit Court of Appeals (Arizona Cattle Growers’ Association, Jeff Menges, vs. the U.S. Fish and Wildlife Service and Bureau of Land Management, and the Southwest Center for Biological Diversity) ruled that the USFWS must show that a threatened or endangered species is present on a project site and that it would be taken by the project activities. According to this ruling, the USFWS can no longer require mitigation based on the probability that the species could use the site. Rather they must show that it is actually present.

Section 9 applies to any person, corporation, federal agency, or any local or State agency. If "take" of a listed species is necessary to complete an otherwise lawful activity, this triggers the need to obtain a incidental take permit either through a Section 7 Consultation as discussed further below (for federal actions or private actions that are permitted or funded by a federal agency), or requires preparation of a Habitat Conservation Plan (HCP) pursuant to Section 10 of FESA (for state and local agencies, or individuals, and projects without a federal “nexus”).

Section 7(a)(2) of the Act requires that each federal agency consult with the USFWS to ensure that any action authorized, funded or carried out by such agency is not likely to jeopardize the continued existence of an endangered or threatened species or result in the destruction or adverse modification of critical habitat for listed species. Critical habitat designations mean: (1) specific areas within a geographic region currently occupied by a listed species, on which are found those physical or biological features that are essential to the conservation of a listed species and that may require special management considerations or protection; and (2) specific areas outside the 1444
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geographical area occupied by a listed species that are determined essential for the conservation of the species.

The Section 7 consultation process only applies to actions taken by federal agencies that are considering authorizing discretionary projects. Section 7 is by and between the NMFS and/or the USFWS and the federal agency contemplating a discretionary approval (that is, the “federal nexus agency,” for example, the Corps or the Federal Highway Administration). Private parties, cities, counties, etc. (i.e., applicants) may participate in the Section 7 consultation at the discretion of the federal agencies conducting the Section 7 consultation. The Section 7 consultation process is triggered by a determination of the “action agency” – that is, the federal agency that is carrying out, funding, or approving a project - that the project “may affect” a listed species or critical habitat. If an action is likely to adversely affect a listed species or designated critical habitat, formal consultation between the nexus agency and the USFWS/NMFS is required. As part of the formal consultation, the USFWS/NMFS may resolve any issues informally with the nexus agency or may prepare a formal Biological Opinion assessing whether the proposed action would be likely to result in “jeopardy” to a listed species or if it could adversely modify designated critical habitat. If the USFWS/NMFS prepares a Biological Opinion, it will contain either a “jeopardy” or “non-jeopardy” decision. If the USFWS/NMFS concludes that a proposed project would result in adverse modification of critical habitat or would jeopardize the continued existence of a federal listed species (that is, it will issue a jeopardy decision), the nexus federal agency would be most unlikely to authorize its discretionary permit. If the USFWS/NMFS prepares a “non-jeopardy” Biological Opinion, the nexus federal agency may authorize the discretionary permit making all conditions of the Biological Opinion conditions of its discretionary permit. A non-jeopardy Biological Opinion constitutes an “incidental take” permit that allows applicants to “take” federally-listed species while otherwise carrying out legally sanctioned projects.

For non-federal entities, for example private parties, cities, counties that are considering a discretionary permit, Section 10 provides the mechanism for obtaining take authorization. Under Section 10 of FESA, for the applicant to obtain an "incidental take permit," the applicant is required to submit a "conservation plan" to the USFWS or NMFS that specifies the impacts that are likely to result to federally-listed species, and the measures the applicant will undertake to minimize and mitigate such impacts, and the funding that will be available to implement those steps. Conservation plans under FESA have come to be known as "habitat conservation plans" or "HCPs" for short. The terms incidental take permit, Section 10 permit, and Section 10(a)(1)(B) permit are used interchangeably by the USFWS. Section 10(a)(2)(B) of FESA provides statutory criteria that must be satisfied before an incidental take permit can be issued.

7.1.1 RESPONSIBLE AGENCY
FESA gives regulatory authority to the USFWS for federally-listed terrestrial species and nonanadromous fish. The NMFS has regulatory authority over federally-listed marine mammals and anadromous fish.

7.1.2 APPLICABILITY TO THE PROPOSED PROJECT
The closest known California red-legged frog occurrence is 1.4 miles east of the project site (CNDDB Occurrence No. 896). The California red-legged frog was found in a dry cement tank 1445
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adjacent to a large quarry pond that supported bullfrogs. State Route 29 is located between the closest California red-legged frog record and the project site and constitutes an effective geographic barrier to overland California red-legged frog movements to/from the known record location and other extant California red-legged frog populations to the project site. There is no hydrologic connectivity along any undeveloped migration route between the known records for this species and the project site. Finally, the project site does not provide suitable habitat for the California red-legged frog. Based on all the available information, it can be concluded that the project site does not provide suitable habitat for the California red-legged frog. Owing to the excessively disturbed conditions on the project site due to prior grading and tree removal activities, this species is not expected to occur on the project site. Therefore, the proposed project will not impact the California red-legged frog.

No other federally listed species are expected to occur on the project site. The project site does not provide fisheries habitat as it consists entirely of upland communities. Therefore, it can be stated with confidence that the proposed project would not impact federally listed plant, animal, or fish species.

7.2 Federal Migratory Bird Treaty Act
The Migratory Bird Treaty Act of 1918 (16 U.S.C. §§ 703-712, July 3, 1918, as amended 1936, 1960, 1968, 1969, 1974, 1978, 1986 and 1989) makes it unlawful to “take” (kill, harm, harass, shoot, etc.) any migratory bird listed in Title 50 of the Code of Federal Regulations, Section

10.13, including their nests, eggs, or young. Migratory birds include geese, ducks, shorebirds, raptors, songbirds, wading birds, seabirds, and passerine birds (such as warblers, flycatchers, swallows, etc.).

7.2.1 APPLICABILITY TO THE PROPOSED PROJECT
Western burrowing owl, northern harrier, Swainson’s hawk, red-shouldered hawk, and red-tailed hawk (Buteo jamaicensis), among other raptors (birds of prey) could nest in the eucalyptus grove in the immediate vicinity of the project site. These raptors would be protected by the Migratory Bird Treaty Act. Also, the common songbirds that could forage on the site would be protected pursuant to this Act. As long as there is no direct mortality of species protected pursuant to this Act caused by development of the site, there should be no constraints to development of the site.

To comply with the Migratory Bird Treaty Act, all active nest sites would have to be avoided while such birds were nesting. Upon completion of nesting, the project could commence as otherwise planned. Please review specific requirements for avoidance of nest sites for potentially occurring species in the Impacts and Mitigations section below.

7.3 California Endangered Species Act

7.3.1 SECTION 2081 OF THE CALIFORNIA ENDANGERED SPECIES ACT In 1984, the state legislated the California Endangered Species Act (CESA) (Fish and Game Code §2050). The basic policy of CESA is to conserve and enhance endangered species and their habitats. State agencies will not approve private or public projects under their jurisdiction that would impact threatened or endangered species if reasonable and prudent alternatives are available. Because CESA does not have a provision for "harm" (see discussion of FESA, above), 1446
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CDFW considerations pursuant to CESA are limited to those actions that would result in the direct take of a listed species.

If CDFW determines that a proposed project could impact a state-listed threatened or endangered species, CDFW will provide recommendations for "reasonable and prudent" project alternatives.

The CEQA lead agency can only approve a project if these alternatives are implemented, unless it finds that the project's benefits clearly outweigh the costs, reasonable mitigation measures are adopted, there has been no "irreversible or irretrievable" commitment of resources made in the interim, and the resulting project would not result in the extinction of the species. In addition, if there would be impacts to threatened or endangered species, the lead agency typically requires project applicants to demonstrate that they have acquired "incidental take" permits from CDFW and/or USFWS (if it is a Federal listed species) prior to allowing/permitting impacts to such species.

If proposed projects would result in impacts to a state-listed species, an "incidental take" permit pursuant to §2081 of the Fish and Game Code would be necessary (versus a Federal incidental take permit for Federal listed species). CDFW will issue an incidental take permit only if:
1) The authorized take is incidental to an otherwise lawful activity; 2) the impacts of the authorized take are minimized and fully mitigated; 3) measures required to minimize and fully mitigate the impacts of the authorized take:
a) are roughly proportional in extent to the impact of the taking on the species; b) maintain the project applicant’s objectives to the greatest extent possible; and, c) capable of successful implementation; and,
4) adequate funding is provided to implement the required minimization and mitigation measures and to monitor compliance with, and the effectiveness of, the measures.

If an applicant is preparing a habitat conservation plan (HCP) as part of the federal 10(a) permit process, the HCP might be incorporated into the §2081 permit if it meets the substantive criteria of §2081(b). To ensure that an HCP meets the mitigation and monitoring standards in Section 2081(b), an applicant should involve CDFW staff in development of the HCP. If a final Biological Opinion (federal action) has been issued for the project pursuant to Section 7 of the federal Endangered Species Act, it might also be incorporated into the §2081 permit if it meets the standards of §2081(b).

No §2081 permit may authorize the take of a species for which the Legislature has imposed strict prohibitions on all forms of “take.” These species are listed in several statutes that identify “fully protected” species and “specified birds.” See Fish and Game Code §§ 3505, 3511, 4700, 5050, 5515, and 5517. If a project is planned in an area where a “fully protected” species or a “specified bird” occurs, an applicant must design the project to avoid all take.

Fish and Game Code §2080.1 allows an applicant who has obtained a “non-jeopardy” federal Biological Opinion pursuant to Section 7 of the FESA, or who has received a federal 10(a) permit (federal incidental take permit) pursuant to the FESA, to submit the federal opinion or permit to CDFW for a determination as to whether the federal document is “consistent” with CESA. If after 30 days CDFW determines that the federal incidental take permit is consistent 1447
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with state law, and that all state-listed species under consideration have been considered in the federal Biological Opinion, then no further permit or consultation is required under CESA for the project. However, if CDFW determines that the federal opinion or permit is not consistent with CESA, or that there are state-listed species that were not considered in the federal Biological Opinion, then the applicant must apply for a state CESA permit under Section 2081(b). Section 2081(b) is of no use if an affected species is state-listed, but not federally-listed.

State and federal incidental take permits are issued on a discretionary basis, and are typically only authorized if applicants are able to demonstrate that impacts to the listed species in question are unavoidable, and can be mitigated to an extent that the reviewing agency can conclude that the proposed impacts would not jeopardize the continued existence of the listed species under review. Typically, if there would be impacts to a listed species, mitigation that includes habitat avoidance, preservation, and creation of endangered species habitat is necessary to demonstrate that projects would not threaten the continued existence of a species. In addition, management endowment fees are usually collected as part of the agreement for the incidental take permit(s).

The endowment is used to manage any lands set-aside to protect listed species, and for biological mitigation monitoring of these lands over (typically) a five-year period.

7.3.2 APPLICABILITY TO THE PROPOSED PROJECT
No state-listed plant species would likely occur on the project site due to an absence of habitat.

The project site does not support any trees and does not provide nesting habitat for the Swainson’s hawk. Suitable nesting habitat for this hawk exists in the eucalyptus trees on the adjacent properties; thus, preconstruction nesting surveys will be necessary to ensure that earthwork or construction does not occur while this raptor is nesting nearby or that if it does, it does not disturb the nesting birds. If the proposed project follows the proposed mitigation measures as detailed in the Impacts and Mitigation section below, an Incidental Take Permit (ITP) from the CDFW should not be necessary for this project.

7.4 California Fish and Game Code § 3503, 3503.5, 3511, and 3513 California Fish and Game Code §3503, 3503.5, 3511, and 3513 prohibit the “take, possession, or destruction of birds, their nests or eggs.” Disturbance that causes nest abandonment and/or loss of reproductive effort (killing or abandonment of eggs or young) is considered “take.” Such a take would also violate federal law protecting migratory birds (Migratory Bird Treaty Act).

All raptors (that is, hawks, eagles, owls) their nests, eggs, and young are protected under California Fish and Game Code (§3503.5). Additionally, “fully protected” birds, such as the white-tailed kite (Elanus leucurus) and golden eagle (Aquila chrysaetos), are protected under California Fish and Game Code (§3511). “Fully protected” birds may not be taken or possessed (that is, kept in captivity) at any time.

7.4.1 APPLICABILITY TO THE PROPOSED PROJECT
Raptors that could be affected by the project include western burrowing owl, northern harrier, Swainson’s hawk, red-shouldered hawk and red-tailed hawk. Preconstruction surveys would have to be conducted for these species to ensure that there is no direct take of these birds including their eggs, or young. Any active nests that were found during preconstruction surveys 1448
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would have to be avoided by the project. Suitable non-disturbance buffers would have to be established around nest sites until the nesting cycle is complete. More specifics on the size of buffers are provided below in the Impacts and Mitigations section.

7.5 City of American Canyon General Plan
The City of American Canyon General Plan sets forth the following goals, objectives, and policies relevant to biological resources on the project site. Only those applicable to the proposed project are discussed herein:

7.5.1 GOAL 8, OBJECTIVE 8.1 AND POLICIES 8.1.1 AND 8.1.4 • Goal 8: Protect and preserve the significant habitats, plants and wildlife that exist in the City and its Planning Area.
• Objective 8.1: Maintain data and information regarding areas of significant biological value within the Planning Area to facilitate resource conservation and the appropriate management of development.
• Policy 8.1.1: Acquire and maintain the most current information available regarding the status and location of sensitive biological elements (species and natural communities) within the City and, as appropriate, within the Sphere of Influence and Urban Limit Line. • Policy 8.1.4: Regularly monitor and review developments proposed within the City's Planning Area to assess their impacts on local biological resources and to recommend appropriate mitigation measures that the developer and/or government agency can implement.

7.5.2 APPLICABILITY TO THE PROPOSED PROJECT
Consistent with General Plan Policies 8.1.1 and 8.1.4, this report provides a detailed assessment of the biological resources present on the project site.

7.5.3 OBJECTIVE 8.2 AND POLICY 8.2.1
• Objective 8.2: Balance the preservation of natural habitat areas, including coastal saltmarsh, mixed hardwood forest, oak savannah, and wetland and riparian habitats, with new development in the City.
• Policy 8.2.1: Land use applications for developments located within sensitive habitats, including coastal saltmarsh, mixed hardwood forest, oak savannah, and riparian habitats (see Figure 8-1) [General Plan], or with areas potentially occupied by vernal pools (see Figure 8-2) [General Plan] shall be accompanied by sufficient technical background data to enable an adequate assessment of the potential for impacts on these resources, and possible measures to reduce any identifiable impacts. In addition to examining Figure 8-1 [General Plan] for information on these sensitive habitats, an on-site assessment shall be conducted by a City approved qualified biologist to determine if sensitive habitats exist on-site. In instances where the potential for significant impacts exists, the applicant must submit a Biological Assessment Report prepared by a qualified professional. 1449
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7.5.4 APPLICABILITY TO THE PROPOSED PROJECT
Consistent with General Plan Policy 8.2.1, the project site has been evaluated for the presence of sensitive biological resources. This report represents a Biological Assessment Report documenting findings from background research, and presents the current habitats and species present on the project site.

7.5.5 OBJECTIVE 8.3 AND POLICY 8.3.1
• Objective 8.3: Protect natural drainages and riparian corridors within the American Canyon Planning Area.
• Policy 8.3.1: Review proposed developments in wetlands and riparian habitats to evaluate their conformance with the following policies and standards:
a. The development plan shall fully consider the nature of existing biological resources and all reasonable measures shall be taken to avoid significant impacts, including retention of sufficient natural open space and undeveloped buffer zones.

7.5.6 APPLICABILITY TO THE PROPOSED PROJECT
No wetland, natural drainages or riparian habitats are proposed to be impacted, as there are none present on the 10-acre project site.

7.5.7 POLICY 8.3.1 B
• Policy 8.3.1 b: Development shall be designed and sited to preserve watercourses, riparian habitat, vernal pools, and wetlands in their natural condition, unless these actions result in an unfeasible project, in which case habitat shall be replaced in accord with subsection "g" (below).

7.5.8 APPLICABILITY TO THE PROPOSED PROJECT
Proposed development on the project site does not impact watercourses, riparian habitat, vernal pools or wetlands.

7.5.9 POLICY 8.3.1 E
• Policy 8.3.1 e: Development shall incorporate fences, walls, vegetative cover, or other measures to adequately buffer habitat areas, linkages or corridors from built environment.

7.5.10 APPLICABILITY TO THE PROPOSED PROJECT
Previous disturbance on the project site prohibits presence of land linkages, corridors, or habitat areas. Similarly, because creation of a mitigation site is not necessary for this site, there will be no habitat area or otherwise natural space in need of buffering.

7.5.11 POLICY 8.3.1 F
• Policy 8.3.1 f: Roads and utilities shall be located and designed such that conflicts with biological resources, habitat areas, linkages or corridors are avoided where feasible. 1450
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7.5.12 APPLICABILITY TO THE PROPOSED PROJECT
Consistent with Policy 8.3.1.f, and Policy 8.3.1.g roads and utilities have been designed to avoid conflicts with biological resources on the project site.

7.5.13 POLICY 8.3.1 G
• Policy 8.3.1 g: Future development shall utilize appropriate open space or conservation easements in order to protect sensitive species or their habitats.

7.5.14 POLICIES 8.3.5 AND 8.3.6
• Policy 8.3.5: Establish a network of open spaces along the City's natural drainages and riparian corridors and link significant biological habitats. Any recreational use of these areas shall be designed to avoid damaging sensitive habitat areas. • Policy 8.3.6: Preserve and integrate the City's natural drainages in new development, as opposed to their channelization or undergrounding, emphasizing opportunities for the development of pedestrian paths and greenbelts along their lengths throughout the City.

7.5.15 APPLICABILITY TO THE PROPOSED PROJECT
There are no drainages on the project site or significant biological habitats onsite; hence, these policies do not apply to the proposed project.

8. CITY OF AMERICAN CANYON –ORDINANCES

8.1 Trees (Ord. 18.40.110)
A. Existing trees shall be preserved on the site unless otherwise approved by the city council as a part of the site development plans.

B. Unless specifically approved by the city council, any tree removed shall be replaced on the site. Replacement trees shall be a minimum size of a twenty-four-inch box of the same species unless specifically approved by the city council. (Ord. 98-10 § 1 (part), 1998).

8.1.1 APPLICABILITY TO THE PROPOSED PROJECT
The project site does not support any trees.

9. REGULATORY REQUIREMENTS PERTAINING TO WATERS OF THE UNITED

STATES AND STATE
This section presents an overview of the criteria used by the U.S. Army Corps of Engineers, the California Regional Water Quality Control Board, the State Water Resources Control Board, and CDFW to determine those areas within a project area that would be subject to their regulation. 1451
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9.1 U.S. Army Corps of Engineers Jurisdiction and General Permitting

9.1.1 SECTION 404 OF THE CLEAN WATER ACT
Congress enacted the Clean Water Act “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters” (33 U.S.C. §1251(a)). Pursuant to Section 404 of the Clean Water Act (33 U.S.C. 1344), the U.S. Army Corps of Engineers (Corps) regulates the disposal of dredged or fill material into "waters of the United States" (33 CFR Parts 328 through 330). This requires project applicants to obtain authorization from the Corps prior to discharging dredged or fill materials into any water of the United States.

In the Federal Register "waters of the United States" are defined as, “...all interstate waters including interstate wetlands...intrastate lakes, rivers, streams (including intermittent streams), wetlands, [and] natural ponds, the use, degradation or destruction of which could affect interstate or foreign commerce...” (33 CFR Section 328.3).

Limits of Corps’ jurisdiction:
(a) Territorial Seas. The limit of jurisdiction in the territorial seas is measured from the baseline in a seaward direction a distance of three nautical miles. (See 33 CFR 329.12) (b) Tidal Waters of the United States. The landward limits of jurisdiction in tidal waters:
(1) Extends to the mean high tide line, or
(2) When adjacent non-tidal waters of the United States are present, the jurisdiction extends to the limits identified in paragraph (c) of this section. (c) Non-Tidal Waters of the United States. The limits of jurisdiction in non-tidal waters:
(1) In the absence of adjacent wetlands, the jurisdiction extends to the ordinary high water mark, or
(2) When adjacent wetlands are present, the jurisdiction extends beyond the ordinary high water mark to the limit of the adjacent wetlands. (3) When the water of the United States consists only of wetlands the jurisdiction extends to the limit of the wetland.

Section 404 jurisdiction in "other waters" such as lakes, ponds, and streams, extends to the upward limit of the ordinary high water mark (OHWM) or the upward extent of any adjacent wetland. The OHWM on a non-tidal water is:
• the "line on shore established by the fluctuations of water and indicated by physical characteristics such as a clear natural line impressed on the bank; shelving; changes in the character of soil; destruction of terrestrial vegetation; the presence of litter or debris; or other appropriate means that consider the characteristics of the surrounding areas" (33 CFR Section 328.3[e]).
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Wetlands are defined as: “...those areas that are inundated or saturated by surface or ground water at a frequency and duration to support a prevalence of vegetation adapted for life in saturated soil conditions” (33 CFR Section 328.8 [b]). Wetlands usually must possess hydrophytic vegetation (i.e., plants adapted to inundated or saturated conditions), wetland hydrology (e.g., topographic low areas, exposed water tables, stream channels), and hydric soils (i.e., soils that are periodically or permanently saturated, inundated or flooded) to be regulated by the Corps pursuant to Section 404 of the Clean Water Act.

9.1.1.1 Significant Nexus of Tributaries
On December 2, 2008, the Corps and the Environmental Protection Agency (EPA) issued joint guidance on implementing the U.S. Supreme Court decision in the consolidated cases Rapanos v.

United States and Carabell v. United States (herein referred to simply as “Rapanos”) which address the jurisdiction over waters of the United States under the Clean Water Act. In this joint guidance these agencies provide guidance on where they will assert jurisdiction over waters of the U.S.

The EPA and Corps will assert jurisdiction over the following waters:
• Traditional navigable waters
• Wetlands adjacent to traditional navigable waters
• Non-navigable tributaries of traditional navigable waters that are relatively permanent where the tributaries typically flow year-round or have continuous flow at least seasonally (for example, typically three months).
• Wetlands that directly abut such tributaries.

The agencies generally will not assert jurisdiction over the following features:
• Swales or erosional features (e.g., gullies, small washes characterized by low volume, infrequent, or short duration flow); and
• Ditches (including roadside ditches) excavated wholly in and draining only uplands and that do not carry a relatively permanent flow of water.

The agencies will apply the significant nexus standard as follows:
• A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by all wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical and biological integrity of downstream traditional navigable waters; and
• Significant nexus includes consideration of hydrologic and ecologic factors.

9.1.1.2 Isolated Areas Excluded from Section 404 Jurisdiction In addition to areas that may be exempt from Section 404 jurisdiction, some isolated wetlands and waters may also be considered outside of Corps jurisdiction as a result of the Supreme Court’s decision in Solid Waste Agency of Northern Cook County (SWANCC) v. United States Army Corps of Engineers (531 U.S. 159 [2001]). Isolated wetlands and waters are those areas 1453
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that do not have a surface or groundwater connection to, and are not adjacent to a navigable “Waters of the U.S.,” and do not otherwise exhibit an interstate commerce connection.

9.1.1.3 Permitting Corps Jurisdictional Areas
To remain in compliance with Section 404 of the Clean Water Act, project proponents and property owners (applicants) are required to be permitted by the Corps prior to discharging or otherwise impacting waters of the United States. In many cases, the Corps must visit a proposed project area (to conduct a “jurisdictional determination”) to confirm the extent of area falling under their jurisdiction prior to authorizing any permit for that project area. Typically, at the time the jurisdictional determination is conducted, applicants (or their representative) will discuss the appropriate permit application that would be filed with the Corps for permitting the proposed impact(s) to “waters of the United States.”
Pursuant to Section 404 of the Clean Water Act, the Corps normally provides two alternatives for permitting impacts to the type of “waters of the United States” found in the project area. The first alternative would be to use Nationwide Permit(s) (NWP). The second alternative is to apply to the Corps for an Individual Permit (33 CFR Section 235.5(2)(b)). The application process for Individual Permits is extensive and includes public interest review procedures (i.e., public notice and receipt of public comments) and must contain an “alternatives analysis” that is prepared pursuant to Section 404(b) of the Clean Water Act (33 U.S.C. 1344(b)). The alternatives analysis is also typically reviewed by the federal EPA and thus brings another resource agency into the permitting framework. Both the Corps and EPA take the initial viewpoint that there are practical alternatives to the proposed project if there would be impacts to waters of the U.S., and the proposed permitted action is not a water dependent project (e.g. a pier or a dredging project).

Alternative analyses therefore must provide convincing reasons that the proposed permitted impacts are unavoidable. Individual Permits may be available for use in the event that discharges into regulated waters fail to meet conditions of NWP(s).

NWPs are a type of general permit administered by the Corps and issued on a nationwide basis that authorize minor activities that affect Corps regulated waters. Under NWP, if certain conditions are met, the specified activities can take place without the need for an individual or regional permit from the Corps (33 CFR, Section 235.5[c][2]). In order to use NWP(s), a project must meet 27 general nationwide permit conditions, and all specific conditions pertaining to the NWP being used (as presented at 33 CFR Section 330, Appendices A and C). It is also important to note that pursuant to 33 CFR Section 330.4(e), there may be special regional conditions or modifications to NWPs that could have relevance to individual proposed projects. Finally, pursuant to 33 CFR Section 330.6(a), Nationwide permittees may, and in some cases must, request from the Corps confirmation that an activity complies with the terms and conditions of the NWP intended for use (i.e., must receive “verification” from the Corps).

Prior to finalizing design plans, the applicant needs to be aware that the Corps maintains a policy of “no net loss” of wetlands (waters of the United States) from project area development.

Therefore, it is incumbent upon applicants that propose to impact Corps regulated areas to submit a mitigation plan that demonstrates that impacted regulated areas would be recreated (i.e., impacts would be mitigated). Typically, the Corps requires mitigation to be “in-kind” (i.e., if a 1454
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stream channel would be filled, mitigation would include replacing it with a new stream channel), and at a minimum of a 1:1 replacement ratio (i.e., one acre or fraction there of recreated for each acre or fraction thereof lost). Often a 2:1 replacement ratio is required. Usually the 2:1 ratio is met by recreation or enhancement of an equivalent amount of wetland as is impacted, in addition to a requirement to preserve an equivalent amount of wetland as is impacted by the project. In some cases, the Corps allows “out-of-kind” mitigation if the compensation site has greater value than the impacted site. For example, if project designs call for filling an intermittent drainage, mitigation should include recreating the same approximate jurisdictional area (same drainage widths) at an offsite location or on a set-aside portion of the project area. Finally, there are many Corps approved wetland mitigation banks where wetland mitigation credits can be purchased by applicants to meet mitigation compensation requirements.

Mitigation banks have defined service areas and the Corps may only allow their use when a project would have minimal impacts to wetlands.

9.1.2 APPLICABILITY TO THE PROPOSED PROJECT
M&A originally prepared a preliminary wetland delineation map of the 35 acre parcel in 2006; however, this map was never submitted to the Corps. In 2011, a formal wetland delineation was conducted on July 14th and July 20th by M&A biologists Ms. Hope Kingma and Mr. Tim O’Donnell. The wetland delineation report and map were submitted to the Corps on August 22, 2011, requesting confirmation of the extent of Corps jurisdiction at the American Canyon Flat Lands site. In a letter dated January 31, 2012 the extent of Corps jurisdiction was confirmed, based on a field investigation on September 21, 2011. That jurisdictional determination expired five (5) years from the date of that letter.

M&A biologists Ms. Hope Kingma and Mr. Devin Jokerst conducted another wetland delineation of the entire 35.85-acre parcel (known as Lot 3), which includes this project site, on November 16, 2016 to re-verify the extent of jurisdictional areas on the site. M&A used the Corps’ 1987 Wetlands Delineation Manual in conjunction with the Regional Supplement for the Arid West Region. The jurisdictional determination request and the Draft Aquatic Resources Delineation Map (Sheet 2) were submitted to the Corps in December 2016. Mr. Bryan Matsumoto of the Corps conducted a site verification visit on May 18, 2017. On May 16, 2018 the Corps issued the jurisdictional determination confirming their jurisdiction over 0.043-acre of waters of the U.S. on the 35.43-acre parcel. The confirmed Jurisdictional Delineation Map (Sheet 2) and letter are attached. None of the jurisdictional features on that map occur on the 10-acre project site that is the subject of this report. As such there will be no impacts to the waters of the U.S. for this project.

9.2 State Water Resources Control Board (SWRCB) / California Regional Water Quality Control Board (RWQCB)

9.2.1 SECTION 401 OF THE CLEAN WATER ACT
The SWRCB and RWQCB regulate activities in "waters of the State" (which includes wetlands) through Section 401 of the Clean Water Act. While the Corps administers a permitting program that authorizes impacts to waters of the United States, including wetlands and other waters, any Corps permit authorized for a proposed project would be inoperative unless it is an NWP that has been certified for use in California by the SWRCB, or if the RWQCB has issued a project specific 1455
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certification of water quality. Certification of NWPs requires a finding by the SWRCB that the activities permitted by the NWP will not violate water quality standards individually or cumulatively over the term of the permit (the term is typically for five years). Certification must be consistent with the requirements of the federal Clean Water Act, the California Environmental Quality Act, the California Endangered Species Act, and the SWRCB’s mandate to protect beneficial uses of waters of the State. Any denied (i.e., not certified) NWPs, and all Individual Corps permits, would require a project specific RWQCB certification of water quality.

9.2.2 APPLICABILITY TO THE PROPOSED PROJECT
The Corps’ Confirmed Reverification Aquatic Resources Delineation Map dated May 22, 2017 is provided as Sheet 2. The proposed project will not impact any waters of the State. Therefore Section 401 of the Clean Water Act is not necessary for this project.

9.3 California Department of Fish and Wildlife Protections

9.3.1 SECTION 1602 OF CALIFORNIA FISH AND GAME CODE
Pursuant to Section 1602 of the California Fish and Game Code: “An entity may not substantially divert or obstruct the natural flow of, or substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake, or deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake, unless all of the following occur:
(1) CDFW receives written notification regarding the activity in the manner prescribed by CDFW. The notification shall include, but is not limited to, all of the following:
(A)A detailed description of the project’s location and a map. (B) The name, if any, of the river, stream, or lake affected. (C) A detailed project description, including, but not limited to, construction plans and drawings, if applicable.
(D)A copy of any document prepared pursuant to Division 13 (commencing with Section 21000) of the Public Resources Code.
(E) A copy of any other applicable local, state, or federal permit or agreement already issued.
(F) Any other information required by CDFW” (Fish & Game Code 2014).

Please see Section 1602 of the current California Fish and Game Code for further details.

Please also note that while not stated in the regulations above, CDFW typically considers its jurisdiction to include riparian vegetation (that is, the trees and bushes growing along the stream).

Thus, any proposed activity in a natural stream channel that would substantially adversely affect an existing fish and/or wildlife resource, including its riparian vegetation, would require entering into a Streambed Alteration Agreement (SBAA) with CDFW prior to commencing with work in the stream. However, prior to authorizing such permits, CDFW typically reviews an analysis of the expected biological impacts, any proposed mitigation plans that would be implemented to offset biological impacts and engineering and erosion control plans. 1456
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9.3.2 APPLICABILITY TO THE PROPOSED PROJECT
There are no streams or drainages on the project site that would be regulated by CDFW. Hence, an SBAA with CDFW would not be necessary for this project.

10. STATE WATER RESOURCES CONTROL BOARD (SWRCB)/RWQCB – STORM

WATER MANAGEMENT

10.1 Construction General Permit
While federal Clean Water Act NPDES regulations allow two permitting options for construction related stormwater discharges (individual permits and General Permits), the State Water Resources Control Board (SWRCB) has elected to adopt only one statewide Construction General Permit at this time that will apply to all stormwater discharges associated with construction activity, except from those on Tribal Lands, in the Lake Tahoe Hydrologic Unit, and those performed by the California Department of Transportation (CalTrans).

The Construction General Permit requires all dischargers where construction activity disturbs greater than one acre of land or those sites less than one acre that are part of a common plan of development or sale that disturbs more than one acre of land surface to:

1. Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) which specifies Best Management Practices (BMPs) that will prevent all construction pollutants from contacting stormwater with the intent of keeping all products of erosion from moving off site into receiving waters.

2. Eliminate or reduce non-stormwater discharges to storm sewer systems and other waters of the nation. Achieve quantitatively-defined (i.e., numeric) pollutant-specific discharge standards, and conduct much more rigorous monitoring based on the project’s projected risk level.

3. Perform inspections of all BMPs.

This Construction General Permit is implemented and enforced by the nine California Regional Water Quality Control Boards (RWQCBs). It is also enforceable through citizens’ suits and represents a dramatic shift in the State Water Board’s approach to regulating new and redevelopment sites, imposing new affirmative duties and fixed standards on builders and developers.

Types of Construction Activity Covered by the Construction General Permit • clearing,
• grading,
• disturbances to the ground such as stockpiling, or excavation that results in soil disturbances of at least one acre or more of total land area. 1457
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Construction activity that results in soil disturbances to a smaller area would still be subject to this General Permit if the construction activity is part of a larger common plan of development that encompasses greater than one acre of soil disturbance, or if there is significant water quality impairment resulting from the activity.

Construction activity does not include:
• routine maintenance to maintain original line and grade, • hydraulic capacity, or original purpose of the facility, • nor does it include emergency construction activities required to protect public health and safety.

The Construction General Permit includes several “post-construction” requirements. These requirements entail that site designs provide no net increase in overall site runoff and match preproject hydrology by maintaining runoff volume and drainage concentrations. To achieve the required results where impervious surfaces such as roofs and paved surfaces are being increased, developers must implement non-structural off-setting BMPs, such as landform grading, site design BMPs, and distributed structural BMPs (bioretention cells, rain gardens, and rain cisterns). This “runoff reduction” approach is essentially a State Water Board-imposed regulatory requirement to implement Low Impact Development (“LID”) design features. Volume that cannot be addressed using non-structural BMPs must be captured in structural BMPs that are approved by the RWQCB.

Improving the quality of site runoff is necessary to improve water quality in impaired and threatened streams, rivers, and lakes (that is, water bodies on the EPA’s 303(d) list). The RWQCB prioritizes the water bodies on the 303(d) list according to potential impacts to beneficial uses. Beneficial uses can include a wide range of uses, such as nautical navigation; wildlife habitat; fish spawning and migration; commercial fishing, including shellfish harvesting; recreation, including swimming, surfing, fishing, boating, beachcombing, and more; water supply for domestic consumption or industrial processes; and groundwater recharge, among other uses. The State is required to develop action plans and establish Total Maximum Daily Loads (TMDLs) to improve water quality within these impaired water bodies. The TMDL is the quantity of a pollutant that can be safely assimilated by a water body without violating the applicable water quality standards.

Pursuant to the CWA, the RWQCB regulates construction discharges under the National Pollutant Discharge Elimination System (NPDES). The project sponsor of construction or other activities that disturb more than 1 acre of land must obtain coverage under NPDES Construction General Permit Order 2009-0009-DWQ, administered by the RWQCB1. 1 CGP Order 2009-0009-DWQ remains in effect, but has been amended by CGP Order 2009-0014-DWQ, effective February 14, 2011, and CGP Order 2009-0016-DWQ, effective July 17, 2012. The first amendment merely provided additional clarification to Order 2009-0009-DWQ, while Order 2009-0016-DWQ eliminated numeric effluent limits on pH and turbidity (except in the case of active treatment systems), in response to a legal challenge to the original order.
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10.1.1 APPLICABILITY TO THE PROPOSED PROJECT
To obtain coverage under the SWRCB administered Construction General Permit, the applicant (typically through its civil engineer) must electronically file a number of permit-related compliance documents (Permit Registration Documents (PRDs), including a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), Notice of Termination (NOT), NAL exceedance reports, and other site-specific PRDs that may be required. The PRDs must be prepared by a Qualified SWPPP Practitioner (QSP) or Qualified SWPPP Developer (QSD) and filed by a Legally Responsible Person (LRP) on the RWQCB’s Stormwater Multi-Application Report Tracking System (SMARTS). (QSDs are typically civil engineers, professional hydrologists, engineering geologists, or landscape architects.) Once filed, these documents become immediately available to the public for review and comment. At a minimum, the SWPPP shall identify Best Management Practices (BMPs) for implementation during project construction that are in accordance with the applicable guidance and procedures contained in the California Stormwater Quality Association’s California Stormwater Best Management Practices Handbook (2015).

10.2 RWQCB Municipal Storm Water Permitting Programs
The federal Clean Water Act (CWA) was amended in 1987 to address urban stormwater runoff pollution of the nation’s waters. In 1990, the U.S. Environmental Protection Agency (USEPA) promulgated rules establishing Phase 1 of the National Pollutant Discharge Elimination System (NPDES) stormwater program. The Phase 1 program for Municipal Separate Storm Sewer System (MS4s) requires operators that serve populations of 100,000 or greater to implement a stormwater management program to control polluted discharges from these MS4s. While Phase 1 of the municipal stormwater program has focused on large urban areas, Phase 2 of the municipal stormwater program was promulgated by the USEPA for smaller urban areas including nontraditional Small MS4s, which are governmental facilities such as military bases, public campuses, and prison and hospital complexes.

MS4 permits require the discharger (or dischargers that are permitted by the MS4 permittees) to develop and implement a Storm Water Management Plan/Program (SWMP) with the goal of reducing the discharge of pollutants to the maximum extent practicable (MEP). MEP is the performance standard specified in Section 402(p) of the Clean Water Act. The management programs specify what best management practices (BMPs) will be used to address certain program areas. The program areas include public education and outreach; illicit discharge detection and elimination; construction and post-construction; and good housekeeping for municipal operations. In general, medium and large municipalities are required to conduct chemical monitoring, though small municipalities are not.

10.2.1 NPDES C.3 REQUIREMENTS
The NPDES C.3 requirements went into effect for any project (public or private) that is “deemed complete” by the City or County (Lead Agency) on or after February 15, 2005, and which will result in the creation or replacement (other than normal maintenance) of at least 10,000 square feet of impervious surface area (roofs, streets, patios, parking lots, etc. Provision C.3 requires the onsite treatment of stormwater prior to its discharge into downstream receiving waters. Note that these requirements are in addition to the existing NPDES requirements for erosion and 1459
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sedimentation controls during project construction that are typically addressed through acquisition of coverage under the SWRCB administered Construction General Permit. The C.3 requirements are typically required to be implemented by MS4 permittees (and their constituencies).

Projects subject to Provision C3 must include the capture and onsite treatment of all stormwater from the site prior to its discharge, including rainwater falling on building rooftops. Project applicants are required to implement appropriate source control and site design measures and to design and implement stormwater treatment measures in order to reduce the discharge of stormwater pollutants to the maximum extent practicable. While the Clean Water Act does not define “maximum extent practicable,” the Stormwater Quality Management Plans required as a condition of the municipal NPDES permits identify control measures (known as Best Management Plans, or BMPs) and, where applicable, performance standards, to establish the level of effort required to satisfy the maximum extent practicable criterion. It is ultimately up to the professional judgment of the reviewing municipal staff in the individual jurisdictions to determine whether a project’s proposed stormwater controls will satisfy the maximum extent practicable criterion. However, there are numeric criteria used to ensure that treatment BMPs have been adequately sized to accommodate and treat a site’s stormwater. The C3 requirements are quite extensive, and their complete explanation is not provided here. However, the following are minimums that should be understood and adhered to:
• The applicant must provide a detailed and realistic site design and impervious surface area calculations. This site design and calculations will be used by the Lead Agency (County or City) to determine/verify the amount of impervious surface area that is being created or replaced. It should include all proposed buildings, roads, walkways, parking lots, landscape areas, etc., that are being created or redeveloped. If large (greater than 10,000 square feet) lots are being created an effort will need to be made to determine the total impervious surface area that could be created on that parcel. For example, if only a portion of the lot is shown as a “building envelope” then the lead agency will need to consider that a driveway will have to be constructed to access the envelope and that the envelope will then be developed as shown. If the C.3 thresholds are met (creation/redevelopment of 10,000 square feet of impervious surface area), a Stormwater Control Plan (SWCP) (if required by the Lead Agency, or whatever steps for compliance with Provision C3 are required locally) must accompany the application.
• If a SWCP is required by the Lead Agency for the project it must be stamped by a Licensed Civil Engineer, Architect, or Landscape Architect.

10.2.2 APPLICABILITY TO THE PROPOSED PROJECT
The Water Board issued county-wide municipal stormwater permits in the early 1990s to operators of MS4s. On November 19, 2015, the Water Board re-issued these county-wide municipal stormwater permits as one Municipal Regional Stormwater NPDES Permit to regulate stormwater discharges from municipalities and local agencies. Permittees in the San Francisco Bay area are included in a Municipal Regional Permit (MRP), issued to 76 cities, counties and 1460
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flood control districts in 2009 and revised in 2015. Each of the Permittee’s must file an Annual Report that is comprised of three parts: regional, countywide, and individual. Some requirements of the MRP are being implemented by the Bay Area Stormwater Management Agencies Association (BASMAA) on behalf of all the MRP Permittees. Other elements are being implemented collaboratively by the Permittees through their respective countywide programs. As such, BASMAA and the countywide programs have submitted Annual Report elements on the regional and countywide collaborative tasks, respectively, on behalf of the MRP Permittees and the individual MRP Permittees have also submitted Annual Report elements on the Permit Provisions they have implemented individually.

It is the applicant’s responsibility to ensure that the project civil engineer prepares all required Storm Water Planning documents for submittal to the City of American Canyon to comply with its MS4 permit requirements. In addition, if the project includes a requirement to obtain a Clean Water Act Section 401 permit from the RWQCB, the Storm Water Management Plan (or equivalent plan) must be submitted to the RWQCB with the application package submitted for acquisition of a Section 401 permit (aka “water quality certification”).

The applicant is proposing to treat all stormwater falling on impervious surfaces in the detention/bioretention basin located on the western edge of the project site (see Sheet UP4).

Once treated, stormwater would be conveyed to “level spreader outfalls” that will be installed along the western project site boundary. The level spreader outfalls consist of perforated pipe set on contour that will discharge flows uniformly across a gradual slope covered by riprap, which will mimic sheet flow conditions similar to current project site runoff (see Storm Drain Level Spreader Detail). Accordingly, the project will not violate any water quality standards.

11. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) REGULATIONS A CEQA lead agency must determine if a proposed activity constitutes a project requiring further review pursuant to the CEQA. Pursuant to CEQA, a lead agency would have to determine if there could be significant adverse impacts to the environment from a proposed project.

Typically, if within the city limits, the city would be the CEQA lead agency. If a discretionary permit (i.e., conditional use permit) would be required for a project (e.g. an occupancy permit must be issued), the lead agency typically must determine if there could be significant environmental impacts. This is usually accomplished by an “Initial Study.” If there could be significant environmental impacts, the lead agency must determine an appropriate level of environmental review prior to approving and/or otherwise permitting the impacts. In some cases, there are “Categorical Exemptions” that apply to the proposed activity; thus, the activity is exempt from CEQA. The Categorical Exemptions are provided in CEQA. There are also Statutory Exemptions in CEQA that must be investigated for any proposed project. If the project is not exempt from CEQA, the lowest level of review typically reserved for projects with no significant effects on the environment would be for the lead agency to prepare a “Negative Declaration.” If a proposed project would have only minimal impacts that can be mitigated to a level of no significance pursuant to the CEQA, then a “Mitigated Negative Declaration” is typically prepared by the lead agency. Finally, those projects that may have significant effects on the environment, or that have impacts that can’t be mitigated to a level considered less than significant pursuant to the CEQA, typically must be reviewed via an Environmental Impact 1461
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Report (EIR). All CEQA review documents are subject to public circulation, and comment periods.

Section 15380 of CEQA defines “endangered” species as those whose survival and reproduction in the wild are in immediate jeopardy from one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, disease, or other factors. “Rare” species are defined by CEQA as those who are in such low numbers that they could become endangered if their environment worsens; or the species is likely to become endangered within the foreseeable future throughout all or a significant portion of its range and may be considered “threatened” as that term is used in FESA. The CEQA Guidelines also state that a project will normally have a significant effect on the environment if it will “substantially affect a rare or endangered species of animal or plant or the habitat of the species.” The significance of impacts to a species under CEQA, therefore, must be based on analyzing actual rarity and threat of extinction to that species despite its legal status or lack thereof.

This report has been prepared as a Biology section that is suitable for incorporation into a Mitigated Negative Declaration. This document addresses potential impacts to species that would be defined as endangered or rare pursuant to Section 15380 of the CEQA and can be incorporated by the CEQA lead agency (in this case City of American Canyon) into an initial study or higher levels of CEQA review including incorporation into the biology section of an Environmental Impact Report.

12. IMPACTS ANALYSIS
Below the criteria used in assessing impacts to Biological Resources is presented.

12.1 Significance Criteria
A significant impact is determined using CEQA and CEQA Guidelines. Pursuant to CEQA §21068, a significant effect on the environment means a substantial, or potentially substantial, adverse change in the environment. Pursuant to CEQA Guideline §15382, a significant effect on the environment is further defined as a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or aesthetic significance. Other Federal, State, and local agencies’ considerations and regulations are also used in the evaluation of significance of proposed actions.

Direct and indirect adverse impacts to biological resources are classified as “significant,” “potentially significant,” or “less than significant.” Biological resources are broken down into four categories: vegetation, wildlife, threatened and endangered species, and regulated “waters of the United States” and/or stream channels.

12.1.1 THRESHOLDS OF SIGNIFICANCE

12.1.1.1 Plants, Wildlife, Waters
In accordance with Appendix G (Environmental Checklist Form) of the CEQA Guidelines, implementing the project would have a significant biological impact if it would:
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• Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
• Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. • Have a substantial adverse effect on federally protected “wetlands” as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. • Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
• Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

12.1.1.2 Waters of the United States and State.

Pursuant to Section 404 of the Clean Water Act (33 U.S.C. 1344), the U.S. Army Corps of Engineers (Corps) regulates the discharge of dredged or fill material into waters of the United States, which includes wetlands, as discussed in the bulleted item above, and also includes “other waters” (stream channels, rivers) (33 CFR Parts 328 through 330). Substantial impacts to Corps regulated areas on a project site would be considered a significant adverse impact. Similarly, pursuant to Section 401 of the Clean Water Act, and to the Porter-Cologne Water Quality Control Act, the RWQCB regulates impacts to waters of the state. Thus, substantial impacts to RWQCB regulated areas on a project site would also be considered a significant adverse impact.

12.1.1.3 Stream Channels
Pursuant to Section 1602 of the California Fish and Game Code, CDFW regulates activities that divert, obstruct, or alter stream flow, or substantially modify the bed, channel, or bank of a stream which CDFW typically considers including riparian vegetation. Any proposed activity that would result in substantial modifications to a natural stream channel would be considered a significant adverse impact.

13. IMPACT ASSESSMENT AND PROPOSED MITIGATION
In this section we discuss potential impacts to sensitive biological resources, including specialstatus wildlife species. We follow each impact with a mitigation prescription that when 1463
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implemented would reduce impacts to the greatest extent possible. This impact analysis is based on the Preliminary Site Plan (Sheet A-1).

13.1 Impact BIO-1. Development of the Project Could Have a Potentially Significant Impact on Nesting Swainson’s hawks (Potentially Significant) The Swainson’s hawk is a state listed threatened species. While the Swainson’s hawk has no special federal status, it is protected from direct take under the Federal Migratory Bird Treaty Act of 1918 (16 U.S.C. 703-711). Swainson’s hawks, their nests, eggs, and young are also protected under California Fish and Game Code (§3503, §3503.5, §3513, and §3800).

No Swainson’s hawk nests have been observed on the site or offsite in the vicinity of the project site during M&A’s multiple project site surveys; however, the nesting population appears to be increasing throughout its nesting range in northern California and thus, it could conceivably nest in trees near the project site in the future.

If Swainson’s hawks are found to be nesting adjacent to the project site, implementation of the proposed project could be viewed by CDFW as a project that could impact nesting Swainson’s hawks. Nest site disturbance which results in: (1) nest abandonment; (2) loss of young; (3) reduced health and vigor of eggs and/or nestlings (resulting in reduced survival rates), may ultimately result in the take (killing) of nestling or fledgling Swainson’s hawks incidental to otherwise lawful activities. The taking of Swainson’s hawks in this manner can be viewed by CDFW as a violation of the Section 2080 of the Fish and Game Code. This interpretation of take has been judicially affirmed by the landmark appellate court decision pertaining to CESA (CDFG v. ACID, 8 CA App. 4, 41554) (CDFG 1994).

Typically, CDFW requires that any impact to a Swainson’s hawk nest be permitted through a Fish and Game Section 2081 management authorization. If an active nest is found adjacent to the project site within an area of influence (which is generally considered to be within 1,000 feet of the project site) “to avoid potential violation of Fish and Game Code 2080 (i.e., killing of listed species), project-related disturbance at active Swainson’s hawk nesting sites should be reduced or eliminated during critical phases of the nesting cycle (March 1- September 15 annually)” (CDFG 1994). If disturbance would occur, a Fish and Game Section 2081 management authorization would be required. As such, in the absence of survey results, it must be concluded that impacts to Swainson’s hawk from the proposed project would be potentially significant pursuant to CEQA.

This impact could be mitigated to a level considered less than significant pursuant to CEQA.

The closest known record for nesting Swainson’s hawk is 2.6 miles north of the project site (CNDDB Occurrence No. 2744). There are extensive foraging opportunities both around the closest nesting location and between this nesting location and the project site. Considering that the entire project site consisted of a eucalyptus grove until 2012, it did not historically provide potential foraging habitat. Also, as the project site is essentially surrounded by eucalyptus forest, it is not a foraging destination which would likely attract foraging Swainson’s hawks. Furthermore, M&A has confirmed that the project site has a low rodent population, therefore development of the project site will not have a significant impact on Swainson’s hawk foraging habitat. Therefore, no mitigation for the loss of foraging habitat is warranted for this project. 1464
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13.2 Mitigation Measure BIO-1. Mitigation for Potential Impacts to Nesting Swainson’s Hawk
Preconstruction surveys shall be conducted for a quarter-mile radius around all project activities and shall be completed for at least two survey periods immediately prior to the project’s initiation.

The survey period timing and methodology shall be conducted in accordance with CDFW’s Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (CDFG 1994), which identifies different survey windows throughout the prenesting and nesting season (ranging from January 1 through July 30/post-fledging) that have different survey methodologies and requirements.

If Swainson’s hawks are found to be nesting on the project site or within a ¼-mile of the project site, consultation with CDFW will be required. The size of the nest protection buffer will be determined during consultation with CDFW but at a minimum there will be a 300-foot nondisturbance buffer around the nest site.

Implementation of this mitigation measure would reduce potential impacts to nesting Swainson’s hawk to a level considered less than significant pursuant to CEQA.

13.3 Impact BIO-2. Development of the Project Could Have a Potentially Significant Impact on Western Burrowing Owl (Potentially Significant) The western burrowing owl is a California Species of Special Concern. This raptor (that is, bird of prey) is also protected under the Migratory Bird Treaty Act (50 CFR 10.13) and its nest, eggs, and young are protected under California Fish and Game Code Sections 3503, 3503.5. While western burrowing owls have not been observed on the project site and their likelihood of presence on the project site is considered to be low, limited suitable nesting habitat occurs on the project site. Since the western burrowing owl is a mobile species that could move onto the project site prior to development, preconstruction surveys would be necessary to determine its presence.

Thus, the project may result in impacts to the western burrowing owl; this would be a potentially significant impact pursuant to CEQA. This impact could be mitigated to a level considered less than significant pursuant to CEQA.

13.4 Mitigation Measure BIO-2. Mitigation for Potential Impacts to Western Burrowing Owl
Based on the presence of this species in the project vicinity and the potential habitat found on the project site, a preconstruction survey for burrowing owls should be conducted 14 days prior or less to initiating ground disturbance. As burrowing owls may recolonize a site after only a few days, time lapses between project activities trigger subsequent take avoidance surveys including but not limited to a final survey conducted within 24 hours prior to ground disturbance to ensure absence. If no owls are found during these surveys, no further regard for the burrowing owl would be necessary.
a. Burrowing owl surveys should be conducted by walking the entire project site. Pedestrian survey transects should be spaced to allow 100 percent visual coverage of the ground surface.

The distance between transect center lines should be 7 meters to 20 meters and should be reduced to account for differences in terrain, vegetation density, and ground surface visibility. 1465
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Poor weather may affect the surveyor’s ability to detect burrowing owls thus, avoid conducting surveys when wind speed is greater than 20 kilometers per hour and there is precipitation or dense fog. To avoid impacts to owls from surveyors, owls and/or occupied burrows should be avoided by a minimum of 50 meters (approximately 160 ft.) wherever practical to avoid flushing occupied burrows. Disturbance to occupied burrows should be avoided during all seasons. b. If burrowing owls are detected on the site, the following restricted activity dates and setback distances are recommended per CDFW’s Staff Report (2012). • From April 1 through October 15, low disturbance and medium disturbance activities should have a 200 meter buffer while high disturbance activities should have a 500 meter buffer from occupied nests.
• From October 16 through March 31, low disturbance activities should have a 50 meter buffer, medium disturbance activities should have a 100 meter buffer, and high disturbance activities should have a 500 meter buffer from occupied nests. • No earth-moving activities or other disturbance should occur within the aforementioned buffer zones of occupied burrows. These buffer zones should be fenced as well. If burrowing owls were found in the project area, a qualified biologist would also need to delineate the extent of burrowing owl habitat on the site.

Implementation of these mitigation measures would reduce potential impacts to burrowing owls to a level considered less than significant pursuant to CEQA.

13.5 Impact BIO-3: Development of the Project Would Have a Potentially Significant Impact on Tree or Ground Nesting Raptors (Potentially Significant) Tree or ground nesting raptors that could be affected by the project include northern harrier, white-tailed kites, red-shouldered hawk and red-tailed hawk. Nesting raptors are protected by the federal Migratory Bird Treaty Act (MBTA) (16 U.S.C. 703-711 and 50 CFR 10.13). All nesting raptors, their eggs and young are protected pursuant to California Fish and Game Code §3503.5.

Specific surveys for nesting raptors have not been conducted. In the absence of survey results indicating otherwise, it is conservatively assumed that implementation of the proposed project may impact nesting raptors which could result in nest abandonment and death of eggs or young.

Therefore, impacts to nesting raptors are regarded as potentially significant pursuant to CEQA.

This impact could be mitigated to a level considered less than significant pursuant to CEQA.

13.6 Mitigation Measure BIO-3: Mitigation for Potential Impacts to Tree or Ground Nesting Raptors
To ensure that impacts to tree or ground nesting raptors are avoided or offset, the following mitigation measures will be implemented:
a. In order to avoid impacts to nesting raptors, a preconstruction nesting survey will be conducted by a qualified raptor biologist prior to commencing with earth-moving or construction work if this work would commence between February 1st and August 31st. The survey should be 1466
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conducted within the 30 day period prior to site disturbance. The raptor nesting surveys will include examination of all trees and ruderal habitat within 200 feet of the project site. b. If nesting raptors are identified during the surveys, the dripline of the nest tree or groundnesting site must be fenced with orange construction fencing (provided the nest site is on the project site), and a 200-foot radius around the nest tree or nest site must be staked with orange construction fencing. If the tree or nest site is located off the project site, then the buffer should be demarcated per above where the buffer occurs on the project site. The size of the buffer may be altered if a qualified raptor biologist conducts behavioral observations and determines the nesting raptors are well acclimated to disturbance. If this occurs, the raptor biologist should prescribe a modified buffer that allows sufficient room to prevent undue disturbance/harassment to the nesting raptors. No construction or earth-moving activity should occur within the established buffer until it is determined by a qualified raptor biologist that the young have fledged (that is, left the nest) and have attained sufficient flight skills to avoid project construction zones. This typically occurs by August 1st. This date may be earlier or later, and would have to be determined by a qualified raptor biologist. If a qualified biologist is not hired to watch the nesting raptors then the buffers should be maintained in place through the month of August and work within the buffer can commence on September 1st. c. If the preconstruction nesting survey identifies a large stick or other type of raptor nest that appears inactive at the time of the survey, but there are territorial raptors evident in the nest site vicinity, a protection buffer (as described above) should be established around the potential nesting tree until the qualified raptor biologist determines that the nest is not being used. In the absence of conclusive observations indicating the nest site is not being used, the buffer should remain in place until a second follow-up nesting survey can be conducted to determine the status of the nest and eliminate the possibility that the nest is utilized by a late-spring nesting raptor (for example, red-tailed hawk). This second survey should be conducted even if construction has commenced. If during the follow-up late season nesting survey a nesting raptor is identified utilizing the nest, the protection buffer should remain until it is determined by a qualified raptor biologist that the young have fledged and have attained sufficient flight skills to avoid project construction zones. If the nest remains inactive, the protection buffer can be removed and construction and earth-moving activities can proceed unrestrained.

Implementation of these mitigation measures would reduce potential impacts to nesting raptors to a level considered less than significant pursuant to CEQA.

13.7 Impact BIO-4: Development of the Project Would Have a Potentially Significant Impact on Nesting Passerine Birds. (Potentially Significant) Nesting passerine birds (i.e., perching birds) are protected by the federal Migratory Bird Treaty Act (MBTA) (16 U.S.C. 703-711 and 50 CFR 10.13) and by California Fish and Game Code §3503 and §3503.5 which protects nesting birds, their eggs and young. These birds frequently change nesting locations from year to year and thus, past nesting histories are not necessarily indicative of future nesting activities. Accordingly, impacts to nesting passerine birds, their eggs, and/or young resulting from the proposed project are considered potentially significant. This impact could be mitigated to a level considered less than significant pursuant to CEQA. 1467
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13.8 Mitigation Measure BIO-4: Mitigation for Potential Impacts to Nesting Passerine Birds.

To ensure that impacts to nesting passerine birds are avoided or offset, a nesting survey shall be conducted 15 days prior to commencing construction/ grading or tree removal activities if this work would commence between March 1 and September 1. If common passerine birds or special-status passerine birds are identified nesting on the project site, a non-disturbance buffer of 75 feet shall be established or as otherwise prescribed by a qualified ornithologist. The buffer shall be demarcated with orange construction fencing. Disturbance within the buffer shall be postponed until it is determined by a qualified ornithologist that the young have fledged and have attained sufficient flight skills to leave the area or that the nesting cycle has otherwise completed.

Typically, most passerine birds in the region of the project site are expected to complete nesting by August 1st. However, many species can complete nesting by the end of June or in early to mid-July. Regardless, nesting buffers shall be maintained until August 1st unless a qualified ornithologist determines that young have fledged and are independent of their nests at an earlier date. If buffers are removed prior to August 1st, the qualified biologist conducting the nesting surveys should prepare a report that provides details about the nesting outcome and the removal of buffers. This report shall be submitted to the City of American Canyon Planning Department prior to the time that nest protection buffers are removed if the date is before August 1st.

Implementation of this mitigation measure would reduce potential impacts nesting passerine birds to a level considered less than significant pursuant to CEQA. 1468
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14. LITERATURE CITED
Baldwin D.H, Goldman D.H., Keil D.J., Patterson R, Rosatti T.J., Wilken D.H. (ed.). 2012. The Jepson Manual Vascular Plants of California: Second Edition. University of California Press, Berkeley. 1568 pps.

Beier, P. and S. Loe. 1992. "In my experience.." a checklist for evaluating impacts to wildlife movement corridors. Wildlife Society Bulletin Vol. 20(4): 6.

Bulger, J.B., N.J. Scott, Jr., R.B. Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands.

Biological Conservation. Vol. 110. Issue 1. March 2003. pps. 85-95.

CDFG (California Department of Fish and Game). 1994. Staff report regarding mitigation for impacts to Swainson’s hawks (Buteo swainsonii) in the central valley of California. 14 pps.

November 1, 1994.

CDFG (California Department of Fish and Game). 2012. Staff report on burrowing owl mitigation.

March 7, 2012. 15 pages plus appendices.

CDFW (California Department of Fish and Game). 2016. Complete List of Amphibian, Reptile, Bird and Mammal Species in California. Published September 2008; updated July 2014.

City of American Canyon. 1994. General Plan for the City of American Canyon.

CNDDB (California Natural Diversity Data Base). 2018. RareFind 3.1. Computer printout for special-status species within a 5-mile radius of the project site. California Natural Heritage Division, California Department of Fish and Wildlife, Sacramento, CA.

CNPS (California Native Plant Society). 2001. Inventory of rare and endangered plants of California (sixth edition). Rare plant scientific advisory committee, David P. Tibor, convening editor. California Native Plant Society. Sacramento, CA. x+338 pps.

CNPS. California Native Plant Society, Rare Plant Program. 2017. Inventory of Rare and Endangered Plants of California (online edition, v8-03 0.39). California Native Plant Society. Sacramento, CA. Accessed 2017 from http://www.rareplants.cnps.org Fellers, Gary M. and Patrick M. Kleeman. 2007. California Red-Legged Frog (Rana draytonii) Movement and Habitat Use: Implications for Conservation. Western Ecological Research Center, USGS, Point Reyes National Seashore, Point Reyes, California 94956 USA.

James, P.C. 1992. Urban-nesting of Swainson's hawks in Saskatchewan. Condor. 94: 773-774.

Jepson Interchange Project website: http://ucjeps.berkeley.edu/interchange/index.html 1469
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Palmer, Ralph S., editor. 1988. Handbook of North American birds. Volume 5. New Haven, CT:

Yale University Press. 463 p.

Schlorff, Ronald W. and Peter H. Bloom. 1984. Importance of riparian systems to nesting Swainson's hawks in the Central Valley of California. In: Warner, Richard E.; Hendrix, Kathleen M., eds. California riparian systems: Ecology, conservation, and productive management: Proceedings of a conference; 1981 September 17-19; Davis, CA. Berkeley, CA: University of California Press: 612-618.

Schmutz, Josef K.; Fyfe, Richard W.; Moore, David A.; Smith, Alan R. 1984. Artificial nests for ferruginous and Swainson's hawks. Journal of Wildlife Management. 48:1009-1013.

Tatarian, P. J. 2005. Movement Patterns of the California Red-legged Frogs (Rana Aurora Draytonii) in an Inland California Environment (Master’s Thesis, Sonoma State University).

U.S. Army Corps of Engineers. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report, Y-87-1. US Army Engineer Waterways Experiment Station. Vicksburg, Mississippi. 100 pp.

U.S. Army Corps of Engineers. 2008. Regional Supplement to the U.S. Army Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2). Ed. J.S. Wakeley, R.W.

Lichvar, and C.V. Noble. ERDC/EL TR-06-16. Vicksburg, MS: U.S. Army Engineer Research and Development Center. September 2008.

USFWS (U.S. Fish & Wildlife Service). 1996. Endangered and threatened wildlife and plants; determination of threatened status for the California red-legged frog. Final rule. Federal register: May 23, 1996 (Volume 61, Number 101).

USFWS (U.S. Fish & Wildlife Service). 2002. Recovery plan for the California red-legged frog (Rana aurora draytonii). U.S. Fish and Wildlife Service, Portland, Oregon. Viii + 173 pps.

USFWS (U.S. Fish & Wildlife Service). 2005. Endangered and threatened wildlife and plants; revised proposed designation of critical habitat for the California red-legged frog (Rana aurora draytonii); proposed rule. (50 CFR Part 17, November 3, 2005). The PDF number is 05-219594 [1].

USFWS (U.S. Fish & Wildlife Service). 2005. Revised guidance on site assessments and field surveys for the California red-legged frog. August 2005. 26 pps.

USFWS (U.S. Fish & Wildlife Service). 2010. Endangered and Threatened Wildlife and Plants:

Revised Designation of Critical Habitat for California Red-Legged Frog; Final Rule.

Federal Register 50 CFR Part 17 March 17, 2010 (Volume 75, Number 51) Page 12815- 12864
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Table 1
Plant Species Observed on the SDG 217 Commerce Distribution Center Project Site monk & associates
Angiosperms - Dicots
Apiaceae
Torilis sp. sock destroyer
Asteraceae
Baccharis pilularis subsp. pilularis Baccharis
*Carduus pycnocephalus subsp. pycnocephalus Italian thistle *Cirsium vulgare Bull thistle
*Dittrichia graveolens Stinkwort
*Hypochaeris radicata Rough cat's-ear
*Sonchus asper subsp. asper Prickly sow-thistle
Brassicaceae
*Hirschfeldia incana Short-podded mustard
*Sinapis alba White mustard
Caryophyllaceae
*Stellaria media Common chickweed
Convolvulaceae
*Convolvulus arvensis Bindweed
Fabaceae
*Medicago polymorpha California burclover
*Trifolium repens White clover
*Vicia sativa Common vetch
Geraniaceae
*Erodium cicutarium Red-stem filaree
*Geranium dissectum Cut-leaf geranium
Montiaceae
Claytonia perfoliata Miner's lettuce
Myrsinaceae
*Lysimachia arvensis Scarlet pimpernel
Orobanchaceae
*Parentucellia viscosa Yellow glandweed
Papaveraceae
*Fumaria parviflora Fumaria
Plantaginaceae
*Plantago lanceolata English plantain
Polygonaceae
*Rumex crispus Curly dock
Ranunculaceae
*Ranunculus muricatus Spiny-fruit buttercup
Rubiaceae
Galium aparine Goose grass
* Indicates a non-native species Page 1 of 2
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Plant Species Observed on the SDG 217 Commerce Distribution Center Project Site monk & associates
Angiosperms -Monocots
Iridaceae
Sisyrinchium californicum Golden-eyed-grass
Juncaceae
Juncus occidentalis Slender rush
Poaceae
*Avena barbata Slender wild oat
*Bromus diandrus Ripgut grass
*Bromus hordeaceus Soft chess
Elymus triticoides Creeping wildrye
*Festuca perennis perennial ryegrass
*Hordeum murinum Wall barley
Phalaris angusta Canary timothy grass
* Indicates a non-native species Page 2 of 2
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Table 2
Wildlife Observed on the ICC SDG 217 Commerce Distribution Center Project Site Monk & Associates
Amphibians
Sierran treefrog Pseudacris sierra
Reptiles
Western fence lizard Sceloporus occidentalis
Birds
Northern flicker Colaptes auratus
Great blue heron Ardea herodias
Turkey vulture Cathartes aura
Canada goose Branta canadensis
Osprey Pandion haliaetus
White-tailed kite Elanus leucurus
Red-shouldered hawk Buteo lineatus
Red-tailed hawk Buteo jamaicensis
American kestrel Falco sparverius
Ring-necked pheasant Phasianus colchicus
Wild turkey Meleagris gallopavo
California quail Callipepla californica
Virginia rail Rallus limicola
Eurasian collared-dove Streptopelia decaocto
Mourning dove Zenaida macroura
Barn owl Tyto alba
Anna's hummingbird Calypte anna
Belted kingfisher Megaceryle alcyon
Nuttall's woodpecker Picoides nuttallii
Black phoebe Sayornis nigricans
Say's phoebe Sayornis saya
California scrub jay Aphelocoma californica
American crow Corvus brachyrhynchos
Common raven Corvus corax
Tree swallow Tachycineta bicolor
Cliff swallow Petrochelidon pyrrhonota
Barn swallow Hirundo rustica
Chestnut-backed chickadee Poecile rufescens
Bushtit Psaltriparus minimus
Brown creeper Certhia americana
Bewick's wren Thryomanes bewickii
Marsh wren Cistothorus palustris
Ruby-crowned kinglet Regulus calendula
Western bluebird Sialia mexicana
American robin Turdus migratorius
Wrentit Chamaea fasciata
Northern mockingbird Mimus polyglottos
European starling Sturnus vulgaris
Yellow-rumped warbler Setophaga coronata
Spotted towhee Pipilo maculatus

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American Canyon City CouncilNovember 19, 2024

American Canyon City Council
November 19, 2024