American Canyon City Council
November 19, 2024

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Table 2
Wildlife Observed on the ICC SDG 217 Commerce Distribution Center Project Site Monk & Associates
California towhee Pipilo crissalis
Savannah sparrow Passerculus sandwichensis
Song sparrow Melospiza melodia
White-crowned sparrow Zonotrichia leucophrys
Dark-eyed junco Junco hyemalis
Red-winged blackbird Agelaius phoeniceus
Brewer's blackbird Euphagus cyanocephalus
Brown-headed cowbird Molothrus ater
Bullock's oriole Icterus bullockii
House finch Haemorhous mexicanus
Lesser goldfinch Spinus psaltria
House sparrow Passer domesticus
Mammals
Western gray squirrel Sciurus griseus
Black-tailed jackrabbit Lepus californicus
California ground squirrel Otospermophilus beecheyi
Columbian black-tailed deer Odocoileus hemionus ssp. columbianus Coyote Canis latrans
Raccoon Procyon lotor
Feral cat Felis catus

1479
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
Asteraceae
Balsamorhiza macrolepis Fed: -
State: -
CNPS: Rank 1B.2
Cismontane woodland;
chaparral; valley and foothill
grassland; [sometimes
serpentinite]. 90 - 1555
meters
None. The project site is highly
disturbed. No suitable habitat on
the project site. Big-scale balsam-root
March-June Closest record is from 2011 and is

3.0 miles east of the project site
(Occurrence No. 7).

Symphyotrichum lentum Fed: -
State: -
CNPS: Rank 1B.2
Marshes and swamps
(brackish and fresh water)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Suisun Marsh aster
August-November Closest record is from 1993 and is

2.5 miles northwest of the project
site (Occurrence No. 128).

Chenopodiaceae
Extriplex joaquinana Fed: -
State: -
CNPS: Rank 1B.2
Chenopod scrub; meadows;
valley and foothill grassland;
[alkaline].

None. The project site is highly
disturbed. No suitable habitat on
the project site. San Joaquin spearscale
April-October Closest record is from and is 1.8
miles south of the project site
(Occurrence No. 58).

Cyperaceae
Carex lyngbyei Fed: -
State: -
CNPS: Rank 2
Marshes or swamps
(brackish or freshwater)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Lyngbye's sedge
May-August Closest record is from 2008 and is

2.3 miles northwest of the project
site (Occurrence No. 28).

Fabaceae
Astragalus tener tener Fed: -
State: -
CNPS: Rank 1B.2
Playas; mesic grasslands
(adobe clay), vernal pools
(alkaline).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Alkali milkvetch
March-June Closest record is from 1993 and is

1.8 miles south of the project site
(Occurrence No. 50).

1480
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
Lathyrus jepsonii jepsonii Fed: -
State: -
CNPS: Rank 1B.2
Marshes and swamps
(freshwater and brackish).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Delta tule pea
May-September Closest record is from 1978 and is

2.6 miles northwest of the project
site (Occurrence No. 13).

Trifolium amoenum Fed: FE
State: -
CNPS: Rank 1B.1
Valley and foothill grassland
(sometimes serpentinite)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Showy Indian clover
April-June Closest record is from 1952 and is

1.2 miles east of the project site
(Occurrence No. 23).

Orobanchaceae
Castilleja affinis neglecta Fed: FE
State: CT
CNPS: Rank 1B.2
Valley and foothill grassland
[serpentinite]
None. The project site is highly
disturbed. No suitable habitat on
the project site. Tiburon paintbrush
April-June Closest record is from 2013 and is

3.0 miles east of the project site
(Occurrence No. 5).

Chloropyron molle molle Fed: FE
State: CR
CNPS: Rank 1B.2
Marshes and swamps
(coastal salt).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Soft bird's-beak
July-September Closest record is from 2010 and is

2.3 miles north of the project site
(Occurrence No. 3).

1481
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
*Status
Federal:

FE - Federal Endangered
FT - Federal Threatened
FPE - Federal Proposed Endangered
FPT - Federal Proposed Threatened
FC - Federal Candidate
State:

CE - California Endangered
CT - California Threatened
CR - California Rare
CC - California Candidate
CSC - California Species of Special Concern
CNPS Continued:

Rank 2 - Plants rare, threatened, or endangered in California, but more common elsewhere
Rank 2A - Extirpated in California, common elsewhere
Rank 2B.1 - Seriously endangered in California, but more common elsewhere Rank 2B.2 - Fairly endangered in California, but more common elsewhere Rank 2B.3 - Not very endangered in California, but more common elsewhere Rank 3 - Plants about which we need more information (Review List) Rank 3.1 - Plants about which we need more information (Review List) Seriously endangered in California
Rank 3.2 - Plants about which we need more information (Review List) Fairly endangered in California
Rank 4 - Plants of limited distribution - a watch list
CNPS:

Rank 1A - Presumed extinct in California
Rank 1B - Plants rare, threatened, or endangered in California and elsewhere Rank 1B.1 - Seriously endangered in California (over 80% occurrences threatened/ high degree and immediacy of threat)
Rank 1B.2 - Fairly endangered in California (20-80% occurrences threatened) Rank 1B.3 - Not very endangered in California (<20% of occurrences threatened or no current threats known)

1482
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Invertebrates
Branchinecta lynchi
Closest record is from 2003 and is 1.5
miles north of the project site
(Occurrence No. 232).

Fed: FT None. No suitable habitat on the project site.

State: -
Endemic to the grasslands of the Central
Valley, central coast mountains, and south
coast mountains. Inhabit static rainfilled/vernal pools, small, clear water sandstone-depression pools and grassed
swale, earth slump, or basalt-flow depression
Vernal pool fairy shrimp
Other:

Fish
Oncorhynchus mykiss irideus
Closest record is from 2000 and is 0.39
miles southwest of the project site
(Occurrence No. 4).

Fed: FT None. No suitable habitat on the project site.

State: -
From Russian River south to Soquel Creek,
and to Pajaro River. Also found in San
Francisco & San Pablo Bay Basins. Spawn in
clear, cool, well oxygenated streams greater
than 18 cm deep.

Steelhead - Central California Coast DPS
Other:

Spirinichus thaleichthys
Closest record is from 2012 and is1.2
miles west of the project site
(Occurrence No. 26).

Fed: -- None. No suitable habitat on the project site.

State: CT
Endemic to the Sacramento-San Joaquin
River system. Inhabits open waters in the
Delta and Suisun Bay. After spawning, larvae
are carried downstream to brackish nursery
areas.

Longfin smelt
Other:

Pogonichthys macrolepidotus
Closest record is from 2001 and is 2.9
miles southwest of the project site
(Occurrence No. 12).

Fed: None. No suitable habitat on the project site.

State: CSC
Endemic to the lakes and rivers of the Central
Valley; now confined to the delta, Suisun
Bay, and associated marshes. Inhabits slow
moving river sections and dead-end sloughs.

Needs flooded vegetation for spawning.

Sacramento splittail
Other:

Amphibians
Rana draytonii
Closest record is from 2006 and is 1.4
miles east of the project site
(Occurrence No. 896).

Fed: FT None. No suitable habitat on the project site.

State: CSC
Occurs in lowlands and foothills in deeper
pools and streams, usually with emergent
wetland vegetation. Requires 11-20 weeks of
permanent water for larval development.

California red-legged frog
Other:

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*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Rana boylii
Closest record is from 193X and is 1.2
miles east of the project site
(Occurrence No. 2341).

Fed: -- None. No suitable habitat on the project site.

State: CC
Found in partially shaded, shallow streams
with rocky substrates. Requires perenial pools
or flowing water. Needs some cobble-sized
rocks as a substrate for egg laying. Requires
water for 15 weeks for larval transformation.

Foothill yellow-legged frog
Other:

Reptiles
Emys marmorata
Closest record is from 2002 and is 0.45
miles northeast of the project site
(Occurrence No. 552).

None. No suitable habitat on or adjacent to the
project site.

Fed: -
State: CSC
Inhabits ponds, marshes, rivers, streams, and
irrigation ditches with aquatic vegetation.

Needs suitable basking sites and upland
habitat for egg laying. Occurs in the Central
Valley and Contra Costa County.

Western pond turtle **
Other:

Birds
Circus cyaneus
Closest record is from 2004 and is 2.8
miles west of the project site
(Occurrence No. 29).

Unlikely to nest onsite. Preconstruction surveys
will be conducted.

Fed: -
State: CSC
Nests on the ground or in shrubby vegetation
typically in grasslands, fallow farm lands,
near freshwater and salt water marshes.

Northern harrier
Other:

Buteo swainsoni
Closest record is from 2013 and is 2.6
miles northeast of the project site
(Occurrence No. 2744).

Unlikely to nest adjacent to project site.

Preconstruction surveys will be conducted.

Fed: -
State: CT
Migratory and resident raptor that breeds in
open areas with scattered trees. Prefers
riparian and sparse oak woodland habitats for
nesting. Requires nearby grasslands, grain
fields, or alfalfa for foraging.

Swainson's hawk
Other:

Buteo regalis
Closest record is from 1988 and is 3.0
miles north of the project site
(Occurrence No. 28).

Fed: -- None. Does not nest in California.

State: WL
Winter migrant to California where they
prefer grasslands, cultivated fields and arid
areas with an abundance of prey species, such
as pocket gophers, black-tailed hares, and
cottontails.

Ferruginous hawk
Other:

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*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Falco peregrinus
Closest record is from 2015 and is 3.0
miles east of the project site
(Occurrence No. 42).

None. No suitable nesting habitat on or near the
project site.

Fed: -
State: -
Nests on high cliffs near wetlands, lakes,
rivers, or other water; also nests on humanmade structures. Nest consists of a scrape on a depression or ledge in an open site. Was
formerly state and federally listed but delisted
due to species recovery.

Peregrine falcon
Other:

Laterallus jamaicensis coturniculus
Closest record is from 2011 and is 2.5
miles northwest of the project site
(Occurrence No. 31).

Fed: -- None. No suitable habitat on the project site.

State: CT
Inhabits salt marshes bordering larger bays.

Prefers tidal salt marshes of pickleweed.

California black rail
Other:

Rallus obsoletus obsoletus
Closest record is from 1989 and is 2.4
miles northwest of the project site
(Occurrence No. 16).

Fed: FE None. No suitable habitat on the project site.

State: CE
Inhabits salt water and brackish marshes with
tidal sloughs in San Francisco Bay. Prefers
dense pickleweed for cover, but forages for
invertebrates along mud-bottomed sloughs.

California Ridgway's rail
Other:

Athene cunicularia hypugaea
Closest record is from 1989 and is 2.6
miles southeast of the project site
(Occurrence No. 109).

Unlikely to nest on the project site.

Preconstruction surveys will be conducted.

Fed: --
State: CSC
Found in 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.

Western burrowing owl
Other:

Geothlypis trichas sinuosa
Closest record is from 2004 and is 2.5
miles northwest of the project site
(Occurrence No. 37).

Fed: - None. No suitable habitat on the project site.

State: CSC
Resident of freshwater and salt water marshes
in the San Francisco Bay region. Requires
thick, continuous cover for foraging and tall
grasses, tules, or willows for nesting.

Salt marsh common yellowthroat
Other:

Melospiza melodia samuelis
Closest record is from 2004 and is 2.8
miles west of the project site
(Occurrence No. 17).

Fed: -- None. No suitable habitat on the project site.

State: CSC
More properly known as Samuels Song
Sparrow. Resident of salt marshes along the
north side of San Francisco and San Pablo
Bays. Inhabits tidal sloughs in the California
marshes; nests in grindelia bordering slough
channels.

San Pablo song sparrow
Other:

1485
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Agelaius tricolor
Closest record is from 2014 and is 1.6
miles northeast of the project site
(Occurrence No. 243).

None. No suitable nesting habitat on the project
site.

Fed: -
State: CC
Colonial nester in dense cattails, tules,
brambles or other dense vegetation. Requires
open water, dense vegetation, and open grassy
areas for foraging.

Tricolored blackbird
Other: CSC
Mammals
Reithrodontomys raviventris
Closest record is from 1989 and is 2.4
miles south of the project site
(Occurrence No. 150).

Fed: FE None. No suitable habitat on the project site.

State: CE
Inhabits saline marshes in the San Francisco
Estuary. Prefers pickleweed marshes.

Requires higher areas for escaping high water.

Salt marsh harvest mouse
Other:
*Status
Federal:

FE - Federal Endangered
FT - Federal Threatened
FPE - Federal Proposed Endangered
FPT - Federal Proposed Threatened
FC - Federal Candidate
FPD - Federally Proposed for delisting
State:

CE - California Endangered
CT - California Threatened
CR - California Rare
CC - California Candidate
CSC - California Species of Special Concern
FP - Fully Protected
WL - Watch List. Not protected pursuant to CEQA
**The USFWS hopes to finish a 12-month finding for western pond turtle in 2021 but until formally listed, it is not afforded the protections of FESA.

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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 1488
Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site SDG Commerce 217 Distribution Center, Napa, California
APN: 058-030-065-000

MONK & ASSOCIATES
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 1489
SDG COMMERCE 217 DISTRIBUTION CENTER

BORROW SITE ROUGH GRADING

AMERICAN CANYON CALIFORNIA
1 1

PRELIMINARY - NOT FOR CONSTRUCTION

CHECKED
DRAWN

DESIGNED
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
NAPA, CALIF. 94559
OFFICE
www.RSAcivil.com
| 252.3301 707|
+ + 1
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SDG COMMERCE 217 DISTRIBUTION CENTER

AMERICAN CANYON CALIFORNIA
20 CHECKEDDRAWNDESIGNEDDATEJOB NO.SHEET NO.

OF SHEETS
APPD REVISIONS BY DATE NO.

Printed on Recycled Paper Please Continue the Cycle
RSA | CONSULTING CIVIL ENGINEERS + SURVEYORS + +
1980
est.
1515 FOURTH STREET
NAPA, CALIF. 94559
OFFICE
www.RSAcivil.com
| 252.3301 707|
+ + BORROW SITE GRADING PLAN
C3.5
14 City of American Canyon
Public Works
Job Site Copy
03/28/2023
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment
FirstCarbon Solutions
D.2 - SDG Commerce Site 220 Documents
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1494

PINECREST ENVIRONMENTAL CONSULTING
6425 TELEGRAPH AVE. #8
OAKLAND, CA 94609
510.881.3039 TEL
[email protected]
WWW.PINECRESTENVIRONMENTAL.ORG
1 S P E C I A L - S T A T U S A N I M A L S U R V E Y R E P O R T Date: August 8, 2023
To: Robert Carroll, FCS International.

From: Dr. Christopher T. DiVittorio, Pinecrest Research Corp., Inc.

Subject: Results of special-status animal surveys at 220 Commerce Court, Napa County, CA (FCS Project 5639.0001)
Robert Carroll,
This special-status animal survey report (Report) details the findings of eleven (11) wildlife surveys conducted between January 18 and July 2 in 2023 at the above-referenced property located in the County of Napa. The site consists of one parcel measuring 10.2 acres and assigned APN 058-030-069. Surveys were conducted in order to determine the pre-construction presence or absence of the following special-status animals: burrowing owl (Athene cunicularia), Swainson’s hawk (Buteo swainsoni), nesting raptors, nesting passerine birds, and Western pond turtle. Surveys were conducted by consulting biologist Dr. Christopher DiVittorio.

Site Description
The entirety of the site is disked and mowed ruderal grassland, with the exception of a row of Eucalyptus trees along the northern property line. The ruderal grassland exhibits low cover of plants and low species diversity with very few native species (Figure 1). The habitat type of this area as determined by Sawyer et al. (2009) Manual of California Vegetation 2nd Edition (MCV) is Bromus (diandrus, hordeaceous)-Brachypodium distachyon Semi-Natural Herbaceous Stand.

On the north side of the parcels is a row of bluegum Eucalyptus. The MCV classification of this habitat is Eucalyptus (globulus, camaldulensis) Semi-Natural Woodland Stands.

Methods
Between January 18 and July 2, 2023, eleven (11) surveys were conducted for nesting passerine birds, raptors (including Swainson’s hawk), burrowing owl, and Western pond turtle. During each survey, the entirety of the "Commerce 220" site as well as the adjacent "Commerce 217" site were examined. These surveys included the entirety of both legal parcels, as well all of the vegetated areas up to the concrete paved area on the developed parcel to the south. Relevant adjacent areas were also examined with binoculars where possible. A total of approximately 45 survey hours were completed across all survey dates. All of the aforementioned animal types were surveyed for at each of the eleven site visits. Survey methods followed established procedures and applicable protocols, including the Recommended Timing and Methodology for Swainson’s Hawk Nesting fSurveys in California’s Central Valley, and the Staff Report on 1495
2 PINECREST ENVIRONMENTAL CONSULTING, INC.

Burrowing Owl Mitigation.
1,2
Survey equipment included high-quality binoculars and a highquality spotting scope. Surveys were conducted during the appropriate times of day (including peak bird detection periods between sunrise and 10 a.m.). Surveys were conducted on foot.

Survey dates with the corresponding Swainson's hawk survey periods are shown below.

Date Swainson’s Hawk Survey Period
1/18/2023 1st survey in Period I
3/20/2023 1st survey in Period II
3/31/2023 2nd survey in Period II
4/4/2023 3rd survey in Period II
4/5/2023 1st survey in Period III
4/6/2023 2nd survey in Period III
4/7/2023 3rd survey in Period III
4/24/2023 1st survey in Period IV
4/28/2023 2nd survey in Period IV
5/29/2023 3rd survey in Period IV
7/2/2023 1st survey in Period V
Results & Recommendations
A total of 56 unique species of birds were observed across the eleven site visits. A total of 4 other species of animals were observed across the eleven site visits. Transcribed field notes from each of the eleven site visits are provided in Appendix A, below. A master list of all species of birds and other animals encountered across the eleven site visits is provided in Appendix B, below.

Due to the lack of suitable nesting habitat on the project site itself, no nesting birds were observed in the project area, although nesting birds were observed in the Eucalyptus stands offsite. Of the nesting birds in the offsite Eucalyptus stands, none of these were special-status including raptors. 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. No adults or nests of Western pond turtle were observed (Appendix A & B).
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. 1496
3 PINECREST ENVIRONMENTAL CONSULTING, INC.

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 onsite also indicates that Swainson's hawk are not utilizing this habitat currently since these species are antagonistic and do not typically share ranges. The negative survey results for Swainson’s hawk despite approximately 45 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)
No active raptor nests were observed within the vicinity of the project site. Several American crow were loitering around the Eucalyptus grove to the east of the parcel and harassing Whitetail 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-shouldered hawk was observed within a large Eucalyptus tree along the north property line however this individual flew offsite after approximately 20 minutes. No other active nests were observed during any of the eleven site visits.

Burrowing Owl
No evidence of burrowing owl activity was observed during any of the eleven 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 eleven field surveys.

There are some wetland features onsite, however there are no ponds or streams onsite that would be suitable for Western pond turtle foraging or breeding. No signs of adults or nests were observed onsite or in the accessible vicinity of the site. Therefore, it is reasonable to conclude Western pond turtle is absent from the project site.

Based on the results of these eleven surveys, we conclude that there are no special-status animal species currently occupying the project site, and no compensatory mitigation for impacts to special-status animal species is recommended at this time. These results do not however, preclude the future existence of the above-referenced species onsite as they may recolonize the site if sufficient time has passed between these surveys and site development.

Please let me know if you have any questions about this or any other studies we've performed for this project.
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4 PINECREST ENVIRONMENTAL CONSULTING, INC.

Sincerely,
Christopher DiVittorio, PhD
President, PEC
(510) 881-3039
[email protected]
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Figure 1: Ruderal Grassland
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Figure 2: Eucalyptus Stands
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Figure 3: Habitat Map
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Appendix A: Animal Survey Field Notes
The following is a transcription of field notes for each of the eleven (11) protocol-level surveys conducted at the project site. Special-status species, if any, are denoted with an asterisk (*).

Site Visit: 1/18/23
Time: 12:00 PM (approx.)
Weather: clear, no wind, 56degF
Notes: started mid-day
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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) Other Animals: None
Site Visit: 3/20/23
Time: 6:35 AM
Weather: no wind, 49 degF, 46% RH
Notes: start at sunrise; park in SE corner
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; early season plant survey
Personnel: Dr. Christopher DiVittorio
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), 1502
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Site Visit: 3/31/23
Time: 6:30 AM
Weather: clear, wind 0 mph, 44.5 degF, 76.5% RH
Notes: parked NE corner
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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), 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
Notes: parked SW corner; 6:15 AM first light, 7:15 first direct sunlight Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; mid-season plant survey
Personnel: Dr. Christopher DiVittorio
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 onsite; parked SW corner Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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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), Other Animals: None
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 onsite; parked SW corner Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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: black-tailed jackrabbit (Lepus californicus) runways, California vole (Microtus californicus) runways
Site Visit: 4/7/23
Start time: 6:30 AM
Weather: cloudy, 54.5 degF, 79% RH, wind 1-2 mph, fewer birds today Notes: met Jerry with Stravinsky onsite
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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), whitecrowned sparrow (Zonotrichia leucophrys), Other Animals: black-tailed jackrabbit (Lepus californicus), 1504
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Site Visit: 4/24/23
Start time: 6:30 AM
Weather: cloudy, then sunny; 61 degF, 64% RH, 1-3 mph wind Notes: met Jerry with Stravinsky onsite for survey at 6:30, began preconstruction meeting 8:00 AM Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; preconstruction meeting with geotechnical engineer, Stravinsky, civil engineer, SWPP monitor, etc.

Personnel: Dr. Christopher DiVittorio
Birds: violet-green swallow (Tachycineta thalassina), Brewer’s blackbird (Euphagus cyanocephalus), California towhee (Melozone crissalis), dark-eyed junco (Junco hyemalis), black phoebe (Sayornis nigricans), lesser goldfinch (Spinus psaltria), crow (Corvus brachyrhynchos), Anna's hummingbird (Calypte anna), house wren (Troglodytes aedon), European starling (Sturnus vulgaris), white-crowned sparrow (Zonotrichia leucophrys), Nuttal's woodpecker (Picoides nuttallii), American goldfinch (Spinus tristis), Western bluebird (Sialia mexicana), turkey vulture (Cathartes aura), mourning dove (Zenaida macroura), White-tailed kite (Elanus leucurus) soaring and hovering over field, juvenile red-tailed hawk (Buteo jamaicensis) offsite to E flushed immediately out of site to the SE, peregrine falcon (Falco peregrinus) fly-through overhead, unidentified species of sparrow, Other Animals: none
Other Notes: Red-tailed hawk nest on south side of existing warehouse to the south of project site is not active this year.

Site Visit: 4/28/23
Start time: 5:45 AM
Weather: cloudy, cold
Notes: met Jerry with Stravinsky onsite, Commerce 217 will be graded tomorrow; silt fencing installed and grass has been mowed since last visit; no burrows or other animal sign onsite; this counts towards the 24-hour BUOW preconstruction survey requirement
Purpose: preconstruction Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
Birds: White-tailed kite (Elanus leucurus) hovering over field, turkey vulture (Cathartes aura), wild turkey (Meleagris gallopavo),
Other Animals: black-tailed jackrabbit (Lepus californicus), Site Visit: 5/29/23
Start time: 8:30 AM
Weather: sunny
Notes: Commerce 220 site has been graded in addition to Commerce 217 Purpose: Swainson's hawk, other raptor, nesting passerine bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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Birds: no sign of BUOW or Swainson's hawk; presence/absence survey only; no comprehensive bird list completed
Other Animals: none
Site Visit: 7/2/23
Start time: 1:00 PM
Weather: clear, sunny, 85 degF, 51% RH, 3-8 mph wind
Note: many species appear to have migrated offsite for the summer Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Bird Species:
house finch (Haemorhous mexicanus), Osprey (Pandion haliaetus), turkey vulture (Cathartes aura), lesser goldfinch (Spinus psaltria), red-tailed hawk (Buteo jamaicensis), Nuttal's woodpecker (Picoides nuttallii), kildeer (Charadrius vociferus), White-tailed kite (Elanus leucurus) Other Animals: none
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Appendix B: Master Species List
The following is a list of animal species observed across the eleven (11) site visits at the project site. Special-status species, if any, are denoted with an asterisk (*).

MASTER BIRD LIST
Allen's hummingbird (Selasphorus sasin)
American coot (Fulica americana)
American goldfinch (Spinus tristis)
American pelican (Pelecanus erythrorhynchos)
American pipit (Anthus rubescens)
American robin (Turdus migratorius)
Anna's hummingbird (Calypte anna)
Bewick's wren (Thryomanes bewickii)
black phoebe (Sayornis nigricans)
Brewer’s blackbird (Euphagus cyanocephalus)
brown creeper (Certhia americana)
brown-headed cowbird (Molothrus ater)
California gull (Larus californicus)
California towhee (Melozone crissalis)
Canada goose (Branta canadensis)
cedar waxwing (Bombycilla cedrorum)
chestnut-backed chickadee (Poecile rufescens)
cliff swallow (Petrochelidon pyrrhonota)
crow (Corvus brachyrhynchos)
dark-eyed junco (Junco hyemalis)
European starling (Sturnus vulgaris)
fox sparrow (Passerella iliaca)
golden-crowned sparrow (Zonotrichia atricapilla)
great blue heron (Ardea herodias)
hermit thrush (Catharus guttatus)
house finch (Haemorhous mexicanus)
house sparrow (Passer domesticus)
house wren (Troglodytes aedon)
kildeer (Charadrius vociferus)
lesser goldfinch (Spinus psaltria)
mallard ducks (Anas platyrhynchos)
mourning dove (Zenaida macroura)
Northern flicker (Colaptes auratus)
Northern mockingbird (Mimus polyglottos)
Nuttal's woodpecker (Picoides nuttallii)
Osprey (Pandion haliaetus)
peregrine falcon (Falco peregrinus)
purple finch (Haemorhous purpureus)
raven (Corvus corax)
red-shouldered blackbird (Agelaius phoeniceus)
red-shouldered hawk (Buteo lineatus)
red-tailed hawk (Buteo jamaicensis)
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rock wren (Salpinctes obsoletus)
ruby-crowned kinglet (Regulus calendula)
song sparrow (Melospiza melodia)
tree swallow (Tachycineta bicolor)
turkey vulture (Cathartes aura)
violet-green swallow (Tachycineta thalassina)
Western bluebird (Sialia mexicana)
Western scrub jay (Aphelocoma californica)
white-crowned sparrow (Zonotrichia leucophrys)
White-tailed kite (Elanus leucurus)
wild turkey (Meleagris gallopavo)
yellow-rumped warbler (Setophaga coronata)
unidentified gull likely Western or California
unidentified species of sparrow

MASTER OTHER ANIMALS LIST
black-tailed deer (Odocoileus hemionus)
black-tailed jackrabbit (Lepus californicus)
California vole (Microtus californicus) runways
domestic cat (Felis catus)
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PINECREST ENVIRONMENTAL CONSULTING
6425 TELEGRAPH AVE. #8
OAKLAND, CA 94609
510.881.3039 TEL
[email protected]
WWW.PINECRESTENVIRONMENTAL.ORG
1 S P E C I A L - S T A T U S P L A N T S U R V E Y R E P O R T Date: July 21, 2023
To: Jason Brandman, FCS International.

From: Dr. Christopher T. DiVittorio, Pinecrest Research Corp., Inc.

Subject: Results of special-status plant surveys at 220 Commerce Court, Napa County, CA (FCS Project 5639.0001)
To Whom It May Concern,
This rare plant survey report (Report) details the findings of three protocol-level special-status plant surveys conducted in 2023 at the above-referenced property located in the County of Napa.

The site consists of one parcel measuring 10.2 acres and assigned APN 058-030-069.

Site Description
The entirety of the site is disked and mowed ruderal grassland, with the exception of some emergent wetland along the north property line. A stand of non-native Eucalyptus spp. exists to the west but this is offsite and located on the adjacent parcel. The ruderal grassland exhibits low cover of plants and low species diversity with very few native species (Figure 1). The habitat type of this area as determined by Sawyer et al. (2009) Manual of California Vegetation 2nd Edition (MCV) is Bromus (diandrus, hordeaceous)-Brachypodium distachyon Semi-Natural Herbaceous Stand. There is also some disturbed/previously developed habitat in the southeast corner (Figure 3). The project will affect only the ruderal grassland portion of the site.

Methods
Special-status plants are defined here to include: (1) all plants that are federal- or state-listed as rare, threatened or endangered, (2) all federal and state candidates for listing, (3) all plants included in Lists 1 through 4 of the CNPS Inventory, and (4) plants that qualify under the definition of "rare" in the California Environmental Quality Act, section 15380. Background information searches were conducted prior to all site visits to identify potential rare plant species or sensitive plant communities recognized by the California Department of Fish and Wildlife (CDFW) that may occur in the Study Area vicinity.

A table of these species, and their protection status, habitat requirements, and likelihood to occur in the Study Area is provided below in Appendix A. Sources for this table include the California Department of Fish and Wildlife (CDFW) Natural Diversity Database (CDFW 2023), the California Native Plant Society (CNPS) Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPS 2023), and the knowledge of PEC staff. CNDDB searches were performed within a "9-quad" area encompassing the surrounding region. 1509
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Site visits were performed 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 site was graded thus the late-season site visit focused on remaining vegetation surrounding the areas of disturbance. Site visits were performed by PEC botanist Dr. Christopher DiVittorio, with secondary identification on voucher and photograph specimens made by PEC botanist Dr. Zoya Akulova. During each site visit, Dr. DiVittorio surveyed the entirety of the project area using methods as specified in the California Department of Fish & Wildlife (CDFW) publication titled Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities, dated March 20, 2018.

During each survey, the entirety of the "Commerce 220" site as well as the adjacent "Commerce 217" site were examined. These surveys included the entirety of both legal parcels, as well all of the vegetated areas up to the concrete paved area on the developed parcel to the south. Field 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 (2012).

Results & Recommendations
The project area is comprised of routinely disked ruderal Bromus (diandrus, hordeaceous) SemiNatural Stands with some isolated individuals of Baccharis pilularis mostly near the edges of the site. A map of habitat types is shown in Figure 3. No special-status plant species or sensitive habitats were positively identified in the project area. A full list of the species encountered during the surveys is provided below in Appendix B. In total, 15 native species were observed onsite and 57 non-native species were observed. No special-status species were found thus we have no recommendations for mitigation or avoidance for this project.

Please let me know if you have any questions about this or any other studies we've performed for this project.

Sincerely,
Christopher DiVittorio, PhD
President, PEC
(510) 881-3039
[email protected]
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Figure 1: Ruderal Grassland
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Figure 2: Eucalyptus Stands
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Figure 3: Habitat Map
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Appendix A: Special-Status Species Considered
The following is a list of sensitive and/or rare plants and habitats generated based on knowledge of the species and habitats of Napa County by PEC staff, from various State and Federal databases, and from the California Natural Diversity Database (CNDDB). Known occurrences within a "9-quad" region around the project site are shown in bold.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
PLANTS
Alkali milk-vetch
(Astragalus tener var. tener)
—/—/1B.2 Alkali grassland Very Low: No alkali habitat exists in the project area.

Anthony peak lupine
(Lupinus antoninus)
—/—/1B.2 Coniferous forest None: No coniferous forest habitat exists in the project area.

Baker's goldfields
(Lasthenia californica ssp. bakeri)
—/—/1B.2 Coastal grasslands Very Low: Some grassland habitat exists in the project area.

Baker's larkspur
(Delphinium bakeri)
FE/SE/1B.1 Coastal scrub Very Low: No coastal scrub habitat exists in the project area.

Baker's manzanita
(Arctostaphylos bakeri ssp. bakeri)
—/—/1B.1 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Baker's navarretia
(Navarretia leucocephala ssp.
bakeri)
—/—/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Beaked tracyina
(Tracyina rostrata)
—/—/1B.2 Grassland, foothill
woodland
Low: Some grassland habitat exists in
the project area.

Bent flowered fiddleneck
(Amsinckia lunaris)
—/—/1B.2 Grassland, foothill
woodland
Low: Some grassland habitat exists in
the project area.

Big-scale balsamroot
(Balsamorhiza macrolepis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Big tarplant
(Blepharizonia plumosa)
—/—/1B.1 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Blasdale's bent grass
(Agrostis blasdalei)
—/—/1B.2 Coastal grassland Very Low: Some grassland habitat exists in the project area.

Blue coast gilia
(Gilia capitata ssp. chamissonis)
—/—/1B.1 Coastal sand dunes None: No sand dune habitat exists in the project area.
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Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Bluff wallflower
(Erysimum concinnum)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Bogg's Lake hedge-hyssop
(Gratiola heterosepala)
—/—/1B.2 Vernal pool, pond None: No vernal pool habitat exists in the project area.

Bolander's horkelia
(Horkelia bolanderi)
—/—/1B.2 Coniferous forest,
grassland
Low: Some grassland exists in the
project area.

Bolander's water hemlock
(Cicuta maculata var. bolanderi)
—/—/2B.1 Salt marsh None: No salt marsh habitat exists in the project area.

Brandegee's eriastrum
(Eriastrum brandegeeae)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Brewer's calandrinia
(Calandrinia breweri)
—/—/4.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Brewer's western flax
(Hesperolinon breweri)
—/—/1B.2 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Bristly leptosiphon
(Leptosiphon aureus)
—/—/4.2 Chaparral None: No chaparral habitat exists in
the project area.

Bristly sedge
(Carex comosa)
—/—/2B.1 Wetland, riparian None: No potential wetland habitat exists in the project area.

Brownish beaked-rush
(Rhynchospora capitellata)
—/—/2B.2 Wetland, riparian None: No potential wetland habitat exists in the project area.

Burke's goldfields
(Lasthenia burkei)
FE/SE/1B.1 Vernal pools,
grassland
Low: Some grassland habitat exists in
the project area.

California alkali grass
(Puccinellia simplex)
—/—/1B.2 Alkali grassland Very Low: No alkali grassland habitat exists in the project area.

California beaked-rush
(Rhynchospora californica)
—/—/1B.1 Freshwater wetlands None: No potential wetland habitat exists in the project area.

California satintail
(Imperata brevifolia)
—/—/2B.1 Chaparral, coastal
scrub
None: No chaparral habitat exists in the
project area.

California sedge
(Carex californica)
—/—/2B.3 Wetlands None: No wetland habitat exists in the project area.

Calistoga ceanothus
(Ceanothus divergens)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.
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Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Calistoga popcornflower
(Plagiobothrys strictus)
FE/ST/1B.1 Wetland, riparian None: No wetland habitat exists in the project area.

Carquinez goldenbrush
(Isocoma arguta)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Chaparral ragwort
(Senecio aphanactis)
—/—/1B.1 Coastal scrub,
woodland
None: No coastal scrub habitat exists
in the project area.

Clara Hunt's milk vetch
(Astragalus claranus)
—/—/1B.1 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Coast iris
(Iris longipetala)
—/—/4.2 Coastal grassland,
wetland
Low: Some grassland habitat exists in
the project area.

Coast lily
(Lilium maritimum)
—/—/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Coastal bluff morning glory
(Calystegia purpurata ssp. saxicola)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Cobb Mountain lupine
(Lupinus sericatus)
—/—/1B.2 Chaparral,
coniferous forest
None: No chaparral habitat exists in
the project area.

Colusa layia
(Layia septentrionalis)
—/—/1B.2 Chaparral, valley
grassland
Low: Some grassland habitat exists in
the project area.

Congdon's tarplant
(Centromadia parryi ssp. congdonii)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Congested-headed hayfield tarplant
(Hemizonia congesta ssp.
congesta)
—/—/1B.2 Grassland, coastal
scrub
Low: Some grassland habitat exists in
the project area.

Contra Costa goldfields
(Lasthenia conjugens)
FE/—/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Crystal Springs lessingia
(Lessingia arachnoidea)
—/—/1B.2 Serpentine grassland None: No serpentine grassland habitat exists in the project area.

Cunningham Marsh cinquefoil
(Potentilla uliginosa)
—/—/1A Wetland None: No wetland habitat exists in the
project area.

Dark-eyed gilia
(Gilia millefoliata)
—/—/1B.2 Coastal sand dunes None: No coastal sand dune habitat exists in the project area.

Dark-mouthed triteleia
(Triteleia lugens)
—/—/4.3 Grassland, chaparral Low: Some grassland habitat exists in the project area.
1516
9 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Deceiving sedge
(Carex saliniformis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Deep-scarred cryptantha
(Cryptantha excavata)
—/—/1B.2 Woodland None: No woodland habitat exists in the project area.

Delta tule pea
(Lathyrus jepsonii var. jepsonii)
—/—/1B.2 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.

Diablo helianthella
(Helianthella castanea)
—/—/1B.2 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Dimorphic snapdragon
(Antirrhinum subcordatum)
—/—/4.3 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Dwarf downingia
(Downingia pusilla)
—/—/2B.2 Vernal pool, wetland None: No vernal pool habitat exists in the project area.

Dwarf soaproot
(Chlorogalum pomeridianum var. minus)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Eel-grass pondweed
(Potamogeton zosteriformis)
—/—/2B.2 Wetland, pond None: No wetland habitat exists in the project area.

Fragrant fritillary
(Fritillaria liliacea)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Few-flowered navarretia
(Navarretia leucocephala ssp. pauciflora)
FE/SE/1B.1 Vernal pool, wetland None: No vernal pool habitat exists in the project area.

Franciscan onion
(Allium peninsulare var. franciscanum)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Geysers panicum
(Panicum acuminatum var. thermale)
—/—/1B.2 Chaparral, wetland None: No chaparral habitat exists in the project area.

Glandular western flax
(Hesperolinon adenophyllum)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Golden larkspur
(Delphinium luteum)
FE/SR/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Grassleaf water plantain
(Alisma gramineum)
—/—/2B.2 Wetland, pond None: No wetland habitat exists in the project area.

Green monardella
(Monardella viridis)
—/—/4.3 Chaparral None: No chaparral habitat exists in
the project area.
1517
10 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Greene's narrow-leaved daisy
(Erigeron greenei)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral habitat exists in the project area.

Hall's harmonia
(Harmonia hallii)
—/—/1B.2 Serpentine chaparral None: No chaparral habitat exists in the project area.

Henderson's bent grass
(Agrostis hendersonii)
—/—/3.2 Vernal pool None: No vernal pool habitat exists in the project area.

Hoffman's bristly jewelflower
(Streptanthus glandulosus spp. hoffmanii)
—/—/1B.3 Chaparral, woodland None: No chaparral habitat exists in the project area.

Holly-leaved ceanothus
(Ceanothus purpureus)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Hospital Canyon larkspur
(Delphinium californicum ssp. interius)
—/—/1B.2 Woodland None: No woodland habitat exists in the project area.

Humboldt County milk vetch
(Astragalus agnicidus)
—/—/1B.1 Coniferous forest None: No coniferous forest habitat exists in the project area.

Jepson's coyote thistle
(Eryngium jepsonii)
—/—/4.2 Wetland, vernal pool None: No wetland habitat exists in the project area.

Jepson's leptosiphon
(Leptosiphon jepsonii)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Jepson's milk-vetch
(Astragalus rattanii var. jepsonianus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Johnny-nip
(Castilleja ambigua var. ambigua)
—/—/4.2 Wetland, riparian None: No wetland habitat exists in the project area.

Kenwood Marsh checkerbloom
(Sidalcea oregana ssp. valida)
FE/SE/1B.1 Wetland None: No wetland habitat exists in the project area.

Konocti manzanita
(Arctostaphylos manzanita ssp. elegans)
—/—/1B.3 Chaparral, woodland None: No chaparral habitat exists in the project area.

Lake County stonecrop
(Sedella leiocarpa)
—/—/1B.1 Wetland None: No wetland habitat exists in the project area.

Legenere
(Legenere limosa)
—/—/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Loch Lomond button-celery
(Eryngium constancei)
FE/SE/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.
1518
11 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Lobb's aquatic buttercup
(Ranunculus lobbii)
—/—/4.2 Vernal pool None: No vernal pool habitat exists in the project area.

Long-styled sand-spurrey
(Spergularia macrotheca var. longistyla)
—/—/1B.2 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Lyngbye's sedge
(Carex lyngbyei)
—/—/2B.2 Salt marsh None: No salt marsh habitat exists in the project area.

Many-flowered navarretia
(Navarretia leucocephala spp. plieantha)
FE/SE/1B.2 Vernal pool None: No wetland habitat exists in the project area.

Maple-leaved checkerbloom
(Sidalcea malachroides)
—/—/4.2 Coastal grassland,
coniferous forest
Very Low: No coastal grassland habitat
exists in the project area.

Marin checker lily
(Fritillaria lanceolata var. tristulis)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Marin checkerbloom
(Sidalcea hickmanii spp. viridis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Marin County navarretia
(Navarretia rosulata)
—/—/1B.2 Serpentine forest None: No serpentine habitat exists in the project area.

Marin knotweed
(Polygonum marinense)
—/—/3.1 Coastal salt marsh None: No coastal salt marsh habitat exists in the project area.

Marin manzanita
(Arctostaphylos virgata)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Marin western flax
(Hesperolinon congestum)
FT/ST/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Marsh checkerbloom
(Sidalcea oregana ssp. hydrophila)
—/—/1B.2 Wetland, riparian None: No wetland habitat exists in the project area.

Marsh microseris
(Microseris paludosa)
—/—/1B.2 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Marsh pea
(Lathyrus palustris)
—/—/2B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Mason's ceanothus
(Ceanothus masonii)
—/SR/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Mason's lilaeopsis
(Lilaeopsis masonii)
—/SR/1B.1 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.
1519
12 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Milo Baker's lupine
(Lupinus milo-bakeri)
—/—/1B.1 Woodland, grassland None: No woodland habitat exists in the project area.

Modest rockcress
(Arabis modesta)
—/—/4.3 Chaparral, forest None: No chaparral habitat exists in the project area.

Morrison's jewelflower
(Streptanthus morrisonii ssp. morrisonii)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Mt. Diablo fairy-lantern
(Calochortus pulchellus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Mt. St. Helena morning glory
(Calystegia collina ssp. oxyphylla)
—/—/4.2 Serpentine chaparral None: No serpentine habitat exists in the project area.

Mt. Tamalpais bristly jewelflower
(Streptanthus glandulosus spp. pulchellus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Mt. Tamalpais manzanita
(Arctostaphylos montana spp. montana)
—/—/1B.3 Chaparral None: No chaparral habitat exists in the project area.

Mt. Tamalpais thistle
(Cirsium hydrophilum var. vaseyi)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Napa bluecurls
(Trichostema ruygtii)
—/—/1B.2 Grassland Medium: Some grassland habitat
exists in the project area.

Napa blue grass
(Poa napensis)
FE/SE/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Napa checkerbloom
(Sidalcea hickmanii ssp. napensis)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Napa false indigo
(Amorpha californica var. napensis)
—/—/1B.2 Forest, woodland None: No woodland habitat exists in the project area.

Napa lomatium
(Lomatium repostum)
—/—/1B.2 Woodland, chaparral None: No woodland habitat exists in the project area.

Narrow-anthered brodiaea
(Brodiaea leptandra)
—/—/1B.2 Woodland, grassland Very Low: Some grassland habitat exists in the project area.

Nodding harmonia
(Harmonia nutans)
—/—/4.3 Woodland, chaparral None: No chaparral habitat exists in the project area.

North Coast semaphore grass
(Pleuropogon hooverianus)
—/—/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.
1520
13 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Nuttall's ribbon-leaved pondweed
(Potamogeton epihydrus)
—/—/2B.2 Pond None: No pond habitat exists in the
project area.

Oval-leaved viburnum
(Viburnum ellipticum)
—/—/2B.3 Chaparral None: No chaparral habitat exists in the project area.

Pacific gilia
(Gilia capitata ssp. pacifica)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Pacific Grove clover
(Trifolium polyodon)
—/—/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

Pappose tarplant
(Centromadia parryi ssp. parryi)
—/—/1B.2 Grassland, wetland Low: Some grassland habitat exists in the project area.

Parry's rough tarplant
(Centromadia parryi ssp. rudisi)
—/—/4.2 Grassland Low: Some grassland habitat exists in the project area.

Pennell's bird's beak
(Cordylanthus tenuis ssp. capillaris)
FE/SR/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Perennial goldfields
(Lasthenia californica ssp. macrantha)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Peruvian dodder
(Cuscuta obtusiflora var.
glandulosa)
—/—/1B.2 Parasitic plant,
grassland, chaparral
Low: Some grassland habitat exists in
the project area.

Petaluma popcornflower
(Plagiobothrys mollis var. vestitus)
—/—/1A Coastal salt marsh None: No coastal salt marsh habitat exists in the project area.

Pink sand verbena
(Abronia umbellata var. breviflora)
—/—/1B.1 Coastal sand dune None: No sand dune habitat exists in the project area.

Pitkin Marsh lily
(Lilium pardalinum ssp.
pitkinense)
FE/SE/1B.1 Wetland None: No wetland habitat exists in the project area.

Pitkin Marsh paintbrush
(Castilleja uliginosa)
FE/SE/1A Wetland None: No wetland habitat exists in the project area.

Point Reyes checkerbloom
(Sidalcea calycosa ssp. rhizomata)
—/—/1B.2 Coastal salt marsh None: No salt marsh habiat exists in the project area.

Point Reyes salty bird's beak
(Chloropyron maritimum ssp. palustre)
—/—/1B.2 Coastal salt marsh None: No salt marsh habitat exists in the project area.
1521
14 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Purple-stemmed checkerbloom
(Sidalcea malviflora spp. purpurea)
—/—/1B.2 Wetland None: No wetland habitat exists in the project area.

Pygmy cypress
(Hesperocyparis pygmaea)
—/—/1B.2 Hardpan soil None: No hardpan forest habitat exists in the project area.

Raiche's manzanita
(Arctostaphylos stanfordiana ssp. raichei)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Raiche's red ribbons
(Clarkia concinna spp. raichei)
—/—/1B.1 Coastal scrub None: No coastal scrub habitat exists in the project area.

Redwood lily
(Lilium rubescens)
—/—/4.2 Chaparral, forest None: No chaparral habitat exists in the project area.

Rincon Ridge ceanothus
(Ceanothus confusus)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Rincon Ridge manzanita
(Arctostaphylos stanfordiana
ssp. decumbens)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Rose leptosiphon
(Leptosiphon rosaceus)
—/—/1B.1 Coastal scrub None: No coastal scrub habitat exists in the project area.

Round-headed beaked rush
(Rhynchospora globularis)
—/—/2B.1 Wetland, riparian None: No wetland habitat exists in the project area.

Round-headed Chinese houses
(Collinsia corymbosa)
—/—/1B.2 Coastal grassland None: No coastal grassland habitat exists in the project area.

Round-leaved filaree
(California macrophylla)
—/—/1B.2 Foothill grassland Low: Some grassland habitat exists in the project area.

Saline clover
(Trifolium hydrophilum)
—/—/1B.2 Wetland, riparian None: No potential wetland habitat exists in the project area.

San Antonio Hills monardella
(Monardella antonina ssp. antonina)
—/—/3.0 Chaparral None: No chaparral habitat exists in
the project area.

San Francisco spineflower
(Chorizanthe cuspidata var. cuspidata)
—/—/1B.2 Coastal sand dunes None: No coastal sand dune habitat exists in the project area.

San Joaquin spearscale
(Extriplex joaquinana)
—/—/1B.2 Alkali scrub,
grassland
Very Low: Some grassland habitat
exists in the project area.

Santa Cruz clover
(Trifolium buckwestiorum)
—/—/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.
1522
15 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Santa Cruz microseris
(Stebbinsoseris decipiens)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Santa Cruz tarplant
(Holocarpha macradenia)
FT/SE/1B.1 Coastal grassland None: No coastal grassland habitat exists in the project area.

Santa Rosa horkelia
(Horkelia tenuiloba)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Seaside bittercress
(Cardamine angulata)
—/—/2B.2 Forest, riparian None: No forest habitat exists in the project area.

Sebastopol meadowfoam
(Limnanthes vinculans)
FE/SE/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.

Serpentine cryptantha
(Cryptantha dissita)
—/—/1B.2 Serpentine chaparral None: No chaparral habitat exists in the project area.

Serpentine daisy
(Erigeron serpentinus)
—/—/1B.3 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Short-leaved evax
(Hesperevax sparsiflora var. brevifolia)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Slender Orcutt grass
(Orcuttia tenuis)
FT/SE/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Small-flowered calycadenia
(Calycadenia micrantha)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Small groundcone
(Kopsiopsis hookeri)
—/—/2B.3 Redwood forest None: No redwood forest habitat exists in the project area.

Small spikerush
(Eleocharis parvula)
—/—/3.0 Woodland, chaparral None: No chaparral habitat exists in the project area.

Soft salty bird's beak
(Chloropyron molle ssp. molle)
FE/ST/1B.2 Coastal salt marsh None: No salt marsh habitat exists in the project area.

Sonoma alopecurus
(Alopecurus aequalis var.
sonomensis)
FE/—/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.

Sonoma beardtongue
(Penstemon newberryi var. sonomensis)
—/—/1B.3 Chaparral None: No chaparral habitat exists in the project area.

Sonoma ceanothus
(Ceanothus sonomensis)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.
1523
16 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Sonoma spineflower
(Chorizanthe valida)
FE/SE/1B.1 Coastal grassland Very Low: Some grassland habitat exists in the project area.

Sonoma sunshine
(Blennosperma bakeri)
FE/SE/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

St. Helena fawn lily
(Erythronium helenae)
—/—/4.2 Grassland, chaparral Very Low: Some grassland habitat exists in the project area.

Streamside daisy
(Erigeron biolettii)
—/—/4.2 Grassland, chaparral Very Low: Some grassland habitat exists in the project area.

Suisun marsh aster
(Symphyotrichum lentum)
—/—/1B.2 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.

Supple daisy
(Erigeron supplex)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Swamp harebell
(Campanula californica)
—/—/1B.2 Coastal grassland,
wetland
Very Low: Some grassland habitat exists
in the project area.

Tamalpais jewelflower
(Streptanthus batrachopus)
—/—/1B.3 Serpentine None: No serpentine habitat exists in the project area.

Tamalpais lessingia
(Lessingia micradenia var. micradenia)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Tamalpais oak
(Quercus parvula var. tamalpaisensis)
—/—/1B.3 Woodland None: No woodland habitat exists in the project area.

The Cedars fairy lantern
(Calochortus raichei)
—/—/1B.2 Hardpan chaparral None: No chaparral habitat exists in the project area.

The Cedars manzanita
(Arctostaphylos bakeri ssp. sublaevis)
—/—/1B.2 Hardpan chaparral None: No chaparral habitat exists in the project area.

Thin-lobed horkelia
(Horkelia tenuiloba)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Thurber's reed grass
(Calamagrostis crassiglumis)
—/—/2B.1 Coastal scrub, wetland None: No wetland habitat exists in the project area.

Tiburon buckwheat
(Eriogonum luteolum var. caninum)
—/—/1B.2 Serpentine grassland Very Low: No serpentine grassland exists in the project area.

Tiburon paintbrush
(Castilleja affinis var. neglecta)
FE/ST/1B.2 Serpentine grassland Very Low: No serpentine grassland exists in the project area.
1524
17 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Tracy's clarkia
(Clarkia gracilis ssp. tracyi)
—/—/4.2 Serpentine chaparral None: No serpentine grassland exists in the project area.

Two-carpellate western flax
(Hesperolinon bicarpellatum)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Twig-like snapdragon
(Antirrhinum virga)
—/—/1B.1 Serpentine chaparral None: No serpentine habitat exists in the project area.

Two-carpellate western flax
(Hesperolinon bicarpellatum)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Two-fork clover
(Trifolium amoenum)
FE/—/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

Vine Hill ceanothus
(Ceanothus foliosus var.
vineatus)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Vine Hill clarkia
(Clarkia imbricata)
FE/SE/1B.1 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Vine Hill manzanita
(Arctostaphylos densiflora)
—/SE/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Watershield
(Brasenia schreberi)
—/—/2B.3 Pond None: No pond habitat exists in the
project area.

Western leatherwood
(Dirca occidentalis)
—/—/1B.2 Woodland, chaparral None: No woodland habitat exists in the project area.

White-beaked rush
(Rhynchospora alba)
—/—/2B.2 Wetland, riparian None: No wetland habitat exists in the project area.

White-flowered rein orchid
(Piperia candida)
—/—/1B.2 Coniferous forest None: No coniferous forest habitat exists in the project area.

White-rayed pentachaeta
(Pentachaeta bellidiflora)
FE/SE/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Wolly-headed gilia
(Gilia capitata ssp. tomentosa)
—/—/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Wolly-headed lessingia
(Lessingia hololeuca)
—/—/3.0 Forest, grassland Very Low: Some grassland habitat exists in the project area.

Wolly meadowfoam
(Limnanthes floccosa ssp. floccosa)
—/—/4.2 Vernal pool None: No wetland habitat exists in the project area.
1525
18 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Wolly spineflower
(Chorizanthe cuspidata var. villosa)
—/—/1B.2 Coastal sand dunes None: No sand dune habitat exists in the project area.

MOSSES, LICHENS & LIVERWORTS
Angel's hair lichen
(Ramalina thrausta)
—/—/2B.1 Forest, woodland None: No forest habitat exists in the project area.

Coastal triquetrella
(Triquetrella californica)
—/—/1B.2 Forest, woodland None: No forest habitat exists in the project area.

Elongate copper moss
(Mielichhoferia elongata)
—/—/4.3 Rock outcrops None: No rock outcrop habitat exists in the project area.

Koch's cord moss
(Entosthodon kochii)
—/—/1B.3 Forest, woodland None: No forest habitat exists in the project area.

Methuselah's beard lichen
(Dolichousnea longissima)
—/—/4.2 Forest, woodland None: No forest habitat exists in the project area.

Slender silver moss
(Anomobryum julaceum)
—/—/4.2 Rocky substrates in
forests
None: No forest habitat exists in the
project area.

Torren's grimmia
(Grimmia torenii)
—/—/1B.3 Forest, woodland None: No forest habitat exists in the project area.

HABITATS
Coastal & Valley Freshwater Marsh
(CVFM)
— — None: No marsh habitat exists in the
project area.

Coastal Brackish Marsh
(CVFM)
— — None: No brackish marshes exist in
the project area.

Northern Coastal Salt Marsh
(NCSM)
— — None: No salt marsh habitat exists in
the project area.

Northern Hardpan Vernal Pool
(NHVP)
— — None: No hardpan vernal pool habitat
exists in the project area.

Northern Vernal Pool
(NVP)
— — None: No vernal pool habitat exists in
the project area.

Serpentine Bunchgrass
(SBG)
— — None: No serpentine bunchgrass
habitat exists in the project area.
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19 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Sycamore Alluvial Woodland
(SAW)
— — None: No woodland habitat exists in the
project area.

Valley Needlegrass Grassland
(VNG)
— — Low: Some grassland habitat exists in
the project area.

Valley Oak Woodland
(VOW)
— — None: No valley oaks exist in the project
area.

Valley Sink Scrub
(VSS)
— — None: No sink scrub habitat exists in the
project area.
1 Status:

Federal
FE = Federally Endangered Species
FT = Federally Threatened Species
State
SE = State Endangered Species
ST = State Threatened Species
SSC = California Species of Special Concern
CFP = California Fully Protected Species
CNPS (applies to plants only)
List 1B = plants considered rare, threatened, or endangered in California and elsewhere List 2B = plants rare, threatened or endangered in California, but more common elsewhere List 3 = plant is likely rare but more information is required List 4 = plants of limited distribution
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20 PINECREST ENVIRONMENTAL CONSULTING, INC.

Appendix B: Plant Species Observed Onsite
The following is a list of plant species generated based on knowledge of the species and habitats of Napa County by PEC staff, and from various State and Federal databases, as described in the Methods section, above. Special-status species, if any, are denoted with an asterisk (*).

Non-Native Plant Species:
bird's foot trefoil (Lotus corniculatus)
bishop's weed (Ammi majus)
black mustard (Brassica nigra)
bluegum (Eucalyptus globulus)
bristly ox-tongue (Helminthotheca echioides)
bull thistle (Cirsium vulgare)
bur clover (Medicago polymorpha)
cheeseweed (Malva parviflora)
chicory (Cichorium intybus)
common dandelion (Taraxacum officinale)
common groundsel (Senecio vulgaris)
crane's bill filaree (Erodium botrys)
curly dock (Rumex crispus)
false brome (Brachypodium distachyon)
fennel (Foeniculum vulgare)
field bindweed (Convolvulus arvensis)
field marigold (Calendula arvensis)
foxtail barley (Hordeum murinum)
Fuller's teasel (Dipsacus fullonum)
hairgrass (Aira caryophyllea)
hairy vetch (Vicia villosa)
Harding grass (Phalaris aquatica)
hedge parsley (Torilis arvensis)
Himalayan blackberry (Rubus armeniacus)
Italian ryegrass (Festuca perennis)
Italian thistle (Circium pycnocephalus)
Jersey cudweed (Pseudognaphalium luteoalbum)
narrowleaf cottonrose (Logfia gallica)
New Zealand flax (Phormium colensoi)
pennyroyal (Mentha pulegium)
pineapple weed (Matricaria discoidea)
poison hemlock (Conium maculatum)
prickly lettuce (Lactuca serriola)
purple star thistle (Centaurea calcitrapa)
red brome (Bromus madritensis)
reed fescue (Festuca arundinacea)
ribwort (Plantago lanceolata)
ripgut brome (Bromus diandrus)
rose clover (Trifolium hirtum)
scarlet pimpernel (Lysimachia arvensis)
seaside barley (Hordeum marinum)
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21 PINECREST ENVIRONMENTAL CONSULTING, INC.
sheep sorrel (Rumex acetocella)
shortpod mustard (Hirschfeldia incana)
shrubby germander (Teucrium fruticans)
smooth cat’s ear (Hypochaeris glabra)
soft chess (Bromus hordeaceous)
spring vetch (Vicia sativa)
sweet pea (Lathyrus latifolius)
tall flatsedge (Cyperus eragrostis)
weedy brome (Bromus caroli-henrici)
wild geranium (Geranium dissectum)
wild lettuce (Lactuca saligna)
wild oatgrass (Avena barbata)
wild radish (Raphanus sativa)
woolly grevillea (Grevillea lanigera)
yellow star thistle (Centaurea solstitialis)
Zorro fescue (Festuca myuros)
Native Plant Species:
blue-eyed grass (Sisyrinchium bellum)
bog rush (Juncus patens)
California poppy (Eschscholzia californica)
common madia (Madia elegans)
common yarrow (Achillea millefolium)
coyote brush (Baccharis pilularis)
hairy gumweed (Grindelia hirsutula)
ladies’ tobacco (Pseudognaphalium californicum)
meadow barley (Hordeum brachyantherum)
mountain dandelion (Agoseris heterophylla)
narrow-leaved miner's lettuce (Claytonia parviflora)
poison oak (Toxicodendron diversilobum)
saltgrass (Distichlis spicata)
slender tarweed (Madia gracilis)
toyon (Heteromeles arbutifolia)
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment
FirstCarbon Solutions
Appendix E:

Plant and Wildlife List
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SDG Commerce 220, LLC–220 Distribution Center Project
Biological Resources Assessment Appendix E
FirstCarbon Solutions

WILDLIFE AND PLANT SPECIES LIST
Table 1: Wildlife Species List
Wildlife Species
Scientific Name Common Name
Agelaius phoeniceus red-shouldered blackbird
Anas platyrhynchos mallard ducks
Anthus rubescens American pipit
Aphelocoma californica western scrub jay
Ardea herodias great blue heron
Bombycilla cedrorum cedar waxwing
Branta canadensis Canada goose
Buteo lineatus red-shouldered hawk
Calypte anna Anna's hummingbird
Cathartes aura turkey vulture
Catharus guttatus hermit thrush
Colaptes auratus northern flicker
Corvus brachyrhynchos crow
Corvus corax raven
Elanus leucurus white-tailed kite
Felis catus domestic cat
Fulica americana American coot
Haemorhous mexicanus house finch
Haemorhous purpureus purple finch
Junco hyemalis dark-eyed junco
Larus californicus California gull
Lepus californicus black-tailed jackrabbit
Meleagris gallopavo wild turkey
Melospiza melodia song sparrow
Melozone crissalis California towhee
Microtus californicus California vole
Molothrus ater brown-headed cowbird
Odocoileus hemionus mule deer
Passerella iliaca fox sparrow
Pelecanus erythrorhynchos American pelican
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Biological Resources Assessment Appendix E
FirstCarbon Solutions
Wildlife Species
Scientific Name Common Name
Petrochelidon pyrrhonota cliff swallow
Picoides nuttallii Nuttal's woodpecker
Poecile rufescens chestnut-backed chickadee
Regulus calendula ruby-crowned kinglet
Salpinctes obsoletus rock wren
Sayornis nigricans black phoebe
Setophaga coronata yellow-rumped warbler
Sialia mexicana western bluebird
Spinus psaltria lesser goldfinch
Spinus tristis American goldfinch
Sturnus vulgaris European starling
Tachycineta bicolor tree swallow
Thryomanes bewickii Bewick's wren
Troglodytes aedon house wren
Turdus migratorius American robin
Zenaida macroura mourning dove
Zonotrichia atricapilla golden-crowned sparrow
Zonotrichia leucophrys white-crowned sparrow
Table 2: Plant Species List
Plant Species
Scientific Name Common Name
Achillea millefolium common yarrow
Agoseris heterophylla mountain dandelion
Aira caryophyllea hairgrass
Ammi majus bishop's weed
Avena barbata wild oatgrass
Baccharis pilularis coyote brush
Brachypodium distachyon false brome
Brassica nigra black mustard
Bromus caroli-henrici weedy brome
Bromus diandrus ripgut brome
Bromus hordeaceous soft chess
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Biological Resources Assessment Appendix E
FirstCarbon Solutions
Plant Species
Scientific Name Common Name
Bromus madritensis red brome
Calendula arvensis field marigold
Centaurea calcitrapa purple star thistle
Centaurea solstitialis yellow star thistle
Cichorium intybus chicory
Circium pycnocephalus Italian thistle
Cirsium sp. upland thistle
Cirsium vulgare bull thistle
Claytonia parviflora narrow-leaved miner's lettuce
Conium maculatum poison hemlock
Convolvulus arvensis field bindweed
Cyperus eragrostis tall flatsedge
Diatoms sp. algal mats
Dipsacus fullonum Fuller's teasel
Distichlis spicata saltgrass
Erodium botrys crane's bill filaree
Erodium cicutarium coastal heron’s bill
Eschscholzia californica California poppy
Eucalyptus globulus) bluegum
Festuca arundinacea reed fescue
Festuca myuros Zorro fescue
Festuca perennis Italian ryegrass
Foeniculum vulgare fennel
Geranium dissectum wild geranium
Grevillea lanigera woolly grevillea
Grindelia hirsutula hairy gumweed
Helminthotheca echioides bristly ox-tongue
Heteromeles arbutifolia toyon
Hirschfeldia incana shortpod mustard
Hordeum brachyantherum meadow barley
Hordeum marinum seaside barley
Hordeum murinum foxtail barley
Hypochaeris glabra smooth cat’s ear
Juncus patens bog rush
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Biological Resources Assessment Appendix E
FirstCarbon Solutions
Plant Species
Scientific Name Common Name
Lactuca saligna wild lettuce
Lactuca serriola prickly lettuce
Lathyrus latifolius sweet pea
Logfia gallica narrowleaf cottonrose
Lotus corniculatus bird's foot trefoil
Lysimachia arvensis scarlet pimpernel
Madia elegans common madia
Madia gracilis slender tarweed
Malva parviflora cheeseweed
Matricaria discoidea pineapple weed
Medicago polymorpha bur clover
Mentha pulegium pennyroyal
Phalaris aquatica harding grass
Phormium colensoi New Zealand flax
Plantago lanceolata ribwort
Pseudognaphalium californicum ladies’ tobacco
Pseudognaphalium luteoalbum Jersey cudweed
Raphanus sativa wild radish
Rubus armeniacus Himalayan blackberry
Rumex acetocella sheep sorrel
Rumex crispus curly dock
Rumex sp. docks
Senecio vulgaris common groundsel
Sisyrinchium bellum blue-eyed grass
Taraxacum officinale common dandelion
Teucrium fruticans shrubby germander
Torilis arvensis hedge parsley
Toxicodendron diversilobum poison oak
Trifolium hirtum rose clover
Vicia sativa spring vetch
Vicia villosa hairy vetch
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FirstCarbon Solutions
C.2 - Commerce 217 Documents
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UNITED STATES
T +1 888 826 5814
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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. 1539
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. 1540
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. 1541
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
1542
Attachment A
Attachment A:

Animal Species Observed
1543
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), 1544
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 1545
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) 1546

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 1547
Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site SDG Commerce 217 Distribution Center, Napa, California
APN: 058-030-065-000

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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 1548
SDG COMMERCE 217 DISTRIBUTION CENTER

BORROW SITE ROUGH GRADING

AMERICAN CANYON CALIFORNIA
1 1

PRELIMINARY - NOT FOR CONSTRUCTION

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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 1552
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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 1553
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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. 1554
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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).

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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); 1558
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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. 1560
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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 1561
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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. 1562
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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 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 (James 1992).

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. 1564
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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. 1565
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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 1566
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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 1567
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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), 1568
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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 1569
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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 1570
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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. 1571
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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. 1572
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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. 1573
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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 1575
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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 1576
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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 1577
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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. 1578
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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. 1579
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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 1581
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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 1582
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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 1583
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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 1585
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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. 1586
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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. 1587
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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 1588
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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. 1589
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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. 1590
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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.

Journal of Herpetology. Vol. 31, No. 2, Pages 276-286, 2007. Copyright 2007 Society for the Study of Amphibian and Reptiles.

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 1591
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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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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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Table 2
Wildlife Observed on the ICC SDG 217 Commerce Distribution Center Project Site Monk & Associates
California towhee Pipilo crissalis
Savannah sparrow Passerculus sandwichensis
Song sparrow Melospiza melodia
White-crowned sparrow Zonotrichia leucophrys
Dark-eyed junco Junco hyemalis
Red-winged blackbird Agelaius phoeniceus
Brewer's blackbird Euphagus cyanocephalus
Brown-headed cowbird Molothrus ater
Bullock's oriole Icterus bullockii
House finch Haemorhous mexicanus
Lesser goldfinch Spinus psaltria
House sparrow Passer domesticus
Mammals
Western gray squirrel Sciurus griseus
Black-tailed jackrabbit Lepus californicus
California ground squirrel Otospermophilus beecheyi
Columbian black-tailed deer Odocoileus hemionus ssp. columbianus Coyote Canis latrans
Raccoon Procyon lotor
Feral cat Felis catus

1601
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
Asteraceae
Balsamorhiza macrolepis Fed: -
State: -
CNPS: Rank 1B.2
Cismontane woodland;
chaparral; valley and foothill
grassland; [sometimes
serpentinite]. 90 - 1555
meters
None. The project site is highly
disturbed. No suitable habitat on
the project site. Big-scale balsam-root
March-June Closest record is from 2011 and is

3.0 miles east of the project site
(Occurrence No. 7).

Symphyotrichum lentum Fed: -
State: -
CNPS: Rank 1B.2
Marshes and swamps
(brackish and fresh water)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Suisun Marsh aster
August-November Closest record is from 1993 and is

2.5 miles northwest of the project
site (Occurrence No. 128).

Chenopodiaceae
Extriplex joaquinana Fed: -
State: -
CNPS: Rank 1B.2
Chenopod scrub; meadows;
valley and foothill grassland;
[alkaline].

None. The project site is highly
disturbed. No suitable habitat on
the project site. San Joaquin spearscale
April-October Closest record is from and is 1.8
miles south of the project site
(Occurrence No. 58).

Cyperaceae
Carex lyngbyei Fed: -
State: -
CNPS: Rank 2
Marshes or swamps
(brackish or freshwater)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Lyngbye's sedge
May-August Closest record is from 2008 and is

2.3 miles northwest of the project
site (Occurrence No. 28).

Fabaceae
Astragalus tener tener Fed: -
State: -
CNPS: Rank 1B.2
Playas; mesic grasslands
(adobe clay), vernal pools
(alkaline).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Alkali milkvetch
March-June Closest record is from 1993 and is

1.8 miles south of the project site
(Occurrence No. 50).

1602
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
Lathyrus jepsonii jepsonii Fed: -
State: -
CNPS: Rank 1B.2
Marshes and swamps
(freshwater and brackish).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Delta tule pea
May-September Closest record is from 1978 and is

2.6 miles northwest of the project
site (Occurrence No. 13).

Trifolium amoenum Fed: FE
State: -
CNPS: Rank 1B.1
Valley and foothill grassland
(sometimes serpentinite)
None. The project site is highly
disturbed. No suitable habitat on
the project site. Showy Indian clover
April-June Closest record is from 1952 and is

1.2 miles east of the project site
(Occurrence No. 23).

Orobanchaceae
Castilleja affinis neglecta Fed: FE
State: CT
CNPS: Rank 1B.2
Valley and foothill grassland
[serpentinite]
None. The project site is highly
disturbed. No suitable habitat on
the project site. Tiburon paintbrush
April-June Closest record is from 2013 and is

3.0 miles east of the project site
(Occurrence No. 5).

Chloropyron molle molle Fed: FE
State: CR
CNPS: Rank 1B.2
Marshes and swamps
(coastal salt).

None. The project site is highly
disturbed. No suitable habitat on
the project site. Soft bird's-beak
July-September Closest record is from 2010 and is

2.3 miles north of the project site
(Occurrence No. 3).

1603
Habitat Probability on Project Site
Family
Taxon
Common Name Status* Flowering Period
Table 3
Special-Status Plant Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site monk & Associates
Area Locations
*Status
Federal:

FE - Federal Endangered
FT - Federal Threatened
FPE - Federal Proposed Endangered
FPT - Federal Proposed Threatened
FC - Federal Candidate
State:

CE - California Endangered
CT - California Threatened
CR - California Rare
CC - California Candidate
CSC - California Species of Special Concern
CNPS Continued:

Rank 2 - Plants rare, threatened, or endangered in California, but more common elsewhere
Rank 2A - Extirpated in California, common elsewhere
Rank 2B.1 - Seriously endangered in California, but more common elsewhere Rank 2B.2 - Fairly endangered in California, but more common elsewhere Rank 2B.3 - Not very endangered in California, but more common elsewhere Rank 3 - Plants about which we need more information (Review List) Rank 3.1 - Plants about which we need more information (Review List) Seriously endangered in California
Rank 3.2 - Plants about which we need more information (Review List) Fairly endangered in California
Rank 4 - Plants of limited distribution - a watch list
CNPS:

Rank 1A - Presumed extinct in California
Rank 1B - Plants rare, threatened, or endangered in California and elsewhere Rank 1B.1 - Seriously endangered in California (over 80% occurrences threatened/ high degree and immediacy of threat)
Rank 1B.2 - Fairly endangered in California (20-80% occurrences threatened) Rank 1B.3 - Not very endangered in California (<20% of occurrences threatened or no current threats known)

1604
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Invertebrates
Branchinecta lynchi
Closest record is from 2003 and is 1.5
miles north of the project site
(Occurrence No. 232).

Fed: FT None. No suitable habitat on the project site.

State: -
Endemic to the grasslands of the Central
Valley, central coast mountains, and south
coast mountains. Inhabit static rainfilled/vernal pools, small, clear water sandstone-depression pools and grassed
swale, earth slump, or basalt-flow depression
Vernal pool fairy shrimp
Other:

Fish
Oncorhynchus mykiss irideus
Closest record is from 2000 and is 0.39
miles southwest of the project site
(Occurrence No. 4).

Fed: FT None. No suitable habitat on the project site.

State: -
From Russian River south to Soquel Creek,
and to Pajaro River. Also found in San
Francisco & San Pablo Bay Basins. Spawn in
clear, cool, well oxygenated streams greater
than 18 cm deep.

Steelhead - Central California Coast DPS
Other:

Spirinichus thaleichthys
Closest record is from 2012 and is1.2
miles west of the project site
(Occurrence No. 26).

Fed: -- None. No suitable habitat on the project site.

State: CT
Endemic to the Sacramento-San Joaquin
River system. Inhabits open waters in the
Delta and Suisun Bay. After spawning, larvae
are carried downstream to brackish nursery
areas.

Longfin smelt
Other:

Pogonichthys macrolepidotus
Closest record is from 2001 and is 2.9
miles southwest of the project site
(Occurrence No. 12).

Fed: None. No suitable habitat on the project site.

State: CSC
Endemic to the lakes and rivers of the Central
Valley; now confined to the delta, Suisun
Bay, and associated marshes. Inhabits slow
moving river sections and dead-end sloughs.

Needs flooded vegetation for spawning.

Sacramento splittail
Other:

Amphibians
Rana draytonii
Closest record is from 2006 and is 1.4
miles east of the project site
(Occurrence No. 896).

Fed: FT None. No suitable habitat on the project site.

State: CSC
Occurs in lowlands and foothills in deeper
pools and streams, usually with emergent
wetland vegetation. Requires 11-20 weeks of
permanent water for larval development.

California red-legged frog
Other:

1605
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Rana boylii
Closest record is from 193X and is 1.2
miles east of the project site
(Occurrence No. 2341).

Fed: -- None. No suitable habitat on the project site.

State: CC
Found in partially shaded, shallow streams
with rocky substrates. Requires perenial pools
or flowing water. Needs some cobble-sized
rocks as a substrate for egg laying. Requires
water for 15 weeks for larval transformation.

Foothill yellow-legged frog
Other:

Reptiles
Emys marmorata
Closest record is from 2002 and is 0.45
miles northeast of the project site
(Occurrence No. 552).

None. No suitable habitat on or adjacent to the
project site.

Fed: -
State: CSC
Inhabits ponds, marshes, rivers, streams, and
irrigation ditches with aquatic vegetation.

Needs suitable basking sites and upland
habitat for egg laying. Occurs in the Central
Valley and Contra Costa County.

Western pond turtle **
Other:

Birds
Circus cyaneus
Closest record is from 2004 and is 2.8
miles west of the project site
(Occurrence No. 29).

Unlikely to nest onsite. Preconstruction surveys
will be conducted.

Fed: -
State: CSC
Nests on the ground or in shrubby vegetation
typically in grasslands, fallow farm lands,
near freshwater and salt water marshes.

Northern harrier
Other:

Buteo swainsoni
Closest record is from 2013 and is 2.6
miles northeast of the project site
(Occurrence No. 2744).

Unlikely to nest adjacent to project site.

Preconstruction surveys will be conducted.

Fed: -
State: CT
Migratory and resident raptor that breeds in
open areas with scattered trees. Prefers
riparian and sparse oak woodland habitats for
nesting. Requires nearby grasslands, grain
fields, or alfalfa for foraging.

Swainson's hawk
Other:

Buteo regalis
Closest record is from 1988 and is 3.0
miles north of the project site
(Occurrence No. 28).

Fed: -- None. Does not nest in California.

State: WL
Winter migrant to California where they
prefer grasslands, cultivated fields and arid
areas with an abundance of prey species, such
as pocket gophers, black-tailed hares, and
cottontails.

Ferruginous hawk
Other:

1606
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Falco peregrinus
Closest record is from 2015 and is 3.0
miles east of the project site
(Occurrence No. 42).

None. No suitable nesting habitat on or near the
project site.

Fed: -
State: -
Nests on high cliffs near wetlands, lakes,
rivers, or other water; also nests on humanmade structures. Nest consists of a scrape on a depression or ledge in an open site. Was
formerly state and federally listed but delisted
due to species recovery.

Peregrine falcon
Other:

Laterallus jamaicensis coturniculus
Closest record is from 2011 and is 2.5
miles northwest of the project site
(Occurrence No. 31).

Fed: -- None. No suitable habitat on the project site.

State: CT
Inhabits salt marshes bordering larger bays.

Prefers tidal salt marshes of pickleweed.

California black rail
Other:

Rallus obsoletus obsoletus
Closest record is from 1989 and is 2.4
miles northwest of the project site
(Occurrence No. 16).

Fed: FE None. No suitable habitat on the project site.

State: CE
Inhabits salt water and brackish marshes with
tidal sloughs in San Francisco Bay. Prefers
dense pickleweed for cover, but forages for
invertebrates along mud-bottomed sloughs.

California Ridgway's rail
Other:

Athene cunicularia hypugaea
Closest record is from 1989 and is 2.6
miles southeast of the project site
(Occurrence No. 109).

Unlikely to nest on the project site.

Preconstruction surveys will be conducted.

Fed: --
State: CSC
Found in 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.

Western burrowing owl
Other:

Geothlypis trichas sinuosa
Closest record is from 2004 and is 2.5
miles northwest of the project site
(Occurrence No. 37).

Fed: - None. No suitable habitat on the project site.

State: CSC
Resident of freshwater and salt water marshes
in the San Francisco Bay region. Requires
thick, continuous cover for foraging and tall
grasses, tules, or willows for nesting.

Salt marsh common yellowthroat
Other:

Melospiza melodia samuelis
Closest record is from 2004 and is 2.8
miles west of the project site
(Occurrence No. 17).

Fed: -- None. No suitable habitat on the project site.

State: CSC
More properly known as Samuels Song
Sparrow. Resident of salt marshes along the
north side of San Francisco and San Pablo
Bays. Inhabits tidal sloughs in the California
marshes; nests in grindelia bordering slough
channels.

San Pablo song sparrow
Other:

1607
*Status Habitat Closest Locations Probability on Project Site Table 4
Special-Status Wildlife Species Known Within 3 Miles of the SDG 217 Commerce Distribution Center Project Site Species
monk & associates
Agelaius tricolor
Closest record is from 2014 and is 1.6
miles northeast of the project site
(Occurrence No. 243).

None. No suitable nesting habitat on the project
site.

Fed: -
State: CC
Colonial nester in dense cattails, tules,
brambles or other dense vegetation. Requires
open water, dense vegetation, and open grassy
areas for foraging.

Tricolored blackbird
Other: CSC
Mammals
Reithrodontomys raviventris
Closest record is from 1989 and is 2.4
miles south of the project site
(Occurrence No. 150).

Fed: FE None. No suitable habitat on the project site.

State: CE
Inhabits saline marshes in the San Francisco
Estuary. Prefers pickleweed marshes.

Requires higher areas for escaping high water.

Salt marsh harvest mouse
Other:
*Status
Federal:

FE - Federal Endangered
FT - Federal Threatened
FPE - Federal Proposed Endangered
FPT - Federal Proposed Threatened
FC - Federal Candidate
FPD - Federally Proposed for delisting
State:

CE - California Endangered
CT - California Threatened
CR - California Rare
CC - California Candidate
CSC - California Species of Special Concern
FP - Fully Protected
WL - Watch List. Not protected pursuant to CEQA
**The USFWS hopes to finish a 12-month finding for western pond turtle in 2021 but until formally listed, it is not afforded the protections of FESA.

1608
1609

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 1610
Addendum Letter to CEQA Biology Report Discussing Proposed Borrow Site SDG Commerce 217 Distribution Center, Napa, California
APN: 058-030-065-000

MONK & ASSOCIATES
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 1611
SDG COMMERCE 217 DISTRIBUTION CENTER

BORROW SITE ROUGH GRADING

AMERICAN CANYON CALIFORNIA
1 1

PRELIMINARY - NOT FOR CONSTRUCTION

CHECKED
DRAWN

DESIGNED
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
NAPA, CALIF. 94559
OFFICE
www.RSAcivil.com
| 252.3301 707|
+ + 1
1612
1613
SDG COMMERCE 217 DISTRIBUTION CENTER

AMERICAN CANYON CALIFORNIA
20 CHECKEDDRAWNDESIGNEDDATEJOB NO.SHEET NO.

OF SHEETS
APPD REVISIONS BY DATE NO.

Printed on Recycled Paper Please Continue the Cycle
RSA | CONSULTING CIVIL ENGINEERS + SURVEYORS + +
1980
est.
1515 FOURTH STREET
NAPA, CALIF. 94559
OFFICE
www.RSAcivil.com
| 252.3301 707|
+ + BORROW SITE GRADING PLAN
C3.5
14 City of American Canyon
Public Works
Job Site Copy
03/28/2023
1614
City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR
FirstCarbon Solutions
C.3 - Commerce 220 Documents
1615

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1616

PINECREST ENVIRONMENTAL CONSULTING
6425 TELEGRAPH AVE. #8
OAKLAND, CA 94609
510.881.3039 TEL
[email protected]
WWW.PINECRESTENVIRONMENTAL.ORG
1 S P E C I A L - S T A T U S A N I M A L S U R V E Y R E P O R T Date: August 8, 2023
To: Robert Carroll, FCS International.

From: Dr. Christopher T. DiVittorio, Pinecrest Research Corp., Inc.

Subject: Results of special-status animal surveys at 220 Commerce Court, Napa County, CA (FCS Project 5639.0001)
Robert Carroll,
This special-status animal survey report (Report) details the findings of eleven (11) wildlife surveys conducted between January 18 and July 2 in 2023 at the above-referenced property located in the County of Napa. The site consists of one parcel measuring 10.2 acres and assigned APN 058-030-069. Surveys were conducted in order to determine the pre-construction presence or absence of the following special-status animals: burrowing owl (Athene cunicularia), Swainson’s hawk (Buteo swainsoni), nesting raptors, nesting passerine birds, and Western pond turtle. Surveys were conducted by consulting biologist Dr. Christopher DiVittorio.

Site Description
The entirety of the site is disked and mowed ruderal grassland, with the exception of a row of Eucalyptus trees along the northern property line. The ruderal grassland exhibits low cover of plants and low species diversity with very few native species (Figure 1). The habitat type of this area as determined by Sawyer et al. (2009) Manual of California Vegetation 2nd Edition (MCV) is Bromus (diandrus, hordeaceous)-Brachypodium distachyon Semi-Natural Herbaceous Stand.

On the north side of the parcels is a row of bluegum Eucalyptus. The MCV classification of this habitat is Eucalyptus (globulus, camaldulensis) Semi-Natural Woodland Stands.

Methods
Between January 18 and July 2, 2023, eleven (11) surveys were conducted for nesting passerine birds, raptors (including Swainson’s hawk), burrowing owl, and Western pond turtle. During each survey, the entirety of the "Commerce 220" site as well as the adjacent "Commerce 217" site were examined. These surveys included the entirety of both legal parcels, as well all of the vegetated areas up to the concrete paved area on the developed parcel to the south. Relevant adjacent areas were also examined with binoculars where possible. A total of approximately 45 survey hours were completed across all survey dates. All of the aforementioned animal types were surveyed for at each of the eleven site visits. Survey methods followed established procedures and applicable protocols, including the Recommended Timing and Methodology for Swainson’s Hawk Nesting fSurveys in California’s Central Valley, and the Staff Report on 1617
2 PINECREST ENVIRONMENTAL CONSULTING, INC.

Burrowing Owl Mitigation.
1,2
Survey equipment included high-quality binoculars and a highquality spotting scope. Surveys were conducted during the appropriate times of day (including peak bird detection periods between sunrise and 10 a.m.). Surveys were conducted on foot.

Survey dates with the corresponding Swainson's hawk survey periods are shown below.

Date Swainson’s Hawk Survey Period
1/18/2023 1st survey in Period I
3/20/2023 1st survey in Period II
3/31/2023 2nd survey in Period II
4/4/2023 3rd survey in Period II
4/5/2023 1st survey in Period III
4/6/2023 2nd survey in Period III
4/7/2023 3rd survey in Period III
4/24/2023 1st survey in Period IV
4/28/2023 2nd survey in Period IV
5/29/2023 3rd survey in Period IV
7/2/2023 1st survey in Period V
Results & Recommendations
A total of 56 unique species of birds were observed across the eleven site visits. A total of 4 other species of animals were observed across the eleven site visits. Transcribed field notes from each of the eleven site visits are provided in Appendix A, below. A master list of all species of birds and other animals encountered across the eleven site visits is provided in Appendix B, below.

Due to the lack of suitable nesting habitat on the project site itself, no nesting birds were observed in the project area, although nesting birds were observed in the Eucalyptus stands offsite. Of the nesting birds in the offsite Eucalyptus stands, none of these were special-status including raptors. 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. No adults or nests of Western pond turtle were observed (Appendix A & B).
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. 1618
3 PINECREST ENVIRONMENTAL CONSULTING, INC.

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 onsite also indicates that Swainson's hawk are not utilizing this habitat currently since these species are antagonistic and do not typically share ranges. The negative survey results for Swainson’s hawk despite approximately 45 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)
No active raptor nests were observed within the vicinity of the project site. Several American crow were loitering around the Eucalyptus grove to the east of the parcel and harassing Whitetail 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-shouldered hawk was observed within a large Eucalyptus tree along the north property line however this individual flew offsite after approximately 20 minutes. No other active nests were observed during any of the eleven site visits.

Burrowing Owl
No evidence of burrowing owl activity was observed during any of the eleven 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 eleven field surveys.

There are some wetland features onsite, however there are no ponds or streams onsite that would be suitable for Western pond turtle foraging or breeding. No signs of adults or nests were observed onsite or in the accessible vicinity of the site. Therefore, it is reasonable to conclude Western pond turtle is absent from the project site.

Based on the results of these eleven surveys, we conclude that there are no special-status animal species currently occupying the project site, and no compensatory mitigation for impacts to special-status animal species is recommended at this time. These results do not however, preclude the future existence of the above-referenced species onsite as they may recolonize the site if sufficient time has passed between these surveys and site development.

Please let me know if you have any questions about this or any other studies we've performed for this project.
1619
4 PINECREST ENVIRONMENTAL CONSULTING, INC.

Sincerely,
Christopher DiVittorio, PhD
President, PEC
(510) 881-3039
[email protected]
1620
5 PINECREST ENVIRONMENTAL CONSULTING, INC.

Figure 1: Ruderal Grassland
1621
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Figure 2: Eucalyptus Stands
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Figure 3: Habitat Map
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Appendix A: Animal Survey Field Notes
The following is a transcription of field notes for each of the eleven (11) protocol-level surveys conducted at the project site. Special-status species, if any, are denoted with an asterisk (*).

Site Visit: 1/18/23
Time: 12:00 PM (approx.)
Weather: clear, no wind, 56degF
Notes: started mid-day
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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) Other Animals: None
Site Visit: 3/20/23
Time: 6:35 AM
Weather: no wind, 49 degF, 46% RH
Notes: start at sunrise; park in SE corner
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; early season plant survey
Personnel: Dr. Christopher DiVittorio
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), 1624
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Site Visit: 3/31/23
Time: 6:30 AM
Weather: clear, wind 0 mph, 44.5 degF, 76.5% RH
Notes: parked NE corner
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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), 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
Notes: parked SW corner; 6:15 AM first light, 7:15 first direct sunlight Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; mid-season plant survey
Personnel: Dr. Christopher DiVittorio
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 onsite; parked SW corner Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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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), Other Animals: None
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 onsite; parked SW corner Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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: black-tailed jackrabbit (Lepus californicus) runways, California vole (Microtus californicus) runways
Site Visit: 4/7/23
Start time: 6:30 AM
Weather: cloudy, 54.5 degF, 79% RH, wind 1-2 mph, fewer birds today Notes: met Jerry with Stravinsky onsite
Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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), whitecrowned sparrow (Zonotrichia leucophrys), Other Animals: black-tailed jackrabbit (Lepus californicus), 1626
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Site Visit: 4/24/23
Start time: 6:30 AM
Weather: cloudy, then sunny; 61 degF, 64% RH, 1-3 mph wind Notes: met Jerry with Stravinsky onsite for survey at 6:30, began preconstruction meeting 8:00 AM Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey; preconstruction meeting with geotechnical engineer, Stravinsky, civil engineer, SWPP monitor, etc.

Personnel: Dr. Christopher DiVittorio
Birds: violet-green swallow (Tachycineta thalassina), Brewer’s blackbird (Euphagus cyanocephalus), California towhee (Melozone crissalis), dark-eyed junco (Junco hyemalis), black phoebe (Sayornis nigricans), lesser goldfinch (Spinus psaltria), crow (Corvus brachyrhynchos), Anna's hummingbird (Calypte anna), house wren (Troglodytes aedon), European starling (Sturnus vulgaris), white-crowned sparrow (Zonotrichia leucophrys), Nuttal's woodpecker (Picoides nuttallii), American goldfinch (Spinus tristis), Western bluebird (Sialia mexicana), turkey vulture (Cathartes aura), mourning dove (Zenaida macroura), White-tailed kite (Elanus leucurus) soaring and hovering over field, juvenile red-tailed hawk (Buteo jamaicensis) offsite to E flushed immediately out of site to the SE, peregrine falcon (Falco peregrinus) fly-through overhead, unidentified species of sparrow, Other Animals: none
Other Notes: Red-tailed hawk nest on south side of existing warehouse to the south of project site is not active this year.

Site Visit: 4/28/23
Start time: 5:45 AM
Weather: cloudy, cold
Notes: met Jerry with Stravinsky onsite, Commerce 217 will be graded tomorrow; silt fencing installed and grass has been mowed since last visit; no burrows or other animal sign onsite; this counts towards the 24-hour BUOW preconstruction survey requirement
Purpose: preconstruction Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
Birds: White-tailed kite (Elanus leucurus) hovering over field, turkey vulture (Cathartes aura), wild turkey (Meleagris gallopavo),
Other Animals: black-tailed jackrabbit (Lepus californicus), Site Visit: 5/29/23
Start time: 8:30 AM
Weather: sunny
Notes: Commerce 220 site has been graded in addition to Commerce 217 Purpose: Swainson's hawk, other raptor, nesting passerine bird, BUOW, western pond turtle survey Personnel: Dr. Christopher DiVittorio
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Birds: no sign of BUOW or Swainson's hawk; presence/absence survey only; no comprehensive bird list completed
Other Animals: none
Site Visit: 7/2/23
Start time: 1:00 PM
Weather: clear, sunny, 85 degF, 51% RH, 3-8 mph wind
Note: many species appear to have migrated offsite for the summer Purpose: Swainson's hawk, other raptor, nesting bird, BUOW, western pond turtle survey Bird Species:
house finch (Haemorhous mexicanus), Osprey (Pandion haliaetus), turkey vulture (Cathartes aura), lesser goldfinch (Spinus psaltria), red-tailed hawk (Buteo jamaicensis), Nuttal's woodpecker (Picoides nuttallii), kildeer (Charadrius vociferus), White-tailed kite (Elanus leucurus) Other Animals: none
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Appendix B: Master Species List
The following is a list of animal species observed across the eleven (11) site visits at the project site. Special-status species, if any, are denoted with an asterisk (*).

MASTER BIRD LIST
Allen's hummingbird (Selasphorus sasin)
American coot (Fulica americana)
American goldfinch (Spinus tristis)
American pelican (Pelecanus erythrorhynchos)
American pipit (Anthus rubescens)
American robin (Turdus migratorius)
Anna's hummingbird (Calypte anna)
Bewick's wren (Thryomanes bewickii)
black phoebe (Sayornis nigricans)
Brewer’s blackbird (Euphagus cyanocephalus)
brown creeper (Certhia americana)
brown-headed cowbird (Molothrus ater)
California gull (Larus californicus)
California towhee (Melozone crissalis)
Canada goose (Branta canadensis)
cedar waxwing (Bombycilla cedrorum)
chestnut-backed chickadee (Poecile rufescens)
cliff swallow (Petrochelidon pyrrhonota)
crow (Corvus brachyrhynchos)
dark-eyed junco (Junco hyemalis)
European starling (Sturnus vulgaris)
fox sparrow (Passerella iliaca)
golden-crowned sparrow (Zonotrichia atricapilla)
great blue heron (Ardea herodias)
hermit thrush (Catharus guttatus)
house finch (Haemorhous mexicanus)
house sparrow (Passer domesticus)
house wren (Troglodytes aedon)
kildeer (Charadrius vociferus)
lesser goldfinch (Spinus psaltria)
mallard ducks (Anas platyrhynchos)
mourning dove (Zenaida macroura)
Northern flicker (Colaptes auratus)
Northern mockingbird (Mimus polyglottos)
Nuttal's woodpecker (Picoides nuttallii)
Osprey (Pandion haliaetus)
peregrine falcon (Falco peregrinus)
purple finch (Haemorhous purpureus)
raven (Corvus corax)
red-shouldered blackbird (Agelaius phoeniceus)
red-shouldered hawk (Buteo lineatus)
red-tailed hawk (Buteo jamaicensis)
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rock wren (Salpinctes obsoletus)
ruby-crowned kinglet (Regulus calendula)
song sparrow (Melospiza melodia)
tree swallow (Tachycineta bicolor)
turkey vulture (Cathartes aura)
violet-green swallow (Tachycineta thalassina)
Western bluebird (Sialia mexicana)
Western scrub jay (Aphelocoma californica)
white-crowned sparrow (Zonotrichia leucophrys)
White-tailed kite (Elanus leucurus)
wild turkey (Meleagris gallopavo)
yellow-rumped warbler (Setophaga coronata)
unidentified gull likely Western or California
unidentified species of sparrow

MASTER OTHER ANIMALS LIST
black-tailed deer (Odocoileus hemionus)
black-tailed jackrabbit (Lepus californicus)
California vole (Microtus californicus) runways
domestic cat (Felis catus)
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PINECREST ENVIRONMENTAL CONSULTING
6425 TELEGRAPH AVE. #8
OAKLAND, CA 94609
510.881.3039 TEL
[email protected]
WWW.PINECRESTENVIRONMENTAL.ORG
1 S P E C I A L - S T A T U S P L A N T S U R V E Y R E P O R T Date: July 21, 2023
To: Jason Brandman, FCS International.

From: Dr. Christopher T. DiVittorio, Pinecrest Research Corp., Inc.

Subject: Results of special-status plant surveys at 220 Commerce Court, Napa County, CA (FCS Project 5639.0001)
To Whom It May Concern,
This rare plant survey report (Report) details the findings of three protocol-level special-status plant surveys conducted in 2023 at the above-referenced property located in the County of Napa.

The site consists of one parcel measuring 10.2 acres and assigned APN 058-030-069.

Site Description
The entirety of the site is disked and mowed ruderal grassland, with the exception of some emergent wetland along the north property line. A stand of non-native Eucalyptus spp. exists to the west but this is offsite and located on the adjacent parcel. The ruderal grassland exhibits low cover of plants and low species diversity with very few native species (Figure 1). The habitat type of this area as determined by Sawyer et al. (2009) Manual of California Vegetation 2nd Edition (MCV) is Bromus (diandrus, hordeaceous)-Brachypodium distachyon Semi-Natural Herbaceous Stand. There is also some disturbed/previously developed habitat in the southeast corner (Figure 3). The project will affect only the ruderal grassland portion of the site.

Methods
Special-status plants are defined here to include: (1) all plants that are federal- or state-listed as rare, threatened or endangered, (2) all federal and state candidates for listing, (3) all plants included in Lists 1 through 4 of the CNPS Inventory, and (4) plants that qualify under the definition of "rare" in the California Environmental Quality Act, section 15380. Background information searches were conducted prior to all site visits to identify potential rare plant species or sensitive plant communities recognized by the California Department of Fish and Wildlife (CDFW) that may occur in the Study Area vicinity.

A table of these species, and their protection status, habitat requirements, and likelihood to occur in the Study Area is provided below in Appendix A. Sources for this table include the California Department of Fish and Wildlife (CDFW) Natural Diversity Database (CDFW 2023), the California Native Plant Society (CNPS) Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPS 2023), and the knowledge of PEC staff. CNDDB searches were performed within a "9-quad" area encompassing the surrounding region. 1631
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Site visits were performed 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 site was graded thus the late-season site visit focused on remaining vegetation surrounding the areas of disturbance. Site visits were performed by PEC botanist Dr. Christopher DiVittorio, with secondary identification on voucher and photograph specimens made by PEC botanist Dr. Zoya Akulova. During each site visit, Dr. DiVittorio surveyed the entirety of the project area using methods as specified in the California Department of Fish & Wildlife (CDFW) publication titled Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities, dated March 20, 2018.

During each survey, the entirety of the "Commerce 220" site as well as the adjacent "Commerce 217" site were examined. These surveys included the entirety of both legal parcels, as well all of the vegetated areas up to the concrete paved area on the developed parcel to the south. Field 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 (2012).

Results & Recommendations
The project area is comprised of routinely disked ruderal Bromus (diandrus, hordeaceous) SemiNatural Stands with some isolated individuals of Baccharis pilularis mostly near the edges of the site. A map of habitat types is shown in Figure 3. No special-status plant species or sensitive habitats were positively identified in the project area. A full list of the species encountered during the surveys is provided below in Appendix B. In total, 15 native species were observed onsite and 57 non-native species were observed. No special-status species were found thus we have no recommendations for mitigation or avoidance for this project.

Please let me know if you have any questions about this or any other studies we've performed for this project.

Sincerely,
Christopher DiVittorio, PhD
President, PEC
(510) 881-3039
[email protected]
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Figure 1: Ruderal Grassland
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Figure 2: Eucalyptus Stands
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Figure 3: Habitat Map
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Appendix A: Special-Status Species Considered
The following is a list of sensitive and/or rare plants and habitats generated based on knowledge of the species and habitats of Napa County by PEC staff, from various State and Federal databases, and from the California Natural Diversity Database (CNDDB). Known occurrences within a "9-quad" region around the project site are shown in bold.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
PLANTS
Alkali milk-vetch
(Astragalus tener var. tener)
—/—/1B.2 Alkali grassland Very Low: No alkali habitat exists in the project area.

Anthony peak lupine
(Lupinus antoninus)
—/—/1B.2 Coniferous forest None: No coniferous forest habitat exists in the project area.

Baker's goldfields
(Lasthenia californica ssp. bakeri)
—/—/1B.2 Coastal grasslands Very Low: Some grassland habitat exists in the project area.

Baker's larkspur
(Delphinium bakeri)
FE/SE/1B.1 Coastal scrub Very Low: No coastal scrub habitat exists in the project area.

Baker's manzanita
(Arctostaphylos bakeri ssp. bakeri)
—/—/1B.1 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Baker's navarretia
(Navarretia leucocephala ssp.
bakeri)
—/—/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Beaked tracyina
(Tracyina rostrata)
—/—/1B.2 Grassland, foothill
woodland
Low: Some grassland habitat exists in
the project area.

Bent flowered fiddleneck
(Amsinckia lunaris)
—/—/1B.2 Grassland, foothill
woodland
Low: Some grassland habitat exists in
the project area.

Big-scale balsamroot
(Balsamorhiza macrolepis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Big tarplant
(Blepharizonia plumosa)
—/—/1B.1 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Blasdale's bent grass
(Agrostis blasdalei)
—/—/1B.2 Coastal grassland Very Low: Some grassland habitat exists in the project area.

Blue coast gilia
(Gilia capitata ssp. chamissonis)
—/—/1B.1 Coastal sand dunes None: No sand dune habitat exists in the project area.

Bluff wallflower
(Erysimum concinnum)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Bogg's Lake hedge-hyssop
(Gratiola heterosepala)
—/—/1B.2 Vernal pool, pond None: No vernal pool habitat exists in the project area.

Bolander's horkelia
(Horkelia bolanderi)
—/—/1B.2 Coniferous forest,
grassland
Low: Some grassland exists in the
project area.
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Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Bolander's water hemlock
(Cicuta maculata var. bolanderi)
—/—/2B.1 Salt marsh None: No salt marsh habitat exists in the project area.

Brandegee's eriastrum
(Eriastrum brandegeeae)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Brewer's calandrinia
(Calandrinia breweri)
—/—/4.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Brewer's western flax
(Hesperolinon breweri)
—/—/1B.2 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Bristly leptosiphon
(Leptosiphon aureus)
—/—/4.2 Chaparral None: No chaparral habitat exists in
the project area.

Bristly sedge
(Carex comosa)
—/—/2B.1 Wetland, riparian None: No potential wetland habitat exists in the project area.

Brownish beaked-rush
(Rhynchospora capitellata)
—/—/2B.2 Wetland, riparian None: No potential wetland habitat exists in the project area.

Burke's goldfields
(Lasthenia burkei)
FE/SE/1B.1 Vernal pools,
grassland
Low: Some grassland habitat exists in
the project area.

California alkali grass
(Puccinellia simplex)
—/—/1B.2 Alkali grassland Very Low: No alkali grassland habitat exists in the project area.

California beaked-rush
(Rhynchospora californica)
—/—/1B.1 Freshwater wetlands None: No potential wetland habitat exists in the project area.

California satintail
(Imperata brevifolia)
—/—/2B.1 Chaparral, coastal
scrub
None: No chaparral habitat exists in the
project area.

California sedge
(Carex californica)
—/—/2B.3 Wetlands None: No wetland habitat exists in the project area.

Calistoga ceanothus
(Ceanothus divergens)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Calistoga popcornflower
(Plagiobothrys strictus)
FE/ST/1B.1 Wetland, riparian None: No wetland habitat exists in the project area.

Carquinez goldenbrush
(Isocoma arguta)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Chaparral ragwort
(Senecio aphanactis)
—/—/1B.1 Coastal scrub,
woodland
None: No coastal scrub habitat exists
in the project area.

Clara Hunt's milk vetch
(Astragalus claranus)
—/—/1B.1 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Coast iris
(Iris longipetala)
—/—/4.2 Coastal grassland,
wetland
Low: Some grassland habitat exists in
the project area.

Coast lily
(Lilium maritimum)
—/—/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.
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Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Coastal bluff morning glory
(Calystegia purpurata ssp. saxicola)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Cobb Mountain lupine
(Lupinus sericatus)
—/—/1B.2 Chaparral,
coniferous forest
None: No chaparral habitat exists in
the project area.

Colusa layia
(Layia septentrionalis)
—/—/1B.2 Chaparral, valley
grassland
Low: Some grassland habitat exists in
the project area.

Congdon's tarplant
(Centromadia parryi ssp. congdonii)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Congested-headed hayfield tarplant
(Hemizonia congesta ssp.
congesta)
—/—/1B.2 Grassland, coastal
scrub
Low: Some grassland habitat exists in
the project area.

Contra Costa goldfields
(Lasthenia conjugens)
FE/—/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Crystal Springs lessingia
(Lessingia arachnoidea)
—/—/1B.2 Serpentine grassland None: No serpentine grassland habitat exists in the project area.

Cunningham Marsh cinquefoil
(Potentilla uliginosa)
—/—/1A Wetland None: No wetland habitat exists in the
project area.

Dark-eyed gilia
(Gilia millefoliata)
—/—/1B.2 Coastal sand dunes None: No coastal sand dune habitat exists in the project area.

Dark-mouthed triteleia
(Triteleia lugens)
—/—/4.3 Grassland, chaparral Low: Some grassland habitat exists in the project area.

Deceiving sedge
(Carex saliniformis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Deep-scarred cryptantha
(Cryptantha excavata)
—/—/1B.2 Woodland None: No woodland habitat exists in the project area.

Delta tule pea
(Lathyrus jepsonii var. jepsonii)
—/—/1B.2 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.

Diablo helianthella
(Helianthella castanea)
—/—/1B.2 Chaparral, grassland Low: Some grassland habitat exists in the project area.

Dimorphic snapdragon
(Antirrhinum subcordatum)
—/—/4.3 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Dwarf downingia
(Downingia pusilla)
—/—/2B.2 Vernal pool, wetland None: No vernal pool habitat exists in the project area.

Dwarf soaproot
(Chlorogalum pomeridianum var. minus)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Eel-grass pondweed
(Potamogeton zosteriformis)
—/—/2B.2 Wetland, pond None: No wetland habitat exists in the project area.

Fragrant fritillary
(Fritillaria liliacea)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.
1638
9 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Few-flowered navarretia
(Navarretia leucocephala ssp. pauciflora)
FE/SE/1B.1 Vernal pool, wetland None: No vernal pool habitat exists in the project area.

Franciscan onion
(Allium peninsulare var. franciscanum)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Geysers panicum
(Panicum acuminatum var. thermale)
—/—/1B.2 Chaparral, wetland None: No chaparral habitat exists in the project area.

Glandular western flax
(Hesperolinon adenophyllum)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Golden larkspur
(Delphinium luteum)
FE/SR/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Grassleaf water plantain
(Alisma gramineum)
—/—/2B.2 Wetland, pond None: No wetland habitat exists in the project area.

Green monardella
(Monardella viridis)
—/—/4.3 Chaparral None: No chaparral habitat exists in
the project area.

Greene's narrow-leaved daisy
(Erigeron greenei)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral habitat exists in the project area.

Hall's harmonia
(Harmonia hallii)
—/—/1B.2 Serpentine chaparral None: No chaparral habitat exists in the project area.

Henderson's bent grass
(Agrostis hendersonii)
—/—/3.2 Vernal pool None: No vernal pool habitat exists in the project area.

Hoffman's bristly jewelflower
(Streptanthus glandulosus spp. hoffmanii)
—/—/1B.3 Chaparral, woodland None: No chaparral habitat exists in the project area.

Holly-leaved ceanothus
(Ceanothus purpureus)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Hospital Canyon larkspur
(Delphinium californicum ssp. interius)
—/—/1B.2 Woodland None: No woodland habitat exists in the project area.

Humboldt County milk vetch
(Astragalus agnicidus)
—/—/1B.1 Coniferous forest None: No coniferous forest habitat exists in the project area.

Jepson's coyote thistle
(Eryngium jepsonii)
—/—/4.2 Wetland, vernal pool None: No wetland habitat exists in the project area.

Jepson's leptosiphon
(Leptosiphon jepsonii)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Jepson's milk-vetch
(Astragalus rattanii var. jepsonianus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Johnny-nip
(Castilleja ambigua var. ambigua)
—/—/4.2 Wetland, riparian None: No wetland habitat exists in the project area.

Kenwood Marsh checkerbloom
(Sidalcea oregana ssp. valida)
FE/SE/1B.1 Wetland None: No wetland habitat exists in the project area.
1639
10 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Konocti manzanita
(Arctostaphylos manzanita ssp. elegans)
—/—/1B.3 Chaparral, woodland None: No chaparral habitat exists in the project area.

Lake County stonecrop
(Sedella leiocarpa)
—/—/1B.1 Wetland None: No wetland habitat exists in the project area.

Legenere
(Legenere limosa)
—/—/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Loch Lomond button-celery
(Eryngium constancei)
FE/SE/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.

Lobb's aquatic buttercup
(Ranunculus lobbii)
—/—/4.2 Vernal pool None: No vernal pool habitat exists in the project area.

Long-styled sand-spurrey
(Spergularia macrotheca var. longistyla)
—/—/1B.2 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Lyngbye's sedge
(Carex lyngbyei)
—/—/2B.2 Salt marsh None: No salt marsh habitat exists in the project area.

Many-flowered navarretia
(Navarretia leucocephala spp. plieantha)
FE/SE/1B.2 Vernal pool None: No wetland habitat exists in the project area.

Maple-leaved checkerbloom
(Sidalcea malachroides)
—/—/4.2 Coastal grassland,
coniferous forest
Very Low: No coastal grassland habitat
exists in the project area.

Marin checker lily
(Fritillaria lanceolata var. tristulis)
—/—/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Marin checkerbloom
(Sidalcea hickmanii spp. viridis)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Marin County navarretia
(Navarretia rosulata)
—/—/1B.2 Serpentine forest None: No serpentine habitat exists in the project area.

Marin knotweed
(Polygonum marinense)
—/—/3.1 Coastal salt marsh None: No coastal salt marsh habitat exists in the project area.

Marin manzanita
(Arctostaphylos virgata)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Marin western flax
(Hesperolinon congestum)
FT/ST/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Marsh checkerbloom
(Sidalcea oregana ssp. hydrophila)
—/—/1B.2 Wetland, riparian None: No wetland habitat exists in the project area.

Marsh microseris
(Microseris paludosa)
—/—/1B.2 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Marsh pea
(Lathyrus palustris)
—/—/2B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Mason's ceanothus
(Ceanothus masonii)
—/SR/1B.2 Chaparral None: No chaparral habitat exists in the project area.
1640
11 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Mason's lilaeopsis
(Lilaeopsis masonii)
—/SR/1B.1 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.

Milo Baker's lupine
(Lupinus milo-bakeri)
—/—/1B.1 Woodland, grassland None: No woodland habitat exists in the project area.

Modest rockcress
(Arabis modesta)
—/—/4.3 Chaparral, forest None: No chaparral habitat exists in the project area.

Morrison's jewelflower
(Streptanthus morrisonii ssp. morrisonii)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Mt. Diablo fairy-lantern
(Calochortus pulchellus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Mt. St. Helena morning glory
(Calystegia collina ssp. oxyphylla)
—/—/4.2 Serpentine chaparral None: No serpentine habitat exists in the project area.

Mt. Tamalpais bristly jewelflower
(Streptanthus glandulosus spp. pulchellus)
—/—/1B.2 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Mt. Tamalpais manzanita
(Arctostaphylos montana spp. montana)
—/—/1B.3 Chaparral None: No chaparral habitat exists in the project area.

Mt. Tamalpais thistle
(Cirsium hydrophilum var. vaseyi)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Napa bluecurls
(Trichostema ruygtii)
—/—/1B.2 Grassland Medium: Some grassland habitat
exists in the project area.

Napa blue grass
(Poa napensis)
FE/SE/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Napa checkerbloom
(Sidalcea hickmanii ssp. napensis)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Napa false indigo
(Amorpha californica var. napensis)
—/—/1B.2 Forest, woodland None: No woodland habitat exists in the project area.

Napa lomatium
(Lomatium repostum)
—/—/1B.2 Woodland, chaparral None: No woodland habitat exists in the project area.

Narrow-anthered brodiaea
(Brodiaea leptandra)
—/—/1B.2 Woodland, grassland Very Low: Some grassland habitat exists in the project area.

Nodding harmonia
(Harmonia nutans)
—/—/4.3 Woodland, chaparral None: No chaparral habitat exists in the project area.

North Coast semaphore grass
(Pleuropogon hooverianus)
—/—/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.

Nuttall's ribbon-leaved pondweed
(Potamogeton epihydrus)
—/—/2B.2 Pond None: No pond habitat exists in the
project area.

Oval-leaved viburnum
(Viburnum ellipticum)
—/—/2B.3 Chaparral None: No chaparral habitat exists in the project area.
1641
12 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Pacific gilia
(Gilia capitata ssp. pacifica)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Pacific Grove clover
(Trifolium polyodon)
—/—/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

Pappose tarplant
(Centromadia parryi ssp. parryi)
—/—/1B.2 Grassland, wetland Low: Some grassland habitat exists in the project area.

Parry's rough tarplant
(Centromadia parryi ssp. rudisi)
—/—/4.2 Grassland Low: Some grassland habitat exists in the project area.

Pennell's bird's beak
(Cordylanthus tenuis ssp. capillaris)
FE/SR/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Perennial goldfields
(Lasthenia californica ssp. macrantha)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Peruvian dodder
(Cuscuta obtusiflora var.
glandulosa)
—/—/1B.2 Parasitic plant,
grassland, chaparral
Low: Some grassland habitat exists in
the project area.

Petaluma popcornflower
(Plagiobothrys mollis var. vestitus)
—/—/1A Coastal salt marsh None: No coastal salt marsh habitat exists in the project area.

Pink sand verbena
(Abronia umbellata var. breviflora)
—/—/1B.1 Coastal sand dune None: No sand dune habitat exists in the project area.

Pitkin Marsh lily
(Lilium pardalinum ssp.
pitkinense)
FE/SE/1B.1 Wetland None: No wetland habitat exists in the project area.

Pitkin Marsh paintbrush
(Castilleja uliginosa)
FE/SE/1A Wetland None: No wetland habitat exists in the project area.

Point Reyes checkerbloom
(Sidalcea calycosa ssp. rhizomata)
—/—/1B.2 Coastal salt marsh None: No salt marsh habiat exists in the project area.

Point Reyes salty bird's beak
(Chloropyron maritimum ssp. palustre)
—/—/1B.2 Coastal salt marsh None: No salt marsh habitat exists in the project area.

Purple-stemmed checkerbloom
(Sidalcea malviflora spp. purpurea)
—/—/1B.2 Wetland None: No wetland habitat exists in the project area.

Pygmy cypress
(Hesperocyparis pygmaea)
—/—/1B.2 Hardpan soil None: No hardpan forest habitat exists in the project area.

Raiche's manzanita
(Arctostaphylos stanfordiana ssp. raichei)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Raiche's red ribbons
(Clarkia concinna spp. raichei)
—/—/1B.1 Coastal scrub None: No coastal scrub habitat exists in the project area.

Redwood lily
(Lilium rubescens)
—/—/4.2 Chaparral, forest None: No chaparral habitat exists in the project area.

Rincon Ridge ceanothus
(Ceanothus confusus)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.
1642
13 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Rincon Ridge manzanita
(Arctostaphylos stanfordiana
ssp. decumbens)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Rose leptosiphon
(Leptosiphon rosaceus)
—/—/1B.1 Coastal scrub None: No coastal scrub habitat exists in the project area.

Round-headed beaked rush
(Rhynchospora globularis)
—/—/2B.1 Wetland, riparian None: No wetland habitat exists in the project area.

Round-headed Chinese houses
(Collinsia corymbosa)
—/—/1B.2 Coastal grassland None: No coastal grassland habitat exists in the project area.

Round-leaved filaree
(California macrophylla)
—/—/1B.2 Foothill grassland Low: Some grassland habitat exists in the project area.

Saline clover
(Trifolium hydrophilum)
—/—/1B.2 Wetland, riparian None: No potential wetland habitat exists in the project area.

San Antonio Hills monardella
(Monardella antonina ssp. antonina)
—/—/3.0 Chaparral None: No chaparral habitat exists in
the project area.

San Francisco spineflower
(Chorizanthe cuspidata var. cuspidata)
—/—/1B.2 Coastal sand dunes None: No coastal sand dune habitat exists in the project area.

San Joaquin spearscale
(Extriplex joaquinana)
—/—/1B.2 Alkali scrub,
grassland
Very Low: Some grassland habitat
exists in the project area.

Santa Cruz clover
(Trifolium buckwestiorum)
—/—/1B.1 Wetland, grassland Very Low: Some grassland habitat exists in the project area.

Santa Cruz microseris
(Stebbinsoseris decipiens)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Santa Cruz tarplant
(Holocarpha macradenia)
FT/SE/1B.1 Coastal grassland None: No coastal grassland habitat exists in the project area.

Santa Rosa horkelia
(Horkelia tenuiloba)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Seaside bittercress
(Cardamine angulata)
—/—/2B.2 Forest, riparian None: No forest habitat exists in the project area.

Sebastopol meadowfoam
(Limnanthes vinculans)
FE/SE/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.

Serpentine cryptantha
(Cryptantha dissita)
—/—/1B.2 Serpentine chaparral None: No chaparral habitat exists in the project area.

Serpentine daisy
(Erigeron serpentinus)
—/—/1B.3 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Short-leaved evax
(Hesperevax sparsiflora var. brevifolia)
—/—/1B.2 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Slender Orcutt grass
(Orcuttia tenuis)
FT/SE/1B.1 Vernal pool None: No vernal pool habitat exists in the project area.
1643
14 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Small-flowered calycadenia
(Calycadenia micrantha)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Small groundcone
(Kopsiopsis hookeri)
—/—/2B.3 Redwood forest None: No redwood forest habitat exists in the project area.

Small spikerush
(Eleocharis parvula)
—/—/3.0 Woodland, chaparral None: No chaparral habitat exists in the project area.

Soft salty bird's beak
(Chloropyron molle ssp. molle)
FE/ST/1B.2 Coastal salt marsh None: No salt marsh habitat exists in the project area.

Sonoma alopecurus
(Alopecurus aequalis var.
sonomensis)
FE/—/1B.1 Wetland, vernal pool None: No wetland habitat exists in the project area.

Sonoma beardtongue
(Penstemon newberryi var. sonomensis)
—/—/1B.3 Chaparral None: No chaparral habitat exists in the project area.

Sonoma ceanothus
(Ceanothus sonomensis)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Sonoma spineflower
(Chorizanthe valida)
FE/SE/1B.1 Coastal grassland Very Low: Some grassland habitat exists in the project area.

Sonoma sunshine
(Blennosperma bakeri)
FE/SE/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

St. Helena fawn lily
(Erythronium helenae)
—/—/4.2 Grassland, chaparral Very Low: Some grassland habitat exists in the project area.

Streamside daisy
(Erigeron biolettii)
—/—/4.2 Grassland, chaparral Very Low: Some grassland habitat exists in the project area.

Suisun marsh aster
(Symphyotrichum lentum)
—/—/1B.2 Freshwater and
brackish marsh
None: No marsh habitat exists in the
project area.

Supple daisy
(Erigeron supplex)
—/—/1B.2 Coastal scrub None: No coastal scrub habitat exists in the project area.

Swamp harebell
(Campanula californica)
—/—/1B.2 Coastal grassland,
wetland
Very Low: Some grassland habitat exists
in the project area.

Tamalpais jewelflower
(Streptanthus batrachopus)
—/—/1B.3 Serpentine None: No serpentine habitat exists in the project area.

Tamalpais lessingia
(Lessingia micradenia var. micradenia)
—/—/1B.2 Grassland Low: Some grassland habitat exists in the project area.

Tamalpais oak
(Quercus parvula var. tamalpaisensis)
—/—/1B.3 Woodland None: No woodland habitat exists in the project area.

The Cedars fairy lantern
(Calochortus raichei)
—/—/1B.2 Hardpan chaparral None: No chaparral habitat exists in the project area.

The Cedars manzanita
(Arctostaphylos bakeri ssp. sublaevis)
—/—/1B.2 Hardpan chaparral None: No chaparral habitat exists in the project area.
1644
15 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Thin-lobed horkelia
(Horkelia tenuiloba)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Thurber's reed grass
(Calamagrostis crassiglumis)
—/—/2B.1 Coastal scrub, wetland None: No wetland habitat exists in the project area.

Tiburon buckwheat
(Eriogonum luteolum var. caninum)
—/—/1B.2 Serpentine grassland Very Low: No serpentine grassland exists in the project area.

Tiburon paintbrush
(Castilleja affinis var. neglecta)
FE/ST/1B.2 Serpentine grassland Very Low: No serpentine grassland exists in the project area.

Tracy's clarkia
(Clarkia gracilis ssp. tracyi)
—/—/4.2 Serpentine chaparral None: No serpentine grassland exists in the project area.

Two-carpellate western flax
(Hesperolinon bicarpellatum)
—/—/1B.2 Serpentine chaparral None: No serpentine chaparral exists in the project area.

Twig-like snapdragon
(Antirrhinum virga)
—/—/1B.1 Serpentine chaparral None: No serpentine habitat exists in the project area.

Two-carpellate western flax
(Hesperolinon bicarpellatum)
—/—/1B.2 Chaparral None: No chaparral habitat exists in the project area.

Two-fork clover
(Trifolium amoenum)
FE/—/1B.1 Grassland, wetland Very Low: Some grassland habitat exists in the project area.

Vine Hill ceanothus
(Ceanothus foliosus var.
vineatus)
—/—/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Vine Hill clarkia
(Clarkia imbricata)
FE/SE/1B.1 Chaparral, grassland Very Low: Some grassland habitat exists in the project area.

Vine Hill manzanita
(Arctostaphylos densiflora)
—/SE/1B.1 Chaparral None: No chaparral habitat exists in the project area.

Watershield
(Brasenia schreberi)
—/—/2B.3 Pond None: No pond habitat exists in the
project area.

Western leatherwood
(Dirca occidentalis)
—/—/1B.2 Woodland, chaparral None: No woodland habitat exists in the project area.

White-beaked rush
(Rhynchospora alba)
—/—/2B.2 Wetland, riparian None: No wetland habitat exists in the project area.

White-flowered rein orchid
(Piperia candida)
—/—/1B.2 Coniferous forest None: No coniferous forest habitat exists in the project area.

White-rayed pentachaeta
(Pentachaeta bellidiflora)
FE/SE/1B.1 Grassland Low: Some grassland habitat exists in the project area.

Wolly-headed gilia
(Gilia capitata ssp. tomentosa)
—/—/1B.1 Coastal grassland Very Low: No coastal grassland habitat exists in the project area.

Wolly-headed lessingia
(Lessingia hololeuca)
—/—/3.0 Forest, grassland Very Low: Some grassland habitat exists in the project area.
1645
16 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Wolly meadowfoam
(Limnanthes floccosa ssp. floccosa)
—/—/4.2 Vernal pool None: No wetland habitat exists in the project area.

Wolly spineflower
(Chorizanthe cuspidata var. villosa)
—/—/1B.2 Coastal sand dunes None: No sand dune habitat exists in the project area.

MOSSES, LICHENS & LIVERWORTS
Angel's hair lichen
(Ramalina thrausta)
—/—/2B.1 Forest, woodland None: No forest habitat exists in the project area.

Coastal triquetrella
(Triquetrella californica)
—/—/1B.2 Forest, woodland None: No forest habitat exists in the project area.

Elongate copper moss
(Mielichhoferia elongata)
—/—/4.3 Rock outcrops None: No rock outcrop habitat exists in the project area.

Koch's cord moss
(Entosthodon kochii)
—/—/1B.3 Forest, woodland None: No forest habitat exists in the project area.

Methuselah's beard lichen
(Dolichousnea longissima)
—/—/4.2 Forest, woodland None: No forest habitat exists in the project area.

Slender silver moss
(Anomobryum julaceum)
—/—/4.2 Rocky substrates in
forests
None: No forest habitat exists in the
project area.

Torren's grimmia
(Grimmia torenii)
—/—/1B.3 Forest, woodland None: No forest habitat exists in the project area.

HABITATS
Coastal & Valley Freshwater Marsh
(CVFM)
— — None: No marsh habitat exists in the
project area.

Coastal Brackish Marsh
(CVFM)
— — None: No brackish marshes exist in
the project area.

Northern Coastal Salt Marsh
(NCSM)
— — None: No salt marsh habitat exists in
the project area.

Northern Hardpan Vernal Pool
(NHVP)
— — None: No hardpan vernal pool habitat
exists in the project area.

Northern Vernal Pool
(NVP)
— — None: No vernal pool habitat exists in
the project area.

Serpentine Bunchgrass
(SBG)
— — None: No serpentine bunchgrass
habitat exists in the project area.

Sycamore Alluvial Woodland
(SAW)
— — None: No woodland habitat exists in the
project area.

Valley Needlegrass Grassland
(VNG)
— — Low: Some grassland habitat exists in
the project area.

Valley Oak Woodland
(VOW)
— — None: No valley oaks exist in the project
area.
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17 PINECREST ENVIRONMENTAL CONSULTING, INC.

Taxon Status1
Fed/State/CNPS
Habitat Potential to Occur Within the Project
Area
Valley Sink Scrub
(VSS)
— — None: No sink scrub habitat exists in the
project area.
1 Status:

Federal
FE = Federally Endangered Species
FT = Federally Threatened Species
State
SE = State Endangered Species
ST = State Threatened Species
SSC = California Species of Special Concern
CFP = California Fully Protected Species
CNPS (applies to plants only)
List 1B = plants considered rare, threatened, or endangered in California and elsewhere List 2B = plants rare, threatened or endangered in California, but more common elsewhere List 3 = plant is likely rare but more information is required List 4 = plants of limited distribution
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18 PINECREST ENVIRONMENTAL CONSULTING, INC.

Appendix B: Plant Species Observed Onsite
The following is a list of plant species generated based on knowledge of the species and habitats of Napa County by PEC staff, and from various State and Federal databases, as described in the Methods section, above. Special-status species, if any, are denoted with an asterisk (*).

Non-Native Plant Species:
bird's foot trefoil (Lotus corniculatus)
bishop's weed (Ammi majus)
black mustard (Brassica nigra)
bluegum (Eucalyptus globulus)
bristly ox-tongue (Helminthotheca echioides)
bull thistle (Cirsium vulgare)
bur clover (Medicago polymorpha)
cheeseweed (Malva parviflora)
chicory (Cichorium intybus)
common dandelion (Taraxacum officinale)
common groundsel (Senecio vulgaris)
crane's bill filaree (Erodium botrys)
curly dock (Rumex crispus)
false brome (Brachypodium distachyon)
fennel (Foeniculum vulgare)
field bindweed (Convolvulus arvensis)
field marigold (Calendula arvensis)
foxtail barley (Hordeum murinum)
Fuller's teasel (Dipsacus fullonum)
hairgrass (Aira caryophyllea)
hairy vetch (Vicia villosa)
Harding grass (Phalaris aquatica)
hedge parsley (Torilis arvensis)
Himalayan blackberry (Rubus armeniacus)
Italian ryegrass (Festuca perennis)
Italian thistle (Circium pycnocephalus)
Jersey cudweed (Pseudognaphalium luteoalbum)
narrowleaf cottonrose (Logfia gallica)
New Zealand flax (Phormium colensoi)
pennyroyal (Mentha pulegium)
pineapple weed (Matricaria discoidea)
poison hemlock (Conium maculatum)
prickly lettuce (Lactuca serriola)
purple star thistle (Centaurea calcitrapa)
red brome (Bromus madritensis)
reed fescue (Festuca arundinacea)
ribwort (Plantago lanceolata)
ripgut brome (Bromus diandrus)
rose clover (Trifolium hirtum)
scarlet pimpernel (Lysimachia arvensis)
seaside barley (Hordeum marinum)
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19 PINECREST ENVIRONMENTAL CONSULTING, INC.
sheep sorrel (Rumex acetocella)
shortpod mustard (Hirschfeldia incana)
shrubby germander (Teucrium fruticans)
smooth cat’s ear (Hypochaeris glabra)
soft chess (Bromus hordeaceous)
spring vetch (Vicia sativa)
sweet pea (Lathyrus latifolius)
tall flatsedge (Cyperus eragrostis)
weedy brome (Bromus caroli-henrici)
wild geranium (Geranium dissectum)
wild lettuce (Lactuca saligna)
wild oatgrass (Avena barbata)
wild radish (Raphanus sativa)
woolly grevillea (Grevillea lanigera)
yellow star thistle (Centaurea solstitialis)
Zorro fescue (Festuca myuros)
Native Plant Species:
blue-eyed grass (Sisyrinchium bellum)
bog rush (Juncus patens)
California poppy (Eschscholzia californica)
common madia (Madia elegans)
common yarrow (Achillea millefolium)
coyote brush (Baccharis pilularis)
hairy gumweed (Grindelia hirsutula)
ladies’ tobacco (Pseudognaphalium californicum)
meadow barley (Hordeum brachyantherum)
mountain dandelion (Agoseris heterophylla)
narrow-leaved miner's lettuce (Claytonia parviflora)
poison oak (Toxicodendron diversilobum)
saltgrass (Distichlis spicata)
slender tarweed (Madia gracilis)
toyon (Heteromeles arbutifolia)
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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR
FirstCarbon Solutions
Appendix D:

Cultural Resources Supporting Information
Appendix D contains sensitive information pertaining to cultural resources and has been withheld from public distribution pursuant to Public Resources Code, Sections 5097.9 and 5097.993.
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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR
FirstCarbon Solutions
Appendix E:

Geotechnical Report
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City of American Canyon—SDG Commerce 220 Distribution Center Project Draft EIR
FirstCarbon Solutions
Appendix F:

Phase I Environmental Site Assessment
1737

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1738
PREPARED FOR:

Stravinski Development Group
5950 Sherry Lane, Suite 480
Dallas, Texas 75225
and
First Carbon Solutions
250 Commerce, Suite 250
Irvine, California 92602
PREPARED BY:
2336 Mariner Square Drive Suite 500
Alameda, California 95401
April 27, 2023

PHASE I ENVIRONMENTAL SITE ASSESSMENT
SDG COMMERCE 220
1055 COMMERCE COURT

AMERICAN CANYON, CALIFORNIA
1739
ii

TABLE OF CONTENTS

1.0 SUMMARY .............................................................................................................................................. 1

2.0 INTRODUCTION ..................................................................................................................................... 2

2.1 Purpose ............................................................................................................................................ 2

2.2 Detailed Scope of Services ............................................................................................................ 2

2.3 Significant Assumptions ................................................................................................................. 2

2.4 Limitations and Exceptions of Assessment .................................................................................... 3

3.0 SITE DESCRIPTION .............................................................................................................................. 5

3.1 Location and Legal Description ...................................................................................................... 5

3.2 Site and Vicinity Characteristics ..................................................................................................... 5

3.3 Current Uses of the Property .......................................................................................................... 5

3.4 Descriptions of Structures, Roads, and Other Improvements to the Site ....................................... 5

4.0 USER PROVIDED INFORMATION ........................................................................................................ 6

4.1 Title Records ................................................................................................................................... 6

4.2 Environmental Liens or Activity and Use Limitations ...................................................................... 6

4.3 Specialized Knowledge .................................................................................................................. 6

4.4 Commonly Known or Reasonably Ascertainable Information ........................................................ 6

4.5 Valuation Reduction for Environmental Issues ............................................................................... 6

4.6 Owner, Property Manager, and Occupant Information ................................................................... 7

4.7 Proceedings Involving the Property ................................................................................................ 7

4.8 Reason for Performing Phase I ESA .............................................................................................. 7

5.0 RECORDS REVIEW ............................................................................................................................... 8

5.1 Standard Environmental Record Sources and Other Ascertainable Records Sources ................. 8

5.2 Standard Environmental Record and Other Ascertainable Records Review ............................... 15

5.3 Vapor Encroachment Condition Summary ................................................................................... 17

5.4 Unmappable Sites ........................................................................................................................ 18

5.5 Additional Environmental Record Sources ................................................................................... 18

5.6 Physical Setting Sources .............................................................................................................. 18

5.7 Historical Use Information ............................................................................................................ 19 1740
iii

5.8 Historical Use Information on Adjoining Properties ...................................................................... 25

6.0 SITE RECONNAISSANCE ................................................................................................................... 27

6.1 Methodology and Limiting Conditions........................................................................................... 27

6.2 General Site Setting ..................................................................................................................... 27

6.3 Subject Property Observations ..................................................................................................... 28

7.0 INTERVIEWS ........................................................................................................................................ 29

7.1 Site Owner/Occupants .................................................................................................................. 29

7.2 Past Owners, Operators, Occupants ............................................................................................ 29

7.3 User .............................................................................................................................................. 29

7.4 State and/or Local Government officials ...................................................................................... 29

8.0 FINDINGS AND CONCLUSIONS ........................................................................................................ 30

9.0 DEVIATIONS ........................................................................................................................................ 31

10.0 REFERENCES.................................................................................................................................... 32

11.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL ................................................................... 34

12.0 ENVIRONMENTAL PROFESSIONAL STATEMENT ........................................................................ 35

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FIGURES
FIGURE 1: Site Vicinity Map
FIGURE 2: Property Map

APPENDICES
APPENDIX A: Photographs
APPENDIX B: User Questionnaire
APPENDIX C: Government Records Report
APPENDIX D: Historical Research Documentation
APPENDIX E: Interview Documentation
APPENDIX F: Professional Qualifications
1742
1 1.0 SUMMARY
Cameron-Cole, LLC (Cameron-Cole) has completed a Phase I Environmental Site Assessment (ESA) for the

10.17-acre property located at 1055 Commerce Court, American Canyon, Napa County, California, hereinafter referred to as the “property”, “subject property”, or “SP”. The assessment was performed in accordance with the Master Environmental Services Agreement between Cameron-Cole, LLC and First Carbon Solutions (FCS) dated January 20, 2023, and authorized by Ms. Mary Bean on January 23, 2023.

The scope of services conforms to the scope and limitations of the American Society for Testing and Materials International (ASTM International) Standard Practice for Environmental Site Assessments, Designation:

E1527-21. The purpose of this Phase I ESA is to identify, to the extent feasible pursuant to the ASTM International Standard E1527-21, recognized environmental conditions (RECs) in connection with the subject property.

According to records maintained by the Napa County Assessor’s office, the subject property is associated with assessor parcel number (APN) 058-030-069. The subject property is an undeveloped 10.17-acre parcel located at 1055 Commerce Court, American Canyon, Napa County, California. The subject property is currently owned by the Stravinski Development Group.

The goal of this Phase I ESA is to identify the presence or likely presence of hazardous substances or petroleum products on the subject property under conditions that indicate an existing release, a past release, or a material threat of release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water on the property. The findings of this report are summarized below and may include known or suspected RECs, Controlled Recognized Environmental Conditions (CRECs), Historical Recognized Environmental Conditions (HRECs), Vapor Encroachment Conditions (VECs), or Business Environmental Risks (BERs) identified during the performance of this Phase I ESA.

There were no RECs, CRECs, HRECS, VECs, or BERs identified at the subject property at the time of this report.
1743
2 2.0 INTRODUCTION

2.1 Purpose
Cameron-Cole performed a Phase I ESA for the 10.17-acre property located at 1055 Commerce Court, American Canyon, Napa County, California in accordance with the Master Environmental Services Agreement between Cameron-Cole, LLC and First Carbon Solutions (the User) on behalf of the Stravinski Development Group (the Owner). The assessment was conducted in general conformance with the ASTM International Standard E1527-21 Standard Practice for Environmental Site Assessments. This ESA was designed to identify, to the extent feasible, the presence or likely presence of RECs in connection with the property.

The purpose of this Phase I ESA is to allow the “User” to benefit from one of the defenses referenced in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) liability: the innocent landowner defense, the contiguous property owner defense, or bona fide prospective purchaser defense. These defenses are collectively referred to as the “landowner liability protections,” or “LLPs”.

ASTM International Standard E1527-21 constitutes “all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice” as defined at 42 U.S.C. §9601(35)(B). Cameron-Cole considers FCS to be the Client and “User” of this report.

The goal of this Phase I ESA is to identify RECs in connection with the subject property consistent with ASTM International Standard E1527-21. A REC is defined as:
1) the presence of hazardous substances or petroleum products in, on, or at the subject property due to a release to the environment; 2) the likely presence of hazardous substances or petroleum products in, on, or at the subject property due to a release or likely release to the environment; or 3) the presence of hazardous substances or petroleum products in, on, or at the subject property under conditions that pose a material threat of a future release to the environment.

2.2 Detailed Scope of Services
This Phase I ESA was conducted in accordance with and the Master Environmental Services Agreement between Cameron-Cole, LLC and First Carbon Solutions and authorized by Ms. Mary Bean on January 23, 2023. The scope of services consists of completing a Phase I ESA in general accordance with ASTM International Standard E1527-21 and the Scope of Services specified in the Master Agreement.

2.3 Significant Assumptions
Historical resources, personal interviews, and federal and state agency files regarding site operations and past historical use have been considered when presenting Cameron-Cole’s findings and opinions. CameronCole considers all information provided by our environmental database subcontractor regarding regulatory status of facilities to be current, accurate, and complete. Although Cameron-Cole made no independent investigation as to the accuracy and completeness of other information derived from secondary sources, Cameron-Cole assumes such information is reliable and representative of site conditions.

1744
3 2.4 Limitations and Exceptions of Assessment

2.4.1 Site-Specific Limitations
Subsurface investigations were not conducted as part of this assessment.

2.4.2 Data Gaps
A data gap is a lack of, or inability to, obtain information required by ASTM International Standard E1527-21 despite good faith efforts to gather such information. Data gaps may result from incompleteness in any of the activities required by ASTM International Standard E1527-21. According to the ASTM International Standard Practice E1527-21, data gaps are only significant if “other information and/or professional experience raise reasonable concerns involving the data gap.” As of the date of this report, Cameron-Cole has not received documents pertaining to historic releases on the site from the County of Napa. In the opinion of Cameron-Cole, this gap does not represent a “significant” data gap as additional information was identified through on-line available sources and on-property observations.

2.4.3 General Limitations and Exceptions
The Phase I ESA is produced in accordance with customary principles and practices in the applicable fields of environmental science and engineering. Cameron-Cole is not responsible for conclusions, opinions, or recommendations made by others based upon the information presented herein.

Although industry standard practices are employed, Phase I ESAs are inherently limited, given that findings and conclusions are developed from limited site evaluation and research. In performing a Phase I ESA, Cameron-Cole can only rely upon those records regarding the subject property and surrounding properties which are available to the public and which can reasonably be obtained by Cameron-Cole. Cameron-Cole's opinions, conclusions and recommendations are therefore limited to those which can be derived from such available and reasonably obtainable records. It is often necessary for Cameron-Cole to rely on information prepared or obtained by others in order to complete the Phase I ESA. Cameron-Cole makes no warranty or representation as to the accuracy or completeness of information obtained from third parties. Additionally, changes may result with the passage of time with respect to characteristics of the subject property and those of surrounding properties. Cameron-Cole and its representatives do not warrant for or against future changes in operations or conditions, nor do they warrant for or against conditions present of a type or at a location not specifically addressed in the Phase I ESA.

Subject to the limitations stated herein, the opinions presented in Phase I ESAs are valid for a period of 180 days from the date of issuance.

Air, soil, and groundwater testing are not part of the Phase I ESA Report. This Phase I ESA is not intended to establish whether air, soil, or groundwater contamination, or waste disposal is present or not present on the subject property or on surrounding properties. Knowledge of actual environmental conditions on the subject property or on any surrounding properties can only be obtained from air, soil, and groundwater testing, the installation of groundwater monitoring wells, and possible additional testing, all of which are outside the scope of the Phase I ESA.

Reasonable efforts were made within the scope of the Phase I ESA to identify the presence of underground storage tanks (USTs), aboveground storage tanks (ASTs), and ancillary equipment on or near the subject property. Limitations to the Phase I ESA exist regarding USTs and ASTs, in as much as information was 1745
4 obtained by Cameron-Cole solely through its review of unobstructed and readily accessible areas, database information, and interviews. Such methods (which are considered industry standard) do not preclude the actual presence of subsurface equipment (including USTs) or regulated materials that are hidden from view due to historical activity such as site paving, re-grading, construction, or debris pile storage. Similarly, it is possible that additional UST facilities not listed in regulatory database files may exist at the subject property or on properties adjacent to the subject property due to owner/operator registration negligence, filing errors with the state regulatory agency or other reasons over which Cameron-Cole has no control or ability to determine.

Conclusions in the Phase I ESA regarding potential environmental impacts of properties and facilities surrounding the subject property are based upon reasonably available information obtained from environmental databases and inferred groundwater flow direction.

No environmental assessment can wholly eliminate uncertainty regarding the potential for RECs in connection with a property. Performance of a Phase I ESA is solely intended to reduce, but not eliminate, uncertainty regarding the potential for RECs in connection with the subject property, and this practice recognizes reasonable limits of time and cost. The Phase I ESA has been prepared for the exclusive use and benefit of FCS subject to the terms and conditions specified in the Master Environmental Services Agreement between Cameron-Cole, LLC. and FCS. The Phase I ESA is for the sole and exclusive use and benefit of FCS, our client. Cameron-Cole makes no warranty as to the Phase I ESA except as to FCS’s exclusive use of the Phase I ESA. The Client bears the sole responsibility for ensuring that the Phase I ESA is distributed or disseminated to only those third parties to whom FCS is strictly obligated by contract, law, regulation, or ordinance to provide it. Cameron-Cole disclaims any and all liability to any person or entity other than FCS who uses or relies on the Phase I ESA in any way whatsoever without the express written consent of both FCS and Cameron-Cole.

Third-party reliance letters may be issued upon request and upon payment of the then current fee for such letters, and only if Cameron-Cole and FCS provide express written consent for any such reliance letters. 1746
5 3.0 SITE DESCRIPTION

3.1 Location and Legal Description
The subject property is located at 1055 Commerce Court, American Canyon, Napa County, California. A Site Vicinity Map is provided as Figure 1 and a Property Map is provided as Figure 2. According to records maintained by the Napa County Assessor’s office, the subject property is associated with APN 058-030-69.

3.2 Site and Vicinity Characteristics
The subject property consists of one parcel with surface area totaling 10.17 acres. The subject property is undeveloped and is surrounded by a warehouse to the south and undeveloped land to the north and west.

The adjoining property east is used as a rural residential and outdoor recreational paintball facility. The warehouse on the adjoining property south, 1005 Commerce Court, contains Valley Wine Warehouse, Boissett Collection, Wine Direct, and Western Wine Services.

3.3 Current Uses of the Property
The subject property is currently undeveloped land.

3.4 Descriptions of Structures, Roads, and Other Improvements to the Site The property can be accessed from Commerce Court which adjoins the eastern property boundary. The majority of the subject property is undeveloped with natural vegetation. There are no structures currently on the subject property. Temporary structures were formerly located on the southeastern corner of the site (see historical review Section 5.7). The area has been cleared of vegetation and gravel pathways remain in the area. Additionally, two stormwater drains are located on the subject property along Commerce Court. 1747
6 4.0 USER PROVIDED INFORMATION
For the User to qualify for one of the LLPs offered by the Small Business Liability Relief and Brownfields Revitalization Act of 2001, Section 6 of ASTM International Standard E1527-21 requires the User to provide the environmental professional (EP) the following information:
• The existence of environmental cleanup liens;
• Activity and Use Limitations (AULs) recorded against the subject property; • Specialized knowledge or experience of the User;
• Relationship of the purchase price to the fair market value of the property if it were not contaminated; • Commonly known or reasonably ascertainable information about the subject property; and • The degree of obviousness of the presence of contamination at the subject property.

A User Questionnaire was completed by Ms. Janna Waligorski Hudson, Senior Project Manager, FCS, on March 28, 2023 (Appendix B).

4.1 Title Records
A historical chain-of-title report and an environmental lien report were not provided by the User or obtained and reviewed by Cameron-Cole as part of the approved scope of services for this project. The property is owned by the Stravinski Development Group (SDG).

4.2 Environmental Liens or Activity and Use Limitations Ms. Hudson indicated via a completed User Questionnaire that she was not aware of any environmental liens or AULs, such as engineering controls, land use restrictions, and institutional controls that have been filed or recorded on the subject property.

4.3 Specialized Knowledge
Ms. Hudson indicated she does not possess specialized knowledge or experience that is material to RECs in connection with the subject property.

4.4 Commonly Known or Reasonably Ascertainable Information Ms. Hudson was asked to provide any commonly known or reasonably ascertainable information within the local community about the subject property that is material to RECs in connection with the subject property.

She indicated that she was not aware of any information regarding the subject property.

Ms. Hudson stated on the questionnaire the Final Initial Study for the SDG Commerce 330 Warehouse project dated January 2019 included the subject property. She stated that the study referenced a Phase I ESA prepared by ATC and dated June 2018 which also included the subject property. Ms. Hudson provided the Final Initial Study for the SDG Commerce 330 Warehouse Project, Grassetti Environmental Consulting, January 2019 and the Geotechnical Engineering Investigation, Proposed SDG Commerce 224 (Draft), Krazan & Associates, Inc., January 18, 2021. Ms. Hudson stated she did not have access to the Phase I ESA prepared by ATC in 2018.

4.5 Valuation Reduction for Environmental Issues
Ms. Hudson indicated she was not involved in the purchase of the property. 1748
7 4.6 Owner, Property Manager, and Occupant Information According to Ms. Hudson, there are no current occupants of the subject property.

4.7 Proceedings Involving the Property
Ms. Hudson indicated that she is unaware of any proceedings regarding the subject property.

4.8 Reason for Performing Phase I ESA
Ms. Hudson indicated via a User Questionnaire completed on March 28, 2023, that the reason for performing the Phase I ESA is to satisfy one of the requirements for the innocent landowner defense under CERCLA and to understand potential environmental conditions that could materially impact the operation of the business associated with the parcel of commercial real estate. 1749
8 5.0 RECORDS REVIEW

5.1 Standard Environmental Record Sources and Other Ascertainable Records Sources Envirosite provided Cameron-Cole with a comprehensive government agency information search in accordance with ASTM International Standard E1527-21. The regulatory search information and a legend of the database acronyms are presented as Appendix C, Regulatory Agency Search Report Maps depicting properties listed in the various databases searched by Envirosite are also provided. The table below provides a summary of the identified standard (ASTM required) federal, state, tribal, and local environmental database records reviewed along with each record’s approximate minimum search distance (AMSD) from the subject property.

STANDARD ENVIRONMENTAL DATABASE RECORD SUMMARY

DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile
TOTAL
MAPPED

FEDERAL RCRA NON-CORRACTS TSD FACILITIES LIST
ARCHIVED RCRA TSDF 0.500 0 0 0 -- -- 0
RCRA_TSDF 0.500 0 0 0 -- -- 0

FEDERAL, STATE, AND TRIBAL REGISTERED STORAGE TANK LISTS AST PBS 0.250 0 0 -- -- -- 0
EPA UST 0.250 0 0 -- -- -- 0
FEMA UST 0.250 0 0 -- -- -- 0
HIST INDIAN UST R7 0.250 0 0 -- -- -- 0
AST - CA 0.250 0 0 -- -- -- 0
FID UST - CA 0.250 0 0 -- -- -- 0
HIST AST - CA 0.250 0 0 -- -- -- 0
HIST UST - CA 0.250 0 0 -- -- -- 0
UST - CA 0.250 0 0 -- -- -- 0
UST_NAPA COUNTY - CA 0.250 0 0 -- -- -- 0

FEDERAL CERCLIS LIST
CERCLIS NFRAP 0.500 0 0 1 -- -- 1
CERCLIS-HIST 0.500 0 0 0 -- -- 0
EPA SAA 0.500 0 0 0 -- -- 0
FEDERAL FACILITY 1.000 0 0 0 0 -- 0
SEMS_8R_ACTIVE SITES 0.500 0 0 0 -- -- 0
SEMS_8R_ARCHIVED
SITES 0.500 0 0 1 -- -- 1

FEDERAL RCRA CORRACTS FACILITIES LIST
CORRACTS 1.000 0 0 0 0 -- 0
HIST CORRACTS 2 1.000 0 0 0 0 -- 0
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9 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile
TOTAL
MAPPED

FEDERAL DELISTED NPL SITE LIST
DELISTED NPL 1.000 0 0 0 0 -- 0

DELISTED PROPOSED
NPL 1.000 0 0 0 0 -- 0
SEMS_DELETED NPL 1.000 0 0 0 0 -- 0

FEDERAL LANDFILL AND/OR SOLID WASTE DISPOSAL SITES LISTS EPA LF MOP 0.500 0 0 1 -- -- 1

FEDERAL, STATE, AND TRIBAL LEAKING STORAGE TANK LISTS
EPA LUST 0.500 0 0 0 -- -- 0
HIST INDIAN LUST R4 0.500 0 0 0 -- -- 0
HIST INDIAN LUST R8 0.500 0 0 0 -- -- 0
LUST REG 1 - CA 0.500 0 0 0 -- -- 0
LUST REG 2 - CA 0.500 0 0 0 -- -- 0
LUST REG 3 - CA 0.500 0 0 0 -- -- 0
LUST REG 4 - CA 0.500 0 0 0 -- -- 0
LUST REG 5 - CA 0.500 0 0 0 -- -- 0
LUST REG 6 - CA 0.500 0 0 0 -- -- 0
LUST REG 7 - CA 0.500 0 0 0 -- -- 0
LUST REG 8 - CA 0.500 0 0 0 -- -- 0
LUST REG 9 - CA 0.500 0 0 0 -- -- 0
SLIC REG 1 - CA 0.500 0 0 0 -- -- 0
SLIC REG 2 - CA 0.500 0 0 0 -- -- 0
SLIC REG 3 - CA 0.500 0 0 0 -- -- 0
SLIC REG 4 - CA 0.500 0 0 0 -- -- 0
SLIC REG 5 - CA 0.500 0 0 0 -- -- 0
SLIC REG 6 - CA 0.500 0 0 0 -- -- 0
SLIC REG 7 - CA 0.500 0 0 0 -- -- 0
SLIC REG 8 - CA 0.500 0 0 0 -- -- 0
SLIC REG 9 - CA 0.500 0 0 0 -- -- 0

FEDERAL ERNS LIST
ERNS SP 0 -- -- -- -- 0

FEDERAL INSTITUTIONAL CONTROLS / ENGINEERING CONTROLS REGISTRIES FED E C 0.500 0 0 0 -- -- 0
FED I C 0.500 0 0 0 -- -- 0
RCRA IC_EC 0.250 0 0 -- -- -- 0
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10 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile
TOTAL
MAPPED

FEDERAL RCRA GENERATORS LIST
HIST RCRA_CESQG 0.250 0 0 -- -- -- 0
HIST RCRA_LQG 0.250 0 0 -- -- -- 0
HIST RCRA_NONGEN 0.250 0 0 -- -- -- 0
HIST RCRA_SQG 0.250 0 0 -- -- -- 0
RCRA_LQG 0.250 0 0 -- -- -- 0
RCRA_NONGEN 0.250 0 1 -- -- -- 1
RCRA_SQG 0.250 0 0 -- -- -- 0
RCRA_VSQG 0.250 0 0 -- -- -- 0

FEDERAL NPL SITE LIST
NPL 1.000 0 0 0 0 -- 0
NPL EPA R1 GIS 1.000 0 0 0 0 -- 0
NPL EPA R3 GIS 1.000 0 0 0 0 -- 0
NPL EPA R6 GIS 1.000 0 0 0 0 -- 0
NPL EPA R8 GIS 1.000 0 0 0 0 -- 0
NPL EPA R9 GIS 1.000 0 0 0 0 -- 0
PART NPL 1.000 0 0 0 0 -- 0
PROPOSED NPL 1.000 0 0 0 0 -- 0
SEMS_FINAL NPL 1.000 0 0 0 0 -- 0
SEMS_PROPOSED NPL 1.000 0 0 0 0 -- 0

STATE- AND TRIBAL - EQUIVALENT CERCLIS
ENVIROSTOR - CA 1.000 0 0 0 2 -- 2
HIST TOXIC PITS - CA 1.000 0 0 0 0 -- 0
OIL & GAS CLEANUP - CA 0.500 0 0 0 -- -- 0
SWRCB CLEANUP - CA 0.500 0 0 0 -- -- 0
SWRCB NON_CASE - CA 0.500 0 0 0 -- -- 0
TOXIC PITS - CA 1.000 0 0 0 0 -- 0
STATE AND TRIBAL – EQUIVALENT NPL
HIST RESPONSE - CA 1.000 0 0 0 -- -- 0
RESPONSE - CA 1.000 0 0 0 -- -- 0

STATE AND TRIBAL LANDFILL AND/OR SOLID WASTE DISPOSAL SITE LISTS HIST SWF/LF - CA 0.500 0 0 0 -- -- 0
SWF/LF - CA 0.500 0 0 1 -- -- 1
1752
11 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile
TOTAL
MAPPED

STATE RCRA GENERATORS LIST
HWG - CA 0.250 0 1 -- -- -- 1

STATE AND TRIBAL BROWNFIELD SITES
TRIBAL BROWNFIELDS 0.500 0 0 0 -- -- 0

STATE AND TRIBAL VOLUNTARY CLEANUP SITES
VCP - CA 0.500 0 0 0 -- -- 0

LOCAL BROWNFIELD LISTS
BROWNFIELDS-ACRES 0.500 0 0 0 -- -- 0
FED BROWNFIELDS 0.500 0 0 0 -- -- 0

LOCAL LISTS OF LANDFILL / SOLID WASATE DISPOSAL SITES
FED CDL SP 0 -- -- -- -- 0
US HIST CDL SP 0 -- -- -- -- 0
CDL - CA SP 0 -- -- -- -- 0
CS_NAPA COUNTY - CA 0.500 0 0 0 -- -- 0
SCH - CA 0.250 0 0 -- -- -- 0

RECORDS OF EMERGENCY RELEASE REPORTS
HMIRS (DOT) SP 0 -- -- -- -- 0
CHMIRS – CA SP 0 -- -- -- -- 0
HIST CHMIRS – CA SP 0 -- -- -- -- 0

LOCAL LAND RECORDS
LIENS 2 SP 0 -- -- -- -- 0
DEED - CA 0.500 0 0 0 -- -- 0
HIST LIENS - CA SP 0 -- -- -- -- 0
LIENS - CA SP 0 -- -- -- -- 0

LOCAL LISTS OF LANDFILL / SOLID WASTE DISPOSAL SITES
ODI 0.500 0 0 0 -- -- 0
TRIBAL ODI 0.500 0 0 0 -- -- 0
HAULERS - CA 0.500 0 0 0 -- -- 0
SWRCY - CA 0.500 0 0 0 -- -- 0
SP = Subject property
Cameron-Cole also conducted a search of other ascertainable records related to the subject property and surrounding properties, where applicable. The table below provides a summary of the other ascertainable records reviewed along with each record AMSD from the subject property:
1753
12 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile TOTAL MAPPED
AFS SP 0 -- -- -- -- 0
ALT FUELING 0.250 0 0 -- -- -- 0
ARENAS SP 0 -- -- -- -- 0
ARENAS 2 SP 0 -- -- -- -- 0
BRS SP 0 -- -- -- -- 0
CDC HAZDAT 1.000 0 0 0 0 -- 0
CHURCHES SP 0 -- -- -- -- 0
COAL ASH DOE 0.500 0 0 0 -- -- 0
COAL ASH EPA 0.500 0 0 0 -- -- 0
COAL GAS 1.000 0 0 0 0 -- 0
COLLEGES SP 0 -- -- -- -- 0
COLLEGES 2 SP 0 -- -- -- -- 0
CONSENT (DECREES) 1.000 0 0 0 0 -- 0
CORRECTIVE ACTIONS_2020 0.500 0 0 0 -- -- 0
DAYCARE SP 0 -- -- -- -- 0
DEBRIS EPA LF 0.500 0 0 0 -- -- 0
DEBRIS EPA SWRCY 0.500 0 0 0 -- -- 0
DOD 1.000 0 0 0 0 -- 0
DOT OPS SP 0 -- -- -- -- 0
ECHO SP 0 -- -- -- -- 0
ENOI SP 0 -- -- -- -- 0
EPA FUELS SP 0 -- -- -- -- 0
EPA OSC SP 0 -- -- -- -- 0
EPA WATCH SP 0 -- -- -- -- 0
FA HWF SP 0 -- -- -- -- 0
FEDLAND 1.000 0 0 0 0 -- 0
FRS SP 0 -- -- -- -- 0
FTTS SP 0 -- -- -- -- 0
FTTS INSP SP 0 -- -- -- -- 0
FUDS 1.000 0 0 0 0 -- 0
GOV MANSIONS SP 0 -- -- -- -- 0
HIST AFS SP 0 -- -- -- -- 0
HIST AFS 2 SP 0 -- -- -- -- 0
HIST DOD 1.000 0 0 0 0 -- 0
HIST LEAD_SMELTER SP 0 -- -- -- -- 0
HIST MLTS SP 0 -- -- -- -- 0
HIST PCB TRANS SP 0 -- -- -- -- 0
HIST PCS ENF 1.000 0 0 0 0 -- 0
HIST PCS FACILITY 1.000 0 0 0 0 -- 0
HIST SSTS SP 0 -- -- -- -- 0
1754
13 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile TOTAL MAPPED
HOSPITALS SP 0 -- -- -- -- 0
ICIS SP 0 -- -- -- -- 0
INACTIVE PCS 1.000 0 1 5 12 -- 18
LUCIS 0.500 0 0 0 -- -- 0
LUCIS 2 0.500 0 0 0 -- -- 0
MANIFEST EPA 0.250 0 1 -- -- -- 0
MINE OPERATIONS 0.250 0 0 -- -- -- 0
MINES 0.250 0 0 -- -- -- 0
MINES USGS 0.250 0 0 -- -- -- 0
MLTS SP 0 -- -- -- -- 0
NPL AOC 1.000 0 0 0 0 -- 0
NPL LIENS SP 0 -- -- -- -- 0
NURSING HOMES SP 0 -- -- -- -- 0
OSHA SP 0 -- -- -- -- 0
PADS SP 0 -- -- -- -- 0
PCB TRANSFORMER SP 0 -- -- -- -- 0
PCS ENF 1.000 0 1 1 3 -- 5
PCS FACILITY 1.000 0 1 5 12 -- 18
PFAS NPL 0.500 0 0 0 -- -- 0
PFAS TRIS 0.500 0 0 0 -- -- 0
PFAS UCMR3 0.500 0 0 0 -- -- 0
PRISONS SP 0 -- -- -- -- 0
PRP SP 0 -- -- -- -- 0
RAATS SP 0 -- -- -- -- 0
RADINFO SP 0 -- -- -- -- 0
RMP 0.500 0 0 0 -- -- 0
ROD 1.000 0 0 0 0 -- 0
SCHOOLS PRIVATE SP 0 -- -- -- -- 0
SCHOOLS PUBLIC SP 0 -- -- -- -- 0
SCRD DRYCLEANERS 0.250 0 0 -- -- -- 0
SEMS_SMELTER SP 0 -- -- -- -- 0
SSTS SP 0 -- -- -- -- 0
STORMWATER SP 0 -- -- -- -- 0
TOSCA-PLANT SP 0 -- -- -- -- 0
TRIS SP 0 -- -- -- -- 0
UMTRA 0.500 0 0 0 -- -- 0
VAPOR 0.500 0 0 0 -- -- 0

BOND EXPENDITURE PLAN -
CA 1.000 0 0 0 0 -- 0
CALEPA SITES – CA 0.250 1 2 -- -- -- 3
CIWQS – CA SP 0 -- -- -- -- 0
1755
14 DATABASE SUBJECT

PROPERTY
SEARCH

DISTANCE
(Miles)
<1/8
Mile
1/8-1/4
Mile
1/4-1/2
Mile
1/2-1
Mile >1 Mile TOTAL MAPPED
CIWQS 2 – CA SP 0 -- -- -- -- 0
CORTESE – CA 0.500 0 0 0 -- -- 0
DAYCARE – CA SP 0 -- -- -- -- 0
DRYCLEANERS – CA SP 0 -- -- -- -- 0
DRYCLEANER_BAY AREA -
CA 0.250 0 0 -- -- -- 0
EMI – CA SP 0 -- -- -- -- 0
FA - CA SP 0 -- -- -- -- 0
FA 2 - CA SP 0 -- -- -- -- 0
FIRE AREAS – CA 1.000 0 0 0 0 -- 0
HAZNET - CA 0.250 0 1 -- -- -- 1
HIGH FIRE -CA 1.000 0 0 0 0 -- 0
HIST CORTESE – CA 0.500 0 0 0 -- -- 0
HIST HAZNET - CA 0.250 0 0 -- -- -- 0
HIST HWP - CA 1.000 0 0 0 0 -- 0
HIST LDS - CA 0.500 0 0 0 -- -- 0
HIST MCS - CA 1.000 0 0 0 0 -- 0
HIST NFA - CA 0.500 0 0 0 -- -- 0

HWM-COMMERCIAL
FACILITIES - CA 0.250 0 0 -- -- -- 0
HWP - CA 1.000 0 0 0 0 -- 0
HWT - CA 0.250 0 0 -- -- -- 0
LDS - CA 0.500 0 0 0 -- -- 0
MCS - CA 1.000 0 0 0 0 -- 0
MWMP - CA 0.250 0 0 -- -- -- 0
MWMP 2 - CA 0.250 0 0 -- -- -- 0
NFA - CA 0.500 0 0 0 -- -- 0
NFE - CA 0.500 0 0 0 -- -- 0
NPDES - CA SP 0 -- -- -- -- 0
PERCHLORATE 2 - CA 0.500 0 0 0 -- -- 0
PFAS - CA 0.500 0 0 0 -- -- 0
PFAS DOD - CA 0.500 0 0 0 -- -- 0
PFAS GAMA - CA 0.500 0 0 0 -- -- 0
PROPOSITION 65 - CA 1.000 0 0 0 0 -- 0
RFR - CA SP 0 -- -- -- -- 0
SWAT - CA SP 0 -- -- -- -- 0
WDR - CA SP 0 -- -- -- -- 0
WDS - CA SP 0 -- -- -- -- 0
WILDLANDS – CA 1.000 0 0 0 0 -- 0
WIP - CA 0.250 0 0 -- -- -- -- 0
SEISMIC - CA 1.000 0 0 0 1 4 -- 5
SP = Subject property
1756
15 5.2 Standard Environmental Record and Other Ascertainable Records Review The following discussion provides a review of results from the standard environmental records and other ascertainable records search with respect to the subject property as well as the adjacent or nearby properties. Per the discretion of the EP, some results may be omitted from this review if they are interpreted to be not of environmental significance based on threat of a material release, distance from the subject property, lower topographic elevations, and interpreted groundwater flow direction. The complete Envirosite report is included as Appendix C and contains all points of interest that were identified within the AMSD.

SUBJECT PROPERTY
The subject property was not identified in any of the standard or other ascertainable records databases searched.

Through the review of historical sources (2018 Phase I ESA by ATC), Cameron-Cole identified that the property at 2 Eucalyptus Drive was listed in the NPDES and the Napa County LUST databases. This property historically included the subject property until approximately 2012. In 1990, the property was inspected by Napa County officials. Two 10,000-gallon USTs, one 3,000-gallon UST, 55-gallon drums, and hazardous materials were observed in the eastern section of the property, which is currently the adjoining property east of the subject property. These items have since been removed from the adjoining property east. Through the review of the prior Phase I and Phase II ESAs (Section 5.7.8) conducted on the property, Cameron-Cole does not consider the historic listing of 2 Eucalyptus Drive in these databases to be an environmental threat to the subject property.

Adjacent and Nearby Off-Site Properties within the AMSD The following provides a summary of relevant identified off-site points of interest with respect to interpreted groundwater flow direction which is inferred to flow west (see Sections 5.6.1 and 6.2.1).

South (cross-gradient)
The SDG Commerce 330 Warehouse site is located on the adjoining property south, 420 feet crossgradient from the subject property, and is listed in the CALEPA SITES – CA, CIWQS – CA, NPDES – CA, and RFR - CA databases.
- The description provided for the site in the CALEPA SITES – CA database references “construction storm water.” No violations are listed for the site in the database. - The CIWQS – CA database lists this site as the Commerce Blvd Pipeline Project. No violations are listed for the site in the database.
- The NPDES – CA database lists the site in the construction program and the status is listed as terminated. No violations are listed for the site in the database. - The RFR – CA database lists the site as an active storm water construction site. No violations are listed for the site in the database.

This site does not appear to present an environmental threat to the subject property. 1757
16 The Napa Junction Elementary School Project, located 1,229 feet southeast and cross-gradient from the subject property, is listed in the CALEPA SITES – CA, CIWQS – CA, CIWQS 2 – CA, and RFR - CA databases.
- The CALEPA SITES – CA database lists this site as a “Wetlands – Fill and Dredge Material”.

Violations are not listed in the database.
- This site is listed in the CIWQS - CA database and no violations are listed for the site in the database.
- This site is listed in the CIWQS 2 - CA database and no violations are listed for the site in the database. The site is listed as a dredge/fill site.
- This site is listed in the RFR – CA database and no violations are listed for the site in the database. The site is listed as a dredge/fill site.

This site does not appear to present an environmental threat to the subject property.

The remaining sites located south of the subject property listed in the database search are located between ¼ and ½ mile south of the subject property. After review of the database listings, these sites do not appear to present an environmental threat to the subject property.

West (downgradient)
The American Canyon Wastewater Treatment Facility site is located at 151 Mezzetta Court, 1,021 feet down gradient from the subject property, and is listed in the CALEPA SITES – CA, CHMIRS – CA, CIWQS – CA, CIWQS 2 – CA, DOCKET, ECHO, EMI – CA, FRS, HAZNET – CA, HWG – CA, ICIS, INACTIVE PCS, MANIFEST EPA, NPDES – CA, PCS ENF, PCS FACILITY, RCRA_NONGEN, RFR - CA databases.
- The CALEPA SITES- CA database lists this site with the descriptions “US EPA Air Emissions Inventory System”, “Waste Discharge Requirements”, “Forestry & Silviculture”, and “Chemical Storage Facilities.” The site is a sewage treatment facility. Violations were not listed in this database for the site.
- The CHMIRS – CA database description states that “valves were left open on the affluent pond which resulted in the release of approximately 10,000 gal of raw sewage which was released into a tributary of the Napa River. Release is contained but unrecoverable.” The incident date was February 10, 2014.
- This site is listed in the CIWQS – CA database as the American Canyon Water Recycling Program site. Violations were not listed in this database for the site. - This site is listed in the CIWQS 2 – CA again as the American Canyon Water Reclamation Facility. Violations were not listed in this database for the site. - The DOCKET database lists the site with the Enforcement Action Case Number, CA-200018545. - This site is listed in the ECHO database. The database indicates that the no violations are identified.
1758
17 - This site is listed in the EMI - CA database. The database indicates that the site is in the San Francisco Bay Area Air Basin.
- This site is listed in the FRS database and no violations are listed for the site in the database. - This site is listed in the HAZNET - CA database and no violations are listed for the site in the database.
- This site is listed in the HWG - CA database and no violations are listed for the site in the database.
- This site is listed in the ICIS database and no violations are listed for the site in the database. - This site is listed in the INACTIVE PCS database. The site has a NPDES Individual Permit. The permit status is expired. No violations are listed for the site in the database. - This site is listed in the MANIFEST EPA database and no violations are listed for the site in the database.
- This site is listed in the NPDES - CA database and no violations are listed for the site in the database.
- This site is listed in the PCS ENF database. The ENF type is listed as a State Clean Water Act Penalty.
- This site is listed in the PCS FACILITY database. The site has a NPDES Individual Permit. The permit status is effective. No violations are listed for the site in the database. - This site is listed in the RCRA_NONGEN database and no violations are listed for the site in the database.
- This site is listed in the RFR - CA database and no violations are listed for the site in the database.

Based on a review of the available database details, the downgradient direction, and distance to the subject property, this site does not appear to present an environmental threat to the subject property.

North (cross-gradient)
No properties were identified in the database searches within ¼ mile north of the subject property. The facilities listed within ¼ and ½ mile north of the subject property do not appear to present an environmental threat to the subject property.

East (upgradient)
No properties were identified in the database searches within ½ mile east of the subject property. The facilities listed within ½ and 1 mile east of the subject property do not appear to present an environmental threat to the subject property.

5.3 Vapor Encroachment Condition Summary
Cameron-Cole conducted a review of available environmental records and conditions observed on the subject property and adjoining parcels to evaluate the potential for a VEC to exist on the subject property. Cameron1759 18 Cole did not identify on-property or off-property land/business uses conducive to a VEC impact to the subject property.

5.4 Unmappable Sites
The Envirosite Report (Appendix C) includes a summary of identified points of intertest that may be in the general area of the subject property; yet do not have adequate location addresses or latitude/longitude coordinates to pinpoint their exact location in relation to the subject property. No unmappable sites were reported in the database search.

5.5 Additional Environmental Record Sources

5.5.1 County Property Assessor/Appraiser
According to records maintained by the Napa County Assessor’s office, the subject property is identified by APN 058-030-069. These records do not identify buildings associated with the subject property.

5.5.2 Fire/Police officials
Cameron-Cole contacted the American Canyon Fire Protection District on March 24, 2023, requesting records pertaining to fires or responses to incidents, spills, or releases of hazardous substances or petroleum products at, or in the immediate vicinity of the property. Martha Banuelos responded on behalf of the American Canyon Fire Protection District and stated that, “The Fire District does not maintain environmental records on properties.”

5.5.3 Other Record Sources
Cameron-Cole contacted the County of Napa Environmental Health Division on March 24, 2023, requesting records regarding environmental violations, releases, or hazardous material or petroleum product storage, storage tanks, or other environmental concerns associated with the subject property. A public records request was submitted to the County of Napa Public Records Department. No response has been received as of the date of this report.

5.6 Physical Setting Sources

5.6.1 Topography
Figure 1 is a Site Vicinity Map which includes information from the 2021 USGS 7.5 Minute Series, Cuttings Warf quadrangle. The map was reviewed to establish the physical setting of the subject site and surrounding area. The site lies approximately 19 feet above mean sea level and generally slopes to the west.

5.6.2 Soils/Geology
The Envirosite report provides a summary of the United States Department of Agriculture (USDA) Soil Survey of the subject property's general area. According to the Envirosite Report, the Clear Lake and Haire series are the primary soil types in the area. The Clear Lake series is a poorly drained clay with high corrosion potential. The Haire series is a moderately well drained clay loam with high corrosion potential. According to California GeoTracker, geology beneath the site is identified as Pleistocene-aged, older alluvium, lake, playa and terrace deposits.

5.6.3 Hydrology
Based on topographic maps, and considering regional flow patterns, the groundwater flow in the vicinity of the site is inferred to be to the west. It must be noted that groundwater flow direction can be influenced by factors such as surface topography, underground structures, seasonal fluctuation, soil and bedrock geology, 1760
19 and production wells which were not considered in this interpretation.

5.7 Historical Use Information
Available historical resources were consulted to develop a history of the previous uses of the property to help identify the likelihood of past uses having led to RECs in connection with the property. Copies of the aerial photographs, historical topographic maps, Fire Insurance Maps, and City Directory Report are provided in Appendix D.

5.7.1 Aerial Photographs
Envirosite provided aerial photographs which depict the subject property for the years 1937, 1948, 1957, 1958, 1965, 1966, 1968, 1970, 1971, 1973, 1975, 1982, 1983, 1985, 1988, 1989, 1993, 1996, 1998, 2005, 2009, 2010, 2012, 2014, 2016, 2018, and 2020. These photographs are included in Appendix D.

Date: 1937
Scale: 1” = 500’
Subject Property: The subject property appears to be used agriculturally.

Adjoining North: The property appears to be undeveloped land with a grove of trees.

Adjoining East: The property appears to be used agriculturally.

Adjoining South: The property appears to be to be used agriculturally.

Adjoining West: The property appears to be to be used agriculturally.

Surrounding Area: The surrounding area is mixed undeveloped and agricultural land.

Date: 1948 through 1958
Scale: 1” = 500’
Subject Property: The subject property appears to be undeveloped land with a grove of trees.

Adjoining North: The property appears to be undeveloped land with a grove of trees.

Adjoining East: The property appears to be undeveloped land with a grove of trees.

Adjoining South: The property appears to be undeveloped land with a grove of trees.

Adjoining West: The property appears to be undeveloped land with a grove of trees.

Surrounding Area: The surrounding area is mainly undeveloped land.

Date: 1965
Scale: 1” = 500’
Subject Property: The subject property appears to be undeveloped land with a grove of trees.

Adjoining North: The property is partially cleared and partially with trees.

Adjoining East: The property appears to have been cleared of trees but remains undeveloped.

Adjoining South: The property appears to be used undeveloped land with a grove of trees.

Adjoining West: The property appears to be used undeveloped land with a grove of trees.

Surrounding Area: The surrounding area is mixed undeveloped and agricultural land. 1761
20 Date: 1966 through 1998
Scale: 1” = 500’ and 1” =1000’
Subject Property: The subject property appears to be undeveloped land with a grove of trees.

Adjoining North: The property appears to be undeveloped land with a grove of trees.

Adjoining East: The property appears to be undeveloped land with a grove of trees.

Adjoining South: The property appears to be undeveloped land with a grove of trees.

Adjoining West: The property appears to be undeveloped land with a grove of trees.

Surrounding Area: The surrounding area appears to be undeveloped. The pond along North Slough currently on the nearby property to the southwest first appears on the 1975 aerial photograph.

Date: 2005 through 2018
Scale: 1” = 500’ and 1” =1000’
Subject Property: The subject property appears to be undeveloped land and cleared of trees in 2012.

Adjoining North: The property appears to be undeveloped land with a grove of trees. A small building is located on the property in 2005 and the property is cleared of trees in 2012.

Adjoining East: The property appears to be undeveloped land with trees.

Adjoining South: The property appears to be undeveloped land and cleared of trees in 2012.

Adjoining West: The property appears to be undeveloped land.

Surrounding Area: The American Canyon Wastewater Treatment Plant to the northwest of the subject property appears in 2005. Additionally, buildings to the north and south of the subject property appear as well as additional paved roads.

Date: 2020
Scale: 1” = 500’
Subject Property: The subject property appears to be undeveloped land. Small temporary structures are located on the southeast corner of the property and appear to be associated with staging for construction of the southern adjacent property. Grading activity appears along the southern border of the subject property and may be the result of the southern adjacent property development.

Adjoining North: The property appears to be undeveloped land.

Adjoining East: The property appears to be undeveloped land with trees.

Adjoining South: The current warehouse building appears on the property.

Adjoining West: The property appears to be undeveloped land.

Surrounding Area: The surrounding area appears to be mixed residential, industrial, and undeveloped.

5.7.2 Fire Insurance Maps (Sanborn Maps)
The Fire Insurance Maps Report provided by Envirosite indicated that coverage does not exist for the subject property and vicinity.
1762
21 5.7.3 Recorded Land Title Records
A historical chain-of-title report was not provided by the User of the report and was not obtained by CameronCole as part of the approved scope of services for this project.

5.7.4 Historical USGS Topographic Maps
Envirosite provided historical topographic maps which depict the subject property for the years 1919, 1942, 1949, 1951, 1949 (revised 1968), 1949 (revised 1981), 2012, 2015, 2018, and 2021. These historical topographic maps are included in Appendix D.

Date: 1916 and 1942, Mare Island Quadrangle
Scale: 1:62500
Subject Property: The subject property appears to be undeveloped land.

Adjoining North: The property appears to be undeveloped land.

Adjoining East: The property appears to be undeveloped land.

Adjoining South: The property appears to be undeveloped land.

Adjoining West: The property appears to be undeveloped land.

Surrounding Area: The surrounding area appears to be undeveloped.

Date: 1949 through 2021, Cuttings Wharf Quadrangle
Scale: 1:2400
Subject Property: The subject property appears to be undeveloped land.

Adjoining North: The property appears to be undeveloped land. A small building is located on the property on the 1951 topographic map.

Adjoining East: The property appears to be undeveloped land.

Adjoining South: The property appears to be undeveloped land.

Adjoining West: The property appears to be undeveloped land.

Surrounding Area: The surrounding area appears to be undeveloped.

5.7.5 Local Street Directories
Historical street directories for the subject property and surrounding property addresses were provided by Envirosite. A copy of the City Directory Report is provided in Appendix D.

Subject Property
No results were noted for the subject property address, 1055 Commerce Court, in directories dated 1993 through 2018.

Adjacent Properties
The address 2 Eucalyptus Drive includes the adjoining property east and historically included the subject property and the adjoining properties north and south until approximately 2012. The address is listed as George and Patricia Couch in 2010, 2013, 2015, 2016, and 2018 and as a paintball business in 2002, 2006, and 2011. No results were noted for the remaining adjoining property addresses in directories dated 1993 1763
22 through 2018.

5.7.6 Building Department Records
Historical use of the subject property was researched using other standard historical sources. Therefore, Building Department records were not reviewed as part of this assessment.

5.7.7 Zoning/Land Use Records
Historical use of the subject property was researched using other standard historical sources. Therefore, historical Zoning/Land Use records were not reviewed as part of this assessment.

5.7.8 Prior Assessment Reports
Phase I Environmental Site Assessment, Couch Property, October 2004 Cameron-Cole reviewed the Phase I Environmental Site Assessment, Couch Property prepared by Environmental Science Associates and dated October 2004. The assessment was conducted on an approximate 106-acre property with the address 2 Eucalyptus Drive. The subject property is in the western section of this larger property.

The assessment identified six RECs including, the undocumented and illegal storage of hazardous materials and waste on the property which were identified by Napa County during an inspection in 1990. At the time of the assessment, it appeared that the 10,000-gallon former underground storage tanks, drums and other containers containing hazardous materials had been removed. However, gas cylinders and a 3,000-gallon underground storage tank remained on the northeastern portion of the property and were considered a REC.

The possibility of methamphetamine labs operating on the property, the possibility of soil containing oil deposited on the northeastern portion of the property including a wood cutting area, two water wells located on the property, and outhouses located on the property were also considered RECs.

The RECs identified during this assessment appear to have been associated with the northeastern portion of the 106-acre property and were not located with the subject property.

Phase II Soil Investigation, Couch Property, July 2005
Cameron-Cole reviewed the Phase II Soil Investigation, Couch Property prepared by Kleinfelder and dated July 2005. The investigation consisted of nine hollow-stem auger borings, four hand auger boring, and two test pits TP-1 and TP-2 located on the 106-acre property. The file reviewed did not include the figures, tables, and appendices to support the letter report. However, the 2018 Phase I ESA performed by ATC included a figure which depicts borings B-4 and B-9 through B-12 installed during this investigation on the adjoining properties north and south, and no borings located on the subject property.

A total of 34 soil samples were submitted for laboratory analysis and groundwater was not encountered in any of the borings. The laboratory analysis did not reveal “a significant release” in any of the samples.

Concentrations of total petroleum hydrocarbons (TPH) including diesel (TPH-d), motor oil (TPH-mo), and gasoline (TPH-g), benzene, toluene, ethylbenzene and xylene (BTEX), methyl tert-butyl ether (MTBE), polycyclic aromatic hydrocarbons (PAH), pesticides, and E. Coli were either below laboratory detection limits or detected below the reported Environmental Screening Levels (ESLs) as defined by the San Francisco Bay Water Board (February 2005) in all samples analyzed. Metals and total coliform were detected above ESLs.

However, Kleinfelder concluded that the results did not appear to reflect a significant release. 1764
23 Phase I Environmental Site Assessment, 2 Eucalyptus Drive, March 2006 Cameron-Cole reviewed the Phase I Environmental Site Assessment, 2 Eucalyptus Drive prepared by Innovated & Creative Environmental Solutions (ICES) and dated March 16, 2006. This assessment was completed on the 106-acre property that includes the subject property.

The assessment resulted in three recommendations. ICES recommended that soil samples be collected in the western portion of the property to assess the potential presence of organochlorine pesticides, arsenic, lead, and mercury associated with the eucalyptus grove. This area appears to include the subject property.

ICES also recommended soil samples be collected in the wood cutting area, located in the southeastern portion of the property, and from the northeastern portion of the property. These areas do not include the subject property. A Phase II addressing these recommendations was not identified during this investigation.

Phase I Environmental Site Assessment, 2 Eucalyptus Drive, December 2009 Cameron-Cole reviewed the Phase I Environmental Site Assessment, 2 Eucalyptus Drive prepared by Kleinfelder and dated December 2009. This assessment also addressed the 106-acre property within which the subject property was located.

The assessment identified two RECs for the site. Kleinfelder stated that there was evidence that “residual petroleum hydrocarbons, solvents, and certain metals may have been released in shallow soil” in the eastern and western portions of the property. The western portion includes the subject property. Kleinfelder also stated that, “….it is possible that the paint within the paintballs may have contained lead and was released to soil.” The area of the site that was used for paintball activities includes the subject property.

Kleinfelder recommended that the three wells on the eastern portion of the property be sampled and abandoned. They recommended that a soil and groundwater investigation be conducted on the site.

Additionally, Kleinfelder recommended that the surface water in the creek located to the west of the site be sampled, the septic tank located in the eastern portion should be abandoned, and an asbestos survey should be conducted.

Limited Site Investigation, 2 Eucalyptus Drive, April 2010 Cameron-Cole reviewed the Limited Site Investigation, 2 Eucalyptus Drive prepared by ICES and dated April 19, 2010. A total of eight soil samples from eight separate locations (TP-1 through TP-8) were collected during the investigation. The investigation appeared to address the Paintball Jungle (West) and the Hurst Firewood Area. The Hurst Firewood Area was located on the property located southeast of the subject property. The test pits TP-1 through TP-4 were located on the western portion of the site, Paintball Jungle (West), and it appears from the figure provided that TP-2 and TP-3 were located on the subject property.

One soil sample was collected from each test pit. The samples were analyzed for TPHg, TPHd, and TPHmo by EPA method 8015B, volatile organic compounds (VOCs) by EPA method 8260B, and CAM 17 metals by EPA method 6020A. The concentrations were compared to the residential ESLs. TPHg, TPHd, TPHmo and VOCs were not detected above laboratory detection limits or above the residential ESLs with the exception of TPHd in TP-2 (160 mg/kg). The residential ESL was reported to be 83 mg/kg. ICES stated that since TP-2 was located in the eucalyptus grove, the elevated concentration identified in the sample may have been the result of the natural oil compounds in eucalyptus trees.

Arsenic (8.8 mg/kg) and vanadium (46 mg/kg and 63 mg/kg) were identified at concentrations above the stated residential RSLs (0.39 mg/kg and 16 mg/kg, respectively) in TP-2 and TP-3. However, ICES stated that the concentrations identified were within background levels for area soils. Lead was not identified in the 1765
24 samples collected from TP-2 and TP-3 above the stated residential RSLs.

ICES stated that, “Based on the findings of this and previous investigations, it appears that the surficial soil within the Site has generally not been impacted by previous activities.” Phase I Environmental Site Assessment, SDG Commerce 330 Distribution Center, June 2018 Cameron-Cole reviewed the Phase I Environmental Site Assessment of SDG Commerce 330 Distribution Center prepared by ATC Group Services, LLC and dated June 6, 2018. The SDG Commerce 330 Distribution Center property included the subject property and the adjoining properties north and south and was associated with the single APN 058-030-065. The property was approximately 35.85 acres of undeveloped land. The findings and conclusions of the assessment identified one REC, one HREC, and one de minimis condition as quoted from the text below.

Note 1) A Phase I ESA was conducted by Environmental Science Associates in 2004. The site reconnaissance of the Couch Property identified small quantities of hazardous wastes and some soil staining. It appeared that the hazardous materials noted by the County in 1990 had been removed by the property owners, except for the gas cylinders and 3,000 gallon former underground storage tank. It is unknown where the County had observed the drums containing hazardous materials, the 10,000-gallon former underground storage tanks (USTs), and the other containers of hazardous materials. However, areas that had recently been disturbed and areas with a lack of vegetation were noted during the site reconnaissance. It appears that some of the hazardous materials, drums and the 10,000-gallon tanks may have been removed by the property owners. Based on the fact that the locations of the former USTs noted above is unknown and the lack of sampling including groundwater sampling, ATC considers the potential impacts from the USTs to be a recognized environmental condition.

Note 2) A Phase II Soil Investigation by Kleinfelder dated July 25, 2005. The investigation was conducted in response to several recognized environmental conditions which were noted in the report by Environmental Science Associates. The investigation was conducted in March through May 2005 and consisted of nine Hollow-stem auger borings, four hand auger, borings, and two test pits. A total of 34 soil samples were submitted for analysis. Groundwater was not sampled or analyzed during this investigation. Analytical tables were referenced in the report but no tables were included in the copy of the report obtained by ATC. Although this investigation was conducted on the approximately 106-acre Couch Property, only borings B-4 through B-12 (Appendix B) were advanced on the 35.85- acre property which is the subject of this report. The concentration of Chromium in B-12 at 15 feet below ground surface (bgs) was noted at the 130 milligrams per kilogram (mg/kg) which was noted above the screening levels used. However, concentrations of chromium in two samples collected at shallower levels from the same boring were noted below this level and, therefore, Kleinfelder determined the elevated concentration of chromium at 15 feet bgs was not due to a significant release. It should be noted that although the concentration of chromium noted above in boring B-12 at 130 mg/kg is above the 2005 ESLs, the concentration is below the current version of the February 2016 ESLs. As such the noted levels of chromium is considered an historical recognized environmental concern.

Note 3) Based on Kleinfelder’s Phase I investigation completed in 2009, the Concentrated Area was reported previously occupied by a trailer a methamphetamine lab in 2000. EPA guidelines note that soil sampling in areas of methamphetamine labs may be warranted if the ground is visibly stained or otherwise affected (e.g., odors burn piles, dead vegetation, or remnants of reaction waste). ATC did 1766
25 not observe evidence of dead vegetation or discarded waste on the day of the site reconnaissance (refer to Section 6.0). Thus, ATC considers the previous methamphetamine lab site to be a de minimis condition to the property.

Limited Phase II Subsurface Investigation, 35.85 Acre Parcel, APN 058-030-065, March 2019 Cameron-Cole reviewed the Limited Phase II Subsurface Investigation, 35.85 Acre Parcel, APN 058-030- 065, prepared by ATC Group Services, LLC and dated March 25, 2019. The Phase II investigation addressed the REC identified during the Phase I ESA dated June 6, 2018, outlined in Note 1 above. On November 6, 2018, ATC advanced two borings along the western border of the adjoining property north. ATC encountered difficulty in the field preventing them from completing boring SB-1. At SB-2, soil samples were field screened with a photo ionization detector (PID) and samples were collected for laboratory analysis from 10, 20, and 38 feet bgs. SB-3 was advanced with a hydropunch sampler for the purpose of collecting a groundwater sample.

Groundwater was not encountered at 40 ft bgs in either boring.

The soil samples were analyzed for TPH by EPA method 8015, VOCs by EPA Method 8260, and CAM 17 by EPA Methods. The Phase II compared the laboratory results to the Tier 1 ESLs from the San Francisco Bay Regional Water Quality Control Board (RWQCB) dated February 2016. TPH and VOCs were not detected above laboratory detection limits in any of the soil samples analyzed. Arsenic was detected at a maximum concentration of 11 milligrams per kilogram (mg/kg), which is above the ESL. However, the Phase II stated that this concentration is at the established background concentration for arsenic in California soils. The remaining metals were either not detected above laboratory detection limits or below the ESL.

The Phase II states that, “Since this investigation indicates that it would appear to be unlikely that impacts from the Couch property could impact the subject property, the recognized environmental condition noted in the Phase I ESA by ATC dated June 6, 2018, is no longer considered to exist. Further investigation of potential impacts from the Couch property on the subject property is not recommended at this time.” Final Initial Study for the SDG Commerce 330 Warehouse Project, January 2019 Cameron-Cole reviewed the Final Initial Study for the SDG Commerce 330 Warehouse Project, prepared by Grassetti Environmental Consulting and dated January 2019. The project site addressed in the report includes the subject property and the adjoining properties north and south. No environmental concerns were identified through this review.

Geotechnical Engineering Investigation, Proposed SDG Commerce 224, January 2021 (Draft) Cameron-Cole reviewed the draft Geotechnical Engineering Investigation, Proposed SDG Commerce 224, prepared by Krazan & Associates, Inc. and dated January 18, 2021. The report addressed the subject property located at 1055 Commerce Court, American Canyon, California. The report was “conducted to evaluate the soil and groundwater conditions at the site, to make geotechnical engineering recommendations.” During the investigation, groundwater was encountered in the borings at depth varying from 18.5 to 22.5 ft bgs.

Laboratory analysis of soils or groundwater for hazardous substances or petroleum products was not conducted.

5.8 Historical Use Information on Adjoining Properties
The following is a summary of adjoining property historical uses based on a review of the historical records reviewed in Section 5.6.

North: The adjoining property to the north appears to have been undeveloped containing a 1767
26 eucalyptus grove from at least 1937 until approximately 2012. The property was used for paintball activities from at least 1992 until approximately 2012. A small building appears on the northwest corner of the property in 2005.

East: The adjoining property to the east appears to have been undeveloped containing a eucalyptus grove from at least 1937. The property was used for paintball activities from at least 1992 to present day. Historically, temporary residences and animal pens were located on the property. The northeast portion of the property, northeast of the subject property, is residential.

The property historically contained undocumented and illegal storage of hazardous materials and waste which were identified by Napa County during an inspection in 1990. Additionally, two 10,000-gallon USTs, a 3,000-gallon UST, drums and other containers containing hazardous materials were in the northeast portion of the property. These items have since been removed.

South: The adjoining property to the south appears to have been undeveloped containing a eucalyptus grove from at least 1937 until approximately 2012. The property was used for paintball activities from at least 1992 until approximately 2012. The current warehouse building was constructed on the property in approximately 2020.

West: The adjoining property to the west appears to have been undeveloped containing a eucalyptus grove from at least 1937 to the present. The property contains the North Slough.

In accordance with ASTM International E1527-21, 8.3.1, the objective of compiling and analyzing historical property information and developing a history of the previous uses of the subject property, adjoining properties, and surrounding area is to help identify the likelihood of past uses having led to recognized environmental conditions in connection with the subject property. All obvious uses of the subject property must be identified from the present, back to the subject property’s first developed use, or back to 1940, whichever is earlier. The report must describe all identified uses, justify the earliest date identified for the subject property’s first developed use, and explain the reason for any gaps in the history of use. This task requires reviewing as many of the standard historical resources in 8.3.4.1 through 8.3.4.8 as are necessary and both reasonably ascertainable and likely to be useful. Data failure occurs when all the standard historical sources that are reasonably ascertainable and likely to be useful have been reviewed and yet the objective has not been met. Data failure is not uncommon in trying to identify historical uses at 5-year intervals back to first use or 1940 (whichever is earlier). If the data failure represents a significant data gap to the Environmental Professional (EP), ASTM International Standard E1527-21 requires documentation of the impact of the data gap on the ability of the EP to identify RECs. No significant historical use information data gaps were encountered.
1768
27 6.0 SITE RECONNAISSANCE

6.1 Methodology and Limiting Conditions
The methodology used by the Cameron-Cole representative during the March 13, 2023, site reconnaissance consisted of visual observations of readily accessible areas of the subject property to determine the presence or absence of hazardous substance or petroleum product storage areas or spills as indicated by stressed vegetation, soil staining, storage tanks, drums, etc.

6.2 General Site Setting
The subject property is approximately 10.17 acres located at 1055 Commerce Court with the Napa County Assessor’s office associated APN 058-030-069. The subject property currently consists of undeveloped land with natural vegetation. The property is currently not being used and it remains undeveloped with no structures or occupants. Evidence of the southeast corner of the property previously used as a staging area during the development of the adjoining property south was observed during the site visit. The area was cleared of vegetation, gravel pathways exist, and footprint areas where temporary offices were located and miscellaneous trash and refuse associated with storage of building materials including rock piles were observed. An observed elongated soil mound was observed along the southern border of the subject property.

The owner’s representative of the subject property, Mr. John Wojtas of SDG, stated that this soil was placed there during the development of the adjoining property south.

6.2.1 Geologic, Hydrogeologic, and Topographic Conditions Based on topographic maps, and considering regional flow patterns, the groundwater flow in the vicinity of the site is inferred to be generally to the west. It must be noted that groundwater flow direction can be influenced by factors such as surface topography, underground structures, seasonal fluctuation, soil and bedrock geology, and production wells which were not considered in this interpretation.

6.2.2 General Description of Structures
There were no noted structures on the subject property during site reconnaissance. Evidence of temporary structures previously located on the southeast corner of the site was observed. The area had been cleared of vegetation and gravel pathways remained in the area.

6.2.3 Roads
Commerce Court borders the subject property to the east.

6.2.4 Potable Water Supply
A potable water source was not observed during the site visit. The owner of the property, SDG, indicates potable water in the area is supplied by the City of American Canyon.

6.2.5 Sewage Disposal System
There were two stormwater drains located on the subject property at the time of site reconnaissance. The owner of the property, SDG, indicates sewage services in the area is provided by the City of American Canyon. 1769
28 6.3 Subject Property Observations

6.3.1 Hazardous Substances and Petroleum Products in Connection with Identified Uses No hazardous substances or petroleum products were observed on the subject property during the March 13, 2023, site reconnaissance.

6.3.2 Storage Tanks
There were no storage tanks located on the subject property during the site reconnaissance.

6.3.3 Odors
Noticeable odors were not identified at the subject property at the time of the site reconnaissance.

6.3.4 Pools of Liquid
No pools of liquid were observed on the subject property during the site reconnaissance.

6.3.5 Drums
Cameron-Cole did not observed drums on the subject property by during the site reconnaissance.

6.3.6 Pits, Ponds, or Lagoons
There were no pits, ponds, or lagoons noted onsite during the site reconnaissance.

6.3.7 Stained Soil or Pavement
A very minimal oil sheen was observed on a puddle of water in the western portion of the site. The sheen was determined to be de minimis and is likely attributed to naturally occurring oils from the historic eucalyptus groves on and adjacent to the subject property.

6.3.8 Stressed Vegetation
Stressed vegetation was not observed during the site reconnaissance.

6.3.9 Solid Waste
A de minimis amount of household waste was noted during site reconnaissance. No hazardous waste was observed during the site reconnaissance. Several rock piles were present throughout the subject property. A large mound of soil was observed on the southern edge of the site. The owner representative of the subject property, Mr. John Wojtas, stated that the soil observed on the property was excess soil placed there during the development of the adjoining property south.

6.3.10 Wastewater
Cameron-Cole did not observe any wastewater on site.

6.3.11 Wells
No groundwater wells were observed during the site reconnaissance.

6.3.12 Septic Systems
Septic systems were not observed at the time of site reconnaissance. 1770
29 7.0 INTERVIEWS

7.1 Site Owner/Occupants
A questionnaire was provided to the owner representative, Mr. John Wojtas. Mr. Wojtas indicated that there was a previous ESA and a Geotechnical report conducted on the property. Cameron-Cole obtained the prior reports from the City of American Canyon website and FCS.

7.2 Past Owners, Operators, Occupants
Past owners, operators, or occupants were not interviewed for this ESA.

7.3 User
Ms. Janna Waligorski Hudson, Senior Project Management, First Carbon Solutions, completed the User Questionnaire. A summary of the responses is provided in Section 4.0, and a copy of the questionnaire is provided in Appendix B.

7.4 State and/or Local Government officials
Cameron-Cole contacted the American Canyon Fire Protection District on March 24, 2023, requesting records pertaining to fires or responses to incidents, spills, or releases of hazardous substances or petroleum products at, or in the immediate vicinity of the property. Martha Banuelos responded on behalf of the American Canyon Fire Protection District and stated that, “The Fire District does not maintain environmental records on properties.” Cameron-Cole contacted the County of Napa Environmental Health Division on March 24, 2023, requesting records regarding environmental violations, releases, or hazardous material or petroleum product storage, storage tanks, or other environmental concerns associated with the subject property. A public records request was submitted to the County of Napa Public Records Department. No response has been received as of the date of this report.
1771
30 8.0 FINDINGS AND CONCLUSIONS
The goal of this Phase I ESA is to identify the presence or likely presence of hazardous substances or petroleum products on the subject property under conditions that indicate an existing release, a past release, or a material threat of release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water on the property. The findings of this report are summarized below and may include known or suspected RECs, CRECs, HRECs, VECs, BERs identified during the performance of this Phase I ESA.
• Through the review of historical aerial photographs, it is possible that the subject property has historically been used for agricultural purposes. Cameron-Cole notes that application of pesticides, herbicides, or fertilizers are commonly associated with properties developed for agricultural purposes. Proper application of these materials is not considered a release under the ASTM International E1527-21 Standard Practice. Therefore, the potential presence of these substances on the property would not be considered a REC, unless evidence of improper application, a spill or release, or a material threat of a spill or release were identified during the Phase I assessment. No evidence of improper application, releases, or potential releases of agricultural chemicals were noted in the report. The possible historic use of the subject property for agricultural purposes is not considered a recognized environmental condition for the subject property.
• The subject property contained a eucalyptus tree grove from at least 1937 through approximately 2012. The property was used for paintball activities from approximately 1992 until approximately 2012.

During the Limited Site Investigation, 2 Eucalyptus Drive prepared by ICES and dated April 19, 2010, two test pits were installed on the subject property, TP-2 and TP-3. One soil sample was collected from each test pit at 6-9 ft. bgs. TPHd was detected in TP-2 (160 mg/kg) above the reported residential ESL (83 mg/kg). ICES stated that since TP-2 was located in the eucalyptus grove, the elevated concentration identified in the sample may have been the result of the natural oil compounds in eucalyptus trees. Arsenic (8.8 mg/kg) and vanadium (46 mg/kg and 63 mg/kg) were also identified at concentrations above the stated residential RSLs in TP-2 and TP-3. However, ICES stated that the concentrations identified were within background levels for area soils.

The current Tier 1 ESL (2019) for TPHd is 230 mg/kg and the 2019 Tier 1 ESLs for arsenic and vanadium are 0.067 mg/kg and 18 mg/kg, respectively. Therefore, the concentration of TPHd identified in 2010 is below the current Tier 1 ESL. Although the concentrations of arsenic and vanadium remain above the current Tier 1 ESL, the concentrations are within background levels for California soils. Evidence was not identified during this assessment that the petroleum products or hazardous substances have been used or stored on the subject property. The concentrations of TPHd, arsenic, and vanadium identified during the 2010 Limited Site Investigation in soils on the subject property are not considered recognized environmental conditions for the subject property.

There were no RECs, CRECs, HRECS, VECs, or BERs identified at the subject property at the time of this report.
1772
31 9.0 DEVIATIONS
There were no contractual excluded elements or deviations from the ASTM International Standard E1527-21.
1773
32 10.0 REFERENCES
Environmental Science Associates, Phase I Environmental Site Assessment, Couch Property, October 2004.

Kleinfelder, Phase II Soil Investigation, Couch Property, July 25, 2005.

Innovated & Creative Environmental Solutions, Phase I Environmental Site Assessment, 2 Eucalyptus Drive, March 16, 2006.

Kleinfelder, Phase I Environmental Site Assessment, 2 Eucalyptus Drive, December 22, 2009.

Innovated & Creative Environmental Solutions, Limited Site Investigation, 2 Eucalyptus Drive, April 19, 2010.

ATC Group Services, LLC, Phase I Environmental Site Assessment of SDG Commerce 330 Distribution Center, June 6, 2018.

ATC Group Services, LLC, Limited Phase II Subsurface Investigation, 35.85 Acre Parcel, APN 058-030-065, American Canyon, California, March 25, 2019.

Grassetti Environmental Consulting, Final Initial Study for the SDG Commerce 330 Warehouse Project, January 2019.

Krazan & Associates, Inc., Geotechnical Engineering Investigation, Proposed SDG Commerce 224 (Draft), January 18, 2021.

American Society of Testing and Materials International (ASTM International) Standard Practice Designation E1527-21.

Aerial Photographs
Envirosite – 1937, 1948, 1957,1958, 1965, 1966, 1968, 1970, 1971, 1973, 1975, 1982, 1983, 1985, 1988, 1989, 1993, 1996, 1998, 2005, 2009, 2010, 2012, 2014, 2016, 2018, and 2020. Report generated March 15, 2023.

USGS Topographic Maps
Envirosite 1916, 1942, 1949, 1951, 1949 (Revised 1968), 1949 (Revised 1981), 2012, 2015, 2018, and 2021 7.5 and 15 USGS Topographic Maps of Mare Island and Cuttings Wharf, California. Report generated March 10, 2023
Standard Environmental Records Search – Completed by Envirosite for SDG Commerce 220, 1055 Commerce Court, American Canyon, California. Report generated March 10, 2023.

Fire Insurance Map Search – Completed by Envirosite for SDG Commerce 220, 1055 Commerce Court, American Canyon, California. Report generated March 13, 2023.

City Directory Abstract – Completed by Envirosite for SDG Commerce 220, 1055 Commerce Court, American Canyon, California. Report generated March 13, 2023.

Parcel Information – Appraiser’s Report obtained from the Napa County Assessor Clerk and Recorders Office.
1774
33 Interviews:

User – Ms. Janna Waligorski Hudson, Senior Project Manager, FCS, interview conducted via User Questionnaire completed on March 28, 2023.

Owner – Mr. John Wojtas, authorized agent with Stravinski Development Group, interview conducted via Owner Questionnaire completed on March 22, 2023.

Local official – American Canyon Fire Protection District records request submitted on March 24, 2023.

Local official – County of Napa Environmental Health Division records request submitted on March 24, 2023. 1775
34 11.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL
The following Cameron-Cole personnel were involved with the site inspection, records search, regulatory review, and drafting of the Phase I Environmental Site Assessment Report for the property located at 1055 Commerce Court, American Canyon, Napa County, California.

Prepared by:

Angela Mattemill
Environmental Scientist
This is to certify that I have reviewed and approve the contents of the Phase I Environmental Site Assessment Report for the property located at 1055 Commerce Court, American Canyon, California. Certification of the environmental professional are provided in Section 14, and professional qualifications are provided in Appendix G.

Reviewed by:

Robert Fagerness, PE
Senior Engineer

1776
35 12.0 ENVIRONMENTAL PROFESSIONAL STATEMENT
I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 312.10 of 40 CFR 312, and I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

Robert Fagerness, PE
Senior Engineer

1777

FIGURES
1778
SCALE:

FIGURE 1

SITE VICINITY MAP
SDG COMMERCE 220
1055 COMMERCE COURT

AMERICAN CANYON, CALIFORNIA
2236 MARINER SQUARE DRIVE SUITE 500 ALAMEDA, CALIFORNIA 94501 PHONE: 510-777-1870 FAX: 510-777-1871 http://www.cameron-cole.com 1" = 24000'

SITE LOCATION

USGS TOPOGRAPHIC MAP
SUBJECT QUAD:

CUTTINGS_WHARF
MAP YEAR: 2021 1779
SCALE:

FIGURE 2
2236 MARINER SQUARE DRIVE SUITE 500 ALAMEDA, CALIFORNIA 94501 PHONE: 510-777-1870 FAX: 510-777-1871 http://www.cameron-cole.com 1" = 200'

PROPERTY MAP
SDG COMMERCE 220
1055 COMMERCE COURT

AMERICAN CANYON, CALIFORNIA
FLIGHT YEAR:
2020
Scale:
1" = 500'
APN 058-030-069
1780

APPENDICES
1781

APPENDIX A
Photographs
1782
Commerce Ct
American Canyon, California
Project No. 5639.0001
1 Photo 1: View into the site from south east corner along Commerce Ct. Seen in picture is survey mark that was
already present to display the corner of the property.

Photo 2: Southern edge of site that borders the current developed parcel, photo taken from southeast corner of
property.

Photo 3: Taken from northeast corner of site, looking
west. Already in place survey mark denoting the northeast corner of site can be seen.

Photo 4: Taken from northeast corner of site, looking
south along Commerce Ct. Already in place survey mark
denoting northeast corner can be seen.

Photo 5: Taken from Northwestern corner of site,
photographer standing next to already in place survey
mark denoting northwestern corner. Taken facing directly west.

Photo 6: Facing south toward adjacent developed parcel, taken from northwest corner of site. Already in place
survey mark denoting northeastern corner can be seen.
1783
Commerce Ct
American Canyon, California
Project No. 5639.0001
2 Photo 7: Facing north along western border of site. Taken from southwest corner.

Photo 8: Facing West along southern border, adjacent
developed parcel can be seen. Photo taken from
southwest corner.

Photo 9: Taken from northeast corner looking across
majority of the site.

Photo 10: Large seemingly unnatural mound present near
southern edge of site. No visually apparent source.

Photo 11: Facing west from on top of mound seen in
photo 10.

Photo 12: Facing east from on top of mound seen in photo

10. 1784
Commerce Ct
American Canyon, California
Project No. 5639.0001
3 Photo 13: Makeshift gate/pathway that connect the
western edge of site and adjacent property.

Photo 14: Minor oil sheen present in water puddle near
western edge of site. No source visually observable.

Photo 15: Gravel lined path near southeastern corner of site that was previously the location of several temporary structures.

Photo 16: Pile of rocks near former location of temporary structures.

Photo 17: Pile of rocks near former location of temporary structures.

Photo 18: Pile of rocks near southwestern corner.
1785
Commerce Ct
American Canyon, California
Project No. 5639.0001
4 Photo 19: Storm drain outlet near southeastern corner. Photo 20: Storm drain outlet near northeastern corner.

Photo 21: Electrical access hole inset about 30 feet from southeastern corner of site.

1786

APPENDIX B
User Questionnaire

1787
PHASE I ESA USER’S QUESTIONNAIRE
AAI User Questionnaire Page 1 of 4
In order to qualify for protection from land owner liability under CERCLA as an innocent landowner, bona fide prospective purchaser, or contiguous property owner, ASTM standard practice E1527-21 and the federal AAI rule (40 CFR 312) require that the User of the Phase I ESA report provide certain information (if available) to the Environmental Professional completing the assessment. Failure to provide this information could result in a determination that “all appropriate inquiry” is not complete. Information that is not or cannot be provided to the Environmental Professional may be identified as a “data gap” in the Phase I ESA report.

Property Information.

Cameron-Cole/Client Project #: 02-5639 Property Name: SDG Commerce 220 Property Address: 1055 Commerce Court
City: American Canyon State: CA Zip: 94503
Property Owner Name: Stravinski Development Group
Please answer the following questions as completely as possible. Attach additional pages as needed.

1. Reason for Completion. Is the reason for performing the Phase I to satisfy one of the requirements for the innocent landowner defense under CERCLA AND/OR to understand potential environmental conditions that could materially impact the operation of the business associated with the parcel of commercial real estate?
X__________ Yes __________ No
Other (indicate if required for property transaction, sale, purchase, exchange, lending requirement, etc).

To support analysis of the project under CEQA

2. Environmental Cleanup Liens. Are you aware of any environmental cleanup liens against the property that are filed or recorded under federal, tribal, state or local law? __________ Yes ____X______ No
If yes, describe or attach details of the lien_____________________________________ _______________________________________________________________________

3. Activity and Land Use Limitations. Are you aware of any activity and use limitations, such as engineering controls, land use restrictions, or institutional controls that are in place at the property and/or have been filed or recorded as applicable to the property as a result of environmental contamination, investigation, cleanup, or related matters? __________ Yes __X________ No
If yes, describe or attach details of the limitations________________________________ _______________________________________________________________________ 1788
PHASE I ESA USER’S QUESTIONNAIRE
AAI User Questionnaire Page 2 of 4

4. Specialized Knowledge or Experience. As the User of this ESA, do you have any specialized knowledge or experience related to the property or nearby properties? For example, are you involved in the same line of business as the current or former occupants of the property or an adjoining property, such that you would have specialized knowledge about chemicals and processes used by this type of business?
__________ Yes ___X_______ No
If yes, describe or attach details of your specialized knowledge or experience__________ _______________________________________________________________________

5. Relationship of Purchase Price to Fair Market Value of Property. Does the purchase price being paid for this property reasonably reflect the fair market value of the property? If you conclude that there is a difference, do you have any reason to believe that the reduced purchase price may be related to contamination known or believed to be present at the property? __________ Yes, I have reason to believe that the purchase price for the property has been reduced in comparison with the fair market value due to contamination known or believed to be present at the property?
__________ No, I have no reason to believe that the purchase price for the property has been reduced in comparison with the fair market value due to contamination known or believed to be present at the property?
_____X____ Not applicable. User is not involved in a purchase of the property.

6. Commonly Known or Reasonably Ascertainable Information. Are you aware of commonly known or reasonably ascertainable information about the property that would help the Environmental Professional to identify conditions indicative of releases or threatened releases of hazardous substances or petroleum products? For example:

Do you know the past uses of the property?
________ Yes (describe) ________________________________________________ _____________________________________________________________________ __X______ No
Do you know of chemicals, hazardous substances or petroleum products that are present or once were present at the property?
________ Yes (describe) ________________________________________________ _____________________________________________________________________ ___X_____ No
Do you know of spills or other releases of chemicals, hazardous substances or petroleum products that have taken place at the property?
________ Yes (describe) ________________________________________________ _____________________________________________________________________ ____X____ No
Do you know of any environmental cleanups that have taken place at the property? ________ Yes (describe) ________________________________________________ _____________________________________________________________________ ____X____ No
1789
PHASE I ESA USER’S QUESTIONNAIRE
AAI User Questionnaire Page 3 of 4

7. The Degree of Obviousness of Contamination. E1527-21 and the federal AAI rule (40 CFR 312.31) require that the Phase I ESA consider the degree of obviousness of the presence or likely presence of contamination at the property, and the ability to detect the contamination by appropriate investigation. Based on your knowledge and experience related to the property, are there any obvious indictors that point to the presence or likely presence of contamination at the property? ________ Yes (describe) ________________________________________________ _____________________________________________________________________ ___X_____ No

8. Availability of Previous Environmental Reports. Are you aware of previous environmental site assessment reports, other environmental reports, documents, correspondence, etc. concerning the property and its environmental condition?
____X____ Yes (please identify and provide copies, if available) __________________ January 2019 Final Initial Study for the SDG Commerce 330 Warehouse Project appears to consider the subject site. It references a Phase I ESA conducted by ATC in June 2018. I do not have access to the 2018 Phase I ESA document. The 2019 Final Initial Study indicates that the 2018 Phase I ESA summarized previous ESA’s conducted on the larger 106-acre Couch Property, of which the subject property was a part of. _____________________________________________________________________ ________ No

9. Proceedings Involving the Property. Are you aware of any proceedings involving the property? For example:

Are you aware of any pending, threatened or past litigation relevant to hazardous substances or petroleum products in, on or from the property? ________ Yes (describe) ________________________________________________ _____________________________________________________________________ ___X_____ No
Are you aware of any pending, threatened or past administrative proceedings relevant to hazardous substances or petroleum products in, on or from the property? ________ Yes (describe) ________________________________________________ _____________________________________________________________________ _____X___ No
Any notices from any governmental entity regarding any possible violation of environmental laws or possible liability relating to hazardous substances or petroleum products?
________ Yes (describe) ________________________________________________ _____________________________________________________________________ ___X_____ No
Signature: ____________________________________________________________________ Name (printed): ____Janna Waligorski Hudson
____________________________________________________________ Title: ____________Senior Project Manager
_____________________________________________________________ Date: ___3/28/23_____________________________________________________________________ 1790

APPENDIX C
Government Records Report
1791
Government Records
Report | 2023
With Platinum Review
Order Number: 84481
Report Generated: 03/10/2023
Project Name: SDG Commerce 220
Project Number: 02-10800-05639
SDG Commerce 220
1055 Commerce Ct
American Canyon, CA 94503
with Envirosite Atlas
Contact us at:
(866) 211-2028
envirositecorp.com
1792
Table of Contents 2023
Section Page
Executive Summary 1
Executive Summary by Distance 2
Executive Summary by Database 3
Property Proximity Map 13
Area Map 14
Map Findings Summary 15
Map Findings 22
Unmappable Summary 457
Environmental Records Searched 458
Geological Landscape Section 483
Geological Landscape Section Soil Map 486
Geological Landscape Section Summary 487
Geological Findings Map 497
Geological Landscape Section Map Findings 498
Geological Landscape Section Map Findings Radon 517
Geological Landscape Records Searched 518
Disclaimer - Copyright and Trademark Notice
All information contained in this report are based on data available from various public, government and other sources and are based upon the best data available from those sources. The information available in this report may be available from other sources and is not exclusive or the exclusive property of Envirosite Corporation.

NO WARRANTY EXPRESSED OR IMPLIED, IS MADE IN CONNECTION WITH THIS REPORT, INCLUDING WITHOUT LIMITATION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ALL RISK IS ASSUMED BY USER AND Envirosite assumes no liability for faulty or inaccurate information. The Reports may utilize a variety of public and other sources reasonably available to Envirosite. Envirosite cannot, and does not assure, warrant, guarantee or assume any liability for the correctness, comprehensiveness, timeliness or completeness of any of such information, nor is the information in any Report to be construed as legal advice with respect to environmental risks associated with any property. Envirosite shall not be liable to anyone for any claims, causes of action, suits, damages, losses, costs and expenses (including, without limitation, attorneys’ fees and costs) arising out of or caused by this report regardless of the acts, errors or omissions, or negligence of Envirosite. Any damages shall be limited to the purchase price of the report.

Purchaser of the report accepts the report “As Is”. The report is intended only to provide information only and should not be considered as providing any legal advice, prediction, forecast, or fact as to the environmental risk for any specific property. Reports are proprietary to Envirosite, and contain copyrighted material and trademarks of Envirosite. All other trademarks used herein are the property of their respective owners. All rights of Envirosite as to the Reports are reserved. 1793
Executive Summary 2023
Envirosite Corporation has conducted a search of all reasonably ascertainable records in accordance with EPA’s AAI (40 CFR Part 312) requirements and the ASTM E-1527-21 Environmental Site Assessments standard.

SUBJECT PROPERTY INFORMATION:

ADDRESS:

SDG Commerce 220
1055 Commerce Ct
American Canyon, CA 94503
COORDINATES:

Latitude (North): 38.185594 - 38°11'8.1"
Longitude (West): -122.273824 - -122°16'25.8"
Universal Transverse Mercator: Zone 10N
UTM X (Meters): 563595.70
UTM Y (Meters): 4226656.54
State Plane Coordinates: 0402 - California Zone 2 (US Survey Feet) X Coordinate (Feet): 6482957.025 E
Y Coordinate (Feet): 1829528.733 N
ELEVATION:

Elevation: 19 ft. above sea level
USGS TOPOGRAPHIC MAP ASSOCIATED WITH SUBJECT PROPERTY:

Subject Property Map: 38122-B3 Cuttings Wharf, CA
Most Recent Revision: 2018