Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-13 measures would avoid a substantial adverse change in the significance of any unique archaeological resources or subsurface historical resources. However, because the project could result in inadvertent discovery and subsequent damage of unique archaeological resources or subsurface historical resources, it would contribute to the environmental significance conclusion in the Program EIR; therefore, for purposes of CEQA compliance, this PSA/Addendum identifies the impact as significant and unavoidable.
This impact is within the scope of the Program EIR because treatment activities and intensity of ground disturbance of the proposed treatments are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the potential for discovery of archaeological resources is essentially the same within and outside the treatable landscape; therefore, the potential impact on unique archaeological resources or subsurface historical resources is also the same, as described above.
SPRs applicable to this impact are AD-3, CUL-1 through CUL-5, and CUL-8. MM CUL-2 would also apply to treatment activities to protect any inadvertent discovery. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT CUL-3
Native American contacts in Santa Clara County were contacted on November 26, 2025, and include Vice Chairperson Ed Ketchum and Chairperson Valentin Lopez of Amah Mutsun Tribal Band; Senior Cultural Monitor and Consultant Michelle Zimmer, Chairperson Irenne Zwierlein, Senior Cultural Monitor and Consultant and Councilman Chritopher Zimmer, and Senior Cultural Monitor and Consultant and Councilwomen Shelby Brown of Amah Mutsun Tribal Band of Mission San Juan Bautista; Language Program Manager Deja Gould, Chairperson Corrina Gould, and Tribal Cultural Resource Manager Cheyenne Gould of Confederated Villages of Lisjan Nation; Tribal Councilmember Carla Munoz, Cultural Resource Officer Samuel Rodriguez, and Cultural Resource Officer Henry Muñoz of Costanoan Rumsen Carmel Tribe; Tribal Chairwoman Kanyon Sayer-Roods and Retired Honorable Elder Ann Marie Sayers of Indian Canyon Mutsun Band of Costanoan; Councilmember/MLC Tribal Representative Richard Massiatt and Chairperson Charlene Nijmeh of Muwekma Ohlone Tribe of the San Francisco Bay Area; Chairperson Katherine Perez and Tribal Compliance Officer Timothy Perez of Northern Valley Yokut/Ohlone Tribe; THPO Johnathan Wasaka Costillas, Secretary Lilian Camarena, and Chairperson Quirina Geary of Tamien Nation; THPO Desiree Vigil, President Emeritus Andrew Galvan, and President Vincent Medina of the Ohlone Indian Tribe; and Chairperson Kenneth Woodrow of Wuksachi Indian Tribe/Eshom Valley Band. Responses were received from the Muwekma Ohlone Tribe of the San Francisco Bay Area and the Tamien Nation, and coordination pursuant to SPR CUL-2 is complete.
Engagement with tribes related to cultural resources protection or cultural burning will continue during implementation of treatments, as requested by tribes.
As described above under Section 1.3.2, “Proposed Project Revisions,” revisions to SPR CUL-4 are proposed to clarify that this SPR applies to all mechanical and prescribed burning treatment activities and manual treatment activities that use tracked chippers beyond established road surfaces. This would exempt manual treatments when woody material is chipped and scattered, chipped and removed, or lopped and scattered, from needing an archaeological and historical resource survey. This constitutes a revision to the program description analyzed in the Program EIR.
Requirements under SPR CUL-4 are intended to prevent damage to archaeological and historical resources. The proposed revisions to SPR CUL-4 would not result in any adverse effects to cultural resources because the revision would allow treatment activities to occur without a survey only when there is no potential for the treatment activity to result in damage to cultural resources. Those activities that may result in damage to cultural resources (e.g., mechanical treatments, prescribed burning) would require pretreatment surveys. Therefore, proposed revisions to SPR CUL-4 would not result in a substantially more severe significant effect related to disturbance of cultural resources than what was covered in the Program EIR. The proposed revisions to SPR CUL-4 are shown in the MMRP (Attachment A).
The potential for the proposed treatment activities to cause a substantial adverse change in the significance of a tribal cultural resource during implementation of vegetation treatment was examined in the Program EIR. This impact is within the scope of the Program EIR because the intensity of ground disturbance of treatments is consistent with that
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-14 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR analyzed in the Program EIR. As explained in the Program EIR, while tribal cultural resources may be identified in the treatable landscape during development of later treatments, implementation of SPRs would avoid any substantial adverse change to any tribal cultural resource. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the tribal cultural affiliations present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact on tribal cultural resources is also the same, as described above. SPRs applicable to this impact are AD-3, CUL-1 through CUL6, and CUL-8. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT CUL-4
Vegetation treatment activities would include mechanical treatments using heavy equipment, including skid steers, excavators, dozers, and masticators, which could uncover human remains. The NWIC records search revealed burials and sites containing human remains within the project area; however these sites are considered archaeological resources and will therefore be avoided according to the provisions of SPR CUL-5. The potential for treatment activities to uncover human remains was examined in the Program EIR. This impact is within the scope of the Program EIR because the treatment activities and intensity of ground disturbance are consistent with those analyzed in the Program EIR. Additionally, consistent with the Program EIR, the project would comply with California Health and Safety Code Section 7050.5 and PRC Section 5097 in the event of a discovery. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the potential for uncovering human remains during implementation is essentially the same within and outside the treatable landscape and treatment activities; therefore, the impact related to disturbance of human remains is also the same, as described above. The SPR applicable to this impact is AD-3. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW ARCHAEOLOGICAL, HISTORICAL, AND TRIBAL CULTURAL RESOURCE IMPACTS The proposed treatment is consistent with the treatment types and activities considered in the CalVTP Program EIR.
The project proponent has considered the site-specific characteristics of the proposed project and determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.5.1, “Environmental Setting,” and Section 3.5.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed project area constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to archaeological, historical, or tribal cultural resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape.
Revisions to SPR CUL-4, as described in Section 1.3.2, “Proposed Project Revisions,” and shown in the MMRP (Attachment A), would constitute a change to the project analyzed in the Program EIR. Revisions to SPR CUL-4 exempt certain treatment activities (e.g., manual treatments, when woody material is chipped and scattered, chipped and removed, or lopped and scattered) from needing an archaeological and historical resource survey. Requirements under SPR CUL-4 are intended to prevent damage to archaeological and historical resources. Activities that may result in damage to cultural resources (e.g., mechanical treatments and prescribed burning) would still require pretreatment surveys; therefore, revisions to SPR CUL-4 would not result in a new impact that was not analyzed in the Program EIR. Therefore, the impacts of the proposed project are also consistent with those covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape, and revisions to SPR CUL-4, would not give rise to any new significant impacts. Therefore, no new impact related to archaeological, historical, or tribal cultural resources would occur.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-15
4.5 BIOLOGICAL RESOURCES
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance in
the Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project
List MMs
Applicable to
the Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be a
Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact BIO-1: Substantially
Affect Special-Status Plant
Species Either Directly or
Through Habitat Modifications
LTSM Impact BIO-1,
pp 3.6-131 –
3.6-138
Yes AD-1
AQ-3, AQ-4
BIO-1, BIO-2
BIO-7, BIO-9
GEO-1, GEO-3
GEO-4, GEO-5
GEO-7
HYD-5
BIO-1a, BIO-1b
BIO-1c
LTSM No Yes
Impact BIO-2: Substantially
Affect Special-Status Wildlife
Species Either Directly or
Through Habitat Modifications
LTSM (all
wildlife
species
except
bumble bees)
PSU (bumble
bees)
Impact BIO2, pp 3.6-138
– 3.6-184
Yes AD-1
BIO-1, BIO-2
BIO-3, BIO-4
BIO-5, BIO-6
BIO-9, BIO-10
BIO-11, BIO-12
HAZ-5, HAZ-6
HYD-1, HYD-3
HYD-4, HYD-5
BIO-2a, BIO-2b
BIO-2c, BIO-2e
BIO-2g, BIO-3a
BIO-3b, BIO-3c
BIO-4, BIO-5
LTSM No Yes
Impact BIO-3: Substantially
Affect Riparian Habitat or
Other Sensitive Natural
Community Through Direct
Loss or Degradation That Leads
to Loss of Habitat Function
LTSM Impact BIO3, pp 3.6-186
– 3.6-191
Yes AD-1
BIO-1, BIO-2
BIO-3, BIO-4
BIO-5, BIO-6
BIO-9
HYD-4, HYD-5
CHAP/CSS-1
BIO-3a
BIO-3b
BIO-3c
LTSM No Yes
Impact BIO-4: Substantially
Affect State or Federally
Protected Wetlands
LTSM Impact BIO4, pp 3.6-191
– 3.6-192
Yes AD-1
BIO-1
HYD-1, HYD-3
HYD-4
BIO-4 LTSM No Yes
Impact BIO-5: Interfere
Substantially with Wildlife
Movement Corridors or
Impede Use of Nurseries
LTSM Impact BIO5, pp 3.6-192
– 3.6-196
Yes AD-1
BIO-1, BIO-4
BIO-5, BIO-10
BIO-11
HYD-1, HYD-4
BIO-5 LTSM No Yes
Impact BIO-6: Substantially
Reduce Habitat or Abundance
of Common Wildlife, Including
Nesting Birds
LTS Impact BIO6, pp 3.6-197
– 3.6-198
Yes AD-1
BIO-1, BIO-2
BIO-3, BIO-4
BIO-5, BIO-12
NA LTS No Yes
Impact BIO-7: Conflict with
Local Policies or Ordinances
Protecting Biological Resources
NI Impact BIO-7,
pp 3.6-198 –
3.6-199
Yes AD-1
AD-3
NA NI No Yes
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-16 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance in
the Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project
List MMs
Applicable to
the Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be a
Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Impact BIO-8: Conflict with the
Provisions of an Adopted
Natural Community
Conservation Plan, Habitat
Conservation Plan, or Other
Approved Habitat Plan
NI Impact BIO8, pp 3.6-199
– 3.6-200
Yes AD-1 NA NI No Yes
Notes: LTS = less than significant; LTSM = less than significant with mitigation; NI = no impact; PSU = potentially significant and unavoidable; SU = significant and unavoidable; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact; None = there are SPRs and/or MMs identified in the Program EIR for this impact, but none are applicable to the treatment project.
New Biological Resources Impacts: Would the treatment result in other impacts to biological resources that are not evaluated in the CalVTP Program EIR? Yes No If yes, complete row(s) below and discussion Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
Pursuant to SPR BIO-1, Ascent biologists conducted a data review of project-specific biological resources, including habitat and vegetation types, special-status plants, special-status wildlife, and sensitive habitats (i.e., sensitive natural communities, oak woodlands, riparian habitat, chaparral, coastal sage scrub, and wetlands) with potential to occur in the project area. The 2020 Santa Cruz and Santa Clara Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2023) and the 2018 San Mateo County Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2022) were used to identify the habitat/vegetation types within the project area. These fine-scale vegetation data follow the same standards, framework, and hierarchy used by both A Manual of California Vegetation (Sawyer et al. 2009) and the National Vegetation Classification System.
The project area lies within the Central California Coast ecoregion and spans a broad elevational range, from approximately 98 feet near the Santa Clara Valley floor in the north to about 3,790 feet in the Santa Cruz Mountains in the south, resulting in a wide diversity of vegetation types. Vegetation types within the project area and total acreage of each type are presented in Table 4.5-1.
A list of special-status plant and wildlife species with potential to occur in the project area was compiled by completing a review of the California Natural Diversity Database (CNDDB) and California Native Plant Society Inventory of Rare and Endangered Plants of California records for the US Geological Survey (USGS) quadrangles containing and surrounding the project area (30 quadrangles total) (CNDDB 2025a; CNPS 2025a); the USFWS Information for Planning and Consultation (IPaC) tool (USFWS 2025a); Appendix BIO-3 (Table 4a, Table 4b, Table 13a, Table 13b, Table 14a, Table 14b, and Table 19) in the Program EIR (Volume II) for special-status plants and wildlife that could occur in the Central California Coast Range ecoregion; and the Santa Clara Valley Habitat Plan (SCVHP) covered species list for special-status plants and wildlife. A list of sensitive natural communities with potential to occur in the project area was compiled by completing a CNDDB search of the USGS quadrangles containing and surrounding the project area (CNDDB 2025a) and reviewing the 2020 Santa Cruz and Santa Clara Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2023) and the 2018 San Mateo County Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2022).
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-17 Table 4.5-1 Vegetation Types in the Project Area
Vegetation/Land Cover Type Ecological
Restoration (Acres) WUI (Acres)1
Fuel Break
(Acres) Total (Acres)2
Forest/Woodland
Acacia melanoxylon provisional semi-natural association 3.9 0.5 5.1 9.5 Acer macrophyllum mapping unit 96.4 15.9 26.6 138.9
Acer macrophyllum – Pseudotsuga menziesii / Polystichum munitum association
4.4 0.7 2.2 7.3
Aesculus californica alliance 225.2 15.2 131.1 371.5
Arbutus menziesii alliance 180.1 13.8 61.4 255.3
Eucalyptus (globulus, camaldulensis) provisional semi-natural association
49.7 58.1 234.2 342
Forest fragment 198.1 48.2 243.9 490.2
Notholithocarpus densiflorus alliance 821.5 36.2 276.4 1134.1 Pinus attenuata alliance 407.1 196.5 584.1 1187.7
Pinus coulteri alliance 2.0 — — 2
Pinus radiata plantation provisional semi-natural association — 0.0* — 0 Pinus sabiniana woodland alliance 52.1 7.2 63.3 122.6
Pseudotsuga menziesii–Notholithocarpus densiflorus /
Vaccinium ovatum association
3,639.3 335.8 1,764.7 5739.8
Quercus (agrifolia, douglasii, garryana, kelloggii, lobata, wislizeni) alliance
536.3 63.3 235.6 835.2
Quercus agrifolia alliance 13,243.8 2,407.7 10,050.7 25702.2 Quercus douglasii alliance 5,296.1 436.6 2,283.0 8015.7 Quercus chrysolepis (tree) alliance 2,414.8 211.2 893.5 3519.5 Quercus kelloggii alliance 1,265.0 144.5 554.8 1964.3
Quercus lobata mapping unit 694.6 297.5 1,115.3 2107.4
Quercus wislizeni–Quercus parvula (tree) alliance 1,493.7 147.5 344.0 1985.2 Sequoia sempervirens alliance 6,471.6 628.1 2,017.9 9,117.6 Umbellularia californica mapping unit 9,360.0 681.1 3,812.0 13,853.1 Forest/woodland total 46,455.7 5,745.6 24,699.8 76,901.1 Shrub/Scrub
Adenostoma fasciculatum alliance3 2,860.3 267.8 894.5 4,022.6 Adenostoma fasciculatum – Salvia spp. alliance3* 258.9 35.7 190.2 484.8 Arctostaphylos (canescens, manzanita, stanfordiana) provisional alliance3
153.1 46.3 82.0 281.4
Arctostaphylos (crustacea, tomentosa) alliance3 375.1 113.0 176.8 664.9 Arctostaphylos (nummularia, sensitiva)–Chrysolepis
chrysophylla alliance3
1.4 — — 1.4
Arctostaphylos glauca alliance3 792.6 70.6 358.0 1,221.2 Artemisia californica–(Salvia leucophiylla) alliance3 647.8 79.6 281.8 1,009.2 Baccharis pilularis alliance 1,385.4 195.0 389.7 1,970.1
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-18 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Vegetation/Land Cover Type Ecological
Restoration (Acres) WUI (Acres)1
Fuel Break
(Acres) Total (Acres)2
Ceanothus cuneatus alliance3 379.4 86.9 279.4 745.7
Ceanothus ferrisiae – Heteromeles arbutifiolia Association 11.9 0.7 13.9 26.5 Ceanothus papillosus Alliance3 2.2 1.1 6.2 9.5
Ceanothus thrysiflorus Alliance 14.4 — — 14.4
Cercocarpus montanus alliance3* 392.9 37.5 132.1 562.5
Cytisus scoparius–Genista monspessulana–Cotoneaster spp. semi-natural alliance
20.8 5.1 11.4 37.3
Eriogonum fasciculatum shrubland alliance310.2 — — 10.2 Frangula californica ssp. californica–Baccharis pilularis / Scrophularia californica association
1.5 1.9 1.0 4.4
Gaultheria shallon–Rubus (ursinus) alliance 2.2 — — 2.2 Lotus scoparius–Lupinus albifrons–Eriodictyon spp. alliance3* 603.4 29.0 169.6 802.0 Prunus ilicifolia–Heteromeles arbutifolia–Ceanothus spinosus alliance3
847.4 68.6 258.6 1,174.6
Quercus berberidifolia alliance31,350.3 155.7 201.4 1,707.4 Quercus durata alliance3 41.2 15.5 52.3 109.0
Quercus wislizeni–Quercus chrysolepis (shrub) alliance3 2.7 — — 2.7 Ribes quercetorum–Rhus trilobata–Frangula californica alliance 1.4 — — 1.4 Salvia mellifera–Artemisia californica alliance31,356.8 153.0 631.4 2,141.2 Shrub fragment 310.5 46.6 220.9 578.0
Toxicodendron diversilobum–(Baccharis pilularis) association 538.8 67.6 232.4 838.8 Shrub/scrub total 12,362.6 1,477.2 4,586.8 18,423.4
Herbaceous
Californian annual and perennial grassland macrogroup 13,326.8 2,169.2 10,400.9 25,896.9 Californian annual and perennial grassland mapping unit 0.6 0.5 0.4 1.5 Californian vernal pool / swale bottomland group — 0.3 — 0.3 Conium maculatum–Foeniculum vulgare semi-natural alliance 3.6 8.1 6.1 17.8 Cortaderia (jubata, selloana) semi-natural alliance 0.2 — — 0.2 Heterotheca (oregana, sessiliflora) herbaceous alliance — — 3.2 3.2 Nonnative herbaceous 94.1 13.8 140.9 248.8
Herbaceous total 13,425.3 2,191.9 10,548.3 26,168.7
Wetland/Riparian1
Acer negundo / (Rubus ursinus) association 11.7 — 0.1 11.8 Alnus rhombifolia alliance 63.0 38.1 54.8 155.9
Arid west interior freshwater marsh group 23.2 1.6 46.4 71.2 Baccharis salicifolia alliance 0.9 1.1 27.8 29.8
Juglans hindsii and hybrids special stands and semi-natural alliance
2.7 2.8 20.3 25.8
Platanus racemosa–Quercus agrifolia alliance 206.6 154.5 678.6 1,039.7 Populus fremontii–Fraxinus velutina – Salix gooddingii alliance 12.5 10.3 220.4 243.2
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-19 Vegetation/Land Cover Type Ecological
Restoration (Acres) WUI (Acres)1
Fuel Break
(Acres) Total (Acres)2
Populus trichocarpa alliance 93.8 0.8 99.0 193.6
Rhus trilobata–Crataegus rivularis–Forestiera pubescens alliance 6.0 — — 6 Rubus armeniacus semi-natural association — 0.3 0.0* 0.3 Salix exigua alliance 4.6 1.3 33.6 39.5
Salix gooddingii–Salix laevigata alliance 124.8 11.9 157.7 294.4 Salix lasiolepis alliance 24.9 5.3 21.4 51.6
Salix lucida ssp. lasiandra association 3.3 1.4 4.2 8.9 Vancouverian lowland marsh, wet meadow and shrubland
group
24.1 0.9 14.5 39.5
Vancouverian lowland marsh, wet meadow and shrubland
macrogroup
18.4 0.4 0.2 19
Wetland/riparian1total 620.5 230.7 1,379.0 2,230.2
Riverine/Lacustrine
Water 666.5 17.7 415.3 1,099.4
Water total 666.5 17.7 415.3 1,099.4
Agricultural
Orchard or grove 8.3 25.0 275.9 309.3
Intensively managed hayfield 350.2 12.5 223.6 586.2
Irrigated pasture 1.7 — — 1.7
Perennial agriculture — 0.0* — 0.0*
Row crop 120.0 17.4 186.9 324.2
Vineyard 194.4 90.2 787.9 1,072.4
Agricultural total 674.6 145.1 1,474.3 2,293.8
Developed/Disturbed/Barren
Barren and sparsely vegetated 349.4 14.5 120.0 483.8
Developed 137.1 1,263.0 9,506.4 10,906.5
Major road 0.1 58.2 3.0 61.3
Mudflat/dry pond bottom mapping unit 0.6 — — 0.6
Nonnative forest 37.5 668.9 3,919.5 4,625.9
Nonnative shrub 5.5 4.4 37.6 47.5
Nursery or ornamental horticulture area 0.5 2.9 130.9 134.4 Developed/disturbed/barren total 530.7 2,011.9 13,717.4 16,260.0 All Vegetation Types Total 74,735.90 11,820.10 56,820.90 143,376.602 1 A minor discrepancy of approximately 2–3 acres occurs due to projection errors. These overlap acres are included in the WUI acreage totals. 2 Acreages have been rounded to the nearest tenth place from their original values. This has caused minor discrepancies in the total acreage calculation. Values shown as 0.0 acres are not truly zero; they represent hundredths place values that are rounded down when displayed to the nearest tenth.
3 These are chaparral and coastal sage scrub alliances that meet the definitions of the vegetation types subject to the restrictions of the Peremptory Writ of Mandate (writ). Within these chaparral and coastal sage scrub alliances, and pursuant to SPR CHAP/CSS-1, which was developed to be consistent with the writ, only certain ecological restoration treatments, wildland urban interface (WUI) fuel reduction treatments, and fuel break maintenance treatments will be conducted. Implementation of treatments in applicable vegetation types will
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-20 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR conform to the requirements of the Judgment After Appeal (judgment) and writ issued by the San Diego Superior Court in California Chaparral Institute et. al v. Board of Forestry and Fire Protection. *These alliances can be classified as either chaparral or coastal sage scrub habitats in the Key to Shrublands in the CNPS A Manual of California Vegetation, depending on their geographic location and specific species composition. For the purposes of this report and the type conversion analysis in Impact BIO-3, the Adenostoma fasciculatum–Salvia spp. alliance and the Cercocarpus montanus alliance are considered chaparral habitat, and the Lotus scoparius–Lupinus albifrons–Eriodictyon spp. alliance is considered coastal sage scrub habitat.
Sources: Tukman Geospatial and Aerial Information Systems 2022, 2023; compiled by Ascent in 2025.
Ascent conducted reconnaissance surveys on August 5 through 7, 2025, to identify and document sensitive resources (i.e., sensitive natural communities, oak woodlands, riparian habitat, chaparral, coastal sage scrub, and wetlands) and to assess the suitability of habitat in the project area for special-status plant and wildlife species. Mapped vegetation types were verified where possible. Reconnaissance surveys were conducted by walking and driving on public land (i.e., city parks, Santa Clara County Parks and Recreation Department, Santa Clara Valley Open Space Authority, Santa Clara Valley Water District, Santa Clara Valley Habitat Agency, and Midpeninsula Regional Open Space District) and “windshield” surveys from public roads in areas where permission to enter was not granted. The reconnaissance surveys did not cover every acre of the project area; reflecting the intent and requirements of SPR BIO-1 and leveraging the existing high-quality fine-scale vegetation map data, these surveys focused on representative sections that reflect the broader project area. Evidence of past vegetation treatment projects that have been implemented within and adjacent to the project area were observed during reconnaissance surveys (see Section 1.4.2, “Project Area Conditions,” for additional details).
In accordance with implementation of SPR BIO-1, including review of occurrence data, species ranges, habitat requirements for each species, results of reconnaissance-level surveys, and habitat and vegetation present within the project area as assessed during reconnaissance surveys, a complete list of all species with potential to occur in the vicinity of the proposed project along with genus and species names, and federal and state listing status was assembled (Attachment B). These species are discussed in detail under Impact BIO-1 (special-status plants) and Impact BIO-2 (special-status wildlife).
IMPACT BIO-1
Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse effects on specialstatus plant species that are present in the project area. Potential impacts resulting from maintenance activities would generally be the same as those resulting from initial vegetation treatments because the same treatment activities would occur. However, treatment frequency and intensity can determine whether effects on certain plant species are beneficial or adverse. Initial treatment that reduces overgrowth, opens the tree canopy to allow more light penetration, or removes invasive competitors can be beneficial for special-status plant populations; however, repeated treatments at too frequent intervals can have adverse effects on those same special-status plants.
SPR BIO-7 would apply to all treatment activities, including maintenance treatments, and protocol-level surveys for special-status plants would be conducted pursuant to Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018a) prior to implementing manual treatment, mechanical treatment, prescribed burning, herbicide application, or prescribed herbivory in any habitat potentially suitable for special-status plants. Pursuant to SPR BIO-7, surveys would not be required for special-status plants not listed under the California Endangered Species Act (CESA) or the federal Endangered Species Act (ESA) if all the following conditions apply:
the target special-status plant species is an herbaceous annual species, stump-sprouting species, or geophyte species (e.g., perennial rhizomatous herbs);
the treatment is carried out during the dormant season for that species or when the species has completed its annual life cycle;
the treatment would not alter habitat in a way that would make it unsuitable for the special-status plants to reestablish following treatment; and
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-21 treatments are limited to those that do not disturb below the soil surface (i.e., manual treatments, herbicide application, prescribed herbivory, and broadcast burning) as not to destroy seeds, stumps, or roots, rhizomes, bulbs, or other underground parts of special-status plants.
However, this would require that treatments in habitat potentially suitable for these special-status plants be restricted to the dormant season for these species and to treatments that do not disturb below the soil surface (i.e., manual treatments, broadcast burning, prescribed herbivory, herbicide application) without prior knowledge of their presence, which may unnecessarily or infeasibly constrain treatment implementation. In this case, surveys would be conducted to determine presence or absence and, depending on the results, may provide greater flexibility in terms of the timing and types of treatments that may be implemented.
Multiple special-status plant species that may occur within the project area are herbaceous annual species or geophytes, and are not listed under ESA or CESA, as indicated in Attachment B. Impacts on these species would be avoided by implementing non-ground-disturbing treatment activities (i.e., manual treatments, prescribed burning, prescribed herbivory, herbicide application) during the dormant season (i.e., when the plant has no live aboveground parts), which would typically occur after seed set and before germination. Typically, germination will occur after the first significant rainfall (approximately 0.5 inches), and cold snap, which generally occurs between October and December (Levine et al. 2008). Control lines for prescribed burning would have to be created outside of potential habitat for special-status plants, or the proposed control line areas would need to be surveyed for special-status plants, including annual species, stump-sprouting species, and geophyte species, prior to installing any control lines.
Ground-disturbing treatment activities (i.e., mechanical treatments) and pile burning may result in adverse effects on these plant species even when dormant and would not be conducted without prior implementation of SPR BIO-7. If non-ground-disturbing treatments cannot be completed in the dormant season and would be implemented during the growing period of these annual and geophyte species, protocol surveys (per SPR BIO-7) and avoidance of any identified special-status plants (per MM BIO-1b) must be implemented, as described below.
The remaining special-status plant species that have potential to occur in the project area are perennial or moss species, or annual species that are protected under ESA or CESA. Perennials and moss species cannot be avoided seasonally in the same manner as herbaceous annual species, stump sprouters, and geophytes. Pursuant to SPR BIO7, seasonal avoidance does not apply to any species protected under ESA or CESA regardless of its life form.
Therefore, protocol-level surveys under SPR BIO-7 would be necessary to identify these species prior to implementing treatment activities in habitat that may support these species, regardless of the timing of treatments.
Where protocol-level surveys are required (per SPR BIO-7) and special-status plants are identified during these surveys, MMs BIO-1a and BIO-1b, depending on species status, would be implemented to avoid loss of identified special-status plants. Pursuant to MMs BIO-1a and BIO-1b, if special-status plants are identified during protocol-level surveys, a no-disturbance buffer of at least 50 feet would be established around the area occupied by the species within which prescribed burning, mechanical treatment, manual treatment, targeted herbicide treatment, and prescribed herbivory would not occur unless a qualified RPF or botanist determines that a smaller buffer will be sufficient to avoid killing or damaging plants.
If a no-disturbance buffer is reduced less than 50 feet from an ESA- or CESA-listed plant, a qualified RPF or botanist shall provide the project proponent with a site- or treatment activity–specific explanation for the buffer reduction and a science-based justification for the deviation, which will be included in the completion report. The no-disturbance buffer for species not listed under ESA or CESA may be adjusted if a qualified RPF or botanist, at the time of treatment, determines that a smaller buffer will be sufficient to avoid loss of or damaging special-status plants, or that a larger buffer is necessary to sufficiently protect plants from the treatment activity. No fire ignition (and associated use of accelerants) will occur within 50 feet of ESA- or CESA-listed plants, or within the no-disturbance buffer for species not listed under ESA or CESA.
Treatments may not occur in areas occupied by special-status species unless a qualified RPF or botanist determines, based on substantial evidence, that the species would benefit from the proposed treatment in the occupied habitat area. In the case of plants listed pursuant to ESA or CESA, the determination of beneficial effects would need to be made in consultation with CDFW or USFWS or both, depending on species status. If treatments are determined to be
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4-22 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR beneficial and would be implemented in areas occupied by special-status plants, under the specific conditions described in MMs BIO-1a and BIO-1b, additional impact minimization and avoidance measures or design alternatives to reduce impacts would be identified. A qualified RPF or botanist would evaluate the appropriate treatment design and frequency needed to maintain habitat function for special-status plants. Initial and follow-up treatments would be implemented in a manner that sustains habitat function for the special-status plant species present. If significant impacts on listed or non-listed special-status plants cannot feasibly be avoided, then MM BIO-1c will apply, and compensatory mitigation will be required.
In addition, pursuant to SPR HYD-5, nontarget vegetation and special-status plant species would be protected from herbicides. No herbicides will be applied within a 50-foot buffer of ESA- or CESA-listed plant species. For spray applications in and adjacent to habitats suitable for special-status species, herbicides containing dye will be used to prevent overspray. In riparian habitats, herbicides would be applied by hand and only during low-flow periods or when seasonal streams are dry. To avoid nontarget vegetation via run-off or aerial drift, herbicide application will not occur during precipitation events, sustained winds, or when weather parameters exceed label specifications.
As described under Section 2.1.1, “General Prescription,” revegetation and replanting would be conducted post-fire where needed to restore desired vegetation composition and forest structure. Efforts will consider native forest conditions, burn severity, and site-specific vegetation types. Treatments may include planting and erosion control measures (e.g., mulching, straw application, seeding with soil-stabilizing species, and silt fences). Revegetation and replanting activities will comply with SPR BIO-9 to prevent the spread of invasive plants. All equipment, vehicles, footwear, and tools will be cleaned before entering and leaving treatment areas. Planting stock and materials used for erosion control or soil stabilization will be sourced from weed-free suppliers, following the Fire and Fuel Management Best Management Practices (BMPs) outlined in Preventing the Spread of Invasive Plants: Best Management Practices for Land Mangers (Cal-IPC 2012, or current version). This includes use of certified weed-free straw, mulch, gravel, and seed. All plant materials used for revegetation will exclude any species listed on the California Invasive Plant Council (Cal-IPC) Invasive Plant Inventory (Cal-IPC 2025, or current version) or designated as noxious weeds by the local agricultural commissioner’s office. These measures reduce the risk of introducing or spreading invasive plants during restoration, while supporting successful establishment of desired native vegetation.
Revegetation efforts will consider existing conditions, including existing vegetation type and burn severity, and will be designed to maintain or restore appropriate vegetation composition. In areas documented as native vegetation types according to the 2020 Santa Cruz and Santa Clara Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2023) and the 2018 San Mateo County Fine Scale Vegetation Map (Tukman Geospatial and Aerial Information Systems 2022), only native plant species characteristic of that vegetation type, as described in the Manual of California Vegetation, online edition (CNPS 2025b), will be used. Exceptions may occur where a mapped native vegetation type reflects past lack of management (e.g., Douglas-fir encroachment) or artificial plantings (e.g., plantations), in which case alternative native vegetation aligned with desired conditions may be selected. For revegetation efforts within 100 feet of special-status plant occurrences, a qualified RPF or biologist will review and approve plant species or seed mixes to ensure they do not result in mortality or degradation of occupied habitat from competition, shading, or changes to soil moisture or chemistry.
Where erosional risks to roads or structures require rapid stabilization, fast-growing, nonnative but noninvasive species or seed mixes may be used. In areas mapped as developed, agriculture, or nonnative vegetation types (nonnative forest, herbaceous, or shrub; semi-natural alliances with an “SNA” state rarity rank), native species appropriate to the desired habitat type will be prioritized whenever feasible. However, when the use of local native species is not feasible, nonnative but noninvasive species may be used.
Conclusion
The potential for treatment activities to result in adverse effects on special-status plants was examined in the Program EIR. This impact on special-status plants is within the scope of the Program EIR because the treatment activities and intensity of disturbance as a result of implementing treatment activities are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-23 project area, the existing habitat characteristics are essentially the same within and outside the treatable landscape (e.g., no resource is affected on land outside the treatable landscape that would not also be similarly affected within the treatable landscape); therefore, the potential impact on special-status plants is also the same, as described above.
As described under Section 1.3.2, “Proposed Project Revisions,” revisions to SPR GEO-1 are proposed. Proposed revisions to SPR GEO-1 would allow for suspension of mechanical treatments, prescribed herbivory, and herbicide treatments if it is raining, soils are saturated, or soils are wet enough to be compacted by mechanical or prescribed herbivory activities, rather than when there is a minimum 30 percent chance of rain. This modification constitutes a revision to the program description analyzed in the Program EIR. Requirements under SPR GEO-1 are intended to prevent soil destabilization during precipitation events that result in soil compaction and disturbance that could have adverse effects on special-status plants if present. Suspension of mechanical, prescribed herbivory, and herbicide treatments in the above-mentioned conditions (e.g., rain, saturated soils, or soils wet enough for compaction to occur) would provide the same level of protection for indirect effects on special-status plants resulting from soil destabilization as the original SPR GEO-1 because these activities would not continue during conditions where soil destabilization could occur. Suspension of these activities would not be based on weather forecasts alone, but rather if weather predictions materialize and lead to precipitation events. Therefore, proposed revisions to SPR GEO-1 would not result in a substantially more severe significant effect on special-status plants than what was covered in the Program EIR.
Biological resource SPRs that apply to project impacts under Impact BIO-1 are SPRs AD-1, AQ-3, AQ-4, BIO-1, BIO-2, BIO-7, BIO-9, GEO-1, GEO-3, GEO-4, GEO-5, GEO-7, and HYD-5. Biological resource MMs that apply to project impacts under Impact BIO-1 are MMs BIO-1a, BIO-1b, and BIO-1c. As explained above, impacts on special-status plants resulting from the proposed project, including proposed revisions to SPR GEO-1, would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-2
Initial vegetation treatments and follow-up maintenance treatments could result in direct or indirect adverse effects on special-status wildlife species and habitat suitable for these species within the project area, as described in the following sections. Potential impacts resulting from maintenance activities would generally be the same as those resulting from initial vegetation treatments because the same treatment activities would occur.
Bay Checkerspot Butterfly
Bay checkerspot butterfly has been documented to occur in portions of the project area (e.g., Santa Teresa Hills, Coyote Valley, Hayes Valley), and although dispersal of the species is limited, it may also be found in other areas of serpentine grassland within the project area (see Attachment B).
Manual treatments, mechanical treatments, prescribed burning, prescribed herbivory and targeted herbicide application within grassland habitat could result in the crushing or burning of host plants and loss of eggs, larvae, and adult bay checkerspot butterflies. The potential for all treatment activities to result in adverse effects on special-status butterflies was examined in the Program EIR.
Bay checkerspot butterfly is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity.
If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and conservation measures contained in the plan for bay checkerspot butterfly would be applied to that portion of the project. As discussed in Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to bay checkerspot butterfly (County Santa Clara et al. 2012a); accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR.
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4-24 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Therefore, impacts on bay checkerspot butterfly through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MM discussed below would apply.
Per SPR BIO-1, if treatment activities occur outside of the serpentine grassland habitat suitable for bay checkerspot butterfly, the species would be physically avoided, and no further measures are needed. Bay checkerspot butterfly and host plants may be present within serpentine grassland habitat in the project area year-round, therefore, seasonal avoidance of bay checkerspot would not be effective to avoid adverse impacts on this species. Therefore, if treatments occur within habitat for the species, SPR BIO-10 would apply, and focused surveys for bay checkerspot butterfly would be required, or presence may be assumed. Because the project area is within the range of the ESAlisted bay checkerspot butterfly and near the only known extant population, MM BIO-2e for bay checkerspot butterfly would be implemented, regardless of the results of SPR BIO-10 surveys, although the implementation of specific measures of MM BIO-2e would be informed by the results of the focused surveys if conducted. Under MM BIO-2e, surveys for bay checkerspot butterfly host plants (i.e., Plantago erecta, Castilleja densiflorus, and C. exserta) would be required; no treatment activities of any kind would occur within 10 feet of host plants in habitat occupied by bay checkerspot butterflies or habitat assumed to be occupied; and no prescribed herbivory would be permitted in known or assumed occupied habitat, unless it can be demonstrated that host plants are unpalatable to the herbivore.
Habitat function for bay checkerspot butterfly would be maintained through prescribed burning, which would result in thinning of nonnative grasses that would approximate conditions under the natural fire regime and provide habitat for the host plants of this species. In addition, MM BIO-2e requires avoidance of host plants in habitat occupied by bay checkerspot or habitat assumed to be occupied and requires that unoccupied habitat be treated in a patchy pattern such that all habitat is not treated in the same year. Furthermore, prescribed burning would maintain serpentine grassland habitat within the project area, which provides habitat for bay checkerspot butterfly.
Pursuant to MM BIO-2e, and because bay checkerspot butterfly is listed under ESA, the Santa Clara County Fire Safe Council (SCCFSC) has notified USFWS on behalf of SFD regarding its determination that mortality, injury, or disturbance would not occur, and habitat function would be maintained. For the reasons summarized above, SFDit was determined that implementation of treatments would maintain habitat function for bay checkerspot butterfly. On December 17, 2025, SCCFSC contacted Ryan Olah at USFWS and described the measures that would be taken to avoid mortality, injury, and disturbance to bay checkerspot butterfly and to maintain habitat function in compliance with MM BIO-2e. No refinements to the project description, SPRs, or MMs related to bay checkerspot butterfly resulted from this consultation.
This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Crotch’s Bumble Bee
Crotch’s bumble bee has been documented within the project area (see Attachment B), and potential grassland, scrub, and open woodland habitat for nesting is present. Bumble bees have three basic habitat requirements: nesting sites for the colonies, availability of nectar and pollen from floral resources throughout the duration of the colony period (spring, summer, and fall), and overwintering sites for the queens. Crotch’s bumble bees nest underground and likely use, at least in part, old rodent burrows (Williams et al. 2014; Xerces Society 2018). Overwintering queens may prefer shaded sites near trees in areas without dense vegetation and north-facing slopes (Liczner and Colla 2019; Williams et al. 2019). Bumble bees in California have been documented overwintering under 1–2 inches of duff, between leaf litter and mineral soil (Williams et al. 2014).
Treatment activities (i.e., manual treatments, mechanical treatments, prescribed burning, prescribed herbivory, and targeted herbicide application) could result in removal of floral resources, as well as inadvertent destruction of bumble bee nests or overwintering sites, if present in the project area, through trampling, crushing, or removal of nesting or overwintering substrate (e.g., downed woody debris, leaf litter). The potential for treatment activities to result in adverse effects on special-status bumble bees was examined in the Program EIR.
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-25 In the Program EIR, MM BIO-2g was proposed as a feasible set of actions to reduce potentially significant impacts on special-status bumble bees by requiring avoidance of prescribed burning and targeted ground application of herbicide treatment during the flight/nesting season and retention of habitat in the range of these species, or compensation for unavoidable loss of special-status bumble bees or habitat function. Recognizing the difficulty in detecting overwintering and nesting bumble bees and determining the occurrence and severity of impacts, limited information about nesting and overwintering behaviors, and the statewide scope of potential effects analyzed, for purposes of good faith and full disclosure under CEQA, this impact was designated in the Program EIR as potentially significant and unavoidable. However, addressing this potential effect at a project-specific level may result in a different significance conclusion if evidence supports it.
Per SPR BIO-1, because Crotch’s bumble bees may use grassland, scrub, and open woodland habitat in the project area year-round, implementation of SPR BIO-10 would be required prior to treatment activities. Under SPR BIO-10, a habitat evaluation for special-status bumble bees would be conducted, and if it determines that habitat for this species is present in a treatment area, focused surveys for Crotch’s bumble bee will be conducted. In lieu of conducting focused surveys (e.g., if conducting a valid survey is not feasible), the potential presence of Crotch’s bumble bee in the project area may be assumed.
If presence of Crotch’s bumble bee is confirmed or assumed within habitat for this species as determined pursuant to SPR BIO-10, then MM BIO-2g would apply, and prescribed (broadcast and pile) burning, mechanical treatments, and targeted herbicide application will be avoided or limited during the colony active season (April through August). If Crotch’s bumble bee nests are detected, then MM BIO-2g will be implemented, and a no-disturbance buffer will be established around active nests for pile burning and mechanical treatments. Furthermore, MM BIO-2g includes additional measures to avoid mortality, injury, or disturbance to Crotch’s bumble bees. These measures include conducting treatments in a patchy pattern to retain floral resources for active colonies and to provide refuge for overwintering bumble bees, restrictions on herbicide application techniques, specific guidance for prescribed burning and biomass placement, and division of the project area such that the entirety of overwintering or colony habitat is not treated in a single year to further provide refuge.
With implementation of MM BIO-2g and applicable SPRs, habitat function for Crotch’s bumble bee would be maintained during and after treatment implementation. Within nesting and overwintering habitat for the species, the general prescription for the project (see Section 2.1.1, “General Prescription”) would retain understory vegetation in a mosaic pattern of patches to maintain habitat heterogeneity and quality, while increasing crown spacing. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape, including preservation of existing grasslands. Ecological restoration treatments would also retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”), which may be used for nesting. WUI treatments would have similar tree retention standards to ecological restoration, which would maintain overwintering habitat for the species, but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”).
Fuel break treatments, both shaded and non-shaded, would remove additional vegetation that provides habitat for Crotch’s bumble bee; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of Crotch’s bumble bee habitat affected by fuel break treatments would not be substantial compared to available habitat across the project area. Furthermore, SPR BIO-5 would be applied, which would retain cover in coastal sage scrub and chaparral habitats used by the species.
Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, and oak woodlands and a mosaic of understory vegetation throughout most of the project area would maintain habitat for Crotch’s bumble bee. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
The proposed vegetation treatments would not cause any conversion or loss of natural land cover or permanent soil disturbance that could remove availability of potential underground nesting or overwintering sites over the long term. With implementation of MM BIO-2g and applicable SPRs, the impact of the project on habitat function for Crotch’s bumble bee would be less than significant with mitigation.
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4-26 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Pursuant to MMs BIO-2a and BIO-2g, the determination that habitat function would be maintained for Crotch’s bumble bee must be made in consultation with CDFW. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for Crotch’s bumble bee and consulted with CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC sent a memo to Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to Crotch’s bumble bee and to maintain habitat function in compliance with MMs BIO-2a and BIO-2g. No refinements to the project description or measures resulted from this notification. These potential effects would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Monarch Butterfly
Monarch butterflies have been documented foraging and breeding in the project area; however, the project area is too far from the coast and bay to provide overwintering habitat for the species (see Attachment B). Monarch butterfly is a candidate for listing under ESA, and as such, currently does not have protection under ESA and is considered an “other special-status species” in the CalVTP Program EIR. However, it is possible that the species will be listed during the life of the project. USFWS also proposed the 4(d) Rule under the ESA, which would provide certain exceptions to “take” prohibitions for projects that have beneficial or negligible impacts on monarch, including forest or fuels management in breeding habitat.
Treatment activities, (i.e., manual treatment, mechanical treatment, prescribed burning, prescribed herbivory, and targeted herbicide application) could result in damage to overwintering site vegetation structure and removal of floral resources used during overwintering or direct mortality of monarch butterflies. Treatments would also occur in grasslands, riparian areas, wetlands, open woodlands, and openings in forests that may provide breeding habitat (i.e., milkweed) for monarchs. Removal of milkweed is not likely during prescribed herbivory treatments because milkweed plants are unpalatable to livestock and contain glycosides that are toxic to goats and sheep. Manual treatment, mechanical treatment, prescribed burning, and targeted herbicide application could result in removal of monarch butterfly hostplants and injury or death of individuals. The potential for treatment activities to result in adverse effects on special-status butterflies was examined in the Program EIR.
Treatments in riparian areas and wetlands would be limited pursuant to SPRs HYD-3, HYD-4, and BIO-4 and MM BIO-4, and milkweed would not be targeted for treatment in these habitats; however, impacts on monarch could still occur in these and other areas that provide habitat for the species. Per SPR BIO-1, if it is not feasible to avoid manual treatment, mechanical treatment, prescribed burning, and targeted herbicide application in breeding habitat when monarch eggs, larvae, and pupae are likely to be present on milkweed (March 15 through October 31), SPR BIO-10 would apply (see SPR BIO-10 in Attachment A).
Pursuant to SPR BIO-10, surveys for milkweed hostplants would be conducted, and if hostplants are found, further surveys for monarch eggs, larvae, and pupae would be conducted or the presence of monarch assumed (see SPR BIO-10 in Attachment A). If breeding monarchs are detected during focused surveys or are assumed to be present on milkweed, then MM BIO-2e would be implemented. Under MM BIO-2e, several measures will be implemented to reduce the likelihood of mortality, injury, or disturbance to monarchs and to maintain habitat function (see MM BIO2e in Attachment A).
Habitat function for monarch would be maintained because all monarch breeding habitat in the project area would not be treated at once (i.e., treatments in the project area would occur over the course of several years). Prescribed fire and prescribed herbivory would also reduce encroachment of woody species and maintain grassland areas where this encroachment is occurring, potentially maintaining grassland foraging and breeding habitat for monarchs. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Special-Status Fish
Habitat for special-status fish is present in the project area. Southern coastal roach, Monterey hitch, and south-central California coast distinct population segment of steelhead may occur in streams in the southern portion of the project area that is within the Pajaro River basin. Central California coast distinct population segment of steelhead may be
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-27 present in Los Trancos Creek, Coyote Creek, and other streams in the project area that are downstream of fish passage barriers that limit distribution of the species. The potential for treatment activities and maintenance treatments to result in adverse effects on special-status fish was examined in the Program EIR.
Per SPR BIO-1, if it is determined that adverse effects on special-status fish can be clearly avoided by physically avoiding habitat for these species, then mitigation would not be required. Treatments would not occur in aquatic habitat for these species. SPR HYD-4 would be implemented, which prohibits operating heavy equipment, crossing watercourses unless dry, equipment fueling, placement of burn piles, and fire ignition within the WLPZ. In addition, prescribed herbivory treatments would be excluded within 50 feet of environmentally sensitive areas, pursuant to SPR HYD-3. Furthermore, SPRs HAZ-5, HAZ-6, and HYD-5 would apply to targeted herbicide application treatments and would require measures that would reduce the likelihood of contaminated runoff from treatment activities reaching the streams that are habitat for special-status fish (see Attachment A). Therefore, adverse effects on special-status fish would be clearly avoided through implementation of these SPRs, and further measures would not be required.
Habitat function for special-status fish would be maintained because treatment activities and maintenance treatments would not occur in aquatic habitat. Furthermore, treatments within WLPZs adjacent to aquatic habitat would be limited pursuant to SPR HYD-4, which requires retention of at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation. This riparian vegetation standard would maintain stream shading and avoid increases in water temperature. In addition, SPR HYD-3 would require that prescribed herbivory treatments are excluded from habitat for these species, and HYD-1 requires compliance with water quality regulations. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
California Red-Legged Frog
California red-legged frog has been documented in multiple portions of the project area from Los Trancos Creek to the Pajaro River and east to Coyote Creek (see Attachment B). Adult and juvenile California red-legged frogs are known to travel through upland habitats (e.g., riparian, woodland, grassland) to move between breeding and nonbreeding sites (e.g., other ponds, deep pools in streams, moist and cool riparian understory, burrows) for access to refugia and foraging habitat, or to disperse to new breeding locations. Movements through upland habitats are known to occur up to approximately 1 mile over the course of a wet season (Bulger et al. 2003). During migration, California red-legged frogs may travel longer distances from aquatic habitat and typically travel in straight lines irrespective of vegetation types; individuals have been documented to move more than 1.7 miles between aquatic habitat sites (Bulger et al. 2003). However, studies have demonstrated that California red-legged frogs generally remain very close to breeding ponds during the nonbreeding season and typically do not move more than a few hundred feet into upland habitats (Bulger et al. 2003; Fellers and Kleeman 2007). California red-legged frogs generally make overland movements (i.e., dispersal, migration, foraging) during the wet season (i.e., October to May), and these movements are typically made at night (Bulger et al. 2003).
Prescribed herbivory would not result in injury or mortality to California red-legged frog because the species would be expected to move to avoid grazing animals, and grazing is not likely to remove or collapse cover for California red-legged frog. Manual treatment, mechanical treatment, prescribed burning, and herbicide use activities may adversely affect this species through direct loss, injury, or other disturbance of individuals if the species is present in treatment areas. Workers conducting manual treatment activities and herbicide application on foot are unlikely to cause injury, mortality, or substantial disturbance to individual California red-legged frog because they move relatively slowly throughout the project area. However, vehicles associated with these treatment activities have the potential to crush individual frogs that may take refuge under vehicles, and if vehicles are driven over areas containing mammal burrows, burrow collapse may result in injury or mortality of any frogs using burrows for refuge.
The potential for treatment activities and maintenance treatments to result in adverse effects on California redlegged frog was examined in the Program EIR.
California red-legged frog is a covered species under the SVCHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity.
If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the
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4-28 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to that portion of the project. Also as discussed for Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to California red-legged frog (County Santa Clara et al. 2012a). Accordingly, this determination for proposed project treatments would be consistent with the less-than-significant determination in the Program EIR.
Therefore, impacts on California red-legged frog through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
The implementation of SPRs HAZ-5, HYD-1, HYD-3, and HYD-4 (see Attachment A) would reduce the impacts of treatment activities by setting buffers around aquatic habitats and limiting activities within those buffers. These SPRs would also reduce impacts on California red-legged frog from manual treatment, mechanical treatment, prescribed burning, and targeted herbicide application. However, injury or mortality cannot be completely avoided by limiting the season or physical location of treatment pursuant to SPR BIO-1 for treatments in habitat for the species, because the species is known to occur year-round and may travel up to 1.7 miles away from aquatic habitat. As a result, the aquatic habitat buffers and treatment limitations would not be sufficient to fully avoid adverse effects on California red-legged frogs.
Because impacts on the species cannot be physical or temporally fully avoided when treatments occur in habitat for the species, SPR BIO-10 would apply. Pursuant to SPR BIO-10, protocol surveys (see SPR BIO-10 in Attachment A) would be conducted, or presence of California red-legged frog would be assumed. If California red-legged frogs are detected during SPR BIO-10 surveys, or presence is assumed, MM BIO-2a will be required.
Because the project area contains potential breeding and nonbreeding habitat, MM BIO-2a would require seasonal pretreatment visual surveys, monitoring during treatments near aquatic habitat, and work stoppages and would prohibit mechanical treatments following precipitation events. Furthermore, targeted herbicide use during project implementation would comply with the herbicide use restrictions in the stipulated injunction issued by the Federal District Court for the Northern District of California (see MM BIO-2a Attachment A).
Habitat function for California red-legged frog would be maintained because downed woody debris would be retained (except for fuel breaks) in strategic locations to maintain forest floor complexity, with a preference for larger, complex logs, generally greater than 12 inches in diameter and totaling approximately 10 tons per acre. Removal of understory vegetation would occur, but a minimum of 10–25 percent understory plant cover per acre would be retained, which would provide shaded, moist microhabitats that support dispersal and cover. Vegetation would be retained in clumps and mosaics to sustain habitat heterogeneity and connectivity, thereby maintaining movement corridors and reducing fragmentation. Root systems would be left intact to allow resprouting and long-term understory recovery. Chipped biomass will not exceed an average of 3 inches in depth, which will allow vegetation to resprout. In addition, degradation of California red-legged frog aquatic habitat that could result from targeted herbicide treatments would be avoided and minimized by implementation of SPRs HAZ-5, HAZ-6, and HYD-5 (see Attachment A), which would retain aquatic habitat function. Habitat for California red-legged frog within oak woodlands and sensitive natural communities would also be maintained through implementation of MM BIO-3a (see Impact BIO-3). MM BIO-4 will further reduce potential impacts by requiring protection of state and federally protected wetlands, which include aquatic habitat for California red-legged frog (see Impact BIO-4). Pursuant to SPR BIO-4, at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation within riparian corridors would be maintained, providing continued habitat function for California red-legged frogs in riparian areas.
Pursuant to MM BIO-2a, and because this species is listed under ESA, SFD must notify USFWS about its proposed measures to avoid mortality, injury, and disturbance of the species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for California red-legged frog and contacted USFWS to seek technical
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-29 input on this determination, as required. On December 17, 2025, SCCFSC contacted Ryan Olah at USFWS on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to California redlegged frogs and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures related to California red-legged frog resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
California Tiger Salamander
The project is within the range of the Central California distinct population segment of California tiger salamander, and individual California tiger salamanders have been documented in grasslands along the eastern and southern portions of the project area (see Attachment B). Aquatic habitat for the species consists of vernal pools, other seasonal wetlands, and seasonal ponds. Grassland and woodland habitats in the project area within 1.3 miles of aquatic habitat may be used as upland habitat for the species.
Manual tree and shrub pruning, prescribed herbivory, and targeted herbicide application are not likely to result in injury, death, or substantial disturbance of individuals due the limited vegetation and ground disturbance that would result from these activities. However, vehicles used for these treatment activities have the potential to crush individual salamanders that may take refuge under vehicles, and if vehicles are driven over areas containing mammal burrows, burrow collapse may result in injury or mortality of any salamanders using burrows for refuge. Mechanical treatments that result in burrow collapse and pile burning (if piles are placed on or near occupied burrows) may cause injury, mortality, or substantial disturbance year-round. In addition, mechanical treatments, manual tree and snag removal, and prescribed burning may cause injury or mortality to individual California tiger salamanders if these activities occur when California tiger salamanders are aboveground during the dispersal season (November 1–April 30). The potential for treatment activities and maintenance treatments to result in adverse effects on California tiger salamander was examined in the Program EIR.
California tiger salamander is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity.
If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to that portion of the project. Also as discussed for Impact BIO-8, participation in the SCVHP requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to California tiger salamander (County Santa Clara et al. 2012a); accordingly, this determination for proposed project treatments would be consistent with the less-than-significant determination in the Program EIR.
Therefore, impacts on California tiger salamander through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
Implementation of SPRs HAZ-5, HAZ-6, and HYD-5 would reduce impacts on California tiger salamander from targeted herbicide treatments (see Attachment A); however, impacts from herbicide application (other than cut stump and basal bark methods) may still occur. Pursuant to SPR BIO-1, if it is not feasible to avoid mechanical treatments or pile-burning activities within 1.3 miles of aquatic habitat or to avoid broadcast burning, manual tree removal, or herbicide application (other than cut stump and basal bark methods) during the dispersal season for the species (November 1–April 30), then SPR BIO-10 would apply. Per SPR BIO-10, protocol-level surveys would be conducted for California tiger salamander in habitat potentially suitable for the species, or presence of the species would be assumed (see Attachment A). If the species is detected during surveys or assumed to be present, MM BIO-2a would be implemented to avoid injury or mortality of the species including pretreatment surveys, limiting heavy equipment (e.g., tracked chippers and masticators) to compacted surfaces or away from small mammal burrows, and placement of burn piles away from small mammal burrows (see MM Bio-2a in Attachment A).
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4-30 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Habitat function for California tiger salamander would be maintained because upland habitat for the species (i.e., grasslands, open woodlands) would be maintained, and additional open woodland habitat would likely be improved or restored through burning, thinning, and removal of ladder fuels. In areas where Douglas-fir trees are encroaching into grasslands, encroaching trees may be removed to restore grassland habitat, which would maintain and improve habitat used by California tiger salamander In addition, impacts on California tiger salamander habitat from targeted herbicide treatments would be avoided and minimized by implementation of SPRs HAZ-5, HAZ-6, and HYD-5 (see Attachment A). Small stands of immature oak trees (i.e., young oak stands that do not have an established, dominant overstory) would be retained, with a cluster radius of approximately 15–25 feet (30-to-50-foot diameter) and spaced approximately 75–100 feet apart. Oak woodland habitat for California tiger salamander would further be maintained through implementation of MM BIO-3a (see Impact BIO-3). MM BIO-4 would further reduce potential impacts by requiring protection of state and federally protected wetlands, which include aquatic habitat for California tiger salamander (see Impact BIO-4).
Pursuant to MM BIO-2a, and because this species is listed under CESA and ESA, SFD must notify CDFW and USFWS about its proposed measures to avoid mortality, injury, and disturbance of the species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for California tiger salamander and contacted CDFW and USFWS to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to California tiger salamanders and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures related to California tiger salamander resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Foothill Yellow-Legged Frog
Foothill yellow-legged frog has been documented within the project area along and south of Los Gatos Creek and occurred historically in the Stevens Creek Watershed (see Attachment B). This species is typically found in perennial streams and areas directly adjacent to streams, depending on the time of year. During the fall and winter, the species may be found in the uplands near streams, and in the spring, individuals move to wider sunlit channels to breed. The species is highly aquatic and is rarely found farther than 36—150 feet from perennial water (CDFW 2018b). A longer dispersal distance has been noted from perennial waterways (over 4.3 miles); although in this observation, the individual frog primarily used wetted channels for dispersal (CDFW 2018b).
Pursuant to SPR HYD-4, a WLPZ of 50 to 150 feet adjacent to all Class I and Class II streams would be implemented.
However, these measures may not result in full avoidance of foothill yellow-legged frogs if frogs travel beyond these buffers or if manual activities implemented within the WLPZ resulted in injury or mortality of frogs. With implementation of SPRs to reduce impacts to aquatic habitat, prescribed herbivory would not result in injury or mortality to foothill yellow-legged frogs because the species would be expected to move to avoid grazing animals, and grazing is not likely to remove or collapse cover for foothill yellow-legged frog in upland habitats. However, treatment activities, including manual tree and snag removal, mechanical treatments, prescribed burning, and targeted herbicide application conducted within upland foothill yellow-legged frog habitat could result in injury or mortality of individuals. The potential for treatment activities, including maintenance treatments, to result in adverse effects on foothill yellow-legged frog was examined in the Program EIR.
Foothill yellow-legged frog is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity.
If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and then the conservation measures contained in the plan would be applied to that portion of the project. Also as discussed for Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to foothill yellow-legged frog (County Santa Clara et al. 2012a); accordingly, this determination for
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-31 proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts to foothill yellow-legged frog through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
Implementation of SPRs HAZ-5, HYD-1, HYD-3, and HYD-4 (see Attachment A) would reduce the impacts of treatment activities by setting buffers around aquatic habitats and limiting activities within those buffers, but because the species is present year-round and the species may be present outside of those buffers, effects on foothill yellowlegged frog would not be completely avoided with implementation of these SPRs. Pursuant to SPR BIO-1, a nodisturbance buffer would be established if feasible within 200 feet of aquatic habitat determined to be suitable for this species, and within this buffer, manual, mechanical, and herbicide application (other than cut-stump and basal bark application) would be prohibited.
Because foothill yellow-legged frogs may travel more than 200 feet from aquatic habitat and because implementation of the buffer pursuant to SPR BIO-1 may not be feasible, effects on the species may not be fully avoided with implementation of SPRs BIO-1 and BIO-10 would be required. Focused surveys for foothill yellow-legged frog would be conducted within 200 feet of aquatic habitat for this species prior to implementation of manual tree and snag removal, mechanical treatments, prescribed burning, and targeted herbicide treatments (other than cut stump and basal bark application), or presence would be assumed pursuant to SPR BIO-10. If no foothill yellowlegged frogs are observed during focused surveys, then additional mitigation would not be required. If foothill yellow-legged frogs are observed during focused surveys or presence of the species is assumed, then MM BIO-2a will be implemented. Under MM BIO-2a, biological monitoring and work stoppages would be implemented to avoid injury to or mortality of individual foothill yellow-legged frogs.
Habitat function for foothill yellow-legged frog would be maintained because select large downed logs would be retained where they do not create an additional hazard or prevent project objectives from being met (e.g., downed logs would not be retained within fuel breaks, see Sections 2.1, “Treatment Prescription,” and 2.2, “Treatment Types”).
Removal of understory vegetation would occur, but a minimum of 50 percent of the understory canopy would be retained within riparian habitats per SPR BIO-4. Outside riparian areas, vegetation would be retained in clumps and mosaics to sustain habitat heterogeneity and connectivity, and root systems would be left intact to allow resprouting and long-term understory recovery. Chipped biomass will not exceed an average of 3 inches in depth. In addition, impacts on foothill yellow-legged frog habitat from targeted herbicide treatments would be avoided and minimized by implementation of SPRs HAZ-5, HAZ-6, and HYD-5 (see Attachment A). Although the species is most often found in riparian and aquatic habitats, upland oak woodland habitat suitable for foothill yellow-legged frog would also be maintained through implementation of MM BIO-3a (see Impact BIO-3). MM BIO-4 would further reduce potential impacts by requiring protection of state and federally protected wetlands, which include aquatic habitat for foothill yellow-legged frog (see Impact BIO-4). Pursuant to SPR BIO-4, at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation within riparian corridors would be maintained.
Pursuant to MM BIO-2a and because this species is listed under CESA and ESA, SFD must notify CDFW and USFWS about its proposed measures to avoid mortality, injury, or disturbance of the species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for foothill yellow-legged frog and contacted CDFW and USFWS to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to foothill yellow-legged frogs and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures related to foothill yellow-legged frog resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Southwestern Pond Turtle
Southwestern pond turtles have been documented throughout the project area from Los Trancos Creek to the Pajaro River and east to Coyote Creek (see Attachment B). Pruning of trees and shrubs, targeted herbicide application, and
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4-32 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR prescribed herbivory are not likely to result in injury, death, or substantial disturbance (e.g., interruption of nest creation) of individuals due the limited vegetation and ground disturbance that would result from these activities.
Prescribed burning, mechanical treatments, and manual tree and snag removal within habitat for southwestern pond turtle may result in the interruption of nest construction, destruction of nests, and injury or death of individuals if present. The potential for initial treatment activities and maintenance treatments to result in adverse effects on southwestern pond turtle was examined in the Program EIR.
Southwestern pond turtle is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity.
If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to the project. Also as discussed for Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to southwestern pond turtle (County Santa Clara et al. 2012a); accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts on southwestern pond turtle through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
The implementation of SPRs-BIO-4, HAZ-5, HYD-1, HYD-3, HYD-4, and HYD-5 (see Attachment A) would reduce the impacts of treatment activities by setting buffers around aquatic habitats and limiting activities within those buffers.
However, these measures may not avoid impacts on southwestern pond turtle when they are present outside of established buffers or if treatment activities implemented within buffers resulted in injury or mortality of southwestern pond turtle. Furthermore, southwestern pond turtle may be present in upland habitats (up to 1,300 feet from aquatic habitat) year-round; therefore, adverse effects on southwestern pond turtles would not be entirely avoided with physical avoidance of habitat pursuant to SPR BIO-1. If treatment activities occur within 1,300 feet of suitable aquatic habitat and prescribed burning, mechanical treatments, or manual tree and snag removal are implemented within habitat for southwestern pond turtles, SPR BIO-10 would apply, and focused surveys for southwestern pond turtle would be required prior to prescribed burning, mechanical treatments, and manual tree and snag removal. If pond turtles are detected during the survey, than MM BIO-2b would apply. Under MM BIO-2b, biological monitoring by a qualified RPF, biologist, biological technician, or trainee will be conducted during all prescribed burning, mechanical treatments, manual tree and snag removal, or herbicide application (other than cut-stump and basal bark application activities) that are conducted within or adjacent to sensitive habitat areas. If any individual pond turtles are detected, a no-disturbance buffer of 100 feet would be implemented, and treatment activities will cease within the area until the animal has left the area.
Southwestern pond turtle is proposed for listing under ESA, and therefore, currently does not have protection under ESA; however, it is possible that the species will be listed during the life of the project. USFWS also proposed the 4(d) Rule, which would provide certain exceptions to “take” prohibitions in the ESA for projects that have beneficial or negligible impacts to the southwestern pond turtle, including wildfire suppression and management projects, such as WSCLRP. If work occurs before the southwestern pond turtle is listed under ESA or if this species is listed with the proposed 4(d) ruling, protective buffers would be implemented pursuant to MM BIO-2b to avoid injury or mortality.
Habitat function for southwestern pond turtle would be maintained because treatment activities and maintenance treatments would not occur in aquatic habitats, and SPRs BIO-4, HYD-4, and HYD-5 would be implemented to protect aquatic and riparian habitat. In addition, impacts on southwestern pond turtle habitat from targeted herbicide treatments would be avoided and minimized with implementation of SPRs HAZ-5, HAZ-6, and HYD-5 (see Attachment A). MM BIO-4 would further reduce potential impacts by requiring protection of state and federally protected wetlands, which include aquatic habitat for southwestern pond turtle (see Impact BIO-4). Upland habitat for the species would be maintained because prescribed burning would thin dense vegetation and target removal of nonnative grasses. Also, in areas where Douglas-fir trees are encroaching into grasslands and other open habitats,
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-33 encroaching trees may be removed to restore habitat. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
San Francisco Gartersnake
The range of San Francisco gartersnake includes San Francisco and San Mateo Counties, with some historic occurrences extending into the base of the Santa Cruz Mountains along the northern and north-western border of the project area. Occurrences have been documented near the town of Woodside, just north of Los Trancos Creek, and within Russian Ridge Open Space Preserve, beyond the northern end of the WSCLRP area. Grasslands contiguous with ponds, creeks, marshes, and wetlands with shallow emergent vegetation and within 6,500 feet of these aquatic habitats (USFWS 2020) support this species; however, the species is not likely to occur in most of the project area because it is outside the geographic range of the species (see Attachment B). This species is active in and near aquatic habitat for most of the year and uses underground rodent burrows or rock piles for shelter during the hibernation period (generally November through February), during which San Francisco gartersnake may occasionally emerge on warm days for dispersal, foraging, and basking.
Pursuant to MM BIO-2a and because this species is listed under CESA and ESA, SFD must notify CDFW and USFWS about its proposed measures to avoid mortality, injury, or disturbance of the species and its determination that habitat function would be maintained after treatments. SFD In initial review of this project, CDFW and USFWS were contacted to seek technical input On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on behalf of SFD regarding San Francisco gartersnake in compliance with MM BIO-2a. Ryan Olah responded on December 18, 2025, stating that USFWS does not consider this species to be present in the action area for WSCLRP and that any garter snakes in the project area would be intergrade individuals with non-listed garter snakes or other non-listed gartersnakes; therefore, San Francisco gartersnake is not expected to occur in this project area.
Other Special-Status Amphibians and Reptiles
California giant salamander, Santa Cruz black salamander, red-bellied newt, coast horned lizard, and Northern California legless lizard are known to occur or may occur within the project area (see Attachment B). California giant salamanders are most likely to be found in wet redwood and Douglas-fir forests within the project area, whereas Santa Cruz black salamanders may be present in conifer forests, oak woodlands, and grasslands. An isolated population of red-bellied newt may be found in riparian and wet forest habitats within the Steven’s Creek watershed; however, the species is not likely to occur south of Los Gatos Creek. Habitat for Northern California legless lizard and coast horned lizard is present in multiple portions of the project area where there is sandy loose soil (see Attachment B).
Prescribed herbivory would not result in injury or mortality to special-status amphibians and reptiles, because the species would be expected to move to avoid grazing animals, and grazing is not likely to remove or collapse cover for special-status amphibians and reptiles. However, manual tree and snag removal, mechanical treatments, prescribed burning, and targeted herbicide treatments (other than basal bark and cut-stump application) conducted in habitat suitable for special-status amphibians and reptiles could result in injury or mortality to these species. The potential for treatment activities to result in adverse effects on special-status reptiles and amphibians was examined in the Program EIR.
These species are present in the project area year-round, and if treatments are conducted in habitat for special-status amphibians and reptiles, effects on these species cannot be clearly avoided pursuant to SPR BIO-1. Therefore, if treatments are conducted in habitat suitable for special-status amphibians and reptiles, SPR BIO-10 would be implemented, and focused surveys would be conducted prior to treatment activities. If individual special-status amphibians and reptiles are detected during pretreatment surveys, then MM BIO-2b would apply, and biological monitoring during treatments, work stoppage, and other measures would be implemented (Attachment A).
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain understory vegetation in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”). WUI treatments would
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4-34 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”).
Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that provides habitat for special-status amphibians and reptiles; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial compared to available habitat in the project area. SPR BIO-4 would be applied to retain riparian habitat function. Furthermore, SPR BIO-5 would be applied, which would retain cover in coastal sage scrub and chaparral habitats used by special-status amphibians and reptiles. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, oak woodlands, and a mosaic of understory vegetation throughout most of the project area would maintain habitat for special-status amphibians and reptiles.
This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Bald Eagle
Bald eagles have been reported to nest and overwinter in the project area, and nesting habitat is present within approximately 1 mile of larger lakes and reservoirs that support fisheries (see Attachment B). Bald eagles overwinter adjacent to foraging habitat (lakes and reservoirs) and may use communal roosts during the winter. Treatments conducted during the nesting season could result in loss of nests, eggs, and young if they disturb active nests; helicopter and drone operations could result in injury or death of individuals year-round due to collisions; and mechanical and manual tree removal could result in loss of communal roosting trees that are vital components of overwintering habitat.
Because the species may be present within the project area year-round and is sensitive to disturbance during both nesting and overwintering, adverse effects on the species cannot be clearly avoided pursuant to SPR BIO-1; therefore, SPR BIO-10 will be implemented, and surveys for both nests and overwintering roosts will be conducted prior treatment activities (see Attachment A). If no active bald eagle nests or communal roosts are observed during focused surveys, then additional avoidance measures for these species would not be required. If active nests or communal roosts are detected during focused surveys, then MM BIO-2a would be required, and no-disturbance buffers would be applied around nests. No treatment activities would occur within these buffers until chicks have fledged or the nest is otherwise no longer active as determined by a qualified RPF or biologist. Additionally, trees containing bald eagle nests would not be removed pursuant to the Bald and Golden Eagle Protection Act. A buffer for helicopter operations and retention of the roost tree would be required around communal roosts.
Habitat for bald eagles would be maintained because the general prescription for the project (see Section 2.1.1, “General Prescription”) would retain trees greater than 16 inches in diameter, other than Douglas-fir, which may be removed up to 36 inches in diameter when needed to reduce encroachment into other existing vegetation types and therefore, would maintain roosting and nesting trees for bald eagles.
Pursuant to MM BIO-2a and because bald eagle is listed under CESA and a fully protected species under California Fish and Game Code, SFD must notify CDFW about its proposed measures to avoid mortality, injury, or disturbance of these species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for golden eagle, Swainson’s hawk, white-tailed kite, and bald eagle and contacted CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to bald eagle and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Burrowing Owl
The species has been documented in the project area in Coyote Valley and Caldero County Park (Attachment B).
Grassland habitat for the species is present in other lower elevation portions of the project area. The eastern portions
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-35 of the project area overlap with the breeding (yearlong) range for burrowing owl, and in this area, nesting may occur in suitable grassland habitat. Most of the project area is outside of the breeding range for burrowing owl but within the winter range of the species, and in these areas, overwintering individuals may be present in burrows or culverts between September 1 and January 31.
Outside of the range of the species, targeted herbicide application is not likely to result in injury, death, or substantial disturbance (i.e., disturbance that could cause burrow abandonment) of overwintering individuals due the limited ground disturbance that would result from this activity. Prescribed burning, other than the disturbance involved in the construction and use of control lines and staging areas, is also not likely to result in injury, death, or substantial disturbance of individuals during the overwintering season (September 1–January 31), because overwintering owls would be able to shelter in a burrow or temporarily flee; prescribed broadcast burns in grassland habitats typically move very quickly and burn at a low intensity, which would allow individual overwintering owls to flee or seek shelter during the short period the burn passes over the burrow. Prescribed herbivory may require placement of fencing, pens, and other infrastructure that causes ground disturbance and can result in injury to, death of, or substantial disturbance to overwintering individuals; however, grazing animal activity is unlikely to result in adverse impacts on burrowing owls because the species is frequently found in areas grazed by native and nonnative ungulates (e.g., deer, elk, cattle, goats), and the herding dogs that may be used for prescribed herbivory are working dogs that are not likely to pursue or injure owls. However, ground-disturbing activities associated with broadcast burning (e.g., control line construction and staging), mechanical treatments, manual tree and snag removal treatments, and placement of infrastructure for prescribed herbivory may result in injury or death of overwintering burrowing owls.
In the easternmost portions of the project area, within the yearlong (breeding) range of the species, the same treatment activities that threaten overwintering owls have the potential to result in injury, death, or substantial disturbance of nesting individuals. Manual tree and snag removal treatments, mechanical treatments, grounddisturbance associated with prescribed burning (e.g., control line construction and staging), and ground disturbance associated with prescribed herbivory (e.g., placement of fencing and other infrastructure) implemented during the nesting season (February 1–August 31) could result in disturbance or loss of burrowing owl burrows, eggs, and young.
In addition, although herbicide treatments would not result in ground disturbance, application close to active nest burrows could cause owls to flush, leading to increased risk of predation.
Burrowing owl is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity. If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to the project. Also as discussed in Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species.
Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to burrowing owl (County Santa Clara et al. 2012a). Accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts on burrowing owl through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR.
If a treatment area or activity is not covered by the SCVHP, then the SPRs and MM discussed below would apply.
As described above, ground-disturbing treatments may result in impacts on overwintering owls if conducted in the overwintering range of the species during the overwintering season. Also, manual treatments, mechanical treatments, prescribed burning, ground disturbance associated with prescribed herbivory (e.g., placement of fencing and other infrastructure), and targeted herbicide application implemented during the nesting season (February 1–August 31) could result in disturbance or loss of burrowing owl burrows, eggs, and young. Therefore, if these activities are conducted within burrowing owl habitat during the sensitive season, effects would not be avoided pursuant to SPR BIO-1, and protocol surveys would be conducted (see SPR BIO-10 in Attachment A). If burrowing owl burrows are detected during surveys (pursuant to SPR BIO-10), MM BIO-2a would apply, and seasonal avoidance and nodisturbance buffers would be implemented to avoid injury or mortality (see MM BIO-2a in Attachment A).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-36 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Habitat function for burrowing owls would be maintained because treatment activities in habitat for burrowing owls, such as mowing or prescribed burning, would thin dense vegetation and nonnative grasses to approximate conditions under the natural fire regime, which would improve habitat to burrowing owls because the species prefers burrows in areas where vegetation is low to reduce predation risk. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because burrowing owl is a candidate for listing under CESA, SFD must consult with CDFW about its determination that mortality, injury, or disturbance would not occur, and habitat function would be maintained. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for burrowing owl and contacted CDFW to seek technical input on this determination, as required.
On December 17, 2025, SCCFSC contacted Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to burrowing owl and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
California Condor
Although California condor is not likely to nest in the project area due to an absence of suitable nesting sites, foraging habitat for California condors (grassland, open coastal scrub, and open chaparral) is present in the project area, and this species is known to occur in the eastern portion of Santa Clara County near Anderson Lake and along SR 152 outside the project area (see Attachment B). Although impacts on nesting California condors would not occur because the species is unlikely to nest within the project area, if California condors are foraging within treatment areas, disruption of normal foraging behavior of California condors may still occur as a result of proposed treatments.
Project-specific guidance to SPR BIO-2 would minimize impacts year-round from all treatment activities on foraging condors (see Attachment A); however, impacts may still occur if condors are actively foraging in the project area during implementation of treatment activities. Therefore, measures to avoid impacts to foraging California condors in MM BIO-2a would apply for all project activities (see Attachment A). MM BIO-2a requires that work crews maintain garbage, hazardous material, equipment, and vehicles in a manner that avoids attracting or harming foraging condors, and requires that treatments temporarily stop if California condors are observed prior to the start of work.
Habitat function for California condor would be maintained because California condors have an expansive range, use a variety of habitats, and would be expected to continue to use existing foraging habitat posttreatment.
Pursuant to MM BIO-2a and because this species is listed under CESA and ESA, SFD must notify CDFW and USFWS about its proposed measures to avoid mortality, injury, or disturbance of the species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for California condor and contacted CDFW and USFWS to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on the behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to California condor and to maintain habitat function in compliance with MM BIO-2a.
No refinements to the project description or measures related to California condor resulted from this notification.
This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR Least Bell’s Vireo
Mature riparian habitat along large, low-elevation streams in the project area may provide nesting habitat for this species (Attachment B). All treatment activities could result in disturbance or loss of least Bell’s vireo, eggs, and young if implemented in habitats for the species during the nesting season (February 1–August 31). In addition, manual treatments and mechanical treatments using handheld power tools (e.g., chainsaws, brush cutters) that occur within 500 feet of nesting habitat for the species may cause nest abandonment resulting in loss of nests, eggs, and young, due to the noise associated with these treatment activities if implemented during the nesting season.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-37 Least Bell’s vireo is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity. If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to the project. Also as discussed for Impact BIO-8, participation in the SCVHP requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species.
Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to least Bell’s vireo (County Santa Clara et al. 2012a). Accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts on least Bell’s vireo through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR. If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
If any treatments occur in least Bell’s vireo habitat or if mechanical treatments or manual treatments that use handheld power tools occur within 250 feet of nesting habitat during the nesting season (February 1–August 31), protocol surveys for the species would be implemented pursuant to SPR BIO-10 or the nesting habitat may be assumed to be occupied (see SPR BIO-10 in Attachment A). If least Bell’s vireo nests are detected during protocol surveys or if nesting habitat is assumed to be occupied, nest season avoidance of nesting habitat and no-disturbance buffers would be implemented to avoid injury or mortality (see MM BIO-2a in Attachment A).
Habitat function for least Bell’s vireo would be maintained because trees greater than 16 inches dbh and select smaller trees would be retained, vegetation would be retained in clumps and mosaics, and root systems would be left intact to allow resprouting. Furthermore, SPRs HYD-4 and HYD-5 would be implemented to protect aquatic habitat, and SPR BIO-4 would prevent loss or degradation of riparian habitat by requiring retention of 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation. MM BIO-3a would avoid loss or degradation of riparian habitats that are also sensitive natural communities. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because least Bell’s vireo is listed as threatened under CESA, SFD must consult with CDFW about its determination that mortality, injury, or disturbance would not occur and habitat function would be maintained. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for least Bell’s vireo and contacted CDFW and USFWS to seek technical input on this determination, as required. On December 17 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to least Bell’s vireo and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures related to least Bell’s vireo resulted from this consultation. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Tricolored Blackbird
Tricolored blackbird has been documented in the project area in Caldero County Park and along Coyote Creek. The species may occur in other portions of the project area where stock ponds, riparian habitats, and wetland features that provide nesting habitat for the species are present with nearby foraging habitat (e.g., grasslands and agricultural lands). All treatment activities could result in disturbance or loss of tricolored black bird nests, nest colonies, eggs, and young if treatments occur in or near nesting habitat during the nesting season (February 1–August 31). In addition, mechanical treatments and manual treatments using handheld power tools (e.g., chainsaws, brush cutters) that occur within 250 feet of nesting habitat for the species may also result in loss of nests, eggs, and young due to the noise associated with these treatment activities if implemented during the nesting season.
Tricolored blackbird is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity. If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-38 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to the project. Also as discussed for Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial to tricolored blackbird (County Santa Clara et al. 2012a). Accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts to tricolored blackbird through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR. If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
If any treatments occur within tricolored blackbird nesting habitat or if mechanical treatments or manual treatments that use handheld power tools occur within 250 feet of nesting habitat during the nesting season (February 1–August 31), focused surveys for the species would be conducted pursuant to SPR BIO-10 or the habitat may be assumed occupied. If tricolored blackbird nest colonies are detected during focused surveys (pursuant to SPR BIO-10) nest buffers would be applied to active nesting colonies or if nesting habitat is assumed to be occupied, nest season avoidance of nesting habitat and no-disturbance buffers would be implemented to avoid injury or mortality (see MM BIO-2A in Attachment A).
Grassland habitat function for tricolored blackbird would be maintained by the project because prescribed burning would thin dense vegetation and nonnative grasses to approximate conditions under the natural fire regime. In areas where Douglas-fir trees are encroaching into grasslands, encroaching trees may be removed to restore grassland habitat. Aquatic habitat would be protected pursuant to SPRs HYD-4 and HYD-5, and SPR BIO-4 would prevent loss or degradation of riparian habitat. MM BIO-4 would avoid treatment activities and maintenance treatments within aquatic habitat when the species is present. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because tricolored blackbird is listed as threatened under CESA, SFD must consult with CDFW about its determination that mortality, injury, or disturbance would not occur and habitat function would be maintained. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for tricolored blackbird and contacted CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to tricolored blackbird and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures resulted from this consultation. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Other Special-Status Birds
Several other special-status bird species are known to occur or may occur in the project area: grasshopper sparrow, golden eagle, short-eared owl, long-eared owl, Swainson’s hawk, Vaux’s swift, northern harrier, olive-sided flycatcher, black swift, white-tailed kite, saltmarsh common yellowthroat, yellow breasted chat, loggerhead shrike, purple martin, and yellow warbler. These species are considered together for this analysis because project-related impacts to these species and avoidance measures that would be applied are similar. Nesting habitat for these species is found in various portions of the project area (see Attachment B), and treatment activities may occur during the nesting season for these species. Several additional special-status bird species have the potential to forage or fly over the project area, but the project is outside of their nesting range, and no impacts to these species are anticipated. These include Barrow’s golden eye, common loon, and American white pelican (Attachment B).
Per SPR BIO-1, if it is determined that adverse effects on nesting habitat for special-status birds will be clearly avoided by physically avoiding nesting habitat for the species or conducting treatments outside of the season of sensitivity (i.e., nesting bird season), then no additional survey would be required. Adverse effects on nesting special-status birds would be avoided for treatments that would occur outside of nesting habitat (see Attachment B) or the nesting season for each species (see SPR BIO-1 in Attachment A). If conducting some treatments outside of the nesting bird
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-39 season is determined to be infeasible for individual treatment areas, then SPR BIO-10 would apply, and focused nesting bird surveys would be conducted prior to implementation of all treatment activities.
If no active bird nests are observed during focused surveys, then additional avoidance measures for these species would not be required. If active special-status bird nests are observed during focused surveys, then MMs BIO-2a (for golden eagle, Swainson’s hawk, white-tailed kite, and bald eagle) and BIO-2b (for grasshopper sparrow, short-eared owl, long-eared owl, Vaux’s swift, northern harrier, olive-sided flycatcher, black swift, saltmarsh common yellowthroat, yellow breasted chat, loggerhead shrike, purple martin, and yellow warbler) would be implemented. Under MMs BIO2a and BIO-2b, no-disturbance buffers would be applied around special-status bird nests (see Attachment A). No treatment activities would occur within these buffers until chicks have fledged or the nest is otherwise no longer active, as determined by a qualified RPF or biologist. Additionally, trees containing golden eagle nests would not be removed pursuant to the Bald and Golden Eagle Protection Act.
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain trees greater than 16 inches in diameter, other than Douglas-fir, which may be removed up to 36 inches in diameter when needed to reduce encroachment into other existing vegetation types, which would maintain roosting trees for raptors.
Understory vegetation would be retained in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain 1–2 snags greater than 12 inches in diameter per acre (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”). Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that provides habitat for special-status birds; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial compared to available habitat in the project area. SPR BIO-4 would be applied to retain riparian habitat function. Furthermore, SPR BIO-5 will be applied, which would retain cover in coastal sage scrub and chaparral habitats used by special-status birds. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, oak woodlands, and a mosaic of understory vegetation throughout the project area as a whole would maintain habitat for special-status birds. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because golden eagle, Swainson’s hawk, and white-tailed kite are listed under CESA or are fully protected under the California Fish and Game Code, SFD must notify CDFW about its proposed measures to avoid mortality, injury, or disturbance of these species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for golden eagle, Swainson’s hawk, and white-tailed kite, and contacted CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and on behalf of SFD and described the measures that would be taken to avoid mortality, injury, and disturbance to golden eagle, Swainson’s hawk, and white-tailed kite and to maintain habitat function in compliance with MM BIO-2a.
No refinements to the project description or measures resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
American Badger
Grassland, open scrub, and open woodland habitat in the project area not subject to high levels of human disturbance may provide habitat for this species, and the species has been observed within the project area (see Attachment B). Other portions of the project area directly adjacent to development or areas regularly used for recreation may not be suitable habitat for the species due to ongoing human disturbance. Mechanical treatments; pile burning; installing control lines for broadcast burning; and the placement of fencing, pens, and other infrastructure for prescribed herbivory in habitats suitable for the species could result in destruction of active dens
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-40 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR and potential loss of adults or young through direct mortality or den collapse. Manual treatments, broadcast burning (other than installation of control lines and staging areas), prescribed herbivory (other than the placement of fencing, pens, and other infrastructure), and targeted herbicide application would not result in destruction of American badger dens, because personnel implementing these treatments would conduct the majority of these activities on foot, and the likelihood of a den being inadvertently crushed or otherwise destroyed would be very low. In addition, broadcast burning, prescribed herbivory, and targeted herbicide application are not likely to cause a substantial disruption in feeding because these activities are not likely to be conducted in the vicinity of a den for a substantial length of time. However, manual treatments, mechanical treatments, installation of control lines and staging areas for prescribed burning, pile burning, and setup of infrastructure associated with prescribed herbivory in the vicinity of a maternity den could result in a substantial interruption of feeding and potential loss of young during the American badger pupping season. The potential for treatment activities to result in adverse effects on American badger was examined in the Program EIR.
American badgers may use a den year-round; therefore, there is no season when all impacts can be avoided (pursuant to SPR BIO-1). Therefore, implementation of SPR BIO-10 would be required before implementation of any mechanical treatments, pile burning, installation of control lines and staging areas for prescribed burning, or the setup of infrastructure for prescribed herbivory activities year-round. SPR BIO-10 would also be required during the pupping season (see Attachment A) for all treatments other than broadcast burning (other than installation of control lines and staging areas), prescribed herbivory (other than setup of infrastructure), and targeted herbicide application.
Under SPR BIO-10, focused surveys would be conducted for American badger dens within habitat suitable for the species (i.e., grasslands, open woodland) by a qualified RPF or biologist. If American badger dens are not detected during focused surveys, then further mitigation for the species would not be required. If American badger dens are detected during focused surveys, MM BIO-2b will be implemented, and a no-disturbance buffer will be established around the den, the size of which will be determined by the season and the treatment activity (see Attachment A).
Habitat function for American badger would be maintained because habitat for the species (i.e., grasslands, open scrub, open woodlands) would be maintained, and additional open woodland habitat would likely be restored through burning, thinning, and removal of ladder fuels. Horizontal crown spacing of approximately 25 to 75 feet between clusters, depending on site-specific conditions and vegetation alliance characteristics, would be implemented, and vegetation retention would create a mosaic of patches or shrub islands. In areas where conifer or hardwood is encroaching into shrublands and grasslands, encroaching trees may be selectively removed to restore these habitats.
Impacts on oak woodlands will further be avoided or minimized through implementation of MM BIO-3a (see Impact BIO-3). This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Mountain Lion
Mountain lion has been documented at multiple locations throughout the project area (Attachment B). The developed portions of the project area with areas of natural vegetation may provide foraging and movement habitat for the species, and more remote portions of the project area containing structures such as rock outcrops, downed trees, large tree hollows, or shrub thickets in woodlands may provide denning or nursery habitat. Targeted herbicide application and prescribed herbivory are not likely to take place in the more remote portions of the project area that may support denning and nursery habitat due to lack of access and are therefore unlikely to have an impact on the species. Manual treatments, mechanical treatments, and prescribed burning conducted in mountain lion nursery habitat could result in injury or mortality of kittens if an active nursery is present and the kittens are too young to move on their own (less than 3 months old). The potential for treatment activities, including maintenance treatments, to result in adverse effects on mountain lion was examined in the Program EIR.
Mountain lions may breed in the project area year-round, and dens and nurseries may be present in a variety of habitat types; therefore, complete avoidance of impacts (pursuant to SPR BIO-1) is not feasible without further measures. Prior to implementation of manual tree and snag removal treatments, mechanical treatments, and prescribed burning, in potential nursery habitat, a desktop analysis of the treatment area would be conducted (see SPR BIO-10 in Attachment A). If nursery habitat exists within a treatment area, a nursery would be assumed to be
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-41 present, and MM BIO-2a would be implemented. MM BIO-2a includes surveys for nurseries, and if a nursery is found a no-disturbance buffer would be established around the nursery (see MM BIO-2a in Attachment A).
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain understory vegetation in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”). Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that may provide denning and nursery habitat for mountain lions; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial compared to available habitat in the project area. Furthermore, SPR BIO-5 will be applied, which would retain cover in coastal sage scrub and chaparral habitats used by the species. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, oak woodlands, and a mosaic of understory vegetation throughout most of the project area would maintain habitat for mountain lions. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because mountain lion is listed as candidate under CESA, SFD must consult with CDFW about its determination that mortality, injury, or disturbance would not occur, and habitat function would be maintained. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for mountain lion and contacted CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to mountain lion and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures resulted from this consultation. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Northern California Ringtail
The forested areas, chaparral (with scattered trees and other denning structures), and riparian habitats in the project area provide habitat for Northern California ringtail (Attachment B). Targeted herbicide application and prescribed herbivory are not expected to result in injury or mortality of ringtail because these treatments would not result in destruction of denning sites. However, manual or mechanical treatments that result in removal of trees and snags greater than 12 inches dbh, as well as prescribed burning, may result in injury or mortality of ringtail if conducted during the maternity season (i.e., the period during which young would be present in a den, approximately April 15– June 30). The potential for treatment activities, including maintenance treatments, to result in adverse effects on ringtail was examined in the Program EIR.
If manual or mechanical removal of trees and snags greater than 12 inches dbh or prescribed burning occurs outside of the maternity season, then adverse effects are clearly avoided, and no further measures are required pursuant to SPR BIO-1. Prior to implementation of prescribed burning or tree or snag removal greater than 12 inches dbh during the ringtail maternity season, focused surveys for ringtail would be conducted (see SPR BIO-10 in Attachment A). If ringtails are detected during focused surveys, then additional surveys by a qualified RPF or biologist would be required to determine whether an active ringtail den is present within a treatment area. If an active den is identified in a treatment area, then MM BIO-2a would be implemented, and a no-disturbance buffer would be applied (Attachment A). If the presence of ringtail in the treatment area is assumed, then implementation of avoidance and minimization measures would be required pursuant to MM BIO-2a before and during implementation manual or mechanical tree and snag removal or prescribed burning conducted during the maternity season (see MM BIO-2a in Attachment A).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-42 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain understory vegetation in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”). Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that may provide denning and nursery habitat for ringtail; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial compared to available habitat in the project area. Furthermore, SPR BIO-5 will be applied, which would retain cover in coastal sage scrub and chaparral habitats used by the species. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities, which provide habitat for the species. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Pursuant to MM BIO-2a and because ringtail is a fully protected species, SFD must consult with CDFW about its determination that mortality, injury, or disturbance would not occur, and habitat function would be maintained. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for ringtail and contacted CDFW to seek technical input on this determination, as required. On December 17, 2025, SCCFSC sent a memo to Julie Lile at CDFW on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to Northern California ringtail and to maintain habitat function in compliance with MMs BIO-2a and BIO-2g. No refinements to the project description or measures resulted from this notification.
This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
San Francisco Dusky-Footed Woodrat
The project area provides habitat for San Francisco dusky-footed woodrat (see Attachment B). Although the species is usually found in nondeveloped land cover types, it may also be present in areas of natural vegetation in the developed landscape as well. This species builds middens (nests) of dried grass, leaves, sticks, and similar materials on the ground, in shrubs, and occasionally in hollows and low branches of large trees. These nests provide shelter yearround in addition to providing a location for breeding and rearing of young. Prescribed burning, mechanical treatments, and manual treatments conducted in habitat for San Francisco dusky-footed woodrats could result in the disturbance or destruction of woodrat nests and potential injury or mortality of individuals if present. Targeted herbicide application and prescribed herbivory are not anticipated to result in destruction of nests or injury or mortality of individuals because nests are constructed of dead materials and would not be affected by herbicides or grazing animals. The potential for treatment activities, including maintenance treatments, to result in adverse effects on San Francisco dusky-footed woodrat was examined in the Program EIR.
San Francisco dusky-footed woodrats may be present in nests in the project area year-round, and nests are present in a variety of habitat types; therefore, clear avoidance of impacts is not feasible (pursuant to SPR BIO-1) for manual treatments, mechanical treatments, or prescribed burning, which could result in the destruction of nests. However, specialized training (see SPR BIO-2 in Attachment A) would be required for crews conducting treatments to allow these crews to recognize and avoid (for manual treatments, mechanical treatments, and pile burning) or minimize (for broadcast burning) destruction of nests. Although crew training under SPR BIO-2 would minimize destruction of nests, SPR BIO-10 also would apply, and focused surveys for San Francisco dusky-footed woodrat nests would be conducted in habitats for the species prior to implementation of mechanical treatments, or nest presence may be assumed for other treatment types (see SPR BIO-10 in Attachment A).
If no woodrat nests are found during pretreatment surveys, no further measures are required. If woodrat nests are found or presence is assumed, MM BIO-2b will apply, and a no-disturbance buffer of approximately 10 feet around nests, which may be adjusted by a qualified RPF or biologist to avoid impacts as needed, will be implemented if feasible for pile burning, mechanical treatments, and manual treatments. In addition, where nests are found or
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-43 assumed to be present, broadcast burning would be avoided during the season when the majority of young are present in the nest (see MM BIO-2b in Attachment A).
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain understory vegetation in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”). Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that provides habitat for San Francisco dusky footed woodrat; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial compared to available habitat in the project area. Furthermore, SPR BIO-5 will be applied, which would retain cover in coastal sage scrub and chaparral habitats used by the species. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, oak woodlands, and a mosaic of understory vegetation throughout most of the project area would maintain habitat for San Francisco dusky-footed woodrat. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
San Joaquin Kit Fox
The portion of the project area in the Coyote Valley and surrounding hills is within the range of this species, and grassland, open oak woodland, and open shrubland habitat for this species is present in that area (see Attachment B).
Mechanical treatment and pile burning activities could result in direct loss or disturbance of active kit fox dens and potential loss of adults year-round. All treatment activities could result in potential disturbance of natal dens if implemented during the pupping/natal season (February 1–September 30).
San Joaquin kit fox is a covered species under the SCVHP. As discussed for Impact BIO-8, treatment activities may qualify as covered activities under the SCVHP depending on the location, responsible agency, and type of activity. If specific treatment areas and activities contained in this PSA/Addendum are covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP, and the conservation measures contained in the plan would be applied to that portion of the project. Also as discussed for Impact BIO-8, participation in the SCVHP, requires applicable conservation measures and participation in support of the reserve system, which preserves habitat for the species. Participation in the SCVHP through implementation of the conditions in the plan and participation in the reserve system were determined to have less-than-significant impacts and would ultimately be beneficial San Joaquin kit fox (County Santa Clara et al. 2012a). Accordingly, this determination for proposed treatments would be consistent with the less-than-significant determination in the Program EIR. Therefore, impacts to San Joaquin kit fox through use of the SCVHP for WSCLRP treatments would not be substantially more severe than what was covered in the Program EIR. If a treatment area or activity is not covered by the SCVHP, then the SPRs and MMs discussed below would apply.
San Joaquin kit fox may be present in treatment areas year-round, and treatments are proposed for grassland, open oak woodland, and open shrub habitats. Therefore, adverse effects cannot be clearly avoided (per SPR BIO-1), and implementation of SPR BIO-10 would be required for all treatment activities during the pupping/natal season, which requires a habitat evaluation of the treatment area, including one walking transect survey to identify potential dens.
SPR BIO-10 would also be required before any pile burning or mechanical treatments year-round (see SPR-BIO-1 in Attachment A). If habitat in the treatment area is found to be suitable for the species and contains potentially occupied dens, further investigation to determine whether San Joaquin kit fox are present would be implemented or the species would be assumed to be present, and a no-disturbance buffer would be placed around dens that are occupied or assumed to be occupied (see MM BIO-2a in Attachment A).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-44 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Habitat function for San Joaquin kit fox would be maintained because habitat for the species (i.e., grasslands, scrub, open woodlands) would be maintained and additional open woodland habitat would likely be restored through burning, thinning, and removal of ladder fuels. Horizontal crown spacing of approximately 25–75 feet between clusters, depending on site-specific conditions and vegetation alliance characteristics, would be implemented, and vegetation retention would create a mosaic of patches or shrub islands (see Section 2.1.1, “General Prescription”). In areas where conifer or hardwood is encroaching into shrublands and grasslands, encroaching trees may be selectively removed to preserve these habitats. Impacts on oak woodlands will further be avoided or minimized through implementation of MM BIO-3a (see Impact BIO-3).
Pursuant to MM BIO-2a and because this species is listed under CESA and ESA, SFD must notify CDFW and USFWS about its proposed measures to avoid mortality, injury, or disturbance of the species and its determination that habitat function would be maintained after treatments. For the reasons summarized above, SFD determined that implementation of treatments would maintain habitat function for San Joaquin kit fox and contacted CDFW and CDFW and USFWS to seek technical input on this determination, as required. On December 17, 2025, SCCFSC contacted Julie Lile at CDFW and Ryan Olah at USFWS on behalf of SFD and described the measures that would be taken to avoid mortality, injury, or disturbance to San Joaquin kit fox and to maintain habitat function in compliance with MM BIO-2a. No refinements to the project description or measures related to San Joaquin kit fox resulted from this notification. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Special-Status Bats
Pallid bat, Townsend’s big-eared bat, western mastiff bat, and western red bat may occur in nondeveloped portions of the project area (see Attachment B). Large trees, abandoned or little-used structures, and rock outcrops in the project area may provide roosts for these species. Some roost habitat for special-status bats (e.g., rock outcrops, abandoned buildings) would not be targeted for treatment, and prescribed herbivory is not anticipated to result in roost removal or substantial disturbance. However, removal of large live hardwoods, live conifers with cavities, snags, or diseased trees by mechanical or manual treatments could result in destruction of roosts. In addition, depending on the proximity of treatment activities to roost habitat, manual treatments, mechanical treatments, prescribed burning, or targeted herbicide application using power equipment during the bat maternity season (April 1–August 31) could disturb active bat roosts due to auditory and visual stimuli (e.g., heavy equipment, chainsaws, vehicles, personnel) or smoke (e.g., prescribed burning), potentially resulting in abandonment of the roost and loss of young. Additionally, manual and mechanical removal of large live hardwoods, live conifers with cavities, and snags could also result in injury or death of hibernating individual special-status bats if these structures contain overwintering roosts, which may be present (approximately from late October to April). The potential for treatment activities, including maintenance treatments, to result in adverse effects on special-status bats was examined in the Program EIR.
If manual treatments, mechanical treatments, prescribed burning, and targeted herbicide application using power equipment can be restricted to the period outside the bat maternity season, and if the removal of large live hardwoods, live conifers with cavities and snags can be implemented outside of the overwintering season, then adverse effects on the species would be avoided (per SPR BIO-1), and no further action is required. If it is infeasible to implement treatments outside of the bat maternity season or to avoid removal of potential roost trees during the overwintering season, focused surveys for special-status bat maternity roosts would be implemented by a qualified RPF or biologist within habitat for these species (see SPR BIO-10 in Attachment A). If special-status bat roosts are identified, MM BIO-2b would be implemented, a no-disturbance buffer would be established around active special-status bat roosts during the maternity season, and removal of roosts would be avoided during the overwintering season (see MM BIO-2b in Attachment A).
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain trees greater than 16 inches in diameter, other than Douglas-fir, which may be removed up to 36 inches in diameter when needed to reduce encroachment into other existing vegetation types. Understory vegetation would be retained in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain 1–2 snags greater than 12 inches in diameter per acre
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-45 (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section 2.2.2, “Wildland-Urban Interface Fuel Reduction”). Fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that provides habitat for the prey species of special-status bats; however, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Therefore, the area of habitat affected by fuel break treatments would not be substantial when compared to available habitat in the project area. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of large trees and snags for roosting and a mosaic of understory vegetation throughout most of the project area would maintain habitat for special-status bats. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Conclusion
The potential for treatment activities to result in adverse effects on special-status wildlife species, as described above, was examined in the Program EIR. This impact on special-status wildlife is within the scope of the Program EIR because the treatment activities and intensity of disturbance resulting from treatment activities are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions and habitat characteristics present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape (e.g., no resource is affected outside the treatable landscape that would not also be similarly affected within the treatable landscape); therefore, the potential impact on special-status wildlife species is also the same, as described above.
As described in Section 1.3.2, “Proposed Project Revisions,” revisions to SPR HYD-4 are proposed to require establishment of WLPZ buffers for only the watercourses within 300 feet of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments. This revision would ensure that all WLPZs in proximity to a treatment area are flagged, without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments, and all other conditions on treatment activities within WLPZs would apply. This establishment of WLPZs within 300 feet of treatment activities would therefore provide the same reduction in impacts on wildlife as provided by SPR HYD-4 in the Program EIR. For the reasons described above, the proposed revisions to SPR HYD-4 would not result in a substantially more severe significant effect related special-status wildlife than what was covered in the Program EIR.
Biological resource SPRs that apply to project impacts under Impact BIO-2 are AD-1, BIO-1 through BIO-6, BIO-9, BIO-10, BIO-11, BIO-12, HYD-1, HYD-2, HYD-4, HYD-5, HAZ-5, and HAZ-6. The biological resource MMs that apply to project impacts under Impact BIO-2 are MMs BIO-2a, BIO-2b, BIO-2c, BIO-2e, BIO-2g, BIO-3a, BIO-3b, BIO-3c, BIO-4, and BIO-5. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-3
Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse effects on sensitive habitats, including designated sensitive natural communities, oak woodland, riparian habitat, chaparral, and coastal sage scrub. Potential impacts resulting from maintenance activities would be generally the same as those resulting from initial vegetation treatments because the same treatment activities are proposed; however, retreatment at too great a frequency could result in additional adverse effects. The potential for treatment activities, including maintenance treatments, to result in adverse effects on sensitive habitats was examined in the Program EIR.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-46 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Sensitive Natural Communities and Oak Woodlands
According to the fine-scale vegetation mapping available for the project area and the reconnaissance-level survey, sensitive natural communities (i.e., alliances with a rarity rank of S1, S2, or S3) are present in the project area (Table 4.5-2). The sensitive natural communities, their associated rarity rank, and the vegetation type within which the sensitive natural communities may occur are presented in Table 4.5-2, below. In addition, several oak woodland and forest types (i.e., mixed oak forest and woodland, coast live oak woodland and forest, canyon live oak forest and woodland, California black oak forest and woodland, blue oak woodland and forest, valley oak woodland and forest, and interior live oak–shreve oak woodland and forest), which are sensitive habitats pursuant to the Oak Woodlands Conservation Act and PRC Section 21083.4, are mapped in the project area and were observed in the project area during reconnaissance level surveys.
Table 4.5-2 Sensitive Natural Communities Documented to Occur in the Project Area Sensitive Natural Community1 Rarity Rank2
Forest/Woodland
Bigleaf maple forest*3 S3
California buckeye grove* S3
Redwood forest and woodland* S3
Tanoak forest* S3.2
Shrub/scrub
Black sage–California sagebrush scrub* S3S4
Canyon live oak–Interior live oak chaparral* S3S4
Brittle leaf–woolly leaf manzanita chaparral S3
Glossy leaf manzanita–golden chinquapin chaparral S2
Hoary, common, and Stanford manzanita chaparral S3
Wart leaf ceanothus chaparral S3
Herbaceous/Barren
Goldenaster patches S3
Wetland/Riparian
Basket bush–river hawthorn–desert olive patches S3.2?
Black cottonwood forest and woodland S3
Box-elder forest and woodland*3 S3
California sycamore–coast live oak riparian woodlands* S3 Fremont cottonwood forest and woodland* S3.2
Goodding's willow–red willow riparian woodland and forest S3 Juglans hindsii and hybrids special stands and semi-natural alliance S1.1 Shining willow groves S3.2
Note: CWHR = California Wildlife Habitat Relationships. 1 These are designated sensitive natural communities with a state rarity rank of S1 (critically imperiled), S2 (imperiled), or S3 (vulnerable). * Species associated with these sensitive natural communities were observed during SPR BIO-1 reconnaissance-level surveys. 2 Older ranks, which need to be updated, may still contain a decimal "threat" rank of 0.1 or 0.2, where 0.1 indicates very threatened and 0.2 indicates moderately threatened. Ranks that contain two state ranks (e.g., S3S4) indicate a range of uncertainty about the status of the species or ecosystem, which may fall under either of the two state rank categories listed. Ranks that are followed with a question mark indicate that the numeric rank is considered inexact or tentative. This inexactness suggests there is uncertainty or insufficient information available to confirm the exact rarity rank of the species or habitat. 3 In some circumstances associations, rather than alliances, were mapped in the project area. The table lists the corresponding alliances within which these associations occur. For example, the Acer macrophyllum–Pseudotsuga menziesii / Polystichum munitum association mapped in the project area occurs within the bigleaf maple (Acer macrophyllum) forest alliance, and the Acer negundo / (Rubus ursinus) association occurs within the box-elder (Acer negundo) forest and woodland alliance.
Source: CNPS 2025b; compiled by Ascent in 2025.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-47 There are areas mapped as “shrub fragment” and “forest fragment” in the project area that were not mapped to the alliance or association level because their size is below the minimum mapping unit used for the fine-scale vegetation mapping. Because of their small size (each area is less than 1 acre) and fragmented nature, they are not expected to support functional sensitive natural communities. There are other portions of the project area that were not mapped to a more refined vegetation classification level that may contain sensitive natural communities: California annual and perennial grassland macrogroup, barren and sparsely vegetated, Acer macrophyllum mapping unit, Umbellularia californica mapping unit, and Quercus lobata mapping unit. Table 4.5-3 presents the sensitive natural communities that may occur within these higher levels of vegetation classification.
Table 4.5-3 Sensitive Natural Communities That May Occur within Broad Vegetation Categories in the Project Area
Broader Vegetation Classification Sensitive Natural Communities with Potential to Occur Sensitive Natural Community Rarity Rank California annual and perennial
grassland macrogroup
Water foxtail meadows
Monolopia–leafy-stemmed tickseed fields
Needle grass–melic grass grassland
S3?
S3
S3S4
Barren and sparsely vegetated
Onion–twistflower–dwarf-flax serpentinite rock outcrop
Coast Range stonecrop draperies
Bushy spikemoss mats
S2S3
S3
S3
Acer macrophyllum mapping unit Bigleaf maple forest and woodland* S3 Umbellularia californica mapping unit California bay forest and woodland* S3 Quercus lobata mapping unit Valley oak woodland and forest* Valley oak riparian forest and woodland*
S3
S3
Source: CNPS 2025b; compiled by Ascent in 2025.
*Species associated with these sensitive natural communities were observed during SPR BIO-1 reconnaissance-level surveys.
During reconnaissance-level surveys conducted pursuant to SPR BIO-1, several species associated with sensitive natural communities were observed, including California bay, California sycamore, bigleaf maple, California buckeye, tanoak, valley oak, canyon live oak, coast live oak, redwood, California sagebrush, and willows (Salix spp.). Not all dominant or characteristic species associated with sensitive natural communities included in Table 4.5-2 were observed during the reconnaissance-level survey, but not all areas of the project area could be visited. Fine-scale vegetation mapping has been completed in most of the project area, and sensitive natural communities have been identified in the treatment area to the alliance level consistent with Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018a) and using A Manual of California Vegetation (including updated natural communities data at http://vegetation.cnps.org/). However, as described above, the few areas classified as California annual and perennial grassland macrogroup, barren and sparsely vegetated, Acer macrophyllum mapping unit, Umbellularia californica mapping unit, and Quercus lobata mapping unit in the project area have not been identified to the alliance or association level, and SPR BIO-3 would be implemented in these areas prior to treatment to determine whether vegetation meets the definition of sensitive natural communities.
As described above, other vegetation treatments have already taken place in the project area (see “Discussion” under Section 4.5). However, per MM BIO-3a, treatments within sensitive natural communities and oak woodlands would be designed to restore the natural fire regime and return vegetation composition and structure to their natural conditions to maintain or improve habitat function of the affected sensitive natural community. Treatments would be designed to replicate the fire regime attributes for the affected sensitive natural community or oak woodland type, including seasonality, fire return interval, fire size, spatial complexity, fire line intensity, severity, and fire type as described in Fire in California’s Ecosystems (Van Wagtendonk et al. 2018) and A Manual of California Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/), and to the extent feasible, prescribed burning would be the primary treatment activity in sensitive natural communities that are fire dependent (e.g., closed-cone forest and woodland alliances, chaparral alliances characterized by fire-stimulated, obligate seeders).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-48 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Treatments will not be implemented in sensitive natural communities that are within their natural fire return interval (i.e., time since last burn is less than the average time required for that vegetation type to recover from fire) or within Condition Class 1. To the extent feasible, no fuel breaks would be created in sensitive natural communities with rarity ranks of S1 (critically imperiled) and S2 (imperiled). To the extent feasible, fuel breaks would not remove more than 20 percent of the native vegetation relative cover from a stand of sensitive natural community vegetation in sensitive natural communities with a rarity rank of S3 (vulnerable) or in oak woodlands. In forest and woodland sensitive natural communities with a rarity rank of S3. In oak woodlands, only shaded fuel breaks would be installed, and they would not be installed in more than 20 percent of the stand of sensitive natural community (i.e., if the sensitive natural community covers 100 acres, no more than 20 acres would be converted to create the fuel break).
If habitat function of sensitive natural communities or oak woodlands would not be maintained through implementation of MM BIO-3a, then MMs BIO-3b and BIO-3c would apply, and unavoidable losses of these resources would be compensated through restoration or preservation of these vegetation types within or outside of the project area.
Riparian Habitat
The project area contains numerous perennial and intermittent (potentially Class I and Class II) and ephemeral (Class III and Class IV) streams. Riparian habitat is present adjacent to segments of some streams, rivers, and wetlands in the project area, and various types of riparian habitats have been identified in the project area (Table 4.5-1). Under SPR HYD-4, a WLPZ of 50–150 feet adjacent to all Class I and Class II streams and lakes would be implemented for mechanical treatment, manual treatment, prescribed burning, prescribed herbivory, and herbicide application, which would limit the extent of treatment activities in riparian habitat. As required under SPR BIO-4, treatments in riparian habitats would retain at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation, would not reduce stream shading and increase stream temperatures, and would be limited to removal of uncharacteristic or undesired fuel loads (e.g., dead or dying vegetation, invasive plants). Large, native riparian hardwood trees (e.g., willow, ash, maple, oak, alder, sycamore, cottonwood) would be retained regardless of size unless they are dead, dying, diseased, or a safety hazard. Therefore, this would prevent removal of the larger, more mature trees within the riparian communities dominated by these species that provide wildlife habitat and a seed source for natural regeneration. Lastly, prescribed herbivory treatments would be excluded within 50 feet of environmentally sensitive areas, such as waterbodies, wetlands, or riparian areas, using temporary fencing or active herding, pursuant to SPR HYD-3. Additionally, prior to any treatments in riparian habitat, CDFW would be notified pursuant to California Fish and Game Code 1602, when required.
Chaparral and Coastal Sage Scrub
As shown in Table 4.5-1, chaparral and coastal sage scrub vegetation types are present within the project area. The chaparral and coastal sage scrub alliances that meet the definitions of the vegetation types subject to the restrictions of the writ are noted in Table 4.5-1. The writ restrictions limit the type, location, and intensity of allowable treatment activities; they are defined in SPR CHAP/CSS-1, which was developed to be consistent with the writ.
Pursuant to CHAP/CSS-1, only certain ecological restoration treatments, WUI fuel reduction treatments, and fuel break treatments will be conducted within applicable chaparral and coastal sage scrub vegetation types. For ecological restoration treatment areas, the requirements of SPR CHAP/CSS-1 supersede those of SPR BIO-5 because SPR CHAP/CSS-1 is more restrictive and limits treatment activities to only the removal of flammable, nonnative vegetation; therefore, only the SPR BIO-5 requirements that apply to fuel break and WUI treatment types remain applicable. Also pursuant to SPR CHAP/CSS-1, WUI fuel reduction within chaparral and coastal sage scrub will only occur within 1,000 feet of the “Interface” layer in CAL FIRE’s Wildland Urban Interface mapping (Attachment B, Figures B-1 through B-38). Although 2,631 acres of chaparral and 1,083 acres of coastal sage scrub have been included in the WUI fuel reduction treatment type (Table 4.5-1), only 194.2 acres of chaparral and 260.1 acres of coastal sage scrub are located within 1,000 feet of the Interface layer (Table 4.5-4) (Attachment B, Figures B-1 through B-38). Therefore, by following the stipulations of the writ, WUI fuel reduction treatments in the project area would be limited to a maximum of 194.2 acres of chaparral and 260.1 acres of coastal sage scrub. Additionally, new fuel breaks are designed to be less than 300 feet in width, and fuel breaks will be maintained over time to exclude and remove
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-49 flammable, nonnative plants. Ongoing maintenance would prevent treated areas from converting to highly flammable nonnative vegetation, thereby reducing the potential for increased fuel continuity, ignition risk, and fire intensity within treatment areas and in adjacent chaparral, coastal sage scrub, and other surrounding vegetation types.
Table 4.5-4 Acres of WUI Treatment in Chaparral and Coastal Sage Scrub within 1,000-feet of the “Interface” layer in the CAL FIRE Wildland Urban Interface Map Vegetation/Land Cover Type Total (Acres)2
Chaparral
Adenostoma fasciculatum 57.9
Adenostoma fasciculatum–Salvia spp. 6.5
Arctostaphylos (crustacea, tomentosa) 2.4
Arctostaphylos glauca 39.9
Ceanothus cuneatus 6.1
Cercocarpus montanus 12.5
Prunus ilicifolia–Heteromeles arbutifolia–Ceanothus spinosus 49.4 Quercus berberidifolia 14.3
Quercus durata 5.2
Chaparral total 194.2
Coastal Sage Scrub
Artemisia californica–(Salvia leucophylla) 102.9
Salvia mellifera–(Artemisia californica) 157.2
Coastal sage scrub total 260.1
Chaparral and Coastal Sage Scrub Types Total 454.3
Source: Sources: Tukman Geospatial and Aerial Information Systems 2022, 2023; compiled by Ascent in 2026.
Consistent with SPR BIO-5, impacts on chaparral and coastal sage scrub from allowable WUI and fuel break treatments are evaluated at a landscape scale to determine whether habitat function would be maintained. For this project, the spatial scale evaluation consisted of publicly owned or otherwise protected lands within the US Level IV Ecoregions that overlap San Mateo, Santa Clara, and Santa Cruz Counties, specifically within ecological subsections 1n (Santa Cruz Mountains), 6t (Diablo Range), 6v (Bay Terraces/Low Hills), and 6x (Leeward Hills). Most of these publicly owned lands adjacent to the project area are designated as protected areas under various jurisdictions, including State of California lands (e.g., California State Parks) and county (e.g., Santa Clara County Parks and Recreation Department) open spaces. Additionally, some adjacent lands are owned in fee and protected for open space purposes through conservation easements, contributing to the preservation of natural land and ecological resources.
Furthermore, a substantial amount of chaparral and coastal sage scrub habitat is also present in the surrounding landscape on private lands outside of the project area. There are approximately 15,711 acres of chaparral habitat and 6,556 acres of coastal sage scrub on these publicly owned or otherwise protected lands outside the project area. In addition, ecological restoration is planned within 7,457 acres of chaparral and 2,618 acres of coastal sage scrub habitat in the project area. Pursuant to SPR CHAP/CSS-1, these treatments would be limited to the removal of flammable, nonnative vegetation; as a result, no chaparral and coastal sage scrub species or native herbaceous cover will be removed as part of the ecological restoration treatments, and habitat function would be maintained or improved by reducing wildfire risk and competitive pressure from nonnative species. Because chaparral and coastal sage scrub habitats within the project area proposed for ecological restoration would maintain or improve habitat function following treatment, these areas are included in the spatial-scale analysis. This spatial scale is appropriate because it represents a substantial, ecologically functional landscape capable of meeting the resource needs of species that rely on these habitats within the region.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-50 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Fuel break treatments would permanently remove up to a maximum of 899 acres of chaparral and 262 acres of coastal sage scrub habitat from the project area (Table 4.5-1). WUI fuel reduction treatments would remove up to a maximum of approximately 194.2 acres of chaparral habitat and 260.1 acres of coastal sage scrub habitat from the project area. Together, fuel break and WUI fuel reduction treatments represent the only treatment types that would result in permanent removal of chaparral and coastal sage scrub habitat. When considered within the spatial scale described above, which includes publicly owned or otherwise protected lands surrounding the project area and chaparral and coastal sage scrub habitats within the project area proposed for ecological restoration, fuel break and WUI treatments constitute approximately 4.7 percent of the 23,168 acres of chaparral and 5.7 percent of the 9,174 acres of coastal sage scrub habitat. Because the majority of chaparral and coastal sage scrub habitat would be retained and remain ecologically functional, the fuel break and WUI treatments would not result in landscape-scale conversion of chaparral and coastal sage scrub habitats to other habitat types, nor would they cause a substantial loss of habitat function at the identified spatial scale, consistent with the requirements of SPR BIO-5. Pursuant to SPR BIO-9, all treatment activities will incorporate measures to reduce the risk of introducing or spreading invasive plant species that contribute to type conversion of chaparral and coastal sage scrub communities after treatment. These measures include cleaning equipment and vehicles before entering treatment areas, staging equipment in uninfested areas where feasible, and targeting significant infestations of invasive plants for removal using treatment methods designed to prevent reestablishment. Treatments will be focused on removing invasive plant species that cause ecological harm to native vegetation types, especially those that can alter fire cycles. Invasive plant biomass will be treated or properly disposed of to minimize propagule spread, and project implementation will follow the Fire and Fuel Management Best Management Practices in Preventing the Spread of Invasive Plants: Best Management Practices for Land Managers (Cal-IPC 2012, or current version).
Within chaparral and coastal sage scrub habitats, these measures would be implemented in coordination with SPR CHAP/CSS-1, which provides additional requirements for these vegetation types. Consistent with SPR CHAP/CSS-1, ecological restoration treatments would be limited to the removal of flammable, nonnative vegetation, and long-term maintenance of fuel break and WUI treatment areas would control flammable nonnative invasive species. Together, the application of SPR BIO-9 and SPR CHAP/CSS-1 would limit opportunities for invasive species to colonize treated areas, thereby helping native vegetation to regenerate and reducing the potential for long-term type conversion of chaparral and coastal sage scrub to herbaceous, nonnative or invasive vegetation types.
Conclusion
Fuel break and WUI treatments represent the only activities that would permanently remove chaparral and coastal sage scrub habitat in the project area, and they would affect a relatively small proportion of these habitats when considered at a landscape scale. Because the majority of chaparral and coastal sage scrub habitat would be retained and remain ecologically functional, the project would not result in landscape-scale habitat conversion or a substantial loss of habitat function, consistent with the requirements of SPR BIO-5.
The potential for treatment activities to result in adverse effects on sensitive habitats, as described above, was examined in the Program EIR. This impact on sensitive habitats is within the scope of the Program EIR because the treatment activities and intensity of disturbance from implementing treatment activities would be consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and habitat conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact on sensitive habitats is also the same, as described above.
Biological resource SPRs that apply to project impacts under Impact BIO-3 are SPRs AD-1, BIO-1 through BIO-6, BIO9, HYD-4, and HYD-5. Revisions to SPR HYD-4 are proposed, which require that WLPZs buffers are established for only the watercourses within 300 feet of treatment activities. This revision would help ensure that all WLPZs in proximity to a treatment area are recently flagged without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the purpose and intent of SPR HYD-4 to prevent degradation of watercourses during implementation of manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments; degradation would be prevented pursuant to the revised
Ascent Project-Specific Analysis/Addendum
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-51 SPR. For the reasons described, the proposed revision to SPR HYD-4 would not result in a substantially more severe significant effect related to riparian habitat or other sensitive natural communities through direct loss or degradation leading to loss of habitat function as compared to what was covered in the Program EIR. The biological resource mitigation measures that apply to project impacts under Impact BIO-3 are MMs BIO-3a, BIO-3b, and BIO-3c. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-4
Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse effects on state or federally protected wetlands. Potential impacts resulting from maintenance activities would be similar to those resulting from initial vegetation treatments because the same treatment activities are proposed. The potential for treatment activities to result in adverse effects on state or federally protected wetlands was examined in the Program EIR.
During the reconnaissance-level survey, riverine features (i.e., perennial, intermittent, and ephemeral drainages), stock ponds, reservoirs, and freshwater emergent wetlands were observed. Vegetation data for the project area includes some broader wetland vegetation classifications: arid west interior freshwater marsh group, Vancouverian lowland marsh, wet meadow and shrubland group and macrogroup, mudflat/dry pond bottom mapping unit, and Californian vernal pool/swale bottomland group (Table 4.5-1). The National Wetlands Inventory (NWI) classifies the project area as having freshwater emergent wetlands, freshwater forested/shrub wetlands, freshwater ponds, lakes, and riverine habitat (USFWS 2025b). The acreage for these aquatic resources is provided below in Table 4.5-5. Aquatic habitats are mapped at a coarse scale in the NWI database and sometimes without field verification.
Table 4.5-5 Aquatic Habitats within the Project Area as Mapped by the National Wetlands Inventory Aquatic Feature Total (acres)
Fresh emergent wetland 229.0
Freshwater forested/shrub wetland 495.6
Freshwater pond 367.4
Lake 1052.0
Riverine 810.1
Total (acres) 2,954.1
Source: USFWS 2025b.
Pursuant to SPR HYD-4, a WLPZ of 50 to 150 feet adjacent to all Class I and Class II streams and lakes would be implemented, and WLPZs of sufficient size to avoid degradation of downstream beneficial uses of water would be established adjacent to all Class III and Class IV streams within the project area for prescribed burning, mechanical treatments, manual treatments, prescribed herbivory, and herbicide application. Establishment of WLPZs would result in avoidance of all stream and pond habitat for manual, mechanical, herbicide, and pile-burning treatments. In addition, prescribed herbivory treatments would be excluded within 50 feet of environmentally sensitive areas, such as waterbodies, wetlands, vernal pools, or riparian areas, using temporary fencing or active herding, pursuant to SPR HYD-3. However, additional wetlands may be present throughout the project area that have not been identified or mapped, as well as ponds smaller than 1 acre (i.e., not considered a lake under Forest Practice Rules), seasonal wetlands, vernal pools, springs, and seeps. Some aquatic habitats, such as fresh emergent wetlands, are not associated only with lakes or streams, and would not be protected by implementation of SPR HYD-4 WLPZs. MM BIO-4 would apply to all treatment activities, and a qualified RPF or biologist would delineate the boundaries of wetland features; establish an appropriate buffer (with a minimum of 25 feet) around seasonal wetlands, springs, seeps, vernal pools, and other wetlands, and would mark the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). A larger buffer may be required if wetlands or other aquatic habitats contain habitat potentially suitable for special-status plants or special-status wildlife (e.g., red-legged frog, western pond turtle; see Impact BIO-1 and Impact BIO-2).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-52 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Conclusion
The potential for treatment activities to adversely affect state or federally protected wetlands was examined in the Program EIR. This impact on wetlands is within the scope of the Program EIR because the treatment activities and intensity of disturbance from implementing treatment activities would be consistent with those analyzed in the Program EIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact on wetlands is also the same, as described above.
As described in Section 1.3.2, “Proposed Project Revisions,” revisions to the requirements under SPR HYD-4 are proposed to require establishment of WLPZ buffers for only the watercourses within 300 feet of treatment activities, including mechanical, manual, herbicide application, pile burning, and staging areas. This revision would ensure that all WLPZs in proximity to a treatment area are flagged, without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments, and all other conditions on treatment activities within WLPZs would apply. This establishment of WLPZs within 300 feet of treatment activities would therefore provide the same reduction in impacts on state or federally protected wetlands as provided by SPR HYD-4 in the Program EIR. For the reasons described above, the proposed revisions to SPR HYD4 would not result in a substantially more severe significant effect related state or federally protected wetlands than what was covered in the Program EIR.
Biological resource SPRs that apply to project impacts under Impact BIO-4 are AD-1, BIO-1, HYD-1, HYD-3, and HYD4. The biological resource MM that applies to project impacts under Impact BIO-4 is MM BIO-4. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-5
Initial vegetation treatments and maintenance treatments within the project area could result in direct or indirect adverse effects on wildlife movement corridors and nurseries because habitat suitable for wildlife is present throughout the project area. According to review and survey of project-specific biological resources (SPR BIO-1), large portions of the project area experience little human disturbance and are ranked as Irreplaceable and Essential Corridors in the California ACE Terrestrial Connectivity dataset (CNDDB 2025b). Although these areas have been subject to fuels management treatments over the last several years, particularly at middle and higher elevations within the Santa Cruz Mountains, they function as key pathways that support both local movement within treatment areas and regional wildlife connectivity across the broader landscape. Portions of the project area near Santa Teresa and Coyote are particularly important as cross-range connections between the Santa Cruz Mountains and the Mount Hamilton Range, sustaining broader landscape-scale movement across the South Bay region. Connectivity values decrease in areas closer to the urbanized Santa Clara Valley floor, where habitat is more fragmented and opportunities for regional movement are limited. In more rural portions of the project area, natural vegetation communities also likely function as nursery sites providing habitat for reproduction by common wildlife (e.g., deer fawning areas, common bat roosts), which may be disturbed by treatment activities. The potential for treatment activities to result in adverse effects on wildlife movement corridors and nurseries was examined in the Program EIR.
Prescribed herbivory treatments would be subject to SPR BIO-11, which would require use of wildlife friendly fencing during treatments (see Attachment A). Although SPR BIO-11 would reduce the adverse effects on wildlife movement, temporary disruption of wildlife movement through treatment areas may occur due to the disturbance related to treatment activities (e.g., noise and visual disturbance). However, because only a small portion of the project would be treated in any one year, this temporary disruption would not result in a substantial impact on wildlife movement through the project area as a whole (see Section 1.2, “Phased Implementation”).
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-53 Ecological restoration treatments, which comprise most of the proposed treatments, would be designed to retain trees greater than 16 inches dbh while incorporating additional measures to maintain wildlife habitat, including selective retention of smaller healthy trees, snags, downed logs, and a mosaic of vegetation patches and understory cover to support habitat heterogeneity and ecosystem function, including function as a movement corridor or nursery site. (see Section 2.2.1, ”Ecological Restoration”). Although shaded fuel break treatments may remove more vegetation and wildlife habitat features than ecological restoration treatments (see Section 2.2.3, “Fuel Break”), not all vegetation would be removed. Select live vegetation that provides canopy cover would be retained to a level that provides shade and maintains the ecological benefits provided by the existing vegetation community, while still reducing the potential spread of wildfire through the understory and into the canopy. Non-shaded fuel breaks would occur only in non-forested vegetation types. Further, SPR CHAP/CSS-1 and SPR BIO-5 would ensure that cover is retained in coastal sage scrub and chaparral habitats, allowing them to continue providing refuge, food sources, and reproduction habitat for plants and animals. All shaded and non-shaded fuel breaks would also be subject to applicable SPRs and MMs. Overall, fuel break treatment areas represent only a minor portion of the potential habitat for wildlife species.
WUI fuel reduction treatments apply ecologically restorative standards across large areas (e.g., selectively retaining trees, snags, downed logs, and vegetation mosaics that support habitat value) while allowing for more intensive vegetation removal than ecological restoration treatments where adjacent to critical infrastructure. Although wildlife may occasionally use areas near human structures, developed areas that experience higher levels of human disturbance may discourage movement of wildlife sensitive to human disturbance. Existing habitat corridors in the WUI are important to allow wildlife to move undisturbed through developed areas to otherwise isolated habitat patches on either side of human development. Select vegetation thinning in the WUI would create more open understory, and this may facilitate improved wildlife movement through WUI areas for larger wildlife species (e.g., mule deer). Retention standards outlined in Section 2.1.1, “General Prescription,” are designed to reduce risk of wildfire while maintaining essential function of core wildlife movement areas and nursery sites, thereby maintaining wildlife connectivity and habitat value. If surveys conducted pursuant to SPR BIO-10 detect wildlife nursery sites (e.g., deer fawning areas, common bat maternity and overwintering roosts), MM BIO-5 would apply, establishing a nodisturbance buffer of appropriate size around the nursery site as determined by a qualified biologist or RPF.
The potential for treatment activities to interfere substantially with wildlife movement corridors or impede use of wildlife nurseries was examined in the Program EIR. The potential for adverse effects on wildlife movement and nurseries is within the scope of the Program EIR because the proposed treatment activities and intensity of disturbance as a result of implementing treatment activities are consistent with those analyzed in the Program EIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact on wildlife movement corridors and wildlife nurseries is also the same, as described above.
As described in Section 1.3.2, “Proposed Project Revisions,” SPR HYD-4 would be revised to require establishment of WLPZ buffers for only the watercourses within 300 feet of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments. This revision would ensure that all WLPZs in proximity to a treatment area are flagged, without unnecessarily slowing down project implementation to establish all WLPZs throughout the entire project area. This revision would provide equivalent protection for WLPZs used by wildlife for movement and nurseries as that established under SPR HYD-4 in the Program EIR. For the reasons described above, the proposed revisions to SPR HYD-4 would not result in a substantially more severe significant effect related to wildlife movement and wildlife nurseries than what was covered in the Program EIR.
Biological resource SPRs that apply to project impacts under Impact BIO-5 are AD-1, BIO-1, BIO-4, BIO-5, BIO-10, BIO-11, HYD-1, and HYD-4. The biological resource MM that applies to project impacts under Impact BIO-5 is MM BIO-5. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-54 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR IMPACT BIO-6
Initial and maintenance treatments could result in direct or indirect adverse effects resulting in a reduction in the abundance of common wildlife, including nesting birds, because habitats for these species are present throughout the treatment areas. The potential for treatment activities, including maintenance treatments, to result in adverse effects on these resources was examined in the Program EIR.
Prescribed burning, mechanical treatments, manual treatments, and prescribed herbivory, and targeted herbicide application conducted during the nesting bird season (February 1 through August 31) could result in direct loss of active nests or disturbance to active nests from auditory and visual stimulus (e.g., heavy equipment, chainsaws, vehicles, personnel), potentially resulting in nest abandonment and loss of eggs or chicks. However, SPR BIO-12 would be applied, and for treatments implemented during the nesting bird season, a survey for common nesting birds would be conducted within the treatment area by a qualified RPF or biologist prior to treatment activities. If no active bird nests are observed during focused surveys, then additional avoidance measures would not be required. If active nests of common birds or raptors are observed during focused surveys, nest disturbance would be avoided by establishing an appropriate buffer around the nests, modifying treatments to avoid disturbance to the nests, or deferring treatment until the nests are no longer active as determined by a qualified RPF, biologist, or biological technician. Buffers may be modified by a qualified biologist based on rationale such as species sensitivity, vegetative cover, nest height, and topography that would attenuate noise and visual disturbance.
The general prescription for the project (see Section 2.1.1, “General Prescription”) would retain trees greater than 16 inches in diameter, other than Douglas-fir, which may be removed up to 36 inches in diameter to reduce encroachment into other existing vegetation types. Understory vegetation would be retained in a mosaic pattern of patches to maintain habitat heterogeneity and quality. Ecological restoration treatments would be designed to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape. Ecological restoration treatments would retain down woody debris in strategic locations (see Section 2.2.1, “Ecological Restoration”). WUI treatments would have similar tree retention standards to ecological restoration but would remove additional vegetation and down woody debris in proximity to structures and roadways (see Section
2.2.2, “Wildland-Urban Interface Fuel Reduction”). Although fuel break treatments, both shaded and non-shaded, would remove additional understory vegetation that provides habitat for common wildlife, including nesting birds, the width of fuel breaks would not exceed 200 feet and would not cover more than approximately 8.2 percent of the project area. Furthermore, SPR BIO-5 will be applied, which would retain cover in coastal scrub and chaparral habitats used by the species. Additionally, pursuant to MM BIO-3a, treatments would be designed to avoid the loss of oak woodlands and sensitive natural communities (see Impact BIO-3). The retention of chaparral, coastal sage scrub, oak woodlands, large trees, and a mosaic of understory vegetation throughout the project area would maintain habitat for common wildlife, including nesting birds. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
The potential for adverse effects on wildlife habitat or the abundance of common wildlife, including nesting birds, is within the scope of the Program EIR because the proposed treatment activities and intensity of disturbance as a result of implementing treatment activities are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, because the existing environmental conditions outside the treatable landscape in the project area are essentially the same as those within the treatable landscape, as described above, the potential impact on common wildlife, including nesting birds, is also the same. Biological resource SPRs that apply to project impacts under Impact BIO-6 are AD-1, BIO-1, BIO-2, BIO-3, BIO-4, BIO-5, and BIO-12. Therefore, this impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-7
The potential for treatment activities to result in conflicts with local policies or ordinances was examined in the Program EIR. The Santa Clara County Tree Preservation and Removal Ordinance (Division C16 Tree Preservation and
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-55 Removal) applies to the removal of all protected trees on public and private property in unincorporated areas in the county, including any tree, regardless of size, within county road rights-of-way and easements, whether within or outside the unincorporated territory of the county. The County finds that preserving trees on public and private lands is essential to maintain tree cover, protect property values, preserve scenic beauty, reduce erosion and flood risks, improve air quality, buffer winds, regulate climate and provide shade, support wildlife habitat, and safeguard historical and community assets. Heritage trees are also protected trees. “Heritage trees” are trees designated as significant by Santa Clara County to have special significance to the community and that have, therefore, been included in the heritage resource inventory adopted by resolution of the Board of Supervisors.
Where the project is within the limits of towns and cities with tree protection ordinances, the local tree protection ordinance of the applicable city or town would apply. The project area includes areas that fall within the incorporated boundaries of the cities and towns of Cupertino, Gilroy, Los Altos, Los Altos Hills, Los Gatos, Monte Sereno, Morgan Hill, Palo Alto, San Jose, and Saratoga.
In the City of Cupertino, authorization is required for removal of public trees or protected trees. Protected trees include heritage trees and specimen trees, which are trees of specific species (e.g., oaks) greater than 12 inches dbh for single trunks and greater than 24 inches dbh for multiple trunks. Authorization can be obtained through an individual tree removal permit or through adoption of tree management plan. In the City of Gilroy, a permit is required to remove native trees larger than 12 inches dbh and any tree larger than 28.5 inches dbh.
Where the project area is located with the Los Altos, a tree removal permit is required to remove any tree 12 inches or greater dbh ,native tree species 10-inches or greater dbh, trees designated as heritage trees, and trees located in the public right-of-way. Removal of hazard trees and tree removal by agencies outside of the jurisdiction of the City of Los Altos (e.g., school district) to maintain safe operation of facilities is exempt from tree permitting with verification by the City of Los Altos. In the City of Los Altos Hills a tree removal permit is required to remove oaks (Quercus spp.) 12 inches or greater dbh. Permits are not required to remove trees of any other species within Los Altos Hills.
In the town limits of Los Gatos, the Los Gatos Tree Protection Ordinance (Chapter 9, Article I, Division 2) applies. This ordinance applies to all trees with a diameter of at least 4 inches located on property that is not residential property, all heritage trees ("heritage trees" are trees or grouping of trees specifically designated by action of the town council, upon the recommendation of the Historic Preservation Commission, that possess exceptional aesthetic, biological, cultural, or historic value and are expected to have a continuing contribution to the community), and large protected trees (“large protected trees” are certain native tree species with a 24-inch or greater diameter or any other species of tree with a 48-inch or greater diameter). With the exception of heritage trees and large protected trees, the requirement for a permit for removal is exempt when removal or maintenance of a tree is to conform with the implementation and maintenance of defensible space. Heritage trees and large protected trees require a permit for removal and tree pruning.
In Morgan Hill, a permit is required for pruning or removing public or street trees, native trees with a diameter greater than 6 inches, or nonnative trees with a diameter greater than 13 inches.
If the treatment activities occur within Monte Sereno, a tree removal permit is required for the removal of significant trees whether alive or dead (Chapter 10.15). Significant trees are defined as oaks and redwoods with a dbh of greater than 6 inches and any other tree species with a dbh greater than 8 inches. Removal of hazard trees and tree removal by public utilities or the City of Monte Sereno to maintain safe operation of public service or public right-of-way is exempt from tree permitting with verification.
The portion of the project area within Palo Alto occurs within the wildland urban interface as defined in Chapter 15 of the Palo Alto Municipal Code. Within this area, defensible space requirements under the California Public Resources Code take precedence over the City of Palo Alto tree ordinance; however, outside of the defensible space zone, the tree protection ordinance (Chapter 8.04 and Chapter 8.10) applies to protected trees, shrubs, hedges, and plants located on public property within the city. A permit is required from the city to prune or remove protected trees, public trees, shrubs, and hedges. Protected trees include a suite of locally native tree species 11.5 inches dbh, coast
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-56 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR redwoods 18 inches dbh, and any other mature tree greater than 15 inches dbh; although, there are exceptions for certain exotic species.
Within the boundaries of San Jose, a permit is required removal of any tree greater than 12 inches dbh with a height of at least 54 inches (4 foot 5 inches), whether the tree is live, dead, or designated as unsuitable for the area by an arborist (Chapter 13 Section 32.020). The tree removal permit must be posted on the site where the subject tree is located, and a certified arborist report must be submitted with the tree removal permit justifying the need for the tree removal.
Where the project is in the city limits of Saratoga, the Saratoga Tree Ordinance applies (Chapter 15, Article 15-50). The ordinance applies to native trees with at least a 6-inch dbh, any tree with at least a 10-inch dbh, any tree within a public street or right-of-way, any tree of historic significance, any tree required to be planted or retained as a condition of any approval, and any tree required to be planted as a replacement. Trees protected under the ordinance require a removal permit and may require a pruning permit, depending on how much is being pruned.
Exceptions include an emergency exception if the condition of the tree presents an immediate hazard to life or property.
In accordance with SPR AD-3, treatments would be designed and implemented in a manner that is consistent with applicable local plans (e.g., general plans), policies, and ordinances to the extent the project is subject to them. In addition, treatments will be designed to retain healthy, live trees up to 16 inches in diameter to achieve appropriate crown and bole spacing, reduce vertical and horizontal fuel continuity, and promote both the growth of residual trees and overall habitat restoration. Healthy hardwoods and conifers will generally be preserved with appropriate canopy spacing, and tree removal will otherwise be limited to dead, dying, diseased, or hazard trees. Trees that do not pose a safety risk will be preferentially retained as standing habitat features, such as snags or live trees with dead limbs that provide nesting and foraging opportunities for wildlife. Together, SPR AD-3 and treatment design ensure a certain level of tree retention, which is consistent with the applicable tree preservation and removal ordinances in each jurisdiction. Therefore, there would be no conflict with local ordinances as a result of implementation of treatment activities.
As explained in the CalVTP Program EIR, projects are required to be consistent with local policies and ordinances.
Therefore, and consistent with the determination in the Program EIR, there would be no impact. The potential for the proposed treatments to conflict with local policies is within the scope of the Program EIR because vegetation treatment locations, types, and activities are consistent with those analyzed in the Program EIR. The SPRs applicable to this impact are AD-1 and AD-3. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the project area boundary, the existing regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential for conflicts with local policies or ordinances is also the same, as described above. This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT BIO-8
A portion of the project area south and east of the Los Gatos Creek watershed overlaps with the permit area of the SCVHP (See Map 3-1, “Santa Clara Valley Habitat Plan Permit Area”), as well as several of the reserves within the SCVHP reserve system. The SCVHP reserve system currently consists of approximately 16,150 acres of reserves (Santa Clara Valley Habitat Agency 2025) that are managed to enhance populations of covered and other native species and maintain ecosystem processes on those lands. The reserves also provide preservation of connections between other protected lands and important habitat areas that are either protected with conservation easements or acquired by the Santa Clara Valley Habitat Agency. Participation in the SCVHP requires that project proponents pay fees that support the reserve system or demonstrate a benefit to covered species from the project, and comply with all relevant conditions on covered activities that are applied based on the activity type, natural community type, and covered species that may be affected directly or indirectly by the project (County Santa Clara et al. 2012b). The effect
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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-57 of financial support of the reserve system or benefits to covered species, and application of conditions on covered activities in the SCVHP would be cumulatively beneficial to covered species (County Santa Clara et al. 2012a).
The SCVHP is a combined habitat conservation plan (HCP) and natural community conservation plan (NCCP).
Participation in the SCVHP is not mandatory for projects occurring within the permit area. Treatment activities in the WSCLRP may qualify as SCVHP-exempt activities or SCVHP-covered activities depending on the location, responsible agency, and type of activity proposed. To qualify as covered activities under the SCVHP, treatment activities would need to take place within the permit area for the plan (Map 3-1).
When treatment activities occur within the SCVHP area, most treatment activities proposed under this PSA/Addendum may be covered by the SCVHP if they would result in reasonable potential or likelihood to take a covered species, depending on the location (i.e., habitat suitable for covered species) and timing of that activity.
Herbicide application is not covered under the HCP portion of the SCVHP, nor would take coverage be available for federally listed species for that activity. However, herbicide is covered under the NCCP portion of the SCVHP, and consequently, take coverage for California-listed species is also included in the SCVHP for herbicide treatments. For specific treatment areas and activities contained in this PSA/Addendum covered under the SCVHP, the responsible agency may elect to enroll that portion of the project in the SCVHP. If the responsible agency (see Section 1.3.1, “Roles Under CEQA”) is a co-permittee under the plan (e.g., SCCP; City of Gilroy, City of Morgan Hill), the permittee would determine whether the treatment activities within a given treatment area would be covered under the SCVHP and would apply the necessary conditions on covered activities. For other responsible agencies that are not copermittees, the responsible agency would apply for coverage under the plan as a “participating special entity,” and the Santa Clara Vally Habitat Agency would determine whether treatment activities are covered activities under the plan. If a portion of the project is enrolled in the SCVHP, all applicable conservation measures of the SCVHP would apply to treatments carried out in that area, and that portion of the project would participate in conservation strategy implementation and support the reserve system through enrollment fees.
The proposed project includes implementation of Ecological Restoration, WUI, and fuel break treatment types (see Section 2.2, “Treatment Types”) in portions of the SCVHP reserve system. Treatments within the reserve system could be covered activities under the plan if they would result in reasonable potential or likelihood to take a covered species (see exception for herbicide above) and therefore would be consistent with the SCVHP. For WSCLRP treatments outside of the reserve system, if the responsible agency elects to enroll a portion of the project in the SCVHP, that portion of the project would be consistent with the SCVHP. For portions of the project within the SCVHP permit area that do not enroll in the SCVHP, consistency with the SCVHP would be met with the habitat retention standards in this PSA/Addendum and the implementation of SPRs and MMs (see Impacts BIO-1, BIO-2, BIO-3, BIO-4, and BIO 5 above) that would avoid impacts to both covered species and habitats. Furthermore, the post-treatment conditions that would result from implementation of the proposed project would enhance grassland habitats through prescribed burning, which would result in the thinning of nonnative grasses that would approximate conditions under the natural fire regime. The SPR that applies to this impact is SPR AD-1.
As explained in the CalVTP Program EIR, project consistency with an adopted HCP is a legal requirement. Therefore, and consistent with the determination in the Program EIR, there would be no impact. The inclusion of land in the proposed project area outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the project area boundary, the existing regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential for conflicts with NCCPs and HCPs is also the same, as described above. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-58 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Source: County Santa Clara et. al. 2012b.
Map 3-1. Santa Clara Valley Habitat Plan Permit Area
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-59
NEW BIOLOGICAL RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR. The project proponent has considered the site-specific characteristics of the proposed project and determined that they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.6.1, “Environmental Setting,” and Section 3.6.2, “Regulatory Setting,” in Volume II of the Final Program EIR).
As described in Section 1.3.2, “Proposed Project Revisions,” revisions to requirements under SPR HYD-4 are proposed to require establishment of WLPZ buffers only for watercourses within 300 feet of treatment activities, including mechanical, manual, herbicide application, pile burning, and staging areas. This revision would ensure that all WLPZs in proximity to a treatment area are flagged, while avoiding unnecessary delays from flagging all WLPZs across the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments. All other conditions on treatment activities within WLPZs would continue to apply. Limiting establishment of WLPZs to within 300 feet of treatment activities would provide the same reduction in impacts to state or federally protected wetlands as SPR HYD-4 in the Program EIR. Therefore, the proposed revision would not result in a substantially more severe significant effect on wetlands than what was previously covered.
Revisions to requirements under SPR GEO-1 are also proposed. Revisions to SPR GEO-1 would allow for suspension of mechanical treatments, herbicide treatments, or prescribed herbivory when it is actively raining, soils are saturated, or wet enough for compaction. This would replace the current rule of suspending activities based on a forecasted 30 percent chance of rain. Suspension of these activities would not be based on weather forecasts alone, but rather if weather predictions materialize and lead to precipitation events. This revision would provide the same level of protection for indirect effects on special-status plants resulting from soil destabilization as the original SPR GEO-1, because these activities would not continue during conditions where soil destabilization occurs. This revision to SPR constitutes a change to the SPR presented in the Program EIR and would not constitute a new significant impact than what was covered in the Program EIR.
The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to biological resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed project are also consistent with those considered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact related to biological resources would occur.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-60 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR
4.6 GEOLOGY, SOILS, PALEONTOLOGY, AND MINERAL RESOURCES Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact GEO-1: Result in
Substantial Erosion or Loss of
Topsoil
LTS Impact GEO-1,
pp. 3.7-26 –
3.7-29
Yes AD-3
AQ-3, AQ-4
GEO-1, GEO-2
GEO-3, GEO-4
GEO-5, GEO-6
GEO-7, GEO-8
HYD-3, HYD-4
NA LTS No Yes
Impact GEO-2: Increase Risk of
Landslide
LTS Impact GEO2, pp. 3.7-29 –
3.7-30
Yes AD-3
AQ-3
GEO-3, GEO-4
GEO-7, GEO-8
NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New Geology, Soils, Paleontology, and Mineral Resource Impacts: Would the treatment result in other impacts to geology, soils, paleontology, and mineral resources that are not evaluated in the CalVTP Program EIR? Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
The project area is located within the Southern Coastal Ranges physiographic and geologic province. The Coastal Ranges physiographic province extends more than 370 miles from the Transverse Ranges in the south to beyond the Oregon border in the north (DeCourten 2009). The mountains in this province, called the Coast Ranges, are all aligned in a consistent northwest trend. The Coast Ranges are generally oriented parallel to the Great Valley and Sierra Nevada provinces to the east and have a similar extent. The relatively recent emergence of the Coast Ranges was strongly affected by the evolution of the San Andreas Fault system and the development of the modern transform boundary between the Pacific and North American plates (DeCourten 2009). The California Coast Ranges have traditionally been divided into northern and southern portions with the San Francisco Bay dividing the two.
However, it is more meaningful to divide the Coast Ranges into northern and southern portions owing to their separation by the San Andreas Fault system. The California Coast Ranges are primarily composed of Jurassic- to Cretaceous-age (about 65–150 million years old) marine sedimentary and volcanic rocks of the Franciscan assemblage. The Franciscan assemblage consists of partially metamorphosed greenstone, basalt, chert, and graywacke that originated as sea floor sediments. The coastline along this province is uplifted, wave-cut, and terraced. The eastern border of the Coast Ranges province is characterized by ridges and valleys in Mesozoic strata (CGS 2002). As discussed in Section 3.7.1, “Environmental Setting,” of the CalVTP Program EIR, the southern portion of the Coastal Ranges exhibit high erodibility risk.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-61 IMPACT GEO-1
Proposed treatment types are ecological restoration, WUI fuel reduction, and fuel break, which would be implemented using manual treatment, mechanical treatment, prescribed burning, prescribed herbivory, and targeted ground application of herbicides. Most of these activities would result in vegetation removal and soil disturbance. The potential for these treatment activities to cause substantial erosion or loss of topsoil was examined in the Program EIR. This impact is within the scope of the Program EIR because the use and type of equipment, extent of vegetation removal, and intensity of prescribed burning are consistent with those analyzed in the Program EIR.
As described above under Section 1.3.2, “Proposed Project Revisions,” SPR GEO-1 would be revised. As presented in the Program EIR, SPR GEO-1 requires suspension of treatment activities, including mechanical treatments, herbicide application, and prescribed herbivory, during heavy precipitation (i.e., if the National Weather Service forecast is a chance [30 percent or more] of rain within the next 24 hours). As described in the CalVTP Program EIR, mechanical treatments and herbicide application conducted during precipitation events can result in soil disturbance, erosion, increased runoff, soil destabilization, and water quality impacts. A revision to the SPR is proposed such that mechanical treatments would be suspended if (1) it is raining, (2) soils are saturated, or (3) soils are wet enough to be compacted by mechanical treatment activities and herbicide application would be suspended if the National Weather Service forecast is a “chance” (30 percent or more averaged over each hour) of rain. In the region where the project is located, forecasts often include a chance of rain; however, precipitation sometimes does not materialize. Therefore, suspension of treatment activities in these cases could result in unnecessary loss of work time. Suspending mechanical treatments, prescribed herbivory, and herbicide treatments during precipitation events would minimize the risk of soil compaction and disturbance; therefore, this revision would not result in any new or substantially more severe impacts related to erosion. This revision is consistent with the purpose of SPR GEO-1, which is to suspend disturbance during heavy precipitation to minimize the risk of soil compaction and disturbance. Therefore, the proposed revisions to SPR GEO-1 would not result in substantial erosion or loss of topsoil or an increased risk of landslides, and revisions to SPR GEO-1 would not result in a substantially more significant effect related to erosion or loss of topsoil and landslides than what was covered in the program EIR.
SPR HYD-4 would be revised to require establishment of WLPZ buffers for only the watercourses within 300 feet of the manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments.
This revision would ensure that all WLPZs in proximity to a treatment area are flagged, without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of manual, mechanical, prescribed pile burning, and targeted herbicide application treatments; degradation would be prevented pursuant to the revised SPR. For the reasons described above, the proposed revisions to SPR HYD-4 would not result in a substantially more severe significant effect related to erosion or loss of topsoil than what was covered in the Program EIR. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the soil characteristics of the project area are essentially the same within and outside the CalVTP treatable landscape; therefore, the potential impact related to soil erosion is also the same, as described above. SPRs applicable to this impact are AD-3, AQ-3, AQ-4, GEO-1 through GEO-8, HYD-3, and HYD-4. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT GEO-2
Treatments would include vegetation removal in areas with steep slopes. Portions of the project area are within an earthquake-induced landslide zone as mapped by the California Geological Survey (CGS 2025). Additionally, portions of the project area are in liquefaction hazard zones and landslide hazard zones (County of Santa Clara 2012). The potential for landslides to occur in the project area is moderate to high (USGS 2025). Along roadways, small slip outs
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-62 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR and slumps are relatively common during severe winter storms. The potential for treatment activities to increase landslide risk was examined in the Program EIR. This impact is within the scope of the Program EIR because the extent of vegetation removal, intensity of treatment activities, and required avoidance of steep slopes and areas of instability are consistent with those analyzed in the Program EIR.
The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact related to landslide risk is also the same, as described above. SPRs applicable to this impact are AD-3, AQ-3, GEO-3, GEO-4, GEO-7, and GEO-8. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW GEOLOGY, SOILS, PALEONTOLOGY, AND MINERAL RESOURCE IMPACTS The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR. The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.7.1, “Environmental Setting,” and Section 3.7.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR, and revisions to an SPR constitute a revision to the program. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to geology, soils, paleontology, and mineral resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed project are the same, and for the reasons described above, impacts are also consistent with those covered in the Program EIR.
Revisions to SPR GEO-1 and SPR HYD-4 would constitute changes to the project analyzed in the Program EIR.
However, as described for Impact GEO-1 above, the revisions would reduce the potential for runoff and soil erosion and would be consistent with the overall intent of SPR GEO-1 and SPR HYD-4. Therefore, revisions to SPR GEO-1 and SPR HYD-4 would not result in a new impact that was not covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape, and revisions to SPR GEO-1 and SPR HYD-4, would not give rise to any new significant impacts. Therefore, no new impact related to geology, soils, paleontology, or mineral resources would occur that is not covered in the Program EIR.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-63
4.7 GREENHOUSE GAS EMISSIONS
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact GHG-1: Conflict with
Applicable Plan, Policy, or
Regulation of an Agency
Adopted for the Purpose of
Reducing the Emissions of
GHGs
LTS Impact GHG1, pp. 3.8-10 –
3.8-11
Yes AD-3 NA LTS No Yes
Impact GHG-2: Generate GHG
Emissions through
Treatment Activities
PSU Impact GHG2, pp. 3.8-11 –
3.8-17
Yes AD-3
AQ-3
GHG-2 SU No Yes
Notes: LTS = less than significant; PSU = potentially significant and unavoidable; SU = significant and unavoidable; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New GHG Emissions Impacts: Would the treatment result in other impacts to GHG emissions that are not evaluated in the CalVTP Program EIR? Yes No If yes, complete row(s) below and discussion Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT GHG-1
Use of vehicles and mechanical equipment and prescribed burning during initial and maintenance treatments would result in greenhouse gas (GHG) emissions. Consistency of treatments under the CalVTP with applicable plans, policies, and regulations aimed at reducing GHG emissions was examined in the Program EIR. Consistent with the Program EIR, although GHG emissions would occur from equipment and vehicles used to implement treatments, the purpose of the proposed project is to reduce wildfire risk, which could reduce GHG emissions and increase carbon sequestration over the long term. This impact is within the scope of the Program EIR because the proposed activities, as well as the associated equipment, duration of use, and resulting GHG emissions, are consistent with those analyzed in the Program EIR.
The inclusion of land in the proposed project area outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the same plans, policies, and regulations adopted to reduce GHG emissions apply in the areas outside the treatable landscape, as well as in the areas within the treatable landscape; therefore, the GHG impact is also the same, as described above. SPR AD-3, which requires consistency with local plans, policies, and ordinances, is applicable to this impact. SPR GHG-1 is not applicable to the proposed project because this project is not a registered offset project under the Board of Forestry and Fire Protection’s AB 1504 Carbon Inventory Process. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-64 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR IMPACT GHG-2
Use of vehicles and mechanical equipment and prescribed burning during initial and maintenance treatments and biomass processing would result in GHG emissions. The potential for treatments under the CalVTP to generate GHG emissions was examined in the Program EIR. This impact was found to be potentially significant and unavoidable after the application of all feasible MMs because of the infeasibility of implementing specific emission reduction techniques and the uncertainties associated with all the parameters and objectives of prescribed burning. MM GHG-2 in the CalVTP Program EIR requires project proponents to implement feasible methods to reduce the GHG emissions from prescribed burning, including pile burning. Accordingly, WSCLRP includes the proposed use of air curtain burners and carbonizers. The essential function of these specialized biomass processing technologies is to reduce smoke and resultant GHG emissions compared to pile burning by consuming biomass quickly and efficiently. According to a 2020 study of biomass, air curtain burners and Oregon kilns emit 54 percent less carbon dioxide (CO2) emissions compared to pile burning (Puettmann et al. 2020, as cited in Ascent 2022). In addition, the production of biochar by air curtain burning and subsequent application as a soil amendment provide long-term carbon sequestration benefits that are not available from pile burning.
This impact is within the scope of the Program EIR because the proposed activities, as well as the associated equipment and duration of use, and the intent of the treatments to reduce wildfire risk and GHG emissions related to wildfire are consistent with those analyzed in the Program EIR. MM GHG-2 will be implemented by using air curtain burners and carbonizers when feasible to reduce GHG emissions associated with prescribed burning. Although use of these specialized biomass processing technologies would substantially reduce GHG emissions, emissions generated by the proposed treatments would still contribute to the annual emissions generated by the CalVTP, and this impact would remain significant and unavoidable, consistent with, and for the same reasons described in, the Program EIR.
The inclusion of land in the proposed project area outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the climate conditions present in the areas outside the treatable landscape are the same as those within the treatable landscape; therefore, the GHG impact is also the same, as described above. SPR AD-3 and SPR AQ-3 are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW IMPACTS RELATED TO GHG EMISSIONS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR. The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined that they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.8.1, “Regulatory Setting,” and Section 3.8.2, “Environmental Setting,” in Volume II of the Final Program EIR). Including land in the proposed project area outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR.
However, within the boundary of the project area, the existing environmental conditions pertinent to the climate conditions that are present in the areas outside the treatable landscape are the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are also consistent with those covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts.
Therefore, no new impact related to GHG emissions would occur.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-65
4.8 ENERGY RESOURCES
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact ENG-1: Result in
Wasteful, Inefficient, or
Unnecessary Consumption of
Energy
LTS Impact ENG-1,
pp. 3.9-7 –
3.9-8
Yes NA NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New Energy Resource Impacts: Would the treatment result in other impacts to energy resources that are not evaluated in the CalVTP Program EIR? Yes No If yes, complete row(s) below and discussion Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT ENG-1
Use of vehicles, mechanical equipment, and some manual equipment (e.g., chainsaws, weed-trimmers, drip torches, propane torches, leaf blowers) during initial treatment and treatment maintenance activities would result in the consumption of energy through the use of fossil fuels. The use of fossil fuels for equipment and vehicles was examined in the Program EIR. The consumption of energy during implementation of the project is within the scope of the Program EIR because the types of activities, as well as the associated equipment and duration of proposed use, are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR.
However, the existing energy consumption is essentially the same within and outside the treatable landscape; therefore, the energy impact is also the same, as described above. No SPRs are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW ENERGY RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP Program EIR.
The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.9.1, “Environmental Setting,” and Section 3.9.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed project area constitutes a change to the geographic extent presented in the Program EIR.
However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to energy resources outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-66 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR consistent with those covered in the Program EIR. The inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impact. Therefore, no new impact related to energy resources would occur.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-67
4.9 HAZARDOUS MATERIALS, PUBLIC HEALTH AND SAFETY
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered In the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact HAZ-1: Create a
Significant Health Hazard from
the Use of Hazardous
Materials
LTS Impact HAZ-1,
pp. 3.10-14 –
3.10-15
Yes AD-3
HAZ-1, HAZ-2
HAZ-3, HAZ-4
HYD-4
NA LTS No Yes
Impact HAZ-2: Create a
Significant Health Hazard from
the Use of Herbicides
LTS Impact HAZ2, pp. 3.10-15
– 3.10-18
Yes AD-3
HAZ-2, HAZ-3
HAZ-4, HAZ-5
HAZ-6, HAZ-7
HAZ-8, HAZ-9
NA LTS No Yes
Impact HAZ-3: Expose the
Public or Environment to
Significant Hazards from
Disturbance to Known
Hazardous Material Sites
LTSM Impact HAZ3, pp. 3.10-18
– 3.10-19
Yes AD-3
HAZ-2
HAZ-3
HAZ-4
HAZ-3 LTSM No Yes
Notes: LTS = less than significant; LTSM = less than significant with mitigation; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New Hazardous Materials, Public Health and Safety Impacts: Would the treatment result in other impacts related to hazardous materials, public health and safety that are not evaluated in the CalVTP Program EIR? Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT HAZ-1
Initial and maintenance treatments would consist of manual treatments, mechanical treatments, prescribed burning, prescribed herbivory, and targeted application of herbicides. These treatment activities would require the use of oils, fuels, lubricants, and related accelerants, which are hazardous materials. The potential for treatment activities to cause a significant health hazard from the use of hazardous materials was examined in the Program EIR. This impact is within the scope of the Program EIR because the types of treatments and associated equipment and types of hazardous materials that would be used are consistent with those analyzed in the Program EIR.
As described under Section 1.3.2, “Proposed Project Revisions,” revisions are proposed to SPR HAZ-1. SPR HAZ-1 would be revised to promptly stabilize any equipment found leaking and fix it on-site, outside of the WLPZ, or remove the leaking equipment from the treatment area. This provides flexibility to fix equipment on-site if feasible and continue treatment rather than requiring all leaking equipment be removed. This would help to prevent unnecessarily slowing down project implementation while maintaining the overall intent of SPR HAZ-1, which is to
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-68 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR minimize hazardous material releases in treatment areas from equipment use. For the reasons described, the proposed revision to SPR HAZ-1 would not result in a substantially more severe significant effect related to creation of a significant health hazard from the use of hazardous materials compared to what was covered in the Program EIR.
Revisions to SPR HYD-4 are also proposed that require that WLPZs buffers are established for only the watercourses within 300 feet of treatment activities. This revision would help ensure that all WLPZs in proximity to a treatment area are recently flagged without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the purpose and intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments; degradation would be prevented pursuant to the revised SPR. For the reasons described, the proposed revision to SPR HYD-4 would not result in a substantially more severe significant effect related to creation of a significant health hazard from the use of hazardous materials compared to what was covered in the Program EIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, the exposure potential and regulatory conditions are essentially the same within and outside the treatable landscape; therefore, the hazardous material impact is also the same, as described above. SPRs AD-3, HAZ-1 through HAZ-4, and HYD-4 are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HAZ-2
Initial and maintenance treatments would include targeted ground-based herbicide application methods, including batch truck application devices (e.g., backpack sprayer, manual brush applicator), and passenger vehicle(s) or allterrain vehicle(s). No aerial spraying of herbicides would occur. The potential for treatment activities to cause a significant health hazard from use of herbicides was examined in the Program EIR. This impact is within the scope of the Program EIR because the herbicides (i.e., clopyralid, glyphosate, velpar, imazapyr, sulfometuron, triclopyr, nonylphenol, and Cleantraxx) and application methods that would be used are consistent with those analyzed in the Program EIR. In addition, herbicides would be applied by licensed applicators in compliance with all laws, regulations, and herbicide label instructions, consistent with herbicide use described in the Program EIR. Consistent with the Program EIR, SPRs AD-3 and HAZ-2 through HAZ-9 would be implemented, which require the preparation of a spill prevention and response plan, triple rinsing of herbicide containers before disposal, proper storage of herbicides, and measures to minimize herbicide drift to non-target areas.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the hazardous materials impact is also the same, as described above. SPRs AD-3 and HAZ-2 through HAZ-9 are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HAZ-3
Treatments would include soil disturbance and prescribed burning, which could expose workers, the public, or the environment to hazardous materials if a contaminated site is present within the project area. The potential for workers participating in treatment activities to encounter contamination that could expose them, the public, or the environment to hazardous materials was examined in the Program EIR. This impact was identified as potentially significant in the Program EIR because hazardous materials sites could be present within treatment sites throughout the large geographic extent of the treatable landscape, and the feasibility of implementing mitigation for exposure of people or the environment to hazards resulting from soil disturbance or burning in a hazardous materials site was uncertain.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-69 As directed by MM HAZ-3, database searches for hazardous materials sites within the project area have been conducted. Six active cleanup sites were identified in the project area: Kerful Cleaners located in Saratoga on SaratogaLos Gatos Road, SJWC Belgatos Station in Los Gatos on Belgatos Road, Hillview Cleaners in Saratoga on Big Basin Way, Sanborn Christensen Nursery Remediation in Saratoga on Sanborn Road, Owens Development located in Los Altos on Middle Fork Lane, and Madera Drive Cupertino Lot Spill located in Cupertino on Madera Drive. There are 19 sites currently being evaluated by the California Environmental Protection Agency in the project area. Fourteen of these are located in the Almaden Quicksilver County Park Area; they are New Almaden-South Randol (60002538), New AlmadenNorth Randol (60002548), New Almaden-Velasco (60002550), New Almaden-San Pedro-Almaden Area (60002539), New Almaden District (60002540), New Almaden-Harry Area (60002541), New Almaden-Santa Marina Area (60002544), New Almaden-San Francisco Area (60002545), New Almaden-Central Stope Area (60002542), New Almaden Mine (60002549), New Almaden-Cora Blanca Area (60002546), Almaden Quicksilver Country Park (43100001), New Almaden Placers and Dump (60002547), and San Francisco Mine (60002543). The project area also encompasses a state response site (Tripp residence/Saratoga House [43280118]), a voluntary agreement site (Mazzone Property [60001951]), a historical site (Kaiser Cement Corp, Permanente Plant [43350079]), and two formerly used defense sites (FUDSs) sites (Nas Moffett Field [80000787]; Almaden Air Force Station). A total of 25 sites under evaluation have been identified within the project area that could have potential contaminants not specified yet. The rest of the sites identified in the project area are not active or have been remediated and closed (SWRCB 2025; DTSC 2025; CalEPA 2025).
All sites that are known to or have potential to contain hazardous waste will be marked, and no prescribed burning or soil-disturbing treatment activities will occur within 100 feet of the site boundaries, in accordance with MM HAZ-3.
Therefore, with the implementation of MM HAZ-3, no hazardous materials sites would be disturbed by treatments, and this impact would be less than significant.
This impact is within the scope of the Program EIR because the types of treatments and associated equipment that could potentially expose workers or the environment to hazardous materials are consistent with those analyzed in the Program EIR. The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the potential to encounter hazardous materials and the regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the hazardous materials impact is also the same, as described above. SPRs AD-3, HAZ-2, HAZ-3, and HAZ-4 are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW HAZARDOUS MATERIALS, PUBLIC HEALTH AND SAFETY IMPACTS The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR.
The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.10.1, “Environmental Setting,” and Section 3.10.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed project areas constitutes a change to the geographic extent presented in the Program EIR, and revisions to an SPR constitute a revision to the program. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to hazardous materials that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are also consistent with those covered in the Program EIR.
Revisions to SPRs HAZ-1 and HYD-4 would constitute a change to the project analyzed in the Program EIR. However, as described for Impact HAZ-1 above, the revisions would reduce the potential for hazardous material releases in treatment areas from equipment use and would prevent degradation of watercourses, consistent with the overall intent of SPRs HAZ-1 and HYD-4. Therefore, revisions to SPRs HAZ-1 and HYD-4 would not result in a new impact that was not covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape and revisions to SPRs HAZ-1 and HYD-4 would not give rise to any new significant impacts. Therefore, no new impact related to hazardous materials, public health, or safety would occur.
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-70 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR
4.10 HYDROLOGY AND WATER QUALITY
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact HYD-1: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface or
Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
the Implementation of
Prescribed Burning
LTS Impact HYD-1,
pp. 3.11-25 –
3.11-27
Yes AD-3
AQ-3
BIO-4
BIO-5
GEO-4
GEO-6
HYD-2
HYD-4
NA LTS No Yes
Impact HYD-2: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface or
Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through the
Implementation of Manual or
Mechanical Treatment Activities
LTS Impact HYD2, pp. 3.11-27
– 3.11-29
Yes AD-3
BIO-1
GEO-1, GEO-2
GEO-3, GEO-4
GEO-5, GEO-7
GEO-8
HYD-1, HYD-2
HYD-4, HYD-5
HAZ-1, HAZ-5
NA LTS No Yes
Impact HYD-3: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface
or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
Prescribed Herbivory
LTS Impact HYD3, p. 3.11-29Yes AD-3
HYD-2
HYD-3
NA LTS No Yes
Impact HYD-4: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface
or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
the Ground Application of
Herbicides
LTS Impact HYD4, pp. 3.11-30
– 3.11-31
Yes AD-3
BIO-4
HAZ-5
HAZ-7
HYD-2
HYD-5
NA LTS No Yes
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-71 Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Impact HYD-5: Substantially
Alter the Existing Drainage
Pattern of a Treatment Site or
Area
LTS Impact HYD5, p. 3.11-31Yes AD-3
GEO-5
HYD-2, HYD-4
HYD-6
NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New Hydrology and Water Quality Impacts: Would the treatment result in other impacts to hydrology and water quality that are not evaluated in the CalVTP Program EIR?
Yes No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
The project area is primarily within the following watersheds: Adobe Creek–Frontal San Francisco Bay Estuaries, San Francisquito Creek, Permanente Creek-Frontal San Francisco Bay Estuaries, Stevens Creek, Saratoga Creek, Corralitos Creek, Calabazas Creek–Frontal San Francisco Bay Estuaries, Los Gatos Creek, Guadalupe River, Alamintos Creek, Canoas Creek, Metcalfe Canyon–Coyote Creek, Little Llagas Creek, Upper Uvas Creek, Lower Uvas Creek, Salsipuedes Creek, Lower Pajaro River, and Lower Llagas Creek. With smaller portions in the Bear Creek–San Lorenzo River, Upper Pescadero Creek, Zayante Creek–San Lorenzo River, Soquel Creek, and Upper Pajaro River watersheds. Some of the major hydrologic features include Adobe Creek, San Francisquito Creek, Bear Creek, Corte Madra Creek, Lexington Reservoir, Permanente Creek, Stevens Creek, Saratoga Creek, Corralitos Creek, Calabazas Creek, Los Gatos Crook, Guadalupe River, Alamintos Creek, Canoas Creek, Coyote Creek, Little Llagas Creek, Upper Uvas Creek, Lower Uvas Creek, Salsipuedes Pescadero Creek, Zayante Creek, San Lorenzo River, Soquel Creek, and Pajaro River.
Several of the impacts below (i.e., Impacts HYD-1 through HYD-4) evaluate compliance with water quality standards or waste discharge requirements. All include implementation of SPR HYD-1, which requires compliance with water quality regulations. The State Water Resources Control Board requires all projects using the CalVTP Program EIR to follow the requirements of their Vegetation Treatment General Order, which would meet the requirements of SPR HYD-1. Users of the CalVTP PSA process are automatically enrolled in the General Order and are required to implement all applicable SPRs and MMs from the Program EIR. In addition, the General Order requires project proponents to comply with any applicable basin plan prohibitions.
IMPACT HYD-1
Initial and maintenance treatments would include prescribed burning. Ash and debris from treatment areas that are treated with prescribed burning could be washed by runoff into adjacent drainages and streams. Prescribed burning would only be implemented during appropriate burn windows (typically fall, winter, spring, and early summer) when environmental conditions (e.g., windspeed, weather forecast, fuel moisture) are conducive to burning targeted fuels, while reducing the risk of high severity burns. WLPZs would be implemented for Class I and Class II streams that are within treatment areas pursuant to SPR HYD-4. The potential for prescribed burning activities to cause runoff and violate water quality regulations or degrade water quality was examined in the Program EIR. This impact is within the
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-72 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR scope of the Program EIR because the use of low intensity prescribed burns and associated impacts to water quality are consistent with those analyzed in the Program EIR.
The proposed revisions to SPR HYD-4 require the establishment of WLPZ buffers for only the watercourses within 300 feet of treatment activities, including prescribed burning. This revision would ensure that all WLPZs in proximity to a treatment area are flagged, without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of treatment activities, including prescribed burning. For the reasons described above, the proposed revisions to SPR HYD-4 would not result in a substantially more severe significant effect related to water quality than what was covered in the Program EIR.
SPR GEO-1 would be revised to remove the requirement of suspending certain treatment activities when rain is in the forecast; all other components of SPR GEO-1 would remain the same. This revision would replace the current requirement of suspending activities based on a forecasted 30 percent chance of rain within the next 24 hours.
Suspension of these activities would not be based on weather forecasts alone (under which precipitation may never materialize), but rather on if weather predictions materialize and lead to precipitation events. This revision is consistent with the overall intent of SPR GEO-1 because the project proponent would be required to suspend mechanical disturbance during heavy precipitation to minimize the risk of soil compaction and soil disturbance.
The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from prescribed burning is also the same, as described above. SPRs applicable to this impact are AD-3, AQ-3, BIO-4, BIO-5, GEO-4, GEO-6, HYD-2, and HYD-4. As explained above, impacts on water quality resulting from the proposed project would not constitute a new or substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HYD-2
Initial and maintenance treatments would include manual and mechanical treatment activities. The potential for mechanical and manual treatment activities to violate water quality regulations or degrade water quality was examined in the Program EIR. This impact is within the scope of the Program EIR because the use of heavy equipment and handheld tools to remove vegetation and associated impacts to water quality are consistent with those analyzed in the Program EIR.
Revisions to SPRs HYD-4, GEO-1, and HAZ-1 are proposed. SPR HYD-4 would be revised to require establishment of WLPZ buffers for only the watercourses within 300 feet of treatment activities, including mechanical and manual treatments. This revision would help ensure that all WLPZs in proximity to a treatment area are recently flagged without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the original purpose and intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of treatment activities, including mechanical and manual treatments.
Revisions to SPR HAZ-1 would allow for leaking equipment to be stabilized and fixed on-site. All other elements of SPR HAZ-1 would remain the same as presented in the Program EIR. This revision is consistent with the original purpose and intent of SPR HAZ-1, which is to minimize hazardous material releases in treatment areas from equipment use, and would allow the project proponent to stabilize and fix leaking equipment promptly on-site, if feasible; otherwise, the equipment would be promptly removed.
Proposed revisions to GEO-1 would require that mechanical treatments would be suspended if (1) it is raining, (2) soils are saturated, or (3) soils are wet enough to be compacted by mechanical treatment activities, rather than when there is a “chance” (30 percent or more averaged over each hour) of rain. This modification constitutes a revision to the program description analyzed in the Program EIR. Requirements under SPR GEO-1 are intended to prevent soil destabilization during precipitation events that could result adverse effects on hydrology and water quality. The revision to SPR GEO-1 would provide the same level of protection to water quality and hydrology resulting from soil
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-73 destabilization as the original SPR GEO-1 because these activities would not continue during conditions where soil destabilization occurs. Suspension of these activities would not be based on weather forecasts alone, but rather on if weather predictions materialize and lead to precipitation events. Therefore, proposed revisions to SPR GEO-1 would not result in a substantially more severe significant effect on water quality or waste discharge requirements than what was covered in the Program EIR.
For the reasons described above, the proposed revisions to SPRs HYD-4, GEO-1, and HAZ-1 would not result in a substantially more severe significant effect related to water quality than what was covered in the Program EIR.
The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from manual and mechanical treatments is also the same, as described above. SPRs applicable to this impact are AD3, HYD-1, HYD-2, HYD-4, HYD-5, GEO-1 through GEO-5, GEO-7, GEO-8, BIO-1, HAZ-1, and HAZ-5. As explained above, this determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HYD-3
Initial and maintenance treatments would include prescribed herbivory. The potential for prescribed herbivory to violate water quality regulations or degrade water quality was examined in the Program EIR. This impact is within the scope of the Program EIR because the use of grazing animals (e.g., goats, sheep) and the grazing intensity to manage and remove vegetation are consistent with those analyzed in the Program EIR. Environmentally sensitive areas, such as watercourses, riparian woodlands, and sensitive habitat areas or areas potentially containing special-status plant species or cultural resources, would be identified and avoided if prescribed herbivory would have an adverse effect on the resource. A herder, fencing, mineral block, or a watering site may be required to keep the grazing animals within the desired area; typically, professional herders or portable electric fencing would be used during prescribed herbivory treatments. A buffer of approximately 50 feet would be maintained between sensitive and actively grazed areas as required by SPR HYD-3.
The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from prescribed herbivory treatments is also the same, as described above. SPRs applicable to this impact are AD-3, HYD-2, and HYD-3. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HYD-4
Initial and maintenance treatments would include targeted application of herbicides to treat invasive plant species as defined by Cal-IPC. Targeted herbicide application would be used to prevent the resprouting of invasive species in the project area. Herbicides would not be used within WLPZ buffers. Targeted herbicide application would occur on up to 143,375 acres of the project area. Consistent with the Program EIR, herbicide application would be implemented only at ground-level by manual application devices (i.e., spot, foliar spray, or cut stump method by hand) and would comply with EPA and DPR label standards. The potential for the use of herbicides to violate water quality regulations or degrade water quality was examined in the Program EIR. This impact is within the scope of the Program EIR because the use of herbicides and associated impacts to water quality are consistent with those analyzed in the Program EIR.
The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from use of herbicides is also the same, as described above. SPRs applicable to this impact are AD-3, HYD-2, HYD-5,
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-74 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR BIO-4, HAZ-5, and HAZ-7. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
IMPACT HYD-5
Initial and maintenance treatments could cause ground disturbance and erosion, which could directly or indirectly modify existing drainage patterns. The potential for treatment activities to substantially alter the existing drainage pattern of a treatment area was examined in the Program EIR. This impact on site drainage is within the scope of the Program EIR because the types of treatments and treatment intensity are consistent with those analyzed in the Program EIR.
SPRs applicable to this impact are AD-3, GEO-5, HYD-2, HYD-4, and HYD-6. Revisions are proposed to SPR HYD-4 that require establishment of WLPZ buffers for watercourses within 300 feet of manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments. This revision would ensure that all WLPZs in proximity to a treatment area are flagged without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area. This revision is consistent with the overall intent of SPR HYD-4, which is to prevent degradation of watercourses during implementation of manual, mechanical, prescribed burning, prescribed herbivory, and targeted herbicide application treatments. For the reasons described above, the proposed revisions to SPR HYD-4 would not result in a substantially more severe significant effect related to drainage patterns than what was covered in the Program EIR.
The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, surface water conditions are essentially the same within and outside the treatable landscape; therefore, the impact related to alteration of site drainage patterns is also the same, as described above. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.
NEW HYDROLOGY AND WATER QUALITY IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR. The site-specific characteristics of the proposed project were considered during the development of this PSA/Addendum, and it is determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.11.1, “Environmental Setting,” and Section 3.11.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the project area constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to hydrology and water quality that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are also consistent with those covered in the Program EIR.
Revisions to SPRs HYD-4, GEO-1, and HAZ-1 would constitute a change to the project analyzed in the Program EIR.
However, as described under Impacts HYD-1, HYD-2, and HYD-5 above, the revisions would reduce the potential for hydrology and water quality impacts consistent with the overall intent of SPRs HYD-4, GEO-1, and HAZ-1. Therefore, revisions to these SPRs would not result in a new impact that was not covered in the Program EIR. No changed circumstances are present; the inclusion of areas outside the CalVTP treatable landscape and revisions to SPRs HYD-4, GEO-1, and HAZ-1 would not give rise to any new significant impacts. Therefore, no new impact related to hydrology and water quality would occur.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-75
4.11 LAND USE AND PLANNING, POPULATION AND HOUSING
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact LU-1: Cause a
Significant Environmental
Impact Due to a Conflict with a
Land Use Plan, Policy, or
Regulation
LTS Impact LU-1,
pp. 3.12-13 –
3.12-14
Yes AD-3
AD-9
NA LTS No Yes
Impact LU-2: Induce
Substantial Unplanned
Population Growth
LTS Impact LU-2,
pp. 3.12-14 –
3.12-15
Yes NA NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.
New Land Use and Planning, Population and Housing Impacts: Would the treatment result in other impacts to land use and planning, population and housing that are not evaluated in the CalVTP Program EIR? Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT LU-1
Vegetation treatment activities would occur in Santa Clara County consisting of approximately 99,209 acres of private land and 44,166 acres of publicly owned land, including land owned by California State Parks; Santa Clara County Parks; Santa Clara Habitat Agency; Santa Clara Valley Open Space Authority; Peninsula Open Space Trust; the Cities of Palo Alto, Cupertino, Saratoga, Morgan Hill, and Gilroy; and the Land Trusts of Santa Clara County and Santa Cruz County. The proposed project would not conflict with any land use plan, policy, or regulation (including noise ordinances, as explained in Section 4.12, or local tree removal ordinances or HCP, as explained under “Impact BIO-7” in Section 4.5).
SPR AD-3 would be implemented, which would ensure that the project does not conflict with land use plans, policies, or regulations. Treatments would be designed and take place in a manner that is consistent with applicable plans, policies, and regulations outlined in the Santa Clara County General Plan (County of Santa Clara 1994), SCC Land Use and Development Code (County of Santa Clara 2022), 2025 Cal Fire Santa Clara Unit Fire Plan (Hernandez 2025), Castle Rock General Plan (California State Parks 2000), Upper Stevens Creek County Park Master Plan (Santa Clara County Parks 1993), Sanborn County Park Master Plan (Santa Clara County Parks 2019), Santa Clara Valley Habitat Plan (ICF International 2012), City of Palo Alto Comprehensive Plan (City of Palo Alto 2023), Cupertino General Plan (City of Cupertino 2016), City of Saratoga General Plan (City of Saratoga 2024), 2035 General Plan of Morgan Hill (City of Morgan Hill 2016), and City of Gilroy General Plan (City of Gilroy 2020).
Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-76 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR The potential for vegetation treatment activities to cause a significant environmental impact due to a conflict with a land use plan, policy, or regulation was examined in the Program EIR. This impact is within the scope of the Program EIR because the treatment types and activities are consistent with those analyzed in the Program EIR. The inclusion of land in the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent considered in the Program EIR. However, land uses in the project area are essentially the same within and outside the treatable landscape; therefore, the land use impact is also the same. Treatment types would be consistent with those described in the Program EIR. SPRs applicable to this impact are AD-3 and AD-9. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than covered in the Program EIR.
IMPACT LU-2
The potential increases in demand for employees to implement initial and maintenance treatments and resultant potential for substantial population growth was examined in the Program EIR. Manual treatments would involve three to 20 workers per treatment, and mechanical treatments would involve one hand crew of approximately five to 20 workers and equipment operators. Prescribed broadcast burns typically last approximately 1 day to up to 2 weeks where the average number of workers on a prescribed burn is approximately 50. Typically, herbicide application would be carried out by two to four workers. Prescribed herbivory typically requires one to two workers on-site to monitor and manage grazing animals. Although treatments would result in temporary increase in the demand of workers, the increase in employee demand would not represent a substantial increase in demand for new residents in the region. Impacts associated with short-term increases in the demand for workers during implementation of the project are within the scope of the Program EIR because the number of workers required for implementation of the treatments is consistent with the crew sizes analyzed in the Program EIR for the treatment activities proposed.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the population and housing impact is also the same, as described above. No SPRs are applicable to this impact. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than covered in the Program EIR.
NEW LAND USE AND PLANNING, POPULATION AND HOUSING IMPACTS The proposed treatments are within the CalVTP treatable landscape and are consistent with the treatment types and activities covered in the CalVTP Program EIR. The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.12.1, “Environmental Setting,” and Section 3.12.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are also consistent with those covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape would not give rise to new significant impacts not addressed in the Program EIR. Therefore, no new impact related to land use and planning or population and housing would occur that is not covered in the Program EIR.
Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-77
4.12 NOISE
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:
Impact NOI-1: Result in a
Substantial Short-Term
Increase in Exterior Ambient
Noise Levels During Treatment
Implementation
LTS Impact NOI-1,
pp. 3.13-9 –
3.13-12;
Appendix
NOI-1
Yes AD-3
NOI-1
NOI-2
NOI-3
NOI-4
NOI-5
NOI-6
NA LTS No Yes
Impact NOI-2: Result in a
Substantial Short-Term
Increase in Truck-Generated
Single-Event Noise Levels
During Treatment Activities
LTS Impact NOI-2,
p. 3.13-12
Yes NOI-1 NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact New Noise Impacts: Would the treatment result in other noise-related impacts that are not evaluated in the CalVTP Program EIR? Yes No If yes, complete row(s) below and discussion Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT NOI-1
Proposed treatments would require the use of heavy, noise-generating equipment. The potential for a substantial short-term increase in ambient noise levels from use of heavy equipment was examined in the Program EIR.
Treatment activities would occur during any time of the year. Prescribed burning may occur any day of the week or time of day within identified burn prescription windows. Manual treatments, mechanical treatments, and targeted herbicide application would occur on any day of the week but would generally be limited to daylight hours.
Prescribed herbivory in one fenced area would occur across the span of days or up to a week at the longest.
Santa Clara County’s Noise and Vibration Ordinance contains provisions that limit noise sources associated with construction (which applies to vegetation treatment) to certain hours. Specifically, Section B.11-154 regulates noise generated by the operation of any tools or equipment on weekdays and Saturday from 7:00 p.m. to 7:00 a.m. and all hours on Sundays and holidays (County of Santa Clara 2025a). Although noise ordinances do not apply to portions of the project in unincorporated areas of Santa Clara County, treatments would still be conducted in a manner consistent with the county noise ordinance.
As discussed in the Program EIR, the most noise-intensive treatment activities are manual, mechanical, and prescribed burning treatments; prescribed herbivory and herbicide application treatments generally result in a negligible amount of noise disturbance. For manual, mechanical, and prescribed burning treatments, noise levels generated by