Gilroy City Council
August 3, 2026

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-78 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR individual equipment range from 75 to 87.9 decibels (dB) at 50 feet from the noise source (75 to 85 dB at 50 feet from the noise source for projects without the use of helicopters). The most frequently used noise-generating types of equipment proposed for this project would be chainsaws, dozers, excavators, and shears on a backhoe. Although multiple pieces of equipment would be operated simultaneously to implement a treatment, they would typically be spread out (i.e., usually more than 100 feet apart) rather than operating next to each other. This is particularly true of larger, heavy-duty off-road equipment, such as masticators and chippers. Noise-generating equipment would be used intermittently between 7:00 a.m. and 6:00 p.m. during treatments. Although there is the potential for some prescribed burning to occur during nighttime and weekend hours, all treatment activities using noise-generating equipment would be limited to 7:00 a.m. to 6:00 p.m., which would avoid the potential to cause sleep disturbance to residents during the more noise-sensitive evening and nighttime hours. This impact is within the scope of the Program EIR because the number of pieces of equipment that would be operated simultaneously, the types of equipment proposed, and the temporary and sporadic nature of the equipment use are consistent with the assumptions 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 exposure potential to any sensitive receptors present in the areas outside the treatable landscape is essentially the same as that within the treatable landscape; therefore, the noise impact is also the same, as described above. SPRs applicable to this impact are AD-3 and NOI-1 through NOI-6. 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 NOI-2
Initial and maintenance treatments would involve large trucks hauling heavy equipment to the project area. These haul truck trips would be dispersed on area roadways providing access to the project area consisting of, but not limited to, SR 9 (Big Basin Way), SR 35 (Skyline Boulevard), SR 17, SR 280, SR 152, Summit Road, Bear Creek Road, Stevens Creek Canyon Road, Redwood Gulch Road, Los Trancos Road, and Page Mill Road. Haul truck trips on the local roadways would pass residential receptors, and the event of each truck passing by could increase the singleevent noise level (SENL). The potential for a substantial short-term increase in SENL was examined in the Program EIR. This impact is within the scope of the Program EIR because the number and types of equipment proposed are consistent with those analyzed in the Program EIR. The haul trips associated with the treatment would occur during daytime hours (per SPR NOI-1), which would avoid the potential to cause sleep disturbance to residents during the more noise-sensitive evening and nighttime hours.

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 exposure potential is essentially the same within and outside the treatable landscape; therefore, the noise impact is also the same, as described above. SPR NOI-1 is 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 NOISE 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 preparation 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 3.13.1, “Environmental Setting,” and Section 3.13.2, “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 noise 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

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-79 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 any new significant impacts.

Therefore, no new impact related to noise would occur.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-80 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

4.13 RECREATION
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 REC-1: Directly or
Indirectly Disrupt Recreational
Activities within Designated
Recreation Areas
LTS Impact REC-1,
pp. 3.14-6 –

3.14-7
Yes REC-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 Recreation Impacts: Would the treatment result in other impacts to recreation 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 provides a diverse array of recreational opportunities, such as hiking, biking, picnicking, camping, and wildlife viewing, at several recreational areas. These areas include Mount Madonna County Park, Uvas Reservoir County Park, Chesbro Reservoir County Park, Calero County Park, Sierra Azul Open Space Preserve, Almaden Quicksilver County Park, Santa Teresa County Park, Bear Creek Redwoods Open Space Preserve, Lexington Reservoir County Park, El Sereno Open Space Preserve, Sanborn County Park, Saratoga Gap Open Space Preserve, Picchetti Ranch Open Space Preserve, Fremont Older Open Space Preserve, Stevens Creek County Park, Rancho San Antonio County Park, Foothills Nature Preserve, and Mont Bello Open Space Preserve. Impact REC-1 evaluates the project’s potential to disrupt recreational activities within these designated recreational areas, including implementation of SPR REC-1, which requires notification of temporary closures of recreational areas.

IMPACT REC-1
Initial and maintenance vegetation treatments would occur along the western boundary of Santa Clara County, from the WUI of the Santa Clara Valley and southern Bay Area west into the Santa Cruz Mountains, and this area contains a variety of recreational areas. Vegetation treatment activities have the potential to disrupt recreational activities by degrading the experience of recreationists in nearby areas through the creation of noise, dust, degradation of scenic views, temporary closure of recreational areas during treatment, or increased traffic when treatments are implemented near recreation areas. The potential for vegetation treatment activities to disrupt recreation activities was examined in the Program EIR. Impacts related to aesthetics, air quality, noise, and transportation would be avoided or minimized to the extent feasible and are within the scope of the Program EIR, as explained in the discussion for those respective resource areas in this PSA/Addendum.

The potential for the proposed project to adversely affect recreation is within the scope of the Program EIR because the treatment activities, and their duration and intensity are consistent with those analyzed in the Program EIR.

Recreational users would be notified of temporary closures of any public recreation areas in advance of treatment activities per SPR REC-1. Where feasible, notice of recreational area closure would be posted 2 weeks prior to

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-81 commencement of treatment activities consistent with SPR REC-1, which would reduce the risk of disruption of recreational activities within the treatment area. Any closures of recreation areas would be temporary and short-term, lasting only the duration of active treatment and required post-treatment cleanup.

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 availability of recreational resources within the project is essentially the same within and outside the CalVTP treatable landscape and the treatment activities and intensity are consistent with those analyzed in the Program EIR. The SPR applicable to this impact is REC-1. 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 RECREATION 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 preparation 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 3.14.1, “Environmental Setting,” and Section 3.14.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the 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 recreation 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 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 any new significant impacts. Therefore, no new impact related to recreation would occur.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-82 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

4.14 TRANSPORTATION
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 TRAN-1: Result in
Temporary Traffic Operations
Impacts by Conflicting with a
Program, Plan, Ordinance, or
Policy Addressing Roadway
Facilities or Prolonged Road
Closures
LTS Impact TRAN1, pp. 3.15-9 –

3.15-10
Yes AD-3
TRAN-1
NA LTS No Yes
Impact TRAN-2: Substantially
Increase Hazards due to a
Design Feature or
Incompatible Uses
LTS Impact TRAN2, pp. 3.15-10
– 3.15-11
Yes AD-3
HYD-2
TRAN-1
NA LTS No Yes
Impact TRAN-3: Result in a Net
Increase in VMT for the
Proposed CalVTP
PSU Impact TRAN3, pp. 3.15-11 –

3.15-13
Yes NA AQ-1 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 Transportation Impacts: Would the treatment result in other impacts to transportation 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 TRAN-1
Initial and maintenance treatments would temporarily increase vehicular traffic along roadways throughout the project area, including SR 9 (Big Basin Way), SR 35 (Skyline Boulevard), SR 17, SR 280, SR 152, Summit Road, Bear Creek Road, Stevens Creek Canyon Road, Redwood Gulch Road, Los Trancos Road, and Page Mill Road. The potential for a temporary increase in traffic to result in traffic operations impacts by conflicting with a program, plan, ordinance, or policy addressing roadway facilities or prolonged road closures was examined in the Program EIR. The proposed treatments would be short term, and temporary increases in traffic are within the scope of the Program EIR because the treatment duration and limited number of vehicles (i.e., heavy equipment transport, crew vehicles for crew members) associated with the proposed treatments are consistent with those analyzed in the Program EIR. In addition, the proposed treatments would not all occur concurrently, and increases in vehicle trips associated with the treatments would be dispersed on multiple roadways across a large project area.

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

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-83 existing transportation conditions (e.g., roadways and road use) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the transportation impact is also the same, as described above. The SPRs applicable to this impact are AD-3 and TRAN-1. 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 TRAN-2
Initial and maintenance treatments would not require the construction or alteration of any roadways. However, the proposed treatments would include prescribed burning, which would produce smoke that could potentially affect visibility along nearby roadways. Hauling heavy machinery and operating large trucks along roadways could also result in a transportation hazard. The potential for smoke to affect visibility along roadways and large trucks to result in hazards during implementation were examined in the Program EIR. As described in Attachment A, SPR TRAN-1 requires that prescribed burning operations are monitored and that traffic control operations be initiated if burning operations begin to affect traffic safety along any roadways. SPR TRAN-1 also requires that if the treatment manager deems it necessary, a traffic management plan (TMP) would be prepared prior to initiating treatment activities when traffic generated by a treatment would result in substantial obstructions, hazards, or delays. This impact is within the scope of the activities and impacts addressed in the Program EIR because the burn duration and intensity and types of equipment used for treatments are consistent with that 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 transportation conditions (e.g., roadways and road use) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the transportation impact is also the same, as described above. SPRs applicable to this impact are AD-3, HYD-2, and TRAN-1. 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 TRAN-3
Treatments could temporarily increase vehicle miles traveled (VMT) above baseline conditions because the proposed project would require vehicle trips to transport crew members and equipment to the treatment areas. This impact was identified as potentially significant and unavoidable in the Program EIR because implementation of the CalVTP would result in a net increase in VMT. As noted under Impact TRAN-3 in the Program EIR, individual vegetation treatments under the CalVTP are likely to generate fewer than 110 trips per day, which would be considered a lessthan-significant transportation impact for specific later activities, as described in the Technical Advisory on Evaluating Transportation Impacts, published by the Governor’s Office of Planning and Research, now known as the Governor’s Office of Land Use and Climate Innovation (OPR 2018). Manual treatments would require one or two crews of approximately three to 20 members to implement treatments. To implement mechanical treatments, one hand crew of approximately five to 20 workers may aid equipment operators in achieving treatment specifications, and the average number of workers on a prescribed broadcast burn would be approximately 50 over a limited period of time.

The operation of an air curtain burner would require a crew of two to three people per burner, and operating multiple burners next to each other would not necessarily require additional people. Herbicide application would be carried out by two to four workers, and prescribed herbivory would require a herder and one to two support workers.

Treatments are expected to be spread across different locations within the project area and would be conducted at different periods of time over the course of the project. Thus, treatments under the proposed project would typically require between one and 50 crew members with several crews implementing treatments simultaneously, dispersed throughout the project area. Therefore, the anticipated crew sizes are sufficiently small so that the total increase in VMT would not likely exceed 110 trips per day. In addition, as mentioned above, the increase in vehicle trips would be dispersed to multiple roadways throughout a large project area. However, individual treatments would contribute to the overall annual net increase in VMT generated by the CalVTP. Although carpooling would be encouraged under

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-84 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR MM AQ-1, crew sizes would be small and may not all be employed with the same company. Therefore, carpooling may not be feasible to implement for most of the workers. Although the net increase in VMT is not expected to generate greater than 110 trips per day, because the project would contribute to the overall annual net increase in VMT generated by the CalVTP, it would contribute to the environmental significance conclusion in the Program EIR; therefore, for purposes of CEQA compliance, this PSA/Addendum notes the impact as significant and unavoidable.

This impact is within the scope of the activities and impacts addressed in the Program EIR because the size and number of crews is consistent with that analyzed in the Program EIR. The increase in vehicle trips would be temporary and dispersed over multiple roadways. 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 transportation-related conditions in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the transportation impact is also the same, as described above. No SPRs are applicable to this impact. 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.

NEW IMPACTS ON TRANSPORTATION
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 preparation 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 3.15.1, “Environmental Setting,” and Section 3.15.2, “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. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to transportation 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. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape would not give rise to any new significant impacts not addressed in the Program EIR. Therefore, no new impact related to transportation 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 4-85

4.15 PUBLIC SERVICES, UTILITIES, AND SERVICE SYSTEMS
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 UTIL-1: Result in
Physical Impacts
Associated with Provision
of Sufficient Water
Supplies, Including Related
Infrastructure Needs
LTS Impact UTIL-1,
p. 3.16-9
Yes AD-3 NA LTS No Yes
Impact UTIL-2: Generate
Solid Waste in Excess of
State Standards or Exceed
Local Infrastructure
Capacity
PSU Impact UTIL-2,
pp. 3.16-10 –

3.16-12
Yes AD-3
UTIL-1
NA SU No Yes
Impact UTIL-3: Comply
with Federal, State, and
Local Management and
Reduction Goals, Statutes,
and Regulations Related to
Solid Waste
LTS Impact UTIL-2,
p. 3.16-12
Yes AD-3
UTIL-1
NA LTS 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 Public Services, Utilities and Service System Impacts: Would the treatment result in other impacts to public services, utilities, and service systems 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 UTIL-1
Initial and maintenance treatments would consist of manual treatments, mechanical treatments, prescribed burning, prescribed herbivory, and targeted herbicide application. Water would be required during implementation of the proposed project as a safety measure for fire suppression during a prescribed burn, for livestock used for prescribed herbivory, and to minimize dust if excessive while traveling on unpaved roads or to remove visible dirt or mud that gets tracked out onto public paved roadways (per SPR AQ-4). If needed, water would be supplied from water trucks or tanks or existing on-site troughs for livestock. The potential increased demand for water was examined in the Program EIR. This impact is within the scope of activities and impacts addressed in the Program EIR because the size of areas proposed for prescribed burn treatments, amount of water required for prescribed burning, dust control, and domestic livestock, as well as water source type are consistent with those analyzed in the Program EIR.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-86 West Santa Clara Landscape Resiliency Project PSA and Addendum to 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 water supply impact is also the same, as described above. SPR AD3 is 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 UTIL-2
Initial and maintenance treatments would generate biomass from vegetation removal within the treatment areas.

Biomass generated by mechanical and manual treatments would be disposed of by several means: chipping, mastication, and lop and scatter on-site. Pile burning, broadcast burning, and specialized biomass processing technologies (e.g., air curtain burning and carbonization) may be used in some areas. Invasive plant and noxious weed biomass would be treated on-site or disposed of off-site at an appropriate waste collection facility to prevent reestablishment or spread of invasive plants and noxious weeds.

The potential for solid waste generation to exceed state standards or local infrastructure capacity was examined in the Program EIR. This impact is within the scope of the activities and impacts addressed in the Program EIR because the types and amount of biomass that may need to be hauled off-site are consistent with those analyzed in the Program EIR. This impact was identified as potentially significant and unavoidable in the Program EIR because biomass hauled off-site in some parts of the treatable landscape could exceed the capacity of existing infrastructure for handling biomass. For the proposed project, approximately 2.5 percent of plant biomass would be hauled off-site to an appropriate waste collection facility. Per SPR UTIL-1, a waste disposition plan would outline the hauling locations prior to biomass being hauled off-site. The two closest large-scale biomass processing facilities are within 155 miles of the project area. DTE Stockton LLC in Stockton, San Joaquin County, California, is approximately 120 miles from the farthest southern section of the project area, and Woodland Biomass Power LLC in Woodland, Yolo County, California, is approximately 152 miles from the farthest southern section of the project area.

The volume of biomass generated from treatments is not expected to exceed the capacity of existing disposal facilities in West Santa Clara County because biomass would be disposed of primarily by other methods (e.g., mastication, chipping, lop and scattering, prescribed burning, and incineration with a curtain burner or carbonator); only an estimated 2.5 percent of the created biomass would only be disposed of by shipping to a waste generation facility.

However, because the project would generate biomass needing off-site disposal, it would contribute to the environmental significance conclusion in the Program EIR. Therefore, for the purposes of CEQA compliance, this PSA/Addendum identifies the impact as significant and unavoidable.

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, conditions related to biomass in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, impacts related to biomass are also the same, as described above. SPR AD-3 is applicable to this impact. SPR UTIL-1 would be applicable for treatments where biomass is hauled off-site. 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 UTIL-3
As discussed above, initial and maintenance treatments would generate biomass from vegetation removal within the treatment areas. If off-site disposal is required, treatment activities would comply with all federal and state management and reduction goals, statutes, and regulations related to solid waste. Compliance with reduction goals, statutes, and regulations related to solid waste was examined in the Program EIR. This impact is within the scope of the activities and impacts addressed in the Program EIR because the types and amount of biomass that would be hauled off-site are consistent with those analyzed 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 4-87 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 biomass conditions in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, impacts related to biomass are also the same, as described above. SPR AD-3 is applicable to this impact. SPR UTIL-1 would be applicable to treatments where biomass is hauled off-site. 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 ON PUBLIC SERVICES, UTILITIES, AND SERVICE SYSTEMS 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 the 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 3.16.1, “Environmental Setting,” and Section 3.16.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including 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 pertinent to public services, utilities, and service systems 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 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 any new significant impacts not addressed in the Program EIR. Therefore, no new impact related to public services, utilities, or service systems would occur that is not covered in the Program EIR.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-88 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

4.16 WILDFIRE
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 WIL-1: Substantially
Exacerbate Fire Risk and
Expose People to Uncontrolled
Spread of a Wildfire
LTS Impact WIL-1,
pp. 3.17-14 –

3.17-15
Yes AD-3
HAZ-2, HAZ-3
HAZ-4
NA LTS No Yes
Impact WIL-2: Expose People
or Structures to Substantial
Risks Related to Postfire
Flooding or Landslides
LTS Impact WIL-2,
pp. 3.17-15 –

3.17-16
Yes AD-3
AQ-3
GEO-3, GEO-4
GEO-5, 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 Wildfire Impacts: Would the treatment result in other impacts related to wildfire 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 WIL-1
Proposed vegetation treatment activities include manual treatment, mechanical treatment, prescribed burning, prescribed herbivory, and targeted ground application of herbicides. Machine-powered hand tools would have federal- or state-approved spark arrestors, which prevent the emissions of flammable debris. Vegetation treatment involving mechanical equipment poses a risk of accidental ignition. Vegetation treatment crews would carry one fire extinguisher per chainsaw and one long-handle shovel and one axe or Pulaski to quickly respond to an ignition should one occur. Temporary increases in risk associated with uncontrolled fire from prescribed burns could also occur. As discussed in Section 3.17.1, “Environmental Setting,” in Volume II of the Final Program EIR, under “Prescribed Burn Planning and Implementation,” implementing a prescribed burn requires extensive planning, including the preparation of prescription burn plans, smoke management plans, site-specific weather forecasting, public notifications, safety considerations, and assessment of favorable weather conditions before a burn can occur on a given day. Prior to implementing a broadcast burn, fire containment lines would be established by clearing vegetation surrounding the designated burn area to help prevent the accidental escape of fire. Water containers and safety equipment would be staged on-site as necessary.

The potential increase in exposure to wildfire during implementation of treatments was examined in the Program EIR.

Increased wildfire risk associated with the use of heavy equipment in vegetated areas and with prescribed burns is within the scope of the Program EIR because the types of equipment, treatment duration, and the types of prescribed burning methods proposed as part of the project are consistent with those analyzed 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 4-89 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 wildfire risk is essentially the same within and outside the treatable landscape; therefore, the wildfire impact is also the same, as described above. SPRs applicable to this impact are AD-3, HAZ-2, HAZ-3, and HAZ-4.

SPR BIO-9 would also be implemented as part of proposed treatment design. This SPR avoids the spread or introduction of annual grasses rated as invasive by Cal-IPC or designated as noxious weeds by the California Department of Food and Agriculture. Invasive annual grasses can provide flashy fuels for wildfire ignition; however, these would be managed pursuant to SPR BIO-9 such that their establishment in treated areas will be avoided.

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 WIL-2
Vegetation treatment activities include manual treatment, mechanical treatment, prescribed burning, prescribed herbivory, and targeted ground application of herbicides, which could exacerbate fire risk as described for Impact WIL-1 above. The potential for post-fire landslides and flooding was evaluated in the Program EIR. The potential exposure of people or structures to post-fire landslides and flooding are within the scope of the activities and impacts covered in the Program EIR because the equipment types, duration, and methods of prescribed burning implementation 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 wildfire risk of the project area is essentially the same within and outside the treatable landscape; therefore, the wildfire impact is also the same, as described above. SPRs applicable to this impact are AD-3, AQ-3, GEO-3 through GEO-5, and GEO-8. Although most mechanical treatment would occur from existing roads or on flat to moderate slopes (i.e., 35–50 percent), SPR GEO-8 would apply if a treatment area contains steep slopes. Furthermore, because the treatments reduce wildfire risk, they would also decrease post-wildfire landslide and flooding risk in treated areas. 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.

NEW IMPACTS ON WILDFIRE
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 was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.17.1, “Environmental Setting,” and Section 3.17.2, “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 wildfire 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 covered in the Program EIR. No changed circumstances would give rise to new significant impacts not addressed in the Program EIR.

Therefore, no new impact related to wildfire would occur that is not covered in the Program EIR.

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 5-1 5 LIST OF PREPARERS
Saratoga Fire Protection District (Lead Agency)
Trina Whitley .........................................................................................................................................................................Business Manager Santa Clara County FireSafe Council
Stephen Harrington .......................................................................................................................Senior Forest Health Project Manager Amanda Brenner-Cannon .......................................................................................Program Director, County Wildfire Coordinator Seth Schalet .................................................................................................................................................................. Chief Executive Officer Auten Resource Consulting (Project Description)
Steve Auten............................................................................................................................................................................Owner, RPF #2734 Heath Hooper..................................................................................................................................................................... Assistant Forester II Shelby Kranich ............................................................................................................................Director of Forest Resilience, RPF #3249 Ascent (CEQA Compliance)
Heather Blair..............................................................................................................................................................................................Principal Grace Mannell...........................................................................................................................................................................Project Manager Lara Rachowicz and Tammie Beyerl...............................................................................................................Senior Biological Reviewer Stephanie Rasmussen...........................................................................................................................................Senior Technical Reviewer Madison Gilmartin .........Agriculture; Geology; Hazardous Materials; Hydrology; Land Use and Planning; Noise; Wildfire Reida Khan ......Aesthetics; Air Quality; Greenhouse gas; Energy; Recreation; Transportation; Public Services and Utilities Roberto Mora.....................................................................................................Archeological, Historic, and Tribal Cultural Resources Alta Cunningham................................................................................................................................ Senior Cultural Resources Reviewer Ted Thayer and Taelor Whittington ......................................................................................................................... Biological Resources Alyssa Luna .......................................................................................................................................................................................GIS Specialist Gretel Hakanson........................................................................................................................................................................ Technical Editor Gayiety Lane, Michele Mattei, Tracy Prybyla, and Riley Smith........................................................................Publishing Specialists

List of Preparers Ascent
Saratoga Fire Protection District
5-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR This page is intentionally left blank.

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 6-1 6 REFERENCES
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6-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Milpitas, Calaveras Reservoir, La Honda, Mindego Hill, Cupertino, San Jose West, San Jose East, Lick Observatory, Big Basin, Los Gatos, Castle Rock Ridge, Morgan Hill, Mt. Sizer, Felton, Laurel, Loma Prieta, Mt.

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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 6-3 ———. 2012. Santa Clara Country Geologic Hazards Zones. Available:
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6-4 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Office of Planning and Research. 2018 (April). Technical Advisory on Evaluating Transportation Impacts in CEQA.

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Attachment A
Mitigation Monitoring and
Reporting Program for the
West Santa Clara Landscape
Resiliency Project

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-i

TABLE OF CONTENTS
STANDARD PROJECT REQUIREMENTS ............................................................................................................................................. A-4 ADMINISTRATIVE STANDARD PROJECT REQUIREMENTS ........................................................................................................... A-4 SPR AD-1: Project Proponent Coordination.............................................................................................................................A-4 SPR AD-2: Delineate Protected Resources:..............................................................................................................................A-4 SPR AD-3: Consistency with Local Plans, Policies, and Ordinances: ...............................................................................A-4 SPR AD-4: Public Notifications for Prescribed Burning: ......................................................................................................A-4 SPR AD-5: Maintain Site Cleanliness: .........................................................................................................................................A-4 SPR AD-6: Public Notifications for Treatment Projects........................................................................................................ A-5 SPR AD-7: Provide Information on Proposed, Approved, and Completed Treatment Projects............................ A-5 AESTHETIC AND VISUAL RESOURCE STANDARD PROJECT REQUIREMENTS ...................................................................................... A-6 SPR AES-1: Vegetation Thinning and Edge Feathering........................................................................................................ A-6 SPR AES-2: Avoid Staging within Viewsheds........................................................................................................................... A-6 SPR AES-3: Provide Vegetation Screening............................................................................................................................... A-6 AIR QUALITY STANDARD PROJECT REQUIREMENTS ............................................................................................................................. A-6 SPR AQ-1: Comply with Air Quality Regulations .................................................................................................................... A-6 SPR AQ-2: Submit Smoke Management Plan......................................................................................................................... A-6 SPR AQ-3: Create Burn Plan.......................................................................................................................................................... A-7 Project-Specific Implementation of SPR AQ-3 ....................................................................................................................... A-7 SPR AQ-4: Minimize Dust .............................................................................................................................................................. A-7 SPR AQ-5: Avoid Naturally Occurring Asbestos .................................................................................................................... A-8 SPR AQ-6: Prescribed Burn Safety Procedures....................................................................................................................... A-8 ARCHAEOLOGICAL, HISTORICAL, AND TRIBAL CULTURAL RESOURCES STANDARD PROJECT REQUIREMENTS............................ A-8 SPR CUL-1: Conduct Record Search ........................................................................................................................................... A-8 SPR CUL-2: Contact Geographically Affiliated Native American Tribes......................................................................... A-8 SPR-CUL-3: Pre-field Research..................................................................................................................................................... A-9 SPR CUL-4: Archaeological Surveys ........................................................................................................................................... A-9 SPR CUL-5: Treatment of Archaeological Resources.......................................................................................................... A-10 SPR CUL-6: Treatment of Tribal Cultural Resources ........................................................................................................... A-10 SPR CUL-7: Avoid Built Historical Resources ......................................................................................................................... A-10 SPR CUL-8: Cultural Resource Training................................................................................................................................... A-10 Chaparral and Coastal Sage Scrub Standard Project Requirement ............................................................................... A-11 SPR CHAP/CSS-1: Chaparral and Coastal Sage Scrub......................................................................................................... A-11 BIOLOGICAL RESOURCES STANDARD PROJECT REQUIREMENTS ....................................................................................................... A-12 SPR BIO-1: Review and Survey Project-Specific Biological Resources .......................................................................... A-12 SPR BIO-2: Require Biological Resource Training for Workers ....................................................................................... A-17 SENSITIVE NATURAL COMMUNITIES AND OTHER SENSITIVE HABITATS ........................................................................................... A-18 SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats ................................................... A-18 SPR BIO-4: Design Treatment to Avoid Loss or Degradation of Riparian Habitat Function ................................ A-18 SPR BIO-5: Avoid Environmental Effects of Type Conversion and Maintain Habitat Function in Chaparral and Coastal Sage Scrub.......................................................................................................................... A-20 SPR BIO-6: Prevent Spread of Plant Pathogens .................................................................................................................. A-22 SPR BIO-7: Survey for Special-Status Plants ......................................................................................................................... A-23

Attachment A Ascent
Saratoga Fire Protection District
A-ii West Santa Clara Landscape Resiliency Project PSA and Addendum INVASIVE PLANTS AND WILDLIFE .......................................................................................................................................................... A-24 SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife.......................................... A-24 WILDLIFE ................................................................................................................................................................................................. A-25 SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites ................................................................................ A-25 SPR BIO-11: Install Wildlife-Friendly Fencing (Prescribed Herbivory)........................................................................... A-30 SPR BIO-12: Protect Common Nesting Birds, Including Raptors................................................................................... A-30 GEOLOGY, SOILS, PALEONTOLOGY, AND MINERAL RESOURCE STANDARD PROJECT REQUIREMENTS ...................................... A-32 SPR GEO-1: Suspend Disturbance during Heavy Precipitation ...................................................................................... A-32 SPR GEO-2: Limit High Ground Pressure Vehicles ............................................................................................................. A-33 SPR GEO-3: Stabilize Disturbed Soil Areas............................................................................................................................ A-33 SPR GEO-4: Erosion Monitoring ............................................................................................................................................... A-33 SPR GEO-5: Drain Stormwater via Water Breaks ................................................................................................................ A-34 SPR GEO-6: Minimize Burn Pile Size ....................................................................................................................................... A-34 SPR GEO-7: Minimize Erosion.................................................................................................................................................... A-34 SPR GEO-8: Steep Slopes............................................................................................................................................................ A-34 HAZARDOUS MATERIAL AND PUBLIC HEALTH AND SAFETY STANDARD PROJECT REQUIREMENTS ........................................... A-35 SPR HAZ-1: Maintain All Equipment........................................................................................................................................ A-35 SPR HAZ-2: Require Spark Arrestors....................................................................................................................................... A-35 SPR HAZ-3: Require Fire Extinguishers................................................................................................................................... A-35 SPR HAZ-4 Prohibit Smoking in Vegetated Areas ............................................................................................................. A-35 SPR HAZ-5: Spill Prevention and Response Plan................................................................................................................ A-35 SPR HAZ-6: Comply with Herbicide Application Regulations ........................................................................................ A-36 SPR HAZ-7: Triple Rinse Herbicide Containers .................................................................................................................... A-36 SPR HAZ-8: Minimize Herbicide Drift to Public Areas ...................................................................................................... A-36 SPR HAZ-9: Notification of Herbicide Use in the Vicinity of Public Areas.................................................................. A-37 HYDROLOGY AND WATER QUALITY STANDARD PROJECT REQUIREMENTS .................................................................................... A-37 SPR HYD-1: Comply with Water Quality Regulations ........................................................................................................ A-37 SPR HYD-2: Avoid Construction of New Roads .................................................................................................................. A-37 SPR HYD-3: Water Quality Protections for Prescribed Herbivory................................................................................. A-38 SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones.............................................................. A-38 SPR HYD-5: Protect Non-Target Vegetation and Special-status Species from Herbicides ................................. A-40 SPR HYD-6: Protect Existing Drainage Systems ................................................................................................................... A-41 NOISE STANDARD PROJECT REQUIREMENTS ....................................................................................................................................... A-41 SPR NOI-1: Limit Heavy Equipment Use to Daytime Hours ............................................................................................. A-41 SPR NOI-2: Equipment Maintenance....................................................................................................................................... A-41 SPR NOI-3: Engine Shroud Closure.......................................................................................................................................... A-41 SPR NOI-4: Locate Staging Areas Away from Noise-Sensitive Land Uses................................................................. A-42 SPR NOI-5: Restrict Equipment Idle Time.............................................................................................................................. A-42 SPR NOI-6: Notify Nearby Off-Site Noise-Sensitive Receptors ..................................................................................... A-42 RECREATION STANDARD PROJECT REQUIREMENTS ........................................................................................................................... A-42 SPR REC-1: Notify Recreational Users of Temporary Closures ....................................................................................... A-42 TRANSPORTATION STANDARD PROJECT REQUIREMENTS ................................................................................................................ A-42 SPR TRAN-1: Implement Traffic Control during Treatments........................................................................................... A-42

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-iii PUBLIC SERVICES AND UTILITIES STANDARD PROJECT REQUIREMENTS .......................................................................................... A-43 SPR UTIL-1: Solid Organic Waste Disposition Plan............................................................................................................. A-43 AESTHETICS ............................................................................................................................................................................................ A-44 Mitigation Measure AES-3: Conduct Visual Reconnaissance for Non-Shaded Fuel Breaks and Relocate or Feather and Screen Publicly Visible Non-Shaded Fuel Breaks .............................................. A-44 AIR QUALITY .......................................................................................................................................................................................... A-44 Mitigation Measure AQ-1: Implement On-Road Vehicle and Off-Road Equipment Exhaust Emission Reduction Techniques ................................................................................................................................................. A-44 ARCHAEOLOGICAL, HISTORICAL, AND TRIBAL CULTURAL RESOURCES .............................................................................. A-45 Mitigation Measure CUL-2: Protect Inadvertent Discoveries of Unique Archaeological Resources or Subsurface Historical Resources............................................................................................................................... A-45 BIOLOGICAL RESOURCES ................................................................................................................................................................... A-45 Mitigation Measure BIO-1a: Avoid Loss of Special-Status Plants Listed under ESA or CESA.............................. A-45 Mitigation Measure BIO-1b: Avoid Loss of Special-Status Plants Not Listed Under ESA or CESA.................... A-46 Mitigation Measure BIO-1c: Compensate for Unavoidable Loss of Special-Status Plants ................................... A-48 Mitigation Measure BIO-2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed Wildlife Species and California Fully Protected Species (All Treatment Activities) .................... A-49 Mitigation Measure BIO-2b: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Other Special-Status Wildlife Species (All Treatment Activities)................................................................... A-56 Mitigation Measure BIO-2c: Compensate for Mortality, Injury, or Disturbance and Loss of Habitat Function for Special-Status Wildlife if Applicable (All Treatment Activities)............................................. A-60 Mitigation Measure BIO-2e: Design Treatment to Retain Special-Status Butterfly Host Plants (All Treatment Activities)..................................................................................................................................................... A-62 Mitigation Measure BIO-2g: Design Treatment to Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Special-Status Bumble Bees (All Treatment Activities) ......................... A-65 Mitigation Measure BIO-3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands ............................................................................................................................................................. A-67 Mitigation Measure BIO-3b: Compensate for Loss of Sensitive Natural Communities and Oak Woodlands....................................................................................................................................................................... A-69 Mitigation Measure BIO-4: Avoid State and Federally Protected Wetlands ............................................................. A-70 Mitigation Measure BIO-5: Retain Nursery Habitat and Implement Buffers to Avoid Nursery Sites................. A-71 GREENHOUSE GAS EMISSIONS ........................................................................................................................................................ A-72 Mitigation Measure GHG-2: Implement GHG Emission Reduction Techniques During Prescribed Burns .................................................................................................................................................................................. A-72 HAZARDOUS MATERIALS, PUBLIC HEALTH AND SAFETY ......................................................................................................... A-72 Mitigation Measure HAZ-3: Identify and Avoid Known Hazardous Waste Sites..................................................... A-72

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-1

MITIGATION MONITORING AND REPORTING PROGRAM

INTRODUCTION
The California Environmental Quality Act (CEQA) and the State CEQA Guidelines (PRC Section 21081.6 and State CEQA Guidelines Sections 15091[d] and 15097) require public agencies “to adopt a reporting and monitoring program for changes to the project which it has adopted or made a condition of project approval to mitigate or avoid significant effects on the environment.” A Mitigation Monitoring and Reporting Program (MMRP) is required for approval of the proposed project because the Project-Specific Analysis/Addendum to the California Vegetation Treatment Program (CalVTP) Program Environmental Impact Report (Program EIR) (PSA/Addendum) identifies potential significant adverse impacts and all feasible mitigation measures have been adopted. Standard project requirements (SPRs), which are part of the project description, have been incorporated to avoid or minimize adverse effects. Where potentially significant impacts remain after application of SPRs, mitigation measures have been identified to further reduce and/or compensate for those impacts. While only mitigation measures are required to be covered in an MMRP, both SPRs and mitigation are included in this MMRP to assist in implementation of all environmental protection features of later activities consistent with the CalVTP Program EIR.

PURPOSE OF MITIGATION MONITORING AND REPORTING PROGRAM
This MMRP has been prepared to facilitate the implementation of SPRs and mitigation measures. The attached table presents the text of each SPR and mitigation measure from the CalVTP Program EIR that is applicable to the project, the timing of its planned implementation, the implementing entity, and the entity with monitoring responsibility. The numbering of SPRs and mitigation measures follows the numbering used in the Program EIR. SPRs and mitigation measures that are referenced more than once in the PSA are not duplicated in the MMRP. Instruction for projectspecific guidance to implement certain SPRs and Mitigation Measures has been added to tailor the specific impact avoidance and minimization actions relevant to the proposed treatments, agency standard practices, and the conditions and resources present within each treatment site. In addition, non-substantive clarifying edits to mitigation measures in the Program EIR are shown in underline and strikethrough. In all cases, the additional project-specific implementation instruction and clarifying edits to mitigation measures maintain the SPRs and mitigation measures as equivalent or more effective than those presented in the Program EIR.

ROLES AND RESPONSIBILITIES
As defined in the CalVTP Program EIR and the PSA/Addendum, the project proponent is a public agency that provides funding for vegetation treatment or has land ownership, land management, or other regulatory responsibility in the treatable landscape and is seeking to fund, authorize, or implement vegetation treatments consistent with the CalVTP. The SPRs and mitigation measures in this MMRP direct the project proponent to implement actions to avoid, minimize and mitigate impacts.

The Saratoga Fire Protection District (SFD) is the lead agency under CEQA. As the CEQA lead agency, SFD will approve the West Santa Clara Landscape Resiliency Project (WSCLRP), approve and adopt the PSA/Addendum, file a CEQA Notice of Determination (NOD), approve and adopt the MMRP, and approve and adopt a statement of overriding considerations, if needed. The Saratoga Fire Protection District will enter into a partnership with Santa Clara County Firesafe Council (SCC FSC) to implement treatments because SCC FSC would be the primary entity to coordinate and implement treatments; this partnership encompasses SFD’s discretionary approval. The partnership may entail the provision of resources, possibly including equipment, staffing, and technical input.

SFD will typically not be implementing treatments directly; rather, treatments will be implemented by landowning and land managing agencies, non-governmental organizations (e.g., SCC FSC), private landowners, and contractors to implement treatments. For treatments requiring a discretionary approval by another agency (e.g., those that would be

Attachment A Ascent
Saratoga Fire Protection District
A-2 West Santa Clara Landscape Resiliency Project PSA and Addendum implemented by another public agency or funded through future public funding sources that have not yet been requested/obtained), that agency would be responsible for adopting the MMRP and statement of overriding considerations, if needed, for their portion of the project and filing a CEQA NOD.

If desired by SFD as the lead agency or for a responsible agency and pursuant to State CEQA Guidelines Section 15097(a), the agency can delegate monitoring and reporting responsibilities to another qualified responsible party (e.g., SCC FSC or a private entity) that accepts the delegation; however, until the mitigation measures and SPRs have been completed, the lead or responsible agency remains responsible for ensuring that implementation of the measures occurs in accordance with this MMRP. For example, SCC FSC (and its contractors) could implement treatments and the associated mitigation measures and SPRs, but the public lead or responsible agency remains responsible for ensuring that implementation of the measures occurs in accordance with this MMRP.

The “project proponent” as identified in the SPRs and mitigation measures would refer to the agency or entity responsible for implementing treatments.

REPORTING
The qualified responsible party as delegated by the lead or responsible agency shall document and describe the compliance of the treatments with the required SPRs and mitigation measures either by adapting the project-specific MMRP table or preparing a separate post-project implementation report pursuant to the requirements of SPR AD-7.

MITIGATION MONITORING AND REPORTING PROGRAM TABLE
The categories identified in the attached MMRP table are described below.  SPRs and Mitigation Measures – This column provides the text of the applicable SPR or adopted mitigation measure.
 Timing – This column identifies the time frame in which the SPR or mitigation measure will be implemented.  Implementing Entity – This column identifies the party responsible for implementing the SPR or mitigation measure.
 Verifying/Monitoring Entity – This column identifies the party responsible for verifying and monitoring implementation of the SPR or mitigation measure.

QUALIFICATION REQUIREMENTS
The biological and cultural resource SPRs and mitigation measures in the attached MMRP table require that qualified individuals implement components of the measures. The requirements listed below will be met to be considered qualified and may be performed by individuals of various titles (including biologist, botanist, ecologist, Registered Professional Forester (RPF), biological technician, or supervised designees working at the direction of a qualified professional) as long as they are qualified for the task at hand.

Archaeologically Trained Resource Professional: To be qualified, an archaeologically-trained resource professional would hold a valid Archaeological Training Certificate issued by CAL FIRE and the Board of Forestry and Fire Protection or equivalent state or local agency training or certification. If CAL FIRE is not leading the project, work performed by an archaeologically-trained resource professional must be reviewed and approved by a qualified archaeologist.

Qualified Archaeologist: To be qualified, an archaeologist would hold a Prehistoric Archeology, Historic Archeology, Conservation, Cultural Anthropology, or Curation degree from an accredited university and meet the Secretary of Interior’s Qualifications Standards (36 CFR Part 61). The project proponent will review the resume and approve the qualifications of the archaeologists.

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-3 Qualified RPF or Biological Technician: To be qualified, an RPF or biological technician would 1) be knowledgeable in relevant species life histories and ecology, 2) be able to correctly identify relevant species and habitats, 3) have experience conducting biological monitoring of relevant species or resources, and 4) be knowledgeable about state and federal laws regarding the protection of special-status species. The project proponent will review the resume and approve the qualifications of RPFs or biological technicians.

Qualified RPF or Biologist: To be qualified, an RPF or biologist would hold a wildlife biology, botany, ecology, forestry, or other relevant degree from an accredited university and: 1) be knowledgeable in relevant species life histories and ecology, 2) be able to correctly identify relevant species and habitats, 3) have experience conducting field surveys of relevant species or resources, 4) be knowledgeable about survey protocols, 5) be knowledgeable about state and federal laws regarding the protection of special-status species, and 6) have experience with CDFW’s California Natural Diversity Database (CNDDB) and Biogeographic Information and Observation System (BIOS). The project proponent will review the resume and approve the qualifications of RPFs or biologists. If species-specific protocol surveys are performed, surveys would be conducted by qualified RPFs or biologists with the minimum qualifications required by the appropriate protocols, including having CDFW or USFWS approval to conduct such surveys, if required by certain protocols.

Qualified RPF or Botanist: To be qualified, an RPF or botanist would 1) be knowledgeable about plant taxonomy, 2) be familiar with plants of the region, including special-status plants and sensitive natural communities, 3) have experience conducting floristic botanical field surveys as described in CDFW “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities” (current version dated March 20, 2018), or experience conducting such botanical field surveys under the direction of an experienced botanical field surveyor, 4) be familiar with the California Manual of Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/), and 5) be familiar with federal, state, and local statutes and regulations related to plants and plant collecting. The project proponent will review the resume and approve the qualifications of RPFs or botanists.

Qualified Responsible Party: A person or entity that possesses the necessary professional qualifications, licenses experience, and/or authority to perform the required duties and who assumes responsibility for carrying out those duties in compliance with this PSA/Addendum and MMRP including applicable laws and regulations as well as contractual obligations.

Attachment A Ascent
Saratoga Fire Protection District
A-4 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Administrative Standard Project Requirements
SPR AD-1: Project Proponent Coordination
For treatments coordinated with CAL FIRE, CAL FIRE will meet with the project proponent to discuss all natural and environmental resources that must be protected using SPRs and any applicable mitigation measures; identify any sensitive resources onsite; and discuss resource protection measures. For any prescribed burn treatments, CAL FIRE will also discuss the details of the burn plan in the incident action plan (IAP). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AD-2: Delineate Protected Resources:

The project proponent will clearly define the boundaries of the treatment area and protected resources on maps for the treatment area and with highly visible flagging or clear, existing landscape demarcations (e.g., edge of a roadway) prior to beginning any treatment to avoid disturbing the resource. “Protected Resources” refers to environmentally sensitive places within or adjacent to the treatment areas that would be avoided or protected to the extent feasible during planned treatment activities to sustain their natural qualities and processes. This work will be performed by a qualified person, as defined for the specific resource (e.g., qualified Registered Professional Forester or biologist). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AD-3: Consistency with Local Plans, Policies, and Ordinances:

The project proponent will design and implement the treatment in a manner that is consistent with applicable local plans (e.g., general plans, Community Wildfire Protection Plans, CAL FIRE Unit Fire Plans), policies, and ordinances to the extent the project is subject to them. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AD-4: Public Notifications for Prescribed Burning:

At least three days prior to the commencement of prescribed burning operations, the project proponent will: 1) post signs along the closest public roadway to the treatment area describing the activity and timing, and requesting persons in the area to contact a designated representative of the project proponent (contact information will be provided with the notice) if they have questions or smoke concerns; 2) publish a public interest notification in a local newspapers or other widely distributed media source describing the activity, timing, and contact information; 3) send the local county supervisor and county administrative officer (or equivalent official responsible for distribution of public information) a notification letter describing the activity, its necessity, timing, and measures being taken to protect the environment and prevent prescribed burn escape. This SPR applies only to prescribed burn treatment activities and all treatment types, including treatment maintenance.

At least three days prior
to prescribed burn
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AD-5: Maintain Site Cleanliness:

If trash receptacles are used on-site, the project proponent will use fully covered trash receptacles with secure lids (wildlife proof) to contain all food, food scraps, food wrappers, beverages, and other worker generated miscellaneous trash. Remove all temporary non-biodegradable flagging, trash, debris, and barriers from the project site upon completion of project activities. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-5 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR AD-6: Public Notifications for Treatment Projects
One to three days prior to the commencement of a treatment activity, the project proponent will post signs in a conspicuous location near the treatment area describing the activity and timing, and requesting persons in the area to contact a designated representative of the project proponent (contact information will be provided with the notice) if they have questions or concerns. This SPR applies to all treatment activities and all treatment types, including treatment maintenance. Prescribed burning is subject to the additional notification requirements of SPR AD-4.

One to three days prior
to treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AD-7: Provide Information on Proposed, Approved, and Completed Treatment Projects For any vegetation treatment project using the CalVTP Program EIR for CEQA compliance, the project proponent will provide the information listed below to the Board of Forestry and Fire Protection (Board) or CAL FIRE during the proposed, approved, and completed stages of the project. The Board or CAL FIRE will make this information available to the public via an online database or other mechanism.

Information on proposed projects (PSA in progress):
 GIS data that include project location (as a point), or project latitude/longitude;  project size (typically acres);
 treatment types and activities; and
 contact information for a representative of the project proponent.

The project proponent will provide information on the proposed project to the Board or CAL FIRE as early as feasible in the planning phase. The project proponent will provide this information to the Board or CAL FIRE with sufficient lead time to allow those agencies to make the information available to the public at least two weeks prior to project approval. The project proponent may also make information available to the public via other mechanisms (e.g., the proponent’s own website).

Information on approved projects (PSA complete):
 A completed PSA Environmental Checklist;
 A completed Mitigation Monitoring and Reporting Program (using Attachment A to the Environmental Checklist);  GIS data that include a polygon(s) of the project area, showing the extent of each treatment type included in the project (ecological restoration, fuel break, WUI fuel reduction) Information on completed projects (following initial treatment):
 GIS data that include a polygon(s) of the treated area, showing the extent of each treatment type implemented (ecological restoration, fuel break, WUI fuel reduction)  A post-project implementation report (referred to by CAL FIRE as a Completion Report) that includes  Size of treated area (typically acres);
 Treatment types and activities;
 Dates of work;
 A list of the SPRs and mitigation measures that were implemented; and Prior to, during, and
following treatment
Information on the
proposed project
(PSA/Addendum in
progress) was submitted
to CAL FIRE on October
14, 2025.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-6 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
 Any explanations regarding implementation if required by SPRs and mitigation measures (e.g., explanation for feasibility determination required by SPR BIO-12; explanation for reduction of a no-disturbance buffer below the general minimum size described in Mitigation Measures BIO-1a and BIO-2b).

This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Aesthetic and Visual Resource Standard Project Requirements SPR AES-1: Vegetation Thinning and Edge Feathering
The project proponent will thin and feather adjacent vegetation to break up or screen linear edges of the clearing and mimic forms of natural clearings as reasonable or appropriate for vegetation conditions. In general, thinning and feathering in irregular patches of varying densities, as well as a gradation of tall to short vegetation at the clearing edge, will achieve a natural transitional appearance. The contrast of a distinct clearing edge will be faded into this transitional band. This SPR only applies to mechanical and manual treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AES-2: Avoid Staging within Viewsheds
The project proponent will store all treatment-related materials, including vehicles, vegetation treatment debris, and equipment, outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. The project proponent will also locate materials staging and storage areas outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AES-3: Provide Vegetation Screening
The project proponent will preserve sufficient vegetation within, at the edge of, or adjacent to treatment areas to screen views from public trails, parks, recreation areas, and roadways as reasonable or appropriate for vegetation conditions. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Air Quality Standard Project Requirements
SPR AQ-1: Comply with Air Quality Regulations
The project proponent will comply with the applicable air quality requirements of air districts within whose jurisdiction the project is located. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AQ-2: Submit Smoke Management Plan
The project proponent will submit a smoke management plan for all prescribed burns to the applicable air district, in accordance with 17 CCR Section 80160. Pursuant to this regulation a smoke management plan will not be required for burns less than 10 acres that also will not be conducted near smoke sensitive areas, unless otherwise directed by the air district. Burning will only be conducted in compliance with the burn authorization program of the applicable air district(s) having jurisdiction over the treatment area. Example of a smoke management plan is in Appendix PD-2. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

Prior to prescribed burn
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-7 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR AQ-3: Create Burn Plan
The project proponent will create a burn plan using the CAL FIRE burn plan template for all prescribed burns. The burn plan will include a fire behavior model output of First Order Fire Effects Model and BEHAVE or other fire behavior modeling simulation and that is performed by a qualified fire behavior technical specialist that predicts fire behavior, calculates consumption of fuels, tree mortality, predicted emissions, greenhouse gas emissions, and soil heating. The project proponent will minimize soil burn severity from broadcast burning to reduce the potential for runoff and soil erosion. The burn plan will be created with input from a qualified technician or certified State burn boss. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

Project-Specific Implementation of SPR AQ-3
The project proponent will create a burn plan for broadcast burns using the CAL FIRE burn plan template or a template accepted by CAL FIRE as equivalent and industry-standard, such as the National Wildfire Coordinating Group (NWCG) template.

Prior to prescribed burn
treatment activities; does
not apply to pile burning
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AQ-4: Minimize Dust
To minimize dust during treatment activities, the project proponent will implement the following measures:
 Limit the speed of vehicles and equipment traveling on unpaved areas to 15 miles per hour to reduce fugitive dust emissions, in accordance with the California Air Resources Board (CARB) Fugitive Dust protocol.  If road use creates excessive dust, the project proponent will wet appurtenant, unpaved, dirt roads using water trucks or treat roads with a non-toxic chemical dust suppressant (e.g., emulsion polymers, organic material) during dry, dusty conditions. Any dust suppressant product used will be environmentally benign (i.e., non-toxic to plants and will not negatively impact water quality) and its use will not be prohibited by ARB, EPA, or the State Water Resources Control Board (SWRCB). The project proponent will not over-water exposed areas such that the water results in runoff. The type of dust suppression method will be selected by the project proponent based on soil, traffic, site-specific conditions, and air quality regulations.  Remove visible dust, silt, or mud tracked-out on to public paved roadways where sufficient water supplies and access to water is available. The project proponent will remove dust, silt, and mud from vehicles at the conclusion of each workday, or at a minimum of every 24 hours for continuous treatment activities, in accordance with Vehicle Code Section 23113.
 Suspend ground-disturbing treatment activities, including land clearing and bulldozer lines, when there is visible dust transport (particulate pollution) outside the treatment boundary, if the particulate emissions may “cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property,” per Health and Safety Code Section 41700.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-8 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR AQ-5: Avoid Naturally Occurring Asbestos
The project proponent will avoid ground-disturbing treatment activities in areas identified as likely to contain naturally occurring asbestos (NOA) per maps and guidance published by the California Geological Survey, unless an Asbestos Dust Control Plan (17 CCR Section 93105) is prepared and approved by the air district(s) with jurisdiction over the treatment area. Any NOA-related guidance provided by the applicable air district will be followed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR AQ-6: Prescribed Burn Safety Procedures
Prescribed burns planned and managed by non-CAL FIRE crews will follow all safety procedures required of CAL FIRE crew, including the implementation of an approved Incident Action Plan (IAP). The IAP will include the burn dates; burn hours; weather limitations; the specific burn prescription; a communications plan; a medical plan; a traffic plan; and special instructions such as minimizing smoke impacts to specific local roadways. The IAP will also assign responsibilities for coordination with the appropriate air district, such as conducting onsite briefings, posting notifications, weather monitoring during burning, and other burn related preparations. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

During prescribed burn
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Archaeological, Historical, and Tribal Cultural Resources Standard Project Requirements SPR CUL-1: Conduct Record Search
An archaeological and historical resource record search will be conducted per the applicable state or local agency procedures. Instead of conducting a new search, the project proponent may use recent record searches containing the treatment area requested by a landowner or other public agency in accordance applicable agency guidance.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment
Record search of project
area and 0.25-mile buffer
surrounding project area
has been conducted; see
PSA/Addendum for a
summary of results.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR CUL-2: Contact Geographically Affiliated Native American Tribes The project proponent will obtain the latest Native American Heritage Commission (NAHC) provided Native Americans Contact List. Using the appropriate Native Americans Contact List, the project proponent will notify the California Native American Tribes in the counties where the treatment activity is located. The notification will contain the following:
 A written description of the treatment location and boundaries.  Brief narrative of the treatment objectives.
 A description of the activities used (e.g., prescribed burning, mastication) and associated acreages.  A map of the treatment area at a sufficient scale to indicate the spatial extent of activities.  A request for information regarding potential impacts to cultural resources from the proposed treatment.  A detailed description of the depth of excavation, if ground disturbance is expected.

In addition, the project proponent will contact the NAHC for a review of their Sacred Lands File. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment
Tribes have been
contacted and Sacred
Lands File (SLF) query
completed; see
PSA/Addendum for a
summary of consultation
and SLF results.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-9 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR-CUL-3: Pre-field Research
The project proponent will conduct research prior to implementing treatments as part of the cultural resource investigation. The purpose of this research is to properly inform survey design, based on the types of resources likely to be encountered within the treatment area, and to be prepared to interpret, record, and evaluate these findings within the context of local history and prehistory. The qualified archaeologist and/or archaeologicallytrained resource professional will review records, study maps, read pertinent ethnographic, archaeological, and historical literature specific to the area being studied, and conduct other tasks to maximize the effectiveness of the survey. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR CUL-4: Archaeological Surveys
The project proponent will coordinate with an archaeologically-trained resource professional and/or qualified archaeologist to conduct a site-specific survey of the treatment area. The survey methodology (e.g., pedestrian survey, subsurface investigation) depends on whether the area has a low, moderate, or high sensitivity for resources, which is based on whether the records search, pre-field research, and/or Native American consultation identifies archaeological or historical resources near or within the treatment area. A survey report will be completed for every cultural resource survey completed. The specific requirements will comply with the applicable state or local agency procedures. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Proposed Revision to SPR CUL-4
SPR CUL-4, as presented in the Program EIR, requires that an archaeological survey report for all treatment activities and treatment types, including treatments that do not result in ground disturbance or other risk of impact to archaeological or historical resources (e.g., manual treatments and herbicide application).

A revision to the SPR is proposed such that archaeological surveys would only be conducted for ground disturbing treatment activities (i.e., treatments that include the use of heavy equipment) and prescribed burning treatment activities.

An excerpt of the original language of SPR CUL-4 is as follows:

This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

The SPR revision modifies the last sentence of the SPR to state the following:

This SPR applies to all treatment activities that have the potential for ground disturbance beyond established road surfaces, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-10 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR CUL-5: Treatment of Archaeological Resources
If cultural resources are identified within a treatment area, and cannot be avoided, a qualified archaeologist will notify the culturally affiliated tribe(s) based on information provided by NAHC and assess, whether an archaeological find qualifies as a unique archaeological resource, an historical resource, or in coordination with said tribe(s), as a tribal cultural resource. The project proponent, in consultation with culturally affiliated tribe(s), will develop effective protection measures for important cultural resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging effects to cultural resources will not occur. These protection measures will be written in clear, enforceable language, and will be included in the survey report in accordance with applicable state or local agency procedures. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR CUL-6: Treatment of Tribal Cultural Resources
The project proponent, in consultation with the culturally affiliated tribe(s), will develop effective protection measures for important tribal cultural resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging effects to cultural resources will not occur. The project proponent will provide the tribe(s) the opportunity to submit comments and participate in consultation to resolve issues of concern. The project proponent will defer implementing the treatment until the tribe approves protection measures, or if agreement cannot be reached after a good-faith effort, the proponent determines that any or all feasible measures have been implemented, where feasible, and the resource is either avoided or protected. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR CUL-7: Avoid Built Historical Resources
If the records search identifies built historical resources, as defined in Section 15064.5 of the State CEQA Guidelines, the project proponent will avoid these resources. Within a buffer of 100 feet of the built historical resource, there will be no prescribed burning or mechanical treatment activities Buffers less than 100 feet for built historical resources will only be used after consultation with and receipt of written approval from a qualified archaeologist. If the records search does not identify known historical resources in the treatment area, but structures (i.e., buildings, bridges, roadways) over 50 years old that have not been evaluated for historic significance are present in the treatment area, they will similarly be avoided. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR CUL-8: Cultural Resource Training
The project proponent will train all crew members and contractors implementing treatment activities on the protection of sensitive archaeological, historical, or tribal cultural resources. Workers will be trained to halt work if archaeological resources are encountered on a treatment site and the treatment method consists of physical disturbance of land surfaces (e.g., soil disturbance). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-11 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Chaparral and Coastal Sage Scrub Standard Project Requirement SPR CHAP/CSS-1: Chaparral and Coastal Sage Scrub
To be consistent with the Writ of Mandate and its Exhibit A (dated November 14, 2025) in Case No. 37-2020- 00005203-CU-TT-CT, for the purposes of this SPR only, chaparral and coastal sage scrub are defined as follows:

Chaparral: Dominated by evergreen, drought-tolerant shrubs that are typically 1.5–3 meters tall (Barbour, KeelerWolf, and Schoenherr 2007) with stiff branches, and sclerophyllous (i.e., hard-leaved) leaves.  Chaparral alliances are listed in level 1, 2 of the Key to Shrublands in the California Native Plant Society's (CNPS) Manual of California Vegetation. This definition does not include alliances dominated by coyote brush (Baccharis pilularis).
 Dominant plant species may include manzanita (Arctostaphylos spp.), ceanothus (Ceanothus spp.), chamise (Adenostoma fasciculatum), redshank (Adenostoma sparsifolium), sugarbush (Rhus ovata), scrub oak species (e.g., Quercus berberdifolia, Q. dumosa, Q. durata), Mission manzanita (Xylococcus bicolor), mountain mahogany (Cercocarpus montanus), hollyleaf cherry (Prunus ilicifolia), redberry (Rhamnus crocea), toyon (Heteromeles arbutifolia), and evergreen buckthorn (Rhamnus ilicifolia).

Coastal sage scrub: Dominated by drought-tolerant, deciduous, lower-growing (typically 1–1 .5 meters tall) (Barbour Keeler-Wolf, and Schoenherr 2007), shallow-rooted, aromatic shrubs with soft, flexible branches, and soft, deciduous leaves that drop off in response to drought.
 Coastal sage scrub alliances are listed in level 15 and 15' under 1, 2', 12', 13', 14 of the Key to Shrublands in the CNPS Manual of California Vegetation. This definition does not include alliances dominated by coyote brush (Baccharis pilularis) or nonnative species (e.g., broom [Genista monspessulana, Cytisus scoparius], Cotoneaster spp.).  Dominant or diagnostic plant species may include California sagebrush (Artemisia californica), white sage (Salvia apiana), black sage (Salvia mellifera), purple sage (Salvia leucophylla), California brittle bush (Encelia californica), buckwheat (Eriogonum spp.), monkey flower (Diplacus spp.), and stands with other species dominant to codominant listed in level 15' under 1, 2', 12', 13', 14.

A stand of chaparral or coastal sage scrub is defined as a spatially continuous unit of shrub vegetation composed of chaparral and/or coastal sage scrub alliances. A chaparral and/or coastal sage scrub stand may be surrounded by forest, grassland, or woodland vegetation.

All references to the CNPS Manual of California Vegetation are to the most current online edition, available at https://vegetation.cnps.org/.

As required in Exhibit A of the Writ of Mandate, treatments in chaparral and coastal sage scrub will be limited to activities listed below:
 New linear, accessible strategic fuel breaks located along ridgelines, roadsides, and in other critical defensive locations determined by responsible fire agencies, provided that long-term maintenance of flammable nonnative vegetation is included. Such fuel break treatments shall be the minimum width necessary to provide for firefighter safety, operational procedures, and back firing operations, and shall not exceed 300 feet in width.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-12 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
 Maintenance of existing fuel breaks and prior treatment areas to control flammable, nonnative invasive plants.  Wildland-urban interface (WUI) fuel reduction treatment located within 1,000 feet of the Interface layer mapped in the CAL FIRE WUI layer (WUI25 1) (available at: https://hub-calfireforestry.hub.arcgis.com/maps/ab3148666b084efcbe3bec0bf6af7441/explore?location=36.998595%2C121.992016%2C13), provided that long-term maintenance of flammable, nonnative vegetation is included, with a preference for hand thinning.
 Ecological restoration treatments consisting of removal of flammable, nonnative vegetation; and/or  Treatments where the stand of chaparral or coastal sage scrub has a state rarity rank of S4 (apparently secure) or S5 (demonstrably secure) according to the California Department of Fish and Wildlife (available at:
https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities#lists) and has generated following a fire within the last 15 years in an area previously characterized by woodland or forest before the fire, as evidenced by satellite imagery and as defined in accordance with the Key to Main Vegetation Categories in the CNPS Manual of California Vegetation.

Biological Resources Standard Project Requirements
SPR BIO-1: Review and Survey Project-Specific Biological Resources The project proponent will require a qualified RPF or biologist to conduct a data review and reconnaissance-level survey prior to treatment, no more than one year prior to the submittal of the PSA, and no more than one year between completion of the PSA and implementation of the treatment project. The data reviewed will include the biological resources setting, species and sensitive natural communities tables, and habitat information in this Program EIR for the ecoregion(s) where the treatment will occur. It will also include review of the best available, current data for the area, including vegetation mapping data, species distribution/range information, CNDDB, California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants of California, relevant BIOS queries, and relevant general and regional plans. Reconnaissance-level biological surveys will be general surveys that include visual and auditory inspection for biological resources to help determine the environmental setting of a project site.

The qualified surveyor will 1.) identify and document sensitive resources, such as riparian or other sensitive habitats, sensitive natural community, wetlands, or wildlife nursery site or habitat (including bird nests), and 2.) assess the suitability of habitat for special-status plant and animal species. The surveyor will also record any incidental wildlife observations. For each treatment project, habitat assessments will be completed at a time of year that is appropriate for identifying habitat and no more than one year prior to the submittal of the PSA, unless it can be demonstrated in the PSA that habitat assessments older than one year remain valid (e.g., site conditions are unchanged and no treatment activity has occurred since the assessment). If more than one year passes between completion of the PSA and initiation of the treatment project, the project proponent will verify the continued accuracy of the PSA prior to beginning the treatment project by reviewing for any data updates and/or visiting the site to verify conditions.

Based on the results of the data review and reconnaissance-level survey, the project proponent, in consultation with a qualified RPF or biologist, will determine which one of the following best characterizes the treatment:

Prior to treatment
Initial data review and
reconnaissance-level
survey have been
conducted, see
PSA/Addendum for
results.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-13 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity

1. Suitable Habitat Is Present but Adverse Effects Can Be Clearly Avoided. If, based on the data review and reconnaissance-level survey, the qualified RPF or biologist determines that suitable habitat for sensitive biological resources is present but adverse effects on the suitable habitat can clearly be avoided through one of the following methods, the avoidance mechanism will be implemented prior to initiating treatment and will remain in effect throughout the treatment:
a. by physically avoiding the suitable habitat, or
b. by conducting treatment outside of the season when a sensitive resource could be present within the suitable habitat or outside the season of sensitivity (e.g., outside of special-status bird nesting season, during dormant season of sensitive annual or geophytic plant species, or outside of maternity and rearing season at wildlife nursery sites).

Physical avoidance will include flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway) to delineate the boundary of the avoidance area around the suitable habitat. For physical avoidance, a buffer may be implemented as determined necessary by the qualified RPF or biologist.

Project-Specific Guidance to Implement SPR BIO-1
Bay checkerspot butterfly
If treatment activities occur outside of the serpentine grassland habitat suitable for bay checkerspot butterfly no further measures are needed; however, if treatments occur within habitat for the species, because bay checkerspot butterfly and host plants may be present within serpentine grassland habitat in the project area year-round, the sensitive season for this species cannot be avoided, and SPR BIO-10 will apply.

Crotch’s bumble bee
If treatment activities occur outside of the grassland, scrub, and woodland habitat suitable for Crotch’s bumble bee no further measures are needed; however, if treatments occur within habitat for the species, because Crotch’s bumble bee may be present within grassland, scrub, and woodland habitat in the project area year-round, the sensitive season for this species cannot be avoided, and SPR BIO-10 will apply.

Monarch butterfly
 To avoid impacts on breeding monarch butterflies, prescribed burning, mechanical, manual, and herbicide treatments will be conducted in grassland, shrub, and oak woodland habitat outside of the season when monarch eggs, larvae, and pupae are likely to be present on milkweed host plants (i.e., treatment will be conducted outside of March 15-October 31) (Xerces Society 2019). This period may be adjusted by a qualified biologist or RPF to reflect local timing of monarch breeding. If it is not feasible to avoid treatments during this sensitive season, then SPR BIO-10 will be implemented.

California red-legged frog
If no California red-legged frog aquatic breeding habitat (as determined by a qualified RPF or biologist) is present within 1.7 miles of the proposed treatment area, then the species is not expected to occur and no further California red-legged frog measures would apply. When treatment activities other than prescribed herbivory or herbicide Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-14 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
application are proposed within 1.7 miles of aquatic breeding habitat for California red-legged frog, a nodisturbance buffer of 300 feet from all aquatic habitat is required or SPR BIO-10 will be implemented.

All herbicide use during project implementation will comply with current herbicide use restrictions. The stipulated injunction issued by the Federal District Court for the Northern District of California to resolve the 2006 case brought against the US Environmental Protection Agency by the Center for Biological Diversity requires that pesticides listed in the injunction will not be applied within aquatic breeding critical habitat, nonbreeding aquatic critical habitat, upland critical habitat for the California red-legged frog, or in buffer zones (60 feet for ground application) measured from the edge of the aquatic breeding, nonbreeding aquatic, or upland critical habitat.

California tiger salamander
If proposed project activities will occur within suitable upland habitat for California tiger salamander as determined by a qualified RPF or biologist, then the following will apply (upland habitat is typically defined as oak woodland or grassland within 1.3 miles of suitable aquatic breeding habitat).  Within upland habitat suitable for California tiger salamander, if no mechanical treatment or pile burning is proposed, and no broadcast burning, manual tree and snag removal, or herbicide application other than cutstump and basal bark application is proposed during the dispersal season (November 1–April 30), then no further avoidance measures are required for California tiger salamander.  If pile burning or mechanical treatment is proposed within suitable upland habitat at any time of the year, then SPR BIO-10 will be implemented.
 If broadcast burning, manual tree and snag removal, or herbicide application other than cut-stump and basal bark application is proposed within suitable upland habitat during the dispersal season for California tiger salamander (November 1–April 30), then SPR BIO-10 will be implemented.

Foothill yellow-legged frog
 To the extent feasible, prior to commencement of prescribed burning, manual treatments, mechanical treatments, and herbicide application other than cut-stump and basal bark application, a no-disturbance buffer of 200 feet will be implemented adjacent to all perennial (i.e., Class I and Class II) watercourses that provide habitat for the species as assessed and determined by a qualified RPF or biologist, if feasible.  If work occurs in upland habitat suitable for foothill yellow-legged frog (as determined by a qualified RPF or biologist), or if the 200-foot no-disturbance buffer is determined to be infeasible for certain treatment areas, then SPR BIO-10 will be implemented.

Southwestern pond turtle
If treatment activities occur more than 1,300 feet (USFWS 2023) from aquatic habitat suitable for southwestern pond turtle, then impacts to the species would be avoided, and no further measures are required. For treatments conducted within 1,300 feet of aquatic suitable habitat for southwestern pond turtle, the following will apply:
 If only manual pruning, prescribed herbivory, or cut-stump and basal bark herbicide application is proposed, then no further avoidance measures are required.

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-15 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
 If prescribed burning, mechanical treatments, manual tree and snag removal, and herbicide application (other than cut-stump and basal bark application) occur within upland habitat for southwestern pond turtle, which may include riparian areas, grasslands, and open oak woodlands on east-facing (Reese and Welsh 1997) or southfacing areas that are less than 25 percent slope (Buskirk 2002) within 1,300 feet of aquatic habitat (USFWS 2023), then SPR BIO-10 will be implemented.

Special-status amphibians and reptiles
 If prescribed burning, mechanical treatments, manual tree and snag removal, and targeted herbicide treatments (other than basal bark and cut stump application) cannot be avoided within habitat suitable for California giant salamander, Santa Cruz black salamander, red-bellied newt, coast horned lizard, and Northern California legless lizard then SPR BIO-10 will be implemented.

Burrowing owl
 To avoid impacts on overwintering burrowing owl, within habitats determined to be suitable for overwintering burrowing owls by a qualified RPF or biologist, a limited operating period from September 1–January 31 would prohibit manual treatments, mechanical treatments, prescribed burning, and prescribed herbivory, if feasible. If conducting treatments outside of the burrowing owl overwintering season is determined to be infeasible, then SPR BIO-10 will be implemented. This applies to all project areas.  To avoid impacts on nesting burrowing owl, within habitats determined to be suitable for nesting burrowing owls by a qualified RPF or biologist, a limited operating period from February 1–August 31 would prohibit manual treatments, mechanical treatments, prescribed burning, prescribed herbivory and herbicide treatments, if feasible. If conducting treatments outside of the burrowing owl nesting season is determined to be infeasible, then SPR BIO-10 will be implemented.
 In areas utilized by burrowing owls year-round (during the overwintering and breeding periods), the species may be present in burrows throughout the year, and adverse impacts on individuals cannot be avoided with a limited operating period. For treatment in areas utilized by burrowing owls year-round, the above measures are infeasible, and SPR BIO-10 will be implemented.

Least Bell’s vireo
 To avoid impacts on least Bell’s vireo, a limited operating period of February 1 through August 31 will be implemented within 250 feet of habitats determined to be suitable for the species by a qualified RPF or biologist, if feasible. If conducting treatments outside of the nesting season is determined to be infeasible, then SPR BIO-10 will be implemented.

Tricolored blackbird
 To avoid impacts on tricolored blackbird, a limited operating period of February 1 through August will be implemented within 250 feet of habitats determined to be suitable for the species by a qualified RPF or biologist, if feasible. If conducting treatments outside of the nesting season is determined to be infeasible, then SPR BIO-10 will be implemented.

Attachment A Ascent
Saratoga Fire Protection District
A-16 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Other Special-Status birds
 To avoid impacts on special-status nesting birds (i.e., grasshopper sparrow, golden eagle, short-eared owl, logeared 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), a limited operating period for all treatment activities from December 1 through July 31 for golden eagle, January 1 through August 31 for white-tailed kite, and February 1 through August 31 for other special-status nesting birds will be implemented within habitats determined to be suitable for these species by a qualified RPF or biologist, if feasible. If conducting treatments outside of the nesting bird season is determined to be infeasible, then SPR BIO-10 will be implemented.

Northern California ringtail
 To avoid impacts on Northern California ringtail, a limited operating period for manual or mechanical tree or snag (i.e., greater than 12 inches DBH) removal activities and prescribed burning during the maternity season from April 15 to July 31 will be implemented, if feasible. If conducting manual and mechanical tree or snag removal or prescribed burning treatments outside of the ringtail maternity season is determined to be infeasible for certain treatments, then SPR BIO-10 will be implemented.

San Francisco dusky-footed woodrat
If proposed project activities will occur within suitable habitat for San Francisco dusky-footed woodrat as determined by a qualified RPF or biologist, then the following will apply.  If only prescribed herbivory or herbicide application is proposed, then no further avoidance measures are required.
 If manual treatments, mechanical treatments, or prescribed burning is proposed, then SPR BIO-10 will be implemented.

Special-Status bats
 To avoid impacts on special-status bat maternity colonies, a limited operating period for prescribed burning, mechanical treatments, and manual treatments and herbicide application using power equipment from April 1 to August 31 during the sensitive season will be implemented, if feasible. If the limited operating period is infeasible, focused surveys will be required per SPR BIO-10.
 To avoid impacts on hibernating special-status bats, avoid removal of structures that may contain roosts as determined by a qualified RPF or biologist (e.g., large hardwoods and conifers containing cavities, and snags) during the overwintering season (October 15 -April 1) if feasible. If avoiding removal of potential roosting trees and snags is infeasible, focused surveys will be required per SPR BIO-10.

2. Suitable Habitat is Present and Adverse Effects Cannot Be Clearly Avoided. Further review and surveys will be conducted to determine presence/absence of sensitive biological resources that may be affected, as described in the SPRs below. Further review may include contacting USFWS, NOAA Fisheries, CDFW, CNPS, or local resource agencies as necessary to determine the potential for special-status species or other sensitive biological resources to be affected by the treatment activity. Focused or protocol-level surveys will be

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-17 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
conducted as necessary to determine presence/absence. If protocol surveys are conducted, survey procedures will adhere to methodologies approved by resource agencies and the scientific community, such as those that are available on the CDFW webpage at: https://www.wildlife.ca.gov/Conservation/Survey-Protocols. Specific survey requirements are addressed for each resource type in relevant SPRs (e.g., additional survey requirements are presented for special-status plants in SPR BIO-7).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Specific Guidance to Implement SPR BIO-1
Special-status plants
For special-status plants not listed under CESA or ESA, to avoid impacts on the annual and geophyte species identified in Attachment B of the PSA/Addendum, only non-ground-disturbing treatment activities (i.e., manual treatments, herbicide application, prescribed herbivory, and prescribed burning) will be implemented and only during the dormant season for these species (i.e., when the plant has no aboveground parts), if feasible, provided the treatment will not alter habitat in a way that would make it unsuitable for the special-status plants to reestablish following treatment, or destroy seedbanks, stumps, or roots, rhizomes, bulbs and other underground parts of these species. If the limited operating period for annual and geophyte species (i.e., only non-ground-disturbing treatment activities conducted during the dormant season) is determined to be infeasible, then protocol-level surveys will be required per SPR BIO-7. Note that ground-disturbing treatment activities (i.e., mechanical treatments) and pile burning may result in impacts on these plant species even when dormant and will not be conducted without prior implementation of SPR BIO-7.

Special-Status Wildlife
Because there is no reliable season during which all impacts on bald eagle, California condor, American badger, mountain lion, and San Joquin kit fox could be avoided, and because full avoidance of habitat is not feasible due to these species’ variable habitat preferences, SPR BIO-10 will apply for these species before all treatment activities.

SPR BIO-2: Require Biological Resource Training for Workers The project proponent will require crew members and contractors to receive training from a qualified RPF or biologist prior to beginning a treatment project. The training will describe the appropriate work practices necessary to effectively implement the biological SPRs and mitigation measures and to comply with the applicable environmental laws and regulations. The training will include the identification, relevant life history information, and avoidance of pertinent special-status species; identification and avoidance of sensitive natural communities and habitats with the potential to occur in the treatment area; impact minimization procedures; and reporting requirements. The training will instruct workers when it is appropriate to stop work and allow wildlife encountered during treatment activities to leave the area unharmed and when it is necessary to report encounters to a qualified RPF, biologist, or biological technician. The qualified RPF, biologist, or biological technician will immediately contact CDFW or USFWS, as appropriate, if any wildlife protected by the California Endangered Species Act (CESA) or Federal Endangered Species Act (ESA) is encountered and cannot leave the site on its own (without being handled).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-18 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Project-Specific Guidance to Implement SPR BIO-2
California Condor
 The qualified RPF or biologist will provide all workers at the project site with “condor hazing” training pursuant to the September 3, 2014, California Condor Recovery Program memo (USFWS 2014). If any California condors enter the project area while work activities are being conducted, the hazing measures would be implemented to avoid the possibility that California condors would become habituated to human activities or be harmed by project activities. Work crews will inform the project biologist should any California condor hazing take place.  In circumstances where California condors are already present in the project area, and engaged in natural behaviors (e.g., roosting, foraging), prior to treatment the hazing protocol would not be implemented and California condors would be allowed to depart on their own. Condors that come into the project area while work activities are taking place will be hazed.

San Francisco Dusky-Footed Woodrat
 The qualified RPF or biologist will provide all workers conducting prescribed burning, mechanical, and manual treatments with specific training on finding the various typical and atypical woodrat nests, and how to estimate a 5 to 10-foot buffer around the nest. Training will include practical training in the field using existing woodrat nests within planned treatment areas or similar habitat types.

Sensitive Natural Communities and Other Sensitive Habitats SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats If SPR BIO-1 determines that sensitive natural communities or sensitive habitats may be present and adverse effects cannot be avoided, the project proponent will:
 require a qualified RPF or biologist to perform a protocol-level survey following the CDFW “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities” (current version dated March 20, 2018) of the treatment area prior to the start of treatment activities for sensitive natural communities and sensitive habitats. Sensitive natural communities will be identified using the best means possible, including keying them out using the most current edition of A Manual of California Vegetation (including updated natural communities data at http://vegetation.cnps.org/), or referring to relevant reports (e.g., reports found on the VegCAMP website).
 map and digitally record, using a Global Positioning System (GPS), the limits of any potential sensitive habitat and sensitive natural community identified in the treatment area.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR BIO-4: Design Treatment to Avoid Loss or Degradation of Riparian Habitat Function Project proponents, in consultation with a qualified RPF or qualified biologist, will design treatments in riparian habitats to retain or improve habitat functions by implementing the following within riparian habitats:
 Retain at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation within the limits of riparian habitat identified and mapped during surveys conducted pursuant to SPR BIO-3.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-19 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Native riparian vegetation will be retained in a well distributed multi-storied stand composed of a diversity of species similar to that found before the start of treatment activities.  Treatments will be limited to removal of uncharacteristic fuel loads (e.g., removing dead or dying vegetation), trimming/limbing of woody species as necessary to reduce ladder fuels, and select thinning of vegetation to restore densities that are characteristic of healthy stands of the riparian vegetation types characteristic of the region. This includes hand removal (or mechanized removal where topography allows) of dead or dying riparian trees and shrubs, invasive plant removal, selective thinning, and removal of encroaching upland species.  Removal of large, native riparian hardwood trees (e.g., willow, ash, maple, oak, alder, sycamore, cottonwood) will be minimized to the extent feasible and 75 percent of the pretreatment native riparian hardwood tree canopy will be retained. Because tree size varies depending on vegetation type present and site conditions, the tree size retention parameter will be determined on a site-specific basis depending on vegetation type present and setting; however, live, healthy, native trees that are considered large for that type of tree and large relative to other trees in that location will be retained. A scientifically-based, project-specific explanation substantiating the retention size parameter for native riparian hardwood tree removal will be provided in the Biological Resources Discussion of the PSA. Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, presence of sufficient seed trees, light availability, and changes in stream shading may inform the tree size retention requirements.
 Removed trees will be felled away from adjacent streams or waterbodies and piled outside of the riparian vegetation zone (unless there is an ecological reason to do otherwise that is approved by applicable regulatory agencies, such as adding large woody material to a stream to enhance fish habitat, e.g., see Accelerated Wood Recruitment and Timber Operations: Process Guidance from the California Timber Harvest Review Team Agencies and National Marine Fisheries Service).
 Vegetation removal that could reduce stream shading and increase stream temperatures will be avoided.  Ground disturbance within riparian habitats will be limited to the minimum necessary to implement effective treatments. This will consist of the minimum disturbance area necessary to reduce hazardous fuels and return the riparian community to a natural fire regime (i.e., Condition Class 1) considering historic fire return intervals, climate change, and land use constraints.
 Only hand application of herbicides approved for use in aquatic environments will be allowed and only during low-flow periods or when seasonal streams are dry.
 The project proponent will notify CDFW when required pursuant to California Fish and Game Code Section 1602 prior to implementing any treatment activities in riparian habitats. Notification will identify the treatment activities, map the vegetation to be removed, identify the impact avoidance identification methods to be used (e.g., flagging), and appropriate protections for the retention of shaded riverine habitat, including buffers and other applicable measures to prevent erosion into the waterway.
 In consideration of spatial variability of riparian vegetation types and condition and consistent with California Forest Practice Rules Section 916.9(v) (February 2019 version), a different set of vegetation retention standards and protection measures from those specified in the above bullets may be implemented on a site-specific basis if

Attachment A Ascent
Saratoga Fire Protection District
A-20 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
the qualified RPF and the project proponent demonstrate through substantial evidence that alternative design measures provide a more effective means of achieving the treatment objectives and would result in effects to the Beneficial Functions of Riparian Zones equal or more favorable than those expected to result from application of the above measures. Deviation from the above design specifications, different protection measures and design standards will only be approved when the treatment plan incorporates an evaluation of beneficial functions of the riparian habitat and with written concurrence from CDFW.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR BIO-5: Avoid Environmental Effects of Type Conversion and Maintain Habitat Function in Chaparral and Coastal Sage Scrub
The project proponent will design treatment activities to avoid type conversion where native coastal sage scrub and chaparral are present. An ecological definition of type conversion is used in the CalVTP Program EIR for assessment of environmental effects: a change from a vegetation type dominated by native shrub species that are characteristic of chaparral and coastal sage scrub vegetation alliances to a vegetation type characterized predominantly by weedy herbaceous cover or annual grasslands. For the Program EIR, type conversion is considered in terms of habitat function, which is defined here as the arrangement and capability of habitat features to provide refuge, food source, and reproduction habitat to plants and animals, and thereby contribute to the conservation of biological and genetic diversity and evolutionary processes (de Groot et al. 2002). Some modification of habitat characteristics may occur provided habitat function is maintained (i.e., the location, essential habitat features, and species supported are not substantially changed).

During the reconnaissance-level survey required in SPR BIO-1, a qualified RPF or biologist will identify chaparral and coastal sage scrub vegetation to the alliance level and determine the condition class and fire return interval departure of the chaparral and/or coastal sage scrub present in each treatment area.

For all treatment types in chaparral and coastal sage scrub, the project proponent, in consultation with a qualified RPF or qualified biologist will:
 Develop a treatment design that avoids environmental effects of type conversion in chaparral and coastal sage scrub vegetation alliances, which will include evaluating and determining the appropriate spatial scale at which the proponent would consider type conversion, and substantiating its appropriateness. The project proponent will demonstrate with substantial evidence that the habitat function of chaparral and coastal sage scrub would be at least maintained within the identified spatial scale at which type conversion is evaluated for the specific treatment project. Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, spatial needs of sensitive species, presence of sufficient seed plants and nurse plants, light availability, and edge effects may inform the determination of an appropriate spatial scale.  The treatment design will maintain a minimum percent cover of mature native shrubs within the treatment area to maintain habitat function; the appropriate percent cover will be identified by the project proponent in the development of treatment design and be specific to the vegetation alliances that are present in the identified spatial scale used to evaluate type conversion. Mature native shrubs that are retained will be distributed contiguously or in patches within the stand. If the stand consists of multiple age classes, patches representing a Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

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range of middle to old age classes will be retained to maintain and improve heterogeneity, to the extent needed to avoid type conversion.

These SPR requirements apply to all treatment activities and all treatment types, including treatment maintenance.

Additional measures will be applied to ecological restoration treatment types:
 For ecological restoration treatment types, complete removal of the mature shrub layer will not occur in native chaparral and coastal sage scrub vegetation types.
 Ecological restoration treatments will not be implemented in vegetation types that are within their natural fire return interval (i.e., time since last burn is less than the average time listed as the fire return interval range in Table 3.6-1) unless the project proponent demonstrates with substantial evidence that the habitat function of chaparral and coastal sage scrub would be improved.
 A minimum of 35 percent relative cover of existing shrubs and associated native vegetation will be retained at existing densities in patches distributed in a mosaic pattern within the treated area or the shrub canopy will be thinned by no more than 20 percent from baseline density (i.e., if baseline shrub canopy density is 60 percent, post treatment shrub canopy density will be no less than 40 percent). A different percent relative cover can be retained if the project proponent demonstrates with substantial evidence that alternative treatment design measures would result in effects on the habitat function of chaparral and coastal sage scrub that are equal or more favorable than those expected to result from application of the above measures. Biological considerations that may inform a deviation from the minimum 35 percent relative cover retention include but are not limited to soil moisture requirements, increased soil temperatures, changes in light/shading, presence of sufficient seed plants and nurse plants, erosion potential, and site hydrology.  If the stand within the treatment area consists of multiple age classes, patches representing a range of middle to old age classes will be retained to maintain and improve heterogeneity.

These SPR requirements apply to all treatment activities and only the ecosystem restoration treatment type, including treatment maintenance.

A determination of compliance with the SB 1260 prohibition of type conversion in chaparral and coastal sage scrub is a statutory issue separate from CEQA compliance that may involve factors additional to the ecological definition and habitat functions presented in the Program EIR, such as geographic context. It is beyond the legal scope of the Program EIR to define SB 1260 type conversion and statutory compliance. The project proponent, acting as lead agency for the proposed later treatment project, will be responsible for defining type conversion in the context of the project and making the finding that type conversion would not occur, as required by SB 1260. The project proponent will determine its criteria for defining and avoiding type conversion and, in making its findings, may draw upon information presented in this Program EIR.

Project-Specific Implementation of SPR BIO-5
This project will implement SPR CHAP/CSS-1 to be consistent with the Writ of Mandate in chaparral and coastal sage scrub habitat areas. Some requirements of SPR CHAP/CSS-1 are more restrictive on ecological restoration treatment activities than SPR BIO-5; therefore, the requirements of SPR CHAP/CSS-1 that are more restrictive

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A-22 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
supersede SPR BIO-5 in ecological restoration treatments of chaparral and coastal sage scrub. To ensure compliance with SPR CHAP/CSS-1, the following text will be removed from SPR BIO-5:

Additional measures will be applied to ecological restoration treatment types:
 For ecological restoration treatment types, complete removal of the mature shrub layer will not occur in native chaparral and coastal sage scrub vegetation types.
 Ecological restoration treatments will not be implemented in vegetation types that are within their natural fire return interval (i.e., time since last burn is less than the average time listed as the fire return interval range in Table 3.6-1) unless the project proponent demonstrates with substantial evidence that the habitat function of chaparral and coastal sage scrub would be improved.
 A minimum of 35 percent relative cover of existing shrubs and associated native vegetation will be retained at existing densities in patches distributed in a mosaic pattern within the treated area or the shrub canopy will be thinned by no more than 20 percent from baseline density (i.e., if baseline shrub canopy density is 60 percent, post treatment shrub canopy density will be no less than 40 percent). A different percent relative cover can be retained if the project proponent demonstrates with substantial evidence that alternative treatment design measures would result in effects on the habitat function of chaparral and coastal sage scrub that are equal or more favorable than those expected to result from application of the above measures. Biological considerations that may inform a deviation from the minimum 35 percent relative cover retention include but are not limited to soil moisture requirements, increased soil temperatures, changes in light/shading, presence of sufficient seed plants and nurse plants, erosion potential, and site hydrology.  If the stand within the treatment area consists of multiple age classes, patches representing a range of middle to old age classes will be retained to maintain and improve heterogeneity.

These SPR requirements apply to all treatment activities and only the ecosystem restoration treatment type, including treatment maintenance.

SPR BIO-6: Prevent Spread of Plant Pathogens
When working in sensitive natural communities, riparian habitats, or oak woodlands that are at risk from plant pathogens (e.g., Ione chaparral, blue oak woodland), the project proponent will implement the following best management practices to prevent the spread of Phytopthora and other plant pathogens (e.g., pitch canker (Fusarium), goldspotted oak borer, shot hole borer, bark beetle):
 clean and sanitize vehicles, equipment, tools, footwear, and clothes before arriving at a treatment site and when leaving a contaminated site, or a site in a county where contamination is a risk;  include training on Phytopthora diseases and other plant pathogens in the worker awareness training;  minimize soil disturbance as much as possible by limiting the number of vehicles, avoiding off-road travel as much as possible, and limiting use of mechanized equipment;  minimize movement of soil and plant material within the site, especially between areas with high and low risk of contamination;
Prior to and during
treatment
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Firesafe Council or
Qualified Responsible
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Santa Clara County
Firesafe Council or
Qualified Responsible
Party

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 clean soil and debris from equipment and sanitize hand tools, buckets, gloves, and footwear when moving from high risk to low risk areas or between widely separated portions of a treatment area; and  follow the procedures listed in Guidance for plant pathogen prevention when working at contaminated restoration sites or with rare plants and sensitive habitat (Working Group for Phytoptheras in Native Habitats 2016).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR BIO-7: Survey for Special-Status Plants
If SPR BIO-1 determines that suitable habitat for special-status plant species is present and cannot be avoided, the project proponent will require a qualified RPF or botanist to conduct protocol-level surveys for special-status plant species with the potential to be affected by a treatment prior to initiation of the treatment. The survey will follow the methods in the current version of CDFW’s “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities.”
Surveys to determine the presence or absence of special-status plant species will be conducted in suitable habitat that could be affected by the treatment and timed to coincide with the blooming or other appropriate phenological period of the target species (as determined by a qualified RPF or botanist), or all species in the same genus as the target species will be assumed to be special-status.

If potentially occurring special-status plants are listed under CESA or ESA, protocol-level surveys to determine presence/absence of the listed species will be conducted in all circumstances, unless determined otherwise by CDFW or USFWS.

For other special-status plants not listed under CESA or ESA, as defined in Section 3.6.1 of this Program EIR, surveys will not be required under the following circumstances:
 If protocol-level surveys, consisting of at least two survey visits (e.g., early blooming season and later blooming season) during a normal weather year, have been completed in the 5 years before implementation of the treatment project and no special-status plants were found, and no treatment activity has occurred following the protocol-level survey, treatment may proceed without additional plant surveys.  If the target special-status plant species is an herbaceous annual, stump-sprouting, or geophyte species, the treatment may be carried out during the dormant season for that species or when the species has completed its annual lifecycle without conducting presence/absence surveys provided the treatment will not alter habitat or destroy seeds, stumps, or roots, rhizomes, bulbs and other underground parts in a way that would make it unsuitable for the target species to reestablish following treatment.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Specific Guidance to Implement SPR BIO-7
 If the limited operating period for annual and perennial geophyte species (i.e., non-ground-disturbing treatment activities conducted during the dormant season) is determined to be infeasible, then protocol-level surveys for these species will be conducted prior to implementation of treatments.  Protocol-level surveys will be conducted for perennial species prior to implementation of treatments.

Prior to treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

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Invasive Plants and Wildlife
SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife The project proponent will take the following actions to prevent the spread of invasive plants, noxious weeds, and invasive wildlife (e.g., New Zealand mudsnail):
 clean clothing, footwear, and equipment used during treatments of soil, seeds, vegetative matter, other debris or seed-bearing material, or water (e.g., rivers, streams, creeks, lakes) before entering the treatment area or when leaving an area with infestations of invasive plants, noxious weeds, or invasive wildlife;  for all heavy equipment and vehicles traveling off road, pressure wash, if feasible, or otherwise appropriately decontaminate equipment at a designated weed-cleaning station prior to entering the treatment area from an area with infestations of invasive plants, noxious weeds, or invasive wildlife. Anti-fungal wash agents will be specified if the equipment has been exposed to any pathogen that could affect native species;  inspect all heavy equipment, vehicles, tools, or other treatment-related materials for sand, mud, or other signs that weed seeds or propagules could be present prior to use in the treatment area. If the equipment is not clean, the qualified RPF or biological technician will deny entry to the work areas;  stage equipment in areas free of invasive plant infestations unless there are no uninfested areas present within a reasonable proximity to the treatment area;
 identify significant infestations of invasive plant species (i.e., those rated as invasive by Cal-IPC or designated as noxious weeds by California Department of Food and Agriculture) during reconnaissance-level surveys and target them for removal during treatment activities. Treatment methods will be selected based on the invasive species present and may include herbicide application, manual or mechanical treatments, prescribed burning, and/or herbivory, and will be designed to maximize success in killing or removing the invasive plants and preventing reestablishment based on the life history characteristics of the invasive plant species present.

Treatments will be focused on removing invasive plant species that cause ecological harm to native vegetation types, especially those that can alter fire cycles;
 treat invasive plant biomass onsite to eliminate seeds and propagules and prevent reestablishment or dispose of invasive plant biomass offsite at an appropriate waste collection facility (if not kept on site); transport invasive plant materials in a closed container or bag to prevent the spread of propagules during transport; and  implement Fire and Fuel Management BMPs outlined in the “Preventing the Spread of Invasive Plants: Best Management Practices for Land Mangers” (Cal-IPC 2012, or current version).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Specific Guidance to Implement SPR BIO-9
 All plant materials used for revegetation will exclude any species listed on the Cal-IPC Invasive Plant Inventory (CalIPC 2025, or current version) or designated as noxious weeds by the local Agricultural Commissioner’s Office.  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 Prior to and during
treatment
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Qualified Responsible
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Firesafe Council or
Qualified Responsible
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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 2025), 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 a “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.

Wildlife
SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites If SPR BIO-1 determines that suitable habitat for special-status wildlife species or nurseries of any wildlife species is present and cannot be avoided, the project proponent will require a qualified RPF or biologist to conduct focused or protocol-level surveys for special-status wildlife species or nursery sites (e.g., bat maternity roosts, deer fawning areas, heron or egret rookeries, monarch overwintering sites) with potential to be directly or indirectly affected by a treatment activity. The survey area will be determined by a qualified RPF or biologist based on the species and habitats and any recommended buffer distances in agency protocols.

The qualified RPF or biologist will determine if following an established protocol is required, and the project proponent may consult with CDFW and/or USFWS for technical information regarding appropriate survey protocols.

Unless otherwise specified in a protocol, the survey will be conducted no more than 14 days prior to the beginning of treatment activities. Focused or protocol surveys for a special-status species with potential to occur in the treatment area may not be required if presence of the species is assumed.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Specific Guidance to Implement SPR BIO-10
Bay checkerspot butterfly
To avoid impacts on bay checkerspot butterfly, focused surveys for the species will be conducted before implementation of all treatment activities in habitat suitable for the species. If focused surveys for bay checkerspot butterfly are not conducted, presence of the butterfly may be assumed. Because the project area is within the range of the federally listed bay checkerspot butterfly, Mitigation Measure BIO-2e (bay checkerspot butterfly) would be implemented, regardless of the results of SPR BIO-10 surveys, although the implementation of Mitigation Measure BIO2e would be informed by the results of the focused surveys if they occur.

No more than 14 days
prior to treatment,
unless otherwise
specified in a protocol
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

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Crotch’s bumble bee
If avoidance of habitat pursuant to SPR BIO-1 is not feasible to avoid impacts on Crotch’s bumble bee, a habitat assessment will be conducted by a qualified biologist or RPF. If habitat suitable for the species is present, focused surveys will be conducted by a biologist or qualified RPF within habitat potentially suitable for Crotch’s bumble bee based on the Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species (CDFW 2023) or more recent guidance, prior to implementation of all treatment activities, or presence of this species in potentially suitable habitat will be assumed, and Mitigation Measure BIO-2g will be implemented.

Monarch butterfly
If it is not feasible to avoid mechanical, manual, herbicide, or prescribed burning treatments in grasslands, shrub, and oak woodland habitat during the period when monarch may be breeding (March 15-October 31) pursuant to SPR BIO-1, focused surveys for milkweed host plants (Asclepias spp.) will be conducted prior to implementing treatment activities. If milkweed is detected during focused surveys, further survey for monarch butterfly eggs, larvae, and pupae may be conducted or presence of monarch may be assumed. If milkweed host plants are detected during focused surveys and monarch butterfly is detected or assumed present, Mitigation Measure BIO-2e will be implemented.

California red-legged frog
Prior to implementation of prescribed burning, mechanical, manual, and herbicide application activities, a qualified RPF or qualified biologist will conduct protocol-level surveys for California red-legged frog pursuant to the Revised Guidance on Site Assessments and Field Surveys for the California Red-Legged Frog (USFWS 2005) within habitat potentially suitable for the species, or presence of the species will be assumed and Mitigation Measure BIO-2a will be implemented. If protocol-level surveys are conducted and California red-legged frogs are not detected within the treatment areas, then no additional mitigation for the species will be required and Mitigation Measure BIO-2a will not be required. If California red-legged frog is detected or assumed present, Mitigation Measure BIO-2a will be implemented.

California tiger salamander
If avoidance is not feasible pursuant to SPR BIO-1, to avoid impacts to California tiger salamander, a qualified RPF or qualified biologist with the appropriate permits will conduct protocol-level surveys for California tiger salamander according to the Interim Guidance of Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander (CDFW 2003) within habitat potentially suitable for the species (i.e., oak woodland and grasslands up to 1.3 miles from aquatic breeding habitat) prior to mechanical treatments and pile burning activities year-round and for broadcast burning, manual tree and snag removal, or herbicide application (other than cut-stump and basal bark application) during the dispersal season for the species (November 1–April 30), or presence may be assumed. If California tiger salamander is detected during surveys or assumed present, Mitigation Measure BIO-2a will be implemented.

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Foothill yellow-legged frog
If avoidance of habitat is not feasible (pursuant to SPR BIO-1) for manual treatments, mechanical treatments, prescribed burning, and herbicide application (other than cut-stump and basal bark application) that occur within 200 feet of Class I and Class II watercourses that may habitat suitable for foothill yellow-legged frog as assessed and determined by a qualified RPF or biologist, focused visual encounter surveys for foothill yellow-legged frog will be conducted prior to treatment activities within the 200-foot buffer, or the presence of the species may be assumed. If foothill yellow-legged frogs are not detected within the treatment area during focused surveys, then no mitigation for the species would be required. If foothill yellow-legged frogs are identified during focused surveys, or presence is assumed, Mitigation Measure BIO-2a would be implemented.

Southwestern pond turtle
If avoidance of habitat is not feasible (pursuant to SPR BIO-1) to avoid impacts on southwestern pond turtle, a focused survey for southwestern pond turtles and nests will be conducted by a qualified biologist or RPF. If southwestern pond turtles or nests are detected during focused surveys, Mitigation Measure BIO-2b will be implemented.

Special-Status amphibians and reptiles
If avoidance of habitat is not feasible (pursuant to SPR BIO-1) to avoid impacts on special-status amphibians and reptiles, a focused survey for special-status amphibians and reptiles will be conducted by a qualified biologist or RPF. If special-status amphibians and reptiles are detected during focused surveys or if the species are assumed to be present, Mitigation Measure BIO-2b will be implemented.

Bald eagle
To avoid impacts on bald eagle the following focused surveys will be conducted:
 For all treatments implemented during the nesting season (December 1 through July 31) conduct surveys for nesting bald eagles within approximately 1.0 miles of lakes and reservoirs with fisheries sufficient to support bald eagle nesting.
 For all treatments implemented during the overwintering (non-nesting season) conduct surveys for communal roosting trees within 0.5 miles of lakes and reservoirs with fisheries sufficient to support bald eagles.  If nesting or communally roosting bald eagles are detected during focused surveys, Mitigation Measure BIO-2a will be implemented.

Burrowing owl
 If it is not feasible to avoid manual treatments, mechanical treatments, prescribed burning, and prescribed herbivory during the burrowing owl overwintering season (September 1–January 31) in habitats suitable for the species, then a survey shall be conducted to determine whether burrowing owls occupy the portions of the treatment area subject to manual treatments, mechanical treatments, ground or human disturbance associated with prescribed burning (e.g., control lines, staging areas) and prescribed herbivory (e.g., fence lines, pens, watering infrastructure, staging areas).

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 Within the yearlong range of the species, if it is not feasible to avoid manual treatments, mechanical treatments, prescribed burning, prescribed herbivory, and herbicide application during the burrowing owl nesting season (February 1–August 31) in habitats suitable for the species, pursuant to SPR BIO-1, a minimum of four surveys shall be conducted to determine whether burrowing owls occupy the treatment area.  Surveys will be conducted referring to Appendix D of the 2012 Staff Report on Burrowing Owl Mitigation prepared by the California Department of Fish and Game (now California Department of Fish and Wildlife) (CDFW 2012) or any subsequent updated guidance within 1,640 feet (0.3 miles) of treatment areas as access to adjacent property and visibility from accessible areas allows. If feasible, at least one survey should be conducted between February 15 and April 15, and the remaining surveys should be conducted between April 15 and July 15, at least 2 weeks apart.

Because burrowing owls may recolonize a site after only a few days, one of the surveys, or an additional survey, shall be conducted no less than 14 days before initiating treatment activities to verify that take of burrowing owl would not occur. Alternatively, following the first survey, any burrows that are potentially suitable for burrowing owl would be assumed to be occupied. If active nesting burrowing owl burrows are detected during protocol surveys or burrows are assumed to be occupied, Mitigation Measure BIO-2a will be implemented.

Least Bell’s vireo
If it is not feasible to avoid all treatments during the nesting season for least Bell’s vireo (February –August 31), as modified by a qualified RPF or biologist based on current conditions), pursuant to SPR BIO-1, protocol surveys for nests of least Bell’s vireo will be conducted following the Least Bell’s Vireo Survey Guidelines (USFWS 2001) within habitat suitable for the species prior to implementing treatment activities within 250 feet of that habitat during the nesting season. If nesting least Bell’s vireos are detected during surveys, Mitigation Measures BIO-2a will be implemented.

Tricolored blackbird
If it is not feasible to avoid all treatments during the nesting season for tricolored blackbird (February –August 31), as modified by a qualified RPF or biologist based on current conditions), pursuant to SPR BIO-1, focused surveys (i.e., nest searches) for nests of tricolored blackbird will be conducted in habitat suitable for the species prior to implementing treatment activities within 250 feet of nesting habitat during the nesting bird season. If nesting tricolored blackbirds are detected during focused surveys, Mitigation Measures BIO-2a will be implemented.

Other Special-Status Birds
If it is not feasible to avoid all treatments during the nesting bird season (from December 1 through July 31 for golden eagle, January 1 through August 31 for white-tailed kite, and February 1 through August 31 for other specialstatus nesting birds, as modified by the qualified RPF or biologist), pursuant to SPR BIO-1, focused surveys (i.e., nest searches) for nests of special-status (i.e., grasshopper sparrow, golden eagle, short-eared owl, log-eared owl, Swainson’s hawk, Vaux’s swift, northern harrier, olive-sided flycatcher, black swift, white-tailed kite, saltmarsh common yellowthroat, bald eagle, yellow breasted chat, loggerhead shrike, purple martin, and yellow warbler) will be conducted in habitat suitable for the species prior to implementing treatment activities during the nesting bird season. If nesting special-status birds are detected during focused surveys, Mitigation Measures BIO-2a or BIO-2b will be implemented depending on the species detected.

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American badger
To avoid impacts on American badger, focused den surveys in habitat determined to be suitable for denning by a qualified biologist or RPF will be conducted prior to implementing pile burning, installation of control lines and staging areas for prescribed burning, mechanical treatments, or the setup of infrastructure for prescribed herbivory activities year-round. Within the pupping season (February 15–July 1) surveys will be conducted prior to, manual treatments, as well as the other activities which require year-round survey. If American badger dens are detected during focused surveys, Mitigation Measure BIO-2b will be implemented.

Mountain lion
To avoid impacts on mountain lion, prior to implementing prescribed burning, manual tree and snag removal treatments, and mechanical treatments, nursery habitat suitable for the species will be identified by a qualified RPF or biologist through desktop analyses (e.g., review of land cover, slope, distance from development, coordination with local experts studying or tracking the species [if available], and field assessments). Potential mountain lion nursery habitat may include large natural cavities within rocky areas, downed trees, shrub thickets, or other areas with structures deemed appropriate for use by mountain lions based on size and other characteristics (e.g., proximity to human development, surrounding habitat). If nursery habitat is confirmed within the treatment area, use of the habitat will be assumed and Mitigation Measure BIO-2a will be applied. If nursery habitat is not identified within the treatment area, no additional measures will be required.

Ringtail
If it is not feasible to avoid manual and mechanical large tree and snag (i.e., greater than 12 inches DBH) removal or prescribed burning within habitat suitable for Northern California ringtail during the ringtail maternity season (pursuant to SPR BIO-1), focused surveys for ringtail will be conducted using trail cameras, track plates, or other non-invasive survey methods to determine whether ringtails are present within the treatment area. Surveys will be conducted by a qualified RPF or biologist with the appropriate permits as needed, or presence may be assumed. If ringtails are detected during focused surveys, or presence is assumed, Mitigation Measure BIO-2a will be implemented.

San Francisco dusky-footed woodrat
To avoid impacts on San Francisco dusky-footed woodrat, focused surveys for the species will be conducted by a qualified RPF, biologist, or biological technician within habitat suitable for the species year-round prior to implementation of traditional mechanical treatments; nest presence may be assumed for other treatment types including mechanical treatments using remote-controlled masticators. If San Francisco dusky-footed woodrat nests are detected during focused surveys or assumed to be present, Mitigation Measure BIO-2b will be implemented.

San Joaquin kit fox
To avoid impacts to San Joaquin kit fox, prior to implementation of pile burning and mechanical treatment activities year-round or any treatment activities during the pupping/natal season (February 1–September 30) within potentially suitable grassland, scrub, and oak savanna habitat, a habitat evaluation of the treatment area including one walking transect survey to identify potential dens following relevant portions of the San Joaquin Kit Fox Survey Protocol for the Northern Range (USFWS 1999) for San Joaquin kit fox would be conducted by a qualified RPF or

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biologist prior to the start of treatment activities. If the habitat within the treatment area is suitable for the species and contains potentially occupied dens, Mitigation Measure BIO-2a will be implemented.

Special-Status bats
If it is not feasible to avoid prescribed burning, mechanical treatments, manual treatments, and herbicide application using power equipment within habitat suitable for special-status bat roosting during the bat maternity season (April 1 through August 31), or to avoid removal of potential roosts during the overwintering season (October 15- April 1) pursuant to SPR BIO-1, focused surveys for roosts will be conducted by a qualified RPF or biologist prior to implementing these treatment activities during the bat maternity and overwintering season. If special-status bat roosts are detected during focused surveys, Mitigation Measure BIO-2b will be implemented.

SPR BIO-11: Install Wildlife-Friendly Fencing (Prescribed Herbivory) If temporary fencing is required for prescribed herbivory treatment, a wildlife-friendly fencing design will be used.

The project proponent will require a qualified RPF or biologist to review and approve the design before installation to minimize the risk of wildlife entanglement. The fencing design will meet the following standards:
 Minimize the chance of wildlife entanglement by avoiding barbed wire, loose or broken wires, or any material that could impale or snag a leaping animal; and, if feasible, keeping electric netting-type fencing electrified at all times or laid down while not in use.
 Charge temporary electric fencing with intermittent pulse energizers; continuous output fence chargers will not be permitted.
 Allow wildlife to jump over easily without injury by installing fencing that can flex as animals pass over it and installing the top wire low enough (no more than approximately 40 inches high on flat ground) to allow adult ungulates to jump over it. The determination of appropriate fence height will consider slope, as steep slopes are more difficult for wildlife to pass.
 Be highly visible to birds and mammals by using high-visibility tape or wire, flagging, or other markers.

This SPR applies only to prescribed herbivory and all treatment types, including treatment maintenance.

During prescribed
herbivory treatment
activities.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR BIO-12: Protect Common Nesting Birds, Including Raptors The project proponent will schedule treatment activities to avoid the active nesting season of common native bird species, including raptors, that could be present within or adjacent to the treatment site, if feasible. Common native birds are species not otherwise treated as special status in the CalVTP Program EIR. The active nesting season will be defined by the qualified RPF or biologist.

If active nesting season avoidance is not feasible, a qualified RPF or biologist will conduct a survey for common nesting birds, including raptors. Existing records (e.g., CNDDB, eBird database, State Wildlife Action Plan) should be reviewed in advance of the survey to identity the common nesting birds, including raptors, that are known to occur in the vicinity of the treatment site. The survey area will encompass reasonably accessible areas of the treatment site and the immediately surrounding vicinity viewable from the treatment site. The survey area will be determined by a qualified RPF or biologist, based on the potential species in the area, location of suitable nesting habitat, and type of treatment. For vegetation removal or project activities that would occur during the nesting season, the survey will be Conduct a survey for
common nesting birds (if
needed) at a time that
balances the
effectiveness of
detecting nests and the
reasonable consideration
of potential avoidance
strategies (typically no
more than approximately
14 days before
treatment); if an active
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-31 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
conducted at a time that balances the effectiveness of detecting nests and the reasonable consideration of potential avoidance strategies. Typically, this timeframe would be up to 3 weeks before treatment. The survey will occur in a single survey period of sufficient duration to reasonably detect nesting birds, including raptors, typically one day for most treatment projects (depending on the size, configuration, and vegetation density in the treatment site), and conducted during the active time of day for target species, typically close to dawn and/or dusk. The survey may be conducted concurrently with other biological surveys, if they are required by other SPRs. Survey methods will be tailored by the qualified RPF or biologist to site and habitat conditions, typically involving walking throughout the survey area, visually searching for nests and birds exhibiting behavior that is typical of breeding (e.g., delivering food).

If an active nest is observed (i.e., presence of eggs and/or chicks) or determined to likely be present based on nesting bird behavior, the project proponent will implement a feasible strategy to avoid disturbance of active nests, which may include, but is not limited to, one or more of the following:
 Establish Buffer. The project proponent will establish a temporary, species-appropriate buffer around the nest sufficient to reasonably expect that breeding would not be disrupted. Treatment activities will be implemented outside of the buffer. The buffer location will be determined by a qualified RPF or biologist. Factors to be considered for determining buffer location will include: presence of natural buffers provided by vegetation or topography, nest height above ground, baseline levels of noise and human activity, species sensitivity, and expected treatment activities. Nests of common birds within the buffer need not be monitored during treatment.

However, buffers will be maintained until young fledge or the nest becomes inactive, as determined by the qualified RPF, biologist, or biological technician.
 Modify Treatment. The project proponent will modify the treatment in the vicinity of an active nest to avoid disturbance of active nests (e.g., by implementing manual treatment methods, rather than mechanical treatment methods). Treatment modifications will be determined by the project proponent in coordination with the qualified RPF or biologist.
 Defer Treatment. The project proponent will defer the timing of treatment in the portion(s) of the treatment site that could disturb the active nest. If this avoidance strategy is implemented, treatment activity will not commence until young fledge or the nest becomes inactive, as determined by the qualified RPF, biologist, or biological technician.

Feasible actions will be taken by the project proponent to avoid loss of common native bird nests. The feasibility of implementing the avoidance strategies will be determined by the project proponent based on whether implementation of this SPR will preclude completing the treatment project within the reasonable period of time necessary to meet CalVTP program objectives, including, but not limited to, protection of vulnerable communities.

Considerations may include limitations on the presence of environmental and atmospheric conditions necessary to execute treatment prescriptions (e.g., the limited seasonal windows during which prescribed burning can occur when vegetation moisture, weather, wind, and other physical conditions are suitable). If it is infeasible to avoid loss of common bird nests (not including raptor nests), the project proponent will document the reasons implementation of the avoidance strategies is infeasible in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any change in the feasibility of avoidance strategies from those nest is observed,
implement avoidance
strategies prior to and
during treatment

Attachment A Ascent
Saratoga Fire Protection District
A-32 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).

The following avoidance strategies may also be considered together with or in lieu of other actions for implementation by a project proponent to avoid disturbance to raptor nests:
 Monitor Active Raptor Nest During Treatment. A qualified RPF, biologist, or biological technician will monitor an active raptor nest during treatment activities to identify signs of agitation, nest defense, or other behaviors that signal disturbance of the active nest is likely (e.g., standing up from a brooding position, flying off the nest). If breeding raptors are showing signs of nest disturbance, one of the other avoidance strategies (establish buffer, modify treatment or defer treatment) will be implemented or a pause in the treatment activity will occur until the disturbance behavior ceases.
 Retention of Raptor Nest Trees. Trees with visible raptor nests, whether occupied or not, will be retained.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Geology, Soils, Paleontology, and Mineral Resource Standard Project Requirements SPR GEO-1: Suspend Disturbance during Heavy Precipitation The project proponent will suspend mechanical, prescribed herbivory, and herbicide treatments if the National Weather Service forecast is a “chance” (30 percent or more) of rain within the next 24 hours. Activities that cause mechanical soil disturbance may resume when precipitation stops and soils are no longer saturated (i.e., when soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur). Indicators of saturated soil conditions may include, but are not limited to: (1) areas of ponded water, (2) pumping of fines from the soil or road surfacing, (3) loss of bearing strength resulting in the deflection of soil or road surfaces under a load, such as the creation of wheel ruts, (4) spinning or churning of wheels or tracks that produces a wet slurry, or (5) inadequate traction without blading wet soil or surfacing materials. This SPR applies only to mechanical, prescribed herbivory, and herbicide treatment activities and all treatment types, including treatment maintenance.

Proposed Revision to SPR GEO-1
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 to suspend herbicide application if the National Weather Service forecast is a “chance” (30 percent or more averaged over each hour) of rain within the next operational day’s 12-hour period between 6:00 a.m. and 6:00 p.m.

An excerpt of the original language of SPR GEO-1 is as follows:

The project proponent will suspend mechanical, prescribed herbivory, and herbicide treatments if the National Weather Service forecast is a “chance” (30 percent or more) of rain within the next 24 hours.

Activities that cause mechanical soil disturbance may resume when precipitation stops and soils are no longer saturated (i.e., when soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur). Indicators of saturated soil conditions may include, but are not limited to: (1) areas of ponded water, (2) pumping of fines from the soil or road surfacing, (3) loss of bearing strength resulting in the deflection of soil or road surfaces under a load, such as the creation of wheel ruts, (4) During mechanical and
herbicide treatment
activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-33 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
spinning or churning of wheels or tracks that produces a wet slurry, or (5) inadequate traction without blading wet soil or surfacing materials. This SPR applies only to mechanical, prescribed herbivory, and herbicide treatment activities and all treatment types, including treatment maintenance.

The SPR revision modifies this sentence to state the following:

The project proponent will suspend prescribed herbivory and herbicide treatments if the National Weather Service forecast is a “chance” (30 percent or more) of rain within the next 24 hours (from 12:00 am to 12:00 pm) and will suspend mechanical treatments when (1) it is raining, (2) soils are saturated, and/or, (3) soils are wet enough to be compacted by mechanical activities.

SPR GEO-2: Limit High Ground Pressure Vehicles
The project proponent will limit heavy equipment that could cause soil disturbance or compaction to be driven through treatment areas when soils are wet and saturated to avoid compaction and/or damage to soil structure.

Saturated soil means that soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur. If use of heavy equipment is required in saturated areas, other measures such as operating on organic debris, using low ground pressure vehicles, or operating on frozen soils/snow covered soils will be implemented to minimize soil compaction. Existing compacted road surfaces are exempted as they are already compacted from use. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

During mechanical
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR GEO-3: Stabilize Disturbed Soil Areas
The project proponent will stabilize soil disturbed during mechanical, prescribed herbivory treatments, and prescribed burns that result in exposure of bare soil over 50 percent or more of the treatment area with mulch or equivalent immediately after treatment activities, to the maximum extent practicable, to minimize the potential for substantial sediment discharge. If mechanical, prescribed herbivory, or prescribed burn treatment activities could result in substantial sediment discharge from soil disturbed by machinery, animal hooves, or being bare, organic material from mastication or mulch will be incorporated onto at least 75 percent of the disturbed soil surface where the soil erosion hazard is moderate or high, and 50 percent of the disturbed soil surface where soil erosion hazard is low to help prevent erosion. Where slash mulch is used, it will be packed into the ground surface with heavy equipment so that it is sufficiently in contact with the soil surface. This SPR only applies to mechanical, prescribed herbivory, and prescribed burns that result in exposure of bare soil over 50 percent of the project area treatment activities and all treatment types, including treatment maintenance.

During mechanical and
prescribed burn
treatment activities that
result in exposure of
bare soil over 50 percent
or more of the treatment
area
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR GEO-4: Erosion Monitoring
The project proponent will inspect treatment areas for the proper implementation of erosion control SPRs and mitigations prior to the rainy season. If erosion control measures are not properly implemented, they will be remediated prior to the first rainfall event per SPR GEO-3 and GEO-8. Additionally, the project proponent will inspect for evidence of erosion after the first large storm or rainfall event (i.e., ≥ 1.5 inches in 24 hours) as soon as is feasible after the event. Any area of erosion that will result in substantial sediment discharge will be remediated within 48 hours per the methods stated in SPRs GEO-3 and GEO-8. This SPR applies only to mechanical, prescribed herbivory, and prescribed burning treatment activities and all treatment types, including treatment maintenance.

Prior to and during
mechanical and
prescribed burning
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-34 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR GEO-5: Drain Stormwater via Water Breaks
The project proponent will drain compacted and/or bare linear treatment areas capable of generating storm runoff via water breaks using the spacing and erosion control guidelines contained in Sections 914.6, 934.6, and 954.6(c) of the California Forest Practice Rules (February 2019 version). Where waterbreaks cannot effectively disperse surface runoff, including where waterbreaks cause surface run-off to be concentrated on downslopes, other erosion controls will be installed as needed to maintain site productivity by minimizing soil loss. This SPR applies only to mechanical, manual, and prescribed burn treatment activities and all treatment types, including treatment maintenance.

During mechanical,
manual, and prescribed
burning treatment
activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR GEO-6: Minimize Burn Pile Size
The project proponent will not create burn piles that exceed 20 feet in length, width, or diameter, except when on landings, road surfaces, or on contour to minimize the spatial extent of soil damage. In addition, burn piles will not occupy more than 15 percent of the total treatment area (Busse et al. 2014). The project proponent will not locate burn piles in a Watercourse and Lake Protection Zone as defined in SPR HYD-4. This SPR applies to mechanical, manual, and prescribed burning treatment activities and all treatment types, including treatment maintenance.

During mechanical,
manual, and prescribed
burning treatment
activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR GEO-7: Minimize Erosion
To minimize erosion, the project proponent will:
(1) Prohibit use of heavy equipment where any of the following conditions are present:
(i) Slopes steeper than 65 percent.
(ii) Slopes steeper than 50 percent where the erosion hazard rating is high or extreme. (iii) Slopes steeper than 50 percent that lead without flattening to sufficiently dissipate water flow and trap sediment before it reaches a watercourse or lake.
(2) On slopes between 50 percent and 65 percent where the erosion hazard rating is moderate, and all slope percentages are for average slope steepness based on sample areas that are 20 acres, or less, heavy equipment will be limited to:
(i) Existing tractor roads that do not require reconstruction, or (ii) New tractor roads flagged by the project proponent prior to the treatment activity. (3) Prescribed herbivory treatments will not be used in areas with over 50 percent slope.

This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR GEO-8: Steep Slopes
The project proponent will require a Registered Professional Forester (RPF) or licensed geologist to evaluate treatment areas with slopes greater than 50 percent for unstable areas (areas with potential for landslide) and unstable soils (soil with moderate to high erosion hazard). If unstable areas or soils are identified within the treatment area, are unavoidable, and will be potentially directly or indirectly affected by the treatment, a licensed geologist (P.G. or C.E.G.) will determine the potential for landslide, erosion, of other issue related to unstable soils and identity measures (e.g., those in SPR GEO-7) that will be implemented by the project proponent such that substantial erosion or loss of topsoil would not occur. This SPR applies only to mechanical treatment activities and WUI fuel reduction, non-shaded fuel breaks, and ecological restoration treatment types, including treatment maintenance.

Prior to and during
mechanical treatment on
slopes greater than 50
percent
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-35 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Hazardous Material and Public Health and Safety Standard Project Requirements SPR HAZ-1: Maintain All Equipment
The project proponent will maintain all diesel- and gasoline-powered equipment per manufacturer’s specifications, and in compliance with all state and federal emissions requirements. Maintenance records will be available for verification. Prior to the start of treatment activities, the project proponent will inspect all equipment for leaks and inspect everyday thereafter until equipment is removed from the site. Any equipment found leaking will be promptly removed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Proposed Revision to SPR HAZ-1
A revision to the SPR is proposed to promptly stabilize any equipment found leaking and fix it on-site or remove the leaking equipment from the treatment area, outside of the Watercourse and Lake Protection Zones (WLPZs).

An excerpt of the original language of SPR HAZ-1 is as follows:

Any equipment found leaking will be promptly removed.

The SPR revision modifies the second to last sentence of the excerpt to state the following:

Any equipment found leaking will be promptly stabilized and fixed onsite or removed.

Prior to and during all
treatments.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-2: Require Spark Arrestors
The project proponent will require mechanized hand tools to have federal- or state-approved spark arrestors. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.

During manual
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-3: Require Fire Extinguishers
The project proponent will require tree cutting crews to carry one fire extinguisher per chainsaw. Each vehicle would be equipped with one long-handled shovel and one axe or Pulaski consistent with PRC Section 4428. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.

During manual
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-4 Prohibit Smoking in Vegetated Areas
The project proponent will require that smoking is only permitted in designated smoking areas barren or cleared to mineral soil at least 3 feet in diameter (PRC Section 4423.4). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-5: Spill Prevention and Response Plan
The project proponent or licensed Pest Control Advisor (PCA) will prepare a Spill Prevention and Response Plan (SPRP) prior to beginning any herbicide treatment activities to provide protection to onsite workers, the public, and the environment from accidental leaks or spills of herbicides, adjuvants, or other potential contaminants. The SPRP will include (but not be limited to):
 a map that delineates staging areas, and storage, loading, and mixing areas for herbicides;  a list of items required in an onsite spill kit that will be maintained throughout the life of the activity; Prepare SPRP prior to
beginning any herbicide
treatment activities;
implement measures
during herbicide
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-36 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
 procedures for the proper storage, use, and disposal of any herbicides, adjuvants, or other chemicals used in vegetation treatment.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

SPR HAZ-6: Comply with Herbicide Application Regulations The project proponent will coordinate pesticide use with the applicable County Agricultural Commissioner(s), and all required licenses and permits will be obtained prior to herbicide application. The project proponent will prepare all herbicide applications to do the following:
 Be implemented consistent with recommendations prepared annually by a licensed PCA.  Comply with all appropriate laws and regulations pertaining to the use of pesticides and safety standards for employees and the public, as governed by the EPA, DPR, and applicable local jurisdictions.  Adhere to label directions for application rates and methods, storage, transportation, mixing, container disposal, and weather limitations to application such as wind speed, humidity, temperature, and precipitation.  Be applied by an applicator appropriately licensed by the State.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

Prior to and during
herbicide treatments
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-7: Triple Rinse Herbicide Containers
The project proponent will triple rinse all herbicide and adjuvant containers with clean water at an approved site, and dispose of rinsate by placing it in the batch tank for application per 3 CCR Section 6684. The project proponent will puncture used containers on the top and bottom to render them unusable, unless said containers are part of a manufacturer’s container recycling program, in which case the manufacturer’s instructions will be followed. Disposal of non-recyclable containers will be at legal dumpsites. Equipment will not be cleaned, and personnel will not be washed in a manner that would allow contaminated water to directly enter any body of water within the treatment area or adjacent watersheds. Disposal of all herbicides will follow label requirements and waste disposal regulations.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

During and following
herbicide treatments
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HAZ-8: Minimize Herbicide Drift to Public Areas
The project proponent will employ the following herbicide application parameters during herbicide application to minimize drift into public areas:
 application will cease when weather parameters exceed label specifications or when sustained winds at the site of application exceeds 7 miles per hour (whichever is more conservative);  spray nozzles will be configured to produce the largest appropriate droplet size to minimize drift;  low nozzle pressures (30-70 pounds per square inch) will be utilized to minimize drift; and  spray nozzles will be kept within 24 inches of vegetation during spraying.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

During herbicide
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-37 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR HAZ-9: Notification of Herbicide Use in the Vicinity of Public Areas For herbicide applications occurring within or adjacent to public recreation areas, residential areas, schools, or any other public areas within 500 feet, the project proponent will post signs at each end of herbicide treatment areas and any intersecting trails notifying the public of the use of herbicides. The signs will include the signal word (i.e., Danger, Warning or Caution), product name, and manufacturer; active ingredient; EPA registration number; target pest; treatment location; date and time of application; restricted entry interval, if applicable per the label requirements; date which notification sign may be removed; and a contact person with a telephone number. Signs will be posted prior to the start of treatment and notification will remain in place for at least 72 hours after treatment ceases. This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

Prior to, during, and 72
hours after herbicide
treatment activities
occurring within or
adjacent to public
recreation areas,
residential areas, schools,
or any other public areas
within 500 feet
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Hydrology and Water Quality Standard Project Requirements SPR HYD-1: Comply with Water Quality Regulations
Project proponents must also conduct proposed vegetation treatments in conformance with appropriate RWQCB timber, vegetation and land disturbance related Waste Discharge Requirements (WDRs) and/or related Conditional Waivers of Waste Discharge Requirements (Waivers), and appropriate Basin Plan Prohibitions. Where these regulatory requirements differ, the most restrictive will apply. If applicable, this includes compliance with the conditions of general waste discharge requirements (WDR) and waste discharge requirement waivers for timber or silviculture activities where these waivers are designed to apply to non-commercial fuel reduction and forest health projects. In general, WDR and Waivers of waste discharge requirements for fuel reduction and forest health activities require that wastes, including but not limited to petroleum products, soil, silt, sand, clay, rock, felled trees, slash, sawdust, bark, ash, and pesticides must not be discharged to surface waters or placed where it may be carried into surface waters; and that Water Board staff must be allowed reasonable access to the property in order to determine compliance with the waiver conditions. The specifications for each WDR and Waiver vary by region. Regions 2 (San Francisco Bay), 4 (Los Angeles), 8 (Santa Ana), and 7 (Colorado River) are highly urban or minimally forested and do not offer WDRs or Waivers for fuel reduction or vegetation management activities. The current applicable WDRs and Waivers for timber and vegetation management activities are included in Appendix HYD-1. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Specific Guidance to Implement SPR HYD-1
Vegetation treatment activities may result in discharges to waters of the state; therefore; compliance with Water Code sections 13260(a)(1) and 13264 are required. The project proponent will use the State Water Board’s Vegetation Treatment General Order, which provides a mechanism for Water Code compliance for projects that prepare a CalVTP PSA or PSA/Addendum. The project will be automatically enrolled (through implementation of SPR AD-7) in the State Water Board’s Vegetation Treatment General Order. The project’s automatic enrollment satisfies the requirements of SPR HYD-1.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HYD-2: Avoid Construction of New Roads
The project proponent will not construct or reconstruct (i.e., cutting or filling involving less than 50 cubic yards/0.25 linear road miles) any new roads (including temporary roads). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-38 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR HYD-3: Water Quality Protections for Prescribed Herbivory The project proponent will include the following water quality protections for all prescribed herbivory treatments:
 Environmentally sensitive areas such as waterbodies, wetlands, or riparian areas will be identified in the treatment prescription and excluded from prescribed herbivory project areas using temporary fencing or active herding. A buffer of approximately 50 feet will be maintained between sensitive and actively grazed areas.  Water will be provided for grazing animals in the form of an on-site stock pond or a portable water source located outside of environmentally sensitive areas.
 Treatment prescriptions will be designed to protect soil stability. Grazing animals will be herded out of an area if accelerated soil erosion is observed.

This SPR applies to prescribed herbivory treatment activities and all treatment types, including treatment maintenance.

Before and during
prescribed herbivory
treatments
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (February 2019 version). WLPZ’s are classified based on the uses of the stream and the presence of aquatic life.

Wider WLPZs are required for steep slopes.

Establish WLPZs during
design of treatment
project; implement WLPZ
protections during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Procedures for Determining Watercourse and Lake Protection Zone (WLPZ) widths Water Class Class I Class II Class III Class IV
Water Class
Characteristics
or Key
Indicator
Beneficial Use
1) Domestic supplies, including
springs, on site and/or within 100
feet downstream of the operations
area and/or
2) Fish always or seasonally present
onsite, includes habitat to sustain
fish migration and spawning.
1) Fish always or seasonally present
offsite within 1000 feet downstream
and/or
2) Aquatic habitat for nonfish
aquatic species.
3) Excludes Class III waters that are
tributary to Class I waters.

No aquatic life present, watercourse
showing evidence of being capable of
sediment transport to Class I and II
waters under normal high-water flow
conditions after completion of timber
operations.

Man-made watercourses,
usually downstream, established
domestic, agricultural,
hydroelectric supply or other
beneficial use.

WLPZ Width (ft) – Distance from top of bank to the edge of WLPZ < 30 % Slope 75 50 Sufficient to prevent the degradation of downstream beneficial uses of water.

Determined on a site-specific basis.
30-50 % Slope 100 75
>50 % Slope 150 100
Source: 14 CCR Section 916.5 [936.5, 956.5] (February 2019 version)

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-39 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
The following WLPZ protections will be applied for all treatments:
 Treatment activities with WLPZs will retain at least 75 percent surface cover and undisturbed area to act as a filter strip for raindrop energy dissipation and for wildlife habitat. If this percentage is reduced a qualified RPF will provide the project proponent with a site- and/or treatment activity-specific explanation for the percent surface cover reduction, which will be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced percent as explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report). This requirement is based on 14 CCR Section 916.4 [936.4, 956.4] Subsection (b)(6) (February 2019 version) and 14 CCR Section 916.5 (February 2019 version).  Equipment, including tractors and vehicles, must not be driven in wet areas or WLPZs, except over existing roads or watercourse crossings where vehicle tires or tracks remain dry.  Equipment used in vegetation removal operations will not be serviced in WLPZs, within wet meadows or other wet areas, or in locations that would allow grease, oil, or fuel to pass into lakes, watercourses, or wet areas.  WLPZs will be kept free of slash, debris, and other material that harm the beneficial uses of water. Accidental deposits will be removed immediately.
 Burn piles will be located outside of WLPZs.
 No fire ignition (nor use of associated accelerants) will occur within WLPZs however low intensity backing fires may be allowed to enter or spread into WLPZs.
 Within Class I and Class II WLPZs, locations where project operations expose a continuous area of mineral soil 800 square feet or larger shall be treated for reduction of soil loss. Treatment shall occur prior to October 15th and disturbances that are created after October 15th shall be treated within 10 days. Stabilization measures shall be selected that will prevent significant movement of soil into water bodies and may include but are not limited to mulching, rip-rap, grass seeding, or chemical soil stabilizers.  Where mineral soil has been exposed by project operations on approaches to watercourse crossings of Class I, II, or III within a WLPZ, the disturbed area shall be stabilized to the extent necessary to prevent the discharge of soil into watercourses or lakes in amounts that would adversely affect the quality and beneficial uses of the watercourse.
 Where necessary to protect beneficial uses of water from project operations, protection measures such as seeding, mulching, or replanting shall be used to retain and improve the natural ability of the ground cover within the WLPZ to filter sediment, minimize soil erosion, and stabilize banks of watercourses and lakes.  Equipment limitation zones (ELZs) will be designated adjacent to Class III and Class IV watercourses with minimum widths of 25 feet where side-slope is less than 30 percent and 50 feet where side-slope is 30 percent or greater. An RPF will describe the limitations of heavy equipment within the ELZ and, where appropriate, will include additional measures to protect the beneficial uses of water.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-40 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
Proposed Revision to SPR HYD-4
A revision to the SPR is proposed to establish the WLPZs for only the watercourses within 300 feet of the manual, mechanical, prescribed pile burning, and herbicide treatments.

An excerpt of the original language of SPR HYD-4 is as follows:

The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (February 2019 version).

The SPR revision modifies the SPR to state the following:

The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) within 300 feet of mechanical, manual, herbicide application, and prescribed pile burning treatment or staging areas on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (February 2019 version).

SPR HYD-5: Protect Non-Target Vegetation and Special-status Species from Herbicides The project proponent will implement the following measures when applying herbicides:
 Locate herbicide mixing sites in areas devoid of vegetation and where there is no potential of a spill reaching non-target vegetation or a waterway.
 Use only herbicides labeled for use in aquatic environments when working in riparian habitats or other areas where there is a possibility the herbicide could come into direct contact with water. Only hand application of herbicides will be allowed in riparian habitats and only during low-flow periods or when seasonal streams are dry.  No terrestrial or aquatic herbicides will be applied within WLPZs of Class I and II watercourses, if feasible. If this is not feasible, hand application of herbicides labeled for use in aquatic environments may be used within the WLPZ provided that the project proponent notifies the applicable regional water quality control board no fewer than 15 days prior to herbicide application. The feasibility of avoiding herbicide application within WLPZ of Class I and II watercourses will be determined by the project proponent and may be based on whether doing so will preclude achieving CalVTP program objectives, including, but not limited to, protection of vulnerable communities. The reasons for infeasibility will be documented in the PSA.  No herbicides will be applied within a 50-foot buffer of ESA or CESA listed plant species or within 50 feet of dry vernal pools.
 For spray applications in and adjacent to habitats suitable for special-status species, use herbicides containing dye (registered for aquatic use by DPR, if warranted) to prevent overspray.  Application will cease when weather parameters exceed label specifications or when sustained winds at the site of application exceeds 7 miles per hour (whichever is more conservative).  No herbicide will be applied during precipitation events or if precipitation is forecast 24 hours before or after project activities.

This SPR applies to herbicide treatment activities and all treatment types, including treatment maintenance.

During herbicide
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-41 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR HYD-6: Protect Existing Drainage Systems
If a treatment activity is adjacent to a roadway with stormwater drainage infrastructure, the existing stormwater drainage infrastructure will be marked prior to ground disturbing activities. If a drainage structure or infiltration system is inadvertently disturbed or modified during project activities, the project proponent will coordinate with owner of the system or feature to repair any damage and restore pre-project drainage conditions. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Mark existing stormwater
drainage infrastructure
prior to ground
disturbing activities; if a
drainage structure or
infiltration system is
inadvertently disturbed
or modified during
treatment, coordinate
with owner to repair
damage, and restore
pre-project drainage
conditions
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Noise Standard Project Requirements
SPR NOI-1: Limit Heavy Equipment Use to Daytime Hours
The project proponent will require that operation of heavy equipment associated with treatment activities (heavy off-road equipment, tools, and delivery of equipment and materials) will occur during daytime hours if such noise would be audible to receptors (e.g., residential land uses, schools, hospitals, places of worship). Cities and counties in the treatable landscape typically restrict construction-noise (which would apply to vegetation treatment noise) to particular daytime hours. If the project proponent is subject to local noise ordinance, it will adhere to those to the extent the project is subject to them. If the applicable jurisdiction does not have a noise ordinance or policy restricting the time-of-day when noise-generating activity can occur noise-generating vegetation treatment activity will be limited to the hours of 7:00 a.m. to 6:00 p.m., Monday through Saturday, and between 9:00 a.m. and 6:00 p.m. on Sunday and federal holidays. If the project proponent is not subject to local ordinances (e.g., CAL FIRE), it will adhere to the restrictions stated above or may elect to adhere to the restrictions identified by the local ordinance encompassing the treatment area. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR NOI-2: Equipment Maintenance
The project proponent will require that all powered treatment equipment and power tools will be used and maintained according to manufacturer specifications. All diesel- and gasoline-powered treatment equipment will be properly maintained and equipped with noise-reduction intake and exhaust mufflers and engine shrouds, in accordance with manufacturers’ recommendations. This SPR applies to all activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR NOI-3: Engine Shroud Closure
The project proponent will require that engine shrouds be closed during equipment operation. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

During mechanical
treatment activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-42 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
SPR NOI-4: Locate Staging Areas Away from Noise-Sensitive Land Uses The project proponent will locate treatment activities, equipment, and equipment staging areas away from nearby noise-sensitive land uses (e.g., residential land uses, schools, hospitals, places of worship), to the extent feasible, to minimize noise exposure. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR NOI-5: Restrict Equipment Idle Time
The project proponent will require that all motorized equipment be shut down when not in use. Idling of equipment and haul trucks will be limited to 5 minutes. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
SPR NOI-6: Notify Nearby Off-Site Noise-Sensitive Receptors For treatment activities utilizing heavy equipment, the project proponent will notify noise-sensitive receptors (e.g., residential land uses, schools, hospitals, places of worship) located within 1,500 feet of the treatment activity.

Notification will include anticipated dates and hours during which treatment activities are anticipated to occur and contact information, including a daytime telephone number, of the project representative. Recommendations to assist noise-sensitive land uses in reducing interior noise levels (e.g., closing windows and doors) will also be included in the notification. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

Prior to mechanical
treatment activities
within 1,500 feet of
noise-sensitive
receptors
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Recreation Standard Project Requirements
SPR REC-1: Notify Recreational Users of Temporary Closures If a treatment activity would require temporary closure of a public recreation area or facility, the project proponent will coordinate with the owner/manager of that recreation area or facility. If temporary closure of a recreation area or facility is required, the project proponent will work with the owner/manager to post notifications of the closure at least 2 weeks prior to the commencement of the treatment activities. Additionally, notification of the treatment activity will be provided to the Administrative Officer (or equivalent official responsible for distribution of public information) of the county(ies) in which the affected recreation area or facility is located. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

If a temporary closure
of a public recreation
area or facility is
required, post
notifications at least 14
days prior to treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Transportation Standard Project Requirements
SPR TRAN-1: Implement Traffic Control during Treatments Prior to initiating vegetation treatment activities the project proponent will work with the agency(ies) with jurisdiction over affected roadways to determine if a Traffic Management Plan (TMP) is needed. A TMP will be needed if traffic generated by the project would result in obstructions, hazards, or delays exceeding applicable jurisdictional standards along access routes for individual vegetation treatments. If needed, a TMP will be prepared to provide measures to reduce potential traffic obstructions, hazards, and service level degradation along affected roadway facilities. The scope of the TMP will depend on the type, intensity, and duration of the Prepare TMP prior to
treatment and
implement during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-43 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring Entity
specific treatment activities under the CalVTP. Measures included in the TMP could include (but are not be limited to) construction signage to provide motorists with notification and information when approaching or traveling along the affected roadway facilities, flaggers for lane closures to provide temporary traffic control along affected roadway facilities, treatment schedule restrictions to avoid seasons or time periods of peak vehicle traffic, haultrip, delivery, and/or commute time restrictions that would be implemented to avoid peak traffic days and times along affected roadway facilities. If the TMP identifies impacts on transportation facilities outside of the jurisdiction of the project proponent, the TMP will be submitted to the agency with jurisdiction over the affected roadways prior to commencement of vegetation treatment projects. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Smoke generated during prescribed burn operations could potentially affect driver visibility and traffic operations along nearby roadways. Direct smoke impacts to roadway visibility and indirect impacts related to driver distraction will be considered during the planning phase of burning operations. Smoke impacts and smoke management practices specific to traffic operations during prescribed fire operations will be identified and addressed within the TMP. The TMP will include measures to monitor smoke dispersion onto public roadways, and traffic control operations will be initiated in the event burning operations could affect traffic safety along any roadways. This SPR applies only to prescribed burn treatment activities and all treatment types, including treatment maintenance.

Public Services and Utilities Standard Project Requirements SPR UTIL-1: Solid Organic Waste Disposition Plan
For projects requiring the disposal of material outside of the treatment area, the project proponent will prepare an Organic Waste Disposition Plan prior to initiating treatment activities. The Solid Organic Waste Disposition Plan will include the amount (e.g., tons) of solid organic waste to be managed onsite (i.e., scattering of wood materials, generating unburned piles, and pile burning) and transported offsite for processing (i.e., biomass power plant, wood product processing facility, composting). If the project proponent intends to transport solid organic waste offsite, the Solid Organic Waste Disposition Plan will clearly identify the location and capacity of the intended processing facility, consistent with local and state regulations to demonstrate that adequate capacity exists to accept the treated materials. This SPR applies only to mechanical and manual treatment activities and all treatment types, including treatment maintenance.

Prepare an Organic
Waste Disposition Plan
prior to mechanical or
manual treatment
activities; implement
plan during mechanical
or manual treatment
activities
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-44 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Aesthetics
Mitigation Measure AES-3: Conduct Visual Reconnaissance for Non-Shaded Fuel Breaks and Relocate or Feather and Screen Publicly Visible Non-Shaded Fuel Breaks
The project proponent will conduct a visual reconnaissance of the treatment area prior to implementing nonshaded fuel breaks to observe the surrounding landscape and determine if public viewing locations, including scenic vistas, public trails, and state scenic highways, have views of the proposed treatment area. If none are identified, the non-shaded fuel break may be implemented without additional visual mitigation.

If the project proponent identifies public viewing points, including heavily used scenic vistas, public trails, recreation areas, and state scenic highways with lengthy views (i.e., longer than a few seconds) of a proposed non-shaded fuel break treatment area, the project proponent will, prior to implementation, attempt to identify any feasible change in location of the fuel break to reduce its visibility from public viewpoints. If no feasible location changes exist that would reduce impacts to public viewers and achieve the intended wildfire risk reduction objectives of the proposed non-shaded fuel break, the project proponent will implement, where feasible, a shaded fuel break rather than a non-shaded fuel break, if the shaded fuel break would achieve the intended wildfire risk reduction objectives. With the shaded fuel break, the project proponent will thin and feather adjacent vegetation to break up the linear edges of the fuel break and strategically preserve vegetation at the edge of the fuel break, as feasible, to help screen public views and minimize the contrast between the fuel break and surrounding vegetation.

Conduct visual
reconnaissance prior to
implementing nonshaded fuel breaks; if
public viewing points
identified, attempt to
relocate, or implement
a shaded fuel break, if
feasible
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Air Quality
Mitigation Measure AQ-1: Implement On-Road Vehicle and Off-Road Equipment Exhaust Emission Reduction Techniques
Where feasible, project proponents will implement emission reduction techniques to reduce exhaust emissions from off-road equipment. It is acknowledged that due to cost, availability, and the limits of current technology, there may be circumstances where implementation of certain emission reduction techniques will not feasible. The project proponent will document the emission reduction techniques that will be applied and will explain the reasons other techniques that could reduce emissions are infeasible.

Techniques for reducing emissions may include, but are not limited to, the following:
 Diesel-powered off-road equipment used in construction will meet EPA’s Tier 4 emission standards as defined in 40 CFR 1039 and comply with the exhaust emission test procedures and provisions of 40 CFR Parts 1065 and 1068. Tier 3 models can be used if a Tier 4 version of the equipment type is not yet produced by manufacturers. This measure can also be achieved by using battery-electric off-road equipment as it becomes available. Prior to implementation of treatment activities, the project proponent will demonstrate the ability to supply the compliant equipment. A copy of each unit’s certified tier specification or model year specification and operating permit (if applicable) will be available upon request at the time of mobilization of each unit of equipment.

During treatment Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-45 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
 Use renewable diesel fuel in diesel-powered construction equipment. Renewable diesel fuel must meet the following criteria:
 meet California’s Low Carbon Fuel Standards and be certified by CARB Executive Officer;  be hydrogenation-derived (reaction with hydrogen at high temperatures) from 100 percent biomass material (i.e., non-petroleum sources), such as animal fats and vegetables;  contain no fatty acids or functionalized fatty acid esters; and  have a chemical structure that is identical to petroleum-based diesel and complies with American Society for Testing and Materials D975 requirements for diesel fuels to ensure compatibility with all existing diesel engines.
 Electric- and gasoline-powered equipment will be substituted for diesel-powered equipment.  Workers will be encouraged to carpool to work sites, and/or use public transportation for their commutes.

Off-road equipment, diesel trucks, and generators will be equipped with Best Available Control Technology for emission reductions of NOX and PM.

Archaeological, Historical, and Tribal Cultural Resources Mitigation Measure CUL-2: Protect Inadvertent Discoveries of Unique Archaeological Resources or Subsurface Historical Resources
If any prehistoric or historic-era subsurface archaeological features or deposits, including locally darkened soil (“midden”), that could conceal cultural deposits, are discovered during ground-disturbing activities, all grounddisturbing activity within 100 feet of the resources will be halted and a qualified archaeologist will assess the significance of the find. The qualified archaeologist will work with the project proponent to develop a primary records report that will comply with applicable state or local agency procedures. If the archaeologist determines that further information is needed to evaluate significance, a data recovery plan will be prepared. If the find is determined to be significant by the qualified archaeologist (i.e., because the find constitutes a unique archaeological resource, subsurface historical resource, or tribal cultural resource), the archaeologist will work with the project proponent to develop appropriate procedures to protect the integrity of the resource.

Procedures could include preservation in place (which is the preferred manner of mitigating impacts to archaeological sites), archival research, subsurface testing, or recovery of scientifically consequential information from and about the resource. Any find will be recorded standard DPR Primary Record forms (Form DPR 523) will be submitted to the appropriate regional information center.

During grounddisturbing activitiesSanta Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Biological Resources
Mitigation Measure BIO-1a: Avoid Loss of Special-Status Plants Listed under ESA or CESA If listed plants are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent will avoid and protect these species by establishing a no-disturbance buffer around the area occupied by listed plants and marking the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway), exceptions to this requirement are listed later in this measure.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Attachment A Ascent
Saratoga Fire Protection District
A-46 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
The no-disturbance buffers will generally be a minimum of 50 feet from listed plants, but the size and shape of the buffer zone may be adjusted if a qualified RPF or botanist determines that a smaller buffer will be sufficient to avoid killing or damaging listed plants or that a larger buffer is necessary to sufficiently protect plants from the treatment activity. The appropriate buffer size will be determined based on plant phenology at the time of treatment (e.g., whether the plants are in a dormant, vegetative, or flowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain. For example, painton or wicking application of herbicides to invasive plants may be implemented within 50 feet of listed plant species without posing a risk, especially if the listed plants are dormant at the time of application. Consideration of factors such as site hydrology, changes in light, edge effects, and potential introduction of invasive plants and noxious weeds may inform the determination of buffer width. If a no-disturbance buffer is reduced below 50 feet from a listed plant, a qualified RPF or botanist will provide the project proponent with a site- and/or treatment activity-specific explanation for the buffer reduction, which will be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced buffer as explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report) with a science-based justification for the deviation. No fire ignition (and associated use of accelerants) will occur within 50 feet of listed plants.

For species listed under ESA or CESA, if the project proponent cannot avoid loss by implementing no-disturbance buffers, the project proponent will implement Mitigation Measure BIO-1c.

The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or botanist, in consultation with CDFW and USFWS, as appropriate depending on species status and location, that the listed plants would benefit from treatment in the occupied habitat area even though some of the listed plants may be lost during treatment activities. For a treatment to be considered beneficial to listed special-status plants, the qualified RPF or botanist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific studies demonstrating that the species (or similar species) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to listed plants, no compensatory mitigation for loss of individuals will be required.

Mitigation Measure BIO-1b: Avoid Loss of Special-Status Plants Not Listed Under ESA or CESA If non-listed special-status plant species (i.e., species not listed under ESA or CESA, but meeting the definition of special-status as stated in Section 3.6.1 of the Program EIR) are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent will implement the following measures to avoid loss of individuals and maintain habitat function of occupied habitat:
 Physically avoid the area occupied by the special-status plants by establishing a no-disturbance buffer around the area occupied by species and marking the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). The no-disturbance buffers will generally be a minimum of 50 feet from special-status plants, but the size and shape of the buffer zone may be adjusted if a Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-47 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
qualified RPF or botanist determines that a smaller buffer will be sufficient to avoid loss of or damaging to special-status plants or that a larger buffer is necessary to sufficiently protect plants from the treatment activity.

The appropriate size and shape of the buffer zone will be determined by a qualified RPF or botanist and will depend on plant phenology at the time of treatment (e.g., whether the plants are in a dormant, vegetative, or flowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain. Consideration of factors such as site hydrology, changes in light, edge effects, and potential introduction of invasive plants and noxious weeds may inform an appropriate buffer size and shape.  Treatments may be conducted within this buffer if the potentially affected special-status plant species is a geophytic, stump-sprouting, or annual species, and the treatment can be conducted outside of the growing season (e.g., after it has completed its annual life cycle) or during the dormant season using only treatment activities that would not damage the stump, root system or other underground parts of special-status plants or destroy the seedbank.
 Treatments will be designed to maintain the function of special-status plant habitat. For example, for a fuel break proposed in treatment areas occupied by special-status plants, if the removal of shade cover would degrade the special-status plant habitat despite the requirement to physically or seasonally avoid the specialstatus plant itself, habitat function would be diminished and the treatment would need to be modified or precluded from implementation.
 No fire ignition (and associated use of accelerants) will occur within the special-status plant buffer.

A qualified RPF or botanist with knowledge of the special-status plant species habitat and life history will review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual effects of the treatment would be significant under CEQA because implementation of the treatment would not maintain habitat function of the special-status plant habitat (i.e., the habitat would be rendered unsuitable) or because the loss of special-status plants would substantially reduce the number or restrict the range of a special-status plant species. If the project proponent determines the impact on special-status plants would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status plants or degradation of occupied habitat would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-1c will be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or botanist that the special-status plants would benefit from treatment in the occupied habitat area even though some of the non-listed special-status plants may be killed during treatment activities. For a treatment to be considered beneficial to non-listed special-status plants, the qualified RPF or botanist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific studies demonstrating that the species (or similar species) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to special-status plants, no compensatory mitigation will be required.

Attachment A Ascent
Saratoga Fire Protection District
A-48 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Mitigation Measure BIO-1c: Compensate for Unavoidable Loss of Special-Status Plants If significant impacts on listed or non-listed special-status plants cannot feasibly be avoided as specified under the circumstances described under Mitigation Measures BIO-1a and 1b, the project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant impacts that require compensatory mitigation and describes the compensatory mitigation strategy being implemented and how unavoidable losses of special-status plants will be compensated. The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan. If the special-status plant taxa are listed under ESA or CESA, the plan will be submitted to CDFW and/or USFWS (as appropriate) for review and comment.

The first priority for compensatory mitigation will be preserving and enhancing existing populations outside of the treatment area in perpetuity, or if that is not an option because existing populations that can be preserved in perpetuity are not available, one of the following mitigation options will be implemented by the project proponent instead:
 creating populations on mitigation sites outside of the treatment area through seed collection and dispersal (annual species) or transplantation (perennial species);  purchasing mitigation credits from a CDFW- or USFWS-approved conservation or mitigation bank in sufficient quantities to offset the loss of occupied habitat; and
 if the affected special-status plants are not listed under ESA or CESA, compensatory mitigation may include restoring or enhancing degraded habitats so that they are made suitable to support special-status plant species in the future.

If relocation efforts are part of the Compensatory Mitigation Plan, the plan will include details on the methods to be used, including collection, storage, propagation, receptor site preparation, installation, long-term protection and management, monitoring and reporting requirements, success criteria, and remedial action responsibilities should the initial effort fail to meet long-term monitoring requirements. The following performance standards will be applied for relocation:
 the extent of occupied area will be substantially similar to the affected occupied habitat and will be suitable for self-producing populations. Re-located/re-established populations will be considered suitable for selfproducing when:
 habitat conditions allow for plants to reestablish annually for a minimum of 5 years with no human intervention, such as supplemental seeding; and
 reestablished habitats contain an occupied area comparable to existing occupied habitat areas in similar habitat types in the region.

If preservation of existing populations or creation of new populations is part of the mitigation plan, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands and actions (e.g., the number and type of credits, location of mitigation bank or easement, restoration or enhancement actions), parties responsible for the long-term management of the land, and the legal and funding mechanisms (e.g., Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-49 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
holder of conservation easement or fee title). The project proponent will submit evidence that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory plant populations will be preserved in perpetuity.

If mitigation includes dedication of conservation easements, purchase of mitigation credits, or other offsite conservation measures, the details of these measures will be included in the mitigation plan, including information on responsible parties for long-term management, conservation easement holders, long-term management requirements, funding assurances, and success criteria such as those listed above and other details, as appropriate to target the preservation of long term viable populations.

If mitigation includes restoring or enhancing habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored habitat.

If the loss of occupied habitat cannot be offset (e.g., if preservation of existing populations or creation of new populations through relocation efforts are not available for a certain species), and as a result treatment activities would substantially reduce the number or restrict the range of listed plant species, then the treatment will not qualify as within the scope of this Program EIR.

Compensatory mitigation may be satisfied through compliance with permit conditions, or other authorizations obtained by the project proponent (e.g., incidental take permit for state-listed plants), if these requirements are equally or more effective than the mitigation identified above.

Mitigation Measure BIO-2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed Wildlife Species and California Fully Protected Species (All Treatment Activities) If California Fully Protected Species or species listed under ESA or CESA are observed during reconnaissance surveys (conducted pursuant to SPR BIO-1) or focused or protocol-level surveys (conducted pursuant to SPR BIO-10), the project proponent will avoid adverse effects to the species by implementing the following.

Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent will implement one of the following two measures to avoid mortality, injury, or disturbance of individuals:

1. Treatment will not be implemented within the occupied habitat. Any treatment activities outside occupied habitat will be a sufficient distance from the occupied habitat such that mortality, injury, or disturbance of the species will not occur, as determined by a qualified RPF or biologist using the most current and commonlyaccepted science and considering published agency guidance; OR

2. Treatment will be implemented outside the sensitive period of the species’ life history (e.g., outside the breeding or nesting season) during which the species may be more susceptible to disturbance, or disturbance could result in loss of eggs or young. For species present year-round, CDFW and/or USFWS/NOAA Fisheries Prior to, during, and
after treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party

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will be consulted to determine if there is a period of time within which treatment could occur that would avoid mortality, injury, or disturbance of the species.
 For species listed under ESA or CESA, if the project proponent cannot avoid mortality, injury or disturbance by implementing one of the two options listed above, the project proponent will implement Mitigation Measure BIO-2c.

Injury or mortality of California Fully Protected Species is prohibited pursuant to Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code and will be avoided.

Maintain Habitat Function
 The project proponent will design treatment activities to maintain the habitat function, by implementing the following:
 While performing review and surveys for SPR BIO-1 and SPR BIO-10, a qualified RPF or biologist will identify any habitat features that are necessary for survival (e.g., habitat necessary for breeding, foraging, shelter, movement) of the affected wildlife species (e.g., trees with complex structure, trees with large cavities, trees with nesting platforms; dens; tree snags; large raptor nests [including inactive nests]; downed woody debris; food sources). These habitat features will be marked and treatments applied to the features will be designed to minimize or avoid the loss or degradation of suitable habitat for listed species during treatments.

Identification and treatment of these features will be based on the life history and habitat requirements of the affected species and the most current, commonly accepted science.  If it is determined during implementation of SPR BIO-1 and SPR BIO-10 that listed or fully protected wildlife with specific requirements for high canopy cover (e.g., Humboldt marten, fisher, spotted owl, coastal California gnatcatcher, riparian woodrat) are present within a treatment area, then tree or shrub canopy cover within existing suitable areas will be retained at the percentage preferred by the species (as determined by expert opinion, published habitat association information, or other documented standards that are commonly accepted [e.g., 50 percent for coastal California gnatcatcher]) such that habitat function is maintained.

A qualified RPF or biologist will determine if, after implementation of the impact avoidance measures listed above, the habitat function will remain for the affected species after implementation of the treatment. Because this measure pertains to species listed under CESA or ESA or fully protected species, the qualified RPF or biologist will consult with CDFW and/or USFWS/NOAA Fisheries regarding the determination that habitat function is maintained. If the lead agency determines after consultation that the treatment will not maintain habitat function for the special-status species, the project proponent will implement Mitigation Measure BIO-2c.

Project-Specific Guidance to Implement Mitigation Measure BIO-2a California Red-Legged Frog
If California red-legged frog is assumed present or detected during protocol-level surveys (pursuant to SPR BIO10), the following measures will be implemented:
 Pretreatment surveys and biological monitoring. Pretreatment visual surveys will be performed daily by a qualified RPF, biologist, biological technician, or trained designee prior to implementation of prescribed

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burning, mechanical treatments, and manual treatments within 300 feet of Class I or Class II streams and within or adjacent to other sensitive habitat areas (e.g., wet intermittent streams, wet seeps) during the dispersal season (October 1–April 1) or within 24 hours following a rain event greater than one-quarter inch.

Surveys and monitoring will be performed year-around prior to any activities within 30 feet of Class I or Class II streams and within or adjacent to other sensitive habitat areas (e.g., wet Class III streams, wet seeps).  If a California red-legged frog is found during pretreatment surveys or enters the project site during treatment activities, all work will stop within a no-disturbance buffer of 100 feet around the individual unless it is determined by the qualified RPF or biologist that a different-sized buffer is appropriate to avoid disturbance, injury, or mortality. Treatment activities will cease within the buffer until the animal leaves on its own and the occurrence will be reported to the qualified biologist and USFWS.  If California red-legged frog is found during pretreatment surveys or enters the project site during treatment activities, the specific habitat features used by the frog when detected will be evaluated by a qualified RPF or biologist for habitat retention, if habitat retention will meet the project goals.  If operators need to move or treat large woody debris greater than 12 inches in diameter, that piece of woody debris (if located within 300 feet of a Class I or Class II water) will be evaluated for California red-legged frog by a qualified biologist, qualified professional, RPF, RPF-supervised designee, or a contractor who has been through the environmental awareness training.
 All mechanized equipment will shut down for 24 hours following any precipitation event of 0.20 inches to less than 1 inch, 48 hours following any precipitation event 1 inch to less than 2 inches, and 72 hours following any precipitation event greater or equal to 2 inches. Manual treatments, mechanical treatments where the machinery is operated on established roads and masticator heads are kept 12 inches from the ground, and stationary chipper operations from compacted surfaces may continue.  No mechanized operations will occur year-round (including track chippers unless on an existing road) in a Watercourse and Lake Protection Zone (WLPZ) of a Class I or Class II watercourse, within 30 feet of a Class III watercourse, or adjacent to other potential sensitive habitat areas (e.g., wet seeps). Only manual treatments may occur in these areas. If manual treatments are proposed, a qualified RPF or biologist must conduct a pretreatment survey in the area no more than 7 days prior to operations.  No heavy equipment shall be fueled within 65 feet of any watercourse.

California tiger salamander
If the treatment area includes California tiger salamander suitable upland habitat (as identified by a qualified RPF or biologist and defined in SPR BIO-1) and the species is assumed present or confirmed present based on the results of SPR BIO-10 surveys, the project proponent will implement the following measures:
 Pretreatment visual surveys will be performed daily by a qualified RPF, qualified biologist, or biological technician during the dispersal season (November 1–April 30) for manual tree and snag removal, mechanical treatments, prescribed burning, or herbicide application other than cut-stump and basal bark application within upland habitat suitable for the species.

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 If a California tiger salamander is found during pretreatment surveys or enters the project site during treatment activities, all work will stop within a no-disturbance buffer of 100 feet around the individual unless it is determined by the qualified RPF or biologist that a different-sized buffer is appropriate to avoid disturbance, injury, or mortality. Treatment activities will cease within the buffer until the animal leaves on its own, the occurrence will be reported to the qualified RPF or biologist, and both CDFW and USFWS will be notified.  Surveys for mammal burrows potentially suitable for use by California tiger salamander will be conducted by a qualified biologist or qualified RPF in upland habitat determined to be suitable for California tiger salamander prior to mechanical treatments conducted off of compacted surfaces or pile burning during any time of year.  Mechanized equipment that may cause burrow collapse (tracked and other heavy equipment) will be driven on compacted surfaces or greater than 50 feet away from mammal burrows determined to be suitable for use by California tiger salamander by a qualified biologist or qualified RPF  Burn piles will not be placed within 50 feet of mammal burrows within upland habitat suitable for California tiger salamander, as determined by a qualified biologist or qualified RPF.

Foothill yellow-legged frog
 If focused surveys pursuant to SPR BIO-10 detect foothill yellow-legged frogs within the treatment area, or presence is assumed based on suitable habitat within the treatment area, daily inspections will be required.  Daily inspection of the day’s treatment area within suitable habitat will be performed by the qualified biologist, qualified RPF, biological technician, or trained designee. The training for designees will include identification of foothill yellow-legged frog, procedures to follow for daily inspection of appropriate habitat features immediately before treatment occurs, and proper procedures to implement if a frog is present (e.g., establish a no-disturbance buffer zone of a size that will appropriately avoid foothill yellow-legged frog where treatment will not occur until the frog has left the area, halt activities if a foothill yellow-legged frog is observed during treatment, allow foothill yellow-legged frogs to move out of the treatment area on their own accord, notify CDFW if foothill yellow-legged frogs are observed).

Bald eagle
 If active bald eagle nests are detected during focused surveys, a no-disturbance buffer of at least 0.5 miles will be established for ground and aerial treatment activities. For helicopter and drone operations, this buffer will be a vertical buffer as well as a horizontal buffer (0.5 miles of horizontal distance or 2,640 feet AGL). No treatment activities will occur within this buffer until the chicks have fledged or the nest is otherwise no longer active as determined by a qualified RPF or biologist. The buffer may be adjusted by a qualified RPF or biologist based on vegetative and topographic screening and other factors.  If active bald eagle communal roosts are detected during focused surveys, a vertical and horizontal nodisturbance buffer of 1,000 feet for helicopter and drone operations will be implemented.  Trees where communal roosts are detected during focused surveys will be retained.

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Burrowing owl
 If an active burrowing owl burrow or a potentially active burrow that is assumed to be occupied is detected in the overwintering season (September 1–January 31) during SPR BIO-10 surveys, a no-disturbance nest buffer of 250 feet will be placed around the burrow. No mechanical or manual treatments, or ground or human disturbance associated with prescribed burning (e.g., control lines, staging areas) and prescribed herbivory (e.g., fence lines, watering infrastructure, staging areas) would occur within this buffer until all burrowing owls have left the burrow (i.e., surveys indicate that no owls have used the burrow for 7 consecutive days) as determined by a qualified biologist or RPF. The buffer distance may be modified by a qualified RPF or biologist based on presence of natural buffers provided by vegetation or topography, nest height above ground, baseline levels of noise and human activity, and expected treatment activities in coordination with CDFW.  Within the year-round range of the species (in the far eastern portion of the WSCLRP area), if an active burrowing owl burrow is detected in the nesting season (February 1–August 31) during SPR BIO-10 surveys, a no-disturbance nest buffer of 1,640 feet will be established around active burrowing owl burrows. If the same burrow is active during the overwintering season (September 1–January 31), a no-disturbance nest buffer of 250 feet will be placed around the burrow during the overwintering season. No mechanical or manual treatments, or ground or human disturbance associated with prescribed burning (e.g., control lines, staging areas) and prescribed herbivory (e.g., fence lines, watering infrastructure, staging areas) would occur within this buffer until all burrowing owls have left the burrow (i.e., surveys indicate that no owls have used the burrow for 7 consecutive days) as determined by a qualified biologist or RPF. The buffer distance may be modified by a qualified RPF or biologist based on presence of natural buffers provided by vegetation or topography, nest height above-ground, baseline levels of noise and human activity, and expected treatment activities in coordination with CDFW.

California condor
 Project activities will be temporarily halted if any California condors are observed within the project area prior to the start of work. California condors will be allowed to depart on their own before project activities resume.

California condors that arrive in the project area or approach work crews while work is on-going will be hazed (additional details regarding hazing are described under SPR BIO-2). Work crews will inform the project biologist should any California condor-related work stoppages take place.  Garbage removal will be required in all contracts. Work crews involved in all project activities will remove all trash associated with this project and ensure that it is disposed of properly.  All personnel involved in implementing the project will be briefed on the importance of not leaving hazardous materials exposed and daily removal of all garbage fragments to maintain condor health.  Work crews will store all project materials, tools, hardware, equipment, and loose items in a manner that will prevent their removal or ingestion by California condors and other wildlife.  Work crews will place all materials that are liquid, granular, or powder in sealed leak-proof containers and store in a manner that prevents access by California condors and other wildlife.  Work crews will keep all parked vehicles and equipment free of leaks.

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Least Bell’s vireo
To avoid impacts to least Bell’s vireo, if protocol surveys for nests of least Bell’s vireo detect an active nest, a nodisturbance buffer for ground and aerial treatment activities of at least 250 feet will be established around the active nest. For helicopter and drone operations, this buffer will be a vertical buffer as well as a horizontal buffer, 250 feet above ground level (AGL). No treatment activities will occur within these buffers until the chicks have fledged or the nest is otherwise no longer active as determined by a qualified RPF or biologist. These buffers may be adjusted by a qualified RPF or biologist based on vegetative and topographic screening and other factors.

Tricolored blackbird
To avoid impacts tricolored blackbird, if protocol surveys detect an active nest, a no-disturbance buffer for ground and aerial treatments activities of at least 250 feet will be established around the active nest. For helicopter and drone operations, this buffer will be a vertical buffer as well as a horizontal buffer, 250 feet AGL.

No treatment activities will occur within these buffers until the chicks have fledged or the nest is otherwise no longer active as determined by a qualified RPF or biologist. These buffers may be adjusted by a qualified RPF or biologist based on vegetative and topographic screening and other factors.

Other Special-Status Birds
If active special-status bird nests are detected during focused surveys, a no-disturbance buffer for ground and aerial treatments activities of at least 1 mile will be established around active nests for golden eagle, 0.5 miles for bald eagle nests and Swainson’s hawk nests, and 0.25 miles for white-tailed kite nests. For helicopter and drone operations, this buffer will be a vertical buffer as well as a horizontal buffer (e.g., for golden eagle, 1 mile of horizontal distance or 5,280 feet AGL). No treatment activities will occur within these buffers until the chicks have fledged or the nest is otherwise no longer active as determined by a qualified RPF or biologist. These buffers may be adjusted by a qualified RPF or biologist based on vegetative and topographic screening and other factors.

Mountain lion
 Within 14 days prior to the start of and manual tree and snag removal treatments, mechanical treatments, or prescribed burning, a qualified RPF or biologist will inspect suitable nursery habitat (as determined pursuant to SPR BIO-10) in the part of the treatment area scheduled to be treated during that 14-day period for mountain lion or signs of mountain lion nurseries. The qualified RPF or biologist will also use publicly available data on recent mountain lion sightings, or survey for signs of mountain lion (e.g., tracks, scat, prey items such as a fresh kill) in the vicinity of potential nursery habitat to help determine whether the area may contain an active mountain lion nursery. If no mountain lion or sign of a nursery is observed, treatment activities may begin. If signs of a mountain lion nursery are observed, further investigation will be required to determine if a mountain lion nursery is present (see below).
 If signs of a mountain lion nursery are found during review of publicly available data or during surveys, further investigation will be required to determine if a mountain lion nursery is present. No treatment will occur in the area while further investigation is occurring. Survey methods will include the use of trail cameras, listening for calling kittens and/or other noninvasive methods, as well as coordination with local experts tracking the

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species (if available). Surveys using these noninvasive methods will be conducted for five days and five nights to determine whether a nursery may be present.
 If a nursery is known to occur in the area or further signs of a nursery are detected based on the surveys described above (e.g., lactating adult females or cubs on camera, repeated detections of an adult female in the area, growls or calls from kittens), no-disturbance buffer of at least 2,000 feet (Wilmers et al. 2013) will be applied for 10 weeks. The duration of the buffer may be shortened by the qualified biologist or RPF based on evidence (e.g., trail camera images) that kittens are old enough to move out of harm’s way independently of the female. Treatment activities will not occur within this buffer during this time to avoid disturbance, injury, or mortality of mountain lion nurseries.

Northern California Ringtail
 To avoid mortality or injury to ringtail the following will be implemented when manual and mechanical large snag (i.e., greater than 12 inches DBH) removal or broadcast burning are implemented during the maternity season (April 15–June 30).
 Within 14 days prior to the start of manual and mechanical tree and snag removal or broadcast burning conducted during the ringtail maternity season, a qualified RPF or biologist will conduct a den search in the treatment area to be treated during that 14-day period. The qualified RPF or biologist will search for den structures, such as hollow logs, snags, rock piles, and large trees and snags (i.e., greater than 12 inches DBH) with appropriate cavities (i.e., holes larger than 3 inches in diameter, with cavities extending approximately 12 inches down from the cavity hole). If found, the qualified biologist or RPF will inspect the cavity using a cell phone with a flash or other tools (e.g., borescopes) to determine whether ringtails are present, unless cavities are not safely accessible. Structures (e.g., large trees) with appropriate den habitat, whether verified as occupied or not, will be marked (e.g., with flagging), for avoidance during the maternity season.  Any potential den structures, where the biologist or qualified RPF is not able to determine if the structure is occupied or not, due to safety or access issues, will be retained until the end of the ringtail maternity season (June 30).
 If active ringtail dens are discovered during a den survey or during treatment activities, a no-disturbance buffer of 0.25 mile will be implemented around the den, and manual and mechanical tree and snag removal or broadcast burning that may result in the destruction or disturbance of the den and associated foraging habitat as determined by a qualified biologist or RPF will not proceed within the buffer until at least the end of the ringtail maternity season (June 30). The qualified RPF or biologist will confirm that the den is unoccupied before treatment activities resume. If an active den is discovered, CDFW will be notified of the den and buffer location. CDFW will be provided an opportunity to visit the site and provide technical information on the size and shape of the den buffer.

San Joaquin kit fox
 If the habitat within the treatment area is determined suitable for the species and contains potentially occupied dens (per SPR BIO-10), to avoid mortality, injury, or substantial disturbance to San Joaquin kit fox,