Gilroy City Council
August 3, 2026

Attachment A Ascent
Saratoga Fire Protection District
A-56 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
the following will be implemented during pile burning or mechanical treatments year-round and for all treatment activities implemented during the pupping/natal season (February 1–September 30).  A spotlight survey following the procedures in the San Joaquin Kit Fox Survey Protocol for the Northern Range (USFWS 1999) will be conducted for 10 nights within a 15-day period prior to project implementation for the treatment area and habitat within a 1.0-mile buffer of the treatment area, or the habitat will be assumed to be occupied. If unidentified canids are detected during spotlighting surveys, camera and scent stations will be implemented to identify potential San Joaquin kit fox following the procedures in the San Joaquin Kit Fox Survey Protocol for the Northern Range (USFWS 1999), or the habitat will be assumed to be occupied.  If San Joaquin kit fox are found during walking transects, spotlighting, camera, or scent stations, or if the habitat is assumed to be occupied, all potential dens will be buffered by a minimum of 250 feet (Santa Clara County et al. 2012); pile burning and mechanical treatments will not be conducted within this buffer yearround; and all treatment activities will be avoided within this buffer during the pupping/natal season (February 1–September 30).
 If San Joaquin kit fox are found within the project area, the occurrence will be reported to CDFW and USFWS.

Mitigation Measure BIO-2b: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Other Special-Status Wildlife Species (All Treatment Activities) If other special-status wildlife species (i.e., species not listed under CESA or ESA or California Fully Protected, but meeting the definition of special status as stated in Section 3.6.1 of the Program EIR) 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 or minimize adverse effects to the species by implementing the following.

Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent will implement the following to avoid mortality, injury, or disturbance of individuals:
 For all treatment activities except prescribed burning, the project proponent will establish a no-disturbance buffer around occupied sites (e.g., nests, dens, roosts, middens, burrows, nurseries). Buffer size will be determined by a qualified RPF or biologist using the most current, commonly accepted science and will consider published agency guidance; however, buffers will generally be a minimum of 100 feet, unless site conditions indicate a smaller buffer would be sufficient for protection or a larger buffer would be needed.

Factors to be considered in determining buffer size will include, but not be limited to, the species’ tolerance to disturbance; the presence of natural buffers provided by vegetation or topography; nest height; locations of foraging territory; baseline levels of noise and human activity; and treatment activity. Buffer size may be adjusted if the qualified RPF or biologist determines that such an adjustment would not be likely to adversely affect (i.e., cause mortality, injury, or disturbance to) the species within the nest, den, burrow, or other occupied site. If a no-disturbance buffer is reduced below 100 feet from an occupied site, a qualified RPF or biologist 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 Prior to, during, and
after 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-57 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
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).
 No-disturbance buffers will be marked with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). No activity will occur within the buffer areas until the qualified RPF or biologist has determined that the young have fledged or dispersed; the nest, den, or other occurrence is no longer active; or reducing the buffer would not likely result in disturbance, mortality, or injury. A qualified RPF, biologist, or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment. If treatment activities cause agitated behavior of the individual(s), the buffer distance will be increased, or treatment activities modified until the agitated behavior stops. The qualified RPF, biologist, or biological technician will have the authority to stop any treatment activities that could result in mortality, injury or disturbance to special-status species.
 For prescribed burning, the project proponent will implement the treatment 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, the qualified RPF or biologist will determine the period of time within which prescribed burning could occur that will avoid or minimize mortality, injury, or disturbance of the species. The project proponent may consult with CDFW and/or USFWS for technical information regarding appropriate limited operating periods.

Maintain Habitat Function
 For all treatment activities, 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; tree snags; large raptor nests [including inactive nests]; downed woody debris).

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 special-status wildlife with specific requirements for high canopy cover (e.g., northern goshawk, Sierra Nevada snowshoe hare) 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) such that the habitat function is maintained.

Attachment A Ascent
Saratoga Fire Protection District
A-58 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
 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. The qualified RPF or biologist may consult with CDFW and/or USFWS for technical information regarding habitat function.

A qualified RPF or biologist with knowledge of the special-status wildlife 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 will not maintain habitat function of the special-status wildlife species’ habitat or because the loss of special-status wildlife would substantially reduce the number or restrict the range of a special-status wildlife species. If the project proponent determines the impact on special-status wildlife would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status wildlife or degradation of occupied habitat would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-2c will be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or biologist that the non-listed special-status wildlife would benefit from treatment in the occupied habitat area even though some of the non-listed special-status wildlife may be killed, injured, or disturbed during treatment activities. For a treatment to be considered beneficial to non-listed special-status wildlife, the qualified RPF or biologist 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 wildlife, no compensatory mitigation will be required. The qualified RPF or biologist may consult with CDFW and/or USFWS for technical information regarding the determination that a non-listed special-status species would benefit from the treatment.

Project-Specific Guidance to Implement Mitigation Measure BIO-2b Southwestern pond turtle
 If southwestern pond turtles are detected during SPR BIO-10 focused surveys, biological monitoring by a qualified RPF, biologist, biological technician, or trainee during prescribed burning, mechanical treatments, manual tree and snag removal, and herbicide application other than cut-stump and basal bark application activities within or adjacent to sensitive habitat areas will be implemented to avoid injury to or mortality of individual southwestern pond turtle.
 If the qualified RPF or biologist detects a southwestern pond turtle during treatments, a no-disturbance buffer of 100 feet, or published agency distance, will be implemented around the individual unless it is determined by a qualified RPF, biologist, or RPF supervised designee that a different sized buffer is appropriate to avoid injury or mortality. Treatment activities will cease within the buffer until the animal has left the area or has been moved out of harm’s way and to other nearby habitat suitable for the species by the qualified RPF or biologist.

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-59 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Special-Status amphibians and reptiles
 If special-status reptiles or amphibians (i.e., California giant salamander, Santa Cruz black salamander, redbellied newt, coast horned lizard, and Northern California legless lizard) are detected during SPR BIO-10 focused surveys, or if California giant salamander, Santa Cruz black salamander, red-bellied newt, coast horned lizard, and Northern California legless lizard is assumed to be present, biological monitoring by a qualified RPF, biologist, biological technician, or trainee during prescribed burning, mechanical treatments, manual tree and snag removal activities, and herbicide application treatments within or adjacent to sensitive habitat areas will be implemented to avoid injury to or mortality of individual special-status reptiles or amphibians. If the qualified RPF or biologist detects a special-status reptile or amphibian during treatments, a no-disturbance buffer of 100 feet, or published agency distance, will be implemented around the individual unless it is determined by a qualified RPF, biologist, or RPF supervised designee that a different sized buffer is appropriate to avoid injury or mortality.

Treatment activities will cease within the buffer until the animal has left the area or has been moved out of harm’s way and to other nearby habitat for the species by the qualified RPF or biologist.

Other Special-Status Birds
 If an active grasshopper sparrow, short-eared owl, log-eared owl, Vaux’s swift, northern harrier, olive-sided flycatcher, black swift, saltmarsh common yellowthroat, yellow breasted chat, loggerhead shrike, purple martin, or yellow warbler nest is detected during SPR BIO-10 focused surveys, a no-disturbance buffer of at least 100 feet will be established around the nest. For helicopter and drone operations, this buffer will be a vertical buffer as well as a horizontal buffer (i.e., 100 feet horizontal distance or 100 feet AGL). No treatment activities will occur within this buffer until the chicks have fledged as determined by a qualified RPF or biologist. 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.

American Badger
 If an active American badger den is detected within treatment areas during SPR BIO-10 focused surveys, a nodisturbance buffer of 100 feet would be established around active maternity dens, and installation of control lines and staging areas for prescribed burning, pile burning, mechanical treatment, manual treatment, and the setup of infrastructure for prescribed herbivory activities would not occur within this buffer during the pupping season (February 15–July 1). If an active American badger den is detected within treatment areas outside of the pupping season, where mechanical treatments, pile burning, installation of control lines and staging areas for prescribed burning, or the setup of infrastructure for prescribed herbivory activities are to be conducted, a buffer of 50 feet will be placed around the den.

San Francisco dusky-footed woodrat
 A no-disturbance buffer of approximately 10 feet in diameter will be established around San Francisco duskyfooted woodrat nests or clusters of nests, and no manual treatments, mechanical treatments, or pile burning will be conducted within that buffer if feasible. The buffer may be estimated by field crews for mechanical treatments using remote-controlled masticators, manual treatments, and pile burning. For traditional

Attachment A Ascent
Saratoga Fire Protection District
A-60 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
mechanical treatments, a reasonable effort shall be made to electronically mark or physically flag the buffer; marking and/or flagging of nests may be reduced where there is a safety issue in accessing the nest. An electronic map will be provided to field crews and used for reference during traditional mechanical treatments.

When visibility of a nest is limited, as determined by a qualified RPF or biologist during survey pursuant to SPR BIO-10, high-visibility flagging or other high visibility physical markers may be used to supplement electronic demarcation or visual estimation of the no-disturbance buffer. The buffer distances may be adjusted as needed by a qualified RPF or biologist to avoid impacts if needed.  If San Francisco dusky-footed woodrat nests are located within prescribed burning treatment areas, or if presence of nests is assumed pursuant to SPR BIO-10, broadcast burning will not occur during the season when the majority of woodrat young are present in the nest (April through mid-July) to avoid loss of young woodrats, unless control lines can be established around the nest.  In areas of existing woodrat habitat where pile burning would occur, pile burning will take place as soon as feasible following placement of the pile to reduce the risk of woodrats occupying the debris piles. Prior to burning, debris piles should be disturbed to ensure any woodrats inside of the piles have the opportunity to escape.

Special-Status Bats
If a special-status bat roost is detected during SPR BIO-10 focused surveys:
 A no-disturbance buffer of 250 feet will be established around the roost during the bat maternity season (April 1–August 31), and prescribed burning, mechanical treatments, and manual treatments and herbicide application using power equipment will not occur within this buffer until the roost is no longer being used as determined by a qualified RPF or biologist. 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.  During the overwintering season (October 15 – April 1) structures (e.g., trees and snags) containing roosts will be retained unless the tree or snag is hazardous and removal is required for heath and safety.

Mitigation Measure BIO-2c: Compensate for Mortality, Injury, or Disturbance and Loss of Habitat Function for Special-Status Wildlife if Applicable (All Treatment Activities) If the provisions of Mitigation Measure BIO-2a, BIO-2b, BIO-2d, BIO-2e, BIO-2f, or BIO-2g cannot be implemented and the project proponent determines that additional mitigation is necessary to reduce significant impacts, the project proponent will compensate for such impacts to species or habitat by acquiring and/or protecting land that provides (or will provide in the case of restoration) habitat function for affected species that is at least equivalent to the habitat function removed or degraded as a result of the treatment.

Compensation may include:

1. Preserving existing habitat outside of the treatment area in perpetuity; this may entail purchasing mitigation credits and/or lands from a CDFW- or USFWS-approved entity in sufficient quantity to offset the residual significant impacts, generally at a ratio of 1:1 for habitat; and Prior to, during, and
after 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-61 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity

2. Restoring or enhancing existing habitat within the treatment area or outside of the treatment area (including decommissioning roads, adding perching structures, removing existing perching structures, or removing existing movement barriers or other existing features that are adversely affecting the species).

The project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant effects that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects, and:

1. For preserving existing habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanisms for long-term conservation (e.g., 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 habitat will be preserved in perpetuity.

2. For 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.

Review requirements are as follows:
 The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan in order to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan.
 For species listed under ESA or CESA or a California Fully Protected Species, the project proponent will submit the mitigation plan to CDFW and/or USFWS/NOAA Fisheries for review and comment.  For other special-status wildlife species the project proponent may consult with CDFW and/or USFWS regarding the availability and applicability of compensatory mitigation and other related technical information.

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

Attachment A Ascent
Saratoga Fire Protection District
A-62 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Mitigation Measure BIO-2e: Design Treatment to Retain Special-Status Butterfly Host Plants (All Treatment Activities)
If federally listed butterflies are identified as occurring or having potential to occur during review and surveys for SPR BIO-1 and confirmed during protocol-level surveys per SPR BIO-10, then the following measures will be implemented:
 Treatment areas within the range of these species will be surveyed for the host plant for each species (Table

3.6-34).
 Host plants for federally listed butterflies within the occupied habitat will be marked with high-visibility flagging, fencing, or stakes, and no treatment activities will occur within 10 feet of these plants.  Because prescribed herbivory could result in the indiscriminate removal of the host plants for federally listed butterflies, this treatment type will not be used within occupied habitat of any federally listed butterfly species, unless it is known that the host plant is unpalatable to the herbivore.  Treatment areas that are not occupied but are within the range of the federally listed butterfly will be divided into as many treatment units as feasible such that the entirety of the habitat is not treated within the same year.
 Treatments will be conducted in a patchy pattern to the extent feasible in areas that are not occupied but are within the range of the federally listed butterfly, such that the entirety of the habitat is not burned or removed and untreated portions of suitable habitat are retained.

If the project proponent cannot implement the measures above to avoid mortality, injury, or disturbance of federally listed butterflies or degradation of occupied habitat (host plants) such that its function would not be maintained, the project proponent will implement Mitigation Measure BIO-2c.

CESA and ESA Listed Species. A qualified RPF or biologist will determine if, after implementation of any feasible impact avoidance measures (potentially including others not listed above), the treatment will result in mortality, injury, or disturbance, or if after implementation of the treatment, habitat function will remain for the affected species. For species listed under CESA or ESA or that are fully protected, the qualified RPF or biologist will consult with CDFW and/or USFWS regarding this determination. If consultation determines that mortality, injury, or disturbance of listed butterflies or degradation of occupied habitat such that its function would not be maintained would occur, the project proponent will implement Mitigation Measure BIO-2c.

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-63 Table 3.6-34 Special-status Butterflies and Associated Host Plants Butterfly Species Host Plants
bay checkerspot butterfly dwarf plantain (Plantago virginica), purple owl’s clover (Castilleja exserta) Behren’s silverspot butterfly blue violet (Viola adunca) callippe silverspot butterfly California golden violet (Viola pedunculata) Carson wandering skipper salt grass (Distichlis spicata) El Segundo blue butterfly seacliff buckwheat (Eriogonum parvifolium) Hermes copper butterfly spiny redberry (Rhamnus crocea) Kern primrose sphinx moth plains evening-primrose (Camissonia contorta), field primrose (Camissonia campestris)
Laguna Mountains skipper Cleveland’s horkelia (Horkelia clevelandii), sticky cinquefoil (Drymocallis glandulosa)
Lange’s metalmark butterfly naked-stemmed buckwheat (Eriogonum nudum) lotis blue butterfly seaside bird’s foot trefoil (Hosackia gracilis) Mission blue butterfly lupine (Lupinus spp.)
Myrtle’s silverspot butterfly blue violet
Oregon silverspot butterfly blue violet
Palos Verdes blue butterfly Santa Barbara milkvetch (Astragalus trichopodus), common deerweed (Acmispon glaber)
San Bruno elfin butterfly broadleaf stonecrop (Sedum spathulifolium), manzanita (Arctostaphylos spp.), huckleberry (Vaccinuum spp.)
Smith’s blue butterfly seacliff buckwheat, seaside buckwheat (Eriogonum latifolium) Quino checkerspot butterfly dwarf plantain, purple owl’s clover

Attachment A Ascent
Saratoga Fire Protection District
A-64 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Other Special-status Species. A qualified RPF or biologist with knowledge of the special-status 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 will not maintain habitat function of the special-status species’ habitat or because the loss of special-status individuals would substantially reduce the number or restrict the range of a special-status species. If the project proponent determines the impact on special-status butterflies would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status butterflies or degradation of occupied habitat would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-2c will be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or biologist that the special-status butterfly species would benefit from treatment in the occupied habitat area even though some may be killed, injured or disturbed during treatment activities. For a treatment to be considered beneficial to special-status butterfly species, the qualified RPF or biologist 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). If it is determined that treatment activities would be beneficial to special-status butterflies, no compensatory mitigation will be required.

Project-Specific Guidance to Implement Mitigation Measure BIO-2e The following measures apply to habitat for bay checkerspot butterfly:
 Bay checkerspot butterfly host plants include dwarf plantain (Plantago erecta), purple owl’s-clover (Castilleja densiflorus, formerly Orthocarpus densiflorus) and exserted paintbrush (Castilleja exserta, formerly Orthocarpus purpurscens).

The measures described above have been tailored to the proposed treatments for monarch butterfly and are as follows:
 If host plants for monarch butterfly are detected, and monarch eggs, larvae, and pupae are detected during focused surveys pursuant to SPR BIO-10 or assumed to be present, host plants will be marked with highvisibility flagging, fencing, or stakes, and no treatment activities (other than prescribed herbivory) will occur within 10 feet of these plants if feasible (unless, pursuant to SPR BIO-1, activities occur outside of the period March 15-October 31, when impacts to eggs, larvae, and pupae can be avoided).

If monarch butterfly is detected during focused surveys pursuant to SPR BIO-10, or presence is assumed, treatments will be conducted in a patchy pattern to the extent feasible in grasslands, shrublands, and oak woodlands, such that the entirety of the habitat is not burned or removed and untreated portions of suitable habitat and floral resources are retained.

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-65 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Mitigation Measure BIO-2g: Design Treatment to Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Special-Status Bumble Bees (All Treatment Activities) If special-status bumble bees are identified as occurring during review and surveys under SPR BIO-1 and confirmed during protocol-level surveys per SPR BIO-10, or if suitable habitat for special-status bumble bees is identified during review and surveys under SPR BIO-1 (e.g., wet meadow, forest meadow, riparian, grassland, or coastal scrub habitat containing sufficient floral resources within the range of the species), then the project proponent will implement the following measures, as feasible:
 Prescribed burning within occupied or suitable habitat for special-status bumble bees will occur from October through February to avoid the bumble bee flight season.  Treatment areas in occupied or suitable habitat will be divided into a sufficient number of treatment units such that the entirety of the habitat is not treated within the same year; the objective of this measure is to provide refuge for special-status bumble bees during treatment activities and temporary retention of suitable floral resources proximate to the treatment area.
 Treatments will be conducted in a patchy pattern to the extent feasible in occupied or suitable habitat, such that the entirety of the habitat is not burned or removed and untreated portions of occupied or suitable habitat are retained (e.g., fire breaks will be aligned to allow for areas of unburned floral resources for specialstatus bumble bees within the treatment area).  Herbicides will not be applied to flowering native plants within occupied or suitable habitat to the extent feasible during the flight season (March through September).

CESA and ESA Listed Species. A qualified RPF or biologist will determine if, after implementation of feasible avoidance measures (potentially including others not listed above), the treatment will result in mortality, injury, or disturbance to the species, or if after implementation of the treatment, habitat function will remain for the affected species. For species listed under CESA or ESA or that are fully protected, the qualified RPF or biologist will consult with CDFW and/or USFWS regarding this determination. If consultation determines that mortality, injury, or disturbance of listed bumble bees (in the event the Candidate listing is confirmed) or degradation of occupied (or assumed to be occupied) habitat such that its function would not be maintained would occur, the project proponent will implement Mitigation Measure BIO-2c.

Other Special-status Species. A qualified RPF or biologist with knowledge of the special-status 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 will not maintain habitat function of the special-status species’ habitat or because the loss of special-status individuals would substantially reduce the number or restrict the range of a special-status species. If the project proponent determines the impact on special-status bumble bees would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status bumble bees or degradation of occupied (or assumed to be occupied) habitat would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-2c will be implemented.

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-66 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or biologist that the special-status bumble bee species would benefit from treatment in the occupied (or assumed to be occupied) habitat area even though some of the non-listed special-status bumble bees may be killed, injured, or disturbed during treatment activities. For a treatment to be considered beneficial to special-status bumble bee species, the qualified RPF or biologist 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 specialstatus bumble bees, no compensatory mitigation will be required.

Project-Specific Guidance to Implement Mitigation Measure BIO-2g To avoid impacts on Crotch’s bumble bee, the following measures will be implemented when implementation of surveys under SPR BIO-10 results in identification of habitat suitable for the species and the species is detected or presence of the species is assumed:
 If Crotch’s bumble bees are detected during focused surveys, a no-disturbance buffer of at least 50 feet will be established around any identified nest colonies, and no pile burning or mechanical treatment activities will occur within this buffer until the nesting colony is no longer occupied as determined by a qualified RPF or biologist. Buffer size may be reduced or adjusted if recommended by a qualified biologist in consultation with CDFW.
 If surveys for nest colonies are not conducted and presence is assumed, pile burning and mechanical treatment will not occur during the colony flight season (April through August) (CDFW 2023). Herbicides will not be applied to flowering native plants within occupied or suitable habitat during the colony flight season (April through August), and herbicide application will not target native flowering plants while blooming.

Herbicide application will be conducted with ground-level application only (i.e., paint-on stems, backpack hand-applicator, hypo-hatchet tree injection, or hand placement of pellets). No aerial spray of herbicides will occur.
 Prescribed burning and biomass disposal will be designed to avoid nesting bumble bees and bumble bee floral resources.
 Chips will not fully block existing rodent burrows, which may provide habitat for bumble bees.  Broadcast burning in habitat suitable for sensitive bumble bees will be restricted to the winter season prior to emergence of bumble bee floral resources. Generally, prescribed burning will be limited to September 1– March 31 (outside of the colony flight season). If conditions in a given year vary and the timing of floral resource emergence is altered by unusual conditions (e.g., heavy rains, extended cold season), the prescribed burning window may be altered with coordination from a qualified bumble bee biologist. Variation from the September 1–March 31 broadcast burning window will be documented in the post-project implementation report.

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-67 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Treatment areas in occupied or suitable habitat will be divided into a sufficient number of treatment units such that the entirety of the habitat is not treated within the same year. The scale will be determined by a qualified biologist or RPF. The objective of this measure is to provide refuge for special-status bumble bees during treatment activities and temporary retention of suitable floral resources proximate to the treatment area.

Mitigation Measure BIO-3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands
The project proponent will implement the following measures when working in treatment areas that contain sensitive natural communities identified during surveys conducted pursuant to SPR BIO-3:
 Reference the Manual of California Vegetation, Appendix 2, Table A2, Fire Characteristics (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/) or other best available information to determine the natural fire regime of the specific sensitive natural community type (i.e., alliance) present. The condition class and fire return interval departure of the vegetation alliances present will also be determined.
 Design treatments in sensitive natural communities and oak woodlands to restore the natural fire regime and return vegetation composition and structure to their natural condition to maintain or improve habitat function of the affected sensitive natural community. Treatments will be designed to replicate the fire regime attributes for the affected sensitive natural community or oak woodland type including seasonality, fire return interval, fire size, spatial complexity, fireline intensity, severity, and fire type as described in Fire in California’s Ecosystems (Van Wagtendonk et al. 2018) and the Manual of California Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/). Treatments will not be implemented in sensitive natural communities that are within their natural fire return interval (i.e., time since last burn is less than the average time required for that vegetation type to recover from fire) or within Condition Class 1.
 To the extent feasible, no fuel breaks will be created in sensitive natural communities with rarity ranks of S1 (critically imperiled) and S2 (imperiled).
 To the extent feasible, fuel breaks will not remove more than 20 percent of the native vegetation relative cover from a stand of sensitive natural community vegetation in sensitive natural communities with a rarity rank of S3 (vulnerable) or in oak woodlands. In forest and woodland sensitive natural communities with a rarity rank of S3, and in oak woodlands, only shaded fuel breaks will be installed, and they will not be installed in more than 20 percent of the stand of sensitive natural community or oak woodland vegetation (i.e., if the sensitive natural community covers 100 acres, no more than 20 acres will be converted to create the fuel break).  Use prescribed burning as the primary treatment activity in sensitive natural communities that are fire dependent (e.g., closed-cone forest and woodland alliances, chaparral alliances characterized by firestimulated, obligate seeders), to the extent feasible and appropriate based on the fire regime attributes as described in Fire in California’s Ecosystems (Van Wagtendonk et al. 2018) and the Manual of California 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-68 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/).
 Time prescribed herbivory to occur when non-target vegetation is not susceptible to damage (e.g. non-target vegetation is dormant or has completed its reproductive cycle for the year). For example, use herbivores to control invasive plants growing in sensitive habitats or sensitive natural communities when sensitive vegetation is dormant but invasive plants are growing. Timing of herbivory to avoid non-target vegetation will be determined by a qualified botanist, RPF, or biologist based on the specific vegetation alliance being treated, the life forms and life conditions of its characteristic plant species, and the sensitivity of the non-target vegetation to the effects of herbivory.

The feasibility of implementing the avoidance measures will be determined by the project proponent based on whether implementation of this mitigation measure 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. If the avoidance measures are determined by the project proponent to be infeasible, the project proponent will document the reasons implementation of the avoidance strategies are 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 explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).

A qualified RPF or botanist with knowledge of the affected sensitive natural community 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 will not maintain habitat functions of the sensitive natural community or oak woodland. If the project proponent determines the impact on sensitive natural communities or oak woodlands would be less than significant, no further mitigation will be required. If the project proponent determines that the loss or degradation of sensitive natural communities or oak woodlands would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-3b 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 sensitive natural community or oak woodland would benefit from treatment in the occupied habitat area even though some loss may occur during treatment activities. For a treatment to be considered beneficial to a sensitive natural community or oak woodland, 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 community (or similar community) 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 sensitive natural communities or oak woodlands, no compensatory mitigation will be required.

Ascent Attachment A
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum A-69 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Mitigation Measure BIO-3b: Compensate for Loss of Sensitive Natural Communities and Oak Woodlands If significant impacts on sensitive natural communities or oak woodlands cannot feasibly be avoided or reduced as specified under Mitigation Measure BIO-3a, the project proponent will implement the following actions:
 Compensate for unavoidable losses of sensitive natural community and oak woodland acreage and function by:
 restoring sensitive natural community or oak woodland functions and acreage within the treatment area;  restoring degraded sensitive natural communities or oak woodlands outside of the treatment area at a sufficient ratio to offset the loss of acreage and habitat function; or  preserving existing sensitive natural communities or oak woodlands of equal or better value to the sensitive natural community lost through a conservation easement at a sufficient ratio to offset the loss of acreage and habitat function.
 The project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant effects on sensitive natural communities or oak woodlands that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects, and:

1. For preserving existing habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., 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 habitat will be preserved in perpetuity.

2. For 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 or enhanced habitat.

The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan in order to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan.

Prior to and during
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Mitigation Measure BIO-3c: Compensate for Unavoidable Loss of Riparian Habitat If, after implementation of SPR BIO-4, impacts to riparian habitat remain significant under CEQA, the project proponent will implement the following:
 Compensate for unavoidable losses of riparian habitat acreage and function by:
 restoring riparian habitat functions and acreage within the treatment area;  restoring degraded riparian habitat outside of the treatment area; 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-70 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
 purchasing riparian habitat credits at a CDFW-approved mitigation bank; or  preserving existing riparian habitat of equal or better value to the riparian habitat lost through a conservation easement at a sufficient ratio to offset the loss of riparian habitat function and value.  The project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant effects on riparian habitat that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects, and:

1. For preserving existing riparian habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., 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.

2. For restoring or enhancing riparian 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 or enhanced habitat.

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. Compensatory mitigation may be satisfied through compliance with permit conditions, or other authorizations obtained by the project proponent (e.g., Lake and Streambed Alteration Agreement), if these requirements are equally or more effective than the mitigation identified above.

Mitigation Measure BIO-4: Avoid State and Federally Protected Wetlands Impacts to wetlands will be avoided using the following measures:
 The qualified RPF or biologist will delineate the boundaries of federally protected wetlands according to methods established in the USACE wetlands delineation manual (Environmental Laboratory 1987) and the appropriate regional supplement for the ecoregion in which the treatment is being implemented.  The qualified RPF or biologist will delineate the boundaries of wetlands that may not meet the definition of waters of the United States, but would qualify as waters of the state, according to the state wetland procedures (California Water Boards 2019 or current procedures).  A qualified RPF or biologist will establish a buffer around wetlands and mark the buffer boundary with highvisibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). The buffer will be a minimum width of 25 feet but may be larger if deemed necessary. The appropriate size and shape of the buffer zone will be determined in coordination with the qualified RPF or biologist and will depend on the type of wetland present (e.g., seasonal wetland, wet meadow, freshwater marsh, vernal pool), 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-71 Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
the timing of treatment (e.g., wet or dry time of year), whether any special-status species may occupy the wetland and the species’ vulnerability to the treatment activities, environmental conditions and terrain, and the treatment activity being implemented.
 A qualified RPF or biological technician will periodically inspect the materials demarcating the buffer to confirm that they are intact and visible, and wetland impacts are being avoided.  Within this buffer, herbicide application is prohibited.  Within this buffer, soil disturbance is prohibited. Accordingly, the following activities are not allowed within the buffer zone: mechanical treatments, prescribed herbivory, equipment and vehicle access or staging.  Only prescribed (broadcast) burning may be implemented in wetland habitats if it is determined by a qualified RPF or biologist that:
 No special-status species are present in the wetland habitat  The wetland habitat function would be maintained.
 The prescribed burn is within the normal fire return interval for the wetland vegetation types present  Fire containment lines and pile burning are prohibited within the buffer No fire ignition (and associated use of accelerants) will occur within the wetland buffer Mitigation Measure BIO-5: Retain Nursery Habitat and Implement Buffers to Avoid Nursery Sites The project proponent will implement the following measures while working in treatment areas that contain nursery sites identified in surveys conducted pursuant to SPR BIO-10:
 Retain Known Nursery Sites. A qualified RPF or biologist will identify the important habitat features of the wildlife nursery and, prior to treatment activities, will mark these features for avoidance and retention during treatment.

Establish Avoidance Buffers. The project proponent will establish a no-disturbance buffer around the nursery site if activities are required while the nursery site is active/occupied. The appropriate size and shape of the buffer will be determined by a qualified RPF or biologist, based on potential effects of project-related habitat disturbance, noise, visual disturbance, and other factors. No treatment activity will commence within the buffer area until a qualified RPF or biologist confirms that the nursery site is no longer active/occupied. Monitoring of the effectiveness of the no-disturbance buffer around the nursery site by a qualified RPF, biologist, or biological technician during and after treatment activities will be required. If treatment activities cause agitated behavior of the individual(s), the buffer distance will be increased, or treatment activities modified until the agitated behavior stops. The qualified RPF, biologist, or biological technician will have the authority to stop any treatment activities that could result in potential adverse effects to special-status species.

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-72 West Santa Clara Landscape Resiliency Project PSA and Addendum Mitigation Measures Timing Implementing Entity Verifying/Monitoring Entity
Greenhouse Gas Emissions
Mitigation Measure GHG-2: Implement GHG Emission Reduction Techniques During Prescribed Burns When planning for and conducting a prescribed burn, project proponents implementing a prescribed burn will incorporate feasible methods for reducing GHG emissions, including the following, which are identified in the National Wildfire Coordinating Group Smoke Management Guide for Prescribed Fire (NWCG 2018):
 reduce the total area burned by isolating and leaving large fuels (e.g., large logs, snags) unburned;  reduce the total area burned through mosaic burning;
 burn when fuels have a higher fuel moisture content;
 reduce fuel loading by removing fuels before ignition. Methods to remove fuels include mechanical treatments, manual treatments, prescribed herbivory, and biomass utilization; and  schedule burns before new fuels appear.

As the science evolves, other feasible methods or technologies to sequester carbon could be incorporated, such as conservation burning, a technique for burning woody material that reduces the production of smoke particulates and carbon released into the atmosphere and generates more biochar. Biochar is produced from the material left over after the burn and spread with compost to increase soil organic matter and soil carbon sequestration. Technologies to reduce greenhouse gas emissions may also include portable units that perform gasification to produce electricity or pyrolysis that produces biooil that can be used as liquid fuel and/or syngas that can be used to generate electricity.

The project proponent will document in the Burn Plan required pursuant to SPR AQ-3 which methods for reducing GHG emissions can feasibly be integrated into the treatment design.

Prior to and during
prescribed burning
treatment
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Santa Clara County
Firesafe Council or
Qualified Responsible
Party
Hazardous Materials, Public Health and Safety
Mitigation Measure HAZ-3: Identify and Avoid Known Hazardous Waste Sites Prior to the start of vegetation treatment activities requiring soil disturbance (i.e., mechanical treatments) or prescribed burning, CAL FIRE and other project proponents will make reasonable efforts to check with the landowner or other entity with jurisdiction (e.g., California Department of Parks and Recreation) to determine if there are any sites known to have previously used, stored, or disposed of hazardous materials. If it is determined that hazardous materials sites could be located within the boundary of a treatment site, the project proponent will conduct a DTSC EnviroStor web search (https://www.envirostor.dtsc.ca.gov/public/) and consult DTSC’s Cortese List to identify any known contamination sites within the project site. If a proposed mechanical treatment or prescribed burn is located on a site included on the DTSC Cortese List as containing potential soil contamination that has not been cleaned up and deemed closed by DTSC, the area will be marked and no prescribed burning or soil disturbing treatment activities will occur within 100 feet of the site boundaries. If it is determined through coordination with landowners or after review of the Cortese List that no potential or known contamination is located on a project site, the project may proceed as planned.

During PSA preparation
Database searches are
complete; 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-73

REFERENCES
Barbour, M. G., T. Keeler-Wolf, and A. A. Schoenherr. 2007. Terrestrial Vegetation of California. Third edition.

University of California Press. Berkeley and Los Angeles, CA, and London, England.

Buskirk, J. 2002. “The Western Pond Turtle, Emys marmorata.” Radiata. Journal of DGHT-AG Schildkroten. 11-2: 3–30.

Busse, Matt D; Hubbert, Ken R.; Moghaddas, Emily E. Y. 2014. Fuel reduction practices and their effects on soil quality.

Gen. Tech. Rep. PSW-GTR-241. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station. 156 p.

California Department of Fish and Wildlife. 2003. Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander. Available:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83915&inline. Accessed: June 8, 2023. ———. 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resources Agency, Department of Fish and Game. Available: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843&inline=true.

Accessed: June 8, 2023
———. 2023 (June 6). Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species. Available: https://wildlife.ca.gov/Conservation/CESA/Resources. Accessed October 8, 2024.

California Invasive Plant Council. 2012. Preventing the Spread of Invasive Plants: Best Management Practices for Land Mangers (3rd Edition). Cal-IPC Publication 2012-03. California Invasive Plant Council. Berkeley, CA. ———. 2025. Cal-IPC Invasive Plant Inventory. California Invasive Plant Council, Berkeley, CA. Available:
https://www.cal-ipc.org/plants/inventory. Accessed September 11, 2025.

California Native Plant Society. 2025. A Manual of California Vegetation, Online Edition. California Native Plant Society, Sacramento, CA. Available: http://www.cnps.org/cnps/vegetation/. Accessed September 11, 2025.

California Water Boards. 2019 (March 22). State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. Available:
https://www.waterboards.ca.gov/water_issues/programs/cwa401/wrapp.html. Accessed October 2019.

Cal-IPC. See California Invasive Plant Council.

CDFW. See California Department of Fish and Wildlife.

CNPS. See California Native Plant Society.
de Groot, RS, MA Wilson, and RM Boumans. 2002. A Typology for the Classification, Description and Valuation of Ecosystem Functions, Goods and Services. Ecological Economics 41:393-408.

Environmental Laboratory. 1987. U.S. Army Corps of Engineers Wetlands Delineation Manual. (Technical Report Y-87-

1.) U.S. Army Corps of Engineers Waterways Experiment Station. Vicksburg, MS.

National Wildfire Coordinating Group. 2018. NWCG Smoke Management Guide for Prescribed Fire. Available:
https://www.nwcg.gov/publications/420-2. Accessed May 20, 2022.

NWCG. See National Wildfire Coordinating Group.

Reese, D. A., and H. H. Welsh. 1997. “Use of Terrestrial Habitat by Western Pond Turtles, Clemmys marmorata:

Implications for Management.” Proceedings: Conservation, Restoration, and Management of Tortoises and Turtles. An International Conference: 352–357.

Sawyer, JO, T Keeler-Wolf, JM Evens. 2009. A Manual of California Vegetation (Second Edition). California Native Plant Society and California Department of Fish and Game.

Attachment A Ascent
Saratoga Fire Protection District
A-74 West Santa Clara Landscape Resiliency Project
Santa Clara County, City of San José, City of Morgan Hill, City of Gilroy, Santa Clara Valley Water District, Santa Clara Valley Transportation Authority. 2012. Final Santa Clara Valley Habitat Plan (HCP/NCCP). San José, CA.

Tukman Geospatial and Aerial Information Systems. 2022. San Mateo County Fine Scale Vegetation Map Prepared by:

Tukman Geospatial & Aerial Information Systems. Prepared for: the Golden Gate National Parks Conservancy.

October 21, 2022. Available: https://www.arcgis.com/home/item.html?id=c1d1ea74e5014dcba6331e8ce01e7d

49. Accessed September 11, 2025.
———. 2023. 2020 Santa Cruz and Santa Clara County Fine Scale Vegetation Map Final Report. Prepared by: Tukman Geospatial & Aerial Information Systems. Prepared for: the Santa Cruz Mountains Stewardship Network. June 19, 2023. Available: https://www.arcgis.com/home/item.html?id=3e01167873d14600ad4ae8551785b3d7.

Accessed September 11, 2025.

US Fish and Wildlife Service. 1999. (June). San Joaquin Kit Fox Survey Protocol for the Northern Range. Prepared by the Sacramento Fish and Wildlife Office. Available: https://www.slocounty.ca.gov/departments/planningbuilding/forms-documents/environmental-forms-and-documents/kit-fox-information/kit-fox-surveyprotocol. Accessed: January 27, 2025. ———. 2001. Least Bell’s Vireo Survey Guidelines. U.S. Fish and Wildlife Service, Ecological Services, Carlsbad Fish and Wildlife Office. Carlsbad, CA. Accessed: August 25, 2025. ———. 2005. Revised Guidance on Site Assessments and Field Surveys for the California Red-Legged Frog. Available:
https://ipac.ecosphere.fws.gov/guideline/survey/population/205/office/11420.pdf. Accessed February 27, 2025. Accessed August 8, 2024.
———. 2014. Recovery Program Guidance on Hazing California Condors. Memo from the California Condor Field Coordinator, Hopper Mountain NWRC to the Project Leader, Ventura Fish and Wildlife Office. September 3, 2014. Accessed: March 24, 2025.
———. 2020 (May). Species Status Assessment for the San Francisco gartersnake (Thamnophis sirtalis tetrataenia) Version 1.0. U.S. Fish and Wildlife Service Region 10. Sacramento, CA. Accessed: August 19, 2025. ———. 2023. Endangered and Threatened Wildlife and Plants; “Threatened Species Status With Section 4(d) Rule for the Northwestern Pond Turtle and Southwestern Pond Turtle.” Proposed Rule. Federal Register 88: 68370– 68399.

USFWS. See US Fish and Wildlife Service.

Van Wagtendonk, J.W., N.G. Sugihara, S.L Stephens, A.E. Thode, K.E. Shaffer, J. A. Fites-Kaufman. 2018. Fire in California’s Ecosystems. University of California Press.

Wilmers, C. C., Y. Wang, B. Nickel, P. Houghtaling, Y. Shakeri, M. L. Allen, J. Kermish-Wells, V. Yovovich, and T.

Williams. 2013. “Scale Dependent Behavioral Responses to Human Development by a Large Predatory, the Puma.” PLoS ONE 8(4) :e60590.

Working Group for Phytophthoras in Native Habitats. 2016 (September). Guidelines to Minimize Phytophthora Pathogens in Restoration Nurseries. Available: https://www.suddenoakdeath.org/wpcontent/uploads/2016/04/Restoration.Nsy_.Guidelines.final_.092216.pdf. Accessed January 17, 2024.

Xerces Society. See Xerces Society for Invertebrate Conservation.

Xerces Society for Invertebrate Conservation. 2019. Western Monarch Management Windows. Timing Management in Monarch Breeding Habitat. Available: https://xerces.org/publications/guidelines/timing-management-inmonarch-breeding-habitat. Retrieved February 2, 2024.

Attachment B
Biological Resources for the West Santa
Clara Landscape Resiliency Project

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-1 Special-Status Plant Species Known to Occur in the Vicinity of the Project Area and Their Potential for Occurrence in the Project Area
Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
San Mateo thornmint
Acanthomintha
duttonii
FE SE 1B.1 No Chaparral, valley and foothill grassland.

Uncommon serpentinite vertisol clays;
in relatively open areas. 170–990 ft in
elevation. Blooms April–June. Annual.

May occur. There are portions of the project
area near Santa Teresa Hills that contain
serpentinite vertisol soils; however, these
areas are largely developed and landscaped,
and would be unlikely to be treated. There
are other portions of the project area in this
region where serpentine soils are mapped
adjacent to vertisol clays, and it is possible
that these areas contain serpentine versitol
clay substrates suitable for this species.

Franciscan onion
Allium peninsulare
var. franciscanum
— — 1B.2 No Ultramafic. Cismontane woodland,
valley and foothill grassland. Clay soils;
sometimes on serpentine or on
volcanics. Dry hillsides. 20–1,150 ft in
elevation. Blooms May–June.

Geophyte.

May occur. There is a historical occurrence of
this species mapped in the project area along
Page Mill Road by Stanford University;
however, the exact location is unknown, and
this area is largely developed (CNDDB 2025a).

Dry hillside habitat is present throughout this
general region that may provide habitat
suitable for this species.

Bent-flowered
fiddleneck
Amsinckia lunaris
— — 1B.2 No Cismontane woodland, valley and
foothill grassland, coastal bluff scrub.
10–2,610 ft in elevation. Blooms
March–June. Annual.

Known to occur. There is a known occurrence
of this species in the project area near
Lexington Reservoir (CNDDB 2025a). Other
woodland and grassland habitat throughout
the project area may provide habitat suitable
for this species.

Anderson's
manzanita
Arctostaphylos
andersonii
— — 1B.2 No Broadleaved upland forest, chaparral,
north coast coniferous forest. Open
sites, redwood forest. 200–2,500 ft in
elevation. Blooms November–May.

Perennial.

Known to occur. There are many known
occurrences of this species in the
southeastern portion of the project area near
Mount Madonna County Park, Sveadal, and
along Summit Road (CNDDB 2025a). Other
chaparral and open areas in redwood forest
habitat in the project area may provide
habitat suitable for this species.

Schreiber's
manzanita
Arctostaphylos
glutinosa
— — 1B.2 No Closed-cone coniferous forest,
chaparral. Mudstone or diatomaceous
shale outcrops; often with Pinus
attenuata. 560–2,250 ft in elevation.

Blooms March–April. Perennial.

Not expected to occur. The project area is
outside of the geographical range of this
species.

Hooker's manzanita
Arctostaphylos
hookeri ssp. hookeri
— — 1B.2 No Chaparral, coastal scrub, closed-cone
coniferous forest, cismontane
woodland. Sandy soils, sandy shales,
sandstone outcrops. 200–1,760 ft in
elevation. Blooms January–June.

Perennial.

Not expected to occur. The project area is
outside of the geographical range of this
species.

Ohlone manzanita
Arctostaphylos
ohloneana
— — 1B.1 No Coastal scrub, closed cone coniferous
forests. Monterey shale. 1,480–1,740 ft
in elevation. Blooms February–March.

Perennial.

Not expected to occur. The project area is
outside of the geographical range of this
species.

Attachment B Ascent
Saratoga Fire Protection District
B-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Pajaro manzanita
Arctostaphylos
pajaroensis
— — 1B.1 No Chaparral. Sandy soils. 100–510 ft in
elevation. Blooms December–March.

Perennial.

Not expected to occur. The project area is
outside of the geographical range of this
species.

Kings Mountain
manzanita
Arctostaphylos
regismontana
— — 1B.2 No Broadleaved upland forest, chaparral,
north coast coniferous forest. Granitic
or sandstone outcrops. 790–2,320 ft in
elevation. Blooms December–April.

Perennial.

May occur. Sandstone substrate in the
southeastern portion of the project area may
provide habitat suitable for this species.

Bonny Doon
manzanita
Arctostaphylos
silvicola
— — 1B.2 No Chaparral, closed-cone coniferous
forest, lower montane coniferous
forest. Only known from Zayante
(inland marine) sands in Santa Cruz
County. 490–1,710 ft in elevation.

Blooms January–March. Perennial.

May occur. This species is known from
Zayante soils, which are not mapped in the
project area. However, there are multiple
observations of this species in the vicinity of
the project area near Lexington Reservoir and
Loma Prieta (iNaturalist 2025; Calflora 2025).

Marsh sandwort
Arenaria paludicola
FE SE 1B.1 No Wetland. Marshes and swamps.

Growing up through dense mats of
Typha, Juncus, Scirpus, etc. in
freshwater marsh. Sandy soil. 10–560 ft
in elevation. Blooms May–August.

Perennial.

Not expected to occur. This species typically
occurs closer to the coast.

Humboldt County
milk-vetch
Astragalus agnicidus
— SE 1B.1 No Broadleafed upland forest, north coast
coniferous forest. Disturbed openings
in partially timbered forest lands; also
along ridgelines; south aspects. 530–
2,200 ft in elevation. Blooms April–
September. Perennial.

May occur. This species was historically
known only from Humboldt and Mendocino
Counties; however, a population was
documented in Bonny Doon following the
2020 CZU Fire. Given its persistent seed bank
and adaptation to post-fire conditions, this
species may occur elsewhere in the Santa
Cruz Mountains, including the project area,
and could emerge in new sites after
disturbance events (Neubauer and Lyons
2023). Furthermore, recent iNaturalist records
indicate additional occurrences closer to the
project area (iNaturalist 2025).

Coastal marsh milkvetch
Astragalus
pycnostachyus var.
pycnostachyus
— — 1B.2 No Wetland. Mesic sites in coastal dunes
or along streams or coastal salt
marshes. 0–510 ft in elevation. Blooms
April–October. Perennial.

Not expected to occur. The project area does
not contain coastal dune, coastal salt marsh,
or other mesic coastal habitat suitable for this
species.

Alkali milk-vetch
Astragalus tener var.
tener
— — 1B.2 No Wetland. Low ground, alkali flats, and
flooded lands; in annual grassland or
in playas or vernal pools. 0–550 ft in
elevation. Blooms March–June. Annual.

May occur. Vernal pool habitat near Boronda
Lake and grasslands throughout the project
area may contain alkaline soils suitable for
this species.

Brittlescale
Atriplex depressa
— — 1B.2 No Usually in alkali scalds or alkaline clay
in meadows or annual grassland; rarely
associated with riparian, marshes, or
vernal pools. 10–1,070 ft in elevation.

Blooms April–October. Annual.

Not expected to occur. This species is
primarily known from the Central Valley and
areas closer to San Francisco Bay.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-3 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Lesser saltscale
Atriplex minuscula
— — 1B.1 No Alkali playa. Chenopod scrub, playas,
valley and foothill grassland. In alkali
sink and grassland in sandy, alkaline
soils. 0–740 ft in elevation. Blooms
May–October. Annual.

Not expected to occur. This species is
primarily known from the Central Valley and
areas closer to San Francisco Bay.

Big-scale balsamroot
Balsamorhiza
macrolepis
— — 1B.2 No Ultramafic. Chaparral, valley and
foothill grassland, cismontane
woodland. Sometimes on serpentine.
120–4,810 ft in elevation. Blooms
March–June. Perennial.

May occur. The project area contains
chaparral, grassland, and woodland habitat,
as well as serpentine soils, potentially suitable
for this species.

Santa Cruz
Mountains
pussypaws
Calyptridium parryi
var. hesseae
— — 1B.1 No Chaparral, cismontane woodland.

Sandy or gravelly openings. 990–5,040
ft in elevation. Blooms May–August.

Annual.

May occur. The project area contains
chaparral and woodland habitat with sandy
and gravelly substrate potentially suitable for
this species. There is a known occurrence of
this species from the vicinity of Loma Prieta,
although the exact location is unknown
(CNDDB 2025a).

Swamp harebell
Campanula
californica
— — 1B.2 No Wetland. Bogs and fens, closed-cone
coniferous forest, coastal prairie,
meadows and seeps, freshwater
marsh, north coast coniferous forest.

Bogs and marshes in a variety of
habitats; uncommon where it occurs.
10–1,330 ft in elevation. Blooms June–
October. Geophyte.

Not expected to occur. This species is known
from habitats closer to the coast; the project
area is likely too far inland for this species.

Bristly sedge
Carex comosa
— — 2B.1 No Marshes and swamps, lake margins,
and wet places in coastal prairie and
valley and foothill grassland. 20–5,320
ft in elevation. Blooms May–
September. Geophyte.

May occur. Wetland and lake margin habitat
throughout the project area may provide
habitat suitable for this species.

Deceiving sedge
Carex saliniformis
— — 1B.2 No Mesic sites in coastal prairie, coastal
scrub, meadows, seeps, and coastal
salt marshes and swamps. 10–760 ft in
elevation. Blooms June. Geophyte.

Not expected to occur. The project area does
not contain coastal prairie, coastal scrub,
coastal salt marsh, or other mesic coastal
habitat suitable for this species.

Tiburon paintbrush
Castilleja affinis var.
neglecta
FE ST 1B.2 Yes Ultramafic. Valley and foothill
grassland. Rocky serpentine sites. 400–
1,310 ft in elevation. Blooms April–June.

Perennial.

May occur. The project area contains rocky
serpentine habitat suitable for this species.

Pink creamsacs
Castilleja rubicundula
var. rubicundula
— — 1B.2 No Openings in chaparral, cismontane
woodland, or grasslands. On
serpentine. 70–3,000 ft in elevation.

Blooms April–June. Annual.

Known to occur. There are two occurrences in
the project area near Sargent and Chesbro
Reservoir (CNDDB 2025a). The project area
contains other serpentine habitat suitable for
this species.

Coyote ceanothus
Ceanothus ferrisiae
FE — 1B.1 Yes Serpentine sites in chaparral, valley
and foothill grassland, and coastal
scrub. 490–1,510 ft in elevation. Blooms
January–May. Perennial.

Known to occur. There are two occurrences in
the project area near Morgan Hill and
Sveadal (CNDDB 2025a). The project area
contains other serpentine habitat suitable for
this species.

Attachment B Ascent
Saratoga Fire Protection District
B-4 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Congdon's tarplant
Centromadia parryi
ssp. congdonii
— — 1B.1 No Valley and foothill grassland. Alkaline
soils, sometimes described as heavy
white clay. 0–760 ft in elevation.

Blooms May–October. Annual.

May occur. Grasslands in the project area
may contain alkali soils suitable for this
species.

Dwarf soaproot
Chlorogalum
pomeridianum var.
minus
— — 1B.2 No Serpentine chaparral. 1,000–3,280 ft in
elevation. Blooms May–August.

Geophyte.

May occur. The project area contains
chaparral habitat with serpentine substrate
suitable for this species.

Point Reyes salty
bird's-beak
Chloropyron
maritimum ssp.
palustre
— — 1B.2 No Coastal salt marsh with Salicornia,
Distichlis, Jaumea, Spartina, etc. 0–380
ft in elevation. Blooms June–October.

Annual.

Not expected to occur. The project area does
not contain coastal salt marsh habitat suitable
for this species.

Ben Lomond
spineflower
Chorizanthe pungens
var. hartwegiana
FE — 1B.1 No Lower montane coniferous forest.

Zayante coarse sands in maritime
ponderosa pine sandhills. 350–1,560 ft
in elevation. Blooms April–July. Annual.

Not expected to occur. The project area does
not contain Zayante sand substrate suitable
for this species.

Monterey
spineflower
Chorizanthe pungens
var. pungens
FT — 1B.2 No Sandy soils in coastal dunes or more
inland within chaparral, cismontane
woodland, or valley and foothill
grassland. 0–560 ft in elevation.

Blooms April–June. Annual.

May occur. The project area contains
chaparral, woodland, and grassland habitat
with sandy substrate suitable for this species.

A possible occurrence of this species was
documented on iNaturalist in the project area
near Mount Madonna, although the record is
inconclusive as reviewers provided differing
identifications within the genus Chorizanthe
(iNaturalist 2025).

Scotts Valley
spineflower
Chorizanthe robusta
var. hartwegii
FE — 1B.1 No Meadows, valley and foothill grassland.

In grasslands with mudstone and
sandstone outcrops. 350–810 ft in
elevation. Blooms April–July. Annual.

May occur. The project area contains
grassland habitat with sandstone and
mudstone substrate that may have outcrops
suitable for this species.

Robust spineflower
Chorizanthe robusta
var. robusta
FE — 1B.1 No Cismontane woodland, coastal dunes,
coastal scrub, chaparral. Sandy
terraces and bluffs or in loose sand.
30–810 ft in elevation. Blooms April–
September. Annual.

Not expected to occur. The project area does
not contain sandy terrace or bluff habitat
suitable for this species.

Mt. Hamilton thistle
Cirsium fontinale var.
campylon
— — 1B.2 Yes Cismontane woodland, chaparral,
valley and foothill grassland. In
seasonal and perennial drainages on
serpentine. 330–2,920 ft in elevation.

Blooms April–October. Perennial.

Known to occur. There are multiple
occurrences of this species throughout the
project area east of Los Gatos (CNDDB
2025a). Serpentine substrate is present
throughout many parts of the project area,
and drainages in these areas provides habitat
suitable for this species.

Fountain thistle
Cirsium fontinale var.
fontinale
FE SE 1B.1 No Serpentine seeps and grassland. 150–
610 ft in elevation. Blooms May–
October. Perennial.

Serpentine grasslands near Los Altos Hills
may contain seep habitat suitable for this
species.

Lost thistle
Cirsium praeteriens
— — 1A No Little information exists on this plant,
habitat is unknown. 0–330 ft in
elevation. Blooms June–July. Perennial.

Not expected to occur. This species has not
been observed since 1901 and is thought to
be extinct.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-5 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Round-headed
collinsia
Collinsia corymbosa
— — 1B.2 No Coastal dunes. 40–100 ft in elevation.

Blooms April–June. Annual.

Not expected to occur. The project area does
not contain coastal dune habitat suitable for
this species.

San Francisco
collinsia
Collinsia multicolor
— — 1B.2 No Closed-cone coniferous forest, coast
live oak woodland, coastal scrub.

Sometimes on serpentine. 100–820 ft
in elevation. Blooms March–May.

Annual.

May occur. This species was observed in
Almaden Quicksilver County Park sometime
between 1982 and 2001, but the exact
location is unknown (CNDDB 2025a). The
project area contains closed-cone pine forest,
coast live oak woodland, and coastal sage
scrub habitat potentially suitable for this
species.

Seaside bird's-beak
Cordylanthus rigidus
ssp. littoralis
— SE 1B.1 No Closed-cone coniferous forest,
chaparral, cismontane woodland,
coastal scrub, coastal dunes. Sandy,
often disturbed sites, usually within
chaparral or coastal scrub. 100–1,710 ft
in elevation. Blooms April–October.

Annual.

Not expected to occur. This species is found
in habitats with more coastal influence.

Tear drop moss
Dacryophyllum
falcifolium
— — 1B.3 No North Coast coniferous forest.

Limestone substrates and rock
outcrops. 170–900 ft in elevation.

Perennial.

Not expected to occur. This species is found
in habitats with more coastal influence.

Hall's tarplant
Deinandra halliana
— — 1B.2 No Cismontane woodland, chenopod
scrub, valley and foothill grassland.

Reported from a variety of substrates
including clay, sand, and alkaline soils.
510–2,990 ft in elevation. Blooms April–
May. Annual.

May occur. Grassland and woodlands in the
project area may provide habitat suitable for
this species.

Hospital Canyon
larkspur
Delphinium
californicum ssp.
interius
— — 1B.2 No In wet, boggy meadows, openings in
chaparral, cismontane woodland,
coastal scrub, and in canyons. 640–
3,600 ft in elevation. Blooms April–
June. Perennial.

May occur. The project area contains
chaparral, woodland, coastal scrub, and
canyon habitat suitable for this species.

Western
leatherwood
Dirca occidentalis
— — 1B.2 No On brushy slopes, mesic sites; mostly
in mixed evergreen and foothill
woodland communities. 80–1,400 ft in
elevation. Blooms January–March.

Perennial.

Known to occur. There are multiple
occurrences of this species throughout the
project area (CNDDB 2025a). The project area
contains brushy slopes and mesic habitat
suitable for this species.

Santa Clara Valley
dudleya
Dudleya abramsii
ssp. setchellii
FE — 1B.1 Yes Ultramafic. Valley and foothill
grassland, cismontane woodland. On
rocky serpentine outcrops and on
rocks within grassland or woodland.
200–1,500 ft in elevation. Blooms April–
October. Perennial.

Known to occur. There are many occurrences
of this species in the project area east of Los
Gatos (CNDDB 2025a). Rocky, serpentine
substrate suitable for this species is present
throughout this portion of the project area.

Eastwood's
goldenbush
Ericameria fasciculata
— — 1B.1 No Closed-cone coniferous forest,
chaparral (maritime), coastal scrub,
coastal dunes. In sandy openings. 100–
900 ft in elevation. Blooms July–
October. Perennial.

Not expected to occur. This species is found
in habitats with more coastal influence.

Attachment B Ascent
Saratoga Fire Protection District
B-6 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Pinnacles buckwheat
Eriogonum nortonii
— — 1B.3 No Chaparral, valley and foothill grassland.

Sandy soils; often on recent burns.
990–3,200 ft in elevation. Blooms May–
August. Annual.

May occur. This species is not known from
the Santa Cruz Mountains, but chaparral and
grassland habitat in the easternmost portion
of the project area may provide habitat
suitable for this species.

Ben Lomond
buckwheat
Eriogonum nudum
var. decurrens
— — 1B.1 No Chaparral, cismontane woodland,
lower montane coniferous forest.

Ponderosa pine sandhills in Santa Cruz
County. 170–2,630 ft in elevation.

Blooms June–October. Perennial.

Not expected to occur. The project area does
not contain sandhills habitat suitable for this
species.

San Mateo woolly
sunflower
Eriophyllum
latilobum
FE SE 1B.1 No Cismontane woodland, coastal scrub,
lower montane coniferous forest.

Often on roadcuts; found on
serpentine. 100–2,000 ft in elevation.

Blooms May–June. Perennial.

May occur. The project area contains
woodland, coastal scrub, and roadcuts with
serpentine substrate suitable for this species.

Hoover's buttoncelery
Eryngium aristulatum
var. hooveri
— — 1B.1 No Alkaline depressions, vernal pools,
roadside ditches and other wet places
near the coast. 10–170 ft in elevation.

Blooms July. Annual/Perennial.

May occur. Vernal pool habitat near Boronda
Lake and roadside ditch and other wet
habitat throughout the project area may
provide habitat suitable for this species.

Jepson's coyotethistle
Eryngium jepsonii
— — 1B.2 No Vernal pools, valley and foothill
grassland. 10–990 ft in elevation.

Blooms April–August. Perennial.

May occur. The Santa Cruz and Santa Clara
fine scale vegetation data identifies vernal
pool habitat near Boronda Lake, which may
provide habitat suitable for this species.

Sand-loving
wallflower
Erysimum
ammophilum
— — 1B.2 No Maritime chaparral, coastal dunes,
coastal scrub. Sandy openings. 0–200
ft in elevation. Blooms February–June.

Perennial.

Not expected to occur. This species is only
found along the coast.

Santa Cruz
wallflower
Erysimum
teretifolium
FE SE 1B.1 No Lower montane coniferous forest,
chaparral. On Zayante coarse sand.
590–1,690 ft in elevation. Blooms
March–July. Perennial.

Not expected to occur. The project area does
not contain Zayante soils suitable for this
species.

San Joaquin
spearscale
Extriplex joaquinana
— — 1B.2 No In seasonal alkali wetlands, grasslands,
or alkali sink scrub with Distichlis
spicata, Frankenia, etc. 10–2,740 ft in
elevation. Blooms April–October.

Annual.

May occur. Grasslands and wetlands in the
project area may contain alkaline soils
suitable for this species.

Minute pocket moss
Fissidens pauperculus
— — 1B.2 No Redwoods. Moss growing on damp
soil along the coast. In dry streambeds
and on stream banks. 40–3,360 ft in
elevation. Perennial.

May occur. The project area contains streams
in redwood forest habitat suitable for this
species.

Fragrant fritillary
Fritillaria liliacea
— — 1B.2 Yes Coastal scrub, valley and foothill
grassland, coastal prairie, cismontane
woodland. Often on serpentine;
various soils reported though usually
on clay, in grassland. 10–1,310 ft in
elevation. Blooms February–April.

Geophyte.

Known to occur. There are multiple
occurrences of this species near Almaden
Quicksilver County Park and Calero Reservoir
County Park (CNDDB 2025a). Serpentine
grassland and woodland habitat suitable for
this species is present throughout this area.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-7 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Monterey gilia
Gilia tenuiflora ssp.
arenaria
FE ST 1B.2 No Coastal dunes. Sandy openings in
bare, wind-sheltered areas. Often near
dune summit or in the hind dunes;
some records from Pleistocene inland
dunes. 20–810 ft in elevation. Blooms
April–June. Annual.

Not expected to occur. The project area does
not contain coastal dune habitat suitable for
this species.

Toren's grimmia
Grimmia torenii
— — 1B.3 No Cismontane woodland, lower montane
coniferous forest, chaparral. Rocky
openings, boulder and rock walls. On
carbonate, sandstone, and volcanic
rocks. 1,070–3,810 ft in elevation.

Perennial.

May occur. The project area contains
sandstone and volcanic substrate that may
contain rocky habitat suitable for this species.

Vaginulate grimmia
Grimmia vaginulata
— — 1B.1 No Limestone. Chaparral. Openings; rocky,
boulder and rock walls, carbonate.
2,250–3,730 ft in elevation. Perennial.

May occur. The project area contains Eocene
formations that may contain limestone or
other carbonate substrate suitable for this
species.

Short-leaved evax
Hesperevax
sparsiflora var.
brevifolia
— — 1B.2 No Coastal bluff scrub, coastal dunes,
coastal prairie. Sandy bluffs and flats.
0–710 ft in elevation. Blooms March–
June. Annual.

Not expected to occur. The project area does
not contain coastal bluff scrub, coastal dune,
and coastal prairie habitat suitable for this
species.

Santa Cruz cypress
Hesperocyparis
abramsiana var.
abramsiana
FT SE 1B.2 No Chaparral, closed-cone coniferous
forest, lower montane coniferous
forest. Restricted to the Santa Cruz
Mountains, on sandstone and graniticderived soils; often with Pinus attenuata and redwoods. 990–3,560 ft
in elevation. Perennial.

May occur. The project area contains
chaparral and closed-cone coniferous forest
habitat suitable for this species and also
contains associate species, including redwood
and Pinus attenuata stands.

Butano Ridge
cypress
Hesperocyparis
abramsiana var.
butanoensis
FT SE 1B.2 No Closed-cone coniferous forest, lower
montane coniferous forest, chaparral.

Sandstone. 1,310–1,610 ft in elevation.

Blooms October. Perennial.

Not expected to occur. This species is only
known from the vicinity of Butano Ridge.

Marin western flax
Hesperolinon
congestum
FT ST 1B.1 No In serpentine barrens and in
serpentine grassland and chaparral.
200–1,220 ft in elevation. Blooms April–
July. Annual.

May occur. The project area contains
chaparral and grassland habitat with
serpentine substrate suitable for this species.

Loma Prieta hoita
Hoita strobilina
— — 1B.1 Yes Ultramafic. Chaparral, cismontane
woodland, riparian woodland.

Serpentine; mesic sites. 200–3,200 ft in
elevation. Blooms May–July. Perennial.

Known to occur. There are many occurrences
of this species throughout the project area
(CNDDB 2025a).

Santa Cruz tarplant
Holocarpha
macradenia
FT SE 1B.1 No Coastal prairie, coastal scrub, valley
and foothill grassland. Light, sandy soil
or sandy clay; often with nonnatives.
40–720 ft in elevation. Blooms June–
October. Annual.

May occur. The project area contains
grasslands with sandy substrate suitable for
this species.

Attachment B Ascent
Saratoga Fire Protection District
B-8 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Kellogg's horkelia
Horkelia cuneata var.
sericea
— — 1B.1 No Closed-cone coniferous forest, coastal
scrub, coastal dunes, chaparral. Old
dunes, coastal sandhills; openings. 20–
710 ft in elevation. Blooms April–
September. Perennial.

Not expected to occur. This species is
typically found closer to the coast, and the
project area does not contain old dune or
sandhill habitat suitable for this species.

Point Reyes horkelia
Horkelia marinensis
— — 1B.2 No Coastal dunes, coastal prairie, coastal
scrub. Sandy flats and dunes near
coast; in grassland or scrub plant
communities. 10–2,550 ft in elevation.

Blooms May–September. Perennial.

Not expected to occur. This species is
typically found closer to the coast.

Contra Costa
goldfields Lasthenia
conjugens
FE — 1B.1 No Valley and foothill grassland, vernal
pools, alkaline playas, cismontane
woodland. Vernal pools, swales, low
depressions, in open grassy areas. 10–
1,480 ft in elevation. Blooms March–
June. Annual.

May occur. Vernal pool habitat near Boronda
Lake and grassland and open woodland
habitat in the lower elevation portions of the
project area may provide habitat suitable for
this species.

Legenere
Legenere limosa
— — 1B.1 No Vernal pools, wetland. In beds of
vernal pools. 10–2,890 ft in elevation.

Blooms April–June. Annual.

May occur. The Santa Cruz and Santa Clara
fine scale vegetation data identifies vernal
pool habitat near Boronda Lake, which may
provide habitat suitable for this species.

Mt. Hamilton
coreopsis
Leptosyne hamiltonii
— — 1B.2 No Cismontane woodland. On steep shale
talus with open southwestern
exposure. 1,740–4,270 ft in elevation.

Blooms March–May. Annual.

Not expected to occur. This species is only
known from the Mount Hamilton range;
therefore, the project area is outside of
geographical range of this species.

Crystal Springs
lessingia
Lessingia
arachnoidea
— — 1B.2 No Coastal sage scrub, valley and foothill
grassland, cismontane woodland.

Grassy slopes on serpentine;
sometimes on roadsides. 300–660 ft in
elevation. Blooms July–October.

Annual.

May occur. Lower elevations of the project
area with serpentine grassland and adjacent
serpentine roadsides may provide habitat
suitable for this species.

Smooth lessingia
Lessingia micradenia
var. glabrata
— — 1B.2 Yes Ultramafic. Chaparral, cismontane
woodland. Serpentine; often on
roadsides. 400–1,380 ft in elevation.

Blooms July–November. Annual.

Known to occur. There are many occurrences
of this species throughout the eastern portion
of the project area, east of Los Gatos (CNDDB
2025a). Chaparral and woodland habitat with
serpentine substrate is present throughout
much of the project area and provides habitat
suitable for this species.

Mt. Hamilton
lomatium
Lomatium
observatorium
— — 1B.2 No Cismontane woodland. Open to
partially shaded openings in Pinus
coulteri-oak woodland. Sedimentary
Franciscan rocks and volcanics. 1,790–
4,010 ft in elevation. Blooms March–
May. Perennial.

Not expected to occur. This species is only
known from the Mount Hamilton range;
therefore, the project area is outside of the
geographical range of this species.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-9 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Indian Valley
bushmallow
Malacothamnus
aboriginum
— — 1B.2 No Cismontane woodland, chaparral.

Granitic outcrops and sandy bare soil,
often in disturbed soils. 490–3,710 ft in
elevation. Blooms April–October.

Perennial.

May occur. This species is primarily known
from the Gabilan Range (CNDDB 2025a);
however, there are historical observations
near Los Gatos (CCH2 Portal 2025). The
project area contains granitic and sandy
substrates that may provide habitat suitable
for this species.

Arcuate bushmallow
Malacothamnus
arcuatus var.
arcuatus
— — 1B.2 No Chaparral, cismontane woodland.

Gravelly alluvium. 10–2,410 ft in
elevation. Blooms April–July. Perennial.

Known to occur. There are multiple
occurrences of this species throughout the
project area (CNDDB 2025).

Hall's bushmallow
Malacothamnus hallii
— — 1B.2 No Chaparral, coastal scrub. Some
populations on serpentine. 40–2,410 ft
in elevation. Blooms May–September.

Perennial.

Known to occur. There are multiple
occurrences of this species in the project area
in the vicinity of Calero Reservoir (CNDDB
2025a). The project area contains many areas
of chaparral and coastal scrub habitat suitable
for this species.

Marsh microseris
Microseris paludosa
— — 1B.2 No Closed-cone coniferous forest,
cismontane woodland, coastal scrub,
valley and foothill grassland. 20–990 ft
in elevation. Blooms April–June.

Perennial.

May occur. Closed-cone coniferous forest,
woodland, coastal scrub, and grassland
habitat throughout the lower elevation areas
of the project area may provide habitat
suitable for this species.

Northern curlyleaved monardella
Monardella sinuata
ssp. nigrescens
— — 1B.2 No Coastal dunes, coastal scrub, chaparral,
lower montane coniferous forest.

Sandy soils. 0–990 ft in elevation.

Blooms May–July. Annual.

Known to occur. There are multiple
occurrences throughout the project area
(iNaturalist 2025). The project area contains
coastal scrub, chaparral, and conifer forest
with sandy soils suitable for this species.

Woodland
woollythreads
Monolopia gracilens
— — 1B.2 No Ultramafic. Chaparral, valley and
foothill grassland, cismontane
woodland, broadleafed upland forest,
north coast coniferous forest. Grassy
sites, in openings; sandy to rocky soils.

Often seen on serpentine after burns
but has a weak affinity to serpentine.
330–3,940 ft in elevation. Blooms
March–July. Annual.

Known to occur. There are multiple
occurrences of this species throughout the
project area (CNDDB 2025a). The project area
contains grassy openings with sandy and
rocky substrates suitable for this species.

Prostrate vernal pool
navarretia
Navarretia prostrata
— — 1B.2 No Wetland. Coastal scrub, valley and
foothill grassland, vernal pools,
meadows and seeps. Alkaline soils in
grassland, or in vernal pools. Mesic,
alkaline sites. 10–4,050 ft in elevation.

Blooms April–July. Annual.

May occur. Vernal pool habitat near Boronda
Lake and grasslands throughout the project
area may contain mesic alkaline soils suitable
for this species.

Kellman's bristle
moss
Orthotrichum
kellmanii
— — 1B.2 No Sandstone outcrops with high calcium
concentrations from eroded boulders
out of non-calcareous sandstone
bedrock. Rock outcrops in small
openings within dense chaparral with
overstory of scattered Pinus attenuata.
1,130–2,250 ft in elevation. Blooms
January–February. Perennial.

May occur. The project area contains dense
chaparral habitat with scattered Pinus
attenuata and sandstone substrate suitable
for this species.

Attachment B Ascent
Saratoga Fire Protection District
B-10 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Dudley's lousewort
Pedicularis dudleyi
— SR 1B.2 No Deep shady woods of older coast
redwood forests; also in maritime
chaparral. 200–2,960 ft in elevation.

Blooms April–June. Perennial.

May occur. The project area contains deep
shady redwood habitat suitable for this
species.

Santa Cruz
Mountains
beardtongue
Penstemon rattanii
var. kleei
— — 1B.2 No Chaparral, lower montane coniferous
forest, north coast coniferous forest.

Sandy shale slopes; sometimes in the
transition between forest and
chaparral. 1,310–3,610 ft in elevation.

Blooms May–June. Perennial.

Known to occur. There are a couple
occurrences of this species near Loma Prieta
and Mount Madonna (CNDDB 2025a). Other
portions of the project area contain forest
and chaparral habitat potentially suitable for
this species.

White-rayed
pentachaeta
Pentachaeta
bellidiflora
FE SE 1B.1 No Valley and foothill grassland,
cismontane woodland. Open dry rocky
slopes and grassy areas, often on soils
derived from serpentine bedrock. 120–
2,000 ft in elevation. Blooms March–
May. Annual.

May occur. The project area contains open
dry rocky slope and grassland habitat suitable
for this species.

Mt. Diablo phacelia
Phacelia phacelioides
— — 1B.2 No Ultramafic. Chaparral, cismontane
woodland. Adjacent to trails, on rock
outcrops and talus slopes; sometimes
on serpentine. 1,990–4,420 ft in
elevation. Blooms April–May. Annual.

Not expected to occur. The project area is
outside of the geographic range of this
species.

White-flowered rein
orchid
Piperia candida
— — 1B.2 No North coast coniferous forest, lower
montane coniferous forest,
broadleafed upland forest.

Occasionally on serpentine. Forest
duff, mossy banks, rock outcrops, and
muskeg. 150–5,300 ft in elevation.

Blooms May–September. Perennial.

May occur. The project area contains forest
habitat with forest duff, mossy banks, and
rock outcrops suitable for this species.

Yadon's rein orchid
Piperia yadonii
FE — 1B.1 No Closed-cone coniferous forest,
chaparral, coastal bluff scrub. On
sandstone and sandy soil, but poorly
drained and often dry. 40–1,660 ft in
elevation. Blooms May–August.

Perennial.

May occur. This species is primarily known
from south of Watsonville; however, the
southeastern portion of the project area
contains closed-cone coniferous forest and
chaparral habitat with sandy soil potentially
suitable for this species.

Choris'
popcornflower
Plagiobothrys
chorisianus var.
chorisianus
— — 1B.2 No Chaparral, coastal scrub, coastal
prairie. Mesic sites. 50–530 ft in
elevation. Blooms March–June. Annual.

May occur. The project area contains
chaparral and coastal scrub habitat
potentially suitable for this species.

San Francisco
popcornflower
Plagiobothrys
diffusus
— SE 1B.1 No Valley and foothill grassland, coastal
prairie. Historically from grassy slopes
with marine influence. 150–1,180 ft in
elevation. Blooms March–June. Annual.

Not expected to occur. This species is
generally associated with coastal habitats,
whereas the project area is situated on the
northeastern flank of the Santa Cruz
Mountains rather than the west-facing,
ocean-influenced slopes. Portions of the
project area nearest to the coast are
characterized primarily by redwood forest,
woodland, and chaparral communities, rather
than marine-influenced grassland slopes.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-11 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Hairless
popcornflower
Plagiobothrys glaber
— — 1A No Salt marsh, vernal pool, wetlands,
alkaline meadows and seeps, coastal
salt marshes and swamps. 20–590 ft in
elevation. Blooms March–May. Annual.

Not expected to occur. This species is
presumed extinct.

Scotts Valley
polygonum
Polygonum hickmanii
FE SE 1B.1 No Valley and foothill grassland. Purisima
sandstone or mudstone with a thin soil
layer; vernally moist due to runoff.
690–760 ft in elevation. Blooms May–
August. Annual.

May occur. In CNDDB, this species is only
known near Scott’s Valley; however, there are
multiple occurrences recorded in iNaturalist
in the project area (iNaturalist 2025a). The
Purisima formation is right on the edge of the
project area, so there may be substrate
suitable for this species.

California alkali grass
Puccinellia simplex
— — 1B.2 No Meadows and seeps, chenopod scrub,
valley and foothill grasslands, vernal
pools. Alkaline, vernally mesic. Sinks,
flats, and lake margins. 10–3,000 ft in
elevation. Blooms March–May. Annual.

Known to occur. There is one occurrence of
this species near Sargent (CNDDB 2025a). The
project area contains lake margin and
grassland habitat that may contain alkaline
substrate suitable for this species.

Chaparral harebell
Ravenella exigua
— — 1B.2 No Chaparral. Rocky, usually serpentine.
900-4,100 ft in elevation. Blooms May–
June. Annual.

Not expected to occur. The project area is
outside of the geographic range of this
species.

Pine rose
Rosa pinetorum
— — 1B.2 No Closed-cone coniferous forest,
cismontane woodland. 20–3,580 ft in
elevation. Blooms May–July. Perennial.

May occur. The project area contains closedcone coniferous forest and woodland habitat potentially suitable for this species.

Sanford's arrowhead
Sagittaria sanfordii
— — 1B.2 No In standing or slow-moving freshwater
ponds, marshes, and ditches. 0–2,140 ft
in elevation. Blooms May–October.

Geophyte.

May occur. The project area contains pond
and ditch habitat potentially suitable for this
species.

Rock sanicle
Sanicula saxatilis
— SR 1B.2 No Bedrock outcrops and talus slopes in
chaparral or oak woodland habitat.
2,200–4,100 ft in elevation. Blooms
April–May. Perennial.

May occur. The project area contains
chaparral and oak woodland habitat that may
have rock outcrop habitat suitable for this
species.

Chaparral ragwort
Senecio aphanactis
— — 2B.2 No Chaparral, cismontane woodland,
coastal scrub. Drying alkaline flats. 70–
2,810 ft in elevation. Blooms January–
April. Annual.

May occur. There is a historic occurrence of
this species in the vicinity of the project area
near Palo Alto Foothills Park, although the
exact location is unknown (CNDDB 2025a).

The project area contains chaparral,
woodland, and coastal scrub habitat that may
contain alkaline substrate suitable for this
species.

San Francisco
campion
Silene verecunda ssp.
verecunda
— — 1B.2 No Ultramafic. Coastal scrub, valley and
foothill grassland, coastal bluff scrub,
chaparral, coastal prairie. Often on
mudstone or shale; one site on
serpentine. 100–2,120 ft in elevation.

Blooms March–June. Perennial.

Not expected to occur. This species is
primarily known from areas closer to the
coast.

Attachment B Ascent
Saratoga Fire Protection District
B-12 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Santa Cruz
microseris
Stebbinsoseris
decipiens
— — 1B.2 No Ultramafic. Broadleafed upland forest,
closed-cone coniferous forest,
chaparral, coastal prairie, coastal scrub,
valley and foothill grassland. Open
areas in loose or disturbed soil, usually
derived from sandstone, shale or
serpentine, on seaward slopes. 40–
1,640 ft in elevation. Blooms April–May.

Annual.

Not expected to occur. This species is
primarily known from areas closer to the
coast.

Metcalf Canyon
jewelflower
Streptanthus albidus
ssp. albidus
FE — 1B.1 Yes Ultramafic. Valley and foothill
grassland. Relatively open areas in dry
grassy meadows on serpentine soils;
also on serpentine balds. 150–2,630 ft
in elevation. Blooms April–July. Annual.

Known to occur. There are multiple
occurrences of this species in the project area
near Tulare Hill (CNDDB 2025a). Other
portions of the project area closer to the
valley floor contain serpentine grasslands
suitable for this species.

Most beautiful
jewelflower
Streptanthus albidus
ssp. peramoenus
— — 1B.2 Yes Ultramafic. Chaparral, valley and
foothill grassland, cismontane
woodland. Serpentine outcrops, on
ridges and slopes. 310–3,280 ft in
elevation. Blooms April–September.

Annual.

Known to occur. There are many occurrences
of this species in the eastern portion of the
project area, east of Los Gatos (CNDDB
2025a). Serpentine grassland, chaparral and
woodland habitat is present throughout the
project area that is suitable for this species.

Mt. Hamilton
jewelflower
Streptanthus callistus
— — 1B.3 No Chaparral, cismontane woodland.

Open talus slopes on shale with gray
pine and/or black oak. 1,970–2,590 ft in
elevation. Blooms April–May. Annual.

Not expected to occur. This species is only
known from the Mount Hamilton range;
therefore, the project area is outside of the
geographical range of this species.

Northern slender
pondweed
Stuckenia filiformis
ssp. alpina
— — 2B.2 No Wetland. Marshes and swamps.

Shallow, clear water of lakes and
drainage channels. 990–7,060 ft in
elevation. Blooms May–July. Geophyte.

May occur. The project area contains lake and
drainage habitat suitable for this species.

California seablite
Suaeda californica
FE — 1B.1 No Margins of coastal salt marshes. 0–20
ft in elevation. Blooms July–October.

Perennial.

Not expected to occur. The project area does
not contain coastal salt marsh habitat suitable
for this species.

Two-fork clover
Trifolium amoenum
FE — 1B.1 No Valley and foothill grassland, coastal
bluff scrub. Sometimes on serpentine
soil, open sunny sites, swales. Most
recently cited on roadside and eroding
cliff face. 20–1,020 ft in elevation.

Blooms April–June. Annual.

May occur. The project area contains
grassland habitat potentially suitable for this
species.

Santa Cruz clover
Trifolium
buckwestiorum
— — 1B.1 No Coastal prairie, broadleafed upland
forest, cismontane woodland, moist
grassland. Gravelly margins. 350–2,000
ft in elevation. Blooms April–October.

Annual.

May occur. The project area contains open
woodland and grassland habitat potentially
suitable for this species.

Saline clover
Trifolium
hydrophilum
— — 1B.2 No Marshes and swamps, valley and
foothill grassland, vernal pools. Mesic,
alkaline sites. 0–990 ft in elevation.

Blooms April–June. Annual.

Known to occur. There is a known occurrence
in the project area near Sargent (CNDDB
2025a). Vernal pools near Boronda Lake and
grassland and wetland habitat elsewhere in
the project area may provide habitat suitable
for this species.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-13 Species
Listing
Status1
Federal
Listing
Status1
State
CRPR SCVHP2 Habitat Potential for Occurrence3
Pacific Grove clover
Trifolium polyodon
— SR 1B.1 No Wetland. Closed-cone coniferous
forest, meadows and seeps, coastal
prairie, valley and foothill grassland.

Along small springs and seeps in
grassy openings. 20–400 ft in
elevation. Blooms April–June. Annual.

May occur. The project area contains closedcone coniferous forest and grassland habitat that may contain spring and seep habitat
suitable for this species.

Notes: ft = feet/foot; CRPR = California Rare Plant Rank; CEQA = California Environmental Quality Act; ESA = Endangered Species Act; NPPA = Native Plant Protection Act.
1 Legal Status Definitions
Federal:

FE Federally Listed as Endangered (legally protected by ESA) FT Federally Listed as Threatened (legally protected by ESA) State:

SE State Listed as Endangered (legally protected by CESA) ST State Listed as Threatened (legally protected by CESA) SR State Listed as Rare (legally protected by NPPA)
California Rare Plant Ranks (CRPR):
1A Plant species that are presumed extirpated or extinct because they have not been seen or collected in the wild in California for many years.

A plant is extinct if it no longer occurs anywhere. A plant that is extirpated from California has been eliminated from California but may still occur elsewhere in its range.
1B Plant species considered rare or endangered in California and elsewhere (protected under CEQA, but not legally protected under ESA or CESA). 2B Plant species considered rare or endangered in California but more common elsewhere (protected under CEQA, but not legally protected under ESA or CESA).

CRPR Threat Ranks:

0.1 Seriously threatened in California (over 80% of occurrences threatened; high degree and immediacy of threat)

0.2 Moderately threatened in California (20-80% occurrences threatened; moderate degree and immediacy of threat)

0.3 Not very threatened in California (less than 20% of occurrences threatened / low degree and immediacy of threat or no current threats known) 2 SCVHP: Covered species under the Santa Clara Valley Habitat Plan (Santa Clara 2014). 3 Potential for Occurrence Definitions
Not expected to occur: Species is unlikely to be present because of poor habitat quality, lack of suitable habitat features, or restricted current distribution of the species.

May occur: Suitable habitat is available and there have been nearby recorded occurrences of the species.

Known to occur: The species has been observed within the treatment areas.

Sources: Calflora 2025; CCH2 Portal 2025; CNDDB 2025a; CNPS 2025; iNaturalist 2025; Neubauer and Lyons 2023; USFWS 2025b.

Attachment B Ascent
Saratoga Fire Protection District
B-14 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Special-Status Wildlife Species Known to Occur in the Vicinity of the Project Area and Their Potential for Occurrence in the Project Area
Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Invertebrates
Crotch's bumble bee
Bombus crotchii
— SC No Found primarily in California: mediterranean,
Pacific coast, western desert, Great Valley,
and adjacent foothills through most of
southwestern California. Habitat includes
open grassland and scrub. Nests
underground.

Known to occur. The species has been
documented to occur within the project
area (CNDDB 2025a), and nesting and
overwintering habitat is present in
multiple portions of the project area.

Western bumble bee
Bombus occidentalis
— SC No Once common throughout much of its range,
in California, this species is currently largely
restricted to high elevation sites in the Sierra
Nevada and the northern California coast.

Habitat includes open grassy areas, chaparral,
scrub, and meadows. Requires suitable
nesting sites for the colonies, availability of
nectar and pollen from floral resources
throughout the duration of the colony period
(spring, summer, and fall), and suitable
overwintering sites for the queens.

Not expected to occur. Although the
project is within the historical range of the
species, the current range is limited to the
mountains of northern California, the
southern Cascades, and central and
northern Sierra Nevada (CDFW 2023).

Vernal pool fairy shrimp
Branchinecta lynchi
FT — No Valley and foothill grassland, vernal pool,
wetland. Endemic to the grasslands of the
Central Valley, Central Coast mountains, and
South Coast mountains, in astatic rain-filled
pools. Inhabit small, clear-water sandstonedepression pools and grassed swale, earth slump, or basalt-flow depression pools.

Not expected to occur. Vernal pools are
present within the project area in the
vicinity of Boronda Lake. These pools
could provide habitat for this species;
however, the species has not been
documented to occur north of Salinas or
west of the Livermore Valley (USFWS
2024a), and therefore, the project area is
likely outside of the range of this species.

Ohlone tiger beetle
Cicindela ohlone
FE — No Coastal prairie. Remnant native grasslands
with California oatgrass and purple
needlegrass in Santa Cruz County. Substrate
is poorly-drained clay or sandy clay soil over
bedrock of Santa Cruz mudstone.

Not expected to occur. The project area is
outside of the range of this species, which
is limited to grasslands within 7 miles of
the city of Santa Cruz and does not
extend east of Scotts Valley (USFWS
2024b).

Monarch
Danaus plexippus
FP — No Habitat requirements include host plants for
larvae (primarily milkweeds [Asclepias spp.]);
adult nectar sources (i.e., flowering plants);
and sites for roosting, thermoregulation,
mating, hibernation, and predator escape.

Additionally, monarch butterfly requires
conditions and resources for initiating and
completing migration both to and from
winter roosting areas. Winter roost sites
extend along the coast from northern
Mendocino to Baja California, Mexico. Roosts
located in wind-protected tree groves
(eucalyptus, Monterey pine, cypress), with
nectar and water sources nearby.

Known to occur. The project area is too
far from the coast and bay to provide
overwintering habitat; however, the
species has been documented to forage
and breed in the project area (Western
Monarch Milkweed Mapper 2025).

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-15 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Smith's blue butterfly
Euphilotes enoptes
smithi
FE — No Coastal dunes, coastal scrub. Most commonly
associated with coastal dunes and coastal
sage scrub plant communities in Monterey
and Santa Cruz counties. Host plants:

Eriogonum latifolium and Eriogonum
parvifolium are utilized as both larval and
adult foodplants.

Not expected to occur. The project area is
outside of the range and habitat of this
species, which is limited to coastal dunes
and coastal scrub in portions of Monterey
and Santa Cruz Counties.

Bay checkerspot
butterfly
Euphydryas editha
bayensis
FT — Yes Coastal dunes, valley and foothill grassland.

Restricted to native grasslands on outcrops
of serpentine soil in the vicinity of San
Francisco Bay. Plantago erecta is the primary
host plant; Castilleja densiflorus (previously
Orthocarpus densiflorus) and C. exserta
(previously Orthocarpus purpurscens are
secondary host plants.

Known to occur. The species is
documented to occur in portions of the
project area (e.g., Santa Teresa Hills,
Coyote Valley, Hayes Valley) (CNDDB
2025a). May be present on other
serpentine grasslands within the project
area.

Vernal pool tadpole
shrimp
Lepidurus packardi
FE — No V pool, wetlands. Inhabits vernal pools and
swales in the Sacramento Valley containing
clear to highly turbid water. Pools commonly
found in grass bottomed swales of unplowed
grasslands. Some pools are mud-bottomed
and highly turbid.

Not expected to occur. Vernal pools are
present within the project area in the
vicinity of Boronda Lake. Although the
species has been documented to occur in
southern Alameda County and San Benito
County (USFWS 2024a), the species is
absent from Santa Clara County;
therefore, the project area is likely outside
of the current range of this species.

Mount Hermon June
beetle
Polyphylla barbata
FE — No Interior dunes. Known only from sand hills in
vicinity of Mt. Hermon, Santa Cruz County.

Not expected to occur. The project area is
located outside of the Zayante Sand Hills
Ecosystem, which is of limited distribution
within Santa Cruz County (Santa Cruz
County 2011), and therefore outside the
range of this species.

Myrtle's silverspot
butterfly
Speyeria zerene
myrtleae
FE — No Coastal dunes. Restricted to the foggy,
coastal dunes/hills of the Point Reyes
peninsula; extirpated from coastal San Mateo
County. Larval foodplant thought to be Viola
adunca.

Not expected to occur. The project area is
located outside of the current range of
this species.

Zayante band-winged
grasshopper
Trimerotropis infantilis
FE — No Chaparral, interior dunes. Isolated sandstone
deposits in the Santa Cruz Mountains (the
Zayante Sand Hills ecosystem) Mostly on
sand parkland habitat but also in areas with
well-developed ground cover and in sparse
chaparral with grass.

Not expected to occur. The project area is
located outside of the Zayante Sand Hills
Ecosystem, which is of limited distribution
within Santa Cruz County (Santa Cruz
County 2011), and therefore outside the
range of this species.

Attachment B Ascent
Saratoga Fire Protection District
B-16 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Fish
Green sturgeon -
southern Distinct
Population Segment
(DPS)
Acipenser medirostris
FT SSC No Aquatic, estuary, marine bay,
Sacramento/San Joaquin flowing waters.

Spawns in the Sacramento, Feather and Yuba
Rivers. Presence in upper Stanislaus and San
Joaquin Rivers may indicate spawning. Nonspawning adults occupy marine/estuarine waters. Delta Estuary is important for rearing
juveniles. Spawning occurs primarily in cool
(11–15 C) sections of mainstem rivers in deep
pools (25–30 feet) with substrate containing
small to medium sized sand, gravel, cobble,
or boulder.

Not expected to occur. The project area is
outside of the documented range of this
species (CNDDB 2025b).

Pacific Lamprey
Entosphenus tridentatus
— SSC No This anadromous species spawns in
freshwater streams, where it spends several
years before migrating to the ocean as
juveniles.

May occur. Los Trancos Creek, Coyote
Creek, and other streams within the
northern portion project area as well as
portions of the Pajaro River and waters
within Pajaro River basin may support this
species below barriers that limit anadromy
(CNDDB 2025c).

Tidewater goby
Eucyclogobius newberryi
FE SSC No Klamath/north coast flowing waters,
Sacramento/San Joaquin flowing waters,
south coast flowing waters. Brackish water
habitats along the California coast from Agua
Hedionda Lagoon, San Diego County to the
mouth of the Smith River. Found in shallow
lagoons and lower stream reaches, needs
fairly still but not stagnant water and high
oxygen levels.

Not expected to occur. The project area
does not contain nor is it adjacent to
brackish water habitat for this species.

Southern coastal roach
Hesperoleucus venustus
subditus
— SSC No Found in the drainages of Tomales Bay and
northern San Francisco Bay in the north, and
drainages of Monterey Bay in the south.

May occur. The project area includes
portions of the Pajaro River and waters
within Pajaro River basin and may support
this species. The northern portion of the
project area is outside of the current
range of the subspecies described in
Baumstieger and Moyle (2019). Although
California roach has been documented in
Los Gatos Creek and Saratoga Creek
(Smith 2013), there are no records of
southern coastal roach in these waters.

Monterey hitch
Lavinia exilicauda
harengus
— SSC No Lowland clear-water pools or small reservoirs, especially in low-gradient sites in the Pajaro
River basin and the Salinas River system.

Require streams with permanent water and
large pools during the summer, especially
those with underwater cover (i.e., fallen trees)
or vegetation overhanging water. This
species does not have a specific sensitive
period. It may be found in its habitat yearround.

May occur. The southern portion of the
project area includes portions of the
Pajaro River and waters within Pajaro River
basin that may support this species.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-17 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Coho salmon - central
California coast
Evolutionary Significant
Unit (ESU)
Oncorhynchus kisutch
FE SE No Federal listing = pops between Punta Gorda
and San Lorenzo River. State listing includes
populations south of Punta Gorda. Require
beds of loose, silt-free, coarse gravel for
spawning. Also need cover, cool water, and
sufficient dissolved oxygen.

Not expected to occur. Coho were
present historically in Coyote Creek prior
to the construction of Anderson Dam. The
species is no longer thought to be present
in the creek above the confluence with
Upper Penitencia Creek (Leidy et al. 2005).

Coho has also been absent from the
Pajaro River and its tributaries since the
late 1960s (The Habitat Restoration Group
1997).

Steelhead - central
California coast DPS
Oncorhynchus mykiss
irideus
FT — No Sacramento/San Joaquin flowing waters.

From Russian River, south to Soquel Creek
and to, but not including, Pajaro River. Also
San Francisco and San Pablo Bay basins.

May occur. Los Trancos Creek, Coyote
Creek, and other streams within the
project area that are downstream of the
limit of anadromy provide habitat for this
DPS.

Steelhead - southcentral California coast
DPS
Oncorhynchus mykiss
irideus
FT — No Sacramento/San Joaquin flowing waters.

South coast flowing waters. Federal listing
refers to runs in coastal basins from the
Pajaro River south to, but not including, the
Santa Maria River.

May occur. The southern portion of the
project area includes portions of the
Pajaro River and waters within Pajaro River
basin that may support this species.

Longfin smelt San
Francisco Bay-Delta
DPS
Spirinchus thaleichthys
FE ST SSC No Estuary. Euryhaline, nektonic and
anadromous. Found in open waters of
estuaries, mostly in middle or bottom of
water column. Prefer salinities of 15-30 ppt,
but can be found in completely freshwater to
almost pure seawater.

Not expected to occur. The project area
does not contain nor is it adjacent to
estuary habitat for this species.

Amphibians
California tiger
salamander - central
California DPS
Ambystoma
californiense
FT ST Yes Lives in vacant or mammal-occupied burrows
throughout most of the year; in grassland,
savanna, or open woodland habitats. Need
underground refuges, especially ground
squirrel burrows, and vernal pools or other
seasonal water sources for breeding.

Known to occur. The species has been
documented in grasslands along the
eastern and lower elevation portions of
the project area (CNDDB 2025a).

Santa Cruz long-toed
salamander
Ambystoma
macrodactylum
croceum
FE SE, FP No Freshwater marsh, marsh and swamp, and
other wetlands. Wet meadows near sea level
in a few restricted locales in Santa Cruz and
Monterey Counties. Aquatic larvae prefer
shallow (less than 12 inches) water, using
clumps of vegetation or debris for cover.

Adults use mammal burrows.

Not expected. The range of the species
does not extend into the project area
(USFWS 2025a).

Santa Cruz black
salamander
Aneides niger
— SSC No Mixed deciduous and coniferous woodlands
and coastal grasslands in San Mateo, Santa
Cruz, and Santa Clara counties. Adults found
under rocks, talus, and damp woody debris.

Known to occur. The species is
documented to occur throughout the
project area at all elevations, from Stevens
Creek to the Pajaro River CNDDB 2025a).

Attachment B Ascent
Saratoga Fire Protection District
B-18 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
California giant
salamander
Dicamptodon ensatus
— SSC No Meadow and seep, north coast coniferous
forest, and riparian forest. Known from wet
coastal forests near streams and seeps from
Mendocino County south to Monterey
County and east to Napa County. Aquatic
larvae found in cold, clear streams,
occasionally in lakes and ponds. Adults
known from wet forests under rocks and logs
near streams and lakes.

Known to occur. The species is
documented to occur throughout the
project area within riparian and conifer
forests from Stevens Creek to Mount
Madonna County Park (CNDDB 2025a;
iNaturalist 2025).

Foothill yellow-legged
frog (Central Coast
DPS)
Rana boylii
FT SE Yes San Francisco Peninsula and Diablo Range
south of San Francisco Bay Estuary, and south
through the Santa Cruz and Gabilan
Mountains east of the Salinas River in the
southern inner Coast Ranges. Partly shaded
shallow streams and riffles with a rocky
substrate in a variety of habitats. Needs at
least some cobble-sized substrate for egglaying and at least 15 weeks to attain metamorphosis.

Known to occur. This species has been
documented to occur along and south of
Los Gatos Creek and has occurred
historically in the Stevens Creek
Watershed (CNDDB 2025a)
California red-legged
frog
Rana draytonii
FT SSC Yes Artificial flowing waters, artificial standing waters, freshwater marsh, marsh and swamp,
riparian forest, riparian scrub, riparian
woodland, Sacramento/San Joaquin flowing
waters, Sacramento/San Joaquin standing
waters, south coast flowing waters. Lowlands
and foothills in or near permanent sources of
deep water with dense, shrubby, or emergent
riparian vegetation. Requires 11-20 weeks of
permanent water for larval development.

Must have access to estivation habitat.

Known to occur. The species has been
documented to occur throughout the
project area from Los Trancos Creek to
the Pajaro River and east to Coyote Creek
(CNDDB 2025a).

Western spadefoot
Spea hammondii
FP SSC No Cismontane woodland, coastal scrub, valley
and foothill grassland, vernal pool, and
wetlands. Occurs primarily in grassland
habitats, but can be found in valley-foothill
hardwood woodlands. Vernal pools are
essential for breeding and egg-laying.

Not likely to occur. The range of the
species in the region does not extend
north of the Pajaro River (CNDDB 2025d).

Red-bellied newt
Taricha rivularis
— SSC No Broadleaved upland forest, north coast
coniferous forest, redwood, riparian forest,
and riparian woodland. Coastal drainages
from Humboldt County south to Sonoma
County, inland to Lake County. Isolated
population of uncertain origin in Santa Clara
County. Lives in terrestrial habitats, juveniles
generally underground, adults active at
surface in moist environments. Will migrate
over 1 km to breed, typically in streams with
moderate flow and clean, rocky substrate.

Known to occur. The species has been
documented to occur within the Stevens
Creek watershed and other areas north of
Los Gatos Creek (CNDDB 2025a); it is not
likely to occur south of Los Gatos Creek.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-19 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Reptiles
Southwestern pond
turtle
Actinemys pallida
FP SSC Yes Ponds, marshes, rivers, streams and irrigation ditches, usually with aquatic vegetation,
below 6,000 ft elevation. Needs basking sites
and suitable (sandy banks or grassy open
fields) upland habitat up to approximately 0.3
miles (0.5 km) from water for egg-laying.

Known to occur. Documented throughout
the project area from Los Trancos Creek
to the Pajaro River and east to Coyote
Creek (CNDDB 2025a).

Northern California
legless lizard
Anniella pulchra
— SSC No Chaparral, coastal dunes, coastal scrub.

Sandy or loose loamy soils under sparse
vegetation. Soil moisture is essential. Prefers
soils with a high moisture content.

Known to occur. The species has been
documented in Helyer County Park. It may
be present in other portions of the project
area where habitat is present (e.g., sandy
soils).

San Joaquin coachwhip
Masticophis flagellum
ruddocki
— SSC No Chenopod scrub, valley and foothill
grassland. Open, dry habitats with little or no
tree cover. Found in valley grassland and
saltbush scrub in the San Joaquin Valley.

Needs mammal burrows for refuge and
oviposition sites.

Not expected to occur. Helyer County
Park is within the documented range of
the species (CNDDB 2025e); however,
open grassland and scrub habitat is not
present in this location. The portions of
the project area along Coyote Creek that
may have habitat marginally suitable for
the species are within 0.25 miles of the
documented range of the species but are
separated from the range by US Route
101, which is likely a barrier to dispersal. In
addition, grassland habitat in the
southernmost portion of the project area
is near the range of the species, but
separated from the range by the Pajaro
River.

Alameda whipsnake
Masticophis lateralis
euryxanthus
FT ST No Chaparral, cismontane woodland, coastal
scrub, valley and foothill grassland. Typically
found in chaparral and scrub habitats but will
also use adjacent grassland, oak savanna and
woodland habitats. Mostly south-facing
slopes and ravines, with rock outcrops, deep
crevices or abundant rodent burrows, where
shrubs form a vegetative mosaic with oak
trees and grasses.

Not expected to occur. The project area is
outside of the documented range of the
species (USFWS 2020a).

Coast horned lizard
Phrynosoma blainvillii
— SSC No Chaparral, cismontane woodland, coastal
bluff scrub, coastal scrub, desert wash,
pinyon and juniper woodlands, riparian
scrub, riparian woodland, valley and foothill
grassland. Frequents a wide variety of
habitats, most common in lowlands along
sandy washes with scattered low bushes.

Open areas for sunning, bushes for cover,
patches of loose soil for burial, and abundant
supply of native ants and other insects.

Known to occur. The species has been
documented within the portion of the
project area north of Los Gatos Creek.

Habitat for the species is present
throughout other portions of the project
area, and the species may occur anywhere
habitat is present.

Attachment B Ascent
Saratoga Fire Protection District
B-20 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
San Francisco
gartersnake
Thamnophis sirtalis
tetrataenia
FE SE FP No Artificial standing waters, marsh and swamp, Sacramento/San Joaquin standing waters,
wetland. Vicinity of freshwater marshes,
ponds and slow-moving streams in San
Mateo County and extreme northern Santa
Cruz County. Prefers dense cover and water
depths of at least one foot. Upland areas
near water are also very important.

Not expected to occur. The range of the
species extends south to near the Town of
Woodside, just north of Los Trancos
Creek. The species is also documented to
occur within Russian Ridge Open Space
Preserve (USFWS 2020b). These locations
are outside and north of the project area.

Although the species is known to occur
near the project area, the northwestern
portion of the project area is within a zone
of hybridization between San Francisco
gartersnake (Thamnophis sirtalis
tetrataenia) and red-sided gartersnake
(Thamnophis sirtalis infernalis), both
subspecies of the common gartersnake
(USFWS 2020b). Because the project falls
within the area of hybridization, San
Francisco gartersnakes are not expected
to occur within the project area.

Birds
Tricolored blackbird
Agelaius tricolor
— ST, SSC Yes Freshwater marsh, swamp, other wetlands.

Highly colonial species, most numerous in
Central Valley and vicinity. Largely endemic
to California. Requires open water, protected
nesting substrate, and foraging area with
insect prey within a few kilometers of the
colony.

Known to occur. The species has been
documented to occur within Caldero
County Park and along Coyote Creek. The
species may occur in other areas of the
project where aquatic and foraging
habitat occur.

Grasshopper sparrow
Ammodramus
savannarum
— SSC No Valley and foothill grassland. Dense
grasslands on rolling hills, lowland plains, in
valleys and on hillsides on lower mountain
slopes. Favors native grasslands with a mix of
grasses, forbs and scattered shrubs. Loosely
colonial when nesting.

Known to occur. The species has been
documented at the northernmost portion
of the project area, Santa Teresa Hills, and
Caldero County Park (iNaturalist 2025).

Grassland habitat for the species is also
present in other portions of the project
area.

Golden eagle
Aquila chrysaetos
— FP No Broadleaved upland forest, cismontane
woodland, coastal prairie, Great Basin
grassland, Great Basin scrub, lower montane
coniferous forest, pinyon and juniper
woodlands, upper montane coniferous forest,
and valley and foothill grassland. Rolling
foothills, mountain areas, sage-juniper flats,
and desert. Cliff-walled canyons provide
nesting habitat in most parts of range; also,
large trees in open areas.

Known to occur. The species has been
documented in the project area, and the
more remote portions of the project area
may provide nesting habitat for the
species (CNDDB 2025a).

Short-eared owl
Asio flammeus — SSC No
Found in swamp lands, both fresh and salt;
lowland meadows; irrigated alfalfa fields. Tule
patches/tall grass needed for
nesting/daytime seclusion. Nests on dry
ground in depression concealed in
vegetation.

May occur. Habitat potentially suitable for
this species may be present within the
project area along Coyote Creek and at
Caldero Reservoir.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-21 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Long-eared owl
Asio otus
— SSC No Cismontane woodland, Great Basin scrub,
riparian forest, riparian woodland, and upper
montane coniferous forest. Riparian
bottomlands with tall willows and
cottonwoods; also, belts of live oak
paralleling stream courses. Require adjacent
open land with mice and the presence of old
nests of crows, hawks, or magpies for
breeding.

May occur. Habitat potentially suitable for
this species may be present within the
project area along Coyote Creek, Pajaro
River, and other riparian corridors.

Burrowing owl
Athene cunicularia
— SC, SSC Yes Coastal prairie, coastal scrub, Great Basin grassland, Great Basin scrub, Mojavean
desert scrub, Sonoran Desert scrub, and
valley and foothill grassland. Open, dry
annual or perennial grasslands, deserts and
scrublands characterized by low-growing
vegetation. Subterranean nester, dependent
on burrowing mammals, most notably, the
California ground squirrel.

Known to occur. The species has been
documented in the Coyote Valley, and
Caldero County Park (iNaturalist 2025).

Grassland habitat for the species is also
present in other portions of the project
area. Grasslands in most of the project
area are within the winter range of the
species, and only the most eastern
portions of the project area are within the
yearlong range where nesting may occur
(CNDDB 2025f).

Marbled murrelet
Brachyramphus
marmoratus
FT SE No Lower montane coniferous forest, old growth
redwood forest. Feeds near shore; nests
inland along coast from Eureka to Oregon
border and from Half Moon Bay to Santa
Cruz. Nests in old-growth redwooddominated forests, up to six miles inland, often in Douglas fir.

Not expected to occur. The species is
documented to occur within the project
region, and the project is within Zone 6 of
the species recovery plan, although
documented occurrences are limited to
San Mateo County and northwestern
Santa Cruz County (CNDDB 2025a)
outside of the project area on the west
side of the crest of the Santa Cruz
Mountains and north of Santa Cruz.

Although recent fires in the region may
have caused shifts in occupancy and
range, it is not likely that the portions of
the project area east of the crest of the
Santa Cruz Mountains or in the
southernmost portion of the project area
(e.g., Mount Madonna County Park) have
been populated by these changes due to
additional mature forest stands closer to
habitat lost in the fires. Individual
redwood and Douglas-fir trees in the
project area may be large enough for
nesting; however, the project is outside of
the known nesting range within the Santa
Cruz Mountains as defined in Paton and
Ralph (1990) and Halbert and Singer
(2017). Therefore, the project area is not
likely to be used by marbled murrelet for
nesting.

Attachment B Ascent
Saratoga Fire Protection District
B-22 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Barrow's goldeneye
Bucephala islandica
— SSC No Breeds in high central and northern Sierra
Nevada mountains, near wooded mountain
lakes or large streams. Nest in tree cavities,
such as a deserted nest-hole of a pileated
woodpecker or flicker; also use nest boxes.

May occur. The species may be present
wintering and foraging at larger reservoirs
in project area, but the project area is
outside of the breeding range of the
species.

Swainson's hawk
Buteo swainsoni
— ST No Great Basin grassland, riparian forest, riparian woodland, valley and foothill grassland.

Breeds in grasslands with scattered trees,
juniper-sage flats, riparian areas, savannahs,
and agricultural or ranch lands with groves or
lines of trees. Requires adjacent suitable
foraging areas such as grasslands, or alfalfa
or grain fields supporting rodent populations.

Known to occur. The species has been
documented to nest within the Coyote
Creek area (CNDDB 2025a) and may occur
in similar locations in the eastern portions
of the project area.

Vaux’s swift
Chaetura vauxi
— SSC No Lower montane coniferous forest, north coast
coniferous forest, old growth redwood forest.

Redwood, Douglas fir, and other coniferous
forests. Nests in large hollow trees and snags.

Often nests in flocks. Forages over most
terrains and habitats but shows a preference
for foraging over rivers and lakes.

Known to occur. The species has been
reported in the project area (iNaturalist
2025), and habitat for the species occurs
in higher elevation portions of the project
area where conifer forests are present.

Western snowy plover
Charadrius nivosus
nivosus
FT SSC No Sandy beaches, salt pond levees, and shores
of large alkali lakes. Needs sandy, gravelly or
friable soils for nesting.

Not expected to occur. Habitat for this
species is not present within the project
area.

Northern harrier
Circus hudsonius
— SSC No Coastal salt and freshwater marsh. Nest and
forage in grasslands, from salt grass in desert
sink to mountain cienagas. Nests on ground
in shrubby vegetation, usually at marsh edge;
nest built of a large mound of sticks in wet
areas.

Known to occur. The species has been
documented to occur in the vicinity of
Caldero Reservoir and in the Los Trancos
watershed. Habitat for the species is likely
present in other portions of the project
area.

Western yellow-billed
cuckoo
Coccyzus americanus
occidentalis
FT SE No Riparian forest. Riparian forest nester, along the broad, lower flood-bottoms of larger
river systems. Nests in riparian jungles of
willow, often mixed with cottonwoods, with
lower story of blackberry, nettles, or wild
grape.

Not expected to occur. Although the
riparian corridor along the Pajaro River is
potentially suitable, the species has not
been documented to occur within the
region (CNDDB 2025a; iNaturalist 2025),
and the project area is outside of the
range of the species.

Olive-sided flycatcher
Contopus cooperi
— SSC No Lower montane coniferous forest, redwood,
upper montane coniferous forest. Nesting
habitats are mixed conifer, montane
hardwood-conifer, Douglas fir, redwood, red
fir and lodgepole pine. Most numerous in
montane conifer forests where tall trees
overlook canyons, meadows, lakes, or other
open terrain.

Known to occur. The species has been
reported in the project area (iNaturalist
2025), and habitat for the species occurs
in portions of the project area where
conifer forests are present.

Yellow rail
Coturnicops
noveboracensis
— SSC No Breeds in freshwater marsh, meadow and
seep. Summer resident in eastern Sierra
Nevada in Mono County. Overwinters in
Fresh-water and brackish water marshlands
along the coast and bay..

Not expected to occur. The project area is
outside of the breeding range of the
species. The species overwinters in fresh
and brackish water marshes along the
coast. However, the project area is too far
from the bay or coastline to be
overwintering habitat.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-23 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Black swift
Cypseloides niger
— SSC No Coastal belt of Santa Cruz and Monterey
Counties; central and southern Sierra
Nevada; San Bernardino and San Jacinto
Mountains. Breeds in small colonies on cliffs
behind or adjacent to waterfalls in deep
canyons and sea-bluffs above the surf;
forages widely
May occur. Some of the larger streams in
the project area may contain waterfalls
that provide nesting habitat for the
species.

White-tailed kite
Elanus leucurus
— FP No Cismontane woodland, marsh and swamp,
riparian woodland, valley and foothill
grassland, and wetlands. Rolling foothills and
valley margins with scattered oaks and river
bottomlands or marshes next to deciduous
woodland. Open grasslands, meadows, or
marshes for foraging close to isolated,
dense-topped trees for nesting and perching.

Known to occur. The species has been
reported in oak woodland and grassland
habitats throughout the project area
(iNaturalist 2025), and juvenile whitetailed kites were observed in Arastradero Preserve during SPR BIO-1 surveys.

Common loon
Gavia immer
— SSC No Great Basin standing waters. Nesting
locations at certain large lakes and reservoirs
in interior of state, primarily in northeastern
plateau region. Bodies of water regularly
frequented are extensive, relatively deep, and
produce quantities of large fish.

May occur in larger reservoirs in the
project area, but the project area is
outside of the breeding range of the
species.

Saltmarsh common
yellowthroat
Geothlypis trichas
sinuosa
BCC SSC No Marsh and swamp. Resident of the San
Francisco Bay region, in fresh and salt water
marshes. Requires thick, continuous cover
down to water surface for foraging; tall
grasses, tule patches, willows for nesting.

May occur. Marsh habitat the may be
suitable for this species, which occurs
around Caldero Reservoir, along Coyote
Creek, and other locations within the
project area.

California condor
Gymnogyps
californianus
FE SE FP No Chaparral, valley and foothill grassland.

Require vast expanses of open savannah,
grasslands, and foothill chaparral in mountain
ranges of moderate altitude. Deep canyons
containing clefts in the rocky walls provide
nesting sites. Forages up to 100 miles from
roost/nest.

May occur. The species has been
documented in the eastern portion of
Santa Clara County near Anderson Lake
and along State Route 152. The species is
not likely to nest in the project area due
to an absence of suitable nesting sites, but
may forage in more open locations.

Bald eagle
Haliaeetus
leucocephalus
— SE FP No Lower montane coniferous forest, old
growth. Ocean shore, lake margins, and rivers
for both nesting and wintering. Most nests
within 1 mile of water. Nests in large, oldgrowth, or dominant live tree with open branches, especially ponderosa pine. Roosts
communally in winter.

Known to occur. The species has been
reported to overwinter and nest within the
project area (iNaturalist 2025), and nesting
habitat is present in the project area near
larger lakes and reservoirs.

Yellow-breasted chat
Icteria virens
— SSC No Riparian forest, riparian scrub, riparian
woodland. Summer resident; inhabits riparian
thickets of willow and other brushy tangles
near watercourses. Nests in low, dense
riparian habitat, consisting of willow,
blackberry, wild grape; forages and nests
within 10 feet of ground.

Known to occur. The species has been
documented near Chesbro Reservoir, and
habitat for the species is present along
many streams throughout the project
area.

Attachment B Ascent
Saratoga Fire Protection District
B-24 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Loggerhead shrike
Lanius ludovicianus
— SSC No Broadleaved upland forest, desert wash,
Joshua tree woodland, Mojavean desert
scrub, pinyon and juniper woodlands,
riparian woodland, Sonoran desert scrub.

Broken woodlands, savannah, pinyon-juniper,
Joshua tree, and riparian woodlands, desert
oases, scrub and washes. Prefers open
country for hunting, with perches for
scanning, and dense shrubs for nesting.

Known to occur. The species as been
documented in Coyote Valley Open Space
Preserve, and habitat for the species
occurs in the more open portions of the
project area.

California black rail
Laterallus jamaicensis
coturniculus
— ST FP No Brackish marsh, freshwater marsh, marsh and
swamp, salt marsh. Inhabits freshwater
marshes, wet meadows and shallow margins
of saltwater marshes bordering larger bays.

Needs water depths of about 1 inch that do
not fluctuate during the year and dense
vegetation for nesting habitat.

Not expected to occur. The project area is
outside of the range of this species
(CNDDB 2025g).

Alameda song sparrow
Melospiza melodia
pusillula
— SSC No Resident of salt marshes bordering south arm
of San Francisco Bay. Inhabits pickleweed
(Salicornia spp.) marshes; nests low in
Grindelia plants (high enough to escape high
tides) and in pickleweed.

Not expected to occur. The species is
unlikely to be present in the project area
because the project area lacks the salt
marsh pickleweed habitat needed for this
species.

American white pelican
Pelecanus
erythrorhynchos
— SSC No Colonial nester on large interior lakes. Nests on large lakes, providing safe roosting and
breeding places in the form of wellsequestered islets.

May occur. Larger reservoirs within the
project area may provide foraging habitat
for this species. However, the project area
is outside of the breeding range of the
species (CNDDB 2025h).

Purple martin
Progne subis
— SSC No Broadleaved upland forest, lower montane
coniferous forest. Inhabits woodlands, low
elevation coniferous forest of Douglas fir,
ponderosa pine, and Monterey pine. Nests in
old woodpecker cavities mostly, also in
human-made structures. Nest is often
located in tall, isolated tree/snag.

Known to occur. The species is
documented to occur within the project
area in the vicinity of Mount Umunhum
(CNDDB 2025a). Large trees and snags
within the project area provide nesting
habitat for this species.

California Ridgway's rail
Rallus obsoletus
obsoletus
FE SE FP No Salt-water and brackish marshes traversed by tidal sloughs in the vicinity of San Francisco
Bay. Associated with abundant growths of
pickleweed, but feeds away from cover on
invertebrates from mud-bottomed sloughs.

Not expected to occur. This species is
unlikely to be present in the project area
because the project area lacks the salt and
brackish marsh habitat needed for this
species.

Bank swallow
Riparia riparia
— ST No Riparian scrub, riparian woodland. Colonial
nester; nests primarily in riparian and other
lowland habitats west of the desert. Requires
vertical banks or cliffs with fine-textured or
sandy soils near streams, rivers, lakes, ocean
to dig nesting hole.

Not expected to occur. The project area is
outside of the documented range of this
species (CNDDB 2025i), and the banks of
streams and the Pajaro River in the project
area are not likely to provide the substrate
needed for nesting.

Black skimmer
Rynchops niger
BCC SSC No Alkali playa, sand shore. Nests on gravel bars, low islets, and sandy beaches, in unvegetated
sites. Nesting colonies usually less than 200
pairs.

Not expected to occur. This species is
unlikely to be present in the project area
because the project area lacks the sandy
shore and alkali playa habitat needed for
this species. No impact is anticipated.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-25 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Yellow warbler
Setophaga petechia
— SSC No Riparian forest, riparian scrub, riparian
woodland. Riparian plant associations near
water. Also nests in montane shrubbery in
open conifer forests in Cascades and Sierra
Nevada. Frequently found nesting and
foraging in willow shrubs and thickets, and in
other riparian plants including cottonwoods,
sycamores, ash, and alders.

Known to occur. The species has been
documented in riparian corridors in
multiple locations throughout the project
area (iNaturalist 2025).

California least tern
Sternula antillarum
browni
FE SE FP No Nests along the coast from San Francisco Bay south to northern Baja California. Colonial
breeder on bare or sparsely vegetated, flat
substrates: sand beaches, alkali flats, landfills,
or paved areas.

Not expected to occur. This species is
unlikely to be present in the project area
because the project area lacks the sand
shore and alkali playa habitat needed for
this species.

Least Bell's vireo
Vireo bellii pusillus
FE SE Yes Riparian forest, riparian scrub, riparian
woodland. Summer resident of southern
California in low riparian habitats or in dry
river bottoms; below 2,000 feet. Nests placed
along margins of shrubs or on twigs
projecting into pathways, usually willow,
coyote brush, mesquite.

May occur. Mature riparian areas with
multiple layered canopies and riparian
shrubs that provide habitat for the species
occur along portions of lower elevation
creeks and streams within the project
area.

Mammals
Pallid bat
Antrozous pallidus
— SSC No Deserts, grasslands, shrublands, woodlands
and forests. Most common in open, dry
habitats with rocky areas for roosting. Tree
roosting has also been documented in large
conifer snags, inside basal hollows of
redwoods and giant sequoias, and bole
cavities in oaks. Roosts must protect bats
from high temperatures. Very sensitive to
disturbance of roosting sites.

May occur. The species has been
documented in the project region
(CNDDB 2025a). Cavities in large trees
and snags within the project area may be
suitable roosts for pallid bat.

Northern California
ringtail
Bassariscus astutus
raptor
— FP — Riparian habitats, forest habitats, and shrub
habitats in lower to middle elevations.

May occur. Habitats potentially suitable
for ringtail are present within riparian
areas, chaparral, and forested areas near
streams and drainages in the project area.

Townsend's big-eared
bat
Corynorhinus
townsendii
— SSC No Throughout California in a wide variety of
habitats. Most common in mesic sites.

Requires large cavities for roosting, which
may include abandoned buildings and mines,
caves, and basal cavities of trees. Roosts in
the open, hanging from walls and ceilings.

Roosting sites limiting. Extremely sensitive to
human disturbance.

May occur. Townsend’s big-eared bat has
been documented in the project region
and historically within the Los Gatos Creek
drainage (CNDDB 2025a). Cavities in large
redwood trees, crevices in rock outcrops,
and abandoned structures within the
project area may provide roosts for
Townsend’s big-eared bat.

Attachment B Ascent
Saratoga Fire Protection District
B-26 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
Western mastiff bat
Eumops perotis
californicus
— SSC No Chaparral, cismontane woodland, coastal
scrub, valley and foothill grassland. Found in
a variety of habitats, from desert scrub to
chaparral to oak woodland and into the
ponderosa pine belt and high elevation
meadows of mixed conifer forests. The
distribution of this species is likely
geomorphically determined, with the species
being present only where there are
significant rock features offering roosting
habitat.

May occur. Rock features potentially
suitable for roosting by western mastiff
bat are present in portions of the project
area.

Western red bat
Lasiurus frantzii
— SSC No Cismontane woodland, lower montane
coniferous forest, riparian forest, riparian
woodland. Roosts primarily in trees, 2–40 feet
above ground, from sea level up through
mixed conifer forests. Prefers habitat edges
and mosaics with trees that are protected
from above and open below with open areas
for foraging.

May occur. Broadleaved and conifer
forests and riparian corridors within the
project area provide habitat for this
species.

San Francisco duskyfooted woodrat
Neotoma fuscipes
annectens
— SSC No . Forest habitats of moderate canopy and
moderate to dense understory. May prefer
chaparral and redwood habitats. Constructs
nests of shredded grass, leaves and other
material. May be limited by availability of
nest-building materials.

Known to occur. The species has been
documented during previous treatment
activities within the project area as well as
during SPR BIO-1 surveys. Forested,
chaparral, and oak woodland habitats
within the project area are suitable for this
species.

Mountain lion
Puma concolor
— SC No Mountain lions inhabit a wide range of
ecosystems, including mountainous regions,
forests, deserts, and wetlands. Mountain lions
establish and defend large territories and can
travel large distances in search of prey or
mates. In April of 2020, the California Fish
and Game Commission found that listing of
the Central Coast and Southern California
Evolutionarily Significant Units may be
warranted, and designated mountain lion
within these ESUs as a candidate species.

Known to occur. The species has been
documented to occur in multiple locations
throughout the project area (iNaturalist
2025). The more remote portions of the
project area that are undisturbed by
human activities may support denning
and nursery habitat.

Salt-marsh harvest
mouse Reithrodontomys
raviventris
FE SE FP No Only in the saline emergent wetlands of San Francisco Bay and its tributaries. Pickleweed
is primary habitat, but may occur in other
marsh vegetation types and in adjacent
upland areas. Does not burrow, builds loosely
organized nests. Requires higher areas for
flood escape.

Not expected to occur. The project area
does not contain nor is it adjacent to salt
marsh habitat for this species.

Salt-marsh wandering
shrew
Sorex vagrans halicoetes
— SSC No Salt marshes of the south arm of San
Francisco Bay. Medium high marsh 6-8 feet
above sea level where abundant driftwood is
scattered among pickleweed (Salicornia spp.).

Not expected to occur. The project area
does not contain nor is it adjacent to salt
marsh habitat for this species.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-27 Species Federal
Status1
State
Status1 SCVHP1
Habitat and Distribution Potential for Occurrence2
American badger
Taxidea taxus — SSC No
American badgers are mostly found in
treeless areas including prairies, grassdominated meadows and fields within forested habitats, and shrub-steppe
communities. Most abundant in drier open
stages of most vegetation types, with friable
soils. Needs sufficient food, friable soils and
open, uncultivated ground. Preys on
burrowing rodents. Digs burrows.

Known to occur. The species has been
documented to occur in grassland
habitats throughout the project area
(CNDDB 2025a).

San Joaquin kit fox
Vulpes macrotis mutica FE ST Yes
Chenopod scrub, valley and foothill
grassland. Annual grasslands or grassy open
stages with scattered shrubby vegetation.

Need loose-textured sandy soils for
burrowing, and suitable prey base.

May occur. The portion of the project area
within the Coyote Valley and surrounding
hills is within the range of the species and
predicted suitable habitat (CNDDB 2025j),
which includes grasslands, oak savannah,
and open shrubland with sandy soils for
burrowing.

Notes: CNDDB = California Natural Diversity Database; CEQA = California Environmental Quality Act. 1 Legal Status Definitions
Federal:

FE Federally Listed as Endangered (legally protected)
FT Federally Listed as Threatened (legally protected)
FD Federally Delisted
FP Proposed for Listing under the federal Endangered Species Act State:

FP Fully Protected (legally protected)
SSC Species of Special Concern (no formal protection other than CEQA consideration) SE State Listed as Endangered (legally protected)
ST State Listed as Threatened (legally protected)
SC State Candidate for listing (legally protected)
SD State Delisted
SCVHP: Covered species under the Santa Clara Valley Habitat Plan (Santa Clara County et al. 2012). 2 Potential for Occurrence Definitions
Not expected to occur: Species is unlikely to be present because of poor habitat quality, lack of suitable habitat features, or restricted current distribution of the species.

May occur: Suitable habitat is available; however, there are little to no other indicators that the species might be present.

Known to occur: Species has been documented within the treatment site.

Sources: Baumstieger and Moyle 2019; CDFW 2023; CNDDB 2025a, 2025b, 2025c, 2025d, 2025e, 2025f, 2025g, 2025h, 2025i, 2025j; Halbert and Singer 2017; Hansen and Shedd 2025; Leidy et al. 2005; Paton and Ralph 1990; Santa Clara County et al. 2012; Santa Cruz County 2011; Smith 2013; The Habitat Restoration Group 1997; USFWS 2020a, 2020b, 2024a, 2024b, 2025a, 2025b; Western Monarch and Milkweed Mapper 2025.

Attachment B Ascent
Saratoga Fire Protection District
B-28 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR This page is intentionally left blank.

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-29 Source: Adapted by Ascent in 2026.

Map B-1. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 1 of 38

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-31 Source: Adapted by Ascent in 2026.

Map B-2. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 2 of 38

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-33 Source: Adapted by Ascent in 2026.

Map B-3. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 3 of 38

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-35 Source: Adapted by Ascent in 2026.

Map B-4. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 4 of 38

Ascent Attachment B
Saratoga Protection Fire District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-37 Source: Adapted by Ascent in 2026.

Map B-5. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 5 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-39 Source: Adapted by Ascent in 2026.

Map B-6. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 6 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-41 Source: Adapted by Ascent in 2026.

Map B-7. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 7 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-43 Source: Adapted by Ascent in 2026.

Map B-8. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 8 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-45 Source: Adapted by Ascent in 2026.

Map B-9. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 9 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-47 Source: Adapted by Ascent in 2026.

Map B-10. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 10 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-49 Source: Adapted by Ascent in 2026.

Map B-11. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 11 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-51 Source: Adapted by Ascent in 2026.

Map B-12. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 12 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-53 Source: Adapted by Ascent in 2026.

Map B-13. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 13 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-55 Source: Adapted by Ascent in 2026.

Map B-14. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 14 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-57 Source: Adapted by Ascent in 2026.

Map B-15. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 15 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-59 Source: Adapted by Ascent in 2026.

Map B-16. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 16 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-61 Source: Adapted by Ascent in 2026.

Map B-17. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 17 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-63 Source: Adapted by Ascent in 2026.

Map B-18. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 18 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-65 Source: Adapted by Ascent in 2026.

Map B-19. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 19 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-67 Source: Adapted by Ascent in 2026.

Map B-20. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 20 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-69 Source: Adapted by Ascent in 2026.

Map B-21. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 21 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-71 Source: Adapted by Ascent in 2026.

Map B-22. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 22 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-73 Source: Adapted by Ascent in 2026.

Map B-23. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 23 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-75 Source: Adapted by Ascent in 2026.

Map B-24. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 24 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-77 Source: Adapted by Ascent in 2026.

Map B-25. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 25 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-79 Source: Adapted by Ascent in 2026.

Map B-26. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 26 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-81 Source: Adapted by Ascent in 2026.

Map B-27. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 27 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-83 Source: Adapted by Ascent in 2026.

Map B-28. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 28 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-85 Source: Adapted by Ascent in 2026.

Map B-29. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 29 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-87 Source: Adapted by Ascent in 2026.

Map B-30. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 30 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-89 Source: Adapted by Ascent in 2026.

Map B-31. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 31 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-91 Source: Adapted by Ascent in 2026.

Map B-32. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 32 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-93 Source: Adapted by Ascent in 2026.

Map B-33. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 33 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-95 Source: Adapted by Ascent in 2026.

Map B-34. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 34 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-97 Source: Adapted by Ascent in 2026.

Map B-35. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 35 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-99 Source: Adapted by Ascent in 2026.

Map B-36. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 36 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-101 Source: Adapted by Ascent in 2026.

Map B-37. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 37 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-103 Source: Adapted by Ascent in 2026.

Map B-38. Chaparral and Coastal Sage Scrub in CAL FIRE Interface Buffer - Map 38 of 38

Ascent Attachment B
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum B-105

REFERENCES
Baumstieger, J., and P. B. Moyle. 2019. A reappraisal of the California Roach/Hitch (Cypiniformes, Cyprinidae, Hesperoleucus/Lavinia species complex. Zootaxa 4543 (2):221-240. Available:
https://mwfb.ucdavis.edu/sites/g/files/dgvnsk1266/files/inline-files/38102.pdf. Accessed June 18, 2025.

Calflora. 2025. Information on California plants for education, research and conservation. [web application]. The Calflora Database. Available: https://www.calflora.org/. Accessed August 21, 2025.

California Department of Fish and Wildlife. 2023. Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species. Available:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline. Accessed November 12, 2024.

California Native Plant Society. 2025. Rare Plant Inventory (online edition, v9.5). Results of electronic records search of the following US Geological Survey quadrangles: Santa Teresa Hills, Woodside, Palo Alto, Mountain View, 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.

Madonna, Gilroy, Gilroy Hot Springs, Watsonville East, Watsonville West, Chittenden, San Felipe, Hollister, San Juan Bautista, and Prunedale. Available: http://www.rareplants.cnps.org. Retrieved July 10, 2025.

California Natural Diversity Database. 2025a. Results of electronic records search of the following US Geological Survey quadrangles: Santa Teresa Hills, Woodside, Palo Alto, Mountain View, 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. Madonna, Gilroy, Gilroy Hot Springs, Watsonville East, Watsonville West, Chittenden, San Felipe, Hollister, San Juan Bautista, and Prunedale. California Department of Fish and Wildlife, Biogeographic Data Branch. Sacramento, CA. Retrieved July 10, 2025.

California Natural Diversity Database. 2025b. Southern Green Sturgeon Range [ds1205] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved July 15, 2025.

California Natural Diversity Database. 2025c. Pacific Lamprey Historical Range and Current Distribution [ds2673] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved July 15, 2025.

California Natural Diversity Database. 2025d. Western Spadefoot Range [ds590] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved August 18, 2025.

California Natural Diversity Database. 2025e. Coachwhip Range [ds1759] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved August 18, 2025.

California Natural Diversity Database. 2025f. Burrowing Owl Range [ds907] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved August 19, 2025.

California Natural Diversity Database. 2025g. California Black Rail Range [ds595] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved August 21, 2025.

California Natural Diversity Database. 2025h. American White Pelican Range [ds964] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved October 21, 2025.

California Natural Diversity Database. 2025i. Bank Swallow Range [ds595] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved August 21, 2025.

California Natural Diversity Database. 2025j. Kit Fox Predicted Habitat [ds2599] Sacramento: California Department of Fish and Wildlife, Biogeographic Data Branch. Retrieved October 21, 2025.

CCH2. See Consortium of California Herbarium 2 Portal.

CDFW. See California Department of Fish and Wildlife.

Consortium of California Herbarium 2 Portal. 2025. Available: https://www.cch2.org/portal/index.php. Accessed on September 03.

Attachment B Ascent
Saratoga Fire Protection District
B-106 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR CNDDB. See California Natural Diversity Database.

CNPS. See California Native Plant Society.

Halbert, P., and S. W. Singer. 2017. Marbled Murrelet Landscape Management Plan for Zone 6. California Department of Parks and Recreation. Santa Cruz District. Felton, CA Hansen, R. W., and J. D. Shedd. 2025. California Amphibians and Reptiles. Princeton University Press. Princeton, NJ. iNaturalist. 2025. Observations of Arctostaphylos silvicola, Astragalus agnicidus, Chorizanthe pungens var. pungens, Monardella sinuata ssp. nigrescens, Polygonum hickmanii, Dicamptodon ensatus, Ammodramus savannarum, Athene cunicularia, Chaetura vauxi, Contopus cooperi, Elanus leucurus, Haliaeetus leucocephalus, and Setophaga petechia from the Santa Cruz mountains. Available: https://www.inaturalist.org/. Retrieved July and August 2025.

Leidy, R. A., Becker, G., and B. Harvey. 2005. Historical Status of Coho Salmon in Streams of the Urbanized San Franciso Estuary, California. California Fish and Game 91(4):219-254 Neubauer, D. M., and D. Lyons. 2023. Noteworthy Collection.” Madroño 70(1): 1–3. Available:
https://doi.org/10.3120/0024-9637-70.1.1. Accessed August 21, 2025.

Paton and Ralph. 1990. Distribution of the Marbled Murrelet at Inland Sites and California. Northwestern Naturalist.

Volume 71: 72–84.

Santa Clara County, City of San José, City of Morgan Hill, City of Gilroy, Santa Clara Valley Water District, Santa Clara Valley Transportation Authority. 2012. Final Santa Clara Valley Habitat Plan (HCP/NCCP). San José, CA.

Santa Cruz County See. Santa Cruz County Planning Department.

Santa Cruz County Planning Department. 2011. Map of Sandhills Distribution in Santa Cruz County.

Smith, J. J. 2013. Northern Santa Clara County Fish Resources. San Jose State University, Department of Biological Sciences. San Jose, CA.

The Habitat Restoration Group. 1997. Fisheries of the Lower Pajaro River and its Tributaries. Prepared for Environmental Science Associates. Felton, CA.

US Fish and Wildlife Service. 2020a. 5-Year Review Alameda whipsnake (Masticophis lateralis euryxanthus). U.S. Fish and Wildlife Service, Sacramento Fish and Wildlife Office, Sacramento, CA. ———. 2020b. Species Status Assessment for the San Francisco gartersnake (Thamnophis sirtalis tetrataenia) Version

1.0. U.S. Fish and Wildlife Service. Region 10. Sacramento, CA. ———. 2024a. Vernal Pool Fairy Shrimp (Branchinecta lynchi), Vernal Pool Tadpole Shrimp (Lepidurus packardi), Conservancy Fairy Shrimp (Branchinecta conservatio) 5-Year Review: Evaluation and Summary. U.S. Fish and Wildlife Service, Sacramento Fish and Wildlife Office. Sacramento, CA. ———. 2024b. Ohlone Tiger Beetle (Cicindela Ohlone) 5-Year Review: Evaluation and Summary. U.S. Fish and Wildlife Service, Ventura Fish and Wildlife Office. Ventura, CA. ———. 2025a. Santa Cruz Long-Toed Salamander (Ambystoma macrodactylum croceum) 5-Year Review: Evaluation and Summary. U.S. Fish and Wildlife Service, Ventura Fish and Wildlife Office. Ventura, CA. ———. 2025b. Information for Planning and Consultation electronic records search. Available:
https://ecos.fws.gov/ipac/. Retrieved July 8, 2025.

USFWS. See US Fish and Wildlife Service.

Western Monarch and Milkweed Mapper. 2025. Data accessed from the Western Monarch Milkweed Mapper, a project by the Xerces Society, US Fish and Wildlife Service, Idaho Department of Fish and Game, and Washington Department of Fish and Wildlife. Available: http://www.monarchmilkweedmapper.org. Accessed July 15, 2025.

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

Attachment A
City of Gilroy
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
City of Gilroy
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

Attachment A
City of Gilroy
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

Attachment A
City of Gilroy
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 City of Gilroy is the responsible agency under CEQA. As the CEQA responsible agency, City of Gilroy 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 City of Gilroy 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 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.

Attachment A
City of Gilroy
A-2 West Santa Clara Landscape Resiliency Project PSA and Addendum If desired by City of Gilroy as the 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., 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, a private entity (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.

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

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-3 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
City of Gilroy
A-4 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
Administrative Standard Project Requirements
0BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
1BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
2BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
3BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
4BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-5 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
5BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
6BSPR 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;
Prior to, during, and
following treatment
Information on the
proposed project
(PSA/Addendum in
progress) was submitted
to CAL FIRE on October
14, 2025.

City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
A-6 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
 Dates of work;
 A list of the SPRs and mitigation measures that were implemented; and  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 7BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
8BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
9BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
Air Quality Standard Project Requirements
10BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
11BSPR 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 Prior to prescribed burn
treatment activities
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-7 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
Appendix PD-2. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.
12BSPR 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.
13BProject-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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
14BSPR 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.

During treatment City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
A-8 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
This SPR applies to all treatment activities and treatment types, including treatment maintenance. 15BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
16BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
Archaeological, Historical, and Tribal Cultural Resources Standard Project Requirements 17BSPR 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.

City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
18BSPR 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.

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.

City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-9 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
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. 19BSPR-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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
20BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
A-10 West Santa Clara Landscape Resiliency Project PSA and Addendum Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
21BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
22BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
23BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
24BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-11 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
25BChaparral and Coastal Sage Scrub Standard Project Requirement 26BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
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
27BSPR 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.

City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
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.

Attachment A
City of Gilroy
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
City of Gilroy
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

Attachment A
City of Gilroy
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. 28BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
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 29BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party
30BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
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
City of Gilroy
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. 31BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-21 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
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 responsible 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

Attachment A
City of Gilroy
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.
32BSPR 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
City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party

Attachment A
City of Gilroy
West Santa Clara Landscape Resiliency Project PSA and Addendum A-23 Standard Project Requirements Timing Implementing Entity Verifying/Monitoring
Entity
 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. 33BSPR 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 City of Gilroy or
Qualified Responsible
Party
City of Gilroy or
Qualified Responsible
Party