Gilroy City Council
August 3, 2026

August 3, 2026 | 6:00 PM Page 1 of 8 City Council
Regular Meeting

CITY COUNCIL

REGULAR MEETING
AGENDA

CITY COUNCIL CHAMBERS, CITY HALL
7351 ROSANNA STREET, GILROY, CA
95020

AMENDED AGENDA
Amended closed session to reflect 2 cases
5:00 PM CLOSED SESSION
6:00 PM REGULAR MEETING
MONDAY, AUGUST 3, 2026 | 6:00 PM
MAYOR
Greg Bozzo

COUNCIL MEMBERS
Dion Bracco
Tom Cline
Terence Fugazzi
Zach Hilton
Carol Marques
Kelly Ramirez
CITY COUNCIL PACKET MATERIALS ARE AVAILABLE ONLINE AT www.cityofgilroy.org AGENDA CLOSING TIME IS 5:00 P.M. THE FRIDAY PRIOR TO THE MEETING Remote Participation
Gilroy City Council meetings are held in person. The community may attend in person or via Zoom (video/teleconference). The meetings are also live-streamed on the City's website and YouTube.

Those wishing to participate in the meetings remotely may join using the following link:
https://bit.ly/GilroyCityCouncilMeetings. Additionally, Zoom participants must be running the latest version or will be required to update to it before joining the meeting remotely.

Remote participation is also available by calling (669) 900-6833 and entering webinar ID: 930 2066 6240#. Dial *9 to raise your hand, and be called upon to speak for up to 3 minutes. Dial *6 to unmute.

Public Comment

COMMENTS BY THE PUBLIC WILL BE TAKEN ON AGENDA ITEMS BEFORE ACTION IS TAKEN BY THE CITY COUNCIL. Public testimony is subject to reasonable regulations, including but not limited to time restrictions for each individual speaker. **Please limit your comments to 3 minutes.** The amount of time allowed per speaker may vary at the Mayor’s discretion depending on the number of speakers and length of the agenda.

Public comment will be heard first from those attending in person, with the submission of a speaker card. Once that is complete, we will move to those on Zoom who have their virtual hand raised. Following public comment from Zoom, we will close the public comment period for that item.

August 3, 2026 | 6:00 PM Page 2 of 8 City Council
Regular Meeting
Please note: Once the third speaker has provided comment on an item, there will be no further speaker cards or virtual raised hands taken for that item.

Written comments on any agenda item may be emailed to the City Clerk’s Office at [email protected] or mailed to the Gilroy City Clerk’s Office at City Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the City Clerk’s Office by 1 p.m. on the day of a Council meeting will be distributed to the City Council prior to or at the meeting and available for public inspection with the agenda packet located in the lobby of Administration at City Hall, 7351 Rosanna Street prior to the meeting. Any correspondence received will be incorporated into the meeting record. Items received after the 1 p.m. deadline will be provided to the City Council as soon as practicable. Written comments are also available on the City’s Public Records Portal at bit.ly/3NuS1IN.

In compliance with the Americans with Disabilities Act, the City will make reasonable arrangements to ensure accessibility to this meeting. If you need special assistance to participate in this meeting, please contact the City Clerk’s Office at least 72 hours prior to the meeting at (408) 846-0204 or [email protected] to help ensure that reasonable arrangements can be made.

If you challenge any planning or land use decision made at this meeting in court, you may be limited to raising only those issues you or someone else raised at the public hearing held at this meeting, or in written correspondence delivered to the City Council at, or prior to, the public hearing. Please take notice that the time within which to seek judicial review of any final administrative determination reached at this meeting is governed by Section 1094.6 of the California Code of Civil Procedure.

A Closed Session may be called during this meeting pursuant to Government Code Section 54956.9 (d)(2) if a point has been reached where, in the opinion of the legislative body of the City on the advice of its legal counsel, based on existing facts and circumstances, there is a significant exposure to litigation against the City.

Materials related to an item on this agenda submitted to the City Council after distribution of the agenda packet are available with the agenda packet on the City website at www.cityofgilroy.org subject to the Staff’s ability to post the documents before the meeting.

KNOW YOUR RIGHTS UNDER THE GILROY OPEN GOVERNMENT ORDINANCE Government's duty is to serve the public, reaching its decisions in full view of the public. Commissions, task forces, councils and other agencies of the City exist to conduct the people's business. This ordinance assures that deliberations are conducted before the people and that City operations are open to the people's review.

FOR MORE INFORMATION ON YOUR RIGHTS UNDER THE OPEN GOVERNMENT

ORDINANCE, TO RECEIVE A FREE COPY OF THE ORDINANCE OR TO REPORT A

VIOLATION OF THE ORDINANCE, CONTACT THE OPEN GOVERNMENT COMMISSION STAFF AT (408) 846-0204.

If you need assistance with translation and would like to speak during public comment, please contact the City Clerk a minimum of 72 hours prior to the meeting at 408-846-0204 or e-mail the City Clerk’s Office at [email protected].

Si necesita un intérprete durante la junta y gustaría dar un comentario público, comuníquese con el Secretario de la Ciudad un mínimo de 72 horas antes de la junta al 408- 846-0204 o envíe un correo electrónico a la Oficina del Secretario de la Ciudad a [email protected].

August 3, 2026 | 6:00 PM Page 3 of 8 City Council
Regular Meeting
To access written translation during the meeting, please scan the QR Code or click this link:

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1. CLOSED SESSION - 5:00 PM

1.1. Call to Order

1.2. Roll Call

1.3. CLOSED SESSION
CONFERENCE WITH LEGAL COUNSEL – ANTICIPATED LITIGATION – Significant exposure to litigation pursuant to Paragraph (2) of Subdivision (d) of Government Code Section 54956.9 and Gilroy City Code Section 17A.11 Subdivision (3); Two Cases

2. OPPORTUNITY FOR PUBLIC COMMENT ON CLOSED SESSION

3. ADJOURN TO OPEN SESSION
The agenda for this regular meeting is outlined as follows:

4. REGULAR MEETING - 6:00 PM

4.1. Call to Order

4.2. Roll Call

4.3. City Clerk's Report on Posting the Agenda

4.4. Pledge of Allegiance

4.5. Invocation

4.6. Orders of the Day

4.7. Employee Introductions

5. CEREMONIAL ITEMS - Proclamations and Awards

August 3, 2026 | 6:00 PM Page 4 of 8 City Council
Regular Meeting

5.1. Screen-Free Week Proclamation

6. PRESENTATIONS TO THE COUNCIL

6.1. PUBLIC COMMENT BY MEMBERS OF THE PUBLIC ON ITEMS NOT ON THE

AGENDA BUT WITHIN THE SUBJECT MATTER JURISDICTION OF THE CITY

COUNCIL
This portion of the meeting is reserved for persons desiring to address the Council on matters within the Gilroy City Council’s jurisdiction but not on the agenda. Persons wishing to address the Council are requested to complete a Speaker’s Card located at the entrances and handed to the City Clerk. Speakers are limited to 1 to 3 minutes each, varying at the Mayor’s discretion depending on the number of speakers and length of the agenda. The law does not permit Council action or extended discussion of any item not on the agenda except under special circumstances. If Council action is requested, the Council may place the matter on a future agenda.

Written comments to address the Council on matters not on this agenda may be e-mailed to the City Clerk’s Office at [email protected] or mailed to the Gilroy City Clerk’s Office at City Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the City Clerk’s Office by 1:00 pm on the day of a Council meeting will be distributed to the City Council prior to or at the meeting and available for public inspection with the agenda packet located in the lobby of Administration at City Hall, 7351 Rosanna Street, prior to the meeting. Any correspondence received will be incorporated into the meeting record. Items received after the 1:00pm deadline will be provided to the City Council as soon as practicable. Written material provided by public members under this section of the agenda will be limited to 10 pages in hard copy. An unlimited amount of material may be provided electronically.

7. REPORTS OF COUNCIL MEMBERS
Council Member Bracco – Santa Clara County Library Joint Powers Authority, Santa Clara Water Commission, Santa Clara Valley Water Joint Water Resources Committee, SCRWA Council Member Fugazzi – Santa Clara Water Commission (alternate), Silicon Valley Regional Interoperability Authority Board (alternate), SCRWA, Visit Gilroy California Welcome Center, VTA Mobility Partnership Committee
Council Member Marques – Gilroy Sister Cities, Santa Clara County Library Joint Powers Authority (alternate), Santa Clara Valley Habitat Agency Governing Board, Santa Clara Valley Habitat Agency Implementation Board, SCRWA (alternate) Council Member Hilton – ABAG, CalTrain Policy Group (alternate), Santa Clara County Expressway Plan 2040 Advisory Board (alternate), Silicon Valley Clean Energy Authority JPA Board, South County Youth Task Force Policy Team, VTA Policy Advisory Committee Council Member Ramirez – ABAG (alternate), Gilroy Gardens Board of Directors

August 3, 2026 | 6:00 PM Page 5 of 8 City Council
Regular Meeting
(alternate), Cities Association of Santa Clara County, Gilroy Youth Task Force (alternate), Santa Clara Valley Habitat Agency Governing Board, Santa Clara Valley Habitat Agency Implementation Board, SCRWA, Santa Clara Housing and Community Development Advisory Committee
Council Member Cline – CalTrain Policy Group (alternate), Gilroy Sister Cities (alternate), Gilroy Youth Task Force, Santa Clara County Expressway Plan 2040 Advisory Board, Silicon Valley Clean Energy Authority JPA Board (alternate), Silicon Valley Regional Interoperability Authority Board, Visit Gilroy California Welcome Center (alternate), VTA Mobility Partnership Committee, VTA Policy Advisory Committee (alternate)
Mayor Bozzo – Gilroy Gardens Board of Directors, Santa Clara Valley Water Joint Water Resources Committee, South County Youth Task Force Policy Team, VTA Board of Directors (alternate), Santa Clara Housing and Community Development Advisory Committee (alternate), Cities Association of Santa Clara County (alternate)

8. CONSENT CALENDAR
All matters listed under the Consent Calendar are considered by the City Council to be routine and will be enacted by one motion. There will be no separate discussion of these items unless a request is made by a member of the City Council or a member of the public.

Any person desiring to speak on any item on the consent calendar should ask to have that item removed from the consent calendar prior to the time the City Council votes to approve. If removed, the item will be discussed in the order in which it appears.

8.1. Approve a Professional Service Agreement with Visit Gilroy/Gilroy Welcome Center for Tourism Business Improvement District management

8.2. Adopt a Resolution Approving the West Santa Clara Landscape Resiliency Project Project-Specific Analysis and Addendum to the California Vegetation Treatment Program Environmental Impact Report, Adopting CEQA Findings, a Statement of Overriding Considerations, and a Mitigation Monitoring and Reporting Program, and Authorizing Filing of a Notice of Determination

8.3. Approval of City's Response to 2025-26 Civil Grand Jury Final Report "Pothole Damage: Improving Claims Processes within Santa Clara County"

8.4. Approval of City's Response to 2025-26 Civil Grand Jury Final Report "VTA’s Management and Oversight of BART Silicon Valley Phase II"

9. BIDS AND PROPOSALS

9.1. Award a Professional Services Agreement to Kimley-Horn for a Not-to-Exceed Amount of $237,117 for the Development of the City of Gilroy Comprehensive Roadway Safety Action Plan, Add the Project to the Capital Improvement Program, and Adopt a Budget Amendment Resolution to Appropriate Grant and Gas Tax Funds to the Project

1. Staff Report:

John Doughty, Public Works Director

August 3, 2026 | 6:00 PM Page 6 of 8 City Council
Regular Meeting

2. Public Comment

3. Recommended Action:

1. Award a Professional Services Agreement to Kimley-Horn for an amount not to exceed $237,117.25 for the development of the City of Gilroy Comprehensive Roadway Safety Action Plan (Project) No. 26- RFP-PW-529, and authorize the City Administrator to execute the contract and associated documents;

2. Add the Project to the Fiscal Year 2027 (FY27) Capital Improvement Program (CIP) with Project Number 801180; and

3. Adopt a resolution amending the FY26 budget within Gas Tax Fund (205) to appropriate $189,693.80 in FY 2024 SS4A Grant Funds to the Project, along with $47,423.45 in local match from the Gas Tax Fund balance, for a total of $237,117.25.

10. PUBLIC HEARINGS

10.1. Public Hearing on Downtown Gilroy Street Banner Policy and Program Guidelines and Fee Schedule Amendment

1. Staff Report:

John Doughty, Public Works Director

2. Public Comment

3. Recommended Action:

1. Open Public Hearing

2. Close Public Hearing

3. Adopt a Resolution:
a. Approving the Downtown Gilroy Street Banner Policy and Program Guidelines; and
b. Approving the updated fee schedule to include a new fee for installation (and removal) of Downtown Streetlight-Pole Banners.

10.2. Consideration of the Report of Abatement of Weeds and Refuse within the City of Gilroy and Adoption of a Resolution Confirming the Imposition of Assessment Liens against the Land

1. Disclosure of Ex-Parte Communications

2. Staff Report:

Sharon Goei, Community Development Director

3. Open Public Hearing

4. Close Public Hearing

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Regular Meeting

5. Recommended Action:

Adopt a resolution allowing the assessment of fees, minus any qualifying objections, as reported by the Santa Clara County Weed Abatement Program.

10.3. Adoption of an Urgency Ordinance of the City Council of the City of Gilroy Establishing a Temporary Moratorium on the Issuance of New Tobacco Retailer Permits Citywide Through December 31, 2026

1. Disclosure of Ex-Parte Communications

2. Staff Report:

Sharon Goei, Community Development Director

3. Open Public Hearing

4. Close Public Hearing

5. Recommended Action:

Adopt an Urgency Ordinance of the City Council of the City of Gilroy establishing a temporary moratorium on the issuance of new Tobacco Retailer Permits Citywide through December 31, 2026.

11. UNFINISHED BUSINESS

11.1. Consideration of Tobacco Retailer Permit Prohibited Areas Around YouthOriented Facilities

1. Staff Report:

Sharon Goei, Community Development Director

2. Public Comment

3. Recommended Action:

Council provide direction regarding the definition of youth-oriented facilities and its desire to prohibit new tobacco retailers from opening in those areas.

12. INTRODUCTION OF NEW BUSINESS

12.1. Report on GilroyConnect/SeeClickFix: Service Level Agreement Performance Update, Benchmarking Comparison, and Communication Protocols

1. Staff Report:

Bryce Atkins, Deputy Director of Community Development

2. Public Comment

3. Recommended Action:

Council receive the report.

12.2. Consider Recommended Actions Before Adopting a Zoning Code Amendment to Section 30.41.31 (Specific Provisions – Noise) (FAIR Memo – Hilton)

1. Staff Report:

August 3, 2026 | 6:00 PM Page 8 of 8 City Council
Regular Meeting
Sharon Goei, Community Development Director

2. Public Comment

3. Recommended Action:

Staff recommends that the City Council authorize both of the following actions concurrently before final adoption of any Zoning Code amendment to Section 30.41.31 (Specific Provisions – Noise):

1. Direct staff to prepare a Zoning Code amendment to Section

30.41.31; and

2. Direct staff to retain the services of a qualified acoustical engineer to conduct a technical analysis of the proposed amendment, quantify the actual reduction in noise levels experienced at residential property lines, and evaluate the feasibility of achieving the proposed standard without materially impacting commercial, industrial, and mixed-use development.

13. CITY ADMINISTRATOR'S REPORTS

14. CITY ATTORNEY'S REPORTS

15. ADJOURNMENT

6.1. City of Gilroy

STAFF REPORT
Agenda Item Title: Approve a Professional Service Agreement with Visit Gilroy/Gilroy Welcome Center for Tourism Business Improvement District management Meeting Date: August 3, 2026
From: Matt Morley, City Administrator
Andy Faber, City Attorney
Kim Mancera, City Clerk
Department: Economic Development
Submitted by: Raissa de la Rosa, Economic Development Director Prepared by: Raissa de la Rosa, Economic Development Director STRATEGIC PLAN GOALS: Promote Economic Development Activities

RECOMMENDATION
Approve a ten-year contract with Gilroy Visitors Bureau, dba Gilroy Welcome Center, effective January 1, 2028, through December 31, 2037, for the provision of Gilroy Tourism Business Improvement District services coinciding with the terms and in accordance with the provisions of that recently renewed assessment district.

EXECUTIVE SUMMARY
On June 15, 2026, City Council adopted Resolution No. 2026-44 renewing the Gilroy Tourism Business Improvement District (GTBID). The Gilroy Welcome Center was designated in the Resolution and the GTBID Management District Plan as the Owners' Association for provision of GTBID services. This contract provides the means by which all GTBID assessment funds collected, less an authorized two percent City administrative fee, are disbursed to pay for those services.

BACKGROUND
The City established the Gilroy Tourism Business Improvement District (GTBID) on September 17, 2012, for an initial five-year term through Resolution No. 2012-36,

6.1. pursuant to the Property and Business Improvement District Law of 1994 (Streets and Highways Code §36600 et seq.). The GTBID was subsequently renewed on October 17, 2016, by Resolution No. 2016-54 for an additional ten-year term that is set to conclude on December 31, 2027. On June 15, 2026, the GTBID was again renewed via Resolution No. 2026-44, further extending the life of the District for another ten-year period to end on December 31, 2037. Throughout the District’s existence, the Gilroy Welcome Center (GWC) has been designated to act as the Owners’ Association responsible for administering GTBID programs and activities. The GTBID is expected to generate approximately $324,000 annually.

ANALYSIS
The proposed agreement formalizes the Gilroy Welcome Center’s (GWC) role as the Owners’ Association for the Gilroy Tourism Business Improvement District (GTBID), as designated by City Council in Resolution No. 2026-44. Establishing this contract ensures the GTBID operates in full compliance with the Property and Business Improvement District Law of 1994 and the Council-approved Management District Plan.

The scope of work outlined in the agreement provides the core framework for fiscal accountability, legal compliance, and transparent administration of GTBID assessment revenues. Requirements such as preparation of the Annual Report, maintenance of financial records, and participation in periodic independent audits are statutory or best-practice mechanisms that ensure assessment funds are properly managed, spent in alignment with the Management District Plan, and subject to regular oversight.

Collectively, these responsibilities allow the City to verify that the GTBID is functioning as intended, that assessment revenues are safeguarded, and that planned tourism-related improvements are delivered. Approval of the agreement enables continued GTBID operations under a clear structure that protects the interests of the City, assessed businesses, and the public.

ALTERNATIVES
As the approved 2026 Resolution of Formation and Management District Plan identify the GWC as the Owners’ Association, no alternatives exist.

FISCAL IMPACT/FUNDING SOURCE
The City is authorized to collect a 2% administrative fee on all assessments collected for the life of the District. The GTBID is estimated to generate $324,000 in assessments in its first year.

PUBLIC OUTREACH

6.1. Not applicable.

NEXT STEPS
None.

Attachments:

1. Contract Process Form - GTBID GWC 2026 PSA

City of Gilroy
Agreement/Contract Tracking
Today’s Date: July 21 2026 Your Name: Raissa de la Rosa Contract
Type:

Services over $5k - Consultant Phone Number: 408-846-0587 Contract Effective Date:
(Date contract goes into effect)
1/1/2028
Contract Expiration Date: 12/31/2037
Contractor / Consultant Name
and Address:

Gilroy Visitors Bureau, dba Gilroy Welcome Center
Contract Subject:
(no more than 100 characters)
Designation as the Gilroy Tourism Business Improvement District Owners’ Association
Contract Amount:
(Inclusive of Orig. and all
amendment amounts)
Click here to enter text.all GTBID assessment funds collected within thirty days of collection, less a two percent (2%) City administrative fee as authorized in the GTBID Managemetn District Plan.

By submitting this form, I confirm
this information is complete:
☒ Procurement method per City Purchasing Policy followed (including Special Policies such as Local Vendor Preference and Wage Theft)
☒ AB339, Bargaining Group was notified on: N/A
(Write ‘N/A’ if not applicable)
☒ Item is budgeted in Org/Obj_1001570 / 51630________________ ☒ Terms of the agreement (start date and completion dates or “until project completion”, cap of compensation to be paid)
☒ Scope of Services, Terms of Payment, Milestone Schedule and exhibit(s) attached
☒ W-9 (Taxpayer ID or SS#) and Contractor License # if applicable ☒ Insurance (Certificate and Endorsement Pages)
☒ Contractor/Consultant signature, name and title
☒ City Administrator or Department Head Name, City Clerk (Attest), City Attorney (Approved as to Form)
Routing Steps for Electronic Signature
Department Head
Risk Manager
City Attorney Approval As to Form
City Administrator (if needed)
Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

City Clerk Attestation
Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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AGREEMENT FOR SERVICES
(For contracts over $5,000 - CONSULTANT)
This AGREEMENT made this 3rd day of August, 2026, between:

CITY: City of Gilroy, having a principal place of business at 7351 Rosanna Street, Gilroy, California
and CONSULTANT: Gilroy Visitors Bureau, dba Gilroy Welcome Center, having a principal place of business at 8155-6 Arroyo Circle, Gilroy, CA 95020.

ARTICLE 1. TERM OF AGREEMENT
This Agreement will become effective on January 1, 2028, and will continue in effect through December 31, 2037, unless terminated in accordance with the provisions of Article 7 of this Agreement.

Any lapse in insurance coverage as required by Article 5, Section D of this Agreement shall terminate this Agreement regardless of any other provision stated herein. ______ Initial
ARTICLE 2. INDEPENDENT CONTRACTOR STATUS
It is the express intention of the parties that CONSULTANT is an independent contractor and not an employee, agent, joint venturer or partner of CITY. Nothing in this Agreement shall be interpreted or construed as creating or establishing the relationship of employer and employee between CITY and CONSULTANT or any employee or agent of CONSULTANT. Both parties acknowledge that CONSULTANT is not an employee for state or federal tax purposes.

CONSULTANT shall not be entitled to any of the rights or benefits afforded to CITY’S employees, including, without limitation, disability or unemployment insurance, workers’ compensation, medical insurance, sick leave, retirement benefits or any other employment benefits. CONSULTANT shall retain the right to perform services for others during the term of this Agreement.

ARTICLE 3. SERVICES TO BE PERFORMED BY CONSULTANT
A. Specific Services
CONSULTANT agrees to: Perform the services as outlined in Exhibit “A” (“Specific Provisions”) and Exhibit “B” (“Scope of Services”), within the time periods described in Exhibit “C” (“Milestone Schedule”).

B. Method of Performing Services
CONSULTANT shall determine the method, details and means of performing the abovedescribed services. CITY shall have no right to, and shall not, control the manner or determine the method of accomplishing CONSULTANT’S services.

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C. Employment of Assistants
CONSULTANT may, at the CONSULTANT’S own expense, employ such assistants as CONSULTANT deems necessary to perform the services required of CONSULTANT by this Agreement, subject to the prohibition against assignment and subcontracting contained in Article 5 below. CITY may not control, direct, or supervise CONSULTANT’S assistants in the performance of those services. CONSULTANT assumes full and sole responsibility for the payment of all compensation and expenses of these assistants and for all state and federal income tax, unemployment insurance, Social Security, disability insurance and other applicable withholding.

D. Place of Work
CONSULTANT shall perform the services required by this Agreement at any place or location and at such times as CONSULTANT shall determine is necessary to properly and timely perform CONSULTANT’S services.

ARTICLE 4. COMPENSATION
A. Consideration
In consideration for the services to be performed by CONSULTANT, CITY agrees to pay CONSULTANT the amounts set forth in Exhibit “D” (“Payment Schedule”). In no event however shall the total compensation paid to CONSULTANT exceed the Gilroy Tourism Business Improvement District (GTBID) assessment funds collected within thirty days of colleciton during the Term of this Agreement, less a two percent (2%) City administrative fee as authorized in the GTBID Management District Plan.

B. Invoices
CONSULTANT shall submit invoices for all services rendered.

C. Payment
Payment shall be due according to the payment schedule set forth in Exhibit “D”. No payment will be made unless CONSULTANT has first provided City with a written receipt of invoice describing the work performed and any approved direct expenses (as provided for in Exhibit “A”, Section IV) incurred during the preceding period. If CITY objects to all or any portion of any invoice, CITY shall notify CONSULTANT of the objection within thirty (30) days from receipt of the invoice, give reasons for the objection, and pay that portion of the invoice not in dispute. It shall not constitute a default or breach of this Agreement for CITY not to pay any invoiced amounts to which it has objected until the objection has been resolved by mutual agreement of the parties.

D. Expenses
CONSULTANT shall be responsible for all costs and expenses incident to the performance of services for CITY, including but not limited to, all costs of equipment used or provided by Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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CONSULTANT, all fees, fines, licenses, bonds or taxes required of or imposed against CONSULTANT and all other of CONSULTANT’S costs of doing business. CITY shall not be responsible for any expenses incurred by CONSULTANT in performing services for CITY, except for those expenses constituting “direct expenses” referenced on Exhibit “A.” ARTICLE 5. OBLIGATIONS OF CONSULTANT
A. Tools and Instrumentalities
CONSULTANT shall supply all tools and instrumentalities required to perform the services under this Agreement at its sole cost and expense. CONSULTANT is not required to purchase or rent any tools, equipment or services from CITY.

B. Workers’ Compensation
CONSULTANT agrees to provide workers’ compensation insurance for CONSULTANT’S employees and agents and agrees to hold harmless, defend with counsel acceptable to CITY and indemnify CITY, its officers, representatives, agents and employees from and against any and all claims, suits, damages, costs, fees, demands, causes of action, losses, liabilities and expenses, including without limitation reasonable attorneys’ fees, arising out of any injury, disability, or death of any of CONSULTANT’S employees.

C. Indemnification of Liability, Duty to Defend

1. As to professional liability, to the fullest extent permitted by law, CONSULTANT shall defend, through counsel approved by CITY (which approval shall not be unreasonably withheld), indemnify and hold harmless CITY, its officers, representatives, agents and employees against any and all suits, damages, costs, fees, claims, demands, causes of action, losses, liabilities and expenses, including without limitation attorneys’ fees, to the extent arising or resulting directly or indirectly from any willful or negligent acts, errors or omissions of CONSULTANT or CONSULTANT’S assistants, employees or agents, including all claims relating to the injury or death of any person or damage to any property.

2. As to other liability, to the fullest extent permitted by law, CONSULTANT shall defend, through counsel approved by CITY (which approval shall not be unreasonably withheld), indemnify and hold harmless CITY, its officers, representatives, agents and employees against any and all suits, damages, costs, fees, claims, demands, causes of action, losses, liabilities and expenses, including without limitation attorneys’ fees, arising or resulting directly or indirectly from any act or omission of CONSULTANT or CONSULTANT’S assistants, employees or agents, including all claims relating to the injury or death of any person or damage to any property.

D. Insurance
In addition to any other obligations under this Agreement, CONSULTANT shall, at no cost to CITY, obtain and maintain throughout the term of this Agreement: (a) Commercial Liability Insurance on a per occurrence basis, including coverage for owned and non-owned automobiles, Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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with a minimum combined single limit coverage of $1,000,000 per occurrence for all damages due to bodily injury, sickness or disease, or death to any person, and damage to property, including the loss of use thereof; and (b) Professional Liability Insurance (Errors & Omissions) with a minimum coverage of $1,000,000 per occurrence or claim, and $2,000,000 aggregate; provided however, Professional Liability Insurance written on a claims made basis must comply with the requirements set forth below. Professional Liability Insurance written on a claims made basis (including without limitation the initial policy obtained and all subsequent policies purchased as renewals or replacements) must show the retroactive date, and the retroactive date must be before the earlier of the effective date of the contract or the beginning of the contract work. Claims made Professional Liability Insurance must be maintained, and written evidence of insurance must be provided, for at least five (5) years after the completion of the contract work. If claims made coverage is canceled or non-renewed, and not replaced with another claims-made policy form with a retroactive date prior to the earlier of the effective date of the contract or the beginning of the contract work, CONSULTANT must purchase so called “extended reporting” or “tail” coverage for a minimum of five (5) years after completion of work, which must also show a retroactive date that is before the earlier of the effective date of the contract or the beginning of the contract work. As a condition precedent to CITY’S obligations under this Agreement, CONSULTANT shall furnish written evidence of such coverage (naming CITY, its officers and employees as additional insureds on the Comprehensive Liability insurance policy referred to in (a) immediately above via a specific endorsement) and requiring thirty (30) days written notice of policy lapse or cancellation, or of a material change in policy terms.

E. Assignment
Notwithstanding any other provision of this Agreement, neither this Agreement nor any duties or obligations of CONSULTANT under this Agreement may be assigned or subcontracted by CONSULTANT without the prior written consent of CITY, which CITY may withhold in its sole and absolute discretion.

F. State and Federal Taxes
As CONSULTANT is not CITY’S employee, CONSULTANT shall be responsible for paying all required state and federal taxes. Without limiting the foregoing, CONSULTANT acknowledges and agrees that:
• CITY will not withhold FICA (Social Security) from CONSULTANT’S payments;
• CITY will not make state or federal unemployment insurance contributions on CONSULTANT’S behalf;
• CITY will not withhold state or federal income tax from payment to CONSULTANT;
• CITY will not make disability insurance contributions on behalf of CONSULTANT;
Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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• CITY will not obtain workers’ compensation insurance on behalf of CONSULTANT.

ARTICLE 6. OBLIGATIONS OF CITY
A. Cooperation of City
CITY agrees to respond to all reasonable requests of CONSULTANT and provide access, at reasonable times following receipt by CITY of reasonable notice, to all documents reasonably necessary to the performance of CONSULTANT’S duties under this Agreement.

B. Assignment
CITY may assign this Agreement or any duties or obligations thereunder to a successor governmental entity without the consent of CONSULTANT. Such assignment shall not release CONSULTANT from any of CONSULTANT’S duties or obligations under this Agreement.

ARTICLE 7. TERMINATION OF AGREEMENT
A. Sale of Consultant’s Business/ Death of Consultant.

CONSULTANT shall notify CITY of the proposed sale of CONSULTANT’s business no later than thirty (30) days prior to any such sale. CITY shall have the option of terminating this Agreement within thirty (30) days after receiving such notice of sale. Any such CITY termination pursuant to this Article 7.A shall be in writing and sent to the address for notices to CONSULTANT set forth in Exhibit A, Subsection V.H., no later than thirty (30) days after CITY’ receipt of such notice of sale.

If CONSULTANT is an individual, this Agreement shall be deemed automatically terminated upon death of CONSULTANT.

B. Termination by City for Default of Consultant
Should CONSULTANT default in the performance of this Agreement or materially breach any of its provisions, CITY, at CITY’S option, may terminate this Agreement by giving written notification to CONSULTANT. For the purposes of this section, material breach of this Agreement shall include, but not be limited to the following:

1. CONSULTANT’S failure to professionally and/or timely perform any of the services contemplated by this Agreement.

2. CONSULTANT’S breach of any of its representations, warranties or covenants contained in this Agreement.

CONSULTANT shall be entitled to payment only for work completed in accordance with the terms of this Agreement through the date of the termination notice, as reasonably determined by CITY, provided that such payment shall not exceed the amounts set forth in this Agreement for the tasks described on Exhibit C” which have been fully, competently and timely rendered by Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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CONSULTANT. Notwithstanding the foregoing, if CITY terminates this Agreement due to CONSULTANT’S default in the performance of this Agreement or material breach by CONSULTANT of any of its provisions, then in addition to any other rights and remedies CITY may have, CONSULTANT shall reimburse CITY, within ten (10) days after demand, for any and all costs and expenses incurred by CITY in order to complete the tasks constituting the scope of work as described in this Agreement, to the extent such costs and expenses exceed the amounts CITY would have been obligated to pay CONSULTANT for the performance of that task pursuant to this Agreement.

C. Termination for Failure to Make Agreed-Upon Payments Should CITY fail to pay CONSULTANT all or any part of the compensation set forth in Article 4 of this Agreement on the date due, then if and only if such nonpayment constitutes a default under this Agreement, CONSULTANT, at the CONSULTANT’S option, may terminate this Agreement if such default is not remedied by CITY within thirty (30) days after demand for such payment is given by CONSULTANT to CITY.

D. Transition after Termination
Upon termination, CONSULTANT shall immediately stop work, unless cessation could potentially cause any damage or harm to person or property, in which case CONSULTANT shall cease such work as soon as it is safe to do so. CONSULTANT shall incur no further expenses in connection with this Agreement. CONSULTANT shall promptly deliver to CITY all work done toward completion of the services required hereunder, and shall act in such a manner as to facilitate any the assumption of CONSULTANT’s duties by any new consultant hired by the CITY to complete such services.

ARTICLE 8. GENERAL PROVISIONS
A. Amendment & Modification
No amendments, modifications, alterations or changes to the terms of this Agreement shall be effective unless and until made in a writing signed by both parties hereto.

B. Americans with Disabilities Act of 1990
Throughout the term of this Agreement, the CONSULTANT shall comply fully with all applicable provisions of the Americans with Disabilities Act of 1990 (“the Act”) in its current form and as it may be amended from time to time. CONSULTANT shall also require such compliance of all subcontractors performing work under this Agreement, subject to the prohibition against assignment and subcontracting contained in Article 5 above. The CONSULTANT shall defend with counsel acceptable to CITY, indemnify and hold harmless the CITY OF GILROY, its officers, employees, agents and representatives from and against all suits, claims, demands, damages, costs, causes of action, losses, liabilities, expenses and fees, including without limitation reasonable attorneys’ fees, that may arise out of any violations of the Act by the CONSULTANT, its subcontractors, or the officers, employees, agents or representatives of either.

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C. Attorneys’ Fees
If any action at law or in equity, including an action for declaratory relief, is brought to enforce or interpret the provisions of this Agreement, the prevailing party will be entitled to reasonable attorneys’ fees, which may be set by the court in the same action or in a separate action brought for that purpose, in addition to any other relief to which that party may be entitled.

D. Captions
The captions and headings of the various sections, paragraphs and subparagraphs of the Agreement are for convenience only and shall not be considered nor referred to for resolving questions of interpretation.

E. Compliance with Laws
The CONSULTANT shall keep itself informed of all State and National laws and all municipal ordinances and regulations of the CITY which in any manner affect those engaged or employed in the work, or the materials used in the work, or which in any way affect the conduct of the work, and of all such orders and decrees of bodies or tribunals having any jurisdiction or authority over the same. Without limiting the foregoing, CONSULTANT agrees to observe the provisions of the Municipal Code of the CITY OF GILROY, obligating every contractor or subcontractor under a contract or subcontract to the CITY OF GILROY for public works or for goods or services to refrain from discriminatory employment or subcontracting practices on the basis of the race, color, sex, religious creed, national origin, ancestry of any employee, applicant for employment, or any potential subcontractor.

F. Conflict of Interest
CONSULTANT certifies that to the best of its knowledge, no CITY employee or office of any public agency interested in this Agreement has any pecuniary interest in the business of CONSULTANT and that no person associated with CONSULTANT has any interest that would constitute a conflict of interest in any manner or degree as to the execution or performance of this Agreement.

G. Entire Agreement
This Agreement supersedes any and all prior agreements, whether oral or written, between the parties hereto with respect to the rendering of services by CONSULTANT for CITY and contains all the covenants and agreements between the parties with respect to the rendering of such services in any manner whatsoever. Each party to this Agreement acknowledges that no representations, inducements, promises or agreements, orally or otherwise, have been made by any party, or anyone acting on behalf of any party, which are not embodied herein, and that no other agreement, statement or promise not contained in this Agreement shall be valid or binding.

No other agreements or conversation with any officer, agent or employee of CITY prior to execution of this Agreement shall affect or modify any of the terms or obligations contained in any documents comprising this Agreement. Such other agreements or conversations shall be considered as unofficial information and in no way binding upon CITY.

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H. Governing Law and Venue
This Agreement shall be governed by and construed in accordance with the laws of the State of California without regard to the conflict of laws provisions of any jurisdiction. The exclusive jurisdiction and venue with respect to any and all disputes arising hereunder shall be in state and federal courts located in Santa Clara County, California.

I. Notices
Any notice to be given hereunder by either party to the other may be effected either by personal delivery in writing or by mail, registered or certified, postage prepaid with return receipt requested. Mailed notices shall be addressed to the parties at the addresses appearing in Exhibit “A”, Section V.H. but each party may change the address by written notice in accordance with this paragraph. Notices delivered personally will be deemed delivered as of actual receipt; mailed notices will be deemed delivered as of three (3) days after mailing.

J. Partial Invalidity
If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions will nevertheless continue in full force without being impaired or invalidated in any way.

K. Time of the Essence
All dates and times referred to in this Agreement are of the essence.

L. Waiver
CONSULTANT agrees that waiver by CITY of any one or more of the conditions of performance under this Agreement shall not be construed as waiver(s) of any other condition of performance under this Agreement.

Executed at Gilroy, California, on the date and year first above written.

CONSULTANT: CITY:

GILROY VISITORS BUREAU dba

GILROY WELCOME CENTER

CITY OF GILROY
By: By:

Name: Frank Johnson Name: Matt Morley
Title: Executive Director Title: City Administrator
Social Security or Taxpayer
Identification Number 77-0553294
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Approved as to Form ATTEST:

City Attorney City Clerk
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EXHIBIT “A”

SPECIFIC PROVISIONS
I. PROJECT MANAGER
CONSULTANT shall provide the services indicated on the attached Exhibit “B”, Scope of Services (“Services”). (All exhibits referenced are incorporated herein by reference.) To accomplish that end, CONSULTANT agrees to assign Frank Johnson, Gilroy Welcome Center Executive Director, who will act in the capacity of Project Manager, and who will personally direct such Services.

Except as may be specified elsewhere in this Agreement, CONSULTANT shall furnish all technical and professional services including labor, material, equipment, transportation, supervision and expertise to perform all operations necessary and required to complete the Services in accordance with the terms of this Agreement.

II. NOTICE TO PROCEED/COMPLETION OF SERVICE
A. NOTICE TO PROCEED
CONSULTANT shall commence the Services upon delivery to CONSULTANT of a written “Notice to Proceed”, which Notice to Proceed shall be in the form of a written communication from designated City contact person(s). Notice to Proceed may be in the form of e-mail, fax or letter authorizing commencement of the Services. For purposes of this Agreement, the Economic Development Director and Manager shall be the designated City contact person(s).

Notice to Proceed shall be deemed to have been delivered upon actual receipt by CONSULTANT or if otherwise delivered as provided in the Section V.H. (“Notices”) of this Exhibit “A”.

B. COMPLETION OF SERVICES
When CITY determines that CONSULTANT has completed all of the Services in accordance with the terms of this Agreement, CITY shall give CONSULTANT written Notice of Final Acceptance, and CONSULTANT shall not incur any further costs hereunder. CONSULTANT may request this determination of completion when, in its opinion, it has completed all of the Services as required by the terms of this Agreement and, if so requested, CITY shall make this determination within two (2) weeks of such request, or if CITY determines that CONSULTANT has not completed all of such Services as required by this Agreement, CITY shall so inform CONSULTANT within this two (2) week period.

III. PROGRESS SCHEDULE
The schedule for performance and completion of the Services will be as set forth in the attached Exhibit “C”.

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IV. PAYMENT OF FEES AND DIRECT EXPENSES
Payments shall be made to CONSULTANT as provided for in Article 4 of this Agreement.

Direct expenses are charges and fees not included in Exhibit “B”. CITY shall be obligated to pay only for those direct expenses which have been previously approved in writing by CITY.

CONSULTANT shall obtain written approval from CITY prior to incurring or billing of direct expenses.

Copies of pertinent financial records, including invoices, will be included with the submission of billing(s) for all direct expenses.

V. OTHER PROVISIONS
A. STANDARD OF WORKMANSHIP
CONSULTANT represents and warrants that it has the qualifications, skills and licenses necessary to perform the Services, and its duties and obligations, expressed and implied, contained herein, and CITY expressly relies upon CONSULTANT’S representations and warranties regarding its skills, qualifications and licenses. CONSULTANT shall perform such Services and duties in conformance to and consistent with the standards generally recognized as being employed by professionals in the same discipline in the State of California.

Any plans, designs, specifications, estimates, calculations, reports and other documents furnished under this Agreement shall be of a quality acceptable to CITY. The minimum criteria for acceptance shall be a product of neat appearance, well-organized, technically and grammatically correct, checked and having the maker and checker identified. The minimum standard of appearance, organization and content of the drawings shall be that used by CITY for similar purposes.

B. RESPONSIBILITY OF CONSULTANT
CONSULTANT shall be responsible for the professional quality, technical accuracy, and the coordination of the Services furnished by it under this Agreement. CONSULTANT shall not be responsible for the accuracy of any project or technical information provided by the CITY. The CITY’S review, acceptance or payment for any of the Services shall not be construed to operate as a waiver of any rights under this Agreement or of any cause of action arising out of the performance of this Agreement, and CONSULTANT shall be and remain liable to CITY in accordance with applicable law for all damages to CITY caused by CONSULTANT’S negligent performance of any of the services furnished under this Agreement.

C. RIGHT OF CITY TO INSPECT RECORDS OF CONSULTANT
CITY, through its authorized employees, representatives or agents, shall have the right, at any and all reasonable times, to audit the books and records (including, but not limited to, invoices, vouchers, canceled checks, time cards, etc.) of CONSULTANT for the purpose of verifying any and all charges made by CONSULTANT in connection with this Agreement. CONSULTANT shall maintain for a minimum period of three (3) years (from the date of final payment to Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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CONSULTANT), or for any longer period required by law, sufficient books and records in accordance with standard California accounting practices to establish the correctness of all charges submitted to CITY by CONSULTANT, all of which shall be made available to CITY at the CITY’s offices within five (5) business days after CITY’s request.

D. CONFIDENTIALITY OF MATERIAL
All ideas, memoranda, specifications, plans, manufacturing procedures, data (including, but not limited to, computer data and source code), drawings, descriptions, documents, discussions or other information developed or received by or for CONSULTANT and all other written and oral information developed or received by or for CONSULTANT and all other written and oral information submitted to CONSULTANT in connection with the performance of this Agreement shall be held confidential by CONSULTANT and shall not, without the prior written consent of CITY, be used for any purposes other than the performance of the Services, nor be disclosed to an entity not connected with the performance of the such Services. Nothing furnished to CONSULTANT which is otherwise known to CONSULTANT or is or becomes generally known to the related industry (other than that which becomes generally known as the result of CONSULTANT’S disclosure thereof) shall be deemed confidential. CONSULTANT shall not use CITY’S name or insignia, or distribute publicity pertaining to the services rendered under this Agreement in any magazine, trade paper, newspaper or other medium without the express written consent of CITY.

E. NO PLEDGING OF CITY’S CREDIT.

Under no circumstances shall CONSULTANT have the authority or power to pledge the credit of CITY or incur any obligation in the name of CITY.

F. OWNERSHIP OF MATERIAL.

All material including, but not limited to, computer information, data and source code, sketches, tracings, drawings, plans, diagrams, quantities, estimates, specifications, proposals, tests, maps, calculations, photographs, reports and other material developed, collected, prepared (or caused to be prepared) under this Agreement shall be the property of CITY, but CONSULTANT may retain and use copies thereof subject to Section V.D of this Exhibit “A”.

CITY shall not be limited in any way in its use of said material at any time for any work, whether or not associated with the City project for which the Services are performed. However, CONSULTANT shall not be responsible for, and City shall indemnify CONSULTANT from, damages resulting from the use of said material for work other than PROJECT, including, but not limited to, the release of this material to third parties for work other than on PROJECT.

G. NO THIRD PARTY BENEFICIARY.

This Agreement shall not be construed or deemed to be an agreement for the benefit of any third party or parties, and no third party or parties shall have any claim or right of action hereunder for any cause whatsoever.

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H. NOTICES.

Notices are to be sent as follows:

CITY: Economic Development Department
City of Gilroy
7351 Rosanna Street
Gilroy, CA 95020
CONSULTANT: Gilroy Visitors Bureau / Gilroy Welcome Center 8155-6 Arroyo Circle
Gilroy, CA 95020
I. FEDERAL FUNDING REQUIREMENTS.

If the box to the left of this sentence is checked, this Agreement involves federal funding and the requirements of this Section V.I. apply.

If the box to the left of this sentence is checked, this Agreement does not involve federal funding and the requirements of this Section V.I. do not apply.

1. DBE Program
CONSULTANT shall comply with the requirements of Title 49, Part 26, Code of Federal Regulations (49 CFR 26) and the City-adopted Disadvantaged Business Enterprise programs.

2. Cost Principles
Federal Acquisition Regulations in Title 48, CFR 31, shall be used to determine the allowable cost for individual items.

3. Covenant against Contingent Fees
The CONSULTANT warrants that he/she has not employed or retained any company or person, other than a bona fide employee working for the CONSULTANT, to solicit or secure this Agreement, and that he/she has not paid or agreed to pay any company or person, other than a bona fide employee, any fee, commission, percentage, brokerage fee, gift or any other consideration, contingent upon or resulting from the award or formation of this Agreement. For breach or violation of this warranty, the Local Agency shall have the right to annul this Agreement without liability or, at its discretion, to deduct from the agreement price or consideration, or otherwise recover, the full amount of such fee, commission, percentage, brokerage fee, gift or contingent fee.

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EXHIBIT “B”

SCOPE OF SERVICES
On June 15, 2026, the City Council adopted Resolution No. 2026-44, hereinafter the "Resolution," renewing the Gilroy Tourism Business Improvement District, herinafter "GTBID," in accordance with the provisions of the Property and Business Improvement District Law of 1994, Streets and Highways Code section 36600 et seq. Contractor was designated in the Resolution and the GTBID Management District Plan as the Owners' Association for provision of GTBID services. The Streets and Highways Code Section 36651 requires the City contract with the Owners' Association for those services.

The City reserves the right to suspend, terminate or abandon the execution of any work by Contractor upon adoption of a resolution disestablishing the GTBID pursuant to the 1994 Law.

Per the 1994 Law, such a resolution may only be adopted if (1) The City Council finds there has been misappropriation of funds, malfeasance, or a violation of law in connection with the management of the district and a noticed hearing on disestablishment is held, or (2) in the thirtyday period following the anniversary of the district's formation, owners paying fifty percent or more of the assessment file a written protest with the City and a hearing on diestablishment is held. In the event the City disestablishes the GTBID, Contractor shall be entitled to retain GTBID revenues only for paying the Contractor's current liabilities of the GTBID. Pursuant to the 1994 Law, Contractor shall refund to City any remaining GTBID revenues or any revenues derived from the sale of assets acquired with GTBID revenues to enable distribution of the revenues to the owners which paid the assessment. Contractor agrees that City has and reserves the right to deny the transfer of GTBID revenues and/or suspend, terminate or abandon the execution of any work by the Contractor in accordance with the agreement or misfeasance, nonfeasance, or gross malfeasance, or criminal conduct as determined by a court of competent jurisdiciton. Any retention of GTBID revenues by Contractor shall comply with the 1994 Law.

The full Scope of Services which Contractor must abide by are outlined in detail within the Coumcil approved GTBID Management District Plan, hereto attached as Attachment 1 to this Agreement.

Furthermore, Contractor shall provide the following services:

1. Preparation of the Annual Report required by the Property and Busines Improvement District Law of 1994 (the "Law"), which shall include the following and be delivered to the City at least thirty (30) days preceding the fiscal year for which assessments are to be levied and collected to pay the cost of improvements:
a. Any recommended changes to the boundaries
b. Improvements and activities to be provided for that fiscal year c. An estimate of cost for providing the improvements and activities Docusign Envelope ID: D7F26965-205E-828D-81AD-301416D8A751

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d. The method and basis of levying the assessment in sufficient detail to allow each business owner to estimate the amount of the assessment to be levied agains his/her business for that fiscal year
e. The amount of any surplis or deficit revenues to be carried over from a previous fiscal year
f. The amount of any contributions to be made from sources other than assessments.

2. Develop and maintain financial records related to receipt and/or expenditure of all funds received from City.

3. Engage and fully cooperate with an independent auditor. Audits to be conducted every three (3) years. Contractor shall provide all documents, financial records, project data, and any other materials reasonably required to complete the audit. The audit will evaluate compliance with contract terms, performance measures, financial accuracy, and any other criteria established by the city. All costs associated with the audit shall be borne by Contractor.

Contractor may use subcontractors to provide any portion of the services identified in this Exhibit A without prior written consent of the City. Contractor shall remain fully responsible for compliance by its subcontractors with all the terms of this Agreement, regardless of the terms of any agreement between Contractor and its subcontractors.

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EXHIBIT “C”

MILESTONE SCHEDULE
Consultant shall follow all reporting, deliverables, and milestones requirements in accordance with the provisions of the Property and Business Imporvement District Law of 1994, Streets and Highways Code section 36600 et seq., as well as the GTBID Management District Plan (Attachment 1).

In addition, Consultant will adhere to the following deliverable schedule:
- Board meetings as required by the Board Bylaws
- Annual Reports as required by the Property and Busines Improvement District Law of 1994 (the "Law"), which shall include the following and be delivered to the City at least thirty (30) days preceding the fiscal year for which assessments are to be levied and collected to pay the cost of improvements:
a. Any recommended changes to the boundaries
b. Improvements and activities to be provided for that fiscal year c. An estimate of cost for providing the improvements and activities d. The method and basis of levying the assessment in sufficient detail to allow each business owner to estimate the amount of the assessment to be levied agains his/her business for that fiscal year
e. The amount of any surplis or deficit revenues to be carried over from a previous fiscal year
f. The amount of any contributions to be made from sources other than assessments.
- Audits to be conducted every three (3) years. Contractor shall provide all documents, financial records, project data, and any other materials reasonably required to complete the audit.

The audit will evaluate compliance with contract terms, performance measures, financial accuracy, and any other criteria established by the city. All costs associated with the audit shall be borne by Contractor. The audits will be due within the first calendar year quarter of the following years:

Audit 1: 2031
Audit 2: 2034
Audit 3: 2037
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EXHIBIT “D”

PAYMENT SCHEDULE
City shall forward to Consultant all GTBID assessment funds collected within thirty days of collection, less a two percent (2%) City administrative fee as authorized in the GTBID Managemetn District Plan.

Payment of all applicable federal, state, and local taxes shall be Consultant's sole responsibility.

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ANY PROPRIETOR/PARTNER/EXECUTIVE
OFFICER/MEMBER EXCLUDED?

INSR ADDL SUBR

LTR INSD WVD

DATE (MM/DD/YYYY)
CONTACT PRODUCER NAME:

PHONE FAX
(A/C, No, Ext): (A/C, No):

E-MAIL
ADDRESS:

INSURER A :

INSURED INSURER B :

INSURER C :

INSURER D :

INSURER E :

INSURER F :

POLICY EFF POLICY EXP TYPE OF INSURANCE LIMITS POLICY NUMBER (MM/DD/YYYY) (MM/DD/YYYY)

AUTOMOBILE LIABILITY

UMBRELLA LIAB

EXCESS LIAB

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

AUTHORIZED REPRESENTATIVE
EACH OCCURRENCE $

DAMAGE TO RENTED
CLAIMS-MADE OCCUR $ PREMISES (Ea occurrence)
MED EXP (Any one person) $
PERSONAL & ADV INJURY $
GEN'L AGGREGATE LIMIT APPLIES PER: GENERAL AGGREGATE $
PRO- POLICY LOC PRODUCTS - COMP/OP AGG $ JECT
$ OTHER:

COMBINED SINGLE LIMIT $
(Ea accident)
ANY AUTO BODILY INJURY (Per person) $
OWNED SCHEDULED BODILY INJURY (Per accident) $ AUTOS ONLY AUTOS HIRED NON-OWNED PROPERTY DAMAGE $
AUTOS ONLY AUTOS ONLY (Per accident)
$
OCCUR EACH OCCURRENCE $
CLAIMS-MADE AGGREGATE $
DED RETENTION $ $
PER OTHSTATUTE ER
E.L. EACH ACCIDENT $
E.L. DISEASE - EA EMPLOYEE $
If yes, describe under
DESCRIPTION OF OPERATIONS below E.L. DISEASE - POLICY LIMIT $ INSURER(S) AFFORDING COVERAGE NAIC #

COMMERCIAL GENERAL LIABILITY
Y / N
N / A
(Mandatory in NH)

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED.

NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE

ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. *LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. LIMITS SHOWN ARE INCLUSIVE OF AMOUNTS REQUESTED BY THE CERTIFICATE HOLDER AND MAY NOT REFLECT POLICY LIMIT AMOUNTS IN EXCESS OF THOSE REQUESTED. *Not Applicable in WY THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

CERTIFICATE HOLDER CANCELLATION
ACORD 25 (2025/12) © 1988-2025 ACORD CORPORATION. All rights reserved.

The ACORD name and logo are registered marks of ACORD

CERTIFICATE OF LIABILITY INSURANCE
Policy Number:

Frank Johnson
8155 Arroyo Circle Ste 6
GILROY, CA 95020
PINHEIRO INSURANCE AGENCY, INC.
190 First St
Gilroy, CA 95020
(408)842-4619
Date Entered:
(408)842-3587
[email protected]
GILROY VISITORS BUREAU, INC, dba: VISIT GILROY
7/15/2026
A
CF1ML-10001096-09 7/1/2026 7/1/2027
2,000,000
2,000,000
1,000,000
1,000,000
100,000
5,000
A
CF1UM-10000228-09 7/1/2026 7/1/2027
1,000,000
B 1639492-2026 7/1/2026 7/1/2027 1,000,000
1,000,000
1,000,000
Location: 8155 Arroyo Circle Ste 6 Gilroy, CA 95020
Certholder is additional insured
City of Gilroy
7351 Rosanna Street
Gilroy, CA 95020
7/15/2026
City of Gilroy, its officers, officials and employees
Included
Stefanie Pinheiro
30,000Business prop
Glass covg
Nova Casualty Company
State Fund
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8.2. City of Gilroy

STAFF REPORT
Agenda Item Title: Adopt a Resolution Approving the West Santa Clara Landscape Resiliency Project Project-Specific Analysis and Addendum to the California Vegetation Treatment Program Environmental Impact Report, Adopting CEQA Findings, a
Statement of Overriding Considerations, and a Mitigation Monitoring and Reporting Program, and Authorizing Filing of a Notice of Determination
Meeting Date: August 3, 2026
From: Matt Morley, City Administrator
Department: Administration
Submitted by: Matt Morley, City Administrator
Prepared by: Andrew Young, Emergency Services & Volunteer Coordinator STRATEGIC PLAN GOALS: Not Applicable

RECOMMENDATION
Staff recommends that the City Council:

1. Adopt the CEQA Findings and Statement of Overriding Considerations for the West Santa Clara Landscape Resiliency Project (WSCLRP);

2. Adopt the Mitigation Monitoring and Reporting Program (MMRP) contained in Attachment A of the Project-Specific Analysis (PSA) and Addendum;

3. Approve the West Santa Clara Landscape Resiliency Project PSA and Addendum to the California Vegetation Treatment Program (CalVTP) Program Environmental Impact Report for activities occurring within the City of Gilroy's jurisdiction;

4. Acknowledge the Saratoga Fire Protection District as the CEQA Lead Agency and the City of Gilroy as a Responsible Agency pursuant to CEQA Guidelines Section 15096; and

5. Adopt the attached Resolution and authorize filing of a Notice of Determination.

8.2. EXECUTIVE SUMMARY
The West Santa Clara Landscape Resiliency Project (WSCLRP) is a regional vegetation management and wildfire resilience initiative led by the Saratoga Fire Protection District. Because portions of the project area are located within the City of Gilroy, the City is acting as a Responsible Agency under the California Environmental Quality Act (CEQA) and must consider the Project-Specific Analysis (PSA), Mitigation Monitoring and Reporting Program, and CEQA Findings. Approval of the PSA/Addendum would allow future qualifying vegetation treatment activities within City jurisdiction to utilize the completed environmental review and mitigation framework.

BACKGROUND
Wildfire risk throughout Santa Clara County continues to increase due to prolonged drought, climate change, historic fire suppression practices, vegetation accumulation, and continued development within and adjacent to wildland areas. In response, regional agencies, landowners, and wildfire resilience partners collaborated to develop the West Santa Clara Landscape Resiliency Project.

The WSCLRP encompasses approximately 143,375 acres extending along the western portion of Santa Clara County from the Santa Clara Valley into the Santa Cruz Mountains. The project includes approximately 74,738 acres of ecological restoration treatments, 56,818 acres of Wildland-Urban Interface (WUI) fuel reduction treatments, and 11,819 acres of strategically located fuel break treatments. The project area includes both public and private lands and involves multiple participating landowners and agencies.

The City of Gilroy is identified as one of the participating public landowners whose properties are included within the project area. Inclusion of City-owned properties within the project area does not require implementation of treatments but allows future qualifying vegetation management activities to utilize the environmental review completed through the PSA/Addendum.

The California Board of Forestry and Fire Protection certified the California Vegetation Treatment Program (CalVTP) Program Environmental Impact Report (EIR) in December 2019. The WSCLRP PSA/Addendum tiers from and supplements the CalVTP Program EIR by evaluating project-specific environmental conditions and proposed treatment activities within the project area. Saratoga Fire Protection District serves as the CEQA Lead Agency for the PSA/Addendum and the City of Gilroy would serve as a

8.2. Responsible Agency.

ANALYSIS
The Saratoga Fire Protection District, acting as the CEQA Lead Agency, prepared the West Santa Clara Landscape Resilience Project (WSCLRP) Project-Specific Analysis (PSA) and Addendum to the California Vegetation Treatment Program (CalVTP) Program Environmental Impact Report (EIR).

The City of Gilroy's role is limited to its responsibilities as a CEQA Responsible Agency.

Pursuant to CEQA Guidelines Section 15096, Responsible Agencies must independently review and consider the environmental documentation prepared by the Lead Agency before approving project activities within their jurisdiction.

The PSA/Addendum evaluates vegetation treatment activities that may occur over time based on funding availability, landowner participation, agency priorities, and wildfire risk reduction objectives. Treatment activities may include:
• Ecological restoration treatments
• Wildland-urban interface fuel reduction
• Fuel break establishment and maintenance
• Defensible space treatments
• Mechanical thinning
• Pruning and limbing
• Removal of hazardous, dead, dying, or diseased vegetation • Biomass processing and disposal
• Ongoing maintenance treatments
The PSA/Addendum incorporates the environmental protections established under the CalVTP Program EIR, including Standard Project Requirements (SPRs), mitigation measures, and a comprehensive Mitigation Monitoring and Reporting Program (MMRP).

These measures address potential impacts to:
• Biological resources
• Cultural and tribal cultural resources
• Air quality
• Water quality and hydrology
• Geology and soils
• Recreation
• Transportation
• Noise

8.2. • Public services and utilities
• Hazardous materials
• Public health and safety
The CEQA Findings prepared for the City conclude that project impacts are adequately addressed through implementation of the adopted SPRs and mitigation measures.

Consistent with the findings certified by the California Board of Forestry and Fire Protection for the CalVTP Program EIR, certain environmental impacts remain significant and unavoidable. Therefore, adoption of a Statement of Overriding Considerations is required.

Significant unavoidable impacts include potential impacts to views from vegetation removal and impacts from smoke where prescribed burns are utilized. There is no specific project or method identified for Gilroy and the City Council would ultimately evaluate and approve any fuel mitigation activities within Gilroy city limits.

Implementation of projects is anticipated to:
• Reduce wildfire intensity and spread
• Increase protection of lives, property, and critical infrastructure • Enhance firefighter access and operational effectiveness • Improve forest and ecosystem health
• Reduce hazardous fuel accumulation
• Improve community wildfire resilience
• Strengthen regional coordination of wildfire mitigation activities

Staff has independently reviewed and considered the:
• CalVTP Program EIR
• WSCLRP PSA/Addendum
• Mitigation Monitoring and Reporting Program (MMRP)
• CEQA Findings
• Statement of Overriding Considerations
Staff finds the environmental documentation adequate to support the City's Responsible Agency approval. Accordingly, staff recommends adoption of the CEQA Findings, Statement of Overriding Considerations, and MMRP, and approval of the PSA/Addendum.

8.2. ALTERNATIVES
Alternative 1 – Approve the Recommended Action (Recommended) Adopt the Resolution, CEQA Findings, Statement of Overriding Considerations, and MMRP and approve the PSA/Addendum for use within the City's jurisdiction.

Alternative 2 – Deny the Request
The City Council may decline to approve the PSA/Addendum. This would limit the City's ability to utilize the completed environmental review for future qualifying vegetation treatment activities and could reduce opportunities for coordinated regional wildfire resilience efforts.

FISCAL IMPACT/FUNDING SOURCE
There is no direct fiscal impact associated with this action. Approval of the PSA/Addendum does not authorize expenditures or commit City funding. Establishing CEQA coverage for future qualifying vegetation management activities may improve the City's ability to pursue future funding opportunities and regional partnerships; however, any future project implementation and associated funding requests would be subject to separate City review and approval.

PUBLIC OUTREACH
Public review and agency coordination for the PSA/Addendum were conducted by Saratoga Fire Protection District as Lead Agency in accordance with CEQA requirements.

This item was publicly noticed and included on the City Council agenda.

NEXT STEPS
Upon Council approval:

1. The Resolution will become effective immediately.

2. The City will adopt the CEQA Findings and Statement of Overriding Considerations.

3. The City will adopt the Mitigation Monitoring and Reporting Program.

8.2. 4. Staff will file a Notice of Determination.

5. The City may utilize the PSA/Addendum as a Responsible Agency for future qualifying vegetation treatment activities within City jurisdiction.

6. Future treatment projects, if any, will proceed subject to applicable permits, funding, landowner participation, and implementation requirements contained within the PSA/Addendum and MMRP.

Attachments:

1. Resolution Approving the West Santa Clara Landscape Resiliency Project ProjectSpecific Analysis and Addendum

2. West Santa Clara Landscape Resilience Project_Project-Specific Analysis - Addendum to the CalVTP

3. Attachment A - Mitigation Monitoring and Reporting Program

4. CEQA Findings and Statement of Overriding Considerations

5. Notice of Determination

RESOLUTION NO. 2026-XX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF GILROY ADOPTING CEQA FINDINGS, A STATEMENT

OF OVERRIDING CONSIDERATIONS, AND A

MITIGATION MONITORING AND REPORTING

PROGRAM, APPROVING THE WEST SANTA CLARA
LANDSCAPE RESILIENCY PROJECT PROJECTSPECIFIC ANALYSIS AND ADDENDUM TO THE

CALIFORNIA VEGETATION TREATMENT PROGRAM

ENVIRONMENTAL IMPACT REPORT, AND

AUTHORIZING FILING OF A NOTICE OF

DETERMINATION
WHEREAS, the California Board of Forestry and Fire Protection certified the California Vegetation Treatment Program Environmental Impact Report ("CalVTP Program EIR") in December 2019; and
WHEREAS, the Saratoga Fire Protection District prepared the West Santa Clara Landscape Resiliency Project ("WSCLRP") Project-Specific Analysis and Addendum ("PSA/Addendum") pursuant to CEQA and the CalVTP Program EIR; and WHEREAS, Saratoga Fire Protection District serves as the CEQA Lead Agency for the WSCLRP PSA/Addendum; and
WHEREAS, portions of the WSCLRP project area are located within the jurisdiction of the City of Gilroy; and
WHEREAS, the City of Gilroy serves as a Responsible Agency pursuant to CEQA Guidelines Section 15096; and
WHEREAS, the City Council has reviewed and considered the CalVTP Program EIR, the PSA/Addendum, the Mitigation Monitoring and Reporting Program, and the CEQA Findings and Statement of Overriding Considerations; and
WHEREAS, the City Council finds that the PSA/Addendum adequately evaluates the environmental impacts associated with the proposed activities within the City's jurisdiction and that adoption of the Findings, Statement of Overriding Considerations, and Mitigation Monitoring and Reporting Program is appropriate.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Gilroy hereby:

Section 1.

Finds that the foregoing recitals are true and correct and are incorporated herein by reference.

Section 2.

Adopts the CEQA Findings and Statement of Overriding Considerations for the West Santa Clara Landscape Resiliency Project.

Section 3.

Adopts the Mitigation Monitoring and Reporting Program contained in Attachment A to the PSA/Addendum.

Section 4.

Approves the West Santa Clara Landscape Resiliency Project Project-Specific Analysis and Addendum to the California Vegetation Treatment Program Environmental Impact Report for activities occurring within the City of Gilroy's jurisdiction.

Section 5.

Authorizes and directs the appropriate City officials to file a Notice of Determination in accordance with CEQA.

Section 6.

Authorizes the City Manager or designee to take such actions as necessary to implement this Resolution.

PASSED AND ADOPTED at a Regular Meeting of the City Council this 3rd day of August 2026 by the following vote.

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

APPROVED:

Greg Bozzo, Mayor
ATTEST:

Kim Mancera, City Clerk

PROJECT-SPECIFIC ANALYSIS

AND ADDENDUM TO THE
CalVTP PROGRAM EIR
West Santa Clara
Landscape Resiliency
Project
Prepared for:

Saratoga Fire Protection District
The Santa Clara County
Firesafe Council
APRIL 2026

PROJECT-SPECIFIC ANALYSIS AND ADDENDUM

TO THE CALVTP PROGRAM EIR
West Santa Clara Landscape
Resiliency Project
Prepared for:

Saratoga Fire Protection District
14380 Saratoga Avenue
Saratoga, CA 95070-5953
Contact:

Trina Whitley, Business Manager
[email protected]
408.867.9001
The Santa Clara County
Firesafe Council
14380 Saratoga Avenue
Saratoga, CA 95070-5953
Contact:

Stephen Harrington, Senior Forest Health Project Manager [email protected]
408.975.9591
Prepared by:

Ascent Environmental, Inc. dba Ascent
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Contact: Grace Mannel
Wildfire Resilience Planner
[email protected]
510.387.7710
Auten Resource Consulting (ARC)
116 Martinelli Street, Suite #8
Watsonville, CA 95076
Contact:

Steve Auten, RPF #2734
[email protected]
831.228.1800
APRIL 2026

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR i

TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS ........................................................................................................................................................................... II 1 INTRODUCTION ........................................................................................................................................................................ 1-1

1.1 Project Overview.................................................................................................................................................................1-1

1.2 Phased Implementation.................................................................................................................................................. 1-5

1.3 Document Purpose........................................................................................................................................................... 1-6

1.4 Existing Conditions.......................................................................................................................................................... 1-12

1.5 Project Objectives........................................................................................................................................................... 1-26 2 PROJECT DESCRIPTION ...........................................................................................................................................................2-1

2.1 Treatment Prescription.................................................................................................................................................... 2-1

2.2 Treatment Types ............................................................................................................................................................... 2-3

2.3 Treatment Activities......................................................................................................................................................... 2-8

2.4 Biomass Processing ....................................................................................................................................................... 2-14

2.5 Treatment Maintenance............................................................................................................................................... 2-16

2.6 Guidance Following PSA Approval............................................................................................................................2-17 3 ENVIRONMENTAL CHECKLIST...............................................................................................................................................3-1 4 PROJECT-SPECIFIC ANALYSIS/ADDENDUM ..................................................................................................................... 4-1

4.1 Aesthetics and Visual Resources .................................................................................................................................. 4-1

4.2 Agriculture and Forestry Resources ........................................................................................................................... 4-4

4.3 Air Quality ........................................................................................................................................................................... 4-6

4.4 Archaeological, Historical, and Tribal Cultural Resources.................................................................................................... 4-11

4.5 Biological Resources...................................................................................................................................................... 4-15

4.6 Geology, Soils, Paleontology, and Mineral Resources....................................................................................... 4-60

4.7 Greenhouse Gas Emissions ......................................................................................................................................... 4-63

4.8 Energy Resources ........................................................................................................................................................... 4-65

4.9 Hazardous Materials, Public Health and Safety................................................................................................... 4-67

4.10 Hydrology and Water Quality.................................................................................................................................... 4-70

4.11 Land Use and Planning, Population and Housing.............................................................................................. 4-75

4.12 Noise................................................................................................................................................................................... 4-77

4.13 Recreation......................................................................................................................................................................... 4-80

4.14 Transportation................................................................................................................................................................. 4-82

4.15 Public Services, Utilities, and Service Systems...................................................................................................... 4-85

4.16 Wildfire............................................................................................................................................................................... 4-88 5 LIST OF PREPARERS ..................................................................................................................................................................5-1 6 REFERENCES ...............................................................................................................................................................................6-1 Attachments
A Mitigation Monitoring and Reporting Program
B Biological Resources

List of Abbreviations Ascent
Saratoga Protection Fire District
ii West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

LIST OF ABBREVIATIONS
AB Assembly Bill
BMP Best Management Practices
Board California Board of Forestry and Fire Protection
CAAQS California ambient air quality standard
CAL FIRE California Department of Forestry and Fire Protection Cal-IPC California Invasive Plant Council
Caltrans California Department of Transportation
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CNDDB California Natural Diversity Database
CWHR California Wildlife Habitat Relationships
dB decibels
dbh diameter at breast height
DPR Department of Pesticide Regulation
EPA US Environmental Protection Agency
ESA Endangered Species Act
FUDS formerly used defense sites
GHG greenhouse gas
GIS Geographic Information System
HCP habitat conservation plan
hex-grid hexagonal-grid
IPaC Information for Planning and Consultation
judgement Judgement After Appeal
LRA Local Responsibility Area
MBARD Monterey Bay Air Resources District
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
NAAQS national ambient air quality standard
NAHC Native American Heritage Commission
NAIP National Agriculture Imagery Program
NCCP natural community conservation plan
NOA naturally occurring asbestos
NOX nitrous oxide

Ascent List of Abbreviations
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR iii NWI National Wetlands Inventory
NWIC Northwest Information Center
PG&E Pacific Gas & Electric
PM particulate matter
PRC Public Resource Code
Program EIR Program Environmental Impact Report
PSA project-specific analysis
ROG reactive organic gas
RPF Registered Professional Foresters
SCCFSC Santa Clara County Fire Safe Council
SCCP Santa Clara County Parks
SCVHP Santa Clara Valley Habitat Plan
SENL single-event noise level
SFD Saratoga Fire Protection District
SOD sudden oak death
SPR standard project requirement
SRA State Responsibility Area
TAC toxic air contaminants
TMP Traffic Management Plan
UCSB University of California Santa Barbara
USFWS United States Fish and Wildlife Service
USFWS US Fish and Wildlife Service
USGS US Geological Survey
VMT vehicle miles traveled
WLPZ Watercourse and Lake Protection Zone
writ Peremptory Writ of Mandate
WSCLRP West Santa Clara Landscape Resiliency Project
WUI wildland-urban interface

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

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-1 1 INTRODUCTION

1.1 PROJECT OVERVIEW
Located along the western boundary of Santa Clara County, the West Santa Clara Landscape Resiliency Project (WSCLRP) covers approximately 143,375 acres, from the wildland-urban interface (WUI) of the Santa Clara Valley and southern Bay Area west into the Santa Cruz Mountains (Map 1-1). The majority of treatment coverage in the project area would be ecological restoration treatments across approximately 74,738 acres, with significant sections of WUI fuel reduction treatments across approximately 56,818 acres, and a network of strategically planned fuel breaks occupying approximately 11,819 acres primarily along ridgetops and important ingress and egress routes throughout the project area.

The project area consists of a discontinuous collection of public and private parcels roughly bound by San Mateo County to the north, major thoroughfares that run to the east (from north to south: Foothill Expressway, State Route [SR] 85, and SR 101), the intersection of SR 101 and SR 129 to the south, and San Mateo and Santa Cruz Counties to the west, primarily along Skyline Boulevard (SR 35) and Summit Road (Map 1-1). The criteria and methodology used to delineate the project area are described under “Project Area Formulation and Mapping,” below.

The project area contains an array of landscape conditions. Vegetation types within the project area include grassland and oak savanna, mixed chaparral and shrubland, hardwood forest, and mixed-conifer forest dominated by redwood (Sequoia sempervirens) and Douglas-fir (Pseudotsuga menziesii). These natural landscapes tightly border and, in most cases, intermix with dense residential communities and critical infrastructure. This dynamic is most pronounced along the eastern boundary of the project where the urban footprint of the greater San Jose metropolitan area meets the foothills of the Santa Cruz Mountains, creating a nearly continuous band, over 50 miles north to south, of WUI communities where the built environment is highly intertwined with densely vegetated and fire-prone wildlands.

These landscapes are increasingly affected by wildfire. Some factors that have led to these conditions include the elimination of cultural burning since the late 1800s, exclusion and suppression of beneficial fire over the last 100 years, a lack of vegetation management, climate change, periods of successive drought, and continued development in the WUI. These factors have resulted in increased spread of forest pathogens, overly dense forests, and high fuel loading, in turn, creating hazardous conditions that can lead to catastrophic wildfire. Compounding these effects are successional changes, such as conifer species displacing hardwoods and other fire resilient native plant species, in turn, lowering biodiversity and affecting the suitability of these habitats for rare and special-status wildlife and plants.

Consequently, ecosystems have undergone major structural and compositional changes that warrant strategic treatment to redirect the effects of changing climatic and ecological conditions.

This project serves to facilitate future landscape-scale wildfire resilience treatments across a variety of settings and land ownership types (e.g., landscape-scale treatments on public land in primarily wildland conditions, small-scale treatments conducted adjacent to urban homes that combine vegetation management efforts with defensible space treatments). This work aims to mitigate wildfire risk, increasing community and ecological wildfire resiliency and enhancing biological diversity.

Introduction Ascent
Saratoga Protection Fire District
1-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Source: Information developed by ARC in collaboration with SCC FSC, SFD, and project partners in 2025.

Map 1-1. WSCLRP Project Area and Vicinity

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-3

1.1.1 Project Area Formulation and Mapping
The project area, a discontinuous collection of public and private parcels, was compiled based on a strategic Geographic Information System (GIS) mapping procedure in which parcels were selected for inclusion in the project area according to characteristics that define wildfire hazard to human and natural communities. This section outlines this methodology, employing three distinct steps—initial mapping, field verification, and final mapping—to formulate the project area.

INITIAL MAPPING
The process of developing the project area began by setting a geographical boundary of Santa Clara County. Then, the project area was refined to include only lands west of US Highway 101, bound to the north by San Mateo County, west by Santa Cruz County, and south by San Benito County. Within this refined area, communication began with regional public landowners to confirm their interest in partnering on the project and identifying lands they wanted in the project area or not (see the “Landowners” section below for more information). These public parcels formed an initial extent of the project area and allowed the identification of adjoining candidate private parcels to be considered for inclusion into the project area based on continuity with public lands and overlap with the Wildfire Risk to Structures dataset created by Tukman Geospatial.
1 The Wildfire Risk to Structures data set considers a series of factors to determine relative fire risk on a scale from lowest to highest in a continuous hexagonal-grid (hex-grid) pattern across the landscape. Parcels that overlapped with Wildfire Risk to Structures hex-grids of moderate to highest risk were selected. These parcels were mapped as WUI treatment type, and all nonoverlapping parcels were identified as the ecological restoration treatment type. The collection of public and private parcels shown in Map 1-2 was the baseline for initial treatment type mapping, field verification, and final mapping. Professional judgment was used to further refine treatment type identification based on conditions illuminated by aerial imagery, building footprint, vegetation, topography, and other available public datasets.

FIELD VERIFICATION
Following this procedure, landscape conditions were field verified across the initial mapped project area. After field observations, the project area was extended into the adjacent WUI and residential areas along the eastern project boundary, and the project description was expanded to include defensible space treatments due to the proximity, intermix, and high degree of connectivity with wildland vegetation and hazardous fuel conditions in relative proximity to residential areas. This decision was made, in part, with the context of the 2025 Palisades and Eaton Fires in mind, particularly the manner in which extreme weather spread fire downslope and across densely developed residential areas to an unprecedented degree.

FINAL MAPPING
To determine the extent of the project area into the WUI communities and the developed residential margin along the eastern project boundary, three factors were considered in order of importance: (1) parcel overlap with moderate to highest Wildfire Risk to Structures hex-grids, (2) vegetation conditions determined from aerial imagery and field observations (e.g., density and continuity with infrastructure), and (3) high topographic variation. The purpose of developing these criteria was to establish a consistent method for parcel inclusion or exclusion in more developed areas. In areas where these criteria did not definitively support parcel inclusion or exclusion, California Department of Forestry and Fire Protection (CAL FIRE) WUI2 modeling data was considered as a secondary criterion, with the recognition that the Wildfire Risk to Structures is a more detailed model driven by more current data sets. 1 The Wildfire Risk to Structures model incorporates the following input data sets: flame length, extreme fire weather potential, ember load index, suppression difficulty, dense urban without wildland vegetation, human development proximity, transmission line proximity, distribution line proximity, historic ignitions, and structure density. More information is available at: https://tukmangeospatial.egnyte.com/dl/MuqO0RacS9. 2 CAL FIRE’s mapped WUI data (2025) is available at: https://egis.fire.ca.gov/portal/home/item.html?id=0c80c733a1f54d60acbf88f3389d4197.

Introduction Ascent
Saratoga Protection Fire District
1-4 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Source: Information adapted by ARC in 2025.

Map 1-2. Land Ownership in the WSCLRP Project Area

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-5 Additional considerations were made in the interest of maintaining consistency across project mapping, such as using roads and city blocks to bound the project whenever possible and allowing professional judgment to supplement the three-criteria procedure in situations where conditions supported both inclusion and exclusion of individual parcels; for example, parcels within approximately one hex-grid (800 feet) of, but not overlapping, moderate to highest Wildfire Risk to Structures hex-grids were evaluated for inclusion in the project area to account for potential error introduced by the large cell size of individual hex-grids.

Fuel break treatment type was mapped on established two-track roads on prominent ridgelines or along the margin of residential developments in wildland settings and on paved roads identified as important ingress or egress routes throughout the project area. Proposed fuel breaks have been mapped to intersect with the footprint of parcels included in the project area; rights-of-way managed by the California Department of Transportation (Caltrans) and other agencies are not included in the project area.

Identification of the project area and proposed treatment types considered the Santa Clara County Community Wildfire Prevention Plan, including consultation and oversight by fire districts and fire safe councils within the project area, CAL FIRE, other experienced fire behavior specialists, and Registered Professional Foresters (RPFs). See Section

2.2, “Treatment Types,” for treatment type maps (Maps 2-1, 2-2).

1.1.2 Landowners
Approximately 99,209 acres of private land are included in the project area, ranging from large parcels of forest and rangeland to residential communities. The public landowners whose lands constitute approximately 44,166 acres of the project area and have expressed interest in using this PSA/Addendum are California State Parks; Santa Clara County Parks; Santa Clara Valley Habitat Agency; Santa Clara Valley Open Space Authority; Peninsula Open Space Trust; the Cities of Palo Alto, Cupertino, Saratoga, Morgan Hill, and Gilroy; and the Land Trusts of Santa Clara County and Santa Cruz County. Parcels included in the project area were evaluated for feasibility of vegetation management treatments; therefore, only select lands owned by these public landowners are included, as described above in the “Project Area Formulation and Mapping” section. See Map 1-2 for land ownership and lands included in the project area. The large gaps across much of the northern half of the project area are primarily composed of the major land holdings of Midpeninsula Open Space District and San Jose Water Company, whose lands have existing California Environmental Quality Act (CEQA) coverage for vegetation treatment. The large gap in the project area southwest of Gilroy is a collection of private lands that also have existing CEQA coverage.

Inclusion of a parcel in the project area does not allow access to implement treatments or for other purposes without the permission of that landowner. Landowners included in the project area may opt into using this PSA/Addendum for CEQA coverage of vegetation management activities if they choose. This PSA/Addendum does not supersede any existing permits or agreements that already exist, so treatment activities may occur under this PSA/Addendum simultaneously and on the same land as implementation of other plans and permits, such as timber harvest plans or CEQA exemptions.

Additionally, the inclusion of one parcel and not an adjacent parcel along the eastern boundary of the project area does not indicate that vegetation should not be managed on that parcel or around that structure; wildfire prevention should be considered for all urban areas in the region.

1.2 PHASED IMPLEMENTATION
Upon approval, the WSCLRP PSA/Addendum will provide CEQA compliance coverage for vegetation management across 143,375 acres of Santa Clara County in the Santa Cruz Mountains, enabling long-term flexibility for Saratoga Fire Protection District, Santa Clara County Fire Safe Council, and other regional partners and collaborators to plan and implement wildfire resilience treatments across the project area. These treatments would not all happen at once but would be phased and maintained over time based on availability of funding, resources, community outreach opportunities, and partner collaboration.

Introduction Ascent
Saratoga Protection Fire District
1-6 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR To support informed decision-making on the location of wildfire resilience treatments under the WSCLRP, a parallel effort will be implemented to strategically prioritize treatment areas for implementation. This effort is referred to as LLPRT (Landscape Level Prioritized Resilience Treatments), which identifies strategically prioritized resilience treatment areas based on an array of planning documents (e.g., unit fire plans, community wildfire protection plans), spatial data, and professional expertise that considers how fire moves across the landscape including, but not limited to, topography, prevailing wind, Wildfire Risk to Structures, fire history, access, costs, protecting and conserving sensitive resources, vegetation type and density, and treatment maintenance. Essentially, LLPRT incorporates landscape-scale GIS data, sophisticated wildfire modeling results, local environmental conditions, and professional expertise to determine wildfire hazard and assign priority for treatments to inform treatment phasing for implementation of the WSCLRP.

Partners or collaborators can view data sets on the LLPRT web map platform to identify prioritized treatment areas, download this information, and plan treatments for implementation.

1.3 DOCUMENT PURPOSE
The California Board of Forestry and Fire Protection (Board) certified the Program Environmental Impact Report (Program EIR) for the CalVTP in December 2019. The Program EIR evaluates the potential environmental effects of implementing vegetation treatments throughout the State Responsibility Area (SRA) and selected portions of the Local Responsibility Area (LRA) in California.

This document serves as a project-specific analysis (PSA) to evaluate whether the proposed treatments would be within the scope of the CalVTP Program EIR. The treatment types and treatment activities are consistent with the CalVTP. If a proposed vegetation treatment project is covered by the evaluation of environmental effects in the Program EIR, it may be approved using a finding that the project is within the scope of the Program EIR for its CEQA compliance, consistent with State CEQA Guidelines Section 15168(c)(2).

An addendum to an EIR is appropriate where a previously certified EIR has been prepared and some changes or revisions to the project are proposed, or the circumstances surrounding the project have changed, but none of the changes or revisions would result in new or substantially more severe significant environmental impacts, consistent with CEQA Section 21166 and State CEQA Guidelines Sections 15162, 15163, 15164, and 15168. In this case, there are no changed circumstances, but the proposed revisions or changes in the project, compared to the Program EIR, are the inclusion of areas outside the CalVTP treatable landscape and proposed revisions to certain standard project requirements; therefore, this document is both a PSA and an addendum to the CalVTP Program EIR for review and analysis of the proposed project under CEQA. The PSA checklist includes the criteria to support an addendum to the CalVTP Program EIR for these proposed revisions or changes in the project, compared to the Program EIR. The checklist evaluates each resource in terms of whether the later treatment project, including the “changed condition” of additional geographic area, would result in significant impacts that would be substantially more severe than those covered in the Program EIR or would result in any new impacts that were not covered in the Program EIR.

It is improbable that every acre within the 143,375-acre project area would be treated. The purpose of a more expansive project area is to provide CEQA coverage across key strategic areas, which span public and private landowners, in upcoming planning efforts, such as updated unit fire plans, community wildfire prevention plans, or other strategic planning efforts. With landscape-scale CEQA coverage, the Saratoga Fire Protection District and other entities operating in the project area can facilitate collaborations across landowners on regional treatment priorities to increase the health and safety of the landscape and the communities encompassed in the project area. This PSA does not put any restrictions on landowners from obtaining other permits or conducting other projects or work on their land that do not trigger CEQA compliance. Rather, the PSA would be available for public agencies to use when CEQA compliance is required for a project on public or private land.

Vegetation management requires compliance with CEQA if it involves a discretionary approval by a public agency.

Prescribed fire, defensible space clearance, and fuel break treatments may be exempted from CEQA pursuant to Section 21080.49 of the Public Resources Code (PRC), which provides a statutory exemption to CEQA for wildfire risk reduction projects that meet certain requirements (e.g., treatments do not exceed 50 acres in size, fuel breaks extend up to 200 feet from structures, tree removal of less than 12 inches diameter at breast height [dbh]). Alternatively, vegetation management treatments may qualify for a categorical exemption from CEQA pursuant to State CEQA

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-7 Guidelines Section 15301 (“Class 1, Existing Facilities”), which includes maintenance of existing landscaping and native growth, or Section 15304 (“Class 4, Minor Alterations to Land”), which includes fuel management activities within 30 to 100 feet of a structure provided certain qualifications are met. Other categorical and statutory CEQA exemptions may also be relevant (e.g., State CEQA Guidelines Section 15269). Project proponents may design a vegetation management treatment within the boundaries of the WSCLRP area and seek CEQA coverage through the PSA or an exemption depending on schedule and treatment objectives.

Also, given the landscape-scale of the project and limited spatial resolution of publicly accessible land ownership boundaries, the potential exists that during pretreatment field layout, the RPF or qualified forestry professional may determine that treatment area boundaries need to shift slightly from the project area identified in this PSA/Addendum to meet treatment objectives and reflect on-the-ground conditions. The RPF or qualified professional would determine whether all resources in the area outside the project boundary were considered in the PSA/Addendum or are substantially the same as those considered in the PSA/Addendum, including that the cultural records search encompassed any expanded area. If resources are present that were not considered in the PSA/Addendum, additional CEQA documentation (e.g., revised PSA) must be prepared to document whether a new significant impact or substantial increase in the severity of an identified significant impact would occur from treatments in the area outside the project boundary. All relevant standard project requirements (SPRs) and mitigation measures (MMs) would be applied throughout the entire treatment area.

Implementation of treatments in chaparral and coastal sage scrub under this PSA/Addendum will conform to the requirements of the Judgment After Appeal (judgment) and Peremptory Writ of Mandate (writ) issued by the San Diego Superior Court in California Chaparral Institute et al. v. Board of Forestry and Fire Protection. The requirements are presented in SPR CHAP/CSS-1. See the “Chaparral and Coastal Sage Scrub,” section under “Impact BIO-3 in Section 4.5, “Biological Resources,” for additional information.

1.3.1 Roles Under CEQA
For the purposes of the CalVTP Program EIR and this PSA/Addendum, a project proponent is any 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. This document is being prepared for the Saratoga Fire Protection District (SFD), in its role as CEQA lead agency, to comply with CEQA for the implementation of vegetation treatments that require a discretionary action of SFD (e.g., implementation of treatments on the properties within its jurisdiction, administer grant funding). The PSA/Addendum would provide environmental information to SFD in its consideration of approval of funding allocations and implementation of treatments.

As the CEQA lead agency, SFD would be responsible for ensuring that implementation of MMs and SPRs related to its discretionary approval occurs in accordance with the Mitigation Monitoring and Reporting Program (MMRP) pursuant to Section 15097(a) of the State CEQA Guidelines. Please refer to the Mitigation Monitoring and Reporting Program (Attachment A) for additional explanation of roles regarding monitoring and reporting.

USE OF THE PSA/ADDENDUM BY OTHER AGENCIES
This PSA/Addendum, in conjunction with the CalVTP Program EIR, may be used for CEQA compliance by other public agencies acting in a responsible agency role when a discretionary approval is needed pertaining to covered activities in the project area, including for public funding through other sources (e.g., CAL FIRE Forest Health Grants). For example, Santa Clara County Parks (SCCP) owns lands within the project area and would implement treatments therein. Therefore, SCCP could use this PSA/Addendum as a responsible agency for CEQA compliance for treatments carried out by the agency on its lands.

A responsible agency would consider its action in light of the PSA/Addendum and confirm the action’s environmental effects are covered. If so, and in conformance with State CEQA Guidelines Section 15096, the responsible agency would adopt its findings, using the SFD findings as a guide if desired, adopt the MMRP as it pertains to its projectrelated approval, and file a notice of determination regarding their project-related approval.

Introduction Ascent
Saratoga Protection Fire District
1-8 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR In the circumstance where another public agency seeks to use the WSCLRP PSA/Addendum for CEQA compliance and there is no related discretionary approval required of SFD, SFD would have no involvement, oversight, or other obligation in the approval, implementation, or documentation of that agency’s actions. For example, the vegetation treatments on SCCP property may require discretionary approval by an agency other than SFD.

1.3.2 Proposed Project Revisions
Under this project, the proposed treatment types and treatment activities are consistent with the Program EIR. However, the project includes land outside the treatable landscape that was not analyzed in the Program EIR. SFD has deemed that certain requirements of four SPRs are operationally infeasible, would prevent achievement of project goals, or are not warranted to maintain the impact analyses conclusions in the Program EIR due to site-specific circumstances.

Revisions to the treatable landscape and four SPRs constitute a change to the CalVTP Program EIR’s description of later project activities and of the analyzed treatment design and implementation. These revisions and substantial evidence that proposed changes do not result in any new or substantially more severe significant impacts on any of the resources evaluated in the Program EIR and described in this PSA/Addendum are described below.

PROJECT AREA OUTSIDE THE CalVTP TREATABLE LANDSCAPE
Among the criteria for determining if a project is within the scope of the CalVTP Program EIR is whether it is located in the CalVTP treatable landscape (i.e., the geographic extent of analysis covered in the Program EIR) (Map 1-3). 3 Although most of the WSCLRP area would be inside, portions of the project area would extend outside the treatable landscape described in the CalVTP Program EIR.

Approximately 95,061 acres of the proposed project area is within the treatable landscape, and 48,314 acres of the project area fall outside the treatable landscape. The portions that are located outside the treatable landscape range from small, discontinuous sections of wildland directly adjacent to other portions of the project area to large swaths of primarily residential communities intermixed with vegetated tracts of wildland. Treating these areas would expand the connectivity of restorative treatments in vegetative and landscape conditions that are essentially the same or substantially similar to those within the treatable landscape in the project area.

The inclusion of areas that are outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, the ecosystem and environmental conditions within and outside CalVTP treatable landscape of this project area are either essentially the same or are CEQA-exempt landscapes. Further, the proposed treatment types and treatment activities are consistent with those evaluated in the Program EIR; therefore, impacts analyzed in this PSA/Addendum would not result in any new or substantially more severe significant impacts than evaluated in the Program EIR. All resource impacts analyzed as part of this PSA/Addendum address the inclusion of land outside the treatable landscape in Chapter 4, “Project-Specific Analysis/Addendum.” PROPOSED REVISIONS TO CalVTP STANDARD PROJECT REQUIREMENTS While the proposed treatment types and treatment activities are consistent with the CalVTP, SFD and partners consulted in development of this project description have determined that specific requirements of certain SPRs are operationally infeasible, if implemented as presented in the Program EIR; would prevent achievement of project objectives; or are not warranted to maintain the impact analyses conclusions in the Program EIR due to site-specific circumstances.

Because SPRs are part of the CalVTP program description and are incorporated into later activities as a standard part of treatment design and implementation, revisions (beyond clarifying edits) would constitute a change to the CalVTP. 3 Per the Program EIR (CalVTP Final Program EIR Volume II Appendix PD-1), the treatable landscape was developed using desktop applications to apply buffers around geographic and topographic features and demarcate jurisdictional boundaries (e.g., SRA and LRA); the method resulted in some treatable landscape areas that are shown on maps to be pixelated and scattered and some that are inheld areas surrounded by treatable landscape. If the areas of the proposed project outside the CalVTP treatable landscape have essentially the same, or substantially similar, landscape conditions as the treatable landscape, the environmental analysis of the Program EIR would be applicable.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-9 Source: Information from CAL FIRE, adapted by ARC in 2025.

Map 1-3. Treatable Landscape within the WSCLRP Project Area

Introduction Ascent
Saratoga Protection Fire District
1-10 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR The proposed revisions to SPRs are described below. These proposed changes would not result in any new or substantially more severe significant impacts on any of the resources evaluated in the Program EIR and described in this PSA/Addendum. Evidence to explain this conclusion is presented under each applicable resource, as summarized below and presented throughout Chapter 4, “Project-Specific Analysis/Addendum” (see Section 4.4, “Archaeological, Historical, and Tribal Cultural Resources”; Section 4.6, “Geology, Soils, Paleontology, and Mineral Resources”; Section

4.9, “Hazardous Materials, Public Health and Safety”; and Section 4.10, “Hydrology and Water Quality.” In addition to the revisions described below, SPR CHAP/CSS-1 has been added to ensure adherence to the requirements of the writ. The addition of SPR CHAP/CSS-1 is a legal provision that does not constitute a revision of the CalVTP; therefore, the addition of SPR CHAP/CSS-1 is not addressed in this section. See the “Chaparral and Coastal Sage Scrub” section under Impact BIO-3 in Section 4.5, “Biological Resources,” for additional information.

SPR CUL-4: Archaeological Surveys
SPR CUL-4, as presented in the Program EIR, requires 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 on archaeological or historical resources (e.g., manual treatments and herbicide application).

A revision to the SPR is proposed such that archaeological surveys would be conducted for only 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:

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 all treatment types, including treatment maintenance.

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

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

As described in CalVTP Program EIR Section 2.5.2, some treatment activities, such as manual treatments and application of herbicide, would not result in ground disturbance and are effectively used in sensitive areas and habitats. Example activities include burn pile construction by hand, carrying material to a chipper, lopping and scattering material, and other manual activities. Surveying for cultural resources if there is no potential for impact would result in inefficient and unnecessary use of human and financial resources. This revision to SPR CUL-4 would prevent unnecessarily slowing down implementation while maintaining the overall intent of SPR CUL-4 in areas where ground disturbance activities have a likelihood of affecting cultural resources.

Potential impacts resulting from revisions to SPR CUL-4 are discussed below under Sections 4.4, “Archaeological, Historical, and Tribal Cultural Resources.” As explained in that section, the proposed revisions to SPR CUL-4 would not result in any new or substantially more severe significant impacts than were analyzed in the Program EIR. Impacts on other resources would not occur as a result of these revisions, because SPR CUL-4 is not required to reduce environmental effects on any other resources from implementation of the project. The proposed revisions to SPR CUL-4 are shown in the MMRP (Attachment A).

SPR GEO-1: Suspend Disturbance during Heavy Precipitation SPR GEO-1, as presented in the Program EIR, requires suspension of treatment activities including mechanical treatments, herbicide application, and prescribed herbivory during heavy precipitation (i.e., if the National Weather Service forecast is a chance [30 percent or more] of rain within the next 24 hours). As described in the CalVTP Program EIR, mechanical treatments and herbicide application conducted during precipitation events can result in soil disturbance, erosion, increased runoff, soil destabilization, and water quality impacts.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-11 A revision to the SPR is proposed such that mechanical treatments would be suspended if (1) it is raining, (2) soils are saturated, or (3) soils are wet enough to be compacted by mechanical treatment activities and that herbicide application would be suspended if the National Weather Service forecast is a “chance” (30 percent or more averaged over each hour) of rain within the next 24-hour period.

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

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

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

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

Potential impacts resulting from revisions to SPR GEO-1 are discussed below in Sections 4.5, “Biological Resources”;

4.6, “Geology, Soils, Paleontology, and Mineral Resources”; and 4.10, “Hydrology and Water Quality.” As explained in these sections, the proposed revisions to SPR GEO-1 would not result in any new or substantially more severe significant impacts than were analyzed in the Program EIR. Impacts on other resources would not occur as a result of these revisions, because SPR GEO-1 is not required to reduce environmental effects on any other resources from implementation of the project. The proposed revisions to SPR GEO-1 are shown in the MMRP (Attachment A).

SPR HAZ-1: Maintain All Equipment
SPR HAZ-1, as presented in the Program EIR, requires that the project proponent inspect all equipment for leaks prior to the start of treatment activities and every day thereafter until equipment is removed from the site, and any equipment found leaking must be promptly removed.

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

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

The project proponent will maintain all diesel- and gasoline-powered equipment per manufacturer’s specifications, and in compliance with all state and federal emissions requirements. Maintenance records will be available for verification. Prior to the start of treatment activities, the project proponent will inspect all equipment for leaks and inspect everyday thereafter until equipment is removed from the site. Any equipment found leaking will be promptly removed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

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

Any equipment found leaking will be promptly stabilized and fixed on-site or removed.

This revision gives the project proponent the flexibility to fix equipment on-site if feasible and continue treatment rather than requiring all leaking equipment be removed. This would help to prevent unnecessarily slowing down of implementation while maintaining the overall intent of SPR HAZ-1 to minimize hazardous material releases in treatment areas from equipment use.

Equipment is checked daily for leaks and is not staged in WLPZs or near sensitive resources. This revision allows leaking equipment to be stabilized immediately and to be moved to a less sensitive area, rather than requiring it to be demobilized and potentially risk spreading the leak through more environmentally sensitive habitat areas or other sensitive resources. All other applicable SPRs would be followed to minimize this impact.

Introduction Ascent
Saratoga Protection Fire District
1-12 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Potential impacts resulting from revisions to SPR HAZ-1 are discussed below in Section 4.3, “Air Quality”; Section 3.9, “Hazardous Materials”; and Section 4.10, “Hydrology and Water Quality.” As explained in these sections, the proposed revisions to SPR HAZ-1 would not result in any new or substantially more severe significant impacts than were analyzed in the Program EIR. Impacts on other resources would not occur as a result of these revisions, because SPR HAZ-1 is not required to reduce environmental effects to any other resources from implementation of the project.

The proposed revisions to SPR HAZ-1 are shown in the MMRP (Attachment A).

SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones SPR HYD-4, as presented in the Program EIR, requires that the project proponent establish WLPZs on either side of Class I, Class II, Class III, and Class IV watercourses, as defined by the California Forest Practice Rules, California Code of Regulations Title 14, Section 916.5 (14 CCR Section 916.5).

A revision to the SPR is proposed to establish the WLPZs for only the watercourses within 300 feet of the manual, mechanical, prescribed pile burning, and herbicide treatments.

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

The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (February 2019 version). WLPZs are classified based on the uses of the stream and the presence of aquatic life. Wider WLPZs are required for steep slopes.

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

The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) within 300 feet of mechanical, manual, herbicide application, and prescribed pile burning treatment or staging areas on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916.5 of the California Forest Practice Rules (February 2019 version).

This revision would limit the amount of time spent by the project proponent identifying and delineating WLPZs, as well as limit the amount of high-visibility flagging used throughout the project area. This would help ensure that all WLPZs within a treatment area, or near a staging area, are recently flagged, without unnecessarily slowing down implementation to establish all WLPZs throughout the entire project area, while maintaining overall intent of SPR HYD-4 to prevent degradation of watercourses during implementation of manual, mechanical, and prescribed pile burning. Existing roads used for ingress or egress to project areas would not constitute a “treatment or staging area” for the purposes of this revision.

Potential impacts resulting from revisions to SPR HYD-4 are discussed below in Section 4.5, “Biological Resources”; Section 4.6, “Geology, Soils, Paleontology, and Mineral Resources”; Section 4.9, “Hazardous Materials”; and Section

4.10, “Hydrology and Water Quality.” As explained in these sections, the proposed revisions to SPR HYD-4 would not result in any new or substantially more severe significant impacts than were analyzed in the Program EIR. Impacts on other resources would not occur as a result of these revisions, because SPR HYD-4 is not required to reduce environmental effects to any other resources from implementation of the project. The proposed revisions to SPR HYD-4 are also shown in the MMRP (Attachment A).

1.4 EXISTING CONDITIONS
This section details existing conditions in the project area, including discussions of vegetation, WUI development and infrastructure, historical land use, and fire history. The maps below depict lifeform4 across the project area (Maps 1-4 and 1-5), a mapping unit classified by broad vegetation and land cover types. Lifeform is an appropriate classification to provide an overview of the extent and variety of environmental conditions in the project area, ranging from native wildland vegetation to developed WUI areas and cultivated lands. The following subsections describe the condition of primary vegetation types, distinct features and conditions of wildland and WUI environments, and the role of past wildfire in shaping these conditions.
4 Derived from the Santa Cruz and Santa Clara County Enhanced Lifeform Map created by Tukman Geospatial. More information is available at:
https://tukmangeospatial.egnyte.com/dl/5YsnZoXrk7.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-13 Source: Information from the Santa Cruz and Santa Clara County Enhanced Lifeform Map by Tuckman Geospatial, adapted by ARC in 2025.

Map 1-4. Lifeform in the Northern Extent of the Project Area

Introduction Ascent
Saratoga Protection Fire District
1-14 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Source: Information from the Santa Cruz and Santa Clara County Enhanced Lifeform Map by Tuckman Geospatial, adapted by ARC in 2025.

Map 1-5. Lifeform in the Southern Extent of the Project Area

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-15

1.4.1 Vegetation Types
Species composition, condition, fuel loading, and potential treatments for primary vegetation types are described below. Although additional vegetation types are present throughout the project area, this section details the most prominent vegetation types where treatments are expected to occur. Treatment specifics are outlined in further detail in Section 2.1, “Treatment Prescription,” and Section 2.2, “Treatment Types,” of this document.

REDWOOD–DOUGLAS-FIR FOREST
Redwood–Douglas-fir forest stands occur across the higher-elevation ridgetops and lower-elevation riparian draws across the project area, concentrated in wetter areas that receive high precipitation (Figure 1-1). The redwood forests in the southern section of the project area are some of the farthest south contiguous stands in the native range of redwood, as few areas south of the Santa Cruz Mountains in California possess climatic conditions suitable for the species. Regionally, these forests are typically characterized by groves of dominant second-growth redwood with areas of co-dominant or dominant Douglas-fir overstory. Understory species like tanoak (Notholithocarpus densiflorus) and California bay laurel (Umbellularia californica) are prevalent while California buckeye (Aesculus californica) and big-leaf maple (Acer macrophyllum) occur less commonly. Smaller-stature understory shrub species include hazelnut (Corylus cornuta), huckleberry (Vaccinium ovatum), toyon (Heteromeles arbutifolia), and coffeeberry (Frangula californica).

Source: Photograph taken by Heath Hooper of ARC in 2025.

Figure 1-1. A Dense Stand of Second-Growth Redwood Forest near Mount Madonna and SR 152, Unincorporated Santa Clara County (Summer 2025)

Introduction Ascent
Saratoga Protection Fire District
1-16 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Forest density within the project area ranges from approximately 200 to 400 trees per acre (TPA) in redwood– Douglas-fir forest types, which is approximately twice as dense compared to stands with natural background fire return intervals. This greater density is most pronounced in small (1 to 12 inches dbh) and midrange (12 to 24 inches dbh) trees. A healthier, less dense forest stand would have approximately 100 to 200 TPA in redwood–Douglas-fir forests. Although high-density stands are naturally occurring in some systems, they rarely occur at the scale and extent of many contemporary forests.

Dense conditions not only contribute to high fuel-loading but also spread forest pathogens, like sudden oak death (SOD), among various hardwoods, and Douglas-fir root rot (Coniferiporia weirii), red ring rot (Porodaedalea pini), and pitch canker (Fusarium circinatum) in Douglas-fir trees. These dense stands are considered impaired forest conditions that require restorative treatments, which predominantly focus on removal of smaller trees to reduce density and competition for resources between individual trees. The management and treatment objectives of redwood–Douglasfir forests would focus on increasing healthy growth of larger trees, increasing sunlight penetration to the forest floor to increase native plant diversity, and reducing ladder fuels and the associated wildfire hazard, ultimately promoting increased resilience to wildfire.

HARDWOOD FOREST
Hardwood forests across the project area are primarily composed of California bay laurel, coast live oak (Quercus agrifolia), canyon live oak (Quercus chrysolepis), California black oak (Quercus kelloggii), Shreve oak (Quercus parvula var. shrevei), interior live oak (Quercus wislizeni), California sycamore (Platanus racemosa), big-leaf maple, and Pacific madrone (Arbutus menziesii) (Figure 1-2). These forests occur across a range of environments, from flat valley floors and steep canyon walls to riparian corridors and sun-exposed ridgetops with drier soils. The overstory is dominated by mature hardwoods intermixed with dominant or co-dominant Douglas-fir, some of which have grown through hardwood canopies and are in various phases of vegetation type transition toward Douglas-fir-dominated overstories. Understories are composed of hardwood regeneration and a mix of native shrubs, including toyon, coffeeberry, and poison oak (Toxicodendron diversilobum). Forest density of hardwood stands is variable, but mature trees are typically spaced 20–40 feet apart, with a more open canopy structure allowing for a diverse understory.

Smaller diameter oaks and madrones (i.e., less than 8 inches dbh) are frequent in the mid- and lower-canopy ranges, connecting horizontal continuities of vegetation. Particularly in the southern extent of the project area and lower elevation foothills throughout, oak-dominated savannas are widespread across typically flatter topography and valley floors. In these environments, grassland is the dominant and, in some cases only, understory component. In these oak savannas, tree spacing is variable but often far greater than 20–40 feet.

Hardwood forests across the project area are affected by the compounding effects of forest pathogens, like SOD, and encroachment of Douglas-fir due to fire exclusion. With competition from co-dominant Douglas-fir trees, oaks and other hardwoods are more prone to various pathogens, like SOD and Pacific Madrone root rot. Hardwood mortality from competition with Douglas-fir trees and the spread of forest pathogens leads to higher amounts of dead and down woody debris in the understory, creating higher fuel connectivity. Forest density in hardwood stands in the project area can be up to 500 TPA in small (1 to 12 inches dbh) trees, primarily where Douglas-fir encroachment occurs. A healthy, resilient hardwood forest would exhibit characteristics of variable forest structure and residual densities ranging from 50–100 TPA; a diverse mosaic of native understory species, including native forbs, grasses, and shrubs, such as toyon and coffeeberry; and a diverse range of wildlife habitat features and refugia, such as tree cavities, snags, mature trees, and riparian corridors. Strategic treatment in hardwood forests would break up fuel continuity in the forest floor, create openings needed for native flora, and remove encroaching Douglas-fir trees to restore hardwood habitat conditions. Prescribed burn treatments (i.e., pile burning and broadcast burning) can be used as follow-up treatments to manual and mechanical treatments in hardwood-dominated forests to promote forest health and native flora, improve resilience, mitigate pest and pathogen outbreaks, and reduce biomass and fuels.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-17 Source: Photograph taken by Heath Hooper of ARC in 2025.

Figure 1-2. Oak Woodland Exhibiting Hazardous Fuel Loading in a Wildland-Urban Interface Area in Blossom Hill, Los Gatos (Spring 2025)

MIXED CHAPARRAL AND COASTAL SCRUB
Across the project area, mixed chaparral and coastal scrub occur primarily on south-facing slopes, higher elevation ridgelines, and disturbed areas (Figure 1-3). Chaparral communities in the project area are typically dominated by manzanita (Arctostaphylos spp.), chamise (Adenostoma fasciculatum), or Ceanothus spp. with components of other shrub species, such as scrub oak (Quercus berberidifolia), toyon, coffeeberry, birchleaf mountain mahogany (Cercocarpus montanus), silk-tassel (Garrya elliptica), and poison oak. In the southern section of the project area, knobcone and gray pine populations are widely intermixed with chaparral. The prominent shrub species that constitute coastal scrub communities in the project area are California sagebrush (Artemisia californica), Salvia spp., and coyote brush (Baccharis pilularis). Across northern California shrublands, and particularly in chaparral communities, the exclusion of fire has disrupted natural fire return intervals in these fire-adapted landscapes, resulting in thick duff layers, accumulations of dead and dying shrubs, and in some cases, conifer encroachment into chaparral. These dynamics often result in dense, impenetrable thickets with a high degree of vertical and horizontal fuel continuity that hinders wildlife movement and facilitates fire movement. Further, these shifts in shrubland structure can contribute to lower biodiversity of wildlife among homogenous shrubland stands. To counteract these dynamics, indigenous tribes in California used periodic fire in chaparral, creating mosaic habitats with structural diversity and an array of species to enhance forage and resource availability (Anderson and Keeley 2018).

Strategic management in mixed chaparral and shrubland habitats would involve reestablishing disturbance regimes to enhance wildlife habitat and reduce wildfire risk. Treatments would generally involve removing select shrubs to create a mosaic structure with retained vegetation. In areas where conifer or hardwood is encroaching into shrubland, encroaching populations would be selectively removed or eradicated to preserve species composition of native shrubs. In some cases, more intensive treatments would occur along roadsides or ridgelines that would act as fuel breaks in the event of wildfire. Away from fuel break locations, special considerations would be given to retain chapparal species, which are obligate seeders (i.e., species that rely on seedbanks for regeneration and do not

Introduction Ascent
Saratoga Protection Fire District
1-18 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR resprout from root crowns or lignotubers). Additionally, prescribed fire would be considered to promote the restoration of these fire-adapted habitats. Treatment would be timed to prevent the intrusion of invasive plant species in treated areas, and best practices would be implemented to avoid introduction of invasive plant seeds into treated areas.

The proposed project area encompasses chaparral and coastal sage scrub vegetation that meets the definition of the vegetation types subject to the restrictions of the writ. Within these chaparral and coastal sage scrub vegetation types, and pursuant to SPR CHAP/CSS-1, which was developed to be consistent with the writ, only certain ecological restoration, wildland urban interface fuel reduction, and fuel break maintenance treatments will be conducted. These proposed treatments are explained in Section 2.2, “Treatment Types.” A detailed discussion of chaparral and coastal sage scrub is included in Section 4.5 Biological Resources, Impact BIO-3.

Source: Photograph taken by Heath Hooper of ARC in 2025.

Figure 1-3. Chamise Chaparral on Trappers Fire Road in Foothills Park, Palo Alto (Spring 2025)

GRASSLAND
“California annual and perennial grasslands” is a broadly applied term for the forb- and grass-dominated meadows and grasslands across the state. This vegetation type occurs throughout the project area on ridgetops and primarily south-facing slopes in the northern project extent and becoming more widespread in the south, where it dominates valley floors (Figure 1-4). It is the most abundant vegetation type across the lower elevations of the Santa Clara Valley, often occurring in the understory of oak savanna. A relatively large subset of grasslands across the project area grows in serpentine soils, a rare parent material high in heavy metals and low in nutrients. These unique soil characteristics lead to high biodiversity and prevalence of endemic species in serpentine grasslands, considered a sensitive habitat by California Department of Fish and Wildlife (CDFW) (Santa Clara County Department of Parks and Recreation 2025).

Most of the grasslands in the region are associated with historical and ongoing grazing, which has contributed to a high abundance of nonnative herbaceous species introduced by livestock. Despite the high component of nonnative species, California annual and perennial grasslands typically have high native species richness (NatureServe 2025).

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-19 Indigenous inhabitants of the region valued grasslands, historically using fire to maintain them and prevent encroachment of shrubs and woodland species. Northern California grasslands are currently declining with the encroachment of trees and shrubs due to the exclusion of fire.

California annual and perennial grasslands are a low-statured, “fine” fuel type, meaning that they grow, senesce, and lose fuel moisture quickly. Given their rapid life cycle and low bulk density, grasslands are typically a lower priority in terms of vegetation management and hazardous fuel loading. However, these characteristics pose serious risks under hazardous wildfire conditions. As a fine fuel, grasslands are generally more susceptible to combustion, particularly in proximity to potential ignition vectors in the WUI. Once ignited, high winds can drive fire quickly across grasslands and into more hazardous fuel types, like shrublands and woodlands. In the scope of this project, strategic management of grasslands would primarily focus on prescribed burning and herbivory to reduce fuel loads. In some cases, mechanical treatments, such as mowing, would be applied, particularly along fuel breaks and on the margins of WUI areas to decrease potential fire spread to structures and critical infrastructure. When strategically managed, prescribed burning and herbivory also help limit the abundance and spread of invasive grasses and herbs.

Source: Photograph taken by Heath Hooper of ARC in 2025.

Figure 1-4. Grassland Hillside in Calero County Park, South San Jose (Summer 2025)

1.4.2 Project Area Conditions
The 143,375-acre project area and surrounding region encompasses an array of landscapes, from features of the built environment to native Californian vegetation types, that often intermix. This section details the differences in vegetative and landscape conditions between wildland environments and the developed WUI and residential areas (WUI-residential). These conditions are primarily driven by the dynamics between natural and anthropogenic processes, such as human land use and development patterns, in the WUI and historical fire suppression.

Several similar vegetation treatment projects have already been implemented within and adjacent to the project area.

These treatments at Sanborn and Upper Stevens Creek County Parks, which were implemented by Santa Clara County Parks under their 2022 Sanborn and Upper Stevens Creek Forest Health Plan and associated CalVTP PSA, and

Introduction Ascent
Saratoga Protection Fire District
1-20 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR the 2019 Mount Madonna Forest Health Plan at Mount Madonna County Park. Other treatments include the Nestldown Ranch Vegetation Treatment Project (2024), the Aldercroft FireWise and Lupine Lodge Project (2024) on the southeastern shore of Lexington Reservoir and along Los Gatos Creek, the Moody Gulch/Summit Road Vegetation Treatment Project (2024) in the Santa Cruz Mountains, and the Burn Operation at Calero County Park, which took place in 2024 and 2025. In addition, activities such as discing and mowing at Pearson Arastradero Preserve have been implemented as part of the Foothill Fires Management Plan. Collectively, these efforts contribute to the baseline condition of the landscape, as portions of the project area have already undergone vegetation treatments. Additional approved or pending vegetation management treatments may also exist within or adjacent to the project area.

WILDLAND CONDITIONS
Wildland environments are present throughout the project area, with isolated parcels intermixed between residential development and large contiguous swaths of private and publicly owned forest and rangeland that collectively span thousands of acres with limited human infrastructure. Vegetation composition across the lower elevations of the project area is dominated by grassland; oak woodland and savanna; pockets of scrub dominated by species, such as California sagebrush and coyote brush; and occasional southern aspect slopes of chaparral dominated by species such as chamise and buck brush (Ceanothus cuneatus). In the middle-elevation foothills, these vegetation communities are also widespread and intermixed with dense hardwood forests of California bay laurel and coast live oak. Hardwood forests primarily occupy ravines, riparian corridors, and northern aspect slopes, while these environments in the southern portion of the project area also contain a significant component of California sycamore.

Chaparral is widespread on southern-aspect, middle-elevation slopes and higher-elevation ridgelines throughout the project area. The rural, mountainous sections of the project area are characterized by large expanses of contiguous wildland vegetation, often distributed in mosaic patterns of various forest, scrub, and occasional ridgetop grassland patches. Dense forests of redwood and Douglas-fir are the dominant vegetation type along the crest of the Santa Cruz Mountains, also appearing in lower elevation draws and northern-aspect slopes throughout the project extent.

Less common across the Santa Cruz Mountains are native stands or intermixed populations of knobcone pine (Pinus attenuata) and gray pine (Pinus sabinana) and disparate, often-nonnative plantations of pine or other conifer species.

Nonnative species that are widespread throughout the project area and pose a heightened wildfire risk include various subspecies of Eucalyptus spp., broom (Genista spp.), and Acacia spp.

Native vegetation communities of the greater Santa Cruz Mountains region were once adapted to frequent fire from indigenous burning, which contributed to a more open vegetative structure of forests, shrublands, and grasslands (Mensing 2006). Expansive clearcut logging and agriculture in the late-1800s to mid-1900s was followed by the subsequent era of fire suppression and contributed to an array of landscape impacts. Since then, second-growth redwood forests have become established, growing in with higher-stand density than their old-growth counterparts.

Climatic changes, such as drought and increasing yearly average temperatures, have heightened ecological stressors and influenced the spread of forest pathogens, like Phytophthora ramorum, or SOD. SOD-infected trees fall and contribute to high fuel loading in the understory of mixed-conifer and hardwood forests (Figure 1-5 below).

Additionally, hardwood, grassland, and shrubland ecosystems have changed from altered disturbance regimes over the last 100–200 years. Conifers have encroached into woodlands, grasslands, and shrublands, restricting native plant species and impairing wildlife habitat (Livingston et al. 2016; Midpeninsula Regional Open Space District 2025).

Ecosystems are shifting in vegetation type and experiencing a decline in biodiversity due to changes in disturbance regimes over time. Consequently, landscapes have become increasingly prone to forest pathogens, have become vulnerable to spread of invasive species, and have increased in fuel loading. In the same period, residential and commercial development has increasingly expanded into the WUI, and thus, the region is at heightened risk of a destructive high severity wildfire event. Although existing vegetation management initiatives unrelated to this project have occurred on lands in the project area to address various goals, the majority of landscapes in the project area currently possess the characteristics of impaired forest conditions and are thus suitable for treatment in the near term.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-21 Source: Photograph taken by Chloe Knowd of ARC in 2025.

Figure 1-5. Madrone and Oak Mortality from SOD. Douglas-Fir Is Overtaking Declining Hardwoods.

These coinciding conditions create uniquely challenging landscapes in terms of fuel conditions and wildfire hazard, while contributing to degradation of habitat quality and ecological resilience. Figures 1-6 and 1-7 depict encroachment promoted by the lack of fire or similar disturbance, increased fuel loading within the project area, and how these dynamics interact with the expanding wildland-urban interface.

Sources: UCSB 1939 (left); County of Santa Clara, Vantor 2025 (right).

Figure 1-6. Forest Expansion into Grasslands (Outlined in Yellow) above Murphys Canyon West of Gilroy from 1939 (Left) to 2022 (Right)

Introduction Ascent
Saratoga Protection Fire District
1-22 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Sources: UCSB 1939 (left); County of Santa Clara, Vantor 2025 (right).

Figure 1-7. Oak Woodland (Outlined in Yellow) and Residential Development Expansion between Llagas Road and El Toro, Morgan Hill from 1939 (Left) to 2022 (Right)

WUI-RESIDENTIAL CONDITIONS
The project area and immediate surroundings are home to over 700,000 people5 and contain critical infrastructure and resources (e.g., water resources) that serve millions of people. The majority of human development within or bordering the project is concentrated along the lower elevation eastern boundary of the project area that runs through the densely populated San Jose metropolitan area and into the Santa Clara Valley. WUI-residential landscapes along the eastern boundary of the project area range from low-density residential communities across rolling hills of oak woodland and savanna or in dense woodlands to higher-density development on flat terrain that abuts large contiguous areas of wildland vegetation. These conditions are nearly continuous across the eastern boundary of the project area, from Palo Alto in the north to Gilroy in the south.

The eastern boundary of the project area borders the region known as Silicon Valley, named for the concentration of technology, research, and educational facilities operating in the area. Several of such facilities directly border the project area, including the IBM laboratories south of San Jose and the offices of major companies, such as SAP and Tesla, which border the project area to the north adjacent to Stanford University. The Pacific Gas & Electric (PG&E) Metcalf Transmission Substation north of Morgan Hill is just outside the southeast border of the project area and provides power to the greater region through a network of transmission and distribution lines that traverse the project area. Additionally, the project area is bisected and bordered by several highly trafficked freeways, highways, and other major thoroughfares.

Apart from power distribution and major roadways, the rural mountainous sections of the project area contain additional critical infrastructure and dispersed residential communities. Several of the high elevation peaks within or adjacent to the project area host towers and other infrastructure relied upon to transmit cellular, broadband, broadcast, public safety, and other communications for the region. Many of the streams and tributaries that run through the eastern Santa Cruz Mountains feed into several reservoirs containing infrastructure for water intake, storage, and transfer that are managed and operated by Santa Clara Valley Water District and San Jose Water Company. Interior mountainous WUI-residential communities include concentrations of structures surrounded by dense wildland vegetation on ridgetops, on midslope flats, and at the base of ravines. Examples of these conditions in the project area include the Skyline Boulevard (SR 35) and Summit Road corridor, the region surrounding SR 17 and Lexington Reservoir, and in the rural southwestern extent of the project area in the vicinity of Loma Prieta Mountain, Sveadal, and Mount Madonna.
5 2020 Census population data, from: https://www.nhgis.org/.

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-23 Figures 1-8 and 1-9 depict how land use has shifted in WUI-residential environments, particularly throughout the eastern boundary of the project area.

Sources: UCSB 1948 (left); County of Santa Clara, Vantor 2025 (right).

Figure 1-8. Canopy Cover and Residential Development Expansion Surrounding the Intersection of Saratoga-Los Gatos Road and Quito Road (in Yellow) from 1948 (Left) to 2022 (Right) Sources: UCSB 1939 (left); County of Santa Clara, Vantor 2025 (right).

Figure 1-9. Vegetation and Residential Development Expansion Surrounding Blossom Hill and Shannon Roads (in Yellow), East Los Gatos from 1939 (Left) to 2022 (Right) Comparing the historical imagery on the left to the current conditions on the right illustrate how areas that were formerly undeveloped or used for agricultural purposes have widely transitioned to densely populated residential communities throughout the Santa Clara Valley and foothills of the Santa Cruz Mountains. Given the density of structures and human inhabitance, natural fire regimes have been interrupted in these environments, leading to increased fuel loads. Figure 1-8 of the region surrounding the intersection of Saratoga-Los Gatos Road (SR 9) and Quito Road depicts how residential development replaced agricultural lands and crept up into the foothills of the Santa Cruz Mountains. In the historical imagery, the darkest shades outline where oak and other hardwood

Introduction Ascent
Saratoga Protection Fire District
1-24 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR woodlands existed, primarily in riparian corridors and highly sloped hillsides, while flatter areas of lighter shades in the image were primarily grassland or cultivated lands. Compared with the current image on the right, there is an observable expansion of woodlands in terms of footprint and in canopy closure between neighboring trees, while the historically grassland and agricultural lands have predominantly been filled in with dense residential development and vegetation.

Conditions such as these, where residential communities are located on or directly adjacent to steep slopes intertwined with contiguous pathways of wildland vegetation, pose hazardous and potentially destructive wildfire conditions. The project area encompasses sections of WUI-residential environments where wildfire hazard poses a heightened risk to structures due to factors such as continuity of vegetation, proximity to fire-prone wildland areas, proximity to ignition vectors, and slope to allow mobility for wildfire protection practitioners and communities to identify potential avenues for wildfire flow into the WUI and take appropriate mitigative action.

Given the highly variable and intermixed nature of the WUI through much of the project area, these environments possess unique characteristics in terms of vegetation conditions and potential treatment options. In WUI-residential environments across the project area, treatments would focus on defensible space clearance, particularly within 1 to 5 feet of structures, and reduction of canopy connectivity through the pruning of tree limbs and strategic removal of trees and shrubs up to 100 feet from structures. For the complete list of treatment activities applicable to WUI communities, see the “Defensible Space Treatments” subsection of Section 2.1.1, “General Prescription,” and Section

2.2.2, “Wildland-Urban Interface Fuel Reduction,” of this document.

FIRE HISTORY
Wildfire prevalence, size, and severity in California and fire-prone environments globally have increased exponentially in recent decades. In California state history, 19 of the 20 largest wildfires in terms of area have occurred since 2000, and 13 of these occurred in the past decade (CAL FIRE 2024). Of the 20 most destructive wildfires in state history by number of structures affected, 18 took place since 2000, with 15 occurring in the past decade (CAL FIRE 2025a). The counties surrounding the project area have experienced two of these largest and most destructive fires in state history, both occurring in fall of 2020 when 95th-percentile fire weather conditions coincided with a concentration of lightning-caused ignitions to fuel the CZU Lightning Complex in Santa Cruz and San Mateo Counties and the SCU Lightning Complex in eastern Santa Clara County (Map 1-6). These simultaneous megafire events burned a cumulative 483,134 acres and affected 1,715 structures, and their proximity to population centers in the Bay Area brought about an increased concern for wildfire in the public consciousness.

Taking a closer look at fire history in the region surrounding the project area, several key takeaways can be identified.

There is a concentration of past fires that occurred within and adjacent to the project area in the vicinity of Loma Prieta Mountain between the rural mountain communities of Lexington Hills and Sveadal (Map 1-6). Of these six overlapping events, two occurred over 40 years ago (the 1985 Lexington Fire and 1961 Austrian Gulch Fire), while four occurred since 2000 (the 2002 Croy Fire, 2008 Summit Fire, and Loma Fires of 2009 and 2016), mirroring the statewide increase in fires this century. Outside of these fires and the 2020 megafires, fire history in the area is notably sparse, occurring at frequencies well below the natural fire regimes of regional vegetation communities, especially when compared to other regions of the state that are both fire-prone and population-dense. However, the lack of fire history in the region does not indicate that it is not prone to future fire events; in other regions, including the burn footprints of both 2020 Lightning Complex fires, historical fire suppression has been shown to predispose vegetation across the landscape to high fuel loading and connectivity, as well as increase continuity into WUI environments. These conditions—connectivity between the WUI and dense wildland vegetation in fire suppressed landscapes along with climatic shifts increasing the intensity and duration of hazardous fire weather each year—have been observed in fueling several of the recent major fire events throughout the state (e.g., 2025 Palisades, Eaton, and Hughes Fires; 2021 Dixie Fire; and 2018 Camp Fire, to name a few) (CAL FIRE 2025b).

Ascent Introduction
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 1-25 Source: Information from CAL FIRE, adapted by ARC in 2025.

Map 1-6. Fire History of the Vicinity of the Project Area, Highlighting the Proximity of the 2020 CZU and SCU Lightning Complexes

Introduction Ascent
Saratoga Protection Fire District
1-26 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Additionally, the 2020 fires challenged preconceived notions regarding vegetation community susceptibility to highseverity wildfire. The CZU Lightning Complex in particular possessed fire behavior and severity unprecedented in the second-growth redwood-Douglas-fir forests of the Santa Cruz Mountains, while the SCU Lightning Complex traveled rapidly across grassland and oak savanna environments similar to those present within the project area. These coinciding dynamics playing out across ecosystems and landscapes in California heighten the urgency of vegetation management treatments for wildfire and ecological resilience.

1.5 PROJECT OBJECTIVES
The effects of fire suppression and climate change have altered and continue to impact the landscape of California.

This combination of stressors has resulted in sensitive habitats that have both declined substantially in their habitat quality and increased their vulnerability to severe wildfire (Ayars et al. 2023; Stephens et al. 2022). Of particular concern are the increasing loss of grasslands, spread of invasive and highly flammable species, overcrowding in conifer and hardwood forests and subsequent understory mortality, and vulnerability of native oak woodland stands to pathogens, including SOD. These impactful conditions have been exacerbated by additional stressors, such as drought and increasing yearly average temperatures. The majority of these dead trees have now fallen to the forest floor and become entangled with overly abundant understory growth, creating hazardous conditions that increase the likelihood of high severity wildfire. Within the project area these dynamics play out in landscapes containing or bordering dense WUI development, highly trafficked road and highway systems, and other critical infrastructure.

Simultaneously, development continues to expand deeper into fire-prone landscapes, creating more potential ignition vectors and increasing that likelihood that fire events have destructive and costly outcomes. To address hazardous and ecologically detrimental landscape conditions while minimizing the threat of destructive future fire events, environmentally sensitive landscape-level treatments are required to redirect the path of both changing climates and ecological conditions impacting the area.

Project objectives to address the coinciding hazardous conditions present in the region in terms of vegetation shifts, fuel loading, climatic changes, and proximity to urban development are to:

1. enhance landscape-level wildfire resiliency, protect critical infrastructure, and provide avenues for WUI communities to take home-hardening measures;

2. increase the ability to safely manage or suppress wildfire and restore use of prescribed fire;

3. improve habitat for rare, threatened, and endangered plant and wildlife species where they are present;

4. promote a mosaic of native vegetation types to support diverse floral, faunal, and fungal assemblages that are resilient to climate change; and

5. reduce impacts on natural and cultural resources.

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-1 2 PROJECT DESCRIPTION

2.1 TREATMENT PRESCRIPTION
This section outlines the restorative, resilience-focused vegetation treatment prescription that would be implemented to achieve vegetation management principles and goals within the WSCLRP area as initial and maintenance treatments. The treatment prescriptions are organized in three sections: a description of the general prescription; prescriptions specific to the three CalVTP Program EIR treatment types; and descriptions of the treatment activities, including operational specifications, applicable to this project.

2.1.1 General Prescription
For all projects developed under the CalVTP Program EIR, proposed vegetation management actions must be categorized under one of three treatment types: ecological restoration, WUI fuels reduction, or fuel break. In addition to these treatment types, treatment may be characterized by specific treatment goals; defensible space treatments may be proposed in either WUI fuel reduction or fuel break areas, and post-fire treatments may be proposed in any area that previously experienced wildfire, regardless of the mapped treatment type. The WSCLRP would employ all three treatment types (ecological restoration, WUI fuel reduction, fuel break) in different areas across the approximately 143,375-acre project area.

Because the three treatment types share a set of baseline prescription specifications, the general prescription outlined below describes the common elements that would be applied across the entire project pre- or post-fire, with the understanding that additional or modified prescriptions would apply based on site-specific objectives and requirements:
 Selectively remove trees less than or equal to 16 inches dbh6 to increase crown spacing, reduce competition for available resources, and reduce horizontal and vertical fuel continuity:
 retain select healthy, live trees less than or equal to 16 inches in diameter to achieve crown and bole spacing with less vertical and horizontal fuel continuity, promote the growth of residual trees, and promote habitat restoration:
• retain healthy native hardwoods and conifers with appropriate canopy spacing, except where Douglas-fir trees and saplings are converting grassland, shrubland, or hardwood forest habitat types through shading; in which case, Douglas-fir up to 36 inches in diameter (i.e., seed trees, or trees that are outcompeting or otherwise supporting encroachment upon the existing vegetation type) would be removed to restore ecosystem conditions;
 remove any dead, dying, and diseased trees and hazard trees of any size:
 where such trees do not present a safety hazard, retain existing standing habitat trees, consisting of standing dead, snags, or live trees with dead portions of stems or branches, that provide nesting and foraging habitat for birds and other wildlife;
 prune lower branches of trees 6–15 feet above the ground but not more than 33 percent of the trees crown where feasible;
 retain micro-stands of immature oak trees (i.e., young oak stands that do not have an established, dominant overstory) with a cluster radius of approximately 15–25 feet (30–50 feet in diameter) and spaced approximately 75–100 feet apart, where feasible, with consideration given to steepness or whether this retention could exacerbate fire behavior, or fire behavior proximal to key infrastructure and assets; 6 Diameter limits for removal may be subject to local ordinances.

Project Description Ascent
Saratoga Protection Fire District
2-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR  retain 10–25 percent relative cover per acre, depending on the potential for exacerbated fire behavior, proximity to key infrastructure and assets, and the need to maintain micro-stands of understory vegetation that reflect the characteristic cover and composition of any sensitive natural communities, as described in A Manual of California Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data). Vegetation retention should emphasize clumps or patches distributed across the treatment area to form a mosaic that supports habitat heterogeneity and quality (Strong et al. 2016). Root systems should be left intact to allow for resprouting, with horizontal crown separation of approximately 25 to 75 feet between clusters, depending on site-specific conditions and vegetation alliance characteristics; for chaparral communities, retain vegetation at a minimum of approximately 35 percent and a target of 50 percent within the immediate contiguous stand boundary of the vegetation type within a treatment polygon. Vegetation retention should create a mosaic pattern of patches or shrub islands to maintain a varied level of habitat continuity and structural diversity throughout the polygon, and should be consistent with retention standards outlined by the treatment type, CalVTP SPRs, and applicable MMs. Additional considerations are required for sensitive natural communities:
 remove populations of nonnative vegetation:
 apply herbicide to areas of removal to control reestablishment of nonnative species;  process non-retained biomass for disposal (e.g., masticate, chip, lop and scatter, prescribed burning, prescribed herbivory, etc.); and
 when revegetating post-fire landscapes:
 consider native forest conditions and desired future forest structure when determining planting spacing and species composition; and
 install erosion control measures consisting of but not limited to mulching and straw application, hillside seeding with soil-stabilizing species, and erosion barriers such as silt fences.

DEFENSIBLE SPACE TREATMENTS
Wildfire protection measures taken on an individual structure basis are typically described in terms of defensible space, the strategic actions taken within the area immediately surrounding structures to prevent fire spread to structures in wildfire-prone areas. To safeguard important infrastructure and allow for expanded hazard mitigation activities in residential areas, defensible space treatments are included under this general prescription.

The project area encompasses 47,076 individual structures (County of Santa Clara 2025b). Given the highly intermixed nature of the natural and built environments throughout the project area, defensible space treatments are applicable across the entire project area, in all mapped treatment types where structures occur. However, these treatments would be primarily applied in areas mapped as WUI fuel reduction treatment type where structure densities are highest.

Maintenance of a defensible space around homes and structures (fire-resistant maintenance of vegetation within 100 feet of structures) is required by PRC Section 4291.
7 PRC Section 4291 and CAL FIRE’s guidelines contain guidance for implementing defensible space in the SRA; at the time this PSA/Addendum was developed, the County of Santa Clara deferred to PRC Section 4291 as the minimum defensible space standard for Local Responsibility Areas (LRA) and does not define more restrictive standards. PRC Section 21080.498 was enacted in July 2025, providing a potential statutory exemption to CEQA for defensible space clearance under certain conditions. Despite being potentially CEQA-exempt by statute, it is foreseeable that defensible space treatments would be conducted under this PSA/Addendum (e.g., large scale, publicly funded grant in a residential area involving defensible space treatments).

For guidance on potential defensible space vegetation management treatments, see CAL FIRE’s guidelines9 adopted from the language of PRC Section 4291 or the statutory exemption under PRC Section 21080.49. 7 PRC 4291, from: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=4291.&lawCode=PRC. 8 CA SB 131, Section 11; https://legiscan.com/CA/text/SB131/id/3259518. 9 CAL FIRE defensible space resources; http://fire.ca.gov/dspace, https://readyforwildfire.org/prepare-for-wildfire/defensible-space/.

Ascent Project Description
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-3

POST-FIRE TREATMENTS
For lands within the project area affected by wildfire, treatments would align with the general prescription specifications with additional consideration of erosion control and soil stability, vegetation recovery monitoring, invasive species management, natural regeneration, and, in some cases, regeneration through replanting to reestablish desired vegetation composition. Post-fire restoration would be established and maintained using varying combinations of prescribed burning, manual, mechanical, targeted herbicide, and prescribed herbivory treatments, and restoration approaches would be shaped with consideration of existing conditions such as vegetation type and burn severity. Post-fire treatments are included under the “General Prescription” section because they would be conducted anywhere in the project area where a fire has occurred.

2.2 TREATMENT TYPES
This section outlines the prescription specifications that are unique to each treatment type and would be implemented in conjunction with the general treatment prescription above. Table 2-1 below outlines the treatment types that would be implemented under this proposed project and is followed by Map 2-1 and Map 2-2, which delineate the boundaries of each treatment type.

Table 2-1: Applicable Treatment Types
Treatment Type Applicable Treatment Activities Maximum Treatment Size (Acres) Ecological restoration Manual, mechanical, prescribed burning, targeted herbicide application, and prescribed herbivory. 74,738
WUI fuel reduction Manual, mechanical, prescribed burning, targeted herbicide application, and prescribed herbivory. 56,818
Fuel break Manual, mechanical, prescribed burning, targeted herbicide application, and prescribed herbivory. 11,819
Source: Compiled by Ascent in 2025.

2.2.1 Ecological Restoration
The goal of the ecological restoration treatment type is to restore ecosystem processes and reestablish resilience of the ecosystem and natural disturbance regimes to the landscape, relative to modern anthropogenic and climatic influences.

Ecological restoration treatments would follow the general treatment prescription above while adhering to the following specifications, more specific to attaining the goals of this treatment type:
 Retain healthy trees less than 16 inches in diameter with the goal of achieving a 10- to 20-foot residual spacing:
 stands made up of only trees less than 16 inches in diameter would be thinned to a spacing of approximately 10–20 feet apart to disconnect horizontal and vertical fuel continuity while maintaining vegetation communities.  Where snags do not present a safety hazard, retain approximately four to six foraging snags (less than 12 inches in diameter) and one or two cavity nesting snags (greater than 12 inches in diameter) per acre.  Retain downed woody debris in strategic locations to maintain forest floor complexity, with a preference for larger, complex logs, generally greater than 12 inches in diameter and totaling approximately 10 tons per acre, while reducing fuel continuity:
 the target retention for downed woody debris would be retention of four larger logs (large end greater than 16 inches in diameter, approximately 15 feet long).

Project Description Ascent
Saratoga Protection Fire District
2-4 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Source: Information developed by ARC in collaboration with SCC FSC, SFD, and project partners in 2025.

Map 2-1. Treatment Types in the Northern Extent of the Project Area

Ascent Project Description
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-5 Source: Information developed by ARC in collaboration with SCC FSC, SFD, and project partners in 2025.

Map 2-2. Treatment Types in the Southern Extent of the Project Area

Project Description Ascent
Saratoga Protection Fire District
2-6 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR  Consistent with the writ and as reflected in SPR CHAP/CSS-1, ecological restoration treatment within chaparral and coastal sage scrub vegetation types (Attachment B Figures B-1 through B-38) will consist of removal of flammable, nonnative vegetation. However, in stands of chaparral or coastal sage scrub that have a state rarity ranking of S4 or S5 and have generated following a fire within the last 15 years in an area that was previously characterized as woodland, ecological restoration treatments would be implemented as described in the general ecological restoration treatment prescription (see bullets above).

Ecological restoration treatments would be established and maintained using varying combinations of prescribed burning, manual, mechanical, targeted herbicide, and prescribed herbivory treatments (Figure 2-1).

Source: Strong et al. 2016; adapted by ARC 2025.

Figure 2-1: Examples of Ecological Restoration Treatment type Outcomes. Pretreatment Conditions Are Represented in the Left Diagram and Posttreatment Conditions Are Represented in the Right Diagram

2.2.2 Wildland-Urban Interface Fuel Reduction
The WUI fuel reduction treatment type targets areas where the wildland and built environment intermix to prevent or slow the spread of nonwind-driven wildfire between structures and wildlands, and vice versa, to prioritize protection of structures and infrastructure.

WUI fuel reduction treatments constitute a middle ground between ecological restoration and fuel break treatments.

They employ ecologically restorative standards similar to those listed in the ecological restoration treatment type across large areas while implementing more intensive vegetation removal along the margins of critical infrastructure to prioritize their protection in the event of wildfire. Like fuel break prescriptions, WUI fuel reduction treatments would be designed to improve ingress and egress on evacuation routes, create emergency access points, and reinforce staging areas for wildfire suppression equipment and operations in proximity to infrastructure. WUI fuel reduction treatments also promote ecosystem resilience through the strategic retention of vegetation and trees that increase habitat value and removal of nonnative species that compete with native vegetation.

WUI fuels reduction treatments would adhere to the general prescription above and the following prescription parameters:
 Selectively remove trees less than or equal to 16 inches in diameter:
 retain healthy trees and vegetation less than 16 inches in diameter with the goal of achieving a 10- to 20-foot spacing; and
 prune tree canopies (above 6 feet) that make direct contact with infrastructure, neighboring tree canopies, or other flammable material.
 Remove or, in some cases, redistribute understory vegetation and downed woody debris to break up surface fuels and continuity to tree and shrub canopies:
 remove surface biomass (approximately 0–3 feet from on the forest floor) within 100 feet of structures and other infrastructure to ensure adequate defensible space; and

Ascent Project Description
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-7  when chipping material within 100 feet of structures, spread chips away from structures and the boles of retained vegetation to the extent feasible (see Section 2.3.2, “Mechanical Treatment,” below for detailed chipping specifications).
 Maintain the control of flammable, nonnative vegetation using manual treatment as a preferred activity.  Remove vegetation or downed woody debris of any size within approximately 20 feet of the edge of roadways that impedes ingress or egress in the event of an emergency.  Consistent with the writ and as reflected in SPR CHAP/CSS-1, WUI fuel reduction treatments within chaparral and coastal sage scrub habitat (Attachment B Figures B-1 through B-38) will be conducted only in chaparral and coastal sage scrub habitat that is located within 1,000 feet of the Interface layer mapped in the CAL FIRE WUI layer. Treatments will be implemented with a preference for hand thinning (manual treatments), and long-term maintenance of flammable, nonnative vegetation will be conducted. No WUI fuel reduction treatment will occur in chaparral outside the 1,000-foot buffer of the CAL FIRE WUI Interface layer.  In stands of chaparral or coastal sage scrub that have a state rarity ranking of S4 or S5 and have generated following a fire within the last 15 years in an area that was previously characterized as woodland, WUI fuel reduction treatments would be implemented as described in the general WUI fuel reduction treatment prescription (see the bullet points above).

WUI fuel reductions would be established and maintained using varying combinations of manual, mechanical, prescribed burning, targeted herbicide, and prescribed herbivory treatments.

2.2.3 Fuel Break
In strategic locations, fuel breaks create zones of vegetation removal, often in a linear layout, which reduce wildfire risk and support fire suppression efforts by providing emergency responders with a staging area or access to a remote landscape for fire control actions. They can also facilitate safe emergency egress during wildfires. Fuel breaks reduce the likelihood that a severe fire would occur within the treated area by minimizing ignition potential, reducing vegetative fuels, and managing regrowth. In all cases, flammable, nonnative invasive plants would be controlled in maintenance treatments of fuel breaks.

Consistent with the writ and as reflected in SPR CHAP/CSS-1, new fuel breaks within chaparral and coastal sage scrub habitat (Attachment B Figures B-1 through B-38) will not exceed 300 feet in width, and long-term maintenance of flammable nonnative vegetation will be included in treatment.

In stands of chaparral or coastal sage scrub that have a state rarity ranking of S4 or S5 and have generated following a fire within the last 15 years in an area that was previously characterized as woodland, fuel breaks would be implemented as described in the fuel break treatment prescriptions below.

NON-SHADED FUEL BREAKS
In areas designated as non-shaded fuel breaks, vegetation would be removed to the extent that canopy cover is eliminated or nearly eliminated to create new or maintain existing fuel breaks for the purposes of wildland fire control and prescribed burning management. For the purposes of this project, non-shaded fuel breaks would occur only in non-forested vegetation types. In fuel breaks and areas adjacent to existing paved and unpaved roads and trails, standing dead and dying, as well as live, vegetation would be cleared. The width of new and reestablished fuel break segments would vary depending on site-specific conditions but would not exceed 200 feet (i.e., for the purposes of the analysis in this PSA/Addendum, non-shaded fuel break has been mapped with a 100-foot buffer on either side of paved and unpaved roads, and ridgeline fuel breaks).

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2-8 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

SHADED FUEL BREAKS
Areas designated as shaded fuel breaks would have similar levels of vegetation removal with the goal of providing similar intended benefits as non-shaded fuel breaks. However, shaded fuel breaks differ in that select live vegetation that provide canopy cover would be retained to a level that provides shade and maintains the ecological benefits provided by the existing vegetation community while still reducing the potential spread of wildfire through the understory and into the canopy. Selective retention of overstory vegetation reduces light penetration to the soil surface, which can slow the regrowth of shrubs and sprouting hardwoods, benefit invasive plan management, and reduce erosion in posttreatment shaded fuel breaks. For the purposes of this PSA/Addendum, shaded fuel breaks would occur in forested vegetation types.

Shaded fuel breaks would be mapped to the same 100-foot buffer off the edge of roadways as non-shaded fuel breaks, and within that area, all dead and the majority of live vegetation would be removed while select, prominent individual trees or shrubs would be retained. Retention standards in shaded fuel breaks would depend on the size, density, and distribution of vegetation, as well as the dominant vegetation types, to result in a residual mosaic of retained vegetation spaced to the extent that horizontal and vertical fuel continuity is thinned while leaving the original vegetation community intact. This treatment is targeted for areas in which fuel breaks are planned in ecologically sensitive vegetation types, such as sensitive natural communities, to limit impacts on existing vegetation composition. Strategic shaded fuel breaks would be established where the residual forest conditions support the establishment of control lines for prescribed burning or to improve ingress and egress for evacuation and emergency vehicle access.

Shaded and non-shaded fuel break objectives would be met through the following prescription bounds in addition to the general prescription:
 Selectively remove of trees less than or equal to 16 inches in diameter:
 retain healthy trees and vegetation less than 16 inches in diameter with the goal of achieving a 10–20 foot spacing; and
 prune tree canopies (above 6 feet) that make direct contact with infrastructure, neighboring tree canopies, or other flammable material.
 Prune lower branches of trees 12–15 feet above the ground where directly adjacent to roads or other infrastructure, but not more than 33 percent of the trees crown where feasible.  Remove understory vegetation and downed woody debris to break up surface fuels and continuity to tree and shrub canopies:
 remove surface biomass (approximately 0–3 feet from on the forest floor) within 100 feet of roads or other infrastructure to ensure adequate access and break in fuel continuity; and  when chipping material within 100 feet of roads or infrastructure, spread chips away from structures and the boles of retained vegetation to the extent feasible (see Section 2.3.2, “Mechanical Treatment,” below for detailed chipping specifications).
 Remove vegetation or downed woody debris of any size within approximately 20 feet of the edge of roadways that impedes ingress or egress in the event of an emergency.

Fuel breaks would be established and maintained using varying combinations of prescribed burning, manual, mechanical, targeted herbicide, and prescribed herbivory treatments.

2.3 TREATMENT ACTIVITIES
The proposed treatment activities for this project are manual treatments, mechanical treatments, prescribed burning, targeted herbicide application, and prescribed herbivory. Each treatment activity is described in more detail below and consistent with the treatment activities described in the Program EIR. Table 2-2 provides a summary of

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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-9 treatments and the maximum acreage of each treatment activity in the project area. Treatment activities could occur during any time of the year. Prescribed burning would occur any day of the week or time of day within identified burn prescription windows. Manual treatments, mechanical treatments, and targeted herbicide application could occur on any day of the week but would generally be limited to daylight hours. Prescribed herbivory in one fenced area could occur across the span of days, up to a week at the longest.

Table 2-2: Applicable Treatment Activities
Treatment Activity Equipment Used for Treatments Typical Duration of Treatments
Maximum Treatment
Size (Acres) *
Manual treatment
Chainsaws, hand saws, brush cutters, pole saws, hand lopping tools, shovels, weed wrenches, weed whips, machetes, pruning shears, other hand tools and hand-operated power tools, and passenger vehicle(s)/all-terrain vehicle(s).
1 week–6 months 143,375
Mechanical treatment
Tracked or wheeled masticators (e.g., skid steers or excavators with masticating heads), tracked and tow-behind chippers, bulldozer or tractor with brush rake or ball-and-chain crushing apparatus, loader with bucket and thumb attachments to pile material for burns or chipping, wheeled skidders, fire suppression vehicles and equipment (e.g., water apparatus, hand tools), and passenger vehicle(s)/allterrain vehicle(s). 1 week–6 months 93,158
Prescribed burning–
broadcast burning **
Drip torch/terra torch, aerial ignition devices, water tender, excavator, fire suppression vehicles and equipment (e.g., water apparatus, fire engines, bulldozers, tractors, skidders, mowers, loader, excavator, hand tools), and passenger vehicle(s)/all-terrain vehicle(s). 1 day–1 week 143,375
Prescribed burning–
pile burning**
Drip torch/terra torch, aerial ignition devices, water tender, excavator, fire suppression vehicles and equipment (e.g., water apparatus, fire engines, bulldozers, tractors, skidders, mowers, loader, excavator, hand tools), air curtain burner, carbonizer, and passenger vehicle(s)/all-terrain vehicle(s).
1 day–1 week 143,375
Targeted herbicide
application
Batch truck, application devices (e.g., backpack sprayer, manual brush applicator), and passenger vehicle(s)/all-terrain vehicle(s). 1 day–2 weeks 143,375 Prescribed herbivory Electric fencing, 10 to 500 head of livestock, water trailer, herding animals (e.g., dogs), and passenger vehicle(s)/all-terrain vehicle(s). 1 day–1 month 143,375 * The sum of acres in maximum treatment size is greater than the total treatment acreage because acreages are approximate, and more than one treatment activity may occur in a given area. While manual treatment, prescribed burning, herbicide application, and prescribed herbivory may occur throughout the entire project area, these treatment activities will be limited to a much smaller area based on feasibility, the scope of individual treatments, and restrictions of the standard project requirements and mitigation measures. ** Cultural burning activities are included under prescribed burning.

Source: Information provided by SCCFSC; compiled by ARC in 2025.

2.3.1 Manual Treatment
Manual treatments primarily include the practice of removing or modifying vegetation through the use of nonmechanized hand tools (e.g., handsaws, Pulaskis, axes, loppers) or mechanized hand tools (e.g., chainsaws, hedge trimmers, pole saws) to cut, remove, hand pile, lop and scatter, and thin trees. In previously burned or otherwise disturbed landscapes in the project area, manual treatments also include tree planting. Generally, manual treatments are not limited by slopes and can be implemented in locations otherwise not accessible for mechanical treatment; however, implementing manual treatments in excessively steep areas may be unsafe and may increase the cost of treatment. Approximately 143,375 acres have been identified as areas in which manual treatment may be implemented in the project area. Manual treatment would be implemented within portions of this overall area based on resource protections, safety concerns, and feasibility.

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Saratoga Protection Fire District
2-10 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Manual treatments would be applied to understory or restorative overstory treatment prescriptions where appropriate. For instance, a manual treatment crew would utilize loppers, chainsaws, or other hand tools to cut and remove understory trees and vegetation, or a hand crew would use a chainsaw paired with other felling tools to remove midrange diameter trees or in some cases larger diameter trees. When large trees jeopardize emergency ingress or egress, are deemed to be hazardous or a threat to infrastructure, or are identified to be causing shifts in surrounding vegetation composition in an undesirable manner through seeding (e.g., Douglas-fir encroachment), they would be removed through manual treatments. Additionally, manual treatments would be used to facilitate future prescribed burning efforts and in conjunction with mechanical treatments.

To implement manual treatments, one or two crews of approximately three to 20 members would use hand tools and hand-operated power tools to cut, clear, or prune trees, herbaceous vegetation, and woody shrubs. The duration of manual treatments varies greatly depending on treatment area conditions (e.g., density of tree and shrub fuel types or slope), the acreage to be treated, and the size of the hand crew. Under this project, manual treatments could be implemented in little as a 1-week period to an 18-month window.

General specifications for manual treatments across the project include:
 Cut vegetation during manual treatments would be scattered within the treatment area and lopped, or reduced to smaller pieces, to promote decomposition and reduce rearranged fuel heights.  Slash material, such as cut branches, tree tops, or other small woody debris, would be lopped to a height below 30 inches from the ground:
 tree boles or larger woody debris would be left on the ground and bucked to achieve ground contact and spaced at approximately 10 feet apart where feasible to avoid large accumulations of downed woody debris, or chipped.
 When chipping:
 chipped residual material would generally average 3 inches in depth and not exceed approximately 6 inches,  chipped residual material would be minimized in forest gaps or openings where increased biodiversity of herbaceous understory regeneration is more likely, and
 chipping equipment must follow all mechanized equipment specifications and avoidance measures.

2.3.2 Mechanical Treatment
As stated in Section 2.5.2 of the CalVTP Final Program EIR Volume II, mechanical treatments are designed to cut, uproot, crush/compact, or chop target trees and other vegetation. For the purpose of this PSA/Addendum, mechanical treatments include the practice of removing or modifying vegetation with heavy equipment, usually assorted with attachments that are appropriate for vegetation modification or processing, such as a masticating head attachment. Approximately 93,158 acres have been identified as the area within which mechanical treatment may be implemented. Mechanical treatment would be implemented within portions of this overall area based on resource protections, safety concerns, and feasibility.

Mechanical treatments would occur on flat to moderate slopes, less than 50 percent, and from existing roads and skid trails where equipment reaches from the edge of the infrastructure to treat adjacent trees and vegetation.

Additionally, mechanical treatments would be applied to understory or restorative overstory treatment prescriptions where appropriate. For instance, understory treatments use smaller heavy equipment, such as a skid steer, to mulch or masticate woody material and vegetation, whereas larger equipment is used to assist the removal of midrange diameter hazard trees or encroaching Douglas-fir trees to reduce damage to the residual stand or increase operational efficiency.

A variety of heavy equipment is capable of conducting mechanical treatments for vegetation and forest management, and consideration should be given to the following specifications to determine what equipment is most appropriate for each project: equipment size and weight, type of tracks (rubber or steel), mobility and reach,

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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-11 and available attachments. Equipment types used would include skid steers, excavators, tractors, tracked chippers, backhoes, skidders, slope mowers, or other available heavy equipment that would achieve project goals. Mechanical treatments would be used to facilitate future prescribed burning efforts. Mechanized equipment would be used to support the implementation of other treatment activities, such as manual treatments; for instance, a tracked chipper may be used to process vegetation removed under the manual treatment activity, or ATV/UTVs or other mechanized equipment or vehicles may be employed for watering or for transporting tools and equipment in areas where tree or shrub planting occurs. Mechanical treatments would occur outside designated sensitive resource avoidance buffers as appropriate, such that no ground disturbance from mechanized equipment would occur.

Remote-controlled masticators would be utilized as mechanical equipment. These types of machines are operated by a grounds person via remote control, while standing at a safe distance away, to cut or mulch vegetation. Remotecontrolled masticators have a low center of gravity, which allows them to operate on moderate slopes (i.e., 35–50 percent). This treatment method also provides the opportunity for improved visibility and precision control because the operator can assess the work area from different vantage points, improving identification of sensitive resources in advance of treatment work.

To implement mechanical treatments, one hand crew of approximately five to 20 workers would aid equipment operators in achieving treatment specifications. The duration of mechanical treatments varies greatly depending on treatment area conditions (e.g., density of tree and shrub fuel types or slope) and the acreage to be treated. Under this project, mechanical treatments could be implemented over as little as a 1-week up to an 18-month period.

General specifications for mechanical treatments across the project include:
 Equipment movement would occur on slopes up to approximately 50 percent, whereas mechanical treatments would occur predominately on slopes up to 40 percent.
 Treatment would target above-ground vegetation, keeping masticating heads out of duff layers and minimizing direct disturbance to subsurface soil layers, allowing intact root systems to resprout and minimizing impacts on burrowing wildlife.
 When chipping, chipped residual material:
 would be broadcast over at least 75 percent of treatment areas, and  would generally average 3 inches in depth and not exceed approximately 6 inches.  Mechanical treatments would be minimized in forest gaps or openings where increased biodiversity of herbaceous understory regeneration is more likely, and equipment would avoid wetlands (e.g., wet meadows, seeps) and WLPZs:
 some vegetation would be removed by reaching an excavator arm into a wet meadow or WLPZ such that no ground disturbance would occur within these areas.

2.3.3 Prescribed Burning
Prescribed burning is the intentional and strategic ignition of fire under specified conditions, which allows fire to behave in more predictable and controlled patterns to achieve a desired outcome. Prescribed burning is implemented by state-certified burn bosses and resources with CAL FIRE coordination. The “Broadcast Burning” and “Pile Burning” sections below describe the general parameters for these treatment activities under this PSA/Addendum. Prescribed burning would also include air curtain burning or carbonization, which are discussed in more detail in the “Biomass Processing” section below. All burning would be implemented in fall, winter, or spring and in accordance with regulations regarding the use of prescribed burning. This would include the preparation and implementation of a burn plan that includes a smoke management plan.

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2-12 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

CULTURAL BURNING
Included under prescribed burning is cultural burning, a practice associated with Indigenous land stewardship under which burning is conducted for ecological and wildfire management benefits, as well as cultural and traditional purposes. Cultural burning practices, which can differ from the prescribed burning described in this section in terms of size, seasonality, timing, prepping/planning, and post-fire treatment, were suppressed following European colonization and the persecution of Native people and their land. However, in recent years, efforts to reintroduce Indigenous land stewardship practices continue to shape statewide approaches to wildland fire management (Wildfire and Forest Resilience Task Force 2022).

In this PSA/Addendum, cultural burning is considered under broadcast burning and pile burning and would be implemented in accordance with regulations, SPRs, and MMs associated with these treatment activities. This would include the preparation and implementation of a burn plan and a smoke management plan, when applicable, and obtaining any required permits to conduct the burn from fire authorities.

BROADCAST BURNING
Broadcast burning would occur under specified conditions that allow fire to spread within a confined, predetermined area to achieve desired fire behavior and characteristics that obtain management goals. Broadcast burns can be used in areas to reintroduce fire to the landscape where naturally occurring wildfire has been excluded outside its historical fire return interval due to nearly a century of fire suppression efforts. Approximately 143,375 acres of the project area have been identified as areas in which broadcast burning treatment may be implemented in the project area.

Broadcast burning would be implemented within portions of this overall area based on resource protections, safety concerns, and feasibility.

Burn units are delineated with the intent of developing landscape connectivity and opportunities for unit compartmentalization through the strategic placement of treatment units and intermediate burn control lines. Burn unit sequencing is proposed to occur in a manner that prioritizes burning next to previously burned units.

Prescribed broadcast burns typically last approximately 1 day to 2 weeks, and the average number of workers on a prescribed burn is approximately 50. Equipment used for a prescribed burn includes between two and 10 engines, up to two bulldozers and bulldozer transports, masticators or track chippers (to create fuel break perimeter prior to broadcast burns), mechanized hand tools (e.g., chainsaw, high weed mowers, pole saws), an on-site water truck for fire suppression, and in the case of aerial ignitions, equipment such as drones, helitorches, and other ignition and aviation apparatus.

PILE BURNING
Pile burning involves the ignition of piles of woody debris that results from forest density reduction activities. Like broadcast burning, piles would only be ignited under a prescribed set of conditions. Pile burning is a useful tool for reducing the amount of biomass left in a project area. Although approximately 143,375 acres of the project area have been identified as areas in which pile burning treatment may be implemented, pile burning would be implemented within portions of this overall area based on resource protections, safety concerns, and feasibility.

Biomass from mechanical treatment and manual treatment would be piled using heavy equipment or hand crews and burned appropriately. As described in the Program EIR (CalVTP Final Program EIR Volume II Section 2.5.2, page 2-18), pile burning can be used as a means of reducing fuel loads and supporting ecological goals. Pile burning would occur in areas with little to no live overstory or areas where flame lengths and heat would not negatively impact overstory trees. Pile burning would not occur within WLPZ buffers.

Pile burning would occur over a 1-week to 1-month period, and the average number of workers on-site for pile burning would be 10. Equipment used for pile burning includes two to five Type 6 engines and an on-site water truck for fire suppression.

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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-13 General specifications for prescribed burning treatments across the project include:
 In and around burn units and other areas where prescribed burning would occur:
 clear vegetation and any combustible material from control lines around burn units;  remove dead, dying, or diseased trees; and
 identify areas where fuel loads exceed safe levels for pile and broadcast burning and reduce fuel continuity.  Avoid wetlands (e.g., wet meadows, seeps) or WLPZs for pile burning and all ignitions:
 broadcast burning would be conducted into wetlands or WLPZs as long as no ignition or ground disturbance occurs within the WLPZ.

2.3.4 Targeted Herbicide Application
Targeted herbicide treatment involves the application of chemicals to targeted plants species to inhibit their growth and control their spread. There are various methods to apply herbicides, consisting of but not limited to backpack sprayer, boom sprayer on an ATV/UTV, and hand application, all of which have subsequent techniques to improve application. Targeted herbicide treatment would primarily be used to prevent the spread of the resprouting of invasive species in the project area. Approximately 143,375 acres have been identified as areas in which targeted herbicide application may be implemented in the project area. Herbicide application would be implemented within portions of this overall area based on resource protections, safety concerns, and feasibility. Herbicide treatments would not occur within WLPZ buffers. Targeted herbicide application would be completed by certified and licensed applicators using application methods, such as spot, foliar spray, or by hand (e.g., cut stump method).

During initial and maintenance treatments, herbicide would be used to control invasive vegetation and prevent growth of species such as French broom (Genista monspessulana) and yellow starthistle (Centaurea solstitis).

Herbicides used under this PSA/Addendum would be consistent with those listed in Section 2.5.2 of the CalVTP Final Program EIR Volume II. Herbicides that may be applied include: borax (tetraborate decahydrate); clopyralid (monoethanolamine salt); glyphosate (isopropylamine salt, potassium salt, dimethylamine salt and diammonium salt); hexazinone; imazapyr (isopropylamine salt); sulfometuron methyl; triclopyr (butoxyethyl ester and triethylamine salt); nonylphenol 9 ethoxylates (NP9E); Cleantraxx (penoxsulam and oxyfluorfen); Velpar (hexazinone); and Indaziflam.

Typically, herbicide application would be carried out by two to four workers and would comply with the US Environmental Protection Agency (EPA) label directions, as well as California Environmental Protection Agency and Department of Pesticide Regulation (DPR) label standards. The project proponent would comply with all laws and regulations governing the use of herbicides for this project. Herbicide application under this project is likely to occur within a 1-week period.

2.3.5 Prescribed Herbivory
Prescribed herbivory may be implemented on up to 143,375 acres of the PSA/Addendum area; however, prescribed herbivory would be limited to a select subsection of this overall area based on resource protections, safety concerns, and feasibility. Prescribed herbivory (also known as “targeted grazing”) is the use of domestic livestock, in this case sheep or goats, to accomplish specific and measurable vegetation management objectives. Objectives include removing herbaceous biomass (e.g., fine fuel loads) and woody biomass; reducing populations of specific plant species; slowing the reestablishment of shrubs on ungrazed, burned, or mechanically thinned sites; and improving plant community structure for wildlife habitat values. Sheep or goats would be used for prescribed herbivory, depending on the target treatment area and goals. Animal type used would be dependent on the site conditions, vegetation community being targeted, and dietary preferences of the grazing animal. All prescribed herbivory conducted under the proposed project would be within seasonally appropriate periods based on vegetation type and excluded from certain areas, to protect sensitive species.

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Saratoga Protection Fire District
2-14 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Cattle grazing is a historical and existing activity with the purpose of maintaining grasslands, enhancing wildlife habitat, and reducing fine fuel loads. Cattle grazing is not included in the proposed project or analysis because cattle grazing currently occurs and historically occurred on many of the properties in this project to maintain grasslands for decades while fire was predominantly excluded. The practice would not be expanded or changed from its current or historical range under this PSA/Addendum.

A herder, fencing, mineral block, or a watering site or some combination would be required to keep the grazing animals within the desired area; typically, professional herders or portable electric fencing would be used during prescribed herbivory treatments. Herds would be moved as often as every 1 to 7 days, and one to two workers would be required on average to implement this treatment activity. Control of livestock movement and prevention of the impacts of overgrazing is critical for the successful use of this treatment method.

Prescribed herbivory results in nonselective removal of vegetation and, therefore, is not recommended for sensitive habitat areas or areas potentially containing special-status plant species or cultural resources areas. Prescribed herbivory is effective at reducing flashy fuels and brush intrusion. Any prescribed herbivory in forested habitat that targets understory materials would include protection measures for selected native understory vegetation to prevent girdling, trampling, and browsing on special-status species. Forest understory vegetation would be maintained in ecological restoration areas consistent with the understory descriptions in A Manual of California Vegetation (Sawyer et al. 2009). Prescribed herbivory would generally not be implemented in riparian woodlands and would only be used along the margins of these areas. Prescribed herbivory would be confined to the dry season, and exclusion zones consistent with CalVTP Program EIR specifications (e.g., SPR HYD-3 and MM BIO-4) around aquatic habitats would be created to minimize potential impacts on these areas from prescribed herbivory activities.

SHEEP
Sheep eat forbs, grasses, and shrubs and graze on steep slopes. Their herding instinct allows prescribed herbivory without the installation and maintenance of fences but requires that a shepherd and trained, professional dogs are present. Sheep grazing requires that drinking water sources be present, which would be provided through hauled water tanks or on-site developed livestock water sources (troughs). A combination of sheep and goats can be a viable option when a mixture of grass, noxious weeds, and shrubs are present in the area to be treated.

GOATS
Goats prefer to browse on woody vegetation (e.g., tree leaves, twigs, vines, shrubs) and eat materials up to 6 feet above the ground. This grazing pattern creates a desirable vertical separation between the canopy and ground cover that is best used in areas with low numbers of plants intended for retention because goats indiscriminately damage most plants. Goat grazing is also preferable in areas of steeper terrain, where other grazing animals are less suited for the topographic conditions and are therefore less effective in grazing to achieve the desired vegetation management results.

Portable electric fences would be used to help control the herd and the outcome of their grazing. Measures would also be taken to prevent girdling of small trees that can result from the goats browsing on tree bark. Herd movement has the advantage of breaking off dead material in a stand, as well as punching a humus layer into the soil (if the ground is somewhat moist), and thereby removing available fuel.

2.4 BIOMASS PROCESSING
Biomass created during the proposed vegetation treatments described above would be disposed of primarily by mastication, chipping and broadcasting throughout the treatment area, lop and scattering, prescribed burning, and incineration with a curtain burner or carbonator. In order to conduct these disposal methods, woody material would be hauled, skidded, and decked to be processed. Whole logs would be stored on-site for later disposal, and where current biomass disposal methods exceed immediate capacity, off-hauling excess chipped material would be

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West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-15 delivered to off-site properties. Should chips from throughout the project area be off-hauled, the project proponent would acquire written acceptance of the volume of chips. The biomass disposal methods are further described as follows (a percent of biomass to be treated through each processing method is estimated for initial treatments and analysis purposes).

2.4.1 Chipping
Chipped material is estimated to account for approximately 12.5 percent of biomass. Materials would be chipped, broadcast, and spread throughout treatment areas in a manner that does not exceed an average depth of approximately 3 inches and does not exceed 6 inches. Material would be chipped in place or into a van to be taken to a different location in the PSA/Addendum area or to be hauled off-site for donation to willing recipients, as outlined in the accompanying wasted discharge plan. Chipping involves the use of a mechanized chipper to chip woody debris and pile or spread the processed material in a given location and would be applied to mechanical and manual treatments.

2.4.2 Mastication
Masticated material is estimated to account for approximately 30 percent of biomass. Mastication, or the mulching of vegetation and woody debris, occurs concurrently with mechanical vegetation removal where all masticated material is left on the ground.

2.4.3 Lop and Scatter
Lop and scattered material is estimated to account for approximately 17.5 percent of biomass. Lop and scatter methods would be used on steeper slopes, in areas where equipment access is not feasible, and as part of any manual treatments. Areas where lopping and scattering would occur would also be subject to broadcast burning.

2.4.4 Pile Burning
Pile burned material is estimated to account for approximately 12.5 percent of biomass.

Cut vegetation during manual or mechanical treatments would be piled in scattered located throughout the treatment area to be ignited under a specified conditions to dispose of cut, chipped, or masticated woody debris and vegetation. Burn piles would be covered with plastic, or other appropriate means, to maintain low fuel moisture in the area designated for ignition.

2.4.5 Broadcast Burning
Broadcast burned material is estimated to account for approximately 20 percent of biomass.

Broadcast burning would occur in designated burn units under predetermined site-specific conditions. Burn units overlap with other treatment activities, where fire would be used as a vegetation maintenance tool to consume understory vegetation and woody debris. Site preparation for burn units would primarily include mastication, chipping, crushing, cutting, lopping and scattering, or other vegetation pretreatments along designated control lines and intermediate controls as appropriate.

2.4.6 Air Curtain Burning and Carbonization
Material that is processed through air curtain burning and carbonization is estimated to account for approximately 5 percent of biomass.

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Saratoga Protection Fire District
2-16 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Air curtain burning and carbonization are new technologies designed to consume biomass inside fireboxes. These technologies use heavy equipment for loading biomass into the fireboxes and are generally set up in large, open areas that are clear of vegetation.

When feasible, biomass resulting from mechanical or manual treatments, such as large material considered inefficient for chipping or other processing methods, would be disposed of using air curtain burning or carbonization. Air curtain burners would be set up on existing roadways or landings that meet the qualifications for their use, which comprise level, previously disturbed areas that are devoid of vegetation. Biomass would be carried from the work sites to the burner and fed into the air curtain burner through the use of heavy machinery. The location of the air curtain burner or carbonizer requires consideration of its proximity to landings and roads that would be used to transport material to the firebox. Once the burning is complete and the produced wood ash has cooled, the ash and biochar may be distributed throughout the treatment area where the biomass originated or be hauled off-site for donation to willing recipients, as outlined in the accompanying waste discharge plan.

The depth of biochar and ash would not exceed 4 inches at any location in the project area. If it is not feasible to distribute biochar and ash in the treatment area in this way, biochar may also be hauled off-site for beneficial use at agricultural or other facilities in the area. Multiple air curtain burners could be operated simultaneously as part of the proposed project. A burner requires a crew of two to three people per burner, and operating multiple burners next to each other would not necessarily require additional people. Air curtain burners have been designed to consume biomass quickly and efficiently with a substantial reduction in smoke.

2.4.7 Biomass Hauling
Material that results from treatment activities, such as material processed through chipping or air curtain burning and carbonization or whole logs, may be hauled off-site and donated to nearby willing recipients, such as privately owned farms or creek restoration projects, for example, due to the lack of nearby biomass processing facilities. Biomass hauling is estimated to account for approximately 2.5 percent of biomass. A waste disposition plan would outline the hauling locations prior to biomass being hauled off-site.

For the purposes of this PSA/Addendum, biomass hauling is not expected to exceed a hauling distance of approximately 155 miles from the project area because the two closest large-scale biomass processing facilities are within this approximate distance of the project area. DTE Stockton LLC in Stockton, San Joaquin County, California, is approximately 120 miles from the farthest southern section of the project area, and Woodland Biomass Power LLC in Woodland, Yolo County, California, is approximately 152 miles from the farthest southern section of the project area.

Biomass may be hauled to willing local recipients in the vicinity of operations where feasible.

2.5 TREATMENT MAINTENANCE
Maintenance treatments, or retreatments, would occur based on annual monitoring of the site conditions.

Maintenance treatment is estimated to occur immediately following initial treatments (e.g., manual, mechanical, prescribed fire, targeted herbicide, or prescribed herbivory) or approximately every 2 to 10 years, or more frequently if the qualified professional/lead agency determines that the initial treatment did not obtain the appropriate results (e.g., the prescribed fire treatment did not result in the appropriate treatment outcome representative of the results expected from the average fire return interval). Maintenance treatment methods employ the same vegetation treatment activities used in the initial treatment or introduce a new treatment activity presented in this PSA/Addendum; for example, mechanical initial treatments may be maintained with prescribed fire treatments.

Retreatment in ecological restoration areas would consider the natural fire return interval (i.e., time since last burn is greater than or equal to the average fire return interval for the habitat type) of a given vegetation type and existing conditions, prior to implementing a maintenance treatment. Treatment activities that do not use fire (e.g., manual treatments, mechanical treatments) are considered “fire surrogates.” In the absence of additional data regarding mechanical and manual treatment activities, fire return interval is used as a proxy to guide the frequency and intensity of these non-fire treatments. This approach assumes that, in some vegetation types, manual treatment functions

Ascent Project Description
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 2-17 similarly to low-severity fire, whereas mechanical treatment more closely resembles the effects of mixed severity fire.

Follow-up maintenance treatment to target invasive species would occur at any time.

Maintenance treatments would generally be lower in intensity and scale than initial treatments. Prior to implementing maintenance treatments, the project proponent would determine the natural fire return interval of the habitat(s) to be retreated, and the project proponent would verify that the expected site conditions as described in the PSA/Addendum are present in the treatment area(s). Additionally, pursuant to SPR BIO-5, all treatments and the maintenance treatment interval would be designed to maintain habitat function of the specific chaparral vegetation alliance being treated and to avoid type conversion of chaparral. As a result, retreatment is generally anticipated to occur between 2 and 10 years following initial treatments in common vegetation types (e.g., annual grassland, Douglas-fir forest); maintenance treatment would be timed to retain habitat function and ensure the habitat is within the natural fire return interval in sensitive natural communities or sensitive habitats (e.g., wetland, riparian, oak woodland, chaparral). Prior to implementing maintenance treatments, the project proponent would determine the natural fire return interval of the habitat(s) to be retreated and would verify that the expected site conditions as described in the PSA/Addendum are present in the treatment area.

As time passes, the continued relevance of the PSA/Addendum would be considered by the project proponent considering potentially changed conditions or circumstances. If environmental conditions evolve or project approaches change to the degree that the project proponent finds new or substantially more severe impacts may occur, the proponent would determine whether a new PSA/Addendum or other environmental analysis is warranted.

2.6 GUIDANCE FOLLOWING PSA APPROVAL

2.6.1 General Actions to Implement Treatment Activities The purpose of the following list is to provide guidance to the implementing entity to ensure that all steps necessary to commence treatments described in the PSA/Addendum are complete prior to operations; this list serves as a timeline and checklist that would be applied to each phase of treatment implementation. Some actions listed below would be completed during the development of the PSA/Addendum, while others must be completed for individual implementation periods (e.g., phases of treatments, initial treatments, maintenance treatments). This checklist is intended to be used in conjunction with the MMRP located in Attachment A.

1. Protocol-level botanical surveys are complete, and sensitive resources are marked (SPR BIO-1, SPR BIO-3, and SPR BIO-7).

2. Protocol-level wildlife and nursery site surveys are complete, and special-status species are marked (SPR BIO-1, SPR BIO-10, MM BIO-2a, and MM BIO-2b).

3. The archaeological survey report process is complete, and archaeological sites are flagged for avoidance and protection (SPR CUL-4, SPR CUL-5, and SPR CUL-7).

4. Burn plan, if necessary, is complete (SPR AQ-3).

5. Smoke management plan, if necessary, has been obtained (SPR AQ-2).

6. Treatment operations maps that consist of, but are not limited to, existing roads, existing stream crossings, staging areas, access points, watercourses, and other sensitive resources, specify treatment activity areas, and potential unstable areas have been prepared (SPR AD-2).

7. CalVTP PSA noticing requirements to neighbors and other appropriate entities are complete (SPR AD-4, SPR AD6, SPR CUL-2, SPR HAZ-9, SPR NOI-6, and SPR REC-1).

8. Final field verification of treatment units that include flagging all sensitive resources consisting of, but not limited to, sample treatment areas flagged for retention, access points, staging areas, property lines where necessary, WLPZs, unstable areas, and existing stream crossings is complete.

Project Description Ascent
Saratoga Protection Fire District
2-18 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

9. Contract bid process has begun, and bid walk has been conducted with contractors to explain the treatment prescription and associated activities and to show them the sample treatment areas.

10. Pretreatment activity surveys are complete, and sensitive resources have been flagged (SPR BIO-7 and SPR BIO10).

11. Nesting bird surveyors are under contract and ready to conduct surveys (SPR BIO-12).

12. Environmental awareness training and cultural resource training are complete with contractors, and treatment operations have begun (SPR BIO-2 and SPR CUL-8).

13. Supervision of contractors occurs consistently throughout project implementation.

14. Implementation meetings occur two to four times a month to keep track of operations and ensure appropriate sensitive resource protection.

15. Roads and other appropriate infrastructure are closed with necessary erosion control measures as winter approaches (SPR GEO-5).

16. Roads and other appropriate infrastructure are checked during the winter to ensure that no erosion issues are occurring as a result of treatment operations (SPR GEO-4).

17. During prescribed herbivory treatments, wildlife-friendly fencing is used to manage livestock (SPR BIO-11), prescribed herbivory treatments are being used in areas with more than a 50 percent slope (SPR GEO-7), and herbivore-specific water quality protections are implemented (SPR HYD-3). MM BIO-2e prohibits use of prescribed herbivory in the occupied habitat of federally listed protected butterflies, such as bay checkerspot butterfly. Other seasonal restrictions may also apply to prescribed herbivory treatments in sensitive natural communities and oak woodlands (see Impact BIO-2 in Section 4.5, “Biological Resources,” Attachment A, MM BIO-3a).

18. Implementation of treatments in chaparral and coastal sage scrub vegetation (as defined in SPR CHAP/CSS-1) will comply with the requirements of SPR CHAP/CSS-1.

Entities enrolled in the Santa Clara Valley Habitat Plan (SCVHP) who are implementing treatments covered by the SCVHP must implement applicable requirements of the SCVHP. See Impact BIO-8 in Section 4.5, “Biological Resources,” for additional details.

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 3-1 3 ENVIRONMENTAL CHECKLIST

VEGETATION TREATMENT PROJECT INFORMATION

1. Project Title: West Santa Clara Landscape Resiliency Project

2. CalVTP I.D. Number: 2025-27

3. Implementing Entity’s Name and Address: Santa Clara FireSafe Council 14380 Saratoga Ave
Saratoga, CA 95070-5953

4. Contact Person Information and Phone Number: Stephen Harrington 831.419.2434
[email protected]

5. Project Proponent Name and Address: Saratoga Fire Protection District 14380 Saratoga Ave, Saratoga, CA 95070

6. Contact Person Information and Phone Number: Trina Whitley [email protected]
408.867.9001

7. Project Location: Western Santa Clara County
PSA/Addendum Area Centroid Coordinates:

Longitude (X): -121.834647
Latitude (Y): 37.149751
See Map 1-1

8. Total Area to Be Treated (acres) Up to 143,375 acres

9. Description of Project:

See Section 2, “Project Description,” above for a detailed description of the proposed project, including initial treatment prescriptions, planned treatment maintenance, equipment used for treatment activities, and planned duration of treatments with cross-references to specific subsections of the Program EIR. In addition, Section 2, “Project Description,” provides a detailed description of the proposed treatment types, treatment activities, and fuel types for initial and maintenance treatments.
a. Initial Treatment
Initial treatments are described in Section 2, “Project Description,” and generally include manual, mechanical, prescribed fire (pile burn and broadcast burn), and herbicide treatments within the ecological restoration treatment type.

Treatment Types
Wildland-Urban Interface Fuel Reduction
Fuel Break
Ecological Restoration
Treatment Activities
Prescribed Burning (Broadcast), ___143,375__ acres
Prescribed Burning (Pile Burning), ___143,375___ acres
Mechanical Treatment, ___93,158___ acres
Manual Treatment, ___143,375__ acres
Prescribed Herbivory, ___143,375___ acres
Herbicide Application, ___143,375___ acres

Environmental Checklist Ascent
Saratoga Protection Fire District
3-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Fuel Type
Grass Fuel Type
Shrub Fuel Type
Tree Fuel Type
b. Treatment Maintenance
See Section 2.5, “Treatment Maintenance,” above for a detailed description of maintenance activities.

Treatment Types
Wildland-Urban Interface Fuel Reduction
Fuel Break
Ecological Restoration
Treatment Activities [See description in CalVTP Program EIR Section 2.5.2, check every applicable category, include number of acres subject to each treatment activity, and provide detail in description of initial treatment.] Prescribed Burning (Broadcast), ___143,375__ acres
Prescribed Burning (Pile Burning), ___143,375__ acres
Mechanical Treatment, ___143,375___ acres
Manual Treatment, ___143,375___ acres
Prescribed Herbivory, ___143,375___ acres
Herbicide Application, ___143,375__ acres
Fuel Type
Grass Fuel Type
Shrub Fuel Type
Tree Fuel Type
Use of the PSA for Treatment Maintenance
Prior to implementing a maintenance treatment, the project proponent would verify that the expected site conditions as described in the PSA are present in the treatment area. As time passes, the continued relevance of the PSA would be considered by the project proponent in light of potentially changed conditions or circumstances. Where the project proponent determines the PSA is no longer sufficiently relevant, the project proponent would determine whether a new PSA or other environmental analysis is warranted.

In addition to verifying that the PSA continues to provide relevant CEQA coverage for treatment maintenance, the project proponent would update the PSA at the time a maintenance treatment is needed when more than 10 years have passed since the approval of the PSA or the latest PSA update. For example, the project proponent may conduct a reconnaissance survey to verify conditions are substantially similar to those anticipated in the PSA.

Updated information should be documented.

10. Regional Setting and Surrounding Land Uses:

The WSCLRP encompasses roughly 143,375 acres from the WUI and residential margin of the Santa Clara Valley to the crest of the Santa Cruz Mountains. This PSA/Addendum area is located entirely within Santa Clara County, primarily in the rural, residential, and open space areas of the Santa Cruz Mountains and foothills. Generally, the project area spans a discontinuous collection of parcels west of Palo Alto to Gilroy, California.

Additional information regarding regional setting and surrounding land uses is provided in Section 1.4, “Existing Conditions,” of this PSA/Addendum.

Ascent Environmental Checklist
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 3-3

11. Other Public Agencies Whose Approval Is Required: (e.g., permits)  Consultation required by the CalVTP was met by submitting a project description, species status list, and pertinent maps to the California Department of Fish and Wildlife (CDFW) during the planning phase of this project on December 17, 2025. Comments from CDFW were received on December 24, 2025. CDFW indicated that they were unable to review the project due to staff shortages, and provided additional general guidance.  Consultation required by the CalVTP was met by submitting a project description, species status list, and pertinent maps to the United States Fish and Wildlife Service (USFWS) during the planning phase of this project on December 17, 2025. Comments from USFWS were received on December 18, 2025, and were incorporated into the PSA project design.
 Smoke management plans will be prepared for the Monterey Bay Air Quality Management District and/or Bay Area Air District, as required.
 Burn permits will be obtained from CAL FIRE and the Monterey Bay Air Quality Management District and/or Bay Area Air District, as required.

Coastal Act Compliance
The proposed project is NOT within the Coastal Zone.

The proposed project is within the Coastal Zone. (Check one of the following boxes.) A coastal development permit has been applied for or obtained from the local Coastal Commission district office or local government with a certified Local Coastal Plan, as applicable.

The local Coastal Commission district office or local government with a certified Local Coastal Plan (in consultation with the local Coastal Commission district office) has determined that a coastal development permit is not required.

12. Native American Consultation. For treatment projects that are within the scope of the CalVTP Program EIR, AB 52 consultation for Assembly Bill (AB) 52 compliance has been completed. The Board conducted consultation pursuant to PRC Section 21080.3.1 during preparation of the Program EIR. For treatment projects with impacts not within the scope of the Program EIR, pursuant to PRC Sections 21080.3.1, 21080.3.2, and 21082.3, project proponents preparing a new negative declaration, mitigated negative declaration, or EIR must notify any California Native American tribe that has submitted written request for notification of a project in the area of the treatment site. Upon written request for consultation by a tribe, the project proponent must begin consultation before the release of the environmental document and must follow the requirements of the cited PRC sections.

The following Native American contacts in Santa Clara County were contacted on November 26, 2025: Vice Chairperson Ed Ketchum and Chairperson Valentin Lopez of Amah Mutsun Tribal Band; Senior Cultural Monitor and Consultant Michelle Zimmer, Chairperson Irenne Zwierlein, Senior Cultural Monitor and Consultant and Councilman Chritopher Zimmer, and Senior Cultural Monitor and Consultant and Councilwomen Shelby Brown of Amah Mutsun Tribal Band of Mission San Juan Bautista; Language Program Manager Deja Gould, Chairperson Corrina Gould, and Tribal Cultural Resource Manager Cheyenne Gould of Confederated Villages of Lisjan Nation; Tribal Councilmember Carla Munoz, Cultural Resource Officer Samuel Rodriguez, and Cultural Resource Officer Henry Muñoz of Costanoan Rumsen Carmel Tribe; Tribal Chairwoman Kanyon Sayer-Roods and Retired Honorable Elder Ann Marie Sayers of Indian Canyon Mutsun Band of Costanoan; Councilmember/MLC Tribal Representative Richard Massiatt and Chairperson Charlene Nijmeh of Muwekma Ohlone Tribe of the San Francisco Bay Area; Chairperson Katherine Perez and Tribal Compliance Officer Timothy Perez of Northern Valley Yokut/Ohlone Tribe; THPO Johnathan Wasaka Costillas, Secretary Lilian Camarena, and Chairperson Quirina Geary of Tamien Nation; THPO Desiree Vigil, President Emeritus Andrew Galvan, and President Vincent Medina of the Ohlone Indian Tribe; and Chairperson Kenneth Woodrow of Wuksachi Indian Tribe/Eshom Valley Band. Responses were received from the Muwekma Ohlone Tribe of the San Francisco Bay Area and the Tamien Nation, and coordination pursuant to SPR CUL-2 is complete.

Engagement with tribes related to cultural resources protection or cultural burning will continue during implementation of treatments as requested by tribes.

Environmental Checklist Ascent

DETERMINATION
On the basis of this PSA and the substantial evidence supporting it:

X I find that the effects of the proposed project (a) have been covered in the CalVTP Program EIR, and (b) all applicable Standard Project Requirements and mitigation measures identified in the CalVTP Program EIR will be implemented. The proposed project is, therefore, WITHIN THE SCOPE of the CalVTP Program EIR. NO ADDITIONAL CEQA DOCUMENTATION is required.

X I find that the presence of proposed project areas outside the CalVTP treatable landscape will not result in substantial changes in the project, no substantial changes in circumstances have occurred, and no new information of substantial importance has been identified. The inclusion of project areas outside the CalVTP treatable landscape will not result in any new or substantially more severe significant impacts. None of the conditions described in State CEQA Guidelines Section 15162 calling for preparation of a subsequent EIR have occurred; therefore, an ADDENDUM is adopted to address the project areas outside the geographic extent presented in the Program EIR.

D I find that the proposed project will have effects that were not covered in the CalVTP Program EIR. These effects are less than significant without any mitigation beyond what is already required pursuant to the CalVTP Program EIR. A NEGATIVE DECLARATION will be prepared.

D I find that the proposed project will have effects that were not covered in the CalVTP Program EIR or will have effects that are substantially more severe than those covered in the CalVTP Program EIR. Although these effects may be significant in the absence of additional mitigation beyond the CalVTP Program El R's measures, revisions to the proposed project or additional mitigation measures have been agreed to by the project partners that would avoid or reduce the effects so that clearly no significant effects would occur. A MmGATED NEGATIVE DECLARATION will be prepared.

D I find that the proposed project will have significant environmental effects that are (a) new and were not covered in the CalVTP Program EIR and/or (b) substantially more severe than those covered in the CalVTP Program EIR.

Because one or more effects may be significant and cannot be clearly mitigated to less than significant, an ENVIRONMENTAL IMPACT REPORT will be prepared.

Signature Date
SR. Pro j ect Mana ger
Printed Name Title
SantaClara Co. FiresafeCouncil .

Agency

Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-1 4 PROJECT-SPECIFIC ANALYSIS/ADDENDUM

4.1 AESTHETICS AND VISUAL RESOURCES
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:

Impact AES-1: Result in ShortTerm, Substantial Degradation of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from Treatment
Activities
LTS Impact AES-1,
pp. 3.2-16 –

3.2-19
Yes AD-3
AD-4
AES-2
AQ-2
AQ-3
REC-1
NA LTS No Yes
Impact AES-2: Result in LongTerm, Substantial Degradation of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from Wildland-Urban
Interface Fuel Reduction,
Ecological Restoration, or
Shaded Fuel Break Treatment
Types
LTS Impact AES-2,
pp. 3.2-20 –

3.2-25
Yes AD-3
AES-1
AES-3
NA LTS No Yes
Impact AES-3: Result in LongTerm Substantial Degradation of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from the Nonshaded
Fuel Break Treatment Type
SU Impact AES-3,
pp. 3.2-25 –

3.2-27
Yes AD-3 AES-3 SU No Yes
Notes: MM = mitigation measure; LTS = less than significant; SU = significant and unavoidable; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.

New Aesthetic and Visual Resource Impacts: Would the treatment result in other impacts to aesthetics and visual resources that are not evaluated in the CalVTP Program EIR?
Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-2 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR Discussion
IMPACT AES-1
Initial and maintenance treatments would be implemented using manual treatment, mechanical treatment, prescribed burning, herbicide application, and prescribed herbivory. The potential for these treatment activities to result in shortterm degradation of the visual character of a project area was examined in the Program EIR. The nearest officially designated state scenic highway is SR 9 (Big Basin Way), which traverses the Santa Cruz Mountains and passes directly through the project area as part of the Saratoga–Los Gatos Road Scenic Corridor (Caltrans 2025). In addition, an officially designated portion of SR 35 (Skyline Boulevard) runs along the ridgeline of the Santa Cruz Mountains, adjacent to the western edge of the project area. Portions of SR 280 located along the northern boundary of the project area are also either officially designated or eligible for state scenic highway designation. SR 17 and a portion of SR 152 are also eligible state scenic highways that pass directly through the project area (Caltrans 2025). Publicly accessible viewpoints within and near the project area from which treatments may be visible are located along public roadways, trails, and recreation areas, including Mount Madonna County Park, Uvas Reservoir County Park, Chesbro Reservoir County Park, Calero County Park, Sierra Azul Open Space Preserve, Almaden Quicksilver County Park, Santa Teresa County Park, Bear Creek Redwoods Open Space Preserve, Lexington Reservoir County Park, El Sereno Open Space Preserve, Sanborn County Park, Saratoga Gap Open Space Preserve, Picchetti Ranch Open Space Preserve, Fremont Older Open Space Preserve, Stevens Creek County Park, Rancho San Antonio County Park, Foothills Nature Preserve, Mont Bello Open Space Preserve, SR 9, SR 17, SR 35, SR 152, and SR 280.

Although portions of the project area are visible from public viewpoints and officially designated state scenic highways (SR 9 and portions of SR 35 and SR 280), the project area has varied topography and is typically densely vegetated with some areas of mature trees, which would substantially reduce the visibility of treatments from public viewpoints and officially designated state scenic highways. In addition, treatments would primarily remove trees smaller than 16 inches dbh, retaining healthy overstory vegetation, and removing select shrubs to create a mosaic structure with retained vegetation. Although the removal of vegetation could be noticeable in the short term after treatment, mature vegetation would remain to provide partial screening of treatment areas. Equipment, crews, and smoke from prescribed burning could also be visible from public viewpoints and officially designated state scenic highways (SR 9 and portions of SR 35 and SR 280) in the short term.

The potential for the project to result in short-term substantial degradation of the visual character of the project area is within the scope of the Program EIR because the proposed treatment activities are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing scenic resources are essentially the same within and outside the treatable landscape; therefore, the short-term aesthetic impact is also the same, as described above. SPRs applicable to the proposed treatments are AD-3, AD-4, AES-2, AQ-2, AQ-3, and REC-1. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AES-2
Proposed initial and maintenance treatments are ecological restoration, WUI fuel reduction, and fuel break (shaded and non-shaded) treatment types. Non-shaded fuel breaks are addressed in Impact AES-3, below. The potential for these treatment types to result in long-term degradation of the visual character of an area was examined in the Program EIR.

Public viewpoints primarily include the publicly accessible recreation areas within the project area described above under Impact AES-1 and public roadways adjacent to the proposed treatments, several of which are eligible or officially designated as state scenic highways (SR 9, SR 17, SR 35, SR 152, SR 280). The long-term visual character and quality of public views after implementation of the proposed ecological restoration, WUI fuel reduction, and fuel break treatments would remain consistent with the current natural, vegetated landscape and, therefore, would not constitute a substantial

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-3 adverse change or degrade the current visual character of the landscape. The potential for the project to result in longterm substantial degradation of the visual character of the project area is within the scope of the Program EIR because the proposed treatment activities are consistent with those analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the long-term aesthetic impact is also the same, as described above.

SPRs applicable to the proposed treatments are AD-3, AES-1, and AES-3. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AES-3
Initial and maintenance treatments would include non-shaded fuel break treatments in non-forested areas. The potential for this treatment type to result in long-term degradation of the visual character of an area was examined in the Program EIR and found to be significant and unavoidable after the application of all feasible MMs because it may be infeasible to relocate a non-shaded fuel break to avoid public visibility. Public viewpoints of the non-shaded fuel breaks include the public recreation areas described above under Impact AES-1 and public roadways (main highways and primary access routes) adjacent to the proposed treatments. Some non-shaded fuel breaks would also be visible from SR 9 and portions of SR 35 and SR 280, which are officially designated state scenic highways. The potential for the project to result in long-term substantial degradation of the visual character of the project area is within the scope of the Program EIR because the proposed treatment activities are consistent with those analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing visual character is essentially the same within and outside of the treatable landscape; therefore, the long-term aesthetic impact is also the same, as described above. SPR AD-3 is applicable to this impact. In addition, MM AES-3 would apply to this treatment to minimize visual impacts, if feasible, from any recreation areas, public roads, and state scenic highways with lengthy views (i.e., longer than a few seconds) of non-shaded fuel breaks. While implementation of MM AES-3 would substantially reduce the potential for substantial long-term degradation of visual character, as noted in the Program EIR, non-shaded fuel breaks may be visible from public viewpoints, and it is not feasible to relocate them because they have been proposed in strategic locations to reduce wildfire risk and support fire suppression by providing responders with a staging area. Therefore, the potential remains for substantial longterm degradation of visual character, and this impact is considered significant and unavoidable. This determination is consistent with the Program EIR and would not constitute a new or substantially more severe significant impact than what was covered in the Program EIR.

NEW AESTHETIC AND VISUAL RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP Program EIR.

The site-specific characteristics of the proposed treatments were considered during development of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.2.1, “Environmental Setting,” and Section 3.2.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed project area constitutes a change to the geographic extent presented in the Program EIR.

However, within the boundary of the project area, the existing environmental conditions pertinent to aesthetics and visual resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are consistent with those covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape would not give rise to any new significant impact.

Therefore, no new impact related to aesthetics and visual resources would occur.

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

4.2 AGRICULTURE AND FORESTRY RESOURCES
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:

Impact AG-1: Directly Result in
the Loss of Forest Land or
Conversion of Forest Land to a
Non-Forest Use or Involve
Other Changes in the Existing
Environment Which, Due to
Their Location or Nature,
Could Result in Conversion of
Forest Land to Non-Forest Use
LTS Impact AG-1,
pp. 3.3-7 –

3.3-8
Yes AD-3 NA LTS No Yes
Notes: LTS = less than significant; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.

New Agriculture and Forestry Resource Impacts: Would the treatment result in other impacts to agriculture and forestry resources that are not evaluated in the CalVTP Program EIR?
Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
Discussion
IMPACT AG-1
Initial and maintenance treatments would include ecological restoration, WUI fuel reduction, and fuel break treatment types. Treatment activities would include manual treatment, mechanical treatment, prescribed burning, prescribed herbivory, and targeted application of herbicides. The potential for these treatment types and treatment activities to result in the loss of forestland or conversion of forestland to non-forest use was examined in the Program EIR.

The project area includes forest land as defined by PRC Section 12220(g) (i.e., land that can support 10 percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits). Treatments proposed under the project may include the removal of healthy trees that are up to 16 inches dbh. Select larger trees may be removed if they are dead, dying, diseased, or a safety hazard, and larger Douglas-fir trees up to 36 inches in diameter if they are outcompeting or otherwise encroaching upon the existing native hardwood forest vegetation type. Treatments would include removal of trees in the overstory and midlevel canopy to improve forest health and reduce wildfire risk. Treatments would not affect the forest stand conditions directly or indirectly in a way that could result in conversion to a non-forest use. Vegetation management has the potential to improve forest stand conditions by reducing competition and improving the forest floor conditions to promote natural seeding of tree species. Vegetation remaining within forest land after treatment would continue to be consistent with the definition of forest land pursuant to PRC Section 12220(g).

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-5 The potential for proposed treatment activities to result in loss or conversion of forest land was examined in the Program EIR. This impact is within the scope of the Program EIR because the treatment activities and intensity are consistent with those analyzed in the Program EIR. The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR.

However, within the boundary of the project area, the composition of forest land and agricultural land present in the areas outside the treatable landscape is essentially the same as that within the treatable landscape; therefore, the impact on forest land is also the same, as described above. SPR AD-3, which requires the project to comply with local plans, policies, and ordinances regarding the conversion of forest land, is applicable to the proposed treatments. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

NEW AGRICULTURE AND FORESTRY RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP Program EIR. The site-specific characteristics of the proposed project were considered during development of this PSA/Addendum, and it was determined that they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.3.1, “Environmental Setting,” and Section 3.3.2, “Regulatory Setting,” in Volume II of the Final Program EIR). Including land from outside the CalVTP treatable landscape in the proposed project area constitutes a change to the geographic extent presented in the Program EIR.

However, within the boundary of the project area, the existing environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, the impacts of the proposed project are also consistent with those covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape would not give rise to new significant impacts not addressed in the Program EIR. Therefore, no new impact related to agriculture and forestry resources would occur that is not covered in the Program EIR.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-6 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR

4.3 AIR QUALITY
Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program
EIR
Identify
Impact
Significance
in the
Program EIR
Identify
Location of
Impact Analysis
in the Program
EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be a
Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:

Impact AQ-1: Generate
Emissions of Criteria Air
Pollutants and Precursors
During Treatment Activities
That Would Exceed CAAQS
or NAAQS
PSU Impact AQ-1,
pp. 3.4-26 –

3.4-32;
Appendix AQ-1
Yes AD-4
AQ-1, AQ-2
AQ-3, AQ-4
AQ-5, AQ-6
AQ-1 SU No Yes
Impact AQ-2: Expose
People to Diesel
Particulate Matter
Emissions and Related
Health Risk
LTS Impact AQ-2,
pp. 3.4-33 –

3.4-34;
Appendix AQ-1
Yes AQ-1
HAZ-1
NOI-4
NOI-5
NA LTS No Yes
Impact AQ-3: Expose
People to Fugitive Dust
Emissions Containing
Naturally Occurring
Asbestos and Related
Health Risk
LTS Impact AQ-3,
pp. 3.4-34 –

3.4-35
Yes AQ-1
AQ-4
AQ-5
NA LTS No Yes
Impact AQ-4: Expose
People to Toxic Air
Contaminants Emitted by
Prescribed Burns and
Related Health Risk
PSU Impact AQ-4,
pp. 3.4-35 –

3.4-37
Yes AD-4
AQ-1
AQ-2
AQ-6
NA SU No Yes
Impact AQ-5: Expose
People to Objectionable
Odors from Diesel Exhaust
LTS Impact AQ-5,
pp. 3.4-37 –

3.4-38
Yes AQ-1
HAZ-1
NOI-4
NOI-5
NA LTS No Yes
Impact AQ-6: Expose
People to Objectionable
Odors from Smoke During
Prescribed Burning
PSU Impact AQ-6; p.

3.4-38
Yes AD-4
AQ-1
AQ-2
AQ-6
NA SU No Yes
Notes: LTS = less than significant; PSU = potentially significant and unavoidable; SU = significant and unavoidable; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact.

New Air Quality Impacts: Would the treatment result in other impacts to air quality that are not evaluated in the CalVTP Program EIR? Yes No If yes, complete row(s) below and discussion Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-7 Discussion
The project area is in the jurisdiction of the Bay Area Air District and the Monterey Bay Air Resources District (MBARD). Pursuant to SPR AQ-1, the project would comply with the applicable air quality requirements of the Bay Area Air District or MBARD or both. Pursuant to SPR AQ-2, the project proponent would prepare a smoke management plan and submit it to the Bay Area Air District and/or MBARD prior to implementing any prescribed burning treatment. In addition, a burn plan would be prepared as required by SPR AQ-3, which would include fire behavior modeling. In addition, SPR AQ-6 requires the implementation of an incident action plan, which identifies burn dates, burn hours, weather limitations, specific burn prescription, communication plan, medical plan, traffic plan, and other special instructions required by the Bay Area Air District or MBARD or both. The Incident Action Plan would also identify the contact personnel for the Bay Area Air District and MBARD to use in coordinating on-site briefings, posting notifications, and weather monitoring during burning.

IMPACT AQ-1
Use of vehicles, mechanical equipment, and prescribed (broadcast and pile) burning during initial and maintenance treatments would result in emissions of criteria pollutants that could exceed California Ambient Air Quality Standard (CAAQS) or National Ambient Air Quality Standard (NAAQS) thresholds. The potential for emissions of criteria pollutants to exceed CAAQS or NAAQS thresholds was examined in the Program EIR and found to be potentially significant and unavoidable after the application of all feasible MMs because of uncertainties in the degree of emissions reduction that would occur during implementation of later treatments.

Emissions of criteria air pollutants related to the proposed treatments are within the scope of the Program EIR because the associated equipment and duration of use are consistent with those analyzed in the Program EIR. MM AQ-1 is also applicable to this impact. The emission reduction techniques proposed in MM AQ-1 would be implemented to the extent feasible. However, it may be cost prohibitive to use equipment that meets the latest efficiency standards, including meeting the EPA’s Tier 4 emission standards, using renewable diesel fuel, electric- and gasoline-powered equipment, and equipment with best available control technology. Carpooling would be encouraged by the implementing entity, but because crews may not all be employed with the same company, it may not be feasible for most workers. For these reasons, this impact would remain significant and unavoidable.

When feasible, specialized biomass processing technologies would be used for biomass disposal in place of pile burning, pursuant to MM GHG-2. Evaluation of criteria air pollutant emissions from these biomass processing technologies conducted by Ascent (2022) indicates that smoke and criteria air pollutant emissions can be substantially reduced, compared to open pile burning. Use of an air curtain burner would substantially reduce reactive organic gas (ROG) and particulate matter (PM) emissions by approximately 96 percent when compared to pile burning. Carbonization would substantially reduce ROG emissions by approximately 98 percent and PM emissions by 71–100 percent compared to pile burning. For nitrous oxide (NOX), air curtains are estimated to reduce NOX emissions by at least 73 percent, and carbonization is estimated to reduce NOX emissions by approximately 39– 94 percent (Ascent 2022). According to available information about emissions from specialized biomass processing technologies, these technologies offer the opportunity to substantially reduce local exposure to PM from smoke, a potentially beneficial difference compared to pile burning.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the air quality conditions present and air basin in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above. The SPRs applicable to this impact are AD-4 and SPR AQ-1 through SPR AQ-6. Despite the substantial reduction in criteria air pollutant emissions afforded by use of these biomass processing technologies, Impact AQ-1 must still be recognized as significant and unavoidable because specialized biomass processing technologies may not be used for every treatment and treatments that do not use an air curtain burner could still result in exceedance of CAAQS or NAAQS thresholds. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-8 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR IMPACT AQ-2
Use of vehicles and mechanical equipment during initial and maintenance treatments could expose people, such as hikers and recreationists, to diesel PM emissions. However, treatment activities would not take place near the same people for an extended period such that prolonged exposure would occur. The potential to expose people to diesel PM emissions was examined in the Program EIR. Diesel PM emissions from the proposed treatments are within the scope of the Program EIR because the exposure potential is the same as analyzed in the Program EIR and the types and amount of equipment that would be used, as well as the duration of use during proposed treatments, are consistent with those analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the air quality conditions and sensitive receptors (i.e., exposure potential) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above. SPRs applicable to this treatment are AQ-1, HAZ-1, NOI-4, and NOI-5.

A revision to SPR HAZ-1 is proposed such that any leaking equipment may be stabilized and fixed on-site. All other elements of SPR HAZ-1 would remain the same as presented in the Program EIR. This revision is consistent with the purpose of SPR HAZ-1 and does not involve any changes to requirements regarding equipment maintenance that could affect diesel particulate emissions. For the reasons described, proposed revisions to SPR HAZ-1 would not result in a substantially more severe significant effect related to emissions of diesel PM than what was covered in the Program EIR.

This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AQ-3
Use of vehicles, mechanical equipment, and prescribed burning during treatments would involve ground-disturbing activities. The potential to expose people to naturally occurring asbestos (NOA)–containing fugitive dust emissions was examined in the Program EIR. Portions of the project area are underlain by serpentine soils (DOC 2000; USGS 2011). These soil types potentially contain thin veins of asbestos fibers that can become airborne when disturbed. In accordance with SPR AQ-5, no ground-disturbing activities would occur in these areas without an asbestos dust control plan if required by 17 CCR Section 93105. Potential NOA exposure from the proposed treatments is within the scope of the activities and impacts addressed in the Program EIR because the types of ground-disturbing activities and the exposure potential are consistent with the impacts analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above. SPRs applicable to this treatment are AQ-1, AQ-4, and AQ-5. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AQ-4
Prescribed burning during initial and ongoing maintenance treatments could expose people to toxic air contaminants (TACs), which was examined in the Program EIR. SPRs applicable to prescribed burning and ongoing maintenance treatments are designed to minimize the risk of exposing people to smoke, which includes TACs; however, prescribed burning during initial and maintenance treatments could still expose people to TACs. This potential exposure risk was examined as an impact in the Program EIR and found to be potentially significant and unavoidable after the application of the SPRs and all feasible MMs because unpredictable changes in weather can occur during prescribed burns resulting in short-term exposure of people to concentrations of TACs and associated levels of acute health risk

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-9 with a Hazard Index greater than 1.0. When feasible, the use of specialized biomass processing technologies is proposed to reduce smoke emissions and associated TACs compared to pile burning. TACs resulting from the combustion of biomass are generally organic in nature and are, therefore, a subset of ROG emissions. According to an evaluation conducted by Ascent (2022), the proposed use of air curtain burners would reduce ROG emissions by at least 96 percent, and the use of air curtain burners and carbonizers would reduce ROG emissions by approximately 98 percent compared to pile burning of equivalent areas. Therefore, the exposure of people to TACs and related health risks would likely be substantially lower with the use of air curtain burners as compared with pile burning. The duration and parameters of the prescribed burns are within the scope of the activities addressed in the Program EIR.

Therefore, the potential for exposure to TACs is also within the scope the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above. SPRs applicable to these treatment activities are AD-4, AQ-1, AQ-2, and AQ-6. All feasible measures to prevent and minimize smoke emissions, as well as exposure to smoke, are included in the SPRs. No additional MMs are feasible, and this impact would remain significant and unavoidable, as explained in the Program EIR. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AQ-5
Use of diesel-powered equipment during vegetation treatments could expose people to objectionable odors from diesel exhaust. The potential to expose people to objectionable odors from diesel exhaust was examined in the Program EIR. Consistent with the Program EIR, diesel exhaust emissions would be temporary, would not be generated at any one location for an extended period of time, and would dissipate rapidly from the source with an increase in distance. This impact is within the scope of the Program EIR because the equipment that would be used and the duration of use under the proposed project are consistent with what was analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the air quality conditions and sensitive receptors present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above.

SPRs applicable to this impact are AQ-1, HAZ-1, NOI-4, and NOI-5.

A revision to SPR HAZ-1 is proposed such that any leaking equipment may be stabilized and fixed on-site. All other elements of SPR HAZ-1 would remain the same as presented in the Program EIR. This revision is consistent with the purpose of SPR HAZ-1 and does not involve any changes to requirements regarding equipment maintenance that affect diesel exhaust emissions and related odors. For the reasons described, proposed revisions to SPR HAZ-1 would not result in a substantially more severe significant effect related to odors from diesel exhaust than what was covered in the Program EIR.

This impact of the proposed project is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT AQ-6
Prescribed burning during initial and maintenance treatments could expose people to objectionable odors. SPRs applicable to prescribed burning are designed to minimize the risk of exposing people to smoke, which includes objectionable odors. The potential to expose people to objectionable odors was examined in the Program EIR and was found to be potentially significant and unavoidable after the application of all feasible MMs because, despite precautions taken, unpredictable weather changes could still result in short-term exposure to odorous smoke emissions. Pursuant to MM GHG-2, the use of air curtain burning and carbonization are proposed to reduce smoke

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-10 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR emissions and associated odors in comparison to pile burning. When compared to pile burning, the proposed biomass processing technologies would substantially reduce smoke through filtering (i.e., air curtains) or eliminate smoke and associated odors altogether (i.e., carbonizers).

The duration and parameters of prescribed burning and the exposure potential are consistent with the activities addressed in the Program EIR, and impacts would be reduced with the use of proposed biomass processing technologies. Therefore, the resultant potential for exposure to objectionable odors from smoke is within the scope of impacts covered in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the air quality conditions present and sensitive receptors in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above.

SPRs that are applicable to the proposed treatments are AD-4, AQ-1, AQ-2, and AQ-6. All feasible measures to prevent and minimize smoke odors, as well as exposure to smoke odors, are included in SPRs; additionally, biomass processing technologies to reduce smoke would be used pursuant to MM GHG-2. No additional MMs are feasible, and this impact would remain significant and unavoidable, as explained in the Program EIR. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

NEW AIR QUALITY IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP Program EIR.

The site-specific characteristics of the proposed treatments were considered during preparation of this PSA/Addendum, and it was determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP Program EIR (refer to Section 3.4.1, “Regulatory Setting,” and Section 3.4.2, “Environmental Setting,” in Volume II of the Final Program EIR). Including land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR.

However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to air quality that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the same, and for the reasons described above, impacts of the proposed project are consistent with those covered in the Program EIR.

Revisions to SPR HAZ-1 would constitute a change to the project analyzed in the Program EIR. However, as described under Impacts AQ-2 and AQ-5 above, the revisions do not involve any changes to requirements regarding equipment maintenance that would affect diesel particulate emissions or diesel exhaust emissions and related odors and would continue to reduce the potential for air quality impacts consistent with the overall intent of SPR HAZ-1. Therefore, revisions to SPR HAZ-1 would not result in a new impact that was not covered in the Program EIR. No changed circumstances are present, and the inclusion of areas outside the CalVTP treatable landscape and revisions to SPR HAZ-1 would not give rise to any new significant impact. Therefore, no new impact related to air quality would occur.

Ascent Project-Specific Analysis/Addendum
Saratoga Fire Protection District
West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR 4-11

4.4 ARCHAEOLOGICAL, HISTORICAL, AND TRIBAL CULTURAL RESOURCES Impact in the Program EIR Project-Specific Checklist
Environmental Impact
Covered in the Program EIR
Identify
Impact
Significance
in the
Program
EIR
Identify
Location of
Impact
Analysis in the
Program EIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project
List MMs
Applicable
to the
Treatment
Project
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
Program EIR?
Is This
Impact
within the
Scope of
the
Program
EIR?
Would the project:

Impact CUL-1: Cause a
Substantial Adverse Change in
the Significance of Built
Historical Resources
LTS Impact CUL-1,
pp. 3.5-14 –

3.5-15
Yes AD-3
CUL-1, CUL-7
CUL-8
NA LTS No Yes
Impact CUL-2: Cause a
Substantial Adverse Change in
the Significance of Unique
Archaeological Resources or
Subsurface Historical
Resources
SU Impact CUL-2,
pp. 3.5-15 –

3.5-16
Yes AD-3
CUL-1, CUL-2
CUL-3, CUL-4
CUL-5, CUL-8
CUL-2 SU No Yes
Impact CUL-3: Cause a
Substantial Adverse Change in
the Significance of a Tribal
Cultural Resource
LTS Impact CUL-3,
p. 3.5-17
Yes AD-3
CUL-1, CUL-2
CUL-3, CUL-4
CUL-5, CUL-6
CUL-8
NA LTS No Yes
Impact CUL-4: Disturb Human
Remains
LTS Impact CUL-4,
p. 3.5-18
Yes AD-3 NA LTS No Yes
Notes: LTS = less than significant; LTSM = less than significant with mitigation; NI = no impact; PSU = potentially significant and unavoidable; SU = significant and unavoidable; NA = not applicable because there are no SPRs and/or MMs identified in the Program EIR for this impact; None = there are SPRs and/or MMs identified in the Program EIR for this impact, but none are applicable to the treatment project.

New Archaeological, Historical, and Tribal Cultural Resource Impacts: Would the treatment result in other impacts to archaeological, historical, and tribal cultural resources that are not evaluated in the CalVTP Program EIR? Yes No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than Significant with
Mitigation Incorporated
Less than Significant
[Identify new impact here, if applicable; add rows as needed.] Discussion
Consistent with SPR CUL-1, a records search of the 143,375-acre project area, including areas within and outside of the CalVTP treatable landscape, was performed by the Northwest Information Center (NWIC) on October 8, 2025 (NWIC File 25-0330). The search revealed 460 previously recorded archaeological sites and historical features within the project area.

Consistent with SPR CUL-2, an updated Native American contact list was obtained from the Native American Heritage Commission (NAHC). On November 26, 2025, letters inviting the tribes to consult were emailed to the 10 tribal representatives indicated by NAHC. Responses were received from the Muwekma Ohlone Tribe of the San Francisco Bay Area and the Tamien Nation, and coordination pursuant to SPR CUL-2 is complete. Engagement with tribes related to cultural resources protection or cultural burning will continue during implementation of treatments, as requested by tribes. An October 17, 2025, search of NAHC’s sacred lands database returned positive results.

Project-Specific Analysis/Addendum Ascent
Saratoga Fire Protection District
4-12 West Santa Clara Landscape Resiliency Project PSA and Addendum to the Program EIR IMPACT CUL-1
Proposed treatment activities include mechanical treatments and prescribed burning, which could damage historical resources. The NWIC records search revealed previously recorded historical features, including single-family residences, school buildings, industrial buildings, bridges, railroads, and farms. However, it is not known if they have been evaluated for eligibility for listing in the CRHR; therefore, it is not known whether they are considered resource under CEQA. Additional structures (i.e., buildings, bridges, roadways) over 50 years old that have not been recorded or evaluated for historical significance may be present in the project area; these structures will be identified and avoided pursuant to SPR CUL-7. The potential for proposed treatment activities to result in disturbance, damage, or destruction of built-environment structures that have not yet been evaluated for historical significance was examined in the Program EIR. This impact is within the scope of the Program EIR because treatment activities and the intensity of ground disturbance of the treatments are consistent with those analyzed in the Program EIR.

The inclusion of land in the proposed project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the Program EIR. However, within the boundary of the project area, the potential to encounter built-environment structures that have not yet been evaluated for historical significance in areas outside the treatable landscape is essentially the same as within the treatable landscape; therefore, the potential impact on historical resources is also the same, as described above. SPRs applicable to this impact are AD-3, CUL-1, CUL-7, and CUL-8. This determination is consistent with the Program EIR and would not constitute a substantially more severe significant impact than what was covered in the Program EIR.

IMPACT CUL-2
Vegetation treatment would include mechanical treatments using heavy equipment that could churn up the surface of the ground during treatment as vegetation is removed; this may result in damage to known or previously unknown archaeological resources. The NWIC records search revealed previously recorded archaeological sites, including indigenous materials (bedrock milling features, hearths, habitation debris, and lithic scatters), and historic-era sites (abandoned water conveyance systems, dams, mines and quarries, trash scatters, major ditches, roadbeds, structure pads, and fences). However, it is not known whether they have been evaluated for eligibility for listing in the CRHR.

Therefore, it is not known whether these sites are considered resources under CEQA. A survey will be conducted before treatment pursuant to SPR CUL-4 to identify any previously unrecorded archaeological resources, and identified resources will be avoided according to the provisions of SPR CUL-5.

As described under Section 1.3.2, “Proposed Project Revisions,” revisions to SPR CUL-4 are proposed to clarify that this SPR applies to all mechanical and prescribed burning treatment activities and manual treatment activities that use tracked chippers beyond established road surfaces. This would exempt manual treatments when woody material is chipped and scattered, chipped and removed, or lopped and scattered from needing an archaeological and historical resource survey. This constitutes a revision to the program description analyzed in the Program EIR. Requirements under SPR CUL-4 are intended to prevent damage to archaeological and historical resources while avoiding unnecessary loss of work time. The proposed revisions to SPR CUL-4 would not result in any adverse effects to cultural resources because the revision would allow treatment activities to occur without a survey only when there is no potential for the treatment activity to result in damage to cultural resources. Activities that may result in damage to cultural resources (e.g., mechanical treatments and prescribed burning) would require pretreatment surveys.

Therefore, proposed revisions to SPR CUL-4 would not result in a substantially more severe significant effect related to disturbance of cultural resources than what was covered in the Program EIR. The proposed revisions to SPR CUL-4 are shown in the MMRP (Attachment A).

The potential for these treatment activities to result in inadvertent discovery and subsequent damage of unique archaeological resources or subsurface historical resources during vegetation treatment was examined in the Program EIR. This impact was identified as significant and unavoidable in the Program EIR because of the large geographic extent of the treatable landscape and the possibility that there could be some rare instances where inadvertent damage of unknown resources may be extensive. For the proposed project, SPRs and MM CUL-2 would require identification and protection of resources, and it is reasonably expected that implementation of these