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noise, substantial permanent increase in ambient noise levels, or substantial temporary increase in ambient noise levels because much of the Wilderness Area would remain undeveloped with the exception of the foot trail. Use of the foot trail would constitute passive recreation engaged by hikers that would not generate substantial noise or groundborne vibration. Recreational visitors may use the proposed trails with leashed dogs, which may occasionally bark. However, dog barking would be isolated incidents and the noise would be buffered by existing treelines, resulting in minimal impacts to residential homes bordering the Wilderness Area. Maintenance of the Wilderness Area consists of manual labor, with no use of machinery with the exception of crew vehicles along fire access roads, which would continue under implementation of the Management Plan.

Therefore, there would be no impact.

The Wilderness Area is not located within two miles of a public airport, is not within an airport land use plan, and implementation of the project would have no impacts to airport safety. The nearest airport is Brackett Air Field, located approximately three and a half miles to the south. Therefore, impacts would be Class IV, no impact.

5.8 Population and Housing
CEQA Guidelines Appendix G (Section XIII) states that a significant impact on population and housing may result if the Project would:
1 Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
2 Displace substantial numbers of existing housing, necessitating the construction or replacement housing elsewhere?
3 Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
The Wilderness Area consists of open space and mostly undeveloped land, and implementation of the project is intended to ensure the continued maintenance and conservation of the Wilderness Area, with the exception of the foot trail for passive recreational use by hikers. The Wilderness Area does not contain housing or associated permanent population that could be displaced upon implementation of the project, and no structures would be built as a result of the project. Similar to existing conditions and operations pertaining to the maintenance of the Wilderness Area, there would be temporary work crews throughout the year to manage vegetation and fuel to prevent wildfires, existing fire access roads, and to maintain the proposed foot trail.

The project would not generate new housing and, therefore, would not impact regional or local population projections for Los Angeles County or the City of La Verne, respectively.

The project would not induce growth in the area by extending major infrastructure into an undeveloped area, and would not displace existing housing or disrupt other existing land uses in the vicinity of the existing trail site. Therefore, impacts would be Class IV, no impact. 281
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5.9 Utilities and Service Systems
CEQA Guidelines Appendix G (Section XVIII) states that a significant noise impact may result if the Project would:
1 Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?
2 Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?
3 Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?
4 Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? 5 Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? 6 Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?
7 Comply with federal, state, and local statutes and regulations related to solid waste? Stormwater generated in the Wilderness Area would flow across the City toward the southwest and eventually drain to the Pacific Ocean; existing stormwater runoff patterns would not be altered by the project. The project would not introduce new impervious surfaces and would not increase stormwater runoff from existing conditions. The project does not include construction of drainage features, and no mitigation measures would be required to implement the project.

The Wilderness Area does not contain build structures or plumbing features, and would remain undeveloped after implementation of the project. Therefore, no potable water service would be provided to the site and no long-term increase in water demand would occur. Therefore, the project would not require new or expanded water entitlements and there would be no impacts.

The 0.6-mile trail loop would not generate solid waste through its operation aside from pet waste from leashed dogs, and trail users would be required to carry out pet waste generated during trail use. Construction of the trail may generate a minimal volume of green waste from clearing vegetation. The City of La Verne is part of the Los Angeles County Sanitation District, and has a contract with Waste Management to provide refuse and recycling collection services to the City’s residents and businesses. The California Integrated Waste Management Act of 1989 (AB 939), requires each city or county’s source reduction and recycling element to include an implementation schedule showing that a city or county 282
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must divert 50 percent of solid waste from landfill disposal or transformation on and after January 1, 2000. SB 1016, passed in 2008, now requires the 50 percent diversion requirement to be calculated in a per capita disposal rate equivalent. The City has maintained a diversion rate of over 50 percent since 2007.

The nearest active landfill that serves the City of La Verne, Azusa Land Reclamation County Landfill located 10 miles southwest of the Wilderness Area, had a remaining capacity of 71 million tons as of 2014 (Waste Management, Inc. 2014). However, the Azusa Land Reclamation County Landfill does not accept green waste, which would most likely be generated from the Wilderness Area during construction of the foot trail. Rather, the Olinda Alpha Landfill located 15 miles south of the Wilderness Area, accepts shredded green waste and has enough capacity to serve residents and businesses until 2030 (Orange County Waste & Recycling 2017). Waste generated during construction of the proposed foot trail would be negligible and temporary, and therefore, would not exceed the capacity of local landfills. Therefore, impacts would be Class III, less than significant.

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6 Other CEQA Required Discussions

6.1 Growth Inducing Effects
Section 15126(d) of the CEQA Guidelines requires a discussion of a proposed project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create substantial physical changes to the environment. However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. A proposed project's growth effects are considered significant if they could result in significant physical effects in one or more environmental issue areas. The most commonly cited example of how a growth effect might create a physical change is where economic growth in one area could create blight conditions elsewhere by causing existing competitors to go out of business and the buildings to be left vacant.

6.1.1 Economic and Population Growth
As discussed in Section 2.0, Project Description, implementation of the proposed Wilderness Area Management Plan consists of improvements in the form of wildlife conservation, public access and safety, and wildland fire risk management. Much of the Wilderness Area would remain unchanged and inaccessible for public recreation with the exception of the proposed 0.6-mile long trail loop for hikers and associated designated street parking along Golden Hill Road. The Management Plan would not entail construction of buildings or infrastructures.

As described in Section 5.8, Population and Housing, implementation of the Management Plan would not generate new housing in or displace existing populations from the Wilderness Area. The project would not induce growth in the City by extending major infrastructure into an undeveloped area, or impact employment opportunities in the City.

6.1.2 Removal of Obstacles to Growth
The proposed Management Plan would allow much of the Wilderness Area to remain unchanged, but better managed to increase wildlife habitat conservation, reduce wildfire hazards, and increase public access and safety. There are no infrastructural improvements, construction of buildings, or expansion of public safety services and utilities services necessary as a result of implementing the Management Plan. Therefore, the Management Plan would not create or remove obstacles to growth, but would rather improve existing conditions of the Wilderness Area.
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6.2 Irreversible Environmental Effects
The CEQA Guidelines require that EIRs evaluating projects involving amendments to public plans, ordinances, or policies contain a discussion of significant irreversible environmental changes. CEQA also requires decision makers to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve a project.

This section addresses non-renewable resources, the commitment of future generations to the proposed uses, and irreversible impacts associated with the proposed development.

Construction activities associated with the proposed Management Plan would involve the use of building materials and energy, some of which are non-renewable resources.

Consumption of these resources would occur with any development in the region and are not unique to the Wilderness Area. The addition of 0.6-mile long trail loop would require trail-building materials (such as gravel and/or wood logs) which would be carried in and placed by crews from City’s Public Works Department. Lockable gates for public safety, signage for the trailhead and designated parking area, and associated parking striping paint would also be required as initial materials to implement the proposed trail head and parking area. The Management Plan contains actions that would ensure continued fuel modification and vegetation management in the Wilderness Area, wherein crews would drive in on designated fire roads and perform vegetation clearing activities with minor equipment such as backhoes and hand tools. Therefore, the development and management envisioned by the proposed Management Plan would not significantly affect local or regional energy supplies.

Growth associated with the proposed Management Plan would not require an irreversible commitment of law enforcement and fire protection (Section 4.6), water supply (Section

4.4), and wastewater treatment and solid waste disposal services (Section 5.9).

6.3 Energy
Appendix F of the CEQA Guidelines requires that EIRs analyze energy conservation consistent with Public Resources Code section 21100(b)(3). According to the CEQA Guidelines, energy impacts that have already been analyzed need not be repeated in later EIRs and EIRs do not need to address “lifecycle emissions,” such as those embedded in the production of building materials used in projects. Lifecycle emissions under CEQA would normally represent “emissions beyond those that could be considered indirect effects of a project as that term is defined in section 15358 of the State CEQA Guidelines” (California Natural Resources Agency 2009).

There are no energy uses in the Wilderness Area, and implementation of the Management Plan would not increase energy use since no proposed buildings or infrastructure are proposed. Therefore, there would be no impacts to energy uses. 286
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7 Alternatives
As required by Section 15126.6 of the CEQA Guidelines, this section of the EIR examines a range of reasonable alternatives to the proposed Management Plan that would feasibly attain most of its basic objectives but would avoid or substantially lessen any of its significant effects on the environment. Section 15126.6 also requires consideration of the “No Project” alternative, regardless of whether it would achieve the project objectives or lessen its environmental effects.

The Management Plan includes selective habitat enhancement actions, the resolution of public safety hazards, and opportunities for limited controlled public access as part of the City’s stewardship responsibilities for the Wilderness Area. To the extent practicable and allowable by physical, biological, and social constraints, the City is committed to the realization of nine overall management goals with specific associated objectives for the Wilderness Area, including:
 Preserve and enhance wildlife habitat corridors and diversity  Provide flood hazard management
 Provide wildfire hazard management
 Provide a tranquil and safe visitor experience
 Provide controlled public access
 Cooperate with others in management of the Wilderness Area  Provide sufficient on-site presence to manage the Wilderness Area  Reflect changes in surrounding use and ownership conditions  Obtain sufficient funds to assure full implementation of the Management Plan.

Implementation of the proposed Management Plan would result in potentially significant impacts related to cultural and tribal resources, hydrology and water quality, land use planning, and transportation and traffic. Alternatives were selected for analysis that could potentially reduce these impacts as well as other impacts determined to be less than significant in this EIR, either with or without mitigation incorporated. The following alternatives are evaluated in this EIR:
 Alternative 1: No Project
 Alternative 2: No Dogs Permitted
 Alternative 3: Trail to Lookout Point
A detailed description of the alternatives is included in the impact analysis for each alternative provided in the following sub-sections. As required by CEQA, this section also includes a discussion of the “environmentally superior alternative” among those studied. 287
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7.1 Alternative 1: No Project

7.1.1 Description
The State grant funds used to acquire the Wilderness Area were dedicated to the “acquisition, development, improvement, rehabilitation or restoration of real property for parks and park safety, senior recreation facilities, gang prevention, beaches, recreation, community or cultural facilities, trails, wildlife habitat or natural land in order to establish open space areas” (County of Los Angeles 1996, 2005). At the time the funds were allocated for purchasing the lands, the City agreed to maintain and operate the property in perpetuity. Conditions in the grant funding include specific stipulations requiring reasonable public access, except where such access would interfere with resource protection (Sections 10c and 13), and prohibiting flood control projects within the grant lands (Section 17d). In order to fulfill the requirements of the land acquisition grant, the Management Plan was prepared to address the resolution of wildlife conservation, public access, and habitat management issues in an integrated program.

The No Project Alternative assumes that the proposed Management Plan would not proceed. If the Management Plan does not proceed, the City would not be fulfilling the requirements set forth in the State grant in 2006 and would therefore have to return the 208 acres acquired through the State grant funds. This would eliminate the requirement for the City to officially re-designate the Wilderness Area to Open Space. Under the No Project Alternative, the 150 acres originally owned by the City would retain the Open Space designation under the Marshall Canyon Estates Specific Plan.

The No Project Alternative would avoid environmental impacts associated with the habitat management and minor site improvements included in the proposed Management Plan and thus, would avoid associated environmental effects to cultural resources, hydrology and water quality, land use and planning, public services, traffic and circulation, and tribal resources. However, the No Project Alternative would have greater impacts to biological resources, wildfire and flooding hazards, and recreational resources due to the lack of habitat and hazard management activities and public access foot trails. The No Project Alternative would not achieve any of the project objectives because it would not include any of the elements of the proposed Management Plan designed to achieve those objectives.

7.1.2 Impact Analysis
Biological Resources
The No Project Alternative would not include the goals and actions pertaining to wildlife habitat conservation, flood and wildfire hazard management as proposed in the Management Plan, and the Wilderness Area would remain in its current condition. This alternative would result in fewer physical changes to the Wilderness Area than under the proposed Management Plan since the proposed trail and habitat conservation actions would not be implemented, and would retain the Wilderness Area’s existing biological 288
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resources, such as dense vegetation that pose wildfire risks. However, the proposed Management Plan would enhance and protect habitat areas by removing abandoned facilities and non-native tree species, preserving significant and heritage trees, and revegetating select areas with appropriate native vegetation. The No Project Alternative would therefore have a potentially greater impact on biological resources than those of the proposed Management Plan.

Cultural Resources
Because the No Project Alternative would not include the minor site improvements or management actions proposed in the Management Plan, there would be no potential ground disturbing activities that may impact known or unanticipated discoveries. Thus, it would eliminate the requirement for Mitigation Measures CR-1 and CR-2. Overall, the No Project Alternative would have less impact on cultural resources than the proposed Management Plan.

Hazards and Hazardous Materials
The No Project Alternative would not include habitat and hazard management activities as proposed in the Management Plan, which would result in the Wilderness Area remaining in present day conditions. Without implementation of the proposed Management Plan, the Wilderness Area would remain unmanaged and retain similar levels of wildfire and flood risks for residential communities in the vicinity. Transportation, use, and generation of hazardous materials and waste would not occur under the No Project Alternative or the proposed Management Plan. The No Project Alternative would have a potentially greater impact on wildfire and flood risks than those of the proposed Management Plan.

Hydrology and Water Quality
The No Project Alternative would not include the habitat and hazard management activities and minor improvements as proposed in the Management Plan and therefore, it would have no impact on hydrology and water quality. The No Project Alternative would not contain management and trail improvements that would potentially result in vegetation clearance, soil disturbance, and soil compaction which may create polluted runoff and could violate water quality standards. Thus, it would eliminate the requirement for Mitigation Measures HWQ-1 and HWQ-2. Overall, the No Project Alternative would have less impact on hydrology and water quality than the proposed Management Plan because it would avoid proposed habitat and hazard management activities and minor site improvements.

Land Use and Planning
As discussed in Section 4.5, Land Use and Planning, the southern portion of the Wilderness Area has a General Plan land use designation of Hillside Residential, which permits up to two dwelling units per acre, while the remainder of the Wilderness Area is designated as Open Space. Likewise, the western half of the Wilderness Area has a zoning designation of Planned Residential that permits one detached dwelling unit per five acres, while the eastern half is designated as Open Space under the Marshall Canyon Estates Specific Plan. 289
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Implementation of the No Project Alternative would potentially allow residential development to occur on appropriately designated parcels, which is incompatible with the land grant used to purchase the Wilderness Area.

The No Project Alternative would not require amendments of the underlying land use and zoning designation land use allowances in order to ensure the Wilderness Area is Open Space and uses are consistent with the land grant. Thus, mitigation measures LU-1 and LU-2 would not be necessary under the No Project Alternative. Therefore, this alternative would have fewer impacts related to existing land use compatibility issues. Overall, the No Project Alternative would have less impact on land use and planning impacts than the proposed Management Plan, though the City would lose the 208 acres of land acquired through the grant.

Public Services
Since the No Project Alternative would not include the management and minor site improvements proposed in the Management Plan, it would have no impact on public services, similar to the less than significant impact of the proposed Management Plan. The No Project Alternative would not create additional demand for public services (such as fire and police protective services, schools, and libraries) because it would not increase the residential population in the Wilderness Area, though the potential for such development exists under current land use and zoning designations. Overall, the No Project Alternative’s impacts on public services would be comparable to the proposed Management Plan.

Recreation
The No Project Alternative would not include impacts to recreational resources, similar to the proposed Management Plan. The No Project Alternative would not create additional recreational resources or increase demand for such facilities. The Wilderness Area would remain inaccessible to the public, which is incompatible with the land grant agreement.

Implementation of the Management Plan would increase recreational resources for residents of La Verne. Therefore, the No Project Alternative would have no impact on recreational resources, though the City would lose the 208 acres of land acquired through the land grant.

Traffic/Circulation
The No Project Alternative would have no traffic impacts because it would not include the creation of the public access trail that is proposed in the Management Plan. Therefore, traffic impacts for the No Project Alternative would be less than those of the proposed Management Plan. In addition, there would be no need to incorporate new parking along Golden Hills Road for visitors to the Wilderness Area and thus, Mitigation Measure T-1 would not be required. Overall, impacts of the No Project Alternative on transportation and circulation would be incrementally less than those of the proposed Management Plan. 290
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Tribal Resources
The No Project Alternative would not involve the management or minor improvement activities as proposed in the Management Plan. The No Project Alternative would also avoid future improvements in the Wilderness Area that may occur under the proposed Management Plan. Thus, it would eliminate the requirement for Mitigation Measures CR-1 and CR-2. Overall, the No Project Alternative would have less impact on tribal resources than the proposed Management Plan because it would avoid proposed habitat and hazard management activities and minor public access improvements.

7.2 Alternative 2: No Dogs Permitted

7.2.1 Description
As proposed, the Management Plan would allow dogs on the trails in the Wilderness Area, pursuant to the City’s Leash Law (La Verne Municipal Code Section 6.16.070). Under Alternative 2, No Dogs Permitted, visitors to the Wilderness Area would be prohibited from bringing dogs on site, even on a leash. Implementation of Alternative 2 would reduce potential loss of wildlife and habitat destruction from dogs that may get become loose and run off designated trails in the Wilderness Area. Pet waste and noise from dog barking would also be eliminated as potential issues under Alternative 2. Furthermore, an amendment to Section 6.16.080, Animals in Parks, of the La Verne Municipal Code would not be required since dogs would not be permitted in the Wilderness Area under Alternative 2.

7.2.2 Impact Analysis
Biological Resources
Alternative 2 would prohibit all dogs from entering the Wilderness Area with recreational users, and would therefore, eliminate potential for loss of wildlife or habitat damage from dogs that may go off trail. Therefore, Alternative 2 would have incrementally less impact on biological resources than the proposed Management Plan.

Cultural Resources
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on cultural resources. Alternative 2 entails the same management and minor site improvements as the project, and would have similar impacts as those resulting from implementation of the proposed Management Plan.

Hazards and Hazardous Materials
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on the presence, transport, storage, or generation of hazards or hazardous materials. Alternative 2 entails the same management and minor site improvements as the 291
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project, and would have similar impacts as those resulting from implementation of the proposed Management Plan.

Hydrology and Water Quality
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on hydrology or water quality. The trails developed under Alternative 2 would still potentially result in soil disturbance, vegetation clearance, and soil compaction which may create polluted runoff and could violate water quality standards. Thus, Mitigation Measures HWQ-1 and HWQ-2 would be required for Alternative 2, as it would for the project. Alternative 2 entails the same management and minor site improvements as the project, and would have impacts similar to those of the proposed Management Plan.

Land Use and Planning
Alternative 2 would not require an amendment to La Verne Municipal Code Section

6.16.080, Animals in Parks, because leashed dogs would be prohibited from the Wilderness Area. All other land use and planning impacts under Alternative 2 would be comparable to the project, as analyzed in Section 4.5, Land Use and Planning. Therefore, impacts of Alternative 2 would be incrementally less than those of the proposed Management Plan.

Public Services
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on public services. Alternative 2 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan.

Recreation
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on recreational resources. Alternative 2 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan.

Traffic/Circulation
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on traffic or circulation since the dogs would arrive and leave the Wilderness Area with recreational visitors. Mitigation measure T-1, which ensures public safety in determining the placement of parking spaces along Golden Hills Road for recreational access to the Wilderness Area, would apply to Alternative 2. Alternative 2 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan. 292
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Tribal Resources
The presence or absence of dogs on the trail, and in the Wilderness Area at large, would have no impact on tribal resources. Alternative 2 entails the same management and minor site improvements as the project, and would have impacts to those resulting from implementation of the proposed Management Plan.

7.3 Alternative 3: Trail to Lookout Point

7.3.1 Description
Alternative 3 would include the same management and minor site improvements as proposed in the Management Plan except that instead of the 8-foot wide, 0.6-mile loop trail, the project would include a 4-foot wide, 0.75-mile trail leading through the southern portion of the Wilderness Area and up the hill to a vista point. Ground disturbance under Alternative 3 would total approximately 0.4 acres. Alternative 3 would reduce the amount of time recreational visitors would spend in the southern portion of the Wilderness Area, better preserving the privacy of the neighboring homes.

7.3.2 Impact Analysis
Biological Resources
Alternative 3 would eliminate the loop in the lower portion of the Wilderness Area and change the total length of the trail from 0.6 miles to 0.75 miles. However, since the trail to a vista point would only be four feet wide, the area of potential disturbance would be less than that under the Management Plan. The loop trail would result in 0.6 acres of disturbance, whereas the reconfigured trail would result in 0.4 acres of disturbance. The reconfiguration of the trail would decrease potential impacts to biological resources that may occur while grading and building the loop trail, while achieving the same public accessibility as would be provided by implementing the Management Plan. Leashed dogs would still be permitted in the Wilderness Area, and habitat and hazard management activities would also be carried out under Alternative 3. Overall, Alternative 3 would have incrementally less impact on biological resources with a trail that leads directly to a vista point than compared to the trail included in the proposed Management Plan.

Cultural Resources
The reconfiguration of the trail under Alternative 3 would decrease potential impacts to cultural resources that may occur while grading and building the loop trail, while achieving the same public accessibility as would be provided by implementing the Management Plan.

Less ground area would be disturbed in implementing the direct trail under Alternative 3, though Mitigation Measure CR-1 and CR-2 would still apply. Under the Management Plan,

0.6 acres of land would be disturbed, whereas under Alternative 3, 0.4 acres of land would be disturbed for trail enhancements. Alternative 3 would entail the same habitat and hazard management activities as those provided in the Management Plan. Overall, 293
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Alternative 3 would have incrementally less impact on cultural resources due to the shorter trail that leads directly to a vista point than compared to the trail included in the proposed Management Plan.

Hazards and Hazardous Materials
The reconfigured trail in Alternative 3 would have no effect on the presence, transport, storage, or generation of hazards or hazardous materials. Alternative 3 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan.

Hydrology and Water Quality
The reconfigured trail in Alternative 3 would retain more permeable surface area in the southern portion of the Wilderness Area by residential homes, thereby absorbing and conveying more runoff than if the loop trail were implemented under the proposed Management Plan. All other management and minor site improvements under Alternative 3 would remain the same as in the proposed Management Plan. The trail developed under Alternative 3 would still potentially result in soil disturbance, vegetation clearance, and soil compaction which may create polluted runoff and could violate water quality standards.

Thus, Mitigation Measures HWQ-1 and HWQ-2 would be required for Alternative 3, as it would for the project. Overall, hydrology and water quality impacts of Alternative 3 would be incrementally less than those resulting from implementation of the proposed Management Plan.

Land Use and Planning
Alternative 3 would entail the same habitat management and minor site improvements as those provided in the Management Plan. Implementation of the reconfigured trail in Alternative 3 would be comparable in impact to the project, as leashed dogs would still be allowed to visit the Wilderness Area with recreational users, which would require an amendment to Section 6.16.080 of the City’s Municipal Code. Implementation of the management and minor site improvements under Alternative 3 would also require amendments of the underlying land use and zoning designation land use allowances, in order to ensure the Wilderness Area is Open Space and uses are consistent with the land grant. Therefore, Alternative 3 would have land use compatibility impacts comparable to those of the proposed Management Plan.

Public Services
The reconfigured trail in Alternative 3 would have no impact on public services. Alternative 3 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan.
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Recreation
Alternative 3 would increase the total trail length by eliminating the 0.6-mile loop trail and implementing a 0.75-mile trail to a vista point. Though the total acreage of the Wilderness Area would not change, Alternative 3 would provide a slightly longer trail network for recreational use. Public access to the Wilderness Area would still be achieved and consistent with the land grant. Therefore, the overall impact of Alternative 3 on recreational resources would be comparable to that of the proposed Management Plan.

Traffic and Circulation
The reconfigured trail in Alternative 3 would have no impact on traffic and circulation because recreational visitors would still arrive and leave in the same manner as they would under the project. Mitigation measure T-1, which ensures public safety in determining the placement of parking spaces along Golden Hills Road for recreational access to the Wilderness Area, would apply to Alternative 3. Alternative 3 entails the same management and minor site improvements as the project, and would have impacts similar to those resulting from implementation of the proposed Management Plan.

Tribal Resources
The reconfigured trail in Alternative 3 would decrease potential impacts to tribal resources that may occur while grading and building the loop trail, while achieving the same public accessibility as would be provided by implementing the Management Plan. Less ground area would be disturbed in implementing the direct trail under Alternative 3, though Mitigation Measure CR-1 and CR-2 would still apply. Under the Management Plan, 0.6 acres of land would be disturbed, whereas under Alternative 3, 0.4 acres of land would be disturbed for trail enhancements. Alternative 3 would entail the same habitat and hazard management activities as those provided in the Management Plan. Overall, Alternative 3 would have incrementally less impact on tribal resources due to the shorter trail that leads directly to a vista point as compared to the trail included in the proposed Management Plan.

7.4 Alternative Sites
The California Supreme Court, in Citizens of Goleta Valley v. Board of Supervisors (1990), indicated that a discussion of alternative sites is needed if a project “may be feasibly accomplished in a successful manner considering the economic, environmental, social, and technological factors involved” at another site. As suggested in Goleta, several criteria form the basis of whether alternative sites need to be considered in detail. These criteria take the form of the following questions:
1 Could the size and other characteristics of another site physically accommodate the project?
2 Is another site reasonably available for acquisition? 295
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3 Is the timing of carrying out development on an alternative site reasonable for the applicant?
4 Is the project economically feasible on another site? 5 What are the land use designation(s) of alternative sites? 6 Does the lead agency have jurisdiction over alternative sites? 7 Are there any social, technological, or other factors that may make the consideration of alternative sites infeasible?
The City of La Verne is pursuing the proposed Management Plan in order to respond to the stipulations of the land grant which requires public access to the Wilderness Area. The land grant funds were used for the purchasing of the La Verne Wilderness Area and there are no alternative locations for which the Management Plan could be implemented. Therefore, analysis of alternative sites is not warranted.

7.5 Alternatives Considered but Rejected
Section 15126.6 (c) of the CEQA Guidelines requires that an EIR identify those alternatives that were considered but rejected by the lead agency because they either did not meet the objectives of the project, were considered infeasible, or could not avoid or substantially lessen one or more significant effects of implementation of the Management Plan.

As noted in Section 1.1, Environmental Impact Report Background, a public EIR scoping meeting was held on September 20, 2016 for interested individuals, groups, and public agencies a forum to provide input in an effort to assist in refining the intended EIR scope and focus. Based on public input, the three following comments were considered in developing alternatives, but rejected for reasons described below.

7.5.1 USFS Management of Wilderness Area Alternative
The sole management of the Wilderness Area by the United State Forest Service (USFS) was discussed during the scoping meeting and considered during the development of potential alternatives to the project. However, the City determined that such a role taken on by USFS would be infeasible since ownership of the Wilderness Area is under the City, per the grant agreement. One of the main goals and multiple objectives of the project stipulate that the City will collaborate with others in management of the Wilderness Area. To this end, the proposed Management Plan contains actions to coordinate management efforts with appropriate federal, state, or local agencies, such as USFS, to ensure management activities are consistent with plans implemented by neighboring areas such as the San Gabriel National Monument and San Dimas Experimental Forest.

7.5.2 Habitat Management Only Alternative
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conservation, public access, and habitat management issues. Excluding the public access component from the proposed Management Plan would be inconsistent with stipulations of the land grant agreement, and would cause the City to relinquish the 208 acres of land acquired through the grant.

7.5.3 Equestrian and Bicycle Use Alternative
Equestrian and bicycle uses on the Wilderness Area trails were considered. Though such uses are encouraged under implementation measure 1.2.b of the City’s General Plan Resource Management Element (“Encourage multiple trail use for biking, jogging, and equestrian use”), public access and recreational use of the Wilderness Area was determined to be limited due to the presence of sensitive habitats, seasonal risks from wildfires and floods, and steep topography.

The conceptual location for the proposed trail loop was determined based on an existing unofficial trail previously used as a maintenance access route, thereby minimizing potential disturbance or damage to additional habitat areas. The 0.6-mile trail loop would be 8 feet wide. The American Association of State Highway and Transportation Officials’ design guidelines, which is often used by trail designers, recommend a minimum of ten feet for multi-use trails. A 10-foot wide trail to accommodate equestrian and bicycle uses was deemed infeasible when determining design and placement of the proposed trails and likely to disturb a greater amount of vegetation during trail construction than the proposed trails.

Furthermore, the topography along the trail extension portion has the potential to create safety issues for multiple users, even if the trail were wide enough to accommodate all uses. Therefore, though additional multi-uses for the trails would be ideal and consistent with the public access goals of the land grant, physical and environmental constraints present at the Wilderness Area limit the amount of trail development that can occur for safe recreational use.

Therefore, these alternatives would pose no advantage to the alternatives chosen for analysis in this EIR, and have therefore been rejected for inclusion in this EIR. No other alternatives were identified that would feasibly attain most of the basic project objectives and would also avoid or substantially lessen the significant effects of the project.

7.6 Environmentally Superior Alternative
CEQA requires the identification of the environmentally superior alternative among the options studied. When the “No Project” alternative is determined to be environmentally superior, CEQA also requires identification of the environmentally superior alternative among the development options.

The primary objective of the Management Plan is to facilitate the public use of the Wilderness Area as required by the land grant and therefore, the No Project Alternative is not a feasible alternative. The other alternatives would meet most, but not all of the project objectives. Alternatives 2 and 3 would reduce but not avoid the proposed Management 297
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Plan’s significant impacts related to cultural resources, land use and planning, and tribal resources.

Table 20 indicates whether each alternative’s environmental impact is greater than, less than, or similar to those of the proposed Management Plan. As shown in Table 22, when taking every environmental impact area into account, the No Project Alternative is the environmentally superior alternative, followed by Alternative 2, and finally, Alternative 3.

Using this method of analysis, the No Project Alternative and Alternative 2 are environmentally superior to the proposed Management Plan and Alternative 3 is equal to the Proposed Management Plan.

Table 20 Impact Comparison of Alternatives
Issue
Management
Plan:

Highest Impact
Classification
Alternative 1:

No Project
Alternative 2:

No Dogs
Permitted
Alternative 3:

Trail to Lookout
Point
Biological
Resources
III - + =
Cultural Resources II + = =
Hazards and
Hazardous
Materials
III - = =
Hydrology and
Water Quality
II + = =
Land Use and
Planning
II + + =
Public Services IV = = =
Recreation IV - - =
Traffic and
Circulation
II + = =
Tribal Resources II + = =
+ Superior to the proposed Master Plan (reduced level of impact) - Inferior to the proposed Master Plan (increased level of impact) = Similar level of impact to the proposed Master Plan (same level of impact) 298
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Draft Environmental Impact Report 195
8 References

8.1 Bibliography
American Dreams, Inc. 2017. National Registrar of Historic Places. http://www.nationalregisterofhistoricplaces.com/ca/los+angeles/state3.html.

Accessed May 2017.

Bean, Walton. 1968. California: An Interpretive History. McGraw-Hill Book Company, New York.

Bean, Lowell John, and Charles R. Smith. 1978. Gabrielino. In California, edited by Robert F.

Heizer, pp. 538–549. Handbook of North American Indians, Vol. 8, William C.

Sturtevant, general editor, Smithsonian Institution, Washington, D.C.

Beck, Warren A., and Ynez D. Haase. 1974. Historical Atlas of California. University of Oklahoma Press. Norman, OK.

Blackburn, Thomas. 1963. Ethnohistoric Descriptions of Gabrielino Material Culture. Annual Report, Archaeological Survey. University of California, Los Angeles.

Bodkin, John J. 1910. San Gabriel Mission 8th Edition. Los Angeles: J.J. Bodkin Publishing Company.

Brackett, F.P. 1920. “A Brief Early History of the San Jose Rancho and its Subsequent Cities:

Pomona, San Dimas, Claremont, La Verne and Spadra” in History of Pomona Valley, California with Biographical Sketches of the Leading Men and Women of the Valley Who Have Been Identified With Its Growth and Development from the Early Days to the Present. Historic Record Company, Los Angeles, CA.

California Association of Local Agency Formation Commissions. 2011. “California Cities by Incorporation Date”. Accessed September 13, 2016 at http://www.calafco.org/ California Department of Conservation, Division of Land Resource Protection. 2015. The California Land Conservation Act 2014 Status Report – The Williamson Act. http://www.conservation.ca.gov/dlrp/lca/stats_reports/Documents/2014%20LCA% 20Status%20Report_March_2015.pdf. Accessed May 2017.
_____. 2016. Los Angeles County Important Farmland 2014. ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2014/los14.pdf. Accessed May 2017.

California Department of Fish and Wildlife. 2010. Natural Communities List. _____. 2016a. California Natural Diversity Database, Rarefind V. 3.1.0. Accessed August 2016.
_____. 2016b. Biogeographic Information and Observation System (BIOS). http://bios.dfg.ca.gov. Accessed August 2016.
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_____. 2016c. California Natural Diversity Database, Sandra Shanks. Diplectrona californica.

Accessed September 2016.

California Department of Forestry and Fire Protection (Cal Fire). 2011. Very High Fire Hazard Severity Zones in LRA as Recommended by Cal Fire.
http://www.fire.ca.gov/fire_prevention/fhsz_maps/FHSZ/los_angeles/La_Verne.pdf.

Accessed May 2017.
_____. 2017. Communities at Risk List.
http://osfm.fire.ca.gov/fireplan/fireplanning_communities_at_risk. Accessed May 2017.
_____. 2004. California Interagency Watershed Map of 1999 (CalWater 2.2.1). Available at:
http://frap.fire.ca.gov/data/frapgisdata-swcalwater_download.php. Accessed May, 2017.

California Department of Transportation. 2011. California Scenic Highway Mapping System. http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/. Accessed May 2017.

California Department of Water Resources (DWR). 2004. San Gabriel Valley Groundwater Basin – California’s Groundwater Bulletin 118.
http://www.water.ca.gov/groundwater/bulletin118/basindescriptions/4-13.pdf.

Accessed May 2017.
_____. 2003. South Coast Hydrologic Region, Chapter 7. Bulletin 118: California’s Groundwater Update 2003. Sacramento, CA: State of California.

California Energy Commission (CEC). 2009. Integrated Energy Policy Report. http://www.energy.ca.gov/2009publications/CEC-100-2009-003/CEC-100-2009-003- CMF.PDF. Accessed May 2017.

California Fire Alliance. 2017. Communities at Risk.
http://www.preventwildfireca.org/Communities-at-Risk/. Accessed May 2017.

California Geological Survey (CGS). 1999. Earthquake Zones of Required Investigation Glendora Quadrangle.
http://gmw.conservation.ca.gov/SHP/EZRIM/Maps/GLENDORA_EZRIM.pdf.

Accessed May 2017.
_____. 2002. California Geomorphic Provinces. California Geological Survey Note 36.

Sacramento, CA. California Department of Conservation.

California Missions Foundation. n.d. “History of Mission San Gabriel Arcángel”. Accessed September 12, 2016 at http://californiamissionsfoundation.org/mission-san-gabriel/ Church of the Brethren. 2016. “History of the Church of the Brethren”. Accessed September 12, 2016 at http://www.brethren.org/about/history.html
County of Los Angeles. 1996. Resolution of the Board of Supervisors of the County of Los Angeles, Acting as the legislative body of the Los Angeles County Regional Park and 300
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References

Draft Environmental Impact Report 197
Open Space District, levying an additional assessment within the District, amending the method of assessment, and authorizing the expenditure of district revenues for any authorized purpose, subject to approval by the County electorate. _____. 2005. Marshall Canyon Land Acquisition Grant Project.

CRM Tech. 2008. Historical/Archaeological Resources Survey Report: University of La Verne Athletic Complex. La Verne, CA.

Dumke, Glenn S. 1944. The Boom of the Eighties in Southern California. Sixth printing, 1991.

Huntington Library Publications, San Marino, California.

Federal Emergency Management Agency (FEMA). 2013. Federal Guidelines for Dam Safety:

Emergency Action Planning for Dams.
http://www.damsafety.org/media/Documents/FEMA/508_FEMA_P- 64_Fed_Guidelines_for_Dams.pdf. Accessed May 2017.
_____. 2004. South Coast Hydrologic Region: San Gabriel Valley Groundwater Basin. Bulletin 118: California’s Groundwater. Sacramento, CA: State of California. _____. 2008. Flood Insurance Rate Map # 06037C1725F.
https://msc.fema.gov/portal/search?AddressQuery=1950 percent20Third percent20St percent2C percent20La percent20Verne percent2C percent20CA percent2091750#searchresultsanchor. Accessed May 2017.
_____. 2016. Historic Averages for La Verne, California. http://www.intellicast.com/Local/History.aspx?location=USCA0571 . Accessed May
2017.

Guinn, J.M. 1977. Gold! Gold! Gold! from San Francisquito! In Los Angeles Biography of a City, edited by John Caughey and LaRee Caughey. University of California Press, Berkeley.

Harrington, John P. 1942. Culture Element Distributions: XIX, Central California Coast.

Anthropological Records 7. University of California Press: Berkeley.

Historical Society of La Verne. N.D. “A Brief History of La Verne”. Accessed September 12, 2016 at http://www.lavernehistoricalsociety.org/a-brief-history-of-la-verne.html

Hoover, Mildred Brooke, Hero Eugene Rensch, Ethel Grace Rensch, and William N. Abeloe. 2002. Historic Spots in California. Fifth edition. Revised by Douglas E. Kyle. Stanford University Press, Stanford, CA.

IDcide. 2017 La Verne, CA Weather. http://www.idcide.com/weather/ca/la-verne.htm.

Accessed May 2017.

Intellicast.com. 2017. La Verne, California – Historic Average. http://www.intellicast.com/Local/History.aspx?location=USCA0571. Accessed May 2017.

Keesey, Dan. 2016. Department Head, City of La Verne Public Works. Personal Communication: Telephone call. November 16, 2016.
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King, Chester D. 1994. Native American Placenames in the Santa Monica Mountains National Recreation Area, Agoura Hills. Topanga Anthropological Consultants, California.

Kroeber, Alfred J. 1925. Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78. Originally published 1925, Smithsonian Printing Office, Washington, D.C. Unabridged reprint 1976, Dover Publications, Inc. New York.

Langenwalter, Paul E., II, Matthew A. Boxt, Lawrence M. Boxt, M.D., and Theodore T. Miller, M.D. 2001. A Sea Otter (Enhydra lutris) Femur with Embedded Projectile Point Fragment from a Late Prehistoric Camp Site in Long Beach, California. Pacific Coast Archaeological Society Quarterly 37(1).

La Verne, City of. 1998. Small Town Big Future, The City of La Verne General Plan. http://www.ci.la-verne.ca.us/index.php/documents/community-development- planning/general-and-specific-plans/224-la-verne-general-plan/file. Accessed April 2017.
_____. 2006. City of La Verne Parks & Community Services Master Plan Second Update. http://www.ci.la-verne.ca.us/index.php/documents/community- development/general-and-specific-plans/227-la-verne-parks-community-services- master-plan-2006/file. Accessed May 2017.
_____. 2012. Natural Hazard Mitigation Plan for the City of La Verne, CA. http://www.ci.la- verne.ca.us/index.php/documents/community-development-planning/general-and- specific-plans/221-natural-hazard-mitigation-plan/file. Accessed May 2017. _____. 2013. Old Town La Verne – Specific Plan. http://www.cityoflaverne.org/otlvsp.pdf.

Accessed May 2017.
_____. 2014. City of La Verne Community Wildfire Protection Plan. http://www.lavernefire.org/download.cfm?ID=107. Accessed June 2017. _____. 2015. Sage Canyon Residential Project TTM 71373 Initial Study/Mitigated Negative Declaration. LSA Associates, Inc. Laverne, CA. November 30, 2015. _____. 2017a. La Verne Municipal Code. http://www.ci.la- verne.ca.us/index.php/government/municipal-code. Accessed May 2017. _____. 2017b. La Verne Wilderness Area Management and Public Access Plan.

La Verne Fire Department (LVFD). 2017. La Verne Fire Department. http://www.lavernefire.org/ps.home.cfm?ID=1. Accessed May 2017.

La Verne Police Department (LVPD). 2017. La Verne Police Department. http://www.lvpd.org/#Home. Accessed May 2017.

Linscott, Law & Greenspan, Engineers. 2016. Traffic Impact Study: University of La Verne Facilities and Technology Master Plan EIR Project.
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References

Draft Environmental Impact Report 199
Los Angeles County. 2015a. General Plan. Chapter 9: Conservation and National Resources Element. http://planning.lacounty.gov/assets/upl/project/gp_final-general-plan.pdf.

Accessed April 2017.
_____. 2015b. General Plan Appendices.
http://planning.lacounty.gov/assets/upl/project/gp_final-general-plan- appendices.pdf. Accessed April 2017.

Los Angeles County Public Library. 2017. La Verne Library. http://www.colapublib.org/libs/laverne/index.php. Accessed May 2017.

Los Angeles Regional Water Quality Control Board (LARWQCB). 1994. Water Quality Control Plan Los Angeles Region: Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties.
http://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/bas in_plan_documentation.shtml. Accessed May 2017.

Main San Gabriel Basin Watermaster (MSGBW). 2015. Annual Report 2014-2015. Azusa, CA. http://media.wix.com/ugd/af1ff8_1d30b7f8d78e4e74878789c229b343e9.pdf.

Accessed May 2017.

McCawley, William. 1996. The First Angelinos: The Gabrielino Indians of Los Angeles. Malki Museum/Ballena Press Cooperative Publication, Banning or Novato, California.

Mithun, Marianne. 2004. The Languages of Native North America. Reprinted. Cambridge University Press, Cambridge, Massachusetts. Originally published 1999, Cambridge University Press, Cambridge, Massachusetts.

National Park Service. 1990. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Electronic document: https://www.nps

Nevin, David. 1978. The Mexican War. Time-Life Books, Inc., Alexandria, Virginia.

O’Neil, Stephen. 2002. The Acjachemen in the Franciscan Mission System: Demographic Collapse and Social Change. Master's thesis, Department of Anthropology, California State University, Fullerton.

Rincon Consultants. 2017a. La Verne Wilderness Management Plan – Fire Hazards Study. ----. 2017b. Biological Resources Assessment – La Verne Wilderness Area Management Plan.

Rivertech Inc. 2016. La Verne Wilderness Area Management Plan – Flood Hazards.

Rolle, Andrew. 2003. California: A History. Revised and expanded sixth edition. Harlan Davidson, Inc., Wheeling, Illinois.

Russell, Robert. 2016. City of La Verne Fire Department. Fire MarshallCaptain. Personal Communication. Phone Call. December 1, 2016.

Sawyer et al. 2010. A Manual of California Vegetation. Second Edition.

Shumay, Burgess McK. 2007. California Ranchos. 2nd Edition. The Borgo Press. Rockville, MD.
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State Water Resources Control Board (SWRCB). 2010. 2010 Integrated Report, Clean Water Act Section 303(d) List / 305(b) Report.
http://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2010.shtm l. Accessed May 2017.

United States Census Bureau. QuickFacts - La Verne City, California. Population, Census, April 1, 2010. Accessed September 12, 2016 at
http://www.census.gov/quickfacts/table/HSG030210/0640830 United States Environmental Protection Agency (EPA). 2014. San Gabriel Valley Groundwater Cleanup Superfund Progress Report.
https://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/84e3d3f748094337882572330079 4f02/0065ed704ae95ccc88257007005e941e/$FILE/46442366.pdf/SGV percent201_14.pdf. Accessed May 2017.
_____. 2016. “Home.” www.epa.gov. Last modified January 9, 2017. Accessed January 2017.

United States Fish and Wildlife Service (USWFS). 2016a. Critical Habitat Portal. http://criticalhabitat.fws.gov
. Accessed August 2016.
_____. 2016b. Information for Planning and Conservation (IPac). http://ecos.fws.gov/ipac/.

Accessed August 2016.
_____. 2016c. National Wetland Inventory. http://www.fws.gov/wetlands/. Accessed August 2016.

United States Forest Service (USFS). 2017. Special Designation Overlays – Angeles National Forest.
https://www.fs.usda.gov/detailfull/angeles/landmanagement/planning/?cid=stelprd b5329231. Accessed July 2017.

United States Geological Survey (USGS). 2017a. The National Map. https://nationalmap.gov/. Accessed May 2017.
_____. 2017b. National Hydrography Dataset. http://nhd.usgs.gov/. Accessed May 2017.

Workman, Boyle. 1935. The City that Grew. Southland Publication Co., Los Angeles.

Western Regional Climate Center. 2016. Big Dalton Dam FC223, California (040758). https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca0758. Accessed May 2017. 304
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References

Draft Environmental Impact Report 201

8.2 List of Preparers
This EIR was prepared by Rincon Consultants, Inc. under contract to the City of La Verne.

Rincon Consultants, Inc.

Stephen Svete, AICP, LEED AP ND, Principal in Charge
Sally Schifman, Senior Environmental Planner/Project Manager Lynette Leighton, MEM, Associate Environmental Planner
Matthew Long, MESc, Senior Environmental Scientist
Christina McAdams, Senior Biologist
Vanessa Villanueva, Associate Environmental Planner

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Appendix A
La Verne Management and Public Access Plan
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Appendix B
NOP
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Appendix C
Biological Resources Assessment
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Appendix D
Fire Hazards Study Report
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Appendix E
Flood Hazards

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La Verne Wilderness Area
Management and Public Access Plan
Final Environmental Impact Report
SCH#2016091030
prepared by
City of La Verne
Community Development Department
3660 D Street
La Verne, California 91750
Contact: Bill Aguirre, Director of Community Services
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 301
Los Angeles, California 90012
September 2018
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September 19, 2022 City Council Meeting
La Verne Wilderness Area
Management and Public Access Plan
Final Environmental Impact Report
SCH#2016091030
prepared by
City of La Verne
Community Development Department
3660 D Street
La Verne, California 91750
Contact: Bill Aguirre, Director of Community Services
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 301
Los Angeles, California 90012
September 2018
313
September 19, 2022 City Council Meeting
This report p
repared on 50% recycled paper with 50% post-consumer content. 314
September 19, 2022 City Council Meeting
Table of Contents
Final Environmental Impact Report i
Table of Contents
1 Introduction .................................................................................................................................... 1

1.1 The EIR Process ................................................................................................................... 1

1.2 EIR Certification Process and Project Approval .................................................................. 1 2 Response to Comments .................................................................................................................. 3

2.1 Summary of Comments Received ....................................................................................... 3 3 Corrections and Additions to the Draft EIR .................................................................................. 45 Figures
Figure 1 Environmental Review Process ........................................................................................... 2 Appendices
Appendix A La Verne Management and Public Access Plan
Appendix B NOP
Appendix C Biological Resources Assessment
Appendix D Fire Hazards Study Report
Appendix E Flood Hazards
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La Verne Wilderness Area Management and Public Access Plan Introduction Final Environmental Impact Report ii
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La Verne Wilderness Area Management and Public Access Plan Introduction Final Environmental Impact Report 1
1 Introduction

1.1 The EIR Process
This Final Environmental Impact Report (Final EIR) is an informational document prepared by the City of La Verne to evaluate the potential environmental impacts that would result from adoption of the La Verne Wilderness Area Management and Public Access Plan (Management Plan). The primary objectives of the EIR process under the California Environmental Quality Act (CEQA) are to inform decision-makers and the public about a project’s potentially significant environmental effects, identify feasible ways to minimize significant effects, and consider a reasonable range of alternatives to the project. This Final EIR has been prepared with assistance from the City of La Verne’s planning and environmental consultant, Rincon Consultants, Inc. The Final EIR has been reviewed by City staff for completeness and adequacy in accordance with Public Resources Code (PRC) Sections 21000–21177 and the State CEQA Guidelines.

As prescribed by the State CEQA Guidelines Sections 15088 and 15132, the lead agency, the City of La Verne, is required to evaluate comments on significant environmental issues received during the public comment period from persons who have reviewed the Draft EIR and to prepare written responses to those comments. This Final EIR, together with the Draft EIR (incorporated by reference in accordance with State CEQA Guidelines Section 15150) will comprise the Environmental Impact Report (EIR) for this project. Pursuant to the requirements of CEQA, the City of La Verne must certify the EIR as complete and adequate prior to approval of the project or a project alternative.

This Final EIR contains individual responses to each comment received during the public review period for the Draft EIR. In accordance with State CEQA Guidelines Section 15088(b), the written responses describe the disposition of significant environmental issues raised.

1.2 EIR Certification Process and Project Approval
In accordance with the requirements of CEQA (see Figure 1) and the procedures of the City of La Verne, the EIR must be certified as complete and adequate prior to any action on the proposed project. Once the EIR is certified and all information considered, using its independent judgment, the City can take action to go forward with the proposed project, make changes, or select an alternative to the proposed project. While the information in the EIR does not constrain the City’s ultimate decision under its land use authority, the City of La Verne must respond to each significant effect and mitigation measure identified in the EIR as required by CEQA by making findings supporting its decision.
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La Verne Wilderness Area Management and Public Access Plan Introduction Final Environmental Impact Report 2
Figure 1 Environmental Review Process
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La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
2 Response to Comments

2.1 Summary of Comments Received
This section includes the comments received during the 45-day public comment period of the Draft EIR for the proposed Wilderness Area Management and Public Access Plan and responses to all comments that raise significant environmental issues as required under CEQA. Where a comment resulted in a change to the Draft EIR text, a notation is made in the response indicating that the text is revised. Changes in text are signified by strikeouts (strikeouts) where text is removed and by underlined font (underlined) where text is added. As indicated more fully below, these changes do not introduce significant new information or otherwise affect the analysis or conclusions of the EIR such that recirculation would be required under State CEQA Guidelines § 15088.5. Rather, this additional information merely clarifies and amplifies the analysis set forth in the Final EIR.

The Draft EIR was circulated for a 45-day public review period that began on June 30, 2018 and ended on August 14, 2018. The City received eleven written comment letters during this period, including one letter from the State Clearinghouse confirming that the City of La Verne has complied with the State Clearinghouse public review requirements pursuant to CEQA.

The commenters and the page number on which each commenter’s letter appear are listed below.

Letter No. and Commenter Page No.
1 Scott Morgan, Director, State Clearinghouse 4
2 Erinn Wilson
, Environmental Program Manager I, California Department of Fish and Wildlife 7 3 Scott P. Harris, Environmental Scientist, California Department of Fish and Wildlife 20 4 Julie Yom, Park Planner, County of Los Angeles Department of Parks and Recreation 22 5 Katherine Winsor, La Verne Land Conservancy 25
6 John Tarrant, Public 31
7 John Tyre, Public 33
8 Monte and Carole Beesley, Public 35
9 Carolyn Tyre, Public 38
10 Sabina Sullivan, Public 40
11 Anne and Ed Larkin, Public 43
The comment letters and responses follow. The comment letters have been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number.

The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in comment Letter 1).
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ST.{TE OF CA Lt FO RN I.\
ED!IU)iD C- BRO!!I.IR.

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August 15,2018
Candice Bowcock
City of La Veme
3660 D Street
La Veme, CA 91750
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Subject: La Veme Wildemess Area Management and Public Access Plan SCH#: 2016091030
Dear Candice Bowcock:

The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on August 14,2018, and the comments from the responding agency (ies) is (are) enclosed. If this comrnent package is not in order, please notify the Srate Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly.

Please note that Section 2l l0.l(c) ofthe Califomia Public Resouces Code states that:
"A responsible or other public agency shall only make substantive comments regarding those activities involved in a project which are within an area of expertise ofthe agency or which are required to be carried out or approved by the agency. Those cornments shall be supported by specifi c documentation."
These comments are forwarded for use in preparing your hnal environmental document. Should you need more information or clarification of the enclosed comments,-we recommend that you contact the commenting agency directly.

This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the Califomia Environmental Quality Act. Please contact the Statc Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process.

Sincerelv.
tu
Director, State Clearinghouse
Enclosures
cc: Resources Agency
1400 l0thSreer P.0.80x3044 Sacramento,California 95912.3044 I-9 15-322-23t8 FAX 1.916-558-3 184,iwwv.opr.ca.gov
Letter 1

1.1 4
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Document Details Report
State Clearinghouse Data Base
scH# 20r 6091030
Project Title La Verne Wildemess Area Management and Public Access Plan Lead Agency La Verne, Cit of
fype EIR Draft EIR
Desctiption Note: Review Per Lead
In early 2006, the City, through State grant funds obtained in cooperation with the Trust for Public Land and the La Verne Land Conservancy, acquired 208 acres in north La Veme adjacent to 150 acres already owned by the City. This land was combined with 150 acres already owned by the city to create an open space preserve of 358 acres, collectively refened to as the Wildemess Area. The Wildemess Area Management and public access plan includes selective habitat enhancement actions, the resolution of public safety hazards, and opportunities for limited controlled public access as part of the city's stewardship responsibilities for the wildness area. The MP includes goals for specific physical improvements or management policies that would implement the vision for the wilderness area.

Lead Agency Contact
Name Candice Eowcock
Agency City of La Veme
Phone 909-596-8737
emal [email protected]
Address 3660 D Street
City La Veme
Fax
Sfate CA Zip 91750
Project Location
Counly Los Angeles
City La Veme
Region
Lat / Long
Cross Sfreets Brydon Road, Calle Aragon, and Monterey Street, Golden Hills Road, and Mountain Springs Road Parcel No. 8678022900 thru 02, 8678015900
lownship Range Section Base
Proximity to:

Highways 5R210
Airpot'as
Railways
Watetways
Schools Afflerbaugh-PaigeCam
Land Use OS/PR1/5D and Marshall Canyon Estates SP/OS and Hills Project lssues Water Quality; Landuse; Toxic/Hazardous; Archaeologic-Historic; Biological Resources; Drainage/Absorption; Flood PlainiFlooding; Forest Land/Fire Hazard; Pubiic Services; Recreation/Parks; Soil Erosion/Compaction/Grading; Trafilc/Circulation; Vegetation; Wetland/Riparian Reviewing Resources Agency; Department of Fish and Wildlife, Region 5; Cal Fire; Office of Historic Agencies Preservation; Department of Parks and Recreation; Department of Water Resources; Califomia Highway Patroli Caltrans, District 7; Regional Water Quality Control Board, Region 4: Office of Emergency Services, Californiai Department of General Services; Air Resources Board, Transportation Projects; State Water Resources Control Board, Division of Drinking Water, District 6; Native American Heritage Commission; San Gabriel & Lower Los Angeles Rivers & Mountains Conservancy Date Received 0612612018 Statl of Review 0612612018 End ofReview 0811412018 Note: Blanks in data fields result from insufficient information provided by lead aqency. 5 321
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 1
COMMENTER: Scott Morgan, Director, State Clearinghouse
DATE: August 15, 2018
Response 1.1
The commenter confirmed that the Draft EIR was circulated to selected state agencies for review during the 45-day public review period. This letter also acknowledges that the City of La Verne has complied with the State Clearinghouse review requirements pursuant to CEQA. This comment is acknowledged and has been incorporated into the administrative record. No changes to the EIR are necessary to address this comment.

The comment letter notes that comments from a responding agency have been forwarded to the City of La Verne. The responding agency is the California Department of Fish and Wildlife, whose letter is included in this section as Letter 2.
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State of California - Natural Resources Aqencv EoMUND G.8RowNJR.. Governor

DEPARTMENT OF FISH AND WILDLIFE
South Coast Region
3883 Ruffin Road
San Diego, CA 52123
(858) 467-4201
www.wildlife.ca.gov
August 14, 201 B
Candice Bowcock, Senior Planner
City of La Veme Community Development
3660 O Street
La Verne, California 91750
E-mail: cbowcook@cityofl averne.org
CHARLTON H, BONHAM, D,rector
Subject: Draft Environmental lmpact Report (DEIR) for the La Verne Wilderness Aroa and Public Access Management Plan, Los Angeles County, SCH # 2016091030 Dear Ms. Bowcock:

The California Department of Fish and Wildlife (CDFW or Department) received a Notice of Availability of a DEIR from the City of La Verne (City), as lead agency, for the La Verne Wilderness Area and Public Access Management Plan (pro.lect) pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines.

Thank you for the opportunily to provide comments and recommendations regarding those activities involved in the proiect that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources and holds them in trust by statute for all the people of the state (Fish & Game Code, SS 71 1 .7, subd. [a] & 1802; Public Resources Code $ 21070; CEQA Guidelines S 15386, subd. [a]). As trustee, CDFW has jurisdiction over the conservation, protection, and management of fish, wildlife, native planls, and habilat necessary for biologically sustainable populations of those species (|d., $ 1802). For purposes of CEQA, CDFW is mandated to provide, as available, biological expertise during public agency environmental review, focusing on projects/activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Public Resources Code S 21069; CEQA Guidelines S 15381). CDFW expects lhat it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteratron (LSA) regulatory authority (Fish & Game Code, S 1600 et seq.). To the extent implementation of the project as proposed may result in "take" as defined by state law of any species protected under the California Endangered Species Act (CESA; Fish & Game Code, S 2050 et seq.) or slate-listed rare plant pursuant to the Native Plant Protection Act (NPPA; Fish and Game Code $1900 et seq.) authorization from CDFW as provided by the applicable Fish and Game Code will be required.

Qanserving Caffirnia's'lilitdffi Since 1 S 70
Letter 2

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Candice Bowcock, Senior Planner
City of La Veme Community D€v€lopment
August 14, 2018

PROJECT DESCRIPNON SUMMARY
Proponent: City of La Veme
Objective: The Project encompasses 208 acres of land acquired through stat€ grant funds from the Wildlfe Cons€Nation Board (WCB) in cooperation with the County of Los Angeles, the Trust for Public Land, and the La Verne Land Consen€ncy. This granfacquired land was combin€d with 150 acres already owned by the City to create an open space preservo totaling 3S8 acres, collectively refened to as the Wildemess Area. The project provides goals/policies for managemenl and specific physical improvements to impl€ment the vision for the Wildemess Area, including selective habitat enhancemenl, the resolulion of public safety hazards, and providing controll€d public access as parl of the City's stewardship responsibilities. project activities are limiled to minor site improvements such as foot trails, benches, and signage, and would not involve demolition of structures, grading, construclion of new facilities, or use of heavy construction equipment. lmplemontation of all future minor site improvaments in the Management Plan will require further evaluation through the City's development review proc€ss and CEQA process when warranted, and appropriate mitigation measures would be idenlified at that time.

This DEIR includes a discussion of three altematives to the proposed Management plan. Thoy are as follows:
. Alternatlve 1: No project
. Altornative 2: No Dogs Permitted
o Alternative 3: Trail to Lookout Point
Location: The Wildemess Ar€a consists of ten City-ownod parcels lhat is tocated norlh of Golden Hills Road, east of Mountain Springs Ranch Road, and west and northwest of Monlerey Street, Catle Aragon, and Brydon Road in the City of La Veme, Los Angeles County. Elevation on-site ranges fiom 1 ,435 feet in lh€ southwest corner to 3,165 feet in the northeast comer of the site. The Wildemess Area is located within, and sunounded lo the wesunorthwest, norlh, and east by the 2014 San Gabriel Mountains National Monument portion of the Angeles National Forest.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the project's signiticant, or potentially significant, dir€cl and indirect impacts on fish, wildlife, and botanical (biological) resources. Editorial comments or other suggestions may also be included to improve the document. l. Project Descriptlon and Rolated lmpac{ Shortcoming
lmpacts to Riparian Resource8
Comment # 1; The project Management Ptan, under Goal 3, Objectve 3.i, Ac{ion 3.i.1,

southem portion of the Wildemess Area annually.

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City of La Verne Community Dev€lopment
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lssue: CDFW is concorned that the project includes activities that may significantly impact streams subject to nolification under Fish and Game code section 1600 el seg. CDFW has observed that irnpacts to riparian/stream resources ftom implementation of weed abatement activities identified in the Management Plan are generally are not adequately characterized or otherwise addressed.

Specific impacts: The proiect may result in lhe loss and/or degradation of streams and associated watershed function and biologioal diversity.

Uthy impacb would occur: Ground and v€getation disturbing activities associaled with weed abatement including, but not limited to grubbing, trampling, use of herbicides, and driving vehicles would physically remove vegetation or disturb ground surfaces resulting in erosion or otherwise alter existing stresms or their watershed function and associaled riparian habitat. Up- and down-stream drainages and associated biological resources beyond the project area tootprint may also b€ impacted by project+elated sediment or alter€d storm water runoff.

Evidence impacts would be significant: The projecl may substantially adversely affect existing habitat and topography at the project site through the alteration of a stream, which absent specific avoidanco or mitigation, could result in substanlial loss of biological resources and significant erosion or siltation on-site or off-site of the projecl.

Recommended Potentially Feasible Mitlgatlon Measure(s)
Mitigation Measure #1: CDFW has concluded that the project and related activities may result in the substantial alteration of slr6ams. For any such activities, the proiect applicant (or'entit/) must provide wriften nolification to CDFW pursuant to section 1600 et seq. of the Fish and Game Code. Based on lhls notification and oth€r information, CDFW determines whether a LSA agreem€nt with the applicant is required prior lo conducling the proposed activities. A notification package for a LSA agreement may b€ obtained by accessing CDFW'S web site at www.wildlife.ca. gov/habcon/1 600.

CDFW's issuance of a LSA agreement for a project that is subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. As a Responsibl€ Agency, CDFW may consider the CEQA document of the Lead Agency for the p@ect. However, the DEIR cunently do€s not meet CDFW's standard cunently because lt does not adequately delineate/map, characterize or inv€ntory existing stream or riparian resources on-sit6 or identify/quantify project impacts to such resources. To minimize additional requirements by CDFW pursuant to section 1600 et seq. and/or under CEQA, the final CEQA document should fully identify lho potential impacts to lhe stream or riparian resourc€s and provide adequate avoidance, mitigation, monitoring and reporting commitments for issuanc€ of a LSA agreement.

Mitigation measure #2: Any LSA agreement issued for the project by CDFW will condition measures to protect stroamb€ds on-site and up- and down-stream of the project, including erosion and pollution oontrol measures. The LSA may also be conditioned to include r€sour@ avoidance and/or on-site or ofi-site creation, enhancement or restoralion of mitigation lands (with protection and management in perpetuity) to compensate for any direct and/or indirect imoacts to stream or riDarian resources.
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Candioe Bowcock, Senlor Planner
City of La Verne Gommunity Development
August 14,2018

lmpacts to Spscial Status Species.

Comment #l: Page 9 of lhe project Management Plan describes fire hazard risks and states, "filandowners, and in many cases HOAS, are responsible for meeting fire hazard reduction standards on privately owned open spaces within established neighborhoods. Existing woodland understory within 200 feel of existing residences south of the Wildemess Area has been altered by annual vegetation removal since the eady 1980s. The City's Public Works Department manages vegotation managem€nt programs for all City-ownad land, which includes the Wilderness fuea. In addition, the City's Community Wildfire Protection Plan contains fuel modiflcation guid€linas for residential properties in this area and continued adherence to thet plan should conlinue to protect lhese neighborhoods from fire risks, to th€ enent possible.

Continued inter-agency coordination betweon the City of La Verne, Los Angeles County, and neighboring foolhill cities for future fire management would also help lower fire risks.' The proiect llanagement Plan, under Goal 3, Objoc'tive 3.1, Action 3.1.2, Page 2l states, "[i]n cooperation wilh Los Angeles County, prepars a local Brush and Fue! Load Vegetation Management Plan in one year of the Wilderness Area opening to the public, and review the plan every five years.'
lssue: CDFW is concerned that, generally, protection of biological resources by entiti€s performing weed abatement are nol sufficient, and as a result sensitive biological resources may be adversely impactod by such activity. CDFW is concerned that the DEIR and/or Management Plan do not appear to fully describe: 1) if weed abatement activities may r€move or dislurb special status vegelative communitios or sp€cial stalus species; 2) if the City will authorize or does authorize private residences or their agents lo conduct weed abatement in lhe Wilderness Area; and, 3) if preconstruction surveys, avoidance and mitigation measures are or will be utilized during weed abatement activities conducted within the Wilderness Area. In addition, the DEIR and Management Plan should include evaluation of alternatives (including no encroachment) to r€duce impacts from brush cl€aring, including targeted thinning, placemonl of walls, and structural/building features (boxed eves, fire.raled walls and windows, sprinklerc, etc.), especially whare d€velopment occurs adiacent to lhe Wildemess Area. Portions of the Wildemess Area were acquired using grant funding from the WCB to protect native habitat; activiti€s that are destructive to biological resources on the Wild€mess Area may be conlrary to the purpose of the intent of the grand funding agreement with WCB.

For example, th€ projecl site supports coastal prickly pear (Opunfla spp.) sctub and associat€d biological r€sourc€s that could be adversely impacted by weed abatem6nt activities. Prolect impacts to coastal prickly pear scrub should be considered a direct and cumulative impact under CEQA. Coastal cactus scrub is imperiled throughout its.ange including the poect aroa along th6 San Gabriel Fooihills as a result of development, wildfire, and unregulated brush clearing activities. Some coast prickly pear scrub alliances are also considered rare (Sawyer et al. 2008) and should be analyzed as such in the DEIR in determining impact significance, avoidance, minimization, and mitigation measures. Also, cactus and succulents are often considered fir€- resistant plants that are appropriate within fuel management areas, reducing the need to remove these species for fire prot€ction purposes.

Because th€ project site supports coast prickly pear scrub, the polential for tho site to also support coastal cactus wren (Campylorhynchus brunneicapillus) is high. Coastal cactus wren is consid€red a Califomia sp€cies of special concem (SSC). Coastal cactus wren is also

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City of La Verne Community Development
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considered by CDFW as a sensitive bird species of greateEt conservation need in San Diego, Orange, Los Angeles, and Ventura County because it is solely dependent upon cactus patches for reproduction. Pockets of cactus patches also provide vital refugia habitat for coastal cactus wren dispersing lo other areas of habital in southern Califomia and is critical in buffering the effects of habitat losses which can lead to genelic isolation and local extirpation.

Specific impact: Population declines of special status species and v€gelation communities resulting in direct localized extirpation and/or conhibution to their cumulaiive extinction.

Why impact would occura The DEIR do6s not provide information on pr+.construction surveys for special status species and vegetatiw communities during weed abatement actiMties. The DE|Rdoes not appear to include a polioy and/or measure that personnel who perform weed abatement be qualified to recognize and avoid special status biological resources when removing or otherwise managing vegetation. Weed abatement may result in direct mortality or injury to special status biological r€sourc€s frcm activiti€s such as trampling by equipment and pe,sonnel, herbicide use, direc't removal of special status plant species, and altoring bird nesting behavior.

Evidence impact would be significant: The project may have a substantial adverse effect, either directly or through habitat modifications, on a species identified as a candidate, sensitive. or special status sp€cies in local or regional plans, policies, or relations, or by CDFW or the United States Fish and Wildlife Service (FWS). Loss of breeding, foraging and movem€nt (dispersal) habitat for coastal cactus wren or other special status species should be considered a significanl direct and cumulative adverse effect under GEQA without implementing appropriate avoid and/or mitigation measures (CEQA Guidelines SS 15064, 15065, 15125[cl and 15380).

Recommond6d Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: CDFW recommends that prior to any proposed weed abatemenl activiti€s, the DEIR identify a requirement to conduct a biological resources survey and implemenl avoidance/mitigation measures for sensitive species (e.g., cectus wren, coastal gnatcatch€r) that are consist€nl with the resource protective measures described in the DEIR and Management Plan for all lhe other proposed project activities.

Mitigation measures should include (but not be limited to) having qualified biologists perform pre-project surveys for special status sp€cies, employing a biological monitor during all weed abatement activilies to direct avoidance of nesling birds and special status species and v€getation communities, and the r€storation or enhancement of habitat for biological resources disturbed by weed abatement activities. For example, there may be many opportunities for enhancement, restoration and creation of native Opuntr'b spp. cactus scrub and coastal sag€ scrub habital to offset unavoidable project impacts or through the habitat enhancement goals described in the Management Plan.

Mitigation Measure #2: Private prop€rty landowners should not be authorized by the City or other entilies lo perform weed abatemenl or other activities that would impact biological resource within the Wilderness Area without following the biological resource protective measures described above in Mitigation Measure #1.
11 327
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Candic€ Bowcock, S€nior Planner
Clty of La Verne Community D€velopment
August 14, 2018

Comment #2: The DEIR describes efforts to survey for special status spocies to inform avoidance and restoration measures resulting from various proposed project activities. lssue: CDFW is concerned that surv€y efforts described in the DEIR may not include measures for the San Gabriel chestnut snail (Glwtostoma gabrielense), which may occur in the Wildemess Area where suitable habitat exists. San Gabriel chestnut snail has a staie rarity ranking of 32 or imperiled in the state because of rarity due to a very restricted endemic range in Los Angeles County. San Gabriel Chestnul Snail has been documented in several areas in the San Gabriel Mountains including the City of Eradbury and may escape detection by survey biologists because of its small size and secretive behavior.

Specific lmpac.t: The project may result in direct and/or indirect take or injury of San Gabriel chestnut snail orthe loss ils habitat resulting in direct local and cumulative extirpation or extinction of this species (CEQA Guidelines $$ 1506a, 15065, 15125[cl and 15380).

Why impact would occur: lmpacts to San Gabriel chestnut snail could result from vegetation clearing and other ground dislurbing activities resulting in in crushing, filling, or desiccation of aclive snail refugia habitat.

Evidence impacts would be signiflcant Project impacts may continue to result in subslantial adverse efiects, either directly or lhrough habitat modificauons, on any sp€cies identified as a candidale, s6nsitive, or special status species in local or regional plans, policies, or regulalions, or by CDFW or FWS. Adv€rse impacts to San Gabriel chestnut snail or their occupied habitat could continue to b€ significant becaus€ the DEIR does nol provide measures to fully detect for presence of this species and provida adequate take avoidance and habitat mitigation for loss of occupied habitat if prosent.

Recommended Potentially Feasible Mitigation Moasure(s):

Mitigation Measure #l: CDFW recommends the Gity require lhat survey measures be performed on the projoct site by qualified malacologisls with experience in detecting San Gabriel chestnut snail to maximize deteclion and avoidance of this species.

Mitigation Measure #2: The Center for Biological Div€rsily (CBD) has petitioned the United States Fish and Wildlife Service to list the San Gabriel Chestnut snail under the Federal Endangered Species Act (CBD.2017).The petition provides useful information on the habitat r€quirsments, threats and managernent recommendations that the City may find useful in adequately planning proj€ct activities to avoid significant impacts under CEQA for lhis species (see website: hftps://www.biologicaldiversity.org/species/invertebrates/pdfs/2017-San-Gabriel Chestnut_ESA-Petilion.pdf ). Specifically, the p€tition states, existing occupied sites should be protected from all activlties that would alter microsite characteristics, including buffer areas large enough to moderate fluctuations in humidity, temperature, and oth€r environm€ntal characteristics of critical importance to ten€strial mollusks. Care should b€ taken to maintain refugia such as downed wood and debris piles. Nativs plant communities should be maintained around occupied sites to provide shade, food sources, and substrates forfungi. Care should be taken to avoid soil compaction and maintain vegetative litler. Pesticides and horbicides should not be applied in or near snail habitat. Educational signs should b€ insialled and site closures should be considered to protect the San Gabriel chestnut snailfrom recreational impacts on lhe Angeles National Forast."

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City of La Veme Community Development
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Genoral Consadoration for Native Nesting Birds
CommEnt #l: The DEIR on page 58 describes native vegetation that could provide suitable nesting habitat tor avian species occuning within th€ project ar€a and the immediat€ vicinity and states, nesting birds are prot€cted by Califomia Fish and Gamo Code 3503 and the Migratory Bird Treaty Act."
The DEIR describes measures to avoid impacting native nesting birds. One measure included is Policy 4.2. (page 64) titled " Protect and prcseve our natNe plant cammunities and habitats' which states in 4.2,e- to reslrict habitat upset to non-nesting months in accordanc€ with the Migratory Bird Treaty Act.'
lssu€: CDFW is concerned that th6 DEIR primarily focuses prolective measures for native nesting bird on proiect related activities conducted within native vegetative communities only.

The Department is concemed that project activities may result in incidental take of native birds if no additional take avoidance measures are proposed within disturb€d, nonnalive vegetalion where the majority of the propos€d w6ed abatement and habitat restoration will take place.

Citing the Migratory Bird Treaty Act as a proteclive measure to avoid incidental take of native bird species should be clarified in the DEIR considering the Department of Interior's recent interpretation of strictly enforcing incldental take of native birds under the Act (see https://www.doi.gov/sileddoi.gov/files/u ploads/m-37050.pdO.

Specific impact: The project may result in death and injury to native bird eggs or young and th€ disruption of natural bird breeding behavior.

Why impact would occur: Focusing avoidance/minimization measures for native birds during project activities lo areas only within native vegetation may result in inadequate delection efforts and take avoidance of aclive nests during project activities conducted within non-nalive vegetation. Project actiMties lhat could advesely impact nesting birds includes (bul are not limited to) vegetation removal/disturbances, ground disturbances, or any other project related disturbances within or adjacenl to nonnative vegetation that could r€sult in incidental take of native birds.

Evidence impac.i would be significant: Proj€ct impacts may result in substantial adverse effects, €ilher directly or through habitat modifications, on any species identified as a candidate, sensitive, or special stalus species in local or rogional plans, policies, or regulations, or by CDFW or the USFWS, and. The projecl may also impede the use of native wildlife nurcery sites.

Recommended Potentlally Feasible Mliigation Measure(s):

Mltigation Moasure: To reduce proj€ct impacts to native birds to less than signilicant under CEQA, CDFW recommends that the City include, as a condition of project approval, that clearing/dislurbing of any v€gelaton, building demolition and conshuction within any habitat that could support native nesting birds, occuroutside of the peak avian breeding season, which generally runs from February 1"'through Septemb€r 1d (as earty as January 1 for some raptors). lf project construction is unavoidable during the bird breeding season, a qualified biologist with exp€rience in conducling bird breeding surve),s should conduct w€€kly bird surveys for nesting birds during work in the area wilh the firsl surv€y commencing wilhin threo days prior lo initiation of work to ensure that no nesting birds in the proiect area would be

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impacted by the proiect. lf an active neet is identified, a buffer shall be established betw€en the construction activities and the nest so that n€sting activities are not interrupled. Th€ buff€r should be a minimum width of 300-feet (500-feet for raptors) and delinealed using lemporary fencing and remain in effecl as long as construction is occuning or until the nest is no longer active. No project activiti€s shall occur within the fenced nest zone until the young have fledged, are no longer being f€d by the parents, have left the nesl, and will no longer be impacted by the project. Reductions in the n€st buffer distance may be appropriate depending on the avian species involved, ambient levels of hutnan activity, screening vegetation, or other factors.

Comment #5: General Measures for Wlldlife
To minimize impacts to wildlife species, CDFW recommends that the City include the following measure a condition of project approval:

Entrapment Hazard iilnlmization Measur€s: CDFW recommends that open pipes b€ capped in a way to prevent wildlife €ntrapment and mortality. Fence posts and oth€r vertical open pipes such as vent pipes found on restrooms at park settings may create a continuous mortality risk by entrapping wildlife. Hallow pipe structures mimic th€ natural cavities preferred by various wildlife for nesting and other shelter needs. Raptor's talons can become €nlrapped within the boltholes of metal fence stakes resulting in mortality. Metal fence stakes should b€ plugged with bolts or other plugging materials to avoid this hazard. Further informalion on this subiect may b€ found at hftp://kern.audubon.org/deathlcipes. htm.

Comment #6: General lleasures for Public Access
Access Minimization tteieures: To minimize impacts to biological resources from public acc€ss, we recommend that the DEIR and Management Plan identify allowable uses and specify that trails are mnditionally compatible uses within Wildemess Area sublecl to a trails assessmenVstudy to determine the least sensitive location for access. Seasonal restrictions on access and limitations on the extent and type of public use (e.9., hiking, biking and equestrian) may ba necessary to avoidiminimize impacts to biological resources. The Management Plan should also include a policy/requiremenl to close and restore unauthorized trails; eliminate redundant aeressi monitor the extent, intensity, duration and frequency of public access where trails are allowed; and, impl€ment adaplive management measures based on access monitoring and other studies.

III. ENVIRONMENTAL DATA
CEQA requires that information dev€loped in environmental impact reports and negative declaralions be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, $ 21003, subd. [e]).

Accordingly, please report any special status sp€cies and natural communities detected during project surveys to the California Natural Diversity Oalabase (CNDDB). The CNNDB field survey form can b€ found at the following link: http:/Arrrww.dfg.ca.govlbiogeodata/cnddb/pdfs/CNDDB- FieldSurveyForm.pdf. The completed form can be mailed eleclronically to CNDDB at the following email address: [email protected]. The types of information reported to CNDDB can be found at the following link: http://www.dfg.ca.gov/biogeodala/cnddb/plants-and- animals.asp.

2.7 2.8

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Page I of I

FILING FEES
The project, as proposed, would have an impact on fish andlor wildlife resources, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the lead agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying project approval to be operative, vested, and final (Cal. Code Regs, tit. 14, S 753.5; Fish & Game Code, $ 711.4; Public Resources Code, $ 2'1089).

CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the city in identifying and mitigating project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Scott Hanis, Environmental Scientist at (805) 644-6305 or e-mail [email protected].

EnvironmentaI Program Manager I
South Coast Region
ec: Ms. Erinn Wilson, CDFW, Los Alamitos
Mr. Scott Hanis, CDFW, Ventura
Office of Planning and Research, State Clearinghouse, Sacramento References
Center for Biological Diversity. 2017. Petition to the USFWS to Protect the San Gabriel Ghestnut Snail under the Endangered Species Act. 41pp.

Sawyer, J. O., Keeler-Wolf, T., and Evens J.M.2008. A manual of California Vegetation,2'd ed. lsBN 978-0-943460-49-9,

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City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 2
COMMENTER: Erinn Wilson, Environmental Program Manager I, California Department of Fish and Wildlife (CDFW)
DATE: August 14, 2018
Response 2.1
The commenter describes the regulatory authority of CDFW in relation to the proposed project. The commenter states that CDFW is California’s Trustee Agency for fish and wildlife resources, and is a Responsible Agency under CEQA for the proposed project, and as such, may need to exercise regulatory authority regarding impacts to wildlife. No response is necessary to this comment.

Response 2.2
The commenter summarizes the project and states that CDFW will provide comments and recommendations to assist the City in adequately identifying and/or mitigating the project’s impacts on biological resources. No response is necessary to this comment.

Response 2.3
The commenter provides information regarding the risk of impacts to riparian resources as a result of weed abatement activities and states that the impacts from weed abatement activities are not adequately characterized or addressed. The commenter provides two recommended mitigation measures including notification to CDFW to determine whether a Lake and Streambed Alteration (LSA) agreement would be required for the proposed activities and implementation of the LSA if issued.

The Management Plan includes goals, objectives and actions which provide the framework for physical improvements or management policies that would implement the vision for the Wilderness Area. Specific physical improvements or management actions that will be guided by the plan have not been defined at this time. The Management Plan prohibits disking and generally proposes weed abatement within coast live oak woodland/grassland areas and low-lying areas of the wash in the southern portion of the Wilderness Area; however, the specific methods and locations of weed abatement have not been established at this time and as such are not defined in the plan or EIR. In addition, Action 3.1.2 of the Management Plan requires facilitators of the Management Plan to prepare a local Brush and Fuel Load Vegetation Management Plan in cooperation with Los Angeles County. The Brush and Fuel Load Vegetation Management Plan will further define specific methods and locations of weed abatement/fuel modification with the Plan Area.

The Draft EIR is clarified as follows to include a general discussion of impacts to riparian resources resulting from weed abatement:

The proposed alterations associated with the Management Plan are limited to minor site improvements, including a 0.6-mile-long, 8-foot-wide foot trail loop, benches, and signage, weed abatement, and fuel modification, which would not utilize heavy construction equipment.

Although the intensity of construction equipment utilized for the proposed alterations would likely be limited to hand tools, and potentially loading trucks and an occasional backhoe for large tree removal, temporary construction activities and permanent management activities 16 332
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La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
associated with implementation of the Management Plan would still have the potential to interfere with existing plant and wildlife species, sensitive natural communities, aquatic resources, and protected trees.

In addition to current City standards in the Municipal Code and General Plan in place to protect and preserve biological resources, implementation of these objectives and actions in the Management Plan and the limited size and accessibility of the proposed foot trail, as well as limited size of areas proposed for weed abatement and fuel modification, would further ensure that impacts to special-status plants, special-status wildlife species, sensitive natural communities, riparian habitats, and protected trees throughout the Plan Area would be less than significant.

The Management Plan includes weed abatement to restore the southern wash corridor and provide wildfire and flood hazard management which may impact riparian resources.

Specifically, Action 3.1.1 of the Management Plan states that weed abatement shall occur in low-lying areas of the wash in the southern portion of the Wilderness Area annually. While the specific methods and locations of weed abatement have not been established at this time, weed abatement activities are designed to improve habitat quality of the wash and surrounding wilderness area. Weed abatement activities would be implemented consistent with current City standards in the Municipal Code and General Plan as well as objectives and actions in the Management Plan designed to protect and preserve biological resources. Specifically, Action

1.1.7 requires special status species surveys prior to any work in sensitive areas, The Management Plan identifies several objectives for the goal of preserving and enhancing wildlife habitat, corridors, and diversity including Action 1.1.9 which requires facilitators of the Management Plan to “coordinate with appropriate federal, state, or local agencies, such as the U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management activities in riparian areas,.” And Action 1.2.2 requires revegetation with appropriate native species.

Therefore, the goals and actions of the proposed Management Plan in combination with existing federal and state regulations would reduce potential impacts to riparian areas as a result of minor improvements in the Wilderness Area remainto less than significant levels.

Impacts to riparian resources would remain less than significant as detailed in the EIR.

Response 2.4
The commenter provides information regarding the risk of impacts to special-status vegetation communities (i.e., coast prickly pear scrub) and associated special-status species (i.e., coastal cactus wren and coastal gnatcatcher) as a result of weed abatement activities. The commenter expresses concern that the EIR does not sufficiently address the potential impacts of weed abatement activities or require sufficient pre-construction surveys for special-status species. The commenter provides two recommended mitigation measures including conducting pre-construction surveys and implementing avoidance /mitigation measures for sensitive species prior to weed abatement activities and prohibiting private property landowners from performing weed abatement in the Wilderness Area without conducting pre-construction surveys and implementing avoidance/ mitigation measures for sensitive species.
17 333
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Please refer to Response 2.3 above which describes weed abatement as currently identified in the Management Plan and clarified the Draft EIR (Page 67, Paragraph 1 and Page 69, Paragraph 1) to include a general discussion of impacts to special-status vegetation communities and special-status species resulting from weed abatement. Please also refer to Action 1.1.6 of the Management Plan which requires avoidance of vegetation removal and management activities within the Coast Prickly Pear Scrub sensitive vegetation community and within areas that provide habitat to sensitive plant and wildlife species and Action 1.1.7 of the Management Plan which requires special status species surveys to be conducted prior to any vegetation removal in sensitive areas. As discussed in the EIR, impacts to special-status plants, special-status wildlife species, and sensitive natural communities, throughout the Plan Area would be less than significant.

Response 2.5
The commenter expresses concern that the EIR does not address impacts on the San Gabriel chestnut snail, which may be present in the plan area. The commenter provides two recommended mitigation measures including requiring biological surveys to be conducted by a qualified malacologist and citing a Center for Biological Diversity petition to list the San Gabriel Chestnut snail under the Federal Endangered Species Act.

San Gabriel chestnut snail is not addressed in the EIR as it was not identified by the United States Fish and Wildlife Service (USFWS) Environmental Conservation Online System (ECOS), or the California Natural Diversity Database (CNDDB) as known, or with potential, to occur within the vicinity of the Wilderness Area. In addition, San Gabriel chestnut snail is not a state or federally threatened or endangered species, nor is it a California Species of Special Concern (SSC). As described in the EIR, implementation of the Management Plan would be consistent with current City standards in the Municipal Code and General Plan as well as objectives and actions in the Management Plan in place to protect and preserve biological resources. Specifically, Action 1.1.7 of the Management Plan which requires special status species surveys to be conducted prior to any vegetation removal in sensitive areas. Compliance with current City standards and implementation of the objectives and actions in the Management Plan and the limited size and accessibility of the proposed foot trail, as well as limited size of areas proposed for weed abatement and fuel modification, would further ensure that impacts to special-status species (including San Gabriel chestnut snail) throughout the Plan Area would be less than significant.

Response 2.6
The commenter expresses concern that the DEIR primarily focuses on protective measures for native nesting birds within native vegetative communities, and does not address impacts to nesting birds within disturbed, nonnative vegetation where the majority of the weed abatement and habitat restoration activities are proposed. The commenter provides a recommended mitigation measure to avoid project activities during the peak of the avian breeding season or to conduct a preconstruction nesting bird survey within three days of initiation of work and weekly during work activities with implementation of no work buffers as needed.

As described in the EIR, weed abatement and habitat restoration activities would be implemented consistent with current City standards in the Municipal Code and General Plan as well as objectives and actions in the Management Plan designed to protect and preserve biological resources. Please refer to General Plan Policy 4.2(e) which restricts habitat upset to non-nesting months in accordance with the Migratory Bird Treaty Act and Action 1.5.3 of the Management Plan which requires tree trimming or removal to take place outside of nesting bird season. 18 334
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Response 2.7
The commenter recommends that the City include a measure as a condition of project approval that open pipes be capped and metal fence stakes be plugged to prevent wildlife entrapment and mortality.

Wildlife habitat conservation is one of the four goals of the Wilderness Plan. Several objectives are identified for the goal of preserving and enhancing wildlife habitat, corridors, and diversity. As such the Wilderness Plan will be implemented to enhance wildlife habitat in the Plan Area. In addition, Action 1.1.8 of the Management Plan restricts management activities that would prohibit wildlife movement through the Wilderness Area.

Response 2.8
The commenter provides recommendations regarding minimizing impacts to biological resources from public access including season trail restrictions, closure/restoration of unauthorized trails, monitoring of public access and implementation of adaptive management.

Please refer to Actions 1.1.3, 1.1.4, 1.1.5, 2.2.1 of the Management Plan which include installation of public access control signing and railings, decommissioning and restoration of volunteer trails, and restricting public access during rain, flooding, periods of extreme fire danger. Please also refer to Goal #5 (Actions 5.1.1 – 5.6.5) and Action 7.1.1 which establish criteria for controlled public access including adaptive management through phased public access and annual use monitoring.

Response 2.9
The commenter provides information regarding CEQA requirements to report any special status species and natural communities detected during project surveys to the California Natural Diversity Database (CNDDB). No response is necessary to this comment.

Response 2.10
The commenter provides information on the payment of filing fees payable upon filing of the Notice of Determination by the lead agency and to help defray the cost of environmental review by CDFW.

No response is necessary to this comment.
19 335
September 19, 2022 City Council Meeting
Candice Bowcock
From:

Sent:

To:

Subject:

Harris, Scott P.@Wildlife <Scott.P.Harris@wildlife,ca.gov> Wednesday, July 11, 2018 4:37 PM
Candice Bowcock
La Verne Wilderness Area Mot. Plan DEIR
Hi Candice,
I'm reviewing the subject DEIR and wanted to know ifthere is a discussion in the Biological Resources lmpact section (or anywhere else) on how fuel modification is expected to impact biological and botanical resources. Also I was wondering if any adjacent private developments will be allowed to use the Wilderness Area as part of their required fuel modification. I did read something about the Marshall Canyon S.P. fuel mod. but I think that it will be kept w.i. the development areas and not enter the Wilderness Park? lt is often the fuel mod. activities that can have the greatest impacts on bio. resources in natural open space management areas so I was wondering where that is discussed in the DEIR. For exam ple, some cities use personnel that do a great job of clea ring brush but they do not have the expertise to perform preconstruction surveys for special status species before they remove vegetation and this can be quite damaging. I read that the city Fire Dept. staff will perform ongoing fuel mod in the Park? Also I noticed that cactus scrub is located in the Wilderness Park. ls there a discussion on surveying for Coastal Cactus Wren w.i. the coast prickly pear scrub described within the Park (if Project proposals including fuel mod. will impact this)? | did a word search for cactus wren but nothing came up. I noticed that CA Gnatcatcher was called out as a species to be surveyed for. Thank you.

Scott P. Harris
Environmental Scientist
California Department of Fish and Wildlife Habitat Conservation Planning 308 S. Dunning 5t.

Ventura, CA 93003
Scott.p. ha rris(awild life.ca.gov
(805) 644-6305
CDFW is California's Trustee Agency for fish and wildlife resources, and holds those resources in trust by statute for all the people of the State. CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those soecies.

SaveOurwater.com * Drought.CA.gov
Letter 3

3.1 3.2
20 336
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 3
COMMENTER: Scott P. Harris, Environmental Scientist, California Department of Fish and Wildlife Habitat Conservation Planning
DATE: July 11, 2018
Response 3.1
The commenter notes that fuel modification activities can impact biological resources, and requests clarification on fuel management and mitigation of the impacts of fuel management.

Please refer to Response 2.3 above.

Response 3.2
The commenter asks if Coastal Cactus Wren is discussed, including discussion of fuel management impacts on the species.

Please refer to Response 2.4 above.
21 337
September 19, 2022 City Council Meeting

COUNTY OF LOS ANGELES

DEPARTMENT OF PARKS AND RECREATION
"Parks Make LIfe Befter!'
' John Wicker, Dlrector Norma E. Garcia, Chief Deputy Olrector July 25,2018
Ms. Candice Bowcock
Senior Planner
Community Developm€nt Department
City of La Veme
3660 D Street
La Veme, CA 91750
Dear Ms. Bowcock:

NOTICE OF AVAILABILITY OF A

DRAFT ENVIRONMENTAL IMPACT REPORT(DEIR) FOR THE
LA VERNE WILDERNESS AREA IIT|ANAGEIUENT AND pUBLtC ACCESS PLAN Thank you for the opportunity to review the Draft Environmental lmpact Report (ElR) for the La veme wildemess Area Management and public Access plan (project). The Draft EIR has been reviewed for potential impacts on facilities operated and'maintained by the Los Angeles county Depadment of Parks and Recreation (DpR). please see our comments below:

Paqe 145, 4.7 Recreation
Please revise the paragraphs in this section as follows:

Marshall Canyon Regional Park and Nursery
Marshall canyon Regional Park and Nurserv, located at 6s50 stephen Ranch Road, is approximately 0.7 wile east of the wilderness Area. lt is a 64{! 1i9,74-acre regionalpark located in an unincorporated area of Los Angeles county, manaoed bv the countv Deoartm-ent of Parks and Recreation. The R€cieFaLeeG_con16in5 s--1gg-s€rc,€€s a trail
staoino area with oerformance arena. horse trail. hiking trail, tree nurserv.volb]6lil court. orouD camDinq site. an outdoor staoe and a oicnic area.

Please add the following paragraphs because Marshall canyon Golf course, Marshall canyon Equestrian center, and Marshalt canyon staging Aiea are separale facilities, not combined with Marshall Canyon Regional park and Nursery.

Marshall Ganvon Golf Course
Mpjs.hgll canvgn Golf course is located at 6100 North steohens Ranch Road. lt is a 186.15-acre oolf -u* in
"n unin*rooot d ar"" of LotAno"l". co*tu. 6Enu*-d-6u
Planning and Dsvalopnsnl lgency . 1000 s. Frenont Avenue, unlt *40, Athambr'. cA 91m3. (626) 588s322 Letter 4

4.1 4.2
22 338
September 19, 2022 City Council Meeting
Ms. Candice Bowcock
July 25,2018
Page2
the,. Countv Deoartment of Parks and Recreation. lt is cateqorized as a special use facilitv ald contains a 18-hole course featurino rollino tenain and scenic sitls nestled in the San Gabriel Mountains.

Marshall Canvon Equestrian Center
Mqrshall Canyon Eqggstrian Center is located at 7OO0 Esperanza Road in an unilmroofteO area of los
P"rks anC Recreation. lt is
"

5.8-"cr"
"o""i"l u." fa.ilitu. rutri"h -nt"ins an
"qr"rtri"nfacilitv with boardino facilitles. trail staoinq area with oerformance arena. and ttorse trail Marshall Canvon Staolnq Area
Mqrshall canvon staoino Area is located at 6300 block of stephens Ranch Road in an uniryorooeteA areg ot l-oPark.
"nd
R""ru"tion. lt i. '1.9-""re. in rir"
"nd ""t"oorir"d ". " -Ek"tJiru roEilii
use.

Thank you for including this Department In the review of this document. should you have any questions or require addlflonal information, please feel free to contact me at(626) 588-531 1 or [email protected] Sincerely, II
\tl
hv-^*'* /frV\I
Julie Yom. AICP
Park Planner
JY:CL;,ly
c: Parks and Recreation (K, King, C. Lau)
23 339
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 4
COMMENTER: Julie Yom, Park Planner, County of Los Angeles Department of Parks and Recreation
DATE: July 25, 2018
Response 4.1
The commenter provides corrections of erroneous information in the EIR regarding the description of Marshall Canyon Regional Park, and provides additional information about the park. The Draft EIR is corrected as follows:

Marshall Canyon Regional Park and Nursery, located at 6550 Stephens Ranch Road, is approximately

0.7 mile east of the Wilderness Area. It is a 640 118.74-acre regional park located in an unincorporated area of Los Angeles County, managed by the County Department of Parks and Recreation. The Regional Park contains a trail staging area with performance arena, horse trail, tree nursery, volleyball court, group camping site, an outdoor stage and a picnic area. a 180-acre golf course, three-acre nursery, an equestrian center, nature trails, and picnic areas. The Marshall Canyon Trail connects to trails in the Angeles National Forest and allows hikers to traverse into the City of La Verne.

Response 4.2
The commenter points out that Marshall Canyon Regional Park and Nursery, Marshall Canyon Golf Course, Marshall Canyon Equestrian Center, and Marshall Canyon Staging Area are separate facilities, and provides descriptions of each. The information provided by the commenter is included in the Final EIR by inclusion of the full text of the comment letter. 24 340
September 19, 2022 City Council Meeting

TIIE LA VERNE LAND CONSERVANCY
August 14, 201 8
Ms. Candice Bowcock
Senior Planner
Community Development Department
City of La Verne
3660 "D" Street
La Verne, CA 91750
Re: Comments Regarding the La Verne's Draft Environmental lmpact Report and Wilderness Area Management and Public Access Plan
Dear Candice,
The La Verne Land Conservancy (LVLC) has reviewed the La Veme Wilderness Area Management and Public Access P/an (Management Plan) dated May 2018 and corresponding Draft Environmental lmpact Repoft (DEIR) dated April 2018. LVLC has been consistently and aclively involved in the La Verne Wilderness Area from the initial acquisition of the parcels in 2005 through the current efforts by the City to evaluate optrons for the continued protection and possible enjoyment of the open space by the community. lt has been our goal over the pasl 1 1 years, to not only ensure the protection and preservation of lhe valuable biological resources within the wilderness area, but to come up with a viable plan that would provide members of the community with opportunities to enjoy the wonderful area through a variety of passive recreational oursuits.

We appreciate the efforts, time and funds expended by the City to develop the Management Plan and the DEIR; it has been 10 years since the last effort to develop a management strategy for the open space, so we are happy to be moving forward! We also understand the difficulty in attempting to create a plan that addresses all of the various, and at times opposing, objectives and needs for the open space.

We agree with the findings of the DEIR with some exceptions. Our concerns and comments regarding both documents are provided below.
1) The DEIR was completed after the City had created a draft of the Management Plan, and it appears it was written to help bolster the strategies and outcomes presented in the Management Plan. By attempting to tt the DEIR into the confines of the "goals" of the Management Plan, the merits ofthe DEIR are lessened, i.e., findings that should have been unbiased are now biased.
2) The Management Plan identifies flood control as an objective, and as consequence, the DEIR addresses flood control. Both documents clearly state that while flooding may be an issue in the foothills above La Verne, "managing" those flood waters (i.e., construction of flood control features such as debris basins) is not allowed on the parcels purchased with State and County grant funds. The DEIR should focus on "managing the open space" not managing floods. We do not believe that discussing options or opportunities for managing Letter 5

5.1 5.2
25 341
September 19, 2022 City Council Meeting
3)
Ms. Candice Bowcock August l4,2018
potential flood waters is appropriate in either document. The documents should be focused on the environmental threats associated with allowing some limited human access in the wilderness areas, not on controlling a flood event that may happen regardless of whether people are allowed in the open space or not. We suggest that the City address managing potential floods in a separate study/document.

On page 3 of the DEIR, three alternatives to the Management Plan are presented:

Alternative 1 : No Project, Alternative 2: No Dogs Permitted, and Alternative 3: Trail to Lookout Point. The DEIR addresses the "No Project" alternative and concludes that while this alternative may be environmentally superior, it "would not achieve any of the project objectives" and because the primary objective of the Management Plan is to "facilitate the public use of the Wilderness Area as required by the land grant," the No project Alternative is not a feasible alternative. Alternative 2, No Dogs Allowed, would not change the usage of the open space, and any concerns would be mitigated by dogs being leashed.

Alternative 3, Trail to Look Out Point, appears to be the best alternative reviewed: the trail would essentially require the same amount of soil disturbance (0.4 acres), it would reduce the amount of time visitors would spend in the southern portion of the Wilderness Area better preserving the privacy of the neighboring homes; it would decrease potential impacts to biological resources that may occurwhile grading and building the Ioop trail, while achieving the same public accessibility; it would retain more permeable surface area in the southern portion of the Wilderness Area by residential homes thereby absorbing and conveying more runoff than if the loop trail were implemenled, and it would entail the same habitat management and minor site improves as those provided in the Management Plan.

This alternative also meels the City of La Verne's General Plan (1998) Policy 1.2, under Resource Management: Develop a connecting trail system. While this alternative was identified in DEIR as being preferable to the "No Project" alternative and environmentally similar to the Management Plan (i.e., the loop trail), no details were provided in either the Management Plan or the DEIR regarding where the "lookout point" was or what the trail would look like - no maps or descriptions were provided in either document. We support Alternative 3 but would like to have seen some details regarding the alternative presented both documents.

The Management Plan has described creating a "loop trail" that is 6 feet wide behind the homes on Monterey. This area, which is degraded, will not provide the "hikers" or trail users with an experience that warrants spending City funds to develop, maintain or manage. lt is highly unlikely that trail enthusiasts would venture onto the loop trail to merely walk in a circle, on a dirt "track," behind houses (and soon to be sandwiched between the homes on Monterey and the planned Sage Canyon development), in an area that is unattractive, and will only provide limited shaded areas.

The loop trail does not provide the community "reasonable public access" as required by the grant documents. The 5 acres where the loop would be built represent only 2.4% of the open space that was given to the City in 2005 (purchased using County and State funds) or only 1.4ok of the total open space in north La Verne. As stated above, one of the City's own General Plan objectives was to "connect trails." The loop trail does not constitute a trail 3)
4)
7407 EoorHtLL BouLEv^Rrt, PMB 773
LA VERNE, CALtEoRNtA 91 750
(909) 223-7293

5.3 5.4

5.5 26
342
September 19, 2022 City Council Meeting
Ms. Candice Bowcock August 14,2018
connection. We recommend that if this trail is constructed, it be done with the intention of connecting it at later date with trails that extend further into the wilderness area. 5) DEIR: lmpact HWQ-1: Hydrology & Water Quality: Soil disturbance may create polluted run- off. Construction is not allowed on the protected open space; installation of trails and benches will not require the development of a Spill, Prevention, Control and Countermeasures (SPCC) plan. The plan prescribes "hazardous materials handling procedures for reducing the potential for a spill during construction." Because construction is not allowed, such a Dlan is not needed.
6) DEIR lmpact T-1: Transportation and Traffic: Locating all parking spaces on the north side of Golden Hills Road significantly reduces the number of parking spaces available.

Installation of a crosswalk, with striping and lights seems excessive.

Finally, the LVLC has been in discussions with the Trust for Public Land (TPL) and the Watershed Conservation Authority (WCA) [part of the San Gabriel and Lower Los Angeles Rivers and Mountains Conservancy (RMC)I about the possibility of expanding the protected areas in North La Verne, and the potential for transferring the City-owned open space to the WCA as part of regional plan aimed at connecting open space areas across the San Gabriel Mountain foothills. TPL is actively engaged in talking with property owners and both TPL and WCA are interested in discussing the possibilities with the City of La Verne. Acquisition of one or two additional parcels in North La Verne could dramatically improve the potential for connecting trails, and the same time would ensure the protection of some very unique riparian habitat. We recommend that the City be available for future discussions with TPL and WCA, and be open to the possibility of expanding the open space areas and extending the trail network.

We appreciate the opportunity to submit our comments regarding the Draft Environmental lmpact Report and Wilderness Area Management and Public Access Plan, and look foMard to working with the City as this project progresses.

Sincerelv.
e/,2;--
Katherine Winsor
President
La Verne Land Conservancy
cc: Members of the La Verne Land Conservancy, via e-mail 7407 FoorHrLL B0ULEVARD, PMB 773
LA VERNE, CALtFoRNtA 91750
(909) 223-1293

5.6 5.7

5.8 27
343
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 5
COMMENTER: Katherine Winsor, La Verne Land Conservancy (LVLC) DATE: August 14, 2018
Response 5.1
The commenter states that the EIR was completed after the Management Plan was drafted, and is therefore biased.

The EIR was prepared in the typical order of events for a project that is in the CEQA environmental review process. This process involves evaluating the potential environmental impacts of a proposed project. In this case, the proposed project is implementation of the Management Plan, which is what the EIR specifically addresses. Updates to the Management Plan were prepared and reviewed by City staff prior to commencing the CEQA analysis. As demonstrated in this Comments and Responses section, the Management Plan has been further amended as a result of information provided by various commenters.

Response 5.2
The commenter expresses the opinion that the EIR should focus on managing open space and that discussing flood management is not appropriate in the EIR or the Management Plan, because flooding may occur regardless of whether or not human access is allowed in the plan area.

Stipulations within the state grant that allowed for the purchase of the plan area prohibit flood control projects within the grant lands. However, due to concerns raised by immediate neighbors to the Wilderness Area, the Management Plan includes a goal to address flooding hazards for the reasonable purposes of providing a safe user experience for the public and to protect downstream neighborhoods, particularly after wildfire events. The Management Plan therefore provides a conceptual plan for constructing basins to manage heavy loads of woody debris that could be carried downstream and result in flooding, even though construction of these basins is currently prohibited. Any agreement at a later date to allow for debris basins would require additional CEQA analysis.

The EIR discusses flooding as part of a comprehensive analysis of environmental impacts of the proposed project. Flooding is discussed in the EIR whenever it is pertinent to impact analysis, and is specifically discussed, as required, in relation to the impact significance thresholds listed in Section

4.4, Hydrology and Water Quality.

Response 5.3
The commenter expresses a preference for Alternative 3 over the proposed project and the other alternatives.

The commenter’s preference for Alternative 3 is noted and is herewith shared with the City’s decision makers for their consideration.

Response 5.4
The commenter states that the loop trail is proposed for an area that is degraded, unattractive, and unshaded, and that trail enthusiasts will not be interested in the trail. 28 344
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
This opinion does not conflict with or challenge the analysis and conclusions of the EIR. However, the commenter’s statements regarding the quality of the trail site are herewith shared with the City’s decision makers for their consideration.

Response 5.5
The commenter expresses the opinion that the proposed loop trail does not access enough of the plan area to constitute providing the community with “reasonable public access.” The commenter adds that the trail does not meet the City General Plan objective of connecting trails, and recommends that if the City constructs the proposed trail, that there should be an intention to connect it at a later date with trails that extend further into the plan area.

As the commenter notes, the trail in the proposed project does not connect to other trails.

However, the EIR analysis determined the Management Plan to be consistent with the City of La Verne General Plan Policy 1.2, “develop a connecting trail system,” under Resource Management Goal 1, “an attractive, safe, and accessible parks and recreation system.” Discussion of consistency notes that the loop trail provides access to the Wilderness Area while preserving and managing the area’s wildlife habitat. Further, the policy regarding development of a connecting trail system does not mandate specific trail connections. The comment is herewith shared with the City’s decision makers for their consideration.

Response 5.6
The commenter states that a Spill Prevention, Control and Countermeasure Plan is not necessary because construction is not allowed in the plan area.

Mitigation Measure HWQ-1, requiring a Spill Response Plan and Spill Prevention, Control and Countermeasure Plan addresses the pollution risks associated with the following activities: soil disturbance associated with creation and/or improvement of the loop trail; installation of benches, signage, and property-line fencing; removal of non-native vegetation; and re-vegetation activities.

These activities may involve construction equipment, such as a backhoe or a loading truck. While direct contamination of surface water is unlikely, there is a potential for creating polluted runoff that violates water quality standards. The mitigation measure helps to reduce impacts to a less than significant level.

Response 5.7
The commenter states that locating all parking spaces on the north side of Golden Hills Road reduces the number of parking spaces, and that installation of a crosswalk with striping and lights seems excessive.

Locating parking spaces on the north side of Golden Hills Road would allow visitors to access the plan area without crossing a street after parking. The installation of a crosswalk with additional safety features would occur if locating all of the parking spaces on the north side of Golden Hills Road is determined not to be feasible. In such a case, the City Engineer would be consulted to help determine what safety features are necessary. It can be further noted that a crosswalk would also benefit users that choose to access the Wilderness Park on foot from areas south of Golden Hills Road.
29 345
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Response 5.8
The commenter informs the city that the LVLC has been in discussions regarding expanding the protected areas in North La Verne and transferring the City-owned open space to the Watershed Conservation Authority. The commenter recommends that the city participate in discussions about expanding open space areas and extending the trail network.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration. 30 346
September 19, 2022 City Council Meeting
Candice Bowcock
From:

Sent:

To:

Subject:

John Tarrant <[email protected]>
N4onday, July 02, 201.8 4:Q2 PM
Cand ice Bowcock
La Verne Wilderness Area l,,4anagement
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Candice,
Overall I must say that I like the plan as submitted. lwould much prefer that it included a trail leading up to Sunset Ridge Motorway. Even if it is phase ll in the process. I believe we need to give community legalaccess to this beautiful wilderness.

Thanks...

John Tarrant
5165 Mountain Springs Ranch Road
La Verne, Ca. 91750
Letter 6

6.1 31
347
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 6
COMMENTER: John Tarrant
DATE: July 2, 2018
Response 6.1
The commenter states support for the Management Plan and for providing public access to the plan area. The commenter expresses a preference for a trail that leads to the Sunset Ridge Motorway.

These comments do not conflict with or challenge the analysis and conclusions of the EIR. However, the comments are herewith shared with the City’s decision makers for their consideration. 32 348
September 19, 2022 City Council Meeting
August 9, 2018
Candice Bowcock Senior planner
Community Development Depaft ment
3660 D. st.

La Verne, CA 91750
fi e.-irtiitdEme ss fi estori t io n
Ms. Bowcock and the City Managers of La Verne
I am totally opposed to the proi
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52OO N. IRvvINDALE AVENUE, SUITE I70
IR\^/INDALE, CALIFORNIA 9I706
OFFICE: 626-960-0061 FAX: 626-337-3593
WWWTYRELAWFIRI,l.COM
Letter 7

7.1 7.2

7.3 33
349
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 7
COMMENTER: John Tyre
DATE: August 9, 2018
Response 7.1
The commenter expresses opposition to the Management Plan, and states that as an adjacent homeowner, the loop trail will destroy his privacy and backyard view.

To protect the privacy of adjacent neighbors, the Management Plan includes a number of design features and mitigation measures. These include: designated parking spaces and overflow parking signage; property line fencing, where not already existing, to separate the public access area from private property; signage addressing respect for neighbors; limited hours of public access use; prohibiting bicycles and equestrians; and requiring dogs to be leashed.

CEQA analysis of aesthetics does not involve analysis of views from individual homes. However, as described in Section 5.1 of the Draft EIR, Aesthetics, the Management Plan involves minor site improvements and construction activities that are not anticipated to cause significant permanent adverse impacts on the plan area’s aesthetics.

Response 7.2
The commenter states that noise, trash, and destruction from increased visitation will kill the plan area’s trees and animals.

Section 4.1 of the EIR, Biological Resources, assesses the potential impacts of the project on wildlife.

Because of increased visitation to the plan area, there would be a potential for adverse impacts to wildlife. However, due to the limited size and accessibility of the proposed loop trail and the limitations on access (pedestrian activities only, day use only, leashes required for dogs), impacts on habitats and special-status species would be less than significant. In addition, the Management Plan includes several objectives for the goal of preserving and enhancing wildlife habitat, corridors, and diversity, including monitoring and restoration activities, and the California Department of Fish and Wildlife has provided recommendations for reducing impacts to biological resources.

Response 7.3
The commenter states that a major rain storm will destroy the trail area.

Section 4.4 of the EIR discusses flood hazard management and acknowledges that trail construction would involve soil compaction, which can reduce infiltration capacity. However, the compacted area would remain semi-permeable and be distributed over only a very small portion of the total drainage area. Adherence to best practices and coordination with appropriate agencies would further reduce the flood hazard impacts associated with the proposed project. 34 350
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August 10,2018
Candice Bowcock, Senior Planner
Community Development Department
3660 D Street
LaVeme Califomia 9l 750
Subject: Draft Environmental Impact Report
We are writing to you in regards to the above Report and plans for opening up the wilderness area to the public behind our home on Monterey St. in LaVeme.

We are very concerned with many things regarding this project as we will explain in the points below:
l. Our privacy will definitely be infringed upon with people coming and going behind our home.

2. Our concem also for this wall or fence being placed directly behind our wall.

3. Parking on Golden Hills and Monterey when Golden Hills is full.

4. Concem about taxpayers having to pay for this project maintainance and liability.

5. The value plus money paid with a ratio for value.

6. Signs being posted.

We are absolutely opposed to this project and plead with you to reconsider. We are sure ifyou we in our position you would feel the same as our property values will definitely decrease. This project is not necessary.

In conclusion we would like to know what would be done to protect from fires etc. With people going back there and careless regard for the property our properties are at risk.

In the past we have seen very little attention given to this area.....we have ugly k rails that have been placed and never adjusted for floods. Care ofthe field consists ofgoats grazing which leaves much ground subject again to fires. Now with this project we predict more negligence and again the property owners are at risk. Also this in not an equal opportunity project for all citizens.

Signed
Monte and Carole Beesley
7127 Monterey St.

LaVeme, CA 91750
Letter 8

8.1 8.2

8.3 8.4

8.5 8.6

8.7 8.8
35 351
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 8
COMMENTER: Monte and Carole Beesley
DATE: August 10, 2018
Response 8.1
The commenters state that their privacy as neighboring homeowners will be infringed upon due to increased visitation.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 7.1 provides information regarding protection of privacy for adjacent neighbors.

Response 8.2
The commenter expresses concerns about construction of walls or fences that would be built behind preexisting walls or fences.

The Management Plan proposes property line fencing as needed, where it does not already exist.

Action 5.6.5 of the Management Plan calls for consultation with immediate adjacent neighbors to plan the location and design of fencing.

Response 8.3
The commenter expresses concerns about where visitors will park.

The Management Plan proposes new parking spaces for visitors and signage identifying appropriate overflow parking.

Response 8.4
The commenter expresses concern about taxpayers having to pay for the project’s maintenance and liability.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 8.5
The commenter expresses concern about the cost and value of the project.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 8.6
The commenter expresses concerns about signage on the project site.

The Management Plan proposes signage to direct visitors to the public access area, as well as management and safety signs that address wildlife habitat, respect for neighbors, and access restrictions.
36 352
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Response 8.7
The commenter expresses concern about maintenance of the project, including unattractive features, vegetation management, and fire hazards.

The Management Plan describes maintenance and management of the plan area in Goal #6, which addresses coordination with agencies and interested parties, and Goal #7, which addresses providing sufficient onsite presence for management needs. Smoking and fires would be prohibited in the plan area, and a Brush and Fuel Load Vegetation Management Plan will be prepared within one year of the Wilderness Area opening to the public.

Response 8.8
The commenter states that the project is not an equal opportunity project for all citizens.

The Management Plan provides public access to the plan area. Providing public access was a condition in the grant funding agreement that allowed for the purchase of the land. 37 353
September 19, 2022 City Council Meeting
Candice Bowcock
From:

Sent:

To:

Subject:

Carolyn Tyre < [email protected] >
Monday, August 13, 2018 12:1.4 PM
Candice Bowcock
DEIR Project
Cand ice Bowcock Senior Planner
Aug 12th 2018
Dear Sirs,
This letter is to relate my feelings and thoughts on the DEIR Project.

I am very much against it. My house backs up to the wilderness area and I am concerned about the noise, pollution, my backyard privacy and environment deterioration . The parking, traffic and security are also concerning.

Please consider this a "NO" vote and I will see you at the meeting in October.

Thank you
Carolyn Tyre
Letter 9

9.1 38
354
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 9
COMMENTER: Carolyn Tyre
DATE: August 12, 2018
Response 9.1
The commenter expresses opposition to the Management Plan. The commenter states that as an adjacent neighbor to the plan area, there are concerns about noise, pollution, privacy, environmental damage, parking, traffic, and security.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration. 39 355
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August 13, 2018
Comments on DEIR: La Verne Wilderness Area Management and Public Access Plan Submitted by: Sabina Sullivan,5140 Parkfield Land, La Verne, CA 1) BIO - Path construction materials are not stated so the impact of trail construction is unclear.

DG or treated clay would provide for those with limited mobility. lf used for accessibility, these materials are non-native and their impact not addressed in the DEIR. 2) BIO - The M P does not include perimeter fencing to the north or east. lf not included; then, the DEIR must address off-site impacts due to visitors leaving the footpath to hike the hills to the no rth.
3) REC - The proposed MP indicates a limited barrier at the east end of the site. Visitors are easily able to walk around it and access private properties farther east. This was not addressed in the DEIR.
4) Aesthetics - Perimeter fencing is to be selected and sited in consultation with adjacent residents. Signage too is required; however, it is not included in the consultation directives or addressed specifically in the DEIR.
5) HAZ - The statement wildland fire and fire exposure will continue to exist is true; however, the find ing that implementation of the M P will not directly impact fire exposure is false. Fire exposure increases with increased public access. This was not addressed in the DEIR. 6) HAZ - Bow hunting during the fall and winter months is permitted in the hills above the proposed site. The probability of high velocity arrows entering the MP area will be a hazard to visitors. This was not addressed in the DEIR.

Letter 10

10.1 10.2

10.3 10.4

10.5 10.6
40 356
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 10
COMMENTER: Sabina Sullivan
DATE: August 13, 2018
Response 10.1
The commenter states because it is unclear what materials would be used on the paths, the impacts of trail construction are unclear.

The composition of the trail surface would consist of natural materials with a firm and stable surface. While a more specific determination of materials has not yet been made, the trail would be constructed based on the guidelines contained in the U.S. Forest Service Trail Construction and Maintenance Notebook. Adherence to these guidelines would minimize the amount of loose and unstable soil following construction, reducing the potential for erosion and polluted runoff.

Response 10.2
The commenter states that because the Management Plan does not include perimeter fencing to the north or east, the EIR should address the impacts of visitors leaving the footpath to hike the hills to the north.

Signage at key locations will inform visitors of where public access is allowed and prohibited. The EIR analysis does not assume that visitors will not abide by public access limits.

Response 10.3
The commenter states that the Management Plan calls for a limited barrier at the east end of the site, and that the impacts of visitors walking around the barrier to access private properties should be addressed.

Signage at key locations will include statements regarding respect for the privacy of adjacent neighbors. Signage will also include a trail map to inform visitors what areas are available for public access.

Response 10.4
The commenter states that the EIR does not call for consultation with neighboring residents regarding selection and placement of signage.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 10.5
The commenter states that increased public access will increase the risk of wildfire.

The Management Plan describes actions to address wildfire risks, including: banning fires for recreation or maintenance; prohibiting smoking; weed abatement and fuel management; and preparation of a local Brush and Fuel Load Vegetation Management Plan. 41 357
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Response 10.6
The commenter states that bow hunting occurs in the hills above the project site, and that there is a risk of arrows entering the Management Plan area.

The commenter’s safety concerns regarding bow hunting are herewith shared with the City’s decision makers for their consideration. At the City’s direction, the plan can be amended to prohibit bow hunting equipment on the park property.
42 358
September 19, 2022 City Council Meeting
Candice Bowcock
From:

Sent:

To:

Subject:

Anne Larkin < [email protected] >
Tuesday, August 14,2018 6:18 PN4
Candice Bowcock
La Verne Wilderness Area Management and Public Access Plan proposed project To: La Verne Planning Commission
Project: La Verne Wildemess Area Management and Public Access Plan We hope that the TEN city-owned parcels of land plus the 150 acres already owned by La Veme in the San Gabriel Mountains National Monument will remain as wilderness.

We ask that you continue to leave the land as an open space preserve - available to wildlife and not human life.

Negative possibilities:

Insurance liability
Risk of accidents to human life
Risk of accidents to animal life
Trampling of important grasses, etc.

Rescues of human life
Fire dangers
Necessities for adding humans to the area:

Parking lot
Safe enclosures for hiking, walking, etc
Picnic safe areas
Marking of boundaries
Trash pick up
Policing for possible drug havens
In the past six months, we who live at 2306 del Marino have noted that one young mountain lion strolled through the back yard. Bobcats have been seen in our back yard on several occasions.

Let's not take away any more of the area that they need for their survival.

Thank you,
Anne and Ed Larkin
2306 del Marino
La Veme, CA 91750
4qrpfu rki ni?roaclrulrncr.com
Letter 11

11.1 11.2

11.3 11.4
43 359
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Response to Comments Final Environmental Impact Report
Letter 11
COMMENTER: Anne and Ed Larkin
DATE: August 14, 2018
Response 11.1
The commenters state a preference for the plan area to remain as a wilderness, without human intrusion.

One of the conditions attached to the grant funding that allowed for the purchase of the plan area was to allow public access. Therefore, the City was obligated to develop a plan that would provide visitation opportunities. The Management Plan allows public access on a small peripheral portion of the plan area, while keeping the vast majority of the land undisturbed.

Response 11.2
The commenters list the following as potential negative impacts of the proposed project: insurance liability, risk of accidents to human life, risk of accidents to animal life, trampling of important grasses, rescues of human life, and fire dangers.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 11.3
The commenters list the following as necessities for dealing with increased visitation to the plan area: parking lot; safe enclosures for hiking, walking, etc.; picnic safe areas; marking of boundaries; trash pick-up; policing for drug havens.

This comment does not conflict with or challenge the analysis and conclusions of the EIR. However, the comment is herewith shared with the City’s decision makers for their consideration.

Response 11.4
The commenters note that mountain lions and bobcats have been sighted in the plan area, and state support for preserving the habitat for such animals.

The Management Plan includes goals related to both wildlife habitat conservation and public access.

The location and siting of the public access to the plan area will reduce impacts to wildlife, while meeting the public access condition described in Response 3.1. 44 360
September 19, 2022 City Council Meeting
City of La Verne
La Verne Wilderness Area Management and Public Access Plan Corrections and Additions to the Draft EIR Final Environmental Impact Report
3 Corrections and Additions to the Draft EIR
The following section provides a summary record of all proposed text corrections, changes, and additions to the Draft EIR. These changes are the result of document review during the public review period. These changes serve to clarify and amplify the content of the EIR. None of the changes would result in alterations to degree of impact or conclusions presented in the Draft EIR, and therefore do not constitute significant new information, in accordance with CEQA Guidelines section 15088.5. Rather, the changes serve to clarify and strengthen the content of the EIR.

Accordingly recirculation is not warranted. Revisions to the Draft EIR text are shown using strikethrough to show where text has been deleted and underline font to show where text has been added.

Section 4.1 Biological Resources
Section 4.1.3 Impact BIO-1 (Page 67)
The proposed alterations associated with the Management Plan are limited to minor site improvements, including a 0.6-mile-long, 8-foot-wide foot trail loop, benches, and signage, weed abatement, and fuel modification, which would not utilize heavy construction equipment.

Although the intensity of construction equipment utilized for the proposed alterations would likely be limited to hand tools, and potentially loading trucks and an occasional backhoe for large tree removal, temporary construction activities and permanent management activities associated with implementation of the Management Plan would still have the potential to interfere with existing plant and wildlife species, sensitive natural communities, aquatic resources, and protected trees.

Section 4.1.3 Impact BIO-1 (Page 69)
In addition to current City standards in the Municipal Code and General Plan in place to protect and preserve biological resources, implementation of these objectives and actions in the Management Plan and the limited size and accessibility of the proposed foot trail, as well as limited size of areas proposed for weed abatement and fuel modification, would further ensure that impacts to special-status plants, special-status wildlife species, sensitive natural communities, riparian habitats, and protected trees throughout the Plan Area would be less than significant.

Section 4.1.3 Impact BIO-2 (Page 70)
The Management Plan includes weed abatement to restore the southern wash corridor and provide wildfire and flood hazard management which may impact riparian resources.

Specifically, Action 3.1.1 of the Management Plan states that weed abatement shall occur in low-lying areas of the wash in the southern portion of the Wilderness Area annually. While the specific methods and locations of weed abatement have not been established at this time, weed abatement activities are designed to improve habitat quality of the wash and surrounding wilderness area. Weed abatement activities would be implemented consistent with current City standards in the Municipal Code and General Plan as well as objectives and actions in the 45 361
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La Verne Wilderness Area Management and Public Access Plan Corrections and Additions to the Draft EIR Final Environmental Impact Report
Management Plan designed to protect and preserve biological resources. Specifically, Action

1.1.7 requires special status species surveys prior to any work in sensitive areas.

The Management Plan identifies several objectives for the goal of preserving and enhancing wildlife habitat, corridors, and diversity including Action 1.1.9 which requires facilitators of the Management Plan to “coordinate with appropriate federal, state, or local agencies, such as the U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management activities in riparian areas,.” And Action 1.2.2 requires revegetation with appropriate native species.

Therefore, the goals and actions of the proposed Management Plan in combination with existing federal and state regulations would reduce potential impacts to riparian areas as a result of minor improvements in the Wilderness Area remainto less than significant levels.

Section 4.7 Recreation
Section 4.7.1 Setting (Page 145)
Marshall Canyon Regional Park and Nursery, located at 6550 Stephens Ranch Road, is approximately 0.7 mile east of the Wilderness Area. It is a 640 118.74-acre regional park located in an unincorporated area of Los Angeles County, managed by the County Department of Parks and Recreation. The Regional Park contains a trail staging area with performance arena, horse trail, tree nursery, volleyball court, group camping site, an outdoor stage and a picnic area. a 180-acre golf course, three-acre nursery, an equestrian center, nature trails, and picnic areas.

The Marshall Canyon Trail connects to trails in the Angeles National Forest and allows hikers to traverse into the City of La Verne.
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Community Service Department and
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Cover image: Northern Mixed Chaparral community at the western edge of the La Verne Wilderness Area, facing southwest © Rincon Consultants, Inc. 2016

La Verne Wilderness Area
Management and Public Access Plan

City of La Verne
Community Service and Community Development Departments 3660 D Street
La Verne, California 91750

prepared with the assistance of

Rincon Consultants
250 East 1st Street, Suite 301
Los Angeles, California 90012

2M Associates
Box 7036
Landscape Station
Berkeley, California 94707
June 2018
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La Verne Wilderness Area Management and Public Access Plan

City of La Verne i
Table of Contents
Vision .......................................................................................................................................... 1 Existing Conditions ...................................................................................................................... 1 Regional Setting ....................................................................................................................... 1 La Verne Wilderness Area ........................................................................................................ 2 Wildlife Habitat Conditions ...................................................................................................... 4 Watershed Conditions.............................................................................................................. 6 Jurisdictional Waters and Wetlands ..................................................................................... 6 Wildfire Conditions .................................................................................................................. 9 Existing Public Access Conditions ............................................................................................. 9 Management and Public Access Plan History ............................................................................. 11 Background ............................................................................................................................ 11 Intent and Purpose ................................................................................................................ 12 Goals, Objectives, and Actions ................................................................................................... 13 Wildlife Habitat Conservation Goals ....................................................................................... 13 Goal #1: Preserve and Enhance Wildlife Habitat Corridors and Diversity .......................... 15 Public Safety Goals ................................................................................................................. 16 Flood Risk .......................................................................................................................... 17 Goal #2: Provide Flood Hazard Management ................................................................... 20 Wildfire Risk ...................................................................................................................... 20 Goal #3: Provide Wildfire Hazard Management ............................................................... 21 Public Access Goals ................................................................................................................ 21 Goal #4: Provide a Tranquil and Safe Visitor Experience ................................................... 25 Goal #5: Provide Controlled Public Access ....................................................................... 26 General Management Goals ................................................................................................... 27 Goal #6: Cooperate with Others in Management of the Wilderness Area ......................... 27 Goal #7: Provide Sufficient Onsite Presence to Manage the Wilderness Area ................... 28 Goal #8: Reflect Changes in Surrounding Use and Ownership Conditions ......................... 28 Goal #9: Obtain Sufficient Funds to Assure Full Implementation of the Management Plan29 Implementation ........................................................................................................................ 31 Priorities ................................................................................................................................ 31 References ................................................................................................................................ 33

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ii Community Services and Community Development Departments List of Figures
Figure 1 Project Location ................................................................................................................... 3 Figure 2 Wilderness Area Vegetation ................................................................................................ . 5 Figure 3 City of La Verne Rivers and Major Tributaries ....................................................................... 7 Figure 4 Wilderness Area Riverine and Freshwater Forested/Shrub Wetlands ................................... 8 Figure 5 Wilderness Area Habitat Enhancement Opportunities ....................................................... 14 Figure 6 Recommended Locations of Woody Debris Racks .............................................................. 18 Figure 7 Conceptualized Woody Debris Rack ................................................................................... 19 Figure 8 Conceptual Public Access ................................................................................................... 23 Figure 9 Conceptual Public Access: Inset ......................................................................................... 24

List of Tables
Table 1 Vegetation Communities ....................................................................................................... 4 Table 2 Implementation Priorities for Individual Goals .................................................................... 31

Appendices
Appendix A Wilderness Area Vegetation and Wildlife species Appendix B Public Workshop Summaries
Appendix C Estimated Implementation Costs

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La Verne Wilderness Area Management and Public Access Plan

City of La Verne 1
Vision
The Wilderness Area is a place where natural resources are managed for diversity. Through controlled public access, it offers a sense of tranquility where individuals and small groups can safely visit to experience, enjoy, and learn. The Wilderness Area is a benefit to its immediate neighbors and the city as a whole.

View of Northern Mixed Chaparral along western portion of La Verne Wilderness Area, facing west. ©Rincon Consultants, Inc. 2016. 369
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Vision

2 Community Services and Community Development Departments

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City of La Verne 1
Existing Conditions
Regional Setting
The city of La Verne is located in the foothills of the San Gabriel and Pomona calleys in the eastern portion of Los Angeles County. The entire incorporated area measures approximately 9.09 square miles. La Verne is bordered by unincorporated portions of Los Angeles County to the north, Claremont to the east, Pomona to the south, and San Dimas to the west. La Verne is located on a broad alluvial fan at the foot of the San Gabriel Mountains. The mountain range serves as a striking backdrop to the City on its northern edge. A variety of land holdings in the northern portions of La Verne are preserved as open space, and areas north of these areas are encompassed in the Angeles National Forest and the San Gabriel Mountains National Monument.

The Angeles National Forest was established by Executive Order in December 1892 and covers approximately 700,000 acres. The Forest, including the San Gabriel Mountains National Monument, provides open space to more than 15 million people living within 90 minutes of the area, and provides a portion of the drinking water to Los Angeles. The land within the Forest is as diverse in appearance and terrain as it is in the opportunities it provides for enjoyment. Elevations range from 1,200 feet to the 10,064-foot Mt. San Antonio, nicknamed Mt. Baldy. Much of the Forest is covered with dense chaparral that shifts to pine and fir-covered slopes at the higher elevations.

San Gabriel Mountains National Monument sign, image courtesy USDA Forest Service. 371
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Existing Conditions

2 Community Services and Community Development Departments The San Gabriel Mountains National Monument (Monument) is located primarily in the Angeles National Forest and measures 346,177 acres. The Antiquities Act of 1906 grants the President or Congress the authority to designate national monuments in order to protect “objects of historic or scientific interest.” The Monument was established in 2014 and is the eighth Forest Service- managed national monument. The Monument is the heaviest used area in the Angeles National Forest, which receives more than four million visitors per year. Hiking, biking, horseback riding, off- highway vehicle use, fishing, hang-gliding, hunting and picnicking are just a few of the recreational activities in the Monument.

Deep canyons, many with perennial streams, provide crucial habitat for rare and unique wildlife, including the California condor, the California spotted owl, bighorn sheep, and 1,000-year-old limber pines. The Monument is also rich with cultural and historic sites. Within the Monument, more than 600 archeological sites exist including several rock art and cupules features exist, the concentration of which is unique to southern California. Two Native American rock art sites are listed on the National Register of Historic Places.

La Verne Wilderness Area
In 2006, the City of La Verne (City), acquired 208 acres in north La Verne through State grant funds obtained in cooperation with the County of Los Angeles, the Trust for Public Land, and the La Verne Land Conservancy. This land was combined with 150 acres already owned by the City to create an open space preserve of 358 acres, collectively referred to as the Wilderness Area. Figure 1 depicts the location of the Wilderness Area boundaries in relation to the City.

The Wilderness Area is located north of Golden Hills Road, east of Mountain Springs Ranch Road, and west of Stephens Ranch Road. Elevation onsite ranges from 1,435 feet in the southwest corner to 3,165 feet in the northeast corner. Based on a review of historic aerial photographs, the Wilderness Area has been maintained in the same largely natural condition since at least 1994. The Wilderness Area is located partially within, and surrounded to the west/northwest, north, and east by the Angeles National Forest and the recently-designated San Gabriel Mountains National Monument. Residential developments are adjacent to the Wilderness Area along Divot Drive to the southwest and along Monterey Street, Calle Aragon, and Brydon Road to the south. The majority of the Wilderness Area consists of open space and mostly undeveloped land. The southwestern corner of the Wilderness Area, along Monterey Street, has been disturbed by mowing activities and a fire road (Sunset Peak Mountainway) traverses the western and northern portions of the Wilderness Area. The remainder of the Wilderness Area is relatively undisturbed and covered in dense vegetation.

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City of La Verne 3
Figure 1 Project Location

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Existing Conditions

4 Community Services and Community Development Departments Wildlife Habitat Conditions
The Wilderness Area consists of relatively undisturbed dense native vegetation with the exception of a few disturbed areas along the southern edge of the Wilderness Area and along the fire road. As shown in Table 1 and depicted in Figure 2 below, eight vegetation communities or land cover types were mapped within the Wilderness Area.

Table 1 Vegetation Communities
Vegetation Community Acreage
Annual Brome Grassland 7.8
California Sagebrush-Black Sage Scrub 7.6
Chamise-Black Sage Chaparral 7.3
Chamise-Laurel Sumac Scrub 251.1
Coast Live Oak Woodland 69.6
Coast Live Oak Woodland/Grass 4.1
Coast Prickly Pear Scrub* 2.9
Developed/Disturbed 12.7
Total Vegetation 363.11
Notes:
*sensitive plant community
1 Acreage counts are approximate as the vegetation communities do not stop and start at the exact boundary lines of the Wilderness Area
The biota of the Wilderness Area is characterized by of large expanses of chaparral, scrub and woodland habitats that provide suitable habitat for several general and special status wildlife species. A full list of vegetation and wildlife species that potentially inhabit the Wilderness Area is included in Appendix A. Native trees (e.g., coast live oak, laurel sumac, California sycamore) and shrubs (e.g., chamise, California sagebrush) that could provide suitable nesting habitat for several common avian species occur within the Wilderness Area and the immediate vicinity. Among the communities mapped with the Wilderness Area, coast prickly pear scrub is considered a sensitive plant community. The California Natural Diversity Database (CNNDB) records 19 sensitive plant species, five sensitive plant communities, 25 sensitive wildlife species, and four sensitive natural communities either in the boundaries of or within the five–mile search radius of the Wilderness Area (CA Department of Fish and Wildlife 2016a and 2016b). The four sensitive natural communities include: Canyon Live Oak Ravine Forest, Riversidean Alluvial Fan Sage Scrub, Southern California Arroyo Chub/Santa Ana Sucker Stream, and Southern Sycamore and Alder Riparian Woodland. 374
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City of La Verne 5
Figure 2 Wilderness Area Vegetation

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Existing Conditions

6 Community Services and Community Development Departments Watershed Conditions
The City of La Verne lies in the San Gabriel River Basin between the San Jose Hills to the south and the San Gabriel Mountains to the north and is surrounded by creeks, washes, and drainages flowing southward off the northern mountains. Three main drainages, San Dimas Wash, Live Oak Creek, and San Jose Wash, collect in a small basin at the northeast of the San Jose Hills, which contains Puddingstone Reservoir. The Emerald Flood Control Channel runs north-south, along “B” Street.

The City of La Verne, including the Wilderness Area, lies in the San Gabriel River Watershed. The watershed drains into the San Gabriel River from the San Gabriel Mountains flowing 58 miles south until its confluence with the Pacific Ocean. Major tributaries to the San Gabriel River include Walnut Creek, San Jose Creek, Coyote Creek, and numerous storm drains entering from the 19 cities that the San Gabriel River passes through. Figure 3 depicts the rivers and major tributaries of the City.

The Wilderness Area consists of vacant, natural open space encompassing several steep, relatively small canyons that drain into a single unimproved watercourse and end at an outlet located at Golden Hills Road. As a consequence, the Wilderness Area and land downstream have been subject to flooding during heavy rain events. Local hydrology studies suggest that prior to any development in the canyon, a system of debris basins be constructed to protect existing and future development downstream. However, pursuant to conditions contained in the grant funding agreement, no flood control improvements are allowed in the 208-acre portion of the Wilderness Area purchased using grant funds.

Jurisdictional Waters and Wetlands
According to the National Wetlands Inventory (USFWS 2016), several riverine and freshwater forested/shrub wetlands are mapped throughout the Wilderness Area (Figure 4). The majority of the mapped features are located in dry upland areas of the watershed and do not contain evidence of flows or riparian vegetation. These areas likely convey runoff during heavy storm events from the upper portions of the watershed to the drainage feature that runs northeast/southwest along the southern portion of the Wilderness Area. The drainage feature along the southern portion of the Wilderness Area contains evidence of flows and scattered riparian vegetation (California sycamore, blue elderberry, mulefat) and connects to the storm drain system after it leaves the Wilderness Area at a private drive, which extends north of Divot Drive at Golden Hills Road. A formal jurisdictional delineation of waters and wetlands is required to comprehensively identify potential jurisdictional aquatic resources within the Wilderness Area and to determine whether the riverine and freshwater forested/shrub wetlands mapped by the National Wetlands Inventory are subject to United States Army Corps of Engineers (USACE), California Department of Fish and Wildlife (CDFW), and/or the Los Angeles Regional Water Quality Control Board (RWQCB) jurisdiction. 376
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Figure 3 City of La Verne Rivers and Major Tributaries

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Existing Conditions

8 Community Services and Community Development Departments Figure 4 Wilderness Area Riverine and Freshwater Forested/Shrub Wetlands

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Wildfire Conditions
The City of La Verne is one of 1,289 communities in California identified as a “community at risk” by the California Department of Forestry and Fire Protection (CAL FIRE). The City is also designated a Hazard Level Code of “3,” which indicates the highest fire threat level. CAL FIRE used three main factors to determine which communities were at risk and their level of fire threat. These factors were: 1) high fuel hazard, 2) probability of a fire, and 3) proximity of intermingled wildland fuels with urban environments.

There are many types of ignition sources resulting in wildland fires including natural (e.g., lightning strikes) and human (accidental or deliberate). The highest risk of fire occurrence comes from human activity, as lightning is a rare event in the lower elevations of the San Gabriel Mountains. Vegetative clusters, which are fuel for ignitions, can be noted along San Dimas Canyon Road, Live Oak Canyon Road, throughout portions of unincorporated La Verne, and near Sycamore Canyon in San Dimas.

Arson fires originating along San Dimas Canyon Road to the north of the Project Site are a concern and have the potential to rapidly impact the Wilderness Area and residential neighborhoods to the south.

The greatest wildfire threat to the City comes from fires spreading from the Angeles National Forest or from undeveloped Los Angeles County lands east of the City, especially during the seasonal surge of Santa Ana winds. While the strong downslope Santa Ana winds present the clearest wildfire hazard to the City, vegetation conditions across the southern front of the San Gabriel Mountains place the community at risk even under typical on-shore wind conditions.

Low-density single-family residential neighborhoods have been developed along the southern and western boundaries of the project site, approximately zero to 1,000 feet from the project area boundary. Single-family residences occur along the southern portion of the project boundary on Monterey Street. There is a proposed residential development (Sage Canyon) adjacent to the Wilderness Area along its southwestern boundary.

Landowners, and in many cases HOAs, are responsible for meeting fire hazard reduction standards on privately owned open spaces within established neighborhoods. Existing woodland understory within 200 feet of existing residences south of the Wilderness Area has been altered by annual vegetation removal since the early 1980s. The City’s Public Works Department manages vegetation management programs for all City-owned land, which includes the Wilderness Area. In addition, the City’s Community Wildfire Protection Plan contains fuel modification guidelines for residential properties in this area and continued adherence to that plan should continue to protect these neighborhoods from fire risks, to the extent possible. Continued inter-agency coordination between the City of La Verne, Los Angeles County, and neighboring foothill cities for future fire management would also help lower fire risks.

Existing Public Access Conditions
From the west, access to the Wilderness Area plateau is currently available via an unimproved parking area off San Dimas Road and a foot trail that connects with Sunset Ridge Road (sometimes referred to as Sunset Ridge Truck Trail or Sunset Peak Motorway). From the northeast, Sunset Ridge Road travels down from Sunset Peak within the Angeles National Forest and along the border of the San Dimas Experimental Forest to the Wilderness Area. Sunset Ridge Road is a 12- to 16-foot wide 379
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10 Community Services and Community Development Departments dirt fire road. Access from the south to and through the lower portions of the Wilderness Area is closed to public use.

The City has vehicular access to the lower wash area of the Wilderness Area off Via Vista Court, which is gated and closed to public use. There is open access to the lower wash area of the Wilderness Area through private property, both at the downstream and upstream ends of the lower wash. There are no City-maintained trails from the wash area connecting uphill with Sunset Ridge Road.

View of dry drainage and surrounding Coastal Live Oak woodland in southwestern corner of La Verne Wilderness Area, facing northeast. ©Rincon Consultants, Inc. 2016.
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Management and Public Access Plan History
Background
The grant funds used to acquire the Wilderness Area were dedicated to the “acquisition, development, improvement, rehabilitation or restoration of real property for parks and park safety, senior recreation facilities, gang prevention, beaches, recreation, community or cultural facilities, trails, wildlife habitat or natural land in order to establish open space areas”(County of Los Angeles 1996, 2005). At the time the funds were allocated for purchasing the lands, the City agreed to maintain and operate the property in perpetuity. Conditions in the grant funding include specific stipulations requiring reasonable public access, except where such access would interfere with resource protection (Sections 10c and 13), and prohibiting flood control projects within the grant lands (Section 17d). In order to fulfill the requirements of the land acquisition grant, the La Verne Wilderness Area Management and Public Access Plan ("Management Plan") was prepared to address the resolution of wildlife conservation, public access, and habitat management issues in an integrated program.

In 2007 and 2008, the City began the planning process to develop a Draft Management Plan for the Wilderness Area. This planning was structured around three facilitated public workshops. An average of approximately 45 individuals, many of them neighbors to the Wilderness Area, attended each workshop. The workshop objectives were as follows:
 November 2007: to solicit community perspectives about a "Vision" for the Wilderness Area and identify resource management and/or passive outdoor recreation and education activities to be evaluated for inclusion in the Management Plan.
 January 2008: to overview management opportunities and constraints, present a framework for management alternatives, and solicit individual views about management alternatives.  March 2008: to overview preferred Draft Management Plan recommendations and solicit individual views about those recommendations.

In addition to the public workshops, the City conducted individual and small group interviews with government agencies, special interest groups, and immediate neighbors to the Wilderness Area to specifically discuss public access. The public access discussions took into account the legal requirements associated with the acquisition grant, management responsibilities, and alternative management methods and facilities that would be helpful in controlling public access.

In October, 2008 a Draft Management Plan was produced for the City’s consideration that outlined recommendations for habitat resource enhancement, public safety actions, and controlled public access along with selected management alternatives. At that time, the City elected to postpone any action in advancing the review and refinement of the Draft Management Plan.

In 2016, the City re-initiated review of the management options presented in the 2008 Draft Management Plan and determined to prepare an Environmental Impact Report for the management program consistent with the California Environmental Quality Act (CEQA) guidelines. On September 20, 2016, a public scoping workshop was conducted to review the resource and public access management concepts being considered and to solicit direction from the community for how to 381
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12 Community Services and Community Development Departments best steward the Wilderness Area resources while also providing low-impact outdoor recreation and educational experiences. There were 26 people in attendance, primarily the neighbors immediately south of the Wilderness Area. A summary of this meeting, as well as those from 2007 and 2008, can be found in Appendix B. All public scoping meeting comments have been incorporated into the 2017 La Verne Wilderness Area Management and Public Access Plan.

Intent and Purpose
The Wildlife Conservation Board’s grant terms requires the Wilderness Area to be managed “for the purposes of wildlife habitat preservation, restoration and management, wildlife-oriented education and research, and for compatible public or private uses, all as may be consistent with wildlife habitat preservation and protection of sensitive biological resources.” Therefore, the Wilderness Area Management and Public Access Plan includes selective habitat enhancement actions, the resolution of public safety hazards, and opportunities for limited controlled public access as part of the City’s stewardship responsibilities for the Wilderness Area.

Northern Mixed Chaparral in western
corner of La Verne Wilderness Area,
facing west.
©Rincon Consultants, Inc. 2016
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Goals, Objectives, and Actions
For the purpose of this Management Plan, stated goals are specific physical improvements or management policies that would implement the Vision for the Wilderness Area. Objectives are subcomponents of the goals that translate the intended improvements into actions to be taken.

Each objective entails taking two or more actions, some of which are common among the objectives, in order to meet the intended goal. To the extent practicable and allowable by physical, biological, and social constraints, the City is committed to the realization of multiple management goals with specific associated objectives for the Wilderness Area.

Goals are organized into the following categories:
 Wildlife Habitat Conservation: addressing habitat enhancement and stewardship activities  Public Safety: addressing potential hazards including flooding and wildfire  Public Access: addressing provision of low-impact trail-related recreation and interpretive education
 General Management Goals: addressing ongoing oversight, operation, and maintenance of the Wilderness Area
Wildlife Habitat Conservation Goals
The Wilderness Area is located in the foothills of the San Gabriel Mountains and supports native vegetation characteristic of the region, including chaparral and oak woodland over the majority of its extent and patches of alluvial fan sage scrub and cactus scrub vegetation occur in localized areas (see Figure 2). In addition, annual grassland is scattered on ridgelines and in the canyon bottom where disturbances cleared native vegetation at some point in the past. This mosaic of vegetation types provides a varied habitat structure for wildlife populations that are expected to be relatively abundant and diverse.

In particular, oak woodland is an important habitat for many wildlife species that require trees for roosting and nesting and acorns as a food source. This importance, combined with its restricted distribution, often makes oak woodland a habitat targeted for conservation in southern California.

Under the City Preservation, Protection, and Removal of Trees Ordinance (No. 999), the City protects native trees. Other regulated biological resources that occur on site are drainage features that fall under the jurisdiction of the USACE, Los Angeles RWQCB, and CDFW, found in the bottom of Marshall Canyon and most of the tributary drainages. Protection of the watershed, wildlife, and general biological diversity in the Wilderness Area was a significant reason for the acquisition grant and community input. Therefore, it is appropriate that multiple objectives were identified under a preservation goal.
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14 Community Services and Community Development Departments Figure 5 Wilderness Area Habitat Enhancement Opportunities

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Several objectives are identified for the goal of preserving and enhancing wildlife habitat, corridors, and diversity. Objectives targeted at enhancing valued habitats (and particularly alluvial fan sage scrub, chaparral, and oak woodlands) are focused on restoration of disturbed areas. Specific areas targeted for habitat enhancement are illustrated in Figure 5.

The City should consider leveraging its management resources through the use of community volunteer labor and partnerships with government and non-government entities to provide funding for enhancement programs and private and public mitigation projects. For example, use of the Wilderness Area restoration and enhancement actions could be tied to conditions of approval at the local (e.g., compliance with CEQA), State (e.g., compliance with CDFW Lake and Streambed Alteration Agreements), or federal (e.g., compliance with USACE Section 404 Permits) levels.

Goal #1: Preserve and Enhance Wildlife Habitat Corridors and Diversity
OBJECTIVE 1.1: E NHANCE AND PROTECT ALL HABITAT AREAS
Action 1.1.1: Remove any abandoned facilities
Action 1.1.2: Remove non-native tree species
Action 1.1.3: Install public access control signing along selected locations of the trail (See Figures 8 and 9) and along Sunrise Ridge Road stating “Habitat Management Area - No Public Access”
Action 1.1.4: Based on results of annual monitoring (see also Objective 7.1), install public access control railings as necessary to inhibit off- trail use and creation of volunteer trails
Action 1.1.5: Based on results of annual monitoring (see also Objective 7.1), decommission, restore to a natural gradient, and/or stabilize any volunteer trails that have been created
Action 1.1.6: Avoid vegetation removal and management activities within the Coast Prickly Pear Scrub sensitive vegetation community (see Figure 2) and in areas that provide habitat to sensitive plant and wildlife species
Action 1.1.7: Should vegetation removal in sensitive areas be determined to be necessary and appropriate, special status species surveys will be conducted prior to any work commencing
Action 1.1.8: Avoid management activities that would prohibit wildlife movement through the Wilderness Area
Action 1.1.9: Coordinate with appropriate federal, state, or local agencies, such as the U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management
activities in riparian areas
Action 1.1.10: Coordinate with the US Forest Service to ensure that management activities are consistent with the Forest Plan, San Gabriel National Monument Plan, and San Dimas Experimental Forest
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16 Community Services and Community Development Departments OBJECTIVE 1.2: R ESTORE THE SOUTHERN WASH CORRIDOR AS RIVERSIDE AN ALLUVIAL

FAN SAGE SCRUB WITH A SURROUNDING MODIFIED COAST LIVE OAK

WOODLAND /GRASSLAND HABITAT
Action 1.2.1: Remove non-native shrubs and trees
Action 1.2.2: Revegetate with appropriate native species Action 1.2.3: Weed abatement shall occur in coast live oak woodland/grassland areas annually. Disking shall be prohibited.

OBJECTIVE 1.3: P RESERVE EXISTING, AND WHERE APPROPRIATE , ENHANCE NORTHERN

MIXED CHAPARRAL /COAST LIVE OAK WOODLAND
Action 1.3.1: Remove non-native shrubs and trees
Action 1.3.2: Revegetate with appropriate native species OBJECTIVE 1.4: R EVEGETATE DISTURBED AREAS
Action 1.4.1: Rip and grade abandoned roads and social trails where appropriate
Action 1.4.2: Hydroseed with native erosion control mix Action 1.4.3: Limit public access during establishment period OBJECTIVE 1.5: P RESERVE SIGNIFICANT AND HERITAGE TREES Action 1.5.1: Avoid trimming and removal of significant and heritage trees Action 1.5.2: Tree replacement will be included in restoration activities as appropriate
Action 1.5.3: Tree trimming or removal will take place outside of nesting bird season
Public Safety Goals
Locating a hiking trail in the floodplain of an intermittent drainage and then crossing the drainage can be challenging relative to the ongoing maintenance of the trail (see Goal #2). Careful design and choice of materials are required to minimize any undercutting of the trail and avoid ongoing rehabilitation costs that may be onerous. A cautious approach in trail siting, design, and development will be used to start a trail route composed of natural materials involving minimal grading. After a sufficient annual monitoring period of runoff patterns, the trail location may be modified and the trail tread upgraded as appropriate.

To address the potential for increased fire hazard associated with public use, the City is committed to programming and implementing fuel modification activities necessary to protect nearby neighborhoods from wildfires (see Goal #3). In addition, as discussed further below, the City will provide rules for use of the Wilderness Area that close the area during periods of potential flood risk and high and extreme fire danger, prohibit fires of any kind, and limit the number of access points for the public to enter (see Objectives 2.2, 3.2, and 3.3). 386
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Flood Risk
The goal that addresses existing flood problems is based on considerations of issues primarily raised by immediate neighbors to the Wilderness Area. The City has explored the construction of a flood control debris basin in the Wilderness Area, as part of a management approach to alleviate the flood hazard onsite and downstream. However, the City's ability to respond to this issue is constrained by the stipulations of the State grant that do not allow such improvements within the 208-acre portion of the Wilderness Area. The 150-acre portion of the Wilderness Area that has no such grant restrictions contains topography that makes locating such a debris basin structure infeasible. There are also questions about the City's ability to adequately budget for the capital improvements and on-going maintenance costs of such structures.

Nevertheless, the City is committed to exploring the possibility of installing and maintaining woody debris racks across three tributary drainages for purposes of reducing the amount of woody debris that could be carried downstream during heavy rainfall, particularly following wildfires in the upstream watershed (see Objective 2.1). The recommended location of these racks is shown in Figure 6 and a schematic diagram showing their conceptual design is provided in Figure 7. The design and construction of these racks would be minor facilities. They are not intended to detain water flow, which is not permitted under the grant funding for the acquisition of the Wilderness Area, and they would have only minimal capability to detain sediment transport. Rather, they are intended to prevent larger woody debris from reaching downstream areas where the debris could become lodged in the channel or at culvert entrances to “block / dam” water flow and cause subsequent damage to the Wilderness Area and adjacent properties.

View of dry drainage in Coastal Live Oak woodland in southwestern corner of La Verne Wilderness Area, facing northea st. ©Rincon Consultants, Inc. 2016.
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18 Community Services and Community Development Departments Figure 6 Recommended Locations of Woody Debris Racks

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Figure 7 Conceptualized Woody Debris Rack

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20 Community Services and Community Development Departments Goal #2: Provide Flood Hazard Management
OBJECTIVE 2.1: M ANAGE STORMWATER , SEDIMENT, AND WOODY DEBRIS Action 2.1.1: Delineate and field stake the 100-year floodplain of the wash and a riparian buffer within the southern limits of the Wilderness Area. Manage as a Coast Live Oak Woodland habitat corridor to provide both habitat diversity and facilitate the transport of floodwaters (See also Goal #1)
Action 2.1.2: Coordinate with appropriate federal, state, or local agencies, such as the U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management
activities in riparian areas
Action 2.1.3: Explore the possibility of installing and maintaining up to three woody debris racks to discourage debris from moving
downstream
OBJECTIVE 2.2: P ROVIDE FOR PUBLIC SAFETY
Action 2.2.1: Close area to public access during potential rain, flood periods, and when the southern drainage crossing is wet
Wildfire Risk
To reduce wildfire risk to the extent possible, the Wilderness Area will be closed during periods of high and extreme fire danger, prohibit fires and smoking of any kind, and limit the number of public access points to the Wilderness Area along its southern boundary to one location.

It is recognized that resource management activities related to the provision of a coast live oak woodland wildlife corridor (Goal #1) and floodplain of the creek in the lower portions of the Wilderness Area (Goal #2) result in a de-facto modification of fuel loads adjacent to existing residences along Monterey Road consistent with California's Wildland-Urban Interface Code requirements for designated areas. Wildfire hazard management within the Wilderness Area requires specialized management provisions. In cooperation with the La Verne Fire Department and other fire authorities (CAL FIRE, Los Angeles County, U.S. Forest Service), a local Brush and Fuel Load Management Plan will be prepared and will include:
 vegetative treatments of native scrub and chaparral along trails (if necessary)  appropriate methods (mechanical clearance, hand-tool thinning, goats, etc.) to provide adequate protection without compromising user experience or causing undo environmental impacts

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Goal #3: Provide Wildfire Hazard Management
OBJECTIVE 3.1: C LEAR BRUSH AND MODIFY FUEL LOAD
Action 3.1.1: Weed abatement shall occur in low-lying areas of the wash in the southern portion of the Wilderness Area annually (See also Goals #1 and #2). Disking shall be prohibited.

Action 3.1.2: In cooperation with Los Angeles County, prepare a local Brush and Fuel Load Vegetation Management Plan in one year of the Wilderness Area opening to the public, and review the plan every five years
OBJECTIVE 3.2: P ROHIBIT FIRES
Action 3.2.1: Prohibit any fires for recreation or maintenance in the Wilderness Area
Action 3.2.2: Prohibit smoking in the Wilderness Area
OBJECTIVE 3.3: P ROVIDE FOR PUBLIC SAFETY
Action 3.3.1: Close area to public access during periods of extreme fire danger, as defined as Fire Weather Warning, announced by the United States National Weather Service
Action 3.3.2: No road or trail maintenance or fuel management activities shall occur during periods of extreme fire danger (Fire Weather Warning or Fire Weather Watch days, as posted by the United States National Weather Service)
Action 3.3.3: In cooperation with other agencies, design, locate, and develop strategies for acquiring and improving emergency access to the Wilderness Area and facilitating evacuation in the event of a wildfire
Action 3.3.4: Notify the responsible agency of any identified fire road maintenance needs
Public Access Goals
Public use and enjoyment of the Wilderness Area's natural setting is understood to be a community- wide benefit. Nevertheless, some immediate neighbors have expressed concerns about the increased potential for wildfires and the interruption of their own quiet enjoyment of backyard environments. These concerns guide the public access goals of the Management Plan.

Considerations for public access and use include a wide range of options. These vary from no public access at any time to open access with hour restrictions. Expressed issues generally fell into the following topical areas: public safety, increased fire hazard, access options, parking at access points, the expansion of trail network and connectivity to adjacent Angeles National Forest lands versus no or limited new trails, the provision of restroom and water facilities, and security and maintenance costs.

In order to address these various perspectives, a number of goals and objectives are incorporated into the Management Plan. Overall, the goals and objectives, when taken as a whole, are aimed at 391
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22 Community Services and Community Development Departments providing an enjoyable outdoor recreation experience directed toward access to the adjacent Angeles National Forest with no or minimal impact to the environment and nearby neighborhoods.

Public access and use of the Wilderness Area will require active management and maintenance, and implies added responsibilities for the City. Specific goals and objectives are crafted to minimize capital improvement and maintenance costs, but provide for sufficient features and staffing for Management Plan implementation. To the extent feasible, the City will pursue opportunities to share and reduce these obligations and their associated costs. Conceptual public access program features are provided in Figure 8 and Figure 9.

Examples of restricted access mechanisms that may be used to manage public access in the La Verne Wilderness A rea Top left Golden Hills Wilderness Park, La Verne ©Rincon Consultants, Inc. 2016; top right Marshall Canyon Staging Area courtesy of County of Los Angeles Department of Parks and Recreation; bottom La Verne Wilderness Area restricted access at Via Vista Court. ©Rincon Consultants, Inc. 2016.
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Figure 8 Conceptual Public Access

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24 Community Services and Community Development Departments Figure 9 Conceptual Public Access: Inset

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Goal #4: Provide a Tranquil and Safe Visitor Experience OBJECTIVE 4.1: S ECURE ACCESS
Action 4.1.1: Employ a dedicated easement for public access from Golden Hills Road to the downstream end of the wash within the southern limits of the Wilderness Area1
OBJECTIVE 4.2: D EVELOP LIMITED USE FACILITIES
Action 4.2.1: Identify space for and create parking spaces, one of which would be an accessible parking space, through striping and/or signage along Golden Hills Road for use to access the Wilderness Area Action 4.2.2: Develop a foot trail to avoid and/or minimize resource impacts and related mitigation to include:
 An accessible trail/maintenance route from Golden Hills Road into the Wilderness Area
 An approximately 0.6-mile, 8-foot wide accessible trail/ maintenance route from Golden Hills Road leading into the Wilderness Area and forming a loop (conceptual trail shown in Figures 8 and 9), and composed of natural materials with a firm and stable surface
Action 4.2.3: Provide benches at key location(s) where there is shade or opportunities to plant trees for future shade
Action 4.2.4: Provide interpretive signs at key locations addressing wildlife habitat and use, and respect for privacy for adjacent neighbors Action 4.2.5: Provide management and safety signs at the Golden Hills Road entrance to include information about general use regulations, a trail map, and universal access conditions. The following information would be conveyed to the trail user:
 Use restrictions
 Permit requirements
 Universal access information, including:
 Degree of difficulty rating
 Length of trail segment
 Surface type
 Typical and minimum tread width
 Typical and maximum running slope
 Typical and maximum cross slope
 Change in elevation over the total trail length and
maximum elevation obtained
 Presence and danger of mountain lions, bears, and
rattlesnakes

1 Reference: Conditions of Approval #34; Case Nos. 35 -15TTM, 36-15ZC, 37-15ZA, and 38-15TR Proposed Residential Subdivision (Sage Canyon) – 1977 Golden Hills Road.
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26 Community Services and Community Development Departments Goal #5: Provide Controlled Public Access
OBJECTIVE 5.1: P ROVIDE FOR PUBLIC SAFETY
Action 5.1.1: Prohibit bicycles and equestrians
Action 5.1.2: Require all dogs to be on leashes pursuant to La Verne Municipal Code Section 6.16.070 Leash Law
OBJECTIVE 5.2: P ROVIDE A SINGLE ACCESS POINT FROM THE CITY Action 5.2.1: Develop access entrance on Golden Hills Road Action 5.2.2: Identify space for parking spaces along Golden Hills Road and post information regarding appropriate alternative overflow parking locations
Action 5.2.3: Install an open / lock gate at Golden Hills Road OBJECTIVE 5.3: D ESIGNATE WILDERNESS AREA AS PEDESTRIAN ACCESS / DAY USE ONLY (NO OVERNIGHT USE)
Action 5.3.1: Install lockable gates and associated fencing at Golden Hills Road Action 5.3.2: Install use and regulatory signs at Golden Hills Road (see also Action 4.2.4 and 4.2.5)
Action 5.3.3: Limit Wilderness Area use from one hour after sunrise to one hour before sunset
OBJECTIVE 5.4: L IMIT USE TO TRAI L-RELATED PEDESTRIAN ACTIVITIES Action 5.4.1: Provide no picnic or restroom facilities
Action 5.4.2: Require groups of 10 or more individuals to obtain a special use permit
Action 5.4.3: Clearly inform the public / post all prohibited uses (see also Action 4.2.4 and 4.2.5)
OBJECTIVE 5.5: P ROVIDE PHASED PUBLIC ACCESS PROGRAM BASED ON AVAILABLE

STAFF RESOURCES AND FUNDING
Action 5.5.1: Phase 1: Allow initial access only to small groups (from 5 up to 20 individuals) through a special use permit system identifying one designated responsible individual (reviewed annually to determine Phase 2)
Phase 2: Based on results of annual use monitoring, issue special use group permits and individual access permits (once
implemented, reviewed annually to determine Phase 3)
Phase 3: Based on results of annual use, allow individual access for general use without permits (once implemented, reviewed annually)
Action 5.5.2 Consider engaging and coordinating with local non-profit organizations, such as the La Verne Land Conservancy, to assist with staffing and patrolling the Wilderness Area
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OBJECTIVE 5.6: P ROTECT ADJACENT PRIVATE PROPERTY
Action 5.6.1: Maintain approximately 50 feet between the public access trail and existing backyard property lines along Monterey Street Action 5.6.2: Install secure property line fencing parallel to Monterey Street where not already existing
Action 5.6.3: Install signs along boundary lines designating the “Wilderness Area Boundary”
Action 5.6.4: Public access to the Wilderness Area through private properties (including from Calle Aragon and Brydon Road) shall be
prohibited
Action 5.6.5: Consult with immediate adjacent neighbors to detail the location and design of boundary line / public access control fencing parallel to Monterey Street and the Wilderness Area entrance General Management Goals
In implementing the Management Plan, the City must consider applicable regulatory compliance, related capital improvement, and on-going maintenance costs.

Selected Management Plan actions may require compliance with regulatory programs at the State and Federal levels. Through the CEQA process and the incumbent identification of any potentially significant adverse impacts, mitigation above and beyond the Management Plan actions will be provided for and documented. Following certification of the document by the City, the mitigation measures will be incorporated into the Plan and monitored to pursuant to State law.

The Stat
e may also claim its jurisdiction over any drainages and the associated riparian habitat encroached upon by any elements of the Management Plan. For instance, the placement of woody debris racks in tributary drainages, any trail crossings of drainages and related habitat enhancement activities could trigger the need to obtain a Lake and Streambed Alteration Agreement with the CDFW pursuant to Section 1600 of the State Fish and Game Code. Similarly, any alterations to drainages claimed to be jurisdictional by the USACE (normally the area within the ordinary high water mark of a drainage) may trigger federal regulation pursuant to Section 404 of the federal Clean Water Act. Depending on the size of jurisdictional area affected, either a pre -constru
ction
notification or nation-wide permit is likely to be required.

Goal #6: Cooperate with Others in Management of the
Wilderness Area
OBJECTIVE 6.1: C OORDINATE WITH OTHER AGENCIES / INTEREST GROUPS / VOLUNTEERS /

NEIGHBORS TO COMPLEMENT CITY STAFF IN IMPLEME NTING RESOURCE

MANAGEMENT ACTI VITIES AND CAPITAL I MPROVEMENTS
Action 6.1.1: Coordinate with appropriate federal, state, or local agencies, such as the Forest Service, U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to
conducting management activities in riparian areas
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28 Community Services and Community Development Departments Action 6.1.2: Coordinate with the US Forest Service to ensure that management activities are consistent with the Forest Plan, San Gabriel Mountains National Monument Plan, and San Dimas Experimental Forest
Action 6.1.3: Where feasible, enter into inter-jurisdictional cooperative agreement with allied agencies such the Angeles National Forest, the San Gabriel Mountains National Monument, Los Angeles County Department of Parks and Recreation, the cities of Claremont and San Dimas, and non-governmental organizations, to implement resource management programs
Action 6.1.4: Consider entering an agreement with local non-profit organizations, such as the La Verne Land Conservancy, to assist in resource management activities
OBJECTIVE 6.2: C OMMUNITY INVOLVEMENT
Action 6.2.1: Consult with immediate adjacent neighbors to detail the location and design of boundary line / public access control fencing parallel to Monterey Street and the Wilderness Area entrance Action 6.2.2: Consult with the community, including non-governmental organizations, such as the La Verne Land Conservancy, to develop the final trail design
Goal #7: Provide Sufficient Onsite Presence to Manage the Wilderness Area
OBJECTIVE 7.1: C OORDINATE WITH OTHER AGENCIES / TR AI L GROUPS / VOLUNTEERS /

NEIGHBORS TO COMPLEMENT CITY ST AFF PRESENCE
Action 7.1.1: Monitor public access conditions at the beginning, middle, and end of the primary recreation season and after major storm events
Action 7.1.2: Provide onsite management presence on weekends and holidays during the prime use season once the Wilderness Area is open for general use (see Objective 5.5 Phase 3) with City staff as funding allows, or through management agreements, others (see also Objective 6.1)
Action 7.1.3: Establish a Wilderness Area Watch hot line Goal #8: Reflect Changes in Surrounding Use and Ownership Conditions
OBJECTIVE 8.1: A SSURE THE MANAGEMENT PLAN REMAINS CURRENT AS CONDITIONS CHANGE .

Action 8.1.1: Review the Management Plan as needed and update as necessary
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City of La Verne 29
Goal #9: Obtain Sufficient Funds to Assure Full Implementation of the Management Plan
OBJECTIVE 9.1: S ECURE FUNDS FOR RESOURCE MANAGEMENT
Action 9.1.1: Subsequent to any Management Plan actions, consider resource management enhancement actions for potential funding
through City project mitigation requirements, or mitigation by others
Action 9.1.2: Apply for funding from watershed management and wildlife enhancement grant programs
OBJECTIVE 9.2: S ECURE FUNDS FOR CAPI TAL IMPROVEMENTS
Action 9.2.1: Apply for funding from watershed, watchable wildlife, and park/open space grant programs
OBJECTIVE 9.3: S ECURE FUNDS FOR PUBLIC ACCESS MANAGEMENT Action 9.3.1: Prior to opening the Wilderness Area to general use without permits (reference Objective 5.5 Phase 3), fund a position to monitor and manage the Wilderness Area and coordinate
habitat management programs in the Wilderness Area

Scalebroom in northwestern portion of La Verne Wilderness Area. ©Rincon Consultants, Inc. 2016

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Goals, Objectives, and Actions

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Implementation
Estimated Cost
Projected capital improvement costs to provide flood protection, enhance natural habitat values, and offer new and enhanced visitor experiences consistent with the goals and objectives of the Management Plan are detailed in Appendix C of this Management Plan. Projected costs are not absolute and should be reassessed as needed.

Priorities
General implementation priorities for individual goals are presented in the table below.

Recommended priorities are not absolute and should be modified based on opportunities that may occur over time.

Table 2 Implementation Priorities for Individual Goals
Priority
General Year 1 to 2 Year 3 to 5 Beyond 5 years
Regulatory Compliance (CEQA and permitting) x
Goal

1. Preserve and enhance habitat, corridors, and diversity x x

2. Provide flood hazard management x

3. Provide wildfire hazard management x x

4. Provide a tranquil and safe visitor experience x x

5. Provide controlled public access x x

6. Cooperate with others in management of Wilderness Area Ongoing

7. Provide sufficient onsite presence to manage Wilderness Area Ongoing

8. Reflect changes in surrounding use and ownership conditions Ongoing

9. Obtain sufficient funds to implement Management Plan Ongoing

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Implementation

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References
California Department of Fish and Wildlife. 2016a. California Natural Diversity Database, Rarefind V.

3.1.0. (August 30, 2016).

California Department of Fish and Wildlife. 2016b. Biogeographic Information and Observation System (BIOS). Retrieved from http://bios.dfg.ca.gov (August 30, 2016).

California Department of Fish and Wildlife. 2016c. California Natural Diversity Database, Sandra Shanks. Diplectrona californica. Retrieved from:
file:///C:/Users/Christina/Downloads/Diplectrona_californica.pdf (September 9, 2016).

La Verne, City of. 2017. Tree Preservation, Protection, and Removal Ordinance. Ordinance No. 999.

Development Code Chapter 18.78. Adopted November 19, 2007.

La Verne, City of. 2016 Proposed Residential Subdivision (Sage Canyon) – 1977 Golden Hills Road.

Case Nos. 35-15TTM, 36-15ZC, 37-15ZA, and 38-15TR. Adopted November 21, 2016.

La Verne Land Conservancy. 2017. http://www.lvlc.org/. Accessed 2017.

Los Angeles, County of. 1996. Resolution of the Board of Supervisors of the County of Los Angeles:

Safe Neighborhood Parks Proposition of 1996, Proposition A.

Los Angeles, County of. Department of Parks and Recreation. 2005. Marshall Canyon Land Acquisition Grant Project. Submitted to County of Los Angeles. La Verne, California. July 14, 2005.

Los Angeles, County of. Department of Parks and Recreation. 2017. Marshall Canyon Staging Area. http://parks.lacounty.gov/wps/portal/dpr/Parks/Marshall_Canyon_Staging_Area. Accessed August 2017.

PCR Services Corporation. 2008. Draft La Verne Wilderness Area Management Plan.

Rincon Consultants. 2017. Biological Resources Assessment – La Verne Wilderness Area Management Plan. February 2017.

Rincon Consultants. 2017. La Verne Wilderness Management Plan Fire Hazards Study. February 2017.

Rivertech. Inc. 2016. La Verne Wilderness Area Management Plan Flood Hazards. December 2016.

State of California. California Code of Regulations. Title 14. Public Resources Code. Natural Resources. Division 1. Fish and Game Commission-Department of Fish and Game, §1602.

State of California. California Code of Regulations. Title 14 - Natural Resources. Division 1.5 - Department of Forestry. Chapter 7 - Fire Protection. Subchapter 2 - SRA Fire Safe Regulations.
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References

34 Community Services and Community Development Departments U.S. Department of Agriculture, Forest Service, Technology and Development Program. 2007. Trail Construction and Maintenance Notebook.

U.S. Department of Agriculture, Forest Service. 2017. Angeles National Forest – San Gabriel Mountains National Monument. https://www.fs.usda.gov/main/angeles/home. Accessed August 2017.

United States Fish and Wildlife Service (USWFS). 2016c. National Wetland Inventory. Retrieved from http://www.fws.gov/wetlands/. Accessed December 2016.

Document Preparation
Rincon Consultants, Inc. prepared the La Verne Wilderness Area Management Plan under contract to the City of La Verne. Bill Aguirre is the Community Service Director for the City of La Verne and oversaw the project planning efforts. Persons involved in data gathering analysis, project management, and quality control include the following.

RINCON CONSULTANTS , INC.

Stephen Svete, AICP, LEED AP ND, Vice President and Director of Planning Sally Schifman, Senior Environmental Planner and Lead Author April Durham, PhD, Senior Technical Editor and Graphic Designer Christina McAdams, Senior Biologist
Matthew Long, MESc, Senior Environmental Scientist
Lilly Rudolph, AICP, Senior Planner
2M ASSOCIATES
Patrick Miller, FASLA
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Appendix A
Wilderness Area Vegetation and Wildlife Species
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City of Laverne Community Services and Community Development Departments Appendix B
Public Workshop Summaries
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City of La Verne Community Services and Community Development Departments Appendix C
Estimated Implementation Costs

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RESOLUTION NO. I232

A RESOLUTION OF THE PLANNING COMMISSION OI'THE CITY OF LA VERNE, COLJNTY

OF LOS ANGELES, STATE OF CALIFORNI,A RECOMMENDING APPROVAL OF THE LA

VERNE WILDERNESS AREA MANAGEMENT AND PUBLIC ACCESS PLAN WITH A

PHASING PLAN AND CERTIFICATION OF THE ENVIRONMENTAL IMPACT REPORT WHEREAS, Sections 2.48.020 through 2.4E.165 of the La Veme Municipal Code empowers the Planning Commission to recommend appropriate legislation to the City Council regarding the orderly growth, developmeng and environmental character ofthe community; and WHEREAS, Sections 65453 et seq. of the Califomia Govemment Code authorize the Planning Commission to consider and recommend action to the City Council conceming plans; and WHEREAS, a notice of public hearing was published in the Inland Valley Daily Bulletin and mailed to all owners olproperties within 300 feet ofthe property; and WHEREAS, the proposed plan has less than significant impacts or less than significant impacts on the environment after mitigation measures are in place and adopts the prepared Environmental Impact Report; and
WHEREAS, the Planning Commission has previously conducted duly noticed public hearings on October 10, 2018, December 12, 2018 and Janu ary 9,2019.

Section l. Environmental Determination. The Planning Commission HEREBY FINDS and DETERMINES that (i) the plan has less than significant impacts or less than significant impacts on the environment after mitigation measures are in place and recommends City Council approval ofthe prepared Environmental Impact Report ("EIR"), (ii) EIR reflects the City's, as lhe lead agency, independent review and analysis ofthe EIR; and (iii) the EIR" as presented, has been prepared in accordance with the CEQA.

Section 2. Findings. In recommending the approval ofthe proposed plan, the Planning Commission HEREBY FINDS AND DETERMINES:
l. The proposed plan, with the mitigation measures is in conformance with the goals and objectives ofthe General Plan.

2. Public necessity, general welfare, and effective city planning practice require and suppo( rhe new plan.

Resolution No. 1232 Page I
WHEREAS, on April 10,2019, the Planning Commission conducted a public hearing in which it recommended adoption of the La Verne Wildemess Area Management and Public Access Plan, finding the plan to be in conformance with the goals and objectives on the La Verne General Plan; and
WI{EREAS, the Planning Commission conducted a duly noticed public hearing on April I 0, 2019 and considered additional public testimony in accordance with City and State requirements.

NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of La Veme as follows:
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3. The character, style, and use of materials harmonize rvith the natural setting.

4. The proposed plan would better serve the area considering the nature, use, and proposed uses of the adjacent properties.

5. Adoption ofthe plan rvould not negatively affect adjacent properties.

Section 3. Approval. Based upon the above findings, the Planning Commission HEREBY RECOMMENDS THE CONDITIONAL APPROVAL of the proposed plan and accompanying environmental documents for the La Veme Wilderness Area Management and Public Access Plan with the accompanied phasing plan for the project as set forth below:

Phase 1: Staffshall explore the option to request to amend the project scope for use of the $650,000 grant obtained in 2016 from RPOSD to fund Phase l. Phase I will begin rvhen funding is obtained.

The lollowing Actions rvill be included in Phase 1 ofthe Implementation Plan Obiective I .0: CommuniW Ensagement
The City will support and engage with the La Verne Land Conservancy, and all interested stakeholders to create a committee or to further evaluate and explore the feasibility ofcreating trail and accessibility options, relying on the existing Environmental [mpact Report (EIR). It is intended that this effort take place within the next 24 months to ensure that data upon which the EIR is based remains valid.

Objective I .l : Enhance and Protect All Habitat Areas:

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Action
Action
Action
Action
Action
Action
L1.1:
t.1.2:

I .1.6:

1.1.7:

I .1.8:

I .1.9:
l.r.10:

Remove any abandoned facilities
Remove non-native tree species
Avoid vegetation removal and management activities within the Coast Prickly Pear Scrub sensitive vegetation community (see Figure 2) and in areas that provide habitat to sensitive plant and wildlife species Should vegetation removal in sensitive areas be determined to be necessary and appropriate, special status species surveys will be conducted prior to any work commencing
Avoid management activities that would prohibit wildlife movement through the Wildemess Area
Coordinate with appropriate federa[, state, or local agencies, such as the U.S.

Army Corps of Engineers, California Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management activities in riparian areas
Coordinate with the US Forest Service to ensure that management activities are consistent with the Forest Plan, San Gabriel National Monument Plan, and San Dimas Experimental Forest
Obiective [.2: Restore the Southern Wash Corridor as Riverside an Alluvial Fan Sage Scrub rvith a irl
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C Live Oak Woodl
?age 2
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Remove non-native shrubs and trees
Revegetate with appropriate native species
Weed abatement shall occur in coast live oak woodland./grassland areas annually. Disking shall be prohibited.
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Action L2.2:

Action 1.2.3:

Obiective 1.3: Preserve Existins. and Where Anoropriate. Enhance Northern Mixed Chaparral/Coast5 6 '7
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Live Oak Woodland
Action L3.1:

Action 1.3.2:

Remove non-native shrubs and trees
Revegetate with appropriate native species
te disturbed areas
Rip and grade abandoned roads and social trails where appropriate Hydroseed with native erosion control mix
Limit public access during establishment period
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Action
Action
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Obiective I .5: Preserve Si ificant and l-leritage Trees Avoid trimming and removal ofsignificant and heritage trees Tree replacement will be included in restoration activities as appropriate Tree trimming or removal will take place outside ofnesting bird season Action [ .5.1 :

Action 1.5.2:

Action 1.5.3:
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Obiective 2.1 : Manase Stormwa ter. Sediment. and Woodv Debris Action2.l.l: Delineate and field stake the 100-year floodplain ofthe wash and a riparian buffer rvithin rhe southern limits of the Wilderness Area. Manage as a Coast Live Oak Woodland habitat corridor to provide both habitat diversity and facilitate the transpon of floodwaters (See also Goal # l) Action 2.1.2: Coordinate with appropriate federal, state, or local agencies, such as the U.S.

Army Corps of Engineers, Califomia Department of Fish and Wildlife, and/or the Los Angeles Regional Water Quality Control Board, prior to conducting management activities in riparian areas
Action 3.1 . I : Weed abatement shall occur in low-lying areas of the wash in the southern portion of the Wildemess Area annually (See also Goals #l and #2). Disking shall be prohibited.

Action 3.1.2: [n cooperation with Los Angeles County, prepare a local Brush and Fuel Load Vegetation Managemenl Plon in one year ofthe Wilderness Area opening to the public, and review the plan every five years Objective 3.2: Prohibit Fires
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Obiective 3. I : Clear Brush and Modifv Fuel Load
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Prohibit any fires for recreation or maintenance in the Wildemess Area Prohibit srnoking in the Wildemess Area2
Action 3.2.1:

Action 3.2.2:
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Action 1.3.3: [n cooperation with other agencies, design, locate, and develop strategies for acquiring and improving emergency access to the Wildemess Area and facilitating evacuation in the event ofa wildfire
Action 3.3.4: Notifl'the responsible agency ofany identified fire road maintenance needs Action 6.1.1:

Action 6.1.2:

Action 6.1.3:

Action 6. L4:

Obiective 8-l: Ass
Coordinate with appropriate federal, state, or local agencies, such as the Forest Service, U.S. Army Corps of Engineers, Califomia Department of Fish and Wildlife. and/or the Los Angeles Regional Water Quality Control Board, prior to conducting managernent activities in riparian areas Coordinate with the US Forest Service to ensure that management activities are consistenl with the Forest Plan, San Gabriel Mountains National Monument PIan, and San Dimas Experimental Forest
Where feasible, enter into inter-jurisdictional cooperative agreement with allied agerrcies such the Angeles National Forest, the San Gabriel Mountains National Monument, Los Angeles County Department ofParks and Recreation, the cities of Claremont and San Dimas, and non-govemmental organizations, to implement resource management programs Consider entering an agreement rvith local non-profit orgarizations, such as the La Veme Land Conservancy, to assist in resource management activities ure the Manasement Plan remains current conditions chanse Action 8.1 .l : Review the Management Plan as needed and update as necessary 29 30
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o t) ect VC l: Secure t'unds for resou management
Action 9.1.1: Subsequent to any Management Plan actions, consider resource management enhancement actions for potential funding through City project mitigation requirements, or mitigation by others
Action 9.1.2: Apply for funding from watershed management and wildlife enhancement grant programs
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Action 9.2. I : Apply for funding from watershed, watchable wildlife, and parVopen space grant programs
Resolution No. 1232 Page 4
Obiective 3.3: Provide for Public Safetv
Obiective 6.1 : Coordinate with other agencies / interest groups / volunteers / neighbors to complement Citv staffin implementing resource manaqement activities and capital improvements 9 IO
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Phase 2: At which time, staff is directed by the City Council to move forward with Phase 2 of the La Verne Wildemess Area Management and Public Access Plan and/or if any new access points and trails are identified in Phase l, staff will include those during Phase 2, noting that an update to the Environmental Impact Report (as necessary), a public workshop, and City Council approval may also be required prior to implementation.

The follorving Actions u,ill be included in Phase 2 ofthe Implementation Plan:

Action 1.1.3:

Action 1.1.4:

Action L I .5:
hstall public access control signing along selected locations ofthe trail (See Figures 8 and 9) and along Sunrise Ridge Road stating "Habitat Management Area - No Public Access"
Based on results of annual monitoring (see also Objective 7. I ), install public access control railings as necessary to inhibit off-trail use and creation of volunteer trails
Based on results ofannual monitoring (see also Objective 7. 1), decommission, reslore to a natural gradient, and/or stabilize any volunteer trails that have been created
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Action 2.1 .3: Explore the possibility ofinstalling and maintaining up to three lvoody debris racks to discourage debris from moving dorvnstream Obiective 2.2: Provide for Public Safew
Action 2.2.1: Close area to public access during potential rain, flood periods. and wh€n the southem drainage crossing is wet
Obiective 3.3: Provide for Public Safetv
Action 3.3.1: Close area to public access during periods of extreme fire danger, as defined as Fire Weather Waming, announced by the United States National Weather Service
Action 3.3.2: No road ortrail maintenance or fuel management activities shall occur during periods of extreme fire danger (Fire Weather Warning or Fire Weather Watch days, as posted by the United States National Weather Service)
Objective 4.1: Secure Access
Action 4.1.1 : Employ a dedicated easement for public access from Golden Hills Road to the downstream end of the wash within the southem limits of the Wilderness Areal
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Resolution No. 1232 Page 5
Objective L I : Enhance and Protect All Ilabitat Areas
Obiective 2.1: Manage Stormwater. Sediment. and Woody Debris 412
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I Obiective 4.2: Develon Limited Use Facilities
Action 4.2.1 : Identifu space for and create parking spaces, one of which would be an accessible parking space, through striping and/or signage along Golden Hills Road for use to access the Wilderness Area
Action 4.2.2: Develop a foot trail to avoid and/or minimize resource impacts and related mitigation to include:
. An accessible traiVmaintenance route from Golden Hills Road into the wilderness Area
. An approximatety 0.6-mile, 8-foot wide accessible traiV maintenance route from Golden Hills Road leading into the Wilderness Area and forming a loop (conceptual trail shown in Figures 8 and 9), and composed of natural materials with a firm and stable surface Action 4.2.3: Provide benches at key location(s) where there is shade or opportunities to plant trees for fuh.rre shade
Action 4.2.4: Provide interpretive signs at key locations addressing wildlife habitat and use, and respect for privacy for adjacent neighbors
Action 4.2.5: Provide management and safety signs at the GoldeD Hills Road entrance to include information about gen€ral use regulations, a trail map, and universal access conditions, The following information would be conveyed to the trail user:
. Use restrictions
' Permit requirements
' Universal access information, including:
" Degree ofdifficulty rating
' Length of trail segment
o Surface type
. Typical and minimum tread width
" Typical and maximum running slope
" Typical and maximum cross slope
o Change in elevation over the total trail length and maximum elevation obtained
. Presence and danger ofmountain lions, bears, and rattlesnakes l0
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Action 5.1 .2:

Prohibit bicycles and equestrians
Require all dogs to be on leashes pursuant to La Veme Municipal Code Section 6.16.070 Leash Law
Obiective 5.2: Provide a S e Access Point from the CiWt1 Action 5.2.1:

Action 5.2.2:

Develop access entrance on Golden Hills Road
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Resolution No. 1232 Page 6
Objective 5.1: Provide for Public Safetv
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Action 5.2.3: Install an open / lock gate at Golden Hills Road 2 3
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Action 5.3.2:

Action 5.3.3:

Install lockable gates and associated fencing at Golden Hills Road lnstall use and regulatory signs at Golden Hills Road (see also Action 4.2.4 and 4.2.5)
Limit Wildemess Area use from one hour after sunrise to one hour before sunset
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Require groups of l0 or more individuals to obtain a special use permit Clearly inform the public / post all prohibited uses (see also Action 4.2.4 and

4.2.s)
Obiective 5.5: Provide Public Access Prosram Based on Available Staff Resources and Action 5.4.1:

Action 5.4.2:

Action 5.4.3:
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Action 5.5.1:

Action 5.5.2
Phase l: Allorv initial access only to small goups (from 5 up to 20 individuals) through a special use permit system identifuing one designated responsible individual (reviewed annually to determine Phase 2) Phase 2: Based on results of annual use monitoring, issue special use group permits and individual access permits (once implemented, revieu,ed annually to detennine Phase 3)
Phase 3: Based on results ofannual use, allow individual access for general use without permits (once implemented, reviewed annually) Consider engaging and coordinaling with local non-profit organizations, such as the La Verne Land Conservancy, to assist with staffing and patrolling the Wilderness Area
rotect Adiacent Private ProDerty29
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Obiective 5.6: P
Action 5.6.1:

Action 5.6.2:

Action 5.6.3:

Action 5.6.4:

Action 5.6.5:

Maintain approximately 50 feet between the public access trail and existing backyard property lines along Mont€rey Street
Install secure property Iine fencing parallel to Monterey Street where not already existing
krstall signs along boundary lines designating the "Wilderness Area Boundary"
Public access to the Wildemess Area through private properties (including from Calle Aragon and Brydon Road) shall be prohibited
Consult with immediate adjacent neighbors to detail the location and design ofboundary line / public access control fencing parallel to Monterey Street and the Wildemess Area entrance
Resolution No. 1232 Page 7
Objective 5.3: Designate Wildemess Area as Pedestrian Access / Day Use Onlv (No Ovemisht Use) 414
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I Obiective 6.2: Communitv [nvolvement
Action 6.2.1: Consult with immediate adjacent neighbors to detail the location and design of boundary line / public access control fencing parallel to Monterey Street and the Wildemess Area entrance
Action 6-2.2: Consult with the community, including non-governmental organizations, such as the La Veme Land Conservancy, to develop the final trail design 2 3
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Action 7.1.1: Monitor public access conditions at the beginning. middle, and end ofthe primary recreation season and after major stonn events
Action 7.1 .2: Provide onsite management presence on weekends and holidays during the prime use season once the Wilderness Area is open for general use (see Objective 5.5 Phase 3) with City staff as funding allows, or through management agreements, others (see also Objective 6.1)
Action 7.1.3: Establish a Wilderness Area Watch hot line l8
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obi ecti 8\Ie 1: Assll the Manauenrent Plan remat ns current as conditions chanqe Action 8.1 .l : Review the Management Plan as needed and update as necessary (Continued from Phase I )
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ective 9.2: Secure funds for caniIal orovements
Action 9.2.1: Apply for funding from watershed, watchable wildlife, and parl</open space grant programs (Continued from Phase I )
ective 9.3: Secure funds for oublic AC management
Action 9.3.1: Prior to opening the Wildemess Area to general use without permits (reference Objective 5.5 Phase 3), fund a position to monitor and manage the Wildemess Area and coordinate habitat management programs in the Wildemess Area
Section 4. The Chairman shall sign and the Secretary shall attest to the passage and adoption of this Resolution
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Objective 7.I : Coordinate with other aqencies / trail groups / volunteers / nei Citv staff oresence
Objective 9.1: Secure funds for resource management
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APPROVED AND ADOPTED this l0th day of April,2019, by the planning Commission at La Veme, Califomia.

Chairman, Plannin lon
ATTEST:
lhu*
Secretary, Planni ng Commiss ton
Resolution No. 1232 Page 9
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S]sTER C TIES
Crrv or LnVBRNE,

CITY HALL
3660 "D" Street, La Verne, California 91750-3539
www.ci.la-verne.ca.us
October 18, 201 8
Los Angeles County Department of Parks and Recreation
Attn: John Wicker
433 South Vermont Avenue, 4'n Floor
Los Angeles, CA 90020
RE: La Verne Wilderness Plan and Environmental lmpact Report Dear Mr. Wicker,
I am writing concerning the La Verne Wilderness Area. As you may know, the La Verne Wilderness Area comprises approximately 286 acres adjacent to the Angeles National Forest. Most of the Wilderness Area is quite rugged and designated a Hazad Level Code of "3," which indicates the highest fire threat level. A map of the area is attached for your reference. In connection with the City's acquisition of the Wilderness Area, the City received Proposition A grant funding from the Department. For over a decade, the City has worked to achieve a wilderness plan that meets the requirements of the grant, preserves wildlife, protects the area's natural resources consistent with the conservation demands of local resource agencies, and is a valued asset to the communlty.

The Draft La Verne Wilderness Plan and associated Environmental lmpact Report were considered by the City's Planning Commission on October 10, 2018. In a well-attended meeting, many community residents [and others] spoke against the public access component of the plan. Objections included arguments that the proposed loop trail design would not be inviting to users and would require significant on-going maintenance due to storm water flows. Others argued that the proposed public access would overly burden nearby residences with traffic and parking impacts. Concerns were also raised regarding public safety, and the increased potential for wild fires in this area due to this area being designated a Hazard Level Code of "3," which indicates the highest fire threat level. Adding to this, the proposed loop trail was also opposed by The La Verne Land Conservancy, who was the proponent who secured the grant funds in 2006. The California Department of Fish and Wildlife has also weighed in, strongly criticizing the environmental impacts posed by the loop trail.

Faced with no vocal support for the public access component contained in the plan, the Planning Commission continued the hearing to December 12, 2018 and requested staff to obtain addition information regarding the required threshold of "public access" for these wilderness lands in order to satisfy the grant funding requirements.

The Wilderness Area was acquired by the City with a combination of Proposition A (Safe Neighborhood Parks Proposition of 1996) and California Proposition 50 funds. The requirement of public access is set out in the Project Agreement (Grant No. 58Ml-06-2075).

Section J.3 orovides.

General Administration 909/596-8726 . Water Customer Service 909/596-8744 . Parks & Community Services 909/596-8700 Public Works 909/596-8741 o Finance 909i596-8716 . Community Development 909/596-8706 . Building 909/596-8713 Police Department 909/596-1913 . Fire Departmenr 909/596-5991 . General Fax 909/596-8737418 September 19, 2022 City Council Meeting
La Verne Wilderness Plan and Environmental lmoact ReDort October 18. 2018
"Grantee agrees to provide for reasonable public access to lands acquired in fee with grant monies, including the provision of parking and public restrooms, except where fhal access may intefiere with resource protection."
The La Verne Wilderness Area currently has existing public access by way of an unpaved road and trails. Access to the Wilderness Area plateau is currently available from the west via an unimproved parking area off of San Dimas Canyon Road and a well-used foot trail that connects with Mountain Springs Ranch Road to the east (See #1 on Map). Headlng south, Mountain Springs Roads leads directly into the Wilderness Area. Additionally, from the northeast, Sunset Ridge Road travels down from Sunset Peak within the Angeles National Forest and along the border of the San Dimas Experimental Forest to the Wilderness Area, merging into the aforementioned Mountain Springs Ranch Road. While the southern access to Mountain Springs Ranch Road accesses a City water tank, this southern access first tracks through a gated community. The City possesses only a limited easement through the community and, although often accessed by mountain bike users going through the community without permission, this is not considered a feasible public access ooint from the south.

The Wilderness Plan proposes one additional public access at the southern boundary of the Wilderness Area by way of a pedestrian easement next to Golden Hills Road, a paved collector road. The pedestrian easement connects to a proposed loop trail.

While this additional access and proposed loop trail would enhance public access, the City's Planning Commission raised concerns that those gains are potentially offset by both environmental and community concerns related to the Golden Hills Road access and the proposed loop trail.

The Planning Commission has asked for clarification as to whether the additional public access from Golden Hills Road into this high fire zone is necessary in order to satisfy the terms of the grant, noting that public access points already exist and the City has no plans to restrict use at those Doints.

The Commission has also asked if the Department has any guidance or definiiions as to the scope of the "public access" requirement contained in the grant so that we can better advise the City in considering public access alternatives. For instance, does the Department consider docent lead groups as meeting the public access requirement when compared to largely unfettered public access?
Thank you for considering the City's concerns. We would be please to meet with you or other Department representatives to discuss any additional details of the Wilderness Plan or to address your questions. I can be contacted by email at [email protected] or by phone at (909) 596-8706.

Sincerelv.

Candice Bowcock
Senior Planner
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tOS ANGETES COUNTY

REGIONAT PARK AND

OPEN SPACE DISTRICT
R POSD.locounty.gov
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twitter. com/R POSD
1O0O S Frenror]t Ave. [Jnrt,140 . Buildi'rg A-9 Eclst, Ground Floor . Alhombro CA 919O3 November 26, 2018
(626) 588-5060
Ms. Candice Bowcock
Senior Planner
City of La Veme
3660 "D" Street
La Verne, CA 91750
Dear Ms. Bowcock:

LA VERNE WILDERNESS PLAN AND EIR
I am writing in response to your letter, dated october 19,2018, regarding the La Verne wilderness Area, and opposition faced by the city of La Verne (city) to proposed improvements to land in the area.
our records indicate, that the Trust for public Land (TpL) entered into a project Agreement for a grant from the Regional park and open space District (RposD) on october 27, 2005, for the Marshall canyon conservation corridor Acquisition project, Grant No. 58M1-06-2075 (Acquisition project). The total amount of the grant was $294,145 and the scope of work completed was the purchase of 236 acres of unimproved real property located in the Marshall canyon area of the city and adjacent unincorpoiated area, now known as the La Verne wilderness Area. The project Agreement was assigned to and assumed by the city in April of 2o11 through an Assignment and Assumption agreement between the City, TPL, and RPOSD.
on December 6, 2016, the city entered into a project Agreement for a grant from RposDfor the La Verne wildemess Area General lmprovements project, Grant No; 58F2-17-2626 (Development project). The total amount of the grant is $650,000 and the scope of work to be completed includes, but is not limited to sitepreparation, signage, construction of a loop trail and debris barriers, and the native plant landscaping within the La Verne wildemess Area. The city has yet to claim any reimbursements and the entire 9650,000 remains in the grant. 422
September 19, 2022 City Council Meeting
Ms. Candice Bowcock
November 26,2018

In your letter, you assert that the city is facing opposition (environmental and community concerns) to completing the proposed improvements for the Development project Furthermore, the city has requested for guidance on public access requirements and the level of public access required to satisfy the grant terms.

The current level of public access to the wilderness Area is sufficient to meet the reasonable public access requirements of both the Acquisition project and the Development Project. Docent led tours are also sufficient.

However, the scope in the Development Project includes trail development and the creation of an additional public access point along with other improvements. lf the proposed improvements detailed in the scope of the Development project are infeasible, then the City may need to request termination of the grant and relinquish its claim to the $650,000 for the project. The city also has the option to request to amend the project scope; however, a scope change must be mutually agreed between the city and RposD.

For additional questions or concerns, please contact Mr. Albert Ablaza, your RPOSD Grant Officer for both grants, at (626) S88-S040 or by e_mail at [email protected].

Sincgrely,
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Jollfr Wicker
Director, RPOSD
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c: City of La Verne (8. Russi, B. Aguirre, D. Keesley)
Board of Supervisors, Fifth District (S. Nemer)
RPOSD (J. Beesley, A. Jordan, W. Ontiveros)
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September 19, 2022 City Council Meeting
Candice Bowcock
From:

Sent:

To:

Subject:

Anne Larkin < [email protected] >
Tuesday, August 14,2018 6:18 PN4
Candice Bowcock
La Verne Wilderness Area Management and Public Access Plan proposed project To: La Verne Planning Commission
Project: La Verne Wildemess Area Management and Public Access Plan We hope that the TEN city-owned parcels of land plus the 150 acres already owned by La Veme in the San Gabriel Mountains National Monument will remain as wilderness.

We ask that you continue to leave the land as an open space preserve - available to wildlife and not human life.

Negative possibilities:

Insurance liability
Risk of accidents to human life
Risk of accidents to animal life
Trampling of important grasses, etc.

Rescues of human life
Fire dangers
Necessities for adding humans to the area:

Parking lot
Safe enclosures for hiking, walking, etc
Picnic safe areas
Marking of boundaries
Trash pick up
Policing for possible drug havens
In the past six months, we who live at 2306 del Marino have noted that one young mountain lion strolled through the back yard. Bobcats have been seen in our back yard on several occasions.

Let's not take away any more of the area that they need for their survival.

Thank you,
Anne and Ed Larkin
2306 del Marino
La Veme, CA 91750
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September 19, 2022 City Council Meeting

TIIE LA VERNE LAND CONSERVANCY
August 14, 201 8
Ms. Candice Bowcock
Senior Planner
Community Development Department
City of La Verne
3660 "D" Street
La Verne, CA 91750
Re: Comments Regarding the La Verne's Draft Environmental lmpact Report and Wilderness Area Management and Public Access Plan
Dear Candice,
The La Verne Land Conservancy (LVLC) has reviewed the La Veme Wilderness Area Management and Public Access P/an (Management Plan) dated May 2018 and corresponding Draft Environmental lmpact Repoft (DEIR) dated April 2018. LVLC has been consistently and aclively involved in the La Verne Wilderness Area from the initial acquisition of the parcels in 2005 through the current efforts by the City to evaluate optrons for the continued protection and possible enjoyment of the open space by the community. lt has been our goal over the pasl 1 1 years, to not only ensure the protection and preservation of lhe valuable biological resources within the wilderness area, but to come up with a viable plan that would provide members of the community with opportunities to enjoy the wonderful area through a variety of passive recreational oursuits.

We appreciate the efforts, time and funds expended by the City to develop the Management Plan and the DEIR; it has been 10 years since the last effort to develop a management strategy for the open space, so we are happy to be moving forward! We also understand the difficulty in attempting to create a plan that addresses all of the various, and at times opposing, objectives and needs for the open space.

We agree with the findings of the DEIR with some exceptions. Our concerns and comments regarding both documents are provided below.
1) The DEIR was completed after the City had created a draft of the Management Plan, and it appears it was written to help bolster the strategies and outcomes presented in the Management Plan. By attempting to tt the DEIR into the confines of the "goals" of the Management Plan, the merits ofthe DEIR are lessened, i.e., findings that should have been unbiased are now biased.
2) The Management Plan identifies flood control as an objective, and as consequence, the DEIR addresses flood control. Both documents clearly state that while flooding may be an issue in the foothills above La Verne, "managing" those flood waters (i.e., construction of flood control features such as debris basins) is not allowed on the parcels purchased with State and County grant funds. The DEIR should focus on "managing the open space" not managing floods. We do not believe that discussing options or opportunities for managing 425
September 19, 2022 City Council Meeting
3)
Ms. Candice Bowcock August l4,2018
potential flood waters is appropriate in either document. The documents should be focused on the environmental threats associated with allowing some limited human access in the wilderness areas, not on controlling a flood event that may happen regardless of whether people are allowed in the open space or not. We suggest that the City address managing potential floods in a separate study/document.

On page 3 of the DEIR, three alternatives to the Management Plan are presented:

Alternative 1 : No Project, Alternative 2: No Dogs Permitted, and Alternative 3: Trail to Lookout Point. The DEIR addresses the "No Project" alternative and concludes that while this alternative may be environmentally superior, it "would not achieve any of the project objectives" and because the primary objective of the Management Plan is to "facilitate the public use of the Wilderness Area as required by the land grant," the No project Alternative is not a feasible alternative. Alternative 2, No Dogs Allowed, would not change the usage of the open space, and any concerns would be mitigated by dogs being leashed.

Alternative 3, Trail to Look Out Point, appears to be the best alternative reviewed: the trail would essentially require the same amount of soil disturbance (0.4 acres), it would reduce the amount of time visitors would spend in the southern portion of the Wilderness Area better preserving the privacy of the neighboring homes; it would decrease potential impacts to biological resources that may occurwhile grading and building the Ioop trail, while achieving the same public accessibility; it would retain more permeable surface area in the southern portion of the Wilderness Area by residential homes thereby absorbing and conveying more runoff than if the loop trail were implemenled, and it would entail the same habitat management and minor site improves as those provided in the Management Plan.

This alternative also meels the City of La Verne's General Plan (1998) Policy 1.2, under Resource Management: Develop a connecting trail system. While this alternative was identified in DEIR as being preferable to the "No Project" alternative and environmentally similar to the Management Plan (i.e., the loop trail), no details were provided in either the Management Plan or the DEIR regarding where the "lookout point" was or what the trail would look like - no maps or descriptions were provided in either document. We support Alternative 3 but would like to have seen some details regarding the alternative presented both documents.

The Management Plan has described creating a "loop trail" that is 6 feet wide behind the homes on Monterey. This area, which is degraded, will not provide the "hikers" or trail users with an experience that warrants spending City funds to develop, maintain or manage. lt is highly unlikely that trail enthusiasts would venture onto the loop trail to merely walk in a circle, on a dirt "track," behind houses (and soon to be sandwiched between the homes on Monterey and the planned Sage Canyon development), in an area that is unattractive, and will only provide limited shaded areas.

The loop trail does not provide the community "reasonable public access" as required by the grant documents. The 5 acres where the loop would be built represent only 2.4% of the open space that was given to the City in 2005 (purchased using County and State funds) or only 1.4ok of the total open space in north La Verne. As stated above, one of the City's own General Plan objectives was to "connect trails." The loop trail does not constitute a trail 3)
4)
7407 EoorHtLL BouLEv^Rrt, PMB 773
LA VERNE, CALtEoRNtA 91 750
(909) 223-7293
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September 19, 2022 City Council Meeting
Ms. Candice Bowcock August 14,2018
connection. We recommend that if this trail is constructed, it be done with the intention of connecting it at later date with trails that extend further into the wilderness area. 5) DEIR: lmpact HWQ-1: Hydrology & Water Quality: Soil disturbance may create polluted run- off. Construction is not allowed on the protected open space; installation of trails and benches will not require the development of a Spill, Prevention, Control and Countermeasures (SPCC) plan. The plan prescribes "hazardous materials handling procedures for reducing the potential for a spill during construction." Because construction is not allowed, such a Dlan is not needed.
6) DEIR lmpact T-1: Transportation and Traffic: Locating all parking spaces on the north side of Golden Hills Road significantly reduces the number of parking spaces available.

Installation of a crosswalk, with striping and lights seems excessive.

Finally, the LVLC has been in discussions with the Trust for Public Land (TPL) and the Watershed Conservation Authority (WCA) [part of the San Gabriel and Lower Los Angeles Rivers and Mountains Conservancy (RMC)I about the possibility of expanding the protected areas in North La Verne, and the potential for transferring the City-owned open space to the WCA as part of regional plan aimed at connecting open space areas across the San Gabriel Mountain foothills. TPL is actively engaged in talking with property owners and both TPL and WCA are interested in discussing the possibilities with the City of La Verne. Acquisition of one or two additional parcels in North La Verne could dramatically improve the potential for connecting trails, and the same time would ensure the protection of some very unique riparian habitat. We recommend that the City be available for future discussions with TPL and WCA, and be open to the possibility of expanding the open space areas and extending the trail network.

We appreciate the opportunity to submit our comments regarding the Draft Environmental lmpact Report and Wilderness Area Management and Public Access Plan, and look foMard to working with the City as this project progresses.

Sincerelv.
e/,2;--
Katherine Winsor
President
La Verne Land Conservancy
cc: Members of the La Verne Land Conservancy, via e-mail 7407 FoorHrLL B0ULEVARD, PMB 773
LA VERNE, CALtFoRNtA 91750
(909) 223-1293
427
September 19, 2022 City Council Meeting
State of California - Natural Resources Aqencv EoMUND G.8RowNJR.. Governor

DEPARTMENT OF FISH AND WILDLIFE
South Coast Region
3883 Ruffin Road
San Diego, CA 52123
(858) 467-4201
www.wildlife.ca.gov
August 14, 201 B
Candice Bowcock, Senior Planner
City of La Veme Community Development
3660 O Street
La Verne, California 91750
E-mail: cbowcook@cityofl averne.org
CHARLTON H, BONHAM, D,rector
Subject: Draft Environmental lmpact Report (DEIR) for the La Verne Wilderness Aroa and Public Access Management Plan, Los Angeles County, SCH # 2016091030 Dear Ms. Bowcock:

The California Department of Fish and Wildlife (CDFW or Department) received a Notice of Availability of a DEIR from the City of La Verne (City), as lead agency, for the La Verne Wilderness Area and Public Access Management Plan (pro.lect) pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines.

Thank you for the opportunily to provide comments and recommendations regarding those activities involved in the proiect that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources and holds them in trust by statute for all the people of the state (Fish & Game Code, SS 71 1 .7, subd. [a] & 1802; Public Resources Code $ 21070; CEQA Guidelines S 15386, subd. [a]). As trustee, CDFW has jurisdiction over the conservation, protection, and management of fish, wildlife, native planls, and habilat necessary for biologically sustainable populations of those species (|d., $ 1802). For purposes of CEQA, CDFW is mandated to provide, as available, biological expertise during public agency environmental review, focusing on projects/activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Public Resources Code S 21069; CEQA Guidelines S 15381). CDFW expects lhat it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteratron (LSA) regulatory authority (Fish & Game Code, S 1600 et seq.). To the extent implementation of the project as proposed may result in "take" as defined by state law of any species protected under the California Endangered Species Act (CESA; Fish & Game Code, S 2050 et seq.) or slate-listed rare plant pursuant to the Native Plant Protection Act (NPPA; Fish and Game Code $1900 et seq.) authorization from CDFW as provided by the applicable Fish and Game Code will be required.

Qanserving Caffirnia's'lilitdffi Since 1 S 70
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September 19, 2022 City Council Meeting
Candice Bowcock, Senior Planner
City of La Veme Community D€v€lopment
August 14, 2018

PROJECT DESCRIPNON SUMMARY
Proponent: City of La Veme
Objective: The Project encompasses 208 acres of land acquired through stat€ grant funds from the Wildlfe Cons€Nation Board (WCB) in cooperation with the County of Los Angeles, the Trust for Public Land, and the La Verne Land Consen€ncy. This granfacquired land was combin€d with 150 acres already owned by the City to create an open space preservo totaling 3S8 acres, collectively refened to as the Wildemess Area. The project provides goals/policies for managemenl and specific physical improvements to impl€ment the vision for the Wildemess Area, including selective habitat enhancemenl, the resolulion of public safety hazards, and providing controll€d public access as parl of the City's stewardship responsibilities. project activities are limiled to minor site improvements such as foot trails, benches, and signage, and would not involve demolition of structures, grading, construclion of new facilities, or use of heavy construction equipment. lmplemontation of all future minor site improvaments in the Management Plan will require further evaluation through the City's development review proc€ss and CEQA process when warranted, and appropriate mitigation measures would be idenlified at that time.

This DEIR includes a discussion of three altematives to the proposed Management plan. Thoy are as follows:
. Alternatlve 1: No project
. Altornative 2: No Dogs Permitted
o Alternative 3: Trail to Lookout Point
Location: The Wildemess Ar€a consists of ten City-ownod parcels lhat is tocated norlh of Golden Hills Road, east of Mountain Springs Ranch Road, and west and northwest of Monlerey Street, Catle Aragon, and Brydon Road in the City of La Veme, Los Angeles County. Elevation on-site ranges fiom 1 ,435 feet in lh€ southwest corner to 3,165 feet in the northeast comer of the site. The Wildemess Area is located within, and sunounded lo the wesunorthwest, norlh, and east by the 2014 San Gabriel Mountains National Monument portion of the Angeles National Forest.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the project's signiticant, or potentially significant, dir€cl and indirect impacts on fish, wildlife, and botanical (biological) resources. Editorial comments or other suggestions may also be included to improve the document. l. Project Descriptlon and Rolated lmpac{ Shortcoming
lmpacts to Riparian Resource8
Comment # 1; The project Management Ptan, under Goal 3, Objectve 3.i, Ac{ion 3.i.1,

southem portion of the Wildemess Area annually.
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September 19, 2022 City Council Meeting
Candice Bowcock. Senior Planner
City of La Verne Community Dev€lopment
August 14, 2018

lssue: CDFW is concorned that the project includes activities that may significantly impact streams subject to nolification under Fish and Game code section 1600 el seg. CDFW has observed that irnpacts to riparian/stream resources ftom implementation of weed abatement activities identified in the Management Plan are generally are not adequately characterized or otherwise addressed.

Specific impacts: The proiect may result in lhe loss and/or degradation of streams and associated watershed function and biologioal diversity.

Uthy impacb would occur: Ground and v€getation disturbing activities associaled with weed abatement including, but not limited to grubbing, trampling, use of herbicides, and driving vehicles would physically remove vegetation or disturb ground surfaces resulting in erosion or otherwise alter existing stresms or their watershed function and associaled riparian habitat. Up- and down-stream drainages and associated biological resources beyond the project area tootprint may also b€ impacted by project+elated sediment or alter€d storm water runoff.

Evidence impacts would be significant: The projecl may substantially adversely affect existing habitat and topography at the project site through the alteration of a stream, which absent specific avoidanco or mitigation, could result in substanlial loss of biological resources and significant erosion or siltation on-site or off-site of the projecl.

Recommended Potentially Feasible Mitlgatlon Measure(s)
Mitigation Measure #1: CDFW has concluded that the project and related activities may result in the substantial alteration of slr6ams. For any such activities, the proiect applicant (or'entit/) must provide wriften nolification to CDFW pursuant to section 1600 et seq. of the Fish and Game Code. Based on lhls notification and oth€r information, CDFW determines whether a LSA agreem€nt with the applicant is required prior lo conducling the proposed activities. A notification package for a LSA agreement may b€ obtained by accessing CDFW'S web site at www.wildlife.ca. gov/habcon/1 600.

CDFW's issuance of a LSA agreement for a project that is subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. As a Responsibl€ Agency, CDFW may consider the CEQA document of the Lead Agency for the p@ect. However, the DEIR cunently do€s not meet CDFW's standard cunently because lt does not adequately delineate/map, characterize or inv€ntory existing stream or riparian resources on-sit6 or identify/quantify project impacts to such resources. To minimize additional requirements by CDFW pursuant to section 1600 et seq. and/or under CEQA, the final CEQA document should fully identify lho potential impacts to lhe stream or riparian resourc€s and provide adequate avoidance, mitigation, monitoring and reporting commitments for issuanc€ of a LSA agreement.

Mitigation measure #2: Any LSA agreement issued for the project by CDFW will condition measures to protect stroamb€ds on-site and up- and down-stream of the project, including erosion and pollution oontrol measures. The LSA may also be conditioned to include r€sour@ avoidance and/or on-site or ofi-site creation, enhancement or restoralion of mitigation lands (with protection and management in perpetuity) to compensate for any direct and/or indirect imoacts to stream or riDarian resources.
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September 19, 2022 City Council Meeting
Candioe Bowcock, Senlor Planner
City of La Verne Gommunity Development
August 14,2018

lmpacts to Spscial Status Species.

Comment #l: Page 9 of lhe project Management Plan describes fire hazard risks and states, "filandowners, and in many cases HOAS, are responsible for meeting fire hazard reduction standards on privately owned open spaces within established neighborhoods. Existing woodland understory within 200 feel of existing residences south of the Wildemess Area has been altered by annual vegetation removal since the eady 1980s. The City's Public Works Department manages vegotation managem€nt programs for all City-ownad land, which includes the Wilderness fuea. In addition, the City's Community Wildfire Protection Plan contains fuel modiflcation guid€linas for residential properties in this area and continued adherence to thet plan should conlinue to protect lhese neighborhoods from fire risks, to th€ enent possible.

Continued inter-agency coordination betweon the City of La Verne, Los Angeles County, and neighboring foolhill cities for future fire management would also help lower fire risks.' The proiect llanagement Plan, under Goal 3, Objoc'tive 3.1, Action 3.1.2, Page 2l states, "[i]n cooperation wilh Los Angeles County, prepars a local Brush and Fue! Load Vegetation Management Plan in one year of the Wilderness Area opening to the public, and review the plan every five years.'
lssue: CDFW is concerned that, generally, protection of biological resources by entiti€s performing weed abatement are nol sufficient, and as a result sensitive biological resources may be adversely impactod by such activity. CDFW is concerned that the DEIR and/or Management Plan do not appear to fully describe: 1) if weed abatement activities may r€move or dislurb special status vegelative communitios or sp€cial stalus species; 2) if the City will authorize or does authorize private residences or their agents lo conduct weed abatement in lhe Wilderness Area; and, 3) if preconstruction surveys, avoidance and mitigation measures are or will be utilized during weed abatement activities conducted within the Wilderness Area. In addition, the DEIR and Management Plan should include evaluation of alternatives (including no encroachment) to r€duce impacts from brush cl€aring, including targeted thinning, placemonl of walls, and structural/building features (boxed eves, fire.raled walls and windows, sprinklerc, etc.), especially whare d€velopment occurs adiacent to lhe Wildemess Area. Portions of the Wildemess Area were acquired using grant funding from the WCB to protect native habitat; activiti€s that are destructive to biological resources on the Wild€mess Area may be conlrary to the purpose of the intent of the grand funding agreement with WCB.

For example, th€ projecl site supports coastal prickly pear (Opunfla spp.) sctub and associat€d biological r€sourc€s that could be adversely impacted by weed abatem6nt activities. Prolect impacts to coastal prickly pear scrub should be considered a direct and cumulative impact under CEQA. Coastal cactus scrub is imperiled throughout its.ange including the poect aroa along th6 San Gabriel Fooihills as a result of development, wildfire, and unregulated brush clearing activities. Some coast prickly pear scrub alliances are also considered rare (Sawyer et al. 2008) and should be analyzed as such in the DEIR in determining impact significance, avoidance, minimization, and mitigation measures. Also, cactus and succulents are often considered fir€- resistant plants that are appropriate within fuel management areas, reducing the need to remove these species for fire prot€ction purposes.

Because th€ project site supports coast prickly pear scrub, the polential for tho site to also support coastal cactus wren (Campylorhynchus brunneicapillus) is high. Coastal cactus wren is consid€red a Califomia sp€cies of special concem (SSC). Coastal cactus wren is also 431
September 19, 2022 City Council Meeting
Candice Bowcock, Senior Planner
City of La Verne Community Development
August 14, 2018

considered by CDFW as a sensitive bird species of greateEt conservation need in San Diego, Orange, Los Angeles, and Ventura County because it is solely dependent upon cactus patches for reproduction. Pockets of cactus patches also provide vital refugia habitat for coastal cactus wren dispersing lo other areas of habital in southern Califomia and is critical in buffering the effects of habitat losses which can lead to genelic isolation and local extirpation.

Specific impact: Population declines of special status species and v€gelation communities resulting in direct localized extirpation and/or conhibution to their cumulaiive extinction.

Why impact would occura The DEIR do6s not provide information on pr+.construction surveys for special status species and vegetatiw communities during weed abatement actiMties. The DE|Rdoes not appear to include a polioy and/or measure that personnel who perform weed abatement be qualified to recognize and avoid special status biological resources when removing or otherwise managing vegetation. Weed abatement may result in direct mortality or injury to special status biological r€sourc€s frcm activiti€s such as trampling by equipment and pe,sonnel, herbicide use, direc't removal of special status plant species, and altoring bird nesting behavior.

Evidence impact would be significant: The project may have a substantial adverse effect, either directly or through habitat modifications, on a species identified as a candidate, sensitive. or special status sp€cies in local or regional plans, policies, or relations, or by CDFW or the United States Fish and Wildlife Service (FWS). Loss of breeding, foraging and movem€nt (dispersal) habitat for coastal cactus wren or other special status species should be considered a significanl direct and cumulative adverse effect under GEQA without implementing appropriate avoid and/or mitigation measures (CEQA Guidelines SS 15064, 15065, 15125[cl and 15380).

Recommond6d Potentially Feasible Mitigation Measure(s):

Mitigation Measure #1: CDFW recommends that prior to any proposed weed abatemenl activiti€s, the DEIR identify a requirement to conduct a biological resources survey and implemenl avoidance/mitigation measures for sensitive species (e.g., cectus wren, coastal gnatcatch€r) that are consist€nl with the resource protective measures described in the DEIR and Management Plan for all lhe other proposed project activities.

Mitigation measures should include (but not be limited to) having qualified biologists perform pre-project surveys for special status sp€cies, employing a biological monitor during all weed abatement activilies to direct avoidance of nesling birds and special status species and v€getation communities, and the r€storation or enhancement of habitat for biological resources disturbed by weed abatement activities. For example, there may be many opportunities for enhancement, restoration and creation of native Opuntr'b spp. cactus scrub and coastal sag€ scrub habital to offset unavoidable project impacts or through the habitat enhancement goals described in the Management Plan.

Mitigation Measure #2: Private prop€rty landowners should not be authorized by the City or other entilies lo perform weed abatemenl or other activities that would impact biological resource within the Wilderness Area without following the biological resource protective measures described above in Mitigation Measure #1.
432
September 19, 2022 City Council Meeting
Candic€ Bowcock, S€nior Planner
Clty of La Verne Community D€velopment
August 14, 2018

Comment #2: The DEIR describes efforts to survey for special status spocies to inform avoidance and restoration measures resulting from various proposed project activities. lssue: CDFW is concerned that surv€y efforts described in the DEIR may not include measures for the San Gabriel chestnut snail (Glwtostoma gabrielense), which may occur in the Wildemess Area where suitable habitat exists. San Gabriel chestnut snail has a staie rarity ranking of 32 or imperiled in the state because of rarity due to a very restricted endemic range in Los Angeles County. San Gabriel Chestnul Snail has been documented in several areas in the San Gabriel Mountains including the City of Eradbury and may escape detection by survey biologists because of its small size and secretive behavior.

Specific lmpac.t: The project may result in direct and/or indirect take or injury of San Gabriel chestnut snail orthe loss ils habitat resulting in direct local and cumulative extirpation or extinction of this species (CEQA Guidelines $$ 1506a, 15065, 15125[cl and 15380).

Why impact would occur: lmpacts to San Gabriel chestnut snail could result from vegetation clearing and other ground dislurbing activities resulting in in crushing, filling, or desiccation of aclive snail refugia habitat.

Evidence impacts would be signiflcant Project impacts may continue to result in subslantial adverse efiects, either directly or lhrough habitat modificauons, on any sp€cies identified as a candidale, s6nsitive, or special status species in local or regional plans, policies, or regulalions, or by CDFW or FWS. Adv€rse impacts to San Gabriel chestnut snail or their occupied habitat could continue to b€ significant becaus€ the DEIR does nol provide measures to fully detect for presence of this species and provida adequate take avoidance and habitat mitigation for loss of occupied habitat if prosent.

Recommended Potentially Feasible Mitigation Moasure(s):

Mitigation Measure #l: CDFW recommends the Gity require lhat survey measures be performed on the projoct site by qualified malacologisls with experience in detecting San Gabriel chestnut snail to maximize deteclion and avoidance of this species.

Mitigation Measure #2: The Center for Biological Div€rsily (CBD) has petitioned the United States Fish and Wildlife Service to list the San Gabriel Chestnut snail under the Federal Endangered Species Act (CBD.2017).The petition provides useful information on the habitat r€quirsments, threats and managernent recommendations that the City may find useful in adequately planning proj€ct activities to avoid significant impacts under CEQA for lhis species (see website: hftps://www.biologicaldiversity.org/species/invertebrates/pdfs/2017-San-Gabriel Chestnut_ESA-Petilion.pdf ). Specifically, the p€tition states, existing occupied sites should be protected from all activlties that would alter microsite characteristics, including buffer areas large enough to moderate fluctuations in humidity, temperature, and oth€r environm€ntal characteristics of critical importance to ten€strial mollusks. Care should b€ taken to maintain refugia such as downed wood and debris piles. Nativs plant communities should be maintained around occupied sites to provide shade, food sources, and substrates forfungi. Care should be taken to avoid soil compaction and maintain vegetative litler. Pesticides and horbicides should not be applied in or near snail habitat. Educational signs should b€ insialled and site closures should be considered to protect the San Gabriel chestnut snailfrom recreational impacts on lhe Angeles National Forast."
433
September 19, 2022 City Council Meeting
Candice Bowcock, Senior Planner
City of La Veme Community Development
August 14, 2018

Genoral Consadoration for Native Nesting Birds
CommEnt #l: The DEIR on page 58 describes native vegetation that could provide suitable nesting habitat tor avian species occuning within th€ project ar€a and the immediat€ vicinity and states, nesting birds are prot€cted by Califomia Fish and Gamo Code 3503 and the Migratory Bird Treaty Act."
The DEIR describes measures to avoid impacting native nesting birds. One measure included is Policy 4.2. (page 64) titled " Protect and prcseve our natNe plant cammunities and habitats' which states in 4.2,e- to reslrict habitat upset to non-nesting months in accordanc€ with the Migratory Bird Treaty Act.'
lssu€: CDFW is concerned that th6 DEIR primarily focuses prolective measures for native nesting bird on proiect related activities conducted within native vegetative communities only.

The Department is concemed that project activities may result in incidental take of native birds if no additional take avoidance measures are proposed within disturb€d, nonnalive vegetalion where the majority of the propos€d w6ed abatement and habitat restoration will take place.

Citing the Migratory Bird Treaty Act as a proteclive measure to avoid incidental take of native bird species should be clarified in the DEIR considering the Department of Interior's recent interpretation of strictly enforcing incldental take of native birds under the Act (see https://www.doi.gov/sileddoi.gov/files/u ploads/m-37050.pdO.

Specific impact: The project may result in death and injury to native bird eggs or young and th€ disruption of natural bird breeding behavior.

Why impact would occur: Focusing avoidance/minimization measures for native birds during project activities lo areas only within native vegetation may result in inadequate delection efforts and take avoidance of aclive nests during project activities conducted within non-nalive vegetation. Project actiMties lhat could advesely impact nesting birds includes (bul are not limited to) vegetation removal/disturbances, ground disturbances, or any other project related disturbances within or adjacenl to nonnative vegetation that could r€sult in incidental take of native birds.

Evidence impac.i would be significant: Proj€ct impacts may result in substantial adverse effects, €ilher directly or through habitat modifications, on any species identified as a candidate, sensitive, or special stalus species in local or rogional plans, policies, or regulations, or by CDFW or the USFWS, and. The projecl may also impede the use of native wildlife nurcery sites.

Recommended Potentlally Feasible Mliigation Measure(s):

Mltigation Moasure: To reduce proj€ct impacts to native birds to less than signilicant under CEQA, CDFW recommends that the City include, as a condition of project approval, that clearing/dislurbing of any v€gelaton, building demolition and conshuction within any habitat that could support native nesting birds, occuroutside of the peak avian breeding season, which generally runs from February 1"'through Septemb€r 1d (as earty as January 1 for some raptors). lf project construction is unavoidable during the bird breeding season, a qualified biologist with exp€rience in conducling bird breeding surve),s should conduct w€€kly bird surveys for nesting birds during work in the area wilh the firsl surv€y commencing wilhin threo days prior lo initiation of work to ensure that no nesting birds in the proiect area would be 434
September 19, 2022 City Council Meeting
Candice Bowcock, Senior Planner
City of La Veme Community Development
August 14,2018