Moreno Valley City Council
February 17, 2026

CADRE
Environmental
October 2025
Bradshaw Collection Tentative Tract Map 37858
City of Moreno Valley, California
Prepared for:

RC Hobbs Companies
1428 East Chapman Avenue
Orange, CA 92866
Contact: Shay Mueller (714) 633-8100
Prepared by:

Cadre Environmental
701 Palomar Airport Road, Suite 300
Carlsbad, CA 92011
Contact: Ruben Ramirez, (949) 300-0212

FINAL REPORT
Biological Resources Technical Report
Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 i

TABLE OF CONTENTS

PAGE
INTRODUCTION 1
PROJECT LOCATION & DESCRIPTION 1
METHODOLOGY 1
LITERATURE REVIEW 1
FIELD SURVEYS 2
EXISTING ENVIRONMENTAL SETTING 6
SURROUNDING LAND USES/TOPOGRAPHY/SOILS 6
VEGETATION COMMUNITIES 6
GENERAL WILDLIFE SPECIES 14
JURISDICTIONAL RESOURCES 14
SENSITIVE BIOLOGICAL RESOURCES 15
FEDERAL PROTECTION AND CLASSIFICATIONS 16
STATE PROTECTION AND CLASSIFICATIONS 17
SENSITIVE HABITATS 20
SENSITIVE PLANTS 20
SENSITIVE WILDLIFE 23
REGIONAL CONNECTIVITY/WILDLIFE MOVEMENT CORRIDORS 37
REGIONAL AND REGULATORY SETTING 38
MSHCP COMPLIANCE ANALYSIS 38
LOCAL 42
FEDERAL 45
STATE 47
ENVIRONMENTAL IMPACTS 49
THRESHOLD OF SIGNIFICANCE 49
DIRECT IMPACTS 51

INDIRECT IMPACTS

56 CUMULATIVE IMPACTS 57
CONSERVATION MEASURES 58
LITERATURE CITED 60

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 ii

LIST OF FIGURES
PAGE
1 – Regional Location Map

7 2 – Project Site Map 8
3 – MSHCP Relationship Map 9
4 – Vegetation Communities Map 10
5 – Current Project Site Photographs 11
6 – Current Project Site Photographs 12
7 – Soils Association Map 13
8 – Vegetation Communities Impact Map 54

LIST OF TABLES
PAGE
1 – Vegetation Communities Acreages

14 2 – Sensitive Plant Species with Potential to Occur Onsite 21 3 – Sensitive Wildlife Species with Potential to Occur Onsite 24 4 – Project Site Vegetation Community Impacts 55

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 iii

GLOSSARY
AMSL Above Mean Sea Level
APN Assessor’s Parcel Number
BMPs Best Management Practices
CAPSA Criteria Area Plant Survey Areas
CDFG California Department of Fish and Game (CDFW effective Jan 1st 2013) CDFW California Department of Fish and Wildlife
CESA California Endangered Species Act
CEQA California Environmental Quality Act
CNDDB California Natural Diversity Database
CNPS California Native Plant Society
CRPR California Rare Plant Ranking
CWA Clean Water Act
DBESP Determination of Biological Equivalent or Superior Preservation FESA federal Endangered Species Act
GIS Geographic Information System
HANS Habitat Acquisition and Negotiation Strategy
JPR Joint Project Review
MBTA Migratory Bird Treaty Act
MND Mitigated Negative Declaration
MSHCP Multiple Species Habitat Conservation Plan
NCCP Natural Communities Conservation Plan
NEPS Narrow Endemic Plant Species
NEPSA Narrow Endemic Plant Survey Areas
NPDES National Pollutant Discharge Elimination System
NPPA Native Plant Protection Act
NWPR Navigable Water Protection Rule
OHWM Ordinary High-Water Mark
RCA Western Riverside County Regional Conservation Authority RCIP Riverside County Integrated Project
ROW Right of Way
RWQCB Regional Water Quality Control Board
SAA Streambed Alteration Agreement
SF Square Feet
SSC California Species of Special Concern
SWRCB State Water Resources Control Board
USACE United States Army Corps of Engineers
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
WDR Waste Discharge Requirements
Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 1 INTRODUCTION

The following biological technical report describes a detailed assessment of potential sensitive natural resources located within and immediately adjacent to the Bradshaw Collection Tentative Tract Map (TTM) 37858 Project Site. Specifically, the report has been prepared to support the California Environmental Quality Act (C EQA), Mitigated Negative Declaration (MND) and Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) documentation, compliance, and review process conducted by the City of Moreno Valley. As discussed below, the assessment includes a thorough literature review, site reconnaissance characterizing baseline conditions (including floral and faunal and dominate vegetation communities), focused sensitive species surveys, impact analysis, and proposed mitigation/conservation measures.

PROJECT LOCATION & DESCRIPTION

The 4.81-acre Project Site (0.19-acre offsite impact area) is located within Assessor’s Parcel Numbers (APNs) 478-090-018, 478-090-024, and 478-090-025 (including rights- of-ways). The Project Site is located within United States Geological Survey (USGS) 7.5’ Series Sunnymead Quadrangle, Riverside County, Township 3 South, Range 3 West, Section 14. Specifically, the Project Site is located north of Cactus Avenue and east of Bradshaw Circle, City of Moreno Valley, Riverside County, California, as shown in Figure 1, Regional Location Map, and Figure 2, Project Site Map.

The Project Site is located within the Western Riverside County MSHCP Reche Canyon/Badlands Plan Area and is not located within an MSHCP Criteria Area Cell, Cell Group, or Linkage Area, as shown in Figure 3, MSHCP Relationship Map (Western Riverside County Reg ional Conservation Authority ( RCA) Geographic Information System (GIS) Data Downloads 2024).

The Project Site is generally flat and dominated by ruderal/disturbed and non-native grassland.

The Project proposes thirty-seven (37) single family residential homes totaling 124,753 square feet (SF), including two (2) water quality management plan basins, and open space recreational area.

METHODOLOGY

LITERATURE REVIEW

Existing biological resource conditions within and adjacent to the Project Site were initially investigated through review of pertinent scientific literature. Federal register listings, protocols, and species data provided by the United States Fish and Wildlife Service (USFWS) were reviewed in conjunction with anticipated federally listed species potentially occurring within the Project Site. The California Natural Diversity Database (CNDDB 2024a), a California Department of Fish and Wildlife ( CDFW) Natural Heritage Division species account database, was also reviewed for all pertinent information regarding the locations of known occurrences of sensitive species in the vicinity of the property. In Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 2 addition, numerous regional floral and faunal field guides were utilized in the identification of species and suitable habitats. Combined, the sources reviewed provided an excellent baseline from which to inventory the biological resources potentially occurring in the area.

Other sources of information included the review of unpublished biological resource letter reports and assessments. Other CDFW reports and publications consulted include the following:

• Special Animals (CDFW 2024b);
• State and Federally Listed Endangered and Threatened Animals of California (CDFW 2024c);
• Endangered, Threatened, and Rare Plants of California (CDFW 2024d); • Special Vascular Plants and Bryophytes List (CDFW 2024e).

FIELD SURVEYS

Initial r econnaissance survey s of the Project Site were conducted by Gonzales Environmental Consulting, LLC on February 7th, 18th, 26th, March 1st, April 17th, May 17th, June 17th and Cadre Environmental on March 12th, 13th, 14th, and 15th, 2024 in order to characterize and identify potential wildlife habitats, sensitive resources, and to establish the accuracy of the data identified in the literature search and previous surveys.

Geologic and soil maps were examined to identify local soil types that may support sensitive taxa. Aerial photograph, topographic maps, and vegetation and rare plant maps prepared by previous studies in the region were used to determine community types and other physical features that may support sensitive plants/wildlife, uncommon taxa, or rare communities that occur within the Project Site.

The MSHCP has determined that the majority of sensitive species potentially occurring within the Project Site ha ve been adequately covered (MSHCP Table 2 -2 Species Considered for Conservation Under the MSHCP Since 1999, 2004). However, additional surveys may be required for narrow endemic plant, criteria area, and specific wildlife species if suitable habitat is do cumented onsite and/or if the property is located within a predetermined “Survey Area” (MSHCP 2004). Based on the initial MSHCP review of predetermined Survey Areas, habitat assessments and focused surveys (as warranted) were conducted for the following six (6) species.

Section 6.1.2 Riparian, Riverine, Vernal Pool Species

• Riverside fairy shrimp (Streptocephalus woottoni) [Federal Endangered FE]; • vernal pool fairy shrimp (Branchinecta lynchi) [Federally Threatened (FT)]; • least Bell's vireo (Vireo bellii pusillus) [FE/State Endangered (SE)]; • southwestern willow flycatcher (Empidonax traillii extimus) [FE/SE]; • western yellow-billed cuckoo (Coccyzus americanus occidentalis) [SE].

Wildlife Species

• burrowing owl (Athene cunicularia) [California Species of Special Concern (SSC)].

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 3 Vegetation Communities/Habitat Classification Mapping

Natural community names and hierarchical structure follows the CDFW “List of California Terrestrial Natural Communities” and/or Holland (1986) classifica tion systems, which have been refined and augmented where appropriate to better characterize the habitat types observed onsite when not addressed by the MSHCP classification system.

Floristic Plant Inventory

A general plant survey was conducted throug hout the Project Site during the initial reconnaissance in a collective effort to identify all species occurring onsite. All plants observed during the survey efforts were either identified in the field or collected and later identified using taxonomic ke ys. Plant taxonomy follows Hickman (1993). Scientific nomenclature and common names used in this report generally follow Roberts et al. (2004) or Baldwin et al. (2012) for updated taxonomy. Scientific names are included only at the first mention of a species; thereafter, common names alone are used.

Wildlife Resources Inventory

All animals identified during the reconnaissance survey by sight, call, tracks, scat, or other characteristic sign were recorded onto a 1:200 scale orthorectified color aerial photograph or documented using a global positioning system (GPS). In addition t o species actually detected, expected use of the site by other wildlife was derived from the analysis of habitats on the site, combined with known habitat preferences of regionally occurring wildlife species.

Vertebrate taxonomy followed in this report is according to the Center for North American Herpetology (2024 for amphibians and reptiles), the American Ornithologists’ Union (1988 and supplemental) for birds, and Baker et al. (2003) for mammals. Both common and scientific names are used during the first mention of a species; common names only are used in the remainder of the text.

Regional Connectivity/Wildlife Movement Corridors

The analysis of wildlife movement corridors associated with the Project Site and immediate vicinity is based on information compiled from literature, analysis of the aerial photograph and direct observations made in the field during the reconnaissance site visit.

A literature review was conducted that includes documents on island biogeography (studies of fragmented and isolated habitat “islands”), reports on wildlife home range sizes and migration patterns, and studies on wildlife dispersal. Wildlife movement studies conducted in southern California were also reviewed. Use of field-verified digital data, in conjunction with the GIS database, allowed proper identification of regional vegetation communities and drainage features. This information was crucial to assessing the relationship of the Project Site to large open space areas in the immediate vicinit y and was also evaluated in terms of connectivity and habitat linkages. Relative to corridor issues, the discussions in this report are intended to focus on wildlife movement associated within the Project Site and the immediate vicinity.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 4 MSHCP Focused Burrowing Owl Survey Area

The Project Site is located almost completely within a n MSHCP Survey Area for burrowing owl, as shown in Figure 3, MSHCP Relationship Map . Therefore, i n accordance with the MSHCP Burrowing Owl Survey Instructions (2006), survey protocol consists of two steps, Step I – Habitat Assessment and Step II – Locating Burrows and Burrowing Owls. Step II is comprised of two parts, Part A: Focused Burrow Surveys and Part B: Focused Burrowing Owl Surveys. Each step is briefly outlined below, followed by the methodology and results of each survey conducted within the Project Site.

Step I – Habitat Assessment

Step 1 of the MSHCP habitat assessment for burrowing owl consists of a walking survey to determine if suitable habitat is present onsite. Initial habitat assessments were conducted by Gonzales Environmental Consulting ,LLC on February 7th, 2020 (Gonzales Environmental Consulting ,LLC 2020a). An updated habitat assessment was conducted by Cadre Environmental on March 12th, 2024. Upon arrival at the Project Site, and prior to initiating the assessment survey, Cadre Environmental used binoculars to scan all suitable habitats on and adjacent to the property, in cluding perch locations, to ascertain owl presence.

All suitable areas of the Project Site were surveyed on foot by walking slowly and methodically while recording/mapping areas that may represent suitable owl habitat onsite. Primary indicators of suitable burrowing owl habitat in western Riverside County include, but are not limited to, native and non-native grassland, interstitial grassland within shrub lands, shrub lands with low density shrub cover, golf courses, drainage d itches, earthen berms, unpaved airfields, pastureland, dairies, fallow fields, and agricultural use areas. Burrowing owls typically use burrows made by fossorial mammals, such as California ground squirrels ( Otospermophilus beecheyi) or American badgers (Taxidea taxus), but they often utilize man -made structures, such as earthen berms, cement culverts, cement, asphalt, rock, or wood debris piles, or openings beneath cement or asphalt pavement. Burrowing owls are often found within, under, or in close proximity to man-made structures.

According to the MSHCP guidelines, if suitable habitat is present the biologist should also walk the perimeter of the property, which consists of a 150-meter (approximately 500 feet) buffer zone around the Project Site bound ary. If permission to access the buffer area cannot be obtained, the biologist shall not trespass, but visually inspect adjacent habitats with binoculars. Results from the habitat assessment indicated that suitable burrowing owl burrows potentially utili zed for refugia and/or nesting were documented within and immediately adjacent to the property including foraging habitat documented throughout the Project Site. Accordingly, if suitable habitat is documented onsite, both Step II surveys and the 30-day pre-construction surveys are required in order to comply with the MSHCP guidelines for the species.

Step II – Locating Burrows and Burrowing Owls

Concurrent with the initial habitat assessment s, a detailed focused burrow survey was conducted and included documentation of appropriately sized natural burrows or suitable Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 5 man-made structures that may be utilized by burrowing owl - as part of the MSHCP protocol, which is described below under Part A. Focused Burrow Survey.

Part A: Focused Burrow Survey

A systematic survey for burrows, including burrowing owl sign, was conducted by walking across all suitable habitats mapped within the Project Site by Gonzales Environmental Consulting, LLC on February 7th, 2020 and Cadre Environmental on March 12 th, 2024.

Pedestrian survey transects were spaced to allow 100% visual coverage of the ground surface. The distances between transect centerlines were no more than 20 meters (approximately 66 ft.) apart to the extent possible. Transect routes were also adjusted to account for topography and in general ground surface visibility. All observations of suitable burrows or dens, natural or man -made, or sightings of burrowing owl, were recorded and mapped during the survey.

Part B: Focused Burrowing Owl Surveys

Four (4) focused burrowing owl surveys were conducted during the spring of 2024 on March 12 th, 13 th, 14 th, and 15 th, 2024 from one hour before sunrise to two hours after sunrise as outlined in Table 1, Burrowing Owl Survey Schedule. Initial focused surveys were conducted by Gonzales Environmental Consulting, LLC on February 7 th, 18th, 26th, March 1st, April 17th, May 17th, June 17th 2020 (Gonzales Environmental Consulting, LLC 2020b). During visual surveys, all potentially suitable burrow or structure entrances were investigated for signs of owl occupation, such as feathers, tracks, or pellets, and carefully observed to determine if burrowing owls utilize these features, when present. All burrows are monitored at a short distance from the entrance, and at a location that would not interfere with potential owl behavior, when present. In addition to monitoring potential burrow locations, all suitable habitats in the Project Site were walked along travel routes which allowed for visual assessments of all suitable habitats

Jurisdictional Resources Assessment

A jurisdictional resources assessment was conducted by Gonzales Environmenta l Consulting, LLC on February 7 th (Gonzales Environmental Consulting, LLC 2020a ). An updated jurisdictional resources assessment was conducted by Cadre Environmental on March 12 th, 2024. The assessment determined the boundaries or absence of potential wetland and non-wetland waters of the United States subject to the regulatory jurisdiction of the U.S. Army Corps of Engineers (USACE) pursuant to Clean Water Act (CWA) Section 404; wetland and non -wetland waters of the State subject to the regulatory jurisdiction of the Regional Water Quality Control Board (RWCQB) pursuant to CWA Section 401 and State Porter -Cologne Water Quality Control Act (Porter -Cologne); streambed and riparian habitat subject to the regulatory jurisdiction of the CDFW pursuant Sections 1600 et seq. of the California Fish and Game Code (CDFG Code); and MSHCP Section 6.1.2 Riparian, Riverine and Vernal Pool resources. All resources delineated as CDFW jurisdictional features were also defined as Western Riverside County MSHCP Section 6.1.2 resources. Wetlands are identified by the presence of three characteristics:
hydrophytic vegetation, wetland hydrology, and hydric soils. If any of these criteria were met, one or more transects were run to determine the extent of the wetland. Specifically, the presence of wetland hydrology was evaluated throughout the Project Site by recording Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 6 the extent of observed surface flows, depth of inundation, depth to saturated soils, and depth to free water in the soil pits, where applicable. In addition, indicators of wetland or riverine hydrology were recorded, including water marks, drift lines, rack, debris, and sediment deposits, as warranted. Any indicators of hydric soils, such as redoximorphic features, buried organic matter, organic streaking, reduced soil conditions, gleyed or low- chroma soils, or sulfidic odor were also recorded.

MSHCP Riparian/Riverine/Vernal Pool Resources

Regulated activities within inland streams, wetlands and riparian areas in Western Riverside County California fall under the jurisdiction of the MSHCP. The MSHCP requires, among other things, assessments for riparian/riverine and vernal pool resources. As projects are proposed within the MSHCP Plan Area, an assessment of the potentially significant effects of those projects on riparian/riverine areas, and vernal pools are required, as currently mandated by CEQA, using available information augmented by project-specific mapping provided to and reviewed by the permittee’s biologist(s).

Riparian/riverine areas and vernal pools are defined for this section as follows in accordance with Section 6.1.2, Vol. I, of the Final MSHCP Plan: Riparian/Riverine Areas are lands which contain habitat dominated by trees, shrubs, persistent emergents, or emergent mosses and lichens, which occur close to or which depend upon soil moisture from a nearby fresh water source; or areas with fresh water flow during all or a portion of the year.” (MSHCP 2004) . It is assumed the first part of the definition defines riparian habitat, and the second part defines riverine areas. Vernal pools are defined as:
“…seasonal wetlands that occur in depression areas that have wetlands indicator s of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season. Obligate hydrophytes and facul tative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season”. (MSHCP 2004)

EXISTING ENVIRONMENTAL SETTING

SURROUNDING LAND USES/TOPOGRAPHY/SOILS

The Project Site is generally flat and primarily characterized as ruderal/disturbed and non- native grassland habitats as illustrated in Figure 4, Vegetation Communities Map and Figures 5 and 6, Current Project Site Photographs. The Soil Survey of Western Riverside Area has the following soils mapped within the boundary of the Project Site as shown on Figure 7, Soils Association Map: SeC2 - San Emigdio fine sandy loam, 2 to 8 precent slopes eroded, SgC - San Emigdio loam, 2 to 8 percent slopes

VEGETATION COMMUNITIES

Natural community names follow the CDFW “List of California Terrestrial Natural Communities” and/or Holland (1986) classification system, which have been refined and where appropriate to better characterize the habitat types onsite when not addressed by the MSHCP classification system. Acreage totals for vegetation communities documented onsite and offsite are listed in Table 1. Vegetation Communities Acreages. §¨¦
10 ·|}þ60
§¨¦
215
·|}þ60
City of
Moreno Valley
City of
Moreno Valley
not to scale

CADRE
Environmental
Project Site
§¨¦
215
§¨¦
10 §¨¦
10 Figure 1 - Regional Location Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California APNs 478-090-018, -024, -025
:ii Ave
'0
er
't)
0 0
3:

TERRA CE
..._
3rd St
> E , Ill St<
Cl
> 0
<
C ..,
E ..

Cl
II) CL
S nBem dno
Intl Alrp t
+

BRY N M AWR
Moreno
Nuevo Rd

PERRI S

EAS T H IG HL A NDS
II)
Cl
Cl
C .., ...
0 Lug on I
Nuevo Rd
>
<
0 R di ds
Munl
Airport
+ <
Ave
ell
C
Men tone Blvd '­

M EN TONE
>
<
J:; .,
NUEVO
0 c,

O CRAF TON
Yuc:ilp

II) DU NL A P ACR ES

EL CASCO
0 Ramona Expy
Q
> <(
C
.,
C
" Coiftour Ava
~ 11!J
1 inch = 80 feet
CADRE
Environmental
Figure 2 - Project Site Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California # Photo Point & Direction
1 2
34 Cactus Avenue
Bradshaw Circle
Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARYOFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARYPROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
478-090-018
478-090-024
478-090-025
RWRW OIFftllTI! lllillPACT l!OONDARY'
1 inch = 80 feet
CADRE
Environmental
Figure 3 - MSHCP Relationship Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California 4 Cactus Avenue
Bradshaw Circle
Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARYOFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARYPROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
478-090-018
478-090-024
478-090-025
RWRW
MSHCP Burrowing Owl
Survey Area
(red hatch)
MSHCP Burrowing Owl
Survey Area
(red hatch)
1 inch = 80 feet
CADRE
Environmental
Figure 4 - Vegetation Communities Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle
Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARYOFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARYPROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
478-090-018
478-090-024
478-090-025
RWRW
Sources: Cadre Environmental 2024
Vegetation Communities
Non-native Grassland
Developed
NNGNNG
DEVDEV
Ruderal/DisturbedRUDRUD
RUDRUD
RUDRUD
RUDRUD
NNGNNG
NNGNNG
DEVDEV
1JIIINtl
PHOTOGRAPH 1 - Southeast view of Project Site from
northwest corner.

PHOTOGRAPH 2 - Southwest view of Project Site from
northeast corner.

CADRE
Environmental
Refer to Figure 2 - Project Site Map for Photographic Key Figure 5 - Current Project Site Photographs
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California PHOTOGRAPH 3 - Northwest view of Project Site from
southeast corner near Cactus Avenue.

PHOTOGRAPH 4 - Northeast view of Project Site from
southwest corner near Cactus Avenue/Bradshaw Circle
Intersection.

CADRE
Environmental
Refer to Figure 2 - Project Site Map for Photographic Key Figure 6 - Current Project Site Photographs
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California 1 inch = 80 feet
CADRE
Environmental
Figure 7 - Soils Association Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle
Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARYOFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARYPROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
478-090-018
478-090-024
478-090-025
RWRW
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SgC
San Emigdio loam
2 to 8 percent slopes
SgC
San Emigdio loam
2 to 8 percent slopes
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
47MNIC-018
Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 14 Table 1.

Vegetation Communities Acreages

Vegetation Type
Acres
(onsite)
Acres
(offsite)
Acres
TOTAL
Ruderal/Disturbed 3.11 0.00 3.11
Non-native Grassland 1.65 0.10 1.75
Developed 0.05 0.09 0.14
TOTAL 4.81 0.19 5.00
Source: Cadre Environmental 2024.

Ruderal/Disturbed

Ruderal/Disturbed habitat was documented in the northern region of the Project Site and adjacent to the existing roadways generally devoid of vegetation. Dominant species documented within this vegetation community include cheeseweed (Malva parviflora ), stinknet ( Oncosiphon piluliferum ), tocalote ( Centaurea melitensis ), tumbling pigweed (Amaranthus albus), red -stemmed filaree ( Erodium cicutarium), white-stemmed filaree (Erodium moschatum), prickly lettuce (Lactuca serriola), shortpod mustard (Hirschfeldia incana), and prickly sow thistle (Sonchus asper).

Non-native Grassland

The southern region of the Project Site is characterized as non-native grassland. Species documented within this vegetation community include wild oat (Avena fatua), wall barley (Hordeum murinum ), ripgut grass ( Bromus diandrus), common fiddleneck ( Amsinckia intermedia), silverleaf nightshade ( Solanum elaeagnifolium ), Russian thistle ( Salsola tragus), horseweed (Erigeron canadensis) and a single Mexican fan palm (Washingtonia robusta).

Developed

The developed regions of the Project Site include the paved reach of Cactus Avenue and Bradshaw Circle.

GENERAL WILDLIFE SPECIES

General wildlife species documented on site include but are not limited to northern mockingbird (Mimus polyglottos), Anna’s hummingbird (Calypte anna), mourning dove (Zenaida macroura), Say’s phoebe (Sayornis saya), European starling (Sturnus vulgaris), lesser goldfinch ( Spinus psaltria ), house finch ( Haemorhous mexicanus ), and pocket gopher (Thomomys bottae).

JURISDICTIONAL RESOURCES

No wetlands or jurisdictional resources regulated by the USACE, CDFW, or RWQCB were documented within or adjacent to the Project Site.

The project will comply with all applicable water quality regulations, including complying with a NPDES regulations and MS4 permit requirements. The MS4 permit places pollution Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 15 prevention requirements on planned developments, construction sites, commercial and industrial businesses, municipal facilities and activities, and residential communities.

Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activ ities and the installation and proper maintenance of structural BMPs to ensure adequate long -term treatment of water before entering into any stream course or municipal system.

MSHCP Riparian/Riverine/Vernal Pool Resources

No MSHCP Section 6.1.2 ripari an scrub, forest or woodland habitat is located within or adjacent to the Project Site.

No evidence of MSHCP Section 6.1.2 vernal pools, seasonal depressions, seasonally inundated road ruts or other wetland features were recorded on the Project Site. Vernal pools are depressions in areas where a hard-underground layer prevents rainwater from draining downward into the subsoils. When rain fills the pools in the winter and spring, the water collects and remains in the depressions. In the springtime, the water gradually evaporates away, until the pools became completely dry in the summer and fall. Vernal pools tend to have an impe rmeable layer that results in ponded water. The soil texture (the amount of sand, silt, and clay particles) typically contains higher amounts of fine silts and clays with lower percolation rates. Pools that retain water for a sufficient length of time will develop hydric cells. Hydric cells form when the soil is saturated from flooding for extended periods of time and anaerobic conditions (lacking oxygen or air) develop.

Consistent with conditions documented onsite and as previously stated, the Project Si te is characterized as San Emigdio fine sandy loam possessing well drained substrates (drainage class). No indication of clay substrates or hydric soils were documented within the Project Site. A review of historic aerials was conducted to determine if i nundated features were present during years of high rainfall when features would certainly be documented. Historic aerials taken in 2011 and 2023 represent an ideal baseline during which know (previously documented) inundated vernal pools, seasonal depressions and road ruts can easily be seen. No sign or indication of inundation was documented within the Project Site during a review of historic ae rials. In summary, none of the conditions (i.e., no inundated depressions including road ruts, hydric soils, historic inundation, etc.) were observed on documented within the Project Site. No features are present that would support fairy shrimp. No standi ng water or other sign of areas that pond water was recorded.

SENSITIVE BIOLOGICAL RESOURCES

The following discussion describes the plant and wildlife species present, or potentially present within the property boundaries, that have been afforded spec ial recognition by federal, state, or local resource conservation agencies and organizations, principally due to the species’ declining or limited population sizes, usually resulting from habitat loss.

Also discussed are habitats that are unique, of relat ively limited distribution, or of particular value to wildlife. Protected sensitive species are classified by state and/or federal resource management agencies, or both, as threatened or endangered, under provisions of the state and federal endangered spe cies act. Vulnerable or “at -risk” Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 16 species that are proposed for listing as threatened or endangered (and thereby for protected status) are categorized administratively as "candidates" by the USFWS. CDFW uses various terminology and classifications to des cribe vulnerable species. There are additional sensitive species classifications applicable in California. These are described below.

Sensitive biological resources are habitats or individual species that have special recognition by federal, state, or l ocal conservation agencies and organizations as endangered, threatened, or rare. The CDFW, USFWS, and special groups like the California Native Plant Society maintain watch lists of such resources. For the purpose of this assessment sources used to determine the sensitive status of biological resources are:

Plants: USFWS (20 24), CNDDB (CDFW 20 24a), CDFW (20 24d, 202 4e), California Native Plant Society ( CNPS 20 24), and Skinner and Pavlik (1994),
Wildlife: California Wildlife Habitat Relationships (2008), USFWS (20 24), CNDDB (CDFW 2024a), and CDFW (2024b, 2024c).

Habitats: CNDDB (CDFW 2024a, 2024f).

FEDERAL PROTECTION AND CLASSIFICATIONS

The Federal Endangered Species Act of 1973 (FESA) defines an endangered species as “any species that is in danger of extinction throughout all or a significant portion of its range...” Threatened species are defined as “any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” Under provisions of Section 9(a)(1)(B) of the FESA it is unlawful to “take” any listed species. “Take” is defined as follows in Section 3(18) of the FESA: “...harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” Further, the USFWS, through regulation, has interpreted the terms “harm” and “harass” to include certain types of habitat modification as forms of a “take.” These interpretations, however, are generally considered and applied on a case-by-case basis and often vary from species to species. In a case where a property owner seeks permission from a federal agency for an action that could affect a federally listed plant and animal species, the property owner and agency are required to consult with USFWS.

Section 9(a)(2)(b) of the FESA addresses the protections afforded to listed plants.

Recently, the USFWS instituted changes in the listing status of former candidate species.

Former C1 (candidate) species are now referred to simp ly as candidate species and represent the only candidates for listing. Former C2 species (for which the USFWS had insufficient evidence to warrant listing at this time) and C3 species (either extinct, no longer a valid taxon or more abundant than was form erly believed) are no longer considered as candidate species. Therefore, these species are no longer maintained in list form by the USFWS, nor are they formally protected. However, some USFWS field offices have issued memoranda stating that former C2 spe cies are henceforth to be considered Federal Species of Concern. This term is employed in this document but carries no official protections. All references to federally protected species in this report (whether listed, proposed for listing or candidate) include the most current published status or candidate category to which each species has been assigned by USFWS. For purposes of this assessment, the following acronyms are used for federal status species:

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 17 FE Federal Endangered
FT Federal Threatened
FPE Federal Proposed Endangered
FPT Federal Proposed Threatened
FC Federal Candidate for Listing

The designation of critical habitat can also have a significant impact on the development of land designated as “critical habitat.” The FESA prohibits federal agencies from taking any action that will “adversely modify or destroy” critical habitat (16 U.S.C. § 1536(a)(2)).

This provision of the FESA applies to the issuance of permits by federal agencies. Before approving an action affecting critical habitat, the federal agency is required to consult with the USFWS who then issues a biological opinion evaluating whether the action will “adversely modify” critical habitat. Thus, the designation of critical habitat effectively gives the USFWS extensive regulatory control over the development of land designated as critical habitat.

The federal Migratory Bird Treaty Act ( MBTA) makes it unlawful to “ take” any migratory bird or part, nest, or egg of such bird listed in wildlife protection tre aties between the United States and Great Britain, the Republic of Mexico, Japan, and the Union of Soviet States. For purposes of the MBTA, “ take” is defined as to pursue, hunt, capture, kill, or possess or attempt to do the same.

The Bald Eagle and Gold en Eagle Protection Act explicitly protects the bald eagle and golden eagle and imposes its own prohibition on any taking of these species. As defined in this act, take means to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, or molest or disturb. Current USFWS policy is not to refer the incidental take of bald eagles for prosecution under the Bald Eagle and Golden Eagle Protection Act (16 U.S.C. 668-668d).

STATE PROTECTION AND CLASSIFICATIONS

California's Endangered Species Act (CESA) defines an endangered species as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant which is in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease.” The State defines a threatened species as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that, although not presently threatened with extinction, is likely to become an endangered species in the foreseeable future in the absence of the special protection and management efforts required by this chapter. Any animal determined by the commission as rare on or before January 1, 1985 is a threatened species.” Candidate species are defined as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for which the commission has published a notice of proposed regulation to add the species to either list.” Candidate species ma y be afforded temporary protection as though they were already listed as threatened or endangered at the discretion of the Fish and Game Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 18 Commission. Unlike FESA, CESA does not include listing provisions for invertebrate species.

Article 3, Sections 2080 through 2085, of CESA addresses the taking of threatened or endangered species by stating “No person shall import into this state, export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product thereof, that the commission determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise provided...” Under CESA, “take” is defined as “...hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” Exceptions authorized by the state to allow “take” require “...permits or memorandums of understanding...” and can be authorized for “...endangered species, threatened species, or candidate species for scientific, educational, or management purposes.” Sections 1901 and 1913 of the California Fish and Game Code provide that notification is required prior to disturbance.

Additionally, some sensitive mammals and birds are protected by the State as Fully Protected Mammals or Fully Prot ected Birds, as described in the California Fish and Game Code, Sections 4700 and 3511, respectively. California Species of Special Concern ( SSC) listings include special status species, including all state and federal protected and candidate taxa, Bureau of Land Management and US Forest Service sensitive species, species considered to be declining or rare by the National Audubon Society, and a selection of species which are considered to be under population stress but are not formally proposed for listing. This list is primarily a working document for the CDFW's CNDDB project. Informally listed taxa are not protected per se but warrant consideration in the preparation of biotic assessments. For some species, the CNDDB is only concerned with specific portions of the life history, such as roosts, rookeries, or nest sites. For the purposes of this assessment, the following acronyms are used for State status species:

SE State Endangered
ST State Threatened
SCE State Candidate Endangered
SCT State Candidate Threatened
SFP State Fully Protected
SP State Protected
SR State Rare
SSC California Species of Special Concern
CWL California Watch List

Nesting birds, including raptors, are protected under California Fish and Game Code Section 3503, which reads, “It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto.” In addition, under California Fish and Game Code Section 3503.5, “it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 19 thereto”. Passerines and non-passerine land birds are further protected under California Fish and Game Code 3513. As such, CDFW typically recommends surveys for nes ting birds that could potentially be directly (e.g., actual removal of trees/vegetation) or indirectly (e.g., noise disturbance) impacted by project -related activities. Disturbance during the breeding season could result in the incidental loss of fertile e ggs or nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “take” by CDFW.

California Native Plant Society

The CNPS is a private plant conservation organization dedi cated to the monitoring and protection of sensitive species in the State. This organization has compiled an inventory comprised of the information focusing on geographic distribution and qualitative characterization of rare, threatened, or endangered vasc ular plant species of California (Tibor 2001). The list serves as the candidate list for listing as threatened and endangered by CDFW. The CNPS has developed five categories of rarity references as California Rare Plant Ranks (CRPR):

CRPR 1A Presumed extinct in California.

CRPR 1B Rare, threatened, or endangered in California and elsewhere.

CRPR 2A Plants presumed extirpated in California but common elsewhere CRPR 2B Plants rare, threatened, or endangered in California but more common elsewhere
CRPR 3 Plants about which we need more information – a review list.

CRPR 4 Species of limited distribution in California (i.e., naturally rare in the wild), but whose existence does not appear to be susceptible to threat.

As stated by the CNPS:

“Threat Rank is an extension added onto the California Rare Plant Rank and designates the level of endangerment by a 1 to 3 ranking with 1 being the most endangered and 3 being the least endangered. A Threat Rank is present for all California Rare Plant Rank 1B's, 2's, 4's, and the majority of California Rare Plant Rank 3's. California Rare Plant Rank 4 plants are seldom assigned a Threat Rank of 0.1, as they generally have large enough populations to not have significant threats to their continued e xistence in California; however, certain conditions exist to make the plant a species of concern and hence be assigned a California Rare Plant Rank. In addition, all California Rare Plant Rank 1A (presumed extinct in California), and some California Rare P lant Rank 3 (need more information) plants, which lack threat information, do not have a Threat Rank extension.” (CNPS 2010)

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

0.2 Fairly threatened in California (20-80% occurrences threatened / moderate degree and immediacy of threat)
Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 20 0.3 Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known)

SENSITIVE HABITATS

As stated by CDFW:

“One purpose of the vegetation classification is to assist in determining the level of rarity and imperilment of vegetation types. Ranking of alliances according to their degree of imperilment (as measured by rarity, trends, and threats) follows NatureServe’s Heritage Methodology, in which all alliances are listed with a G (global) and S (state) rank. For alliances with State ranks of S1 -S3, all associations within them are also considered to be highly imperiled” (CDFW 2012)

No vegetation communities listed by CDFW as sensitive were documented within or adjacent to the Project Site.

SENSITIVE PLANTS

The following discussion is presented in three (3) parts:

I) MSHCP Narrow Endemic and Criteria Area Plant Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment and Not Found or Expected to Occur Onsite;
II) Species that can be Excluded from the Project Site Based on Lack of Suitable Habitat Onsite; and
III) Special-Status Species Potentially Occurring Onsite.

I: MSHCP Narrow Endemic and Criteria Area Plant Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment and Not Found or Expected to Occur Onsite

The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.3.2.

II: Sensitive Species that can be Excluded from the Project Site Based on Lack of Suitable Habitat Onsite

No state or federally listed threatened or endangered plant species were documented or expected to occur onsite based on a lack of suitable habitat , as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 21 III. Special-Status Species Potentially Occurring Onsite

No potential habitat and/or substrates was detected onsite for CNPS special-status plants not covered under the MSHCP , as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite.

Table 4.

Sensitive Plant Species with Potential to Occur Onsite.

Species Name
(Scientific Name)

Status
Habitat Description Comments

Chaparral sand-verbena
(Abronia villosa var. aurita)

CRPR 1B.1
Sandy soils in sage-scrub,
chaparral.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

San Diego sagewort
(Artemisia palmeri)

CRPR 4.2
Found in sandy and mesic
soils within chaparral, coastal
scrub, riparian forest, riparian
scrub, and riparian woodland.

Found at elevations ranging
from 49 to 3,002 feet.

Blooming period is from
February to September.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Plummer's mariposa lily
(Calochortus plummerae)

CRPR 1B.2
MSHCP Covered

Granitic, rock soils within
chaparral, cismontane
woodland, coastal sage
scrub, lower montane
coniferous forest, and valley
and foothill grassland.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Payson’s jewelflower
(Caulanthus simulans)

CRPR List 4.2
MSHCP Covered

Annual herb generally
blooming from February to
June within chaparral and
costal scrub habitats in
association with granitic and
sandy substrates (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Smooth tarplant
(Centromadia pungens ssp.
laevis)

CRPR 1B.1
MSHCP Covered
Alkaline soils in chenopod
scrub, meadows and seeps,
playas, and disturbed
habitats.

No Potential. No suitable
habitat or alkaline substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 22 Species Name
(Scientific Name)

Status
Habitat Description Comments
Peninsular spine flower
(Chorizanthe leptotheca)

CRPR 4.2
Annual herb generally
blooming from May to August
within alluvial fan, granitic
chaparral, coastal scrub and
lower montane coniferous
forest habitats (CNPS 2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Parry's spineflower
(Chorizanthe parryi var.
parryi)

CRPR 3.2
MSHCP Covered
Sandy or rocky soils in open
habitats of chaparral and
coastal sage scrub.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

White-bracted spineflower
(Chorizanthe xanti var.
leucotheca)

CRPR 1B.2

Annual herb generally
blooming from April to June
within coastal scrub (alluvial
fans), Mojavean desert scrub
and pinyon and juniper
woodland habitats (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Paniculate tarplant
(Deinandra paniculata)

CRPR 4.2
Usually vernally mesic,
sometimes sandy, coastal
scrub, valley and foothill
grasslands, and vernal pools;
25-940m.

Apr-Nov
No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Coulter’s goldfields
(Lasthenia glabrata ssp.
coulteri)

CRPR List 1B.1

MSHCP CAPSA
Coulter’s goldfields is
associated with low-lying
alkali and saline habitats
along the coast and inland
valleys. The majority of the
populations are associated
with coastal salt marsh. In
Riverside County, Coulter’s
goldfields primarily grow in
highly alkaline, silty clays
associated with the Traver-
Domino-Willows soils, and
usually in the wet areas in
the alkali vernal plain
community.

No Potential. No suitable
habitat or alkaline substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Robinson’s pepper-grass
(Lepidium virginicum var.
robinsonii)

CRPR 4.3
Annual herb generally
blooming from January to
July within chaparral and
coastal scrub habitats (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 23 Species Name
(Scientific Name)

Status
Habitat Description Comments
San Bernardino aster
(Symphyotrichum defoliatum)

CRPR 1B.2

Occurs in cismontane
woodland, coastal scrub,
lower montane coniferous
forest, meadows and seeps,
marshes and swamps, and
valley and foothill grassland
(vernally mesic)/near ditches,
streams springs.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal non-
native vegetation.

California Native Plant Society (CNPS): California Rare Plant Rank (CRPR) CRPR 1A – plants presumed extinct in California
CRPR 1B – plants rare, threatened, or endangered in California, but more common elsewhere CRPR 2A – plants presumed extirpated in California but common elsewhere CRPR 2B – plants rare, threatened, or endangered in California but more common elsewhere CRPR 3 – plants about which we need more information, a review list CRPR 4 – plants of limited distribution, a watch list
.1 – Seriously endangered in California
.2 – Fairly endangered in California
.3 – Not very endangered in California

Federal (USFWS) Protection and Classification
FE – Federally Endangered
FT – Federally Threatened
FC – Federal Candidate for Listing

State (CDFW) Protection and Classification
SE – State Endangered
ST – State Threatened
Source : Cadre Environmental 2024.

SENSITIVE WILDLIFE

The following discussion is presented in two (2) parts:

I) MSHCP Wildlife Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment;
II) Special-Status Species Potentially Occurring Onsite.

I: MSHCP Wildlife Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment

The Project Site is not located within an MSHCP Amphibian Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is cons istent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Mammal Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site occurs almost c ompletely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map . Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 24 burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2024 focused survey efforts (Gonzales Environmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non -native vegetation as shown in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat.

An MSHCP preconstruction survey will be required at least 30-days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction surv ey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of the burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2.

II. Special-Status Species Potentially Occurring Onsite

Moderate to low potential habitat was documented onsite for five (5) MSHCP covered species including sharp-shinned hawk (Accipiter striatus) - foraging, grasshopper sparrow (Ammodramus savannarum), California horned lark (Eremophila alpestris actia), northern harrier (Circus cyaneus) - foraging, and white-tailed kite (Elanus leucurus) - foraging, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite . As previously stated, the MSHCP has determined that these sensitive species potentially occurring within Project Site have been adequately covered (MSHCP Table 2-2 Species Considered for Conservation Under the MSHCP Since 1999, 2004).

No suitable habitat was documented onsite for wildlife species not covered under the MSHCP, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite.

Table 5.

Sensitive Wildlife Species with Potential to Occur Onsite.

Species Name
(Scientific Name)
Status
Habitat Description Comments

INVERTEBRATES
Crotch’s bumble bee
(Bombus crotchii)

SCE
Range extends from
southern to northern
California within a variety
of habitats including
grassland, scrub,
chaparral and desert
habitats. Food plants
include but are not limited
to the following genera:

Antirrhinum, Phacelia,
Clarkia, Cordylanthus,
No Potential. No suitable
food plants were documented
within or adjacent to the
Project Site. The Project Site
is heavily disturbed and
dominated by ruderal non-
native vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 25 Species Name
(Scientific Name)
Status
Habitat Description Comments
Dendromecon,
Eschscholzia, Eriogonum,
Hypericum, Lantana,
Lupinus, Salvia,
Asclepias, Cirsium,
Monardella, Keckiella,
Acmispon, Euthamia,
Ehrendorferia, Vicia,
and/or Trichostema.

Vernal pool fairy shrimp
(Branchinecta lynchi)

FT
MSHCP Covered Species

Vernal pool fairy shrimp is
restricted to seasonal
vernal pools (Eng, Belk,
and Eriksen 1990;
USFWS 1994). The vernal
pool fairy shrimp prefers
cool-water pools that have
low to moderate dissolved
solids, are unpredictable,
and often short lived
(Eriksen and Belk 1999,
MSHCP 2004).

No Potential. No suitable
habitat including vernal
pools, seasonal depressions
or indication of inundation
was documented within or
adjacent to the Project Site.

Riverside fairy shrimp
(Streptocephalus woottoni)

FE
MSHCP Covered Species
S. woottoni is restricted to
deep seasonal vernal
pools/ephemeral ponds,
and stock ponds and
other human modified
depressions (Eng, Belk,
and Eriksen 1990,
USFWS 1993, USFWS
2001). Riverside fairy
shrimp prefer warm-water
pools that have low to
moderate dissolved
solids, are less
predictable, and remained
filled for extended periods
of time (MSHCP 2004).

No Potential. No suitable
habitat including vernal
pools, seasonal depressions
or indication of inundation
was documented within or
adjacent to the Project Site.

AMPHIBIANS
Arroyo toad
(Anaxyrus californicus)

FE/SSC
MSHCP Covered Species
Shallow, slow moving
active and braided stream
channels with sandy
substrates for breeding,
bench and terrace
habitats for foraging and
aestivation, willow scrub,
coastal sage scrub and
riparian/oak woodlands.

No Potential. No suitable
breeding or upland habitat
documented within or
adjacent to the Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 26 Species Name
(Scientific Name)
Status
Habitat Description Comments
Western spadefoot
(Spea hammondii)

SSC
MSHCP Covered Species
The western spadefoot
population is patchily but
widely distributed
throughout the Riverside
Lowlands and San Jacinto
Foothills Bioregions.

Habitat for this species
includes suitable breeding
habitat below 1500 meters
(i.e., vernal pools or other
standing water is free of
exotic species) secondary
habitats including
adjacent chaparral, sage
scrub, grassland, and
alluvial scrub habitats
(MSHCP 2004).

No Potential. No suitable
breeding habitat including
vernal pools, seasonal
depressions or indication of
inundation was documented
within or adjacent to the
Project Site.

REPTILES
Southern California legless
lizard
(Anniella stebbinsi)

SSC
Occurs in moist warm
loose soil with plant cover.

Moisture is essential.

Occurs in sparsely
vegetated areas of beach
dunes, chaparral, pine-
oak woodlands, desert
scrub, sandy washes, and
stream terraces with
sycamores, cottonwoods,
or oaks.

No Potential. No suitable
habitat was documented
within the Project Site based
on a lack of mesic conditions.

Orange-throated whiptail
(Aspidoscelis hyperythra)

CWL
MSHCP Covered Species
The orange-throated
whiptail occurs primarily in
a wide variety of habitats
but is more closely tied to
coastal sage scrub and
chaparral habitats with
less than 90 percent
vegetative cover.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coastal western whiptail
(Aspidoscelis tigris stejnegeri)

SSC
MSHCP Covered Species
The coastal western
whiptail occurs in a wide
variety of habitats
including coastal sage
scrub, desert scrub,
Riversidean alluvial fan
scrub, woodlands,
grasslands, playas, and
respective ecotones
between these habitats
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 27 Species Name
(Scientific Name)
Status
Habitat Description Comments
San Diego banded gecko
(Coleonyx variegatus abbotti)

SSC
MSHCP Covered Species
San Diego banded gecko
is a microhabitat
generalist and also occurs
in habitats ranging from
cismontane chaparral and
desert scrub to open sand
dunes and arid tropical
forests (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Red-diamond rattlesnake
(Crotalus ruber)

SSC
MSHCP Covered Species
The red-diamond
rattlesnake is often found
in areas with dense
vegetation especially
chaparral and sage scrub
up to 1,520 meters in
elevation (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Western pond turtle
(Actinemys marmorata)

SSC
MSHCP Covered Species
The western pond turtle
inhabits slow moving
permanent or intermittent
streams, small ponds,
small lakes, reservoirs,
abandoned gravel pits,
permanent and ephemeral
shallow wetlands, stock
ponds, and sewage
treatment lagoons
(Rathbun et al., 1992;
Holland, 1994). Pools are
the preferred habitat
within streams (Bury,
1972, MSHCP 2004)
No Potential. No suitable
habitat was documented
within the Project Site.

Coast horned lizard
(Phrynosoma blainvillii)

SSC
MSHCP Covered Species
The horned lizard occurs
primarily in scrub,
chaparral, and grassland
habitats. The species is
common in most areas of
the Plan Area except
where adjacent to urban
situations (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coast patch-nosed snake
(Salvadora hexalepis virgultea)

SSC
The coast patch-nosed
snake prefers brushy
coastal sage scrub/
chaparral habitats.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 28 Species Name
(Scientific Name)
Status
Habitat Description Comments
BIRDS
Cooper's hawk
(Accipiter cooperii)

SSC
MSHCP Covered Species
Cooper’s hawk is most
commonly found within or
adjacent to riparian/oak
forest and woodland
habitats. This uncommon
resident of California
increases in numbers
during winter migration.

No Potential. No suitable
breeding or foraging habitat
was documented within the
Project Site. The Project Site
is heavily disturbed and
dominated by ruderal non-
native vegetation.

Sharp-shinned hawk
(Accipiter striatus)

SSC
MSHCP Covered Species
For the purpose of the
conservation analysis,
potential habitat for the
sharp-shinned hawk
includes montane
coniferous forest for
potential breeding areas
(none have been
documented) and riparian
scrub, woodland, and
forest habitat, oak
woodland and forest,
chaparral, coastal sage
scrub, desert scrub, and
Riversidean alluvial fan
sage scrub for foraging.
(MSHCP 2004)
Moderate Potential. Suitable
foraging habitat is present
on-site. This species does
not nest in southern
California. This species is
adapted to urban
environments and occurs
commonly.

Tri-colored blackbird
(Agelaius tricolor)

ST/SSC
MSHCP Covered Species
Marshes and grasslands.

Breeding colonies require
nearby water, nesting
substrate, and open range
foraging habitat of natural
grassland, woodland, or
agricultural cropland.

No Potential. No suitable
breeding or foraging habitat
was documented within the
Project Site.

Southern California rufous-
crowned sparrow
(Aimophila ruficeps canescens)

CWL
MSHCP Covered Species
Southern California
rufous-crowned sparrow is
a non-migratory bird
species that primarily
occurs within sage scrub
and grassland habitats
and to a lesser extent
chaparral sub-
associations (Unitt 2004).

This species generally
breeds on the ground
within grassland and
scrub communities in the
western and central
regions of California.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 29 Species Name
(Scientific Name)
Status
Habitat Description Comments
Grasshopper sparrow
(Ammodramus savannarum)

SSC
MSHCP Covered Species
The grasshopper sparrow
generally prefers
moderately open
grasslands and prairies
with patchy bare ground
(MSHCP 2004).

Low Potential. The patches
of non-native grassland
documented onsite provides
suitable habitat for the
species.

Golden eagle
(Aquila chrysaetos)

CWL, SFP
MSHCP Covered Species

Within southern California,
the species prefers
grasslands, brushlands
(coastal sage scrub and
chaparral), deserts, oak
savannas, open
coniferous forests, and
montane valleys (MSHCP
2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Bell's sage sparrow
(Artemisiospiza belli belli)

CWL
MSHCP Covered Species
Bell's sage sparrow is an
uncommon to fairly
common but localized
resident breeder in dry
chaparral and coastal
sage scrub along the
coastal lowlands, inland
valleys, and in the lower
foothills of local mountains
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Short-eared owl
(Asio otus)

SSC

Suitable habitats include
salt- and freshwater
marshes, irrigated alfalfa
or grain fields, and
ungrazed grasslands and
old pastures. Tule marsh
or tall grasslands with
cover 30 to 50 cm in
height can support nesting
pairs.

No Potential.

Lack of suitable habitat.

Long-eared owl
(Asio otus)

SSC

Deciduous and evergreen
forests, orchards, wooded
parks, farm woodlots, river
woods, desert oases.

Wooded areas with dense
vegetation needed for
roosting and nesting,
open areas for hunting.

Often associated with
deciduous woods near
water.

No Potential.

Lack of suitable habitat.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 30 Species Name
(Scientific Name)
Status
Habitat Description Comments
Burrowing owl
(Athene cunicularia)

SSC
MSHCP Covered Species
The burrowing owl uses
predominantly open land,
including grassland,
agriculture (e.g., dry-land
farming and grazing
areas), playa, and sparse
coastal sage scrub and
desert scrub habitats
(Garrett and Dunn 1981).

Some breeding burrowing
owls are year-round
residents and additional
individuals from the north
may winter throughout the
MSHCP Area Plan
(MSHCP 2004).

No Potential. The Project Site
does not currently provide
suitable foraging habitat and
burrows larger than 4 inches
in diameter were not
detected within and adjacent
to the property boundaries.

The species was not
detected within or adjacent to
the property following
focused surveys conducted
in 2020 and 2024 (Gonzales
Environmental Consulting,
LLC. 2020b, Cadre
Environmental 2024)

Ferruginous hawk
(Buteo regalis)

CWL
MSHCP Covered Species
Range-wide, within
California, ferruginous
hawks winter in open
terrain and grasslands of
plains and foothills
(Grinnell and Miller 1944).

Within southern California,
including the ferruginous
hawks typically winter in
open fields, grasslands,
and agricultural areas.

No Potential. No suitable
habitat was documented
within the Project Site.

Swainson’s hawk
(Buteo swainsoni)

ST
MSHCP Covered Species
Typical habitat is open
desert, grassland, or
cropland containing
scattered, large trees or
small groves. Breeds in
stands with few trees in
juniper-sage flats, riparian
areas, and in oak
savannah in the Central
Valley. Forages in
adjacent grassland or
suitable grain or alfalfa
fields or livestock
pastures.

No Potential. No suitable
habitat was documented
within the Project Site.

Vaux’s swift
(Chaetura vauxi)

SSC
refers redwood and
Douglas-fir habitats with
nest-sites in large hollow
trees and snags,
especially tall, burned-out
snags. Fairly common
migrant throughout most
of the state in April and
May, and August and
September.

No Potential. No suitable
habitat was documented
within the Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 31 Species Name
(Scientific Name)
Status
Habitat Description Comments
Northern harrier
(Circus cyaneus)

SSC

The northern harrier
frequents open wetlands,
wet/lightly grazed
pastures, fields, dry
uplands/prairies, mesic
grasslands, drained
marshlands, croplands,
meadows, grasslands,
open rangelands, fresh
and saltwater emergent
wetlands.

Low Potential. May
occasionally forage onsite.

Western yellow-billed cuckoo
(Coccyzus americanus
occidentalis)

FT/SE
MSHCP Covered Species
Although the preferred
habitat, riparian scrub and
forest, is well distributed
at scattered locations
within the Plan Area in the
Riverside Lowland
Bioregions, the western
yellow-billed cuckoo
apparently no longer
inhabits much of this
habitat (MSHCP 2004).

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

White-tailed kite
(Elanus leucurus)

SFP
MSHCP Covered Species
The white-tailed kite is
found in riparian, oak
woodlands adjacent to
large open spaces
including grasslands,
wetlands, savannahs and
agricultural fields. This
non-migratory bird
species occurs throughout
the lower elevations of
California and commonly
nests in coast live oaks
(Unitt 2004).

Low Potential. May
occasionally forage onsite.

Southwestern willow
flycatcher
(Empidonax traillii extimus)

FE/SE
MSHCP Covered Species
The southwestern willow
flycatcher is narrowly
distributed at few
locations within the Plan
Area. Although the
preferred habitat, riparian
woodland and select other
forests, is well distributed
within all bioregions and
spread over the entire
Plan Area, few current
locations for the willow
flycatcher have been
documented (MSHCP
2004).

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 32 Species Name
(Scientific Name)
Status
Habitat Description Comments
California horned lark
(Eremophila alpestris actia)

SWL
MSHCP Covered Species

Habitat for the California
horned lark includes
agriculture (field
croplands), grassland,
cismontane alkali marsh,
playa and vernal pool
habitat, Riversidean
alluvial fan sage scrub,
and coastal sage scrub
(Garrett and Dunn 1988).

It has been recorded in
chaparral and riparian
habitat - however these
are not typical habitats
used by the species.

Moderate Potential. May
occasionally forage onsite.

Merlin
(Falco columbarius)

CWL
MSHCP Covered Species

The merlin has a sparse
and widespread
distribution throughout the
MSHCP Plan Area within
almost every habitat that
occurs within the Plan
Area. It occurs within the
Plan Area as a transient in
the spring and fall and
may occasionally winter
within the area. It does not
require specific conditions
or locations for nesting
because it does not nest
in the region. (MSHCP
2004)
No Potential. No suitable
habitat was documented
within the Project Site.

Prairie falcon
(Falco mexicanus)

CWL
MSHCP Covered Species

Habitat use of the prairie
falcon includes annual
grasslands to alpine
meadows. The prairie
falcon is associated
primarily with perennial
grasslands, savannahs,
rangeland, some
agricultural fields during
the winter season, and
desert scrub areas, all
typically dry environments
of western North
American where there are
cliffs or bluffs for nest
sites (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 33 Species Name
(Scientific Name)
Status
Habitat Description Comments
American peregrine falcon
(Falco peregrinus anatum)

SFP
MSHCP Covered Species

Throughout the species'
range, peregrine falcons
are found in a large
variety of open habitats,
including tundra, marshes,
seacoasts, savannahs
and high mountains (AOU
1998, MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Yellow-breasted chat
(Icteria virens)

SSC
MSHCP Covered Species
The yellow-breasted chat
is associated with riparian
woodland and riparian
scrub habitats (MSHCP
2004)
No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Loggerhead shrike
(Lanius ludovicianus)

SSC
MSHCP Covered Species
Loggerhead shrike prefer
open ground for foraging
and thick trees and shrubs
including sage scrub,
chaparral, and desert
scrub habitats for nesting.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coastal California gnatcatcher
(Polioptila californica californica)

FT/SSC
MSHCP Covered Species
The coastal California
gnatcatcher is a non-
migratory bird species that
primarily occurs within
sage scrub habitats in
coastal southern
California dominated by
California sagebrush
(Artemisia californica),
and California buckwheat
(Eriogonum fasciculatum).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Yellow warbler
(Setophaga petechia)

SSC
MSHCP Covered Species
Habitat characteristics of
the yellow warbler are well
known to include riparian
scrub and forest and
woodland (MSHCP 2004)
No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Least Bell's vireo
(Vireo bellii pusillus)

FE/SE
MSHCP Covered Species
Least Bell’s vireo resides
in riparian habitats with a
well-defined understory
including southern willow
scrub, mule fat, and
riparian forest/woodland
habitats.

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Yellow-headed blackbird
(Xanthocephalus
xanthocephalus)

SSC
Prefers freshwater
marshes habitat
dominated by cattails and
tule.

No Potential. No suitable
marsh habitat was
documented within or
adjacent to the Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 34 Species Name
(Scientific Name)
Status
Habitat Description Comments

MAMMALS
Pallid bat
(Antrozous pallidus)

SSC
In California, the species
as occurring in a variety of
habitats, including
coniferous forests, oak
woodlands, brushy terrain,
rocky canyons, open
farmland, and desert.

Roosts are selected on
the basis of
temperature/proximity to
foraging habitat. They are
generalists in their
roosting requirements,
using a variety of
structures including rock
crevices, tree hollows,
mines/caves, structures.

No Potential. No suitable
roosting habitat documented
within Project Site.

Northwestern San Diego
pocket mouse
(Chaetodipus fallax fallax)

SSC
MSHCP Covered Species
The northwestern San
Diego pocket mouse
occurs throughout the
Plan Area in coastal sage
scrub (including Diegan
and Riversidean upland
sage scrubs and alluvial
fan sage scrub), sage
scrub/grassland ecotones,
chaparral at all elevations
up to 6,000 feet (MSHCP
2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

San Bernardino kangaroo rat
(Dipodomys merriami parvus)

FE
MSHCP Covered Species
Alluvial sage scrub on
alluvial fans, flood plains,
along washes, in adjacent
upland areas, and in
areas with historic braided
stream channels; these
habitats characterized by
sand, loam, sandy loam,
or gravelly soils. Prefers
the more open early and
intermediate phases of
alluvial sage scrub, but
mature sage scrub is
important as refugia
during floods.

No Potential. No suitable
habitat documented onsite.

Stephens' kangaroo rat
(Dipodomys stephensi)

FE/ST
MSHCP Covered Species
The Stephens' kangaroo
rat is found almost
exclusively in open
grasslands or sparse
shrublands with cover of
less than 50 percent
No Potential. No suitable
open grassland habitat
documented onsite.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 35 Species Name
(Scientific Name)
Status
Habitat Description Comments
during the summer
(MSHCP 2004).

Western mastiff bat
(Eumops perotis californicus)

SSC

Western mastiff bats are
found in a variety of biotic
environments from low
desert scrub to chaparral,
oak woodland and
ponderosa pine.

No Potential. No suitable
roosting habitat documented
onsite.

Western yellow bat
(Lasiurus xanthinus)

SSC
Although formerly
associated only with the
desert palm oasis in
California (Bond, 1970),
yellow bats appear to be
expanding their range to
the coast and northward,
possibly as a result of the
planting of ornamental
palms.

No Potential. No suitable
roosting habitat documented
onsite.

San Diego black-tailed
jackrabbit
(Lepus californicus bennettii)

SSC
MSHCP Covered Species
The San Diego black-
tailed jackrabbit in open
habitats, primarily
including grasslands,
sage scrub, alluvial fan
sage scrub, and Great
Basin sage scrub.

No Potential. Not detected
onsite.

Bobcat
(Lynx rufus)

MSHCP Covered Species
The bobcat requires large
expanses of relatively
undisturbed brushy and
rocky habitats near
springs or other perennial
water sources.

No Potential. No suitable
habitat documented onsite.

Pocketed free-tailed bat
(Nyctinomops femorosaccus)

SSC

Usually associated with
rugged canyons, high
cliffs, and rock
outcroppings. Roosts in
rock crevices and caves
during the day; may also
roost in buildings or under
roof tiles (Ziener et al.
1988-1990).

No Potential. No suitable
roosting habitat documented
onsite.

Big free-tailed bat
(Nyctinomops macrotis)

SSC
Desert habitats. Roosts in
rock crevices in cliffs
No Potential. No suitable
roosting habitat documented
onsite.

Townsend’s big-eared bat
(Corynorhinus townsendii)

SSC
A wide variety of habitats
including woodlands and
arid grasslands. Roosts in
mines and caves.

No Potential. No suitable
roosting habitat documented
within Project Site.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 36 Species Name
(Scientific Name)
Status
Habitat Description Comments
Dulzura kangaroo rat
(Dipodomys simulans)

MSHCP Covered Species
The Dulzura kangaroo rat
occurs throughout the
Plan Area in coastal sage
scrub (including Diegan
and Riversidean upland
sage scrubs and alluvial
fan sage scrub), sage
scrub/grassland ecotones,
chaparral, and desert
scrubs at all elevations up
to 2,600 feet (MSHCP
2004)
No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

San Diego desert woodrat
(Neotoma lepida intermedia)

SSC
MSHCP Covered Species
The San Diego desert
woodrat is found
throughout the Plan Area
in sage scrub and
chaparral wherever there
are rock outcrops,
boulders, cactus patches
and dense undergrowth
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Los Angeles pocket mouse
(Perognathus longimembris
brevinasus)

SSC
MSHCP Covered Species
The Los Angeles pocket
mouse appears to be
limited to sparsely
vegetated habitat areas in
patches of fine sandy soils
associated with washes or
of aeolian (windblown)
origin, such as dunes
(MSHCP 2004)
No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

American badger
(Taxidea taxus)

SSC
The American badger
prefers friable soils in
open grassland and scrub
habitat in southern
California.

No Potential. No burrows
documented onsite.

Federal (USFWS) Protection and Classification
FE – Federally Endangered
FT – Federally Threatened
FC – Federal Candidate for Listing

State (CDFW) Protection and Classification
SE – State Endangered
SCE – State Candidate Endangered
ST – State Threatened
SSC – State Species of Special Concern
CWL – California Watch List
SPF – State Fully Protected

Sources: Cadre Environmental 2024.

Critical habitat designations by the USFWS were researched to determine if any of the Project Site is located within USFWS critical habitat. The Project Site does not occur within a designated critical habitat for federally endangered or threatened species.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 37 REGIONAL CONNECTIVITY/WILDLIFE MOVEMENT CORRIDORS

Overview

Wildlife corridors link areas of suitable habitat that are otherwise separated by rugged terrain, changes in vegetation, or human disturbance. The fragmentation of open space areas by urban ization creates isolated “islands” of wildlife habitat. In the absence of habitat linkages that allow movement to adjoining open space areas, various studies have concluded that some wildlife species, especially the larger and more mobile mammals, will no t likely persist over time in fragmented or isolated habitat areas because they prohibit the infusion of new individuals and genetic information (MacArthur and Wilson 1967; Soule 1987; Harris and Gallager 1989; Bennett 1990). Corridors effectively act as links between different populations of a species. A group of smaller populations (termed “demes”) linked together via a system of corridors is termed a “metapopulation.” The long-term health of each deme within the metapopulation is dependent upon its size and the frequency of interchange of individuals (immigration vs. emigration). The smaller the deme, the more important immigration becomes, because prolonged inbreeding with the same individuals can reduce genetic variability. Immigrant individuals that move into the deme from adjoining demes mate with individuals and supply that deme with new genes and gene combinations that increases overall genetic diversity. An increase in a population’s genetic variability is generally associated with an increase in a population’s health. Corridors mitigate the effects of habitat fragmentation by:

(1) allowing animals to move between remaining habitats, which allows depleted populations to be replenished and promotes genetic diversity; (2) providing escape routes from fire, predators, and human disturbances, thus reducing the risk that catastrophic events (such as fires or disease) will result in population or local species extinction; and
(3) serving as travel routes for individual animals as they move within their home ranges in search of food, water, mates, and other needs (Noss 1983; Fahrig and Merriam 1985; Simberloff and Cox 1987; Harris and Gallagher 1989).

Wildlife movement activities usually fall into one of three movement categories: (1) dispersal (e.g., juvenile animals from natal areas, individuals extending range distributions); (2) seasonal migration; and (3) movements related to home range activities (foraging for food or water, defending territories, searching for mates, breeding areas, or cover). A number of terms have been used in various wildlife movement studies, such as “wildlife corridor”, “travel route”, “habitat linkage”, and “wildlife crossing” to refer to areas in which wildlife moves from one area to another. To clarify the meaning of these terms and facilitate the discussion on wildlife movement in this study, these terms are defined as follows:

Travel Route: A landscape feature (such as a ridge line, drainage, canyon, or riparian strip) within a larger natural habitat area that is used frequently by animals to facilitate movement and provide access to necessary resources (e.g., water, food, cover, den sites). The travel route is generally preferred because it provides the least amount of topographic resistance in moving from one ar ea to another; it contains adequate food, water, and/or cover while moving between habitat areas; and provides a relatively direct link between target habitat areas.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 38 Wildlife Corridor: A piece of habitat, usually linear in nature, that connects two or mo re habitat patches that would otherwise be fragmented or isolated from one another. Wildlife corridors are usually bounded by urban land areas or other areas unsuitable for wildlife.

The corridor generally contains suitable cover, food, and/or water to support species and facilitate movement while in the corridor. Larger, landscape-level corridors (often referred to as “habitat or landscape linkages”) can provide both transitory and resident habitat for a variety of species.

Wildlife Crossing : A small, narrow area, relatively short in length and generally constricted in nature, that allows wildlife to pass under or through an obstacle or barrier that otherwise hinders or prevents movement. Crossings typically are manmade and include culverts, underpasses, drainage pipes, and tunnels to provide access across or under roads, highways, pipelines, or other physical obstacles. These are often “choke points” along a movement corridor.

Wildlife Movement within Project Site

The Project Site is not located within or adjacent to an MSHCP designated core, extension of existing core, non -contiguous habitat block, constrained linkage, or linkage area.

Specifically, the Project Site is located adjacent ( extending east and west) to ruderal vegetation which is collectively bound by high density residential development, high traffic roadways and commercial development. The Project Site does not represent a regional wildlife movement corridor and provides extremely limited cover, food, and no natural unrestricted water courses that would facilitate regional wildlife movement on or through the site.

REGIONAL AND REGULATORY SETTING

MSHCP COMPLIANCE ANALYSIS

Western Riverside County Multiple Species Habitat Conservation Plan Compliance Analysis

The proposed Project Site is located completely within the MSHCP, which is a comprehensive multi -jurisdictional effort that includes western Riverside County and eighteen (18) cities including the County of Riverside. Rather than addressing sensitive species on an individual basis, the MSHCP focuses on conservation of 146 species, including those listed at the federal and state levels and those that could become listed in the future. The MSHCP proposed a reserve system of approximate 500,000 acres, of which 347,000 acres are currently within public ownership and 153,000 acres will need to be assembled from lands currently in private ownership. The MHSCP allows the County and other permittees to issue take permits for listed species so that applicants do not need to receive endangered species incidental take authorization from the USFWS and CDFW.

On June 7 th, 2003, the County Board of Supervisors adopted the MSHCP, cer tified the Environmental Impact Report/Environmental Impact Statement, and authorized the Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 39 Chairman to sign the Implementing Agreement with the respective wildlife agencies. The Incidental Take Permit was issued by the wildlife agencies on June 22nd, 2004. The City of Moreno Valley is a Permittee under the MSHCP.

MSHCP Reserve Design & Criteria Area Objectives

Regions of the MHSCP have been organized into Area Plans that generally coincide with logical political boundaries, including city limits or long -standing unincorporated communities.

The project is located within the Reche Canyon/Badlands Plan Area . The Reche Canyon/Badlands Plan Area has a target conservation acreage of 30,815 - 35,905 acres; it is composed of approximately 20,295 -acres of existing Public/Quasi-Public Lands and 10,520 - 15,610 acres of Additional Reserve Lands. The target acreage range within the City of Moreno Valley is 10,520 - 15,610 acres (MSHCP 2004).

The Proj ect Site is not located within an MSHCP Criteria Area Cell or Cell Group.

Therefore, no Habitat Evaluation and Acquisition Negotiation Strategy (HANS) or Joint Project Review (JPR) are required.

MSHCP Sensitive Species Surveys

The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.3.2.

The Project Site is not located within an MSHCP Amphibian Species Survey Area; therefore, no surveys are required ( RCA GIS Data Downloads 20 24). The project is consistent with MSHCP Section 6.3.2.

The Project Site is not located within an MSHCP Mammal Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site occurs almost completely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map . Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2024 focused survey efforts (Gonzales E nvironmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non -native vegetation as shown Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 40 in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat.

An MSHCP preconstruction survey will be required at least 30-days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction survey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of the burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2.

MSHCP Riparian, Riverine, Vernal Pool Resources (Section 6.1.2)

Regulated activities within inland streams, wetlands and riparian areas in Western Riverside County California fall under the jurisdiction of the MSHCP. The MSHCP requires, among other things, assessments for riparian/riverine and vernal pool resources. As projects are proposed within the MSHCP Plan Area, an assessment of the potentially significant effects of those projects on riparian/riverine areas, and vernal pools are required, as currently mandated by CEQA, using available information augmented by project-specific mapping provided to and reviewed by the permittee’s biologist(s).

Riparian/riverine areas and vernal pools are defined for this section as follows in accordance with Section 6.1.2, Vol. I, of the Final MSHCP Plan:

“Riparian/Riverine Areas are lands which contain habitat dominated by trees, shrubs, persistent emergents, or emergent mosses and lichens, which occur close to or which depend upon soil moisture from a nearby fresh water source; or areas with fresh water flow during all or a port ion of the year.” (MSHCP 2004)

It is assumed the first part of the definition defines riparian habitat, and the second part defines riverine areas. Vernal pools are defined as:

“…seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season. Obligate hydrophytes and facultative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season”. (MSHCP 2004)

No MSHCP Section 6.1.2 riparian or riverine resources were documented within or adjacent to the Project Site. Specifically, no MSHCP Section 6.1.2 riparian scrub, forest or woodland resources representing suitable habitat for the least Bell’s vireo, southwestern willow flycatcher or western yellow-billed cuckoo was detected within or adjacent to the Project Site; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.2.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 41 No evidence of MSHCP Section 6.1.2 vernal pools, seasonal depressions, seasonally inundated road ruts or other wetland features were recorded on the Project Site. Vernal pools are depressions in areas where a hard-underground layer prevents rainwater from draining downward into the subsoils. When rain fills the pools in the winter and spring, the water collects and remains in the depressions. In the springtime, the water gradually evaporates away, until the pools became completely dry in the summer and fall. Vernal pools tend to have an impe rmeable layer that results in ponded water. The soil texture (the amount of sand, silt, and clay particles) typically contains higher amounts of fine silts and clays with lower percolation rates. Pools that retain water for a sufficient length of time will develop hydric cells. Hydric cells form when the soil is saturated from flooding for extended periods of time and anaerobic conditions (lacking oxygen or air) develop.

Consistent with conditions documented onsite and as previously stated, the Project Si te is characterized as San Emigdio fine sandy loam possessing well drained substrates (drainage class). No indication of clay substrates or hydric soils were documented within the Project Site. A review of historic aerials was conducted to determine if i nundated features were present during years of high rainfall when features would certainly be documented. Historic aerials taken in 2011 and 2023 represent an ideal baseline during which know (previously documented) inundated vernal pools, seasonal depressions and road ruts can easily be seen. No sign or indication of inundation was documented within the Project Site during a review of historic aerials . In summary, none of the conditions (i.e., no inundated depressions including road ruts, hydric soils, historic inundation, etc.) were observed on documented within the Project Site. No features are present that would support fairy shrimp. No standing water or other sign of areas that pond water was recorded. The project is consistent with MSHCP Section 6.1.2.

MSHCP Urban/Wildlands Interface Guidelines

The MSHCP Urban/Wildlands Interface guidelines presented in Section 6.1.4 are intended to address indirect effects associated with locating commercial, mixed uses and residential developments in proximity to a MSHCP Conservation Area. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.1.4.

MSHCP Fuels Management Guidelines

The fuels management guidelines presented in Section 6.4 of the MSHCP are intended to address brush management activities around new development within or adjacent to MSHCP Conservation Areas. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.4.

City of Moreno Valley (MSHCP Local Development Mitigation Fee)

The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and impleme nted by the City of Moreno Valley . Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 42 Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

Stephens’ Kangaroo Rat Fee

At the time of permit issuance, a fee of $500 per acre is due for all new developmen t.

Single-family residences where lots sizes are greater than ½ acre will only be subject to a flat fee of $500 per unit. Non -profit entities reduced by 75% as defined in 26 U.S.C. section 501 (c) (3).

LOCAL

City of Moreno Valley General Plan 2006

Conservation Element Goals (9.7.1) To achieve the wise use of natural resources within the City of Moreno Valley, its sphere of influence and planning area.

Conservation Element Objectives and Policies (9.7.2)

Objective 7.4 - Maintain, protect, and preserve biologically significant habitats where practical, including the San Jacinto Wildlife Area, riparian areas, habitats of rare and endangered species, and other areas of natural significance.

No sensitive biological resources, sensi tive vegetation , riparian habitat, wetlands or endangered species are located within or adjacent to the Project Site. The Project Site is not located within or adjacent to the San Jacinto Wildlife Area. Regardless, implementation of Conservation Measures BIO-CM1 through BIO-CM4, would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements. The proposed action would not conflict with Objective 7.4.

Policy 7.4.1 – Require all development, including roads, proposed adjacent to riparian and other biologically sensitive habitats to provide adequate buffers to mitigate impacts to such areas.

The Project Site is not located adjacent to riparian and other biologically sensitive habitats. No riparian or other biologically sensitive habitats are located onsite. The proposed action would not conflict with Objective 7.4.1.

Policy 7.4.2 - Limit the removal of natural vegetation in hillside areas when retaining natural habitat does not pose threats to public safety.

The Project Site is not located within or adjacent to a hillside. The proposed action would not conflict with Objective 7.4.2.

Policy 7.4.3 - Preserve natural drainage courses in their natural state and the natural hydrology, unless the protection of life and property necessitate improvement as concrete channels.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 43 No resources including drainage courses regulated by the USACE, RWQCB and CDFW are located within or adjacent to the Project Site. The proposed action would not conflict with Objective 7.4.3.

Policy 7.4.4 - Incorporate significant rock formations into the design of hillside developments.

The Project Site is not located within or adjacent to a hillside and no rock outcrops or formations are located within or adjacent to the property. The proposed action would not conflict with Objective 7.4.4.

Policy 7.4.5 - The City shall fulfill its obligations set forth within any agreement(s) and permit(s) that the City may enter into for the purpose of implementing the Western Riverside County Multi Species Habitat Conservation Plan.

The project proposes conservation and avoidance measures to address those adverse impacts determined to be potentially significant or are relevant to the protection of endangered, threatened and sensitive species as p art of ensuring compliance and compliance with all MSHCP conservation goals and CEQA guidelines.

The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley . Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside (BIO-CM3 SKR Fee Area).

City of Moreno Valley General Plan 2040

Goal OSRC -1: Preserve, protect, and enhance natural resources, habitats, and watersheds in Moreno Valley and the surrounding area, promoting responsible management practices.

Habitat Conservation and Species Protection

Policy OSRC.1-8: Cooperate with federal, State, and local regulatory agencies as well as non-profit organizations to promote the responsible stewardship of natural resources and habitats within the planning area.

No resources regulated by the USACE, RWQCB and CDFW are located within or adjacent to the Project Site . No sensitive vegetation is located within or adjacent to the Project Site. The proposed action would not conflict with Policy OSRC.1-8.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 44 Policy OSRC.1 -9: Ensure that adverse impacts on sensitive biological resources, sensitive natural communities, se nsitive habitat, and wetlands are avoided or mitigated to the greatest extent feasible as development takes place.

No sensitive biological resources, sensitive vegetation or wetlands are located within or adjacent to the Project Site. Regardless, implementation of Conservation Measures BIO- CM1 through BIO -CM4, would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements.

Policy OSRC.1-10: In areas where development (including trails or other improvements) has the potential for adverse effects on special-status species, require project proponents to submit a study conducted by a qualified professional that identifies the presence or absence of spe cial-status species at the proposed development site. If special -status species are determined to be present, require incorporation of appropriate mitigation measures as part of the proposed development prior to final approval.

Implementation of Conservation Measures BIO-CM1 through BIO-CM4, would reduce all potential significant unavoidable impacts special-status species below a level of significance and ensure compliance with MSHCP conservation requirements.

Policy OSRC.1 -11: Require all development, including roads, proposed adjacent to riparian and other biologically sensitive habitats to mitigate impacts to such areas.

The Project Site is not located within or adjacent to biologically sensitive habitats including riparian scrub, forest or woodland vegetation. No Impact. The proposed action would not conflict with Policy OSRC.1-11.

Policy OSRC.1-12: Limit to the extent feasible the removal of natural vegetation in hillside areas when retaining natural habitat does not pose threats to public safety.

OSRC.1-13: Promote the use of conservation easements and preserves as means to conserve natural habitats and protect natural resources.

No natural undisturbed vegetation is present within or adjacent to the Project Site. The proposed action would not conflict with Policy OSRC.1-12.

Actions OSRC.1 -D: Continue to participate in the implementation of regional habitat conservation and restoration programs, including the Western Riverside County Multiple Species Habitat Conservation Plan and the Stephens’ Kangaroo Rat Habitat Conservation Plan.

The project proposes conservation and avoidance measures to address those adverse impacts determined to be potentially significant or are relevant to the protection of endangered, threatened and sensitive species as part of ensuring compliance and compliance with all MSHCP conservation goals and CEQA guidelines.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 45 The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley . Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside (BIO-CM3 SKR Fee Area).

City of Moreno Valley Municipal Code

No trees meeting the City of Moreno Valley tree removal ordinance as outlined in Municipal Code Chapter 9.17, Landscape and Water Efficiency Requirements are located within or adjacent to the Project Site. No impact.

FEDERAL

Federal Endangered Species Act

The MSHCP serves as an HCP pursuant to Section 10(a)(1)(B) of the FESA of 1973, allowing participating jurisdictions to authorize " take" of plant and wildlife species. The MSHCP has been issued under this Section and provides incidental take for all covered species.

Clean Water Act

The Clean Water Act, Section 401 provides guidance for the restoration and maintenance of the chemical, physical, and biological integrity of the nation’s waters. Section 401 requires a project operator to obtain a federal license or permit that allows activities resulting in a discharge to waters of the United States to obtain state certification, thereby ensuring that the discharge will comply with provisions of the CWA. The Regional Water Quality Control Board administers the certification program in California. Section 404 establishes a permit program administered by the USACE that regulates the discharge of dredged or fill material into waters of the United States, including wetlands. The USACE implementing regulations are found at 33 CFR 320 and 330. Guidelines for implementation are referred t o as the Section 404(b)(1) Guidelines, which were developed by the United States Environmental Protection Agency in conjunction with the USACE (40 CFR 230). The guidelines allow the discharge of dredged or fill material into the aquatic system only if there is no practicable alternative that would have less adverse impacts.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 46 Wetland Definition Pursuant to Section 404 of the Clean Water Act

Aquatic resources, including riparian areas, wetlands, and certain aquatic vegetation communities, are considered sensitive biological resources and fall under the jurisdiction of several regulatory agencies. The USACE exerts jurisdiction over waters of th e United States, including all waters that are subject to the ebb and flow of the tide; wetlands and other waters such as lakes, rivers, streams (including intermittent or ephemeral streams), mudflats, sandflats, sloughs, prairie potholes, vernal pools, wet meadows, playa lakes, or natural ponds; and tributaries of the above features. The extent of waters of the United States is generally defined as the portion that falls within the limits of the OHWM. The OHWM is defined as the “line on the shore establish ed by the fluctuation of water and indicated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas.”

On April 21, 2020 the U.S. Environmental Protection Agency (EPA) and the USACE published the Navigable Waters Protection Rule to define “Waters of the United States” in the Fede ral Register. The April 2020 definition includes four simple categories of jurisdictional waters, including: (1) the territorial seas and traditional navigable waters; (2) perennial and intermittent tributaries to those waters; (3) certain lakes, ponds and impoundments; and (4) wetlands adjacent to jurisdictional waters.

The April 2020 definition provides clear exclusions for many water features that traditionally have been regulated, such as ephemeral drainages. The April 2020 definition has been formally adopted by EPA and the USACE and was used for this Jurisdictional Delineation.

Wetlands, including swamps, bogs, seasonal wetlands, seeps, marshes, and similar areas, are defined by USACE as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR 328.3[b]; 40 CFR 230.3[t]). Indicators of three wetland parameters (i.e., hydric soils, hydrophytic vegetation, and wetlands hydrology), as determined by field investigation, must be present for a site to be classified as a wetland by USACE (USACE 1987).

It is important to note that the RWQCB definition of w etland was redefined and the new definition went into effect May 28 th, 2020. The definition of a wetland is as follows: An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation. This RWQCB modif ied three -parameter definition is similar to the federal definition in that it identifies three wetland characteristics that determine the presence of a wetland: wetland hydrology, hydric soils, and hydrophytic vegetation. Unlike the federal definition, however, the RWQCB wetland definition allows for the presence of hydric substrates as a criterion for wetland identification (not just wetland soils) and Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 47 wetland hydrology for an area devoid of vegetation (less than 5% cover) to be considered a wetland.

However, if any vegetation is present, then the USACE delineation procedures would apply to the vegetated component (i.e., hydrophytes must dominate). Examples of waters that would be considered wetlands by the RWQCB definition, but not by the federal wetland definition, are non -vegetated wetlands, or wetlands characterized by exposed bare substrates like mudflats and playas, as long as they meet the three -parameters as described in the RWQCB definition. It is important to note that while the USACE may not designate a feature as a wetland, that feature could be considered a special aquatic site or other water of the U.S. by the USACE and potentially subject to USACE jurisdiction.

Migratory Bird Treaty and Bald and Golden Eagle Protection Acts

Migratory birds including resident raptors and passerines are protected under the federal MBTA. The MBTA of 1918 implemented the 1916 convention between the United States and Great Britain for the protection of birds migrating between the U.S. and Canada.

Similar conventions between the United States and Mexico (1936), Japan (1972) and the Union of Soviet Socialists Republics (1976) further expanded the scope of international protection of migratory birds. Each new treaty has been incorporated into the MBTA as an amendment and the provisions of the new treaty are implemented domestically. These four treaties and their enabling legislation, the MBTA, established Federal responsibilities for the protection of nearly all species of birds, their eggs and nests. The MBTA made it illegal for people to "take" migratory birds, their eggs, feathers or nests. Take is defined in the MBTA to include by any means or in any manner, any attempt at hunting, pursuing, wounding, killing, possessing or transporting any migra tory bird, nest, egg, or part thereof. The Bald and Golden Eagle Protection Act affords additional protection to all bald and golden eagles.

STATE

California Endangered Species Act

The CESA is similar to FESA in that it contains a process for listing of species regulating potential impacts to listed species. Section 2081 of the CESA authorizes the CDFW to enter into a memorandum of agreement for take of listed species for scientific, educational, or management purposes. The MSHCP serves as an HCP pursuant the Natural Communities Conservation Plan (NCCP) under the NCCP Act of 2001, allowing participating jurisdictions to authorize "Take" of plant and wildlife species.

As stated by CDFW:

“On June 22, 2004, the Department issued NCCP Approval and Take Authorization for the Western Riverside County MSCHP per Section 2800 et seq. of the California Fish and Game Code. The MSHCP establishes a multiple species conservation program to minimize and mitigate habitat loss and the incidental take of covered species in association with activities covered under the permit.” (CDFG 2004)

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 48 California Fish and Game Code 3503 and 3513

As stated by CDFW:

“CHAPTER 1. General Provisions [3500 - 3516] (Chapter 1 enacted by Stats. 1957, Ch. 456.) It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. (Amended by Stats. 1971, Ch. 1470.)”

Native Plant Protection Act

The Native Plant Protection Act (NPPA) enacted a process by which plants are listed as rare or endangered. The NPPA regulates collection, transport, and commerce in plants that are listed. The CESA follows the NPPA and covers both plants and wildlife determined to be threatened with extinction or endangered. Plants listed as rare under the NPPA are designated as threated under the CESA. No plants listed under the CESA occur on the Project Site onsite or offsite impact areas.

Regional Water Quality Control Board

The RWQCB also has jurisdiction over waters deemed “isolated” or not subject to Section 404 jurisdiction under the Solid Waste Agency of Northern Cook County v. Corps decision. Dredging, filling, or excavation of isolated waters constitutes a discharge of waste to waters of the state and prospective dischargers are required to obtain authorization through an Order of Waste Discharge or waiver thereof from the RWQCB and comply with other requirements of Porter-Cologne Act.

Under Section 401 of the CWA, th e local RWQCB must certify that actions receiving authorization under Section 404 of the CWA also meet state water quality standards. The RWQCB requires projects to avoid impacts to wetlands if feasible and requires that projects do not result in a net los s of wetland acreage or a net loss of wetland function and values.

CDFW Streambed Alteration Agreement

Waters of the State are regulated by the California Department of Fish and Wildlife (CDFW) through Section 1600 et seq. of the California Fish and Gam e Code. Section 1600 et seq. requires notifying the CDFW prior to any project activity that might (1) substantially divert or obstruct the natural flow of any river, stream, or lake; (2) substantially change or use any material from the bed, channel, or ba nk of any river, stream, or lake; or (3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake.

If, after this notification, the CDFW determines that the act ivity may substantially adversely affect fish and wildlife resources, a Lake or Streambed Alteration Agreement will need to be obtained. CDFW may then place conditions in the Section 1602 Streambed Alteration Agreement to avoid, minimize, and mitigate any potentially significant adverse impacts within CDFW jurisdictional limits.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 49 The limits of Waters of the State are defined as the “body of water that flows at least periodically or intermittently through a bed or channel having banks and supports fish or other aquatic life. This includes watercourses having surface or subsurface flow that supports or has supported riparian vegetation." Therefore, the limits extend from the channel bed to the top of the bank, with the addition of the canopy of any riparian habitat associated with the watercourse.

ENVIRONMENTAL IMPACTS

The following sections include an analysis of the direct impacts, indirect impacts, and cumulative effects of the proposed action on sensitive biological resources. This analysis characterizes the project related activities that are anticipated to adverse ly impact the species, and when feasible, quantifies such impacts. Direct effects are defined as actions that may cause an immediate effect on the species or its habitat, including the effects of interrelated actions and interdependent actions. Indirect effects are caused by or result from the proposed actions, are later in time, and are reasonably certain to occur. Indirect effects may occur outside of the area directly affected by the proposed action.

Cumulative impacts refer to incremental, individual environmental effects of two or more projects when considered together. These impacts taken individually may be minor but may be collectively significant. Cumulative effects include future tribal, local, or private actions that are reasonably certain to occur in the proposal vicinity considered in this report. A cumulative impact to biological resources may occur if a project has the potential to collectively degrade the quality of the environment, substantially reduce the habitat of wildlife species or cause a population to drop below self -sustaining levels, thereby threatening to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal species.

THRESHOLD OF SIGNIFICANCE

The environmental impacts relative to biological resources are assessed using impact significance criteria which mirror the policy statement contained in the CEQA at Section 21001 (c) of the Public Resources Code. This section reflects that the legislature has established it to be the policy of the state to:

“Prevent the elimination of fish and wildlife species due to man’s activities, ensure that fish and wildlife populations do not drop below self-perpetuating levels, and preserve for future generations representatio ns of all plant and animal communities…”

The following definitions apply to the significance criteria for biological resources:

• “Endangered” means that the species is listed as endangered under state or federal law.

• “Threatened” means that the species is listed as threatened under state or federal law.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 50 • “Rare” means that the species exists in such small numbers throughout all or a significant portion of its range that it may become endangered if its environment worsens.

• “Region” refers to the area within southern California that is within the range of the individual species.

• “Sensitive habitat” refers to habitat for plants and animals (1) which plays a special role in perpetuating species utilizing the habitat on the property, and (2) without which there would be substantial danger that the population of that species would drop below self-perpetuating levels.

• “Substantial effect” means significance loss or harm of a magnitude which, based on current scientific data and knowledge, (1) would cause a species or a native plant or animal community to drop below self -perpetuating levels on a statewide or regional basis or (2) would cause a species to become threatened or endangered.

Impacts to biological resources may result in a significant adv erse impact if one or more of the following conditions would result from implementation of the proposed project.

• Have a substantial adverse effect, either directly or through habitat modification, on any endangered, or threatened species, as listed in Tittle 14 of the California Code of Regulations (Sections 670.2 or 670.5) or Title 50, Code of Federal Regulations (Sections 17.11 or 17.12).

• Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a c andidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS, and meets the definition of Section 15380 (b), (c), or (d) of the CEQA Guidelines.

• Have a substantial adverse effect on any ripar ian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS.

• Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

• Interfere substantially with the movement of any native resident or migratory fish and wildlife species or with established native resident migratory wildlife corridors, or impede the use of native nursery sites.

• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

• Conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or state conservation plan.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 51 Also, the determination of impacts has been made according to the federal definition of “take”. The federal FESA prohibits the “ taking” of a member of an e ndangered or threatened wildlife species or removing, damaging, or destroying a listed plant species by any person (including private individuals and private or government entities). The FESA defines “take” as “to harass, harm, pursue, hunt, shoot, would, kill, trap, capture or collect” an endangered or threatened species, or to attempt to engage in these activities.

Specifically, the biological resources assessment report addresses the following CEQA Environmental Checklist items.

Environmental Issues

Potentially
Significant
Impact
Less than
Significant
with
Mitigation

Less than
Significant
Impact

No
Impact
Would the Project:
a) Have a substantial adverse effect, either
directly or through habitat modification, on
any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations,
or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife
Service?

X

b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service?

X
c) Have a substantial adverse effect on
federally protected wetlands as defined by
Section 404 of the Clean Water Act
(including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal,
filling, hydrological interruption, or other
means?

X

d) Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?

X

e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?

X

f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Native
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?

X

DIRECT IMPACTS

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS? Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 52 Sensitive Plants

The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.1.3. No Impact.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.3.2. No Impact.

No state or federally listed threatened or endangered plant species were documented or expected to occur onsite based on a lack of suitable habitat, as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite. No Impact.

No potential habitat and/or substrates was detected onsite for CNPS special-status plants not covered under the MSHCP , as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite. No Impact.

Sensitive Wildlife

No vernal pools, depressions or inundated features are present that would support sensitive fairy shrimp. No Impact.

The Project Site is not located within an MSHCP Amphibian Species Survey Area; therefore, no surveys are required (RCA GIS Data Download s 2024). The project is consistent with MSHCP Section 6.3.2. No Impact.

The Project Site occurs almost completely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map . Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2 024 focused survey efforts (Gonzales Environmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non -native vegetation as shown in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat. An MSHCP preconstruction survey will be required at least 30- days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction survey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of th e burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2 (BIO-CM2 MSHCP B urrowing Owl 30-Day Preconstruction Surveys ). Less than Significant Impact.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 53 No MSHCP Section 6.1.2 riparian scrub, forest or woodland habitat is located within or adjacent to the Project Site. No suitable habitat for the least Bell’s vireo, southwestern willow flycatcher or western yellow -billed cuckoo was detected within or adjacent to t he Project Site; therefore, no surveys are required (RCA GIS Data Downloads 202 4). The project is consistent with MSHCP Section 6.1.2. No Impact

The Project Site is not located within an MSHCP Mammal Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2. No Impact.

Moderate to low potential habitat was documented onsite for five (5) MSHCP covered species including sharp-shinned hawk - foraging, grasshopper sparrow, California horned lark, northern harrier - foraging, and white-tailed kite - foraging, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite . As previously stated, the MSHCP has determined that these sensitive species potentially occurring within Project Site have been adequately covered (MSHCP Table 2 -2 Species Considered for Conservation Under the MSHCP Since 1999, 2004). Potential impacts to MSHCP Covered sensitive wildlife species will be mitigated following payment of the MSHCP Local Development Mitigation Fee (BIO-CM1 MSHCP Local Development Mitigation Fee). Less than Significant Impact with Mitigation.

No suitable habitat was documented onsite for wildlife species not covered under the MSHCP, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite.

No Impact.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or USFWS?

No riparian scrub, forest or woodlands habitats are located within the Project Site. Also, as previously stated, no vegetation communities listed by CDFW as sensitive were documented within or adjacent to the Project Site. No Impact.

A total of 5.00-acres (4.81-acres onsite, 0.19-acre offsite) ruderal/disturbed, non -native grassland and developed vegetation communities will be directly and permanently impacted as a result of project implementation as summarized in Table 4, Project Site Vegetation Community Impacts, and illustrated on Figure 8, Vegetation Communities Impact Map. Compliance with the City of Moreno Valley MSHCP Local Development Mitigation Fees (Condition of Approval) would ensure direct impacts to all vegetation communities will remain consistent with MSHCP guidelines , BIO-CM1 MSHCP Local Development Mitigation Fee.

3 L E C R A P
4 1 1 8 M P
8 2 / 8 3 B M P
1 L E C R A P
6 3 6 6 1 M P
6 1 / 6 9 B M P
PARCEL 2
6 3 6 6 1 M P
6 1 / 6 9 B M P
1 inch = 80 feet
CADRE
Environmental
Figure 8 - Vegetation Communities Impact Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle
Cactus Avenue
Bradshaw Circle

PROJECT SITE BOUNDARYPROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
478-090-018
478-090-024
478-090-025
RWRW
Sources: Cadre Environmental 2024
Vegetation Communities
Non-native Grassland
Developed
NNGNNG
DEVDEV
Ruderal/DisturbedRUDRUD
RUDRUD
RUDRUD
RUDRUD
NNGNNG
NNGNNG
DEVDEV
Project Site Onsite Impacts
Project Site Offsite Impacts

OFFSITE IMPACT BOUNDARYOFFSITE IMPACT BOUNDARY
® ®
l
I ® w
I
~~ -
[-J
@ ®
I
j
II
~
et)
®
® '
EB
~
CD ffi
1 xJ56 L 5 \
ffi @y
\
. ---.

I
. ---.
fZZZJ
Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 55 Table 4.

Project Site Vegetation Community Impacts

Vegetation Type
Acres
(onsite)
Acres
(offsite)
Impact
Acres
TOTAL
Ruderal/Disturbed 3.11 0.00 3.11
Non-native Grassland 1.65 0.10 1.75
Developed 0.05 0.09 0.14
TOTAL 4.81 0.19 5.00
Source: Cadre Environmental 2024.

c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

No wetlands are located within or adjacent to the Project Site. No Impact.

The project will comply with all applicable water quality regulations, including complying with a NPDES regulations and MS4 permit requirements. The MS4 permit places pollution prevention requirements on planned developments, construction sites, commercial and industrial businesses, municipal facilities and activities, and residential communities.

Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activ ities and the installation and proper maintenance of structural BMPs to ensure adequate long -term treatment of water before entering into any stream course or municipal system.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

The Project Site is not located within or adjacent to an MSHCP designated core, extension of existing core, non -contiguous habitat block, constrained linkage, or linkage area.

Specifically, the Project Site is located adjacent (extending east and west) to ruderal vegetation which is collectively bound by high density residential development, high traffic roadways and commercial development. The Project Site does not represent a regional wildlife movement corridor and provides extremely limited cover, food, and no natural unrestricted water courses that would facilitate regional wildlife movement on or through the site.

The Project Site possess vegetation expected to potentially provide nesting habitat for migratory birds protected under the MBTA and CDFG Code Section 3503, 3503.5, and 3513. Measures for potential direct/indirect impacts to common and sensitive bird and raptor species will require compliance with the MBTA and CDFG Code Section 3503, 3503.5, and 3513. Construction outside the nesting season (between September 1st and January 3 1st) does not require preconstruction nesting bird surveys. However, if construction is proposed between February 1 st and August 31st, a qualified biologist will conduct a preconstruction nesting bird and raptor survey(s) no more than three (3) days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent to the Project Site. Loss of an active nest would be considered a Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 56 potentially significant impact. Impacts to nesting birds would be reduced to less than significant with mitigation following the implementation of Conservation Measure BIO- CM4: Nesting Bird Preconstruction Surveys.

e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

No trees meeting the City of Moreno Valley tree removal ordinance as outlined in Municipal Code Chapter 9.17, Landscape and Water Efficiency Requirements are located within or adjacent to the Project Site. No impact.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Native Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

The Project Site is located within the Western Riverside County MSHCP Reche Canyon/Badlands Plan Area and is not located within an MSHCP Criteria Area Cell, Cell Group, or Linkage Area, as shown in Figure 3, MSHCP Relationship Map . Following implementation of BIO-CM1 MSHCP Local Development Mitigation Fee , BIO-CM2 MSHCP 30-Day Preconstruction Surveys, and BIO-CM4 Nesting Bird Preconstruction Surveys, the project will be in compliance with MSHCP guidelines. Less than Significant Impact with Mitigation.

A detailed summary of MSHCP compliance is presented in the Regional and Regulatory Setting/Western Riverside County Multiple Species Habitat Conservation Plan Compliance Analysis section of the report.

INDIRECT IMPACTS

MSHCP Urban/Wildlands Interface Guidelines

The MSHCP Urban/Wildlands Interface guidelines presented in Section 6.1.4 are intended to address indirect effects associated with locating commercial, mixed uses and residential developments in proximity to a MSHCP Conservation Area. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.1.4.

The fuels management guidelines presented in Section 6.4 of the MSHCP are intended to address brush management activities around new development within or adjacent to MSHCP Conservation Areas. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.4.

Water Quality/Hydrology

The project will comply with all applicable water quality regulations, including obtaining and complying with those conditions established in (WDRs) and a NPDES permits. Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activities and the installation and proper maintenance of structural BMPs to ensure adequate long -term Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 57 treatment of water before entering into any stream course. No significant impacts are anticipated.

Toxics

Storm water treatment systems will be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant material, or other elements that could degrade or harm downstream biological or aquatic resources. Toxic sources within the Project Site would be limited to those commonly associated with residential development, such as pesticides, insecticides, herbicides, fertilizers, and vehicle emissions. In order to mitigate the potential effects of these toxics, the project will incorporate structural BMPs, as required in association with compliance with the NPDES permit system, in order to reduce or prevent the level of toxins introduced into downstream resources including the San Jacinto River. No significant impacts are anticipated.

Lighting

The Project Site is not located within or adjacent to proposed conserved or sensitive receptor lands. No impact.

Noise

The Project Site is not located within or adjacent to proposed conserved or sensitive receptor lands. No impact.

CUMULATIVE IMPACTS

The direct and/or indirect impacts of the project would not result in cumulative impacts (CEQA Section 15310) to environmental resources within the region of the Project Site.

Cumulative impacts refer to incremental effects of an indiv idual project when assessed with the effects of past, current, and proposed projects. The Project Site is located completely within the City of Moreno Valley , an MSHCP permittee. As stated in the County of Riverside Transportation and Land Management Agency:

”Implementation of the MSHCP and Covered Projects will not result in a cumulative adverse effect, either directly or through habitat modifications, on any of the Covered Species, including the 31 species that are currently listed as threatened or end angered and the one species that is currently proposed for listing. Implementation of the MSHCP will benefit the Covered Species by preserving their habitat in order to address their life cycle needs.

Thus, based on the features of the Plan itself, impacts to Covered Species are mitigated below a level of significance .” (County of Riverside Transportation and Land Management Agency 2003)

Although the project would result in the permanent loss of 5.00-acres (4.81-acre onsite,

0.19-acre offsite) of ruderal/disturbed, non-native grassland and developed vegetation communities, as referenced above, the MSHCP was developed to address the comprehensive regional planning effort and anticipated growth in the City of Moreno Valley.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 58 As stated in the County of Riverside Transportation and Land Management Agency:
“The Plan will not cause adverse cumulative effects related to the reduction of sensitive vegetation communities within the Plan Area; rather, the Plan is designed to preserve sufficient acreage of the sensitive vegetation communities present in western Riverside County. Similarly, the Plan will not cause adverse cumulative effects related to interference with the movement of any native resident or migratory fish or wildlife species or obstruction of gen etic flow for the identified Planning Species. Part of the purpose and goals of the MSHCP is to use regional planning efforts to assemble a reserve that will preserve contiguous blocks of habitat in large enough areas to ensure that the reserve will allow movement of species and flow of genetic information.

The MSHCP will not cause adverse cumulative impacts by conflicting with the provisions of any adopted Habitat Conservation Plan, Natural Communities Conservation Plan or other approved local, regional, or State habitat conservation plan either within or outside of the Plan area. Rather, the MSHCP has been written specifically to complement existing HCPs, such as the Stephens’ kangaroo rat long -term HCP.” (County of Riverside Transportation and Land Management Agency 2003)

The proposed project has been designed and conservation measures will be implemented to remain in compliance with all MSHCP conservation goals and guidelines and therefore will not result in an adverse cumulative impact. No Impact.

CONSERVATION MEASURES

The following biological conservation measures address those adverse impacts determined to be potentially significant or are relevant to the protection of biological resources to the extent practicable as part of ensuring compliance and consistency with all MSHCP conservation goals and CEQA guidelines.

BIO-CM1 MSHCP Local Development Mitigation Fee

The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley . Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 59 BIO-CM2 MSHCP Burrowing Owl 30-Day Preconstruction Surveys

A pre-construction survey for burrowing owls is required within 30 -days prior to initial ground-disturbing activities (e.g., vegetation clearing, clearing and grubbing, grading, tree removal, site watering, equipment staging) to ensure that no owls have colonized the site in the days or weeks preceding the ground -disturbing activities. If burrowing owls have colonized the project site prior to the initiation of ground -disturbing activities, the project proponent will immediately inform the City of Moreno Val ley and the Wildlife Agencies and will need to coordinate further with City and the Wildlife Agencies, including the possibility of preparing a Burrowing Owl Protection and Relocation Plan, prior to initiating ground disturbance. If ground -disturbing activities occur, but the site is left undisturbed for more than 30 days, a pre -construction survey will again be necessary to ensure that burrowing owl have not colonized the site since it was last disturbed. If burrowing owl is found, the same coordination de scribed above will be necessary. Following completion of the 30-day preconstruction survey in compliance with MSHCP conservation goals for the target species, the project will be consistent with MSHCP Section 6.3.2.

BIO-CM3 SKR Fee Area

The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside.

BIO-CM4 Nesting Bird Preconstruction Surveys

Regulatory requirement for potential direct/indirect impacts to nesting common and sensitive bird species will require compliance with the MBTA and CDFG Code Section 3503, 3503.5, and 3513 . Construction outside the nesting season ( between September 1st and January 31st) do not require pre -removal nesting bird surveys. If construction is proposed between February 1 st and August 31 st, a qualified biologist will conduct a preconstruction nesting bird and raptor survey(s) no more than three (3) days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent to the Project Site.

The survey(s) will focus on identifying any bird nests that would be directly or indirectly affected by construction activities. If active nests are documented, species -specific measures will be prepared by a qualified biologist and implemented to prevent abandonment of the active nest. At a minimum, grading in the vi cinity of a nest will be postponed until the young birds have fledged. The perimeter of the nest setback zone will be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by a qualified biologist verifying that no active nests are present, or that the young have fledged, will be submitted to the City of Moreno Valley for review and approval prior to initiation of grading in the nest -setback zone. The qualified biologist will serve as a construction monitor during those periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. A final monitoring report of the findings, prepared by a qualified biologist, will be submitted to the City of Moreno Valley documenting compliance with the CDFG Code. Any nest permanently vacated for the season would not warrant protection pursuant to the CDFG Code.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 60 Implementation of Conservation Measures BIO-CM1 through BIO-CM4 would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements.

LITERATURE CITED

American Ornithologist Union (AOU). 1998. Check-list of North American Birds. 7th ed.

American Ornithologists’ Union, Washington, DC.

Baker, R. J., L. C. Bradley, R. D. Bradley, J. W. Dragoo, M. D. Engstrom, R. S. Hoffman, C. A. Jones, F. Reid, D. W. Rice, and C. Jones. 2003. Revised checklist of North American mammals north of Mexico. Occasional Papers of the Museum of Texas Tech University. No. 229: 1-23.

Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, eds. 2012. The Jepson manual: vascular plants of California, 2nd ed. University of California Press, Berkeley.

Bennett, A. F. 1990. Habitat Corridors: their role in wildlife management and conservation, Department of Conservation and Environment, Melbour ne, Australia.

Cadre Environmental. 2024. Focused Burrowing Owl Surveys – TTM 37858.

California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation.

California Department of Fish and Wildlife (CDFW), Natural Diversity Data Base (CNDDB). 2024a. Sensitive Element Record Search for the Sunnymead Quadrangle.

California Department of Fish and Wildlife. Sacramento, California. Accessed June 2024.

California Department of Fish and Wildlife (CDFW). 2024b. Special Animals. Natural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024c. State and Federally Listed Endangered and Threatened Animals of California. Natural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024d. Endangered, Threatened, and Rare Plants of California. Nat ural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024e. Special Vascular Plants, Bryophytes, and Lichens. Natural Heritage Division, Natural Diversity Data Base.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 61 California Department of Fish and Wildlife (CDFW) 2024f. https://wildlife.ca.gov/Explore/Organization/BDB

California Native Plant Society. 2001. Botanical survey guidelines of the California Native Plant Society. Fremontia 29: 64-65.

California Native Plant Society. 2024. Inventory of Rare and Endangered Plants in California, 8th Edition, http://www.cnps.org/cnps/rareplants/inventory/ Accessed March 2024.

City of Moreno Valley. 2021. General Plan Amendment 2040.

City of Moreno Valley. 2006. General Plan.

County of Riverside. 2006. Burrowing Owl Survey Instructions – Western Riverside Multiple Species Habitat Conservation Plan Area.

Environmental Laboratory. 1987. USACE of Engineers Wetlands Delineation Manual, Technical Report Y -87-1, U.S. Army Engineer Waterways Experimental Station, Vicksburg, Mississippi.

Farhig, L. and G. Merriam. 1985. Habitat patch connectivity and population survival.

Ecology 66:1762-1768.

Ferren, W.R., Jr., P.L. Fiedler, R.A. Leidy, K. D. Lafferty, and L. A. K. Mertes. 1996b.

Wetlands of California. Part III. Key to the catalogue of wetlands of the central California and southern California coast and coastal watershed. Madroño 32:183- 223.

Ferren, W.R., Jr., P.L. Fiedler, and R.A. Leidy. 1996c. Wetlands of California. Part I.

History of wetland habitat. Madroño 32:105-124.

Gonzales Environmental Consulting, LLC. 2020a. Habitat Assessment including the results of Focused Bur rowing Owl Survey and Overview MSHCP Consistency Tentative Tract Map 37585.

Gonzales Environmental Consulting, LLC. 2020b. Habitat Assessment and Focused Surveys for Burrowing Owl Tentative Tract Map 37585.

Grinnell, J. 1933. Review of the recent mammal fauna of California. Univ. Calif. Publ. Zool. 40:71-234

Hickman, J. C. 1993. The Jepson Manual: Higher Plants of California. Berkeley:

University of California Press.

Jepson Flora Project. 2024 (v. 1.0 & supplements). Jepson eFlora. http://ucjeps.berkeley.edu/IJM.html. Accessed March 2024.

Biological Resources Technical Report TTM 37858 Cadre Environmental October 2025 62 Klein, A., and J. Evens. 2005. Vegetation alliances of western Riverside County, California. Final draft report prepared for California Department of Fish and Game, Habitat Conservation Division, Contract Number P0185404, California Native Plant Society, Sacramento, California.

Knecht, A. 1971. Soil Survey of Western Riverside Area, California. United States Department of Agriculture, Soil Conservation Service, Washington, DC.

McArthur, R. and Wilson, E. O. 1967. The theory of Island Biogeography . Princeton University Press, 1967.

Multiple Species Habitat Conservation Plan (MSHCP), Riverside County Integrated Project (RCIP). March 2004.

Noss, R. F. 1983. A regional landscape approach to maintain diversity. BioScience 33:700-706.

Roberts, F. M., Jr., S. D. White, A. C. Sanders, D. E. Bramlet, and S. Boyd. 2004. The vascular plants of western Riverside County, California: an annotated checklist.

F.M. Roberts Publications, San Luis Rey, California, USA.

Simberloff, D. and J. Cox. 1987. Consequences and cost of conservation corridors.

Conservation Biology 1:63-71.

Skinner, M. W. and B. M. Pavlik. 1994. California Native Plant Society's Inventory of Rare and Endangered Vascular Plants of California. California Native Plant Society. Special Publication, no. 1, 5th ed. Sacramento, California.

Soil Survey Staff, Natural Resources Conservation Service (NRCS), United States Department of Agriculture (USDA). Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed March 2024.

United States Fish and Wildlife Service. 2024. Threatened and Endangered Species.

Pacific Southwest Region. Carlsbad Office. Available online at http://www.fws.gov/carlsbad/SpeciesStatusList/CFWO_Species_Status_List%20. htm Accessed March 2024.

Certification “I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this biological evaluation, and that the facts, statements, and information presented are true and correct to the best of my knowledge.

Author:___________________________________________Date:_________________ October 10, 2025
Contact: Ruben S. Ramirez, Jr. 949-300-0212, [email protected]