Pleasanton City Council
April 21, 2026

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CalVTP Project-Specific Analysis and Addendum
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Table 17. Consistency of project -related wildfire impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report. ......................................................... 4-93

ATTACHMENTS
Attachment A. Mitigation and Monitoring Reporting Program Attachment B. Cultural Resources (Confidential)
Attachment C. Statement of Overriding Considerations

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LIST OF ABBREVIATIONS
BAAD Bay Area Air District
BMP best management practice
CAAQS California Ambient Air Quality Standards
CalEPA California Environmental Protection Agency
CAL FIRE California Department of Forestry and Fire Protection Cal-IPC California Invasive Plant Council
CalVTP California Vegetation Treatment Program
CARB California Air Resources Board
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CGS California Geological Survey
City The City of Pleasanton
CRHR California Register of Historical Resources
CWHR California Wildlife Habitat Relationship
DBH diameter at breast height
DPR Department of Pesticide RegulationEIR Environmental Impact Report GHG greenhouse gas
HCP Habitat Conservation Plan
I-680 Interstate 680
MM mitigation measure
MMRP mitigation monitoring and reporting program
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NOA naturally occurring asbestos
NRHP National Register of Historic Places
NWIC Northwest Information Center
PEIR Programmatic Environmental Impact Report

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CalVTP Project-Specific Analysis and Addendum
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PFIRS Prescribed Fire Information Reporting System
PRC Public Resources Code
PSA Project-Specific Analysis
RPF Registered Professional Forester
RWQCB Regional Water Quality Control Board
SCP Scientific Collecting Permit
SENL single-event noise level
SMP smoke management plan
SOD Sudden Oak Death
SPR standard project requirement
SRA State Responsibility Area
TMP traffic management plan
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
VMT vehicle miles traveled
WLPZ Watercourse and Lake Protection Zone
WUI wildland-urban interface

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1.0 INTRODUCTION

1.1. Overview of the Proposed Project
The City of Pleasanton (City) is proposing the Augustin Bernal Community Park Fuel Red uction Project (Project) within Pleasanton, California (Figure 1). The project area includes critical watershed and major transportation routes that collectively provide services to millions of regional residents. These include Interstate 680 (I -680) and local city roads. The Project would decrease the risk of wildfire- related disruptions to critical services and protect multiple community centers.

Elements of this project would include publicity to build support and awareness of the Project amongst residents of the region; continued defensible space and home hardening education and enforcement to reinforce the Project’s benefits; and fuel reduction/removal management to include all environmental monitoring and fuel treatment operations. This project would be carried out in coordination with the City’s ongoing community education/outreach efforts to aggressively reduce the risk of wildfire in the regi on.

Working collaboratively with the City, Livermore-Pleasanton Fire Department, Golden Eagle Estates, East Bay Regional Park District, and community members, the Project would result in the following outcomes:
• Reduce biomass of woody and vegetative material available for combustion • Significantly reduce the probability of uncontrolled wildfires starting in or entering Augustin Bernal Community Park and surrounding communities
• Increase effectiveness of defensible space surrounding residential structures in Augustin Bernal Community Park and surrounding communities
• Decrease available woody and vegetative material for conversion to greenhouse gases (GHGs) through unplanned combustion processes (e.g., wildfire)
• Provide a safer community with improved evacuation routes and access points for fire crews to establish anchor points
The goal of the Project is to create and maintain a reduced fuel zone around Augustin Bernal Community Park and surrounding community (Figures 1 and 2). The Project would provide a strategic location for firefighters to suppress fires, reduce the intensity of incipient fires, and prevent incipient fires from laddering into the tree canopy or causing fires to drop to the ground within the fuel break and wildland- urban interface ( WUI). The treatments proposed in this Project -Specific Analysis (PSA) would reduce dangerous wildfire fuels in a deliberate manner designed to minimize environmental impacts to wildlife and protected plants consistent with the California Vegetation Treatment Program (CalVTP) Programmatic Environmental Impact Report (PEIR; Ascent Environmental 2019). The Project would involve conducting vegetation management activities to contribute shaded fuel break/WUI fuel reduction as part of a regional effort, totaling approximately 162 acres of fuel reduction.

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Figure 1. Regional setting map of the Augustin Bernal Community Park Fuel Reduction Project site.

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Figure 2. Treatment areas map of the Augustin Bernal Community Park Fuel Reduction Project site.

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The CalVTP PEIR identified 20.3 million acres across the State of California within 31 -million-acre State Responsibility Areas ( SRAs) that may be appropriate for vegetation treatments as part of the CalVTP .

The PEIR calls this the “treatable landscape” or “treatable areas.” CalVTP recognizes that the treatable landscape represents areas suitable for CalVTP vegetation treatments, but projects would not necessarily occur in every location within the treatable landscape. The location and geographic extent of p rojects would be determined based on several factors, including environmental constraints and treatment objectives, which are analyzed for the proposed project within this PSA. Of the approximately 162-acre project footprint, approximately 69.5 acres are located within the CalVTP treatable landscape, and approximately 92.4 acres are outside of the defined treatable landscape (Figure 3).

An Addendum to an Environmental Impact Report (EIR) is appropriate where a previously certified EIR has been prepared and some changes or revisions to the project are proposed, or the circumstances surrounding the project have changed, but none of the changes or revisions would result in new or substantially more severe significant environmental impacts, consistent with California Environmental Quality Act (CEQA) Section 21166 and CEQA Guidelines Sections 15162, 15163, 15164, and 15168. In this case, there are no changed circumstances, but the proposed revision or change in the Project, compared to the PEIR, is the inclusion of areas of the scattered sections of Local Responsibility Area (LRA) outside of the CalVTP treatable landscape. The PSA checklist (refer to Section 3.0, Environmental Checklist) includes the criteria to support an Addendum to the CalVTP PEIR for the inclusion of proposed treatment areas outside the CalVTP treatable landscape. The checklist evaluates each resource in terms of whether the later treatment project, including the “changed condition” of additional geographic area, would result in significant impacts that would be substantially more severe than those covered in the CalVTP PEIR and/or would result in any new impacts that were not covered in the P EIR. This document serves as both a PSA and an Addendum to the CalVTP PEIR to provide CEQA compliance for the proposed vegetation treatments within and outside of the treatable landscape. The project-specific mitigation monitoring and reporting program (MM RP), which includes the CalVTP standard project requirements (SPRs) and mitigation measures (MMs) applicable to the proposed project, is presented in Attachment A. The SPRs identified in the MMRP have been incorporated into the proposed vegetation treatments as a standard part of treatment design and implementation of the proposed Project.

1.2. California Environmental Quality Act
The CalVTP PEIR evaluated the potential environmental effects of implementing qualifying vegetation treatments to reduce the risk of wildfire within the California Department of Forestry and Fire Protection’s (CAL FIRE) SRA.

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Figure 3. Treatable Landscape on the Augustin Bernal Community Park Fuel Reduction Project.

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Serving as the lead agency under the CEQA, the City proposes to implement vegetation treatments on 162 acres of land within Pleasanton, California. The proposed treatment types include shaded fuel breaks and fuel reduction. The treatment activities and methods include manual vegetation management, mechanical treatment, prescribed herbivory treatment, herbicide application, and prescribed burning.

The City has evaluated the proposed treatments for CEQA compliance as later activities covered by the CalVTP PEIR using the PSA checklist herein. These treatment types and treatment activities are consistent with those covered in the CalVTP PEIR. Ongoing maint enance of the proposed vegetation treatments would involve the same activities as the original treatments (i.e., manual, mechanical, prescribed herbivory, herbicide, and prescribed burning treatments).

1.3. Purpose of this Project-Specific Analysis and Addendum This document serves as the PSA to evaluate whether the proposed project is within the scope of the CalVTP PEIR. As described above, the treatment types and treatment activities are consistent with the CalVTP , which identifies the portion of the SRA that may be appropriate for vegetation treatments as “the treatable landscape.” One criterion for determining whether a treatment project is within the scope of the CalVTP PEIR is whether it is within the CalVTP treatable landscape (i.e., the geographic extent o f analysis covered in the PEIR). Within the project area, 69.5 acres are within the treatable landscape, and 92.5 acres are outside of the treatable landscape (Figure 3).

The PSA checklist (see Section 3.0) includes the criteria to support an addendum to the CalVTP PEIR for the inclusion of proposed treatment areas outside the CalVTP treatable landscape. The checklist evaluates each resource in terms of whether the later treatment project, including the “changed condition” of additional geographic area, would result in significant impacts that would be more severe than those covered in the CalVTP PEIR and/or would result in any new impacts that were not covered in the PEIR. The project-specific MMRP , which includes the CalVTP SPRs and MMs applicable to the proposed project, is presented in Attachment A. The SPRs and MMs have been tailored to the specific impact avoidance and minimization actions relevant to the proposed treatments, agency standard practices, and the conditions and resources present within each treatment site. In all cases, the additional project -specific implementation instructions and clarifying edits to MMs maintain the SPRs and MMs as equivalent to or more effective than those presented in the PEIR. Where applicable, the SPRs identified in the MMRP have been incorporated into the proposed vegetation treatments as a standard part of treatment design and implementation of the proposed project.

This document also serves as an addendum to the CalVTP PEIR for the inclusion of the additional 93 acres outside of the treatable landscape. An addendum to an EIR is appropriate when a previously certified EIR has been prepared and some changes or revisions to the project are proposed, or the circumstances

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surrounding the project have changed, but none of the changes or revisions would result in new or substantially more severe significant environmental impacts. In this case, there are no changed circumstances.

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2.0 PROJECT DESCRIPTION
The proposed project would create and maintain a 162 -acre reduced fuel zone in the San Francisco East Bay within and adjacent to Augustin Bernal Community Park, located in the high fire hazard severity zone on Pleasanton Ridge in Alameda County, California (Figures 1 and 2). The Project would be implemented on land owned and/or managed by the City, Golden Eagle Estates, and East Bay Regional Park District at elevations between approximately 600 feet and 1620 feet. The Project is within Augustin Bernal Community Park, adjacent to the unincorporated community of Kilkare Woods, and the neighborhoods of Golden Eagle Estates and The Club at Castlewood. The Project starts southwest of the City of Pleasanton, Alameda County, from the start of Long View Trail between Longview Drive and Longview Lane, extending southeast to the Golden Eagle Trail entrance off Golden Eagle Way, adjacent to Castlewood Country Club, then expanding west to the top of Pleasanton Ridge. A small section of the western portion of the Project is within the East Bay Regional Park District’s Pleasanton Ridge Regional Park.

While the p roject footprint includes 69.5 acres of land mapped as treatable landscape by the CalVTP , it also includes 92.5 acres not included in the CalVTP treatable landscape ( Figure 3). Treatment types and treatment activities would be consistent throughout the project footprint regardless of whether it has been mapped as treatable landscape. Treatment types and activities would be contingent upon site conditions, accessibility, and fu els management needs to achieve the shaded fuel break. This project proposes two treatment types consistent with the CalVTP PEIR: fuel breaks and WUI fuel reduction. The Project’s proposed treatment activities would be consistent with those described in the CalVTP PEIR:
manual treatment, mechanical treatment, prescribed burning (broadcast and pile), prescribed herbivory, and herbicide (spot treatment).

The project footprint and surrounding area have a wildfire hazard risk that is considered by CAL FIRE to be “high” to “very high.” Wildfire hazard risk is attributed to widespread invasive, noxious, fire -hazardous vegetation; decades of dead vegetation accumulation; over a century of fire suppression; and the increased risk of anthropogenic ignition associated with dense urban development (CAL FIRE 2023). The desired result of the Project is to restore fuel loads to more natural levels that can be maintained through prescribed fire and other methods. The Project would reduce excess and ladder fuels within an approximately 200 -foot-wide shaded fuel break and WUI, creating safer fire road access for first responders and community members.

The Project follows a route throughout the landscape that supports a strategic approach to wildfires in the WUI. Project implementation would not stop fire spread during periods of strong, warm, downslope winds with low relative humidity (i.e., Foehn winds), when pieces of burning material can be blown across fuel breaks. However, the Project would provide safer access and a point from which firefighting resources can “anchor” to conduct suppression activities, and it would increase the construction rate of fire lines while

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simultaneously reducing the amount of air-delivered fire retardant required to coat vegetation effectively.

Slowing down the spread of wildfire would provide additional time for an effective community evacuation.

Fuels work done on the Project would also p rovide an area largely cleared of vegetative fuels, which can act as a muster point for any persons within the park during incipient wildfire activity.

Uncontrolled wildfire is associated with environmental degradation impacts, such as increased GHG emissions and habitat loss. This project would reduce dangerous wildfire fuels in a deliberate manner designed to minimize environmental impacts to wildlife and protected plants.

Treatment types and activities described in the CalVTP aim to mimic conditions that exist in a natural environment where natural fires would have occurred. Strategic fuel removal would concentrate on areas of high fuel concentrations and disrupt the horizontal and vertical continuity of fuel beds.

Biological diversity in the area would be maintained by promoting conditions that favor native plant and animal species. Forest health would be improved through enhancing native, fire -resilient plant communities, primarily through ladder fuel and weed removal, opening space for native plants to return.

Healthy mature trees and scrub dominating the canopy would be thinned out and retained, reducing new brush and understory growth while preserving the carbon sequestration function. Biomass would be strategically diminished in open grassy areas.

In addition to the project treatment types and activities being consistent with the CalVTP , The City follows CAL FIRE’s best management practices (BMPs), which include identifying and avoiding sensitive resources to ensure environmental protection when des igning and constructing fuels reduction projects.

Implementation of these BMPs in combination with the CalVTP’s SPRs and MMs would protect lives, property, and natural resources while implementing fuels reduction activities.

2.1. Treatment Types
The proposed project would utilize two treatment types in combination to create fuel break and reduction for firefighting resources to contain or stop a fire: WUI fuel reduction and fuel break. Strategic placement of the WUI fuel break would be based upon the prevailing vegetation types, topographic characteristics, environmental considerations, and surrounding land uses. Fuels in the project area are primarily heavy loads of oak ( Quercus spp.), coyote brush ( Baccharis pilularis ), sticky monkey flower (Diplacus aurantiacus), poison oak ( Toxicodendron diversilobum), and grass; the general topography is steep with trail access through majority of the project area.

Residential homes adjacent to the project are primarily moderate to large in size ( 2,000 to 4,000 square feet) on moderate to large lots with densely intermixed vegetation and landscaping.

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The placement of the Project considered downwind areas with an active fire history that currently have inadequate evacuation routes. The goal of the Project is to reduce fuel loads in a high fire hazard area, protecting the City and surrounding neighborhoods while simultaneously creating safer access for first responders. The Project would use a “light touch” approach with an emphasis on ladder fuel reduction adjacent to existing fire trails and roads. This approach would minimize soil disturbance, maximize production rates, and limit the impact to special-status species of both flora and fauna.

WUI and shaded fuel breaks are defined in the sections below, and they would be used in combination.

Creation of the combined WUI shaded fuel break would strategically use several treatment activities based on the prevailing vegetation types, topographic c haracteristics, environmental considerations, and surrounding land uses. Work would be completed with minimal to no disturbance to the ground and remaining vegetation. Treatment activities by fuel type are described in more detail below and in Section

2.3. 2.1.1. Wildland-Urban Interface Fuel Reduction
WUI fuel reduction involves strategic removal of vegetation to prevent or slow the spread of non -wind- driven wildfire between structures and wildlands. In areas where wildland and manmade structures overlap, higher intensity fuel reduction typical of defensible space would occur within 100 to 150 feet of manmade structures, as determined by fire professionals and based on site conditions. Beyond 100 to 150 feet from manmade structures, vegetation treatments would be implemented with lower intensity. Fuel reduction would focus primarily on removal of fire hazardous vegetation such as dead, dying, and diseased vegetation, including trees, invasive plants, and noxious weeds, as well as limbing up of healthy trees.

2.1.2. Fuel Breaks
Fuel breaks give firefighters access to control wildfires and are useful in slowing fires bef ore they grow beyond initial attack capabilities. Fuel breaks permit first responders to reach the leading edges of a fire and protect isolated communities, and fuel breaks can stop or reduce the lateral spread of fires. In heavily wooded areas, a shaded fuel break would be implemented; the retained canopy shade would slow future growth of many grass and brush species and assist in future maintenance efforts. In sui table Alameda whipsnake (Masticophis lateralis euryxanthus) habitat, a “scrub island” strategy would be implemented to retain habitat function; this is discussed in more detail in later sections. Development and maintenance of a fuel reduction zone within a 100 -foot-wide fuel break would extend around community s tructures located adjacent to undeveloped open spaces. Portions of the fuel break would extend up to a width of 400 feet based on topography, site conditions, and land management constraints.

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2.2. Treatment Activities
Treatment activities to achieve project objectives would be applied singularly or in combination, depending on site conditions and site -specific goals. The Project’s proposed treatment activities are consistent with the CalVTP PEIR (Ascent Environmental 2019) and would include:
• Prescribed Burning: Includes broadcast burning (prescribed burning to reduce fuels over a larger area or restore fire resiliency in target fire -adapted plant communities conducted under specific conditions related to fuels, weather, and other variables) and pile burning (prescribed burning of piles of vegetative material to reduce fuel and/or remove biomass following treatment) • Mechanical Treatment: Use of motorized equipment to chip vegetation and mow select areas • Manual Treatment: Use of hand tools and hand -operated power tools to cut, clear, or prune herbaceous or woody species
• Prescribed Herbivory: U s e o f d o m e s ti c l i v e s t o c k t o r e d u c e a t a r g e t p l a n t p o p u l a ti o n , t h e r e b y reducing fire fuels or competition of desired plant species • Herbicides: Chemical application designed to inhibit growth of target plant species

2.2.1. Prescribed Burning (Broadcast)
Prescribed understory fires would mimic periodic low-intensity wildfires historically prevalent in the region and create similar structural and habitat conditions that benefit many plant and wildlife species. Gradual reintroduction of fire presents an opportunity to improve forest health, reduce critical fuel loading, improve emergency access, and regenerate a healthy ecosystem. Prescribed low -intensity surface fires (broadcast burning) would be used to control vegetation and manage fuel loads. Prescribed burning would remain within a predetermined area and w ould occur only with specific fuels and in safe weather conditions. Prescribed burns would be used for maintenance of treatments, and they would occur approximately every 5 years, as appropriate.

Active burns would follow environmental safety guidelines, including burning only after consideration of specific weather conditions (e.g., appropriate humidity, wind direction, etc.) and coordinating with resource agencies, such as the California Air Resources Board ( CARB). Specifically, active burns would include the preparation and implementation of a burn plan, including a smoke management plan (SMP).

The City would report site conditions and request approval to burn through the Prescribed Fire Information Reporting System (PFIRS), which serves as an interface between air quality managers, land management agencies, and individuals that conduct prescribed burning in California. A prescribed burn SMP must be submitted to and approved by the Bay Area Air District (BAAD) at least 30 days prior to burning.

Prescribed burns would typically be ignited using a flamethrower from a side-by-side utility terrain vehicle, by walking with a drip torch or fusee, or via other methods , as determined by a professional. Prescribed burns are typically completed in a single day but, under certain circumstances, could be maintained for up

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to 1 week. On average, up to 45 workers are present on-site for a prescribed burn. Heavy equipment would typically be operated from an existing road. In anticipation of completely avoiding the federally threatened Alameda whipsnake and minimizing habitat impacts for this species on the project site, prescribed burning within highly suitable Alameda whipsnake habitat would be restricted between November 1 and March 31 or when temperatures are conducive to snake movement, which is typically when soil surface temperatures reach or exceed 66 °F (19 °C).

2.2.2. Mechanical Treatment
Mechanical treatments would mow target vegetation with special care to avoid ground disturbance in sensitive habitat. Lawn mowers, or similar, would target vegetation, including standing and downed vegetation. Mechanical treatments would also be employed a s a biomass disposal method to chip and broadcast woody debris. Chipping and broadcasting equipment would remain on existing roads and fire trails. Mechanical treatment activities would occur predominantly on slopes below 40 percent grade, along ridges, and on slopes greater than 40 percent grade with equipment that can reach target vegetation from existing road infrastructure. No mechanical treatment would occur on slopes above 50 percent grade.

Mowing activity would avoid Alameda whipsnake habitat, state or federally jurisdictional waters, and riparian habitat by a no-work buffer, as defined in later sections of this document.

Typical mechanical treatments would require a team with up to 20 workers and equipment such as riding lawn mowers, tow chippers, and track chippers. Typical mechanical treatments would require several days to several months to complete, depending on the si ze of the treatment area, steepness of terrain, and type and density of vegetation.

2.2.3. Manual Treatment
Ground crews would use hand tools and hand-operated power tools, including chainsaws, hand saws, pole saws, McLeods, Pulaskis, weed pullers, weed eaters (e.g., string, plastic blades, or circular blades), brush cutters, and loppers to cut, clear, and/or prune trees, herbaceous vegetation, and woody shrubs. Where feasible, treatments would prioritize removal of invasive plants and noxious weeds. Within suitable Alameda whipsnake scrub habitat, hand -removal would prioritize removal of dead woody vegetation, dead branches, and invasive weeds. Manual treatment activities would avoid state or federally jurisdictional waters and riparian habitat by a standard buffer, as described in a later section.

Manual treatments within the project area would require several days to several months to complete, depending on the size of the treatment area, steepness of terrain, and type and density of vegetation.

Manual treatment typically clears 0.3 acres or more per day, per team. Manual treatments typically require 1 or 2 hand crew teams with a total of 20 to 40 crew members present on-site.

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2.2.4. Prescribed Herbivory
Prescribed herbivory involves transporting, releasing, herding, and moving grazing animals such as cattle, sheep, goats, or horses to designated sites. Herds would be installed strategically within areas with wildlife-safe fencing and a professional shepherd who would coordinate animal movements to prevent excessive grazing and ground disturbance. Moving livest ock from one grazing ground to another would occur at a frequency based on numerous site -specific factors, including slope, density and type of vegetation, stocking rate, type of livestock, and precipitation/moisture content of vegetation. Stocking rate would vary based on species of grazer (e.g., a herd of cattle would require a larger acreage than a herd of goats of the same size). Site conditions (e.g., relative density or quantity of the vegetation to be treated, etc.) would determine herd size and the grazing time to complete the job.

Prescribed herbivory would require temporary wildlife-safe fencing where natural barriers are not present, temporary water facilities and other infrastructure (e.g., corrals, fences), and guard animals and/or a shepherd to be present on-site. Any areas identified as sensitive to grazing activity would be clearly marked on project maps, and protection measures would be communicated to the herder and project manager, including a pre-vegetation removal field visit, as appropriate.

To prevent undesirable introduction of invasive or noxious plant species to the site, consideration would be given to where animals are coming from and whether viable seeds of undesirable species are present.

As necessary, the herd would be fed a weed-free diet for an appropriate period prior to being introduced to the grazing site. Any supplemental feed brought on-site would be free of noxious weeds.

2.2.5. Herbicide Application
Herbicides would be used strategically to supplement other treatment methods to prevent the spread and resprouting of invasive species within the treatment areas and along roads. Effective herbicides identified by the California Invasive Plant Council (Cal- IPC) and U.S. Department of Agriculture that are consistent with those described in the CalVTP PEIR (e.g., glyphosate and species-specific chemicals) would be applied.

On-the-ground application methods include painting cut stems or stumps and using backpa ck hand applicators targeted on focal invasive plants; no aerial spraying or spraying from trucks would occur. No herbicide used would occur within 25 feet of aquatic habitat except for direct application to freshly cut invasive tree stumps.

Herbicide application would comply with the U.S. Environmental Protection Agency ( USEPA) label directions and both California Environmental Protection Agency (CalEPA) and California Department of Pesticide Regulation (DPR) label standards. All herbicide application would be performed by certified and licensed pesticide applicators in accordance with all local, state, and federal regulations. Herbicide application would not take place within 24 hours of a rain event.

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2.2.6. Biomass Disposal
The goal of biomass disposal is to reduce ignitable material and associated air quality impacts from wildfire, reduce brood material for harmful insects and disease, and enhance aesthetics. By reducing the available fuel in the shaded fuel break, the fuel continuity is disrupted, which slows down the spread of wildfires and decreases potential fire intensity.

Methods for managing biomass include natural decomposition (e.g., chip and broadcast, lop and scatter), hauling off-site, and pile burning. To mitigate brood stratum opportunities for beetles, downed logs would not be left on site, in accordance with California Forest Practice Rules (CAL FIRE 2019) and BMPs.

Whenever feasible, natural decomposition of biomass would be preferred because: (1) forestry mulch aids in mitigating erosion and excessive soil disturbance; (2) keeping material on -site prevents the spread of disease and pathogens to other sites, with Sudden Oak Death (SOD; Phytophthora ramorum) being of particular concern in our region; and (3) GHG emissions are reduced by avoiding the transportation of material off-site to green waste facilities. For all these reasons, the most climate-friendly option is to leave woody biomass on-site to decompose naturally.

2.2.6.1. Natural Decomposition
Cut vegetation may be retained on-site to decompose naturally via lopping and scattering or chipping and broadcasting across the landscape. Lopping plants involves cutting a plant low to the ground and distributing the cut material. In some cases, a road -based chipper or an all -terrain vehicle and tracked towable chipper would be used to process cut vegetative materials. The vegetative material would be fed through the chipper and broadcast widely into treatment areas. Biomass would be chipped to 3 inches or smaller in size and spread up to 4 inches deep. Cut vegetation and chips would not be placed below the ordinary high water mark of aquatic features, within wetlands or riparian areas, or on top of burrows or rock piles. Understory debris chipped and scattered on-site would follow BMPs for reducing the spread of pests, disease, noxious weeds, and invasive species (see Section 2.5).

2.2.6.2. Hauling Off-Site
Vegetation moved off-site would be hauled to an appropriate biomass -processing facility. Transported invasive plant materials would be stored in a closed container to prevent spreading during transport.

2.2.6.3. Pile Burning
Hand-cut material would be piled as “feeder piles,” with the cut stems facing in one direction in a manner to minimize any overstory scorch when the piles are restacked and burned. Most of the piles would be built in open areas of the forest floor or on th e roadside. Suitable areas for pile burning are open areas

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away from tree canopies and power lines. Sites suitable for pile burning would depend on location of sensitive species habitat and safety guidelines (e.g., humidity, wind direction, etc.). General operations for pile burning would adhere to the following guidelines:
• Multiple piles would be burned on a single day
• Pile size would not exceed 20 feet in diameter
• Piles would not block vehicle access on any road or trail • Piles created within suitable Alameda whipsnake habitat and left for any significant period of time would be dismantled and re-piled prior to igniting
Pile burning would be conducted in compliance with the local authority having jurisdiction or CAL FIRE and BAAD Regulation 5 for open burning and burn day restrictions. Burns would be coordinated with appropriate resource agencies (e.g., CARB) and would fo llow a burn plan that includes a n SMP. The City would report site conditions and request approval to burn through PFIRS, which serves as an interface between air quality managers, land management agencies, and individuals that conduct prescribed burning in California.

2.3. Treatment Prescriptions by Fuel Type
The Project is divided into two distinct operations: removal of ladder and ground fuels and removal of ground fuels such as dead, dying, diseased, and downed vegetation, branches, and trees. Both operations would manage excess ladder and ground fuels throu gh a combination of treatment activities, including manual, mechanical, prescribed burning, prescribed herbivory, and herbicide spot -treatment. Resulting biomass would be pile burned, left to decompose naturally, or hauled off-site.

2.3.1. Ladder and Ground Fuel Removal

2.3.1.1. Fire Trails and Roads
Ladder and ground fuels along fire trails and roads would be managed at a distance of twice the flame length indicated by the prevailing fuel model for that area. This distance would ensure the effectiveness of fire trails and roads in slowing or stopping a fire’s spread during Diablo wind conditions. Trailside and roadside fuel reduction areas would provide an anchor point from which fire suppression resources would engage wildfires.

Treatment activities along fire trails and roads follow a combination of mowing and other similar mechanical means, hand crew trimming and thinning, prescribed grazing, prescribed burning, and spot herbicide treatment. The prescription would remove ladder fuels, remove or pile leaf litter and duff for pile burning, thin or remove dense brush, and trim low-hanging branches within 6 feet of the ground, or a height deemed appropriate to reach site goals by a professional. Annual grass and herbaceous weeds

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would be mowed or grazed to less than approximately 6 inches by cattle or goats, or a height appropriate to reduce fire risk and maintain habitat function as deemed by a professional.

2.3.1.2. Off-Trail and Off-Road
Beyond twice the flame length of trails/roadsides, excess ladder and ground fuel would be removed by hand crews, chippers, and mowing.

2.3.2. Dead, Dying, Diseased, and Downed Trees
The second operation would remove all dead, dying, diseased, and downed vegetation, branches , and trees presenting a fuel hazard, as determined by a Registered Professional Forester (RPF) or biologist.

Biomass would be hauled off-site or chipped and scattered on-site dependent on size, health of tree, and access to the biomass. Downed trees would be removed or piled for winter burning.

2.3.3. Habitat-Specific Prescriptions
Traditional fuel reduction methods adopt treatment activities that are typically determined by fuel type.

Vegetation types for proposed treatment within the project footprint are a mosaic of blue and coastal oak woodland, coastal scrub, and annual grasslands. One other California Wildlife Habitat Relationship (CWHR) classification system vegetation type found on the project site is urban, which corresponds primarily to roads. Treatment strategies are a combination of treatment activities broadly described f or each vegetation type. The treatment approach would generally adhere to the following basic guidelines:
• Prioritize removal of invasive plants and dead woody material while retaining live native vegetation
• Hazardous trees (e.g., dead or dying trees) identified by an RPF or qualified fire professional would be removed
• Tree canopy would be retained to the greatest extent feasible while removing ladder fuels o Large trees (greater than approximately 6 inches in diameter at breast height [DBH]) would be limbed up to approximately 6 feet or as determined by a professional o Small trees and brush (less than approximately 6 inches DBH) would be removed strategically, cutting stumps to within 4 inches of bare mineral soil o Small trees and large shrubs in open areas that have the potential to provide shade and reduce invasive plant species would be limbed up to approximately 6 feet, or as deemed by a professional, and the canopy would be left intact
o Tree canopy over emergency access roads would be trimmed up to approximately 15 feet from the ground, or as deemed by a professional based on site goals, to facilitate passage of emergency vehicles during a fire event
o A 6-foot gap from the tree canopy to the nearest shrub will be maintained • No commercial forest products would be removed

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2.3.3.1. Grass Fuel Type Treatment Activities
Grass fuel type would include habitat classified as annual grassland by the CWHR. Within non -native grassland, treatment activities would cut grasses to a maximum of approximately 6 inches, achieve horizontal spacing, and reduce overall fuel loading. Prescribed herbivory, mowing, prescribed burning, and herbicide spot treatment would be strategically combined in grass- and herb-dominated areas and in areas of shrub encroachment.

Prescribed Herbivory Treatment
Goats, cattle, or other grazing animals would be installed strategically within areas with wildlife -safe fencing or other existing barriers. A professional shepherd would coordinate animal movements to prevent excessive grazing and ground disturbance.

Mechanical Treatment Activities
Mowing would be performed using riding lawn mowers, or similar, which would not be used within 50 feet of suitable Alameda whipsnake habitat. Mechanical equipment that may be used to ignite or limit the spread of the prescribed burn would be present with appropriate fire department and City personnel.

Prescribed Burning Treatment Activities
Burning would be timed to control invasive non-native grasses where present. Perimeter fire lines would include existing roads and natural features where possible to maintain aesthetic values. Prescribed fires would be conducted in conditions promoting a light to moderate burn (i.e., when soil and duff are moist) to increase the productivity of the habitat without resulting in adverse impacts to wildlife. All prescribed burning (both broadcast and pile burns) would be done under applicable burn and air qual ity permits to minimize potential environmental impacts. Within suitable Alameda whipsnake habitat, prescribed burning and pile burning would be restricted to times when temperatures are conducive to snake movement, which is typically when soil surface temperatures reach or exceed 66 °F (19 °C).

Manual and Herbicide Treatment Activities
Crews equipped with hand -tools would trim dead, dying branches from native shrubs occurring within grassland. Small, isolated trees (6 inches or smaller in DBH) growing in the grassland would be cut and piled for burning. Larger trees encroaching on or distributed throughout grasslands would be limbed up to reduce vertical fuel continuity. Cut vegetation would be lopped and scattered, chipped and broadcasted, pile burned, or hauled off -site. Invasive shrubs and noxious weeds encountered in the grasslands wo uld

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be treated with the appropriate method for the species and life stage. Herbicide spot treatment would target invasive species and would be applied by hand or by backpack sprayer.

Biomass Disposal
Biomass from non-invasive, non-noxious plants would be left to naturally decompose (e.g., lop and scatter, chip and broadcast), pile burned, or hauled off -site. Poison oak would be cut and left in place (lop and scatter). Where chipper access is not practical, cut material would be piled strategically for later burning.

Within suitable habitat for Alameda whipsnake, piles left in place for a critical length of time as determined by a professional would be dismantled and reconstructed prior to burning.

2.3.3.2. Shrub Fuel Type Treatment Activities
Shrub fuel type would include habitat classified by the CWHR as coastal scrub . Shrub habitat present in the project area is limited to one large patch of coyote brush scrub and three shrub fragments (less than 1-acre in size), which are also dominated by coyote brush. The general approach in suitable Alameda whipsnake scrub habitat would be to strategically reduce hazardous fuels in a way that retains scrub habitat. Selective removal of invasive species and dead, woody vegetation and limbs would retain scrub habitat characteristics suitable for Alameda whipsnake with a mosaic of open and closed canopy patches.

The resulting patches would be irregular, oblong shapes to maintain a natural condition and retaining rocky outcrops through avoidance. Scrub patch characteristics would model naturally occurring scrub and would include variable age classes. Treatment activities within suitable Alameda whipsnake habitat would involve primarily manual thinning to remove dead woody vegetation and invasive species to achieve horizontal spacing. Other treatment activities in shrub fuel types would include prescribed herbivory in shrubby areas with interspersed grasses and areas adjacent to grasslands being grazed. Vegetation removal activities would retain scrub, and the overall dominant scrub habitat type would not be converted to a different habitat type.

Specifications for suitable Alameda whipsnake habitat are described by the U.S. Fish and Wildlife Service (USFWS) as follows: coastal scrub, coyote brush scrub, or maritime chaparral areas greater than 0.5 acres in size, or scrub areas greater than 0.2 acre s in size that are within 50 feet of scrub patches greater than

0.5 acres in size (FEMA 2013). Scrub islands created through mosaic thinning or patch retention thinning would result in a total canopy cover of between 30 and 50 percent shrubs and 50 to 70 percent grassy openings (FEMA 2013). Scrub retained in these dimensions also retains the overall habitat function for Alameda whipsnake while still serving the needs of the shaded fuel break.

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Manual and Herbicide Treatment Activities
Scrub would be retained in a natural mosaic through the removal of invasive species, thinning out dead branches from shrubs, and limbing up large shrubs. Small encroaching trees (under 6 inches DBH) may be removed, and limbs would be removed from larger trees up to 6 feet, as appropriate. Cut vegetation would be lopped and scattered, chipped and broadcasted, pile burned, or hauled off-site. Broom plants or other invasive shrubs and noxious weeds would either be uprooted and pulled or cut low to the ground and spot treated with herbicide. Herbicide spot treatment of invasive species and noxious weeds would be hand applied.

Prescribed Herbivory Treatment
Goats, cattle, or other grazing animals would be installed strategically within areas with wildlife -safe fencing or existing barriers . A professional shepherd would coordinate animal movements to prevent excessive grazing and ground disturbance.

Biomass Disposal
Biomass from non-invasive, non-noxious plants would be left to naturally decompose (e.g., lop and scatter, chip and broadcast), pile burned, or hauled off -site. Poison oak would be cut and left in place (lop and scatter). Where chipper access is not practical, cut material would be piled strategically for later burning.

Within suitable habitat for Alameda whipsnake, piles left in place for a critical length of time as determined by a professional would be dismantled and reconstructed prior to burning.

2.3.3.3. Tree Fuel Type Treatment Activities
Tree fuel types would include habitat classified by the CWHR as blue oak woodland, coastal oak woodland, and valley oak woodland. The general approach to tree fuel types would be designed to prevent fire from approaching or departing the fuel break, prevent fire from laddering into the tree canopy, and promote establishment of native trees. Selective thinning would result in a shaded fuel break that retains the tree canopy. This would be achieved through removal of select trees, branches, shrubs, and both l iving and dead vegetation that could facilitate the upward spread of fire from surface fuels to the forest canopy. The shade of the retained canopy would reduce the potential for rapid re -growth of understory, and the selectively treated areas would provide firefighters an opportunity to access lower-intensity ground fires should they occur. Within all wooded areas, vegetation removal would be addressed primarily with manual treatment activities to preserve a natural appearance. Other treatment activities used within forest fuel types would include mechanical equipment, herbicides, prescribed herbivory, and prescribed burning.

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Manual Treatment Activities
Hand-held tools would remove and thin understory shrubs and brush, as well as dead and dying trees and small (less than 6 inches DBH) , non-native, invasive trees. Lower tree limbs would be pruned, and most ground vegetation would be removed to break up the horizontal and vertical continuity of flammable vegetation. Invasive species and noxious weeds would be strategically removed first followed by fire-prone native species, such as oak, pine (Pinus spp.), coffee berry (Frangula spp.), sage (Artemisa spp.), etc. Native trees would be strategically retained in forested areas with 25 to 50 feet of space between crowns, where the tree crown is approximately 10 to 15 feet wide. Spacing may be closer than 25 feet on level ground as needed and greater than 50 fee t on steeper ground to mitigate wildfire behavior or near structures for structure protection.

Mechanical Treatment Activities
Mowing would be performed using riding lawn mowers, or similar, to remove hazardous fuels in the understory which would not be used within 50 feet of suitable Alameda whipsnake scrub habitat.

Mechanical equipment would be used to chip and scatter biomass from stable operating surfaces.

Herbicide Treatment
Invasive species and noxious weeds cut low to the ground may be hand-painted with herbicide.

Prescribed Herbivory Treatment
Goats, cattle, or other grazing animals would be installed strategically within areas with wildlife -safe fencing or existing barriers . A professional shepherd would coordinate animal movements to prevent excessive grazing and ground disturbance.

Biomass Disposal
Biomass from non-invasive, non-noxious plants would be left to naturally decompose (e.g., lop and scatter, chip and broadcast), pile burned, or hauled off -site. Poison oak would be cut and left in place (lop and scatter). Where chipper access is not practical, cut material would be piled strategically for later burning.

2.3.3.4. Riparian Habitat and Watercourses
All treatment activities and biomass distribution would avoid wetland, riverine, and other aquatic features by a standard minimum 25 -foot buffer, which would be increased based on recommendations of a qualified biologist or RPF and/or factors such as slope , existing erosion, sensitivity of the vegetative

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habitat, or presence of sensitive resources. Refueling of equipment would occur outside these buffers and would be performed using containment to mitigate the risk of spills.

2.4. General

2.4.1. Timing of Initial Treatment
The City would commence initial fuel treatment within the project footprint in April 2026 and would complete the work by the end of 2029.

2.4.2. Workers
The City and/or subcontractors would conduct all treatment activities. Crew team sizes would vary and would typically be fewer than 25 workers per site, per day. Multiple teams would work at the same time.

2.4.3. Site Access
Treatment areas would be accessed via existing fire roads and trails. No new roads or access points would be created. The Augustin Bernal Community Park parking lot would be used as the primary access point.

Vehicles and equipment would be staged at the contractor’s yard daily or on -site in the park, in coordination with the City.

2.4.4. Treatment Schedule and Duration
Treatments except herbivory would occur primarily on weekdays during daylight hours only. Prescribed burning will also be limited to the months of November 1 to March 31 during the winter hibernation season for Alameda whipsnake as described in Section 2.2.1 During prescribed burning, crews would need to conduct some maintenance burning on weekends to manage overall smoke impacts. Noise-generating treatments would comply with local regulations.

2.5. Pests, Diseases, and Invasive Species
Without proper prevention, project treatments have potential to spread pathogens, diseases, pests, or invasive species. SOD, pitch canker (Fusarium circinatum), yellow starthistle (Centaurea solstitialis), French broom ( Genista monspessulana), stinkwort ( Dittrichia graveolens ), and snake fungal disease (Ophidiomyces ophiodiicola) occur in the region and have potential to spread in the project area from one work area to another or from the project area to off-site areas. The goal of reducing invasive plant species within the p roject area is in conformity with the overall project goals of fuels reduction and wildfire

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prevention. Invasive plants can be spread when crews and equipment travel between sites, transporting soil and mud contaminated with seeds.

2.5.1. Sudden Oak Death
SOD infects coastal forests throughout California and Oregon and kills susceptible species, including valley oak (Quercus lobata), coast live oak ( Q. agrifolia), California black oak ( Q. kelloggii), canyon live oak ( Q. chrysolepis), and Pacific madrone (Arbutus menziesii) saplings. Host species that are in the treatment area include California bay laurel (Umbellularia californica) and coast redwood (Sequoia sempervirens). To avoid the spread of this pathogen, all hand equipment and boots worn by treatment crews would be sanitized, and heavy equipment, hosed off, prior to operations in areas where the spread of SOD is possible. The California Oak Mortality Task Force offers additional information regarding treatment and disposal measures for plants infected with SOD, which would be monitored for changes in SOD tre atment recommendations (California Oak Mortality Task Force 2023).

2.5.2. Pitch Canker
The fungal disease commonly referred to as pitch canker affects many pine species and can infect Monterey pine (Pinus radiata). Most California native pines are susceptible to pitch canker, but Monterey pine is the most widely affected host. To avoid the spread of this pathogen, the same measures described above to prevent the spread of SOD would be implemented. The Pitch Canker Task Force offers additional information regarding treatment and guidelines for handling woody material infected by pitch canker fungus, which would be monitored for recommendation changes (Pitch Canker Task Force 2023).

2.5.3. Yellow Starthistle
Yellow starthistle is an annual that germinates in February and March and matures in June and July. It produces viable seeds at late senescence of the flower head, and it is therefore vital to control before that point. Management would strategically combine chemical, manual, and mechanical (mowing) methods for removal. Physical methods should focus on reducing seed production and preventing seed germination. Methods for yellow starthistle removal would be based on treatments described by the Cal- IPC. Effec tive and common treatment methods for yellow starthistle include mowing and focused herbicide application, but other methods may be used as determined by a professional.

2.5.4. French Broom
French broom is a particularly ignitable invasive species known for its ability to shade out seedlings, replace native plant species, and carry fire into tree canopies. This species creates a large seed bank and readily resprouts from the root after cutting, freezing, or fire (Cal-IPC 2020). Removal of French broom is

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a priority, as the species presents increased fire hazard, has a robust seedbank, and causes adverse impacts to habitat and aesthetics. Methods for French broom removal would be based on treatments described by the Cal-IPC. Effective and common treatment methods for French broom include pulling and focused herbicide application, but other methods may be used as determined by a professional.

2.5.5. Stinkwort
S ti n k w o r t i s a s t r o n g-smelling, sticky annual that is common in disturbed areas. Due to prolific seed production, seed barbules, and lack of livestock palatability, stinkwort may easily colonize and subsequently disperse and outcompete native species. Pulling by hand or with a hoe to remove the entire plant, along with its roots, is the best method of control. Removal should occur prior to flowering in the fall to avoid spreading of seeds. Focused herbicide applications can be used as well, as determined by a professional.

2.5.6. Snake Fungal Disease
Snake fungal disease comes from a fungus that lives in the soil. This disease causes face abnormalities, scabs, abnormal molting, and other issues as the fungus consumes keratin in the scales (Thompson et al. 2 0 1 8 ) . S y m p t o m s a r e t y p i c a l l y m i l d b u t c a n b e f a t a l , a s t h e y m a y p r e v e n t s n a k e s f r o m l o c a ti n g a n d consuming prey. Snakes, such as the federally and state-threatened Alameda whipsnake, are susceptible to this disease. Spread of the fungus to new locations may occur when people track contaminated soil embedded in clothing, shoes, or equipment. In addition to applicable CalVTP SPRs and MMs, the measures described to prevent the spread of SOD would be implemented.

2.6. Treatment Maintenance
The City would monitor the treated areas for maintenance of desired vegetation conditions (“treatment maintenance,” per the CalVTP PEIR). The City would work with the high -risk Golden Eagle neighborhood to identify areas for priority in treatment maintenance to ensure that the defensible space is maintained for maximum benefit. Timing between maintenance activities would vary by habitat type, by changing site condition, and as determined by the City and Golden Eagle. In forested areas, treatment maintenance may occur every 3 to 5 years. In brush-dominated areas, treatment maintenance such as herbivory may occur every 1 to 5 years. In grassland areas or areas where initial treatments were primarily manual, treatment maintenance may occur annually.

Maintenance treatments are anticipated to follow the same methods as initial treatments but are subject to change depending on site response to initial treatment. For example, at locations where intensive vegetation removal (e.g., prescribed burning) occurred, treatment maintenance may use lower-intensity

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manual treatment activities in subsequent years. Because vegetation communities are dynamic, treatment activities would be modified to reflect changes.

Throughout the treatment maintenance period, the City would consider the continued relevance of the PSA. Where the City determines that the PSA is no longer sufficiently relevant, the City would determine whether a new or amended PSA or other environmental analysis is warranted. In addition, if more than 10 years pass since approval of the latest PSA update, the City would review the PSA for its applicability to current conditions. For example, the City would conduct a reconnaissance survey to verify that conditions are substantially similar to those anticipated in the PSA. Any updates would be documented.

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3.0 ENVIRONMENTAL CHECKLIST

3.1. Vegetation Treatment Project Information

1. Project Title: Augustin Bernal Community Park Fuel Reduction

2. CalVTP ID Number: 2025-22

3. Project Proponent’s
Name and Address:

The City of Pleasanton
200 Old Bernal Avenue, P .O. Box 520
Pleasanton, California 94566

4. Contact Person
Information and Phone
Number:

Matt Gruber, City Landscape Architect
(925) 931-5672
[email protected]

5. Project Location: Augustin Bernal Community Park and surrounding communities.

UTMs: 10S 596065m E 4166218m N

6. Total Area to Be Treated: 162 acres

7. Description of Project:

The proposed project would involve conducting fuel reduction vegetation management activities on 162 acres across Augustin Bernal Park, Golden Eagle Estates, and surrounding communities in Pleasanton, California. See Section 2.0 for the expanded Project Description. a. Initial Treatment
See Section 2.0 for expanded Project Description.

Treatment Types
☒ Wildland-Urban Interface Fuel Reduction
☒ Fuel Break (Shaded)
☐ Ecological Restoration
Treatment Activities
Multiple strategies will be utilized to achieve the shaded fuel break and WUI fuel reduction, and therefore the acreage sum below will exceed the actual acreage of the project area. ☒ Prescribed Burning (Broadcast), approximately 42 acres ☒ Prescribed Burning (Pile Burning), approximately 162 acres ☒ Mechanical Treatment, approximately 17 acres, outside of Alameda whipsnake habitat

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☒ Manual Treatment, approximately 162 acres
☒ Prescribed Herbivory, approximately 60 acres
☒ Herbicide Application, approximately 1 acre
Fuel Type
☒ Grass Fuel Type
☒ Shrub Fuel Type
☒ Tree Fuel Type
b. Treatment Maintenance
Per Section 2.6, Treatment Maintenance, maintenance treatments are anticipated to follow the same methods as initial treatments but are subject to change depending on site response to initial treatment.

Treatment Types
☒ Wildland-Urban Interface Fuel Reduction
☒ Fuel Break (Shaded)
☐ Ecological Restoration
Treatment Activities
Multiple strategies will be utilized to achieve the shaded fuel break and WUI fuel reduction, and therefore the acreage sum below will exceed the actual acreage of the project area. ☒ Prescribed Burning (Broadcast), approximately 42 acres ☒ Prescribed Burning (Pile Burning), approximately 162 acres ☒ Mechanical Treatment, approximately 17 acres, outside of Alameda whipsnake habitat ☒ Manual Treatment, approximately 162 acres
☒ Prescribed Herbivory, approximately 60 acres
☒ Herbicide Application, approximately 1 acre
Fuel Type
☒ Grass Fuel Type
☒ Shrub Fuel Type
☒ Tree Fuel Type

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8. Regional Setting and Surrounding Land Uses:

The proposed project would create and maintain a 162-acre reduced fuel zone in the San Francisco East Bay within and adjacent to Augustin Bernal Community Park, located in the high fire hazard severity zone on Pleasanton Ridge in Alameda County, California ( Figures 1 and 2). The Project would be implemented on land owned and/or managed by the City, Golden Eagle Estates, and East Bay Regional Park District at elevations between approximately 600 feet and 1620 feet. The Project is within Augustin Bernal Community Park, adjace nt to the unincorporated community of Kilkare Woods, and the neighborhoods of Golden Eagle Estates and The Club at Castlewood. The Project starts southwest of the City, Alameda County, from the start of Long View Trail between Longview Drive and Longview Lane, extending southeast to the Golden Eagle Trail entrance off Golden Eagle Way, adjacent to Castlewood Country Club, then expanding west to the top of Pleasanton Ridge. A small portion of the western portion of the Project is within Pleasanton Ridge Regional Park.

9. Other Public Agencies Whose Approval Is Potentially Required (e.g., permits):
• Pesticide application permit from Alameda County Agricultural Commissioner • SMP from BAAD
• Burn permit from BAAD
• Burn permit from CAL FIRE
• Waste discharge requirement from the San Francisco Regional Water Quality Control Board (RWQCB)
• Encroachment permits from local public works departments • Informal consultation with California Department of Fish and Wildlife (CDFW) • Informal consultation with USFWS
Coastal Act Compliance
☒ The proposed Project is NOT within the Coastal Zone
☐ The proposed Project is within the Coastal Zone (check one of the following boxes) ☐ A coastal development permit has been applied for or obtained from the local Coastal Commission district office or local government with a certified Local Coastal Plan, as applicable.
☐ The local Coastal Commission district office or local government with a certified Local Coastal Plan (in consultation with the local Coastal Commission district office) has determined that a coastal development permit is not required.

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10. Native American Consultation:

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

Pursuant to CalVTP SPR CUL-2, an updated Native American contact list and sacred lands file search was obtained from the Native American Heritage Commission (NAHC). The sacred lands data file indicated that no sacred sites occur within the project area or adjacent lands. On July 2, 2025, letters were sent via email to each of the 2 7 Tribal contacts provided by the NAHC that requested any additional information regarding Tribal resources and to notify the City if they wished to initiate consultation regarding the Project actions. As of the filing date, four responses ha ve been received—two requesting consultation and two confirming receipt. As planning proceeds, the City would continue to consult with interested Tribal representatives regarding the Project and incorporate their concerns into Project planning and mitigation as warranted.

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3.2. Determination
On the basis of this PSA and the substantial evidence supporting it:
☒ I find that (a) all of the effects of the proposed project have been covered in the CalVTP PEIR and (b) all applicable SPRs and MMs identified in the CalVTP PEIR will be implemented. The proposed project is, therefore, WITHIN THE SCOPE of the CalVTP PEIR. NO ADDITIONAL CEQA DOCUMENTATION is required.
☐ I find that the proposed project will have effects that were not covered in the CalVTP PEIR. These effects are less than significant without any mitigation beyond what is already required pursuant to the CalVTP PEIR. A NEGATIVE DECLARATION will be prepared. ☐ I find that the proposed project will have effects that were not covered in the CalVTP PEIR or will have effects that are substantially more severe than those covered in the CalVTP PEIR. Although these effects may be significant in the absence of additional mitigation beyond the CalVTP PEIR’s measures, revisions to the proposed project or additional MMs have been agreed to by the project proponent that would avoid or reduce the effects so that clearly no significant effects would occur.

A MITIGATED NEGATIVE DECLARATION will be prepared.
☐ I find that the proposed project will have significant environmental effects that are (a) new and were not covered in the CalVTP PEIR and/or (b) substantially more severe than those covered in the CalVTP PEIR. Because one or more effects may be significant and cannot be clearly mitigated to less than significant, an ENVIRONMENTAL IMPACT REPORT will be prepared.

SIGNATURE DATE
Matt Gruber La ndscape Architect

PRINTED NAME TITLE
City of Pleasanton
AGENCY
4-9-2026

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4.0 PROJECT-SPECIFIC ANALYSIS AND ADDENDUM

4.1. Aesthetics and Visual Resources
Table 1. Consistency of project-related aesthetics and visual resources impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

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

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

3.2-25
Yes
AD-4, REC-
1, AES-1,
AES-2, AES-
3 NA LTS No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact AES-3: Result in Long-Term
Substantial Degradation of a Scenic
Vista or Visual Character or Quality
of Public Views, or Damage to Scenic
Resources in a State Scenic Highway
from the Nonshaded Fuel Break
Treatment Type
SU
Impact AES-3,
pp. 3.2-25–

3.2-27
No NA None NA NA NA
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

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

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CalVTP Project-Specific Analysis and Addendum
Augustin Bernal Community Park Fuel Reduction
November 2025
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4.1.1. Discussion

4.1.1.1. Impact AES-1
The Project would involve prescribed (broadcast) burning, mechanical treatment, manual treatment, prescribed herbivory, and application of herbicides. The potential for these treatment activities to result in short -term degradation of visual character was examined in the PEIR and found to be less than significant.

Portions of the treatment area would be visible from the southbound lanes of I-680, an officially designated state scenic highway, as well as the northbound lanes of I-680, an eligible state scenic highway (California Department of Transportation 2019). Pursuant to the City’s General Plan, a scenic highway designation protects the scenic values of an area, as well as providing passive recreational opportunities to view the associated scenic vistas (City of Pleasanton 2009, page 7 -2 4 ) . A c c o r d i n g t o t h e C a ltrans California Scenic Highway Map, the project site is located approximately 1.3 miles southwest of the nearest point of both the southbound and northbound lanes of I-680 and SR 24 (which run in parallel along this segment of both highways). Augustin Bernal Park is identified in the City’ s 2022 Housing Element Dr aft PEIR as part of a series of public and private open space, parks, and greenways that further distinguish the visual character of the City. Additionally, the City’s General Plan further identifies the Pleasanton Ridgelands (which includes the project area) as areas of special visual interest that include approximately 13,000 acres and are generally bounded I -580 to the north, the 670 -foot elevation near Foothill Road to the east, Niles Canyon Road to the south, and Palomares Road to the west (City of Pleasanton 2022, page

3.1-4). Although in the short term after treatment, the absence of treated vegetation could be noticeable, mature vegetation would remain to provide partial screening of treatment areas. However, equipment, crews, and smoke from prescribed burning could be visible from public viewpoints , including locally designated scenic vistas, and an eligible and officially designated state scenic highway (I-680) in the short term.

Consistent with the PEIR, the presence of large equipment could contrast with the natural environment where publicly visible, such as adjacent to a public trail or roadway. However, treatment and its visibility would be temporary and would not dominate a view or block any views from scenic vistas or state scenic highways. It is important to note that portions of the project treatment area would be shielded by a ridgeline that would largely block public views from I -680 towards those portions of the treatment area.

Smoke from prescribed burning could also be visible from public viewpoints/scenic vistas and I-680. These activities also would not substantially degrade the existing visual character or quality of an area, given that the treatment activities would be limited in geographic extent. The potential for the Project to result in short-term substantial degradation of the visual character of the project area within the treatable landscape (69.5 acres) is within the scope of the PEIR because the proposed treatment activities and types

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of equipment proposed for use are consistent with those analyzed in the PEIR. The inclusion of land that is outside the CalVTP treatable landscape (92.5 acres) in the proposed project area constitutes a change to the geographic extent presented in the PEIR . However, within the boundary of the project area, the existing scenic resources are essentially the same within and outside of the treatable landscape; therefore, the short-term aesthetic impact is also the same, as described abo ve. SPRs applicable to th e proposed treatments are AD-4, AES-2, AQ-2, AQ-3, and REC -1, which require that public notice be given for any prescribed burning activities, treatment-related equipment be stored outside of the public viewshed, a n SMP be submitted if the prescribed burning triggers the threshold (17 CCR Section 80160), a Burn Plan be created, and recreational users be notified of any temporary recreation area closures.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing scenic resources are essentially the same within and outside of the treatable landscape; therefore, the short-term aesthetic impact would also be the same, as described above. The impact of the Project is c onsistent with the PEIR and would not c onstitut e a substantially more severe significant impact than what was covered in the PEIR.

4.1.1.2. Impact AES-2
Initial and maintenance treatments would include shaded fuel break and WUI fuel reduction treatment types. The potential for these treatment types to result in long -term degradation of the visual character of an area was examined in the PEIR and found to be less than significant. Treatments would occur on both public and private lands. Removal of dead or dying vegetation and hazard trees, thinning shrub-dominated areas, and prescribed burning would result in a change in views. The shaded fuel break treatment would retain canopy cover and retain trees larger than 6 inches DBH while limbing up larger trees to 6 feet. Shrub- dominated areas would be thinned through elective removal of invasive species and dead, woody vegetation and limbs. Vegetation removal activities would retain scrub, and overall dominant scrub habitat type would not be converted to a different habitat type. These methods would largely preserve the natural appearance. Therefore, these treatments would not substantially affect views.

As described in the PEIR, prescribed burning would result in grasses temporarily changing color from green or brown to a dark gray/black. Grass would regrow during the following winter, so this adverse change would be temporary and short in duration. Additionally, prescribed burning and wildfires occur in this area under existing conditions, so similar burned vegetation is already visible in the vicinity of the treatment areas. Finally, the proposed project would be designed to create a landscape appearance closer to native conditions and could therefore result in long-term beneficial visual impacts.

As described in Impact AES-1, portions of the treatment area are visible from I-680, an eligible and official designated state scenic highway, as well as locally designated scenic vistas and viewsheds . Public hiking

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trails, in the form of single -track trails and unpaved roads, are also present within and adjacent to the treatment areas. The aesthetic impacts would be temporary and short -term, and the natural characteristics of the treatment areas would remain following treatment. SPRs applicable to the proposed treatments are S PRs AD-4, AES-1, AES -2, AES -3, and REC -1, which require public notification of any prescribed burning and that treatment-related equipment be stored outside of the public viewshed, treatment area edges are feathered to create a natural transitional appearance, vegetation screening is provided within and adjacent to treatment areas, and recreational users be notified of any temporary recreation area closures. The potential for the Project to result in long-term substantial degradation of the visual character of the p roject area is within the scope of the PEIR because the proposed treatment activities are consistent with those analyzed in the PEIR.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing scenic resources are essentially the same within and outside of the treatable landscape; therefore, the short-term aesthetic impact would also be the same, as described above. The impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.1.1.3. Impact AES-3
This impact does not apply to the proposed project because no non-shaded fuel breaks are proposed.

4.1.1.4. New Aesthetic and Visual Resource Impacts
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of the proposed treatments and determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (per Sections 3.2.1, Environmental Setting, and 3.2.2, Regulatory Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape (92.5 acres of a total of 162 acres or approximately 57 percent of the total project treatment area) constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental conditions pertinent to aesthetics and visual resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts would be the same, and, for the reasons described above, impacts of the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.

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

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4.2. Agriculture and Forestry Resources
Table 2. Consistency of project-related agriculture and forestry resources impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

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

3.3-8
Yes NA NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Agriculture and Forestry Resource Impacts: Would the treatment result in other impacts to agriculture and forestry resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No
If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.2.1. Discussion

4.2.1.1. Impact AG-1
The proposed project would incorporate a variety of vegetation management strategies, including manual treatment and mechanical methods such as chipping and mowing. It would also utilize prescribed herbivory, controlled burning— both pile and broadcast —and targeted herbicide application. Biomass disposal would be carried out through techniques like lopping, scattering or broadcasting, off-site removal, and pile burning. The vegetation communities in the project area include coastal scrub, annual grasslands, blue oak woodland, and coastal oak woodland. There is no farmland within the project area. The PEIR found the potential loss of forest land from proposed treatments to be a less-than-significant impact, as activities aim to reduce wildfire risk and improve forest health without permanently converting land.

Potential impacts of the Project resulting in the conversion of forest land are within the scope of the PEIR as the treatment activities are consistent with those addressed in the PEIR. The creation of th e WUI fuel reduction zone and shaded fuel break would employ a treatment approach which generally follows guidelines for the removal of ladder fuels, invasive plants, understory vegetation, and hazard trees within the vegetation treatment types. The treatm ent approach would also retain tree canopy to the greatest extent feasible, including strategic removal, and retain live native vegetation. Post-treatment tree cover in woodlands and forests would meet the PRC 12220(g) definition of forest land —capable of supporting at least 10 percent native tree cover under natural conditions. The proposed project would not remove trees for commercial purposes and would not result in conversion of the dominant vegetation types. Therefore, the Project would not result in loss of forest land or conversion of forest land to non-forest use. This impact is within the scope of the PEIR because the treatment activities and intensity are consistent with those analyzed in the PEIR.

The inclusion of approximately 93 acres of land that are outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. Within the project area, existing conditions within forested land are essentially the same within and outside of the treatable landscape. Therefore, the impact to forested land is also t he same. No Prime Farmland, Unique Farmland, or Farmland of Statewide Importance is present within the project area (California Department of Conservation 2022); therefore, no conversion of farmland would occur. No SPRs are applicable to this impact. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.2.1.2. New Agriculture and Forestry Resource Impacts
Treatments included in the proposed project are consistent with the treatments and activities that are considered in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of

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the proposed p roject and determined that they are consistent with the environmental and regulatory settings stated in the CalVTP PEIR (V olume II, Sections 3.3.1 and 3.3.2). The project proponent has also determined that the inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances would lead to new significant impacts not addressed in the PEIR.

Therefore, no new impact related to agriculture and forestry resources that is not covered in the PEIR would occur.

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CalVTP Project-Specific Analysis and Addendum
Augustin Bernal Community Park Fuel Reduction
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4.3. Air Quality
Table 3. Consistency of project-related air quality impacts with the scope of the Cal ifornia Vegetation Treatment Program P rogrammatic Environmental Impact Report.

Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact AQ-1: Generate Emissions of
Criteria Air Pollutants and Precursors
During Treatment Activities that
would exceed California Ambient Air
Quality Standards (CAAQS) or
National Ambient Air Quality
Standards (NAAQS)
PSU
Table 3.4-1;
Impact AQ-1,
pp. 3.4-26–

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

3.4-34; App.

AQ-1
Yes
AQ-1, HAZ-
1, NOI-4,
NOI-5
NA LTS No Yes
Impact AQ-3: Expose People to
Fugitive Dust Emissions Containing
Naturally Occurring Asbestos (NOA)
and Related Health Risk
LTS
Section 3.4.2;
Impact AQ-3,
pp. 3.4-34–

3.4-35
No None NA No Impact No Yes
Impact AQ-4: Expose People to Toxic
Air Contaminants Emitted by
Prescribed Burns and Related Health
Risk
PSU
Section 3.4.2;
Impact AQ-4,
pp. 3.4-35–

3.4-37
Yes
AD-4, AQ-1,
AQ-2, AQ-3,
AQ-6
NA (no
feasible
mitigation
available)
SU No Yes

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Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact AQ-5: Expose People to
Objectionable Odors from Diesel
Exhaust
LTS
Impact AQ-5,
pp. 3.4-37–

3.4-38
Yes HAZ-1, NOI-
4, NOI-5 NA LTS No Yes
Impact AQ-6: Expose People to
Objectionable Odors from Smoke
During Prescribed Burning
PSU
Section 2.5.2;
Impact AQ-6;
pp. 3.4-38
Yes
AD-4, AQ-1,
AQ-2, AQ-3,
AQ-6
NA (no
feasible
mitigation
available)
SU No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

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

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4.3.1. Discussion

4.3.1.1. Impact AQ-1
The use of vehicles, mechanical equipment, prescribed herbivory, herbicides, and prescribed burning during initial and maintenance treatments would result in emissions of criteria pollutants that could exceed CAAQS or NAAQS thresholds for the San Francisco Bay Area Air Basin. The potential for emissions of criteria pollutants to exceed CAAQS or NAAQS thresholds was examined in the PEIR and was found to be potentially significant because treatment activities could generate pollutants —such as particulate matter, ozone precursors, or nitrogen oxides—in quantities that might surpass regulatory limits, especially in areas already designated as nonattainment for one or more pollutants . Emissions of criteria air pollutants related to the proposed treatment are within the scope of the PEIR because the associated equipment and duration of use are consistent with those analyzed in the PEIR.

The SPRs applicable to this treatment project are AD-1, AD-4, AQ-1 through AQ-4, and AQ-6, which require public notification for prescribed burning; compliance with applicable BAAD air quality requirements ; submittal of an SMP and Burn Plan if the prescribed burning triggers the threshold (17 CCR Section 80160); minimizing dust; and f ollowing all sa f e ty pr ocedur es r equir ed of a CAL FIR E cr e w . SPR A Q-5 would not apply because no NOA, ultramafic rock outcrops, or former asbestos mines are mapped in or near th e treatment area ( USGS 2011, 2017). Additionally, t he City would implement the emission reduction techniques included in MM AQ -1 to the extent feasible. However, because the treatments would be implemented by a public agency with limited funding, procuring or paying additional amounts for contractors that use equipment meeting the latest efficiency standards, including meeting USEPA’s Tier 4 emission standards, using renewable diesel fuel, using electric - and gasoline-powered equipment, and using equipment with Best Available Control Technology may be cost -prohibitive. Carpooling would be encouraged by the City, but because crews may not all be employed with the same company, carpooling may not be feasible to implement for most of the workers. The City would document the extent the agency and/or its contractors are able to implement MM AQ-1. Renewable diesel would be used by the City and/or its contractors to the extent required by state regulations. For these reasons, and as explained in the PEIR, this impact would remain significant and unavoidable. In addition to the CalVTP PEIR SPRs and MMs, additional project-specific measures are described below each applicable measure. • MM AQ -1: Implement On -Road Vehicle and Off -Road Equipment Exhaust Emission Reduction Techniques
The City would document the extent that it and/or its contractors are able to implement MM AQ -1 by documenting each unit’s certified engine tier specification and applicable CARB fleet regulation compliance certificates prior to mobilization. This information would be compiled in an annual monitoring

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compliance report for the Project. Renewable diesel would be used by the agency and/or its contractors to the extent required by state regulations.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the air quality conditions present and air basin in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described above. This determ ination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what w as covered in the PEIR.

4.3.1.2. Impact AQ-2
The use of vehicles and mechanical equipment during initial and maintenance treatments could expose people to diesel particulate matter emissions. The potential to expose people to diesel particulate matter emissions was examined in the PEIR and found to b e less than significant because the activities would comply with air quality regulations, use modern equipment with emission controls, and limit exposure through operational safeguards and distance from sensitive receptors. Diesel particulate matter emissions from the proposed treatments are within the scope of the PEIR because the exposure potential is the same as analyzed in the PEIR, and the types and amount of equipment that would be used, as well as the duration of use during proposed treatments , are consistent with those analyzed in the PEIR. SPRs applicable to this treatment are AQ-1, HAZ-1, NOI-4, and NOI-5, which require complying with air quality regulations, maintaining equipment, locating staging areas away from sensitive receptors, and lim iting equipment idling time, respectively.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. The portions of the project area that lie outside the CalVTP treatable landscape are located within 0.25 miles of the treatable landscape. The inclusion of land outside of the treatable landscape does not affect the pace at which treatment activities move across sites as outlined in the PEIR, and, therefore, diesel p a r ti c u l a t e m a tt e r e m i s s i o n s w o u l d n o t o c c u r n e a r a n y o n e s e n s i ti v e r e c e p t o r f o r a p r o l o n g e d ti m e .

Additionally, air quality conditions and the presence of sensitive receptors within the broader project area are essentially the same as those inside or near the treatable landscape, resulting in comparable exposure potential and air quality impacts as previously described. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

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4.3.1.3. Impact AQ-3
This impact does not apply to the treatment project because no NOA, ultramafic rock outcrops, serpentine soils, or former asbestos mines are mapped in or near the treatment area , and no serpentine soils or serpentine outcrops were observed during biological reconnaissance surveys (USGS 2011, 2017; Sequoia 2025).

4.3.1.4. Impact AQ-4
Prescribed burning during initial and maintenance treatments could expose people to toxic air contaminants. The potential to expose people to toxic air contaminants from prescribed burning was examined in the PEIR and found to be potentially significant because such burns release smoke containing fine particulate matter and other harmful compounds that can affect respiratory and cardiovascular health, especially in areas near sensitive populations or regions already experiencing poor air quality. The duration and parameters of the prescribed burns are within the scope of the activities addressed in the PEIR, and within the BAAB, air quality conditions are consistent with those analyzed in the PEIR for Alameda County and Pleasanton. Therefore, the potential for exposure to toxic air contaminants is also within the scope of the PEIR. SPRs applicable to these treatment activities are AD -4, AQ-1, AQ-2, AQ-3, and AQ-6. All feasible measures to prevent and minimize smoke emissions, as well as exposure to smoke, are included in SPRs; however, this impact would remain significant and unavoidable, as explained in the PEIR.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the air quality conditions present and air basin in the areas outside the treatable landscape are essentially the same as those within the treatable landscape.

Therefore, the air quality impact is also the same, as described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.3.1.5. Impact AQ-5
The use of vehicles and mechanical equipment during initial and maintenance treatments could expose people to objectionable odors from diesel exhaust. The PEIR determined that the potential for exposing individuals to diesel exhaust odors is less than significant, as these odors are typically short-lived, confined to specific areas, and classified as nuisance pollutants rather than health risks. Addition ally, treatment activities are brief and spread out, reducing the likelihood of sustained exposure near sensitive locations.

This impact is within the scope of the PEIR because the exposure potential and the proposed activities, as well as the associated equipment and duration of use, are consistent with those analyzed in the PEIR. SPRs

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applicable to this treatment are HAZ-1, NOI-4, and NOI-5, which would require equipment maintenance, limiting vehicle idling time to 5 minutes, and notification of off-site sensitive receptors.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the air quality conditions and types of sensitive receptors present in the areas outside the treatable landscape are essentially the same as those within, or adjacent to, the treatable landscape; therefore, the air quality impact is also the s ame, as described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.3.1.6. Impact AQ-6
Prescribed burning during initial and maintenance treatments could expose people to objectionable odors.

The PEIR found the impact due to odors from prescribed burning to be potentially significant due to their intensity, duration, proximity to sensitive receptors, and likelihood of sustained exposure impacting nearby communities. The duration and parameters of the prescribed burn treatment and the exposure potential of the Project are consistent with the activities addressed in the PEIR. Therefore, the resultant potential for exposure to objectionable odors from smoke associated with the Project is also within the scope of impacts covered in the PEIR. SPRs that are applicable to this treatment project are AD-4, AQ-1, AQ-2, AQ- 3, and AQ-6. All feasible measures to prevent and minimize smoke odors, as well as exposure to smoke odors, are included in SPRs; however, this impact would remain significant and unavoidable, as explained in the PEIR.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the air quality conditions present and types of sensitive receptors in the areas outside the treatable landscape are essentially the same as those within, or adjacent to, the treatable landscape; therefore, the air quality impact is also the s ame, as described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.3.1.7. New Air Quality Impacts
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of the proposed treatments and determined they are consistent with the applicable regulatory and environmental conditions presented in the CalVTP PEIR (refer to Sections 3.4.1, Regulatory Setting, and 3.4.2, Environmental Setting, in Volume II of the Final PEIR). The inclusion of approximately 93 acres of land that is outside the CalVTP

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treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR, but the added acreage would not expand the total annual acreage of 250,000 acres per year proposed for treatment under the PEIR. Additionally, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to air quality that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape because they are immediately adjacent to each other, the air basin is the same, and the treatment activities and associated air emissions are the same. Therefore, the impacts are the same, and, for the reasons described above, impacts of the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impact not addressed in the PEIR. No new impact related to air quality that is not covered in the PEIR would occur.

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4.4. Archaeological, Historical, and Tribal Cultural Resources Table 4. Consistency of project-related archaeological, historical, and tribal cultural resources impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Environmental Impact Covered in the
PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact CUL-1: Cause a Substantial
Adverse Change in the Significance of
Built Historical Resources
LTS
Impact CUL-1,
pp. 3.5-14–3.5-
15 Yes CUL-1, CUL-
7, CUL-8 NA LTS No Yes
Impact CUL-2: Cause a Substantial
Adverse Change in the Significance of
Unique Archaeological Resources or
Subsurface Historical Resources
SU
Impact CUL-2,
pp. 3.5-15–3.5-
16 Yes
CUL-1, CUL-
2, CUL-3,
CUL-4, CUL-
5, CUL-8
CUL-2 LTSM No Yes
Impact CUL-3: Cause a Substantial
Adverse Change in the Significance of a
Tribal Cultural Resource
LTS Impact CUL-3,
p. 3.5-17 Yes
CUL-1, CUL-
2, CUL-3,
CUL-4, CUL-
5, CUL-6,
CUL-8
NA LTS No Yes
Impact CUL-4: Disturb Human Remains LTS Impact CUL-4,
p. 3.5-18 Yes NA NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Archaeological, Historical, and Tribal Cultural Resource Impacts: Would the treatment result in other impacts to archaeological, historical, and Tribal cultural resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below
and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.4.1. Discussion
A cultural resources assessment report has been prepared for the project area (Attachment B), which includes the treatment areas. The methods performed for this report included a background records search consistent with SPR CUL -1, notifications to local Native American representatives consistent with SPR CUL -2, cultural resource research consist e n t w i t h S P R C U L-3, and a stratified sampling- approach pedestrian survey of the project area consistent with SPR CUL -4. A record search was requested at the Northwest Information Center (NWIC) to determine whether any portions of the project area had been previously surveyed for cultural resources and identify the presence of any previously recorded cultural resources within the project area, as well as a 0.25-mile buffer (the search radius). The records search was received on March 27, 2025 (NWIC File No. 2 4-1367). Other sources of information that were reviewed included, but were not limited to, the current listings of properties on the National Register of Historic Places (NRHP), California Historical Landmarks, California Register of Historical Resources (CRHR), California Points of Historical Interest as listed in the Office of Historic Preservation’s Historic Property Directory, and the Built Environment Resource Directory for Alameda County (OHP 2025).

No resources have been previously recorded within the project area or search radius, and no CRHR - or NRHP-listed historical resources or properties have been recorded within the treatment area or the search radius. According to the record search results, the boundaries of 2 previous studies intersect the project area. Of the approximately 162 acres of land within the project area, about 152 acres have been previously surveyed for cultural resources.

A pedestrian survey was conducted on June 9, 2025 , by Montrose Environmental archaeologists. Due to the extensive steep topography in the project area, the survey strategy was stratified to take into account both slope and accessibility from a travel-cost perspective. Specifically, some portions of the project area that represented slopes of 10 percent or lower and were over 2 acres in area were subjected to more intensive survey techniques (transects of 20 meters or less). Not all areas that represent these flat slopes were surveyed due to their isolation within areas surrounded by steep hillsides. Other areas that represented slopes between 10 and 20 percent were surveyed, based on sensitivity and lack of isolation within steeper areas, using wider intervals of 20 to 40 meters. No other areas were subject to pedestrian survey due to the steepness of the slopes (greater than 20 percent) or, as mentioned above, because they were isolated within areas surrounded by steep mountainous areas where the travel costs on foot would minimize the potential for long-term habitation or settlement by prehistoric populations (Byrd et al. 2017).

A total of about 60 acres were subject to either intensive or cursory archaeological survey.

A hand trowel was used to remove vegetation in order to observe the ground surface throughout the surveyed areas. In addition, due to the heavy vegetation and grass cover that overlays the entire project area, two shovel test pits were dug in areas considered of higher sensitivity for archaeological resources

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in order to better observe the subsurface conditions and inspect for evidence of archaeological deposits.

No evidence of archaeological deposits was identified as the result of the survey.

Consistent with CalVTP SPR CUL -2, an updated Native American contact list and sacred lands file search was obtained from the NAHC. The sacred lands data file indicated no sacred sites had previously been recorded within the project area or adjacent land s. On July 2, 2025, letters were sent to each of the 27 Tribal contacts provided by the NAHC via email. T he letters requested information regarding Tribal resources and asked the T ribes to notify the City if they wished to initiate consultation regarding the project actions. To date, responses have been received from the Confederated Villages of Lisjan Nation, Tamien Nation, Wilton Rancheria, the Ohlone Indian Tribe, and the Costanoan Rumsen Carmel Tribe.

The Confederated Villages of Lisjan Nation responded on July 2, 2025, and requested consultation. The Tribe also requested specific information regarding proposed ground disturbance and the NWIC search results and cultural resources report for the Project. The Costanoan Rumsen Carmel Tribe responded on July 23, 2025, and stated that the Tribe would like to set up a consultation meeting to further discuss the Project. The Ohlone Indian Tribe responded on July 3, 2025, and requested the results of SPR CUL -2.

Tamien Nation responded on July 3, 2025, and stated that the Tribe will defer consultation to the Confederated Villages of Lisjan Nation. Wilton Rancheria responded on August 1, 2025, stating that the Tribe currently has no concerns regarding the Project and requesting to be notified if there are any changes or updates to the Project. As planning proceeds, the City will continue to consult with interested Tribal representatives regarding the Project and incorporate their concerns into project planning and mitigation as warranted.

4.4.1.1. Impact CUL-1
The potential for vegetation treatment activities, such as manual and mechanical treatments that cause ground disturbance, to cause adverse effects to historical resources (those resources evaluated as eligible for listing in the CRHR) was examined in the PEIR and found to be less than significant. According to the NWIC results, no historic -era built environment resources have been previously recorded within the project area. Additionally, the cultural pedestrian survey conducted for the Project did not ide ntify any historic-era built cultural resources. Any impact to potential historical resources, including, but not limited to, structures, buildings, or foundations, would be avoided, per SPR CUL-7, due to the lack of any proposed demolition or material alteration of a structure or building or overall setting. This potential impact is within the scope of the PEIR because the treatment activities and the intensity of ground disturbance that would occur under the proposed project are consistent with those anal yzed in the PEIR. SPRs applicable to this impact are CUL -1, CUL-7, and CUL -8. As described above, archaeological and historical resource record searches have been conducted per SPR CUL-1. SPR CUL-7 requires the avoidance of known built historical

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resources and the avoidance of built -environment structures that have not yet been evaluated for historical significance, and SPR CUL-8 requires worker training regarding protection of historical resources.

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

4.4.1.2. Impact CUL-2
Vegetation treatment activities will include mechanical treatments that use heavy equipment that could result in ground disturbance as vegetation is removed, which may result in adverse impacts to unknown historical resources (archaeological sites) or unique archaeological resources if present within a treatment area. According to the NWIC records search, no previously recorded resources are located within the project area. Consequently, no impact to previously recorded resources is expected to occur from t he program actions. However, subsurface components of unknown archaeological sites may exist within the areas of proposed activity.

The potential for treatment activities to result in disturbance to, damage to, or destruction of archaeological resources was examined in the PEIR and found to be significant but would be less than significant for the proposed project with implementation of SPRs and mitigation. This impact is within the scope of the PEIR because the treatment activities and the intensity of ground disturbance that would occur under the proposed project are consistent with those analyzed in the PEIR. SPRs applicable to this impact are CUL-1 through CUL-5 and CUL-8. As described above, methods consistent with SPR-1 through SPR-4 have been implemented for the purposes of this PSA. Further, SPR CUL -8 shall be implemented, which requires worker training regarding the protection of sensitive archaeological, historical, and Tribal cultural resources.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the treatment area, the potential for discovery of archaeological resources is essentially the same within and outside the treatable landscape; therefore, the potential impact to unique archaeological resources or subsurface historical resources is also the same, as described above. This impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

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4.4.1.3. Impact CUL-3
As previously summarized, Native American contacts identified by the NAHC were sent an invitation to consult via email on July 2, 2025, consistent with the requirements of SPR CUL-2. To date, responses have been received from the Confederated Villages of Lisjan Natio n, Tamien Nation, Wilton Rancheria, the Ohlone Indian Tribe, and the Costanoan Rumsen Carmel Tribe. The potential for treatment activities to cause a substantial adverse change in the significance of a Tribal cultural resource was examined in th e PEIR. Proposed treatment activities include manual and mechanical treatment activities that may require ground disturbance, as well as the use of herbicides, which may adversely affect ethnobotanicals or material culture that may have Tribal importance. The potential for the proposed treatment activities to cause a substantial adverse change in the significance of a Tribal cultural resource during vegetation treatment was examined in the PEIR and found to be less than significant with the implementation of SPR CUL-6. As planning proceeds, additional information provided by Tribes during the consultation process may identify the potential for a substantial adverse change to a Tribal cultural resource to result from project-related actions, and measures to protect the resource shall be formulated consistent with SPR CUL- 6, which, upon implementation, would avoid any substantial adverse change to any Tribal cultural resource. The potential for adverse effects on Tribal cultural resources during implementation of the proposed project is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of ground disturbance are consistent with those analyzed in the PEIR.

SPRs applicable to this treatment are CUL -1 through CUL -6 and CUL-8. SPRs CUL -1 through CUL -4 have been conducted during preparation of this PSA. SPR CUL -5 and CUL -6 require consulting with the geographically affiliated Tribes to avoid and protect any resources identified, and SPR CUL -8 requires worker training regarding the protection of sensitive archaeological, historical, and Tribal cultural resources.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the potential for tribal cultural resources present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the potential impact to Tribal cultural resources is also the same, as described above. This impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.4.1.4. Impact CUL-4
Vegetation treatment activities would include mechanical treatments that use heavy equipment that could result in ground disturbance as vegetation is removed, which could uncover human remains, if present in a treatment area. The potential for treatment activities to uncover human remains was examined in the

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PEIR and found to be less than significant. T h e N W I C r e c o r d s s e a r c h d i d n o t i d e n ti f y a n y p r e v i o u s l y recorded burials or sites that have the potential to contain human remains. This impact is within the scope of the PEIR because the intensity of ground disturbance under the proposed project is consistent with what was analyzed in the PEIR. Additionally, consistent with the PEIR, the proposed project would comply with California Health and Safety Code Sections 7050.5 and 7052 and PRC Section 5097 in the event of a discovery.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the potential for discovery of human remains present in the areas outside the treatable landscape is essentially the same as within the treatable landscape; therefore, the potential impact to human remains is also the same, as described above. This impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.4.1.5. New Archaeological, Historical, and Tribal Cultural Resource Impacts The proposed project treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project proponent has considered the site- specific characteristics of the proposed treatment Project and determined they are consistent with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Sections 3.5.1, Enviro nmental Setting , and 3.5.2, Regulatory Setting, in V olume II of the Final PEIR). The project proponent has also determined that the inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a changed circumstance to the geographic extent presented in the PEIR. However, within the boundary of the treatment area, the existing environmental and regulatory conditions pertinent to archaeological, built historical resources, or Tribal cultural resources that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new or more severe significant impacts. Therefore, no new impact related to archaeological, historical, or Tribal cultural resources would occur.

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4.5. Biological Resources
Table 5. Consistency of project-related biological resources impacts with the scope of the Cal ifornia Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact BIO-1: Substantially Affect
Special-Status Plant Species Either
Directly or through Habitat
Modifications
LTSM
Impact BIO-1,
pp. 3.6-131–

3.6.138
No
AD-2, AD-3,
AD-5, AQ-3,
AQ-4, BIO-
1, BIO-2,
BIO-3, BIO-
6, BIO-7,
BIO-9, GEO-
1, GEO-3,
GEO-4,
GEO-5,
GEO-7,
HAZ-5,
HAZ-6,
HYD-2,
HYD-5
BIO-1a,
BIO-1b,
BIO-2a,
BIO-2b,
BIO-3a,
BIO-4
LTS No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact BIO-2: Substantially Affect
Special-Status Wildlife Species Either
Directly or through Habitat
Modifications
LTSM
Impact BIO-2,
pp. 3.6-138–

3.6-184
Yes
AD-2, AD-3,
AD-5, AQ-4,
BIO-1, BIO-
2, BIO-3,
BIO-9, BIO-
10, BIO-11,
BIO-12,
GEO-1,
HAZ-5,
HAZ-6,
HYD-1,
HYD-2,
HYD-3,
HYD-4,
HYD-5
BIO-2a,
BIO-2b,
BIO-2e,
BIO-2g,
BIO-3a,
BIO-4, BIO-
5 SU: Crotch’s
and obscure
bumble-bee

PS: Alameda
whipsnake

LTSM for all
others
No Yes
Impact BIO-3: Substantially Affect
Riparian Habitat or Other Sensitive
Natural Community through Direct
Loss or Degradation that Leads to
Loss of Habitat Function
LTSM
Impact BIO-3,
pp. 3.6-186–

3.6-191
Yes
AD-2, AD-3,
AD-5, BIO-
1, BIO-2,
BIO-3, BIO-
6, BIO-9,
HYD-4
BIO-3a LTSM No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact BIO-4: Substantially Affect
State or Federally Protected
Wetlands
LTSM
Impact BIO-4,
pp. 3.6-191–

3.6-192
Yes
AD-2, AD-3,
AD-5, BIO-
1, BIO-9,
HAZ-5,
HAZ-6,
HAZ-7,
HYD-1,
HYD-2,
HYD-3,
HYD-4,
HYD-5,
HYD-6
BIO-4 LTSM No Yes
Impact BIO-5: Interfere Substantially
with Wildlife Movement Corridors or
Impede Use of Nurseries
LTSM
Impact BIO-5,
pp. 3.6-192–

3.6-196
Yes
AD-2, AD-3,
AD-5, BIO-
1, BIO-2,
BIO-3, BIO-
10, BIO-11,
HYD-4,
HYD-5
BIO-5 LTSM No Yes
Impact BIO-6: Substantially Reduce
Habitat or Abundance of Common
Wildlife
LTS
Impact BIO-6,
pp. 3.6-197–

3.6-198
Yes
AD-2, AD-3,
AD-5, BIO-
1, BIO-2,
BIO-3, BIO-
12 -- LTS No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact BIO-7: Conflict with Local
Policies or Ordinances Protecting
Biological Resources
No Impact
Impact BIO-7,
pp. 3.6-198–

3.6-199
Yes AD-3 -- No Impact No Yes
Impact BIO-8: Conflict with the
Provisions of an Adopted Natural
Community Conservation Plan,
Habitat Conservation Plan, or Other
Approved Habitat Plan
No Impact
Impact BIO-8,
pp. 3.6-199–

3.6-200
No -- -- -- -- --
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact. None: There are SPRs and/or MMs identified in the PEIR for this impact, but none are applicable to the treatment project.

New Biological Resources Impacts: Would the treatment result in other impacts to biological resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.5.1. Discussion

4.5.1.1. Impact BIO-1
The Project proposes manual and mechanical vegetation removal, prescribed burning, pile burning, prescribed herbivory, and targeted herbicide application. These treatment activities could result in direct or indirect adverse effects to special-status plant species. Mechanical treatment and herbicide application have potential to impact special-status species directly or indirectly if not strategically applied; however, strategic removal of understory vegetation and invasive species would promote the regeneration of native species that support a healthier residual forest. The Project is designed to reduce the risk of catastrophic stand-replace wildfires, which would threaten known sensitive plant populations.

The potential for adverse effects to special -status plant species is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment activities are consistent with those analyzed in the PEIR. Impacts to special-status plants would be reduced to less than significant through following certain SPRs and MMs (Attachment A).

In addition to the CalVTP PEIR SPRs and MMs, additional project-specific measures are described below each applicable measure.

No special-status plant species have moderate to high potential to occur on the project site. The potential for adverse effects to special -status plant species is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment activ ities are consistent with those analyzed in the CalVTP PEIR. Impacts to special-status plants would be reduced to less than significant with the following SPRs and MMs.

Additional project-specific measures are described below each applicable measure. • SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR AQ-3: Create Burn Plan
o No fire ignition (nor use of associated accelerants) would occur within 50 feet of listed plants
• SPR AQ-4: Minimize Dust
• SPR BIO -1: Review and Survey Project -Specific Biological Resources and Determine whether Avoidance Is Possible
• SPR BIO-2: Require Biological Resource Training for Workers • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats and Map Locations o If any rare plant populations are found, the location, quantity, and description would be reported to the California Natural Diversity Database
o Any in-field methods of identification that would require handling would follow proper permitting and protocols

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• SPR BIO-6: Prevent Spread of Plant Pathogens
o To contain the spread of P . ramorum, crews would minimize the movement of soil and leaf litter under and around infected trees , and boots, treads, and equipment such as saws, shovels, hoes, and other tools would be scrubbed free of soil and debris that come from infected sites
o All reasonable methods to sanitize shoes and equipment would be used in areas with susceptible species, both before and after work in those areas ; these methods would follow best practices, which would include disinfecting material with 10 percent bleach, Lysol, or 70 percent isopropyl alcohol after the surface has been scrubbed free of debris with bristle brushes, or other BMPs
o Any material suspected of being infected would stay in the area, as close to the origin point as possible
o Generally, removal of P . ramorum-infected or killed oak trees would only be necessary if the tree is considered hazardous in a park setting
 When infected oaks are cut down and left on-site, the branches would be chipped and cut and split, if possible, to reduce fire hazard and facilitate decomposition; if chipping is not possible, material would be lopped and scattered downslope and away from host species to reduce fire hazard and further spread  When it is not feasible to leave debris on-site, infested material would be disposed of at an approved and permitted dump facility
• SPR BIO-7: Survey for Special-Status Plants
• SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife o Treatment of invasive plants and noxious weeds would follow the guidelines provided by Cal-IPC and other current scientifically based methods
o When working in areas with broom, starthistle, or other invasive plants, crews would ensure equipment is cleaned of all soil, mud, and debris before departing the site o Whenever possible, crews and equipment would remain on paved, rocked, and well - traveled trails and would avoid cross-country travel
o Mud, soil, and organic debris would be removed from equipment, treads, and boots before moving between work sites, with removed soil being left at its original location • SPR GEO-1: Suspend Disturbance during Heavy Precipitation • SPR GEO-3: Stabilize Disturbed Soil Areas
• SPR GEO-4: Erosion Monitoring
• SPR GEO-5: Drain Stormwater via Water Breaks
• SPR GEO-7: Minimize Erosion
o Whenever feasible, heavy equipment would remain on a stable operating surface to prevent erosion
 Heavy equipment would not occur on slopes of 50 percent or greater • SPR HAZ-5: Spill Prevention and Response Plan
o Herbicide application would not occur within protective buffers for special -status plants to prevent drift and non-target application
• SPR HAZ-6: Comply with Herbicide Application Regulations • SPR HYD-2: Avoid Construction of New Roads
• SPR HYD-5: Protect Non-target Vegetation and Special-Status Species from Herbicides

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Even with implementation of the above SPRs, impacts could be potentially significant per the CalVTP PEIR.

MMs BIO-1a and BIO-1b would be required when the following conditions are met:
• Where sensitive species are known to occur
• When treatments cannot be completed in the dormant season, or the species are persistent year- round due to its lifecycle (woody or non-dormant)
• When treatments would be implemented during the growing period of sensitive annual and geophyte species
• Where protocol-level surveys are required (per SPR BIO-7) and special-status plants are identified during these surveys
Following implementation of MMs BIO -1a and BIO -1b, special-status plants identified during protocol - level surveys would be given a no -disturbance buffer of 50 feet , within which vegetation treatment activities would not occur unless a qualified RPF or biologist determines that the species would benefit from treatment in the occupied habitat area. The size and shape of the generally 50-foot buffer would be adjusted if a qualified RPF or biologist determines that a smaller or larger buffer would be sufficient to avoid impacts on listed plants. Additionally, all state- and federally protected wetlands would be avoided (MM BIO-4) by a standard buffer of 25 feet and would be adjusted if slopes or other conditions warrant an increased buffer. Mitigation of the 15 special-status plant species with potential to occur is considered based on persistence of detection throughout their lifecycle. • MM BIO-1a: Avoid Loss of Special-Status Plants Listed under Federal Endangered Species Act (ESA) or California Endangered Species Act (CESA)
• MM BIO-1b: Avoid Loss of Special-Status Plants Not Listed under ESA or CESA • MM BIO -2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed Wildlife Species and California Fully Protected Species (All Treatment Activities) • MM BIO -2b: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Other Special-Status Wildlife Species (All Treatment Activities) • MM BIO -3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands
• MM BIO-4: Avoid State- and Federally Protected Wetlands Impacts to Sensitive Natural Communities
To avoid impacts on sensitive natural communities, focused botanical surveys would be performed (MM BIO-1a and MM BIO-1b). If identified, sensitive natural communities would be recorded using a GPS device and mapped. No project-related ground disturbance would occur within 50 feet of these sensitive natural communities (MM BIO-3a).

With implementation of all SPRs and MMs listed above, including survey protocols and preoperational meetings, impacts to special-status plant species would be reduced to less than significant.

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4.5.1.2. Impact BIO-2
Manual and mechanical vegetation removal, broadcast and pile burning, targeted herbicide application, and prescribed herbivory have the potential to result in direct or indirect adverse effects to special-status wildlife species or habitat. Manual and mechanical treatments, herbivory, prescribed broadcast burn, and targeted herbicide application would reduce understory vegetation that may modify preferred habitats for some species and have the potential to promote a healthier native habitat.

The potential for adverse effects to eight special-status wildlife species is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment activities are consistent with those analyzed in the PEIR. With the exception of two species (Crotch’s bumble bee [Bombus crotchii] and monarch butterfly [Danaus plexippus plexippus pop. 1]), impacts to special-status wildlife would be reduced to less than significant with the following SPRs and MMs. Additional project-specific measures are described, as appropriate, with each applicable CalVTP SPR or MM within the species-focused discussion.
• SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR AQ-3: Create Burn Plan
o No fire ignition (nor use of associated accelerants) would occur within 50 feet of listed plants, riparian habitat, or aquatic features, or any identified sensitive species or habitat o Within suitable winter retreats for Alameda whipsnake , prescribed burning would not occur between approximately November 1 and March 31 (as determined by a qualified biologist based on temperature and weather conditions)
o Within suitable Alameda whipsnake habitat, prescribed burning and pile burning would be restricted to when temperatures are conducive to Alameda whipsnake movement, which is typically when soil surface temperatures reach 66 °F (19 °C ; Hammerson 1979); alternatively, piles left in place for more than a day would be investigated for Alameda whipsnake through dismantling and rebuilding piles prior to pile burning • SPR AQ-4: Minimize Dust
• SPR BIO -1: Review and Survey Project -Specific Biological Resources and Determine Whether Avoidance Is Possible
• SPR BIO-2: Require Biological Resource Training for Workers • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats and Map Locations • SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife • SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites • SPR BIO-11: Install Wildlife-Friendly Fencing during Prescribed Herbivory • SPR BIO-12: Protect Common Nesting Birds, Including Raptors o Use of Avoidance Buffers
o Treatment Modification, or Treatment Delay
o Monitor Active Raptor Nest during Treatment
o Retain Raptor Nest Trees

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• SPR GEO-1: Suspend Disturbance during Heavy Precipitation • SPR HAZ-5: Spill Prevention and Response Plan
• SPR HAZ-6: Comply with Herbicide Application Regulations • SPR HYD-1: Comply with Water Quality Regulations
• SPR HYD-2: Avoid Construction of New Roads
• SPR HYD-3: Water Quality Protections for Prescribed Herbivory • SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones • SPR HYD-5: Protect Non-target Vegetation and Special-Status Species from Herbicides Even with implementation of the above SPRs, impacts could be potentially significant per the CalVTP PEIR.

Implementation will follow additional MMs BIO-2a, BIO-2b, BIO-2e, BIO-2g, BIO-4, and BIO-5, and species- specific measures, as described below.
• MM BIO -2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed Wildlife Species and California Fully Protected Species • MM BIO -2b: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Other Special-Status Wildlife Species
• MM BIO-2e: Design Treatment to Retain Special-Status Butterfly Host Plants—Monarch Butterfly • MM BIO -2g: Design Treatment to Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Special-Status Bumble Bees
• MM BIO -3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands
• MM BIO-4: Avoid State and Federally Protected Wetlands • MM BIO-5: Retain Nursery Habitat and Implement Buffers to Avoid Nursery Site Impacts to Crotch’s Bumble Bee
Direct and indirect impacts could occur to Crotch ’s bumble bee through off -road machinery, prescribed burning, herbicide use, and removal of flowering plants. Primary threats to the survival of special- status bumble bees include habitat loss or modification due to development, agriculture, high-intensity fire, fire suppression, and herbicide use (Xerces Society et al. 2018). Because little is known about the life history and behaviors of bumble bees and there is no established methodology for detecting over wintering or nesting colonies, they can be difficult to detect and therefore to completely avoid during treatment activities. If colonies were destroyed, it is possible that populations of these species would be reduced below self-sustaining levels, and treatment activities could substantially reduce the number or restrict the range of species.

The Project does not impact chaparral or coastal sage scrub, is designed to avoid riparian habitat, and no new roads will be created (SPR HYD -2). These factors should limit ground disturbance that may impact nests. Pre-treatment surveys would combine a focused survey (SPR BIO -1 , S P R B I O-3, SPR BIO- 10) to identify burrows and suitable habitat within the project site. Survey and monitoring protocols will be referenced per CDFW guidelines (CDFW 2023a and 2023b). In lieu of or in addition to surveys, the project

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proponent may choose to assume presence and rely on habitat as an indicator of presence. Crew members and contractors would be trained to identify and avoid this species if encountered (SPR BIO -2), and a biologist would be available as needed to provide gu idance when crews are working within suitable bumble bee habitat. If work occurs within occupied bumble bee habitat, MM BIO -2b requires flagging areas for avoidance and establishing no-work buffers. MM BIO-2b also states: “A qualified RPF, biologist, or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment.” If identified, these burrows would be protected with an avoidance buffer (SPR AD-2). A Spill Prevention and Response Plan (SPR HAZ-5) will be developed as part of p roject implementation, and the project proponent will comply with herbicide application regulations (SPR HAZ-6) and restrict use of herbicide to avoid native plants.

The objectives of the CalVTP treatment activities are to reduce the occurrence of high -intensity wildfire and to modify past practices of fire suppression. Project implementation could thus be beneficial to bumble bees by reducing high-intensity wildfire and improving habitat for bumble bee species; however, in the process of achieving this objective, there are potentially significant direct impacts to bumble bees.

The CalVTP PEIR acknowledges the difficulty in detecting overwintering and nesting bumble bee s and in determining the occurrence and severity of impacts; it concludes that implementation of the CalVTP could cause impacts to special- status bumble bees which are potentially significant and unavoidable. The proposed project impacts are consistent with those described in the CalVTP PEIR, and the proposed treatment activities may result in impacts to Crotch ’s bumble bee that are potentially significant and unavoidable.

Impacts to Monarch Butterfly
Direct and indirect impacts could occur to monarch butterfly through removal of flowering plants providing nectar, removal of native milkweed (Asclepias) stands for larval development, removal of overwintering habitat, and collisions with project vehicles.

Pre-treatment surveys would be combined with a focused survey (SPR BIO -1 , S P R B I O-3, SPR BIO- 10) within suitable monarch butterfly larval and overwintering habitat. Crew members and contractors would be trained to identify and avoid milkweed and monarch butterfly if encountered (SPR BIO -2), and a qualified RPF or biologist would be available to provide guidance as needed. If identified, larval or overwintering monarchs would be protected with an appropriate avoidance buffer (SPR AD -2). A Spill Prevention and Response Plan (SPR HAZ -5) would be developed as part of project implementation, and the project proponent would comply with herbicide application regulations (SPR HAZ -6) and restrict use of herbicide to avoid native plants.

Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, the implementation of MM s BIO-2a, BIO -2b, BIO -2e, and BIO -3a would be implemented, including

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targeting removal of invasive vegetation, protecting native milkweed, protecting overwintering sites, and restricting prescribed burning activities in suitable monarch habitat when the species is observed to avoid direct impacts to individuals. If monarch butterfly, monarch larvae host plants (e.g., Asclepias californica, A. fascicularis, A. speciosa), or overwintering roost trees are identified during focused surveys (conducted pursuant to SPR BIO-10), or the species is assumed to be present in lieu of conducting surveys, the project proponent would avoid or minimize adverse effects on the species by avoiding treatment activities in suitable monarch habitat during overwintering or larval periods . If monarch overwintering groups or larvae are detected, a buffer determined appropriate by a qualified RPF or biologist would be established.

The project proponent would flag avoidance buffers, within which no treatment activities would occur, a qualified biologist or RPF would be available to provide guidance as needed, and /or other measures recommended by CDFW would be followed as necessary to avoid injury to or mortality of these species or impacts to the population. If work occurs within occupied monarch habitat, MM BIO-2b requires flagging areas for avoidance and establishing no-work buffers. MM BIO-2b also states: “A qualified RPF, biologist, or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment.” Bec ause the Project proposes to remove invasive species through various treatments, the results of project implementation may improve habitat quality for monarch butterfly. With these additional focused MMs, impacts to monarch butterfly would be reduced to less than significant. This impact is consistent with the CalVTP PEIR.

Impacts to Alameda Whipsnake
Direct impacts to Alameda whipsnake could occur through crushing the animals with vehicles, collapsing occupied burrows, or burning occupied piles. Indirect impacts could occur from habitat type conversion of scrub and chaparral. Within Alameda whipsnake h abitat, treatment methods would primarily include manual methods, and in adjacent habitat, grazing and prescribed burning. Mechanical equipment would not be operated within suitable Alameda whipsnake habitat.

The Project does not impact chaparral or coastal sage scrub and is designed to avoid creation of new roads (SPR HYD-2). SPR GEO-1 would suspend treatment activities during heavy precipitation until soils are no longer saturated, reduce the potential for project activities to disturb ground -supporting burrows, and reduce the potential for impacts to this species. Within suitable Alameda whipsnake habitat, pre - treatment surveys would be combined with a focused survey (SPR BIO -1, SPR BIO- 3, SPR BIO- 10) to identify individuals and burrow sites within the project footprint. Crew members and contractors would be trained to identify individuals and burrows (SPR BIO-2), and a biological monitor would be present on- site within Alameda whipsnake habitat to provide guidance as needed. If individuals are encountered, they would be protected with an appropriate avoidance buffer (SPR AD-2) and would be allowed to le ave the work area of their own volition. To protect habitat, a Spill Prevention and Response Plan (SPR HAZ-5) would

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be developed as part of project implementation. The project proponent would follow herbicide application regulations (SPR HAZ-6).

Even following the above SPRs, project impacts could still be considered potentially significant. Measures that ensure full avoidance of Alameda whipsnake take would be implemented at all project areas.

Therefore, implementation of the following Alameda whipsnake avoidance and minimization strategy would be utilized, which is consistent with CalVTP MMs: BIO-2a, BIO-2b, and BIO-5.

Treatment will either avoid occupied habitat or be implemented in such a way that it does not disturb Alameda whipsnake. If work occurs within occupied habitat , MM BIO -2b requires flagging areas for avoidance and establishing no -work buffers. MM BIO -2b also states: “A qualified RPF, biologist, or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment.” Implementing treatment activities within suitable Alameda whipsnake habitat would require focused surveys to determine presence of Alameda whipsnake each day prior to work at each new area. If crews are working within suitable Alameda whipsnake habitat, a qualified RPF or biologist would conduct ongoing focused pre -treatment surveys during treatment activities, adhering to methodologies recommended in Miller and Alvarez (2016). Within highly suitable habitat, surveys would be repeated in treatment areas immediately prior to vegetation removal to ensure that the species is not present prior to the start of work in each scrub area. A qualified RPF or biologist would check suitable refugia within the work area, including vegetation and rock piles.

When dense vegetation within suitable Alameda whipsnake habitat inhibits visual survey effectiveness, the biologist would work closely with the crew to intermittently cut a small amount of brush to allow surveys of small areas. Active surveys would be performed thr oughout the vegetation removal activity within suitable Alameda whipsnake habitat, and if work ceases for more than 1 hour, the area would be re-surveyed prior to restarting work . During this survey effort, the qualified RPF or biologist would also advise the crew on avoidance of on-site potential refugia, such as burrows and rock piles.

The nature of shaded fuel break work would not change habitat function for Alameda whipsnake dispersal, foraging, and core scrub habitat. Alameda whipsnake core scrub habitat is described as shrub communities with a mosaic of open and closed canopy patches. USFWS defines scrub as coastal scrub, coyote brush scrub, or maritime chaparral areas (or “scrub”) greater than 0.5 acres in size, or scrub areas above 0.2 acres in size that are within 50 feet of scrub patches greater than 0.5 acres in size (USFWS 2006) . When work is occurring within core scrub habitat areas, the crew would work closely with the biologist to selectively remove scrub in a way that retains these dimensions and, therefore, retains the overall habitat function while still serving the needs of the shaded fuel break. This technique has been used on previous projects and aims to provide a “scrub mosaic” that retains Alameda whipsnake habitat function. Scrub mosaic recommendations may vary depending on site conditions.

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In addition to pre - and during- treatment surveys and monitoring, the following avoidance and minimization strategies will be employed:
• Prior to vegetation clearing activities within suitable Alameda whipsnake habitat, coverboards would be installed in key areas as determined by an RFP or qualified biologist o The coverboards would be strategically placed to provide refuge for the Alameda whipsnake leaving the work area
o Coverboards would be inspected at the end of each workday , and wildlife using them would be recorded
• Prior to operating stationary vehicles and equipment, all contractors, their employees, and agency personnel would check under and near vehicles/equipment for the presence of Alameda whipsnake and any wildlife that may have moved there
o If Alameda whipsnake or any wildlife are discovered, the qualified biologist would be contacted immediately; the qualified biologist shall have the authority to halt Project activities until the animal leaves the area of its own accord, and shall contact USFWS, as necessary, to determine necessary steps
o Manual removal of the species is not anticipated during vegetation treatment activities, but permitted biologists with applicable CDFW SCPs and/or USFWS 10(a)(1)(A) permits would be on-call during project activities
• Within suitable Alameda whipsnake habitat, mechanical treatment and prescribed burning would be avoided when temperatures are determined by the qualified biologist to be too low for Alameda whipsnake movement (soil surface temperatures reach 66 °F [19 °C; Hammerson 1979]) o Manual treatments may occur in cooler conditions after the qualified biologist has thoroughly surveyed the area
• In habitat suitable for Alameda whipsnake winter retreats, as determined by a qualified biologist, prescribed broadcast burning can occur between November 1 and March 31 and typically when soil surface temperatures reach 66 °F (19 °C; Hammerson 1979), or as determined by a qualified biologist
• Contractors would immediately (i.e., the same day) process (i.e., remove completely from the treatment area, chip, permanently place within the treatment area for soil stabilization) all cut materials as they are produced to avoid attracting Alameda whipsnake to the vegetation piles; if processing within the same day is not feasible, the RPF or qualified biologist would advise crews on a suitable location for temporary storage of cut materials that cannot be processed immediately, or the materials would be deconstructed and investigated prior to processing under the advisory of the qualified RPF or biologist, and c hipped materials would not be spread on suitable refugia for Alameda whipsnake, such as rodent burrows or rocky outcrops o The following measures apply when work occurs in suitable Alameda whipsnake habitat:
 During any season, vegetation piles for burning would either be burned the same day, or the pile would be deconstructed and investigated prior to burning  Placement of piles for burning would avoid suitable refugia for Alameda whipsnake, including large rodent burrows and rocky outcrops  Fires would be lit from one end of the pile (typically the uphill side on slopes) to allow Alameda whipsnake to escape, rather than lighting the whole pile at once CalVTP MM BIO-2a requires habitat function to be maintained for Alameda whipsnake. Suitable Alameda whipsnake habitat is described in the USFWS Critical Habitat Designation (USFWS 2006) as comprising

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three habitat types: core scrub, dispersal/foraging habitat, and rocky outcrop habitat. Dispersal and foraging habitat include woodland or annual grassland contiguous to core scrub habitat. The nature of the project activities would not change the habitat function of dispersal and foraging habitat because large oak woodland trees would be retained, and scrub and grassland habitat would not be heavily targeted for treatment.

Core scrub habitat is described as shrub communities with a mosaic of open and closed canopy patches.

USFWS defines scrub as coastal scrub, coyote brush scrub, or maritime chaparral areas (or “scrub”) greater than 0.5 acres in size, or scrub areas greater than 0.2 acres in size that are within 50 feet of scrub patches greater than 0.5 acres in size (USFWS 2006). When work is occurring within core scrub habitat areas, the c r e w w o u l d w o r k c l o s e l y w i t h t h e b i o l o g i s t t o s e l e c ti v e l y r e m o v e s c r u b i n a w a y t h a t r etains these dimensions and, therefore, retains the overall habitat function while still serving the needs of the shaded fuel break. This technique has been used on previous projects and aims to provide a “scrub mosaic” that retains Alameda whipsnake habitat function. Scrub mosaic recommendations may vary depending on site conditions. The following techniques would be implemented during treatment:
• Vegetation removal would occur in irregular, oblong shapes to maintain a natural condition • Vegetation removal would avoid rocky outcrops
• The overall dominant habitat type would not be converted • Vegetation removal would focus on dead, woody vegetation, and invasive plants Preliminary and post -treatment surveys that would assess the condition and acreage of Alameda whipsnake core scrub habitat would be conducted. Post-treatment conditions would be assessed to ensure that there is no overall loss of habitat function within Alameda whipsnake core scrub. It should be noted that scrub is a transitional habitat type and, over time, canopy in these areas grows taller and denser, and larger tree species such as oak and madrone are naturally recruited and become increasingly dominant.

Without any intervention, over a long period of time, scrub communities would naturally convert to woodland and forested habitat. Thoughtful treatment of select areas that incorporates retention of scrub islands suitable for Alameda whipsnake core scrub is expected to be more effective in retaining key core scrub habitat for Alameda whipsnake than complete inaction in these areas. This is consistent with Alameda whipsnake habitat protections described in CalVTP MM BIO-2b.

The following additional measures apply within suitable Alameda whipsnake habitat:
• All contractors, their employees, and agency personnel involved in the implementation of the Project would check for the presence of sensitive wildlife under or next to stationary vehicles prior to operating their vehicles
o If an Alameda whipsnake or any wildlife is found, the qualified RPF or biologist would determine necessary steps to avoid impact
• Pile burning treatment would avoid potential refugia for Alameda whipsnake

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• Within suitable habitat, heavy equipment, including mowing equipment which may collapse burrows, would be utilized exclusively from stable operating surfaces , such as established roads and trails
With these additional focused MMs, impacts to Alameda whipsnake would be reduced to less than significant. This impact is consistent with the CalVTP PEIR.

Impacts to Special -Status Avian Species (White- Tailed Kite and Yellow Warbler) and Nesting Birds
Direct impacts to special-status avian species could occur if nest trees, snags, or shrubs are removed, or if ground nests are destroyed through mechanical or prescribed herbivory treatments. Indirect impacts include disturbance of active nests within a zo ne of influence of project activities, depending on the equipment to be used, anticipated amount of time for construction at a given location, sensitivity to disturbance of any nesting birds present, and other factors. Limbing-up of nest trees or trees adjacent to nest trees could disturb nesting activity. Removal of vegetative cover could indirectly impact nesting birds by reducing cover protecting bird nests or prey species.

The Project does not impact chaparral or coastal sage scrub, is designed to avoid riparian habitat and no new roads would be created (SPR HYD -2). Trees greater than approximately 6 inches DBH would be retained unless they pose a fire hazard , as determined by the project proponent. SPR GEO -1 would suspend treatment activities during heavy precipitation until soils are no longer saturated, reduce the potential for project activities to disturb ground-supporting burrows for prey species such as rabbits and small mammals, and reduce the potential for indirect impacts to these species. During prescribed herbivory activities, wildlife -friendly fencing would be installed to allow perching by avian species and prevent electrocution (SPR BIO -11). Pre-treatment surveys would be combined with a focused nesting survey during nesting season (SPR BIO-1, SPR BIO-3, SPR BIO-10) to identify avian nests within the project footprint and species -specific buffers. Crew members and contractors would be trained to identify and avoid special-status avian nests if encountered (SPR BIO -2), and a qualified RPF or biologist would be available to provide guidance as needed. If identified, active nests (e.g., eggs, nestlings, parental attendance) would be protected with an avoidance buffer (SPR AD-2).

Even following the above SPRs, project impacts to special- status avian species could still be considered potentially significant. Therefore, MMs BIO -2a, BIO -2b, and BIO -4 would be implemented, including avoidance of sensitive habitats, retention of habitat function, prevention of habitat type conversion, and restriction of treatment activities to the non -nesting season as feasible for project objectives to avoid impacts to nest success (as applicable), nests, and prey base. If active bird nests are detected during focused surveys, a no -disturbance buffer would be established based on species and life stage, and no

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treatment activities would occur within this buffer until the chicks have fledged or the nest is otherwise no longer active, or as determined by a qualified RPF or biologist.

If it is infeasible to avoid vegetation treatment within nesting season, only manual treatment would be permitted, and an RPF or biological monitor would be available during treatment activities. If work occurs within the vicinity of an active nest, MM BIO-2b requires flagging areas for avoidance and establishing no- work buffers. MM BIO-2b also states: “A qualified RPF, biologist, or biological technician will be required to monitor the effectiveness of the no -disturbance buffer around the nest, den, burrow , or other occurrence during treatment.” A biological monitor would be present on -site during work within the vicinity of raptor, eagle, or special-status bird nests. No trees containing raptor nests would be removed.

Additionally, trees containing golden eagle nests would not be removed pursuant to the Bald and Golden Eagle Protection Act.

With these additional focused MMs, impacts to special-status avian species would be reduced to less than significant. This impact is consistent with the CalVTP PEIR.

Impacts to Nesting Birds Protected by the Migratory Bird Treaty Act Project treatment activities could result in direct loss of active nests through crushing or destroying nests or nest vegetation or by force-fledging nestlings before completion of the nestling period. Indirect impacts could include loss of habitat for nes ting and resources for foraging. Indirect impacts could also include disturbance to active nests from auditory and visual stimuli (e.g., heavy equipment, chain saws, vehicles, personnel), potentially resulting in abandonment and loss of eggs or chicks. Ind irect impacts to nesting birds could occur by drawing the attention of visual predators through the removal of vegetative cover around a nest which had previously hidden the nest from predators and provided ample cover for parents to sneak on and off active nests and the removal of food base (seeds, insects, fruit, rodents, etc.).

The Project does not impact chaparral or coastal sage scrub, is designed to avoid riparian habitat, and no new roads would be created (SPR HYD-2). Crew members and contractors would be trained to identify and avoid raptor nests if encountered (SPR BIO -2), and a n RPF or biological monitor would be on -site to monitor active raptor nests during project implementation. A Spill Prevention and Response Plan (SPR HAZ-5) would be developed as part of project implementation, and the project proponent would comply with herbicide application regulations (SPR HAZ-6) and restrict use of herbicide to avoid native plants. SPR GEO-1 would suspend treatment activities during heavy precipitation until soils are no longer saturated, reduce the potential for project activities to disturb ground-supporting burrows for prey species such as insects and small mammals, and reduce the potential for indirect impacts to these species. During prescribed herbivory activities, wildlife -friendly fencing that would allow pe rching by avian species and prevent electrocution would be installed (SPR BIO-11).

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Adverse effects on nesting birds can be avoided by conducting initial treatments between September 1 and January 31, outside of the nesting bird season (February 1 to August 31). Pre-treatment surveys would be combined with a focused nesting survey during nesting season (SPR BIO-10) to identify nests within the project footprint and establish at minimum a 50 -foot buffer, performed by qualified RPF or biologist.

Nesting bird surveys would occur no more than 7 days prior to work to ensure that no nests would be disturbed during treatment activities. If work pauses for more than 7 days, a follow -up survey would be conducted by a qualified RPF or biologist prior to the restarting of work. Appropriate survey areas would be determined by the qualified RPF or biologist depending on the p roject footprint, type of activity proposed, and suitable habitat for nesting birds. Surveys would be conducted during periods of high bird activity (i.e., 1–3 hours after sunrise and 1–3 hours before sunset) and under suitable weather conditions for detecting nesting birds. If the RPF or qualified biologist determines that visibility is significantly obstructed due to on-site conditions (e.g., access issues, rain, fog, smoke, or sound disturbance [including high wind]), surveys would be deferred until conditions are suitable for nest detection. Should the biologist encounter an active nest of a migratory bird species, the biologist would establish an avoidance buffer of at least 50 feet (SPR AD-2) until the nest is fledged or deemed inactive. If it is infeasible to avoid vegetation treatment within nesting season, only manual treatment would be permitted, and the project proponent would work closely with a n RPF or biological monitor, which is consistent with SPR BIO -12. A biological monitor would be present on-site for work within the vicinity of raptor or eagle nests. No trees containing raptor nests would be removed.

Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, MMs BIO-2a, BIO-2b, BIO-3a, and BIO-4 would be implemented, including avoidance of protected aquatic features, targeted removal of non-native vegetation, strategic native vegetation removal to retain habitat function and prevent type conversion, and restriction of treatment activities to the non-nesting season if feasible to avoid impacts to nest success. If it is infeasible to avoid vegetation treatment within the nesting season, only manual treatment would be permitted and an RPF or biological monitor would be available during treatment activities. If work occurs within the vicinity of an active nest, MM BIO -2b requires flagging areas for avoidance and establishing no -work buffers. MM BIO -2b also states: “A qualified RPF , biologist, or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment.” A biological monitor would be present on -site during work within the vicinity of raptor, eagle, or special- status bird nests. No trees containing raptor nests would be removed. Additionally, trees containing golden eagle nests would not be removed pursuant to the Bald and Golden Eagle Protection Act.

With these additional focused MMs, impacts to nesting birds would be reduced to less than significant.

This impact is consistent with the CalVTP PEIR.

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Impacts to Special-Status Bats: Pallid Bat and Townsend’s Big-Eared Bat Depending on the species present, the size of the roost, the type of roost (e.g., maternity, day, night, hibernation), and the season when tree removal would occur, the removal of trees and limbs could affect bats through removal of the roost and injury to bats. Tree removal activities could impact colonial bat species, which select a variety of trees and roost features, including cavities, crevices, and deep fissures in the wood or bark of trees and/or exfoliating bark. Indirect impacts to special- status b ats include introduction of white-nose syndrome, modification or loss of roosting or foraging habitat, and disturbance to maternity roosts. Loud mechanical equipment used within the shaded fuel break could impact bat species roosting in buildings or structures in the area. Smoke from pile burning could also impact roosting bats by disturbing them during sleep, breeding, or hibernation.

The Project does not impact chaparral or coastal sage scrub and is designed to avoid riparian habitat. Crew members and contractors would be trained to identify and avoid bat roosts if encountered (SPR BIO-2). If identified, active maternity or night roosts would be protected with an avoidance buffer (SPR AD-2). A Spill Prevention and Response Plan (SPR HAZ -5) would be developed as part of project implementation, and the project proponent would comply with herbicide application regulations (SPR HAZ -6) and restrict use of herbicide.

SPR BIO -10 requires focused surveys when working in potentially suitable habitat for special -status species, which includes roosting bats, and during maternity roosting season (April to July 31). Due to the difficulty of detecting bats during traditional daytime surveys, pre-treatment bat surveys would focus on identifying potential bat habitat and roosting structures. If potentially suitable roosting structures occur in project areas, a qualified bat biologist would conduct a Level 1 survey (year -round) for evidence of bat occupation, specifically looking for signs of day -roosting, such as fecal matter, staining, and carcasses.

Based on the results of Level 1 surveys, day and night emergence Level 2 surveys would be performed (April 1 to September 15).

Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, MMs BIO-2a, BIO-2b, BIO-3a, and BIO-4 would be implemented, including avoidance of protected aquatic features, targeted removal of non-native vegetation, strategic native vegetation removal to retain habitat function and prevent type conversion, and restriction of treatment activities to the non-breeding season as much as possible to avoid impacts to bats and their insect prey base. If special-status bat roosts are identified during focused surveys, a no-disturbance buffer of 250 feet would be established around active pallid bat (Antrozous pallidus), Townsend’s big-eared bat (Corynorhinus townsendii), and other special- status bat roosts, and mechanical treatments, manual treatments, and broadcast and pile burning would not occur within this buffer. MM BIO-2b also states: “A qualified RPF, biologist, or biological technician will

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be required to monitor the effectiveness of the no -disturbance buffer around the nest, den, burrow, or other occurrence during treatment.”
Bats may be excluded from roost locations by a qualified bat biologist or , under the direct advisory of a qualified bat biologist , from roosting structures in the work area only during the periods from mid - February until mid -April (hibernation) and late August until mid -October (to avoid hibernation and maternity season). Bat elimination would follow BMPs and must include the combination of two actions:
1) careful blockage of all openings that are large enough to allow bats to enter and 2) installation of one- way valves placed on the actively used openings to allow the bats to fly outside as they normally would but not to re -enter. After 7–10 days, the one -way valves are removed, and the remaining openings are blocked or sealed. Note that bats show a strong propensity to use any available openings to reclaim access to the roost when excluded, and blockages must be performed with great thoroughness and attention to detail. Bat exclusions must be overseen by a qualified bat biologist.

With these additional focused MMs, impacts to special- status bats would be reduced to less than significant. This impact is consistent with the CalVTP PEIR.

Impacts to San Francisco Dusky-Footed Woodrat
Direct impacts could result in nest damage during manual or mechanical removal of middens or tree nests.

Indirect impacts could include disturbing a San Francisco dusky -footed woodrat (Neotoma fuscipes annectens) f r o m t h e s a f e t y o f i t s n e s t , p u tti n g i t a t g r e a t e r r i s k o f p r e d a ti o n a n d r i s k i n g r e p r o d u c ti v e success.

Crews would be trained before the start of work to recognize woodrat nests and follow proper avoidance protocol (SPR BIO -2). If previously unknown nests are uncovered during work, crews would consult a biologist. Biologists would flag woodrat nest avoidance buffers during the pre-activity surveys (SPR AD-2).

Pre-treatment surveys would be combined with a focused survey (SPR BIO -1, SPR BIO-3, SPR BIO-10) to identify nest sites within the project footprint. If a San Francisco dusky-footed woodrat nest is identified during focused surveys, a minimum 10-foot no-disturbance buffer would be established around the nest, which would be assumed to be occupied. This buffer would include surrounding vegetation, including the vegetative canopy above the nest. The size of the buffer would be determined by the qualified RPF or biologist, and no treatment activities would occur within this buffer. If any individual of this species is detected during pre-activity surveys or work, the animal would be allowed to leave the area of its own volition.

Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, MMs BIO-2a, BIO-2b, BIO-3a, and BIO-4 would be implemented. MM BIO -2b includes flagging areas for nest avoidance and establishing no work-buffers. MM BIO -2b also states: “A qualified RPF , biologist, or

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biological technician will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment.” Nests that are deemed hazardous by the project proponent, such as those creating ladder fuels, may be dismantled under the supervision of a qualified biologist using a phased approach that allows woodrats to safely disperse. The following additional measures would be implemented when dismantling a woodrat nest:
• Prior to any nest removal, safety measures would be employed to minimize potential human exposure to possible diseases carried by woodrats
o Adequate protection, such as protective clothing, equipment and tools, gloves, and appropriate masks, is recommended to ensure safety regarding viruses and diseases potentially carried by rodents
• Vegetation immediately surrounding each nest to be removed would be cleared without disturbing the nest to prevent displaced woodrats from taking cover in dense vegetation within the work area
o All vegetation would be hauled off-site immediately; no brush piles or dense understory vegetation that could be used for cover by woodrats would be retained in the nest removal area after the nest is removed
• Nest removal efforts would not take place during inclement or extreme weather conditions and would take place at dusk or dawn when woodrats are least susceptible to predators • Each nest would be carefully dismantled using hand tools (e.g., a rake and pitchfork) • If a litter of young is found or suspected, the nest material would be replaced and the nest left alone for 2 to 3 weeks; after this time, the nest would be rechecked to verify that the young are capable of independent survival before proceeding with nest dismantling With these additional MMs, impacts to San Francisco dusky-footed woodrat would be reduced to less than significant. This impact is consistent with the CalVTP PEIR.

4.5.1.3. Impact BIO-3
Riparian habitat and 24 sensitive natural communities (CDFW 2018) have potential to occur within the project footprint:
• 71.060.00 Coast live oak woodland and forest
• 71.060.26 Quercus agrifolia—Arbutus menziesii–Umbellularia californica • 71.060.48 Quercus agrifolia—Umbellularia californica
• 71.060.08 Quercus agrifolia/Artemisia californica
• 71.100.00 Mixed oak forest and woodland
• 71.100.15 Quercus agrifolia—Quercus garryana—Quercus kelloggii • 74.100.00 California bay forest and woodland
• 74.100.01 Umbellularia californica
• 74.100.09 Umbellularia californica/Toxicodendron diversilobum

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• 71.040.00 Valley oak woodland and forest
• 71.020.00 Blue oak woodland and forest
• 61.130.24 Populus fremontii—Salix (laevigata, lasiolepis, lucida ssp. lasiandra) • 32.060.00 Coyote brush scrub
• 32.060.21 Baccharis pilularis/(Nassella pulchra—Elymus glaucus—Bromus carinatus) • 32.010.11 Artemisia californica—Diplacus aurantiacus
• 37.940.00 Poison oak scrub
• 37.940.02 Toxicodendron diversilobum—Artemisia californica/Leymus condensatus • 43.200.00 California poppy—lupine fields
• 43.200.02 Lupinus bicolor
• 41.080.02 Leymus triticoides—Bromus spp.—Avena spp.
• 41.080.04 Leymus triticoides—Carduus pycnocephalus—Geranium dissectum • 41.151.00 Needle grass—melic grass grassland
• 41.150.01 Nassella pulchra—Lolium perenne—(Trifolium spp.) • 41.150.05 Nassella pulchra—Avena spp.—Bromus spp.

Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse impacts on sensitive habitats, including designated sensitive natural communities. Direct impacts on sensitive habitats include direct loss or degradation o f habitat quantity or quality through vegetation removal. Indirect impacts include inadvertent introduction of invasive plant species or pathogens that would result in a habitat loss and degradation and disturbance of the ecosystem through loss of species community members (flora or fauna) through repeated presence of human activities.

The potential for adverse effects to riparian or sensitive natural communities is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment activities are consistent with those analyzed in the PEIR. Impacts to special-status wildlife would be reduced to less than significant with the following SPRs and MMs:
• SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR BIO -1: Review and Survey Project -Specific Biological Resources and Determine whether Avoidance Is Possible
• SPR BIO-2: Require Biological Resource Training for Workers • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats and Map Locations o Scrub habitat in the project footprint is suitable Alameda whipsnake habitat, and work would be restricted to hand tools only
o The following techniques would be implemented during treatment:
 Vegetation removal would occur in irregular, oblong shapes to maintain a natural condition
 Vegetation removal would avoid rocky outcroppings
 The overall dominant habitat type would not be converted  Vegetation removal would focus on dead, woody materials, and invasive plants

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o Preliminary and post -treatment surveys would be conducted that would assess the condition and acreage of core scrub habitat
 Post-treatment conditions would be assessed to ensure that there is no overall loss of habitat functionality within Alameda whipsnake core scrub o It should be noted that scrub is a transitional habitat, and, over time, canopy in these areas grows taller and denser, and larger tree species such as oak and madrone are naturally recruited and become increasingly dominant; without any intervention, over a long period of time, chaparral and scrub communities would naturally be converted to woodland and forested habitat
 Thoughtful treatment of select areas that retains scrub islands suitable for Alameda whipsnake core scrub is expected to be more effective in retaining key core scrub Alameda whipsnake habitat than complete avoidance of these areas • SPR BIO-6: Prevent Spread of Plant Pathogens
• SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife • SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats Implementation of SPR BIO-1 and the survey required under SPR BIO-3 would ensure any riparian habitat, sensitive communities, or oak woodlands would be identified. In accordance with the project description, all riparian areas would be avoided, and no work would occur within riparian habitats. Riparian habitats would be avoided with a 50 -foot buffer, but buffers may be increased based on recommendations of a qualified biologist and/or factors such as slope, existing erosion, sensitivity of the vegetative ha bitat, or presence of sensitive resources. SPR BIO-6 requires that BMPs be employed to avoid the spread of plant pathogens; and SPR BIO-9 prescribes actions to prevent the spread of invasive plants.

Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, MM BIO -3a would be implemented. Under MM BIO -3a, the qualified biologist would determine the natural fire regime, condition class, and fire return interval for each sensitive natural community and oak woodland type. Treatment activities in sensitive natural communities and oak woodlands would be designed to restore the natural fire regime and return vegetation composition and structure to their natural condition to maintain or improve habitat function. • MM BIO -3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands
The impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR. Impacts would be less than significant with mitigation, consistent with the PEIR.

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4.5.1.4. Impact BIO-4
Aquatic resources were identified within the project footprint as blue-line waters and one pond with an ephemeral drainage flowing into the pond. Initial vegetation and maintenance treatments could result in direct or indirect adverse effects on state- or federally protected wetlands. The potential for adverse effects to wetlands is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment acti vities are consistent with those analyzed in the PEIR. Impacts to wetlands would be reduced to less than significant with the following SPRs and MMs:
• SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife • SPR HAZ-5: Spill Prevention and Response Plan
• SPR HAZ-6: Comply with Herbicide Application Regulations • SPR HYD-1: Comply with Water Quality Regulations
• SPR HYD-2: Avoid Construction of New Roads
• SPR HYD-3: Water Quality Protections for Prescribed Herbivory • SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones • SPR HYD-5: Protect Non-Target Vegetation and Special-Status Species from Herbicides The aquatic habitat in the vicinity of the project area has been excluded from the project area during design of the treatments, and riparian habitat would be avoided at a minimum standard 50 -foot buffer.

Implementation of water quality protections in accordance with SPR HYD-1, identification of Watercourse and Lake Protection Zones (WLPZs), and establishing no-work buffers in accordance with SPR HYD-4 and SPR BIO-9 would minimize potential for invasive species spread in protected wetlands and riparian areas.

With implementation of the SPRs described above, impacts to state- and federally protected wetlands and riparian corridors from the treatment project would be less than significant with mitigation incorporated. • MM BIO-4: Avoid State and Federally Protected Wetlands Even following the above SPRs, project impacts could still be considered potentially significant. Therefore, MM BIO-4 would be implemented. Avoidance of state- and federally protected wetlands, per MM BIO-4, would ensure no impacts to wetlands in the identified features. With implementation of the above listed SPRs and MMs, riparian habitat and sensitive natural communities would be retained. These impacts were found to be within the scope of the PEIR, and treatment activities proposed are consistent with those analyzed in the PEIR.

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4.5.1.5. Impact BIO-5
The treatment areas have the potential to provide essential connectivity areas for wildlife. However, no known wildlife nursery sites or indications of nursery sites, such as deer -fawning habitat or potential rookery trees with whitewash, were identified within the project area during the reconnaissance survey.

Habitat within the treatment area may be used for movement (e.g., mule deer migration) and protective cover for common wildlife species. Noise during work may impede some movement, but work is generally within close proximity to urban landscapes , and wildlife inhabiting the area are likely habituated to regular noise disturbance. Tree limb removal, hazardous tree removal, and ground - disturbing activities have the potential to impact nursery sites for native wildlife. Use of noise-generating equipment could disturb roosting birds and bats, impeding use of nursery sites.

Manual, mechanical, prescribed burning, and prescribed herbivory treatments could result in some limited direct or indirect adverse effects on wildlife corridors and nurseries. The potential for treatment activities to result in impacts to special wildlife corridors and nurseries was examined in the PEIR and was found to be less than significant with mitigation.

Due to the history of fire suppression and dense understory vegetative growth throughout much of the project footprint, it is expected that wildlife corridors for some species would be improved by the treatment activities. By minimizing the potential for catastrophic wildfire and thereby protecting the forest ecosystem, the wildlife corridors, while slightly degraded in the short-term, would be protected from high- intensity wildfire in the future. Implementation of the SPRs and MMs listed below would minimize changes in habitat function within treatment areas that serve as wildlife-movement corridors:
• SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR BIO -1: Review and Survey Project -Specific Biological Resources and Determine whether Avoidance Is Possible
• SPR BIO-2: Require Biological Resource Training for Workers • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats and Map Locations • SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites • SPR BIO-11: Install Wildlife-Friendly Fencing During Prescribed Herbivory • SPR HYD-4: Identify and Protect Watercourse and Lake Protection Zones • SPR HYD-5: Protect Non-target Vegetation and Special-Status Species from Herbicides Existing habitat would remain to permit movement of wildlife species. Vegetation management activities would not block or obstruct streams or creeks. SPR BIO -10 would generally apply to many areas where special-status species could occur. During prescribed herbivory activities, wildlife-friendly fencing would be installed that would allow safe passage for common wildlife across the landscape (SPR BIO-11). With

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implementation of the above -listed SPRs, areas of intact wildlife corridors would be retained. These impacts were found to be within the scope of the PEIR, and treatment activities proposed are consistent with those analyzed in the PEIR.
• MM BIO-5: Retain Nursery Habitat and Implement Buffers to Avoid Nursery Sites Even following the above SPRs, wildlife nursery sites could still be significantly impacted if not avoided.

Therefore, MM BIO -5 would be implemented. If wildlife nursery sites are identified during surveys conducted pursuant to SPR BIO -10, MM BIO -5 would a pply. This MM requires that nursery habitat be marked for avoidance during treatment activities and a non -disturbance buffer be installed around the nursery site if activities are required to occur while the site is active or occupied.

Impacts would be less than significant with mitigation, consistent with the PEIR.

4.5.1.6. Impact BIO-6
Initial vegetation treatment activities and treatment maintenance activities could result in direct or indirect adverse effects resulting in reduction of habitat or abundance of common wildlife, including nesting birds, because habitat suitable for these species is present throughout the treatment areas.

The potential for adverse effects to special-status wildlife species is within the scope of the activities and impacts addressed in the PEIR because the treatment activities and intensity of disturbance resulting from implementing treatment activities are consistent with those analyzed in the PEIR. Impacts to special-status wildlife would be reduced to less than significant with the following SPRs and MMs (Attachment A). In addition to the CalVTP PEIR SPRs and MMs, additional Project-specific measures are described below each applicable measure:
• SPR AD-2: Delineate Protected Resources for Avoidance • SPR AD-3: Consistency with Local Plans, Policies, and Ordinances • SPR AD-5: Maintain Site Cleanliness
• SPR BIO -1: Review and Survey Project -Specific Biological Resources and Determine whether Avoidance Is Possible
• SPR BIO-2: Require Biological Resource Training for Workers • SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats and Map Locations • SPR BIO-12: Protect Common Nesting Birds, Including Raptors o Institute the use of avoidance buffers, treatment modification, or treatment delay; monitor active raptor nests during treatment and retain raptor nest trees Regarding general common wildlife, implementation of SPR BIO-1, SPR BIO-2, and SPR BIO-3 would limit the loss and degradation of high -quality habitat for common species within the project site. SPR BIO -2 would require worker training in sensitive biological resources; SPR BIO -3 would ensure mapping of

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sensitive habitats . Therefore, p roject treatment would remove vegetation and alter habitat structure locally but would not result in permanent habitat degradation or conversion.

The potential for adverse effects on common wildlife, including nesting birds, is within the scope of the PEIR because the treatment activities and extent of expected disturbance as a result of implementing vegetation treatments, including maintenance treatments, are consistent with those analyzed in the PEIR.

The implementation of SPRs BIO-1, BIO-2, BIO-3, BIO-5, and BIO-12, in addition to measures described for special-status species under Impact BIO-1, BIO-2, BIO-3, and BIO-5, would reduce the risk of this project, resulting in less than significant adverse effects to habitat and the abundance of common wildlife.

The potential for treatment activities, including maintenance treatments, to result in adverse effects on these resources was examined in the PEIR and was found to be less than significant.

4.5.1.7. Impact BIO-7
Local policies or ordinances would apply to resources that occur within the proposed p roject area, particularly tree ordinances or noise ordinances. The potential for treatment activities to result in conflict with local policies or ordinances was examined in the PEIR. The potential for the proposed project to conflict with local policies or ordinances is within the scope of the activities and impacts addressed in the PEIR because the treatment projects implemented under the CalVTP are required to comply wi th any applicable county, city, or other local policies, ordinances, and permitting procedures related to protection of biological resources.
• SPR AD-3: Consistency with Local Plans, Policies, and Ordinances Additionally, SPR AD-3 (Consistency with Local Plans, Policies, and Ordinances) requires that the project proponent design and implement the treatment in a manner that is consistent with applicable local plans (e.g., general plans), policies, and ordinances to the extent the Project is subject to them ( see Section

3.12.2, Regulatory Setting, in the PEIR for more information). Impacts would be less than significant and consistent with the PEIR.

4.5.1.8. Impact BIO-8
The CalVTP recognized eight HCPs and/or NCCPs in the planning or implementation phase in the Central California Coast Section. In addition, the E ast Bay Municipal Utility District Low Effect East Bay HCP lies within the Central California Coast Section and west of the project area. The proposed p roject does not fall under the jurisdiction of any known HCPs or NCCPs; therefore, this impact does not apply to the treatment areas.

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4.5.1.9. New Biological Resources Impacts
The proposed treatments are consistent with the treatment types and activities evaluated in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of the project area and has determined they are consistent with the environmental and regulatory settings discussed in the PEIR. The project proponent has also determined that the inclusion of the portion of the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR.

However, the existing environmental and regulatory conditions pertinent to biological resources that are present within the treatable landscape are essentially the same as those areas outside the treatable landscape. Therefore, the impacts of the proposed project are also consistent with those covered in the PEIR. No changed circumstances would lead to new significant impacts not addressed in the PEIR.

Therefore, no new impact to biological resources would occur.

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4.6. Geology, Soils, Paleontology, and Mineral Resources Table 6. Consistency of project-related geology, soils, paleontology, and mineral resources impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact GEO-1: Result in Substantial
Erosion or Loss of Topsoil LTS
Impact GEO-
1, pp. 3.7-26
– 3.7-29
Yes
AD-3, GEO-
1 through
GEO-8, AQ-
3, AQ-4,
HYD-3,
HYD-4
NA LTS No Yes
Impact GEO-2: Increase Risk of
Landslide LTS
Impact GEO-
2, pp. 3.7-29
– 3.7-30
Yes
AD-3, GEO-
1, GEO-3,
GEO-4,
GEO-7,
GEO-8, AQ-
3 NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Geology, Soils, Paleontology, and Mineral Resource Impacts:

Would the treatment result in other impacts to geology, soils, paleontology, and mineral resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.6.1. Discussion
The project area is located in Alameda County, within the Coast Ranges Geomorphic Province, which is characterized by northwest -trending mountain ranges and valleys (California Geological Survey [CGS] 2002). The Coast Ranges are primarily composed of Jurassic - to Cretaceous-age (about 65 –150 million years old) marine sedimentary and volcanic rocks of the Franciscan assemblage. The Franciscan assemblage consists of partially metamorphosed greenstone, basalt, chert, and graywacke that originated as sea floor sediments.

The California Department of Conservation CGS Landslide Inventory (beta) map (CGS 2015) and the CGS Earthquake Zones of Required Investigation Dublin Quadrangle (CGS 2008) were reviewed to identify unstable areas within or in proximity to the treatment areas. The treatment areas are located on and surrounded by land that has been and currently is subject to landslide, both weather -induced and seismically induced.

Soils within the treatment areas are dominated by Los Gatos–Los Osos complex, 30 to 75 percent slopes, eroded (65.3 percent), and Millsholm silt loam, 30 to 45 percent slopes (20.0 percent). Other soils make up smaller percentages of the project footprint, such as Los Osos and Millsholm soils, 7 to 30 percent slopes (8.1 percent) , and Millsholm silt loam, 45 to 75 percent slopes, eroded (6.5 percent ; Natural Resources Conservation Service [NRCS] 2025). Table 8 below shows all soil types present within the footprint of the treatment areas. The parent material for these soils consists of sandstone and shale, and these soils are well drained to somewhat excessively well drained (NRCS 2025). The erosion hazard for the soils ranges from moderately low to moderately high (NRCS 2025). As stated in the project description, mechanical treatments would occur but would occur predominantly on slopes below 40 percent grade, along ridges, and on slopes greater than 40 percent grade with equipment that can reach target vegetation from existing road infrastructure. No mechanical treatment would occur on slopes greater than 50 percent.

Table 7. Soil types and percentages within the project area.

Soil Type Acres Percent of Total
Footprint
Los Gatos-Los Osos complex, 30 to 75 percent slopes, eroded, Major Land Resource Area 15 105.8 65.3%
Los Osos and Millsholm soils, 7 to 30 percent slopes 13.2 8.1% Millsholm silt loam, 30 to 45 percent slopes, eroded 32.3 20% Millsholm silt loam, 45 to 75 percent slopes, eroded 32.3 20% Totals 161.9 100.0%
Source: NRCS 2025.

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4.6.1.1. Impact GEO-1
The proposed project would include prescribed burning, manual and mechanical treatments, prescribed herbivory, and applied herbicide , as well as biomass disposal. These activities would create soil disturbance and vegetation removal, which have the potential to create erosion and the loss of topsoil.

The potential impacts fall within the scope of the PEIR because the proposed work activities are similar to those analyzed in the PEIR.

The PEIR identified the potential for project treatments to cause a substantial erosion or loss of topsoil as less than significant. Implementation of SPRs AD-3, GEO-1 through GEO-8, HYD-3, HYD-4, AQ-3, and AQ-4 would further minimize the risk of soil disturbance and the removal of topsoil caused by project treatments. SPR GEO-1 would require that soil -disturbing activities be put on hold during precipitation; SPR GEO-2 would limit the use of vehicles with high ground pressure that could lead to soil disturbance or compaction on wet or saturated soils; SPR GEO-3 would require disturbed soil areas to be stabilized during treatment activities; SPR GEO-4 would require treatment areas be inspected for correct erosion control measures prior to the start of the rainy season and following the first large rain event; SPR GEO -5 would require that stormwater be drained using water breaks to decrease the potential for channelized erosion down linear treatment areas; SPR GEO-6 would require that the size of burn piles be minimized in order to limit the spatial extent of damage done to soil; SPR GEO -7 would minimize erosion resulting from the use of heavy equipment and herbivory that is prescribed on slopes; SPR-8 would require an RPF or licensed geologist to evaluate treatment areas with slopes greater than 50 percent for unstable areas (areas with potential for landslide) and unstable soils (soil with moderate to high erosion hazard) ; SPR HYD-3 would require that environmentally sensitive areas be identified and excluded from all prescribed herbivory; SPR HYD-4 would require the establishment of WLPZs in order to reduce erosion near streams; SPR AQ-3 would require the creation of a Burn Plan and minimize the severity of soil burn to reduce the potential for runoff and soil erosion; and SPR AQ-4 would require that unpaved dirt roads be wetted in order to control dust.

The proposed treatment area includes land that is outside of the CalVTP treatable landscape. While this constitutes as a change to the geographic extent that is outlined in the PEIR, the slopes and soil characteristics of the project area are equivalent within and outside the treatable landscape. However, SPRs would be implemented as described above, which would limit the potential for erosion to occur. For t h a t r e a s o n , t h e p o t e n ti a l i m p a c t r e l a t e d t o s o i l e r o s i o n i s a l s o t h e s ame, as described above. This determination is therefore consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

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4.6.1.2. Impact GEO-2
Proposed treatment activities, such as vegetation removal and prescribed burning, which limit vegetative cover and impact root systems , could diminish the stability of soils, potentially increasing the risk of landslides. The PEIR identified the potential for treatment activities to increase the risk of landslides as less than significant. Because the treatments being proposed are analyzed in a manner consistent with the treatments in the PEIR, the potential impact falls within the PEIR scope. Additionally, implementing SPRs AD-3, GEO-1, GEO-3, GEO-4, GEO-7, GEO-8, and AQ-3 would minimize the potential for landslides created by project treatments. SPR GEO -1 would require that soil -disturbing activities be put on hold during precipitation; SPR GEO -3 would require that treatment areas be inspected for correct erosion control measures prior to the start of the rainy season and following the first large rain event; SPR GEO -4 would require that treatment areas be inspected for proper erosion control measures; SPR GEO-7 would minimize erosion resulting from the use of heavy equipment and herbivory that is prescribed on slopes; SPR-8 would require an RPF or licensed geologist to evaluate treatment areas with slopes greater than 50 percent for unstable areas (areas with potential for landslide); and SPR AQ-3 would minimize the severity of soil burn to reduce the potential for landslides caused by the destabilization of root structures and the loss of vegetative cover.

As discussed in Impact GEO -1, the proposed treatment area includes land that is outside of the CalVTP treatable landscape. While this constitutes a change to the geographic extent that is outlined in the PEIR, the slopes and landslide conditions of the project area that are within the treatable landscape are equivalent to the areas outside of it. SPRs would also be implemented as described above. For these reasons, the potential impact related to the risk of landslides would not differ from what was discussed in the CalVTP . Therefore, proposed treatments outside of the original area covered in the CalVTP treatable landscape would not constitute a substantially more severe significant impact than what was analyzed in the PEIR.

4.6.1.3. New Geology, Soils, Paleontology, and Mineral Resource Impacts The proposed treatments are consistent with the treatment types and activities evaluated in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of the proposed treatment project and has determined they are consistent with the environmental and regulatory settings discussed in the PEIR. The project proponent has also determined that the inclusion of the portion of the project area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, the existing environmental and regulatory conditions pertinent to geology and soils that are present within the treatable landscape are essentially the same as those areas outside the treatable landscape. Therefore, the impa cts of the proposed project are also consistent with those

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covered in the PEIR. No changed circumstances would lead to new significant impacts not addressed in the PEIR. Therefore, no new impact to geology and soils would occur.

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4.7. Greenhouse Gas Emissions
Table 8. Consistency of project-related greenhouse gas emissions impacts with the scope of the Cal ifornia Vegetation Treatment Program Programmatic Environmental Impact Report.

Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact GHG-1: Conflict with
Applicable Plan, Policy, or Regulation
of an Agency Adopted for the
Purpose of Reducing the Emissions
of GHGs
LTS
Impact GHG-
1, pp. 3.8-10–

3.8-11
Yes AD-3 NA LTS No Yes
Impact GHG-2: Generate GHG
Emissions through Treatment
Activities
PSU
Impact GHG-
2, pp. 3.8-11–

3.8-17
Yes AQ-3 GHG-2 SU No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New GHG Emissions Impacts: Would the treatment result in other impacts to GHG emissions that are not evaluated in the CalVTP PEIR? ☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.7.1. Discussion

4.7.1.1. Impact GHG-1
Vegetation treatments—including manual and mechanical removal, prescribed burning, targeted grazing, and herbicide use—along with biomass disposal methods such as chipping and pile burning, would result in the generation of GHG emissions. The PEIR concluded that CalVTP treatments are consistent with relevant plans, policies, and regulations targeting GHG reduction, and that any associated emissions are less than significant due to the inclusion of SPRS, as well as the long-term climate benefits from reduced wildfire risk and enhanced ecosystem health.

The Project would be consistent with the applicable policies, plans, and regulations to reduce GHG emissions as described in California’s 2022 Climate Change Scoping Plan (CARB 2022), the California Forest Carbon Plan (Forest Climate Action Team 2018), and the Draft California 2030 Natural and Working Lands Climate Change Implementation Plan (CARB 2019). Since the Project is consistent with the latest Climate Change Scoping Plan measures, it is on target to achieve the legislated GHG emission target for 2030 and substantially advance toward the 2050 climate goals. The Project would also be consistent with the City of Pleasanton Climate Action Plan 2.0 (City of Pleasanton 2022) and the Alameda County Climate Action Plan (Alameda County 2023), which contain GHG reduction strategies and policies, and details impacts of worsening wildfires on public health. Additionally, it would be consistent with the City of Pleasanton General Plan 2005–2025 (City of Pleasanton 2009) and Alameda County General Plan ( Alameda County 2013), which contain goals and policies relating to fire protection and wildland fire prevention using controlled burns, fuel removal, and fuel breaks.

Impacts related to GHG emissions from these types of treatment activities are within the scope of the PEIR because the proposed activities, as well as the associated equipment, duration of use, and resultant GHG emissions, are consistent with those analyzed in the PEIR, which were found to be less than significant.

SPR GHG-1 is not applicable to the proposed project as the Project is not subject to the requirement to provide information to inform reporting under the Board of Forestry and Fire Protection’s AB 1504 Carbon Inventory Process because the Project is not a registered offset project. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the same plans, policies, and regulations adopted to reduce GHG emissions apply in the areas outside the treatable landscape as well as in areas within the treatable landscape; therefore, the GHG impact is also the same as described above.

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4.7.1.2. Impact GHG-2
The use of vehicles and mechanical equipment, prescribed herbivory, herbicide application, and prescribed burning during initial and maintenance treatments would result in GHG emissions. However, these treatments would have relatively low GHG emissions compared to GHG emissions from catastrophic wildfires. Wildfire hazards, including wildfire intensity and rate of spread , could be somewhat reduced through implementation of the Project. The PEIR evaluated the potential for CalVTP treatments to produce GHG emissions and determined the impact to be potentially significant and unavoidable. This was found to be the cause because a lthough SPRs and MMs are in place, cumulative emissions from activities like mechanical vegetation removal, prescribed burning, and equipment operation may still surpass thresholds established by climate action policies. No feasible mitigation that could fully offset or elim inate these emissions was identified.

This impact falls within the scope of the PEIR, as the Project’s proposed activities —including the type of equipment used, duration of operations, and the objective to reduce wildfire risk and associated GHG emissions—align with those evaluated in the PEIR . MM GHG-2 would be implemented to reduce GHG emissions from pile burning by targeting burns when fuel moisture is higher, minimizing the total area burned through mosaic patterns, leaving large fuels unburned, and timing burns to occur before the emergence of new fuels. Despite the implementation of this measure, treatment activities would contribute to annual GHG emissions generated under the CalVTP , and this impact would fall within the finding of potentially significant and unavoidable , as identified in the PEIR . Methods for reducing GHG emissions from burns would be integrated into SPR AQ-3 (Burn Plan) as described in MM GHG-2.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR , and the added acreage would not expand the total annual acreage of 250,000 acres per year proposed for treatment under the PEIR. However, GHG emissions and associated climate change impacts are global in nature and are not contained within the boundary of the treatable areas. Therefore, the GHG impact is also the same, as described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.7.1.3. New Impacts Related to GHG Emissions
The proposed treatment is consistent with the treatment types and activities considered in the CalVTP PEIR. The project proponent has considered the site -specific characteristics of the proposed treatments and determined they are consistent with the applic able regulatory and environmental conditions presented in the CalVTP PEIR (Section 3.8.1, Regulatory Setting, and Section 3.8.2, Environmental Setting, in Volume II of the Final PEIR).

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The inclusion of approximately 93 acres of land that is outside of the treatable landscapes constitutes a change to the geographic extent of the PEIR. However, the same plans, policies, and regulations aimed at reducing GHG emissions apply equally both within the treatable landscape and in surrounding areas.

Similarly, the climate conditions within the treatable landscape are consistent with those in adjacent areas.

Therefore, impacts of the Project are also consistent with those covered in the PEIR. No changed circumstances are present, and since the added 93 acres would not expand the total annual acreage of 250,000 acres per year proposed for treatment under the PEIR, the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. No new impact related to GHG emissions would occur.

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4.8. Energy Resources
Table 9. Consistency of project-related energy resources impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact ENG-1: Result in Wasteful,
Inefficient, or Unnecessary
Consumption of Energy
LTS
Impact ENG-
1, pp. 3.9-7–

3.9-8
Yes NA NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Energy Resource Impacts: Would the treatment result in other impacts to energy resources that are not evaluated in the CalVTP PEIR? ☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.8.1. Discussion

4.8.1.1. Impact ENG-1
The use of vehicles and mechanical equipment during initial treatment and treatment maintenance activities would result in the consumption of energy in the form of fossil fuels. The CalVTP PEIR identified a less than significant impact for the potential wasteful, inefficient, or unnecessary consumption of energy because the treatments analyzed do not involve grid-based energy use, rely primarily on short-term use of petroleum fuels for treatment activities, and would incorporate practices that minimize energy waste.

The consumption of energy during implementation of the Project is within the scope of the PEIR because the types of activities, as well as the associated equipment and duration of proposed use, are consistent with those analyzed in the PEIR. Diesel and gasoline would be used temporarily to operate heavy-duty vehicles and mechanical equipment and transport personnel, tools, and livestock to, from, and within the project site. However, this use of petroleum fuels would be short-term and would not constitute a wasteful or inefficient use of energy. Additionally, t he Project would aid in fire prevention and suppression by lowering wildfire risk and reducing the intensity of emergency responses, which typically involve rapid deployment of personnel and equipment from statewide or national sources and lead to inefficient energy use. There are no SPRs applicable to this impact. Overall, the project treatment activities would not result in wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.

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

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, the existing environmental and regulatory conditions are essentially the same within and outside the treatable landscape, and the types of treatmen t activities and associated use of energy are of the same scale and scope as analyzed in the PEIR; therefore, the energy impact is also the same. No SPRs are applicable to this impact. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than covered in the PEIR.

4.8.1.2. New Energy Resource Impacts
The project proponent has considered the site-specific characteristics of the proposed treatment project both inside and outside the treatable landscape and determined they are consistent with the applicable regulatory and environmental conditions presented in the CalVTP PEIR (Sections 3.9.1, Regulatory Setting, and 3.9.2, Environmental Setting, in Volume II of the Final PEIR), since the added acreage would not expand the total annual acreage of 250,000 acres per year proposed for treatment under the PEIR. Therefore, the impacts of the proposed project are consistent with those considered in the PEIR. N o changed

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circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not g i v e r i s e t o a n y n e w s i g n i fi c a n t i m p a c t s . T h e r e f o r e , n o n e w i m p a c t r e l a t e d t o e n e r g y r e s o u r c e s w o u l d occur.

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4.9. Hazardous Materials, Public Health, and Safety
Table 10. Consistency of project-related hazardous materials, public health, and safety impacts with the scope of the Cal ifornia Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in the
PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact HAZ-1: Create a Significant
Health Hazard from the Use of
Hazardous Materials
LTS
Impact HAZ-1,
pp. 3.10-14–

3.10-15
Yes HAZ-1, HAZ-
5 NA LTS No Yes
Impact HAZ-2: Create a Significant
Health Hazard from the Use of
Herbicides
LTS
Impact HAZ-2,
pp. 3.10-15–

3.10-18
Yes
HAZ-5, HAZ-
6, HAZ-7,
HAZ-8, HAZ-
9 NA LTS No Yes
Impact HAZ-3: Expose the Public or
Environment to Significant Hazards
from Disturbance to Known Hazardous
Material Sites
PS
Impact HAZ-3,
pp. 3.10-18–

3.10-19
Yes NA HAZ-3 LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Hazardous Materials, Public Health, and Safety Impacts: Would the treatment result in other impacts related to hazardous materials, public health and safety that are not evaluated in the CalVTP PEIR? ☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.9.1. Discussion

4.9.1.1. Impact HAZ-1
The Project would involve mechanical treatments, manual treatments, prescribed herbivory, herbicide application, and prescribed burning. These activities would involve equipment and vehicles that use fuels, oils, and lubricants —which are classified as hazardous materials. The PEIR analyzed potential health hazards from hazardous materials used in treatment activities and found impacts to be less than significant due to strict regulatory compliance, safety measures, and limited exposure risk. This impact falls within the scope of the PEIR, as the treatment methods, equipment, and hazardous materials involved align with those previously analyzed. All equipment associated with the proposed project would comply with SPR s HAZ-1 and HAZ-5. SPR HAZ-1 would require that equipment is properly maintained to minimize leaks, and SPR HAZ-5 would require that proper spill prevention measures would be implemented on-site to prevent impacts related to the accidental leak or spill of hazardous materials. Herbicide application impacts are discussed under Impact HAZ-2, below.

The proposed treatment area includes approximately 93 acres of land that is outside of the CalVTP treatable landscape. While this constitutes as a change to the geographic extent that is outlined in the PEIR, regulatory conditions and the use of hazardous materials are essentially the same within and outside the treatable landscape. Therefore, the impact related to the use of hazardous materials is also the same.

This determination is consistent with the PEIR and would not constitute a substantially more se vere significant impact than what was covered in the PEIR.

4.9.1.2. Impact HAZ-2
The Project would include herbicide application to control species that increase wildfire hazards. Herbicide application would involve transportation, use, storage, and disposal of herbicides, which could result in risks related to human exposure when applied in areas in close proximity to the public. However, only ground-level application would occur; no aerial spraying or spraying of herbicides from trucks would occur .

The PEIR found the potential health hazard from herbicide use during treatment activities to be less than significant because the herbicides would be applied in accordance with regulatory standards, using trained personnel, approved products, and methods designed to minimize exposure to humans and the environment. The potential impacts related to the use of herbicides during treatment activities are within the scope of the activities and impacts discussed within the PEIR because the types of herbicides (e.g., glyphosate and species-specific chemicals), as well as application methods that would be used, which are limited to ground-based applications, are consistent with those analyzed in the PEIR. Herbicides may be applied sparingly and strategically (by hand or backpack applicator) to invasive plants and noxious weeds

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to minimize the spread and eliminate re -sprouting of invasive species to reduce wildfire risk within the treatment areas.

Furthermore, under the CalVTP , herbicide treatments would be limited to ground-level application and must comply with all USEPA label directions as well as be applied by licensed applicators in compliance with all laws and regulations. The Project would comply with SPRs HAZ -5 through HAZ-9, which require preparation of a Spill Prevention and Response Plan prior to any herbicide treatment activities to provide protection from accidental spills or leaks of herbicides to workers, the public, and the environmen t; compliance with herbicide application regulations to protect worker and public safety; triple rinsing herbicide containers and disposal of rinsed materials at an approved site and disposal of all herbicides following label requirements and waste disposal regulations; minimization of herbicide drift into public areas through application parameters such as limitations for nozzle pressure and nozzle distance from vegetation; and notification of herbicide application within 500 feet of public areas by postin g signs at herbicide treatment areas. Herbicide application would not take place within 24 hours of a rain event.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, the potential of exposure to herbicides is essentially the same within and outside the treatable landscape.

Therefore, the impact related to the potential for the Project to result in a significant health hazard from the use of herbicides is also the same. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.9.1.3. Impact HAZ-3
The Project would include mechanical treatments that could result in ground disturbance, which could expose workers, the public, or the environment to hazardous materials if a contaminated site is present within the project area. Additionally, prescribed b urning activities could lead to unexpected ignitions should flammable hazardous waste be present, which could expose workers to risks associated with unexpected fire or explosions. The PEIR identified the potential for treatment activities to disturb contaminated sites that could expose workers, the public, or the environment to hazardous materials as potentially significant. This impact was identified as potentially significant in the PEIR because hazardous materials sites could be present within treatment sites, and so il disturbance or burning in those areas could expose people or the environment to hazards. In evaluating the potential for effects related to the proposed project, database searches for hazardous materials sites within the project area were conducted as directed by MM HAZ-3. There are no sites located inside of, or within 0.25 miles of, the project area (DTSC 2025a, 2025b, 2025c; SWRCB 2025a, 2025b; CalEPA 2025a, 2025b). The proposed project would not involve ground disturbance that would have the potential to disturb contaminated sites outside of the

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project area. Therefore, this impact is less than significant. No SPRs are applicable to this impact, and no additional mitigation is required.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the potential to encounter hazardous materials and the regulatory conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape.

Therefore, the hazardous materials impact related to exposing the public or environment to hazards from disturbance of known hazardous material sites is also the same. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.9.1.4. New Hazardous Materials, Public Health, and Safety Impacts The Project is consistent with the treatment types and activities considered in the CalVTP PEIR. The project proponent has considered all site -specific characteristics of the proposed project and determined that they are in compliance with the applicable environmental and regulatory setting conditions presented in the CalVTP PEIR (Volume II, 3.10.1 and 3.10.2). The project proponent has also determined that the inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and regulatory conditions pertinent to hazardous materials that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape. Therefore, the impacts are the same, and the impacts of the proposed project are also consistent with those covered in the PEIR. No changed circumstances would create new significant impacts not addressed in the PEIR, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact related to hazardous materials, public health, or safety would occur.

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4.10. Hydrology and Water Quality
Table 11. Consistency of project-related hydrology and water quality impacts with the scope of the Cal ifornia Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact HYD-1: Violate Water Quality
Standards or Waste Discharge
Requirements, Substantially Degrade
Surface or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water Quality
Control Plan through the
Implementation of Prescribed
Burning
LTS
Impact HYD-
1, pp. 3.11-
25–3.11-27
Yes
AD-3, AQ-3,
GEO-4
through
GEO-7,
HYD-1,
HYD-4,
HYD-6
NA LTS No Yes
Impact HYD-2: Violate Water Quality
Standards or Waste Discharge
Requirements, Substantially Degrade
Surface or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water Quality
Control Plan through the
Implementation of Manual or
Mechanical Treatment Activities
LTS
Impact HYD-
2, pp. 3.11-
27–3.11-29
Yes
AD-3, AQ-3,
GEO-3
through
GEO-7,
HYD-1,
HYD-4,
HYD-6
NA LTS No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact HYD-3: Violate Water Quality
Standards or Waste Discharge
Requirements, Substantially Degrade
Surface or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water Quality
Control Plan through Prescribed
Herbivory
LTS Impact HYD-
3, p. 3.11-29 Yes
AD-3, HYD-
1, HYD-2,
HYD-4,
HYD-6,
GEO-1
through
GEO-4,
GEO-7, BIO-
1, HAZ-1
NA LTS No Yes
Impact HYD-4: Violate Water Quality
Standards or Waste Discharge
Requirements, Substantially Degrade
Surface or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water Quality
Control Plan through the Ground
Application of Herbicides
LTS
Impact HYD-
4, pp. 3.11-
30–3.11-31
Yes
AD-3, BIO-
1, BIO-4,
BIO-5, GEO-
1, GEO-3,
GEO-4,
GEO-7,
HYD-1,
HYD-2,
HYD-3,
HYD-6,
HAZ-1
NA LTS No Yes

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Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact HYD-5: Substantially Alter
the Existing Drainage Pattern of a
Treatment Site or Area
LTS Impact HYD-
5, p. 3.11-31 Yes
AD-3, BIO-
1, BIO-4,
GEO-1,
HAZ-1,
HAZ-5,
HAZ-6,
HAZ-7,
HYD-1,HYD-
4, HYD-5
NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Hydrology and Water Quality Impacts: Would the treatment result in other impacts to hydrology and water quality that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.10.1. Discussion
The project area is within Augustin Bernal Park in Alameda County, under the San Francisco Bay RWQCB and Hydrologic Region . Water features in or near the project area include Sinbad Creek, a tributary to Arroyo de la Laguna, and an unnamed , manmade pond located within the park boundary. Both features are part of the Alameda Creek Watershed, which is impaired for sediment, nutrients, and pathogens and subject to Total Maximum Daily Load regulations. The area receives about 17.8 inches of annual rainfall, mainly from November to April, with runoff and erosion during storms (Climate-Data.org n.d.). Elevations range from 600 to 1,200 feet, with steep slopes draining toward Sinbad Creek or the Arroyo del la Laguna.

The site lies outside mapped groundwater basins and has limited recharge due to shallow soils and terrain.

4.10.1.1. Impact HYD-1
Project treatments may include prescribed burning in the form of low -intensity surface fires. Ash and debris from treatment areas could be washed by runoff into adjacent drainages and streams. The PEIR identified the potential for any prescribed burning treatment areas to impact water quality regulations or degrade water quality due to the creation of runoff which transports ash and debris as less than significant.

This conclusion was based on the use of low -intensity burns, the use of SPRs (e.g. , setbacks and erosion controls), and site -specific planning measures , such as Burn Plans. Together, these practices effectively minimize the risk of violating water quality standards or causing degradation. This impact falls within the scope of the PEIR because the use of pile burning and prescribed low -intensity surface fires and all associated impacts to water quality are consistent with what is analyzed in the PEIR. Applicable SPRs for this treatment include AD -3, AQ-3, HYD-1, HYD-4, HYD-6, and GEO-3 through GEO-7. SPR AD -3 requires that the treatment design align with local plans, policies, and ordinances, while SPR AQ -3 mandates preparation of a Burn Plan. SPRs GEO-3 through GEO-7 address soil stabilization, erosion monitoring, use of water breaks to manage stormwater, and limiting burn pile size. SPRs HYD-1, HYD-4, and HYD-6 ensure compliance with water quality regulations, require implementation of WLPZs ranging from 50 to 150 feet depending on watercourse classification, and prohibit burn piles within WLPZs.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. As mentioned above, there are two waterbodies located within or adjacent to the project area, Sinbad Creek and an unnamed manmade pond. The unnamed manmade pond is located within the project area and is flooded year -round during years with average rainfall. This feature is located outside of the C alVTP treatable landscape. Sinbad Creek is located less than 0.25 miles southwest of the project area and is located within the CalVTP treatable landscape. The surface water conditions of the project area boundary are essentially the same within and outside the treatable landscape; therefore, the water quality impact from prescribed burning is also the same, as described above. This determination is consistent with the

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PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.10.1.2. Impact HYD-2
This project would include both manual and mechanical treatments. Any watercourses that are within treatment areas pursuant to SPR HYD -4 would have WLPZs ranging from 50 to 150 feet. The PEIR concluded that manual and mechanical treatments are unlikely to violate water quality regulations or degrade water quality, and therefore the impact is less than significant. These treatments are carefully controlled, result in minimal soil disturbance, and are subject to SPRs that mandate erosion control, setbacks from water bodies, and full compliance with water quality standards. Together, these measures effectively reduce runoff and protect surrounding water resources. Because the use of heavy equipment and handheld tools to remove vegetation and associated impacts to water quality are consistent with those analyzed in the PEIR, this impact falls within the scope of the PEIR. SPRs applicable to this treatment are AD-3, HYD-1, HYD-2, HYD-4, HYD-6, GEO-1 through GEO-4, GEO-7, BIO-1, and HAZ-1. SPRs AD-3, HYD- 1, HYD-4, HYD-6, and GEO-1 through GEO-7 are described under Impact HYD -1. SPR GEO-1 requires the suspension of soil -disturbing treatment activities during precipitation and limits high ground pressure vehicles that could cause soil disturbance or compaction on wet or saturated soils. SPR HYD-2 ensures that the construction of new roads would be avoided. SPR BIO -1 requires the review and survey of specified biological resources, including riparian areas. SPR HAZ -1 requires that all equipment be maintained and regularly inspected for leaks.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. As mentioned in Impact HYD-1, a few segments of the project treatment areas that are located outside the CalVTP treatable landscape are in close proximity to waterbodies entirely or partially outside the treatable landscape boundary. However, within the boundary of the project area, the surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from manual and mechanical treatments is also the same, as described above. This determination is consistent with the PEIR and would not constitute a subst antially more severe significant impact than what was covered in the PEIR.

4.10.1.3. Impact HYD-3
Project treatments would include prescribed herbivory to reduce fuel loads and may be used for treatment maintenance or as a pre -treatment before implementation of other methods. The prescribed herbivory livestock used as part of the proposed project would typically involve use of cattle, goats, and other grazing animals; under the CalVTP , this could also include horses and may require the installation of temporary

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fencing where natural barriers are not present. The use of temporary water facilities for the livestock and guard animals and/or shepherd, as well as other temporary infrastructure (e.g., tanks, corrals, wildlife-safe fences), may be required with the use of prescribed herbivory as a treatment method. The CalVTP PEIR determined that prescribed herbivory poses a less than significant impact to water quality because it involves minimal soil disturbance, is carefully managed, and is subject to protective measures under SPRs.

Because the proposed prescribed herbivory treatments align with those evaluated in the PEIR, potential impacts to water quality are considered within the scope of the CalVTP and have been fully addressed.

SPRs applicable to this treatment are AD-3, BIO-1, BIO-4, BIO-5, GEO-1, GEO-3, GEO-4, GEO-7, HYD-1, HYD- 2, HYD-3, HYD-4, HYD-6, and HAZ-1. All applicable SPRs listed, except SPRs BIO-4, GEO-3, and HYD-3, are described in Impact HYD -1 and Impact HYD -2. SPR BIO-4 requires that treatment design avoid loss of riparian habitat function. SPR GEO -3 requires stabilization of soil disturbed during prescribed herbivory treatments, and HYD -3 requires various water quality protections for prescribed herbivory treatments.

These SPRs avoid and minimize the risk of substantial water quality degradation by implementation of prescribed herbivory treatment, making the impact less than significant.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR . As mentioned in Impact HYD-1, a few segments of the project treatment areas that are located outside the CalVTP treatable landscape are in close proximity to waterbodies entirely or partially outside the treatable landscape boundary. However, within the boundary of the project area, the surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from prescribed herbivory treatments is also the same, as described above. This determination is consistent with the PEIR and would not constitute a substa ntially more severe significant impact than what was covered in the PEIR.

4.10.1.4. Impact HYD-4
Project treatments could include targeted herbicide application to kill, or prevent regrowth of, invasive plants and noxious weeds. No aerial spraying of herbicides would occur. Herbicides would be applied in adherence with all USEPA, CalEPA, and California DPR guidelines. Even so, the use of herbicides has the potential to violate water quality standard regulations or degrade water quality . The CalVTP PEIR found that the use of herbicides has a less-than-significant impact on water quality because herbicide application is tightly regulated, applied in accordance with label instructions and legal requirements, and subject to SPRs that include buffer zones, timing restrictions, and site-specific planning to prevent contamination of water bodies. Because the proposed herbicide treatments are consistent with those evaluated in the PEIR, potential impacts to water quality are considered within the scope of the CalVTP and have been fully addressed through regulatory safeguards and SPRs. The SPRs applicable to this treatment are AD-3, BIO- 1, BIO-4, GEO-1, HAZ-1, HAZ-5, HAZ-6, HAZ-7, HYD-1, HYD-4, and HYD-5. All applicable SPRs listed, except

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SPRs HYD-5, HAZ-5, HAZ-6, and HAZ-7, are described in Impacts HYD-1 through Impact HYD-3. SPR HYD-5 prohibits non-aquatic herbicide formulations from being applied within 50 feet of a waterbody or riparian area and prohibits application during precipitation or within 24 hours of forecasted precipitation. SPRs HAZ-5, HAZ-6, and HAZ-7 ensure that a spill prevention and response plan is implemented, that herbicide application regulations are followed, and that herbicide containers are triple rinsed. These SPRs avoid and minimize the risk of substantial water quality degradation by implementation of herbicide treatment, thereby making the impacts less than significant.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the Project constitutes a change to the geographic extent presented in the PEIR. As mentioned in Impact HYD- 1, a few segments of the project treatment areas that are located outside the CalVTP treatable landscape are in close proximity to waterbodies entirely or partially outside the treatable landscape boundary.

However, within the boundary of the project area, the existing environmental conditions present in the areas outside the treatable landscape are es sentially the same as those within the treatable landscape because they have similar environmental conditions and the same regulatory setting. Potential impacts outside the treatable area are within the scope of the activities and impacts addressed in the PEIR because the methods of herbicide application, transportation, storage, and disposal are consistent with those analyzed in the PEIR with implementation of the same SPRs. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.10.1.5. Impact HYD-5
Some of the project treatments could cause ground disturbance and minor erosion, which could directly or indirectly modify existing drainage patterns. The PEIR analyzed the potential for treatments to violate water quality standard regulations or degrade water quality, and the impacts were found to be less than significant. As described in the PEIR, these activities would have minor impacts to on -site drainage with implementation of SPRs. The potential impacts are within the scope of the activities and impacts addressed in the PEIR because the use of equipment and treatment activities are consistent with those analyzed in the PEIR. SPRs applicable to this treatment are AD -3, BIO-4, GEO-1 through GEO-7, HYD-1, HYD-2, HYD-4, and HYD-6. All applicable SPRs listed are described in Impacts HYD-1 through HYD-4. These SPRs would avoid and minimize the risk of substantial alteration of the existing drainage pattern, thereby making the impact less than significant.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. As mentioned in Impact HYD-1, a few segments of the project treatment areas that are located outside the CalVTP treatable landscape are in close proximity to waterbodies entirely or partially not outside the treatable landscape boundary. However, within the boundary of the project area, the existing environmental conditions present in the areas outside

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the treatable landscape are essentially the same as those within the treatable landscape, and existing drainage patterns pass through both areas. Therefore, the impact related to alteration of site drainage patterns is also the same. The potential for thos e treatments to substantially alter the existing drainage patterns of the treatable landscape was evaluated in the PEIR and was found to be less than significant w i t h i m p l e m e n t a ti o n o f t h e s a m e S P R s . T h i s d e t e r m i n a ti o n i s c o n s i s t e n t w i t h t h e P E I R a n d w o u l d not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.10.1.6. New Hydrology and Water Quality Impacts
All proposed treatments are consistent with the treatment types and activities addressed in the PEIR. The site-specific characteristics of the proposed treatment project are consistent with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (Sections 3.11.1, Regulatory Setting, and 3.11.2, Environmental Setting, in Volume II of the Final PEIR). The inclusion of approximately 93 acres of land that is outside of the treatable landscapes constitutes a change to the geographic extent presented in the PEIR. However, the hydrology, water quality, and treatment methods are consistent with those analyzed in the PEIR; thus, they are also within the scope of the PEIR. Additionally, the existing environmental and regulatory conditions p ertinent to hydrology and water quality are also consistent within as well as outside of the treatable landscape included in the project area. No changed circumstances would create new significant impacts not addressed in the PEIR, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact related to hydrology and water quality would occur.

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4.11. Land Use and Planning, Population, and Housing
Table 12. Consistency of project-related land use and planning, population, and housing impacts with the scope of the Cal ifornia Vegetation Treatment Program Programmatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact LU-1: Cause a Significant
Environmental Impact Due to a
Conflict with a Land Use Plan, Policy,
or Regulation
LTS
Impact LU-1,
pp. 3.12-13–

3.12-14
Yes AD-3 N/A LTS No Yes
Impact LU-2: Induce Substantial
Unplanned Population Growth LTS
Impact LU-2,
pp. 3.12-14–

3.12-15
Yes N/A N/A LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Land Use and Planning, Population, and Housing Impacts: Would the treatment result in other impacts to land use and planning, population and housing that are not evaluated in the CalVTP PEIR? ☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.11.1. Discussion

4.11.1.1. Impact LU-1
Initial treatment and treatment maintenance activities would take place in th e City in Alameda County.

Landowners include the City, Golden Eagle Estates, and the East Bay Regional Park District . SPR AD -3 (Consistency with Local Plans, Policies, and Ordinances) requires that the project proponent design and implement the treatment in a manner that is consistent with applicable local plans (e.g., general plans), policies, and ordinances to the extent the Project is subject to them. The Project would be consistent with the Pleasanton General Plan (City of Pleasanton 2009 ) and the Alameda County General Plan (Alameda County 1994), which contain goals and policies relating to fire protection and wildland fire prevention. As described in the project description and Section 4.12, Noise, noise-generating treatment activities would occur during daytime hours and would be consistent with the local ordinances of the City and Alameda County.

Land parcels within the treatment area are classified as “Low Density Residential,” “Agriculture,” “Single- Family Residential,” and “Open Space” (City of Pleasanton n.d .). The CalVTP PEIR determined that the potential for treatment activities to conflict with land use plans, policies, or regulations would result in a less than significant impact because all vegetation treatments must be designed to comply with applicable local, regional, and state land use requirements. The potential for vegetation treatment activities to cause a significant environmental impact is within the scope of the PEIR because the treatment types and activities are consistent with those evaluated in the PEIR. SPR AD-3 is applicable to the proposed project, and it requires proposed project treatments to be consistent with local plans, policies, and ordinances.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent considered in the PEIR. However, because the land uses in the project area are generally the same within and outside the treatable landscape, the land use impact is also the same. Furthermore, no conflict would occur because the project proponent would adhere to SPR AD -3. This determination is consistent with the PEIR and would not constitute a more severe impact than that which is described in the PEIR.

4.11.1.2. Impact LU-2
The PEIR found the impact of vegetation treatments on population growth to be less than significant because the work is temporary, relies on local labor, and does not induce long- term housing or infrastructure development. Impacts associated with a short -term increase in the demand for workers during implementation of the treatment project are within the scope of the PEIR because the number of workers required for the proposed project is c onsist ent with the crew siz e analyz ed in the PEIR f or the types of tr eatments proposed. Additionally, as evaluated in the PEIR, the workforce needed for project

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treatments and maintenance can largely be met by hiring local residents near the treatment areas. While some employees may relocate to meet workforce demands, adequate housing is expected to be available to accommodate those who move from outside the region.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the project treatment area is considered a change to the geographic extent presented in the PEIR. However, because the population and housing characteristics of the project area are similar both within and outside the treatable landscape, the population and housing impact is also the same, as described above. There are no SPRs applicable to this impact. This determination is consistent with the PEIR and would n ot constitute a substantially more severe significant impact than that which was evaluated in the PEIR.

4.11.1.3. New Land Use and Planning, Population, and Housing Impacts The proposed project is consistent with the treatment types and activities described in the CalVTP PEIR.

The project proponent has considered the site -specific characteristics of the proposed project and determined they are consistent with the applicable environmental and regulatory conditions described in the CalVTP PEIR (refer to Sections 3.12.1, Environmental Setting, and 3.12.2, Regulatory Setting, in Volume II of the Final PEIR). The project proponent has also determined that including land that is outside the treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, within the project area boundary, the existing conditions relevant to land use and planning, population, and housing that are present in the areas outside the treatable landscape are very similar to those within the treatable landscape; therefore, the impacts of the p roposed project are also consistent with those analyzed in the PEIR. No changed circumstances are present , and the inclusion of lands outside the CalVTP treatable landscape would not result in any new significant impacts.

In conclusion, no new impact related to land use and planning, population, and housing would occur.

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4.12. Noise
Table 13. Consistency of project-related noise impacts with the scope of the Cal ifornia Vegetation Treatment Program P rogrammatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

Impact NOI-1: Result in a Substantial
Short-Term Increase in Exterior
Ambient Noise Levels During
Treatment Implementation
LTS
Impact NOI-1,
pp. 3.13-9–

3.13-12;
Appendix
NOI-1
Yes
AD-3, NOI-
1, NOI-2,
NOI-3, NOI-
4, NOI-5,
NOI-6
NOI-1 LTSM No Yes
Impact NOI-2: Result in a Substantial
Short-Term Increase in Truck-
Generated Single-Event Noise Levels
(SENLs) During Treatment Activities
LTS Impact NOI-2,
p. 3.13-12 Yes
AD-3, NOI-
1, NOI-2,
NOI-3, NOI-
4, NOI-5,
NOI-6
NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Noise Impacts: Would the treatment result in other noise-related impacts that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.12.1. Discussion

4.12.1.1. Impact NOI-1
The project treatment activities that have the potential for short -term increase in ambient noise level include manual treatments and ground -based mechanical treatments. Prescribed herbivory would potentially occur 24 hours a day, but as noted in the PEIR, it would not require the use of heavy off-road equipment. Although noise generated by prescribed herbivory would be generally negligible, it is discussed further in this section as the local jurisdictions where the Project is located have ordinances specifically related to animal noise.

The manual treatments for this project include hand -operated power tools, and the mechanical treatments include but are not limited to bucket trucks, tow chippers, track chippers, fire engines, and riding lawn mowers. Manual and mechanical treatments would occur on weekdays during daylight hours only. Table 11 -5 of the City of Pleasanton General Plan (City of Pleasanton 2009) and Figure 2 of the Alameda County General Plan (Alameda County 1994) present noise restrictions within the project area.

When work would be conducted within these jurisdictions with more restrictive noise ordinances, manual and mechanical treatments would only be conducted within the allowable hours for noise -generating activities. Multiple crews may be working at the same time and using mechanical and manual methods that may generate varying noise levels, temporarily increasing ambient noise in the vicinity. Du e to the nature of the proposed project, private residences and other noise-sensitive land uses are located adjacent to the P roject and treatment areas and would temporarily be exposed to noise. The Project would fall within jurisdictions of both the City and unincorporated Alameda County. The potential for treatment activities to cause substantial short -term increases in exterior ambient noise level was addressed in the PEIR and was found to be less than significant. This impact is within the scope of the PEIR because the types of treatments and associated equipment, and thus the noise generated, are consistent with those analyzed in the PEIR. SPRs applicable to the proposed project include AD-3, which requires the treatments to be consistent with local plans, policies, and ordinances. As described in the project description, all treatments except herbivory would occur primarily on weekdays during daylight hours only.

Alameda County (§ 6.60.050) and the City (§ 7.08.010) have animal noise ordinances which prohibit the keeping of animals which frequently or continuously generate noise deemed to disturb any reasonable person’s peace and quiet. Animals used for herbivory treatment may make noises that could violate these ordinances; however, this is considered unlikely. MM NOI -1 would require posting of signs during herbivory treatment specifying who to contact regarding noise complaints. The City would take into consideration future use of herbivory treatments in areas that receive noise complaints. With implementation of MM NOI-1, the impact of animal noises would be in line with the local ordinances and be less than significant with mitigation.

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• MM NOI-1: Avoid Conflicts with Local Noise Ordinances During Prescribed Herbivory Prior to commencing prescribed herbivory treatments, the City would post signs containing contact information, including a daytime telephone number, of the project representative, who may be contacted regarding noise complaints. The City would take into consideration future use of herbivory treatments in areas that receive noise complaints and may adjust the limits of treatment areas to be further from sensitive receptors.

Noise-generating treatments would be within the Alameda County and the City construction noise requirements. The Alameda County noise ordinance ( § 6.60.120) identifies that construction noise is permitted between 7 a.m. and 7 p.m. on weekdays and 8 a.m. and 5 p.m. on weekends. The City noise ordinance (§ 9.04.100) identifies that construction noise is exempt b etween the hours of 8:00 a.m. and 8:00 p.m. daily, except Sunday and holidays, when the exemption shall apply between 10:00 a.m. and 6:00 p.m. Noise-generating treatments would comply with the local regulations outlined in Table 11-5 of the City of Pleasanton General Plan (City of Pleasanton 2009) and Figure 2 of the Alameda County General Plan (Alameda County 1994), and, therefore, all work would be within the allowable limits, per SPR AD-3.

Additional SPRs applicable to the proposed project include NOI-1, NOI-2, NOI-3, NOI-4, NOI-5, and NOI-6.

SPRs NOI-1 through NOI -6 would require that heavy equipment be used only during daytime h ours, all equipment be properly maintained, engine shrouds be closed during mechanical equipment operation and idle time be restricted to 5 minutes, all staging areas be placed away from noise sensitive land types, and any noise sensitive receptors be notified ahead of work to ensure impacts to ambient noise levels would be less than significant.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. The northernmost portion of the Project is further from the treatable landscape than other portions of th e Project; however, the added acreage would not expand the total annual acreage of 250,000 acres per year proposed for treatment under the PEIR. The existing environmental conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape because they would be subject to the same noise ordinances and would have similar noise -sensitive receptors.

Therefore, the noise impact is also the same, as described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.12.1.2. Impact NOI-2
Project treatment activities would require large trucks to haul equipment, crews, and livestock to the project site. While trucks would pass residential sensitive receptors, it is not anticipated that project traffic would result in a substantial increase in truck-generated noise along local roads. These large trucks have

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the potential for a substantial short-term increase in SENLs, but haul trucks would only be in use during daytime hours, generally Monday through Friday, and in compliance with other more stringent local noise ordinances (see Impact NOI-1). The SENL descri bes a receiver’s cumulative noise exposure from a single impulsive noise event (e.g., an automobile passing by or an aircraft flying overhead), which is defined as an acoustic event of short duration and involves a change in sound pressure above some reference value.

The impacts are within the scope of the PEIR because the treatment activities and methods are the same as those analyzed in the PEIR. SPRs applicable to this treatment are AD-3, NOI-1, NOI-2, NOI-3, NOI-4, NOI- 5, and NOI-6, described under Impact NOI -1. The potential for a substantial short -term increase in SENL during the project treatments was evaluated in the PEIR and was found to be less than significant with the implementation of these SPRs.

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. As described in Impact NOI-1, the northernmost portion of the Project is further from the treatable landscape than other portions of the Project. For much of the Project area, the existing roadway network and access roads used by the worker vehicles and trucks for hauling would be the same to reach the treatable landscape inside the CalVTP as outside the CalVTP . For portions of the project area that are further from CalVTP treatable landscape areas, like the northernmost portion, the types of sensitive receptors located along existing roads and access roads would be the same as those covered in the PEIR. Therefore, the noise impact is also the same as described above and would be less than significant with the application of the same SPRs. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

4.12.1.3. New Noise Impacts
The proposed treatment is consistent with the treatment types and activities discussed in the PEIR. The site-specific characteristics of the proposed treatments are consistent with the applicable environmental and regulatory conditions presented in the Cal VTP PEIR (Sections 3.13.1, Environmental Setting , and

3.13.2, Regulatory Setting, in Volume II of the Final PEIR).

The inclusion of approximately 9 3 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, the existing environmental and regulatory conditions pertinent to noise that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape, as previously described. The Project is consistent with the types of projects covered in the PEIR. The local jurisdictions where the Project would occur have specific noise ordinances related to noise from animals.

The potential for animals used for herbivory treatments to violate local noise ordinances for animals was not specifically addressed in the PEIR but is analyzed in impact NOI-1 above. This would be considered a

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new impact. An additional MM, MM NOI-1, has been included for the Project, which would reduce the impact to less than significant. With inclusion of this MM, no new significant impacts would occur.

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4.13. Recreation
Table 14. Consistency of project-related recreation impacts with the scope of the Cal ifornia Vegetation Treatment Program P rogrammatic Environmental Impact Report.

Impact in the PEIR Project-Specific Checklist
Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

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

3.14-7
Yes REC-1 NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Recreation Impacts: Would the treatment result in other impacts to recreation that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.13.1. Discussion

4.13.1.1. Impact REC-1
Initial treatment and treatment maintenance activities would take place on land in and adjacent to the City and unincorporated Alameda County. Some portions of the pr o j e c t a r e a a r e d e s i g n a t e d b y t h e relevant jurisdictions as open space and/or parks and recreation space. Access to some treatment areas would rely on unpaved roads, which are sometimes used as recreational trails. The potential for treatment activities to directly or indirectly disrupt recreational activities within designated recreation areas was evaluated in the PEIR and found to be less than significant. The potential for vegetation treatment and maintenance activities (including prescribed fire) to cause a significant environmental impact is within the scope of the PEIR because the treatment types and activities are consistent with those evaluated in the PEIR. SPR AD-3 is applicable to the proposed project, and it requires proposed project treatments to be consistent with local plans, policies, and ordinances relevant to recreation, which inc lude general plans, zoning ordinances, and adopted policies to avoid conflicts with recreational uses. SPR REC-1 is applicable to the proposed project, and it requires the project proponent to coordinate with the owner/manager of any recreation area or facility that would be temporarily closed during treatment activity, including posting notifications at least 2 weeks prior to the commencement of the treatment activities. The potential for the proposed treatment project to impact recreation is within the sc ope of the PEIR and would be less than significant because the treatment activities and intensity are consistent with those analyzed in the PEIR.

The inclusion of land that is outside the CalVTP treatable landscape in the proposed treatment area (92.5 acres) constitutes a change to the geographic extent presented in the PEIR. However, the availability of recreational resources within the project area is essentially the same as outside the treatable landscape because the areas are near to each other and the recreational users would be the same. Impacts to recreation would be the same as previously described and would be less than significant. Implementation of SPRs AD-3 and REC-1 would minimize disruption to recreational activities within the project area. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than covered in the PEIR.

4.13.1.2. New Recreation Impacts
The proposed project is consistent with the treatment types and activities considered in the CalVTP PEIR.

The site- specific characteristics of the proposed treatments are consistent with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Sections 3.14.1, Environmental Setting, and 3.14.2, Regulatory Setting, in Volume II of the Final PEIR).

The inclusion of land that is outside the treatable landscape in the proposed treatment area (92.5 acres) constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the

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project area, the existing environmental conditions pertinent to recreation that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape, as described previously. The proposed project is consistent with the types of projects covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact related to recreation would occur.

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4.14. Transportation
Table 15. Consistency of project-related transportation impacts with the scope of the California Vegetation Treatment Program Programmatic Environmental Impact Report.

Environmental Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:

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

3.15-10
Yes AD-3,
TRAN-1 NA LTS No Yes
Impact TRAN-2: Substantially
Increase Hazards due to a Design
Feature or Incompatible Uses
LTS
Impact TRAN-
2, pp. 3.15-
10–3.15-11
Yes AD-3,
TRAN-1 NA LTS No Yes
Impact TRAN-3: Result in a Net
Increase in vehicles miles travelled
(VMT) for the Proposed CalVTP
PSU
Impact TRAN-
3, pp. 3.15-
11–3.15-13
Yes NA AQ-1 SU No Yes
1NA: Not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.

New Transportation Impacts: Would the treatment result in other impacts to transportation that are not evaluated in the CalVTP PEIR? ☐ Yes ☒ No If yes, complete row(s)
below and discussion
Potentially Significant Less than Significant with
Mitigation Incorporated Less than Significant
☐ ☐ ☐

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4.14.1. Discussion

4.14.1.1. Impact TRAN-1
Initial treatment and treatment maintenance activities would take place within and adjacent to Augustin Bernal Community Park in Alameda County, California. The Project would require limited vehicular traffic along public roadways used to access existing fire roads and trails leading to the specific treatment areas.

Project-related traffic would include heavy -vehicle trips to haul equipment and materials and w orker commute trips to and from the treatment areas. Crew sizes would typically be less than 25 wor kers per site, although multiple teams may be working at the same time. Crews would not be more than 45 workers for prescribed burns. All treatments except herbivory would occur primarily on weekdays during daylight hours only. During prescribed burning, crews would need to conduct some maintenance burning on weekends to manage overall smoke impacts. As described in the project description and Section 4.12, “Noise,” noise-generating treatment activities would occur during daytime hours and would be consistent with the local ordinances of the City and Alameda County. Therefore, the increase of vehicle traffic on the surrounding local roads would occur during allowed construction hours.

The number of truck trips and worker vehicle trips to and from the project area would vary based on the size of the area being treated, the type of treatment being implemented, and the duration of the vegetation treatments. No road closures would be necessary for the implementation of this project. The CalVTP PEIR found traffic impacts to be less than significant because vehicle increases and road closures during vegetation treatments are short-term, use existing roads, and are managed through traffic plans, agency coordination, and safety measures t hat prevent conflicts with transportation policies. The proposed temporary increases in traffic related to the Project are within the scope of the PEIR because the treatment duration and limited number of vehicles associated with the proposed treatments are consistent with those analyzed in the PEIR. The proposed treatments would not all occur concurrently, and increases in vehicle trips associated with the treatments , particularly relating to commuting workers, would be dispersed on multiple roads as the distance from the Project Site increases. SPRs applicable to this treatment are AD -3 and TRAN -1. Implementing SPR AD -3 requires the treatments to be consistent with local plans, policies, and ordinances, and SPR TRAN-1 requires that the project proponent implement a traffic management plan (TMP) and that traffic control measures be placed on affected roadways during Project treatment activities. With the implementation of these SPRs, the determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.

The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area constitutes a change to the geographic extent presented in the PEIR. However, the existing transportation conditions (e.g., roadways, road use) present in the areas outside the treatable