Agenda packet, regular meeting — Pleasanton City Council, April 21, 2026 (part 4 of 7)

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landscape are essentially the same as those within the treatable landscape because they continue from roadways from within the treatable landscape and are under the same jurisdictions and would be subject to the same programs, plans, ordinances, or policies regarding roadway facilities and closures. Therefore, the transportation impact is also the same and would be less than signiﬁcant with the implementation of the same SPRs. 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.

4.14.1.2. Impact TRAN-2
The project treatment activity that would have the potential to increase transportation hazards during proposed treatment and maintenance activities would be the use of prescribed burning due to the smoke produced, which could temporarily aﬀect visibility on nearby roadways. The CalVTP PEIR found smok e- related visibility impacts from prescribed burning to be less than signiﬁcant because burns are carefully planned and regulated through SMPs , weather-based burn scheduling, and traﬃc safety protocols that minimize risks near roadways. Vegetation piles for burning would not exceed 20 feet in diameter.

Prescribed and pile burning would be conducted in compliance with CAL FIRE and the BAAD Regulation 5 for open burning and burn day restrictions. 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 pr escribed burning in California. Moreover, project treatments would reduce the density of vegetation along roads and trails, improving line of sight and safety of motorists. SPRs applicable to this treatment are AD -3 and TRAN-1, described under Impact TRAN -1. The project proponent would prepare and implement a TMP to avoid and minimize temporary transportation impacts under this SPR. SPR TRAN -1 would also require the project proponent to m onitor prescribed burning operations and the associated smoke dispersion. Therefore, the project treatment activities would not substantially increase hazards due to a design feature or incompatible uses, and impacts would be less than signiﬁcant. 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.

The project area includes approximately 93 acres of land that is outside the CalVTP treatable landscape.

While this constitutes a change to the geographic area considered in the PEIR, the existing environmental conditions for the land outside the treatable landscape and on the land within the treatable landscape are essentially the same. Further, the existing transportation conditions (e.g., roadways, road use) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape because they continue beyond the treatable landscape. Therefore, the potential to increase hazards is the same for project areas outside the CalVTP treatable landscape as for areas within the treatable landscape.

As a result, the impact to increased hazards is also the same and within the scope of the PEIR. The Project would result in a less-than-signiﬁcant impact related to increasing road hazards and would not result in a more signiﬁcant impact than covered in the PEIR.

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4.14.1.3. Impact TRAN-3
The project treatments could temporarily increase VMT above baseline conditions because the project access locations are in residential areas with small, local roadways, requiring vehicle trips to access the treatment areas. Project-related traﬃc would include heavy-vehicle trips to haul equipment and materials as well as worker commute trips to and from the treatment areas. 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. Should vehicles be given landowner consent to stage on-site or in close proximity, the most VMT would occur at the beginning and end of the Project to haul equipment in and out of the project area. Daily VMT would largely consist of crew transportation to and from the site and, potentially, hauling removed material. This impact was identiﬁed as potentially signiﬁcant and unavoidable in the PEIR because implementati on of the CalVTP would result in a net increase in VMT. However, as stated in Impact TRAN-3 of the PEIR, individual projects under the CalVTP are likely to generate fewer than 110 trips per day, which is expected to cause a less - than-signiﬁcant transportation impact for speciﬁc later activities, as described in the Technical Advisory on Evaluating Transportation Impacts published by the Governor’s Oﬃce of Planning and Research (Governor’s Oﬃce of Planning and Research 2018). According to the analysis methodologies presented in the PEIR, projects that generate or attract fewer than 110 trips per day generally may be assumed to cause a less-than-signiﬁcant transportation impact. As presented in the PEIR, this amount would allow for up to 50 vehicles bringing crews and equipment to and from the project site and hauling materials away in a single day. Because of the small sizes of the crews needed for the proposed project (not more than 45 workers), the limited equipment needed, and the limited materials to be hauled in any one day, the total VMT would not exceed 110 trips per day. Initial t reatment would likely involve more vehicle trips than subsequent maintenance. Additionally, vehicle trips for commuting workers would be dispersed across multiple roadways, particularly as distance increases from the project site. Hiring local contractors would be encouraged where feasible to reduce the amount of VMT.

Although the PEIR determined that individual vegetation treatments would likely be less than signiﬁcant, the overall impact was identiﬁed as potentially signiﬁcant in the PEIR because implementation of the CalVTP would result in a net increase in VMT attributable to the program as a whole. Because the Project would generate VMT during implementation, it would contribute to the environmental signiﬁcance conclusion in the PEIR; therefore, this impact is considered signiﬁcant and unavoidable. No SPRs apply to this impact. As discussed for Impact AQ-1 in Section 4.3, Air Quality, the City would implement MM AQ-1 to the extent feasible. MM AQ-1 would reduce the impact by encouraging workers to carpool and/or use public transportation. However, due to the required equipment and number of employees (i.e., the primary trip-generators associated with vegetation treatments) associated with the Project, it would not be feasible to reduce VMT substantially. Therefore, the impact would remain signiﬁcant and unavoidable.

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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 transportation conditions (e.g., roadways, road use) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape because they continue beyond the treatable landscape. Therefore, the transportation impact identiﬁed in the PEIR for individual projects is also the same, as described above, and would be signiﬁcant and unavoidable.

4.14.1.4. New Impacts on Transportation
The proposed treatments are consistent with the treatment types and activities covered 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 3.15.1, Environmental Setting, and 3.15.2, Regulatory Setting, in Volume II of the Final 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 environmental conditions pertinent to transportation that are present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape, as previously described. The proposed project is consistent with the types of projects covered in t he 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 transportation would occur.

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4.15. Public Services, Utilities, and Service Systems
Table 16. Consistency of project-related public services, utilities, and service systems 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 UTIL-1: Result in Physical
Impacts Associated with Provision of
Suﬃcient Water Supplies, including
Related Infrastructure Needs
LTS Impact UTIL-1,
p. 3.16-9 Yes NA NA LTS No Yes
Impact UTIL-2: Generate Solid Waste
in Excess of State Standards or Exceed
Local Infrastructure Capacity
PSU
Impact UTIL-2,
pp. 3.16-10–

3.16-12
Yes AD-3, UTIL-1 NA LTS No Yes
Impact UTIL-3: Comply with Federal,
State, and Local Management and
Reduction Goals, Statutes, and
Regulations Related to Solid Waste
LTS Impact UTIL-2,
p. 3.16-12 Yes AD-3, UTIL-1 NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identiﬁed in the PEIR for this impact.

New Public Services, Utilities, and Service System Impacts: Would the treatment result in other impacts to public services, utilities and service systems 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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4.15.1. Discussion

4.15.1.1. Impact UTIL-1
The proposed p roject would include the following treatment activities: prescribed burning ( pile and broadcast), mechanical treatment (mowing, chipping and broadcasting vegetation), manual treatment (using hand tools and hand -operated power tools such as hand saws, pol e saws, McLeods, brush cutter, etc.), targeted herbicide application, and biomass disposal. A minimal amount of water would be required for ﬁre suppression during prescribed and pile burning activities and for dust control during mechanical treatments. Depending on the location of the prescribed burning, pile burning, or mechanical treatments, water would be supplied via nearby ﬁre hydrants or be transported via ﬁre trucks. The CalVTP PEIR found increased water demand for vegetation activities to be a less-than-signiﬁcant impact because vegetation treatments use minimal water and rely on existing sources without straining local supplies. The Project’s impacts are consistent with those analyzed in the PEIR because the amount of water required for prescribed burning and dust control is within the scope of activities and impacts determined in the PEIR.

Due to the minimal amount of water required for these treatment activities, there would be minimal water demand on local water providers. 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.

The proposed p roject includes approximately 93 acres of land that is outside the CalVTP treatable landscape in the proposed treatment area, which constitutes a change to the geographic extent presented in the PEIR. The conditions outside the treatable landscape area are similar to those within it, primarily because they rely on the same water service providers and usage patterns. As such, the potential impacts are already addressed by the PEIR and would be considered a less than signiﬁcant impact. 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.

4.15.1.2. Impact UTIL-2
Mechanical and manual vegetation treatments would generate organic woody biomass as a result of vegetation removal within the project treatment areas. Methods for managing biomass for th e Project include natural decomposition (e.g., chip and broadcast, lop and scatter), chipping and hauling, and pile burning. Any biomass not broadcast on -site or pile burned would be taken oﬀ -site to an appropriate biomass-processing facility, such as the Pleasanton Garbage Service, Inc. The CalVTP PEIR found that solid waste generation from vegetation treatments would be less than signiﬁcant because most biomass is either left on-site, burned, or reused (e.g., for mulch or energy), and any waste generated is minimal and managed in compliance with state disposal standards. The potential biomass impact is within the scope of

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the activities and impacts identiﬁed in the PEIR as the conditions for removing biomass are consistent with the analysis in the PEIR. SPRs AD-3 and UTIL -1 would be implemented . S P R A D-3 requires the project proponent to design and implement the Project consistent with local plans and ordinances, and SPR UTIL- 1 requires the project proponent to prepare a Solid Organic Waste Disposition Plan to guide biomass disposal.

The PEIR found that while some localities within the state may currently have the requisite infrastructure to process woody biomass or may develop this capacity in the near future, it cannot be guaranteed that all localities across the state would develop the capacities to process excess solid organic waste produced from treatment activities within the timeframes of the proposed activities. Because no feasible mitigation is available, and to avoid downplaying potential future impacts given uncertainties around market response, the PEIR classiﬁed the impact as potentially signiﬁcant and unavoidable. This classiﬁcation stands despite the possibility that treatment capacity could scale suﬃciently to accommodate most or all individual treatments. The Pleasanton Garbage Service Inc. and additional biomass -processing facilities are located within 5 miles of the proposed project. Therefore, the impact to solid waste disposal is less than signiﬁcant. This determination is consistent with the PEIR and would not constitute a substantially more severe impact than identiﬁed in the PEIR.

The proposed p roject includes land that is outside the CalVTP treatable landscape in the proposed treatment area, which constitutes a change to the geographic extent presented in the PEIR. However, the environmental conditions outside the treatable landscape are essentially the same as those within the treatable landscape because they a re adjacent to the treatable landscape, would generate a similar amount of solid waste, and would use the same biomass disposal methods. SPRs AD-3 and UTIL-1 would be implemented to ensure consistency with local plans and ordinances and ensure implementation of a Solid Organic Waste Disposition Plan. This proposed project reﬂects a lesser impact than the statewide program, and the determination is consistent with the PEIR and would not constitute a substantially more severe impact than identiﬁed in the PEIR.

4.15.1.3. Impact UTIL-3
Project treatments as a result of vegetation removal within the project site would generate biomass, which would be disposed of by natural decomposition (e.g., chip and broadcast, lop and scatter), hauling oﬀ-site, and pile burning. The CalVTP PEIR found solid waste impacts to be less than signiﬁcant because vegetation treatments produce minimal waste, reuse most biomass, and follow all disposal regulations through SPRs.

The Project is within the scope of activities and impacts identiﬁed in the PEIR, as it uses the same methods of biomass generation that are outlined in the PEIR. Biomass from the Project not disposed on-site would be hauled oﬀ-site to the nearest appropriate facility (Pleasanton Garbage Service, Inc.) and would not be placed in a landﬁll. The Project would be in compliance with federal, state, and local goals related to solid

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waste, as required by SPR AD-3. The Project would apply SPR UTIL-1, which requires implementation of a Solid Organic Waste Disposition Plan.

The inclusion of approximately 93 acres of land outside the treatable landscape constitutes a change to the geographic extent of the PEIR. However, the environmental conditions outside the treatable landscape are essentially the same as those within the treatable landscape because they are adjacent to the treatable landscape, would generate a similar amount of solid waste, and would use the same biomass disposal methods and facilities. Therefore, the impact related to compliance with federal, state, and local goals and regulations regarding solid waste is 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.

4.15.1.4. New Impacts on Public Services, Utilities, and Service Systems The proposed treatments are consistent with the treatment types and activities considered in the PEIR.

The site- speciﬁc characteristics of the proposed treatments have been considered and found to be consistent with the applicable environmental and regula tory conditions presented in the CalVTP PEIR (refer to Sections 3.16.1, Environmental Setting, and 3.16.2, Regulatory Setting, in Volume II of the Final PEIR). 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, the conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape, as described above. Therefore, the impacts of the 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 signiﬁcant impacts not addressed in the PEIR.

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4.16. Wildﬁre
Table 17. Consistency of project-related wildﬁre impacts with the scope of the Cal ifornia Vegetation Treatment Program P rogrammatic Environmental Impact Report.

Impact WIL-1: Substantially
Exacerbate Fire Risk and Expose
People to Uncontrolled Spread of a
Wildﬁre
LTS
Section

3.17.1;
Impact WIL-1
pp. 3.17-14–

3.17-15
Yes
AD-3, HAZ-
2, HAZ-3,
HAZ-4
NA LTS No Yes
Impact WIL-2: Expose People or
Structures to Substantial Risks
Related to Postfire Flooding or
Landslides
LTS
Section

3.17.1;
Impact WIL-2
pp. 3.17-15–

3.17-16
Yes
AD-3, AQ-3,
GEO-3,
GEO-4,
GEO-5
NA LTS No Yes
1NA: Not applicable; there are no SPRs and/or MMs identiﬁed in the PEIR for this impact.

New Wildﬁre Impacts: Would the treatment result in other impacts related to wildﬁre 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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4.16.1. Discussion

4.16.1.1. Impact WIL-1
The Project would create and maintain a 162-acre reduced fuel zone within and adjacent to Augustin Bernal Community Park on Pleasanton Ridge in Alameda County, California. The Project would reduce ladder fuels within a shaded fuel break and WUI, ranging from 100 to 400 feet wide, creating safer ﬁre road access for ﬁrst responders and community members.

Initial and maintenance treatments would include prescribed burning (pile and broadcast) and mechanical treatments, which could result in temporary risks associated with uncontrolled wildﬁre, accidental wildﬁre ignition, or risk of a prescribed ﬁre escaping its control lines. The CalVTP PEIR found wildﬁre risk during treatment implementation to be a less-than-signiﬁcant impact because activities are conducted under strict safety protocols and planning that prevent increased ﬁre hazards. The Project is covered under the PEIR because prescribed pile and broadcast burning, along with the use of heavy equipment in vegetated areas, are activities included within its scope. SPRs HAZ-2, HAZ-3, HAZ-4, and AD-3 would be implemented to reduce the risk of exposure to wildﬁre by requiring spark arrestors on mechanical hand tools, requiring crews to carry one ﬁre extinguisher per chainsaw, prohibiting smoking in vegetated areas, and requiring consistency with local plans, policies, and ordinances. Based on the imp lementation of the SPRs, the potential to substantially exacerbate ﬁre risk and expose people to uncontrolled spread of wildﬁre would be less than signiﬁcant and within the scope of the PEIR.

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

4.16.1.2. Impact WIL-2
Initial and maintenance treatments would include prescribed burning (pile and broadcast), mechanical treatment using motorized equipment, and prescribed herbivory. The CalVTP PEIR found post -ﬁre ﬂooding, erosion, and landslide risks to be a less than signiﬁcant impact because treatments are designed to reduce fuel loads and are implemented with erosion control measures and site -speciﬁc planning that minimize soil disturbance and runoﬀ. The Project is within the scope of the PEIR, as its activities are consistent with those analyzed in the document. Mechanical treatment activities would occur predominantly on slopes below 40 percent grade and along ridges and may occur on slopes greater than 40 percent grade with equipment that can reach ta rget vegetation from existing road infrastructure.

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Mechanical treatments would not be applied on slopes above 50 percent. Implementation of SPRs AD-3, AQ-3, and GEO -3 through GEO -5 would reduce the risk of erosion and landslides post -prescribed burn and/or post-ﬁre, in the event that a wildﬁre occurred a s a result of the proposed treatments or an unrelated occurrence. Implementation of AD -3 would ensure consistency with local plans, policies, and related ordinances. Implementation of SPR AQ -3 would minimize soil burn severity during prescribed burns, which would help to retain vegetation to stabilize the soil. SPR GEO-3 would require stabilization of disturbed soil areas during treatment activities, SPR GEO-4 would require inspection of the treatment area for proper erosion control measures prior to the rainy season and immediately following the ﬁrst large rainfall event, and SPR GEO-5 would require stormwater to be drained via water breaks to decrease the potential for channelized erosion within linear treatment areas. As described in Impact WIL-1, this project intends to create and maintain a reduced fuel zone, which may lead to smaller burn scars, or less area susceptible to post-ﬁre ﬂooding or erosion.

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 post -ﬁre landslide risk of the project area is es sentially the same within and outside the treatable landscape due to similar slopes, soils, and hydrological and geological conditions. Therefore, the wildﬁre impact outside the treatable landscape is also the same and less than signiﬁcant, as described above, with implementation of the same SPRs. The impact outside the treatable landscapes would be consistent with the lands analyzed in the PEIR. The Project would not create any substantially more severe signiﬁcant impacts than identiﬁed in the PEIR.

4.16.1.3. New Impacts to Wildﬁre
The proposed treatments are consistent with the treatment types and activities considered in the PEIR.

The site- speciﬁc characteristics of the proposed treatments have been considered and found to be consistent with the applicable environmental and regula tory conditions presented in the CalVTP PEIR (refer to Sections 3.16.1, Environmental Setting, and 3.16.2, Regulatory Setting, in Volume 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 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 wildﬁre 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 signiﬁcant impacts. Therefore, no new impact related to wildﬁre risk would occur.

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5.0 LIST OF PREPARERS

5.1. The City of Pleasanton (Responsible Agency)
Matt Gruber City Landscape Architect
Sarah Hosterman Landscape Architect Assistant

5.2. Sequoia Ecological Consulting, Inc. (California Environmental Quality Act Compliance)
Debie Montana CEO and President/Principal Biologist
Stuart Poulter, AICP Wildﬁre Resilience & Environmental Program Manager/Senior Planner Alex Hirth Project Manager/Biologist/GIS Specialist
Soumya Suresh Biologist
Kelyn McGuire Biologist

5.3. Montrose Environmental (California Environmental Quality Act Compliance)
Ken Schwarz, Ph.D. Principal
Emma White Project Manager
Diana Roberts Senior Associate
Zachary Cornejo Senior Associate
Debra Lilly Senior Associate
Bridget Parry Archaeologist
Alexandria Fraser Associate
Susannah Kiteck Analyst

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6.0 REFERENCES
Alameda County. 2013. Alameda County General Plan Safety Element. https://www.alamedacountyca.gov/cda/planning/generalplans/documents/SafetyElement- updateapprovedbyBOS31722-FINAL.pdf.
———. 2023. Alameda County Climate Action Plan.
https://www.alamedacountyca.gov/sustain/documents/2023- 05AlamedaCountyClimateActionPlanforGovtServicesOperations.pdf.

Ascent Environmental. 2019. California Vegetation Treatment Program Final Program Environmental Impact Report. State Clearinghouse #2019012052. Sacramento: California Board of Forestry and Fire Protection. July 2025. https://bof.ﬁre.ca.gov/projects-and-programs/calvtp-homepage-and- storymap/.

Bard, J.C., Donna M. Garaventa, Michael R. Fong, Sondra Jarvis, Stuart Guedon, Robert Harmon, Conrad Praetzel, Melody Tannam, and Colin I. Busby. 1994. Limited Data Recovery Program, CA-CCO-309, the Rossmoor Site, City of Walnut Creek, Contra Costa County, California. On ﬁle at the Northwest Information Center, Sonoma State University. S- 16395.

Byrd, B.F., A.R. Whitaker, P .J. Mikkelsen, and J.S. Rosenthal. 2017. San Francisco Bay-Delta Regional Context and Research Design for Native American Archaeological Resources, Caltrans District 4.

Submitted to California Department of Transportation District 4, Oakland.

California Air Resources Board (CARB). 2019. Draft California 2030 Natural and Working Lands Climate Change Implementation Plan. http://ww2.arb.ca.gov/sites/default/ﬁles/2020-10/draft-nwl-ip- 040419.pdf.
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California Department of Forestry and Fire Protection Resource Management (CAL FIRE). 2019. California Forest Practice Rules 2019. Sacramento, CA: Resource Management, Forest Practice Program. https://bof.ﬁre.ca.gov/media/9095/2019-forest-practice-rules-and-act_ﬁnal_version-ada.pdf.

California Department of Toxic Substances Control (DTSC). 2025a. EnviroStor. https://www.envirostor.dtsc.ca.gov/public/.

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———. 2025b. Hazardous Waste and Substances Site List (CORTESE). https://www.envirostor.dtsc.ca.gov/public/search.asp?page=3&cmd=search&business_name=&mai n_street_name=&city=&zip=&county=&status=ACT%2CBKLG%2CCOM&branch=&site_type=CSITES% 2CFUDS&npl=&funding=&reporttitle=HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIST+%28CORT ESE%29&reporttype=CORTESE&federal_superfund=&state_response=&voluntary_cleanup=&school_ cleanup=&operating=&post_closure=&non_operating=&corrective_action=&tiered_permit=&evalua tion=&spec_prog=&national_priority_list=&senate=&congress=&assembly=&critical_pol=&business _type=&case_type=&searchtype=&hwmp_site_type=&cleanup_type=&ocieerp=&hwmp=False&per mitted=&pc_permitted=&inspections=&inspectionsother=&complaints=&censustract=&cesdecile=& school_district=&orderby=county.
———. 2025c. Land Use Restrictions.
https://www.envirostor.dtsc.ca.gov/public/deed_restrictions?orderby=county.

California Department of Transportation. 2019. List of Eligible and Oﬃcially Designated State Scenic Highways. August. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways.

California Environmental Protection Agency (CalEPA). 2025a. Cortese List Database. https://calepa.ca.gov/wp-content/uploads/2016/10/SiteCleanup-CorteseList-CurrentList.pdf. ———. 2025b. Cortese List: Section 65962.5(a). https://calepa.ca.gov/sitecleanup/corteselist/section- 65962-5a/.

California Geological Survey (CGS). 2002. California Geomorphic Provinces. (Note 36.) Available at:
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Accessed July 1, 2025.
———. 2008. Earthquake Zones of Required Investigation Dublin Quadrangle. Available at:
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Accessed July 1, 2025.

California Invasive Plant Council (Cal-IPC). 2020. Weed Control User Tool (WeedCUT). https://weedcut.ipm.ucanr.edu/#gsc.tab=0.

California Oak Mortality Task Force. 2023. Sudden Oak Death. https://www.suddenoakdeath.org/.

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City of Pleasanton. n.d. GIS Mapping & Data. https://www.cityofpleasantonca.gov/our-government/gis- mapping-data/.
———. 2009. City of Pleasanton General Plan 2005-2025.
https://www.cityofpleasantonca.gov/assets/our-government/community-development/cop-gen- plan-2005-25.pdf.
———. 2022. The City of Pleasanton Climate Action Plan 2.0. https://www.cityofpleasantonca.gov/assets/our-government/key-initiatives/climate-action- plan/climate-action-plan-2023-02-21.pdf.

Climate-Data.org. n.d. Climate Pleasanton – California. Retrieved October 22, 2025, from https://en.climate-data.org/north-america/united-states-of-america/california/pleasanton-16080/.

Federal Emergency Management Agency (FEMA). 2013. Biological Opinion 81420-2010-F-0849-3.

Biological Opinion for the Proposed Federal Emergency Management Agency Hazardous Fire Risk Reduction Project in the East Bay Hills of Alameda and Contra Costa Counties, California (HMGP 1731-16-34, PDM-PJ-09-CA-2005- 003, PDM-PJ-09-CA-2005-011, and PDM-PJ-09-CA-2006-004).

Forest Climate Action Team. 2018. California Forest Carbon Plan: Managing Our Forest Landscapes in a Changing Climate. Sacramento, CA. 178p. https://resources.ca.gov/CNRALegacyFiles/wp- content/uploads/2018/05/California-Forest-Carbon-Plan-Final-Draft-for-Public-Release-May- 2018.pdf.

Fredrickson, D.A. 1963. Archaeological Site Record, CA-CCO-309 (P-07-000186). On ﬁle at the Northwest Information Center, Sonoma State University.

Governor’s Oﬃce of Planning and Research. 2018. Technical Advisory on Evaluating Transportation Impacts. https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf.

Hammerson, G.A. 1979. Thermal Ecology of the Striped Racer, Masticophis lateralis. Herpetologica, 35(3), 267–273. http://www.jstor.org/stable/3891698.

Miller, A., and J.A. Alvarez. 2016. Habitat Use and Management Considerations for the Threatened Alameda Whipsnake (Masticophis lateralis euryxanthus) in Central California. Western Wildlife 3: 29–

32. https://wwjournal.org/wp-content/uploads/sites/9/2021/05/Miller_Alvarez_WW_2016.pdf.

Natural Resources Conservation Service (NRCS). 2025. Web Soil Survey. https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx.

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Oﬃce of Historic Preservation (OHP). 2020. Built Environment Resource Directory (BERD), Contra Costa County. https://ohp.parks.ca.gov/pages/1068/ﬁles/Contra%20Costa.csv. ———. 2025. California Historical Landmarks by County. Alameda. Available:
https://ohp.parks.ca.gov/?page_id=21388. Accessed: June 3, 2025.

Pitch Canker Task Force. 2023. Pitch Canker. https://ufei.calpoly.edu/pitch-canker-task-force/.

State Water Resources Control Board (SWRCB). 2025a. GeoTracker. https://geotracker.waterboards.ca.gov/.
———. 2025b. CDOCAO List. https://calepa.ca.gov/wp-content/uploads/2016/10/SiteCleanup- CorteseList-CDOCAOList.xlsx.

Supernowicz, D. 2017. California Department of Parks and Recreation Primary Record, P-07-004688. On ﬁle at the Northwest Information Center, Sonoma State University.

Thompson, N.E., E.W. Lankau, and G.M. Rogall. 2018. Snake Fungal Disease in North America: U.S.

Geological Survey Updates, U.S. Geological Survey.
https://pubs.usgs.gov/fs/2017/3064/fs20173064.pdf.

United States Fish and Wildlife Service. 2005. Revised Guidance on Site Assessments and Field Surveys for the California Red-legged Frog. August 1. Sacramento, CA: Sacramento Fish and Wildlife Oﬃce. https://ipac.ecosphere.fws.gov/guideline/survey/population/205/oﬃce/11420.pdf. ———. 2006. Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the Alameda Whipsnake; Final Rule. Federal Register 71(190):58176–58231. October 2.

United States Geological Survey (USGS). 2011. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California. https://pubs.usgs.gov/of/2011/1188/.
———. 2017. Geologic maps of US states. https://mrdata.usgs.gov/geology/state/.

William Self and Associates (WSA). 2006. Archaeological Investigation at CA-CCO-309, Rossmoor Basin, Contra Costa County, California. Prepared by Price, H. A. Arrigoni, J. Price, E. Strother, and J. Allan. On ﬁle at the Northwest Information Center, Sonoma State University (S-31416).

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Xerces Society for Invertebrate Conservation (Xerces Society), Defenders of Wildlife, and Center for Food Safety. 2018. A Petition to the State of California Fish and Game Commission to List the Crotch Bumble Bee (Bombus crotchii), Franklin’s Bumble Bee (Bombus franklini), Suckley Cuckoo Bumble Bee (Bombus suckleyi), and Western Bumble Bee (Bombus occidentalis occidentalis) as Endangered under the California Endangered Species Act.

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Attachment
A

Attachment A
Mitigation and Monitoring Reporting Program

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A.1 AUGUSTIN BERNAL COMMUNITY PARK FUELS REDUCTION PROJECT: MITIGATION MONITORING AND

REPORTING PROGRAM
Table A-1. Standard project requirements.

STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Administrative Standard Project Requirements
SPR AD-1 Project Proponent Coordination
For treatments coordinated with CAL FIRE, CAL FIRE would meet with the project proponent to discuss all natural and environmental resources that must be protected using SPRs and any applicable mitigation measures; identify any sensitive resources on-site; and discuss resource protection measures. For any prescribed burn treatments, CAL FIRE would also discuss the details of the Burn Plan in the incident action plan (IAP). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
SPR AD-2 Delineate Protected Resources
The project proponent would clearly deﬁne the boundaries of the treatment area and protected resources on maps for the treatment area and with highly visible ﬂagging or clear, existing landscape demarcations (e.g., edge of a roadway) prior to beginning any treatment to avoid disturbing the resource. “Protected Resources” refers to environmentally sensitive places within or adjacent to the treatment areas that would be avoided or protected to the extent feasible during planned treatment activities to sustain their natural qualities and processes. This work would be performed by a qualiﬁed person, as deﬁned for the speciﬁc resource (e.g., qualiﬁed RPF or biologist). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
treatment
The City of
Pleasanton
The City of
Pleasanton
SPR AD-3 Consistency with Local Plans, Policies, and Ordinances Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during
treatment
The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
The project proponent would design and implement the treatment in a manner that is consistent with applicable local plans (e.g., general plans, Community Wildﬁre Protection Plans, CAL FIRE Unit Fire Plans), policies, and ordinances to the extent the project is subject to them. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR AD-4 Public Notiﬁcations for Prescribed Burning
At least 3 days (timing to be determined by the Project Owner) prior to the commencement of prescribed burning operations, the project proponent would:
1) post signs along the closest public roadway to the treatment area describing the activity and timing, and requesting persons in the area to contact a designated representative of the project proponent (contact information would be provided with the notice) if they have questions or smoke concerns; 2) publish a public interest notiﬁcation in a local newspapers or other widely distributed media source describing the activity, timing, and contact information; and 3) send the local county supervisor and county administrative oﬃcer (or equivalent oﬃcial responsible for distribution of public information) a notiﬁcation letter describing the activity, its necessity, timing, and measures being taken to protect the environment and prevent prescribed burn escape. This SPR applies only to prescribed burn treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior
At least 3 days
prior to
prescribed burn
treatment
activities
The City of
Pleasanton
The City of
Pleasanton
SPR AD-5 Maintain Site Cleanliness
If trash receptacles are used on-site, the project proponent would use fully covered trash receptacles with secure lids (wildlife proof) to contain all food, food scraps, food wrappers, beverages, and other worker generated miscellaneous trash. Remove all temporary non-biodegradable ﬂagging, trash, debris, and barriers from the Project site upon completion of project activities. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to, during,
and following
treatment
The City of
Pleasanton
The City of
Pleasanton
SPR AD-6 Public Notiﬁcations for Treatment Projects Initial Treatment: Y
1–3 days prior to
treatment
activities
The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
One to three days prior to the commencement of a treatment activity, the project proponent would post signs in a conspicuous location near the treatment area describing the activity and timing and requesting persons in the area to contact a designated representative of the project proponent (contact information would be provided with the notice) if they have questions or concerns. This SPR applies to all treatment activities and all treatment types, including treatment maintenance. Prescribed burning is subject to the additional notiﬁcation requirements of SPR AD-4.

Treatment
Maintenance:

Y
SPR AD-7 Provide Information on Proposed, Approved, and Completed Treatment Projects
For any vegetation treatment project using the CalVTP PEIR for CEQA compliance, the project proponent would provide the information listed below to the Board of Forestry or CAL FIRE during the proposed, approved, and completed stages of the project. The Board or CAL FIRE would make this information available to the public via an online database or other mechanism. Information on proposed Projects (PSA in progress):
• Geographic Information Systems (GIS) data that include project location (as a point)
• Project size (typically acres)
• Treatment types and activities; and
• Contact information for a representative of the project proponent The project proponent would provide information on the proposed project to the Board or CAL FIRE as early as feasible in the planning phase. The project proponent would provide this information to the Board or CAL FIRE with suﬃcient lead time to allow those agencies to make the information available to the public no later than 2 weeks prior to project approval. The project proponent may also make information available to the public via other mechanisms (e.g., the proponent’s own website).

Information on approved projects (PSA complete):

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during,
post
The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
• A completed PSA Environmental Checklist
• A completed MMRP (using Attachment A to the Environmental Checklist)
• GIS data that include a polygon(s) of the Project area, showing the extent of each treatment type included in the project (ecological restoration, fuel break, WUI fuel reduction)
Information on completed projects:
• GIS data that include a polygon(s) of the treated area, showing the extent of each treatment type implemented (ecological restoration, fuel break, WUI fuel reduction)
• A post-project implementation report (referred to by CAL FIRE as a Completion Report) that includes:
o Size of treated area (typically acres)
o Treatment types and activities
o Dates of work;
o A list of the SPRs and mitigation measures that were
implemented; and
o Any explanations regarding implementation if required by SPRs and mitigation measures (e.g., explanation for feasibility determination required by SPR BIO-12; explanation for
reduction of a no-disturbance buﬀer below the general
minimum size described in MMs BIO-1a and BIO-2b)
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

SPR AD-8 Request Access for Post-Treatment Assessment
Initial
Treatment: Y
Treatment
Maintenance:

Y
Annually The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
For CAL FIRE projects, during contract development, CAL FIRE would include access to the treated area over a prescribed period (usually up to 3 years) to assess treatment eﬀectiveness in achieving desired fuel conditions and other CalVTP objectives as well as any necessary maintenance, as a contract term for consideration by the landowner. For public landowners, access to the treated area over a prescribed period would be a requirement of the executed contract.

This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

SPR AD-9: Obtain a Coastal Development Permit for Proposed Treatment Within the Coastal Zone Where Required
When planning a treatment project within the Coastal Zone, the project proponent would contact the local Coastal Commission district oﬃce, or applicable local government to determine if the Project area is within the jurisdiction of the Coastal Commission, a local government with a certiﬁed Local Coastal Program (LCP), or both. All treatment projects in the Coastal Zone would be reviewed by the local Coastal Commission district oﬃce or local government with a certiﬁed LCP (in consultation with the local Coastal Commission district oﬃce regarding whether a Coastal Development Permit [CDP] is required). If a CDP is required, the treatment project would be designed to meet the following conditions:
i. The treatment project would be designed in compliance with applicable provisions of the Coastal Act that provide substantive performance standards for the protection of potentially aﬀected coastal resources, if the treatment activity would occur within the original jurisdiction of the Commission or an area of a local coastal government without a certiﬁed LCP; and
ii. The treatment project would be designed in compliance with the applicable provisions of the certiﬁed LCP , speciﬁcally the substantive performance standards for the protection of potentially aﬀected coastal resources, if the treatment activity would occur within the jurisdiction of a local coastal government with a certiﬁed LCP .

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Aesthetic and Visual Resource Standard Project Requirements SPR AES-1 Vegetation Thinning and Edge Feathering
The project proponent would thin and feather adjacent vegetation to break up or screen linear edges of the clearing and mimic forms of natural clearings as reasonable or appropriate for vegetation conditions. In general, thinning and feathering in irregular patches of varying densities, as well as a gradation of tall to short vegetation at the clearing edge, would achieve a natural transitional appearance. The contrast of a distinct clearing edge would be faded into this transitional band. This SPR only applies to mechanical and manual treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR AES-2 Avoid Staging within Viewsheds
The project proponent would store all treatment-related materials, including vehicles, vegetation treatment debris, and equipment, outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. The project proponent would also locate materials staging and storage areas outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR AES-3 Provide Vegetation Screening
The project proponent would preserve suﬃcient vegetation within, at the edge of, or adjacent to treatment areas to screen views from public trails, parks, recreation areas, and roadways as reasonable or appropriate for vegetation conditions. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during The City of
Pleasanton
The City of
Pleasanton
Air Quality Standard Project Requirements
SPR AQ-1 Comply with Air Quality Regulations Initial
Treatment: Y During The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
The project proponent would comply with the applicable air quality requirements of air districts within whose jurisdiction the project is located. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Treatment
Maintenance:

Y
SPR AQ-2 Submit Smoke Management Plan
The project proponent would submit a smoke management plan for all prescribed burns to the applicable air district, in accordance with 17 CCR Section 80160. Pursuant to this regulation, a smoke management plan would not be required for burns less than 10 acres that also would not be conducted near smoke sensitive areas, unless otherwise directed by the air district. Burning would only be conducted in compliance with the burn authorization program of the applicable air district(s) having jurisdiction over the treatment area. Example of a smoke management plan is in Appendix PD-2. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton
SPR AQ-3 Create Burn Plan
The project proponent would create a Burn Plan using the CAL FIRE Burn Plan template for all prescribed burns. The Burn Plan would include a ﬁre behavior model output of First Order Fire Eﬀects Model and BEHAVE or other ﬁre behavior modeling simulation and that is performed by a qualiﬁed ﬁre behavior technical specialist that predicts ﬁre behavior, calculates consumption of fuels, tree mortality, predicted emissions, greenhouse gas emissions, and soil heating. The project proponent would minimize soil burn severity from broadcast burning to reduce the potential for runoﬀ and soil erosion. The Burn Plan would be created with input from a qualiﬁed technician or certiﬁed State burn boss. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

Project-Speciﬁc Measures
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton

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(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
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.

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).

SPR AQ-4 Minimize Dust
To minimize dust during treatment activities, the project proponent would implement the following measures:
• Limit the speed of vehicles and equipment traveling on unpaved areas to 15 miles per hour to reduce fugitive dust emissions, in accordance with the CARB Fugitive Dust protocol
• If road use creates excessive dust, the project proponent would wet appurtenant, unpaved, dirt roads using water trucks or treat roads with a non-toxic chemical dust suppressant (e.g., emulsion polymers, organic material) during dry, dusty conditions
o Any dust suppressant product used would be environmentally benign (i.e., non-toxic to plants and would not negatively impact water quality), and its use would not be prohibited by CARB, EPA, or the SWRCB.
o The project proponent would not over-water exposed areas such that the water results in runoﬀ
Initial
Treatment: Y
Treatment
Maintenance:

Y
During
The City of
Pleasanton/
Contractor
The City of
Pleasanton

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(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
o The type of dust suppression method would be selected by the project proponent based on soil, traﬃc, site-speciﬁc conditions, and air quality regulations
• Remove visible dust, silt, or mud tracked-out on to public paved roadways where suﬃcient water supplies and access to water is available
o The project proponent would remove dust, silt, and mud from vehicles at the conclusion of each workday, or at a minimum of every 24 hours for continuous treatment activities, in
accordance with Vehicle Code Section 23113
• Suspend ground-disturbing treatment activities, including land clearing and bulldozer lines, when there is visible dust transport (particulate pollution) outside the treatment boundary, if the particulate emissions may “cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property,” per Health and Safety Code Section 41700 This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR AQ-6: Prescribed Burn Safety Procedures
Prescribed burns planned and managed by non-CAL FIRE crews would follow all safety procedures required of CAL FIRE crew, including the implementation of an approved IAP , which would include the burn dates; burn hours; weather limitations; the speciﬁc burn prescription; a communications plan; a medical plan; a traﬃc plan; and special instructions, such as minimizing smoke impacts to speciﬁc local roadways. The IAP would also assign responsibilities for coordination with the appropriate air district, such as conducting on-site brieﬁngs, posting notiﬁcations, weather monitoring during burning, and other burn related preparations. This SPR applies only to prescribed burning treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During
prescribed burn
treatment
activities
The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Archaeological, Historical, and Tribal Cultural Resources Standard Project Requirements SPR CUL-1 Conduct Record Search
An archaeological and historical resource record search would be conducted per the applicable state or local agency procedures. Instead of conducting a new search, the project proponent may use recent record searches containing the treatment area requested by a landowner or other public agency in accordance applicable agency guidance. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

N
Prior The City of
Pleasanton
The City of
Pleasanton
SPR CUL-2 Contact Geographically Aﬃliated Native American Tribes The project proponent would obtain the latest NAHC-provided Native Americans Contact List. Using the appropriate Native Americans Contact List, the project proponent would notify the California Native American Tribes in the counties where the treatment activity is located. The notiﬁcation would contain the following:
• A written description of the treatment location and boundaries • Brief narrative of the treatment objectives
• A description of the activities used (e.g., prescribed burning, mastication) and associated acreages
• A map of the treatment area at a suﬃcient scale to indicate the spatial extent of activities
• A request for information regarding potential impacts to cultural resources from the proposed treatment
A detailed description of the depth of excavation, if ground disturbance is expected.

In addition, the project proponent would contact the NAHC for a review of their Sacred Lands File. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

N
Prior The City of
Pleasanton
The City of
Pleasanton
SPR-CUL-3 Pre-ﬁeld Research Initial
Treatment: Y Prior The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
The project proponent would conduct research prior to implementing treatments as part of the cultural resource investigation. The purpose of this research is to properly inform survey design, based on the types of resources likely to be encountered within the treatment area, and to be prepared to interpret, record, and evaluate these ﬁndings within the context of local history and prehistory. The qualiﬁed archaeologist and/or archaeologically trained resource professional would review records; study maps; read pertinent ethnographic, archaeological, and historical literature speciﬁc to the area being studied; and conduct other tasks to maximize the eﬀectiveness of the survey. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Treatment
Maintenance:

N
SPR CUL-4 Archaeological Surveys
The project proponent would coordinate with an archaeologically trained resource professional and/or qualiﬁed archaeologist to conduct a site-speciﬁc survey of the treatment area. The survey methodology (e.g., pedestrian survey, subsurface investigation) depends on whether the area has a low, moderate, or high sensitivity for resources, which is based on whether the records search, pre- ﬁeld research, and/or Native American consultation identiﬁes archaeological or historical resources near or within the treatment area. A survey report would be completed for every cultural resource survey completed. The speciﬁc requirements would comply with the applicable state or local agency procedures.

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

N
Prior The City of
Pleasanton
The City of
Pleasanton
SPR CUL-5 Treatment of Archaeological Resources
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
If cultural resources are identiﬁed within a treatment area and cannot be avoided, a qualiﬁed archaeologist will notify the culturally aﬃliated Tribe(s) based on information provided by NAHC and assess whether an archaeological ﬁnd qualiﬁes as a unique archaeological resource, a historical resource, or, in coordination with said Tribe(s), as a Tribal cultural resource. The project proponent, in consultation with culturally aﬃliated Tribe(s), will develop eﬀective protection measures for important cultural resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging eﬀects to cultural resources will not occur. These protection measures will be written in clear, enforceable language, and will be included in the survey report in accordance with applicable state or local agency procedures. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR CUL-6 Treatment of Tribal Cultural Resources
The project proponent, in consultation with the culturally aﬃliated Tribe(s), would develop eﬀective protection measures for important Tribal cultural resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging eﬀects to cultural resources would not occur. The project proponent would provide the Tribe(s) the opportunity to submit comments and participate in consultation to resolve issues of concern. The project proponent would defer implementing the treatment until the tribe approves protection measures, or if agreement cannot be reached after a good-faith eﬀort, the proponent determines that any or all feasible measures have been implemented, where feasible, and the resource is either avoided or protected. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during The City of
Pleasanton
The City of
Pleasanton
SPR CUL-7 Avoid Built Historical Resources Initial
Treatment: Y Prior, during The City of
Pleasanton
The City of
Pleasanton

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November 2025
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If the records search identiﬁes built historical resources, as deﬁned in Section 15064.5 of the State CEQA Guidelines, the project proponent would avoid these resources. Within a buﬀer of 100 feet of the built historical resource, there would be no prescribed burning or mechanical treatment activities Buﬀers less than 100 feet for built historical resources would only be used after consultation with and receipt of written approval from a qualiﬁed archaeologist. If the records search does not identify known historical resources in the treatment area, but structures (i.e., buildings, bridges, roadways) over 50 years old that have not been evaluated for historic signiﬁcance are present in the treatment area, they would similarly be avoided. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Treatment
Maintenance:

Y
SPR CUL-8 Cultural Resource Training
The project proponent would train all crew members and contractors implementing treatment activities on the protection of sensitive archaeological, historical, or Tribal cultural resources. Workers would be trained to halt work if archaeological resources are encountered on a treatment site and the treatment method consists of physical disturbance of land surfaces (e.g., soil disturbance).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment
The City of
Pleasanton
The City of
Pleasanton
Biological Resources Standard Project Requirements
SPR BIO-1 Review and Survey Project-Speciﬁc Biological Resources Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
treatment and
treatment
maintenance
Initial data
review and
reconnaissance-
level survey are
complete
(Attachment B)
The City of
Pleasanton
The City of
Pleasanton

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November 2025
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(Y/N) TIMING IMPLEMENTING
ENTITY

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ENTITY
The project proponent would require a qualiﬁed RPF or biologist to conduct a data review and reconnaissance-level survey prior to treatment, no more than one year prior to the submittal of the PSA, and no more than one year between completion of the PSA and implementation of the treatment project. The data reviewed would include the biological resources setting, species and sensitive natural communities tables, and habitat information in this PEIR for the ecoregion(s) where the treatment would occur. It would also include review of the best available, current data for the area, including vegetation mapping data, species distribution/range information, the CNDDB, the CNPS Inventory of Rare and Endangered Plants of California, relevant BIOS queries, and relevant general and regional plans. Reconnaissance-level biological surveys would be general surveys that include visual and auditory inspection for biological resources to help determine the environmental setting of a Project site. The qualiﬁed surveyor would identify and document sensitive resources, such as riparian or other sensitive habitats, sensitive natural community, wetlands, or wildlife nursery site or habitat (including bird nests) and assess the suitability of habitat for special- status plant and animal species. The surveyor would also record any incidental wildlife observations. For each treatment project, habitat assessments would be completed at a time of year that is appropriate for identifying habitat and no more than one year prior to the submittal of the PSA, unless it can be demonstrated in the PSA that habitat assessments older than one year remain valid (e.g., site conditions are unchanged, and no treatment activity has occurred since the assessment). If more than one year passes between completion of the PSA and initiation of the treatment project, the project proponent would verify the continued accuracy of the PSA prior to beginning the treatment project by reviewing for any data updates and/or visiting the site to verify conditions. Based on the results of the data review and reconnaissance-level survey, the project proponent, in consultation with a qualiﬁed RPF or biologist, would determine which one of the following best characterizes the treatment:

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1. Suitable Habitat Is Present but Adverse Eﬀects Can Be Clearly Avoided. If, based on the data review and reconnaissance-level survey, the qualiﬁed RPF or biologist determines that suitable habitat for sensitive biological resources is present but adverse eﬀects on the suitable habitat can clearly be avoided through one of the following methods, the avoidance mechanism would be implemented prior to initiating treatment and would remain in eﬀect throughout the treatment:
a. By physically avoiding the suitable habitat, or
b. By conducting treatment outside of the season when a sensitive resource could be present within the suitable habitat or outside the season of sensitivity (e.g., outside of special-status bird nesting season, during dormant season of sensitive annual or geophytic plant species, or outside of maternity and rearing season at wildlife nursery sites).

Physical avoidance would include ﬂagging, fencing, stakes, or clear existing landscape demarcations (e.g., edge of a roadway) to delineate the boundary of the avoidance area around the suitable habitat. For physical avoidance, a buﬀer may be implemented as determined necessary by the qualiﬁed RPF or biologist.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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November 2025
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ENTITY

VERIFYING/

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ENTITY

2. Suitable Habitat Is Present and Adverse Eﬀects Cannot Be Clearly Avoided.

Further review and surveys would be conducted to determine presence/absence of sensitive biological resources that may be aﬀected, as described in the SPRs below. Further review may include contacting USFWS, National Oceanic and Atmospheric Administration (NOAA) Fisheries, CDFW, CNPS, or local resource agencies as necessary to determine the potential for special-status species or other sensitive biological resources to be aﬀected by the treatment activity. Focused or protocol-level surveys would be conducted as necessary to determine presence/absence. If protocol surveys are conducted, survey procedures would adhere to methodologies approved by resource agencies and the scientiﬁc community, such as those that are available on the CDFW webpage at:
https://www.wildlife.ca.gov/Conservation/Survey-Protocols. Speciﬁc survey requirements are addressed for each resource type in relevant SPRs (e.g., additional survey requirements are presented for special-status plants in SPR BIO-7).

This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Speciﬁc Measures
A qualiﬁed RPF or biologist would conduct a pre-treatment survey to identify, map, and ﬂag any sensitive plants or vegetative communities for avoidance or follow-up surveys if needed. The surveys would be conducted when weather conditions and timeframes are suitable for the detection of sensitive resources.

No work would occur in the work area until the area has been adequately surveyed and assessed for sensitive resources.

SPR BIO-2: Require Biological Resource Training for Workers Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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November 2025
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ENTITY

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ENTITY
The project proponent would require crew members and contractors to receive training from a qualiﬁed RPF or biologist prior to beginning a treatment project.

The training would describe the appropriate work practices necessary to eﬀectively implement the biological SPRs and mitigation measures and to comply with the applicable environmental laws and regulations. The training would include the identiﬁcation, relevant life history information, and avoidance of pertinent special-status species; identiﬁcation and avoidance of sensitive natural communities and habitats with the potential to occur in the treatment area; impact minimization procedures; and reporting requirements. The training would instruct workers when it is appropriate to stop work and allow wildlife encountered during treatment activities to leave the area unharmed and when it is necessary to report encounters to a qualiﬁed RPF, biologist, or biological technician. The qualiﬁed RPF, biologist, or biological technician would immediately contact CDFW or USFWS, as appropriate, if any wildlife protected by CESA or ESA is encountered and cannot leave the site on its own (without being handled). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Sensitive Natural Communities and Other Sensitive Habitats SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive Habitats If SPR BIO-1 determines that sensitive natural communities or sensitive habitats may be present and adverse eﬀects cannot be avoided, the project proponent would:
• Require a qualiﬁed RPF or biologist to perform a protocol-level survey following the most current CDFW protocols (CDFW 2023a) of the treatment area prior to the start of treatment activities for sensitive natural communities and sensitive habitats
o Sensitive natural communities would be identiﬁed using the best means possible, including keying them out using the most current edition of A Manual of California Vegetation (including updated natural communities data; CNPS 2023) or referring to relevant reports (e.g., reports found on the Vegetation Classiﬁcation and Mapping Program website)
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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November 2025
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(Y/N) TIMING IMPLEMENTING
ENTITY

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ENTITY
• Map and digitally record, using a Global Positioning System unit, the limits of any potential sensitive habitat and sensitive natural community identiﬁed in the treatment area
This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Speciﬁc Measures
If any rare plant populations are found, location, quantity and description would be reported to the CNDDB. Any in-ﬁeld methods of identiﬁcation that would require handling would follow proper permitting and protocols.

Work in Alameda whipsnake scrub habitat will be restricted to hand tools only, and vegetation removal will include dead, woody branches, and invasive plants.

The nature of shaded fuel break work will not change the habitat functions of dispersal and foraging of species occurring within, including Alameda whipsnake.

In habitat suitable for Alameda whipsnake suitable winter retreats (e.g., within native scrub habitat, rock outcrops within approximately 50 feet of scrub habitat), as determined by a qualiﬁed RPF or biologist, prescribed burning would not occur between approximately November 1 and March 31 (as determined by a qualiﬁed biologist based on temperature and weather conditions) in order to avoid potential disturbance of hibernating Alameda whipsnake. Prescribed burning and pile burning would be restricted to when temperatures are conducive to AWS movement, which is typically when soil surface temperatures reach 66°F (19°C; Hammerson 1979).

SPR BIO-4: Design Treatment to Avoid Loss or Degradation of Riparian Habitat Function
Project proponents, in consultation with a qualiﬁed RPF or biologist, would design treatments in riparian habitats to retain or improve habitat functions by implementing the following within riparian habitats:
• Retain at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation within the limits of Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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ENTITY

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ENTITY
riparian habitat identiﬁed and mapped during surveys conducted pursuant to SPR BIO-3
o Native riparian vegetation would be retained in a well distributed multi-storied stand composed of a diversity of species similar to that found before the start of treatment activities
• Treatments would be limited to removal of uncharacteristic fuel loads (e.g., removing dead or dying vegetation), trimming/limbing of woody species as necessary to reduce ladder fuels, and select thinning of vegetation to restore densities that are characteristic of healthy stands of the riparian vegetation types characteristic of the region o This includes hand removal (or mechanized removal where topography allows) of dead or dying riparian trees and shrubs, invasive plant removal, selective thinning, and removal of encroaching upland species
• Removal of large, native riparian hardwood trees (e.g., willow, ash, maple, oak, alder, sycamore, cottonwood) would be minimized to the extent feasible, and 75 percent of the pretreatment native riparian hardwood tree canopy would be retained
o Because tree size varies depending on vegetation type present and site conditions, the tree size retention parameter would be determined on a site-speciﬁc basis depending on vegetation type present and setting; however, live, healthy, native trees that are considered large for that type of tree and large relative to other trees in that location would be retained
o A scientiﬁcally based, project-speciﬁc explanation
substantiating the retention size parameter for native riparian hardwood tree removal would be provided in the Biological Resources Discussion of the PSA
o Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, presence of suﬃcient Treatment will
avoid riparian
habitat by a
minimum 50-
foot buﬀer

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seed trees, light availability, and changes in stream shading may inform the tree size retention requirements
• Removed trees would be felled away from adjacent streams or waterbodies and piled outside of the riparian vegetation zone (unless there is an ecological reason to do otherwise that is approved by applicable regulatory agencies, such as adding large woody material to a stream to enhance ﬁsh habitat [e.g., see NMFS et al. 2018]) • Vegetation removal that could reduce stream shading and increase stream temperatures would be avoided
• Ground disturbance within riparian habitats would be limited to the minimum necessary to implement eﬀective treatments
o This would consist of the minimum disturbance area necessary to reduce hazardous fuels and return the riparian community to a natural ﬁre regime (i.e., Condition Class 1) considering historic ﬁre return intervals, climate change, and land use constraints
• Only hand application of herbicides approved for use in aquatic environments would be allowed and only during low-ﬂow periods or when seasonal streams are dry
• The project proponent would notify CDFW when required by California Fish and Game Code Section 1602 prior to implementing any treatment activities in riparian habitats
o Notiﬁcation would identify the treatment activities, map the vegetation to be removed, identify the impact avoidance identiﬁcation methods to be used (e.g., ﬂagging), and
appropriate protections for the retention of shaded riverine habitat, including buﬀers and other applicable measures to prevent erosion into the waterway
• In consideration of spatial variability of riparian vegetation types and condition and consistent with California Forest Practice Rules Section 916.9(v) (February 2019 version; CAL FIRE 2019), a diﬀerent set of vegetation retention standards and protection measures from those

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(Y/N) TIMING IMPLEMENTING
ENTITY

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ENTITY
speciﬁed in the above bullets may be implemented on a site-speciﬁc basis if the qualiﬁed RPF and the project proponent demonstrate through substantial evidence that alternative design measures provide a more eﬀective means of achieving the treatment goals objectives and would result in eﬀects to the Beneﬁcial Functions of Riparian Zones equal or more favorable than those expected to result from application of the above measures
o Deviation from the above design speciﬁcations, diﬀerent protection measures, and design standards would only be approved when the treatment plan incorporates an evaluation of beneﬁcial functions of the riparian habitat and with written concurrence from CDFW
This SPR applies to all treatment activities and treatment types, including treatment maintenance.

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SPR BIO-5: Avoid Environmental Eﬀects of Type Conversion and Maintain Habitat Function in Chaparral and Coastal Sage Scrub
The project proponent would design treatment activities to avoid type conversion where native coastal sage scrub and chaparral are present. An ecological deﬁnition of type conversion is used in the CalVTP PEIR for assessment of environmental eﬀects: a change from a vegetation type dominated by native shrub species that are characteristic of chaparral and coastal sage scrub vegetation alliances to a vegetation type characterized predominantly by weedy herbaceous cover or annual grasslands. For the PEIR, type conversion is considered in terms of habitat function, which is deﬁned here as the arrangement and capability of habitat features to provide refuge, food source, and reproduction habitat to plants and animals, and thereby contribute to the conservation of biological and genetic diversity and evolutionary processes (de Groot et al. 2002). Some modiﬁcation of habitat characteristics may occur, provided habitat function is maintained (i.e., the location, essential habitat features, and species supported are not substantially changed).

During the reconnaissance-level survey required in SPR BIO-1, a qualiﬁed RPF or biologist would identify chaparral and coastal sage scrub vegetation to the alliance level and determine the condition class and ﬁre return interval departure of the chaparral and/or coastal sage scrub present in each treatment area.

For all treatment types in chaparral and coastal sage scrub, the project proponent, in consultation with a qualiﬁed RPF or biologist would:
• Develop a treatment design that avoids environmental eﬀects of type conversion in chaparral and coastal sage scrub vegetation alliances, which would include evaluating and determining the appropriate spatial scale at which the proponent would consider type conversion and substantiating its appropriateness
o The project proponent would demonstrate with substantial evidence that the habitat function of chaparral and coastal sage scrub would be at least maintained within the identiﬁed spatial scale at which type conversion is evaluated for the speciﬁc treatment project
o Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, spatial needs of Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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sensitive species, presence of suﬃcient seed plants and nurse plants, light availability, and edge eﬀects may inform the determination of an appropriate spatial scale
• The treatment design would maintain a minimum percent cover of mature native shrubs within the treatment area to maintain habitat function; the appropriate percent cover would be identiﬁed by the project proponent in the development of treatment design and be speciﬁc to the vegetation alliances that are present in the identiﬁed spatial scale used to evaluate type conversion
o Mature native shrubs that are retained would be distributed contiguously or in patches within the stand
o If the stand consists of multiple age classes, patches representing a range of middle to old age classes would be retained to maintain and improve heterogeneity, to the extent needed to avoid type conversion
These SPR requirements apply to all treatment activities and all treatment types, including treatment maintenance.

Additional measures would be applied to ecological restoration treatment types:
• For ecological restoration treatment types, complete removal of the mature shrub layer would not occur in native chaparral and coastal sage scrub vegetation types
• Ecological restoration treatments would not be implemented in vegetation types that are within their natural ﬁre return interval (i.e., time since last burn is less than the average time listed as the ﬁre return interval range in Table 3.6-1) unless the project proponent demonstrates with substantial evidence that the habitat function of chaparral and coastal sage scrub would be improved
• A minimum of 35 percent relative cover of existing shrubs and associated native vegetation would be retained at existing densities in patches distributed in a mosaic pattern within the treated area, or the shrub canopy would be thinned by no more than 20 percent from

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baseline density (e.g., if baseline shrub canopy density is 60 percent, post treatment shrub canopy density would be no less than 40 percent) o A diﬀerent percent relative cover can be retained if the project proponent demonstrates with substantial evidence that
alternative treatment design measures would result in eﬀects on the habitat function of chaparral and coastal sage scrub that are equal or more favorable than those expected to result from application of the above measures
o Biological considerations that may inform a deviation from the minimum 35 percent relative cover retention include but are not limited to soil moisture requirements, increased soil temperatures, changes in light/shading, presence of suﬃcient seed plants and nurse plants, erosion potential, and site hydrology
• If the stand within the treatment area consists of multiple age classes, patches representing a range of middle to old age classes would be retained to maintain and improve heterogeneity
These SPR requirements apply to all treatment activities and only the ecosystem restoration treatment type, including treatment maintenance.

A determination of compliance with the SB 1260 prohibition of type conversion in chaparral and coastal sage scrub is a statutory issue separate from CEQA compliance that may involve factors additional to the ecological deﬁnition and habitat functions presented in the PEIR, such as geographic context. It is beyond the legal scope of the PEIR to deﬁne SB 1260 type conversion and statutory compliance. The project proponent, acting as lead agency for the proposed later treatment project, would be responsible for deﬁning type conversion in the context of the project and making the ﬁnding that type conversion would not occur, as required by SB 1260. The project proponent would determine its criteria for deﬁning and avoiding type conversion and, in making its ﬁndings, may draw upon information presented in this PEIR.

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SPR BIO-6: Prevent Spread of Plant Pathogens
When working in sensitive natural communities, riparian habitats, or oak woodlands that are at risk from plant pathogens (e.g., Ione chaparral, blue oak woodland), the project proponent would implement the following BMPs to prevent the spread of Phytophthora and other plant pathogens (e.g., pitch canker, goldspotted oak borer, shot hole borer, bark beetle):
• Clean and sanitize vehicles, equipment, tools, footwear, and clothes before arriving at a treatment site and when leaving a contaminated site, or a site in a county where contamination is a risk; • Include training on Phytophthora diseases and other plant pathogens in the worker awareness training;
• Minimize soil disturbance as much as possible by limiting the number of vehicles, avoiding oﬀ-road travel as much as possible, and limiting use of mechanized equipment
• Minimize movement of soil and plant material within the site, especially between areas with high and low risk of contamination
• Clean soil and debris from equipment and sanitize hand tools, buckets, gloves, and footwear when moving from high-risk to low-risk areas or between widely separated portions of a treatment area; and • Follow the procedures listed in Guidance for plant pathogen prevention when working at contaminated restoration-sites or with rare plants and sensitive habitat (UC Cooperative Extension et al. 2016) This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Speciﬁc Measures
To contain the spread of Phytophthora ramorum, crews would minimize the movement of soil and leaf litter under and around infected trees. 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. 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 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.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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ENTITY

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Any material suspected of being infected must stay in the area, as close to the origin point as possible. Generally, removal of P . ramorum-infected or killed oak trees is only 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 debris may not be left, infested material would be disposed of at an approved and permitted dump facility.

Special-Status Plants
SPR BIO-7: Survey for Special-Status Plants
If SPR BIO-1 determines that suitable habitat for special-status plant species is present and cannot be avoided, the project proponent would require a qualiﬁed RPF or botanist to conduct protocol-level surveys for special-status plant species with the potential to be aﬀected by a treatment prior to initiation of the treatment. The survey would follow the surveying and evaluation methods for special-status plants and sensitive natural communities (CDFW 2018).

Surveys to determine the presence or absence of special-status plant species would be conducted in suitable habitat that could be aﬀected by the treatment and timed to coincide with the blooming or other appropriate phenological period of the target species (as determined by a qualiﬁed RPF or botanist), or all species in the same genus as the target species would be assumed to be special- status.

If potentially occurring special-status plants are listed under CESA or ESA, protocol-level surveys to determine presence/absence of the listed species would be conducted in all circumstances, unless determined otherwise by CDFW or USFWS. For other special-status plants not listed under CESA or ESA, as deﬁned in Section 3.6.1 of this PEIR, surveys would not be required under the following circumstances:

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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• If protocol-level surveys, consisting of at least two survey visits (e.g., early blooming season and later blooming season) during a normal weather year, have been completed in the 5 years before implementation of the treatment project and no special-status plants were found, and no treatment activity has occurred following the protocol-level survey, treatment may proceed without additional plant surveys
• If the target special-status plant species is an herbaceous annual, stump- sprouting, or geophyte species, the treatment may be carried out during the dormant season for that species or when the species has completed its annual lifecycle without conducting presence/absence surveys, provided the treatment would not alter habitat or destroy seeds, stumps, or roots, rhizomes, bulbs and other underground parts in a way that would make it unsuitable for the target species to reestablish following treatment
This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Environmentally Sensitive Habitat Areas
SPR BIO-8: Identify and Avoid or Minimize Impacts in Coastal Zone ESHAs When planning a treatment project within the Coastal Zone, the project proponent would, in consultation with the Coastal Commission or a local government with a certiﬁed LCP (as applicable), identify the habitat types and species present to determine if the area qualiﬁes as an Environmentally Sensitive Habitat Area (ESHA). If the area is an ESHA, the treatment project may be allowed pursuant to this PEIR, if it meets the following conditions. If a project requires a CDP by the Coastal Commission or a local government with a certiﬁed LCP (as applicable), the CDP approval may require modiﬁcation to these conditions to further avoid and minimize impacts:
• The treatment would be designed, in compliance with the Coastal Act or LCP if a site is within a certiﬁed LCP area, to protect the habitat function Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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of the aﬀected ESHA, protect habitat values, and prevent loss or type conversion of habitat and vegetation types that deﬁne the ESHA, or loss of special-status species that inhabit the ESHA
• Treatment actions would be limited to eradication or control of invasive plants, removal of uncharacteristic fuel loads (e.g., removing dead, diseased, or dying vegetation), trimming/limbing of woody species as necessary to reduce ladder fuels, and select thinning of vegetation to restore densities that are characteristic of healthy stands of the vegetation types present in the ESHA
• A qualiﬁed biologist or RPF familiar with the ecology of the treatment area would monitor all treatment activities in ESHAs
• Appropriate no-disturbance buﬀers would be developed in compliance with the Coastal Act or relevant LCP policies for treatment activities in the vicinity of ESHAs to avoid adverse direct and indirect eﬀects to ESHAs
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Project-Speciﬁc Measures
To avoid impacts to sensitive natural communities, focused botanical surveys would be performed (MM BIO-1a and MM BIO-1b). If these communities are identiﬁed, they would be recorded using a GPS and mapped. No Project-related ground disturbance would occur within 50 feet of these sensitive natural communities (MM BIO-3a).

Invasive Plants and Wildlife
SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and Invasive Wildlife
The project proponent would take the following actions to prevent the spread of invasive plants, noxious weeds, and invasive wildlife (e.g., New Zealand mudsnail):

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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• Clean clothing, footwear, and equipment used during treatments of soil, seeds, vegetative matter, other debris or seed-bearing material, or water (e.g., rivers, streams, creeks, lakes) before entering the treatment area or when leaving an area with infestations of invasive plants, noxious weeds, or invasive wildlife
• For all heavy equipment and vehicles traveling oﬀ road, pressure wash, if feasible, or otherwise appropriately decontaminate equipment at a designated weed-cleaning station prior to entering the treatment area from an area with infestations of invasive plants, noxious weeds, or invasive wildlife
o Anti-fungal wash agents would be speciﬁed if the equipment has been exposed to any pathogen that could aﬀect native species
• Inspect all heavy equipment, vehicles, tools, or other treatment-related materials for sand, mud, or other signs that weed seeds or propagules could be present prior to use in the treatment area
o If the equipment is not clean, the qualiﬁed RPF or biological technician would deny entry to the work areas
• Stage equipment in areas free of invasive plant infestations unless there are no uninfested areas present within a reasonable proximity to the treatment area
• Identify signiﬁcant infestations of invasive plant species (i.e., those rated as invasive by Cal-IPC or designated as noxious weeds by California Department of Food and Agriculture) during reconnaissance-level surveys and target them for removal during treatment activities o Treatment methods would be selected based on the invasive species present; and may include herbicide application, manual or mechanical treatments, prescribed burning, and/or
herbivory; and would be designed to maximize success in killing or removing the invasive plants and preventing reestablishment based on the life history characteristics of the invasive plant species present

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o Treatments would be focused on removing invasive plant species that cause ecological harm to native vegetation types, especially those that can alter ﬁre cycles
• Treat invasive plant biomass on-site to eliminate seeds and propagules and prevent reestablishment or dispose of invasive plant biomass oﬀsite at an appropriate waste collection facility (if not kept on-site); transport invasive plant materials in a closed container or bag to prevent the spread of propagules during transport; and
• Implement Fire and Fuel Management BMPs outlined in Cal-IPC manual (Cal-IPC 2012 or current version)
This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Speciﬁc Measures
Control of invasive plants and noxious weeds would follow the recommendations given by the Cal-IPC and the most updated scientiﬁc methods. 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.

Whenever possible, crews and equipment would remain on paved, rocked, and well-traveled trails and would avoid cross-country travel. Mud, soil, and organic debris must be removed from equipment, treads, and boots before moving between work sites, with removed soil being left at its original location. Crews can remove soil and vegetative debris by brushing and blowing, followed by water or sanitizing solution if necessary. If water is used, crews would ensure that no erosion occurs, and no waterways are contaminated.

Wildlife
SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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If SPR BIO-1 determines that suitable habitat for special-status wildlife species or nurseries of any wildlife species is present and cannot be avoided, the project proponent would require a qualiﬁed RPF or biologist to conduct focused or protocol-level surveys for special-status wildlife species or nursery sites (e.g., bat maternity roosts, deer fawning areas, heron or egret rookeries, monarch overwintering sites) with potential to be directly or indirectly aﬀected by a treatment activity. The survey area would be determined by a qualiﬁed RPF or biologist based on the species and habitats and any recommended buﬀer distances in agency protocols.

The qualiﬁed RPF or biologist would determine if following an established protocol is required, and the project proponent may consult with CDFW and/or USFWS for technical information regarding appropriate survey protocols. Unless otherwise speciﬁed in a protocol, the survey would be conducted no more than 14 days prior to the beginning of treatment activities. Focused or protocol surveys for a special-status species with potential to occur in the treatment area may not be required if presence of the species is assumed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR BIO-11. Install Wildlife-Friendly Fencing (Prescribed Herbivory) If temporary fencing is required for prescribed herbivory treatment, a wildlife- friendly fencing design would be used. The project proponent would require a qualiﬁed RPF or biologist to review and approve the design before installation to minimize the risk of wildlife entanglement. The fencing design would meet the following standards:
• Minimize the chance of wildlife entanglement by avoiding barbed wire, loose or broken wires, or any material that could impale or snag a leaping animal, and, if feasible, keeping electric netting-type fencing electriﬁed at all times or laid down while not in use
• Charge temporary electric fencing with intermittent pulse energizers; continuous output fence chargers would not be permitted • Allow wildlife to jump over easily without injury by installing fencing that can ﬂex as animals pass over it and installing the top wire low Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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enough (no more than approximately 40 inches high on ﬂat ground) to allow adult ungulates to jump over it
o The determination of appropriate fence height would consider slope, as steep slopes are more diﬃcult for wildlife to pass • Be highly visible to birds and mammals by using high-visibility tape or wire, ﬂagging, or other markers
This SPR applies only to prescribed herbivory and all treatment types, including treatment maintenance.

SPR BIO-12. Protect Common Nesting Birds, Including Raptors The project proponent would schedule treatment activities to avoid the active nesting season of common native bird species, including raptors, that could be present within or adjacent to the treatment site, if feasible. Common native birds are species not otherwise treated as special-status in the CalVTP PEIR. The active nesting season would be deﬁned by the qualiﬁed RPF or biologist.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to and
during
treatment and
treatment
maintenance
The City of
Pleasanton
The City of
Pleasanton

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If active nesting season avoidance is not feasible, a qualiﬁed RPF or biologist would conduct a survey for common nesting birds, including raptors. Existing records (e.g., CNDDB, eBird database, State Wildlife Action Plan) should be reviewed in advance of the survey to identity the common nesting birds, including raptors, that are known to occur in the vicinity of the treatment site.

The survey area would encompass reasonably accessible areas of the treatment site and the immediately surrounding vicinity viewable from the treatment site.

The survey area would be determined by a qualiﬁed RPF or biologist, based on the potential species in the area, location of suitable nesting habitat, and type of treatment. For vegetation removal or project activities that would occur during the nesting season, the survey would be conducted at a time that balances the eﬀectiveness of detecting nests and the reasonable consideration of potential avoidance strategies. Typically, this timeframe would be up to 3 weeks before treatment. The survey would occur in a single survey period of suﬃcient duration to reasonably detect nesting birds, including raptors, typically 1 day for most treatment projects (depending on the size, conﬁguration, and vegetation density in the treatment site), and conducted during the active time of day for target species, typically close to dawn and/or dusk. The survey may be conducted concurrently with other biological surveys if they are required by other SPRs.

Survey methods would be tailored to site and habitat conditions by the qualiﬁed RPF or biologist, typically involving walking throughout the survey area, visually searching for nests and birds exhibiting behavior that is typical of breeding (e.g., delivering food).

If an active nest is observed (i.e., presence of eggs and/or chicks) or determined to likely be present based on nesting bird behavior, the project proponent would implement a feasible strategy to avoid disturbance of active nests, which may include but is not limited to one or more of the following:
• Establish Buﬀer: The project proponent would establish a temporary, species-appropriate buﬀer around the nest suﬃcient to reasonably expect that breeding would not be disrupted

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o Treatment activities would be implemented outside of the buﬀer, the location of which would be determined by a
qualiﬁed RPF or biologist
o Factors to be considered for determining buﬀer location would include presence of natural buﬀers provided by vegetation or topography, nest height above ground, baseline levels of noise and human activity, species sensitivity, and expected treatment activities
o Nests of common birds within the buﬀer need not be
monitored during treatment; however, buﬀers would be
maintained until young ﬂedge or the nest becomes inactive, as determined by the qualiﬁed RPF, biologist, or biological technician
• Modify Treatment: The project proponent would modify the treatment in the vicinity of an active nest to avoid disturbance of active nests (e.g., by implementing manual treatment methods, rather than mechanical treatment methods)
o Treatment modiﬁcations would be determined by the project proponent in coordination with the qualiﬁed RPF or biologist • Defer Treatment: The project proponent would defer the timing of treatment in the portion(s) of the treatment site that could disturb the active nest
o If this avoidance strategy is implemented, treatment activity would not commence until young ﬂedge or the nest becomes inactive, as determined by the qualiﬁed RPF, biologist, or biological technician

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Feasible actions would be taken by the project proponent to avoid loss of common native bird nests. The feasibility of implementing the avoidance strategies would be determined by the project proponent based on whether implementation of this SPR would preclude completing the treatment project within the reasonable period of time necessary to meet CalVTP program objectives, including, but not limited to, protection of vulnerable communities.

Considerations may include limitations on the presence of environmental and atmospheric conditions necessary to execute treatment prescriptions (e.g., the limited seasonal windows during which prescribed burning can occur when vegetation moisture, weather, wind, and other physical conditions are suitable).

If it is infeasible to avoid loss of common bird nests (not including raptor nests), the project proponent would document the reasons implementation of the avoidance strategies is infeasible in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any change in the feasibility of avoidance strategies from those explained in the PSA, this would be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).

The following avoidance strategies may also be considered together with or in lieu of other actions for implementation by a project proponent to avoid disturbance to raptor nests:
• Monitor Active Raptor Nest During Treatment: A qualiﬁed RPF, biologist, or biological technician would monitor an active raptor nest during treatment activities to identify signs of agitation, nest defense, or other behaviors that signal disturbance of the active nest is likely (e.g., standing up from a brooding position, ﬂying oﬀ the nest) o If breeding raptors are showing signs of nest disturbance, one of the other avoidance strategies (establish buﬀer, modify treatment, or defer treatment) would be implemented or a pause in the treatment activity would occur until the
disturbance behavior ceases

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• Retention of Raptor Nest Trees: Trees with visible raptor nests, whether occupied or not, would be retained
This SPR applies to all treatment activities and treatment types, including treatment maintenance.

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

Project-Speciﬁc Measures
Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton

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To prevent herbicides from being mobilized and soil from being compacted, which increases runoﬀ and erosion risk, the project proponent would suspend mechanical and herbicide treatments if: (1) it is raining, (2) soils are saturated, and/or (3) soils are wet enough to mobilize herbicides or be compacted by mechanical activities. The project proponent would be prepared to completely suspend mechanical and herbicide treatment activities prior to the initiation of the rain event. Activities that cause mechanical soil disturbance may resume when precipitation stops and soils are no longer very wet or saturated (i.e., when soil and/or surface material pore spaces are ﬁlled with water to such an extent that runoﬀ is likely to occur). Indicators of very wet or saturated soil conditions may include but are not limited to: (1) areas of ponded water, (2) pumping of ﬁnes from the soil or road surfacing, (3) loss of bearing strength resulting in the deﬂection of soil or road surfaces under a load, such as the creation of wheel ruts, (4) spinning or churning of wheels or tracks that produces a wet slurry, (5) inadequate traction without blading wet soil or surfacing materials, or (6) tire track imprints or hoof marks in the soil. This SPR applies only to mechanical and herbicide treatment activities and all treatment types, including treatment maintenance.

SPR GEO-2 Limit High Ground Pressure Vehicles
The project proponent would limit heavy equipment that could cause soil disturbance or compaction to be driven through treatment areas when soils are wet and saturated to avoid compaction and/or damage to soil structure.

Saturated soil means that soil and/or surface material pore spaces are ﬁlled with water to such an extent that runoﬀ is likely to occur. If use of heavy equipment is required in saturated areas, other measures, such as operating on organic debris, using low ground pressure vehicles, or operating on frozen soils/snow-covered soils, would be implemented to minimize soil compaction. Existing compacted road surfaces are exempted as they are already compacted from use. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR GEO-3 Stabilize Disturbed Soil Areas Initial
Treatment: Y During The City of
Pleasanton
The City of
Pleasanton

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The project proponent would stabilize soil disturbed during mechanical, prescribed herbivory treatments, and prescribed burns that result in exposure of bare soil over 50 percent or more of the treatment area with mulch or equivalent immediately after treatment activities, to the maximum extent practicable, to minimize the potential for substantial sediment discharge. If mechanical, prescribed herbivory, or prescribed burn treatment activities could result in substantial sediment discharge from soil disturbed by machinery, animal hooves, or being bare, organic material from mastication or mulch would be incorporated onto at least 75 percent of the disturbed soil surface where the soil erosion hazard is moderate or high, and 50 percent of the disturbed soil surface where soil erosion hazard is low to help prevent erosion. Where slash mulch is used, it would be packed into the ground surface with heavy equipment so that it is suﬃciently in contact with the soil surface. This SPR only applies to mechanical, prescribed herbivory, and prescribed burns that result in exposure of bare soil over 50 percent of the Project area treatment activities and all treatment types, including treatment maintenance.

Treatment
Maintenance:

Y
SPR GEO-4 Erosion Monitoring
The project proponent would inspect treatment areas for the proper implementation of erosion control SPRs and mitigations prior to the rainy season. If erosion control measures are not properly implemented, they would be remediated prior to the ﬁrst rainfall event per SPR GEO-3 and GEO-8.

Additionally, the project proponent would inspect for evidence of erosion after the ﬁrst large storm or rainfall event (i.e., ≥ 1.5 inches in 24 hours) as soon as is feasible after the event. Any area of erosion that would result in substantial sediment discharge would be remediated within 48 hours per the methods stated in SPRs GEO-3 and GEO-8. This SPR applies only to mechanical, prescribed herbivory, and prescribed burning treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During, after

The City of
Pleasanton
The City of
Pleasanton
SPR GEO-5 Drain Stormwater via Water Breaks Initial
Treatment: Y During The City of
Pleasanton
The City of
Pleasanton

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The project proponent would drain compacted and/or bare linear treatment areas capable of generating storm runoﬀ via water breaks using the spacing and erosion control guidelines contained in Sections 914.6, 934.6, and 954.6(c) of the California Forest Practice Rules (CAL FIRE 2019). Where waterbreaks cannot eﬀectively disperse surface runoﬀ, including where waterbreaks cause surface run-oﬀ to be concentrated on downslopes, other erosion controls would be installed as needed to maintain site productivity by minimizing soil loss. This SPR applies only to mechanical, manual, and prescribed burn treatment activities and all treatment types, including treatment maintenance.

Treatment
Maintenance:

Y
SPR GEO-6 Minimize Burn Pile Size
The project proponent would not create burn piles that exceed 20 feet in length, width, or diameter, except when on landings, road surfaces, or on contour to minimize the spatial extent of soil damage. In addition, burn piles would not occupy more than 15 percent of the total treatment area (Busse, Hubbert, and Moghaddas 2014). The project proponent would not locate burn piles in a Watercourse and Lake Protection Zone as deﬁned in SPR HYD-4. This SPR applies to mechanical, manual, and prescribed burning treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR GEO-7 Minimize Erosion
To minimize erosion, the project proponent would:

1. Prohibit use of heavy equipment where any of the following conditions are present:
a. Slopes steeper than 65 percent
b. Slopes steeper than 50 percent where the erosion hazard rating is high or extreme
c. Slopes steeper than 50 percent that lead without ﬂattening to suﬃciently dissipate water ﬂow and trap sediment before it reaches a watercourse or lake

2. On slopes between 50 percent and 65 percent where the erosion hazard rating is moderate and all slope percentages are for average slope Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton

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steepness based on sample areas that are 20 acres or less, heavy equipment would be limited to:
a. Existing tractor roads that do not require reconstruction, or b. New tractor roads ﬂagged by the project proponent prior to the treatment activity

3. Prescribed herbivory treatments would not be used in areas with over 50 percent slope
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

SPR GEO-8 Steep Slopes
The project proponent would require a 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). If unstable areas or soils are identiﬁed within the treatment area, are unavoidable, and would be potentially directly or indirectly aﬀected by the treatment, a licensed geologist (P .G. or C.E.G.) would determine the potential for landslide, erosion, of other issue related to unstable soils and identity measures (e.g., those in SPR GEO-7) that would be implemented by the project proponent such that substantial erosion or loss of topsoil would not occur. This SPR applies only to mechanical treatment activities and WUI fuel reduction, non- shaded fuel breaks, and ecological restoration treatment types, including treatment maintenance.

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A
Greenhouse Gas Emissions Standard Project Requirements
SPR GHG-1 Contribute to the AB 1504 Carbon Inventory Process The project proponent of treatment projects subject to the AB 1504 process would provide all necessary data about the treatment that is needed by the U.S.

Forest Service and Fire and Resource Assessment Program (FRAP) to fulﬁll requirements of the AB 1504 carbon inventory, and to aid in the ongoing research about the long-term net change in carbon sequestration resulting from treatment activity. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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Hazardous Material and Public Health and Safety Standard Project Requirements SPR HAZ-1 Maintain All Equipment
The project proponent would maintain all diesel- and gasoline-powered equipment per manufacturer’s speciﬁcations, and in compliance with all state and federal emissions requirements. Maintenance records would be available for veriﬁcation. Prior to the start of treatment activities, the project proponent would inspect all equipment for leaks and inspect everyday thereafter until equipment is removed from the site. Any equipment found leaking would be promptly removed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during,
after
The City of
Pleasanton
The City of
Pleasanton
SPR HAZ-2 Require Spark Arrestors
The project proponent would require mechanized hand tools to have federal- or state-approved spark arrestors. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR HAZ-3 Require Fire Extinguishers
The project proponent would require tree cutting crews to carry one ﬁre extinguisher per chainsaw. Each vehicle would be equipped with one long- handled shovel and one axe or Pulaski, consistent with PRC Section 4428. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR HAZ-4 Prohibit Smoking in Vegetated Areas
The project proponent would require that smoking is only permitted in designated smoking areas barren or cleared to mineral soil at least 3 feet in diameter (PRC Section 4423.4). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR HAZ-5 Spill Prevention and Response Plan
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton

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The project proponent or licensed Pest Control Advisor would prepare a Spill Prevention and Response Plan prior to beginning any herbicide treatment activities to provide protection to on-site workers, the public, and the environment from accidental leaks or spills of herbicides, adjuvants, or other potential contaminants. The Spill Prevention and Response Plan would include (but not be limited to):
• A map that delineates staging areas, and storage, loading, and mixing areas for herbicides;
• A list of items required in an on-site spill kit to be maintained throughout the life of the activity;
• Procedures for the proper storage, use, and disposal of any herbicides, adjuvants, or other chemicals used in vegetation treatment This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

Project-Speciﬁc Measures
Herbicide application would not occur within protective buﬀers for special-status plants and riparian habitat to prevent drift and non-target application.

SPR HAZ-6 Comply with Herbicide Application Regulations The project proponent would coordinate pesticide use with the applicable County Agricultural Commissioner(s), and all required licenses and permits would be obtained prior to herbicide application. The project proponent would prepare all herbicide applications to do the following:
• Be implemented consistent with recommendations prepared annually by a licensed Pest Control Advisor
• Comply with all appropriate laws and regulations pertaining to the use of pesticides and safety standards for employees and the public, as governed by the EPA, the Department of Pesticide Regulation (DPR), and applicable local jurisdictions
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior, during The City of
Pleasanton
The City of
Pleasanton

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• Adhere to label directions for application rates and methods, storage, transportation, mixing, container disposal, and weather limitations to application, such as wind speed, humidity, temperature, and precipitation
• Be applied by an applicator appropriately licensed by the State.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

SPR HAZ-7 Triple Rinse Herbicide Containers
The project proponent would triple rinse all herbicide and adjuvant containers with clean water at an approved site and dispose of rinsate by placing it in the batch tank for application per 3 CCR Section 6684. The project proponent would puncture used containers on the top and bottom to render them unusable, unless said containers are part of a manufacturer’s container recycling program, in which case the manufacturer’s instructions would be followed. Disposal of non-recyclable containers would be at legal dumpsites. Equipment would not be cleaned, and personnel would not be washed in a manner that would allow contaminated water to directly enter any body of water within the treatment area or adjacent watersheds. Disposal of all herbicides would follow label requirements and waste disposal regulations.

This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR HAZ-8 Minimize Herbicide Drift to Public Areas
The project proponent would employ the following herbicide application parameters during herbicide application to minimize drift into public areas:
• Application would cease when weather parameters exceed label speciﬁcations or when sustained winds at the site of application exceeds 7 miles per hour (whichever is more conservative);
• Spray nozzles would be conﬁgured to produce the largest appropriate droplet size to minimize drift;
Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton

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• Low nozzle pressures (30–70 pounds per square inch) would be utilized to minimize drift; and
• Spray nozzles would be kept within 24 inches of vegetation during spraying
This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

SPR HAZ-9 Notiﬁcation of Herbicide Use in the Vicinity of Public Areas For herbicide applications occurring within or adjacent to public recreation areas, residential areas, schools, or any other public areas within 500 feet, the project proponent would post signs at each end of herbicide treatment areas and any intersecting trails notifying the public of the use of herbicides. The signs would include the signal word (e.g., Danger, Warning, or Caution); product name; and manufacturer; active ingredient; EPA registration number; target pest; treatment location; date and time of application; restricted entry interval, if applicable per the label requirements; date which notiﬁcation sign may be removed; and a contact person with a telephone number. Signs would be posted prior to the start of treatment and notiﬁcation would remain in place for at least 72 hours after treatment ceases. This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
Hydrology and Water Quality Standard Project Requirements SPR HYD-1 Comply with Water Quality Regulations
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton

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ENTITY

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ENTITY
Project proponents must also conduct proposed vegetation treatments in conformance with appropriate RWQCB timber, vegetation, and land disturbance- related Waste Discharge Requirements (WDRs) and/or related Conditional Waivers of Waste Discharge Requirements (Waivers) and appropriate Basin Plan Prohibitions. Where these regulatory requirements diﬀer, the most restrictive would apply. If applicable, this includes compliance with the conditions of general WDRs and WDR waivers for timber or silviculture activities where these waivers are designed to apply to non-commercial fuel reduction and forest health projects. In general, WDRs and Waivers of WDRs for fuel reduction and forest health activities require that wastes, including but not limited to petroleum products, soil, silt, sand, clay, rock, felled trees, slash, sawdust, bark, ash, and pesticides must not be discharged to surface waters or placed where it may be carried into surface waters; and that Water Board staﬀ must be allowed reasonable access to the property in order to determine compliance with the waiver conditions. The speciﬁcations for each WDR and Waiver vary by region.

Regions 2 (San Francisco Bay), 4 (Los Angeles), 8 (Santa Ana), and 7 (Colorado River) are highly urban or minimally forested and do not oﬀer WDRs or Waivers for fuel reduction or vegetation management activities. The current applicable WDRs and Waivers for timber and vegetation management activities are included in Appendix HYD-1. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Project-Speciﬁc Measures
Vegetation treatment activities may result in discharges to waters of the state; therefore, compliance with Water Code sections 13260(a)(1) and 13264 are required. The project proponent would use the State Water Board’s Vegetation Treatment General Order, which provides a mechanism for Water Code compliance for projects that prepare a PSA/Addendum. The project would be automatically enrolled (through implementation of SPR AD-7) in the State Water Board’s Vegetation Treatment General Order. The project’s automatic enrollment satisﬁes the requirements of SPR HYD-1.

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ENTITY

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ENTITY
SPR HYD-2 Avoid Construction of New Roads
The project proponent would not construct or reconstruct (i.e., cutting or ﬁlling involving less than 50 cubic yards/0.25 linear road miles) any new roads (including temporary roads). This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
SPR HYD-3 Water Quality Protections for Prescribed Herbivory The project proponent would include the following water quality protections for all prescribed herbivory treatments:
• Environmentally sensitive areas such as waterbodies, wetlands, or riparian areas would be identiﬁed in the treatment prescription and excluded from prescribed herbivory project areas using temporary fencing or active herding
o A buﬀer of approximately 50 feet would be maintained
between sensitive and actively grazed areas
• Water would be provided for grazing animals in the form of an on-site stock pond or a portable water source located outside of environmentally sensitive areas
• Treatment prescriptions would be designed to protect soil stability.

Grazing animals would be herded out of an area if accelerated soil erosion is observed
This SPR applies to prescribed herbivory treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
SPR HYD-4 Identify and Protect Watercourse and Lake Protection Zones The project proponent would establish WLPZs on either side of watercourses as deﬁned in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (CAL FIRE 2019). WLPZ’s are classiﬁed based on the uses of the stream and the presence of aquatic life. Wider WLPZs are required for steep slopes.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton

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Procedures for Determining WLPZ Widths
Water Class Class I Class II Class III Class IV
Water Class
Characteristic
s or Key
Indicator
Beneﬁcial Use
1) Domestic
supplies,
including
springs, on-site
and/or within
100 feet
downstream of
the operations
area and/or
2) Fish always
or seasonally
present on-site,
includes habitat
to sustain ﬁsh
migration and
spawning.
1) Fish always or
seasonally present
oﬀsite within 1,000
feet downstream
and/or
2) Aquatic habitat
for non-ﬁsh aquatic
species.
3) Excludes Class III
waters that are
tributary to Class I
waters.

No aquatic life
present,
watercourse
showing evidence
of being capable of
sediment transport
to Class I and II
waters under
normal high-water
ﬂow conditions
after completion of
timber operations.

Man-made
watercourses,
usually
downstream,
established
domestic,
agricultural,
hydroelectric
supply or other
beneﬁcial use.

WLPZ Width (feet) – Distance from top of bank to the edge of WLPZ < 30 % Slope 75 50 Suﬃcient to prevent the
degradation of downstream
beneﬁcial uses of water.

Determined on a site-speciﬁc
basis.
30–50 % Slope 100 75
> 50 % Slope 150 100
Source: 14 CCR Section 916.5 [936.5, 956.5] (February 2019 version).

The following WLPZ protections would be applied for all treatments:
• Treatment activities with WLPZs would retain at least 75 percent surface cover and undisturbed area to act as a ﬁlter strip for raindrop energy dissipation and for wildlife habitat
o If this percentage is reduced, a qualiﬁed RPF would provide the project proponent with a site- and/or treatment activity-

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speciﬁc explanation for the percent surface cover reduction, which would be included in the PSA
▪ After completion of the PSA and prior to or during
treatment implementation, if there is any deviation
(e.g., further reduction) from the reduced percent as
explained in the PSA, this would be documented in the
post-project implementation report (referred to by
CAL FIRE as a Completion Report)
o This requirement is based on 14 CCR Section 916.4 [936.4, 956.4] Subsection (b)(6) (February 2019 version) and 14 CCR Section 916.5 (February 2019 version)
• Equipment, including tractors and vehicles, must not be driven in wet areas or WLPZs, except over existing roads or watercourse crossings where vehicle tires or tracks remain dry
• Equipment used in vegetation removal operations would not be serviced in WLPZs, within wet meadows or other wet areas, or in locations that would allow grease, oil, or fuel to pass into lakes, watercourses, or wet areas
• WLPZs would be kept free of slash, debris, and other material that harm the beneﬁcial uses of water
o Accidental deposits would be removed immediately
• Burn piles would be located outside of WLPZs
• No ﬁre ignition (nor use of associated accelerants) would occur within WLPZs; however, low-intensity backing ﬁres may be allowed to enter or spread into WLPZs
• Within Class I and Class II WLPZs, locations where project operations expose a continuous area of mineral soil 800 square feet or larger shall be treated for reduction of soil loss
o Treatment shall occur prior to October 15th, and disturbances that are created after October 15th shall be treated within 10 days

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
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ENTITY
o Stabilization measures shall be selected that would prevent signiﬁcant movement of soil into water bodies and may include but are not limited to mulching, riprap, grass seeding, or chemical soil stabilizers
• Where mineral soil has been exposed by project operations on approaches to watercourse crossings of Class I, II, or III within a WLPZ, the disturbed area shall be stabilized to the extent necessary to prevent the discharge of soil into watercourses or lakes in amounts that would adversely aﬀect the quality and beneﬁcial uses of the watercourse • Where necessary to protect beneﬁcial uses of water from project operations, protection measures such as seeding, mulching, or replanting shall be used to retain and improve the natural ability of the ground cover within the WLPZ to ﬁlter sediment, minimize soil erosion, and stabilize banks of watercourses and lakes
• Equipment limitation zones (ELZs) would be designated adjacent to Class III and Class IV watercourses with minimum widths of 25 feet where side-slope is less than 30 percent and 50 feet where side-slope is 30 percent or greater
o An RPF would describe the limitations of heavy equipment within the ELZ and, where appropriate, would include
additional measures to protect the beneﬁcial uses of water This SPR applies to all treatment activities and treatment types, including treatment maintenance.

SPR HYD-5 Protect Non-target Vegetation and Special-Status Species from Herbicides
The project proponent would implement the following measures when applying herbicides:
• Locate herbicide mixing sites in areas devoid of vegetation and where there is no potential of a spill reaching non-target vegetation or a waterway
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton

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(Y/N) TIMING IMPLEMENTING
ENTITY

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ENTITY
• Use only herbicides labeled for use in aquatic environments when working in riparian habitats or other areas where there is a possibility the herbicide could come into direct contact with water o Only hand application of herbicides would be allowed in riparian habitats and only during low-ﬂow periods or when seasonal streams are dry
• No terrestrial or aquatic herbicides would be applied within WLPZs of Class I and II watercourses, if feasible
o If this is not feasible, hand application of herbicides labeled for use in aquatic environments may be used within the WLPZ, provided that the project proponent notiﬁes the applicable regional water quality control board no fewer than 15 days prior to herbicide application
o The feasibility of avoiding herbicide application within WLPZ of Class I and II watercourses would be determined by the project proponent and may be based on whether doing so would
preclude achieving CalVTP program objectives, including but not limited to protection of vulnerable communities
o The reasons for infeasibility would be documented in the PSA • No herbicides would be applied within a 50-foot buﬀer of ESA or CESA listed plant species or within 50 feet of dry vernal pools • For spray applications in and adjacent to habitats suitable for special- status species, use herbicides containing dye (registered for aquatic use by DPR, if warranted) to prevent overspray
• Application would cease when weather parameters exceed label speciﬁcations or when sustained winds at the site of application exceeds 7 miles per hour (whichever is more conservative)
• No herbicide would be applied during precipitation events or if precipitation is forecast 24 hours before or after project activities This SPR applies to herbicide treatment activities and all treatment types, including treatment maintenance.

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ENTITY

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ENTITY
SPR HYD-6 Protect Existing Drainage Systems
If a treatment activity is adjacent to a roadway with stormwater drainage infrastructure, the existing stormwater drainage infrastructure would be marked prior to ground disturbing activities. If a drainage structure or inﬁltration system is inadvertently disturbed or modiﬁed during project activities, the project proponent would coordinate with owner of the system or feature to repair any damage and restore pre-project drainage conditions. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
Noise Standard Project Requirements
SPR NOI-1 Limit Heavy Equipment Use to Daytime Hours
The project proponent would require that operation of heavy equipment associated with treatment activities (heavy oﬀ-road equipment, tools, and delivery of equipment and materials) would occur during daytime hours if such noise would be audible to receptors (e.g., residential land uses, schools, hospitals, places of worship). Cities and counties in the treatable landscape typically restrict construction-noise (which would apply to vegetation treatment noise) to particular daytime hours. If the project proponent is subject to local noise ordinance, it would adhere to those to the extent the project is subject to them. If the applicable jurisdiction does not have a noise ordinance or policy restricting the time of day when noise-generating activity can occur, noise- generating vegetation treatment activity would be limited to the hours of 7:00 a.m. to 6:00 p.m., Monday through Saturday, and between 9:00 a.m. and 6:00 p.m. on Sunday and federal holidays. If the project proponent is not subject to local ordinances (e.g., CAL FIRE), it would adhere to the restrictions stated above or may elect to adhere to the restrictions identiﬁed by the local ordinance encompassing the treatment area. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR NOI-2 Equipment Maintenance Initial
Treatment: Y Prior and during The City of
Pleasanton
The City of
Pleasanton

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
The project proponent would require that all powered treatment equipment and power tools would be used and maintained according to manufacturer speciﬁcations. All diesel- and gasoline-powered treatment equipment would be properly maintained and equipped with noise-reduction intake and exhaust muﬄers and engine shrouds, in accordance with manufacturers’ recommendations. This SPR applies to all activities and all treatment types, including treatment maintenance.

Treatment
Maintenance:

Y
SPR NOI-3 Engine Shroud Closure
The project proponent would require that engine shrouds be closed during equipment operation. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR NOI-4 Locate Staging Areas Away from Noise-Sensitive Land Uses The project proponent would locate treatment activities, equipment, and equipment staging areas away from nearby noise-sensitive land uses (e.g., residential land uses, schools, hospitals, places of worship), to the extent feasible, to minimize noise exposure. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior and during The City of
Pleasanton
The City of
Pleasanton
SPR NOI-5 Restrict Equipment Idle Time
The project proponent would require that all motorized equipment be shut down when not in use. Idling of equipment and haul trucks would be limited to 5 minutes. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
During The City of
Pleasanton
The City of
Pleasanton
SPR NOI-6 Notify Nearby Oﬀ-Site Noise-Sensitive Receptors Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton

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(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
For treatment activities utilizing heavy equipment, the project proponent would notify noise-sensitive receptors (e.g., residential land uses, schools, hospitals, places of worship) located within 1,500 feet of the treatment activity. Notiﬁcation would include anticipated dates and hours during which treatment activities are anticipated to occur and contact information, including a daytime telephone number, of the project representative. Recommendations to assist noise-sensitive land uses in reducing interior noise levels (e.g., closing windows and doors) would also be included in the notiﬁcation. This SPR applies only to mechanical treatment activities and all treatment types, including treatment maintenance.

Recreation Standard Project Requirements
SPR REC-1 Notify Recreational Users of Temporary Closures If a treatment activity would require temporary closure of a public recreation area or facility, the project proponent would coordinate with the owner/manager of that recreation area or facility. If temporary closure of a recreation area or facility is required, the project proponent would work with the owner/manager to post notiﬁcations of the closure at least 2 weeks prior to the commencement of the treatment activities. Additionally, notiﬁcation of the treatment activity would be provided to the Administrative Oﬃcer (or equivalent oﬃcial responsible for distribution of public information) of the county(ies) in which the aﬀected recreation area or facility is located. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton
Transportation Standard Project Requirements
SPR TRAN-1 Implement Traﬃc Control during Treatments
Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Prior to initiating vegetation treatment activities, the project proponent would work with the agency(ies) with jurisdiction over aﬀected roadways to determine if a TMP is needed if traﬃc generated by the project would result in obstructions, hazards, or delays exceeding applicable jurisdictional standards along access routes for individual vegetation treatments. If needed, a TMP would be prepared to provide measures to reduce potential traﬃc obstructions, hazards, and service level degradation along aﬀected roadway facilities. The scope of the TMP would depend on the type, intensity, and duration of the speciﬁc treatment activities under the CalVTP . Measures included in the TMP could include but are not limited to construction signage to provide motorists with notiﬁcation and information when approaching or traveling along the aﬀected roadway facilities, ﬂaggers for lane closures to provide temporary traﬃc control along aﬀected roadway facilities, treatment schedule restrictions to avoid seasons or time periods of peak vehicle traﬃc, haul-trip, delivery, and/or commute time restrictions that would be implemented to avoid peak traﬃc days and times along aﬀected roadway facilities.

If the TMP identiﬁes impacts on transportation facilities outside of the jurisdiction of the project proponent, the TMP would be submitted to the agency with jurisdiction over the aﬀected roadways prior to commencement of vegetation treatment projects. This SPR applies to all treatment activities and treatment types, including treatment maintenance.

Smoke generated during prescribed burn operations could potentially aﬀect driver visibility and traﬃc operations along nearby roadways. Direct smoke impacts to roadway visibility and indirect impacts related to driver distraction would be considered during the planning phase of burning operations. Smoke impacts and smoke management practices speciﬁc to traﬃc operations during prescribed ﬁre operations would be identiﬁed and addressed within the TMP , which would include measures to monitor smoke dispersion onto public roadways, and traﬃc control operations that would be initiated in the event burning operations could aﬀect traﬃc safety along any roadways. This SPR applies only to prescribed burn treatment activities and all treatment types, including treatment maintenance.

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STANDARD PROJECT REQUIREMENTS APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Public Services and Utilities Standard Project Requirements SPR UTIL-1: Solid Organic Waste Disposition Plan
For projects requiring the disposal of material outside of the treatment area, the project proponent would prepare an Organic Waste Disposition Plan prior to initiating treatment activities. The Solid Organic Waste Disposition Plan would include the amount (e.g., tons) of solid organic waste to be managed on-site (i.e., scattering of wood materials, generating unburned piles, and pile burning) and transported oﬀ site for processing (i.e., biomass power plant, wood product processing facility, composting). If the project proponent intends to transport solid organic waste oﬀsite, the Solid Organic Waste Disposition Plan would clearly identify the location and capacity of the intended processing facility, consistent with local and state regulations to demonstrate that adequate capacity exists to accept the treated materials. This SPR applies only to mechanical and manual treatment activities and all treatment types, including treatment maintenance.

Initial
Treatment: Y
Treatment
Maintenance:

N
Prior The City of
Pleasanton
The City of
Pleasanton

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Table A-2. Mitigation Measures.

MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Aesthetics and Visual Resources
MM AES-3: Conduct Visual Reconnaissance for Non-Shaded Fuel Breaks and Relocate or Feather and Screen Publicly Visible Non-Shaded Fuel Breaks The project proponent would conduct a visual reconnaissance of the treatment area prior to implementing non-shaded fuel breaks to observe the surrounding landscape and determine if public viewing locations, including scenic vistas, public trails, and state scenic highways, have views of the proposed treatment area. If none are identiﬁed, the non- shaded fuel break may be implemented without additional visual mitigation.

If the project proponent identiﬁes public viewing points, including heavily used scenic vistas, public trails, recreation areas, and state scenic highways with lengthy views (i.e., longer than a few seconds) of a proposed non-shaded fuel break treatment area, the project proponent would, prior to implementation, attempt to identify any feasible change in location of the fuel break to reduce its visibility from public viewpoints. If no feasible location changes exist that would reduce impacts to public viewers and achieve the intended wildﬁre risk reduction objectives of the proposed non-shaded fuel break, the project proponent would implement, where feasible, a shaded fuel break rather than a non-shaded fuel break, if the shaded fuel break would achieve the intended wildﬁre risk reduction objectives. With the shaded fuel break, the project proponent would thin and feather adjacent vegetation to break up the linear edges of the fuel break and strategically preserve vegetation at the edge of the fuel break, as feasible, to help screen public views and minimize the contrast between the fuel break and surrounding vegetation.

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A
Air Quality
MM AQ-1: Implement On-Road Vehicle and Oﬀ-Road Equipment Exhaust Emission Reduction Techniques
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
and
during
The City of
Pleasanton
The City of
Pleasanton

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Where feasible, project proponents would implement emission reduction techniques to reduce exhaust emissions from oﬀ-road equipment. It is acknowledged that due to cost, availability, and the limits of current technology, there may be circumstances where implementation of certain emission reduction techniques would not feasible. The project proponent would document the emission reduction techniques that would be applied and would explain the reasons other techniques that could reduce emissions are infeasible.

Techniques for reducing emissions may include but are not limited to the following:
• Diesel-powered oﬀ-road equipment used in construction would meet EPA’s Tier 4 emission standards, as deﬁned in 40 CFR 1039, and comply with the exhaust emission test procedures and provisions of 40 CFR Parts 1065 and 1068 o Tier 3 models can be used if a Tier 4 version of the equipment type is not yet produced by manufacturers
o This measure can also be achieved by using battery-electric oﬀ-road equipment as it becomes available
o Prior to implementation of treatment activities, the project proponent would demonstrate the ability to supply the compliant equipment o A copy of each unit’s certiﬁed tier speciﬁcation or model year speciﬁcation and operating permit (if applicable) would be available upon request at the time of mobilization of each unit of equipment • Use renewable diesel fuel in diesel-powered construction equipment o Renewable diesel fuel must meet the following criteria:
▪ Meet California’s Low Carbon Fuel Standards and be certiﬁed by CARB Executive Oﬃcer
▪ Be hydrogenation-derived (reaction with hydrogen at high temperatures) from 100 percent biomass material (i.e., non- petroleum sources), such as animal fats and vegetables
▪ Contain no fatty acids or functionalized fatty acid esters ▪ Have a chemical structure that is identical to petroleum-based diesel and complies with American Society for Testing and Materials D975 requirements for diesel fuels to ensure
compatibility with all existing diesel engines

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• Electric- and gasoline-powered equipment would be substituted for diesel- powered equipment
• Workers would be encouraged to carpool to work sites and/or use public transportation for their commutes
• Oﬀ-road equipment, diesel trucks, and generators would be equipped with Best Available Control Technology for emission reductions of Project-Speciﬁc Measures
The City of Pleasanton 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 compliance report for the project.

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

Archaeological, Historical, and Tribal Cultural Resources MM CUL-2: Protect Inadvertent Discoveries of Unique Archaeological Resources or Subsurface Historical Resources
Initial
Treatment: Y
Treatment
Maintenance:

Y
During
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after
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If any prehistoric or historic-era subsurface archaeological features or deposits, including locally darkened soil (“midden”), that could conceal cultural deposits are discovered during ground-disturbing activities, all ground-disturbing activity within 100 feet of the resources would be halted and a qualiﬁed archaeologist would assess the signiﬁcance of the ﬁnd. The qualiﬁed archaeologist would work with the project proponent to develop a primary records report that would comply with applicable state or local agency procedures. If the archaeologist determines that further information is needed to evaluate signiﬁcance, a data recovery plan would be prepared. If the ﬁnd is determined to be signiﬁcant by the qualiﬁed archaeologist (i.e., because the ﬁnd constitutes a unique archaeological resource, subsurface historical resource, or Tribal cultural resource), the archaeologist would work with the project proponent to develop appropriate procedures to protect the integrity of the resource. Procedures could include preservation in place (which is the preferred manner of mitigating impacts to archaeological sites), archival research, subsurface testing, or recovery of scientiﬁcally consequential information from and about the resource. Any ﬁnd would be recorded standard DPR Primary Record forms (Form DPR 523) would be submitted to the appropriate regional information center.

Biological Resources
MM BIO-1a: Avoid Loss of Special-Status Plants Listed under ESA or CESA Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
and
during
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If listed plants are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent would avoid and protect these species by establishing a no- disturbance buﬀer around the area occupied by listed plants and marking the buﬀer boundary with high-visibility ﬂagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). Exceptions to this requirement are listed later in this measure. The no-disturbance buﬀers would generally be a minimum of 50 feet from listed plants, but the size and shape of the buﬀer zone may be adjusted if a qualiﬁed RPF or botanist determines that a smaller buﬀer would be suﬃcient to avoid killing or damaging listed plants or that a larger buﬀer is necessary to suﬃciently protect plants from the treatment activity. The appropriate buﬀer size would be determined based on plant phenology at the time of treatment (e.g., whether the plants are in a dormant, vegetative, or ﬂowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain. For example, paint-on or wicking application of herbicides to invasive plants may be implemented within 50 feet of listed plant species without posing a risk, especially if the listed plants are dormant at the time of application. Consideration of factors such as site hydrology, changes in light, edge eﬀects, and potential introduction of invasive plants and noxious weeds may inform the determination of buﬀer width. If a no-disturbance buﬀer is reduced below 50 feet from a listed plant, a qualiﬁed RPF or botanist would provide the project proponent with a site- and/or treatment activity-speciﬁc explanation for the buﬀer reduction, which would be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced buﬀer as explained in the PSA, this would be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report) with a science-based justiﬁcation for the deviation. No ﬁre ignition (nor use of associated accelerants) would occur within 50 feet of listed plants.

For species listed under ESA or CESA, if the project proponent cannot avoid loss by implementing no-disturbance buﬀers, the project proponent would implement MM BIO- 1c.

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The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or botanist, in consultation with CDFW and USFWS, as appropriate depending on species status and location, that the listed plants would beneﬁt from treatment in the occupied habitat area even though some of the listed plants may be lost during treatment activities. For a treatment to be considered beneﬁcial to listed special- status plants, the qualiﬁed RPF or botanist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the species (or similar species) has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence would be included in the PSA. If it is determined that treatment activities would be beneﬁcial to listed plants, no compensatory mitigation for loss of individuals would be required.

MM BIO-1b: Avoid Loss of Special-Status Plants Not Listed Under ESA or CESA If non-listed special-status plant species (i.e., species not listed under ESA or CESA, but meeting the deﬁnition of special-status as stated in Section 3.6.1 of the Program EIR) are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent would implement the following measures to avoid loss of individuals and maintain habitat function of occupied habitat:
• Physically avoid the area occupied by the special-status plants by establishing a no-disturbance buﬀer around the area occupied by species and marking the buﬀer boundary with high-visibility ﬂagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway)
o The no-disturbance buﬀers would generally be a minimum of 50 feet from special-status plants, but the size and shape of the buﬀer zone may be adjusted if a qualiﬁed RPF or botanist determines that a smaller buﬀer would be suﬃcient to avoid loss of or damaging to special-status plants or that a larger buﬀer is necessary to suﬃciently protect plants from the treatment activity
o The appropriate size and shape of the buﬀer zone would be determined by a qualiﬁed RPF or botanist and would depend on plant phenology at Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
and
during
treatme
nt
The City of
Pleasanton
The City of
Pleasanton

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the time of treatment (e.g., whether the plants are in a dormant, vegetative, or ﬂowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain
o Consideration of factors such as site hydrology, changes in light, edge eﬀects, and potential introduction of invasive plants and noxious weeds may inform an appropriate buﬀer size and shape
• Treatments may be conducted within this buﬀer if the potentially aﬀected special-status plant species is a geophytic, stump-sprouting, or annual species and the treatment can be conducted outside of the growing season (e.g., after it has completed its annual life cycle) or during the dormant season using only treatment activities that would not damage the stump, root system, or other underground parts of special-status plants or destroy the seedbank • Treatments would be designed to maintain the function of special-status plant habitat
o For example, for a fuel break proposed in treatment areas occupied by special-status plants, if the removal of shade cover would degrade the special-status plant habitat despite the requirement to physically or seasonally avoid the special-status plant itself, habitat function would be diminished, and the treatment would need to be modiﬁed or precluded from implementation
• No ﬁre ignition (nor use of associated accelerants) would occur within the special-status plant buﬀer

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A qualiﬁed RPF or botanist with knowledge of the special-status plant species habitat and life history would review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual eﬀects of the treatment would be signiﬁcant under CEQA because implementation of the treatment would not maintain habitat function of the special- status plant habitat (i.e., the habitat would be rendered unsuitable) or because the loss of special-status plants would substantially reduce the number or restrict the range of a special-status plant species. If the project proponent determines the impact on special- status plants would be less than signiﬁcant, no further mitigation would be required. If the project proponent determines that the loss of special-status plants or degradation of occupied habitat would be signiﬁcant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then MM BIO-1c would be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or botanist that the special-status plants would beneﬁt from treatment in the occupied habitat area even though some of the non-listed special-status plants may be killed during treatment activities. For a treatment to be considered beneﬁcial to non- listed special-status plants, the qualiﬁed RPF or botanist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the species [or similar species] has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence would be included in the PSA. If it is determined that treatment activities would be beneﬁcial to special-status plants, no compensatory mitigation would be required.

Project-Speciﬁc Measures

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To avoid impacts on herbaceous annual forb species within suitable habitat, prescribed herbivory, prescribed burning, and mowing would be restricted to outside the vegetative growth period in occupied habitat until after the species has set seed. Manual treatments may occur with an avoidance buﬀer under the advisory of a qualiﬁed RPF or biologist. No Project-related ground disturbance would occur generally within a 50-foot buﬀer of these identiﬁed locations. The size and shape of the generally 50-foot buﬀer may be adjusted if a qualiﬁed RPF or biologist determines that a smaller or larger buﬀer would be suﬃcient to avoid impacts on listed plants.

To avoid impacts on special-status herbaceous perennial forb species within suitable habitat, prescribed herbivory, prescribed burning, and mowing would be restricted to outside the vegetative grown period in occupied habitat until after the species has set seed. Manual treatments may occur with an avoidance buﬀer. 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 may be adjusted if a qualiﬁed RPF or biologist determines that a smaller or larger buﬀer would be suﬃcient to avoid impacts.

To avoid impacts on persistent above-ground perennial species within suitable habitat, a no-disturbance buﬀer of at least 50 feet will be implemented, 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 may be adjusted if a qualiﬁed RPF or biologist determines that a smaller or larger buﬀer would be suﬃcient to avoid impacts on listed plants.

If pre-treatment surveys are conducted outside of the bloom period for these species, and individuals within the same genus of special-status plants are identiﬁed, these individuals would be treated as potentially special-status species and would be oﬀered the same protective buﬀer for avoidance.

MM BIO-1c: Compensate for Unavoidable Loss of Special-Status Plants Initial Treatment: N N/A N/A N/A

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If signiﬁcant impacts on listed or non-listed special-status plants cannot feasibly be avoided as speciﬁed under the circumstances described under MMs BIO-1a and 1b, the project proponent would prepare a Compensatory Mitigation Plan that identiﬁes the residual signiﬁcant impacts that require compensatory mitigation and describes the compensatory mitigation strategy being implemented and how unavoidable losses of special-status plants would be compensated. The project proponent would consult with CDFW and/or any other applicable responsible agency prior to ﬁnalizing the Compensatory Mitigation Plan to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan. If the special-status plant taxa are listed under ESA or CESA, the plan would be submitted to CDFW and/or USFWS (as appropriate) for review and comment.

The ﬁrst priority for compensatory mitigation would be preserving and enhancing existing populations outside of the treatment area in perpetuity, or if that is not an option because existing populations that can be preserved in perpetuity are not available, one of the following mitigation options would be implemented by the project proponent instead:
• Creating populations on mitigation-sites outside of the treatment area through seed collection and dispersal (annual species) or transplantation (perennial species)
• Purchasing mitigation credits from a CDFW- or USFWS-approved conservation or mitigation bank in suﬃcient quantities to oﬀset the loss of occupied habitat • If the aﬀected special-status plants are not listed under ESA or CESA, compensatory mitigation may include restoring or enhancing degraded habitats so that they are made suitable to support special-status plant species in the future
If relocation eﬀorts are part of the Compensatory Mitigation Plan, the plan would include details on the methods to be used, including collection, storage, propagation, receptor site preparation, installation, long-term protection and management, monitoring and reporting requirements, success criteria, and remedial action responsibilities should the initial eﬀort fail to meet long-term monitoring requirements. The following performance standards would be applied for relocation:

Treatment
Maintenance:

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• The extent of occupied area would be substantially similar to the aﬀected occupied habitat and would be suitable for self-producing populations o Re-located/re-established populations would be considered suitable for self-producing when:
▪ Habitat conditions allow for plants to reestablish annually for a minimum of 5 years with no human intervention, such as
supplemental seeding; and
▪ Reestablished habitats contain an occupied area comparable to existing occupied habitat areas in similar habitat types in the region
If preservation of existing populations or creation of new populations is part of the mitigation plan, the Compensatory Mitigation Plan would include a summary of the proposed compensation lands and actions (e.g., the number and type of credits, location of mitigation bank or easement, restoration or enhancement actions), parties responsible for the long-term management of the land, and the legal and funding mechanisms (e.g., holder of conservation easement or fee title). The project proponent would submit evidence that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory plant populations would be preserved in perpetuity.

If mitigation includes dedication of conservation easements, purchase of mitigation credits, or other oﬀ-site conservation measures, the details of these measures would be included in the mitigation plan, including information on responsible parties for long-term management, conservation easement holders, long-term management requirements, funding assurances, and success criteria such as those listed above and other details, as appropriate to target the preservation of long-term viable populations.

If mitigation includes restoring or enhancing habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan would include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored habitat.

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If the loss of occupied habitat cannot be oﬀset (e.g., if preservation of existing populations or creation of new populations through relocation eﬀorts are not available for a certain species), and as a result, treatment activities would substantially reduce the number or restrict the range of listed plant species, then the treatment would not qualify as within the scope of this PEIR.

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

MM BIO-2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed Wildlife Species and California Fully Protected Species (All Treatment Activities) If California Fully Protected Species or species listed under ESA or CESA are observed during reconnaissance surveys (conducted pursuant to SPR BIO-1) or focused or protocol- level surveys (conducted pursuant to SPR BIO-10), the project proponent would avoid adverse eﬀects to the species by implementing the following:

Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent would implement one of the following two measures to avoid mortality, injury, or disturbance of individuals:

1. Treatment would not be implemented within the occupied habitat. Any treatment activities outside occupied habitat would be a suﬃcient distance from the occupied habitat such that mortality, injury, or disturbance of the species would not occur, as determined by a qualiﬁed RPF or biologist using the most current and commonly accepted science and considering published agency guidance; OR

2. Treatment would be implemented outside the sensitive period of the species’ life history (e.g., outside the breeding or nesting season), during which the species may be more susceptible to disturbance or disturbance could result in loss of eggs or young. For species present year-round, CDFW and/or USFWS/NOAA Fisheries would be consulted to determine if there is a period of time within Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
and
during
The City of
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The City of
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which treatment could occur that would avoid mortality, injury, or disturbance of the species.
a. For species listed under ESA or CESA, if the project proponent cannot avoid mortality, injury, or disturbance by implementing one of the two options listed above, the project proponent would implement MM BIO- 2c.
b. Injury or mortality of California Fully Protected Species is prohibited pursuant to Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code and would be avoided.

Maintain Habitat Function
The project proponent would design treatment activities to maintain the habitat function by implementing the following:
• While performing review and surveys for SPR BIO-1 and SPR BIO-10, a qualiﬁed RPF or biologist would identify any habitat features that are necessary for survival (e.g., habitat necessary for breeding, foraging, shelter, movement) of the aﬀected wildlife species (e.g., trees with complex structure, trees with large cavities, trees with nesting platforms; dens; tree snags; large raptor nests [including inactive nests]; downed woody debris; food sources) o These habitat features would be marked and treatments applied to the features would be designed to minimize or avoid the loss or degradation of suitable habitat for listed species during treatments o Identiﬁcation and treatment of these features would be based on the life history and habitat requirements of the aﬀected species and the most current, commonly accepted science
• If it is determined during implementation of SPR BIO-1 and SPR BIO-10 that listed or fully protected wildlife with speciﬁc requirements for high canopy cover (e.g., Humboldt marten, ﬁsher, spotted owl, coastal California gnatcatcher, riparian woodrat) are present within a treatment area, then tree or shrub canopy cover within existing suitable areas would be retained at the percentage preferred by the species (as determined by expert opinion, published habitat association information, or other documented standards that are commonly accepted [e.g.,

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50 percent for coastal California gnatcatcher]) such that habitat function is maintained
• A qualiﬁed RPF or biologist would determine if, after implementation of the impact avoidance measures listed above, the habitat function would remain for the aﬀected species after implementation of the treatment o Because this measure pertains to species listed under CESA or ESA or are fully protected, the qualiﬁed RPF or biologist would consult with CDFW and/or USFWS/NOAA Fisheries regarding the determination that habitat function is maintained
▪ If consultation determines that the treatment would not maintain habitat function for the special-status species, the project proponent would implement MM BIO-2c
Project-Speciﬁc Measures
California Red-Legged Frog
If California red-legged frog is assumed present or detected during protocol-level surveys, the following measures would be implemented:

Mechanized operations would be shut down when the precipitation threshold is met, and the shutdown period would begin once the precipitation event has ended.

If California red-legged frog is detected during focused surveys, the project proponent would require ﬂagging areas for avoidance in which no treatment activities would occur, biological monitoring, or other measures recommended by CDFW as necessary to avoid injury to or mortality of these species. If impacts would remain signiﬁcant under CEQA and the project proponent determines that additional mitigation is necessary to reduce signiﬁcant impacts, MM BIO-2c would be required, and incidental take permitting under CESA may be required pursuant to consultation with CDFW.

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During the dispersal season from October 15 (or after the ﬁrst rainfall of the year) through April 15, pre-treatment visual surveys would be performed daily by an RPF, qualiﬁed biologist, or biological monitor, prior to implementation of any treatment activities (i.e., mechanical, manual, and herbicide) within breeding, upland, or dispersal habitat as determined by a qualiﬁed biologist. If a California red-legged frog is found during pre- activity surveys or enters the Project site during treatment activities, all work would stop within a non-disturbance buﬀer of 100 feet around the individual unless the qualiﬁed RPF or biologist determines that a diﬀerent sized buﬀer is appropriate to avoid disturbance, injury, or mortality. Treatment activities would cease within the buﬀer until the animal leaves on its own, and the occurrence would be reported to the qualiﬁed RPF or biologist and USFWS.

Speciﬁc habitat features (i.e., log, tree, debris pile) used by frogs observed on-site would be evaluated by a qualiﬁed RPF or biologist for habitat retention, if habitat retention is achievable while meeting project goals of reducing fuel loads.

All herbicide use during project implementation would comply with the herbicide use restrictions in the stipulated injunction issued by the Federal District Court for the Northern District of California to resolve the 2006 case brought against USEPA by the Center for Biological Diversity. For example, to comply with the injunction, only cut stump and basal bark applications would be allowed in California red-legged frog habitat under the following conditions.

Cut stump and basal bark applications may be used but would not be applied within 60 feet of breeding or non-breeding aquatic habitat.

If operators need to move or treat large woody debris greater than 12 inches in diameter, that piece of woody debris would be evaluated for the presence of California red-legged frog by a qualiﬁed biologist, qualiﬁed professional, RPF, RPF-supervised designee, or a contractor who has been through the environmental awareness training.

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All contractors, their employees, and agency personnel involved in the implementation of the project would check for the presence of any sensitive wildlife under or next to stationary vehicles prior to operating their vehicles. If a special-status reptile or amphibian is found, the qualiﬁed RPF or biologist would determine necessary next steps to avoid impact.

If pile burning is implemented, piles would be placed away from mammal burrows, rock outcrops, or scrub habitat that could serve as refugia for Alameda whipsnake, western pond turtle, or California red-legged frog. Within suitable habitat for California red-legged frog, burn piles would be burned gradually and lit from one end (the uphill side on slopes) to allow animals that may be using the pile for refuge to escape. When feasible, a single pile would be ignited, and all other piles in the vicinity of the burning pile would be carried to the burning pile and burned in the same location as the initial burn pile. When feasible, this strategy would minimize risk to wildlife using piles for refuge.

Whenever feasible in forested environments adjacent to scrublands (for Alameda whipsnake and California red-legged frog) or in oak woodland or grasslands (for California red-legged frog), understory vegetation would be removed ﬁrst, followed by trees, to facilitate visibility of sensitive reptiles and amphibians by a qualiﬁed RPF or biologist.

Alameda Whipsnake
Within suitable Alameda whipsnake habitat, pre-treatment surveys would be combined with a focused survey to identify individuals and burrow sites within the Project footprint.

If individuals are encountered, they would be protected with an appropriate avoidance buﬀer and would be allowed to leave the work area of their own volition.

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Pre- and during-treatment Surveys. Either treatment will avoid occupied habitat or treatment will be implemented in such a way that it does not disturb Alameda whipsnake.

If work occurs within occupied a qualiﬁed RPF or biologist be present on-site to monitor for Alameda whipsnake, ﬂag areas for avoidance and establish no-work buﬀers. 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 throughout the vegetation removal activity within suitable Alameda whipsnake habitat, and if work ceases more than one 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.

Prior to vegetation clearing activities within suitable Alameda whipsnake habitat, coverboards would be installed in key areas as determined by a RFP or qualiﬁed biologist.

The coverboards would be strategically placed to provide refuge for the Alameda whipsnake leaving the work area. Coverboards would be inspected at the end of each workday, and wildlife using them would be recorded.

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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. 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. 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 habitat, heavy equipment, including mowing equipment which may collapse burrows, would be utilized exclusively from stable operating surfaces such as established roads and trails.

Seasonal restrictions: 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)). Manual treatments may occur in cooler conditions, after the qualiﬁed biologist has thoroughly surveyed the area. In habitat suitable for Alameda whipsnake suitable winter retreats, as determined by a qualiﬁed biologist, prescribed broadcast burning would not occur between approximately 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.

Debris management: 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. Chipped materials would not be spread on suitable refugia for Alameda whipsnake such as rodent burrows or rocky outcrops.

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Pile burning: 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. Directional pile burning: 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.

Maintaining Alameda Whipsnake Habitat Function. Suitable Alameda whipsnake habitat is described in the USFWS Critical Habitat Designation (USFWS 2006) as comprising three habitat types: core scrub, dispersal/foraging habitat, and rocky outcrop habitat. Dispersal and foraging habitat includes woodland or annual grassland contiguous to core scrub habitat. The nature of the Project activities would not change the habitat functional 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 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. The following techniques would be implemented during treatment: 1. Vegetation removal would occur in irregular, oblong shapes to maintain a natural condition. 2. Vegetation removal would avoid rocky outcrops.

3. The overall dominant habitat type would not be converted. 4. Vegetation removal would focus on dead, woody vegetation, and invasive plants.

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Preliminary and post-treatment surveys would be conducted that would assess the condition and acreage of Alameda whipsnake core scrub habitat. 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 types 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.

Listed Avian Species
If it is infeasible to avoid vegetation treatment within nesting season, only manual treatment would be permitted and a RPF or biological monitor would be available on- site 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.” No trees containing raptor nests would be removed; trees containing golden eagle nests would not be removed pursuant to the Bald and Golden Eagle Protection Act.

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

3.6.1 of the Program EIR) are observed during reconnaissance surveys (conducted pursuant to SPR BIO-1) or focused or protocol-level surveys (conducted pursuant to SPR BIO-10), the project proponent would avoid or minimize adverse eﬀects to the species by implementing the following:

Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior to
and
during
The City of
Pleasanton
The City of
Pleasanton

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Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent would implement the following to avoid mortality, injury, or disturbance of individuals:
• For all treatment activities except prescribed burning, the project proponent would establish a no-disturbance buﬀer around occupied sites (e.g., nests, dens, roosts, middens, burrows, nurseries)
o Buﬀer size would be determined by a qualiﬁed RPF or biologist using the most current, commonly accepted science and would consider published agency guidance; however, buﬀers would generally be a minimum of 100 feet, unless site conditions indicate a smaller buﬀer would be suﬃcient for protection or a larger buﬀer would be needed o Factors to be considered in determining buﬀer size would include but not be limited to the species’ tolerance to disturbance; the presence of natural buﬀers provided by vegetation or topography; nest height; locations of foraging territory; baseline levels of noise and human activity; and treatment activity
o Buﬀer size may be adjusted if the qualiﬁed RPF or biologist determines that such an adjustment would not be likely to adversely aﬀect (i.e., cause mortality, injury, or disturbance to) the species within the nest, den, burrow, or other occupied site
o If a no-disturbance buﬀer is reduced below 100 feet from an occupied site, a qualiﬁed RPF or biologist would provide the project proponent with a site- and/or treatment activity-speciﬁc explanation for the buﬀer reduction, which would be included in the PSA
▪ After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced buﬀer as explained in the PSA, this would be documented in the post-project implementation
report (referred to by CAL FIRE as a Completion Report). o No-disturbance buﬀers would be marked with high-visibility ﬂagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway)
o No activity would occur within the buﬀer areas until the qualiﬁed RPF or biologist has determined that the young have ﬂedged or dispersed; the

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nest, den, or other occurrence is no longer active; or reducing the buﬀer would not likely result in disturbance, mortality, or injury o A qualiﬁed RPF, biologist, or biological technician would be required to monitor the eﬀectiveness of the no-disturbance buﬀer around the nest, den, burrow, or other occurrence during treatment
▪ If treatment activities cause agitated behavior of the individual(s), the buﬀer distance would be increased, or treatment activities modiﬁed until the agitated behavior stops ▪ The qualiﬁed RPF, biologist, or biological technician would have the authority to stop any treatment activities that could result in mortality, injury, or disturbance to special-status species • For prescribed burning, the project proponent would implement the treatment outside the sensitive period of the species’ life history (e.g., outside the breeding or nesting season), during which the species may be more susceptible to disturbance, or disturbance could result in loss of eggs or young o For species present year-round, the qualiﬁed RPF or biologist would determine the period of time within which prescribed burning could occur that would avoid or minimize mortality, injury, or disturbance of the species
o The project proponent may consult with CDFW and/or USFWS for technical information regarding appropriate limited operating periods Maintain Habitat Function
For all treatment activities, the project proponent would design treatment activities to maintain the habitat function by implementing the following:
• While performing review and surveys for SPR BIO-1 and SPR BIO-10, a qualiﬁed RPF or biologist would identify any habitat features that are necessary for survival (e.g., habitat necessary for breeding, foraging, shelter, movement) of the aﬀected wildlife species (e.g., trees with complex structure, trees with large cavities, trees with nesting platforms; tree snags; large raptor nests [including inactive nests]; downed woody debris)

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o These habitat features would be marked and treatments applied to the features would be designed to minimize or avoid the loss or degradation of suitable habitat for listed species during treatments. Identiﬁcation and treatment of these features would be based on the life history and habitat requirements of the aﬀected species and the most current, commonly accepted science
• If it is determined during implementation of SPR BIO-1 and SPR BIO-10 that special-status wildlife with speciﬁc requirements for high canopy cover (e.g., northern goshawk, Sierra Nevada snowshoe hare) are present within a treatment area, then tree or shrub canopy cover within existing suitable areas would be retained at the percentage preferred by the species (as determined by expert opinion, published habitat association information, or other documented standards that are commonly accepted) such that the habitat function is maintained
o A qualiﬁed RPF or biologist would determine if, after implementation of the impact avoidance measures listed above, the habitat function would remain for the aﬀected species after implementation of the treatment o The qualiﬁed RPF or biologist may consult with CDFW and/or USFWS for technical information regarding habitat function
• A qualiﬁed RPF or biologist with knowledge of the special-status wildlife species habitat and life history would review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual eﬀects of the treatment would be signiﬁcant under CEQA because implementation of the treatment would not maintain habitat function of the special-status wildlife species’ habitat or because the loss of special-status wildlife would substantially reduce the number or restrict the range of a special-status wildlife species
o If the project proponent determines the impact on special-status wildlife would be less than signiﬁcant, no further mitigation would be required o If the project proponent determines that the loss of special-status wildlife or degradation of occupied habitat would be signiﬁcant under

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CEQA after implementing feasible treatment design alternatives and impact minimization measures, then MM BIO-2c would be implemented The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or biologist that the non-listed special-status wildlife would beneﬁt from treatment in the occupied habitat area even though some of the non-listed special-status wildlife may be killed, injured, or disturbed during treatment activities. For a treatment to be considered beneﬁcial to non-listed special-status wildlife, the qualiﬁed RPF or biologist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the species [or similar species] has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence would be included in the PSA. If it is determined that treatment activities would be beneﬁcial to special-status wildlife, no compensatory mitigation would be required. The qualiﬁed RPF or biologist may consult with CDFW and/or USFWS for technical information regarding the determination that a non-listed special-status species would beneﬁt from the treatment.

Project-Speciﬁc Measures
Northwestern pond turtle
To avoid impacts on northwestern pond turtle, focused visual encounter surveys will be incorporated with pre-treatment surveys within suitable habitat to detect species and potentially suitable burrows. Surveys would be conducted within approximately 1,500 feet of aquatic habitat (e.g., streams, ponds). If upland habitat with suitable burrows/nest sites for northwestern pond turtle is detected, the qualiﬁed RPF or biologist would inspect the burrow to determine whether it is occupied. If northwestern pond turtle is detected or assumed present, MM BIO-2b for these species would be implemented.

Within suitable habitat where northwestern pond turtle is detected or assumed present, following measures would be implemented:
• Mechanized operations would be shut down when the precipitation threshold is met, and the shutdown period would begin once the precipitation event has ended

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• If treatment activities occur within or adjacent to suitable or occupied habitat for special-status aquatic reptile and amphibians, MM BIO-2b requires ﬂagging areas for avoidance and establishing no-work buﬀers
o 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 impacts would remain signiﬁcant under CEQA and the Project proponent determines that additional mitigation is necessary to reduce signiﬁcant impacts, MM BIO-2c would be required, and incidental take permitting under CESA may be required pursuant to consultation with CDFW
• If a special-status aquatic reptile or amphibian enters the Project site during treatment activities, all work would stop within a non-disturbance buﬀer around the individual as determined by a qualiﬁed RPF or biologist o Treatment activities would cease within the buﬀer until the animal leaves on its own volition
• 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 a special-status reptile or amphibian is found, the qualiﬁed RPF or biologist would determine necessary next steps to avoid impact • Pile burning treatment would avoid potential refugia for special-status aquatic reptile and amphibian species
• 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
Burrowing Owl

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If burrowing owl is detected during focused surveys or assumed present, a no-disturbance buﬀer would be established around the den or habitat assumed to be occupied, the size of which would be determined by the qualiﬁed RPF or biologist, and no treatment activities would occur within this buﬀer. 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 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.

Special-Status Avian Species
If it is infeasible to avoid vegetation treatment within nesting season, only manual treatment would be permitted, and a 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.

Special-Status Bats: Pallid bat and Townsend’s big-eared bat

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Due to the diﬃculty of detecting bats during traditional daytime surveys, pre-treatment bat surveys would incorporate 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). If special-status bat roosts are detected during focused surveys, a no-disturbance buﬀer of 250 feet would be established around active pallid bat, Townsend’s big-eared bat, 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 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 from 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. Bat exclusion must be overseen by a qualiﬁed bat biologist.

San Francisco Dusky-Footed Woodrat

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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.

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, to ensure safety regarding viruses and diseases potentially carried by rodents, is recommended. • 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
o 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

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American Badger
If American badger is detected during focused surveys or assumed present, a no- disturbance buﬀer would be established around the den or habitat assumed to be occupied, the size of which would be determined by the qualiﬁed RPF or biologist, and no treatment activities would occur within this buﬀer. 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 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.

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

Compensation may include:

1. Preserving existing habitat outside of the treatment area in perpetuity; this may entail purchasing mitigation credits and/or lands from a CDFW- or USFWS-approved entity in suﬃcient quantity to oﬀset the residual signiﬁcant impacts, generally at a ratio of 1:1 for habitat; and

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

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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

1. For preserving existing habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan would include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanisms for long- term conservation (e.g., holder of conservation easement or fee title). The project proponent would submit evidence that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory habitat would be preserved in perpetuity.

2. For restoring or enhancing habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan would include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long- term management and monitoring of the restored habitat.

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

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

MM BIO-2d: Implement Protective Measures for Valley Elderberry Longhorn Beetle (All Treatment Activities)
If elderberry shrubs within the documented range of valley elderberry longhorn beetle are identiﬁed during review and surveys for SPR BIO-1, and valley elderberry longhorn beetle or likely occupied suitable elderberry habitat (e.g., within riparian, within historic riparian, containing exit holes) is conﬁrmed to be present during protocol-level surveys following the protocol outlined in USFWS 2017 per SPR BIO-10, the following protective measures would be implemented to avoid and minimize impacts to valley elderberry longhorn beetle:
• If elderberry shrubs are 165 feet or more from the treatment area and treatment activities would not encroach within this distance, direct or indirect impacts are not expected, and further mitigation is not required
• If elderberry shrubs are located within 165 feet of the treatment area, the following measures would be implemented:
o A minimum avoidance area of at least 20 feet from the dripline of each elderberry plant would be fenced or ﬂagged and maintained to avoid direct impacts (e.g., damage to root system) that could damage or kill the plant, with the exception of the following activities:
▪ Manual trimming of elderberry shrubs would only occur between November and February and would avoid removal of any branches or stems that are greater than or equal to 1 inch in diameter to avoid and minimize adverse eﬀects on valley elderberry longhorn beetle
▪ Manual or mechanical vegetation treatment within the drip line of any elderberry shrub would be limited to the season when adults are not active (August–February), would be limited to methods that do not cause ground disturbance, and would avoid damaging the elderberry
Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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o A qualiﬁed RPF, biologist, or biological technician familiar with valley elderberry longhorn beetle and its life history would monitor the work area to verify the avoidance and minimization measures are implemented
▪ The qualiﬁed RPF, biologist, or biological technician would have the authority to stop any treatment activities that could result in potential adverse eﬀects to valley elderberry longhorn beetle If the project proponent cannot implement the measures above to avoid mortality, injury, or disturbance of valley elderberry longhorn beetle or degradation of occupied habitat such that its function would not be maintained, the project proponent would implement MM BIO-2c.

MM BIO-2e: Design Treatment to Retain Special-Status Butterﬂy Host Plants (All Treatment Activities)
If federally listed butterﬂies are identiﬁed as occurring or having potential to occur during review and surveys for SPR BIO-1 and conﬁrmed during protocol-level surveys per SPR BIO-10, then the following measures would be implemented:
• Treatment areas within the range of these species would be surveyed for the host plant for each species (Table 3.6-34)
• Host plants for federally listed butterﬂies within the occupied habitat would be marked with high-visibility ﬂagging, fencing, or stakes, and no treatment activities would occur within 10 feet of these plants
• Because prescribed herbivory could result in the indiscriminate removal of the host plants for federally listed butterﬂies, this treatment type would not be used within occupied habitat of any federally listed butterﬂy species, unless it is known that the host plant is unpalatable to the herbivore
• Treatment areas that are not occupied but are within the range of the federally listed butterﬂy would be divided into as many treatment units as feasible such that the entirety of the habitat is not treated within the same year • Treatments would be conducted in a patchy pattern to the extent feasible in areas that are not occupied but are within the range of the federally listed Initial
Treatment: Y
Treatment
Maintenance:

Y
Before
and
during
The City of
Pleasanton
The City of
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butterﬂy, such that the entirety of the habitat is not burned or removed and untreated portions of suitable habitat are retained
If the project proponent cannot implement the measures above to avoid mortality, injury, or disturbance of federally listed butterﬂies or degradation of occupied habitat (host plants) such that its function would not be maintained, the project proponent would implement MM BIO-2c.

CESA- and ESA-Listed Species. A qualiﬁed RPF or biologist would determine if, after implementation of any feasible impact avoidance measures (potentially including others not listed above), the treatment would result in mortality, injury, or disturbance, or if after implementation of the treatment, habitat function would remain for the aﬀected species.

For species listed under CESA or ESA or that are fully protected, the qualiﬁed RPF or biologist would consult with CDFW and/or USFWS regarding this determination. If consultation determines that mortality, injury, or disturbance of listed butterﬂies or degradation of occupied habitat such that its function would not be maintained would occur, the project proponent would implement MM BIO-2c.

Other Special-Status Species. A qualiﬁed RPF or biologist with knowledge of the special- status species’ habitat and life history would review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual eﬀects of the treatment would be signiﬁcant under CEQA because implementation of the treatment would not maintain habitat function of the special-status species’ habitat or because the loss of special-status individuals would substantially reduce the number or restrict the range of a special-status species. If the project proponent determines the impact on special-status butterﬂies would be less than signiﬁcant, no further mitigation would be required. If the project proponent determines that the loss of special-status butterﬂies or degradation of occupied habitat would be signiﬁcant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then MM BIO-2c would be implemented.

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The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or biologist that the special-status butterﬂy species would beneﬁt from treatment in the occupied habitat area even though some may be killed, injured, or disturbed during treatment activities. For a treatment to be considered beneﬁcial to special-status butterﬂy species, the qualiﬁed RPF or biologist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the species (or similar species) has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources). If it is determined that treatment activities would be beneﬁcial to special-status butterﬂies, no compensatory mitigation would be required.

Table 3.6-34 Special-Status Butterﬂies and Associated Host Plants Butterﬂy Species Host Plants
bay checkerspot butterﬂy dwarf plantain (Plantago virginica), purple owl’s clover (Castilleja exserta)
Behren’s silverspot butterﬂy blue violet (Viola adunca) callippe silverspot butterﬂy California golden violet (Viola pedunculata) Carson wandering skipper salt grass (Distichlis spicata) El Segundo blue butterﬂy seacliﬀ buckwheat (Eriogonum parvifolium) Hermes copper butterﬂy spiny redberry (Rhamnus crocea)
Kern primrose sphinx moth plains evening-primrose (Camissonia contorta), ﬁeld primrose (Camissonia campestris)
Laguna Mountains skipper Cleveland’s horkelia (Horkelia clevelandii), sticky cinquefoil (Drymocallis glandulosa)
Lange’s metalmark butterﬂy naked-stemmed buckwheat (Eriogonum nudum)

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lotis blue butterﬂy seaside bird’s foot trefoil (Hosackia gracilis) Mission blue butterﬂy lupine (Lupinus spp.)
Myrtle’s silverspot butterﬂy blue violet
Oregon silverspot butterﬂy blue violet
Palos Verdes blue butterﬂy Santa Barbara milkvetch (Astragalus trichopodus), common deerweed (Acmispon glaber)
San Bruno elﬁn butterﬂy broadleaf stonecrop (Sedum spathulifolium), manzanita (Arctostaphylos spp.), huckleberry (Vaccinuum spp.)
Smith’s blue butterﬂy seacliﬀ buckwheat, seaside buckwheat (Eriogonum latifolium) Quino checkerspot butterﬂy dwarf plantain, purple owl’s clover Project-Speciﬁc Measures
Monarch Butterﬂy
Pre-treatment surveys would incorporate a focused survey to identify suitable larval and overwintering habitat and all life stages of monarch butterﬂy. If monarch butterﬂy, monarch larvae host plants (e.g., Asclepias californica, A. fascicularis, A. speciosa) or overwintering roost trees are detected, 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, an appropriate buﬀer would be established as determined by a qualiﬁed RPF or biologist. Avoidance buﬀers would be ﬂagged by the Project proponent within which no treatment activities would occur, a qualiﬁed biologist or RPF would be available to provide guidance as needed. 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.”

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MM BIO-2f: Avoid Habitat for Special-Status Beetles, Flies, Grasshoppers, and Snails (All Treatment Activities)
If treatment activities would occur within the limited range of any state or federally listed beetle, ﬂy, grasshopper, or snail, and these species are identiﬁed as occurring or having potential to occur due to the presence of potentially suitable habitat during review and surveys for SPR BIO-1 and surveys for SPR BIO-10, then the following measures would be implemented:
• To avoid and minimize impacts to Mount Hermon June beetle and Zayante band- winged grasshopper, treatment activities would not occur within “Sandhills” habitat in Santa Cruz County, the only suitable habitat for these species • To avoid and minimize impacts to Casey’s June beetle, Delhi Sands ﬂower-loving ﬂy (Rhaphiomidas terminates abdominalis), Delta green ground beetle (Elaphrus virisis), Morro shoulderband snail, Ohlone tiger beetle (Cicindela ohlone), and Trinity bristle snail, treatment activities would not occur within habitat in the range of these species that is deemed suitable by a qualiﬁed RPF or biologist with familiarity of the species
If the project proponent cannot implement the measures above to avoid mortality, injury, or disturbance to listed beetles, ﬂies, grasshoppers, and snails, or degradation of suitable habitat such that its function would not be maintained, the project proponent would implement MM BIO-2c.

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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MM BIO-2g: Design Treatment to Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Special-Status Bumble Bees (All Treatment Activities) If special-status bumble bees are identiﬁed as occurring during review and surveys under SPR BIO-1 and conﬁrmed during protocol-level surveys per SPR BIO-10, or if suitable habitat for special-status bumble bees is identiﬁed during review and surveys under SPR BIO-1 (e.g., wet meadow, forest meadow, riparian, grassland, or coastal scrub habitat containing suﬃcient ﬂoral resources within the range of the species), then the project proponent would implement the following measures, as feasible:
• Prescribed burning within occupied or suitable habitat for special-status bumble bees would occur from October through February to avoid the bumble bee ﬂight season
• Treatment areas in occupied or suitable habitat would be divided into a suﬃcient number of treatment units such that the entirety of the habitat is not treated within the same year; the objective of this measure is to provide refuge for special-status bumble bees during treatment activities and temporary retention of suitable ﬂoral resources proximate to the treatment area • Treatments would be conducted in a patchy pattern to the extent feasible in occupied or suitable habitat, such that the entirety of the habitat is not burned or removed and untreated portions of occupied or suitable habitat are retained (e.g., ﬁre breaks would be aligned to allow for areas of unburned ﬂoral resources for special-status bumble bees within the treatment area) • Herbicides would not be applied to ﬂowering native plants within occupied or suitable habitat to the extent feasible during the ﬂight season (March– September)
CESA- and ESA-Listed Species. A qualiﬁed RPF or biologist would determine if, after implementation of feasible avoidance measures (potentially including others not listed above), the treatment would result in mortality, injury, or disturbance to the species, or if after implementation of the treatment, habitat function would remain for the aﬀected species. For species listed under CESA or ESA or that are fully protected, the qualiﬁed RPF or biologist would consult with CDFW and/or USFWS regarding this determination. If consultation determines that mortality, injury, or disturbance of listed bumble bees (in the event the Candidate listing is conﬁrmed) or degradation of occupied (or assumed to be occupied) habitat such that its function would not be maintained would occur, the project proponent would implement MM BIO-2c.

Initial
Treatment: Y
Treatment
Maintenance:

Y
Before
and
during
The City of
Pleasanton
The City of
Pleasanton

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Other Special-Status Species. A qualiﬁed RPF or biologist with knowledge of the special- status species’ habitat and life history would review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual eﬀects of the treatment would be signiﬁcant under CEQA because implementation of the treatment would not maintain habitat function of the special-status species’ habitat or because the loss of special-status individuals would substantially reduce the number or restrict the range of a special-status species. If the project proponent determines the impact on special-status bumble bees would be less than signiﬁcant, no further mitigation would be required. If the project proponent determines that the loss of special-status bumble bees or degradation of occupied (or assumed to be occupied) habitat would be signiﬁcant under CEQA after applying feasible treatment design alternatives and impact minimization measures, then MM BIO-2c would be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or biologist that the special-status bumble bee species would beneﬁt from treatment in the occupied (or assumed to be occupied) habitat area even though some of the non-listed special-status bumble bees may be killed, injured, or disturbed during treatment activities. For a treatment to be considered beneﬁcial to special-status bumble bee species, the qualiﬁed RPF or biologist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the species (or similar species) has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence would be included in the PSA. If it is determined that treatment activities would be beneﬁcial to special-status bumble bees, no compensatory mitigation would be required.

Project-Speciﬁc Measures

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CDFW (2023) issued “Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species”, which oﬀers a survey methodology for Crotch's and obscure bumble bees, among others. In lieu of or in addition to surveys, the Project 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, and a biologist would be available as needed to provide guidance when crews are working within suitable bumble bee habitat. If identiﬁed, these burrows would be protected with an avoidance buﬀer.

MM BIO-2h: Avoid Potential Disease Transmission Between Domestic Livestock and Special-Status Ungulates (Prescribed Herbivory)
The project proponent would implement the following measure if treatment activities are planned within the range of desert bighorn sheep, peninsular bighorn sheep, Sierra Nevada bighorn sheep, or pronghorn:
• Prescribed herbivory activities would be prohibited within a 14-mile buﬀer around suitable habitat for any species of bighorn sheep within the range of these species consistent with the more stringent recommendations in the bighorn sheep recovery plan (USFWS 2007)
• Prescribed herbivory activities would be avoided within the range of pronghorn where feasible (where this range does not overlap with the range of any species of bighorn sheep)
Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A
MM BIO-3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak Woodlands
The project proponent would implement the following measures when working in treatment areas that contain sensitive natural communities identiﬁed during surveys conducted pursuant to SPR BIO-3:
• Reference Appendix 2, Table A2 of California vegetation (Sawyer, Keeler-Wolf, and Evens 2009 or current version, including updated natural communities data online) or other best available information to determine the natural ﬁre regime of the speciﬁc sensitive natural community type (i.e., alliance) present Initial
Treatment: Y
Treatment
Maintenance:

Y
Before
and
during
The City of
Pleasanton
The City of
Pleasanton

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o The condition class and ﬁre return interval departure of the vegetation alliances present would also be determined
• Design treatments in sensitive natural communities and oak woodlands to restore the natural ﬁre regime and return vegetation composition and structure to their natural condition to maintain or improve habitat function of the aﬀected sensitive natural community
o Treatments would be designed to replicate the ﬁre regime attributes for the aﬀected sensitive natural community or oak woodland type, including seasonality, ﬁre return interval, ﬁre size, spatial complexity, ﬁreline intensity, severity, and ﬁre type (as described in Van Wagtendonk et al. 2018 and Sawyer, Keeler-Wolf, and Evens 2009 or current version, including updated natural communities data online)
o Treatments would not be implemented in sensitive natural communities that are within their natural ﬁre return interval (i.e., time since last burn is less than the average time required for that vegetation type to recover from ﬁre) or within Condition Class 1
• To the extent feasible, no fuel breaks would be created in sensitive natural communities with rarity ranks of S1 (critically imperiled) and S2 (imperiled) • To the extent feasible, fuel breaks would not remove more than 20 percent of the native vegetation relative cover from a stand of sensitive natural community vegetation in sensitive natural communities with a rarity rank of S3 (vulnerable) or in oak woodlands
o In forest and woodland sensitive natural communities with a rarity rank of S3, and in oak woodlands, only shaded fuel breaks would be installed, and they would not be installed in more than 20 percent of the stand of sensitive natural community or oak woodland vegetation (i.e., if the sensitive natural community covers 100 acres, no more than 20 acres would be converted to create the fuel break)
• Use prescribed burning as the primary treatment activity in sensitive natural communities that are ﬁre-dependent (e.g., closed-cone forest and woodland alliances, chaparral alliances characterized by ﬁre-stimulated, obligate seeders), to the extent feasible and appropriate based on the ﬁre regime attributes (as

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described in Van Wagtendonk et al. 2018 and Sawyer, Keeler-Wolf, and Evens 2009 or current version, including updated natural communities data online) • Time prescribed herbivory to occur when non-target vegetation is not susceptible to damage (e.g., non-target vegetation is dormant or has completed its reproductive cycle for the year)
o For example, use herbivores to control invasive plants growing in sensitive habitats or sensitive natural communities when sensitive vegetation is dormant but invasive plants are growing
o Timing of herbivory to avoid non-target vegetation would be determined by a qualiﬁed botanist, RPF, or biologist based on the speciﬁc vegetation alliance being treated, the life forms and life conditions of its characteristic plant species, and the sensitivity of the non-target vegetation to the eﬀects of herbivory
The feasibility of implementing the avoidance measures would be determined by the project proponent based on whether implementation of this MM would preclude completing the treatment project within the reasonable period of time necessary to meet CalVTP program objectives, including but not limited to protection of vulnerable communities. If the avoidance measures are determined by the project proponent to be infeasible, the project proponent would document the reasons implementation of the avoidance strategies are infeasible in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any change in the feasibility of avoidance strategies from those explained in the PSA, this would be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).

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A qualiﬁed RPF or botanist with knowledge of the aﬀected sensitive natural community would review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual eﬀects of the treatment would be signiﬁcant under CEQA because implementation of the treatment would not maintain habitat functions of the sensitive natural community or oak woodland. If the project proponent determines the impact on sensitive natural communities or oak woodlands would be less than signiﬁcant, no further mitigation would be required. If the project proponent determines that the loss or degradation of sensitive natural communities or oak woodlands would be signiﬁcant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then MM BIO-3b would be implemented.

The only exception to this mitigation approach is in cases where it is determined by a qualiﬁed RPF or botanist that the sensitive natural community or oak woodland would beneﬁt from treatment in the occupied habitat area even though some loss may occur during treatment activities. For a treatment to be considered beneﬁcial to a sensitive natural community or oak woodland, the qualiﬁed RPF or botanist would demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientiﬁc studies demonstrating that the community (or similar community) has beneﬁtted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence would be included in the PSA. If it is determined that treatment activities would be beneﬁcial to sensitive natural communities or oak woodlands, no compensatory mitigation would be required.

MM BIO-3b: Compensate for Loss of Sensitive Natural Communities and Oak Woodlands If signiﬁcant impacts on sensitive natural communities or oak woodlands cannot feasibly be avoided or reduced as speciﬁed under MM BIO-3a, the project proponent would implement the following actions:
• Compensate for unavoidable losses of sensitive natural community and oak woodland acreage and function by:

Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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o Restoring sensitive natural community or oak woodland functions and acreage within the treatment area
o Restoring degraded sensitive natural communities or oak woodlands outside of the treatment area at a suﬃcient ratio to oﬀset the loss of acreage and habitat function; or
o Preserving existing sensitive natural communities or oak woodlands of equal or better value to the sensitive natural community lost through a conservation easement at a suﬃcient ratio to oﬀset the loss of acreage and habitat function
• The project proponent would prepare a Compensatory Mitigation Plan that identiﬁes the residual signiﬁcant eﬀects on sensitive natural communities or oak woodlands that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual eﬀects, and:
o For preserving existing habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan would include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., holder of conservation easement or fee title)
▪ The project proponent would submit evidence that the
necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory habitat would be preserved in
perpetuity
o For restoring or enhancing habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan would include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties

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responsible for long-term management and monitoring of the restored or enhanced habitat
The project proponent would consult with CDFW and/or any other applicable responsible agency prior to ﬁnalizing the Compensatory Mitigation Plan in order to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan.

MM BIO-3c: Compensate for Unavoidable Loss of Riparian Habitat If, after implementation of SPR BIO-4, impacts to riparian habitat remain signiﬁcant under CEQA, the project proponent would implement the following:
• Compensate for unavoidable losses of riparian habitat acreage and function by:
o Restoring riparian habitat functions and acreage within the treatment area
o Restoring degraded riparian habitat outside of the treatment area; o Purchasing riparian habitat credits at a CDFW-approved mitigation bank; or
o Preserving existing riparian habitat of equal or better value to the riparian habitat lost through a conservation easement at a suﬃcient ratio to oﬀset the loss of riparian habitat function and value • The project proponent would prepare a Compensatory Mitigation Plan that identiﬁes the residual signiﬁcant eﬀects on riparian habitat that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual eﬀects, and:
o For preserving existing riparian habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan would include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., holder of conservation easement or fee title)
▪ The project proponent would submit evidence that the
necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it Initial
Treatment: N
Treatment
Maintenance:

N/A N/A N/A

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and that compensatory plant populations would be preserved in perpetuity
o For restoring or enhancing riparian habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan would include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored or enhanced habitat
The project proponent would consult with CDFW and/or any other applicable responsible agency prior to ﬁnalizing the Compensatory Mitigation Plan to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan. Compensatory mitigation may be satisﬁed through compliance with permit conditions, or other authorizations obtained by the project proponent (e.g., Lake and Streambed Alteration Agreement), if these requirements are equally or more eﬀective than the mitigation identiﬁed above.

MM BIO-4: Avoid State and Federally Protected Wetlands
Impacts to wetlands would be avoided using the following measures:
• The qualiﬁed RPF or biologist would delineate the boundaries of federally protected wetlands according to methods established in the USACE wetlands delineation manual (Environmental Laboratory 1987) and the appropriate regional supplement for the ecoregion in which the treatment is being implemented
• The qualiﬁed RPF or biologist would delineate the boundaries of wetlands that may not meet the deﬁnition of waters of the United States, but would qualify as waters of the state, according to the state wetland procedures (California Water Boards 2019 or current procedures)
• A qualiﬁed RPF or biologist would establish a buﬀer around wetlands and mark the buﬀer boundary with high-visibility ﬂagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway)
o The buﬀer would be a minimum width of 25 feet but may be larger if deemed necessary
Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior
and
during
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Pleasanton
The City of
Pleasanton

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
o The appropriate size and shape of the buﬀer zone would be determined in coordination with the qualiﬁed RPF or biologist and would depend on the type of wetland present (e.g., seasonal wetland, wet meadow, freshwater marsh, vernal pool), the timing of treatment (e.g., wet or dry time of year), whether any special-status species may occupy the wetland and the species’ vulnerability to the treatment activities, environmental conditions and terrain, and the treatment activity being implemented
• A qualiﬁed RPF or biological technician would periodically inspect the materials demarcating the buﬀer to conﬁrm that they are intact and visible, and wetland impacts are being avoided
• Within this buﬀer, herbicide application is prohibited • Within this buﬀer, soil disturbance is prohibited
o Accordingly, the following activities are not allowed within the buﬀer zone: mechanical treatments, prescribed herbivory, equipment and vehicle access or staging
• Only prescribed (broadcast) burning may be implemented in wetland habitats if it is determined by a qualiﬁed RPF or biologist that:
o No special-status species are present in the wetland habitat o The wetland habitat function would be maintained
o The prescribed burn is within the normal ﬁre return interval for the wetland vegetation types present
o Fire containment lines and pile burning are prohibited within the buﬀer No ﬁre ignition (nor use of associated accelerants) would occur within the wetland buﬀer.

MM BIO-5: Retain Nursery Habitat and Implement Buﬀers to Avoid Nursery Sites The project proponent would implement the following measures while working in treatment areas that contain nursery sites identiﬁed in surveys conducted pursuant to SPR BIO-10:
• Retain Known Nursery Sites: A qualiﬁed RPF or biologist would identify the important habitat features of the wildlife nursery and, prior to treatment Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior
and
during
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The City of
Pleasanton

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

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ENTITY
activities, would mark these features for avoidance and retention during treatment
• Establish Avoidance Buﬀers: The project proponent would establish a non- disturbance buﬀer around the nursery site if activities are required while the nursery site is active/occupied
o The appropriate size and shape of the buﬀer would be determined by a qualiﬁed RPF or biologist, based on potential eﬀects of project-related habitat disturbance, noise, visual disturbance, and other factors o No treatment activity would commence within the buﬀer area until a qualiﬁed RPF or biologist conﬁrms that the nursery site is no longer active/occupied
o Monitoring of the eﬀectiveness of the non-disturbance buﬀer around the nursery site by a qualiﬁed RPF, biologist, or biological technician during and after treatment activities would be required o If treatment activities cause agitated behavior of the individual(s), the buﬀer distance would be increased, or treatment activities modiﬁed until the agitated behavior stops
o The qualiﬁed RPF, biologist, or biological technician would have the authority to stop any treatment activities that could result in potential adverse eﬀects to special-status species
Project-Speciﬁc Measures
Pre-treatment surveys would be combined with a focused nesting (birds) and maternity roost (bats) survey during appropriate breeding season within the project footprint and at minimum 50-foot buﬀer.

Nesting Birds

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
Pre-treatment surveys would incorporate a focused nesting survey during nesting season to identify active nests within the Project footprint and would be 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 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 Project 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 qualiﬁed RPF or 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 qualiﬁed RPF or biologist encounter an active nest of a migratory bird species, the biologist would establish an avoidance buﬀer of at least 50 feet 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 will work closely with a qualiﬁed RPF or biologist. 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.

Greenhouse Gas Emissions
MM GHG-2. Implement GHG Emission Reduction Techniques During Prescribed Burns When planning for and conducting a prescribed burn, project proponents implementing a prescribed burn would incorporate feasible methods for reducing GHG emissions, including the following, which are identiﬁed in NWCG (2020):
• Reduce the total area burned by isolating and leaving large fuels (e.g., large logs, snags) unburned
• Reduce the total area burned through mosaic burning;
• Burn when fuels have a higher fuel moisture content;
• Reduce fuel loading by removing fuels before ignition Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior
and
during
The City of
Pleasanton
The City of
Pleasanton

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

MONITORING
ENTITY
o Methods to remove fuels include mechanical treatments, manual treatments, prescribed herbivory, and biomass utilization; and • Schedule burns before new fuels appear
As the science evolves, other feasible methods or technologies to sequester carbon could be incorporated, such as conservation burning, a technique for burning woody material that reduces the production of smoke particulates and carbon released into the atmosphere and generates more biochar. Biochar is produced from the material left over after the burn and spread with compost to increase soil organic matter and soil carbon sequestration. Technologies to reduce greenhouse gas emissions may also include portable units that perform gasiﬁcation to produce electricity or pyrolysis that produces biooil that can be used as liquid fuel and/or syngas that can be used to generate electricity.

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

Hazardous Materials, Public Health, and Safety
MM HAZ-3: Identify and Avoid Known Hazardous Waste Sites Initial
Treatment: Y
Treatment
Maintenance:

Y
Prior The City of
Pleasanton
The City of
Pleasanton

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MITIGATION MEASURES APPLICABLE?
(Y/N) TIMING IMPLEMENTING
ENTITY

VERIFYING/

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

Noise
MM NOI-1: Avoid Conﬂicts with Local Noise Ordinances During Prescribed Herbivory Prior to commencing prescribed herbivory treatments, The City would post signs including 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.

Y Prior,
During
The City of
Pleasanton
The City of
Pleasanton

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November 2025
Attachment
B

Attachment B
Cultural Resources Report (Conﬁdential)

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November 2025
Attachment
C

Attachment C
Statement of Overriding Considerations

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November 2025
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Project-Speciﬁc California Environmental Quality Act
Findings and Statement of Overriding Considerations

INTRODUCTION
The City of Pleasanton , referred to herein as “Project Proponent,” in the exercise of its independent judgment, makes and adopts the following ﬁndings regarding its decision to approve the Augustin Bernal Community Park Fuel Reduction Project, referred to herein as “vegetation treatment project,” within the scope of the California Vegetation Treatment Program (CalVTP). This document has been prepared in accordance with the California Environmental Quality Act ( CEQA; Pub. Resources Code, Sections 21000 et seq.) and the CEQA Guidelines (Cal.

Code Regs., Tit. 14, Sections 15000 et seq.).

STATUTORY REQUIREMENTS FOR FINDINGS
Public Resources Code section 21002 provides that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the signiﬁcant environmental eﬀects of such projects[.]” The same section provides that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the signiﬁcant eﬀects of projects and the feasible alternatives or feasib le mitigation measures which will avoid or substantially lessen such signiﬁcant eﬀects” (Pub. Resources Code, Section 21002). Section 21002 goes on to provide that “in the event [that] speciﬁc economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more signiﬁcant eﬀects thereof.” The mandate and principles announced in Public Resources Code section 21002 are implemented, in part, through the requirement that agencies must adopt ﬁndings before approving projects for which Environmental Impact Reports (EIRs) are required (see Pub. Resources Code, Section 21081, subd. [a]; CEQA Guidelines, Section 15091, subd. [a]). For each signiﬁcant environmental eﬀect identiﬁed in an EIR for a project, the approving agency must issue a written ﬁnding reaching one or more of three permissible conclusions per CEQA Guidelines, Section 15091, subd. (a), and Pub. Resources Code, Section 21081, subd. (a):

1. Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the signiﬁcant environmental eﬀect as identiﬁed in the ﬁnal EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the ﬁnding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

3. Speciﬁc economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identiﬁed in the ﬁnal EIR.

EXHIBIT B

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Public Resources Code section 21061.1 deﬁnes “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, legal, and technological factors” (see also Citizens of Goleta Valley v. Bd. of Supervisors [1990] 52 Cal.3d 553, 565).

With respect to a project for which signiﬁcant impacts are not avoided or substantially lessened, a public agency, after adopting proper ﬁndings, may nevertheless approve the project if the agency ﬁrst adopts a Statement of Overriding Considerations setting forth the speciﬁc reasons why the agency found that the project’s “beneﬁts” rendered “acceptable” its “unavoidable adverse environmental eﬀects” (CEQA Guidelines, Sections 15093, 15043, subd. (b); see also Pub. Resources Code, Section 21081, subd. (b)). The California Board of Forestry and Fire Protection (the Board) adopted Findings and a Statement of Overriding Considerations on December 30, 2019.

Here, as explained in the Board’s Findings, the Draft Program EIR (Draft PEIR), and the Final PEIR (collectively, the “PEIR”), the CalVTP would result in signiﬁcant and unavoidable environmental eﬀects to Aesthetics; Air Quality; Archaeological, Historical, and Tribal Cultural Resources; Biological Resources; Greenhouse Gas Emissions; Transportation; and Public Services, Utilities, and Service Systems. For reasons set forth in the Board’s Statement of Overriding Considerations , however, the Board determined that overriding economic, social, and other considerations outweigh the signiﬁcant, unavoidable eﬀects of the CalVTP.

When a responsible agency approves a vegetation treatment project using a within the scope ﬁnding for all environmental impacts, it must adopt its own CEQA ﬁndings, pursuant to Section 15091 of the CEQA Guidelines and, if needed, a statement of overriding considerations, pursuant to Section 15093 of the CEQA Guidelines (see CEQA Guidelines Section 15096 [h]). According to case law, a responsible agency’s ﬁndings need only address environmental impacts “within the scope of the responsible agency’s jurisdic tion” ( Riverwatch v. Olivenhain Municipal Water District [2009] 170 Cal.App.4th 1186, 1202) . Although each responsible agency must adopt its own ﬁndings, such agencies have the option of reusing, incorporating, or adapting all or part of the ﬁndings adopted by the Board for the CalVTP PEIR to meet the agency’s own requirements to the extent the ﬁndings are applicable to the proposed vegetation treatment project. The following document sets forth the required ﬁndings for an agency’s project-speciﬁc approval that relies on and implements the CalVTP PEIR.

The Project Proponent adopts these ﬁndings to document its exercise of its independent judgment regarding the potential environmental eﬀects analyzed in the PEIR and to document its reasoning for approving the vegetation treatment project under the CalVTP in spite of these eﬀects.

BACKGROUND AND PROJECT DESCRIPTION
PD-3: 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 the Augustin Bernal Community Park, located in the high ﬁre hazard severity zone on Pleasanton Ridge in Alameda County, California (Figures C-1 and C-2; CAL FIRE 2022). The Project would be implemented on

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land owned and/or managed by the Project Proponent, 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 portion of the western portion of the Project is within Pleasanton Ridge Regional Park.

While the project 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 C-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 fuels management needs to achieve the shaded fuel break. This project proposes two treatment types consistent with the CalVTP PEIR: fuel breaks and Wildland-Urban Interface ( 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 maintaine d 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 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 provide 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 greenhouse (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.

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Pleasanton City CouncilApril 21, 2026

Pleasanton City Council
April 21, 2026