Riverside City Council
January 25, 2022

Sycamore Hills Distribution Center Project
Draft
Environmental Impact Report (DEIR)
Appendix D – Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Report; Determination of Biologically Equivalent or Superior Preservation (DBESP) Report; Jurisdictional Delineation Report; 2020 Least Bell's Vireo, Southwestern Willow Flycatcher, and Yellow-Billed Cuckoo Survey Results; and Burrowing Owl Focused Survey Report

Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report
Sycamore Hills Distribution Center Project
Riverside County, California

18 December 2020
Submitted to:

Ruth Villalobos & Associates
3602 Inland Empire Blvd., Suite C310
Ontario, California 91764
Contact: Sonya Hooker
Director of Environmental Services
(909) 245-1128
Submitted by:

Wood Environment & Infrastructure Solutions, Inc.
1845 Chicago Avenue, Suite D
Riverside, CA 92507
Contact: John F. Green
Senior Biologist
(951) 369-8060, [email protected]

Wood Project Number: 175550229

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
December 2020
Page ii

TABLE OF CONTENTS PAGE

1.0 INTRODUCTION ............................................................................................................. 1

2.0 PROJECT LOCATION AND SITE DESCRIPTION ......................................................... 1

3.0 METHODS ...................................................................................................................... 9

3.1 Literature Review ................................................................................................. 9

3.2 Biological Resources and Habitat Assessment (Field Investigation)..................... 9

3.3 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas10

4.0 RESULTS ..................................................................................................................... 11

4.1 Soils ................................................................................................................... 11

4.2 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas11

4.3 Vegetation.......................................................................................................... 16

4.4 Habitat Conservation Plans ................................................................................ 21

4.5 Fauna ................................................................................................................ 27

5.0 TEMPORARY AND PERMANENT IMPACTS TO NATURAL COMMUNITIES ............. 29

6.0 RECOMMENDATIONS ................................................................................................. 32

6.1 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas32

6.2 Guidelines Pertaining to the Urban/Wildlands Interface (MSHCP Section 6.1.4) ... 32

6.3 MSHCP BEST MANAGEMENT PRACTICES ..................................................... 38

6.4 SKRHCP and MSHCP ....................................................................................... 42

6.5 Burrowing Owl ................................................................................................... 42

6.6 Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools (MSHCP Section 6.1.2) ...................................................................................... 43

6.7 Paniculate Tarplant and Robinson’s pepper-grass ............................................. 43

6.8 The Federal Migratory Bird Treaty Act and State Codes Protecting Birds .......... 43

7.0 LITERATURE CITED .................................................................................................... 45

LIST OF FIGURES
Figure 1. Regional Map ............................................................................................................ 3 Figure 2. Project Location ......................................................................................................... 5 Figure 3. USGS Topographic Map ............................................................................................ 7 Figure 4. Soils ........................................................................................................................ 12 Figure 5. Drainages ................................................................................................................ 14 Figure 6. Vegetation Communities .......................................................................................... 18 Figure 7. CNDDB Occurrences ............................................................................................... 20 Figure 8. Western Riverside County MSHCP Conservation Lands ......................................... 23 Figure 9. Western Riverside County MSHCP Conservation Lands ......................................... 25 Figure 10. Entry Road Plan ...................................................................................................... 30

LIST OF TABLES
Table 1. Vegetation Communities and Impacts...................................................................... 29

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
December 2020
Page iii

LIST OF APPENDICES
Appendix A Plant Species
Appendix B Vertebrate Species List
Appendix C Photographs
Appendix D Jurisdictional Delineation
Appendix E Sycamore Hills Distribution Center Project, Focused Surveys for the Southwestern Willow Flycatcher and Least Bell’s Vireo
Appendix F Mitigation Planting Plan
Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
December 2020
1 1.0 INTRODUCTION

1.1 Purpose
Wood Environment and Infrastructure Solutions, Inc. (Wood) was contracted by Ruth Villalobos & Associates to conduct an updated biological resources and habitat assessment, including a Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) consistency analysis. The purpose of this assessment and analysis is to support a proposed warehouse project in the City of Riverside, Riverside County, California (Figures 1 and 2) for compliance with the MSHCP and other environmental regulations.

1.2 MSHCP Background
The MSHCP is a comprehensive, multi-jurisdictional effort that includes western Riverside County, the cities within it, and seven public agencies. Rather than address sensitive species on an individual basis, the purpose of the MSHCP is to focus on the collective conservation of 146 species known to occur in the coverage area. Most importantly, the MSHCP allows participating entities to issue take permits for listed species so that individual applicants need not seek their own permits on a case-by-case basis from the USFWS and/or the CDFW.

In western Riverside County many federal and state listed or sensitive species and habitats are now considered “covered species” under the MSHCP. In most instances the MSHCP requires no further surveys for covered species; however, under certain circumstances or in certain areas additional surveys for 38 of these species are required. This plan also satisfies requirements of the Natural Communities Conservation Plan (NCCP) legislation. The MSHCP does not address Section 404 of the Clean Water Act nor the Streambed Alteration Agreement provisions of the California Fish and Game Code, (Section 1600). Projects that currently require a Section 404 permit or Streambed Alteration Agreement will continue to do so notwithstanding the MSHCP. Additionally, the MSHCP does not provide a means of compliance with the federal Migratory Bird Treaty Act (MBTA) or state codes protecting native birds.

1.3 Stephens’ Kangaroo Rat Habitat Conservation Plan Background The Stephens’ Kangaroo Rat Habitat Conservation Plan (SKRHCP) allows for "take" of Stephens’ Kangaroo Rat as part of development activity. "Take" is defined by the Endangered Species Act as any attempt to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to engage in any such conduct. As individual projects are proposed and approved in the SKRHCP fee area, public and private land developers are required to pay a mitigation fee for land that is developed and removes habitat of SKR.

2.0 PROJECT LOCATION AND SITE DESCRIPTION
The proposed project site includes Assessor’s Parcel Numbers: 263-060-022, 263-060-024, and 263-060-026 on 48.64 gross acres (per title report). The project occurs within the MSHCP area.

The project area is bounded by Barton Street (west), Sycamore Canyon Wilderness Park (north), Alessandro Boulevard and self-storage development (south), and vacant property (east). The study area is currently undeveloped with no existing structures. Surrounding land uses include preserved open space to the north as part of Sycamore Canyon Wilderness Park, Metropolitan Water District’s water treatment plant to the west across Barton Street; single- family residential and commercial to the south, across Alessandro Boulevard; a storage facility to the southwest; and undeveloped land to the east.

The project site is located in Section 9 of Township 3 South, Range 4 West, as shown on the United States Geological Survey (USGS) 7.5 minute Riverside East, Ca. quadrangle (Figure 3).

The elevation of the gently rolling project site ranges between 1,574 and 1,610 feet above sea Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
December 2020
2 level. Several drainages and small rock outcrops occur within the site. The geographic coordinates near the middle of the site are 33.91916° North latitude and -117.30918° West longitude.

The property is spread in an east to west direction with natural rolling land descending gradually from a west to east direction. There are two jurisdictional drainages on the site. The undeveloped parcels are covered with a low to moderate growth of vegetation cover consisting of natural grasses and weeds with some granitic rock outcrops.

The project site contains an existing area of approximately 11.6 acres legally designated as “Restricted Property”, see Figure 2. The Restricted Property area supports a jurisdictional drainage and associated riparian habitat and was required as a condition of the Clean Water Act Section 404 permit from the US Army Corps of Engineers for construction of the Grove Community Church at an offsite location, approximately one mile southwest.

Project Description
The project proposes subdividing the site into two numbered parcels (Parcels 1 and 2), and three lettered parcels (Parcels A, B, and C). Each parcel is proposed to be developed with a high cube transload short-term warehouse building (Buildings A and B). Building A, a 400,000 square foot warehouse, will be constructed on Parcel 1. Building B, a 203,100 square foot warehouse, will be constructed on Parcel 2. Associated improvements include parking, fire lanes, fencing and walls (including retaining walls), landscaping, and water quality treatment areas.

Parcels A and Parcel B consist of existing Restricted Property of natural land, with a supporting jurisdictional feature, totaling approximately 11.6 acres. A 0.67-acre driveway will be constructed through the Restricted Property to provide street access from Alessandro Boulevard to Parcel 1, which would reduce the Restricted Property to 10.93 acres. However, 1.44 acres will be added to Parcel A to mitigate this loss., resulting in a total of 12.37 acres of Restricted Property (net gain of 0.77 acres). A Conservation Easement is proposed to be placed over the amended 12.37 acres of Restricted Property.

A trailhead parking lot is proposed on Parcel C, totaling 1.18 acres, for access to the Sycamore Canyon Wilderness Park. Improvements include a parking lot, sidewalk, shade structure, bike rack, drinking fountain, fencing, and a Fire Department and access gate. Parcel C will be dedicated to the City.

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Regional Map
Sycamore Hills Distribution Center
Riverside, CA
Project Location

FIGURE 2
Project Location
Sycamore Hills Distribution Center
Riverside, CA
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Project Details
Additional Restricted Boundary
Existing Restricted Boundary
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USGS Topographic Map
Sycamore Hills Distribution Center
Riverside, CA
Project Location

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
9 3.0 METHODS
The biological study area (BSA ) consisted of the project site. No off-site staging is required.

Development of the Project will be limited to the Project parcels, with the exception of off-site utility and roadway improvements in the existing improved Alessandro Boulevard and Barton Street roadways, directly to the south and west. This section provides brief descriptions of the methods utilized to produce this report and guide the field visit.

3.1 Literature Review
Prior to the field visit a literature review was conducted of the environmental and regulatory setting for the BSA. The literature review provides a baseline from which to evaluate the biological resources potentially occurring within the BSA, and within the local and regional vicinity (a two-mile radius). These references included:
 California Department of Fish and Wildlife (CDFW) California Natural Diversity Data Base (CNDDB) (CDFW 2019a) for known records of special-status elements in the project area. The CNDDB has collected records of special-status elements (plants, animals, natural communities) from museum specimens and other sources dating back for over 100 years and biologists’ reports up to and including today.  California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants of California (CNPS 2019). The CNPS tracks localities and status of plant species of conservation concern. Their database overlaps the CNDDB, but also includes additional records and species not tracked by the CNDDB.
 Soil Survey data (USDA 2019) which includes mapping of all soil types in western Riverside County. This data is important because some specific soil types are associated with certain special-status species.
 MSHCP (Western Riverside County Regional Conservation Authority [WRCRCA] 2019a and 2019b), providing information on how the project will affect the plan and vice versa.  USGS 7.5 minute Riverside East, Ca. topographic quadrangle  Pertinent documents from the Wood library and project files, including records of Wood visits to the project site dating back to January 2014 (Wood was named Amec, then Amec Foster Wheeler during that time period). A complete list of literature and references is included in Section 7.

3.2 Biological Resources and Habitat Assessment (Field Investigation) A 2019 review visit of the BSA was made on November 19, 2019, by Wood senior biologist John F. Green from 8:30 a.m. to 11:00 a.m. The entire project site was walked and/or surveyed by binocular for an overview of current conditions following a normal rainfall year in 2019. This was a field reconnaissance survey, not a focused survey, but the literature review and multiple past visits to the site informed Green of species and habitats to consider. All flora and fauna detected (e.g., through direct observation, vocalizations, presence of scat, tracks, and/or bones) on the project site during the course of the survey were recorded in field notes and are included in Appendices A & B. Plant species of uncertain identity were collected and identified by Andrew Sanders of the University of California, Riverside Herbarium. Multiple photographs were taken for reference during the preparation of this report. A representative sample of project feature photographs is included in Appendix C.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
10 3.3 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas Wood waters and wetlands specialist Dale Hameister visited the site on November 14, 2019, to update the previously prepared 2018 jurisdictional delineation report. Both the original report and this update were prepared according to current guidelines provided by the U.S. Army Corps of Engineers (USACE), CDFW, and Regional Water Quality Control Board (RWQCB). Details are provided in the full report, attached here as Appendix D.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
11 4.0 RESULTS
The literature review and field surveys revealed the following information:

4.1 Soils
The study area crosses seven different mapped soil types (Figure 4) as follows:
 Arlington fine sandy loam (AnC) – This well-drained soil occurs on alluvial fans and terraces with 2 to 8 percent slopes. It is composed of fine sandy loam and the parent material is composed of alluvium dominantly from granitic rocks.  Cieneba sandy loam, eroded (ChF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of sandy loam on the surface and the parent material is composed of coarse-grained igneous rock.  Cieneba rocky sandy loam, eroded (CkF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of rocky sandy loam on the surface and the parent material is composed of coarse-grained igneous rock.  Fallbrook sandy loam, eroded (FaD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of sandy loam and developed on granodiorite and tonalite.
 Fallbrook sandy loam, shallow, eroded (FbC2) – This well-drained soil occurs on uplands with 5 to 8 percent slopes. It is composed of sandy loam and developed on granodiorite and tonalite.
 Fallbrook fine sandy loam, shallow, eroded (FkD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of fine sandy loam and developed on granodiorite and tonalite.
 Vista coarse sandy loam, eroded (VsD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of coarse sandy loam and developed on weathered granite and granodiorite.

None of these common soil types are specifically associated with special-status species.

4.2 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas Wood waters and wetlands specialist Dale Hameister prepared an updated jurisdictional delineation (Appendix D). A Jurisdictional Delineation was conducted to determine if drainages in the BSA qualify as Waters of the United States (WUS) (“WUS” on Figure 5), waters of the state (CDFW on Figure ), and MSHCP riverine/riparian areas (both WUS and CDFW on Figure 5).

ChF2
CkF2
VsD2
AnC
ChF2
FaD2
VsD2
CkF2
FkD2
VsF2
ChD2
FbF2
CkF2
CkF2
FkD2
CkF2
FaD2
AnC
FaD2
FbC2
FfC2
FkD2
FkD2
FbC2
Project Boundary
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°
02 0 0
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FIGURE 4
Soils
Sycamore Hills Distribution Center
Riverside, CA
Label Description
AnC Arlington fine sandy loam, 2 to 8 percent slopes
ChD2 Cieneba sandy loam, 8 to 15 percent slopes, eroded ChF2 Cieneba sandy loam, 15 to 50 percent slopes, eroded CkF2 Cieneba rocky sandy loam, 15 to 50 percent slopes, eroded FaD2 Fallbrook sandy loam, 8 to 15 percent slopes, eroded FbC2 Fallbrook sandy loam, shallow, 5 to 8 percent slopes, eroded FbF2 Fallbrook sandy loam, shallow, 15 to 35 percent slopes, eroded FfC2 Fallbrook fine sandy loam, 2 to 8 percent slopes, eroded FkD2 Fallbrook fine sandy loam, shallow, 8 to 15 percent slopes, eroded VsD2 Vista coarse sandy loam, 8 to 15 percent slopes, eroded VsF2 Vista coarse sandy loam, 15 to 35 percent slopes, eroded Drainage A
Drainage B
Area C
Project Boundary
Project Details
Additional Restricted Boundary
Existing Restricted Boundary
Jurisdictional Areas
CDFW
WUS
1 inch = 200 feet
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FIGURE 5
Drainages
Sycamore Hills Distribution Center
Riverside, CA
Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
16 4.3 Vegetation
The BSA includes the following vegetation categories or types: non-native grassland, riparian woodland, Riversidean sage scrub, and disturbed. The study area is covered with Non-Native Grassland crossed by several drainages, some of which contain Riparian Woodland. Patches of sparse Riversidean Sage Scrub are present in the uplands. Several unpaved trails, which fall in the disturbed category, cross the uplands and drainages within the study area. These four categories are shown on Figure 6. Appendix A lists all vascular plant species observed by Wood to date within the study area.

The site is not within a Narrow Endemic Plant Species Survey Area (NEPSSA) or Criteria Area Plant Species Survey Area (CAPSSA), so no plant surveys are required at the project site for compliance with the MSHCP. For this reason, no focused plant survey has been conducted on the proposed project site, but one special status plant species, paniculate tarplant ( Deinandra paniculata), has been noted incidentally during site visits. Individuals of tarplant ( Deinandra paniculata) have been seen scattered throughout the non-native grassland areas (Figure 6) of the BSA, especially in years with ample rainfall. Paniculate tarplant, which is not covered by the MSHCP, is an annual which has a CNPS California Rare Plant Rank (CRPR) of 4.2. Paniculate tarplant is not state or federally listed as threatened or endangered, and List 4 plants have the lowest sensitivity ranking in the CNPS system as “Plants of Limited Distribution - a Watch List”.

Paniculate tarplant primarily blooms from April through November, but has been recorded blooming in March and December at some locations.

Non-native Grassland
Non-native grassland (40.71 acres in the BSA, see Figure 6) supports a dense to sparse cover of annual grasses. Dominant species include non-native species such as wild oats (Avena spp.), red brome ( Bromus madritensis ssp. rubens), and non-native forbs such as short-pod mustard ( Hirschfeldia incana ) and filaree ( Erodium spp.). A variety of native forbs are associated with this habitat, but their presence is episodic and rainfall dependent. Plants will generally be dead through the summer to fall dry season, with germination beginning with the fall to winter rains and growth and seed-set through the spring.

Riparian Woodland
The riparian woodland (5.12 acres in the BSA, see Figure 6) is dominated by trees and shrubs such as willows ( Salix sp.) and cottonwood ( Populus fremontii) for the over-story species, and mulefat (Baccharis salicifolia) for understory. The understory is relatively sparse, lacking a well- developed mid-story canopy with herbaceous plant species more common than shrubs. The vegetation in this community has suffered from drought and homeless occupation, with some trees and shrubs dead or dying. None of the plant species mentioned here are special-status, but riparian communities provide potential habitat for special-status species.

Riversidean Sage Scrub
Riversidean Sage Scrub (1.68 acres in the BSA, see Figure 6) is dominated by low-statured, a
romatic, drought-deciduous shrubs, and subshrub species. Characteristic species present in the BSA include brittlebush ( Encelia farinosa), California buckwheat ( E riogonum fasciculatum), and California sagebrush ( Artemisia californica). None of the plant species mentioned here are special-status, but Riversidean Sage Scrub provides potential habitat for special-status specie s.

Disturbed
Several open, cleared dirt trails crisscross the study area, comprising 0.76 acre in the BSA (Figure 6). The trails are not vegetated and are used by both humans and animals.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
17 CNDDB records of additional special status vegetation communities and plant species recorded in the past within two miles of the project site are shown on Figure 7. These include:
 Centromadia pungens ssp. laevis, smooth tarplant (MSHCP, CNPS 1B.1). This species has a designated survey area in the MSHCP, and the project is not within that survey area.
 Chorizanthe parryi var. parryi, Parry's spineflower (MSHCP, CNPS 1B.1). Habitat present in the BSA.
 Lepidium virginicum var. robinsonii, Robinson's pepper-grass (CNPS 4.3, not covered by MSHCP). Habitat present in the BSA.
 Southern Sycamore Alder Riparian Woodland. This is not a species, but a CDFW recognized special-status vegetation community that does not occur in the BSA.

For an MSHCP-covered project, potential impacts to smooth tarplant and Parry’s spineflower are covered with no further action necessary. Southern Sycamore Alder Woodland is not present, so is of no further concern. Like paniculate tarplant, Robinson’s pepper-grass is not covered by the MSHCP, and it is an annual which has a CNPS CRPR of 4.3. Robinson’s pepper-grass is not state or federally listed as threatened or endangered, and CNPS List 4 plants have the lowest sensitivity ranking in the CNPS system as “Plants of Limited Distribution - a Watch List”. It is not known to occur on site, but it has not been surveyed for. If any mitigation is determined to be necessary for paniculate tarplant, it could be applied to Robinson’s pepper- grass as well.

Project Boundary
Project Details
No Impact (13.32 acres)
Permanent Impact (34.79 acres)
T emporary Impact (0.16 acres)
Vegetation Community
Disturbed (0.76 acres)
Non-native Grassland
(40.71 acres)
Riparian (5.12 acres)
Riversidean Sage Scrub
(1.68 acres)
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02 0 0
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FIGURE 6
Vegetation Communities
Sycamore Hills Distribution Center
Riverside, CA
No Impact Permanent Impacts Temporary Impacts Grand Total Disturbed/Trail 0.15 0.60 0.01 0.76
Non-native Grassland 7.30 33.27 0.14 40.71
Riparian 4.27 0.84 0.02 5.12
Sparse Riversidean Sage Scrub 0.35 1.33 1.68
Grand Total 12.07 36.04 0.16 48.27

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
21 4.4 Habitat Conservation Plans
The entire project lies within the MSHCP boundaries and is within the “Cities of Riverside and Norco” Area Plan. It is also within the SKRHCP.

MSHCP
Conservation and Reserve Assembly
The project site is not in a criteria area for the MSHCP (not within a Criteria Cell, Cell Group, habitat core or linkage), therefore the project is not required for conservation and it will have no effect on reserve assembly. It is immediately adjacent to the Sycamore Canyon Wilderness Park to the north, which is designated as Public Quasi Public (PQP) lands and Existing Core D of the MSHCP conservation area (Figure 8). Where adjacent to Sycamore Canyon Wilderness Park, the project is at the MSHCP defined urban/wildlands interface. As such, the project is required to comply with the Guidelines Pertaining to the Urban/Wildlands Interface of the MSHCP (Section 6.1.4) and is discussed further in section 6.2 of this report.

Species Associated with Riparian Riverine Areas and Vernal Pools (Section 6.1.2) The areas mapped as WUS and CDFW on Figure 5 are MSHCP riverine/riparian. The implications of this are discussed below. Drainages are considered riverine/riparian if they support habitat for species that are not adequately conserved, such as least Bell’s vireo ( Vireo bellii pusillus), southwestern willow flycatcher ( Empidonax traillii extimus ), and western yellow- billed cuckoo (Coccyzus americanus occidentalis) which are discussed below. Riverine/riparian also includes drainages within MSHCP conservation areas or which might have downstream effects on the MSHCP conservation area.

The habitat assessment for the project determined that habitat was present for the least Bell’s vireo and southwestern willow flycatcher ( Empidonax traillii extimus ) within the riparian woodland vegetation, therefore, the MSHCP requires focused surveys for them pursuant to the MSHCP Section 6.1.2, Protection of Species Associated with Riparian/ Riverine Areas and Vernal Pools. Focused surveys in accordance with USFWS protocols were conducted for the least Bell’s vireo and southwestern willow flycatcher in 2014, with positive results for the vireo and negative results for the flycatcher (see Amec 2014, attached as Appendix E). The least Bell’s vireo protocol requires eight surveys to be conducted at least 10 days apart between April 10 and July 31
st. The southwestern willow flycatcher protocol requires five surveys, and that first survey be performed from May 15 to 31, the next two surveys from June 1 to 24, and the final two surveys between June 25 and July 17, with each survey at least five days apart. The surveys were performed concurrently for least Bell’s vireo and southwestern willow flycatcher.

Habitat is not present for the western yellow-billed cuckoo ( Coccyzus americanus occidentalis) or other riverine/riparian species that would require surveys.

The project site does not contain habitat for fairy shrimp. Fairy shrimp occur in natural vernal pools and other less natural features such as stock ponds, road ruts, and compacted soils.

V
ernal pools are seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation, and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season. Obligate hydrophytes and facultative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season. The determination that an area exhibits vernal pool characteristics, and the definition of the watershed supporting vernal pool hydrology, must be made on a case-by-case basis. Such determinations should consider the length of the time the area exhibits upland and wetland characteristics and the manner in which the area fits into the overall ecological system as a Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
22 wetland. Evidence concerning the persistence of an area's wetness can be obtained from its history, vegetation, soils, and drainage characteristics, uses to which it has been subjected, and weather and hydrologic records ( WRCRCA 2019b ). A fairy shrimp habitat assessment is t
ypically done during a single site visit at any time of year. Wood biologists, however, have a long history on this site dating back to 2014, and no sign of ephemeral pooling has ever been noted during ≥15 visits in all seasons, further supporting the conclusion that fairy shrimp habitat is not present.

Narrow Endemic Plant Species (Section 6.1.3) and Additional Survey Needs and Procedures (Section 6.3.2)
The project is not within the MSHCP designated Criteria Area Plant Species Survey Area (CAPSSA) or Narrow Endemic Plant Species Survey Area (NEPSSA), or within designated survey areas for amphibians or mammals so no additional assessments or focused surveys are required for any of these MSHCP covered plants and wildlife. The project is within the survey area for burrowing owl
Burrowing Owls
The project site is within the MSHCP designated survey area (Figure 9) for burrowing owl (Athene cunicularia ). Focused surveys were conducted for the BUOW in 2018 with negative results (Wood 2018a). The focused surveys were conducted according to the MSHCP’s protocol following the Burrowing Owl Survey Instructions for the Western Riverside Multiple Species Habitat Conservation Plan Area from one hour before sunrise to two hours after sunrise or in the early evening two hours before sunset to one hour after sunset. Surveys were conducted by walking straight line transects spaced no more than 20 meters apart throughout all suitable areas of the site. Burrows suitable for BUOW occupation were closely monitored and inspected during each visit for evidence of BUOW use ( i.e., whitewash, pellets, feathers and other adornments). Binoculars were used to identify birds and to survey perches and potential burrows prior to closer approach. A handheld GPS unit was used to mark potential BUOW burrows. A handheld anemometer (Kestrel model #2000) was used to record temperatures and wind speeds.

No BUOWs or BUOW sign (i.e., whitewash, pellets, feathers, tracks or burrow adornments) were observed or otherwise detected during the course of the 2018 focused surveys. Although no individual BUOW or BUOW sign was observed during the surveys, potentially suitable BUOW burrows were observed within the study area and 150 meter buffer. The nearest known occurrences of burrowing owls (BUOW) are approximately one mile south of the BSA in a Stephens’ kangaroo rat preserve (CDFW 2019a). Focused surveys of potential burrows will be required during the breeding season of March 1 – August 31 to determine if burrowing owls are present now.

SKR HCP
Sycamore Canyon Wilderness Park is designated as part of the Sycamore Canyon-March Air Force Base Core Reserve of the SKRHCP, but the project is not within this reserve. Payment of the fee associated with the SKRHCP will cover all potential impacts to Stephens’ kangaroo rat.

FIGURE 7
Western Riverside County MSHCP
Conservation Lands
Sycamore Hills Distribution Center
Riverside, CA
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0 500250
Feet
1 inch = 500 feet
Service Layer Credits: Esri, HERE, Garmin, (c) OpenStreetMap contributors Project Boundary
Public/Quasi-Public Conserved Lands
FIGURE 8
Western Riverside County MSHCP
Survey Areas
Sycamore Hills Distribution Center
Riverside, CA
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0 500250
Feet
1 inch = 500 feet
Service Layer Credits: Esri, HERE, Garmin, (c) OpenStreetMap contributors Project Boundary
MSHCP Burrowing Owl Survey Area
Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
27 4.5 Fauna
Appendix B lists all wildlife species detected by Wood to date within the BSA. Common wildlife species detected during biological resource assessments include common side-blotched lizard (Uta stansburiana ), Nuttall’s woodpecker ( Picoides nuttallii ), bushtit ( Psaltriparus minimus ), Anna’s hummingbird ( Calypte anna ), house finch ( Carpodacus mexicanus), California ground squirrel ( Otospermophilus beecheyi ), coyote ( Canis latrans ), and desert cottontail ( Sylvilagus audubonii). All native birds are protected by the federal MBTA and state Fish and Game Code.

Wood has also encountered the following special status wildlife species during surveys in the BSA:
2019
 Circus hudsonius, northern harrier (MSHCP, SSC)
 Accipiter cooperii, Cooper's hawk (MSHCP; WL)
 Lepus californicus bennettii, San Diego black-tailed jackrabbit (MSHCP; SSC)  Dipodomys stephensi, Stephens’ kangaroo rat (observed burrows & sign; MSHCP; FE; ST)
 Neotoma sp., wood rat middens* (MSHCP; SSC)
2014-2018
 Crotalus ruber, red-diamond rattlesnake (MSHCP; SSC; S)  Selasphorus rufus/sasin , rufous/Allen’s hummingbird (rufous is a BCC). During the migratory period when rufous and Allen’s occur together, most individuals cannot be identified to species level.
 Phalacrocorax auritus, double-crested cormorant (MSHCP; WL)  Empidonax traillii, willow flycatcher (MSHCP; SE; BCC)  Vireo bellii pusillus, least Bell's vireo (MSHCP; FE, SE)  Eremophila alpestris actia, California horned lark (MSHCP; WL)  Spinus lawrencei, Lawrence’s goldfinch (BCC)
 Setophaga petechia brewsteri, yellow warbler (MSHCP; BCC; SSC)  Aimophila ruficeps canescens, southern California rufous-crowned sparrow (MSHCP; WL)
FE - Federally Endangered; BCC – United States Fish and Wildlife Service Birds of Conservation Concern; SE – California State Endangered, ST – California State Threatened, WL - CDFW Watch List, SSC - CDFW Species of Special Concern; S- USFS Sensitive.
*The MSHCP / SSC San Diego desert woodrat Neotoma lepida ssp. intermedia is the expected species within the study area.

All of the avian, reptile and mammals species above could be found foraging and/or breeding in the non-native grassland community and the associated riparian habitat with the exception of a double-crested cormorant (flyover only). Rufous hummingbird may forage, but only in migration; they do not breed in southern California. The willow flycatchers detected in the BSA were migrants present for foraging only, likely of more northerly subspecies which do not nest in southern California ( E.t. adastus or E.t. brewsteri ), and not southwestern willow flycatchers (subspecies E.t. extimus ). USFWS protocol does not recognize willow flycatchers as the “southwestern” species unless they are found to be nesting or if they stay on-site past the Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
28 migratory period. The MSHCP covers most of the aforementioned species, although some, such as the least Bell’s vireo, have special requirements. Rufous hummingbird and Lawrence’s goldfinch are not covered by the MSHCP but would be protected by migratory bird recommendations below. CNDDB records of additional special status species recorded in the past within two miles of the project site are shown on Figure 7. These records include many of the species already recorded in the BSA, but also:
 Aspidoscelis hyperythra, orange-throated whiptail (MSHCP, WL). Habitat present in the BSA.
 Agelaius tricolor, tricolored blackbird (MSHCP, ST, SSC, BCC). No habitat present in the BSA.
 Chaetodipus fallax fallax, northwestern San Diego pocket mouse (MSHCP, SSC).

Habitat present in the BSA.
 Spea hammondii, western spadefoot (MSHCP, SSC). Like fairy shrimp, this species requires temporary pools to breed. No breeding habitat is present.  Onychomys torridus ramona, southern grasshopper mouse (not covered by MSHCP, SSC). Habitat present in the BSA.
 Lanius ludovicianus, loggerhead shrike (MSHCP, SSC, BCC). Habitat present in the BSA.
 Athene cunicularia, burrowing owl (MSHCP, SSC, BCC). This species has a designated survey area in the MSHCP and the project is within it. 2018 surveys did not detect the species.
 Dipodomys merriami parvus, San Bernardino kangaroo rat (MSHCP, FE, state candidate for listing as endangered, SSC). This species has a designated survey area in the MSHCP, and the project is not within that survey area.
 Phrynosoma blainvillii, coast horned lizard (MSHCP, SSC). Habitat present in the BSA.  Nyctinomops femorosaccus, pocketed free-tailed bat (SSC, not covered by MSHCP). No roosting habitat in the BSA could forage.
 Perognathus longimembris brevinasus, Los Angeles pocket mouse (MSHCP, SSC). This species has a designated survey area in the MSHCP, and the project is not within that survey area.

Least Bell’s vireo and Stephens’ kangaroo rat are the only federally and state listed threatened and/or endangered species that have been observed in the study area. Stephens’ kangaroo rat burrows, scat, sign, and tracks are present throughout the entire grassland areas up to and including 2019. Least Bell’s vireos were detected in the BSA during 2014 focused surveys (Amec 2014). The locations for these detections are shown in Appendix E. Wood avian biologists have not been in the BSA in the breeding season for this species since 2014, but the riparian woodland habitat within the project site is still suitable to support least Bell’s vireo from the time they begin to arrive in mid-March until their departure by early September. There are also multiple CNDDB records of least Bell’s vireo within the surrounding 2-mile radius of the site (Figure 7). Therefore, the future occurrence of least Bell’s vireo, including for nesting, in the BSA is of high potential in the study area. For the purposes of this analysis it is assumed that least Bell’s vireos continue to utilize the riparian woodland habitat areas in the BSA for foraging and nesting in the spring and summer.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
29 Although not covered by the MSHCP, the loss of habitat and/or individuals of southern grasshopper mouse or foraging habitat for pocketed free-tailed bat would not be considered significant. These species are not state or federally listed as threatened or endangered, and are of potential occurrence onsite, but not known to occur. The approximately 12 acres onsite that will be preserved and the Sycamore Canyon Wilderness Park immediately to the north would continue to provide ample habitat for these species in the project area, thus the small incremental loss of potential habitat from development of the project would be insignificant.

The existing culverts flowing into the BSA provide little or no benefit for wildlife movement as they come out of developed areas. A new elevated driveway is proposed to bisect Area C and will include two separate culvert under-crossings: one that crosses in a southwest to northeast direction with two 38-inch high x 57-inch wide arch pipes and one that crosses in a west to east direction with one 38-inch high x 57-inch wide arch pipe (Figure 10). These culverts were included in the design to provide hydrological connection and allow for wildlife to move across Area C without having to cross over the driveway. Animals likely to use these under-crossings include most terrestrial amphibians, reptiles, and mammals that have been recorded onsite such as Baja California treefrog ( Pseudacris hypochondriaca ), western fence lizard ( Sceloporus occidentalis), red-diamond rattlesnake ( Crotalus ruber ), San Diego black-tailed jackrabbit (Lepus californicus bennettii), coyote (Canis latrans), and bobcat (Lynx rufus). Wall nesting birds such as black phoebe ( Sayornis nigricans) and barn swallow ( Hirundo rustica) may also utilize the culvert.

5.0 TEMPORARY AND PERMANENT IMPACTS TO NATURAL COMMUNITIES Impacts to natural communities will occur from the replacement of vegetation with the proposed project facilities and associated parking lots. A total of 35.15 acres of habitat would be temporarily and permanently impacted by the proposed Project. Nonnative grassland will suffer the largest impacts with a total of 0.14 acre temporarily and 32.34 acres permanently impacted.

Riparian woodland habitat will incur 0.02 acre of temporary impact and lose 0.51 acre to permanent impacts. Riversidean sage scrub will not have temporary impacts but losses will total

1.33 acres. Disturbed areas will lose 0.60 acre with an additional 0.01 acre of temporary impacts.

Approximately 8.23 acres of nonnative grassland, 4.59 acres of riparian woodland, 0.35 acre of Riversidean sage scrub and 0.15 acre of disturbed areas within the BSA will not be impacted by project activities but avoided and preserved in place. Vegetation communities and impacts are illustrated in Figure 6.

Table 1 – Vegetation Communities and Impacts
Vegetation Type
Vegetation
Acres Before
Impacts
Temporary
Impacts
(acres)
Permanent
Impacts
(acres)
Total Impacts
(acres)
Vegetation
Not Impacted
(acres)
Non-Native
Grassland 40.71 0.14 32.34 32.57 8.23
Riparian Woodland 5.12 0.02 0.51 0.56 4.59
Riversidean Sage
Scrub 1.68 0 1.33 1.41 0.35
Disturbed 0.76 0.01 0.60 0.61 0.15
Totals 48.27 0.16 34.79 35.15 13.12

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FIGURE 9
Entry Road Plan
Sycamore Hills Distribution Center
Riverside, CA
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
merriami
parvus
Crotalus
ruber
Nyctinomops
femorosaccusPhrynosoma
blainvillii
Aspidoscelis
hyperythra
Crotalus
ruber
Spea
hammondii
Onychomys
torridus
ramona
Lanius
ludovicianus
Chorizanthe
parryi var.
parryi
Lepidium
virginicum var.
robinsonii
Dipodomys
stephensi
Dipodomys
stephensi
Aspidoscelis
hyperythra
Centromadia
pungens
ssp. laevis
Southern Sycamore
Alder Riparian
Woodland
Vireo
bellii
pusillus
Southern Sycamore
Alder Riparian
Woodland
Vireo
bellii
pusillus
Vireo bellii
pusillus
Vireo
bellii
pusillus
Aspidoscelis
hyperythra
Agelaius
tricolor
Dipodomys
stephensi
Spea
hammondii
Dipodomys
stephensi
Dipodomys
stephensi
Vireo bellii
pusillus
Southern Sycamore
Alder Riparian
Woodland
Chaetodipus
fallax
fallax
Dipodomys
stephensi
Perognathus
longimembris
brevinasus
Eremophila
alpestris
actia
Chaetodipus
fallax
fallax
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
stephensi
Vireo bellii
pusillus
Vireo
bellii
pusillus
Vireo
bellii
pusillus
Vireo
bellii
pusillus
Dipodomys
stephensi
Dipodomys
stephensi
Dipodomys
stephensi
Centromadia
pungens
ssp. laevis
Centromadia
pungens
ssp. laevis
Centromadia
pungens
ssp. laevis
Centromadia
pungens
ssp. laevis
Vireo
bellii
pusillus
Athene
cunicularia
Athene
cunicularia
Vireo
bellii
pusillus
Legend
Project Area
2 mile Buffer of Project Area
CNDDB Occurrences
Plants
Wildlife
Vegetation Community
FIGURE
10 1 inch = 0.5 milesCNDDB Occurrences
Sycamore Hills
Riverside County, CA o
00 . 5
Miles
Path: Q:\3554_NaturalResources\SycamoreCanyon_1755500029\MXD\ReportFigures\BioResources_MSHCP_Report_2019\Fig10_CNDDB.mxd, aaron.johnson, 11/22/2019 Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
32 6.0 RECOMMENDATIONS
To comply with applicable regulations protecting waters, wetlands, migratory birds, and for compliance with the MSHCP and SKRHCP, the following is recommended, including Mitigation Measures BIOLOGY-1 through BIOLOGY-8 as identified below under relevant sections of the MSHCP.

6.1 Jurisdictional Waters and Wetlands, Including MSHCP Riverine/Riparian Areas Permitting from the USACE, CDFW, and RWQCB will be required for permanent and temporary impacts to WUS and waters of the state (CDFW). As the onsite WUS and waters of the state also meet the definition of riparian and riverine areas in Section 6.1.2 of the MSHCP, a MSHCP Determination of Biological Equivalent or Superior Preservation (DBESP) is required as 100% avoidance of onsite riparian/riverine areas cannot be met with the proposed project. Section

6.1.2 of the MSHCP outlines the process and the information required as part of a DBESP. A separate DBESP report has been prepared to demonstrate a DBESP finding for the proposed project. Refer to the DBESP for mitigation to ensure replacement of any lost functions and values of WUS, waters of the state, and riparian/riverine areas.

6.2 Guidelines Pertaining to the Urban/Wildlands Interface (MSHCP Section 6.1.4) MSHCP Urban/Wildlands Interface Guidelines are intended to address indirect effects associated with locating development in proximity to the MSHCP Conservation Area. The project site is immediately adjacent to lands to the north, which are conserved as Public Quasi- Public (PQP). Development in proximity to the MSHCP Conservation Area may result in “edge effects” that could adversely affect biological resources within the MSHCP Conservation Area.

To minimize such edge effects, the following guidelines shall be implemented in conjunction with review of development projects in proximity to the MSHCP Conservation Area:
 Drainage
Proposed Developments in proximity to the MSHCP Conservation Area shall incorporate measures, including measures required through the National Pollutant Discharge Elimination System (NPDES) requirements, to ensure that the quantity and quality of runoff discharged to the MSHCP Conservation Area is not altered in an adverse way when compared with existing conditions. In particular, measures shall be put in place to avoid discharge of untreated surface runoff from developed and paved areas into the MSHCP Conservation Area. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials or other elements that might degrade or harm biological resources or ecosystem processes within the MSHCP Conservation Area. This can be accomplished using a variety of methods including natural detention basins, grass swales, or mechanical trapping devices. Regular maintenance shall occur to ensure effective operations of runoff control systems.

A design feature of the proposed project is for the storm water runoff that currently supports Drainage A downstream and outside of the project boundary to continue to flow through the site via an underground 48-inch pipe in the northern parking lot of Building B and convey the discharge flows to Drainage A at the northwest corner of Building B. The project design also includes continued conveyance of stormwater and non-stormwater runoff and connectivity to Drainage B as well as Area C. The existing hydrology support to the riparian/riverine areas located outside and downstream of the project site will not be cut off or significantly reduced. The project will be required to implement these design features as a City condition of approval.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
33  Toxics
Land uses proposed in proximity to the MSHCP Conservation Area that use chemicals or generate bioproducts such as manure that are potentially toxic or may adversely affect wildlife species, habitat, or water quality shall incorporate measures to ensure that application of such chemicals does not result in discharge to the MSHCP Conservation Area. Measures such as those employed to address drainage issues shall be implemented.

The proposed project is required to implement a Project Specific Water Quality Management Plan (WQMP) with Best Management Practices (BMPs) to address the project’s pollutants and preventing them from being discharged into Drainage B or Area C and offsite into downstream receiving waterbodies, including Sycamore Canyon Creek and the Santa Ana River. The project will be required to implement the WQMP as a City condition of approval.
 Lighting
Night lighting shall be directed away from the MSHCP Conservation Area to protect species within the MSHCP Conservation Area from direct night lighting. Shielding shall be incorporated in project designs to ensure ambient lighting in the MSHCP Conservation Area is not increased.

The warehouse buildings will have nighttime lighting for security; however, the lights will be shielded downwards, will have motion detectors, and will only be turned on if and when employees are present. A photometric study is required by the city to ensure that the light sources will be shielded to minimize off-site glare, will not direct light skyward, and will be directed away from adjacent properties and public rights-of-way. If lights are proposed to be mounted on buildings, down-lights shall be utilized. Light poles shall not exceed 20-feet in height. An 8-foot combination wall (4-foot high concrete with 4-foot wrought iron on top) will be constructed along the northern side of Building B to separate the Building B parking and drive areas from the trailhead parking area and block any vehicle headlights from shining into the Sycamore Canyon Wilderness Park to the north. The project will be required to implement these design features as a City condition of approval.

The trail head parking lot, which is located along the northern side of Building B, is a buffer between the warehouse operations at Building B and the wilderness park/preserve. The trail head parking lot will be deeded to the City of Riverside. Per Riverside Municipal Code (RMC) Section 9.08.110, all parks owned by the City of Riverside shall be closed from thirty minutes after sunset of one day and thirty minutes before sunrise of the next day, unless otherwise exempt. Therefore, the trail head parking lot is anticipated to be closed between dusk and dawn and would not have vehicle headlights shining into the park from the parking lot.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
34  Noise
Proposed noise generating land uses affecting the MSHCP Conservation Area shall incorporate setbacks, berms, or walls to minimize the effects of noise on MSHCP Conservation Area resources pursuant to applicable rules, regulations and guidelines related to land use noise standards. For planning purposes, wildlife within the MSHCP Conservation Area should not be subject to noise that would exceed residential noise standards.

Construction
To control noise impacts associated with the construction of a permitted Project, the City of Riverside limits hours of construction to 7:00 a.m. to 7:00 p.m. Monday through Friday, and 8:00 a.m. to 5:00 p.m. on Saturdays. No construction is permitted on Sundays or federal holidays, as outlined in Section 7.35.020 (G) of the General Noise Regulations. Therefore, Project construction noise levels are considered exempt from municipal regulation if activities occur within the hours specified in Section 7.35.020 (G); provided a permit has been obtained from the City as required. However, neither the City of Riverside General Plan nor Municipal Code establish numeric maximum acceptable construction source noise levels at potentially affected receivers for residential uses or sensitive biological resources. A maximum acceptable construction source noise level of 65 dBA is recommended by the Western Riverside County Regional Conservation Authority (RCA) for sensitive riparian/riverine biological receiver locations.
1 Construction noise is anticipated to exceed 65 dBA(A) Leq within portions of the sensitive riparian habitat between the buildings (associated with Drainage B) and the adjacent Sycamore Canyon Wilderness Park. Construction noise impacts will be minimized with implementation of a mitigation measure Noise -1 identified in the project-specific Noise Study for the project as outlined below.

Mitigation Measure Noise-1 : Should LBVI be present in the Sycamore Canyon Wilderness Park within 300 feet of the project site, in Parcel A on-site conservation area, or within Parcel B on-site conservation area within 100 feet of the development footprint, construction noise impacts shall be minimized through implementation of the following measures:

1. Install a 12-foot high temporary noise barrier at the perimeter of the limits of disturbance between the construction activities and the adjacent Sycamore Canyon Wilderness Park to the north and east and the on-site conservation areas. The barrier shall be continuous without openings, holes or cracks, and shall reach the ground. The barrier may be constructed with 1-inch plywood and provide a reduction of at least 10 dB(A) to ensure noise levels do not exceed 65 dB(A) at the Sycamore Canyon Wilderness Park and on-site conservation areas.

Other materials providing the same reduction shall also be permitted.

2. Heavy grade rubber mats/pads will be used within the bed of the trucks. These mats will help attenuate initial impact noise generated when an excavator drops rock and debris into the bed of the truck. These mats must be maintained and/or replaced as necessary.

3. During all project site excavation and grading on-site, construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturer standards.

1 Personal communication between Sonya Hooker, Director of Environmental Services, Ruth Villalobos & Associates, Inc. and Elizabeth Dionne, Ecological Resources Specialist, Western Riverside County Regional Conservation Authority, December 2019.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
35 4. The contractor shall place all stationary construction equipment so that emitted noise is directed away from the noise sensitive receptors nearest the project site.

5. Equipment shall be shut off and not left to idle when not in use.

6. The contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise/vibration sources and sensitive receptors nearest the project site during all project construction.

7. The project proponent shall mandate that the construction contractor prohibit the use of music or sound amplification on the project site during construction.

8. The construction contractor shall limit haul truck deliveries to the same hours specified for construction equipment (7:00 am to 7:00 pm on weekdays, and 8:00 am to 5:00 pm on Saturdays).

9. Limit the use of heavy equipment or vibratory rollers and soil compressors along the project boundaries to the greatest extent possible. It is acknowledged that some soil compression may be necessary along the project boundaries.

10. Any jackhammers, pneumatic equipment and all other portable stationary noise sources shall be shielded and noise shall be directed away from sensitive receptors.

11. For the duration of construction activities, the construction manager shall serve as the contact person should noise levels become disruptive to local residents. A sign shall be posted at the project site with the contact phone number. This sign shall be posted at the Alessandro Boulevard frontage as well as the Barton Street frontage.

Operation
As outlined in Chapter 7.25 of Title 7 of the City’s Municipal Code, residential noise standards include limits of 55 dB(A) Leq during the daytime hours and 45 dB(A) Leq during the nighttime hours, therefore these limits are applied at the property line of the proposed development and adjacent Sycamore Canyon Wilderness Park and on-site conservation areas. Operational noise from the warehouses will be prevented from extending out into the park/preserve by a minimum 4-foot high concrete wall or 8-foot high concrete walls located along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate sound to the sensitive habitat areas: the riparian/riverine habitat in the conservation areas between the buildings and the wilderness park/preserve to the north. An 8-foot high concrete wall will be constructed along the western, northern and eastern sides of the Parcel 1/Building A site and 42-inch high metal post and cable fence will be located along the northern property line of Parcel 1/Building A site. An 8-foot high concrete wall will be constructed along the northeast and eastern side and a 4-foot high concrete wall along the northern side of the Parcel 2/Building B site, along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate light and sound to adjacent area. The project-specific Noise Study indicates operational noise will not exceed residential noise standards in the on-site conservation areas or adjacent Sycamore Canyon Wilderness Park.

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
36  Barriers
Proposed land uses adjacent to the MSHCP Conservation Area shall incorporate barriers, where appropriate in individual project designs to minimize unauthorized public access, domestic animal predation, illegal trespass or dumping in the MSHCP Conservation Area. Such barriers may include native landscaping, rocks/boulders, fencing, walls, signage, and/or other appropriate mechanisms.

As outlined above, the warehouses will have 8-foot high concrete walls located along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate sound to the sensitive habitat areas: the riparian/riverine habitat in the conservation areas between the buildings and the wilderness park/preserve to the north. A 42-inch high cable rail theme fence will be located along the northern property line of Parcel 1/Building A site and the Sycamore Canyon Wilderness Park. Remaining perimeters of the site include 8-foot high tubular steel fence. Therefore, the proposed project includes appropriate barriers to minimize unauthorized public access to the on- site conservation areas. The project will be required to implement these design features as a City condition of approval.
 Grading/Land Development
Manufactured slopes associated with proposed site development shall not extend into the MSHCP Conservation Area.

The proposed project does not include manufactured slopes in the on-site conservation area or the adjacent Sycamore Canyon Wilderness Park.
 Invasives
When approving landscape plans for Development that are proposed adjacent to the MSHCP Conservation Area, Permittees shall consider the invasive, non-native plant species listed below and shall require revisions to landscape plans (subject to the limitations of their jurisdiction) to avoid the use of invasive species for the portions of Development that are adjacent to the MSHCP Conservation Area. Considerations in reviewing the applicability of this list shall include proximity of planting areas to the MSHCP Conservation Areas, species considered in the planting plans, resources being protected within the MSHCP Conservation Area and their relative sensitivity to invasion, and barriers to plant and seed dispersal, such as walls, topography and other features.

Plants That Should Be Avoided Adjacent to the Conservation Area (MSHCP Table 6-2) Botanical Name Common Name
Acacia spp. (all species) acacia
Achillea millefolium var. millefolium common yarrow
Ailanthus altissima tree of heaven
Aptenia cordifolia red apple
Arctotheca calendula cape weed
Arctotis spp. (all species & hybrids) African daisy
Arundo donax giant reed or arundo grass
Asphodelus fistulosus asphodel
Atriplex glauca white saltbush
Atriplex semibaccata Australian saltbush
Carex spp. (all species*) sedge
Carpobrotus chilensis ice plant
Carpobrotus edulis sea fig
Centranthus ruber red valerian
Chrysanthemum coronarium annual chrysanthemum
Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
37 Cistus ladanifer (incl. hybrids/varieties) gum rockrose Cortaderia jubata [syn.C. Atacamensis] jubata grass, pampas grass Cortaderia dioica [syn. C. sellowana] pampas grass
Cotoneaster spp. (all species) cotoneaster
Cynodon dactylon (incl. hybrids, varieties) Bermuda grass Cyperus spp. (all species*) nutsedge, umbrella plant
Cytisus spp. (all species) broom
Delosperma ‘Alba’ white trailing ice plant
Dimorphotheca spp. (all species) African daisy, Cape marigold Drosanthemum floribundum rosea ice plant
Drosanthemum hispidum purple ice plant
Eichhornia crassipes water hyacinth
Elaegnus angustifolia Russian olive
Eucalyptus spp. (all species) eucalyptus or gum tree
Eupatorium coelestinum [syn. Ageratina sp.] mist flower Festuca arundinacea tall fescue
Festuca rubra creeping red fescue
Foeniculum vulgare sweet fennel
Fraxinus uhdei (and cultivars) evergreen ash, shamel ash Gaura (spp.) (all species) gaura
Gazania spp. (all species & hybrids) gazania
Genista spp. (all species) broom
Hedera canariensis Algerian ivy
Hedera helix English ivy
Hypericum spp. (all species) St. John’s Wort
Ipomoea acuminata Mexican morning glory
Lampranthus spectabilis trailing ice plant
Lantana camara common garden lantana
Lantana montevidensis [syn. L. sellowiana] lantana
Limonium perezii sea lavender
Linaria bipartita toadflax
Lolium multiflorum Italian ryegrass
Lolium perenne perennial ryegrass
Lonicera japonica (incl. ‘Halliana’) Japanese honeysuckle Lotus corniculatus birdsfoot trefoil
Lupinus arboreus yellow bush lupine
Lupinus texanus Texas blue bonnets
Malephora crocea ice plant
Malephora luteola ice plant
Mesembryanthemum nodiflorum little ice plant
Myoporum laetum myoporum
Myoporum pacificum shiny myoproum
Myoporum parvifolium (incl. ‘Prostratum’) ground cover myoporum Oenothera berlandieri Mexican evening primrose
Olea europea European olive tree
Opuntia ficus-indica Indian fig
Osteospermum spp. (all species) trailing African daisy, African daisy, Oxalis pes-caprae Bermuda buttercup
Parkinsonia aculeata Mexican palo verde
Pennisetum clandestinum Kikuyu grass
Pennisetum setaceum fountain grass
Phoenix canariensis Canary Island date palm
Phoenix dactylifera date palm
Plumbago auriculata cape plumbago
Polygonum spp. (all species) knotweed
Populus nigra ‘italica’ Lombardy poplar
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38 Prosopis spp. (all species*) mesquite
Ricinus communis castorbean
Robinia pseudoacacia black locust
Rubus procerus Himalayan blackberry
Sapium sebiferum Chinese tallow tree
Saponaria officinalis bouncing bet, soapwart
Schinus molle Peruvian pepper tree, California pepper
Schinus terebinthifolius Brazilian pepper tree
Spartium junceum Spanish broom
Tamarix spp. (all species) tamarisk, salt cedar
Trifolium tragiferum strawberry clover
Tropaelolum majus garden nasturtium
Ulex europaeus prickly broom
Vinca major periwinkle
Yucca gloriosa Spanish dagger
An asterisk (*) indicates some native species of the genera exist that may be appropriate.

Through the City’s Design Review process, the City has required the removal of any plants identified in Table 6.2 of the MSHCP from the Conceptual Landscape Plan.

6.3 MSHCP BEST MANAGEMENT PRACTICES
Standard best management practices (BMPs) from Volume I, Appendix C of the MSHCP shall be implemented to avoid impacts to biological resources of the MSHCP, as follows:

1. A condition shall be placed on grading permits requiring a qualified biologist to conduct a training session for project personnel prior to grading. The training shall include a description of the species of concern and its habitats, the general provisions of the Endangered Species Act (Act) and the MSHCP, the need to adhere to the provisions of the Act and the MSHCP, the penalties associated with violating the provisions of the Act, the general measures that are being implemented to conserve the species of concern as they relate to the project, and the access routes to and project site boundaries within which the project activities must be accomplished.

2. Water pollution and erosion control plans shall be developed and implemented in accordance with RWQCB requirements.

3. The footprint of disturbance shall be minimized to the maximum extent feasible. Access to sites shall be via pre-existing access routes to the greatest extent possible.

4. The upstream and downstream limits of projects disturbance plus lateral limits of disturbance on either side of the stream shall be clearly defined and marked in the field and reviewed by the biologist prior to initiation of work.

5. Projects should be designed to avoid the placement of equipment and personnel within the stream channel or on sand and gravel bars, banks, and adjacent upland habitats used by target species of concern.

6. Projects that cannot be conducted without placing equipment or personnel in sensitive habitats should be timed to avoid the breeding season of riparian species identified in MSHCP Global Species Objective No. 7.

7. When stream flows must be diverted, the diversions shall be conducted using sandbags or other methods requiring minimal instream impacts. Silt fencing or other sediment trapping materials shall be installed at the downstream end of construction activity to minimize the transport of sediments offsite. Settling ponds where sediment is collected shall be cleaned out in a manner that prevents the sediment from reentering the stream.

Biological Resources & MSHCP Consistency Report
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September 2020
39 Care shall be exercised when removing silt fences, as feasible, to prevent debris or sediment from returning to the stream.

8. Equipment storage, fueling, and staging areas shall be located on upland sites with minimal risks of direct drainage into riparian areas or other sensitive habitats. These designated areas shall be located in such a manner as to prevent any runoff from entering sensitive habitat. Necessary precautions shall be taken to prevent the release of cement or other toxic substances into surface waters. Project related spills of hazardous materials shall be reported to appropriate entities including but not limited to applicable jurisdictional city, USFWS, and CDFW, RWQCB and shall be cleaned up immediately and contaminated soils removed to approved disposal areas.

9. Erodible fill material shall not be deposited into water courses. Brush, loose soils, or other similar debris material shall not be stockpiled within the stream channel or on its banks.

10. The qualified project biologist shall monitor construction activities for the duration of the project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat and species of concern outside the project footprint.

11. The removal of native vegetation shall be avoided and minimized to the maximum extent practicable. Temporary impacts shall be returned to pre-existing contours and revegetated with appropriate native species.

12. Exotic species that prey upon or displace target species of concern should be permanently removed from the site to the extent feasible.

13. To avoid attracting predators of the species of concern, the project site shall be kept as clean of debris as possible. All food related trash items shall be enclosed in sealed containers and regularly removed from the site(s).

14. Construction employees shall strictly limit their activities, vehicles, equipment, and construction materials to the proposed project footprint and designated staging areas and routes of travel. The construction area(s) shall be the minimal area necessary to complete the project and shall be specified in the construction plans. Construction limits will be fenced with orange snow screen. Exclusion fencing should be maintained until the completion of all construction activities. Employees shall be instructed that their activities are restricted to the construction areas.

15. The Permittee shall have the right to access and inspect any sites of approved projects including any restoration/enhancement area for compliance with project approval conditions including these BMPs
To ensure compliance with MSHCP Best Management Practices the following mitigation measures are recommended:

Mitigation Measure BIOLOGY-1: The Project has been designed to avoid direct construction impacts to riparian plant communities to the greatest extent feasible. Avoidance and minimization measures shall be included in the Project specifications for implementation during construction to further reduce the potential for any temporary, indirect impacts to occur to these areas during construction activities, including the following:
 Trash and other debris shall be properly disposed of and not left on-site in areas where it could fall into protected habitat.

Biological Resources & MSHCP Consistency Report
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40  Project boundaries shall be clearly marked with fencing, or other suitable type of marking material as directed by a qualified biologist. Vehicles and other Project construction personnel shall stay within these delineated Project boundaries.  Sensitive areas (i.e., jurisdictional drainage features, riparian habitats, and MSHCP Conservation Areas) in proximity to the construction footprint shall be clearly marked, with fencing or other suitable type of marking material as directed by a qualified biologist, for awareness and avoidance.
 Refueling, washing, or other vehicular maintenance activities shall occur a minimum of 100 feet away from riparian areas, including the conserved riparian habitat.  Equipment would be maintained and checked at least on a daily basis for leaks.  All vehicle leaks or other hazardous material leaks shall be contained and cleaned up immediately. All contaminated soil shall be removed from the site and disposed of properly.

Mitigation Measure BIOLOGY-2: During soil excavation, grading, or other subsurface disturbances, the construction contractor shall supervise provision and maintenance of all standard dust control BMPs to reduce fugitive dust emissions, including but not limited to the following actions:
 Water any exposed soil areas a minimum of twice per day, or as allowed under any imposed drought restrictions. On windy days or when fugitive dust can be observed leaving the construction site, additional water shall be applied at a frequency to be determined by the on-site construction superintendent.
 Pave, periodically water, or apply chemical stabilizer to construction access/egress points.
 Minimize the amount of area disturbed by clearing, grading, earthmoving, or excavation operations at all times.
 Operate all vehicles on graded areas at speeds less than 15 miles per hour.  Cover all stockpiles that would not be utilized within three days with plastic or equivalent material, to be determined by the on-site construction superintendent, or spray them with a non-toxic chemical stabilizer.

Mitigation Measure BIOLOGY-3: To address potential short-term impacts to water quality within the on-site drainages from construction runoff that may carry storm water pollutants, a SWPPP shall be implemented by the construction contractor as required by the California General Construction Storm Water Permit pursuant the Regional Board regulations. The SWPPP shall identify BMPs related to the control of toxic substances, including construction fuels, oils, and other liquids. These BMPs would be implemented by the construction contractor prior to the start of any ground clearing activity, shall be subject to periodic inspections by the City and the Project’s hydrological consultant, shall be maintained throughout the construction period and remain in place until all landscape and permanent BMPs are in place. BMPs shall be monitored and repaired if necessary, to ensure maximum erosion, sediment, and pollution control.
 The use of erosion control materials potentially harmful to fish and wildlife species, such as mono-filament netting (erosion control matting) or similar material, within and adjacent to conserved riparian habitat shall be prohibited.

Biological Resources & MSHCP Consistency Report
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September 2020
41  All fiber roles, 2 straw waddles, and/or hay bales utilized within and adjacent to the Project site shall be free of non-native plant materials.  Construction contractor shall comply with all litter and pollution laws. All contractors, subcontractors, and employees shall also obey these laws.  Water containing mud, silt, or other pollutants from grading, aggregate washing, or other activities shall not be allowed to enter the conserved riparian habitat or be placed in locations that may be subjected to high storm flows.  Spoil sites shall not be located within jurisdictional areas and MSHCP Conservation Areas or locations that may be subjected to high storm flows, where spoil shall be washed back into the conserved riparian habitat where it would impact streambed habitat and aquatic or riparian vegetation.
 Raw cement/concrete or washings thereof, asphalt, paint, or other coating material, oil or other petroleum products, or any other substances which could be hazardous to fish and wildlife resources resulting from Project related activities shall be prevented from contaminating the soil and/or entering the conserved riparian habitat.

These materials, placed within or where they may enter the conserved riparian habitat or any party working under contract to the construction contractor, shall be removed immediately.
 No equipment maintenance shall be done within or near the conserved riparian habitat where petroleum products or other pollutants from the equipment may enter these areas under any flow.
 No broken concrete, cement, debris, soil, silt, sand, bark, slash, sawdust, rubbish, or washings thereof, oil or petroleum products, or other organic or earthen material from any construction or associated activity of whatever nature shall be allowed to enter into or be placed where it may be washed by rainfall or runoff into the conserved riparian habitat. When operations are completed, any excess materials or debris shall be removed from the work area. No rubbish shall be deposited within 150 feet of the conserved riparian habitat.

Mitigation Measure BIOLOGY-4: The following measures shall also be incorporated into the construction documents and specifications, and implemented by the contractor, to avoid potential construction-related impacts to the conserved riparian habitat outside of the approved disturbance limits:
 Construction worker training shall be provided by a qualified biologist at the first on- site construction meeting;
 Project boundaries shall be clearly marked and or signs shall be erected near the top of slope adjacent to the conserved riparian habitat to prevent accidental/unauthorized intrusions during construction; and  Staging areas for storage of materials and heavy equipment, and for fueling, cleaning, or maintenance of construction vehicles or equipment, shall be prohibited within 20 feet from the top of slope adjacent to the conserved riparian habitat.

2 Fiber rolls or erosion control mesh shall be made of loose-weave mesh that is not fused at the intersections of the weave, such as jute, or coconut (coir) fiber, or other products without welded weaves. Non-welded weaves reduce entanglement risks to wildlife by allowing animals to push through the weave, which expands when spread.

Biological Resources & MSHCP Consistency Report
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September 2020
42 Mitigation Measure BIOLOGY-5: The Project shall incorporate special edge treatments to minimize edge effects by providing a safe transition between developed areas and the conserved riparian habitat, and which would be compatible with Project operation and the protection and sustainability of conserved areas. The following special edge treatments are applicable to the Project, and shall be implemented:
a) The Project is required to stage construction vehicles and equipment outside of the limits of CDFW jurisdictional streambed and riparian habitat to the maximum feasible distance; and
b) Any manufactured slopes shall be kept within the boundaries of the Project footprint and not encroach into the conserved riparian habitat or the MSHCP Conservation Area.

6.4 SKRHCP and MSHCP
Payment of the SKRHCP fee is required for the project. Impacts to and take authorization for the Stephens’ kangaroo rat is covered under the SKRHCP for this project. Payment of MSHCP fees is required for the project. Payment of the MSHCP fee and compliance with Section 6 of the MSHCP provides full mitigation for the project’s impacts on MSHCP covered species.

To ensure compliance with the mitigation fee requirements of the MSHCP the following mitigation measures are recommended:

Mitigation Measure BIOLOGY-6: The Project shall issue payment to the City for the appropriate SKRHCP fee prior to issuance of a grading permit.

Mitigation Measure BIOLOGY-7: The Project shall issue payment to the City for the appropriate MSHCP fee prior to issuance of a grading permit.

6.5 Burrowing Owl
A focused burrowing owl survey must be conducted during the breeding season (four visits between 1 March - 31 August). Regardless of the result of those surveys, because of the presence of suitable habitat that could be occupied at any time, a one-day preconstruction survey must also be conducted 30 days or less before groundbreaking.

To ensure compliance with section 6.3.2 of the MSHCP the following mitigation measure is recommended:

Mitigation Measure BIOLOGY-8: Prior to issuance of a grading permit, a 30-day pre- construction burrowing owl survey (in accordance with the Burrowing Owl Survey Instructions for the Western Riverside County Multiple Species Habitat Conservation Plan) shall be conducted by a qualified biologist to ensure burrowing owl remain absent from the project site. If burrowing owls are observed on the project site during the pre-construction surveys, a burrowing owl relocation plan shall be prepared and submitted to CDFW and the RCA for review and approval prior to commencement of vegetation clearing/grubbing, grading, and construction activities on the project site. The burrowing owl relocation plan shall outline methods to relocate any burrowing owls occurring on the project site and ensure compliance with the MSHCP, MBTA and California Fish and Game Code. If an active burrow is found during the breeding season (February 1 through August 31) occupied burrows will not be disturbed and will be provided with a protective buffer unless a qualified biologist verifies through noninvasive means that either: (1) the birds have not begun egg laying, or (2) juveniles from the occupied burrows are foraging independently and are capable of independent survival. The size of the buffer will depend on the time of year and level of disturbance.

Biological Resources & MSHCP Consistency Report
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43 6.6 Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools (MSHCP Section 6.1.2)
Focused surveys for the least Bell’s vireo and southwestern willow flycatcher were required pursuant to Section 6.1.2 since suitable habitat is present for them in the BSA. Least Bell’s vireo was present in the BSA during the 2014 focused survey for that species and southwestern willow flycatcher. The project proponent intends to assume that the least Bell’s vireo and southwestern willow flycatcher are present and mitigate accordingly. The DBESP for these species, prepared by RVA (2020) will detail how project mitigation will be equivalent or superior to MSHCP requirements for the preservation of these species and their habitat.

For southwestern willow flycatcher MSHCP requirements are:
 If survey results are positive, 100 percent of the occupied portions of the property that provide for long-term conservation value for the southwestern willow flycatcher shall be conserved in a manner consistent with conservation of the flycatcher. This will involve including 100 meters of undeveloped landscape adjacent to the habitat conserved.

For least Bell's vireo MSHCP requirements are:
 If survey results are positive, 90 percent of the occupied portions of the property that provide for long-term conservation value for the least Bell’s vireo shall be conserved in a manner consistent with conservation of the vireo. This will involve including 100 meters of undeveloped landscape adjacent to the habitat conserved.

6.7 Paniculate Tarplant and Robinson’s pepper-grass
Although not covered by the MSHCP, paniculate tarplant only has a CRPR of 4.2. CNPS List 4 plants have the lowest sensitivity ranking in the CNPS system, “Plants of Limited Distribution - A Watch List.” Impacts from the project on this species are not expected to be significant as it is not expected to substantially reduce the habitat for this species throughout its range. To further reduce impacts to this species, we recommend that seed be collected at the appropriate season and / or that topsoil containing the seed bank be preserved for use in restoration following project completion. This will also benefit Robinson’s pepper-grass, should it occur.

Mitigation Measure BIOLOGY-9: Prior to issuance of a grading permit, a qualified biologist shall collect seed for paniculate tarplant and Robinson’s pepper-grass throughout the proposed development footprint of the project. The seeds shall be stored in accordance with the biologist’s recommendations until restoration efforts are commenced within the existing and additional Restricted Property/conservation area. If seed is not collected prior to grading permit issuance then topsoil, where identified by the qualified biologist, shall be salvaged and temporarily stored in accordance with the qualified biologists’ recommendations until restoration efforts are commenced. On site restoration efforts shall incorporate the collected seed or salvaged topsoil.

6.8 The Federal Migratory Bird Treaty Act and State Codes Protecting Birds The Federal MBTA and/or state codes protect all native bird species - both common and special status. In most scenarios, MSHCP coverage does not override the nesting bird protections provided by these. Impacts to nesting birds, both direct and indirect, can be minimized or eliminated by conducting work activities outside of the local breeding season. Although nesting can occur in any month in southern California for some species, breeding in the study area, given the habitat, would primarily be expected from about February 1 st through August 31 st .

Work from about September 1st through January 31 st would avoid most negative affects to birds and nesting activity. If work must be done during the breeding season, surveys for nesting birds should occur prior to all vegetation clearing and ground disturbance. In order to avoid Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020
44 violation of the MBTA and avoid and/or mitigate impacts to special status bird species known from the project site which are not covered by the MSHCP, the following mitigation is recommended.

Mitigation Measure BIOLOGY-9: Grading and site preparation activities shall be conducted outside the nesting season, generally from February 1 st through August 31 st. If grading and other site preparation activities cannot occur outside of the nesting season, then a pre- construction clearance survey for nesting birds shall be conducted by a qualified biologist within seven (7) days of the start of site preparation activities to ensure that no nesting birds will be disturbed during construction. If active nests are found, and determined by the qualified biologist that the next may be impacted, they should be avoided until young have fledged. While there is no established protocol for nest avoidance, when consulted the CDFW generally recommends avoidance buffers of about 500 feet for raptors and threatened/endangered species and 100 – 300 feet for non-raptors. Any active nests observed during the survey shall be mapped on an aerial photograph. Only construction activities (if any) that have been approved by a Biological Monitoring shall take place within the buffer zone until the nest is vacated. The biologist shall serve as a construction monitor when construction activities take place near active nest areas to ensure that no inadvertent impacts on these nests occur. Results of the pre-construction survey and any subsequent monitoring shall be provided to the applicant and the City Planning Department. The monitoring report shall summarize the results of the next monitoring, describe construction restrictions currently in place, and confirm that construction activities can proceed with in the buffer area without jeopardizing the survival of the young birds.

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45 7.0 LITERATURE CITED
Amec. 2014. Sycamore Hills Distribution Center Project, Focused Surveys for the Southwestern Willow Flycatcher and Least Bell’s Vireo. Unpublished report for Albert A. Webb Associates.

California Bird Records Committee. 2019. Official California Checklist. Accessed online at:
http://californiabirds.org/ca_list.asp
California Department of Fish and Wildlife (CDFW). 2019a. California Natural Diversity Database (CNDDB) RareFind 5 records of sensitive elements.

CDFW. 2019b. Special Animals List. August. Periodic publication. Sacramento, CA. Accessed online at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=1 09406&inline CDFW. 2016. Complete List of Amphibian, Reptile, Bird and Mammal Species in California.

Accessed online at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=8 7155&inline California Native Plant Society (CNPS). Rare Plant Program. 2019. Inventory of Rare and Endangered Plants of California Accessed online at: http://www.rareplants.cnps.org/ Charters, Michael L. 2019. Southern California Plant Communities. Accessed online at:
http://www.calflora.net/botanicalnames/plantcommunit ies.html Declaration of Restrictive Covenants. June 11, 2009. March Joint Powers Authority. Riverside County Clerk Doc # 2009-0303932. https://www.asrclkrec.com/home Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. Calif. Fish Game, Sacramento.

Jepson Flora Project. 2019. Jepson eFlora. Accessed online at:
http://ucjeps.berkeley.edu/IJM.html
Permit No. 199915206-RRS amendment letter. March 5, 2003. Department of the Army. Los Angeles District, Corps of Engineers.

Sawyer, J.O., T. Keeler-Wolf and J. M. Evans, 2009, A Manual of California Vegetation, Second Ed., California Native Plant Society Press, Sacramento, CA.

United States Department of Agriculture (USDA). 2019. PLANTS Database. Accessed online at:
http://plants.usda.gov
USDA. 2019. Web Soil Survey. Accessed online at: http://websoilsurvey.nrcs.usda.gov/app/ United States Fish and Wildlife Service (USFWS). 2016. A Guide to the Laws and Treaties of the United States for Protecting Migratory Birds. Accessed online at:
https://www.fws.gov/birds/policies-and-regulations/l aws-legislations.php Western Riverside County Regional Conservation Authority (WRCRCA). 2019a. WRCRCA MSHCP Information Tool. Accessed from: https://www.wrc-rca.org/rcamaps/ WRCRCA. 2019b. Western Riverside County Multiple Species Habitat Conservation Plan.

Accessed online at: http://www.wrc-rca.org/about-rca/multiple-species-ha bitat- conservation-plan/
Wood. 2018a. Biological Resources Report, Sycamore Hills Distribution Center Project. Also presented the results of 2018 burrowing owl surveys. Unpublished report prepared for Ruth Villalobos & Associates.

Wood. 2018b. Sycamore Hills Distribution Center, Mitigation Planting Plan. Unpublished report prepared for Ruth Villalobos & Associates.

Biological Resources & MSHCP Consistency Report
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APPENDIX A

PLANT SPECIES

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PLANT SPECIES LIST
─────────────────────────────────────────────────────────── This list reports plant species observed in the project area during Wood site visits dating back to January 2014. Species seen only during field visits prior to 2019 are highlighted. Other species may have been overlooked or undetectable due to their seasonal growth patterns.

Nomenclature and taxonomy for flora observed on site follows the Jepson eFlora (2019). If no common name is listed in Jepson, the United States Department of Agriculture PLANTS database (2019) is followed.
─────────────────────────────────────────────────────────── SYMBOLS AND ABBREVIATIONS:
─────────────────────────────────────────────────────────── * Non-native species
** Sensitive species (State or federally listed as endangered, threatened, or candidate; state species of special concern/watchlist/tracked; Bureau of Land Management and/or Forest Service sensitive; MSHCP)
sp. Identified only to genus; species unknown (plural = spp.) ssp. Subspecies
var. Variety
cf. Uncertain identification, but plant specimen "compares favorably" to named species ──────────────────────────────────────────────────────────── ANGIOSPERMAE: DICOTYLEDONES DICOT FLOWERING PLANTS
Adoxaceae Muskroot Family
Sambucus nigra ssp. caerulea blue elderberry
Anacardiaceae Sumac Family
*Schinus molle pepper tree
*Schinus terebinthifolius Brazilian pepper tree
Apiaceae Carrot Family
*Apium graveolens celery
Apocynaceae Dogbane Family
Asclepias fascicularis narrow-leaf milkweed
Asteraceae Sunflower Family
Ambrosia acanthicarpa annual bur-sage
Artemisia californica California sagebrush
Baccharis pilularis coyote brush
Baccharis salicifolia mulefat
Baccharis salicina willow baccharis
Baccharis sarothroides broom baccharis
Carduus pycnocephalus ssp. pycnocephalus Italian thistle *Centaurea melitensis tocalote
*Cirsium vulgare bull thistle
Corethrogyne filaginifolia California-aster
**Deinandra paniculata paniculate tarplant
Encelia farinosa brittlebush
Ericameria palmeri var. pachylepis thickbracted goldenbush Erigeron canadensis horseweed
Gnaphalium palustre western marsh cudweed
Helianthus annuus common sunflower
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Heterotheca grandiflora telegraph weed
Isocoma menziesii coastal goldenbush
*Lactuca serriola prickly lettuce
Lepidospartum squamatum scale-broom
*Oncosiphon pilulifer stinknet
Pseudognaphalium californicum ladies' tobacco
Stephanomeria exigua small wirelettuce
Xanthium strumarium cocklebur
Boraginaceae Borage Family
Amsinckia intermedia common fiddleneck
Heliotropium curassavicum var. oculatum alkali heliotrope Pectocarya linearis ssp. ferocula narrow-toothed pectocarya Phacelia ramosissima branching phacelia
Plagiobothrys collinus var. californicus California popcornflower Brassicaceae Mustard Family
*Hirschfeldia incana short-pod mustard
Cactaceae Cactus Family
Cylindropuntia californica var. parkeri valley cholla
Crassulaceae Stonecrop Family
Crassula connata pygmy-weed
Cucurbitaceae Gourd Family
Marah macrocarpa man-root
Euphorbiaceae Spurge Family
Croton setiger doveweed
Euphorbia albomarginata rattlesnake sandmat
*Euphorbia peplus petty spurge
Euphorbia serpillifolia thyme-leafed spurge
*Ricinus communis castor bean
Fabaceae Pea Family
Astragalus pomonensis Pomona milkvetch
Lupinus sp. unidentified lupine
Trifolium sp. clover
Geraniaceae Geranium Family
*Erodium botrys broadleaf filaree
*Erodium cicutarium redstem filaree
Lamiaceae Mint Family
*Marrubium vulgare horehound
Salvia apiana white sage
Trichostema lanceolatum vinegar weed
Montiaceae Miner’s Lettuce Family
Calandrinia ciliata red maids
Nyctaginaceae Four o’clock Family
Mirabilis laevis var. crassifolia wishbone bush
Oleaceae Olive Family
Fraxinus velutina velvet ash
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Phrymaceae Lopseed Family
Erythranthe guttata seep monkeyflower
Platanaceae Sycamore Family
Platanus racemosa western sycamore
Polygonaceae Buckwheat Family
Eriogonum fasciculatum – two ssp. California buckwheat
*Rumex crispus curly dock
Salicaceae Willow Family
Populus fremontii Fremont cottonwood
Salix gooddingii black willow
Salix laevigata red willow
Salix lasiolepis arroyo willow
Solanaceae Nightshade Family
Datura wrightii jimson weed
*Nicotiana glauca tree tobacco
Tamaricaceae Tamarisk Family
*Tamarix ramosissima saltcedar
Urticaceae Nettle Family
Urtica dioica stinging nettle
Verbenaceae Vervain Family
Verbena lasiostachys western vervain

MONOCOTYLEDONEAE MONOCOT FLOWERING PLANTS
Arecaceae Palm Family
*Washingtonia sp. fan palm sp.

Cyperaceae Sedge Family
Cyperus eragrostis tall flatsedge
Juncaceae Rush Family
Juncus balticus ssp. ater Baltic rush
Poaceae Grass Family
*Avena cf. fatua wild oat
*Bromus madritensis ssp. rubens red brome
Distichlis spicata salt grass
*Ehrharta erecta panic veldt grass
*Poa annua annual blue grass
*Polypogon monspeliensis rabbitfoot grass
*Schismus sp. Mediterranean grass

Biological Resources & MSHCP Consistency Report
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APPENDIX B

VERTEBRATE SPECIES LIST
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VERTEBRATE ANIMALS LIST
─────────────────────────────────────────────────────────── This list reports vertebrate animal species observed in the project area during Wood site visits dating back to January 2014. Species seen only during field visits prior to 2019 are highlighted.

Other species may have been overlooked or undetectable due to their seasonal or daily activity patterns. Nomenclature and taxonomy for fauna observed on site follows the California Bird Records Committee Official California Checklist (2019) for birds and CDFW (2016) for herpetofauna and mammals.
─────────────────────────────────────────────────────────── SYMBOLS AND ABBREVIATIONS:
─────────────────────────────────────────────────────────── * Non-native species
** Sensitive species (State or federally listed as endangered, threatened, or candidate; state species of special concern/watchlist/tracked; USFWS bird of conservation concern; Bureau of Land Management and/or Forest Service sensitive) sp. Identified only to genus; species unknown (plural = spp.) ───────────────────────────────────────────────────────────

HERPETOFAUNA REPTILES & AMPHIBIANS
Hylidae Treefrogs
Pseudacris hypochondriaca Baja California treefrog
Phrynosomatidae Spiny Lizards
Uta stansburiana common side-blotched lizard
Sceloporus occidentalis western fence lizard
Sceloporus orcutti granite-spiny lizard
Crotalidae Pitvipers
**Crotalus ruber red-diamond rattlesnake

AVIFAUNA BIRDS
Anatidae Ducks, Geese, and Swans
Anas platyrhynchos mallard
Aythya americana redhead
Odontophoridae New World Quail
Callipepla californica California quail
Columbidae Pigeons and Doves
*Columba livia rock pigeon
Patagioenas fasciata band-tailed pigeon
*Streptopelia decaocto Eurasian collared dove
Zenaida macroura mourning dove
Cuculidae Cuckoos, Roadrunners, and Anis
Geococcyx californianus greater roadrunner
Trochilidae Hummingbirds
Archilochus alexandri black-chinned hummingbird
Calypte anna Anna's hummingbird
Calypte costae Costa’s hummingbird
Selasphorus **rufus/S. sasin rufous or Allen’s hummingbird Rallidae Rails
Porzana carolina sora
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Fulica americana American coot
Charadriidae Plovers and Lapwings
Charadrius vociferus killdeer
Phalacrocoracidae Cormorants and Shags
Phalacrocorax auritas double-crested cormorant
Cathartidae New World Vultures
Cathartes aura turkey vulture
Accipitridae Hawks, Eagles, Harriers, Kites
**Circus hudsonius northern harrier
**Accipiter cooperii Cooper’s hawk
Buteo lineatus red-shouldered hawk
Buteo jamaicensis red-tailed hawk
Tytonidae Barn Owls
Tyto alba barn owl
Picidae Woodpeckers
Melanerpes formicivorus acorn woodpecker
Dryobates nuttallii Nuttall’s woodpecker
Colaptes auratus northern flicker
Falconidae Caracaras and Falcons
Falco sparverius American kestrel
Tyrannidae Flycatchers
Myiarchus cinerascens ash-throated flycatcher
Tyrannus vociferans Cassin’s kingbird
Tyrannus verticalis western kingbird
Contopus sordidulus western wood-pewee
**Empidonax traillii willow flycatcher
Sayornis nigricans black phoebe
Sayornis saya Say’s phoebe
Vireonidae Vireos
**Vireo bellii least Bell’s vireo
Vireo cassinii Cassin’s vireo
Vireo gilvus warbling vireo
Corvidae Jays, Crows, Ravens, Magpies
Corvus brachyrhynchos American crow
Corvus corax common raven
Alaudidae Larks
**Eremophila alpestris actia California horned lark
Hirundinidae Swallows
Stelgidopteryx serripennis northern rough-winged swallow Hirundo rustica barn swallow
Petrochelidon pyrrhonota cliff swallow
Aegithalidae Bushtits and Long-tailed Tits
Psaltripus minimus bushtit
Troglodytidae Wrens
Thryomanes bewickii Bewick’s wren
Polioptilidae Gnatcatchers and Gnatwrens
Polioptila caerulea blue-gray gnatcatcher
Regulidae Kinglets
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Regulus calendula ruby-crowned kinglet
Turdidae Thrushes
Catharus ustulatus Swainson's thrush
Catharus guttatus hermit thrush
Mimidae Mockingbirds and Thrashers
Mimus polyglottos northern mockingbird
Toxostoma redivivum California thrasher
Sturnidae Starlings
*Sturnus vulgaris European starling
Ptiliogonatidae Silky-flycatchers
Phainopepla nitens phainopepla
Passeridae Old World Sparrows
*Passer domesticus house sparrow
Fringillidae Finches
Carpodacus mexicanus house finch
Carduelis psaltria lesser goldfinch
**Spinus lawrencei Lawrence’s goldfinch
Passerellidae New World Sparrows
Chondestes grammacus lark sparrow
Zonotrichia leucophrys white-crowned sparrow
Passerculus sandwichensis s avannah sparrow
M
elospiza melodia song sparrow
Melozone crissalis California towhee
**Aimophila ruficeps canescens southern California rufous-crowned sparrow Pipilo maculatus spotted towhee
Icteridae Orioles, Grackles and Cowbirds
Sturnella neglecta western meadowlark
Icterus cucullatus hooded oriole
Agelaius phoeniceus red-winged blackbird
Molothrus ater brown-headed cowbird
Euphagus cyanocephalus Brewer’s blackbird
Parulidae New World Warblers
**Setophaga petechia yellow warbler
Setophaga coronata yellow-rumped warbler
Setophaga nigrescens black-throated gray warbler
Cardinella pusilla Wilson’s warbler
Cardinalidae Cardinals and Allies
Passerina caerulea Blue Grosbeak

MAMMALIA MAMMALS
Leporidae Rabbits and Hares
Sylvilagus audubonii desert cottontail
**Lepus californicus bennettii San Diego black-tailed jackrabbit Sciuridae Squirrels
Spermophilus beecheyi California ground squirrel (burrows) Geomyidae Pocket Gophers
Thomomys bottae Botta’s pocket gopher (mounds)
Heteromyidae Kangaroo Rats and Relatives
**Dipodomys stephensi Stephens’ kangaroo rat (burrows, sign) Biological Resources & MSHCP Consistency Report
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Muridae Mice, Rats, and Voles
Neotoma sp. wood rat (middens)
Canidae Foxes, Wolves, and Relatives
Canis latrans coyote (scat)
Felidae Cats
Lynx rufus bobcat (scat)

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APPENDIX C

PHOTOGRAPHS

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
November 2019

The report cover photo (page i) looks south at proposed new project driveway location.

Photo 1. Non-native grassland from center of eastern site. Burrowing owl habitat.

Photo 2. Sparse Riversidean sage scrub from northwestern corner of western site.

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Photo 3. Riparian (state & federally jurisdictional waters, MSHCP riverine/riparian, and potential least Bell’s vireo & southwestern willow flycatcher habitat. This area is project designated as restricted property to be preserved.

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APPENDIX D

JURISDICTIONAL DELINEATION

JURISDICTIONAL DELINEATION REPORT

SYCAMORE HILLS DISTRIBUTION CENTER

CITY OF RIVERSIDE, RIVERSIDE COUNTY, CALIFORNIA

Prepared for:

Darrell Butler
3241 Alta Laguna Boulevard
Laguna Beach, California 92651
Office: (949) 632-9892
Contact: Darrell Butler

Prepared by:

Wood Environment and Infrastructure, Inc.
1845 Chicago Avenue, Suite D
Riverside, CA 92507
Principal Investigator: Dale Hameister

18 December 2020

Wood Project No. 1755500029

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Page ii

TABLE OF CONTENTS
PAGE
ACRONYMS AND ABBREVIATIONS ........................................................................................ iv

1.0 INTRODUCTION ............................................................................................. 1

1.1 Project Description ............................................................................................... 1

1.2 Project Location .................................................................................................... 1

2.0 REGULATORY FRAMEWORK .......................................................................10

1.1 U.S. Army Corps of Engineers .............................................................................10

1.1.1 Waters of the U.S. ...................................................................................10

1.1.2 Wetlands and Other Special Aquatic Sites ...............................................10

1.1.3 Supreme Court Decisions ........................................................................11

1.1.4 2015 Clean Water Rule ............................................................................11

1.1.5 2020 The Navigable Waters Protection Rule ...........................................12

1.2 Regional Water Quality Control Board .................................................................12

1.3 California Department of Fish and Wildlife ...........................................................14

2.1 Western Riverside County MSHCP .....................................................................14

3.0 METHODS ......................................................................................................16

4.0 ENVIRONMENTAL SETTING .........................................................................18

4.1 Existing Conditions ..............................................................................................18

4.2 Hydrology ............................................................................................................18

4.3 Vegetation ...........................................................................................................18

4.4 Soils ....................................................................................................................18

4.5 National Wetlands Inventory ................................................................................19

5.0 RESULTS .......................................................................................................22

5.1 Drainage A ..........................................................................................................22

5.2 Drainage B ..........................................................................................................23

5.3 Area C .................................................................................................................23

5.4 Jurisdictional Determination .................................................................................26

6.0 IMPACTS TO JURISDICTIONAL AREAS .......................................................28

6.1 Permitting Requirements .....................................................................................28

6.1.1 U.S. Army Corps of Engineers .................................................................28

6.1.2 Regional Water Quality Control Board ......................................................29

6.1.3 California Department of Fish and Wildlife ................................................29

6.1.4 Western Riverside County MSHCP ..........................................................29

7.0 REFERENCES ...............................................................................................33

8.0 PHOTOGRAPHS ............................................................................................35

LIST OF TABLES
Table 1. Summary of Jurisdictional Areas .................................................................................22 Table 2. Impacts to Jurisdictional Areas ....................................................................................28 Jurisdictional Delineation Report
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Page iii

TABLE OF CONTENTS (CONT.)

LIST OF FIGURES
Figure 1. Vicinity and Location .................................................................................................. 4 Figure 2. Location Map ............................................................................................................. 6 Figure 3. Topo Map ................................................................................................................... 8 Figure 4. Soils Map ..................................................................................................................20 Figure 5. Delineation Map ........................................................................................................24 Figure 6. Impacts to Jurisdictional Areas ..................................................................................31

LIST OF APPENDICES

APPENDIX A WETLAND DETERMINATION DATA FORMS

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Page iv

ACRONYMS AND ABBREVIATIONS
Wood Wood Environment and Infrastructure, Inc.

AMSL above mean sea level
APN assessor parcel number
CEQA California Environmental Quality Act
CDFW California Department of Fish and Wildlife
CWA Clean Water Act
DBESP Determination of Biologically Equivalent or Superior Preservation EPA Environmental Protection Agency
FAC facultative
FACU facultative upland
FACW facultative wetland
GIS Geographic Information System
IP Individual Permit
MSHCP Multiple Species Habitat Conservation Plan
NEPA National Environmental Policy Act
NL not listed
NWI National Wetlands Inventory
NWP Nationwide Permit
OBL obligate
OHWM ordinary high-water mark
Rapanos Rapanos v. U.S. and Carabell v. U.S.

RPW relatively permanent waterway
RWQCB Regional Water Quality Control Board
SWANCC Solid Waste Agency of Northern Cook County v. USACE TNW traditionally navigable waterway
UPL upland
USACE U.S. Army Corps of Engineers
USDA United States Department of Agriculture, Natural Resources Conservation Service
USFWS United States Fish and Wildlife Service
USGS U.S. Geological Survey
WSC Waters of the State of California
WUS Waters of the United States
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1.0 INTRODUCTION
Darrell Butler is proposing to develop the Sycamore Hills Distribution Center (proposed project).

Darrell Butler retained Wood Environment and Infrastructure, Inc. (Wood) to determine the potential for impacts to jurisdictional waters from the development of the proposed project.

This report presents regulatory framework, methods, and results of a delineation of jurisdictional waters, wetlands, and associated riparian habitat potentially impacted by the development of the proposed project. The purpose of the delineation is to determine the extent of state and federal jurisdiction within the project area potentially subject to regulation by the U.S. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act (CWA), Regional Water Quality Control Board (RWQCB) under Section 401 of the CWA and Porter Cologne Water Quality Control Act, California Department of Fish and Wildlife (CDFW) under Section 1602 of the California Fish and Game Code, and the County of Riverside under the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP).

1.1 Project Description
The project proposes subdividing the site into two numbered parcels (Parcels 1 and 2), and three lettered parcels (Parcels A, B, and C). Each parcel is proposed to be developed with a high cube transload short-term warehouse building (Buildings A and B). Building A, a 400,000 square foot warehouse, will be constructed on Parcel 1. Building B, a 203,100 square foot warehouse, will be constructed on Parcel 2. Associated improvements include parking, fire lanes, fencing and walls (including retaining walls), landscaping, and water quality treatment areas.

Parcels A and Parcel B consist of existing Restricted Property of natural land, with a supporting jurisdictional feature, totaling approximately 11.6 acres. A 0.67-acre driveway will be constructed through the Restricted Property to provide street access from Alessandro Boulevard to Parcel 1, which would reduce the Restricted Property to 10.93 acres. However, 1.44 acres will be added to Parcel A to mitigate this loss, resulting in a total of 12.37 acres of Restricted Property (net gain of 0.77 acres). A Conservation Easement is proposed to be placed over the amended 12.37 acres of Restricted Property.

A trailhead parking lot is proposed on Parcel C, totaling 1.18 acres, for access to the Sycamore Canyon Wilderness Park. Improvements include a parking lot, sidewalk, shade structure, bike rack, drinking fountain, fencing, and a Fire Department and access gate. Parcel C will be dedicated to the City.

1.2 Project Location
The study area consists of assessor parcel numbers 263-060-022, -024, and -026 which encompass approximately 49.60 acres. It is located in the City of Riverside, Riverside County, California (Figure 1). Specifically, it is located within Section 9 of Township 3 South, Range 4 West, as shown on the United States Geological Survey (USGS) 7.5-minute Riverside East, California Jurisdictional Delineation Report
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quadrangle (Figure 2). The geographic coordinates near the middle of the site are 33.91916° North latitude and 117.30918° West longitude. The proposed project site is bordered to the south by East Alessandro Boulevard, to the west by Barton Street, and to the north by Sycamore Canyon Regional Park, with unimproved private land to the east.

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Project Location

FIGURE 2
Project Location
Sycamore Hills Distribution Center
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Existing Restricted Property
Additional Restricted Property
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2.0 REGULATORY FRAMEWORK

1.1 U.S. Army Corps of Engineers
The USACE regulates the discharge of dredged or fill material in waters of the United States (WUS) pursuant to Section 404 of the CWA.

1.1.1 Waters of the U.S.

CWA regulations (33 CFR 328.3(a)) define WUS as follows:

1. All waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;

2. All interstate waters including interstate wetlands;

3. All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation or destruction of which could affect interstate or foreign commerce including any such waters: (i) Which are or could be used by interstate or foreign travelers for recreational or other purposes; or (ii) From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or (iii) Which are used or could be used for industrial purpose by industries in interstate commerce;

4. All impoundments of waters otherwise defined as WUS under the definition;

5. Tributaries of WUS;

6. The territorial seas;

7. Wetlands adjacent to WUS (other than waters that are themselves wetlands).

The USACE delineates non-wetland waters in the Arid West Region by identifying the ordinary high-water mark (OHWM) in ephemeral and intermittent channels (USACE 2008a). The OHWM is defined in 33 CFR 328.3(e) as:

“…that line on the shore established by the fluctuations of water and indicated by physical characteristics such as clear, natural line impresses on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas.” Identification of OHWM involves assessments of stream geomorphology and vegetation response to the dominant stream discharge. Determining whether any non-wetland water is a jurisdictional WUS involves further assessment in accordance with the regulations, case law, and clarifying guidance as discussed below.

1.1.2 Wetlands and Other Special Aquatic Sites
Wetlands are defined at 33 CFR 328.3(b) as “those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil Jurisdictional Delineation Report
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conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” Special aquatic sites are geographic areas, large or small, possessing special ecological characteristics of productivity, habitat, wildlife protection, or other important and easily disrupted ecological values. These areas are generally recognized as significantly influencing or positively contributing to the general overall environmental health or vitality of the entire ecosystem of a region. Special aquatic sites include sanctuaries and refuges, wetlands, mud flats, vegetated shallows, coral reefs, and riffle and pool complexes. They are defined in 40 CFR 230 Subpart E.

1.1.3 Supreme Court Decisions
Solid Waste Agency of Northern Cook County

On January 9, 2001, the Supreme Court of the United States issued a decision on Solid Waste Agency of Northern Cook County v. United States Army Corps of Engineers, et al. with respect to whether the USACE could assert jurisdiction over isolated waters. The Solid Waste Agency of North Cook County (SWANCC) ruling stated that the USACE does not have jurisdiction over “non- navigable, isolated, intrastate” waters.

1.1.4 Rapanos/Carabell
In the Supreme Court cases of Rapanos v. United States and Carabell v. United States (herein referred to as Rapanos), the court attempted to clarify the extent of USACE jurisdiction under the CWA. The nine Supreme Court justices issued five separate opinions (one plurality opinion, two concurring opinions, and two dissenting opinions) with no single opinion commanding a majority of the Court. In light of the Rapanos decision, the USACE will assert jurisdiction over a traditional navigable waterway (TNW), wetlands adjacent to TNWs, non-navigable tributaries of TNWs that are a relatively permanent waterway (RPW) where the tributaries typically flow year-round or have continuous flow at least seasonally (e.g., typically three months) and wetlands that directly abut such tributaries. The USACE will decide jurisdiction over the following waters based on a fact- specific analysis to determine whether they have a significant nexus with a TNW: non-navigable tributaries that are not relatively permanent, wetlands adjacent to non-navigable tributaries that are not RPWs, and wetlands adjacent to but that do not directly abut a non-navigable RPW.

Flow characteristics and functions of the tributary itself and the functions performed by all wetlands adjacent to the tributary indicate whether they significantly affect the chemical, physical and biological integrity of downstream TNWs. Analysis of potentially jurisdictional streams includes consideration of hydrologic and ecologic factors. The consideration of hydrological factors includes volume, duration, and frequency of flow, proximity to traditional navigable waters, size of watershed, average annual rainfall, and average annual winter snow pack. The consideration of ecological factors also includes the ability for tributaries to carry pollutants and flood waters to a TNW, the ability of a tributary to provide aquatic habitat that supports a TNW, the ability of wetlands to trap and filter pollutants or store flood waters, and maintenance of water quality.

1.1.5 2015 Clean Water Rule
The federal government issued the Clean Water Rule in 2015 in order to resolve jurisdictional ambiguity resulting from previous Supreme Court decisions (i.e. SWANNC, Rapanos). On June 22, 2015, the USACE and EPA published the Clean Water Rule: Definition of ‘‘Waters of the United States’’; Final Rule (40 CFR Parts 110, 112, 116, 117, 122, 230, 232, 300, 302, and 401).

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The Clean Water Rule was repealed October 22, 2019.

1.1.6 2020 The Navigable Waters Protection Rule
On January 23, 2020, the Environmental Protection Agency (EPA) and the Department of the Army published a final rule called “The Navigable Water Protection Rule.”

In this final rule, the agencies interpret WUS to encompass:

 The territorial seas and traditional navigable waters;  Perennial and intermittent tributaries that contribute surface water flow to such waters;  Certain lakes, ponds, and impoundments of jurisdictional waters; and  Wetlands adjacent to other jurisdictional waters.

The final rule excludes from the definition of WUS all waters or features not mentioned above, specifically clarifying that WUS do not include the following:

 groundwater, including groundwater drained through subsurface drainage systems;  ephemeral features that flow only in direct response to precipitation, including ephemeral streams, swales, gullies, rills, and pools;
 diffuse stormwater runoff and directional sheet flow over upland;  ditches that are not traditional navigable waters, tributaries, or that are not constructed in adjacent wetlands, subject to certain limitations;
 prior converted cropland;
 artificially irrigated areas that would revert to upland if artificial irrigation ceases;  artificial lakes and ponds that are not jurisdictional impoundments and that are constructed or excavated in upland or non-jurisdictional waters;
 water-filled depressions constructed or excavated in upland or in non-jurisdictional waters incidental to mining or construction activity, and pits excavated in upland or in non- jurisdictional waters for the purpose of obtaining fill, sand, or gravel;  stormwater control features constructed or excavated in upland or in non-jurisdictional waters to convey, treat, infiltrate, or store stormwater run-off;  groundwater recharge, water reuse, and wastewater recycling structures constructed or excavated in upland or in non-jurisdictional waters; and  waste treatment systems.

This rule was published in the Federal Register on April 21, 2020 and went into effect on June 22, 2020.

1.2 Regional Water Quality Control Board
The RWQCB regulates activities pursuant to Section 401(a)(1) of the CWA. Section 401 of the CWA specifies that certification from the State is required for any applicant requesting a federal license or permit including a Section 404 permit. Through the Porter Cologne Water Quality Control Act, the RWQCB asserts jurisdiction over Waters of the State of California (WSC) which is generally the same as WUS but may also include waters not in federal jurisdiction.

The State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State was adopted in April 2020 and put into effect statewide on May 28, 2020 (State Water Jurisdictional Delineation Report
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Resources Control Board, 2020).

The Water Boards define an area as wetland as follows:

An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.

The Water Code defines WSC broadly to include “any surface water or groundwater, including saline waters, within the boundaries of the state.” WSC include all WUS but also includes waters not in federal jurisdiction.

The following wetlands are waters of the state:

1. Natural wetlands,

2. Wetlands created by modification of a surface water of the state, and

3. Artificial wetlands that meet any of the following criteria:
a. Approved by an agency as compensatory mitigation for impacts to other waters of the state, except where the approving agency explicitly identifies the mitigation as being of limited duration;
b. Specifically identified in a water quality control plan as a wetland or other water of the state;
c. Resulted from historic human activity, is not subject to ongoing operation and maintenance, and has become a relatively permanent part of the natural landscape; or
d. Greater than or equal to one acre in size, unless the artificial wetland was constructed, and is currently used and maintained, primarily for one or more of the following purposes (i.e., the following artificial wetlands are not waters of the state unless they also satisfy the criteria set forth in 2, 3a, or 3b):
i. Industrial or municipal wastewater treatment or disposal, ii. Settling of sediment,
iii. Detention, retention, infiltration, or treatment of stormwater runoff and other pollutants or runoff subject to regulation under a municipal, construction, or industrial stormwater permitting program,
iv. Treatment of surface waters,
v. Agricultural crop irrigation or stock watering,
vi. Fire suppression,
vii. Industrial processing or cooling,
viii. Active surface mining – even if the site is managed for interim wetlands functions and values,
ix. Log storage,
x. Treatment, storage, or distribution of recycled water, or xi. Maximizing groundwater recharge (this does not include wetlands that have incidental groundwater recharge benefits); or
xii. Fields flooded for rice growing.

All artificial wetlands that are less than an acre in size and do not satisfy the criteria set forth in 2,

3.a, 3.b, or 3.c are not WSC.

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1.3 California Department of Fish and Wildlife
The CDFW regulates water resources under Section 1600-1616 of the California Fish and Game Code. Section 1602 states:
“An entity may not substantially divert or obstruct the natural flow of, or substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake, or deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake (CDFW, 2015).”

Evaluation of CDFW jurisdiction followed guidance in the Fish and Game Code and A Review of Stream Processes and Forms in Dryland Watersheds. In general, under 1602 of the Fish and Game Code, CDFW jurisdiction extends to the maximum extent or expression of a stream on the landscape (CDFW, 2010). It has been the practice of CDFW to define a stream as “a body of water that flows perennially or episodically and that is defined by the area in a channel which water currently flows, or has flowed over a given course during the historic hydrologic course regime, and where the width of its course can reasonably be identified by physical or biological indicators” (Brady and Vyverberg, 2013). Thus, a channel is not defined by a specific flow event, nor by the path of surface water as this path might vary seasonally. Rather, it is CDFW's practice to define the channel based on the topography or elevations of land that confine the water to a definite course when the waters of a creek rise to their highest point.

2.1 Western Riverside County MSHCP
Section 6.1.2, Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools, of the Western Riverside County MSHCP defines riparian/riverine areas as “lands which contain habitat dominated by trees, shrubs, persistent emergents, or emergent mosses and lichens, which occur close to or which depend upon soil moisture from a nearby fresh water source; or areas with fresh water flow during all or a portion of the year”.

Section 6.1.2 of the Western Riverside County MSHCP further defines vernal pools as “seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season.

Obligate hydrophytes and facultative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season. The determination that an area exhibits vernal pool characteristics and the definition of the watershed supporting vernal pool hydrology must be made on a case-by-case basis. Such determinations should consider the length of the time the area exhibits upland and wetland characteristics and the manner in which the area fits into the overall ecological system as a wetland. Evidence concerning the persistence of an area's wetness can be obtained from its history, vegetation, soils, and drainage characteristics, uses to which it has been subjected, and weather and hydrologic records”.

Areas meeting the definition of riparian/riverine or vernal pools which are artificially created are not included in these definitions, with the exception of wetlands created for the purposes of providing Jurisdictional Delineation Report
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wetlands habitat or resulting from human actions to create open waters or from the alteration of natural stream courses.

Preparation of a Determination of Biologically Equivalent or Superior Preservation (DBESP) report is required under the Western Riverside County MSHCP for projects that involve impacts to riparian/riverine resources and/or vernal pools. The purpose of the DBESP report is to ensure replacement of any lost functions and values of habitat as it relates to covered species.

Jurisdictional Delineation Report
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3.0 METHODS
Prior to conducting delineation fieldwork, the following literature and materials were reviewed:
 Aerial photographs of the project site at a scale of 1:1800 with 10-foot elevation contours to determine the potential locations of jurisdictional waters or wetlands;  USGS topographic map (Figure 2) to determine the presence of any “blue line” drainages or other mapped water features;
 USDA soil mapping data; and
 USFWS NWI maps to identify areas mapped as wetland features.

Field surveys of the study area were conducted by Wood biologist Scot Chandler on 17 and 28 January 2014, 09 September 2015 and was verified on 18 May 2017. A revised impact analysis was conducted in September of 2018. James Mace of the US Army Corps of Engineers conducted a site visit and evaluation on 25 September 2018 and confirmed Scot Chandler’s delineation of Waters of the US. An additional field survey of the area was conducted by Wood Senior Biologist Dale Hameister on 14 November 2019 to update existing conditions. Surveys consisted of walking the entire study area and identifying potentially jurisdictional water features. Visual observations of vegetation types and changes in hydrology were used to locate areas for evaluation. Weather conditions during delineation fieldwork were conducive for surveying with generally clear skies.

USACE regulated WUS, including wetlands, and RWQCB WSC were delineated according to the methods outlined in A Field Guide to the Identification of the Ordinary High-Water Mark (OHWM) in the Arid West Region of the Western United States (USACE, 2008a). The extent of WUS was determined based on indicators of an OHWM. The OHWM width was measured at points wherever clear changes in width occurred.

Federally regulated wetlands were identified based on the Wetlands Delineation Manual (USACE, 1987) and Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (USACE, 2008b). Additional data was recorded to determine if an area fulfilled the wetland criteria parameters. Three criteria must be fulfilled in order to classify an area as a wetland under the jurisdiction of the USACE: 1) a predominance of hydrophytic vegetation, 2) the presence of hydric soils, and 3) the presence of wetland hydrology. Details of these criteria are described below:
 Hydrophytic Vegetation. The hydrophytic vegetation criterion is satisfied at a location if greater than 50% of all the dominant species present within the vegetation unit have a wetland indicator status of obligate (OBL), facultative wetland (FACW), or facultative (FAC) (USACE, 2008b). An OBL indicator status refers to plants that almost always occur in wetlands. A FACW indicator status refers to plants that usually occur in wetlands but may occur in non-wetlands. A FAC indicator status refers to plants that occur in wetlands and non-wetlands. Other wetland indicator statuses include facultative upland (FACU) which refers to plants that usually occur in non-wetlands, but may occur in wetlands, upland (UPL) for species that almost never occur in wetlands, Jurisdictional Delineation Report
Sycamore Hills Distribution Center
17 July2020

and NL for plants that are not listed on the National Wetland Plant List . The wetland indicator status used for this report follows the 2013 National Wetland Plant List (Arid West Region) (Lichvar, 2014).
 Hydric Soils. The hydric soil criterion is satisfied at a location if soils in the area can be inferred or observed to have a high groundwater table, if there is evidence of prolonged soil saturation, or if there are any indicators suggesting a long-term reducing environment in the upper part of the soil profile. Reducing conditions are most easily assessed using soil color. Soil colors were evaluated using the Munsell Soil Color Charts (Gretag/Macbeth, 2000).
 Wetland Hydrology. The wetland hydrology criterion is satisfied at a location based upon conclusions inferred from field observations that indicate an area has a high probability of being inundated or saturated (flooded, ponded, or tidally influenced) long enough during the growing season to develop anaerobic conditions in the surface soil environment, especially the root zone (USACE, 1987 and 2008b).

Areas meeting all three parameters would be designated as USACE wetlands. Site photographs are at the end of this report, and wetland delineation data sheets are included as Appendix A.

There were no wetlands identified in the study area during this investigation based of the absence of hydric soil indicators.

CDFW jurisdiction was delineated by measuring the elevations of land that confine a stream to a definite course when its waters rise to their highest level and to the extent of associated riparian vegetation.

Riparian/riverine areas jurisdictional under the MSHCP were mapped similar to CDFW jurisdiction except where the water feature was artificially created for purposes other than mitigation or enhancement of wildlife habitat.

To determine jurisdictional boundaries, the surveyor walked the length of the drainage within the project area and recorded the centerline with a Trimble GeoXH global positioning system. The width of the drainage was determined by the OHWM and bankfull width measurements at locations where transitions were apparent. Other data recorded included bank height and morphology, substrate type, and all vegetation within the streambed and riparian vegetation adjacent to the streambed. Upon completion of fieldwork, all data collected in the field were incorporated into a Geographic Information System (GIS) along with basemap data. The GIS was then used to quantify the extent of jurisdictional waters.

Jurisdictional Delineation Report
Sycamore Hills Distribution Center
17 July 2020

4.0 ENVIRONMENTAL SETTING

4.1 Existing Conditions
The study area is currently undeveloped with no existing structures. It is dominated by disturbed non-native grassland with a few ephemeral drainages, some with riparian vegetation, transecting the site (Figure 5). The study area appears to be regularly mowed for fire control purposes.

Surrounding land uses include preserved open space to the north as part of Sycamore Canyon Wilderness Park, a municipal water treatment plant and single-family residential to the west, single-family residential to the south with a strip of retail along the south side of Alessandro Boulevard, and undeveloped land to the east (Figure 2).

Elevations within the study area range from approximately 1,616 feet above mean sea level (AMSL) in the northwest portion of the study area to 1,574 feet AMSL near the northern-central portion of the study area.

4.2 Hydrology
The average rainfall for the area is 9.86 inches per year (Western Regional Climate Center 2013).

Weather data was recorded approximately 3.5 miles northwest of the project site.

After exiting the site, the on-site drainages flow north for ½ mile before converging with Sycamore Canyon Creek. Sycamore Canyon Creek flows for 2.5 miles northwest before converging with Tequesquito Arroyo. Tequesquito Arroyo flows for 6.9 miles before reaching the Santa Ana River.

The Santa Ana River flows southwest for 16 miles before reaching Prado Basin. The Santa Ana River continues west for 30 miles before reaching the Pacific Ocean.

4.3 Vegetation
The study area is dominated by non-native grassland and riparian woodland. The on-site non- native grassland was dominated by common fiddleneck (Amsinckia intermedia), filaree (Erodium sp.), California-aster (Corethrogyne filaginifolia), and short-pod mustard (Hirschfeldia incana). The riparian woodland was dominated by willows ( Salix sp.), mulefat ( Baccharis salicifolia ), and cottonwood (Populus fremontii). Vegetation nomenclature follows The Jepson Manual, Vascular Plants of California, 2nd Edition (Baldwin, 2012). When The Jepson Manual does not list a common name, common name nomenclature follows the United States Department of Agriculture, Natural Resources Conservation Service (USDA) Plants Database (USDA, 2014).

4.4 Soils
The USDA online Web Soil Survey (based on the 1971 Soil Survey of Western Riverside Area, California) (Soil Survey Staff, 2018) was reviewed to determine the soil types mapped as occurring within the study area. None of the soil types within the study area are found on the Jurisdictional Delineation Report
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National List of Hydric Soils (USDA, 2018b). The study area crosses seven different soil series (Figure 3) including:
 Arlington fine sandy loam (AnC) – This well-drained soil occurs on alluvial fans and terraces with 2 to 8 percent slopes. It is composed of fine sandy loam and the parent material is composed of alluvium dominantly from granitic rocks.  Cieneba sandy loam, eroded (ChF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of sandy loam on the surface and the parent material is composed of coarse grained igneous rock.  Cieneba rocky sandy loam, eroded (CkF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of rocky sandy loam on the surface and the parent material is composed of coarse grained igneous rock.  Fallbrook sandy loam, eroded (FaD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of sandy loam and developed on granodiorite and tonalite.
 Fallbrook sandy loam, shallow, eroded (FbC2) – This well-drained soil occurs on uplands with 5 to 8 percent slopes. It is composed of sandy loam and developed on granodiorite and tonalite.
 Fallbrook fine sandy loam, shallow, eroded (FkD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of fine sandy loam and developed on granodiorite and tonalite.
 Vista coarse sandy loam, eroded (VsD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of coarse sandy loam and developed on weathered granite and granodiorite.

4.5 National Wetlands Inventory
The United States Fish and Wildlife Service (USFWS) is the principal Federal agency that provides information to the public on the extent and status of the Nation’s wetlands. The USFWS has developed a series of maps, known as the National Wetlands Inventory (NWI) to show wetlands and deepwater habitat. This geospatial information is used by Federal, State, and local agencies, academic institutions, and private industry for management, research, policy development, education, and planning activities. The NWI program was neither designed nor intended to produce legal or regulatory products; therefore, wetlands identified by the NWI program are not the same as wetlands defined by the USACE.

The NWI Mapper (USFWS, 2018) was accessed online to review mapped wetlands within the project study area. No NWI wetlands were identified within the study area. The nearest NWI wetland is located approximately 1/4-mile northeast of the study area within Sycamore Canyon Creek. It is classified as Riverine, Intermittent, Streambed, Intermittently Flooded/Temporary (Cowardin, et. al., 1979).

ChF2
CkF2
VsD2
AnC
ChF2
FaD2
VsD2
CkF2
FkD2
VsF2
ChD2
FbF2
CkF2
CkF2
FkD2
CkF2
FaD2
AnC
FaD2
FbC2
FfC2
FkD2
FkD2
FbC2
Project Boundary
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°
02 0 0
Feet
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FIGURE 4
Soils
Sycamore Hills Distribution Center
Riverside, CA
Label Description
AnC Arlington fine sandy loam, 2 to 8 percent slopes
ChD2 Cieneba sandy loam, 8 to 15 percent slopes, eroded ChF2 Cieneba sandy loam, 15 to 50 percent slopes, eroded CkF2 Cieneba rocky sandy loam, 15 to 50 percent slopes, eroded FaD2 Fallbrook sandy loam, 8 to 15 percent slopes, eroded FbC2 Fallbrook sandy loam, shallow, 5 to 8 percent slopes, eroded FbF2 Fallbrook sandy loam, shallow, 15 to 35 percent slopes, eroded FfC2 Fallbrook fine sandy loam, 2 to 8 percent slopes, eroded FkD2 Fallbrook fine sandy loam, shallow, 8 to 15 percent slopes, eroded VsD2 Vista coarse sandy loam, 8 to 15 percent slopes, eroded VsF2 Vista coarse sandy loam, 15 to 35 percent slopes, eroded Jurisdictional Delineation Report
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17 July 2020

5.0 RESULTS
The study area contains two jurisdictional drainages identified as Drainage A and Drainage B and a riparian area identified as Area C. The Jurisdictional Delineation Map (Figure 5) identifies all on- site jurisdictional drainages and includes the photo point locations and direction the photo was taken. Table 1 includes a list of jurisdictional areas identified in the project area, their jurisdictional status and area of jurisdiction, Cowardin classification (Cowardin et. al., 1979), and length of waterway within the project study area.

The USACE, in combination with the Environmental Protection Agency (EPA), when necessary, reserves the ultimate authority in making the final jurisdictional determination of WUS and the RWQCB reserves the ultimate authority in making the final jurisdictional determination of WSC.

Additionally, CDFW has ultimate discretion in the determination of their jurisdiction.

Table 1.

Summary of Jurisdictional Areas
Drainage
ID
Non-Wetland

WUS, WSC
(acres)
CDFW
Jurisdiction
(acres)
Length
(feet)
Latitude/
Longitude
Cowardin
Class
Class of
Aquatic
Resource
A 0.08 0.35 1,183 33.91902/
-117.31228
R4SBW non-
section 10-
non wetland
B 0.11 1.36 918 33.91961/
-117.31018
R4SBW non-
section 10-
non wetland
Area C 0 .45 n/a 33.91740/
-117.30845
n/a non-
section 10-
non wetland
Total 0.19 5.16 2,101 n/a n/a n/a
WUS – Waters of the United States WSC – Waters of the State CDFW – California Department of Fish and Wildlife
R4SBW – Riverine, Intermittent, Streambed, Intermittently Flooded/Temporary based on Classification of Wetlands and Deepwater Habitats of the United States (Cowardin, et. al., 1979).

5.1 Drainage A
Drainage A is shown on Figure 5 and in Photos 1 through 3. Drainage A enters the study area near the northern portion of the western boundary and flows for approximately 1,183 feet before exiting the site near the middle of the northern boundary. USACE jurisdiction averaged 3 feet wide based on OHWM limits which included a break in bank slope and change in substrate. CDFW jurisdiction ranged from 3 feet wide based on the bankfull width in the upland vegetated portions of the drainage to 65 feet wide based on the extent of riparian vegetation. The banks of Drainage A ranged from vertically-incised to steeply-sloping with depths averaging 6 inches to 1 foot.

Drainage A contained sparsely vegetated sections and areas of dense riparian vegetation. The sparsely vegetated portions of the streambed of Drainage A were dominated by short-pod mustard, western marsh cudweed (Gnaphalium palustre), and pygmy-weed (Crassula connata).

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The patches of riparian vegetation were dominated by mulefat, willow baccharis ( Baccharis salicina), Goodding’s black willow ( Salix gooddingii), arroyo willow ( Salix lasiolepis), red willow (Salix laevigata) and blue elderberry (Sambucus nigra subsp. caerulea).

The presence of USACE wetlands was investigated by recording the soil and hydrology characteristics and vegetation at a sampling point at the downstream end of Drainage A. The sampling point location is shown on Figure 5 and the Wetland Determination Data Form is included in Appendix B. Sampling point 1 exhibited hydrophytic vegetation but lacked hydric soils and wetland hydrology, and is therefore not defined as a wetland.

5.2 Drainage B
Drainage B is shown on Figure 5 and in Photos 4 through 7. Drainage B enters the study area near the middle of the southern boundary and flows for approximately 981 feet before exiting the site near the middle of the northern boundary. USACE jurisdiction averaged 5 feet wide based on OHWM limits which included the destruction of terrestrial vegetation. CDFW jurisdiction ranged from 30 to 100 feet wide based on the extent of riparian vegetation. The banks of Drainage B ranged from gently sloping to vertically incised with depths averaging 1 to 2 feet.

Drainage B contained dense riparian vegetation throughout the entire on-site extent. The canopy layer was dominated by Fremont cottonwood (Populus fremontii subsp. fremontii,) and red willow.

The understory was dominated by mulefat, willow baccharis, hoary nettle ( Urtica dioica subsp. holosericea), saltgrass (Distichlis spicata), and emergent grasses.

The presence of USACE wetlands was investigated by recording the soil and hydrology characteristics and vegetation at a sampling point at the downstream end of Drainage B. The sampling point location is shown on Figure 5 and the Wetland Determination Data Form is included in Appendix A. Sampling point 2 exhibited hydrophytic vegetation but lacked hydric soils and wetland hydrology and is therefore not defined as a wetland.

5.3 Area C
Area C is shown on Figure 5 and in Photos 8 through 10. Area C contains riparian dominated habitat but does not exhibit a channel or other signs of confined water flow. It is located in the southeast portion of the study area. There is no USACE jurisdiction associated with Area C due to a lack of an OHWM. CDFW jurisdiction totaled 3.45 acres based on the extent of riparian vegetation. Area C contained dense riparian vegetation dominated by mulefat, hoary nettle, willow baccharis, branching phacelia (Phacelia ramosissima), and Goodding’s black willow.

The presence of USACE wetlands was investigated by recording the soil and hydrology characteristics and vegetation at a sampling point within the eastern portion of Area C. The sampling point location is shown on Figure 5 and the Wetland Determination Data Form is included in Appendix A. Sampling point 3 exhibited hydrophytic vegetation but lacked hydric soils and wetland hydrology.

Jurisdictional Delineation Report
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17 July 2020

5.4 Jurisdictional Determination
The findings of the previous 2018 report were verified in 2019. Drainages A and B are ephemeral and likely flow for less than 3 months per year and would therefore be classified as non-RPWs by the USACE. The on-site drainages flow into an RPW, the Santa Ana River 9.9 miles downstream of the study area; and a TNW, the Pacific Ocean, approximately 56 river miles downstream of the study area.

The on-site drainages have a surface water connection to a TNW, and therefore would be considered jurisdictional WUS based on SWANCC. Due to the proximity of the on-site drainages to the Pacific Ocean, it is likely that the USACE would consider it to have a “significant nexus” with a TNW and be considered a jurisdictional WUS based on Rapanos.

The USACE may determine that due to the ephemeral nature of the on-site drainages, they may not be considered jurisdictional based on the 2020 Clean Navigable Waters Rule.

The USACE is ultimately responsible for jurisdictional determinations, and this report has been prepared to provide the necessary information to assist the USACE with that determination.

!.
!.
!.

Drainage A
Drainage B
Area C
1 2
3 !. Sampling Point
Project Boundary
Project Details
Additional Restricted Boundary
Existing Restricted Boundary
Jurisdictional Areas
CDFW
WUS
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°
02 0 0
Feet
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Esri, HERE, Garmin, (c) OpenStreetMap contributors
FIGURE 5
Drainages
Sycamore Hills Distribution Center
Riverside, CA
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Sycamore Hills Distribution Center
18 December 2020

6.0 IMPACTS TO JURISDICTIONAL AREAS
The proposed development plan (Appendix B) was overlaid on the jurisdictional delineation boundary using GIS to determine the extent of impacts to jurisdictional areas (Figure 6). The buildings, parking lots, and driveway were considered permanent impacts. Temporary impacts were assessed for the temporary construction crossing at the downstream end of Drainage B.

Table 2 portrays the proposed impacts to jurisdictional waters in the on-site drainages. Permanent impacts to Drainage A are for all but 100 feet of this drainage; the 100 feet on the property to the northeast of the building site will not be impacted. There will no permanent impacts to Drainage B. Permanent impact to Area C will total 0.25 acres.

Table 2.

Impacts to Jurisdictional Areas
Drainage
Temporary
Impacts to non-
wetland WUS
Permanent
Impacts to non-
wetland WUS
Temporary
Impacts to CDFW
Jurisdiction
Permanent
Impacts to CDFW
Jurisdiction
A 0 0.07 acre
1,044 linear feet
0 0.23acre
1,044 linear feet
B 0.002 acre
21 linear feet
0 0.017 acre 0
Area C 0 0 0 0.57 acres
258 linear feet
Total 0.002 acre
21 linear feet

0.08 acre
1,302 linear feet

0.017 acre 0.8 acre
1,044 linear feet

6.1 Permitting Requirements
The proposed project requires temporary and permanent impacts to a jurisdictional drainage and therefore, authorizations from the USACE, RWQCB, and CDFW may be required as described below.

6.1.1 U.S. Army Corps of Engineers
The two most common types of permits issued by USACE under Section 404 of the CWA to authorize the discharge of dredged or fill material into WUS are: a nationwide permit (NWP) or an individual permit (IP).

NWPs are general permits for specific categories of activities that result in minimal impacts to aquatic resources.

NWP 39 can be used for commercial and institutional developments. This NWP authorizes the construction or expansion of commercial and institutional building foundations and building pads and attendant features that are necessary for the use and maintenance of the structures.

Attendant features may include but are not limited to roads, parking lots, garages, yards, utility lines, storm water management facilities, septic fields, and recreation facilities such as playgrounds and playing fields. The discharge must not cause the loss of greater than 1/2-acre of non-tidal WUS, including the loss of no more than 300 linear feet of stream bed, unless for Jurisdictional Delineation Report
Sycamore Hills Distribution Center
18 December 2020

intermittent and ephemeral stream beds the district engineer waives the 300-linear foot limit by making a written determination concluding that the discharge will result in minimal adverse effects.

This NWP does not authorize discharges into non-tidal wetlands adjacent to tidal waters. The permittee must submit a pre-construction notification to the district engineer prior to commencing the activity. If the USACE asserts jurisdiction over Drainage A, the proposed project would likely qualify under NWP 39, if the 300-foot limit is waived.

For project impacts that do not meet the provisions of an existing NWP, the USACE would require an IP. An IP requires detailed analysis and compliance with the USACE formal review process.

This process includes preparation of an alternatives analysis as required by EPA Section 404(b)(1) Guidelines and the National Environmental Policy Act (NEPA), and requires compliance with NEPA’s environmental review process. This process provides opportunities for public notice and comment.

The USACE must comply with the federal Endangered Species Act and Section 106 of the National Historic Preservation Act when issuing a NWP or IP.

6.1.2 Regional Water Quality Control Board
The project area is within the jurisdiction of the Santa Ana RWQCB (Region 8). Under Section 401 of the CWA, the RWQCB must certify that the discharge of dredged or fill material into WUS does not violate state water quality standards.

The RWQCB also regulates impacts to WSC under the Porter Cologne Water Quality Control Act through issuance of a Construction General Permit, State General Waste Discharge Order, or Waste Discharge Requirements, depending upon the level of impact and the properties of the waterway.

The project proponent would need to obtain a Water Quality Certification. In addition to the formal application materials and fee (based on area of impact), a copy of the appropriate California Environmental Quality Act (CEQA) documentation must be included with the application.

6.1.3 California Department of Fish and Wildlife
A 1602 Streambed Alteration Agreement is required for all activities that alter streams and lakes and their associated riparian habitat. Therefore, the project proponent would need to obtain a Streambed Alteration Agreement. In addition to the formal application materials and fee (based on cost of the project), a copy of the appropriate CEQA documentation must be included with the application.

6.1.4 Western Riverside County MSHCP
Preparation of a DBESP report is required under the MSHCP for projects that involve impacts to riparian/riverine resources and/or vernal pools. The purpose of the DBESP report is to ensure replacement of any lost functions and values of habitat as it relates to covered species. The Jurisdictional Delineation Report
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project proponent would need to prepare a DBESP since the proposed project will impact riparian/riverine areas.

Drainage A
Drainage B
Area C
Project Boundary
Additional Restricted Boundary
Existing Restricted Boundary
Jurisdictional Areas
CDFW
WUS
No Impact
Temporary Impact
Permanent Impact
1 inch = 200 feet
°
02 0 0
Feet
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Esri, HERE, Garmin, (c) OpenStreetMap contributors
FIGURE 6
Impact Areas
Sycamore Hills Distribution Center
Riverside, CA
Jurisdictional Delineation Report
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18 December 2020

7.0 REFERENCES
Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, editors. 2012. The Jepson manual: vascular plants of California, second edition. University of California Press, Berkeley.

Brady, Roland H. III, Kris Vyverberg. 2013. Methods to Describe and Delineate Episodic Stream Processes on Arid Landscapes for Permitting Utility-Scale Solar Power Plants. California Energy Commission. Publication Number: CEC-500-2014-013.

California Department of Fish and Wildlife (CDFW). 2010. A Review of Stream Processes and Forms in Dryland Watersheds. Prepared by Kris Vyverberg, Conservation Engineering. 32 p.

CDFW. 2015. Fish and Game Code of California. http://www.leginfo.ca.gov/calaw.html.

Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Department of the Interior.

Gretag/Macbeth. 2000. Munsell color. New Windsor, NY.

Lichvar, R.W., M. Butterwick, N.C. Melvin, and W.N. Kirchner. 2014. The National Wetland Plant List: 2014 Update of Wetland Ratings. Phytoneuron 2014-41: 1-42.

Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/.

Accessed 01 September 2018.

U.S. Army Corps of Engineers (USACE). 1987. Wetlands Delineation Manual, Technical Report Y-8. U.S. Army Engineer Waterways Experiment Station, Vicksburg, Mississippi. 100 pp. + append.

USACE. 2008a. A Field Guide to the Identification of the Ordinary High-Water Mark (OHWM) in the Arid West Region of the Western United States. A Delineation Manual. Lichvar and McColley. August.

USACE. 2008b. Regional Supplement to the Corps of Engineers Wetland Delineation Manual:

Arid West Region. September.

United States Department of Agriculture, Natural Resources Conservation Service (USDA). 2018a. The PLANTS Database. (http://plants.usda.gov, 01 September 2018). National Plant Data Team, Greensboro, NC 27401-4901 USA.

USDA. 2018b. List of Hydric Soils. Available online at:
http://www.nrcs.usda.gov/wps/PA_NRCSConsumption/download?cid=stelprdb12485 96&ext=xlsx.

Fish and Wildlife Service. 2018. National Wetlands Inventory Mapper. Available online at:
http://www.fws.gov/wetlands/Data/Mapper.html. Accessed 01 September 2018.

Western Regional Climate Center. 2019. Desert Research Institute. Available online at:
http://www.wrcc.dri.edu/coopmap. Accessed 13 November 2019.

Jurisdictional Delineation Report
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8.0 PHOTOGRAPHS
Photo 1 – View of Drainage A facing downstream near where it enters the site through a 4-foot concrete pipe.

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Photo 2 - View of Drainage A facing upstream near the middle of the on-site extent.

The Ordinary High-Water Mark width is approximately 3 feet.

Photo 3 – Downstream-facing perspective of Drainage A near the downstream end.

Jurisdictional Delineation Report
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Photo 4 - View Drainage B facing downstream at the upstream end.

Photo 5 - View of the channel beneath the riparian canopy of Drainage B where the Ordinary High-Water Mark is approximately 5 feet wide.

Jurisdictional Delineation Report
Sycamore Hills Distribution Center
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Photo 6 – Upstream-facing perspective of Drainage B.

Photo 7 - View of Drainage B facing downstream at the downstream end.

Jurisdictional Delineation Report
Sycamore Hills Distribution Center
18 December 2020

Photo 8 - View of riparian Area C that did not exhibit an Ordinary High Water Mark.

Photo 9 - View of isolated riparian habitat near where a permanent access road will be constructed.

Jurisdictional Delineation Report
Sycamore Hills Distribution Center
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Photo 10 - View of riparian habitat within Area C that did not exhibit an Ordinary High Water Mark.

Jurisdictional Delineation Report
Sycamore Hills Distribution Center
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APPENDIX A

WETLAND DETERMINATION DATA FORMS

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020

APPENDIX E

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT, FOCUSED

SURVEYS FOR THE SOUTHWESTERN WILLOW FLYCATCHER AND
LEAST BELL’S VIREO

Biological Resources & MSHCP Consistency Report
Sycamore Hills Distribution Center Project
September 2020

APPENDIX F

MITIGATION PLANTING PLAN

Memo
To Sonya Hooker
Roth Villalobos & Associates, Inc.

Wood Project No. 1755500029
From Carla Scheidlinger cc
Tel (858) 300-4300
Date November 21, 2018

Subject SYCAMORE HILLS DISTRIBUTION CENTER

CITY OF RIVERSIDE, RIVERSIDE COUNTY, CALIFORNIA

MITIGATION PLANTING PLAN

1.0 Introduction
Inland Investments, Inc. is proposing to develop the Sycamore Hills Distribution Center (Project).

The Project area consists of assessor parcel numbers 263-060-022, -024, and -026 which encompass approximately 47.85 acres. It is located in the City of Riverside, Riverside County, California (Figure 1). Specifically, it is located within Section 9 of Township 3 South, Range 4 West, as shown on the United States Geological Survey (USGS) 7.5 minute Riverside East, California quadrangle (Figure 2). The geographic coordinates near the middle of the site are

33.91916° North latitude and 117.30918° West longitude. The proposed project site is bordered to the south by East Alessandro Boulevard, to the west by Barton Street, and to the north by Sycamore Canyon Regional Park, with unimproved private land to the east.

Impacts to jurisdictional resources have been quantified by a jurisdictional determination (Wood 2018). Permanent impacts identified to ephemeral drainages total 0.08 acre and 1,083 linear feet that were identified as being both Non-Wetland Waters of the United States (WUS) and Waters of the State of California (WSC). The patches of riparian vegetation in all impacted areas lack an ordinary high water mark (OHWM) and are therefore jurisdictional only to CDFW. These areas total an additional 0.52 acre of permanent impact. Permanent impacts are mitigated by habitat creation (establishment). In addition, there are 0.2 acre of temporary impact to CDFW jurisdictional resources which are mitigated by restoration.

The impacted habitat was described as riparian woodland dominated by Goodings black willow (Salix gooddingii), red willow (Salix laevigata), arroyo willow (Salix lasiolepis), mulefat (Baccharis salicifolia), blue elderberry ( Sambucus nigra subsp. caerulea), and cottonwood ( Populus fremontii). The drainage with no permanent impacts on the site includes the riparian trees listed above, and an understory dominated by mulefat, willow baccharis ( Baccharis salicina ), hoary nettle (Urtica dioica subsp. holosericea), saltgrass ( Distichlis spicata), and branching phacelia (Phacelia ramosissima).

The concept is to replace the impacted riparian habitat with on-site and in-kind habitat establishment, and to perform enhancement for all un-impacted juri sdictional areas. The

Wood Environment & Infrastructure Solutions, Inc.
9210 Sky Park Court, Suite 200
San Diego, California 92123
(858) 300-4300
www.woodplc.com

2 mitigation proposes to create (establish) 0.61 acre of riparian woodland of a type jurisdictional to CDFW adjacent to the existing CDFW riparian woodland area south of the project site and north of Alessandro Blvd. In addition, the project will enhance a total of 1.58 acres of riparian habitat:

0.01 acre in Drainage A, 1.34 acre in Drainage B and 0.23 acre in Area C. Temporary impact to

0.02 acre of riparian habitat in Drainage B will be restored. In addition, the non-jurisdictional upland areas of slopes associated with the access road will be restored, as will be the temporary construction road. These actions are summarized in Table 1. A map of the proposed mitigations and their positions relative to the development footprint and to the existing habitat areas is shown in Figure 3.

Table 1. Summary of Mitigation Actions by Drainage or Habitat Area Type of Action Drainage A Drainage B (acre) Area C (acre) Non-jurisdictional areas (upland roads)
Restoration
(temporary impact)

0.00 0.02 0.00 0.73
Enhancement 0.01 1.34 0.23 0.00
Creation
(Establishment)

0.00 0.00 0.61 0.00

2.0 Mitigation Implementation

2.1 Grading
The 0.61 acre creation site will be graded to a level approximating that of the adjacent unimpacted riparian areas to the east and west as shown in Figure 3. The grading will produce a shallow basin, with slopes will be relatively shallow (no more than 3:1 length to height) at the north and south ends, and will approximate the existing grade adjacent to existing habitat to the east and west. The total created habitat will be approximately 28,000 square feet (ft 2).

There is no need to salvage topsoil, as it would contain the seeds of weeds that would not be desirable in the habitat creation area.

The 0.01 acre Drainage B restoration area will be graded back to the natural contour of the channel and its banks after the temporary construction road has been abandoned. The restoration areas associated with the access road slopes and toes, and the temporary construction road will be graded to the contours specified in the grading plans. No further grading is required.

No grading is proposed for the enhancement areas.

2.2 Site Preparation
As the created habitat is designed to mitigate for impacts to riparian vegetation, it is important to provide the habitat area with sufficient water to allow for successful establishment of riparian vegetation. There is no expectation that there will be continual water delivered to the site, but some initial “charging” of the water table would be desirable. Water should be delivered into the graded basin to a depth that fills it approximately half way, and allowed to percolate into the ground. If time allows between the conclusion of the grading and the acceptable planting window,

3 the flooding should be repeated when the surface area has dried. Once the surface is dry enough to allow for plant installation (not muddy, but possibly damp), planting can be initiated.

Alternatively, a temporary irrigation system can be installed that would deliver water to each planting location. Such a system would remain in place until the plants were able to access the shallow water table and become self-sustaining.

For the enhancement areas, removal of all non-native species that contribute to the degradation of riparian habitat quality will be done. It is anticipated that such species will include Tamarix ramosissima (salt cedar), Arundo donax (giant reed), Schinus terebinthifolius (Brazilian pepper tree), and Nicotiana glauca (tree tobacco), all of which have been observed in the enhancement area. Removal of mustards (Brassica spp. and Hirshfeldia sp.) will also be done within the riparian habitat area. No effort will be made to eliminate annual grasses. Removal will be done with a combination of mechanical, manual, and chemical strategies, employed using the strategies of Integrated Pest Control (IPC), as appropriate for the species being treated. Only chemicals approved for aquatic application will be used.

The upland restoration area of the temporary construction road will be de-compacted and smoothed. No site preparation is required for the upland restoration areas associated with the slopes and toes of the access road. No site preparation is required for the Drainage B restoration area.

2.3 Planting Plan: Creation Area
The plant palette presented in Table 2 describes the species and spacing to be used for the establishment of the riparian habitat. The species are those which are represented elsewhere on the property and in the impacted areas, as well as several species suggested by the United States Fish and Wildlife Service botanist (J. Thiede, pers. comm.). The actual location of where each plant is to be installed will be at the discretion of the contractor retained to implement the planting plan.

Table 2. Planting Palette for Creation (Establishment) Area

size spacing restoration area
Species Common name (gallon) sf ea (feet) number total sf location Baccharis salicifolia mulefat 1 64 8 75 4800 low
Baccharis salicina willow baccharis 1 64 8 75 4800 low
Fraxinus velutina velvet ash 5 289 17 5 1445 high
Populus fremontii cottonwood 5 289 17 8 2312 mid
Salix laevigata red willow 5 289 17 15 4335 mid
Salix lasiolepis arroyo willow 5 289 17 15 4335 mid
Salix gooddingii black willow 5 289 17 15 4335 low
Sambucus nigra ssp. caerulea blue elderberry 1 16 4 10 160 high Artemesia palmeri San Diego sagewort 1 16 4 40 640 high Total 258 27162
If smaller plants are used, the spacing should be reduced by 30%, and the numbers increased by 100%

4 In addition, the areas between installed plants of the creation area will be seeded to assure soil stability and to provide species diversity in the area. The seed palette is in Table 3.

Table 3. See ding Palette for Creation (Establishment) Area

2.4 Planting Plan: Restoration Areas
The Restoration area in Drainage B will be planted with some of the same species in Table 2. As this area occupies only about 300 ft 2, a single individual of each of the Bacc haris species and each of the willow species will be installed. The actual location for installation of each plant will be determined by the restoration contractor. The same seed mixture shown in Table 3 will also be distributed.

Additional restoration will be done in non-jurisdictional areas including the temporary construction road, and the slopes and toes of the new access road. The species shown in Tables 4 and 5 will be used at these locations. No container plant installation is proposed for the tempor ary construction road area; this area will be seeded only.

2.5 Planting Plan: Enhancement Areas
When non-native species have been removed, they will be replaced with native species. The woody species listed in Table 2 will all be appropriate for installation, at the discretion of the restoration contractor. Density of installed plants will approximate the density that had been occupied by the non-native species removed.

2.6 Planting Plan: Restoration Areas (access road shoulders and toes, and temporary construction road)
The Project anticipates that there will be 9,722 ft 2 of planted slopes associated with the development of the access road from Alessandro Blvd. to Building A. An additional 8,000 ft 2 is Species Common Name Lbs /ac
Marah macrocarpus Wild cucumber 2
Distichlis spicata Saltgrass 2
Bromus carinatus California brome 3
Carex praegracilis Field sedge 4
Oenothera elata Hooker's Evening Primrose 1
Urtica dioica Hoary nettle 1
Malacothamnus fasciculatus
var. fasciculatus Bush Mallow 1
Nassella pulchra Purple Needlegrass 4
Rosa californica Wild Rose 2
Leymus triticoides Creeping wild rye 4
Stachys ajugoides Hedge Nettle 1
Helianthus annuus Common sunflower 1
Artemesia douglasiana Mugwort 4
Total 30

5 also anticipated to be temporarily impacted during the construction of the roadway, at the toe of the slopes. Both of these areas would be outside the habitat establishment area. Where these areas impact jurisdictional resources, the entire disturbance area has been calculated to be mitigated with the 0.61 acre of establishment as described above. In addition, the temporary construction road will be restored to native vegetation.

The developer is committed to restoring the slopes of the access road, the temporary impact areas at the toe of the slopes, and the temporary construction road with native vegetation. The species palettes for these areas are shown in Tables 4 and 5.

Table 4. Planting palette for upland restoration area access road slopes

Table 5. Seed for upland restoration areas

2.7 Planting Methods
For the habitat creation area, plants can be installed directly into the flat basin areas, with no additional soil stabilization.

Species Common name spacing (ft) sf/plant number total sf Acmispon glaber deerweed 3.5 12.25 80 980
Artemisia californica California sagebrush 3.5 12.25 60 735 Baccharis salicina willow baccharis 3.5 12.25 60 735
Corethrogyne filaginifolia California Aster 3.5 12.25 100 1225 Dipalcus aurantiacus monkey flower 3.5 12.25 100 1225
Eriogonum fasciculatum California buckwheat 3.5 12.25 100 1225 Encelia californica encelia 3.5 12.25 120 1470
Isocoma mensiezii golden bush 3.5 12.25 80 980
Salvia apiana white sage 3.5 12.25 30 367.5
Salvia leucophylla purple sage 3.5 12.25 40 490
Salvia mellifera black sage 3.5 12.25 30 367.5
Total 800 9800
Spacing based on 1 gallon size for all species
Species Common name PLS lbs/ac
Achillea millefolium western yarrow 3
Deschampsia caespitosa tuften hairgrass 3
Melica imperfecta smallflower melic 3
Muhlenbergia rigens deergrass 4
Nassella cernua nodding needlegrass 5
Nasella lepida foothill needlegrass 4
Nasella pulchra purple needlegrass 5
Sisyrinchium bellum blue-eyed grass 3
TOTAL 30

6 For the enhancement areas, plants can be installed directly into the areas that have been vacated by the removal of non-native species. If root material requires removal (as may be the case for large patches of giant reed), that will be done prior to planting. The new planting site would then be smoothed and contoured by hand.

For the restoration area slopes associated with the access road , it will be necessary to install a jute or similar erosion control mat on the final slope area, as the proposed 2:1 slope is too steep for stability otherwise (NRCS 2006). Container plants will be installed through the net by cutting appropriately sized and spaced holes. Bark mulch may be placed on top of the mat around the plants to assist with water retention.

For the restoration of other upland temporary impact areas including the toe of the access road and the temporary construction road, it is anticipated that the areas will be basically flat, or with gentle slopes. The seeds can be distributed by hydroseeding or by broadcasting and raking in.

Sprinkler irrigation will be provided initially to assist with establishment.

General container plant installation and seeding specifications:

Mark with flags where container plants should be planted. Flags will have identification on them indicating which species are to be planted in each location. The proposed species would be planted in zones of appropriate moisture for each species, based on location within the basin.

Acquire and inspect container plants. Plants will be minimum one gallon size or equivalent (plants that are planted in taller, narrower pots than standard one gallon size may be appropriate for some species). Tree species will be acquired in 5-gallon containers, provided that suitable material can be located at a reasonable distance from the site.

Auger planting holes using a small tracked or wheeled machine such as a Bobcat for the introduction of container plants. Holes may also be dug by hand. Container plants will be installed into a hole at least 2 times as deep as the container, and 1.5 times as wide.

Plant container plants into the holes prepared. Mulch will be used as backfill, mixed with native soil, for container plants. Planting will be performed under the supervision of a Restoration Biologist. Planting methods are detailed below:

The planting hole will be filled with water and allowed to drain prior to planting. A small amount of backfill with mulch will be placed in the hole and lightly tamped down prior to placing the container stock.

The plant root ball will be placed on the backfill and the area will be backfilled entirely while applying water to the backfill soil. A small berm (water ring) will encircle the plantings to keep water centralized on each plant. The newly planted vegetation will then be watered.

Distribute seed into the planted areas, or onto the graded upland surfaces, and rake it in.

Subsequent irrigation will be done in all areas with the most appropriate method being determined by the restoration contractor. Options for the creation area include flooding, drip irrigation,

7 sprinkler irrigation, or a combination of these strategies. For the enhancement areas, options include drip irrigation and hand watering. For the riparian restoration area, hand watering may be the most appropriate strategy. For in the restored slopes, toes, and road areas, sprinklers and/or drip irrigation could be used. In all cases, water will be distributed as necessary. Irrigation times and rates will depend on vegetation condition and natural precipitation.

3.0 References
NRCS. 2006. Prevent Soil Erosion On Your Property: A Homeowner's Guide To Erosion Control.

NRCS document 144p2_063808. Available from:
https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_063808.pdf

Thiede, James. pers. comm. October 10, 2018.

Wood Environment & Infrastructure Solutions, Inc. 2018. Jurisdictional Delineation Report:

Sycamore Hills Distribution Center. 15 October 2018.

Please do not hesitate to contact us if you have any questions concerning this memo.

Respectfully submitted,
Amec Foster Wheeler Environment & Infrastructure, Inc.

Carla Scheidlinger
Senior Scientist/Restoration Ecology

Legend
Study Area
Vicinity & Location
Sycamore Hills Distribution Center
Date: 2/13/2014Source: Background-ESRI imagery, WEBB Scheme 5 new.dwg S:\active projects\Barton & Alessandro JD 1355400566\maps 1 ^_
FIGURE
²
0 1,400 2,800700
Feet
1 in = 2,000 feet
Name:Mindy Beohm
8 Legend
Study Area
Topographic Map
Sycamore Hills Distribution Center
Date: 2/13/2014User Name: mindy.beohmSource: Background-USGS topo Riveside east 7.5' quad S:\active projects\Barton & Alessandro JD 1355400566\maps 2 FIGURE
²
0 1,400 2,800700
Feet
1 in = 2,000 feet
9 Drainage A
Drainage B
Area C
Project Boundary
Existing Restricted Property
Additional Restricted Property
Jurisdictional Areas
CDFW
WUS
Proposed Mitigation Opportunities
Enhancement
Restoration
Creation
1 inch = 200 feet
°
02 0 0
Feet
Path: Q:\3554_NaturalResources\SycamoreCanyon_1755500029\MXD\ReportFigures\BioResourcesReport\FigXX_PotentialMitigation.mxd, aaron.johnson, 11/16/2018 Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community
FIGURE ͵
Proposed Mitigation Opportunities
Sycamore Hills Distribution Center
Riverside, CA
10 Determination of
Biologically Equivalent or Superior Preservation (DBESP) Report for Impacts to Riparian/Riverine Resources

Sycamore Hills Distribution Center
Darrell Butler
Inland Investments, Inc.
3241 Alta Laguna Boulevard
Laguna Beach, CA 92641
(949) 632-9892

Ruth Villalobos and Associates, Inc.
3602 Inland Empire Blvd. Suite C310
Ontario, CA 91764
(909) 245-1128

January 2021

DBESP Report

i
Contents
1 INTRODUCTION ................................................................................................................................ .................. 1

1.1 Project Area ................................................................................................................................ .................. 1

1.2 Project Description ................................................................................................................................ ....... 2

1.3 Avoidance Alternative ................................................................................................................................ ... 5 2 EXISTING CONDITIONS ................................................................................................................................ ..... 5

2.1 Existing and Adjacent Land Uses ................................................................................................ ................. 5

2.2 Soils ................................................................................................................................ .............................. 5

2.3 Hydrology ................................................................................................................................ ..................... 7

2.4 Riparian/Riverine Resources ................................................................................................ ........................ 7

2.5 Riparian-Nesting Birds ................................................................................................................................ 10

2.6 Vernal Pools ............................................................................................................................................... 11

2.7 Fairy Shrimp ............................................................................................................................................... 12

2.8 Functions and Values Assessment of Riparian/Riverine Resources .......................................................... 12 3 IMPACTS............................................................................................................................................................ 12

3.1 Avoidance ................................................................................................................................................... 12

3.2 Direct Impacts ............................................................................................................................................. 13

3.3 Indirect Impacts .......................................................................................................................................... 14 4 MITIGATION AND EQUIVALENCY .................................................................................................................... 18 5 REFERENCES/ APPENDICES .......................................................................................................................... 21 6 FIGURES............................................................................................................................................................ 22 APPENDICES .............................................................................................................................................................. 33 Appendix 1: Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report
Appendix 2: Least Bell’s Vireo, Southwestern Willow Flycatcher & Yellow-billed Cuckoo Survey Report

DBESP Report

1 Determination of Biologically Equivalent or Superior Preservation (DBESP) Report
1 INTRODUCTION
Section 6.1.2 of the Western Riverside County MS HCP outlines the process through which protection of riparian/riverine areas and vernal pools would occur in the MSHCP Plan area . The purpose of the DBESP analysis is to demonstrate that the proposed mitigation would provide a biologically equivalent or superior preservation to the impacted resources.

The Sycamore Hills Distribution Center Project will be acquiring project coverage under the MSCHP through the City of Riverside which is a permittee under the MSHCP. The objective of this report is to demonstrate that the proposed mitigation would provide equivalent or superior preservation of habitat function and value of lost riverine, riparian , and wetland habitats. This DBESP analysis includes a review of the riverine, riparian, and wetland habitats onsite that are proposed to be impacted, and incorporates avoidance, minimization, and mitigation measures adequate to offset these impacts and bring them to a level of less than significant.

1.1 Project Area
The proposed project is to construct an industrial warehouse development on three par cels [Assessor Parcel Numbers (APNs) 263-060-022, 263-060-024, 263-060-026], totaling 48.64 gross acres. The property is located at the northeast corner of Barton Street and Alessandro Boulevard in the City of Riverside (City), immediately south of the Sycamore Canyon Wilderness Park. Refer to Figure 1, Project Vicinity and Location and Figure 2, Project Site Aerial Photo. Alessandro Boulevard, directly south of the project site, is a major east -west roadway, with 3 lanes of traffic in each direction and a landscaped median. The project area is within Section 9 of Township 3 South, Range 4 West, USGS 7.5-minute Riverside Eas t quadrangle in the City of Riverside, Riverside County. Refer to Figure 3, Project Site Topographic Map. The project area’s geographic coordinates near the middle of the site are 33.91916° North latitude and - 117.30918° West longitude.

1.2 Background/ History of Site
The Grove Community Church formerly owned the Project site property and planned to build a new church there. However, as the site is located within the C -1 Primary Approach/Departure Zone of the March Air Reserve Base/ Inland Port Airport Lan d Use Compatibility Plan, and due to restrictions regarding the height of the building and the maximum number of people allowed to congregate at any time, it was not conducive to the church’s plans. March Joint Powers Authority (MJPA) assisted the church i n finding a new location for the church, approximately one mile to the southwest at 19900 Grove Community Drive, Riverside (Refer to Figure 1, Project Vicinity & Location).

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2 Construction of the Grove Community Church at this location had impacts to a juris dictional drainage and associated riparian habitat. To mitigate for impacts at the Grove Community Drive site, a portion of the Project site at Alessandro Boulevard and Barton Street was set aside and preserved in a legally designated “Restricted Property,” recorded in 2009. The 11.6 acre Restricted Property area supports a jurisdictional drainage and associated riparian habitat and was required as a condition of the Clean Water Act Section 404 permit from the US Army Corps of Engineers for construction of the church at the Grove Community Drive site.

MJPA purchased the Project site property from the church with the intent to sell and to convey title of the Restricted Property area to the City of Riverside. However, a parcel map was not created, and the title transfer did not take place. MJPA is still the owner of the entire Project site property. The Project applicant intends to purchase the property from MJPA upon project entitlement approvals. (Refer to Figure 1, Project Vicinity & Location).

1.3 Project Description
Proposed Description
The project proposes subdividing the site into two parcels (Parcels 1 and 2), and three lettered parcels (Parcels A, B, and C).

Parcels 1 and 2
Each parcel is proposed to be developed with a high cube transload short-term warehouse building (Buildings A and B). Building A, a 400,000 square foot warehouse, will be constructed on Parcel

1. Building B, a 203,100 square foot warehouse, will be constr ucted on Parcel 2. Associated improvements include parking, fire lanes, fencing and walls (including retaining walls), landscaping, and water quality treatment areas. Both warehouse buildings are proposed for high cube transload short -term use, primarily for the short -term storage and/or consolidation of manufactured goods (and to a lesser extent, raw materials), usually on pallet loads or larger handling products prior to their distribution to retail locations or other warehouses. A typical high cube warehouse has a high level of on-site automation and logistics management. No refrigeration use is proposed. Refer to Figure 4, Site Plan.

The buildings will have nighttime lighting for security. Exterior lights will be shielded downwards and set to motion detectors and will only turn on if employees are present at either of the buildings when it is dark. Interior lights will also be on motion detectors.

The proposed Project includes modifications to the Restricted Property to facilitate access from Alessandro Boulevard to Building A on Parcel 1. As the access road will cross an area that is at a lower elevation than Alessandro Boulevard and the elevation of proposed Parcel 1/ Building A, it will be elevated and constructed on earthen fill with 2:1 side slopes. The elevated access road will have two culverts (38-inch x 57-inch wide arch pipe) that cross under the fill and access road to DBESP Report
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3 provide surface hydrology and wildlife access underneath. (Refer to Figure 5, Parcel 1 Entry Road Plan) A new traffic signal is proposed at Vista Grande Drive and Alessandro Boulevard to facilitate access to Building A.

Perimeter walls proposed on Parcel 1 include: 1) 42 -inch high cable rail theme fence along the northerly, westerly, and a portion of the southwesterly property line; 2) 8- foot high concrete wall along most of the easterly property line; 3) 8 -foot high tubular steel fence along a portion of the southeasterly property line; and 4) 8-foot high tubular steel fence along the southerly property line.

The access road to from Alessandro Boulevard to Building A would include 42- inch high cable rail theme fence on each side of the road. Parcel 1’s landscaping includes fire resistant groundcover, shrubs and columnar trees.

Perimeter walls proposed on Parcel 2 include: 1) 8- foot high tubular steel fence along the northwesterly property line; 2) 8-foot high combination screening fence/wall, consisting of 4-foot high tubular steel fence on top of 4- foot high screen wall, along the northerly property line; 3) 8 - foot high concrete wall along a portion of the northeasterly and most of the easterly property line; 4) 42-inch high cable rail theme fence along a portion of the southeasterly property line; 5) 6-foot high tubular steel fence along the westerly boundary of the parcel with two separate arm gates located toward the northwesterly and southwesterly portion of the boundary; and 6) 8- foot high tubular steel fence along the southerly property line. Parcel 2’s landscaping also includes fire resistant groundcover, shrubs and columnar trees.

Parcels A, B, and C
Parcels A and B contain the existing 11.6-acre Restricted Property that landlocks Parcel 1. Parcel C will be designated open space for a trailhead parking lot. Parcel A, B, and C are described in more detail below:
• Parcel A consists of 313,196 square feet (7.19 acres) and is designated as a Conservation Area. Parcel A will be part of the Restricted Property on the west side of the proposed access road along Alessandro Boulevard. The proposed Project includes removing 0.81 acres of the Restricted Property to create a driveway connecting Parcel 1/Building A to Alessandro Boulevard. As part of mitigation for the Project, 1.44 acres will be incorporated into Parcel A, for a net gain of 0.63 acre of new Restricted Property. Thus, Parcel A and B will have a total of 12.23 acres of Restricted Property as part of the Project. • Parcel B consists of 219,542 square feet (5.04 acres) and is designated as a Conservati on Area. Parcel B will be part of the Restricted Property on the east side of the proposed access road along Alessandro Boulevard. The access road would include two elliptical shaped corrugated metal pipes measuring 38 inches high and 57 inches wide to al low drainage and wildlife connectivity between Parcel A and Parcel B. Parcels A and B will be managed in perpetuity by a professional conservation organization funded by the applicant as part of mitigation for the Project.

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4 • Parcel C is proposed to be developed with a trailhead parking lot for the Sycamore Canyon Wilderness Park and will be designated as open space. It consists of 51,284 square feet (1.18 acres). The northerly terminus of Barton Street is identified as “a minor trailhead” in the Sycamore Canyon Wilderness Park Stephens’ Kangaroo Rat Management Plan and Updated Conceptual Development Plan. The proposed trailhead parking lot will include an improved decomposed granite parking lot, landscaping, a shade structure with benches, a bike rack, a drinking fountain (including for pets), and ADA (Americans with Disabilities Act) compliant parking spaces and sidewalk. Trail fencing, gates, and signage will also be installed to direct access, circulation and trail connection to existing trails as well as th e master planned multipurpose trail on the west side of Barton Street. The proposed trailhead parking lot is not required but is being provided by the applicant as an amenity and addition to the City’s Sycamore Canyon Wilderness Park. Parcel C would be ded icated to the City and operated and managed by the City’s Parks, Recreation, & Community Services Department.

Construction
The developed site for Parcel 1/Building A consists of approximately 24.31 acres with undulating topography (approximately 1,570’ to 1,615’ above mean sea level, “MSL ”). The site for Parcel 2/Building B consists of approximately 10.32 acres with undulating topography (1,580’ to 1,618’ above MSL). It is anticipated that excavation of decomposed granite may be performed utilizing conventional earthmoving equipment. Blasting will not be required and is not proposed as part of the Project site preparation activities. The planned grading results in cut areas up to 16 feet and fill areas as much as 12 feet. Over-excavation may be required to provide necessary structural support but is not expected to exceed 3 feet in depth.

Construction will occur in accordance with the City’s Noise ordinance, during the hours of 7 am to 7 pm Monday through Friday, 8 am to 5 pm on Saturdays, and not on Sundays or federal holidays. Overall construction is anticipated to last approximately 15 months. Grading and preliminary road construction is the first phase and is expected to last approximately 3 months.

After grading, building construction will last approximately 12 months and includes slab and wall framing, concrete pouring, roof installation building interiors, architectural coatings, parking lots, roadway improvements, landscaping, storm drains and water quality basins, etc.

Operation
An opening/operational year of 2023 is anticipated. Operation of Buildings A and B as high cube transload short-term warehouse are expected 24 hours a day, 7 days a week. The buildings will have nighttime lighting for security; however, the lights will be shielded downwards and will be on motion detectors so will only come on if employees are present at either of the buildings when it is dark.

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5 1.4 Avoidance Alternative
The proposed Parcel 1/ Building A site is bounded on the north by the Sycamore Canyon Wilderness Park, on the east by vacant private property, and on the south and west by the 11.6- acre legally designated as “Restricted Property.” Therefore, the proposed Parcel 1/ Building A site does not have access to Alessandro Boulevard or Barton Street without crossing the Restricted Property and the existing riparian/riverine areas. Access for Parcel 1/ Building A would require construction of an access road across the Restrictive Property and associated riparian/riverine areas. The proposed access road location was selected in an effort to minimize the impacts to riparian/riverine areas to the greatest extent feasible as well as align the new traffic signal with Vista Grande Drive, south of the Project site.
2 EXISTING CONDITIONS

2.1 Existing and Adjacent Land Uses
The project area is not located within a Cell group, Criteria Cell Area, or adjacent to a Criteria Cell Area. The project area is located directly adjacent to and south of the Sycamore Canyon Wilderness Park, which is owned by the City of Riverside and a portion directly north of the project by the State of California. The Sycamore Canyon Wilderness Park is approximately 1,500 acres of open space parkland that provides public access recreation, including hiking and biking, and is also home to a variety of plant and animal species , including the federally endangered Stephens’ kangaroo rat (SKR). Sycamore Canyon Wilderness Park is one of eight core reserves for SKR in western Riverside County , established as part of the SKR Habitat Conservation Plan and designated as a Public/Quasi -Public Land under the Western Riverside County MSHCP. The project area is not located within US Fish and Wi ldlife Service (USFWS) designated critical habitat for any federally listed species.

The project area is currently undeveloped with no existing structures. It is dominated by disturbed non-native grassland with two ephemeral drainages, some with riparian vegetation, transecting the site and one riparian feature along the southern portion of the site adjacent to Alessandro Boulevard. Metropolitan Water District’s (MWD) Henry Mills Water Treatment Plant is located directly to the west, a self -storage facility to the southwest, Alessandro B oulevard, a six -lane roadway to the south with residential and commercial on the south side of Alessandro Boulevard, and undeveloped private property to the east.

2.2 Soils
Appendix 1 contains the Project’s Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report, in which the Jurisdictional Delineation is included as Appendix D to that report. As part of the jurisdictional delineation, the project site was DBESP Report
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6 assessed to determine the presence of US Army Corps of Engineers (USACE) jurisdictional wetlands, which are identified by three criteria : the presence of hydrophytic vegetation, hydric soils, and wetland hydrology. The USDA online Web Soil Survey (based on the 1971 Soil Survey of Western Riverside Area, California ) was reviewed to determine the soil types mapped as occurring within the project site. None of the soil types within the project site are found on the USDA’s National List of Hydric Soils. Th us, no wetlands were identified within the project site based on the absence of hydric soil indicators. The project site crosses seven different mapped soil series (Figure 6, Soils) including:
• Arlington fine sandy loam (AnC) – This well-drained soil occurs on alluvial fans and terraces with 2 to 8 percent slopes. It is composed of fine sandy loam and the parent material is composed of alluvium dominantly from granitic rocks. • Cieneba sandy loam, eroded (ChF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of sandy loam on the surface and the parent material is composed of coarse-grained igneous rock. • Cieneba rocky sandy loam, eroded (CkF2) – This somewhat excessively drained soil occurs on uplands with 15 to 50 percent slopes. It is composed of rocky sandy loam on the surface and the parent material is composed of coarse-grained igneous rock. • Fallbrook sandy loam, eroded (FaD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of sandy loam and developed on granodiorite and tonalite.
• Fallbrook sandy loam, shallow, eroded (FbC2) – This well-drained soil occurs on uplands with 5 to 8 percent slopes. It is composed of sandy loam and developed on gr anodiorite and tonalite.
• Fallbrook fine sandy loam, shallow, eroded (FkD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of fine sandy loam and developed on granodiorite and tonalite.
• Vista coarse sandy loam, eroded (VsD2) – This well-drained soil occurs on uplands with 8 to 15 percent slopes. It is composed of coarse sandy loam and developed on weathered granite and granodiorite.

None of these common soil types are specifically associated with special-status species.

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7 2.3 Hydrology
The average rainfall for the area is 9.86 inches per year. Weather data was recorded approximately

3.5 miles northwest of the project site.

There are two ephemeral drainages that traverse portions of the project site in a southwest to northeast direction. Storm water runoff flow in these drainages generally in a northeast direction. (Refer to Figure 8, Riparian Riverine Areas)
These drainages likely flow for less than 3 months per year but do eventually flow into the Santa Ana River. As the two ephemeral drainages exit the site, the drainage flows continue north for ½ mile before converging with Sycamore Canyon Creek. Sycamore Canyon Creek flows for 2.5 miles northwest before converging with Tequesquit e Arroyo. Tequesquite Arroyo flows for 6.9 miles before reaching the Santa Ana River. The Santa Ana River flows southeast for 16 miles before reaching Prado Basin. The Santa Ana River continues west for 30 miles before reaching the Pacific Ocean.

2.4 Riparian/Riverine Resources
The identification and mapping of riparian/riverine resources for this DBESP is based on information contained in the Jurisdictional Delineation Report and the Biological Resources Report for the project (Wood 2020).

A delineation of jurisdictional waters, in cluding wetlands, was originally conducted by wetland specialist Scot Chandler on January 17 and 28, 2014, and was verified on May 18, 2017. A revised impact analysis was conducted in September of 2018. James Mace of the US Army Corps of Engineers, Los Angeles District conducted a site visit and evaluation on September 25, 2018, and confirmed Scot Chandler’s delineation of Waters of the US. An additional field survey of the area was conducted by Wood Senior Biologist Dale Hameister on November 14, 2019, to update existing conditions.

MSHCP riverine and riparian areas were mapped consistent with waters of the US regulated by USACE and streambeds and associated riparian vegetation under the jurisdiction of the California Department of Fish and Wildlife ( CDFW). The MSHCP Section 6.1.2 definition of riparian/riverine areas, vernal pools, and fairy shrimp habitat exclude areas artificially created , unless artificially created for the purpose of mitigation wetlands or open waters . However, there are no artificial ly created riparian/riverine or vernal pool features onsite . T he drainages are consistent with USGS topographic maps and historic aerial photographs.

Upstream and downstream connectivity of waterways was reviewed in the field and on aerial photographs and topographic maps to determine waters of the US/State/riverine areas/streambeds.

Ephemeral washes with a physical connection to Sycamore Canyon Creek, and ultimately the DBESP Report
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8 Pacific Ocean, were determined to be waters of the US/State and CDFW streambeds and riverine areas.

Evaluation of CDFW jurisdiction followed guidance in the Fish and Game Code and A Field Guide to Lake and Streambed Alteration Agreements (California Department of Fish and Game, 1994).

Specifically, CDFW jurisdiction was delineated by measuring the outer width and length boundaries of on-site streambeds which consisted of either the top of bank measurement (bankfull width) or the extent of associated riparian vegetation.

To determine jurisdictional boundaries, the surveyors walked the length of the drainage within the project area and recorded the centerline with a Trimble GeoXH global positioning system. The width of the drainage was determined by the Ordinary High Water Mark (OHWM ) and bankfull width measurements at locations where transitions were apparent. Other data recorded included bank height and morphology, substrate type, and all vegetation within the streambed and riparian vegetation adjacent to the streambed. Upon completion of fieldwork, all data collected in the field were incorporated into a Geographic Information System (GIS) along with basemap data. The GIS was then used to quantify the extent of jurisdictional waters.

There are two riverine/riparian drainages onsite and one riparian resource area as mapped in the Jurisdictional Delineation Report and are shown in Figure 7, Vegetation Communities and Figure 8, Riparian/ Riverine Areas.

Drainage A
The first riverine/riparian feature (Drainage A) enters the project site near the northern portion of the western boundary and exits the site near the middle of the northern boundary. Drainage A contains sparsely vegetated sections and areas of dense riparian vegetation. The sparsely vegetated portions of the streambed of Drainage A were dominated by short -pod mustard, western marsh cudweed (Gnaphalium palustre), and pygmy- weed (Crassula connata). The patches of riparian vegetation were dominated by mulefat, willow baccharis, (Baccharis salicina), Goodding’s black willow (Salix gooddingii), arroyo willow (Salix lasiolepis), red willow (Salix laevigata) and blue elderberry (Sambucus nigra subsp. caerulea). The presence of USACE wetlands was investigated and although the sampling point exhibited hydrophytic vegetation, it lacked hydric soils and wetland hydrology. As previously discussed, the presence of hydric soils and wetland hydrology are among the three criteria that must be fulfilled in order to classify an area as a wetland under the jurisdiction of USACE. Thus, as the sampling point lacked these criteria features, no presence of USACE jurisdictional wetlands was detected.

USACE jurisdiction/riverine area averaged 3 feet wide based on OHWM limits which included a break in bank slope and change in substrate. CDFW jurisdiction/ riparian areas ranged from 3 feet wide based on bankfull width in the upland vegetated portions of the drainage to 65 feet wide based on the extent of riparian vegetation. The banks of Drainage A ranged from vertically incised DBESP Report
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9 to steeply-sloping with depths averaging 6 inches to 1 foot. The extent of non- wetland waters of the US/State/riverine area on-site for Drainage A is 0.08 acre and 1,183 linear feet. The extent of riparian area on-site for Drainage A is 0.35 acre.

Drainage B
The second riverine/riparian feature (Drainage B) enters the project site near the middle of the southern boundary and exits the site near the middle of the northern boundary. Drainage B contains dense riparian vegetation throughout the entire on-site extent. The canopy layer was dominated by Fremont cottonwood ( Populus fremontii subsp. fremontii) and red willow. The understory was dominated by mulefat, willow baccharis, hoary nettle (Urtica dioica subsp. holosericea), saltgrass (Distichlis spicata), and emergent grasses. Herbs are more common than shrubs in this community within the project site, which lacks a well-developed mid-story canopy, and contains a relatively sparse understory. The understory has been damaged significantly by unsheltered poverty-stricken individuals (homeless encampments). The presence of USACE wetlands was investigated and although the sampling point exhibited hydrophytic vegetation it lacked hydric soils and wetland hydrology. Thus, as the sampling point lacked these two criteria USACE wetland features, no presence of USACE wetlands was detected.

USACE jurisdiction/riverine area averaged 5 feet wide based on OHWM limits which included the destruction of terrestrial vegetation. CDFW jurisdiction/ riparian areas ranged from 30 to 100 feet wide based on the extent of riparian vegetation. The banks of Drainage B ranged from gently- sloping to vertically incised with depths averaging 1- 2 foot. The extent of non- wetland waters of the US/State/riverine area on -site for Drainage B is 0.11 acre and 918 linear feet. The extent of riparian area on-site for Drainage B is 1.36 acres.

Area C
There is a third area wi th only riparian features that does not exhibit a channel or other signs of confined water flow (Area C). It is located in the southeast portion of the project site. Area C contains dense riparian vegetation dominated by mulefat, hoary nettle, willow baccharis, branching phacelia ( Phacelia ramosissima ), and Goodding’s black willow. The presence of USACE wetlands was investigated and although the sampling point exhibited hydrophytic vegetation it lacked hydric soils and wetland hydrology. Thus, as the sampling point lacked these two criteria USACE wetland features, no presence of USACE wetlands was detected.

There is no USACE jurisdiction/riverine area associated with Area C due to lack of OHWM. The extent of CDFW jurisdiction/riparian area on -site for Area C is 3.45 acres based on the extent of riparian vegetation.

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10 Table 1: Onsite Riparian and Riverine Resources
Drainage Feature Linear Feet (LF) Riverine Area (acre) Riparian Area (acre) Drainage A 1,183 0.08 0.35
Drainage B 918 0.11 1.36
Area C n/a 0 3.45
Total 2,101 0.19 5.16

2.5 Riparian-Nesting Birds
Habitat is present for the least Bell’s vireo (Vireo bellii pusillus; LBVI) and southwestern willow flycatcher (Empidonax traillii extimus; SWFL), two state and federally listed endangered riparian- nesting birds. Because habitat is present on site, the MSHCP requires focused surveys for these birds pursuant to Section 6.1.2, Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools . Surveys were conducted for the least Bell’s vireo and southwestern willow flycatcher in 2014, with positive results for the vireo and negative results for the flycatcher. Refer to Figure 9, Vireo and Flycatcher Observation Locations, for the locations where they were observed in 2014. Surveys for LBVI and SWFL were conducted again in 2020. All potentially suitable LBVI habitat areas were surveyed eight (8) times between April 10 and July 31, 2020 and five (5) SWFL surveys were conducted in May 2020. The 2020 SWFL surveys were conducted in the riparian woodland habitat along the north- south drainage as habitat in the eastern portion of the study area was deemed not suitable due to the lack of canopy present and small patch size .

Protection of riparian/riverine areas and vernal pools is important to conservation of o ther bird species also: the bald eagle (Haliaeetus leucocephalus), peregrine falcon (Falco peregrinus), and western yellow-billed cuckoo (Coccyzus americanus occidentalis). However, habitat is not present for the bald eagle, peregrine falcon, or the yellow -billed cuckoo; thus, focused surveys for these species were not warranted or completed.

Two (2) LBVI males were detected during a May 2020 survey; however, only one male remained for all subsequent surveys during the 2020 season (Kidd Biological, 2020). As outlined in the Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report (Wood 2020), the project site contains habitat that is still suitable to support LBVI from the time they begin to arrive in mid -March until their departure by early September.

There are multiple records of LBVI within the surrounding 2-mile (and further) radius of the site.

Some records predate 2008 through to the present of numerous territor ies, pairs and DBESP Report
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11 fledglings/young in Sycamore Canyon, Box Springs Canyon, and Alessandro Arroyo. Therefore, for the purposes of this analysis it is assumed that least Bell’s vireos continue to utilize the riparian woodland habitat areas in the project area for foraging and nesting in the spring and summer.

No SWFL were detected within the survey area during the 2014 protocol surveys nor within the survey area during the 2020 season. However, willow flycatchers were detected during two surveys- one on May 22, 2014, and two on June 2, 2014; see Figure 9, Vireo and Flycatcher Observation Locations. These occurrence dates are within the normal period of spring migration of this species in southern California. To support this fact, no willow flycatchers were found during surveys conducted after the end of known SWFL migration times. Therefore, it is assumed that all of the observed willow flycatchers were migrants, (likely of more northerly subspecies [E.t. adastus or E.t. brewsteri]), and not southwestern willow flycatchers (subspecies E.t. extimus).

No southwestern willow flycatchers have been docu mented within a 2- mile radius of the study area, but potential habitat is present within and near that area, so SWFL is considered to be of potential occurrence. However, the marginal habitat present on the project site makes it unlikely that the site will be used in the future by this species.

2.6 Vernal Pools
Section 6.1.2 of the Western Riverside County MSHCP further defines vernal pools as “seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season.

Obligate hydrophytes and facultative wetlands plant species are nor mally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season. The determination that an area exhibits vernal pool characteristics and the definition of the watershed supporting vernal pool hydrology must be made on a case- by-case basis. Such determinations should consider the length of the time the area exhibits upland and wetland characteristics and the manner in which the area fits into the overall ecological system as a wetland. Evidence concerning the persistence of an area's wetness can be obtained from its history, vegetation, soils, and drainage characteristics, uses to which it has been subjected, and weather and hydrologic records.”
The two on-site drainages (Drainage A and B) are ephemeral and flow across the site in a northeast direction and then into Sycamore Canyon Creek. Although there are no defined bed and bank, the riparian area (Area C) also conveys ephemeral storm water runoff in a northeast direction towards and into Sycamore Canyon Creek. All three of these feature’s flow follows the topographic relief of the site. There are no low-lying sumps in the project site that would collect and retain water and support a vernal pool. The existing topography of the site conveys storm water offsite and does not support vernal pools.

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12 2.7 Fairy Shrimp
The project site does not contain habitat for fairy shrimp including any stock ponds, ephemeral pools, or other features with a potential to support Riverside, vernal pool , or Santa Rosa fairy shrimp. Thus, focused surveys for these species were not warranted or completed.

2.8 Functions and Values Assessment of Riparian/Riverine Resources The riparian/riverine areas within the proposed project limits are supported by stormwater runoff and non-storm water runoff from residential and commercial developed areas to the south and southwest, including runoff from Alessandro Boulevard. Water runoff from the west of the site comes from the MWD treatment plant. Drainage A enters the site through a 4 -foot concrete pipe near the northern portion of the western boundary and ranges in areas of sparse vegetation sections to areas of dense riparian vegetat ion. Drainage A provides low to moderate functions and values for ephemeral stream flows, nutrient cycling, water quality, energy transfer, and wildlife habitat.

A majority of Drainage A within the project site would be impacted through project implementation.

Drainage B begins south of the site and extends onto the site from its southern boundary and on the east side of the self -storage development. This drainage supports dense riparian vegetation throughout the entire extent of the project and provides moderate to high functions and values to the watershed. Drainage B is an ephemeral stream that provides ecological and hydrological functions by moving water, nutrients, and habitat for sensitive species. It extends through the site to the north into the Sy camore Canyon Wilderness Park. Within the project site boundaries, it occurs within the conservation area and would therefore not be impacted through project implementation.

Area C has riparian habitat but does not exhibit riverine or water flows within a defined bed and banks. Because this riparian feature is not connected and does not contribute hydrologically to the watershed, it is considered to be low value for hydrological functioning. It does, however, provide moderate values for flood storage, sediment trapping, nutrient retention, toxicant trapping, and wildlife habitat for sensitive species. It extends through the site to the east into undeveloped private property. Within the project site boundaries, it occurs within the conservation area and would therefore not be impacted through project implementation. 3 IMPACTS

3.1 Avoidance
The existing 11.6- acre Restricted Property/ conservation area would remain in place with only minor impacts to the riparian habitat within the conservation area and minor revisions being DBESP Report
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13 proposed to the size and configuration of this conserved area. The project will avoid 0.11 acre of riverine habitat and 4.36 acres of riparian habitat within the Restricted Property/ conservation area.

3.2 Direct Impacts
Vernal Pools/Fairy Shrimp
The habitat assessments, delineation of jurisdictional waters, and various focused surveys did not identify depressions within the project area that would meet the definition of vernal pools or suitable habitat for fairy shrimp per Section 6.1.2 of the MSCHP. Therefore, the project would not impact vernal pools or fairy shrimp.

Drainage A
Drainage A impacts would include 0.08 acre of permanent impacts to riverine resources and 0.23 acre of permanent impacts to riparian resources from development of the Building B site.

Drainage B
Drainage B impacts would include only temporary impacts, 0.002 acre to riverine resources and

0.017 acre of temporary impacts to riparian resources from use of an existing trail during construction activities.

Area C
Area C impacts would include 0.57 acre of permanent impacts to riparian resources. Permanent impacts would occur through the development of the access road to Building A.

Table 2 below provides the acreages of impacts to both riparian and riverine resources within the project site.

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14 Table 2: Impacts to Riparian and Riverine Resources
Drainage
Feature
Riverine Resources (acres) Riparian Resources (acres)
On-Site
Acreage
Permanent
Impacts
Temporary
Impacts
On-Site
Acreage
Permanent
Impacts
Temporary
Impacts
Drainage
A

0.08 acre
1,183 LF

0.07 acre
1,044 LF
0 0.27 acre 0.23 acre 0
Drainage
B

0.11 acre
918 LF
0 0.002 acre
21 LF

1.25 acre 0 0.017 acre
Area C 0 0 0 3.45
acres

0.57 acre 0
Total 0.19 acre
2,101 LF

0.07 acre
983 LF

0.002 acre
22 LF

4.97 acre 0.80 acre 0.017 acre
In summary, the total riparian/riverine areas within the project site total 5.16 acres. The total permanent impacts to riparian/riverine areas is 0.80 acre and the total temporary impacts are 0.017 acre within the project site.

3.3 Indirect Impacts
The two warehouses are direct ly adjacent to the Sycamore Canyon Wilderness Park, which is a Stephens’ kangaroo rat reserve and supports habitat and individuals of other endangered birds .

Potential indirect impacts include new sources of noise and night-time lighting that could extend out into the adjacent park/preserve and adversely affect habitat for SKR and other sensitive species.

New sources of light and noise could also adversely affect the animals directly by disturbing their normal activities. Toxic pollutants and invasive plant species co uld be conveyed via storm water and non- stormwater runoff from the site into the adjacent park/preserve and adversely affect habitat for sensitive species.

However, the following requirements and de sign elements will be implemented as part of the project and will avoid or substantially reduce these potential indirect impacts to the adjacent park/preserve and sensitive biological resources.

Drainage
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15 With development of the Proposed Project, Drainage A storm water runoff will continue to flow through the site via an underground 48-inch pipe that will cross through the proposed project along the northern parking lot of Building B and will continue to convey the discharge flows to an off - site location. The continued conveyance of stormwater and non-s tormwater runoff and connectivity to Drainage B as well as Area C will not be altered and the hydrology support to the riparian/riverine areas located outside and downstream of the project site will not be cut off or significantly reduced. The project will be required to implement these design features as a City condition of approval.

Toxics
The proposed project is required to implement a Project Specific Water Quality Management Plan (WQMP) with Best Management Practices (BMPs) to address the project’s pollutants and preventing them from being discharged int o Drainage B or Area C and offsite into downstream receiving waterbodies, including Sycamore Canyon Creek and the Santa Ana River. The project will be required to implement the WQMP as a City condition of approval.

Lighting
Per Section 6.1.4, Guidelines Pertaining to the Urban/Wildlands Interface, night lighting is to be directed away from MSHCP Conservation Areas to protect species within the Areas from direct night lighting. As such, while the warehouse buildings will have nighttime lighting for security, the lights will be shielded downwards , have motion detectors and will only be turned on if and when employees are present. A photometric study is required by the city to ensure that the lig ht sources will be shielded to minimize off- site glare, will not direct light skyward , and will be directed away from adjacent properties and public right -of-ways. If lights are proposed to be mounted on buildings, down-lights shall be utilized. Light poles shall not exceed 20-feet in height.

An 8 -foot combination wall (4 -foot high concrete with 4- foot wrought iron on top) will be constructed along the northern side of Building B to separate the Building B parking and drive areas from the trailhead parking area and block any vehicle headlights from shining into the Sycamore Canyon Wilderness Park to the north. The project will be required to implement these design features as a City condition of approval.

The trail head parking lot, which is located along the northern side of Building B, is a buffer between the warehouse operations at Building B and the wilderness park/preserve. The trail head parking lot will be deeded to the City of Riverside. Per Riverside Municipal Code (RMC) Section

9.08.110, all parks owned by the City of Riverside shall be closed from thirty minutes after sunset of one day and thirty minutes before sunrise of the next day, unless otherwise exempt. Therefore, the trail head parking lot is anticipated to be closed between dusk and dawn and would not have vehicle headlights shining into the park from the parking lot.

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16 Noise
Construction noise is anticipated to exceed 65 dBA(A) Leq within portions of the sensitive riparian habitat between the buildings ( associated with Drainage B) and the adjacent Sycamore Canyon Wilderness Park . Construction noise impacts will be minimized with implementation of a mitigation measure Noise-1 identified in the project- specific Noise Study for the project as outlined below.

Mitigation Measure Noise-1: Should LBVI be present in the Sycamore Canyon Wilderness Park within 300 feet of the project site, in Parcel A on-site conservation area, or within Parcel B on-site conservation area within 100 feet of the development footprint, construction noise impacts shall be minimized through implementation of the following measures:

1. Install a 12-foot high temporary noise barrier at the perimeter of the limits of disturbance between the construction activities and the adjacent Sycamore Canyon Wilderness Park to the north and east and the on -site conservation areas. The barrier shall be continuous without openings, holes or cracks, and shall reach the ground. The barrier may be constructed with 1- inch plywood and provide a reduction of at least 10 dB(A) to ensure noise levels do not exceed 65 dB(A) at the Sycamore Canyon Wilderness Park and on-site conservation areas. Other materials providing the same reduction shall also be permitted.

2. Heavy grade rubber mats/pads will be used within the bed of the trucks. These mats w ill help attenuate initial impact noise generated when an excavator drops rock and debris into the bed of the truck. These mats must be maintained and/or replaced as necessary.

3. During all project site excavation and grading on-site, construction contractors shall equip all construction equi pment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturer standards.

4. The contractor shall place all stationary construction equipment so that emitted noise is directed away from the noise sensitive receptors nearest the project site.

5. Equipment shall be shut off and not left to idle when not in use.

6. The contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise/vibr ation sources and sensitive receptors nearest the project site during all project construction.

7. The project proponent shall mandate that the construction contractor prohibit the use of music or sound amplification on the project site during construction.

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17 8. The construction contractor shall limit haul truck deliveries to the same hours specified for construction equipment (7:00 am to 7:00 pm on weekdays, and 8:00 am to 5:00 pm on Saturdays).

9. Limit the use of heavy equipment or vibratory rollers and soil compre ssors along the project boundaries to the greatest extent possible. It is acknowledged that some soil compression may be necessary along the project boundaries.

10. Any jackhammers, pneumatic equipment and all other portable stationary noise sources shall be shielded and noise shall be directed away from sensitive receptors.

11. For the duration of construction activities, the construction manager shall serve as the contact person should noise levels become disruptive to local residents. A sign shall be posted at the project site with the contact phone number. This sign shall be posted at the Alessandro Boulevard frontage as well as the Barton Street frontage.

Operational noise from the warehouses will be prevented from extending out into the park/preserve by 8-foot high concrete walls located along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate sound to the sensitive habitat areas: the riparian/riverine habitat in the conservation areas between the buildings and the wilderness park/preserve to the north. An 8 -foot high concrete wall will be constructed along the western, northern and eastern sides of the Parcel 1/ Building A site. An 8- foot high concrete wall will be constructed along the northeast and eastern side of the Parcel 2/ Building B site, along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate sound to adjacent area. The project specific Noise Study indicates operational noise will not exceed residential noise standards in the on -site conservation areas or adjacent Sycamore Canyon Wilderness Park.

Therefore, with implementation of temporary sound barriers for construc tion adjacent to the riparian areas during the LBVI nesting season and with construction of 8-foot high walls between the dock door areas and sensitive habitat areas, the project would not result in increased noise that would adversely affect sensitive wildlife.

Barriers
As outlined above, the warehouses will have 8- foot high concrete walls located along the outer edge of the parking areas/drive aisles to surround the truck docking and drive areas and attenuate sound to the sensitive habitat areas: the riparian/riverine habitat in the conservation areas between the buildings and the wilderness park/preserve to the north. A 42-inch high cable rail theme fence will be located along the northern property line of Parcel 1/Building A site and the Sycamore Canyon Wilderness Park. Remaining perimeters of the site include 6- to-8-foot high tubular steel DBESP Report
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18 fence. Therefore, the proposed project includes appropriate barriers to minimize unauthorized public access to the on -site conservation areas. The project will be requ ired to implement these design features as a City condition of approval.

Grading/ Land Development
The proposed project does not include manufactured slopes in the onsite conservation area or the adjacent Sycamore Canyon Wilderness Park.

Invasives
The landscape plans will not include any of the species included on the MSHCP Table 6-2, Plants That Should Be Avoided Adjacent To The MSHCP Conservation Area (Volume I, Section 6, page 6-44). Through the City’s Design Review process, the City has required the removal of any plants identified in Table 6.2 of the MSHCP from the Conceptual Landscape Plan. 4 MITIGATION AND EQUIVALENCY
The proposed mitigation is to replace the impacted riparian habitat with on-site and in-kind habitat establishment, and to perform enhancement for all un -impacted riparian/riverine areas. The mitigation propose d is creation (establishment) of 0.61 acre of riparian woodland of a type jurisdictional to CDFW adjacent to the existing CDFW riparian woodland area south of the project area and north of Alessandro Blvd. In addition, the project will enhance a total of 1.58 acres of riparian habitat: 0.01 acre in Drainage A, 1.34 acre in Drainage B, and 0.23 acre in Area C.

Temporary impact to 0.017 acre of riparian habitat in Drainage B will be restored. In addition, the non-jurisdictional, non- riparian/riverine upland areas of slopes associated with the access road will be restored, as will be the temporary construction road. Table 3 below summarizes the mitigation for onsite riparian/riverine resources and Figure 10 provides the Mitigation Plan

1. 1 The Mitigation Planting Plan was prepared in November 2018 based on the site plan at that time. Since that time there have been a few minor adjustments to the site plan in response to wildlife and regulatory agency comments. This DBESP report reflects the current impact and proposed Conservation Area acreages. The same acreages of proposed mitigation will be implemented as outlined in the Mitigation Planting Plan and in Table 3, although the location may be shifted slightly to account for the minor adjustments to the site plan.

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19 Table 3. Proposed Mitigation Plan
Type of Action Drainage A
(acreage)
Drainage B
(acreage)
Area C
(acreage)
Upland Areas
(acreage)
Restoration of
Temporary
Impacts

0.00 0.02 0.00 0.73
Enhancement 0.01 1.34 0.23 0.00
Creation 0.00 0.00 0.61 0.00
The loss of 0.07 acre of riverine habitat, and 0.80 acre of riparian habitat will be offset by the enhancement, creation, and preservation of Drainage B and Area C that will increase the available onsite riparian habitat from 5.16 acre to 5.77 acres. The creation of riparian habitat in Area C would reconnect fragmented habitat and provide improved biological connection for foraging habit for the least Bell’s vireo and willow flycatcher. The roadway to the project site would also include culverts to provide a hydrological connection to the riparian habitat on the other side and a corridor for small wildlife species.

Details regarding the methods of establishment, restoration, and enhancement including grading, site preparation, and a planting pl an for each area can be found in Appendix A, the Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report, which contains the project’s Mitigation Planting Plan.

The riparian/riverine resources proposed to be enhanced and conserved in perpetuity would provide a biologically superior riparian habitat for riparian species, including least Bell’s vireo and willow flycatcher. The creation of riparian habitat on the southernmost portion of the project site would provide biologically superior habitat by connecting two patches of riparian habitats allowing for more acreage of habitat and movement opportunities for small wildlife species.

A Pre -Application meeting for this project was conducted on October 10, 2018 with representatives from the Western Riverside County Regional Conservation Authority (RCA), USFWS, CDFW, USACE, the Santa Ana Regional Water Quality Control Board, the applicant and the applicant’s consultants. The proposed mitigation plan was presented and discussed, with general consensus of the overall on- site mitigation plan, and with a request to include a culvert under the Parcel 1/ Building A access road to provide a hydrological connection and a corridor for small wildlife species.

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20 With the pr oposed project design and mitigation efforts described above (restoration, enhancement, and creation), the project would provide a biologically superior alternative than the existing conditions of the property.

The on-site mitigation is summarized below:

1. Enhancement of a total of 1.58 acres of riparian habitat: 0.01 acre in Drainage A, 1.34 acre in Drainage B, and 0.23 acre in Area C

2. Create (establish) 0.61 acre of in-kind riparian woodland in Area C

3. Restoration of 0.02 acre of riparian habitat in Drainage B

4. The non-jurisdictional, non- riparian/riverine upland areas of slopes associated with the access road will be restored/ replanted with native seed mix

5. The roadway/access to Parcel 1/ Building A will include culverts to provide a hydrological connection to the riparian habitat on the east side of the roadway and a corridor for small wildlife species

6. Record lettered parcels for portions of the site that will not be developed for warehouse use but designated as conservation area. Parcel A approximately 7.19 acres and is proposed to largely include the existing Restricted Property, with modifications to remove 0.81 acre for the access road to Parcel 1/ Building A from Alessandro Boulevard, and to add 1.44 acres of land, for a net increase in the Restricted Property area of 0.63 acre. Parcel B is 5.04 acres and includes the Restricted Property on the east side of the access road to Parcel 1/ Building A. (Refer to Figure 4, Site Plan) Parcels A and B will be designated as Conservation Areas, with a combined total of 12.23 acres and will be managed in perpetuity by a 3 rd party, anticipated to be the Rivers and Lands Conservancy, with an endowment funded by the developer. The 12.23-acre Conservation Area (Parcels A & B) do not include the access road to Parcel 1/Building A or access ramps for maintenance of the culverts under the roadway.

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21 5 REFERENCES/ APPENDICES
Appendix 1 - Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report, Sycamore Hills Distribution Center Project, Riverside County, California: WOOD. December 18, 2020.

Appendix A: Plant Species
Appendix B: Vert ebrate Species List
Appendix C: Photographs
Appendix D: Jurisdictional Delineation
Appendix E: Focused Surveys for the Southwestern Willow Flycatcher and Least Bell’s Vireo
Appendix F: Mitigation Planting Plan
Appendix 2 – 2020 Least Bell’s Vireo, Southwestern Willow Flycatcher & Yellow-billed Cuckoo Survey Results for the Sycamore Hills Distribution Center, Riverside, California, Kidd Biological, Inc. August 2020.

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22 6 FIGURES

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Project Vicinity & Location
Figure 1
°
0 0.50.25
Miles
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\01 Project Vicinity and Location.mxd AP Source: ESRI World Transportation Basemap, Esri World Imagery Legend
Project Site
)
Grove Community
Church

Barton St
Vista Grande Dr
Camino del Sol

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Project Site Aerial Photo
Figure 2
°
0 1,000500
Feet
5/12/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\02 Project Site Aerial Photo.mxd AP Source: Nearmap, January 2020
Legend
Restricted Property
Project Site
E Allessandro Blvd

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Project Site Topographic Map
Figure 3
°
0 10.5
Miles
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\03 Project Site Topographic Map.mxd AP Source: Esri USGS Topographic Basemap
Legend
Project Site

SYCAMORE HILLS DISTRIBUTION CENTER
Project Site Map
Figure 4
Source: Bing Aerial Microsoft Corporation 2020, Datum: NAD 83, Coordinate Sytem: State Plane 6 Date: G:\Projects\2020-0007SycamoreDist\GIS\DBESP\2020-0007ProjectSiteDBESP .mxd 0 225 450112.5
Feet
¯
Legend
Additional Restricted Property
Restricted Property Property
Boundary
Site Plan
East Allesandro Boulevard
Barton Street
Avendida Hacienda
Vista Grande Drive
Sycamore Canyon Wildernes Park
Parcel 1
Building A
400,000 S.F.

Parcel 2
Building B
203,100 S.F.

Parcel A
Conservation Area
Parcel A
Conservation
Area
Parcel B
Conservation Area
Parcel C

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Parcel 1 Entry Road Plan
Exhibit 5
°
3/18/2020 JN M:\Mdata\RVA\Sycamore Hills\MXD\05 Parcel 1 Road Entry Plan.mxd <User Name> Source: SDH & Associates
Not to Scale

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Soils
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\06 Soils.mxd Source: Esri World Imagery, Esri, Soil Survey Geographic Database (SSURGO), Natural Resources Conservation Service (NRCS) FaD2
°
0 500 1,000
Feet
Legend
Arlington fine sandy loam, 2 to 8% slopes
Cieneba rocky sandy loam, 15 to 50% slopes, eroded
Cieneba sandy loam, 15 to 50 percent slopes, eroded
Fallbrook fine sandy loam, shallow, 8 to 15% slopes, eroded Fallbrook sandy loam, 8 to 15% slopes, eroded
Fallbrook sandy loam, shallow, 5 to 8% slopes, eroded
Vista coarse sandy loam, 8 to 15% slopes, eroded
Exhibit 6
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\06 Soils.mxd E Allessandro Blvd
Barton StBarton St
Camino del SolVista Grande Dr
AnC
AnC
FaD2
FaD2
ChF2
VsD2
VsD2
FkD2
FkD2
CkF2
CkF2
FaD2
FbC2
FbC2
ChF2
AnC
AnC
CkF2
FkD2

SYCAMORE HILLS DISTRIBUTION CENTER PROJECT
Vegetation Communities
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\07 Vegetation Communities.mxd Source: Esri World Imagery, Wood PLC
°
0 250 500
Feet
Legend
Project Site
Disturbed/Trail
Non-Native Grassland
Riparian
Exhibit 7
5/11/2020 JN T:\Mdata\RVA\Sycamore Hills\MXD\07 Vegetation Communities.mxd E Allessandro Blvd
Barton St
Vista Grande Dr