Sacramento City Council
December 2, 2025

are required to be EV capable, and 25 percent of the EV capable spaces are required to include electric vehicle supply equipment (EVSE), which is installed charging receptacles or permanently installed chargers. The proposed project would be required to comply with the 2022 CBSC. As a result, a total of 734 EV capable spaces, and 184 EVSE spaces would be required within the site. Therefore, the actual consumption of gasoline associated with the proposed project is anticipated to be even lower than the 0.0024 percent statewide contribution noted above. Additionally, the proposed project would be required to comply with all applicable regulations associated with vehicle efficiency and fuel economy.

Conclusion
Based on the above, the proposed project would not be considered to result in a wasteful, inefficient, or unnecessary use of energy, and the proposed project is not anticipated to conflict with a State or local plan for renewable energy or energy efficiency. Thus, impacts would be considered less than significant.

Mitigation Measure(s)
None required.

Cumulative Impacts and Mitigation Measures
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

A project’s emissions may be individually limited, but cumulatively considerable when taken in combination with past, present, and future development projects. The geographic context for the cumulative air quality and GHG analysis includes the City of Sacramento and surrounding areas within the portion of the SVAB that is designated nonattainment for ozone and PM10. Refer to Chapter 6, Statutorily Required Sections, for additional detail regarding the cumulative setting evaluated in this EIR.

4.3-6 Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). Based on the analysis below, and with the implementation of mitigation, the impact would be cumulatively considerable and
significant and unavoidable.

The following discussion applies to the potential for both project components to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors).

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Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
The proposed project is within a nonattainment area for ozone and PM10. By nature, air pollution is largely a cumulative impact. The population growth and vehicle usage within the nonattainment area from the proposed project, in combination with other past, present, and reasonably foreseeable projects within Sacramento and surrounding areas, contributes to the region’s adverse air quality impacts on a cumulative basis, and could either delay attainment of AAQS or require the adoption of additional controls on existing and future air pollution sources to offset emission increases. Thus, the project’s emissions of criteria air pollutants would contribute to cumulative regional air quality effects.

As noted in the Standards of Significance section above, SMAQMD directs lead agencies to use the region’s existing attainment plans as a basis for analysis of cumulative emissions. A project’s interference with such plans may be determined through the use of the SMAQMD’s recommended thresholds of significance for ozone precursors, PM2.5, and PM10. The SMAQMD’s recommended cumulative thresholds are identical to the operational thresholds, both of which are presented in Table 4.3-6.

Accordingly, if the proposed project would result in an increase of ROG, NOX, PM10, or PM2.5 in excess of SMAQMD’s operational phase cumulative-level emissions threshold, which are equivalent to SMAQMD’s project-level operational emissions thresholds, the project could potentially result in a significant incremental contribution towards cumulative air quality impacts. The proposed project’s unmitigated cumulative contribution to regional emissions is equivalent to the project’s unmitigated operational emissions, as presented in Table 4.3-9.

As shown in Table 4.3-9, the proposed project’s unmitigated operational emissions of PM10 and PM2.5 would be below the SMAQMD’s applicable thresholds of significance.

However, the proposed project would result in operational emissions of ROG and NOX, which exceed all applicable SMAQMD thresholds of significance. Therefore, the proposed project could be considered to result in a cumulatively considerable net increase of a criteria pollutant for which the project region is non-attainment.

Mitigation Measure(s)
Implementation of the following mitigation measure represents all feasible mitigation to address criteria pollutant emissions. However, as presented in Table 4.3-10, emission levels would still exceed the applicable thresholds of significance and, therefore, the impact would remain significant and unavoidable.

4.3-6 Implement Mitigation Measure 4.3-2.

4.3-7 Generation of GHG emissions that may have a significant impact on the environment or conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. Based on the analysis below, and with the implementation of mitigation, the project’s Draft EIR
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incremental contribution to this significant cumulative impact is less than cumulatively considerable.

The following discussion applies to the potential for both project components to result in the generation of GHG emissions that may have a significant impact on the environment or conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Buildout of the proposed project would contribute to increases of GHG emissions that are associated with global climate change during construction and operation, which are discussed in further detail below. It should be noted that the proposed off-site force main would result in GHG emissions only during project construction.

Construction GHG Emissions
The estimated unmitigated maximum construction-related emissions associated with the Proposed Project Scenario are presented in Table 4.3-13. Similarly, Table 4.3-14 presents the estimated unmitigated maximum construction-related emissions associated with the Full Buildout of the Annexation Area Scenario.

Table 4.3-13
Maximum Unmitigated On-Site Construction GHG Emissions
– Proposed Project (MTCO2e/yr)
GHG Emissions
Threshold of
Significance Exceeds Threshold?
5,422.54 1,100 YES
Source: CalEEMod, June 2023 (see Appendix C).

Table 4.3-14
Maximum Unmitigated On-Site Construction GHG Emissions
– Full Buildout of the Annexation Area (MTCO2e/yr)
GHG Emissions
Threshold of
Significance Exceeds Threshold?
6,400.43 1,100 YES
Source: CalEEMod, June 2023 (see Appendix C).

As shown in the tables, the maximum annual construction-related GHG emissions would be above the SMAQMD threshold of 1,100 MTCO2e/yr under both project scenarios. Therefore, project construction could be considered to result in a cumulatively considerable contribution to global climate change. However, it should be noted that the net change in GHG emissions related to construction associated with the nonparticipating parcels would be 977.89 MTCO2e/yr, which is approximately 15 percent of the overall GHG emissions associated with project construction.

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Operational GHG Emissions
The unmitigated maximum annual operational GHG emissions were estimated under both the Proposed Project Scenario and the Full Buildout of the Annexation Area Scenario. The results are presented in Table 4.3-15.

Table 4.3-15
Unmitigated Annual Operational GHG Emissions
(MTCO2e/yr)
Emission Source Proposed Project
Full Buildout of
Annexation Area
Area 0.24 0.26
Energy 15,810.63 20,241.33
Mobile1 41,607.79 48,833.4
Offroad 2,893.68 4,411.25
Waste 3,375.85 4,251.88
Water 1,729.94 2,193.65
TOTAL ANNUAL GHG EMISSIONS 65,418.13 79,931.77 1 Mobile emissions include both passenger vehicle emissions estimated in CalEEMod, as well as heavy-duty vehicle emissions calculated off-model using EMFAC2021.

Source: CalEEMod, June 2023 (see Appendix C).

The proposed project’s compliance with the SMAQMD’s BMPs is discussed in further detail below.

BMP-1: No Natural Gas
In order to be consistent with BMP 1, the proposed project (including both the industrial park and nonparticipating parcels) is required to include all electric appliances and plumbing. However, project specific information is not available to ensure that the proposed project would be designed and constructed without natural gas infrastructure. In addition, the complete prohibition of natural gas may be infeasible for the proposed project, as natural gas is anticipated to be used for cooking appliances in the proposed restaurant uses associated with the on-site highway commercial portion of the proposed project. All other components of the proposed project, including any space heating and HVAC systems on-site, would be required to be electric with implementation of Mitigation Measure 4.3-7(b).

Pursuant to SMAQMD’s Guidance, BMP-1 may be replaced with an alternative mitigation strategy that would reduce GHG to the same extent.

Nonetheless, the proposed restaurant components of the proposed project would be required to pre-wire for a future retrofit to remove natural gas plumbing and become all-electric.

According to the CalEEMod results, natural gas combustion associated with the proposed restaurant uses would account for 158.77 MTCO2e/yr.

In order to fully comply with BMP-1 at full buildout, the proposed project must reduce overall GHG emissions by 158.77 MTCO2e/yr. Compliance Draft EIR
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with BMP-1 through the equivalent reduction in GHG emissions would be ensured by Mitigation Measure 4.3-7(b).

BMP-2: EV-Ready
Consistent with BMP-2, the proposed project would be required to provide EV Ready parking spaces at the ratio with which the current CalGreen Tier 2 standards require EV Capable spaces (see Table 4.3-16). Given that the proposed project is anticipated to include a total of approximately 3,670 parking stalls, the project would be required to provide 1,652 EV Ready spaces, and 545 of the EV Ready spaces would be required to have EVSE, which are installed charging receptacles or permanently installed chargers.

However, project specific information is not available to ensure that the proposed project would be designed to include the required number of EV Ready spaces. Therefore, compliance with BMP-2 would be ensured by Mitigation Measure 4.3-7(c).

Table 4.3-16
EV Parking Space Requirements for Nonresidential
Land Uses
Total Number
of Actual
Parking Spaces
Tier 2 Number of
Required EV
Capable Spaces
Tier 2 Number of EVCS
(EV Capable Spaces
Provided with EVSE)2
0-9 3 0
10-25 8 3
26-50 17 6
51-75 28 9
76-100 40 13
101-150 57 19
151-200 79 26
201 and over 45 percent of total
parking spaces1
33 percent of EV capable
spaces 1 The Calculation for spaces shall be rounded up to the nearest whole number. 2 The number of required EVCS (EV capable spaces provided with EVSE) in column 3 count toward the total number of required EV capable spaces shown in column 2.

Source: 2022 CalGreen Code (Table A5.106.5.3.2)
BMP-3: No Net increase in Total VMT
Because the project is located within the jurisdiction of SMAQMD, the project is required to implement BMPs 1 and 2. However, even with implementation of BMPs 1 and 2, the project would still result in annual emissions over the SMAQMD’s threshold of significance and, therefore, would be subject to BMP 3.

As discussed in Chapter 4.12, Transportation, of this EIR, the proposed project does not include any retail uses in excess of 50,000 sf. Therefore, the highway commercial uses are considered to be local-serving retail, and consistent with OPR guidance, would result in a less-than-significant impact related to VMT. However, based on the SACOG SACSIM 19 travel demand model, the on-site industrial uses are anticipated to generate VMT Draft EIR
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at 128 percent of the regional average, which is above the significance threshold established for the proposed project.

Therefore, the proposed project would be required to comply with Mitigation Measure 4.12-3, which requires that the owner/operator of on-site industrial building prepare and implement a VMT Reduction Plan to reduce VMT by at least 22 percent prior to the certificate of occupancy, consistent with the VMT Mitigation Memorandum prepared by the City’s Public Works Department for the proposed project. As noted in Chapter 4.12, with implementation Mitigation Measure 4.12-3, the proposed project would achieve a 22 percent reduction in VMT to ensure that a net increase in total VMT would not occur as a result of the proposed project, and a less-thansignificant impact would occur.

Based on the above, with implementation of Mitigation Measure 4.12-3, the proposed project would meet the requirements of an established local SB 743 target, which would ensure the proposed project would comply with BMP-3.

Consistency with City of Sacramento CAAP
The City of Sacramento has integrated a CAAP into the City’s 2040 General Plan, and, thus, in addition to project compliance with SMAQMD’s established thresholds, as discussed above, potential impacts related to climate change from development within the City are assessed based on the project’s compliance with the City’s newly adopted CAAP reduction measures. The majority of the reduction measures set forth in the CAAP are citywide efforts in support of reducing overall citywide emissions of GHG and are not applicable to individual development projects. However, various measures related to new development within the City would directly apply to the proposed project. The project’s general consistency with the applicable CAAP measures is discussed below.

Measure E-2 of the CAAP encourages the elimination of natural gas in new construction. As required by Mitigation Measure 4.3-7(b), the proposed project would be designed such that all project components, with the exception of the on-site restaurant kitchens, are built all-electric. The kitchens would be required to include pre-wiring to allow for the future retrofit of all natural gas appliances with all-electric appliances, and if natural gas is installed in the kitchens, the project applicant would be required to reduce GHG emissions associated with on-site restaurant kitchens at a rate of 158.77 MTCO2e/yr. Therefore, the proposed project would generally be consistent with Measure E-2 of the CAAP.

In addition, as discussed in Chapter 4.12, Transportation, of this EIR, Mitigation Measure 4.12-2 would require that the proposed project implement new bicycle and pedestrian improvements along the project frontage, in compliance with City standards. In addition, all internal roadways and associated bicycle and pedestrian improvements would be constructed in conformance with City standards. As such, the proposed project would generally comply with Action TR-1.2 of the CAAP.

Furthermore, as required by Mitigation Measure 4.3-7(c), the project would provide 1,652 EV Ready spaces, and 545 spaces with EVSE. As such, the proposed project Draft EIR
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would comply with Section 4.106.4 of the CALGreen Code, thus generally complying with Measure TR-3 of the CAAP.

Finally, including low impact development (LID) such as the proposed on-site bioretention basins, the proposed project would also generally comply with Action WW-1.4 of the CAAP.

Consistency with 2022 Scoping Plan
Appendix D to the CARB’s 2022 Scoping Plan provides examples of key project attributes that could be considered to assess a project’s compliance with the State’s 2030 GHG emissions reductions goals. Thus, general implementation of the suggested project attributes within the 2022 Scoping Plan would be considered to demonstrate the project’s compliance with SB 32. The project’s consistency with the key attributes within the 2022 Scoping Plan is assessed in Table 4.3-17 below.

Table 4.3-17
Project Consistency with the 2022 Scoping Plan
Key Project Attributes Consistency Discussion
Provides EV charging infrastructure that, at
minimum, meets the most ambitious
voluntary standard in the California Green
Building Standards Code at the time of
project approval.

Consistent with SMAQMD BMP-2, as
discussed above, the proposed project
would provide EV Ready parking spaces at
the ratio with which the current CalGreen
Tier 2 standards require EV Capable spaces
(see Table 4.3-16). Compliance with BMP-2
would be ensured by Mitigation Measure 4.3-
2(c).

Is located on infill sites that are surrounded
by existing urban uses and reuses or
redevelops previously undeveloped or
underutilized land that is presently served
by existing utilities and essential public
services (e.g., transit, streets, water,
sewer).

The project site is bound to the north by I-5
and to the east by the City of Sacramento.

The site is currently undeveloped, and a
portion of Bayou Way is located within the
project site, which is generally laid out in an
east-to-west direction. Surrounding existing
land uses include a Life Storage facility and
the Westlake single-family residential
subdivision to the east; the West Drainage
Canal, vacant agricultural land, open space
land, and the Paso Verde K-8 School to the
south; undeveloped agricultural land to the
west; the Sacramento International Airport to
the northwest, across I-5; and the Metro Air
Park, Amazon SMF-1 Fulfillment Center, and
the under-construction Northlake
(Greenbriar) subdivision to the north, across
I-5. It should also be noted that the approved
Sacramento International Airport Master
Plan is located to the northwest of the project
site, and the proposed SWIFT Project is
located adjacent to the project site’s western
boundary. Therefore, the proposed project
would develop the site with urban uses
consistent with the existing and planned
uses in the project vicinity. The project would
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Table 4.3-17
Project Consistency with the 2022 Scoping Plan
Key Project Attributes Consistency Discussion
also include the development of additional
roadways throughout the project site.

Does not result in the loss or conversion of
natural and working lands.

As discussed in Chapter 4.2, Agricultural
Resources, of this EIR, the existing land
uses within the Development Area are
predominantly agricultural and appears to
contain active farmland, including
approximately 31.3 acres of Prime Farmland
and approximately 12.1 acres of Farmland of
Statewide Importance. Thus, the proposed
project would result in the conversion of
farmland to non-agricultural uses.

Nonetheless, as discussed in Chapter 4.4,
Biological Resources, of this EIR, portions of
the project site are located within the
Natomas Basin Habitat Conservation Plan
(HCP) policy area boundaries. As discussed
therein, the proposed project would be
subject to applicable fees for the conversion
of habitat to urban uses. As such, in
compliance with Natomas Basin HCP
requirements, the proposed project would be
required to identify appropriate lands to be
set aside in permanent conservation
easement at a ratio of 0.5 Farmland acre
located within the Natomas Basin HCP policy
area converted to urban land uses to one
acre of habitat preserved. Therefore,
although the proposed project would involve
the conversion of farmland to nonagricultural uses, through compliance with Natomas Basin HCP requirements, other
farmland would be preserved elsewhere.

Consists of transit-supportive densities
(minimum of 20 residential dwelling units per
acre), or
Is in proximity to existing transit stops (within
a half mile), or
Satisfies more detailed and stringent criteria
specified in the region’s SCS.

The proposed project is industrial in nature
and does not include any residential
development. Therefore, the first criterion of
this key project attribute is not applicable to
the proposed project.

As discussed in Chapter 4.12,
Transportation, of this EIR, the closest transit
stop to the project site is a Sacramento
Regional Transit (SacRT) stop located north
of the project site. However, the existing stop
is located more than 0.5-mile from the site.

Therefore, the proposed project is not within
a half mile of an existing transit stop.

As further discussed in Chapter 4.12, the
proposed project does not include any retail
uses in excess of 50,000 sf. Therefore, the
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Table 4.3-17
Project Consistency with the 2022 Scoping Plan
Key Project Attributes Consistency Discussion
highway commercial uses are considered to
be local-serving retail, and consistent with
OPR guidance, would result in a less-thansignificant impact related to VMT. However, based on the SACOG SACSIM 19 travel
demand model, the on-site industrial uses
are anticipated to generate VMT at 128
percent of the regional average, which is
above the significance threshold established
for the proposed project. Therefore, the
proposed project would be required to
comply with Mitigation Measure 4.12-3,
which requires that the owner/operator of onsite industrial building prepare and implement a VMT Reduction Plan to reduce
VMT by at least 22 percent prior to the
certificate of occupancy, consistent with the
VMT Mitigation Memorandum prepared by
the City’s Public Works Department for the
proposed project. As noted in Chapter 4.12,
with implementation Mitigation Measure

4.12-3, the proposed project would achieve
a 22 percent reduction in VMT, and a lessthan-significant impact would occur.

Therefore, compliance with Mitigation
Measure 4.12-3 would ensure that the
proposed project would not preclude
implementation of the transportation goals
included in the SACOG MTP/SCS.

Reduces parking requirements by:
 Eliminating parking requirements or
including maximum allowable
parking ratios (i.e., the ratio of
parking spaces to residential units or
square feet); or
 Providing residential parking supply
at a ratio of less than one parking
space per dwelling unit; or
 For multifamily residential
development, requiring parking
costs to be unbundled from costs to
rent or own a residential unit.

The proposed project would include the
development of an industrial park within an
approximately 353.5-acre portion of the
project site, as well as approximately 98,200
sf of retail/highway commercial uses on
approximately 13.4 acres of the site. As
such, the proposed project does not include
the development of residential uses, and this
key project attribute would not be applicable
to the proposed project.

At least 20 percent of units included are
affordable to lower-income residents.

The proposed project would include the
development of an industrial park within an
approximately 353.5-acre portion of the
project site, as well as approximately 98,200
sf of retail/highway commercial uses on
approximately 13.4 acres of the site. As
such, the proposed project does not include
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Table 4.3-17
Project Consistency with the 2022 Scoping Plan
Key Project Attributes Consistency Discussion
the development of residential uses, and this
key project attribute would not be applicable
to the proposed project.

Results in no net loss of existing affordable
units.

The project site does not currently include
any affordable housing units. Therefore, the
proposed project would not result in a net
loss of existing affordable units.

Uses all-electric appliances without any
natural gas connections and does not use
propane or other fossil fuels for space
heating, water heating, or indoor cooking.

As discussed above, in order to be
consistent with SMAQMD BMP 1, the
proposed project is required to include all
electric appliances and plumbing. However,
project specific information is not available to
ensure that the proposed project would be
designed and constructed without natural
gas infrastructure. In addition, the complete
prohibition of natural gas may be infeasible
for the proposed project, as natural gas is
anticipated to be used for cooking appliances
in the proposed restaurant uses associated
with the on-site highway commercial portion
of the proposed project. All other
components of the proposed project,
including any space heating and HVAC
systems on-site, would be required to be
electric with implementation of Mitigation
Measure 4.3-7(b). Furthermore, pursuant to
SMAQMD’s Guidance, BMP-1 may be
replaced with an alternative mitigation
strategy that would reduce GHG to the same
extent. As such, compliance with BMP-1
through the equivalent reduction in GHG
emissions would be ensured by Mitigation
Measure 4.3-7(b).

Source: California Air Resources Board. 2022 Scoping Plan [Appendix D]. December 2022.

As shown in Table 4.3-17 the proposed project would generally comply with the applicable suggested project attributes included in the 2022 Scoping Plan. Because the 2022 Scoping Plan is the CARB’s strategy for meeting the State’s 2030 emissions goals established by SB 32, the project would not be considered to conflict with SB

32. Conclusion
Based on the analysis presented above, the proposed project would generally comply with the applicable suggested project attributes included in the 2022 Scoping Plan.

However, the proposed project would exceed SMAQMD’s 1,100 MTCO2e/yr threshold of significance during construction. In addition, compliance with the SMAQMD BMPs cannot be ensured at this time. Thus, the proposed project could be considered to generate GHG emissions, either directly or indirectly, that would have a significant impact on the environment, or conflict with an applicable plan, policy, or regulation Draft EIR
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adopted for the purpose of reducing the emissions of GHGs. Consequently, the project could result in a cumulatively considerable incremental contribution to GHG emissions or climate change and the project’s impact would be significant.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potentially significant impact to a less-than-significant level.

Construction

4.3-7(a) Prior to the initiation of construction of the industrial park, the project applicant shall demonstrate that construction-related GHG emissions would be reduced to 935 MTCO2e/yr and shall submit proof to the City of Sacramento Community Development Department. In addition, prior to the initiation of construction of the nonparticipating parcels, the future applicant of all future development proposals on such parcels shall demonstrate that construction-related GHG emissions would be reduced to 165 MTCO2e/yr and shall submit proof to the City of Sacramento Community Development Department.

Construction-related GHG emissions can be reduced through several options. The SMAQMD recommends the following options for reducing greenhouse gas emission from construction projects:
 Modify the construction schedule to reduce the intensity of construction to lower emissions;
 Ensure that phases of development do not overlap;
 Use of renewable diesel for construction fuel rather than diesel;  Improve fuel efficiency from construction equipment by:
o Minimizing idling time either by shutting equipment off when not in use or reducing the time of idling to no more than three minutes (five-minute limit is required by the state airborne toxics control measure [Title 13, sections 2449(d)(3) and 2485 of the California Code of Regulations]). Provide clear signage that posts this requirement for workers at the
entrances to the site; and
o Using equipment with new technologies (repowered
engines, electric drive trains).
 Perform on-site emission reductions such as implementing on-site material hauling with trucks equipped with on-road engines (if determined to be less emissive than the off-road engines) or real, quantifiable, permanent, verifiable, and enforceable on-site emission reductions;
 Use alternative fuels for generators at construction sites such as propane or solar, or use electrical power;
 Use a CARB-approved low carbon fuel for construction equipment; (NOX emissions from the use of low carbon fuel must be reviewed and increases mitigated.)
 Encourage and provide carpools, shuttle vans, transit passes and/or secure bicycle parking for construction worker commutes; Draft EIR
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 Reduce electricity use in the construction office by using LED bulbs, powering off computers every day, and replacing heating and cooling units with more efficient ones;
 Recycle or salvage non-hazardous construction and demolition debris (goal of at least 75 percent by weight);
 Use locally sourced or recycled materials for construction materials (goal of at least 20 percent based on costs for building materials, and based on volume for roadway, parking lot, sidewalk and curb materials). Wood products utilized should be certified through a sustainable forestry program;
 Minimize the amount of concrete for paved surfaces or utilize a low carbon concrete option;
 Produce concrete on-site if determined to be less emissive than transporting ready mix;
 Use SmartWay certified trucks for deliveries and equipment transport; and
 Develop a plan to efficiently use water for adequate dust control.

The project applicant may elect to implement any combination of the foregoing measures to reduce construction-related GHG emissions. All GHG emissions reductions must be quantified. Compliance with the aforementioned measures shall be ensured by the City of Sacramento Community Development Department.

If the quantified reduction measures do not reduce construction-related GHG emissions to below 935 MTCO2e/yr for the industrial park and 165, MTCO2e/yr for the nonparticipating parcels, offsite carbon credits may be purchased to make up the difference. The purchase of off-site mitigation credits shall be negotiated with the City and SMAQMD at the time that credits are sought. Off-site mitigation credits shall be real, quantifiable, permanent, verifiable, enforceable, and additional, consistent with the standards set forth in Health and Safety Code section 38562, subdivisions (d)(1) and (d)(2). The offsets shall be retired, and emissions must be offset through the year 2045. Such credits shall be based on CARB-approved protocols that are consistent with the criteria set forth in subdivision (a) of Section 95972 of Title 17 of the California Code of Regulations, and shall not allow the use of offset projects originating outside of California, except to the extent that the quality of the offsets, and their sufficiency under the standards set forth herein, can be verified by the City of Sacramento and/or the SMAQMD. Such credits must be purchased through one of the following: (i) a CARB-approved registry, such as the Climate Action Reserve, the American Carbon Registry, and the Verified Carbon Standard; (ii) any registry approved by CARB to act as a registry under the California Cap and Trade program; or (iii) any registry established by SMAQMD.

Operations

4.3-7(b) Prior to the approval of any building permits, the applicant shall implement the following measures:

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1. The proposed project shall be designed such that all project components, with the exception of the on-site restaurant kitchens, are built all-electric. The kitchens shall include pre-wiring to allow for the future retrofit of all natural gas appliances with all-electric appliances. If the kitchens are electrically powered and do not use natural gas, further mitigation is not required; and

2. If natural gas is installed in the kitchens, the applicant shall reduce GHG emissions associated with on-site restaurant kitchens at a rate of 158.77 MTCO2e/yr through any combination of the following onsite mitigation options:
o Requiring on-site renewable energy generation in excess of Code requirements.
o Increasing the number of EV charging stations.
o Constructing on-site or fund off-site carbon sequestration projects (such as tree plantings or reforestation projects). o Implementing a Transportation Demand Management
Program.
o Should new and quantifiable GHG emission reduction
technology become available, the applicant may otherwise achieve the required GHG emissions reduction through
other means, subject to review and approval by the City of Sacramento and the SMAQMD.

The project applicant may elect to implement any combination of the foregoing measures to reduce operational GHG emissions. All GHG emissions reductions must be quantified.

If it is determined that the above on-site mitigation options are not sufficient to achieve the required GHG reduction, subject to the discretion of the City of Sacramento and the SMAQMD, off-site carbon credits may be purchased to make up the difference. The purchase of off-site mitigation credits shall be negotiated with the City and SMAQMD at the time that credits are sought. Off-site mitigation credits shall be real, quantifiable, permanent, verifiable, enforceable, and additional, consistent with the standards set forth in Health and Safety Code section 38562, subdivisions (d)(1) and (d)(2). The offsets shall be retired, and emissions must be offset through the year 2045. Such credits shall be based on CARBapproved protocols that are consistent with the criteria set forth in subdivision (a) of Section 95972 of Title 17 of the California Code of Regulations, and shall not allow the use of offset projects originating outside of California, except to the extent that the quality of the offsets, and their sufficiency under the standards set forth herein, can be verified by the City of Sacramento and/or the SMAQMD. Such credits must be purchased through one of the following: (i) a CARB-approved registry, such as the Climate Action Reserve, the American Carbon Registry, and the Verified Carbon Standard; (ii) any registry approved by CARB to act as a registry Draft EIR
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under the California Cap and Trade program; or (iii) any registry established by SMAQMD.

Compliance with the aforementioned measures shall be ensured by the City of Sacramento Community Development Department.

4.3-7(c) Consistent with SMAQMD’s GHG BMP-2, prior to the approval of project improvement plans, the applicant shall indicate that EV Ready parking spaces shall be installed throughout the project site at the ratio with which the current CalGreen Tier 2 standards require EV Capable spaces.

Compliance with this measure shall be ensured by the City of Sacramento Community Development Department.

4.3-7(d) Implement Mitigation Measure 4.12-3.

4.3-8 Result in a cumulatively considerable inefficient or wasteful use of energy or conflict with a State or local plan for renewable energy or energy efficiency. Based on the analysis below, the impact is less than significant.

The following discussion applies to the potential for both project components to result in a cumulatively considerable inefficient or wasteful use of energy, or conflict with a State or local plan for renewable energy or energy efficiency. In addition, the analysis includes evaluation of the proposed off-site improvements.

Industrial Park, Nonparticipating Parcels, and Off-Site Improvement Area
Impact 4.3-5 discusses the consumption of energy on a project level, within the context of existing State plans and regulations. As discussed previously, the project would involve consumption of diesel, gasoline, and electricity throughout construction and operations. However, all proposed structures would be built in compliance with existing statewide mandatory energy efficiency standards, such as those contained in the California Building Energy Efficiency Standards and the CALGreen Code. Compliance with the energy efficiency standards would reduce the amount of electricity consumed by the proposed development. State regulations would also help to reduce the amount of energy consumed by on-road vehicles over time. For instance, State and federal emissions standards and fuel economy standards result in increased fuel efficiency for on-road vehicles. Overall, as concluded above, the proposed project would result in a less-than-significant impact related to the inefficient or wasteful use of energy or conflicting with a State or local plan for renewable energy or energy efficiency.

Furthermore, a minimum of 184 EV charging stations would be required to be implemented within the project site, as required by the 2022 CBSC, which would help to further reduce transportation energy use associated with the proposed project.

Similar to the proposed project, all future development within the City of Sacramento would be required to comply with applicable State and local regulations related to energy efficiency. Increased efficiency would be ensured in the future as cumulative development occurs due to compliance with the State’s robust energy efficiency requirements. For example, pursuant to 2022 CBSC, new non-residential buildings Draft EIR
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associated with cumulative development would be required to be solar ready.

Furthermore, energy efficiency regulations have been getting progressively more stringent over time. Thus, as cumulative development occurs under the increasingly stringent regulations, the energy use associated with such cumulative development is anticipated to be increasingly energy efficient over time as well.

Based on the above, implementation of the project in combination with other cumulative development in the project region would not result in the wasteful or inefficient use of energy. Because the project would not conflict with a local plan to increase energy efficiency and reduce energy consumption, a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

4.4 BIOLOGICAL RESOURCES

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4.4.1 INTRODUCTION
This chapter of the EIR evaluates the biological resources known to occur or that could potentially occur within the project site and surrounding environs. The chapter describes the proposed project’s potential impacts to biological resources and identifies measures to eliminate or substantially reduce impacts to a less-than-significant level. Existing plant communities, wetlands, wildlife habitats, and potential for special-status species and communities are discussed for the project region. The information contained in the analysis is primarily based on a Biological Resources Assessment (BRA) (see Appendix E of this EIR)1 and Aquatic Resources Delineation (ARD) Report (see Appendix F of this EIR)2 prepared for the proposed project by Bargas Environmental Consulting (Bargas). Further information was sourced from the City of Sacramento 2040 General Plan,3 the City of Sacramento 2040 Master EIR (MEIR),4 and the Natomas Basin Habitat Conservation Plan (HCP).5
The project site, as defined by this EIR, consists of 474.4 acres located to the southeast of the intersection of Interstate 5 (I-5) and Power Line Road. The project site includes the industrial park footprint and several nonparticipating parcels that would not be developed as part of the proposed project, but would receive first-tier entitlements for future industrial uses and would be annexed into the City. In addition, a portion of right-of-way (ROW) under the jurisdiction of the California Department of Transportation (Caltrans) is within the project site.

As discussed further in the Method of Analysis subsection of this chapter, the entire 474.4-acre project site was evaluated at an appropriate level as part of the BRA.6 The BRA identifies the project site through the use of various terms (i.e., Biological Study Area [study area], Annexation Area, and Regional Study Area). The foregoing terms are applied to the project site within the BRA, based on the specific area of the site being discussed (see Figure 4.4-1). Further information on the terminology used in the BRA and the acreage surveyed as part of the BRA is provided in the Method of Analysis subsection below.

4.4.2 EXISTING ENVIRONMENTAL SETTING
The following sections describe the existing environmental setting and biological resources occurring in the proposed project region and project site. 1 Bargas Environmental Consulting. Biological Resources Assessment, Airport South Industrial Park, Sacramento County, California. January 2023. 2 Bargas Environmental Consulting. Aquatic Resources Delineation, Airport South Industrial Park, Sacramento County, California. September 2022. 3 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 4 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023. 5 The Natomas Basin Conservancy. Natomas Basin Habitat Conservation Plan. Revised 2003. 6 Note: All areas of the 474.4-acre project site were evaluated, as appropriate, based on the existing conditions of the site and whether the portion in question: (i) would be developed as part of the proposed project (the industrial park footprint), (ii) would only receive first-tier entitlements as part of annexation into the City limits (nonparticipating parcels), or (iii) would not be developed (Caltrans ROW).

4.4 BIOLOGICAL RESOURCES
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Figure 4.4-1
Study Areas
Note: All areas of the 474.4-acre project site were evaluated, as appropriate, based on the existing conditions of the site and whether the portion in question would be developed as part of the proposed project (the industrial park footprint), would only receive first-tier entitlements as part of annexation into the City limits (nonparticipating parcels), or would not be developed (Caltrans ROW).

Biological Evaluation Area Biological Survey Area
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Regional Setting
The project site is located southeast of the I-5/Power Line Road intersection, within the Natomas Basin, in a currently unincorporated portion of Sacramento County, California. The Natomas Basin is a low-lying area in the Sacramento Valley, located east of the Sacramento River and north of the river’s confluence with the American River. Of the 36,656 acres within the Natomas Basin, 23,820 are within the jurisdiction of unincorporated Sacramento County and 12,836 acres lie within the City of Sacramento.

Prior to modern reclamation efforts, drainage off the western slopes of the Sierra Nevada produced regular flooding and created the Natomas Basin as an area of highly fertile, alluvial sands. Early conditions within the basin consisted of various lakes, a large extent of riparian scrubshrub (e.g., willows), and a large expanse of dry-farmed open plain. However, since 1914, land reclamation and reclamation facilities, canals, levees, and pumping stations have resulted in the conversion of more than 80 percent of the Natomas Basin to agricultural production. A high proportion of the soils in the basin are underlain by impervious clay, which creates poor drainage conditions that favor irrigated rice farming – a regional agricultural use that has been prevalent since the 1940s.

The predominant crops produced in the Natomas Basin are rice, corn, grain, tomatoes, and pasture lands. The overall topography of the basin remains that of a shallow bowl, but the irregular small-scale topographic features of the original landscape have largely been eliminated by agriculture. The current drainage pattern of the basin has been altered so that stormwater runoff is pumped into the surrounding canals and the Sacramento River at several locations. Even with the pumping, portions of the basin are subject to shallow flooding from rainfall that cannot be conveyed quickly enough to external drainage systems. Natural and uncultivated vegetation types are interspersed throughout the agricultural areas of the basin. Natural vegetation is found primarily along irrigation canals, drainage ditches, pastures, and uncultivated fields. Borders of canals and ditches often have narrow strips of emergent vegetation (e.g., cattails and bulrushes) or wooded riparian areas. The presence of water conveyance systems among the mosaic of agricultural fields and riparian areas provides important nesting, feeding, and migration corridor habitat for a variety of wildlife species that inhabit the Natomas Basin.

Project Setting
The project site is bounded by I-5 to the north, a fire break along Lanfranco Circle to the east, the West Drainage Canal and an unpaved road to the south, and Power Line Road to the west, which is paved and features two vehicle lanes. Within the northern portion of the site, Bayou Way, a paved road consisting of two vehicle lanes, meanders in a west-to-east direction through the site.

The site was historically used as hay fields, with possible intermittent rice fields from 1937 until at least 2020. Currently, the site consists of vacant, fallow agricultural land. As of July 27, 2023, a portion of the site (Assessor’s Parcel Numbers 225-0030-023 and 225-0030-045) is within the Natomas Basin HCP permit area (see Figure 4.4-2).7
The project site, relatively flat, features a ground surface elevation approximately 17 feet above mean sea level (amsl). The lands within the site are currently devoid of structures and primarily composed of fallowed agricultural fields, with some undeveloped land present within and adjacent to the road and the I-5 ROW along the site’s northern boundary. 7 California Department of Fish and Wildlife. Response to Request for Revision pursuant to Section VI.L.3(2) of the 2003 Natomas Basin Habitat Conservation Plan (NBHCP) to clarify the City of Sacramento’s Permit Area Boundary. July 27, 2023.

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Figure 4.4-2
Natomas Basin Habitat Conservation Plan 2023 Permit Area Draft EIR
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As discussed further below, various vegetation communities occur on-site. In addition, unnamed drainage canals proceed through the site generally in a north-to-south direction in both the site’s western and eastern portions. Unimproved dirt roads provide access to the interior of the project site, which is subdivided into multiple agricultural plots. The site is surrounded by vacant fields to the north, across I-5, and west, active agricultural fields and the Paso Verde K-8 School to the south, and the Westlake Subdivision residential community to the east. Portions of the project site adjacent to I-5 have been previously disturbed as part of construction of the I-5/Metro Air Parkway interchange. Potential impacts to biological resources in such areas have already been mitigated by Caltrans and/or the Metro Air Park and would not require additional mitigation by the proposed project.

Terrestrial Plant Communities
According to the BRA, 11 habitat types exist within the study area, including perennial rye grass fields, upland mustards or star-thistle fields, developed/disturbed land covers, open water, unknown row crops, poison hemlock or fennel patches, Himalayan blackberry – rattlebox – edible fig riparian scrub, Goodding’s willow – red willow riparian woodland and forest, valley oak riparian forest woodland, hardstem and California bulrush marsh, and cattail marsh. The terrestrial land cover types in the study area are summarized below.

Perennial Rye Grass Fields
Perennial rye grass fields (Lolium perenne [now Festuca perennis], Herbaceous Semi-Natural Alliance) occur within the project site. Historic aerial imagery and field observations suggest the vegetation may be managed in the foregoing areas through mowing or shallow tilling for fire fuel abatement. The vegetation community was observed within two large fallowed agricultural fields, as well as in lower topographical roadside areas that receive sheet-flow stormwater runoff from roads, including areas to the west and east of the Metro Air Park north of I-5, and Ditch-2 (discussed further in the Aquatic Resources subsection). The dominant plant species observed in the foregonig areas was rye grass, with smaller amounts of the following species: perennial pepperweed (Lepidium latifolium), ripgut grass, little-seeded canary grass (Phalaris minor), and Johnson grass.

Upland Mustards or Star-Thistle Fields
Upland mustards or star-thistle fields (Brassica nigra – Centaurea [solstitialis, melitensis], Herbaceous Semi-Natural Alliance) occur within the project site. Historic aerial imagery and field observations suggest the vegetation may be managed through mowing or shallow tilling for fire fuel abatement. The vegetation community was observed within one large fallowed agricultural field and most roadside areas. The dominant plants species observed in the foregoing areas include black mustard, jointed charlock (Raphanus raphinastrum), little mallow (Malva parviflora), bristly oxtongue, and ripgut grass.

Developed/Disturbed
Developed/disturbed land cover occurs within the project site. Several paved roads transect the study area, including Power Line Road, Bayou Way, I-5, and an irrigation district access road.

Bayou Way transects the northern end of the project site and the southern end of Metro Air Parkway terminates at Bayou Way within the project site’s boundaries. A paved irrigation district access road also transects the northern end of the site along the south side of Ditch-2, between Bayou Way and I-5. The areas described above are best described as developed. In addition, the following areas are best described as disturbed: gravel road shoulders adjacent to paved roads, an unpaved farm road south of Canal-3 (discussed further in the Aquatic Resources subsection), Draft EIR
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a construction yard on the south side of Bayou Way to the west of Metro Air Park, and a fire break and unpaved fire road along the east side of the study area.

Open Water
Open water in the form of canals and ditches is found on portions of the project site. These areas include aquatic features Canal-1, Canal-2, Canal-3, and Ditch-2, which were mapped during the formal ARD. The four features were observed to be inundated and lacking significant amounts of living emergent vegetation during most of the surveys.

Unknown Row Crops
Unknown row crop land cover occurs on the agricultural field south of Canal-3 and adjacent to Power Line Road. The species being cultivated and plant species otherwise present within the field are unknown.

Poison Hemlock or Fennel Patches
Poison hemlock or fennel patches (Conium maculatum – Foeniculum vulgare, Herbaceous SemiNatural Alliance) are found within the project site. Historic aerial imagery and field observations suggest the vegetation in the foregoing areas may not be regularly managed for fire fuel abatement, due to their locations along the corners or edges of fields. The dominant plant species observed in the poison hemlock or fennel patches include poison hemlock, fennel, milk thistle, wild teasel (Dipsacus fullonum), little mallow, and ripgut.

Himalayan Blackberry – Rattlebox – Edible Fig Riparian Scrub Himalayan blackberry – rattlebox – edible fig riparian scrub (Rubus armeniacus - Sesbania punicea – Ficus carica, Shrubland Semi-Natural Alliance) is found on the project site. The community is present in large patches along Ditch-1 and along a smaller ditch just outside of the southeastern project site boundary. The vegetation patches are predominantly composed of Himalayan blackberry, with smaller amounts of the following species also observed: western poison oak (Toxicodendron diversilobum), edible fig (Ficus carica), wild teasel, poison hemlock, and fennel.

Goodding’s Willow – Red Willow Riparian Woodland and Forest Goodding’s willow – red willow riparian woodland and forest (Salix gooddingii – Salix laevigata, Forest and Woodland Alliance) can be found adjacent to the south bank of Canal-2, where the community turns east and follows parallel to Bayou Way, and along a ditch on the north side of Bayou Way. The trees are all of a single species, Goodding’s willow, and range in height from approximately 15 to 25 feet. Himalayan blackberry, common tule, tall flatsedge, curly dock, and Johnson grass are present in the understory along the ditch. Other parts of the understory are characterized by weedy species more typical of the perennial rye grass field, upland mustards and star-thistle fields, and poison hemlock or fennel patch communities previously discussed above.

Valley Oak Riparian Forest Woodland
Valley oak riparian forest woodland (Quercus lobata, Riparian Forest and Woodland Alliance) is present within and adjacent to both banks of Canal-2 where it meets Canal-3 on the southern side of the study area. Several small groves of trees are also present along both banks of Canal-3 to the west of Canal-2. The trees are all of a single species, Valley Oak (Quercus lobata), and range in height from approximately 15 to 40 feet tall. Many of the trees are rooted within the bank and are failing as the bank erodes into the canal. The understory is characterized by weedy species Draft EIR
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more typical of the Perennial Rye Grass Field, Upland Mustards and Star-thistle Field, and Poison Hemlock or Fennel Patch communities described in the sections above.

Hardstem and California Bullrush Marsh
Hardstem and California bulrush marsh (Schoenoplectus [acutus, californicus], Herbaceous Alliance) is found on the project site. The dominant plant species observed include common tule, tall flatsedge, curly dock, Johnson grass, and bristly ox-tongue. A few Fremont cottonwood (Populus fremonti) trees, ranging in height from approximately 15 to 30 feet, are present and rooted within or adjacent to Ditch-1 where the hardstem and California bulrush marsh community occurs.

Cattail Marsh
The southern portion of Ditch-1 widens just north of where the ditch discharges to the West Drainage Canal and contains two patches of cattail marsh (Typha [angustifolia, domingensis, latifolia], Herbaceous Alliance). The areas are dominated by cattail species (Typha sp.), with smaller amounts of common tule.

Sensitive Vegetation Communities
The California Department of Fish and Wildlife (CDFW) evaluates Natural Communities using NatureServe’s Heritage Methodology, which is the same system used to assign global and State rarity ranks for plant and animal species in the California Natural Diversity Database (CNDDB).

Threat scope (typically assessed within a 20-year timeframe for vegetation) and severity are used to calculate an overall threat score, which is added to the overall rarity score for a single rank of 1 through 5. Evaluation is done at both the global (full natural range within and outside of California) and State (within California) levels, resulting in a single global (G) and State (S) rank that ranges from 1 (very rare and threatened) to 5 (demonstrably secure). Natural Communities with ranks of S1 to S3 are considered Sensitive Natural Communities and must be addressed in the CEQA environmental review processes.

The following vegetation communities identified within the study area are designated by CDFW and the California Native Plant Society (CNPS) as Sensitive Natural Communities: Goodding’s willow – red willow riparian woodland and forest, valley oak riparian forest woodland, and hardstem and California bulrush marsh. Goodding’s willow – red willow riparian woodland and forest, as well as valley oak riparian forest woodland, are S3-ranked natural communities.

Hardstem and California bulrush marsh is an S3/S4-ranked natural community.

In addition, the following additional Sensitive Natural Communities have been identified within the Regional Study Area, beyond the boundaries of the project site:
 Great Valley Cottonwood Riparian Forest: The nearest occurrence as recorded in the CNDDB is more than four miles to the south of the study area along the Sacramento River.

The community is not present within the study area or overall project site, based on aerial photography and surveys.
 Northern Claypan Vernal Pool: The only CNDDB record for the community is four miles to the east of the study area along Dry Creek. The community is not present within the study area or overall project site, based on aerial photography and surveys.

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Aquatic Resources
Pursuant to the ARD, a total of 2.018 acres of potential jurisdictional tributary drainages and other waters of the U.S. were identified within the project site in accordance with the minimum standards set forth by the U.S. Army Corps of Engineers (USACE) South Pacific Division and Sacramento District Regulatory Program, as well as the Corps of Engineers Wetlands Delineation Manual, Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region, and A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States (see Figure 4.4-3).

The identified features are subject to the interpretation and verification of the USACE Sacramento District Regulatory Division. Table 4.4-1 summarizes the aquatic features, which are discussed further below.

Table 4.4-1
Aquatic Features Observed in the Project Site
Feature Name Area (acres) Length (linear feet)
Tributary Drainages
Canal-1 0.04 2,149
Canal-2 1.46 3,204
Canal-3 0.001 5,335
Subtotal 1.501 10,688
Other Waters
Ditch-1 0.19 2,278
Ditch-2 0.39 2,458
Subtotal 0.58 4,736
Overall Total 2.081 15,424
Source: Bargas Environmental Consulting, 2023.

Canal-1
Canal-1 is a north-south-oriented, manmade drainage canal that partially overlaps the project site’s western boundary. The canal’s origin can be traced on the U.S. Geological Survey (USGS) topographic map and the Reclamation District (RD) 1000 facilities map as beginning within the Sacramento International Airport grounds, approximately two to three miles northwest of the project site. Canal-1 is a direct tributary to Canal-3 (West Drainage Canal), directly connecting at the southwest corner of the project site. The feature conveys stormwater and irrigation runoff collected in various small ditches and stormwater infrastructure in the project vicinity.

Canal-2
Canal-2 is a named feature, the Lone Tree Canal, and is a north-south-oriented, manmade drainage canal that transects the eastern third of the proposed industrial park footprint. The canal’s origin can be traced on the USGS topographic map and the RD 1000 facilities map as beginning along Lone Tree Road, just north of West Elkhorn Boulevard, approximately two to three miles north of the industrial park footprint. Canal-2 is a direct tributary to Canal-3 (West Drainage Canal), directly connecting at the south boundary of the industrial park footprint. The feature conveys stormwater and irrigation runoff collected in various small ditches and stormwater infrastructure in the project vicinity.

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Figure 4.4-3
Aquatic Resources
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Canal-3
Canal-3 is a named feature, the West Drainage Canal, and is a west-east-oriented, manmade drainage canal that partially overlaps the south boundary of the industrial park footprint. The canal’s origin can be traced on the USGS topographic map and the RD 1000 facilities map as beginning along Elkhorn Boulevard east of Garden Highway, approximately three miles northwest of the industrial park footprint.

The canal receives water from several other smaller drainage canals that convey stormwater and irrigation runoff collected in various small ditches and stormwater infrastructure in the project vicinity. Flows are ultimately discharged to the Sacramento River in a controlled and managed way by way of several different pump stations.

Ditch-1
Ditch-1 is a north-south-oriented, manmade irrigation drainage ditch that transects the western third of the industrial park footprint, starting at Bayou Way on the canal’s northern terminus and discharges to Canal-3 (West Drainage Canal) on its south terminus. The feature conveys excess irrigation water and stormwater runoff from the adjacent agricultural fields to Canal-3.

Ditch-2
Ditch-2 is an east-west-oriented, manmade drainage ditch that transects the northern edge of the industrial park footprint. The ditch starts outside of the industrial park footprint on the north side of Bayou Way, across the road from Canal-2, passes through the industrial park footprint, then ultimately discharges to an extension of Canal-1 outside of the footprint. The feature conveys stormwater runoff from the adjacent roads and uplands within the Caltrans I-5 fee title ROW to Canal-1.

Special-Status Species
Special-status species are species that have been listed as threatened or endangered under the federal Endangered Species Act (FESA), California Endangered Species Act (CESA), or are of special concern to federal resource agencies, the State, or private conservation organizations. A species may be considered to have special status due to declining populations, vulnerability to habitat change, or restricted distributions. A general description of the criteria and laws pertaining to special-status classifications is described below. Special-status plant and wildlife species may meet one or more of the following criteria:
 Listed as threatened or endangered, or proposed or candidates for listing by the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS);  Listed as threatened or endangered and candidates for listing by the CDFW;  Identified as Fully Protected species or Species of Special Concern by CDFW;  Plant species considered to be rare, threatened, or endangered in California by the CNPS and CDFW (California Rare Plant Rank [CRPR] 1, 2, and 3):
o CRPR 1A: Plants presumed extinct.
o CRPR 1B: Plants rare, threatened, or endangered in California and elsewhere. o CRPR 2A: Plants extirpated in California, but common elsewhere. o CRPR 2B: Plants rare, threatened, or endangered in California, but more common elsewhere.
o CRPR 3: Plants about which the CNPS needs more information.

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Listed and Special-Status Plant Species
According to the records search conducted as part of the BRA, 20 special-status plant species have the potential to occur in the Regional Study Area. Biological conditions (i.e., vegetation communities, wildlife habitats, disturbances, etc.) and the habitat and life cycle requirements of special-status species identified for analysis in the records search were considered. Additionally, the BRA defined “recent” occurrences as species observed within the past 30 years. Based on such considerations, species were assigned to the following categories:
 Present: Species is known to occur in the project site, based on recent surveys, CNDDB records (within 30 years), or other records;
 High: Species with known recent recorded occurrences/populations near the project site and highly suitable habitat occurs within the project site. Highly suitable habitat includes all necessary elements to support the species (e.g., elevation, hydrology, soils, cover, habitat type, food resources);
 Moderate: Species with known recent recorded occurrences/populations near the project site; however, habitat within the project site has been moderately disturbed, fragmented, or is small in extent. Moderately suitable habitat includes several elements to support the species (e.g., elevation, hydrology, soils, cover, habitat type, food resources).

Furthermore, moderately suitable habitat may also be located at the edge of the species’ range, or occurrences have not been reported nearby;
 Low: Species with few known recent recorded occurrences/populations near the project site and habitat within the project site is highly disturbed or extremely limited. A low potential is assigned to annual or perennial plant species that may have been detectable during a focused survey in the appropriate blooming period but was not found; however, small populations or scattered individuals are still considered to have a low potential to occur. Additionally, species for which poor-quality habitat may support the species within the project site, but the reported extant range is far outside the study area and/or any species observations are anticipated to being migratory (i.e., not likely to reproduce within the study area); and
 Presumed Absent/No Potential: Focused surveys were conducted and the species was not detected, or the species was found in the literature review, but suitable habitat (soil, vegetation, elevational range) was not found in the project site or the project site is not within the known geographic range of the species.

Based on focused field surveys and literature review (detailed further in this chapter under the Method of Analysis subsection), the following six plant species were determined to have low potential for occurrence within the study area: pappose tarplant, Heckard’s pepper-grass, San Joaquin spearscale, woolly rose-mallow, palmate-bracted bird’s beak, and Sanford’s arrowhead.

Further details on all identified 20 plant species is provided in Table 4.4-2.

Listed and Special-Status Wildlife Species
According to the records search conducted as part of the BRA, 28 special-status wildlife species have the potential to occur in the Regional Study Area (see Table 4.4-2). Based on field observations and literature review (detailed further in this chapter under the Method of Analysis subsection), 12 of the 28 special-status wildlife species were determined to have the potential to occur within the project site. In accordance with the categories listed above for potential of occurrence, species that are considered present include giant garter snake, northwestern pond turtle, northern harrier, and Swainson’s hawk.

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Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Plants
Centromadia parryi ssp.
parryi
Pappose tarplant
-- CRPR 1B.2 No
Occurs in chaparral, coastal prairie, marshes and swamps, meadows and seeps, valley and foothill grassland at elevations ranging from sea level to 1,380 feet. Blooms from May to November.

Low. Habitat within the project site is considered low quality. The nearest records of the species are 8.5 miles to the southwest of the project site. Ongoing agriculture-related site disturbance limits the potential for species to occur.

Lepidium latipes var.
heckardii
Heckard’s pepper-grass
-- CRPR 1B.2 No
Occurs in valley and foothill grassland at elevations ranging from five to 655 feet. Blooms from March to May.

Low. Habitat within the project site is considered low quality. The nearest extant occurrence is 7.5 miles to the southwest of the project site. Ongoing agriculture-related site disturbance limits the potential for species to occur.

Extriplex joaquinana
San Joaquin spearscale -- CRPR 1B.2 No
Occurs in chenopod scrub, meadows and seeps, playas, and valley and foothill grassland at elevations ranging from five to 2,740 feet. Blooms from April to October.

Low. Habitat within the project site is considered low quality. The nearest records are 7.5 miles to the west of the project site. Ongoing agriculture-related site disturbance limits the potential for species to occur.

Hibiscus lasiocarpos var.
occidentalis
Woolly rose-mallow
-- CRPR 1B.2 No
Occurs in marshes and swamps at elevations ranging from sea level to 395 feet. Blooms from June to September.

Low. Habitat within the project site is considered low quality. The nearest record is at the margins of a canal. Ongoing agriculture-related site disturbance limits the potential for species to occur.

Chloropyron palmatum
Palmate-bracted bird’s
beak
FE CE, CRPR 1B.1 No
Occurs in chenopod scrub, as well as valley and foothill grassland, at elevations ranging from 15 to 510 feet. Blooms from May to October.

Low. Habitat within the project site is considered low quality. The nearest records are 7.5 miles to the west of the project site. Ongoing agriculture-related site disturbance limits the potential for species to occur. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Sagittaria sanfordii
Sanford’s arrowhead -- CRPR 1B.2 Yes
Occurs in marshes and swamps at elevations ranging from sea level to 2,135 feet. Blooms from May to October.

Low. Habitat within the project site is considered low quality. The species is known to occur along roadside ditches and canals; however, all records are to the east and southeast of the project site and appear to be at the edge or outside of the species’ distribution. Ongoing agriculture-related site disturbance limits the potential for species to occur.

Symphyotrichum lentum
Suisun marsh aster -- CRPR 1B.2 No
Occurs in marshes and swamps at elevations ranging from sea level to 10 feet. Blooms from May to November.

No potential. Habitat is not present within the project site.

Downingia pusilla
Dwarf downingia -- CRPR 2B.2 No
Occurs in valley and foothill grassland and vernal pools at elevations ranging from five to 1,460 feet. Blooms from March to May.

No potential. Habitat is not present within the project site.

Legenere limosa
Legenere -- CRPR 1B.1 Yes
Occurs in vernal pools at elevations ranging from five to 2,885 feet. Blooms from April to June.

No potential. Habitat is not present within the project site.

Atriplex cordulata var.
cordulata
Heartsacle
-- CRPR 1B.2 No
Occurs in chenopod scrub, meadows and seeps, and valley and foothill grassland at elevations ranging from sea level to 1,835 feet. Blooms from April to October.

No potential. Habitat is not present within the project site.

Atriplex depressa
Brittlescale -- CRPR 1B.2 No
Occurs in chenopod scrub, meadows and seeps, playas, valley and foothill grassland, and vernal pools at elevations ranging from five to 1,050 feet. Blooms from April to October.

No potential. Habitat is not present within the project site. (Continues on next page)
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Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Astragalus tener var.
ferrisiae
Ferris' milk-vetch
-- CRPR 1B.1 No
Meadows and seeps and valley and foothill grassland at elevations ranging from five to 245 feet. Blooms from April to May.

No potential. Habitat is not present within the project site.

Astragalus tener var.
tener
Alkali milk-vetch
-- CRPR 1B.2 No
Occurs in playas, valley and foothill grassland, and vernal pools at elevations ranging from five to 195 feet. Blooms from March to June.

No potential. Habitat is not present within the project site.

Lathyrus jepsonii var.
jepsonii
Delta tule pea
-- CRPR 1B.2 Yes
Occurs in marshes and swamps at elevations ranging from sea level to 15 feet. Blooms from May to July.

No potential. Habitat is not present within the project site.

Trifolium hydrophilum
Saline clover -- CRPR 1B.2 No
Occurs in marshes and swamps, valley and foothill grassland, and vernal pools at elevations ranging from sea level to 985 feet. Blooms from April to June.

No potential. Habitat is not present within the project site.

Gratiola heterosepala
Boggs Lake hedgehyssop -- CE, CRPR 1B.2 Yes
Occurs in marshes and swamps (lake margins), and vernal pools at elevations ranging from 35 to 7,790 feet. Blooms from April to August.

No potential. Habitat is not present within the project site.

Neostapfia colusana
Colusa grass FT CE, CRPR 1B.1 Yes Occurs in vernal pools at elevations ranging from 15 to 655 feet. Blooms from May to August. No potential. Habitat is not present within the project site.

Orcuttia tenuis
Slender Orcutt grass FT CE, CRPR 1B.1 Yes
Occurs in vernal pools at elevations ranging from 115 to 5,775 feet. Blooms from May to September.

No potential. Habitat is not present within the project site. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Orcuttia viscida
Sacramento Orcutt grass FE CE, CRPR 1B.1 Yes
Occurs in vernal pools at elevations ranging from 100 to 330 feet. Blooms from April to July.

No potential. Habitat is not present within the project site.

Puccinellia simplex
California alkali grass -- CRPR 1B.2 No
Occurs in chenopod scrub, meadows and seeps, valley and foothill grassland, and vernal pools at elevations ranging from five to 3,050 feet. Blooms from March to May.

No potential. Habitat is not present within the project site.

Invertebrates
Bombus crotchii
Crotch’s bumble bee -- CC No
Occurs in open grasslands and scrub habitats. This species occurs primarily in California, including the Mediterranean region, Pacific Coast, Western Desert, Great Valley, and adjacent foothills through most of southwestern California. The species was historically common in the Central Valley of California, but now appears to be absent from most of the region, especially in the center of its historic range.

No potential. The ongoing agriculturerelated site disturbance precludes suitable habitat to accommodate the species from occurring on-site. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Danaus plexippus
Monarch butterfly FC -- No
A migratory species that is most prevalent in the Central Valley in summer and early fall. Dependent upon milkweed (Asclepias species) plants as their exclusive larval host.

Low. Habitat within the project site is considered low quality. The nearest records are 38 miles to the southwest of the project site; however, as a migratory species with flight capability, the monarch butterfly has potential to occur anywhere during movements. Ongoing agriculture-related site disturbance and lack of suitable host plants limit the potential for species to occur.

Branchinecta lynchi
Vernal pool fairy shrimp FT -- Yes
Commonly observed in grass or mud-bottomed swales, earth sump, or basalt flow depression pools in unplowed grasslands.

No potential. Habitat is not present within the project site.

Branchinecta
mesovallensis
Midvalley fairy shrimp
-- -- Yes
Found in vernal pools, vernal swales, and ephemeral wetlands in the Central Valley.

No potential. Habitat is not present within the project site.

Lepidurus packardi
Vernal pool tadpole
shrimp
FE -- Yes
Inhabits vernal pools and swales containing clear to highly turbid water.

No potential. Habitat is not present within the project site.

Desmocerus californicus
dimorphus
Valley elderberry
longhorn beetle
FT -- Yes
Endemic to the Central Valley. Found only in association with the species’ host plant, the elderberry (Sambucus spp.)
No potential. Habitat is not present
within the project site.

Fish
Acipenser medirostris
Green Sturgeon –
Southern DPS
FT CSC No
Originate from coastal watersheds
south of the Eel River, with the only known spawning population in the Sacramento River. Adults begin spawning migrations in late February. Spawning occurs from March to July, with peak activity from mid-April to mid-June.

No potential. Habitat is not present
within the project site.
(Continues on next page)
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May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Oncorhynchus mykiss
irideus
Central Valley steelhead
DPS
FT -- No
Anadromous species requiring freshwater water courses with gravelly substrates for breeding. Originates below natural and manmade, impassable barriers from the Sacramento and San Joaquin rivers and their tributaries. The young remain in freshwater areas before migrating to estuarine and marine environments.

No potential. Habitat is not present within the project site.

Oncorhynchus
tshawytscha
Central Valley spring-run
chinook Salmon ESU
FT CT No
Adult Central Valley spring-run chinook salmon leave the ocean to begin their upstream migration in late January and early February and enter the Sacramento River between March and September, primarily in May and June. Spawning normally occurs between mid-August and early October, peaking in September.

No potential. Habitat is not present within the project site.

Oncorhynchus
tshawytscha
Sacramento River
winter-run chinook
Salmon ESU
FE CE No
Adult winter-run chinook salmon upstream spawning migration through the Sacramento/San Joaquin Delta (Delta) and into the lower Sacramento River occurs from December through July, with a peak during the period extending from January through April. Spawning occurs between late-April and mid-August, with a peak in June and July.

No potential. Habitat is not present within the project site. (Continues on next page)
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May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Hypomesus
transpacificus
Delta smelt
FT CE No
Endemic to California and occurs only in the San Francisco Estuary. The Delta Smelt life cycle follows the four seasons: spring spawning in freshwater, summer migration/rearing in the lowsalinity zone, fall maturation in the low-salinity zone, and winter upstream migration shortly before spawning.

No potential. Habitat is not present
within the project site.

Spirinchus thaleichthys
Longfin smelt FC CT No
In California, longfin smelt has been historically found in the San Francisco Estuary and the Delta, Humboldt Bay, and the estuaries of the Eel River and Klamath River. Spawning occurs from November through May, with a peak from February through April.

No potential. Habitat is not present within the project site.

Pogonichthys
macrolepidotus
Sacramento splittail
-- CSC No
Splittail depend both on brackishwater rearing habitats in the San Francisco Estuary and on floodplain and river-edge spawning habitats immediately above the estuary. Most migrate between the two habitat types on a near annual basis. The Sacramento splittail is endemic to the Central Valley.

No potential. Habitat is not present within the project site. (Continues on next page)
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Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Amphibians
Rana draytonii
California red-legged
frog
FT CSC No
Occurs along the Coast Ranges
from Mendocino County towards the south and in portions of the Sierra Nevada and Cascades ranges, usually below 3936 feet. Breeds in permanent to semipermanent aquatic habitats including lakes, ponds, marshes, creeks, and other drainages.

No potential. Habitat is not present within the project site.

Spea hammondii
Western spadefoot toad -- CSC Yes
Ranges throughout the Central
Valley and adjacent foothills. Occurs primarily in grasslands, but occasional populations also occur in valley-foothill hardwood woodlands. Elevations of occurrence extend from near sea level to 4460 feet in the southern Sierra Nevada foothills.

No potential. Habitat is not present within the project site.

Ambystoma
californiense
California tiger
salamander
FE CE Yes
Commonly found in annual
grassland habitat, but also occurs in the grassy understory of valley foothill hardwood habitats, and uncommonly along stream courses in valley foothill riparian habitats. The species occurs from near Petaluma, east through the Central Valley to Yolo and Sacramento counties and south to Tulare County; and from the vicinity of San Francisco Bay south to Santa Barbara County. Occurs at elevations to 3,200 feet.

No potential. Habitat is not present within the project site. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Reptiles
Thamnophis gigas
Giant garter snake FT CT Yes
Historically ranged in the Sacramento and San Joaquin valleys. Current range is much reduced and apparently extirpated south of Fresno County, except for western Kern County. Primarily associated with marshes and sloughs, less with slow-moving creeks, and absent from larger rivers. Active from mid-March until October.

Assumed Present. Habitat within the project site is considered medium quality. Several CNDDB records within the past 20 years document the presence of giant garter snake in the West Drainage Canal. Habitat in the project site is unlikely to support a permanent population, due to the lack of suitable burrows and high levels of vegetation management. However, the marginal habitat provides connectivity to occupied sites to the north and south of the project site.

Actinemys marmorata
Northwestern pond turtle -- CSC Yes
Associated with permanent or nearly permanent water in a wide variety of habitat types. Uncommon to common in suitable aquatic habitat throughout California, west of the SierraCascade crest and absent from desert regions, except in the Mojave Desert along the Mojave River and its tributaries. Elevation range extends from near sea level to 4,690 feet.

Present. Habitat within the project site is considered medium quality. The species was detected during three field surveys in Canal-2 and Canal-3 within the project site. Individuals were observed sunning on floating debris and/or vegetation within the canals. Adjacent upland habitats are marginal for the species. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Birds
Circus hudsonius
Northern harrier -- CSC No
Occurs from annual grassland up
to lodgepole pine and alpine meadow habitats, as high as 10,000 feet. Breeds from sea level to 5,700 feet in the Central Valley and Sierra Nevada, and up to 3,600 feet in northeastern California. Frequents meadows, grasslands, open rangelands, desert sinks, and fresh and saltwater emergent wetlands. Seldomly found in wooded areas.

Present. Habitat within the project site is considered high quality. Northern harrier was observed foraging on and flying over the proposed industrial park footprint of the project site during two field surveys.

Buteo swainsoni
Swainson's hawk -- CT Yes
Breeds in stands with few trees in
juniper-sage flats, riparian areas, and in oak savannah in the Central Valley. Forages in adjacent grasslands or suitable grain or alfalfa fields, or livestock pastures.

Present. Foraging habitat within the project site is considered high quality. Swainson’s hawk was observed during April and May field surveys. Nesting activity was not detected. Nesting habitat is limited in the project site.

Elanus leucurus
White-tailed kite -- CFP No
Common to uncommon, yearlong
resident in coastal and valley lowlands. Rarely found away from agricultural areas. Inhabits herbaceous and open stages of most habitats, mostly in cismontane California.

High. Habitat within the project site is considered high quality. The industrial park footprint of the project site contains foraging habitat that could support the species; however, nesting habitat is limited and composed of the relatively few Goodding’s black willow, valley oak, and other trees along the canal and ditch banks. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Athene cunicularia
Burrowing owl -- CSC Yes
A yearlong resident of open, dry
grassland and desert habitats, and in grass, forb and open shrub stages of pinyon-juniper and ponderosa pine habitats.

Moderate. Habitat within the project site is considered high quality. Most regional records are east of State Route (SR) 99. However, recent CNDDB records document the species as having occurred within the vicinity of the Sacramento International Airport. The project site contains some open disturbed areas that provide marginal habitat; however, existing suitable burrows and ground squirrels were not observed.

Branta hutchinsii
leucopareia
Aleutian cackling goose
-- -- Yes
Preferred habitats include
lacustrine, fresh emergent wetlands, and moist grasslands, croplands, pastures, and meadows. The species occurs mainly in the foregoing habitats during winter in Del Norte County, the San Francisco Bay-Delta, and southern Central Valley.

Low. Habitat within the project site is considered low quality. The nearest record is 28 miles to the north of the project site. The species has not been recorded within the Natomas Basin. Sometimes occurs with more numerous Canada Geese, which will often feed in agricultural fields, especially during winter months.

Plegadis chihi
White-faced ibis -- -- Yes
Uncommon summer resident in
sections of Southern California. Rare visitor in the Central Valley and more widespread in migration. Prefers to feed in fresh emergent wetland, shallow lacustrine waters, muddy ground of wet meadows, and irrigated or flooded pastures and croplands. Nests in dense, fresh emergent wetland.

Low. Habitat within the project site is considered low quality. The nearest records are eight miles to the west of the project site. Has potential to be observed on the industrial park footprint of the project site at the margins of canals or adjacent agricultural areas for foraging. Nesting habitat does not occur. (Continues on next page)
Draft EIR
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May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Lanius ludovicianus
Loggerhead shrike -- CSC Yes
Common resident and winter
visitor in lowlands and foothills throughout California. Prefers open habitats with scattered shrubs, trees, posts, fences, utility lines, or other perches. Highest density occurs in open-canopied valley foothill hardwood, valley foothill hardwood-conifer, valley foothill riparian, pinyon-juniper, juniper, desert riparian, and Joshua Tree habitats.

Low. Habitat within the project site is considered low quality. The nearest records are more than 50 miles from the project site. Occurs sparingly in the Natomas Basin. Unlikely to be present on the industrial park footprint of the project site due to lack of scrubby habitat, which is normally present in preferred areas.

Melospiza melodia
Song sparrow "Modesto"
population
-- CSC No
Avoids higher mountains and
occurs only locally in southern deserts. In winter, most leave montane habitats; more abundant and widespread than in lowlands and deserts. Prefers riparian, fresh or saline emergent wetland, and wet meadow habitats. Breeds in riparian thickets of willows, other shrubs, vines, tall herbs, and in fresh or saline emergent vegetation.

Low. Habitat within the project site is considered low quality. This resident form of the song sparrow has been recorded in sparsely vegetated margins of canals, such as those bordering the industrial park footprint of the project site, which contains limited habitat that could support nesting.

Agelaius tricolor
Tricolored blackbird -- CT, CSC Yes
Occurs locally throughout Central
Valley and in coastal districts. Breeds near freshwater, preferably in emergent wetland with tall, dense cattails or tules, but also in thickets of willow, blackberry, wild rose, and tall herbs. Feeds in grassland and cropland habitats. Breeds locally in northeastern California.

Low. Habitat within the project site is considered low quality. Appropriate breeding habitat is not present; however, the species will often forage in agricultural fields, especially in winter. (Continues on next page)
Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Table 4.4-2
Special-Status Species with Potential to Occur Within the Project Site Scientific Name
(Common Name)
Federal
Status
State
Status
HCP Covered
Species Habitat Requirements Potential for Occurrence
Vireo bellii pusillus
Least Bell's vireo FE CE No
Winter in southern Baja California, Mexico, where they occupy a variety of habitats, including mesquite scrub within arroyos, palm groves, and hedgerows bordering agricultural and residential areas. The birds generally arrive in southern California breeding areas by midMarch to early April, with males arriving before females. Generally remains on the breeding grounds until late September, although some post-breeding migration may begin as early as late July.

No potential. Habitat is not present within the project site.

Riparia riparia
Bank swallow -- CT Yes
Found primarily in riparian and other lowland habitats in California west of the deserts during the spring-fall period. In summer, restricted to riparian, lacustrine, and coastal areas with vertical banks, bluffs, and cliffs with fine-textured or sandy soils.

No potential. Habitat is not present within the project site.

Status Codes:

CC: CDFW Candidate for Listing CT: CDFW Threatened CE: CDFW Endangered FE: Federally Endangered CFP: CDFW Fully Protected FT: Federally Threatened CRPR: California Rare Plant Rank CSC: CDFW Species of Concern Source: Bargas Environmental Consulting, 2023.

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May 2024
Chapter 4.4 – Biological Resources

Species that are considered to have high potential to occur include white-tailed kite. Species that are considered to have moderate potential to occur include burrowing owl. Species that are considered to have low potential to occur include monarch butterfly, cackling goose, white-faced ibis, loggerhead shrike, song sparrow “Modesto” population, and tricolored blackbird.

As discussed further in Section 4.4.4, Impacts and Mitigation Measures, of this chapter, the requisite habitat to support special-status wildlife species with low potential to occur on-site is not available at such a level to accommodate said species. Thus, the following discussions provide further details of only the six special-status wildlife species that are either present or have moderate to high potential of occurring on-site.

Giant Garter Snake
Giant garter snake (Thamnophis gigas) is federally and State-listed as threatened and is a Covered Species under the Natomas Basin HCP. The giant garter snake is an endemic species of wetlands in the Central Valley. Historically, the species was found from the Butte County vicinity to southward towards Bakersfield in Kern County. Currently, populations are found in the Sacramento Valley and in isolated pockets of the San Joaquin Valley. The giant garter snake forages in marshes, low-gradient open waterways, and flooded rice fields, and hibernates in canal berms and other uplands.

Giant garter snake was not observed during the field surveys conducted as part of the BRA.

However, the CNDDB includes several occurrences of the species within the past 20 years, where the reptile has been documented in the West Drainage Canal in the project vicinity. The West Drainage Canal is hydrologically connected to Fisherman’s Lake, located approximately 0.5-mile south of the proposed industrial park footprint of the project site and where a known population of giant garter snake occurs. Habitat within the on-site canals for the species is best described as marginal, containing some of elements required by the species and capable of supporting transient individuals. Based on the above, giant garter snake is assumed to be present within the project site.

Northwestern Pond Turtle
Northwestern pond turtle (Actinemys marmorata) is not federally or State-listed. The species is designated as a California Species of Special Concern and is a Covered Species under the Natomas Basin HCP. The species is uncommon to common in suitable aquatic habitat throughout California, west of the Sierra-Cascade crest, and absent from desert regions, except in the Mojave Desert along the Mojave River and its tributaries. Northwestern pond turtle occurs at elevations ranging from near sea level to 4,690 feet amsl. The species lives in permanent bodies of water, requires floating vegetation, logs, rocks, or banks for basking, and hibernates and lays eggs in upland areas.

Northwestern pond turtle was observed during three field surveys conducted as part of the BRA in Canal-2 and Canal-3 within the project site. Adjacent upland habitats are marginal for the species, as much of the canal banks are vertical and undercut. In addition, the top of the canal banks are highly compacted and show evidence of repeated mowing and grading along many reaches. Based on the above, northwestern pond turtle is considered present within the project site.

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May 2024
Chapter 4.4 – Biological Resources

Northern Harrier
Northern harrier (Circus hudsonius) is not federally or State-listed. The species is designated as a California Species of Special Concern. The species breeds at elevations ranging from sea level to 5,700 feet above mean sea level in the Central Valley and the Sierra Nevada, and up to 3,600 feet in northeastern California. Northern harrier frequents meadows, grasslands, open rangelands, desert sinks, fresh and saltwater emergent wetlands. The species is seldom found in wooded areas. The northern harrier is a permanent resident of the northeastern plateau and coastal areas, but is less common in the Central Valley.

Northern harrier was observed foraging on and flying over the proposed industrial park footprint of the project site during two field surveys conducted as part of the BRA. In addition, the foraging habitat within the project site is considered high quality. Based on the above, northern harrier is considered present within the project site.

Swainson’s Hawk
Swainson’s hawk (Buteo swainsoni) is State-listed as threatened and is a Covered Species under the Natomas Basin HCP. The Swainson’s hawk breeds in stands with few trees in juniper-sage flats, riparian areas, and in oak savannah in the Central Valley. The species forages in adjacent grasslands or suitable grain or alfalfa fields, or livestock pastures. Swainson’ hawk was formerly abundant in California, with wider breeding range; however, the species’ decline occurred, in part, from loss of nesting habitat.

Swainson’s hawk was observed during the April and May field surveys conducted as part of the BRA. In addition, foraging habitat within the project site is considered high quality. Based on the above, Swainson’s hawk is considered present within the project site.

White-Tailed Kite
White-tailed kite (Elanus leucurus) is a CDFW Fully Protected species. White-tailed kite is a common-to-uncommon, yearlong resident in coastal and valley lowlands and rarely found away from agricultural areas. The species inhabits herbaceous and open stages of most habitats, mostly in cismontane California. White-tailed kite has extended its range and increased its numbers in recent decades.

The proposed industrial park footprint of the project site contains foraging habitat that could support white-tailed kite; however, nesting habitat is limited and composed of the relatively few Goodding’s black willow, valley oak, and other trees along the canal and ditch banks. Overall, foraging habitat within the project site is considered high quality. Based on the above, white-tailed kite is considered to have high potential for occurrence within the project site.

Burrowing Owl
Burrowing owl (Athene cunicularia) is not federally or State-listed. The species is designated as a California Species of Special Concern and is a Covered Species under the Natomas Basin HCP. Burrowing owl is a yearlong resident of open, dry grassland and desert habitats, as well as grass, forb, and open shrub stages of pinyon-juniper and ponderosa pine habitats. The species was previously common in appropriate habitats throughout the State, excluding the humid northwest coastal forests and high mountains. The species typically uses burrows created by fossorial mammals, most notably the California ground squirrel, but may also use manmade structures such as culverts; cement, asphalt, or wood debris piles; or openings beneath cement or asphalt pavement. The species’ breeding season extends from February through August.

Draft EIR
Airport South Industrial Project
May 2024
Chapter 4.4 – Biological Resources

Most regional records are east of SR 99. However, recent CNDDB records document the species as having occurred within the vicinity of the Sacramento International Airport. The project site contains some open disturbed areas that provide marginal habitat; however, existing suitable burrows and ground squirrels were not observed. Based on the above, burrowing owl is considered to have moderate potential for occurrence within the project site.

Trees
A preliminary tree survey was conducted by Raney Planning and Management, Inc. (Raney) on May 10, 2023 of the project site to identify on-site trees. As shown in Figure 4.4-4, the site contains 11 trees within the industrial park footprint, as well as a cluster of seven trees along the southern boundary of Parcel 5, which is contiguous with Parcel 8, a nonparticipating parcel that could be developed with future industrial uses. Additional trees are located within the boundaries of various nonparticipating parcels. The trees are identified as follows:

1. One willow;

2. Seven willows;

3. Two cottonwoods;

4. One cottonwood; and

5. Seven-tree cluster of Goodding’s willow – red willow riparian woodland south of Parcel 5 boundary.

As detailed further in Section 4.3.3, Regulatory Context, of this chapter, removal of protected trees, as defined by the City of Sacramento Tree Ordinance set forth in Sacramento City Code Chapter 12.56, requires issuance of a Tree Permit.

4.4.3 REGULATORY CONTEXT
A number of federal, State, and local policies provide the regulatory framework that guides the protection of biological resources. The following discussion summarizes those laws that are most relevant to biological resources in the vicinity of the project site.

Federal Regulations
The following are the federal environmental laws and policies relevant to biological resources.

Federal Endangered Species Act
The U.S. Congress passed the FESA in 1973 to protect species that are endangered or threatened with extinction. FESA is intended to operate in conjunction with the National Environmental Policy Act (NEPA) to help protect the ecosystems upon which endangered and threatened species depend. Under the FESA, the Secretary of the Interior and the Secretary of Commerce have joint authority to list a species as threatened or endangered (16 U.S. Code [USC] Section 1533[c]). Two federal agencies oversee the FESA: the USFWS has jurisdiction over plants, wildlife, and resident fish, while the NMFS has jurisdiction over anadromous fish and marine fish and mammals. Section 7 of the FESA mandates that federal agencies consult with the USFWS and/or NMFS to ensure that federal agency actions do not jeopardize the continued existence of a listed species or destroy or adversely modify critical habitat for listed species.

FESA prohibits the “take” of endangered or threatened wildlife species. “Take” is defined to include harassing, harming, pursuing, hunting, shooting, wounding, killing, trapping, capturing, or collecting wildlife species or any attempt to engage in such conduct (FESA Section 3 [3], [19]).

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Figure 4.4-4
Tree Locations Within the Project Site
Legend

1. One willow 2. Seven willows 3. Two cottonwoods 4. One cottonwood 5. Seven-tree cluster of Goodding’s willow – red willow riparian woodland south of Parcel 5 boundary
Project Site Boundaries
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Harm is further defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns (50 Code of Federal Regulations [CFR] Section 17.3). Harass is defined as actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns (50 CFR Section 17.3). Absent authorization from USFWS, actions that result in take can result in civil or criminal penalties.

For federally listed species covered under the Natomas Basin HCP, the Biological Opinion issued by the USFWS provides take coverage for covered projects that may impact federally listed species that are Covered Species under the Natomas Basin HCP. Further consultation is not required as long as the covered project complies with the applicable Natomas Basin HCP requirements. For federally listed species that are not Covered Species, FESA consultation with USFWS or the NMFS would be initiated if development resulted in take of a threatened or endangered species or if issuance of a Section 404 permit or other federal agency action could result in take of an endangered species not covered under the Natomas Basin HCP or adversely modify critical habitat of such a species.

Migratory Bird Treaty Act
Raptors (birds of prey), migratory birds, and other avian species are protected by a number of State and federal laws. The federal Migratory Bird Treaty Act (MBTA) prohibits the killing, possessing, or trading of migratory birds except in accordance with regulations prescribed by the Secretary of Interior.

Clean Water Act
The USACE regulates discharge of dredged or fill material into waters of the U.S. under Section 404 of the Clean Water Act (CWA). “Discharge of fill material” is defined as the addition of fill material into waters of the U.S., including, but not limited to, the following: placement of fill that is necessary for the construction of any structure, or impoundment requiring rock, sand, dirt, or other material for the construction; site-development fills for recreational, industrial, commercial, residential, and other uses; causeways or road fills; and fill for intake and outfall pipes and subaqueous utility lines (33 CFR Section 328.2[f]). In addition, Section 401 of the CWA (Title 33 USC, Section 1341) requires any applicant for a federal license or permit to conduct any activity that may result in a discharge of a pollutant into waters of the U.S. to obtain a certification that the discharge would comply with the applicable effluent limitations and water quality standards.

Waters of the U.S. include a range of wet environments such as lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, and wet meadows. Wetlands are defined as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support and under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR Section 328.3[b]).

Furthermore, jurisdictional waters of the U.S. can be defined by exhibiting a defined bed and bank and OHWM. The OHWM is defined by the USACE as “that line on shore established by the fluctuations of water and indicated by physical character of the soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas” (33 CFR Section 328.3[e]).

In addition to discharge of dredged or fill material into waters of the U.S. under Section 404, the CWA regulates municipal and industrial discharges to surface waters of the U.S through the Draft EIR
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National Pollutant Discharge Elimination System (NPDES) permit system, which is discussed in detail in Chapter 4.8, Hydrology and Water Quality, of this EIR.

State Regulations
The following are the State environmental laws and policies relevant to biological resources.

California Department of Fish and Wildlife
CDFW administers a number of laws and programs designed to protect fish and wildlife resources under the California Fish and Game Code (CFGC), such as CESA (CFGC Section 2050, et seq.), Fully Protected Species (CFGC Section 3511) and the Lake or Streambed Alteration Agreement (LSAA) Program (CFGC Sections 1600 to 1616). Such regulations are summarized in the following sections.

California Endangered Species Act
The State of California enacted CESA in 1984. CESA is similar to the FESA but pertains to Statelisted endangered and threatened species. CESA requires State agencies to consult with CDFW when preparing CEQA documents to ensure that the State lead agency actions do not jeopardize the existence of listed species. CESA directs agencies to consult with CDFW on projects or actions that could affect listed species, directs CDFW to determine whether jeopardy would occur, and allows CDFW to identify “reasonable and prudent alternatives” to the project consistent with conserving the species.

As with FESA, for covered projects that may impact State-listed species under CESA that are also Covered Species under the Natomas Basin HCP, direct consultation with CDFW for Statelisted take authorization is not required as long as the covered project complies with the applicable HCP requirements. For projects that may result in take of State-listed species that are not Natomas Basin HCP Covered Species, CESA directs agencies to consult with CDFW on projects or actions that could affect listed species, directs CDFW to determine whether jeopardy would occur, and allows CDFW to identify “reasonable and prudent alternatives” to the project consistent with conserving the species. CESA allows CDFW to authorize exceptions to the State’s prohibition against take of a listed species if the "take" of a listed species is incidental to carrying out an otherwise lawful activity and the impacts of the taking are minimized and fully mitigated (CFGC Section 2081).

California Fish and Game Codes
A number of species have been designated “fully protected” species under Sections 5515, 5050, 3511, and 4700 of the CFGC, but are not listed as endangered (Section 2062) or threatened (Section 2067) species under CESA. Except for take related to scientific research, all take of fully protected species is prohibited. The CFGC defines take as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.”
Birds of prey are protected in California under provisions of the CFGC Section 3503.5 (1992), which states, “it is unlawful to take, possess, or destroy any birds in the order Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto.” Construction disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “taking” by CDFW.

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Lake or Streambed Alteration Program
The CDFW is responsible for conserving, protecting, and managing California’s fish, wildlife, and native plant resources. To meet this responsibility, the CFGC Section 1602 requires notification to CDFW of any proposed activity that may substantially modify a river, stream, or lake.

Notification is required by any person, business, State or local government agency, or public utility that proposes an activity that would:
 substantially divert or obstruct the natural flow of any river, stream or lake;  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.

For the purposes of Section 1602, rivers, streams, and lakes must flow at least intermittently through a bed or channel.8 If notification is required and CDFW believes the proposed activity is likely to result in harm to the natural environment, the CDFW requires that the parties enter into a LSAA.

CDFW Species of Special Concern
In addition to formal listings under FESA and CESA, plant and wildlife species receive additional consideration during the CEQA process. Species that may be considered for review are included on a list of “Species of Special Concern” developed by CDFW. Species whose numbers, reproductive success, or habitat may be threatened are tracked by CDFW in California.

Native Plant Protection Act
The Native Plant Protection Act (NPPA) was enacted in 1977 and allows the Fish and Game Commission to designate plants as rare or endangered. Currently 64 species, subspecies, and varieties of plants that are protected as rare under the NPPA. The NPPA prohibits take of endangered or rare native plants, but includes some exceptions for agricultural and nursery operations, emergencies, and after properly notifying CDFW for vegetation removal from canals, roads, and other sites, changes in land use, and in certain other situations.

Regional Water Quality Control Board
Any action requiring a CWA Section 404 permit, or a Rivers and Harbors Act Section 10 permit, must also obtain a CWA Section 401 Water Quality Certification (WQC). The State of California WQC Program was formally initiated by the State Water Resources Control Board (SWRCB) in 1990 under the requirements stipulated by Section 401 of the federal CWA. Although the CWA is a federal law, Section 401 of the CWA recognizes that states have the primary authority and responsibility for setting water quality standards. In California, under Section 401, the SWRCB and Regional Water Quality Control Boards (RWQCBs) are the authorities that certify that issuance of a federal license or permit does not violate California’s water quality standards (i.e., that they do not violate Porter-Cologne and the Water Code). The WQC Program currently issues the WQC for discharges requiring USACE’s permits for fill and dredge discharges within waters of the U.S., and also implements the State's wetland protection and hydromodification regulation program under the Porter Cologne Water Quality Control Act. 8 CFGC Section 1602 also applies to ephemeral flow.

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On April 2, 2019, the SWRCB adopted a State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (Procedures), for inclusion in the forthcoming Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California Plan. The Procedures consist of four major elements: (1) a wetland definition; (2) a framework for determining if a feature that meets the wetland definition is a water of the State; (3) wetland delineation procedures; and (4) procedures for the submittal, review, and approval of applications for WQCs and Waste Discharge Requirements (WDR) for dredge or fill activities. The State Office of Administrative Law (OAL) approved the Procedures on August 28, 2019, and the Procedures became effective May 28, 2020.

Under the Procedures and the State Water Code (Water Code Section 13050[e]), “waters of the State” are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state.” Unless excluded by the Procedures, any activity that could result in discharge of dredged or fill material to waters of the State, which includes waters of the U.S. and non-federal waters of the State, requires filing of an application under the Procedures.

The Porter-Cologne Water Quality Control Act (Porter-Cologne Act, Water Code Section 13000, et seq.) is California’s statutory authority for the protection of water quality in conjunction with the federal CWA. The Porter-Cologne Act requires the SWRCB and RWQCBs under the CWA to adopt and periodically update water quality control plans, or basin plans. Basin plans are plans in which beneficial uses, water quality objectives, and implementation programs are established for each of the nine regions in California. The Porter-Cologne Act also requires dischargers of pollutants or dredged or fill material to notify the RWQCBs of such activities by filing Reports of Waste Discharge and authorizes the SWRCB and RWQCBs to issue and enforce waste discharge requirements, NPDES permits, Section 401 water quality certifications, or other approvals.

Local Regulations
The following are the local environmental laws and policies relevant to biological resources.

City of Sacramento 2040 General Plan
The following goals and policies from the City of Sacramento 2040 General Plan related to biological resources are applicable to the proposed project.

Environmental Resources and Constraints Element
Goal ERC-2 Thriving rivers, wildlife, and natural open spaces that contribute to public health, livability, and protection of the environment for future generations.

Policy ERC-2.1 Conservation of Water Resources in Open Space Areas.

The City shall continue to preserve, protect, and provide appropriate access to designated open space areas along the American and Sacramento Rivers, floodways, and
undevelopable floodplains, provided access would not disturb sensitive habitats or species, and shall support efforts to conserve and, where feasible, create or restore areas that provide important water quality and habitat benefits such as creeks, riparian corridors, buffer zones, wetlands, open space areas, levees, and drainage canals for the purpose of protecting Draft EIR
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water resources and habitats in the city’s watersheds, creeks, and the Sacramento and American Rivers.

Policy ERC-2.2 Biological Resources. The City shall ensure that adverse impacts on sensitive biological resources, including specialstatus species, sensitive natural communities, sensitive habitat, and wetlands are avoided, minimized, or mitigated to the greatest extent feasible as development takes place.

Policy ERC-2.3 Onsite Preservation. The City shall encourage new development to preserve and restore on-site natural elements that contribute to the community’s native plant and wildlife species value. For sites that lack existing natural elements, encourage planting of native species in preserved areas to establish or re-establish these values and aesthetic character.

Policy ERC-2.6 Wetland Protection. The City shall preserve and protect wetland resources including creeks, rivers, ponds, marshes, vernal pools, and other seasonal wetlands, to the extent feasible. If not feasible, the mitigation of all adverse impacts on wetland resources shall be required in compliance with State and Federal regulations protecting wetland resources, and if applicable, threatened or endangered species. Additionally, the City shall require either on- or off-site permanent preservation of an equivalent amount of wetland habitat to ensure no-netloss of value and/or function.

Policy ERC-2.7 Annual Grasslands. The City shall preserve and protect native grasslands and vernal pools that provide habitat for rare and endangered species. If not feasible, the mitigation of all adverse impacts on annual grasslands shall comply with State and Federal regulations protecting foraging habitat for those species known to utilize this habitat.

Policy ERC-2.8 Wildlife Corridors. The City shall preserve, protect, and avoid impacts to natural, undisturbed habitats that provides
movement corridors for sensitive wildlife species. If corridors are adversely affected, damaged habitat shall be replaced with habitat of equivalent value or enhanced to enable the continued movement of species.

Policy ERC-2.9 Habitat Assessments. The City shall consider the potential impact on sensitive plants and wildlife for each project requiring discretionary approval. If site conditions are such that potential habitat for sensitive plant and/or wildlife species may be present, the City shall require habitat assessments, prepared by a qualified biologist, for sensitive plant and wildlife species. If the habitat assessment determines that suitable habitat for sensitive plant and/or wildlife species is present, then either:

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1. Protocol-level surveys shall be conducted (where survey protocol has been established by a resource agency),
or, in the absence of established survey protocol, a
focused survey shall be conducted consistent with
industry-recognized best practices; or

2. Suitable habitat and presence of the species shall be assumed to occur within all potential habitat locations identified on the project site. Survey Reports shall be prepared and submitted to the City and the California
Department of Fish and Wildlife (CDFW) or the United
States Fish and Wildlife Service (USFWS) (depending
on the species) for further consultation and development of avoidance and/or mitigation measures consistent with state and federal law.

Policy ERC-2.10 Agency Coordination. The City shall coordinate with State and Federal resource agencies (e.g., California Department of Fish and Wildlife (CDFW), U.S. Army Corps of Engineers, and
United States Fish and Wildlife Service (USFWS) to protect areas containing rare or endangered species of plants and animals.

Policy ERC-2.11 Natomas Basin Habitat Conservation Plan. The City shall continue to participate in and support the policies of the Natomas Basin Habitat Conservation Plan for the protection of biological resources in the Natomas Basin.

Policy ERC-2.12 Support Habitat Conservation Plan Efforts. The City shall encourage and support regional habitat conservation planning efforts to conserve and manage habitat for special status species. New or amended Habitat Conservation Plans should provide a robust adaptive management component sufficient to ensure that habitat preserves are resilient to climate change effects/impacts and to ensure their mitigation value over time.

Provisions should include, but are not limited to: greater habitat ranges and diversity; corridors and transition zones to accommodate retreat or spatial shifts in natural areas; redundant water supply; elevated topography to accommodate extreme flooding; and flexible management and fee structure.

Policy ERC-2.13 Climate Change-related Habitat Shifts. The City shall support the efforts of The Natomas Basin Conservancy and other
habitat preserve managers to adaptively manage wildlife preserves to ensure adequate connectivity, habitat range, and diversity of topographic and climatic conditions are provided for species to move as climate shifts.

Policy ERC-2.14 Climate Change-related Habitat Restoration and Enhancement. The City shall support active habitat restoration and enhancement to reduce impact of climate change stressors Draft EIR
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and improve overall resilience of habitat within existing parks and open space in the city. The City shall support the efforts of Sacramento County to improve the resilience of habitat areas in the American River Parkway.

Goal ERC-3 A well-maintained, resilient, healthy, expansive and equitable urban forest for an environmentally sustainable future.

Policy ERC-3.1 Urban Forest Plan. The City shall maintain and implement an Urban Forest Plan.

Policy ERC-3.2 Tree Canopy Expansion. The City should strive to achieve a 25 percent urban tree canopy cover by 2030 and 35 percent by 2045. Prioritize tree planting and tree maintenance in areas with the lowest average canopy cover and explore strategies to reduce barriers to tree planting in disadvantaged communities and improve tree health.

Policy ERC-3.3 Tree Protection. The City shall encourage public agencies and require private development projects to consider alternatives to removals of healthy trees whenever feasible and to evaluate the longer-term consequences of the inability to meet tree canopy objectives when conducting project analyses and
environmental documents. Ensure adequate protections during construction to protect existing tree roots and structure.

Policy ERC-3.7 Trees of Significance. The City shall promote stewardship of city trees and private protected trees and ensure that the design of development projects provides for the retention of these trees where possible. Where removal cannot be avoided, the City shall require replacement or appropriate remediation.

Natomas Basin Habitat Conservation Plan
The Natomas Basin HCP, adopted in November 1997 and revised in 2003, was designed to promote biological conservation along with economic development and continuation of agriculture in the Natomas Basin. The Natomas Basin HCP provides for the conservation of 22 wildlife and plant Covered Species through a multi-species conservation program to minimize and mitigate the expected loss of habitat values and incidental take of Covered Species that could result from urban development and certain activities associated with The Natomas Basin Conservancy’s management of reserves established under the HCP. The Natomas Basin HCP applies to the 53,537-acre area interior to the toe of levees surrounding the basin, which is located in the northern portion of Sacramento County and the southern portion of Sutter County. The basin contains incorporated and unincorporated areas within Sacramento County and Sutter County.

The USFWS and CDFW have each approved the Natomas Basin HCP and issued incidental take permits to the City and Sutter County for take of listed species (USFWS for federally listed species, CDFW for State-listed species) resulting from urban development in the Natomas Basin.

As Sacramento County is not a permittee under the Natomas Basin HCP, urban development within the unincorporated portions of the County is not covered under the Natomas Basin HCP.

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However, an HCP has been adopted for Metro Air Park, which is managed by the Natomas Basin Conservancy. The combined area covered by the Natomas Basin HCP and Metro Air Park HCP authorizes take associated with 17,500 acres of urban development. Management of the Natomas Basin HCP is heavily focused on the two most widely distributed Covered Species in the basin:

Swainson’s hawk and giant garter snake.

Swainson’s hawk is an upland foraging species that nests along the Sacramento River and in isolated trees and groves throughout the Natomas Basin. The Natomas Basin HCP seeks to avoid development in the Swainson’s Hawk Zone and to acquire upland habitat as mitigation lands inside the Swainson’s Hawk Zone.9 Giant garter snake is found primarily in agricultural wetlands, such as rice fields, and other waterways, such as drainage canals, as well as adjacent uplands in many portions of the Natomas Basin. Management of habitat for Swainson’s hawk and giant garter snake has been anticipated to benefit other Covered Species under the Natomas Basin HCP. The eastern portion of the project site is within the Natomas Basin HCP permit area (see Figure 4.4-2).

City of Sacramento Tree Ordinance
The City of Sacramento Tree Ordinance is set forth in Sacramento City Code Chapter 12.56. The Sacramento Tree Ordinance serves “to provide for the conservation of existing tree resources; to optimize tree canopy coverage throughout the city while recognizing individual rights to develop and make reasonable use of private property consistent with the general plan; and to provide clear standards for protection, removal, and replacement of city trees and private protected trees” (Sacramento City Code Section 12.56.010). For the purposes of this ordinance, the two categories of protected trees are defined as:
 A “City Tree” is any tree, the trunk of which when measured 4.5 feet above ground is partially or completely located in a City park, on real property the City owns in fee, or on a public ROW, including any street, road, sidewalk, park strip, mow strip, or alley; and  A “Private Protected Tree” is any of the following:
o A tree that is designated by City Council resolution to have special historical value, special environmental value, or significant community benefit, and is located on private property;
o Any native valley oak (Quercus lobata), blue oak (Quercus douglasii), interior live oak (Quercus wislizenii), coast live oak (Quercus agrifolia), California buckeye (Aesculus californica), or California sycamore (Platanus racemose), that has a diameter at standard height (DSH) of 12 inches or more and is located on private property;
o A tree that has a DSH of 24 inches or more and is located on private property that is an undeveloped lot or does not include any single unit or duplex dwellings; or o A tree that has a DSH of 32 inches or more located on private property that includes any single unit or duplex dwelling.
9 The Natomas Basin HCP Swainson’s Hawk Zone is defined as the lands that are not currently developed (excluding the 250 acres of land designated “Urban” in the City of Sacramento General Plan and the North Natomas Community Plan, located within the City of Sacramento) and located within the Natomas Basin, within one mile east of the toe of the inside levee of the Sacramento River and extending from the Natomas Cross Canal on the north and I-80 on the south.

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The City recognizes that “trees are a signature of the city and are an important element in promoting the well-being of the citizens of Sacramento” (Sacramento City Code Section

12.56.010). The City requires a Tree Permit to perform any activity, not including routine maintenance, that could adversely impact the health of a City Tree or Private Protected Tree (Sacramento City Code Section 12.56.020). Regulated work activities include removal of a tree; pruning of branches or roots; affixing signs, lights, or other hardware to a tree; grading, clearing, excavating, adding fill soil, trenching, boring, compacting, or paving within the Tree Protection Zone; placing or storing construction equipment or construction material within the Tree Protection Zone; application of any harmful substance within the Tree Protection Zone; and topping of a tree.

4.4.4 IMPACTS AND MITIGATION MEASURES
The following section describes the standards of significance and methodology used to analyze and determine the proposed project’s potential impacts related to biological resources. In addition, a discussion of the project’s impacts, as well as mitigation measures where necessary, is also presented.

Standards of Significance
Consistent with Appendix G of the CEQA Guidelines, the City’s General Plan, and professional judgment, a significant impact would occur if the proposed project would result in the following:
 Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS;  Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or USFWS;
 Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
 Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites;
 Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; and
 Conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan.

Method of Analysis
The information presented in this chapter is primarily based on the BRA and ARD prepared by Bargas, as well as a preliminary tree survey of the project site and compliance with the Natomas Basin HCP. Each is discussed further below.

Biological Resource Assessment
The analysis within the BRA (see Appendix E of this EIR) is based on a literature review and field surveys of the study area. The terminology and acreages, literature review, and field surveys are detailed further below. Due to the proposed off-site force main alignment occurring along existing roadway ROW and other previously disturbed areas, the BRA did not include evaluation of the force Draft EIR
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main alignment, as special-status species and their habitat, as well as other protected biological resources, would not occur in such areas.

Terminology and Acreages
The BRA defines the industrial park footprint as the “project site” (see Figure 4.4-1). However, as discussed in the Project Description chapter of this EIR, the project site consists of 474.4 acres, with a 353.5-acre footprint related to the construction of the proposed industrial park and highway commercial, an 83-acre portion comprised of nonparticipating parcels anticipated for future industrial uses, and a 37.9-acre area containing Caltrans I-5 fee title ROW. The BRA additionally includes definitions for the following areas:
 Annexation Area: The area proposed for annexation into the City, which encompasses the BRA-defined “project site” and is delineated by the BRA with a 475-acre boundary;  Biological Study Area: The BRA-defined “project site” and a 250-foot buffer; and  Regional Study Area: The BRA-defined “project site” and a five-mile buffer.

The Biological Study Area is the area in which Bargas surveyed for potential habitat to support special-status plant and wildlife species, as well as for occurrences of special-status species, within the industrial park footprint. The Annexation Area (which encompasses the nonparticipating parcels and Caltrans ROW) were also evaluated at an appropriate level, as detailed further below.

Additionally, the Regional Study Area was used as the basis for determining special-status biological resource records for consideration in the BRA.

Literature Review
Prior to conducting field surveys, Bargas conducted an initial review of literature and data sources to characterize biological conditions and to compile records of sensitive biological resources that could potentially occur in the study area. In order to better understand the biological setting of the study area, including terrain, hydrology, soils, land uses, and other features that support or inhibit biological resources, the following resources were reviewed in detail:
 The USFWS National Wetlands Inventory to determine if surface waters and wetlands have been mapped on or adjacent to the study area;
 The USGS National Hydrography Dataset to determine if hydrological features have been mapped on or adjacent to the study area;
 The U.S. Department of Agriculture National Resource Conservation Service (NRCS) Web Soil Survey to map and describe soil(s) within the study area; and  Google Earth Pro aerial map images of the study area, including historical aerial images.

In addition, the following data sources were queried to create a well-defined list of habitats and species that could reasonably be expected to occur on the proposed industrial park footprint of the project site in order to analyze potential impacts on biological resources:
 USFWS Information for Planning and Consultation (IPaC) portal for a list of federally listed species and designated critical habitat recommended for impact analysis consideration, based on an upload of the study area limits;
 CNDDB for special-status species and habitat records within the Regional Study Area; and
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 CNPS Inventory of Rare and Endangered Plants for a list of special-status plant species occurrences within the USGS 7.5-minute quadrangles that overlap the Regional Study Area.

Field Surveys
Bargas conducted a total of five field surveys on the following dates: October 27 and 28, 2021, and March 9, April 12, May 27, and July 5, 2022. The biological survey was conducted across the March and April 2022 site visits, consisting of transects through the industrial park footprint and scanning adjacent areas within the study area and 474.4-acre overall project site using binoculars.

All areas within the overall project site that were accessible from public ROW or visible from the industrial park footprint were evaluated for the presence of habitat components that could support the special-status plant and wildlife species identified during the literature and database review described above. The biological surveys conducted were comprehensive. As discussed within the various analyses below of potential impacts that could occur to special-status species, the proposed project’s compliance with Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP, as well as non-Natomas Basin HCP mitigation measures required by this EIR, would ensure that preconstruction protocol-level surveys, when necessary to prevent potential impacts to special-status species, would be completed.

The surveys also included a formal ARD (described below). A site visit was also conducted in May 2022 with the project applicant and staff from various agencies during which additional bird species observations were documented. The surveys occurred within the typical nesting bird season (February 15 to August 31) and within the blooming period of all 27 special-status plant species identified in the literature and database review.

Aquatic Resources Delineation
Bargas conducted the ARD on October 27 and 28, 2021 (see Appendix F of this EIR), in accordance with the minimum standards set forth by the USACE South Pacific Division and Sacramento District Regulatory Program, as well as the Corps of Engineers Wetlands Delineation Manual, Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region, and A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States. An additional site visit was conducted on July 5, 2022 to collect additional data. Prior to conducting the field ARD, the following information sources were reviewed:
• Google Earth aerial imagery of the industrial park footprint and surrounding vicinity; • NRCS soil survey maps and unit descriptions, Web Soil Survey, Sacramento County; • USFWS National Wetlands Inventory – Wetlands Online Mapper; and • USGS National Hydrography Dataset to determine if hydrological features have been mapped on or adjacent to the industrial park footprint.

The site assessment consisted of walking meandering transects throughout the portions of the industrial park footprint south of Bayou Way to identify wetlands or waterways potentially under the jurisdiction of USACE. Where wetlands were suspected to be present based on aerial signatures and conditions observed in the field, soil pits were excavated to a depth of approximately 18 inches or until an impermeable layer was reached. The three wetland criteria (i.e., hydrophytic vegetation, hydric soils, and wetland hydrology) were evaluated following the USACE protocol for the Arid West. The locations of the sample points and aquatic features were noted on aerial images of the industrial park footprint. Mapped soil types in the industrial park Draft EIR
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footprint were determined using the NRCS Web Soil Survey, Custom Soil Resource Report. A standard Munsell Soil Color Chart was used to determine soil matrix and mottle colors in the field.

Where present, the OHWM for all identified potential non-wetland waters of the U.S. were delineated. Plant community names followed the CNPS A Manual of California Vegetation, Second Edition, where applicable. Plant nomenclature followed Jepson eFlora. The USACE National Wetland Plant List, Version 3.5 was used to determine the status of observed plants as wetland indicator species.

Boundaries of hydrologic features (including man-made features) within the industrial park footprint were surveyed and mapped using an Eos Arrow 100 receiver paired with the Eos Pro Tools and ESRI Field Maps applications. Global Positioning System (GPS) data were downloaded through ArcGIS Online and converted into ESRI shapefile format. The geographic coordinate system used to reference the data was Universal Transverse Mercator (UTM–Zone 10), North American Datum (NAD83) in meters.

Each wetland was assessed by determining the wetland feature/upland edges and by observing the mandatory wetland indicators at selected points along each transect as defined by the USACE standards discussed above. Potential wetland boundaries were mapped at a level of accuracy of less than one meter. Soil pits were hand-excavated to obtain soil data for wetlands. Data were overlaid on an aerial photograph provided by ESRI ArcGIS World Imagery. The top of bank was mapped for non-wetland waters (canals). The bankfull width and location of the OHWM in relation to the top of bank was noted. Desktop methods were then used to map the location of the OHWM on both banks of each non-wetland feature and top of bank opposite the bank mapped with GPS in the field. The ESRI data and GIS software were used to calculate the acreage of each polygon.

Mapping requirements, as set forth by the USACE Updated Map and Drawing Standards for the South Pacific Division Regulatory Program and the Minimum Standards for Acceptance of Aquatic Resources Delineation Reports for the Sacramento District were followed.

Data for each potential wetland were collected using the USACE Wetland Determination Data Form – Arid West Region. Data forms were completed at representative locations to determine whether suspect features qualify as jurisdictional wetlands or other waters of the U.S. Wetlands were determined based on the presence of the three factors that define wetlands. Data for each potential non-wetland water were collected using the USACE Arid West Ephemeral and Intermittent Streams OHWM Datasheet. Data for each linear feature were collected at representative cross sections with observations on sediment texture and vegetation characteristics summarized for each floodplain unit present. The OHWM for each linear feature were determined based upon the presence of certain indicators, which can include a change in average sediment texture, vegetation species, vegetation cover, and breaks in bank slope.

Tree Survey
A preliminary tree survey was conducted by Raney on May 10, 2023 of the project site to identify a stem count of trees that would be potentially impacted by development of the proposed industrial park, as well as trees within nonparticipating parcels that could be impacted is such areas are developed with industrial uses in the future. The site was surveyed by driving around the site boundaries to identify trees that occur along the perimeter and internal to the site. Internal trees were further examined on-foot.

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Natomas Basin Habitat Conservation Plan
The Natomas Basin HCP and accompanying incidental take permits issued by USFWS and CDFW (collectively, the Wildlife Agencies) are based on a limit on urban development within the Natomas Basin to 17,500 acres, 8,050 acres of which are allocated to the City of Sacramento. To fund protection of habitat under the Natomas Basin HCP, a mitigation fee must be paid by developers and landowners when they obtain development permits from the City of Sacramento, with revenue from those fees used to acquire, enhance, and manage habitat for the Covered Species.

The Natomas Basin HCP requires that a system of habitat mitigation lands or reserves be established to provide wetland and upland habitat values for giant garter snake, Swainson’s hawk, and other species. The Natomas Basin HCP requires that 0.5-acre of mitigation land be conserved for each acre of land that is developed in the Natomas Basin. In addition, projects of more than 50 acres in size pay a reduced fee in conjunction with providing land dedication at a

0.5:1 ratio. The land dedication is required to be located in Natomas Basin and the mitigation property is deeded to the Natomas Basin Conservancy. Under the Natomas Basin HCP, the Natomas Basin Conservancy carries out habitat acquisition and management activities set forth in the Natomas Basin HCP. To the maximum extent practicable, the Natomas Basin Conservancy must complete habitat acquisition in advance of habitat conversion resulting from authorized development in the Natomas Basin.

Mitigation land may be acquired either using mitigation fees paid by developers or through transfer of mitigation lands from developers as part of their mitigation obligation. Fees are paid based on the acreage of land approved for development and the funds necessary to assure the establishment of reserve lands consistent with Natomas Basin HCP requirements. When the Natomas Basin HCP was first adopted, an initial fee was established through a funding study prepared by Economic and Planning Systems, Inc. The fee has increased periodically to adjust for inflation and reflect increases in operation and land costs, adaptive management, and plan modifications resulting from Giant Garter Snake Recovery Plan implementation.

Natomas Basin HCP fees and acreages have been tracked by the City for more than 20 years pursuant to the Natomas Basin HCP and Implementation Agreement, which requires the City to provide an Annual Report to the Wildlife Agencies detailing authorized urban development activities (Implementation Agreement, Section 3.1.15; Natomas Basin HCP, Section VI-G). The Annual Report includes maps and charts that depict the City’s monitoring of urban development associated with the Natomas Basin HCP. The latest report shows the City has authorized grading of 6,791.83 acres under the Natomas Basin HCP through calendar year 2023 and collected more than $52.4 million in HCP fees (excluding valuation of land dedications) (2023 Annual Report of Urban Development for the City of Sacramento, April 3, 2024). Starting in 2009, the City’s Annual Reports began including a graphic that showed “HCP Fee Areas Remaining.” The graphic shows lands remaining to pay fees under the Natomas Basin HCP, including 121.68 acres of the project area (2023 Annual Report, Attachment E). Over the years since 2009, similar attachments to the City’s annual reports have shown that the total area graded under the HCP, plus the identified fee areas remaining, totaled less than 8,050 acres. In other words, the City’s records show a surplus of acreage of HCP coverage not attributed to a particular project or parcel. The current 2023 HCP Annual Report shows a surplus of 358 acres.

In order to generate payment of all fees that were anticipated under the Natomas Basin HCP to come from City development, projects will need to utilize the surplus HCP coverage and pay fees Draft EIR
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under the Natomas Basin HCP. A portion of that surplus may be available for use by the portion of the project site that is not currently within the HCP permit area.

Since 2003, the Natomas Basin Conservancy has acquired more than 5,000 acres of land, utilizing the proceeds of the Natomas Basin HCP fees collected by the City, Sutter County, and pursuant to the Metro Air Park HCP. In 2022, the Natomas Basin Conservancy reached an important milestone. The Natomas Basin HCP required that, by the end of the 50-year lifespan of the Natomas Basin HCP, one habitat block within the reserve system must be at least 2,500 acres in size. The 2,500-acre block was completed in 2022 with acquisition of the Lauppe North tract.

The City’s processing and tracking of HCP fees have played a significant role in helping the Natomas Basin Conservancy accomplish this goal in less than 20 years.

Project-Specific Impacts and Mitigation Measures
The following discussion of impacts related to biological resources is based on implementation of the proposed project in comparison to existing conditions and the standards of significance presented above.

4.4-1 Impacts to special-status plant species, either directly (e.g., threaten to eliminate a plant community) or through
substantial habitat modifications. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

The project site, historically used as hay fields and potentially planted intermittently with rice fields from 1937 to 2020, currently consists of fallow agricultural land, devoid of structures. Unnamed drainage canals proceed through the site generally in a northto-south direction in both the site’s western and eastern portions. Unimproved dirt roads provide access to the interior of the project site, which is subdivided into multiple agricultural plots. Within the northern portion of the study area, Bayou Way, a paved road consisting of two vehicle lanes, meanders in a west-to-east direction through the site.

As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to special-status plant species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact special-status plants. Because installation of the proposed off-site force main, including each of the three potential force main segment options, would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to specialstatus plant species, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Of the 20 special-status plant species with potential to occur in the Regional Study Area, the following six species were determined to have low potential to occur in the project site: pappose tarplant, Heckard’s pepper-grass, San Joaquin spearscale, woolly rose-mallow, palmate-bracted bird’s beak, and Sanford’s arrowhead. Of the aforementioned species, only Sanford’s arrowhead is a Covered Species under the Natomas Basin HCP.

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As detailed in Table 4.4-2, habitat within the project site for all of the aforementioned plant species is considered low quality. In addition, the ongoing agriculture-related site disturbance limits the potential for any of the species to occur within the site. None of the plant species were identified as part of the comprehensive field surveys conducted as part of the BRA, which were conducted within the blooming period of all specialstatus plant species identified in the literature and database review. Thus, pappose tarplant, Heckard’s pepper-grass, San Joaquin spearscale, woolly rose-mallow, palmate-bracted bird’s beak, and Sanford’s arrowhead are not anticipated to occur within the proposed industrial park footprint of the project site.

However, given enough time, the possibility of special-status plants becoming established in areas where suitable habitat exists cannot be ruled out. As such, special-status plant species could occur within the on-site grasses and canals of the industrial park footprint and nonparticipating parcels prior to future commencement of construction. Thus, without a preconstruction survey to confirm the presence or absence of the aforementioned plant species, buildout of the project site could potentially impact protected plant species.

Based on the above, development of the proposed industrial park and nonparticipating parcels could result in impacts to special-status plant species, either directly or through substantial habitat modifications, and a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level. Although only a portion of the industrial park footprint and nonparticipating parcels are within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to special-status plant species with potential to occur on-site, including those not covered under the Natomas Basin HCP. The applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP have been included in this chapter largely as they are written in the Natomas Basin HCP, including references to CDFW’s previous name, which was the California Department of Fish and Game, or “CDFG.” Where appropriate, the measures have been adapted consistent with the Natomas Basin HCP to apply to the project-specific context.

Industrial Park and Nonparticipating Parcels

4.4-1(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities associated with development of the industrial park footprint and nonparticipating parcels, the following Natomas Basin Habitat Conservation Plan (HCP) Take Avoidance, Minimization, and Mitigation Measures shall be implemented, as applicable:

Natomas Basin HCP Section V.A.1:

Not less than 30 days or more than 6 months prior to commencement of construction activities, a pre-construction survey of the portion of the site to be disturbed shall be conducted to determine the status and Draft EIR
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presence of, and likely impacts to, all Covered Species on the site.

However, pre-construction surveys for an individual species may be completed up to one year in advance if the sole period for reliable detection of that species is between May 1 and December 31. The project proponent will be responsible for contracting with qualified biological consultants to carry out the pre-construction surveys, and as necessary, to implement specific take minimization, and other Conservation Measures set forth in the Natomas Basin HCP and approved by the Wildlife Agencies.

The results of the pre-construction surveys along with recommended take minimization measures shall be documented in a report and shall be submitted to the City, USFWS, CDFG and the Natomas Basin Conservancy. Based upon the survey results, the City will identify applicable take avoidance and other site-specific Conservation Measures, consistent with the Natomas Basin HCP, required to be carried out on the site. The approved pre-construction survey documents and list of Conservation Measures will be submitted by the developer to the City to demonstrate compliance with the Natomas Basin HCP.

Natomas Basin HCP Section V.A.5.o:

If Sanford’s arrowhead plants are identified through a pre-construction survey, the City shall provide notice to USFWS, CDFG and the California Native Plant Society. Under such circumstances, the development proponent shall allow the transplantation of plants prior to site disturbance.

Natomas Basin HCP Section V.A.5.p:

Prior to issuance of a grading permit, the City shall require a preconstruction survey. If such survey determines Boggs Lake hedgehyssop, Sacramento orcutt grass, Slender orcutt grass, Colusa grass, or legenere are present, the City shall require the developer to consult with USFWS to determine appropriate measures to avoid and minimize loss of individuals.

4.4-1(b) With respect to special-status plant species not covered under the Natomas Basin HCP, prior to the commencement of construction activities associated with the nonparticipating parcels, a qualified biologist shall conduct preconstruction protocol-level surveys for special-status plants with potential to occur on-site. The surveys may be conducted concurrently with the preconstruction surveys set forth by Mitigation Measure 4.4-1(a). The results of the surveys shall be submitted for review and approval to the City of Sacramento Community Development Department and shall be valid for two years. If special-status plant species are not found, further mitigation shall not be required.

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If any special-status plants are located during the foregoing surveys, the appropriate agency (i.e., CDFW and/or USFWS, depending on the species) shall be consulted to develop appropriate mitigation for the proposed project for expected impacts. If special-status plants would be impacted, as determined by the qualified biologist, a mitigation plan shall be developed in coordination with the appropriate agency and submitted for review and approval to the City of Sacramento Community Development Department. Mitigation shall include that if special-status perennial species are found in areas proposed for disturbance, the plants shall be dug up and transplanted into a suitable avoided area on-site prior to construction. If the plant found is an annual, then mitigation shall consist of collecting seed-bearing soil and spreading it into a suitable location.

4.4-2 Have a substantial adverse effect, either directly or through habitat modifications, on monarch butterfly. Based on the analysis below, the impact is less than significant.

The footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats. As such, the potential for impacts to monarch butterfly that could occur from developing either project component would be similar.

Thus, the following discussion applies to the potential for both project components to impact monarch butterfly. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to monarch butterfly, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Adult monarch butterflies require a diversity of blooming nectar resources during breeding and migration (spring through fall). Monarchs also need milkweed (for both oviposition and larval feeding) embedded within the diverse nectaring habitat.

Pursuant to the BRA, monarch butterflies are unlikely to reside within the proposed industrial park footprint, as the area’s ongoing agriculture-related site disturbance limits the availability of suitable habitat to accommodate the species. Similarly, the nonparticipating parcels would also be unlikely to support monarch butterflies, as the parcels also feature ongoing site disturbance related to agriculture.

Based on the above, neither the proposed industrial park, nor future development of the nonparticipating parcels would have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (monarch butterfly) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

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4.4-3 Have a substantial adverse effect, either directly or through habitat modifications, on giant garter snake. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Giant garter snake is a Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact giant garter snake. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to giant garter snake, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Giant garter snake was not observed during any of five surveys conducted as part of the BRA. However, the CNDDB contains several records documenting the species within the previous 20 years as having occurred in the West Drainage Canal in the project vicinity. The canal hydrologically connects to Fisherman’s Lake, which contains a known population of giant garter snake.

Habitat for the species in the project site consists of interconnected drainage canals (i.e., Canal-1, Canal-2, and Canal-3), which are inundated under typical circumstances during the summer, as they collect irrigation and stormwater runoff from surrounding lands during the growing season. All canals were observed during the BRA field surveys to contain some cover of emergent aquatic vegetation dominated by floating water primrose (Ludwigia peploides), with small areas of cattail, and common tule.

Although the cover of the emergent aquatic species was low at the time of the April 2022 survey, large areas of open water had remnants of floating water primrose from the previous growing season, indicating that the cover of giant garter snake may be substantial in mid-summer.

The BRA found that habitat in the project site is unlikely to support a permanent giant garter snake population, as suitable burrows do not occur within the site and the project site is subject to ongoing high levels of vegetation management. For instance, much of the on-site canal banks are vertical and undercut with few visible burrows suitable for the species. Additionally, the tops of the canal banks are highly compacted and show evidence of repeated mowing and grading along many reaches.

Furthermore, burrows capable of supporting overwintering giant garter snake were not observed during the April 2022 survey.

Nevertheless, the on-site habitat, while marginal, still provides connectivity to occupied sites to the north and south of the site within the American Basin. Though not ideal for giant garter snake, the canals within site could support transient individuals on a temporary basis. As such, in the event the species is present in the upland areas adjacent to the on-site canals, construction activities associated with the proposed industrial park and future development of the nonparticipating parcels could directly impact giant garter snake.

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Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels could have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (giant garter snake) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level. Although only a portion of the project site is within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to giant garter snake. In addition, as discussed under Impact 4.4-14, the proposed project would be subject to applicable mitigation fees for land acquisition, enhancement, and management and monitoring activities, which are assessed on new development within the Natomas Basin HCP permit area. The applicable Take Avoidance, Minimization, and Mitigation Measures have been included in this chapter and have been adapted consistent with the Natomas Basin HCP, where appropriate, to apply to the project-specific context.

Industrial Park and Nonparticipating Parcels

4.4-3 Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measures have been implemented:

Natomas Basin HCP Section V.A.5.a:

1. Within the Natomas Basin, all construction activity involving disturbance of habitat, such as site preparation and initial grading, is restricted to the period between May 1 and
September 30. This is the active period for the giant garter snake and direct mortality is lessened, because snakes are expected to actively move and avoid danger.

2. Pre-construction surveys for giant garter snake, as well as other NBHCP Covered Species, must be completed for all
development projects by a qualified biologist approved by USFWS. If any giant garter snake habitat is found within a specific site, the following additional measures shall be implemented to minimize disturbance of habitat and
harassment of giant garter snake, unless such project is specifically exempted by USFWS.

3. Between April 15 and September 30, all irrigation ditches, canals, or other aquatic habitat should be completely
dewatered, with no puddled water remaining, for at least 15 consecutive days prior to the excavation or filling in of the dewatered habitat. Make sure dewatered habitat does not continue to support giant garter snake prey, which could detain or attract snakes into the area. If a site cannot be completely dewatered, netting and salvage of prey items may be
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necessary. This measure removes aquatic habitat component and allows giant garter snake to leave on their own.

4. For sites that contain giant garter snake habitat, no more than 24-hours prior to start of construction activities (site preparation and/or grading), the project area shall be surveyed for the presence of giant garter snake. If construction activities stop on the project site for a period of two weeks or more, a new giant garter snake survey shall be completed no more than 24-hours prior to the re-start of construction activities.

5. Confine clearing to the minimal area necessary to facilitate construction activities. Flag and designate avoided giant garter snake habitat within or adjacent to the project as
Environmentally Sensitive Areas. This area shall be avoided by all construction personnel.

6. Construction personnel completing site preparation and grading operations shall receive USFWS approved environmental
awareness training. This training instructs workers on how to identify giant garter snakes and their habitats, and what to do if a giant garter snake is encountered during construction activities. During this training an on-site biological monitor shall be designated.

7. If a live giant garter snake is found during construction activities, immediately notify the USFWS and the project’s biological monitor. The biological monitor, or his/her assignee, shall do the following:
a. Stop construction in the vicinity of the snake. Monitor the snake and allow the snake to leave on its own. The
monitor shall remain in the area for the remainder of the work day to make sure the snake is not harmed or if it
leaves the site, does not return. Escape routes for giant garter snake should be determined in advance of
construction and snakes should always be allowed to
leave on their own. If a giant garter snake does not leave on its own within 1 working day, further consultation with USFWS is required.

8. Upon locating dead, injured or sick threatened or endangered wildlife species, the project applicant must notify within 1 working day the Service’s Division of Law Enforcement (2800 Cottage Way, Sacramento CA 95825) or the Sacramento Fish and Wildlife Office (2800 Cottage Way, Room W2605,
Sacramento, CA 95825, telephone 916 414-6600). Written
notification to both offices must be made within 3 calendar days and must include the date, time, and location of the finding of a specimen and any other pertinent information.

9. Fill or construction debris may be used by giant garter snake as an over-wintering site. Therefore, upon completion of
construction activities remove any temporary fill and/or construction debris from the site. If this material is situated near Draft EIR
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undisturbed giant garter snake habitat and it is to be removed between October 1 and April 30, it shall be inspected by a qualified biologist to assure that giant garter snake are not using it as hibernaculae.

10. No plastic, monofilament, jute, or similar erosion control matting that could entangle snakes will be placed on a project site when working within 200 feet of snake aquatic or rice habitat. Possible substitutions include coconut coir matting, tactified
hydroseeding compounds, or other material approved by the Wildlife Agencies.

4.4-4 Have a substantial adverse effect, either directly or through habitat modifications, on northwestern pond turtle. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Northwestern pond turtle is a Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact northwestern pond turtle. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to northwestern pond turtle, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
With respect to on-site upland areas that could support northwestern pond turtle, the top of the canal banks within the project site are highly compacted and show evidence of repeated mowing and grading along several reaches. Such conditions limit the potential for the species to occur within areas upland of the on-site canals. In addition, adjacent upland habitats are marginal, as much of the canal banks are vertical and undercut. Nevertheless, northwestern pond turtle was observed within the project site during three field surveys conducted as part of the BRA, specifically in Canal-2 and Canal-3. Individuals were observed sunning on floating debris and/or vegetation within the canals. Given the BRA’s confirmation of northwestern pond turtle in the project site, the potential for the species to be present within the uplands adjacent to the canals cannot be entirely ruled out. In the event the species is present, construction activities associated with the proposed industrial park and future development of the nonparticipating parcels could directly impact northwestern pond turtle.

Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels could have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (northwestern pond turtle) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a significant impact could occur.

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Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level. Although only a portion of the project site is within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to northwestern pond turtle.

The applicable Take Avoidance, Minimization, and Mitigation Measures have been included in this chapter and have been adapted consistent with the Natomas Basin HCP, where appropriate, to apply to the project-specific context. Additionally, as detailed below, potential impacts to northwestern pond turtle would be further minimized through compliance with Mitigation Measure 4.4-3, which includes provisions for mitigation impacts to giant garter snake that would simultaneously address impacts to northwestern pond turtle.

Industrial Park and Nonparticipating Parcels

4.4-4(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.j:

1. Take of the northwestern pond turtle as a result of habitat destruction during construction activities, including the removal of irrigation ditches and drains, and during ditch and drain maintenance, will be minimized by the dewatering requirement described above for giant garter snake (see Section 5.a.(3)).

4.4-4(b) Implement Mitigation Measure 4.4-1(a).

4.4-5 Have a substantial adverse effect, either directly or through habitat modifications, on Swainson’s hawk. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Swainson’s hawk is a Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact Swainson’s hawk. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to Swainson’s hawk, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Swainson’s hawk was observed during the April and May 2022 surveys. Although nesting activity was not detected during these surveys, in the event the species is nesting within the project site, which contains limited nesting habitat, the proposed Draft EIR
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project could directly affect the success of nesting hawks through destruction of preexisting nests, active nests, and young or visual and/or audible disturbance from construction activities. Furthermore, the BRA found that high-quality foraging habitat occurs on-site, which would be converted to industrial uses as part of the proposed project. As such, the project would result in potential impacts related to the loss of Swainson’s hawk foraging habitat.

As previously discussed, this chapter applies the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to address the majority of identified potential impacts that could occur as a result of the proposed project to special-status plant and wildlife species. However, a portion of the identified Swainson’s hawk foraging habitat within the project site occurs outside of the Natomas Basin HCP permit area.

In the event that a portion of the City’s surplus HCP coverage acreage is made available to the non-HCP covered portion of the project site, the applicant could address impacts to Swainson’s hawk foraging habitat through payment of the Natomas Basin HCP mitigation fees. Conversely, if the aforementioned option is not available to the project, the project would be required to address potential impacts to Swainson’s hawk foraging habitat through preserving habitat elsewhere in compliance with applicable CDFW guidelines. As part of such compliance, the project applicant would be required to establish off-site mitigation lands and fund an endowment for perpetual preservation of same.

Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels could have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (Swainson’s hawk) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level. Although only a portion of the project site is within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to Swainson’s hawk. The applicable Take Avoidance, Minimization, and Mitigation Measures have been included in this chapter and have been adapted consistent with the Natomas Basin HCP, where appropriate, to apply to the project-specific context.

In addition, to address potential impacts to Swainson’s hawk foraging habit that occurs within on-site areas outside of the Natomas Basin HCP permit area, the project applicant would implement Mitigation Measure 4.4-5(b), which would require the applicant to pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities, should a portion of the City’s surplus HCP coverage acreage be made available to the project. In the event that the proposed project cannot mitigate potential impacts to Swainson’s hawk foraging habitat through such means, the applicant would be required to preserve Swainson’s hawk foraging habitat elsewhere, in accordance with applicable CDFW Draft EIR
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guidelines. Preservation of foraging habitat for Swainson’s hawk would additionally address potential impacts to the foraging habitat of other protected species that have potential to occur within Swainson’s hawk foraging habitat (i.e., burrowing owl and other birds and raptors protected under the MBTA and CFGC). To ensure overall preservation of Swainson’s hawk foraging habitat at a 1:1 ratio, the proposed project would also be subject to Mitigation Measure 4.2-1, which is detailed in the Agricultural Resources chapter of this EIR and necessitates preservation of off-site farmland at a ratio of one Farmland acre converted to urban land uses outside the Natomas Basin HCP policy area to 0.5-acre preserved. Combined with the requirements of Mitigation Measure 4.4-5(b), the proposed project would preserve Swainson’s hawk foraging habitat at a 1:1 ratio.

Industrial Park and Nonparticipating Parcels

4.4-5(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.b:

Measures to Reduce Nest Disturbance

1. Prior to the commencement of development activities, a preconstruction survey shall be completed to determine whether any Swainson’s hawk nest trees will be removed on-site, or active Swainson’s hawk nest sites occur on or within ½ mile of the development site. These surveys shall be conducted
according to the Swainson’s Hawk Technical Advisory
Committee’s (May 31, 2000) methodology or updated
methodologies, as approved by the Service and CDFG, using experienced Swainson’s hawk surveyors.

2. If breeding Swainson’s hawks (i.e. exhibiting nest building or nesting behavior) are identified, no new disturbances (e.g., heavy equipment operation associated with construction) will occur within ½ mile of an active nest between March 15 and September 15, or until a qualified biologist, with concurrence by CDFG, has determined that young have fledged or that the nest is no longer occupied. If the active nest site is located within 1/4 mile of existing urban development, the no new disturbance zone can be limited to the ¼ mile versus ½ mile. Routine disturbances such as agricultural activities, commuter traffic, and routine facility maintenance activities within ½ mile of an active nest are not restricted.

3. Where disturbance of a Swainson’s hawk nest cannot be avoided, such disturbance shall be temporarily avoided (i.e., defer construction activities until after the nesting season) and then, if unavoidable, the nest tree may be destroyed during the non-nesting season. For purposes of this provision the
Swainson's hawk nesting season is defined as March 15 to Draft EIR
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September 15. If a nest tree (any tree that has an active nest in the year the impact is to occur) must be removed, tree removal shall only occur between September 15 and February 1.

4. If a Swainson’s hawk nest tree is to be removed and fledglings are present, the tree may not be removed until September 15 or until the California Department of Fish and Game has concurred that the young have fledged and are no longer dependent upon the nest tree.

5. If construction or other project related activities which may cause nest abandonment or forced fledgling are proposed within the ¼ mile buffer zone, intensive monitoring (funded by the project sponsor) by a Department of Fish and Game
approved raptor biologist will be required. Exact implementation of this measure will be based on specific information at the project site.

4.4-5(b) To address potential impacts to Swainson’s hawk foraging habitat that occurs on-site, but outside of the Natomas Basin HCP permit area, the project applicant shall pay the Natomas Basin HCP mitigation fees for land acquisition, enhancement, and management and monitoring activities, should a portion of the City’s surplus HCP coverage be made available to the proposed project.

OR
Pursuant to CDFW guidelines, the applicant shall preserve Swainson’s hawk foraging habitat at a 0.5:1 ratio. The preserved habitat shall be at a location approved by the CDFW. Preservation may occur through purchase of conservation easements or fee title of lands with suitable Swainson’s hawk foraging habitat (consistent with CDFW guidelines).

4.4-6 Have a substantial adverse effect, either directly or through habitat modifications, on burrowing owl. Based on the
analysis below and with implementation of mitigation, the impact is less than significant.

Burrowing owl is a Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact burrowing owl. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to burrowing owl, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Pursuant to the BRA, most regional records for burrowing owl within the greater project vicinity are east of SR 99. However, recent CNDDB records document occurrences of Draft EIR
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the species at the Sacramento International Airport to the northwest of the project site.

As such, burrowing owl could potentially occur over a wide range within the project vicinity during migration and winter in appropriate open habitats and disturbed areas.

Although suitable burrows and ground-squirrels were not observed during the field surveys conducted for the BRA, the project site contains some open disturbed areas, primarily in the construction staging area along the south side of Bayou Way and west of Metro Air Parkway, which provide marginal habitat for burrowing owl. In addition, in the event that ground squirrels move into the property from adjacent undeveloped land and establish burrows prior to project construction activities, burrowing owl could use burrows within the site. Therefore, the proposed project could directly impact the species through destruction of burrows containing overwintering or nesting individuals or visual and/or audible disturbance from construction activities.

Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels could have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (burrowing owl) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level. Although only a portion of the project site is within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to burrowing owl. The applicable Take Avoidance, Minimization, and Mitigation Measures have been included in this chapter and have been adapted consistent with the Natomas Basin HCP, where appropriate, to apply to the project-specific context.

Industrial Park and Nonparticipating Parcels

4.4-6 Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.h:

1. Prior to the initiation of grading or earth disturbing activities, the applicant/developer shall hire a CDFG approved qualified biologist to perform a pre-construction survey of the site to determine if any burrowing owls are using the site for foraging or nesting. The pre-construction survey shall be submitted to the City prior to the developer’s commencement of construction activities and a mitigation program shall be developed and agreed to by the City and developer prior to initiation of any physical disturbance on the site.

2. Occupied burrows shall not be disturbed during nesting season (February 1 through August 31) unless a qualified biologist Draft EIR
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approved by the CDFG verifies through non-invasive measures that either: 1) the birds have not begun egg-laying and incubation; or 2) that juveniles from the occupied burrows are foraging independently and are capable of independent
survival.

3. If nest sites are found, the USFWS and CDFG shall be contacted regarding suitable mitigation measures, which may include a 300 foot buffer from the nest site during the breeding season (February 1 - August 31), or a relocation effort for the burrowing owls if the birds have not begun egg-laying and incubation or the juveniles from the occupied burrows are foraging independently and are capable of independent
survival. If on-site avoidance is required, the location of the buffer zone will be determined by a qualified biologist. The developer shall mark the limit of the buffer zone with yellow caution tape, stakes, or temporary fencing. The buffer will be maintained throughout the construction period.

4. If relocation of the owls is approved for the site by USFWS and CDFG, the developer shall hire a qualified biologist to prepare a plan for relocating the owls to a suitable site. The relocation plan must include: (a) the location of the nest and owls proposed for relocation; (b) the location of the proposed relocation site; (c) the number of owls involved and the time of year when the relocation is proposed to take place; (d) the name and
credentials of the biologist who will be retained to supervise the relocation; (e) the proposed method of capture and transport for the owls to the new site; (f) a description of the site preparations at the relocation site (e.g., enhancement of existing burrows, creation of artificial burrows, one-time or long-term vegetation control, etc.); and (g) a description of efforts and funding support proposed to monitor the relocation.

Relocation options may include passive relocation to another area of the site not subject to disturbance through one way doors on burrow openings, or construction of artificial burrows in accordance with the CDFG’s October 17, 1995, Staff Report on Burrowing Owls Mitigation (see Appendix D).

5. Where on-site avoidance is not possible, disturbance and/or destruction of burrows shall be offset through development of suitable habitat on TNBC upland reserves or in other suitable preserved uplands. Such habitat shall include creation of new burrows with adequate foraging area (a minimum of 6.5 acres) or 300 feet radii around the newly created burrows. Additional habitat design and mitigation measures are described in CDFW’s March 7, 2012, Staff Report on Burrowing Owl
Mitigation.

Draft EIR
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4.4-7 Have a substantial adverse effect, either directly or through habitat modifications, on Aleutian cackling goose, whitefaced ibis, and tricolored blackbird. Based on the analysis below, the impact is less than significant.

Aleutian cackling goose, white-faced ibis, and tricolored blackbird are Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact Aleutian cackling goose, white-faced ibis, and tricolored blackbird. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to the foregoing species, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
With respect to Aleutian cackling goose, the nearest CNDDB occurrence is 28 miles to the north of the project site, and the species has not been recorded within the Natomas Basin. Aleutian cackling goose sometimes occurs singly or in small numbers with more numerous Canada geese, which often feed in agricultural fields, especially during winter months. However, pursuant to the BRA, on-site habitat for the species is of low quality. Thus, Aleutian cackling goose is not anticipated to occur on-site.

Furthermore, although the proposed industrial park would include stormwater retention/detention areas primarily along the western and southern project site boundaries, which could attract avian species such as Aleutian cackling goose and expose them to collisions with aircraft associated with the Sacramento International Airport, the project includes a Wildlife Hazard Management Plan to prevent such aviation hazards from occurring, as required by Mitigation Measure 4.7-5(a). The Wildlife Hazard Management Plan would be prepared by a qualified wildlife hazard damage biologist, subject to review by the Sacramento County Airport System, and include various provisions to reduce bird attractants within the retention/detention areas, such as refuse and birdfeed. Based on the above, through incorporation of the Wildlife Hazard Management Plan, Aleutian cackling goose would not occur within the retention/detention areas during project operation, and a less-than-significant impact would occur.

With respect to white-faced ibis, the nearest CNDDB-documented occurrences are eight miles to the west of the project site, though the species is known to be present in high numbers at the Yolo Bypass five miles to the southwest. Although white-faced ibis has limited potential to forage within the project site at the margins of canals or adjacent agricultural areas, the species is anticipated to forage elsewhere while construction disturbance is occurring. In addition, the project site does not contain habitat to support nesting. Based on the above, white-faced ibis is not anticipated to occur on-site, and a less-than-significant impact would occur.

With regard to tricolored blackbird, nesting habitat does not occur within the project site. In addition, similar to white-faced ibis, tricolored blackbird is anticipated to forage elsewhere while construction disturbance is occurring.

Draft EIR
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Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels would not have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (Aleutian cackling goose, white-faced ibis, and tricolored blackbird) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a less-than-significant impact could occur.

Mitigation Measure(s)
None required.

4.4-8 Have a substantial adverse effect, either directly or through habitat modifications, on loggerhead shrike. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Loggerhead shrike is a Covered Species under the Natomas Basin HCP. As the footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats, the potential for impacts to the species from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact loggerhead shrike. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to loggerhead shrike, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
Although the nearest documented CNDDB occurrences of loggerhead shrike are more than 50 miles from the project site, the BRA found that the species is underreported in the CNDDB, as loggerhead shrike occurs sparingly in the Natomas Basin. Although the species is unlikely to be present on-site due to the lack of scrubby habitat to accommodate the species, the BRA determined that the possibility of active loggerhead shrike nests occurring on-site could not be ruled out. In addition, the BRA found that the proposed project could potentially impact the species through the loss of suitable foraging habitat within the site. As such, the project could result in impacts to loggerhead shrike.

Based on the above, development of the proposed industrial park and future buildout of the nonparticipating parcels would not have a substantial adverse effect, either directly or through habitat modifications, on a wildlife species (loggerhead shrike) identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Thus, a less-than-significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level. Although only a portion of the project site is within the Natomas Basin HCP permit area, the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP would be applied to all project construction activities to address potential impacts to loggerhead shrike. As Draft EIR
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discussed under Impact 4.4-5, preservation of foraging habitat for Swainson’s hawk through Mitigation Measures 4.4-5(a) and 4.4-5(b) would additionally address potential impacts to the foraging habitat of other protected species that have potential to occur within Swainson’s hawk foraging habitat, such as loggerhead shrike. The applicable Take Avoidance, Minimization, and Mitigation Measures have been included in this chapter and have been adapted consistent with the Natomas Basin HCP, where appropriate, to apply to the project-specific context.

Industrial Park and Nonparticipating Parcels

4.4-8 Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall ensure that the following Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measure has been implemented:

Natomas Basin HCP Section V.A.5.g:

1. Prior to issuance of a grading permit, the City shall require a preconstruction survey.

2. If surveys identify an active loggerhead shrike nest that will be impacted by development, the developer shall install brightly colored construction fencing that establishes a boundary 100 feet from the active nest. No disturbance associated with development shall occur within the 100 foot fenced area during the nesting season of March 1 through July 31. A qualified biologist, with concurrence of USFWS must determine young have fledged or that the nest is no longer occupied prior to disturbance of the nest site.

4.4-9 Have a substantial adverse effect, either directly or through habitat modifications, on northern harrier, white-tailed kite, song sparrow, and other nesting birds and raptors protected under the MBTA and CFGC. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

The footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats. As such, the potential for impacts to northern harrier, white-tailed kite, song sparrow “Modesto” population, and other nesting birds and raptors protected under the MBTA and CFGC that could occur from developing either project component would be similar. Thus, the following discussion applies to the potential for both project components to impact the aforementioned species.

Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to the aforementioned species, either directly or through substantial habitat modifications.

Industrial Park and Nonparticipating Parcels
The vegetation communities within the project site and proposed off-site areas provide suitable nesting habitat to accommodate songbirds and raptors that are not covered Draft EIR
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under the Natomas Basin HCP, but which are, nevertheless, protected under the MBTA and CFGC. Such species include northern harrier, white-tailed kite, and song sparrow, as well as other avian species. In regard to northern harrier, the species was observed foraging on and flying over the project site during two of the five surveys conducted as part of the BRA. Thus, the species is considered present. In the event northern harrier is nesting within the site prior to project construction, the BRA concluded that the proposed project could directly affect the success of nesting northern harrier through destruction of active nests and young or visual and/or audible disturbance from construction activities. The project could also potentially impact species through the loss of suitable foraging habitat.

With respect to white-tailed kite, although nesting habitat is limited and composed of relatively few Goodding’s black willow, valley oak, and other trees along the canal and ditch banks, in the event the species is nesting within the project site, the BRA found that the proposed project could directly affect the success of nesting white-tailed kite through destruction of pre-existing nests, active nests, and young or visual and/or audible disturbance from construction activities. In addition, the project site contains foraging habitat that could support the species, which would be converted as part of project construction activities. However, it should be noted that with implementation of Mitigation Measure 4.4-5(a) of this EIR, potential impacts to foraging habitat would be reduced to a less-than-significant level.

With respect to song sparrow, while population levels have dropped by 90 percent from historical highs, the “Modesto” population of song sparrow has been recorded in sparsely vegetated margins of canals, such as those associated with the project site.

Although the on-site habitat to support nesting activities for song sparrow is limited, in the event the species is present within the project site, the BRA found that the proposed project could directly affect the success of nesting song sparrow through destruction of active nests and young or visual and/or audible disturbance from construction activities.

Similar to potential impacts to northern harrier, white-tailed kite, and song sparrow, most native songbirds and raptors have baseline protections under the CFGC and guidelines for protections under the federal MBTA. Each prohibits the intentional killing, collecting, or trapping of covered species, including their active nests (those with eggs or young). Given the presence of various trees within the project site which provide suitable nesting habitat to native songbirds and raptors, the proposed project could result in potential impacts to other species protected under the CFGC and MBTA.

With respect to project operation, as discussed under Impact 4.4-7, the project includes a Wildlife Hazard Management Plan to prevent aviation hazards from occurring to protected avian species. The Wildlife Hazard Management Plan would be prepared by a qualified wildlife hazard damage biologist, subject to review by the Sacramento County Airport System, and include various provisions to reduce bird attractants within the retention/detention areas, such as refuse and birdfeed. Based on the above, through incorporation of the Wildlife Hazard Management Plan, protected nesting birds and raptors would not occur within the retention/detention areas during project operation, and a less-than-significant impact would occur.

Draft EIR
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Based on the above, the project could have a substantial adverse effect during project construction, either directly or through habitat modifications, on nesting songbirds and raptor species protected under the MBTA and CFGC. Thus, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

Industrial Park and Nonparticipating Parcels

4.4-9(a) Raptors: If ground disturbance or other construction activities are proposed during the nesting season (February 1 to August 31), a focused survey for nesting raptors protected under the California Fish and Game Code (CFGC) and Migratory Bird Treaty Act (MBTA) shall be conducted by a qualified biologist within seven days prior to the beginning of construction activities in order to identify active nests. The survey shall be conducted within the proposed construction area and all accessible areas within 0.5-mile. A report summarizing the results of the survey shall be submitted for review and approval to the City of Sacramento Community Development Department. If active nests are not found during the focused survey(s), additional mitigation shall not be required. For any period of project inactivity of more than seven days, the qualified biologist shall conduct a field check of the previously surveyed area before construction activities recommence to confirm nesting raptors have not entered during the interim.

If active raptor nests are found within 0.5-mile of a construction area, construction shall not commence within 0.5-mile of the nest until a qualified biologist determines that the young have fledged, or the biologist has determined that the nesting attempt has failed. If construction activities within 0.5-mile of the nest are necessary, the qualified biologist shall be consulted to determine if the nest buffer can be reduced. The applicant and qualified biologist shall jointly determine the nest avoidance buffer, and what (if any) nest monitoring is necessary.

If an active raptor nest is found within the project area prior to construction and is in a tree that is proposed for removal, then the project applicant shall implement additional mitigation recommended by a qualified biologist based on CDFW guidelines and obtain any required permits from CDFW.

4.4-9(b) Songbirds: If ground disturbance or other construction activities are proposed during the nesting season (February 1 to August 31), a focused survey for birds protected under the MBTA shall be conducted by a qualified biologist within seven days prior to the beginning of construction activities in order to identify active nests. The survey shall be conducted within the proposed construction area and all accessible areas within 500 feet. A report summarizing the results of the survey Draft EIR
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shall be submitted for review and approval to the City of Sacramento Community Development Department. If active nests are not found during the focused survey(s), additional mitigation shall not be required.

For any period of project inactivity of more than seven days, the qualified biologist shall conduct a field check of the previously surveyed area before construction activities recommence to confirm nesting songbirds have not entered during the interim.

If active special-status species nests/nesting colonies are located during the survey, the project applicant shall work with a qualified biologist to determine a suitable avoidance buffer and the extent and duration of nest monitoring needed. The perimeter of the protected area shall be indicated by bright orange temporary fencing and signage.

Construction activities and/or personnel shall not enter the protected area, except with approval of the biologist. If trees containing nests or burrows must be removed as a result of project implementation, removal shall be completed during the nonbreeding season (late September to January 31).

If active songbird nests are found, a qualified biologist shall establish a 100-foot non-disturbance buffer. The non-disturbance buffers may be reduced based on consultation and approval by the City of Sacramento Community Development Department. The perimeter of the protected area shall be indicated by bright orange temporary fencing.

Construction activities or personnel shall not enter the protected area, except with approval of the biologist. If trees containing nests must be removed as a result of project implementation, removal shall be completed during the nonbreeding season (late September to January 31) or after the adults and young are not dependent on the nest site, as determined by a qualified biologist.

4.4-10 Have a substantial adverse effect on any riparian habitat or other Sensitive Natural Community identified in local or regional plans, policies, regulations or by the CDFW or USFWS. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

The following discussions include a project-level analysis of potential impacts related to riparian habitat or other Sensitive Natural Community associated with development of the proposed industrial park, as well as a program-level analysis of potential impacts associated with the future buildout of the nonparticipating parcels. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to riparian habitat or other Sensitive Natural Communities.

Industrial Park
Construction of the proposed industrial park would result in direct impacts to 0.37-acre of Goodding’s willow – red willow riparian woodland and forest, 0.07-acre of valley oak Draft EIR
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riparian forest woodland, and 0.02-acre of California bulrush marsh. As previously discussed, the aforementioned vegetation communities are designated by the CDFW and CNPS as Sensitive Natural Communities.

To address the potential impact to the aforementioned vegetation communities, the project would require notification of CDFW, pursuant to the provisions set forth by CFGC Section 1600, et seq. If CDFW determines that the proposed activity would substantially affect fish and wildlife resources, a LSAA containing measures to protect affected fish and wildlife resources would be required, in accordance with CFGC Section 1600. The LSAA would be comprised of the final mitigation measure(s) and condition(s) mutually agreed upon by CDFW and the City. CDFW may choose to address potential temporary impacts to Sensitive Natural Communities through the LSAA process. Additionally, projects that require a LSAA often additionally require a permit from the USACE under Section 404 of the CWA. In such instances, the conditions of the Section 404 permit and the LSAA may overlap. Without compliance with the LSAA and/or Section 404 permit, a significant impact could occur.

Nonparticipating Parcels
A portion of the 0.75-acre of valley oak riparian forest woodland identified within the project site occurs within the nonparticipating parcels. As such, future buildout of the nonparticipating parcels with industrial uses could result in impacts to a Sensitive Natural Community. Furthermore, areas of the nonparticipating parcels that were not surveyed as part of the BRA could additionally contain vegetation communities designated by the CDFW and CNPS as Sensitive Natural Communities. As such, development of the nonparticipating parcels would require a review of vegetation communities that occur on-site, prior to the commencement of construction, to ensure that all Sensitive Natural Community acreages have been verified, with appropriate mitigation incorporated to address potential impacts. Without compliance with the aforementioned provisions, a significant impact could occur.

Conclusion
Based on the above, without compliance with the provisions of CFGC Section 1600, et seq., development of the proposed industrial park could have a substantial adverse effect on riparian habitat identified in local or regional plans, policies, regulations or by the CDFW or USFWS. In addition, without a review of vegetation communities that occur within the nonparticipating parcels prior to their development, future buildout of the parcels could result in impacts to a Sensitive Natural Community. Therefore, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

Industrial Park

4.4-10(a) Prior to the commencement of ground-disturbing activities, the project applicant shall notify CDFW, pursuant to CFGC Section 1600. The notification shall include a description of all of the activities associated with the proposed industrial park, not just those associated with the drainages and/or riparian vegetation. Impacts shall be outlined in the Draft EIR
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notification and are expected to be in substantial conformance with the impacts to biological resources outlined in the Biological Resources Assessment prepared for the Airport South Industrial Project by Bargas Environmental Consulting. Impacts for each activity shall be broken down by temporary and permanent impacts. A description of the proposed mitigation for biological resource impacts shall be outlined per activity and then by temporary and permanent impact. Information regarding project-specific drainage and hydrology changes resulting from project implementation shall be provided, as well as a description of stormwater treatment methods. Minimization and avoidance measures shall be proposed, as appropriate, and may include preconstruction species surveys and reporting, protective fencing around avoided biological resources, worker environmental awareness training, seeding disturbed areas adjacent to open space areas with native seed, and installation of project-specific stormwater Best Management Practices (BMPs). Mitigation for impacts to Goodding’s willow – red willow riparian woodland and forest, valley oak riparian forest woodland, and California bulrush marsh may include restoration or enhancement of resources on- or off-site, or any other method acceptable to CDFW. Mitigation shall not result in a net loss of a Sensitive Natural Community.

If CDFW determines through the course of the CFGC Section 1600 notification process that the project does not require a Lake or Streambed Alteration Agreement (LSAA) to address potential impacts to Goodding’s willow – red willow riparian woodland and forest, valley oak riparian forest woodland, and California bulrush marsh, further mitigation regarding the aforementioned vegetation communities shall not be required. Written verification of the applicant’s compliance with the Section 1600 LSAA process shall be submitted to the City of Sacramento Community Development Department.

Nonparticipating Parcels

4.4-10(b) As part of any application associated with development of the nonparticipating parcels, the applicant shall ensure that a qualified biologist has reviewed areas proposed for disturbance to identify vegetation communities that occur in the development footprint and confirm the presence and acreages of Sensitive Natural Communities.

If a Sensitive Natural Community would not be impacted, further mitigation shall not be required. The qualified biologist shall detail any recommendations to avoid impacts to identified Sensitive Natural Communities in a report, which shall be submitted for review and approval to the City of Sacramento Community Development Department.

4.4-10(c) If a Sensitive Natural Community is identified in a nonparticipating parcel for which a development application has been submitted, the applicant shall implement Mitigation Measure 4.4-10(a).

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4.4-11 Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Wetlands are generally considered to be areas that are periodically or permanently inundated by surface or groundwater, and support vegetation adapted to life in saturated soil. Wetlands are recognized as important features on a regional and national level due to their high inherent value to fish and wildlife, use as storage areas for storm and flood waters, and water recharge, filtration, and purification functions.

The USACE, CDFW, and RWQCB have jurisdiction over modifications to stream channels, river banks, lakes, and other wetland features. The USACE’s jurisdiction is established through the provisions of Section 404 of the CWA, which prohibits the discharge of dredged or fill material into waters of the U.S. without a permit, including certain wetlands and unvegetated “other waters of the U.S.” The jurisdictional authority of the RWQCB is established pursuant to Section 401 of the CWA, which typically requires a water quality certification when an individual or nationwide permit is issued by the USACE. The RWQCB also has jurisdiction over waters of the State under the Porter-Cologne Water Quality Control Act.

The following discussions include a project-level analysis of potential impacts related to State- or federally protected wetlands associated with development of the proposed industrial park and a program-level analysis of potential impacts associated with future buildout of the nonparticipating parcels. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not result in a substantial adverse effect to federally or State-protected wetlands.

Industrial Park
Pursuant to the BRA, the proposed project is anticipated to have adverse effects, either directly or through indirect impacts, to wetlands that are potentially protected by the State and/or federal government, as the project includes grading of the entire industrial park footprint. Based upon the ARD, a total of 1.501 acres of tributary waters and 0.58-acre of other waters potentially subject to USACE jurisdiction occur within the grading limits of the proposed industrial park (see Figure 4.4-3). The foregoing acreages have not yet been formally verified by USACE and may be subject to change.

In addition, the features are potential tributary waters and other waters of the State, subject to Central Valley RWQCB jurisdiction, as well as aquatic/riparian habitat, subject to requirements set forth by CWA Section 401 and CFGC Section 1600, respectively.

The proposed project would result in disturbance to a portion of the on-site tributary waters and other waters identified as part of the ARD. As shown in Figure 3-3 of the Project Description chapter of this EIR, the proposed Airport South Industrial Drive would include construction of a bridge and culvert across Canal 2, to the west of the Lot D detention/retention basin. In addition, construction of the proposed commercial lots (Parcels 6A through 6C and 7A through 7C) would result in disturbances to Ditch Draft EIR
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1 and Ditch 2. For potential impacts to State- or federally protected wetlands, the proposed project would require a CWA Section 404 permit from the USACE and a Section 401 permit from the RWQCB and would be subject to all the conditions set forth therein. The project would also be subject to the regulations set forth under CFGC Section 1600, et seq., discussed above under Impact 4.4-10. Without compliance with the above, development of the proposed industrial park could result in a significant impact related to federally or State-protected wetlands.

Nonparticipating Parcels
As previously discussed, the nonparticipating parcels feature similar land cover and aquatic resources as those that occur in the proposed industrial park footprint (see Figure 4.4-3). As such, prior to the development of the nonparticipating parcels, an ARD would be required to identify potential jurisdictional tributary drainages and other waters of the U.S. The ARD would be required to be in accordance with applicable standards, such as the minimum standards set forth by the USACE South Pacific Division and Sacramento District Regulatory Program. Any identified aquatic features would be subject to the interpretation and verification of the USACE Sacramento District Regulatory Division. Thus, without compliance with the aforementioned requirements, a significant impact could occur.

Conclusion
Based on the above, without compliance with the provisions of CWA Sections 404 and 401, as well as CFGC Section 1600, et seq., development of the proposed industrial park could have a substantial adverse effect on riparian habitat identified in local or regional plans, policies, regulations or by the CDFW or USFWS. In addition, without of an ARD to identify aquatic resources that occur within the nonparticipating parcels prior to their development, future buildout of the parcels could result in impacts to State- and/or federally protected wetlands. Therefore, a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

Industrial Park

4.4-11(a) Prior to the issuance of grading permits, the project applicant shall submit the Aquatic Resources Delineation (ARD) prepared for the proposed project by Bargas Environmental Consulting to the U.S. Army Corps of Engineers (USACE) for a Preliminary Jurisdictional Determination and obtain authorization for the fill of jurisdictional waters of the U.S. through the Clean Water Act (CWA) Section 404 permitting process. Timing for compliance with the specific conditions of the Section 404 permit shall be pursuant to the conditions specified by USACE as part of permit issuance. Proof of compliance with the requirements established herein shall be submitted for review and approval to the City of Sacramento Community Development Department.

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4.4-11(b) Prior to construction in any areas containing wetlands or waters of the U.S. and/or State, the project applicant shall obtain a water quality certification pursuant to Section 401 of the CWA. Any measures required as part of the issuance of the water quality certification shall be implemented.

4.4-11(c) Prior to construction in any areas containing wetlands or waters of the U.S. and/or State, the project applicant shall file a report of waste discharge with the Central Valley Regional Water Quality Control Board (RWQCB) for activities affecting wetlands or waters of the State that are not also under USACE jurisdiction, if applicable.

4.4-11(d) Implement Mitigation Measure 4.4-10(a).

Nonparticipating Parcels

4.4-11(e) As part of any application associated with development of the nonparticipating parcels, the applicant shall ensure that a qualified biologist has conducted an Aquatic Resources Delineation (ARD) for areas proposed for disturbance to identify potential waters of the U.S. and/or State. The ARD shall be conducted in accordance with the minimum standards set forth by the USACE South Pacific Division and Sacramento District Regulatory Program, as well as the Corps of Engineers Wetlands Delineation Manual, Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region, and A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States or any manuals that supplement or replace these manuals.

If potential waters of the U.S. and/or State are not identified, further mitigation shall not be required. The ARD shall be submitted for review and approval to the City of Sacramento Community Development Department and USACE Sacramento District Regulatory Division.

4.4-11(f) If waters of the U.S. and/or State are identified within areas proposed for disturbance, the project applicant shall implement Mitigation Measures 4.4-11(a) through 4.4-11(d), as applicable.

4.4-12 Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Based on the analysis below and with implementation of mitigation, the impact is less than significant.

Wildlife corridors link areas of suitable wildlife habitat that are otherwise separated by rugged terrain, changes in vegetation, or human disturbance. The fragmentation of open space areas by urbanization creates isolated "islands" of wildlife habitat.

Fragmentation also occurs when a portion of one or more habitats is converted into another habitat, such as when woodland or scrub habitat is altered or converted into Draft EIR
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grasslands after a disturbance, such as fire, mudslide, or grading activities. Wildlife corridors mitigate the effects of fragmentation by (1) allowing animals to move between remaining habitats, thereby permitting depleted populations to be replenished and promoting genetic exchange; (2) providing escape routes from fire, predators, and human disturbances, thereby reducing the risk of catastrophic events (such as fire or disease) on population or local species extinction; and (3) serving as travel routes for individual animals as they move within their home ranges in search of food, water, mates, and other needs.

The footprints of the proposed industrial park and nonparticipating parcels are contiguous and feature similar habitats. As such, the potential for impacts related to migratory wildlife corridors and wildlife nursery sites that could occur from developing either project component would be similar. Thus, the following discussion includes both a project-level and program-level analysis of potential impacts that could occur as a result of developing the proposed industrial park and nonparticipating parcels.

Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not interfere substantially with the movement of any native resident or migratory wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Industrial Park and Nonparticipating Parcels
Pursuant to the BRA, the overall project site largely does not function as a wildlife corridor to terrestrial wildlife, as the site is bounded by physical barriers (i.e., roads, urban development, agricultural fields). For example, due to the project site’s location along I-5, north-to-south migration through the site by wildlife is limited. Similarly, the existing single-family residential communities immediately to the east of the site limits east-to-west through travel. However, as discussed under Impact 4.4-3, the canals within project site (see Figure 4.4-3 and the discussions under the Aquatic Resources heading above) could support transient giant garter snake on a temporary basis. As such, in the event the species is present in the upland areas adjacent to the on-site canals, construction activities associated with the proposed industrial park and future development of the nonparticipating parcels could interfere substantially with the movement of giant garter snake through the site. However, through compliance with Mitigation Measure 4.4-3, the proposed project would be required to implement the provisions of the applicable Take Avoidance, Minimization, and Mitigation Measure set forth by the Natomas Basin HCP, which includes, but is not limited to, completion of preconstruction surveys for giant garter snake, additional site inspections for sites that contain the species, USFWS environmental awareness training, USFWS notification if a live giant garter snake is found, and prohibition of erosion control matting that could entangle snakes.

Based on the above, the proposed project would not impede the use of native wildlife nursery sites. However, the project could interfere substantially with the movement of any native resident or migratory wildlife species or with established native resident or migratory wildlife corridors. Therefore, a significant impact could occur.

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Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

4.4-12 Implement Mitigation Measure 4.4-3.

4.4-13 Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Based on the analysis below and with
implementation of mitigation, the impact is less than
significant.

The following discussion includes both a project-level and program-level analysis of potential impacts that could occur to protected trees. Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not conflict with a local policy or ordinance protecting biological resources.

Industrial Park
As shown in Figure 4.4-4, the industrial park footprint portion of the project site contains 11 trees. In addition, a cluster of seven trees occurs along the southern boundary of Parcel 5, which is contiguous with Parcel 8, a nonparticipating parcel. As none of the trees are located in a City park, on real property the City owns in fee, or within a public ROW, none of the trees would qualify as a protected City Tree.

However, the on-site trees could potentially qualify as a Private Protected Tree, which the City defines as a tree on private property that is designated by City Council resolution to have special historical value, special environmental value, or significant community benefit, as well a tree that has a DSH of 24 inches or more and is located on private property that is undeveloped or does not include any single unit or duplex dwellings. Further analysis would be required to confirm if the on-site trees meet the definition of a Private Protected Tree, as established by Sacramento City Code Section

12.56.020.

The City requires a Tree Permit to perform any activity, not including routine maintenance, that could adversely impact the health of a City Tree or Private Protected Tree. To address the potential impact, the proposed project would be required to obtain a Tree Permit in accordance with the requirements set forth in Sacramento City Code Chapter 12.56, pay all applicable fees, and comply with the provisions set forth therein by said permit.

Based on the above, without compliance with requirements set forth by Sacramento City Code Chapter 12.56, development of the proposed industrial park could conflict with a local policy or ordinance protecting biological resources, such as a tree preservation policy or ordinance, and a significant impact could occur.

Nonparticipating Parcels
Various trees occur in and along the boundaries of the nonparticipating parcels that could be developed in the future with industrial uses. As such, prior to the development Draft EIR
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of the nonparticipating parcels, a tree survey would be required to be conducted in order to confirm the presence of trees that meet the definitions of a City Tree or Private Protected Tree, as established by Sacramento City Code Section 12.56.020. Any such trees within areas proposed for disturbance as part of development of the nonparticipating parcels would require a Tree Permit from the City of Sacramento Community Development Department to address potential impacts to such trees.

Future development projects would also be required to pay all applicable fees and comply with the provisions set forth therein by said permit, in accordance with Sacramento City Code Chapter 12.56.

Based on the above, without compliance with requirements set forth by Sacramento City Code Chapter 12.56, future development of nonparticipating parcels could conflict with a local policy or ordinance protecting biological resources, such as a tree preservation policy or ordinance, and a significant impact could occur.

Conclusion
Based on the above, without compliance with requirements set forth by Sacramento City Code Chapter 12.56, development of the proposed industrial park and future development of nonparticipating parcels could conflict with a local policy or ordinance protecting biological resources, such as a tree preservation policy or ordinance, and a significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

Industrial Park

4.4-13(a) Prior to the issuance of any grading permit and commencement of ground-disturbing activities, the project applicant shall hire a qualified arborist to evaluate all trees within areas proposed for disturbance to confirm if the trees meet the definition of a Private Protected Tree, as set forth by Sacramento City Code Section 12.56.020. Results of the tree survey shall be submitted for review and approval to the City of Sacramento Department of Public Works’ Urban Forestry section.

Should any on-site tree that would be potentially impacted by the proposed project be found to qualify as a Private Protected Tree, the project applicant shall obtain a Tree Permit from the City of Sacramento Community Development Department and comply with the permit requirements in effect at the time of project grading for removal, pruning, or soil disturbance within the canopy dripline of a Private Protected Tree.

Nonparticipating Parcels

4.4-13(b) As part of any application associated with development of the nonparticipating parcels, the applicant shall hire a qualified arborist to conduct a tree survey of areas proposed for disturbance to identify any trees that meet the definition of a Private Protected Tree, as established by Sacramento City Code Section 12.56.020. A report detailing the results of the survey shall be submitted for review and approval to the Draft EIR
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City of Sacramento Community Development Department. If protected trees are not identified, further mitigation shall not be required.

4.4-13(c) If protected trees are identified in areas proposed for disturbance of nonparticipating parcels, the applicant shall implement Mitigation Measure 4.4-13(a).

4.4-14 Conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan.

Based on the analysis below, the impact is less than
significant.

A portion of the project site is within the Natomas Basin HCP permit area, which includes portions of both the proposed industrial park and the nonparticipating parcels.

However, all development facilitated by the proposed project would be subject to the applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to address direct impacts to Covered Species that could occur as a result of project construction activities. Therefore, the following discussion includes both a project-level and program-level analysis of potential impacts that could occur from development of the proposed industrial park and nonparticipating parcels.

Because installation of the proposed off-site force main would occur either in existing roadway ROW or in other previously disturbed areas, construction of the off-site force main alignment would not conflict with the provisions of the Natomas Basin HCP.

Industrial Park and Nonparticipating Parcels
Under the Natomas Basin HCP, mitigation fees for land acquisition, enhancement, and management and monitoring activities are assessed on new development within the HCP permit area. Fees are paid on the basis of a one-time, up-front fee levied upon an authorized development site that is subject to mitigation based upon a 0.5:1 mitigation ratio.

The mitigation fee consists of the following five components: Land Acquisition Fee Component, Restoration and Enhancement Fee Component, Administration and Operations and Maintenance (O&M) Fee Component, O&M Endowment Fund Fee Component, and Supplemental Endowment Fund Fee Component. In addition to the mitigation fee, land dedication is required for any project of more than 50 acres; however, land dedicated is in lieu of paying the Land Acquisition Fee Component of the mitigation fee. For projects 50 acres or less, the full mitigation fee is required to be paid; however, land dedication is not required.

As previously discussed, development of the proposed industrial park and nonparticipating parcels, regardless of a parcel’s location within or outside of the Natomas Basin HCP permit area, would be subject to the applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to address direct impacts to Covered Species. With respect to payment of the Natomas Basin HCP mitigation fees, only site development occurring within the Natomas Basin HCP permit area would be required to pay the fees. However, to ensure the proposed project addresses potential impacts to Swainson’s hawk foraging habitat in on-site areas outside of the Natomas Basin HCP permit area, Mitigation Measure 4.4-5(b) Draft EIR
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requires the project applicant to pay the mitigation fees, should a portion of the City’s surplus HCP coverage acreage be made available to the project.

Because the Natomas Basin HCP’s Operating Conservation Plan (OCP) is based upon the City limiting total development to 8,050 acres within the City’s portion of the HCP permit area, approval by the City of future urban development beyond the 8,050 acres would trigger a re-evaluation of the Natomas Basin HCP, a new effects analysis, potential amendments, and/or revisions to the Natomas Basin HCP and incidental take permits, a separate conservation strategy, and the need for the City to obtain a new incidental take coverage for that additional development.

As noted above, the City’s annual reports have shown surplus acreage available within the 8,050 acres of development allowed under the City’s incidental take permit. Due to this surplus acreage, the City could approve the project without exceeding the 8,050-acre development acreage limit. Nonetheless, this EIR includes the following analysis of effects on the Natomas Basin HCP that could result from implementation of the proposed project.

Potential Effects to Natomas Basin HCP Conservation Strategy Key Components
The project site was evaluated to identify the potential effects of the proposed development on key components of the Natomas Basin HCP (taken from Chapter IV, Section C.1 of the Natomas Basin HCP), which were developed to mitigate for 17,500 acres of urban development projected in 2003. The Natomas Basin HCP key components are as follows:
a. Basis for 0.5:1 mitigation ratio (Section IV.C.1.a); b. Preparation of site-specific management plans (SSMPs) (Section IV.C.1.b); c. Buffers within the reserve lands (Section IV.C.1.c); d. Connectivity (Section IV.C.1.d);
e. Foraging habitat (Section IV.C.1.e); and
f. 2,500-acre/400-acre minimum habitat block size requirements (Section IV.C.1.f).

The goal of the Natomas Basin HCP is the conservation of Covered Species through the acquisition (conservation easement or fee title), protection, and enhancement of existing habitats in the Natomas Basin, minimizing impacts of Covered Activities, including development activities, water facility maintenance, and reserve management activities, and focusing upon the preservation of the overall habitat values in the Natomas Basin. The Natomas Basin HCP was developed to allow some urban development to occur, while ensuring that habitat values are maintained and increased, to the maximum extent practicable, within the Natomas Basin. The Natomas Basin HCP sets forth guidelines and practices including the size and acreage of reserves to be established, acquisition criteria for upland and wetland areas to be acquired and managed by the Natomas Basin Conservancy, and reserve management practices to be employed to ensure successful habitat enhancement to support the Covered Species.

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The project site supports suitable habitat for several Natomas Basin HCP Covered Species; however, the project site is adjacent to and largely surrounded by existing urbanized areas including residential neighborhoods, I-5, Metro Air Park, and the Sacramento International Airport master plan area.

The potential effects related to the development of the proposed project on key Natomas Basin HCP components are discussed in the following sections.

Mitigation Ratio
The Natomas Basin HCP proposed a minimum 0.5:1 mitigation ratio to be applied to authorized development covered under the Natomas Basin HCP. In describing the basis for the 0.5:1 mitigation ratio, the Natomas Basin HCP states that the 0.5:1 ratio mitigates the impacts of the incidental take authorized under the Natomas Basin HCP, because much of the land to be developed does not provide habitat or provides only marginal habitat and the Natomas Basin Conservancy-managed reserves will provide habitat of higher quality than the eliminated habitat. The proposed project would not alter the habitat value of land authorized for development under the Natomas Basin HCP, and as further discussed below, would not adversely affect the habitat value of existing Natomas Basin Conservancy reserves established under the Natomas Basin HCP. Therefore, the proposed project would not affect the efficacy of the 0.5:1 mitigation ratio identified by the Natomas Basin HCP.

The proposed project would not alter the habitat value of land authorized for development under the Natomas Basin HCP and would not adversely affect the habitat value of the Natomas Basin Conservancy reserves established under the Natomas Basin HCP. Therefore, the proposed project would not affect the effectiveness of the

0.5:1 mitigation ratio for the 17,500 acres of urban development authorized by the Natomas Basin HCP.

Site-Specific Management Plan
Development of the proposed project is not anticipated to adversely affect any SiteSpecific Management Plans (SSMPs) for existing or future Natomas Basin Conservancy reserves in the vicinity of any of the properties associated with the project. The Natomas Basin Conservancy prepares and implements an SSMP for each reserve that addresses the specific resources and habitat values of each reserve site, and how they will be managed in support of the goals and objectives of the Natomas Basin HCP. SSMPs for each existing Natomas Basin Conservancy reserve are currently designed to maximize benefits to Covered Species using the resources within that individual reserve or reserve block and incorporate adaptive management strategies. Thus, changes in land use outside of an existing reserve are unlikely to necessitate changes to an SSMP. Although the proposed project would reduce available Swainson’s hawk foraging habitat within the project site, which is in the vicinity of two existing Natomas Basin Conservancy reserves, the external factor would not alter the site-specific management of either nearby reserve. The two reserves include the 106-acre “Rosa East” property, which is part of the Natomas Basin HCP reserve system managed by the Natomas Basin Conservancy, and the approximately 100-acre “Rosa Central” reserve, which is also part of the reserve system. Both lie south of the project site on the opposite side of the West Drainage Canal (see Appendix A, Figure 7, Natomas Basin Conservancy Mitigation Lands).

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Changes in land use outside of an existing Natomas Basin Conservancy reserve because of the development of the proposed project are unlikely to necessitate changes to existing SSMPs.

Buffers within Reserve Lands
Pursuant to the Natomas Basin HCP, internal buffers ranging from 30- to 70-foot-wide strips of native or ruderal vegetation within the edge of the reserve are often incorporated into the Natomas Basin Conservancy reserves to minimize the effects of incompatible adjoining land uses (see Natomas Basin HCP, Section IV.C.1.c). The Natomas Basin HCP provides that such buffers are to be “considered during the preparation of a site-specific management plan for each reserve site,” and anticipates that such buffers would be used for reserve lands that include improved wetland habitat.

The Natomas Basin Conservancy reserve lands closest to the project site do not currently include improved wetland habitats. In any case, the Natomas Basin HCP provides flexibility for adjusting buffer width within reserve areas depending on conditions. The proposed project would not affect the Natomas Basin Conservancy’s ability to buffer future wetland uses from the project site within the existing reserve lands pursuant to the Natomas Basin HCP.

In addition, areas proposed for disturbance closest to the existing Natomas Basin Conservancy reserve properties are planned to be located more than 300 feet from the West Drainage Canal that separates the project site from the reserves. Thus, planned urban development within the project site would not alter the effectiveness of buffers within the reserve lands. As a result, implementation of the proposed project would not affect buffers within existing Natomas Basin Conservancy reserves.

Habitat Connectivity
The proposed project is not expected to significantly affect the connectivity of reserve habitat, relative to avian species covered under the Natomas Basin HCP due to their highly mobile and migratory nature. Most of the avian species that frequent the Natomas Basin and the Natomas Basin Conservancy reserves are migratory in nature, and effects on habitat connectivity of reserves for avian species are not anticipated due to the development of the project site.

The Natomas Basin HCP emphasizes maintaining connectivity of aquatic habitat between Natomas Basin Conservancy reserves to facilitate giant garter snake movement within the Natomas Basin. The species is focal for two reasons: (1) giant garter snake is the most prevalent Covered Species within the Natomas Basin that requires land/water connectivity to travel within the basin, and (2) if adequate connectivity is provided for giant garter snake, then other Covered Species are anticipated to also be afforded adequate opportunities to migrate within the Natomas Basin.

Aquatic habitat in the Natomas Basin consists primarily of drainage and flood control channels. RD 1000, a public agency, operates the primary drainage canals within the Natomas Basin and is responsible for conveying and pumping non-urban stormwater runoff from the Natomas Basin. Runoff from agricultural lands within the Natomas Draft EIR
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Basin flows into numerous local drainage ditches that ultimately flow into the primary RD 1000 canals. RD 1000’s primary system of interior drains includes the following:
 The East Drainage Canal conveys drainage water from the northern and eastern Natomas Basin to its confluence with the Main Drainage Canal northwest of the I-80/I-5 interchange;
 The West Drainage Canal conveys drainage water from the western Natomas Basin northwest of Sacramento International Airport to its confluence with the Main Drainage Canal. Fisherman’s Lake, a natural slough, is a portion of the West Drainage Canal. The West Drainage Canal runs along the southern boundary of the project site at its closest point;
 The Main Drainage Canal conveys the combined flows of the East and West Drainage Canals from their confluence northwest of the I-80/I-5 interchange through portions of Willow Creek and Metro Center south of I-80; and  The Cross Canal conveys drainage water from central portions of Sutter County westward to the Sacramento River.

In addition, Natomas Central Mutual Water Company (NCMWC), a private water company, provides irrigation water through water diversions at five locations along the Sacramento River and the Natomas Cross Canal and distributes the water throughout the Natomas Basin through a series of canals and pump stations. The drainage and irrigation canals form a network throughout the Natomas Basin and provide a series of interconnected corridors for aquatic species to disperse and forage.

With respect to the Lone Tree Canal (Canal-2), the canal is an indirect tributary to the Sacramento River by way of the West Drainage Canal. In the Natomas Basin, Lone Tree Canal collects drainage flows and runoff from adjacent properties, including Metro Air Park and the Northlake subdivision site (Greenbriar), and flows southward, where flows are conveyed under I-5 through a multi-cell concrete box culvert, through the project site to the West Drainage Canal. As shown in Figure 3-3 in the Project Description chapter of this EIR, the project would include a new bridge crossing over the Lone Tree Canal as part of construction of the new Airport South Industrial Drive.

The bridge would include installation of a new culvert to the canal. Thus, the proposed project could temporarily impede giant garter snakes’ ability to migrate through the site by way of the Lone Tree Canal. However, as discussed under Impacts 4.4-3 and 4.4- 12, through compliance with the Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP related to giant garter snake, potential impacts to the species, including those associated with the species’ use of the on-site canals as migratory corridors, would be reduced to a less-than-significant level. As a result, implementation of the proposed project would not affect habitat connectivity within the Lone Tree Canal.

Swainson’s Hawk Foraging Habitat
Based on the analysis in this chapter, the proposed project would reduce the overall upland land cover in the Natomas Basin that is capable of providing foraging habitat for Swainson’s hawk by approximately 436.5 acres (which does not include the 37.9 acre Caltrans I-5 fee title ROW portion of the project site that does not provide Swainson’s hawk foraging habitat). The majority of the project’s development area is currently zoned for agriculture. However, the success of the Natomas Basin HCP does Draft EIR
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not require a certain amount of agricultural land remaining in the basin. In addition, the project site is not within the Swainson’s Hawk Zone established by the Natomas Basin HCP.

The success of the Natomas Basin HCP does not require a certain amount of agricultural land remaining in the basin. For example, portions of the project site, along with other “uncommitted” agricultural acreage, were acknowledged by the Natomas Basin HCP to provide foraging habitat for Swainson’s hawk, but such “existing baseline foraging habitat is not considered mitigation under the [Natomas Basin HCP]” (see Natomas Basin HCP, Section IV-13). Similarly, CDFW found that the impacts of development authorized by the Natomas Basin HCP were fully mitigated by the implementation of the Natomas Basin HCP avoidance and minimization measures, as well as the “establishment, enhancement, and active management of as much as 8,750 acres of high-quality reserve habitat in perpetuity designed and managed specifically for the benefit of the Covered Species” (see Natomas Basin HCP California Endangered Species Act Findings). CDFW’s analysis did not mention, nor rely on, any additional “uncommitted” acreage remaining in agriculture.

Swainson’s hawk is a focal species that shares habitat requirements with numerous Natomas Basin HCP Covered Species in addition to other special-status species not covered by the Natomas Basin HCP. The effects of the proposed project on foraging habitat would not alter the viability of any of the populations of Natomas Basin HCP Covered Species.

Minimum Block Size
The Natomas Basin HCP stipulates that, by the end of its 50-year lifespan, the Natomas Basin Conservancy reserve system will have reached 8,750 acres with one habitat block at least 2,500 acres in size and the balance of reserve lands in habitat blocks of at least 400 acres in size. The Natomas Basin HCP provides the following basis for the size requirements:

1. Large blocks minimize the “perimeter effect”;

2. Large blocks promote biodiversity by allowing multiple species and niches to occupy the site;

3. The benefit to the genetic diversity of dispersing interconnected reserves throughout the Natomas Basin; and

4. The 400-acre reserve size is considered the minimum size to allow the persistence of Covered Species.

Implementation of the proposed project would not prevent the Natomas Basin Conservancy from establishing 8,750 acres of reserves in the Natomas Basin, as identified in the Natomas Basin HCP, as the project site constitutes only 0.89 percent of the acreage in the Natomas Basin and the Natomas Basin Conservancy is well on its way to securing all the reserve lands required to meet its obligations.

The Natomas Basin HCP is now about 20 years into its 50-year timeframe and has already successfully completed its largest land acquisition milestone by completing the 2,500-acre block requirement (see Table 4.4-3). The requisite 2,500-acre block is made up of the following preserves, as shown on the Natomas Basin HCP 2023 Base Draft EIR
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Map. Figure 4.4-5 provides a visual representation of the preserves in relation to project site.

Table 4.4-3
Natomas Basin HCP 2,500-Acre Block
Tract Acquisition Date Acres

4. Bennett North 5-17-99 227

5. Bennett South 5-17-99 132

7. Lucich South 5-18-99 352

14. Atkinson 6-12-03 181

15. Ruby Ranch 6-23-03 91

16. Huffman West 9-30-03 158

17. Huffman East 9-30-03 136

21. Bolen North 4-29-05 114

22. Bolen South 4-29-05 102

23. Vestal 9-12-05 95

24. Bolen West 9-1-06 155

25. Nestor 9-1-06 233

31. Lauppe South 6-30-20 172

32. Verona (CE) 7-2-20 116

34. Willey 10-19-20 108

36. Lauppe North 1-5-22 185
Total 2,557
Source: The Natomas Basin Conservancy, 2023 Base Map, 2023.

With regard to habitat blocks of at least 400 acres, as shown on Figure 4.4-5, the nearest Natomas Basin HCP habitat blocks to the project site include the Rosa East, Rosa Central, Souza, and Natomas Farms reserves totaling approximately 301 acres, and the Cummings and Rudin reserves, totaling approximately 109 acres.

The project site does not include the property lying between the aforementioned two nearby clusters of reserve land and would not preclude the future acquisition of connectivity between the two areas by the Natomas Basin Conservancy.

Conclusion
Thus, when looking at all of the above factors, the proposed project would not reduce the effectiveness of the Natomas Basin HCP’s OCP. In addition, with respect to compliance with the Natomas Basin HCP, although only a portion of the project site is within the Natomas Basin HCP permit area, this chapter requires all project construction activities to comply with the applicable Take Avoidance, Minimization, and Mitigation Measures set forth by the Natomas Basin HCP to mitigate potential impacts to a less-than-significant level. Thus, compliance with the aforementioned measures would provide benefits to the Natomas Basin HCP’s Covered Species, as discussed above. Based on the above, the proposed project would not conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or State habitat conservation plan, and a less-than-significant impact would occur.

Mitigation Measure(s)
None required.

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Figure 4.4-5
Natomas Basin Conservancy 2023 Base Map
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Cumulative Impacts and Mitigation Measures
As defined in Section 15355 of the CEQA Guidelines, “cumulative impacts” refers to two or more individual effects which, when considered together, are considerable, compound, or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.

The geographic scope for the cumulative biological resources analysis generally includes buildout of the City of Sacramento General Plan policy area, including the Northlake (Greenbriar) subdivision to the north of the project site, as well as the sites of the Metro Air Park, the Upper Westside Specific Plan (formerly referred to as “The Boot” precinct area of the Natomas Joint Vision Plan), the Grandpark Specific Plan (formerly North Precinct per the Natomas Joint Vision Plan), the Sacramento International Airport Master Plan, and the Elkhorn Boulevard Extension Project. For further details related to the cumulative setting of the proposed project, refer to Chapter 6, Statutorily Required Sections, of this EIR.

4.4-15 Cumulative loss of habitat for special-status species. Based on the analysis below and with implementation of mitigation, the project’s incremental contribution to the significant cumulative impact is less than cumulatively considerable.

Pursuant to the City of Sacramento MEIR, the City’s General Plan policy area encompasses a 102-square-mile area. As detailed in the MEIR, although the majority of the policy area is developed with residential, commercial, and other urban uses, valuable natural habitat still exists. Such habitats are located primarily outside the City boundaries in the northern, southern and eastern portions of the policy area, but also occur within the policy area along river and stream corridors and on a number of undeveloped parcels. Habitats present include annual grasslands, riparian woodlands, oak woodlands, riverine, ponds, freshwater marshes, seasonal wetlands, and vernal pools.

The MEIR evaluated the potential for development facilitated by buildout of the General Plan policy area to contribute to regional loss of special-status plant or wildlife species or their habitat under Impact 4.3-11 (of the MEIR) and concluded that even with implementation of applicable General Plan policies, a significant and unavoidable impact would occur. As detailed therein, as development in the City of Sacramento and in the greater Sacramento Valley continues, habitat for sensitive plant and wildlife species native to the region, including those species listed under FESA and CESA and those individuals identified by State and federal resources agencies as Species of Concern or Fully Protected, would be lost through conversion of existing open space to urban development. Additionally, future development of the Northlake subdivision, the Metro Air Park, the Upper Westside Specific Plan, the Grandpark Specific Plan, the Sacramento International Airport Master Plan, and the Elkhorn Boulevard Extension Project, all located within the Natomas Basin, would further reduce the availability of habitat to accommodate protected plant and wildlife species, relative to existing levels. In addition, potential jurisdictional wetlands, riparian habitat, and designated Sensitive Natural Communities occur throughout the policy area and Draft EIR
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potentially occur in the aforementioned development sites, which could further result in the loss of regional biological resources as future development occurs.

However, with respect to cumulative development within the more immediate project vicinity, the Natomas Basin HCP is specifically designed to address potential impacts to biological resources on a cumulative scale within the basin. The Natomas Basin HCP is a multi-species conservation program adopted for the purposes of minimizing and mitigating the loss of habitat values and incidental take of Covered Species resulting from urban development, operation and maintenance of irrigation and drainage systems, and various activities associated with the Natomas Basin Conservancy’s management of reserves established under the Natomas Basin HCP.

Through compliance with applicable Take Avoidance, Minimization, and Mitigation Measures, potential impacts to biological resources covered under the Natomas Basin HCP within the permit area are reduced to a less-than-significant level. In addition, as discussed under Impact 4.4-14, the Natomas Basin HCP is now about 20 years into its 50-year timeframe and has already successfully completed its largest land acquisition milestone by completing the 2,500-acre block requirement (see Table 4.4- 3). Thus, by the end of the Natomas Basin HCP’s lifespan, the Natomas Basin Conservancy reserve system is anticipated to reach 8,750 acres, with one habitat block at least 2,500 acres in size and the remaining balance of reserve lands in habitat blocks of at least 400 acres in size.

With respect to the proposed project, the project site is not currently within the City limits. Through approval of the proposed Sphere of Influence (SOI) Amendment and Annexation, the project site would be annexed into the City of Sacramento. As such, the MEIR’s evaluation of potential impacts to biological resources did not include consideration of the project site. As discussed above, the site contains perennial rye grass field, upland mustards or star-thistle fields, developed/disturbed land covers, open water, unknown row crops, poison hemlock or fennel patches, Himalayan blackberry – rattlebox – edible fig riparian scrub, Goodding’s willow – red willow riparian woodland and forest, valley oak riparian forest woodland, hardstem and California bulrush marsh, and cattail marsh. In addition, a total of 2.018 acres of potential jurisdictional tributary drainages and other waters of the U.S. were identified within the project site. Development of the proposed industrial park and future development of the nonparticipating parcels could result in potential impacts to portions of the foregoing areas. As discussed throughout this chapter, the above areas represent potential habitat for various special-status species listed in Table 4.4-2.

However, this chapter provides a wide range of mitigation to minimize all potential adverse effects to habitat for special-status species that could occur as part of the proposed project. With respect to potential impacts that could occur to special-status plant and wildlife species, mitigation measures would require implementation of applicable Natomas Basin HCP Take Avoidance, Minimization, and Mitigation Measures for Covered Species to address potential impacts that could occur as a result of all project-associated construction activities, regardless of whether they occur within or outside of the Natomas Basin HCP permit area. Compliance with the aforementioned Take Avoidance, Minimization, and Mitigation Measures would reduce potential impacts to protected plant species, giant garter snake, northwestern pond turtle, Swainson’s hawk, burrowing owl, and loggerhead shrike to a less-thansignificant level.

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For species not covered under the Natomas Basin HCP, such as northern harrier, white-tailed kite, song sparrow, and other nesting birds and raptors protected under the MBTA and CFGC, mitigation measures are also included to address potential impacts. Such measures necessitate preconstruction surveys to identify active nests and further provisions should active nests be on-site or in areas immediately adjacent to the site. In addition, in the event that a portion of the City’s surplus HCP coverage acreage is not available to the project to address potential impacts to on-site foraging habitat outside of the Natomas Basin HCP permit area, Mitigation Measure 4.4-5(b) requires the project to preserve Swainson’s hawk foraging habitat elsewhere, in accordance with applicable CDFW guidelines. Furthermore, potential impacts to riparian habitat or other Sensitive Natural Communities are addressed through mitigation requiring compliance with Section 1600 of the CFGC. Finally, potential impacts to protected wetlands are addressed through mitigation requiring compliance with Sections 404 and 401 of the CWA. Overall, with incorporation of the mitigation measures set forth herein, potential impacts to biological resources that could occur as a result of the proposed project would all be reduced to a less-than-significant level.

As such, the proposed project would not result in substantial adverse effects to biological resources protected under CEQA.

With respect to potential impacts that could occur to biological resources as part of development of buildout of the General Plan policy area including the Northlake subdivision or areas within the unincorporated Sacramento County portions of the Natomas Basin, such as the Metro Air Park (which is subject to its own Metro Air Park HCP), the Upper Westside Specific Plan, the Grandpark Specific Plan, the Sacramento International Airport Master Plan, and the Elkhorn Boulevard Extension Project, such areas in the cumulative setting would be subject to applicable policies, regulations, and standards set forth at the federal, State, and local level, including preconstruction surveys, compliance with CFGC Section 1600, and Sections 404 and 401 of the CWA. Therefore, all potential impacts that could occur through development in the cumulative setting would be reduced through applicable regulatory requirements.

Information regarding several past, present, and future projects in the Natomas Basin is provided below, although the level of detail available varies by project.

Northlake Subdivision
The Northlake subdivision is located in the City of Sacramento, in the central portion of the Natomas Basin at the intersections of I-5 and SR 99. The Northlake subdivision received first-tier entitlements for development in 2008 and a Tentative Map for the first phase of development in 2017. The 577-acre site includes residential, commercial, and public land uses, and is partially built out. The project included on-site and off-site habitat reserves at greater than a 1:1 ratio.

The Northlake subdivision is not within the City’s permit area under the Natomas Basin HCP, and its on- and off-site reserves were in addition to the reserve system originally contemplated for the NBHCP. Thus, a project-level effects analysis was prepared to evaluate the Northlake subdivision’s potential effects on the Natomas Basin HCP Covered Species and their habitats.

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Metro Air Park
The Metro Air Park consists of the development of approximately 1,892 acres with a combination of commercial, industrial, manufacturing, and airport-related land uses in unincorporated Sacramento County. The Metro Air Park is located generally east of the Sacramento International Airport, north of I-5, and west/northwest of the Northlake subdivision. Development within the Metro Air Park is ongoing, and is subject to the Metro Air Park HCP, which was developed consistent with the Natomas Basin HCP.

Reserve lands obtained pursuant to the Metro Air Park HCP are managed by the Natomas Basin Conservancy along with those reserve lands acquired under the Natomas Basin HCP.

Upper Westside Specific Plan
Another project in the region, the Upper Westside Specific Plan, encompasses approximately 2,066 acres in the unincorporated Natomas community of Sacramento County, approximately 3.5 miles from downtown Sacramento. The Upper Westside Specific Plan area is bounded by I-80 to the south, the West Drainage Canal to the east, Fisherman’s Lake Slough to the north, and Garden Highway to the west. The Upper Westside Specific Plan is located outside of the County’s Urban Policy Area and Urban Services Boundary, but is bounded on three sides by the City of Sacramento, bordering the communities of North and South Natomas. Similar to the Grandpark Specific Plan, publicly available information regarding the potential biological impacts of the Upper Westside Specific Plan is not available. The Notice of Preparation (NOP) states that the EIR will analyze impacts to special-status species and habitats, as well as analyze potential conflicts with adopted HCPs.

Grandpark Specific Plan
The Grandpark Specific Plan is an approximately 5,675.6-acre mixed-use project located in the Natomas community of unincorporated northwestern Sacramento County, south of Sutter County and southwest of Placer County, east of SR 99, and north of Elkhorn Boulevard and the City of Sacramento. The Grandpark Specific Plan includes a broad range of residential land uses, as well as commercial and employment land uses, schools, parks, and open space to support the residential land uses. The Grandpark Specific Plan’s potential impacts on biological resources are not yet publicly available, although the NOP indicated the project’s EIR would be used as part of pursuing a Section 10 consultation with the USFWS, as well as an incidental take permit from CDFW. While analysis of potential impacts is not available, Sacramento County, USFWS and CDFW are reasonably assumed to ensure that the project minimizes and fully mitigates its impacts to special-status species and habitats, as well as impacts related to conflicts with the Natomas Basin HCP.

Sacramento International Airport Master Plan
The Sacramento International Airport Master Plan, most recently updated in 2022, includes the major improvements that are needed at the Sacramento International Airport over a 20-year planning horizon. The improvements are safety-, security-, and capacity-enhancement projects that enable the Sacramento County Airport System to meet customer service goals at increased levels of activity in passengers, air cargo, and aircraft operations.

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The Sacramento International Airport Master Plan defines planned projects within Sacramento County-owned lands over approximately a 20-year horizon, including terminal expansions, transportation improvements, and related projects.

Environmental impacts associated with the projects were evaluated and addressed most recently in a Supplemental EIR certified by Sacramento County in 2022.

Conclusion
As further discussed in Chapter 6 of this EIR, CEQA Guidelines Section 15064, Subdivision (h)(5) states, “[…]the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.” Therefore, even where cumulative impacts are significant, any level of incremental contribution is not necessarily deemed cumulatively considerable (see also CEQA Guidelines Section 15130). In addition, the courts have explicitly rejected the notion that a finding of significance is required simply because a proposed project would result in a net loss of habitat. “[M]itigation need not account for every square foot of impacted habitat to be adequate. What matters is that the unmitigated impact is no longer significant,” (Save Panoche Valley v. San Benito County [2013] 217 Cal.App.4th 503, 528, quoting Banning Ranch Conservancy v. City of Newport Beach [2012] 211 Cal.App.4th 1209, 1233).

The above discussion provides substantial evidence that, while the combined effects on the habitats of special-status species resulting from approved/planned development throughout the cumulative setting may be considered significant, the proposed project’s incremental contribution to the potentially significant cumulative effect would be reduced with implementation of the project-specific mitigation measures required in this EIR.

Based on the above, cumulative conditions may result in a significant cumulative impact related to the loss of special-status species habitat in the vicinity of the project.

Although habitat impacts covered by the Natomas Basin HCP or Metro Air Park HCP are mitigated under the foregoing HCPs, and habitat impacts associated with buildout of the Northlake subdivision were separately addressed through project-specific mitigation measures, the City does not control mitigation for ongoing and future projects in unincorporated Sacramento County. Therefore, the overall habitat impact would be considered significant. Therefore, the proposed project’s contribution to the significant impact could be cumulatively considerable.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less than cumulatively considerable level.

Industrial Park

4.4-15(a) Implement Mitigation Measures 4.4-1(a) and 4.4-1(b), 4.4-3, 4.4-4(a),

4.4-5(a) and 4.4-5(b), 4.4-6, 4.4-8, 4.4-9(a) and 4.4-9(b), 4.4-10(a), 4.4- 11(a) through 4.4-11(c), and 4.4-13(a).

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Nonparticipating Parcels

4.4-15(b) Implement Mitigation Measures 4.4-1(a) and 4.4-1(b), 4.4-3, 4.4-4(a),

4.4-5(a) and 4.4-5(b), 4.4-6, 4.4-8, 4.4-9(a) and 4.4-9(b), 4.4-10(b) and

4.4-10(c), 4.4-11(e) and 4.4-11(f), and 4.4-13(b) and 4.4-13(c).

4.5 CULTURAL RESOURCES

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4.5.1 INTRODUCTION
The Cultural Resources chapter of the EIR addresses known and unknown historic and prehistoric cultural resources in the vicinity of the project area. Cultural resources can be categorized into prehistoric or historic resources. Prehistoric resources are those sites and artifacts of or related to a time period generally prior to contact with people of European descent. Historic resources include structures, features, artifacts, and sites that date from Euroamerican settlement of the region. The chapter summarizes the existing setting with respect to cultural resources, identifies thresholds of significance, evaluates project impacts to such resources, and sets forth mitigation measures. Information presented in the chapter is primarily drawn from the Cultural Resources Study prepared by Tom Origer & Associates,1 as well as the City of Sacramento 2040 General Plan2
and the City of Sacramento 2040 Master EIR (MEIR).3
Tribal cultural resources are addressed in Chapter 4.13, Tribal Cultural Resources, of this EIR. In addition, as discussed further in Chapter 3, Project Description, of this EIR, the project site is divided into two portions: the industrial park, which consists of the majority of the western portion and the northeast corner of the overall site, and the nonparticipating parcels, primarily located in the southeastern portion of the overall site. While the proposed project would require approval of a Sphere of Influence (SOI) Amendment and Annexation of the entire project site into the City limits, only the industrial park is currently proposed for development. In addition, the proposed project would include construction of an off-site force main to convey wastewater generated from the proposed uses to the 48-inch Sacramento Area Sewer District (SacSewer) North Natomas interceptor line in East Commerce Way.

4.5.2 EXISTING ENVIRONMENTAL SETTING
The Central Valley of California contains a rich cultural resource heritage that includes archeological and historical sites and resources. Archaeological materials, including human burials, have been found throughout the City and Sacramento County. Areas of high sensitivity for archaeological resources, as identified in the 2040 General Plan Background Report, are generally located within close proximity to the rivers, creeks and sloughs. In addition, recent discoveries during infill construction in downtown Sacramento have shown that the downtown area is highly sensitive for both historic- and prehistoric-period archaeological resources. Given the rich heritage of the area, many archeological and historical sites and resources may remain undiscovered within the City.

The 474.4-acre project site is undeveloped and consists entirely of agricultural land. The project site lies within the American Basin of the Sacramento Valley. The American Basin is a low-lying 1 Tom Origer & Associates. Cultural Resources Study for the Airport South Industrial Park Project. March 7, 2022. 2 City of Sacramento. Sacramento 2040 General Plan. Adopted February 27, 2024. 3 City of Sacramento. Sacramento 2040 General Plan and Climate Action & Adaptation Plan Master Environmental Impact Report. August 2023.

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geological depression in the plains bounded by the Feather River to the north, the Sacramento River to the west, the Sierra foothills to the east, and the American River on the south. The project site is situated on generally level land with a slope of three percent or less. The area surrounding the project site has remained rural until the relatively recent spread of commercial, industrial, and residential development.

The following sections provide further details regarding the prehistoric overview, ethnographic overview, and historic overview of the project area, as well as a description of any identified cultural resources associated with the project site.

Prehistoric Overview
The concept of prehistory refers to the period of time before events were recorded in writing and varies worldwide. Because a written record does not exist, the understanding of California prehistory relies on archaeological materials and oral histories passed down through generations. Early archaeological research in Central California began with the work of Max Uhle and Nels Nelson. Uhle is credited with the first scientific excavation in California with his work at the Emeryville Shellmound in 1902, and Nelson spent several years (1906 to 1908) surveying the San Francisco Bay margins and California coast for archaeological sites. In the 1930s, archaeologists began piecing together a sequence of cultures primarily based on burial patterns and ornamental artifact from sites in the lower Sacramento Valley. The cultural sequence became known as the Central California Taxonomic System (CCTS), which identified three culture periods termed the Early, Middle, and Late Horizons, but without offering date ranges.

Refinement of the CCTS became a chief concern of archaeologists as the century progressed.

In 1973, David Fredrickson developed a regional chronology that is still currently used, albeit modified for locality-specific circumstances. Fredrickson’s regional chronology shows that native peoples have occupied central California for over 11,000 years. In addition, Fredrickson defined cultural patterns pertinent to the Central Valley, known as the Windmiller, Berkeley, and Augustine patterns. After Fredrickson’s definition of cultural chronology and patterns, Rosenthal et al. examined the body of archaeological work conducted in the Central Valley and found that most of the substantial sites that would be able to provide chronological data over long periods had been excavated many years prior. Given little new information had been obtained to refine Fredrickson’s chronology, Rosenthal et al. were only able to summarize observations made to date. As devised by Rosenthal et al., and with the timeframes adjusted for modern calibration curves for radiocarbon dates, the chronological sequence for the Central Valley is: Paleo-Indian (11500 to 8550 cal [calibrated] B.C.), Lower Archaic (8550 to 5550 cal B.C.), Middle Archaic (5550 to 550 cal B.C.), Upper Archaic (550 cal B.C. to cal A.D. 1100), and Emergent or Late Prehistoric Period (cal A.D. 1100 to Historic Contact).

In 1960, the first study of obsidian hydration as a dating tool for archaeologists was published.

The study showed that the chemical composition of the obsidian and temperature affect the hydration process. In the 1980s, research into the obsidian hydration dating method was conducted for the North Bay Area which had four major obsidian sources. In 1987, Thomas Origer devised a hydration chronology for the North Bay Area. Origer was able to develop a hydration rate for Annadel and Napa Valley obsidian sources as a result of his study. Later, comparison constants were developed among the four primary obsidian sources in the North Bay Area. The concept of comparison constants allows for the calculation of dates from hydration band measurements taken from obsidian specimens from sources with unknown hydration rates.

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The development of obsidian hydration rates for central California obsidian sources has provided archaeologists the ability to obtain dates from sites that could not previously be dated due to the lack of diagnostic artifacts or organic material suitable for radiocarbon dating, and the previous chronology of the area was refined.

According to the City of Sacramento General Plan Background Report, the first settlements in the Sacramento Valley likely occurred during the late Pleistocene and early Holocene (14,000 to 8,000 B.P.) period. Sacramento’s location within a great valley and at the confluence of two rivers, the Sacramento River and the American River, shaped the early and modern settlements of the area. However, the archaeological record of such use is sparse. Paleo- Indian populations likely occupied the area with villages located near watercourses.

Ethnographic Overview
The project site is located in lands historically occupied by the Nisenan (also known as the Southern Maidu). Prior to Euro-American contact, Nisenan territory included the southern extent of the Sacramento Valley, east of the Sacramento River between the North Fork Yuba River and Cosumnes River on the north and south, respectively, and extended east into the foothills of the Sierra Nevada. For a full ethnographic overview of the project area, see Chapter 4.13, Tribal Cultural Resources, of this EIR.

Historic Overview
The project site is within the Sacramento Valley, which constitutes the northern portion of the Central Valley region. The earliest expeditions into the Central Valley were conducted by the Spanish during the late 18th and early 19th centuries. Spanish settlers navigated the waters of the Sacramento River searching for suitable sites to build new missions. Another early expedition through the Sacramento Valley by land was conducted by an American named Jedediah Smith in 1826. The trail he created became known as the Sacramento Trail and it was used for trade and travel.

John Sutter immigrated to the United States in 1834 from Switzerland. Two years later he arrived in California and into the company of Governor Juan Alvarado. Sutter told Alvarado that he was interested in settling on land along the Sacramento River. Likely due to concerns that the Russians and Americans would invade the land, Alvarado promised Sutter Mexican citizenship and land. Alvarado told Sutter to find the land he wanted, return to him within a year, and the land would be his. In September 1839, Sutter founded his fort. Sutter was granted Mexican citizenship and the rancho Nuevo Helvetia which totaled nearly 50,000 acres in size was established. Sutter’s Fort was the first major settlement in the lower Sacramento/upper San Joaquin valleys and was at a major crossroads for people traveling into and through California.

Spanish and Mexican settlers did little to alter the Delta’s landscape, but when California became a U.S. state, the federal law outlined in the Swamp and Overflowed Land Act of 1850 applied to the vast wetlands of the Delta. “Swamp and overflowed” land was a legal term used to identify land that was too wet to cultivate. The Swamp and Overflowed Land Act gave states the power to sell “swamp and overflowed” land and was designed to encourage the reclamation of the land and subsequent use. Review of historical maps shows that the project site was classified as swamp and overflowed land, and that most of the project site was once part of Fisherman’s Lake, which would have been the closest water source during prehistoric times.

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Reclamation District (RD) 1000 was formed by the California legislature in 1911, to allow for the reclamation of the American Basin for agricultural purposes. The Natomas Consolidated Company began the reclamation of tens of thousands of acres along the east side of the Sacramento River between the American and Feather Rivers. RD 1000 was constructed as a drainage system consisting of over 30 miles of main canals and 150 miles of ditches used for flood control as well as crop irrigation for nearly 87 square miles of land. Eventually, the reclamation efforts were confronted with continual flooding, which resulted in slower progress and rising costs associated with the project. Due to the lands not selling as hoped, and the federal government gearing up for World War I in 1914, the Natomas Consolidated Company could not keep up with expenses and reorganized in 1928 to form the Natomas Company. By 1955, the Natomas Company finally sold the rest of the reclaimed land, relinquishing the remaining control over the district to the landowners.

Historic period site indicators generally include: fragments of glass, ceramic, and metal objects; milled and split lumber; and structure and feature remains such as building foundations and discrete trash deposits (e.g., wells, privy pits, dumps).

Project Site History
A review of 19th and 20th-century maps and aerial photos shows several buildings and structures within the project site, with the earliest evidence being a 1937 aerial. As described below, most of the buildings were previously documented and subsequently demolished. One building complex in the eastern portion of the project site was not documented. However, aerial photos show that the complex was demolished between 1981 and 1993.

Several ditches and a canal were also shown within the project site. The earliest ditches were present by 1937; but most of the ditches are not currently extant or have been modified since original construction. One ditch is present within the eastern portion of the project site that dates to 1937. However, the northern half of the ditch was filled in between 1961 and 1970. A canal is shown bisecting the project site as early as 1937. The canal connected to the West Drainage Canal and continued north outside of the project site to an unnamed ditch along Elkhorn Boulevard. Between 1961 and 1970 the course of the canal was altered within the project site.

The southeastern portion of the project site contains a low-lying area that drains into the West Drainage Canal; however, the area appears to have been modified in 1961. The remaining six ditches within the project site appear to be modern.

Known Cultural Resources
Archival research was carried out as part of the Cultural Resources Study prepared for the proposed project by Tom Origer & Associates, including review of available historic documents and a records search. A records search of the North Central Information Center (NCIC) of the California Historical Resources Information System (CHRIS) was conducted for the project site and vicinity at California State University, Sacramento. In addition, Tom Origer & Associates conducted field surveys of the project site on February 9 and 10, 2022, and February 16, 2022.

The records search determined that 11 cultural resources studies have been conducted within

0.25-mile of the project site, five of which included portions of the project site. Three resources were recorded within the project site including P-34-000876, P-34-000877, and P-34-000878. In addition, the project site lies within two districts documented as P-34-005251 and P-34-005225.

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