Policy 12.4 Identify fire-prone habitats to plan for increased risk of larger and more frequent wildfires.
4.6.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to wildfire are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to CEQA Guidelines Appendix G, a significant impact related to wildfire would occur if a Project located in or near State Responsibility Areas or lands classified as Very High FHSZs would incur the following:
Substantially impair an adopted emergency response plan or emergency evacuation plan.
Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.
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Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.
4.6.4 Impact Analysis
As shown in Figure 3-4, portions of the Project Site are in areas designated as Moderate and High FHSZs, and bordered by areas designated as Moderate, High and Very High FHSZs to the north and south (CAL FIRE 2025c).
A. Would the Project substantially impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Impairment of an emergency response or EOP would occur if there was a substantial increase in the population evacuating an area that would not adequately be served by the existing circulation system, or planned potential evacuation routes are impaired during future construction or operation. As discussed above (Section 4.6.2, Relevant Plans, Policies, and Ordinances), the City has three primary documents related to emergency and evacuation planning (i.e., the County EOP, the Santee EOP, and the County MJHMP). The County MJHMP identifies risks, minimizes damage from natural and human-made disasters, and is generally intended to provide compliance with regulatory requirements associated with emergency response efforts (County of San Diego 2023). The County EOP is written in coordination with the MJHMP and contains an Evacuation Annex, which describes how emergency personnel shall implement a response to a disaster when and if evacuation is needed. The County EOP covers all of San Diego County, including Santee. According to the City’s General Plan Safety and Environmental Justice Element, the Santee EOP was developed from the County EOP and provides a system for the effective management of emergencies consistent with the County EOP and tailored to the City’s needs (City of Santee 2025b). The County EOP identifies major interstates and highways that serve as primary transportation routes in the case of an evacuation. Routes that run through the City to be used for evacuation include State Route 52 (east/west), State Route 67 (north/south), and State Route 125 (south) (USDCESO and County of San Diego 2022).
The Project includes the reduction of hazardous fuel loads within the San Diego River Corridor through the implementation of the Fuels Treatment Plan. Implementation of the Project would include vegetation removal and treatment of non-native, invasive, and dead plant material. The Project does not include any proposed development, nor would the Project result in an increased population that would impact evacuation.
As discussed in Section 4.3 Hazards and Hazardous Materials, the proposed Project may result in a temporary increase in traffic on roadways surrounding the Project Site due to increased truck loads or the transport of construction equipment to and from the Project Site during treatment and maintenance activities. Access to the Project Site would occur at designated routes that occur at the end of existing roadways and do not currently allow for through traffic (Figure 3-6, Access Routes). These routes will be confirmed by the vegetation management contractor prior to use and are subject to change. Furthermore, these routes are not previously identified evacuation routes. In addition to these routes, it is anticipated that overland travel by foot will be conducted by field crews along disturbed land to access vegetation management work locations. Implementation of vegetation management and treatment would prioritize
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existing roads and trails to minimize the need for new disturbances. If access via public roadways is necessary, the contractor will be responsible for traffic control to maintain safe working conditions and ensure emergency access is not impaired. Therefore, the Project would not conflict with or impair implementation of the MJHMP and the County’s or City’s EOP, nor would the Project impair use of potential evacuation routes in the City, and impacts would be less than significant.
B. Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? The Project Site is located along the San Diego River within the City’s jurisdiction, which does not support or include residential development that houses permanent residents. Occupancy at the Project Site includes people accessing the San Diego River for recreational purposes such as walking, birding, etc. In addition, the San Diego River Foundation identifies that homeless encampments are a critical social and environmental challenge in and around the San Diego River. The unhoused population in the riverbed are harder to reach by service providers, medical crews, and emergency responders, further from existing homeless resource infrastructure, and at higher vulnerability to environmental hazards like fires and floods (San Diego River Park Foundation 2026). Therefore, although the Project Site does not include residential properties that house permanent occupants, recreational visitors and people experiencing homelessness in the riverbed would be vulnerable to exposure of pollutant concentrations from wildfire or the uncontrolled spread of a wildfire at the Project Site.
The Project would include vegetation management through the implementation of the Fuels Treatment Plan, the purpose of which is to reduce hazardous fuel loads within the San Diego River Corridor. The vegetation management techniques that are recommended for each zone are classified into three categories: hand labor (e.g., hand cutting, trimming), mechanical (e.g., mowing, masticating), and chemical (e.g., EPA-approved herbicide). Hand labor and chemical management techniques are not activities that pose a risk for wildfire ignition; however, mechanical vegetation management requires the use of heavy machinery, which could result in ignition during high-fire-hazard weather conditions.
The following analysis discusses the potential wildfire risks that could be exacerbated by vegetation management on site.
Topography and Terrain
As described above, the Project Site is located within a broad alluvial valley bounded by foothill terrain to the north and east. The east–west orientation of the corridor river reflects a broader regional drainage pattern that can channel Santa Ana winds toward the coast, increasing wind speeds within valley bottoms and contributing to rapid fire spread (CAL FIRE 2025a). Implementation of the Project would include vegetation management activities that would reduce fire risk in the San Diego River Corridor by creating and maintaining a defensible space and managing hazardous fuel loads. Additionally, the Project would implement Fire Protection BMPs (Fire Protection BMP-1-5) during the use of mechanical vegetation management techniques, which would reduce the potential for ignition and wildfire risk during Project implementation. Further, because the proposed Project does not include or encourage “occupants,” it would not expose occupants to significant pollutant concentrations. Therefore, while the Project is located within a valley bottom that can contribute to rapid fire spread, implementation of the Project would not exacerbate wildfire risks.
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Prevailing Winds
A defining feature of the region’s fire weather is the occurrence of Santa Ana winds, which develop when warm, dry air flows from inland deserts toward the coast. These winds, which occur in late summer through the winter months, can reach sustained speeds of 25 to 35 mph on ridge tops and produce gusts exceeding 60 mph that travel efficiently through east–west oriented drainages such as the San Diego River valley.
Relative humidity during Santa Ana events often drops into the single digits, rapidly drying fine fuels and enabling fast, wind-driven fire spread (RCD of Greater San Diego County and San Diego County Fire Safe Council 2019; CAL FIRE 2025b). Seasonal winds in the inland foothills generally blow west to southwest during the summer but shift to northerly and easterly directions during fall and winter storm cycles, reinforcing the potential for wind alignment within the corridor (Eucalyptus Hills Fire Safe Council 2009).
During such events, ignitions have the potential to develop into fast-moving, high-intensity fires capable of significant spotting and embers carried long distances through the wildland–urban interface.
As mentioned above, implementation of the Project would include vegetation management activities that would reduce fire risk in the San Diego River Corridor by creating a defensible space and managing hazardous fuel loads. Ongoing maintenance activities would occur as needed based on biannual inspections to maintain a reduction in wildfire hazard on the Project Site after the initial treatment of the Project Site. In addition, the Project would not involve altering slopes or creating new wind patterns. Further, because the proposed Project does not include or encourage occupants, it would not expose occupants to significant pollutant concentrations. Therefore, while the Project is located in an area susceptible to prevailing winds, the Project would not exacerbate wildfire risk due to prevailing winds and impacts would be less than significant.
Vegetation
Vegetation at the Project Site reflects the composition typical of inland valleys and river corridors in western San Diego County. Riparian vegetation, including willows, cottonwoods, mulefat, and associated understory species, dominates the immediate river margins. Although riparian vegetation often retains higher moisture levels, it can contain dense stands of shrubs, branches, and debris, along with invasive species such as Arundo donax, which can contribute to elevated fire intensity. Implementation of the Project would include vegetation management activities that would reduce fire risk in the San Diego River Corridor by creating a defensible space and managing hazardous fuel loads. Ongoing maintenance activities would occur as needed based on biannual inspections to maintain a reduction in wildfire hazard on the Project Site after the initial treatment of the Project Site. Further, because the proposed Project does not include or encourage “occupants,” it would not expose occupants to significant pollutant concentrations. Therefore, the Project would not increase fire risk through the introduction of vegetation at the Project Site, and impacts would be less than significant.
While the Project Site contains factors that exacerbate wildfire risk, implementation of the Project is intended to enhance community safety within the City through reduction of wildfire risk, and to reduce ignition potential and fire intensity within the San Diego River Corridor. Temporary risks associated with mechanical treatment would be reduced with implementation of BMPs Fire Protection BMP-1-5). Project implementation would not exacerbate wildfire risks and thereby would not expose permanent occupants or employees to pollutant concentrations from wildfire or the uncontrolled spread of a wildfire, and impacts would be less than significant.
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C. Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
The Project would include the implementation of the Fuels Treatment Plan, which includes vegetation management and removal. Ongoing maintenance activities would occur as needed based on biannual inspections to maintain a reduction in wildfire hazard on the Project Site after the initial treatment of the Project Site. It is expected that approximately one-quarter of the total Project Site will be maintained annually to preserve reduced hazardous fuel conditions. Access to the Project Site would use existing roads and trails in the San Diego River Corridor. A map of the access routes is presented in Figure 3-6. In addition to these routes, it is anticipated that overland travel by foot will be conducted by field crews along disturbed land to access vegetation management work locations. Implementation of the Project would include vegetation management activities that would reduce fire risk in the San Diego River Corridor by creating and maintaining a defensible space and managing hazardous fuel loads. Specific fuel breaks are not proposed as part of the Project. Therefore, the Project does not propose development that would result in the installation or maintenance of associated infrastructure such as public roadways, fuel breaks, emergency water sources, power lines, or other utilities that would exacerbate fire risk or that may result in temporary or ongoing impacts on the environment, and impacts would be less than significant.
D. Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Wildfire can significantly alter the way water interacts with the landscape to the extent that even modest rainstorms can produce dangerous flash floods and debris flows. Burned landscapes are particularly susceptible to debris flow because wildfire removes vegetation, which plays a vital role in maintaining existing drainage patterns and the stability of soils. Removal of surface vegetation reduces the ability of the soil surface to absorb rainwater and can allow for increased runoff that may include large amounts of debris or mud-flows. If hydrophobic conditions exist post-fire, the rate of surface water runoff is increased as water percolation into the soil is reduced (Moench and Fusaro 2012). The potential for surface runoff and debris flows therefore increases for areas recently burned by large wildfires (Moench and Fusaro 2012).
The Project Site is located within the San Diego River Watershed and is in the San Diego River Corridor, which is designated as a Federal Emergency Management Agency Floodway (FEMA 2026). Because the Project Site is designated as a floodway, there is potential that people could be put at risk in post fire condition. However, as identified in Figure 1 of Appendix C of the City’s Safety and Environmental Justice Element, the Project Site is not categorized as an area susceptible to landslides (City of Santee 2025a).
Post-treatment, there is the potential for erosion caused by the removal of vegetation cover and dead or dying vegetative debris that previously had intercepted rain and runoff or slowed down the velocity of rainfall and runoff. This is an especially crucial consideration as erosion within the Project Site has the potential to contribute to sedimentation of the San Diego River, resulting in turbidity and potential infill. To minimize the risk of excessive erosion post-treatment, this Project includes a combination of erosion and sedimentation BMPs from the construction and forestry industries, including the California Forest Practice Rules, San Diego County Erosion and Sediment BMPs, and U.S. Environmental Protection Agency erosion and sediment control BMPs (Slope Stability/Erosion BMP-1-10). Furthermore, the proposed Project would not change the drainage pattern of the river. Therefore, with implementation of BMPs, the likelihood for downslope or downstream flooding or landslides as a result of runoff, post-fire slope instability, or drainage changes would be minimal, and impacts would be less than significant.
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4.6.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to wildfire would be less than significant. No mitigation is required.
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5 Effects Found Not to Be Significant
Section 15128 of the California Environmental Quality Act Guidelines requires that an Environmental Impact Report briefly describe potential environmental effects that were determined not to be significant and therefore were not discussed in detail in the Environmental Impact Report. The environmental issues discussed in the following sections are not considered significant for the San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan (Project), and the reasons for these less-than-significant impact or no impact determinations are discussed herein.
5.1 Aesthetics
The Project Site consists of typical riverine open space within the San Diego River Corridor within Santee’s jurisdictional limits. The Project Site contains recreational walking trails. The Project Site is surrounded by residential, commercial, industrial, recreational, and transportation related development. Views of the Project Site are generally visible from surrounding roadways adjacent to the Project Site and consist of dense trees and shrubs on site, some of which are dead. Due to the dense vegetation, views of the Project Site are limited to immediate views of trees and shrubs. The City of Santee does not identify designated scenic vistas in its General Plan (City of Santee 2020). The Project would include vegetation management activities that would remove invasive and dead and dying vegetation and have targeted thinning of vegetation within Zone 1 and Zone 2. In Zone 3, which includes the broader vegetated areas of the river corridor beyond 100 feet from structures, vegetation management is limited to the treatment or removal of non-native species, dead or dying vegetation, and storm-deposited accumulations, while maintaining riparian canopy and ecological structure; removal of native vegetation is not included in this zone. Vegetation management activities would not obstruct views, introduce structures, or alter the defining visual features of a designated scenic vista, therefore, impacts would be less than significant The Project Site is not located within or adjacent to a state-designated or eligible scenic highway (Caltrans 2026).
The nearest designated state scenic highway to the Project is a segment of State Route (SR) 52, that is approximately 1.6 miles from the Project Site. This designated scenic corridor ends near the Western edge of Santee and the Project Site and is not visible from SR-52 due to topography and vegetation. The closest eligible scenic highway is SR-52 south of the Project Site, approximately 0.3 miles away. Views of the Project Site from the eligible portion of SR-52 are not visible due to topography and vegetation. Therefore, because the Project Site is not visible from a scenic highway, the Project would not result in damage of scenic resources from a scenic highway and impacts would be less than significant.
The California Public Resource Code 2701 defines an urbanized area for an incorporated city that has a population of at least 100,000 persons or has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons. As of July 2024, the U.S Census Bureau estimates the population of Santee to be 59,104; however, the City of El Cajon adjacent to the City of Santee has a population of 103,291 (USCB 2024), and therefore, the City of Santee is considered an urbanized area. The City of Santee does not have any zoning regulations related to scenic quality that would be applicable to the Project. The City of Santee General Plan does contain policies intended to protect aesthetic resources. The Conservation Element specifically identifies Objective 2.0 and Policy 2.1, which seek to protect the aesthetic quality along water corridors, and scenic value of the San Diego River Corridor (City of Santee 2020). 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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As described above, the Project consists of vegetation management activities, including the removal of dead, dying and non-native and invasive vegetation, and targeted thinning of shrubs, fine fuels within Zone 1 and 2. The Project would result in less obstruction of visual resources within the San Diego River Corridor and would maintain the scenic resources within the San Diego River Corridor.
The Project would include vegetation management activities and occur during daytime hours. The Project would not introduce new light sources, reflective materials, or surfaces capable of producing glare. Therefore, the Project would not result in new substantial sources of light or glare, and impacts would be less than significant.
5.2 Agricultural and Forestry Resources
The California Department of Conservation has not identified the Project Site as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (DOC 2022). The Project would not result in the conversion of important farmland. The Project Site is designated as “Other and Urban Built-Up Land,” by the California Department of Conservation, which is not a category under this California Environmental Quality Act criterion. Because the Project Site is not identified as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, there would be no impact related to converting Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural use.
The Project Site is designated as Park/Open Space and Public land uses and is used as open space (City of Santee 2017). Surrounding lands are parks, preserves, and developed residential, commercial, industrial, and transportation uses. No portions of the Project Site or surrounding area are used for agricultural operations. No agricultural or forestry uses are located within or adjacent to the Project Site. According to the City’s Draft Program Environmental Impact Report for the Housing Element Rezone Program Implementation, there are no lands protected by a Williamson Act Contract within the City (City of Santee 2022). Therefore, there would be no impact related to conflict with existing zones or a Williamson Act Contract.
No portion of the Project Site is zoned or mapped as forest land, timberland, or timberland production as defined in California Public Resources Code Section 12220(g). Timberland (as defined by California Public Resources Code Section 4526) or timberland-zoned timberland production (as defined by Section 51104[g] of the Government Code) is not present on site, nor are there any active or potential commercial timber operations present in the area.
The Project involves vegetation management and would not involve the conversion of forest land to non-forest use.
Therefore, the Project would not conflict with lands zoned for forest land, timberland, or timberland production and no impact would occur.
5.3 Air Quality
The San Diego County Air Pollution Control District (SDAPCD) implements regional air-quality planning through the San Diego Regional Air Quality Strategy (SDAPCD 2022) and the San Diego portion of the State Implementation Plan. These plans identify control measures and strategies needed for attainment and ambient air-quality standards. The Project consists of short-term vegetation management activities does not introduce new development, does not generate long-term emissions, and does not alter land-use or growth assumptions that Regional Air Quality Strategy/State Implementation Plan rely on for air-quality forecasting. Vegetation management activities would require short-term use of fuel-powered equipment such as chainsaws, chippers, and small mowers; however, these activities would be temporary in nature and limited in scale and duration. Ongoing maintenance activities would occur as needed based on biannual inspections and would not occur across the entire Project Site 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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during each maintenance cycle. The Project would also implement best management practices (BMPs) that have been identified in Section 3.6 of Chapter 3, Project Description, such as controlling fugitive dust, reducing idling times, and maintaining equipment to reduce generation of air pollution during vegetation management activities (Air Quality BMP-1).
The Project’s emissions are temporary, minimized through BMPs, and do not interfere with SDAPCD control measures; it does not obstruct or conflict with the air quality plan.
Sensitive receptors including nearby residential neighborhoods and recreational users on adjacent parks and multi-use trails are located near portions of the Project Site. All work would occur during daytime hours and incorporate dust control, access management, and equipment restrictions to minimize temporary exposure.
Because vegetation management activities are temporary, intermittent, and would implement BMPs, the Project would not result in substantial pollutant exposure for nearby sensitive receptors.
The Project would also not introduce any long-term odor-emitting sources. Minor, short duration odors associated with equipment exhaust or vegetation handling may occur during implementation; however, these would be temporary and limited. Vegetation material would be transported off site for green waste processing rather than stockpiled, further reducing the potential for odor generation.
Based on the Project’s temporary and minor nature of equipment-related emissions, the implementation of air quality BMPs, and the absence of long-term emission sources, the Project would not result in a substantial adverse air quality impact. Therefore, air quality impacts including those related to emissions, sensitive receptor exposure, and odor generation would be less than significant.
5.4 Energy
Energy use for vegetation management activities would be limited to temporary, short-term fuel usage associated with Project equipment. The Project does not require long-term energy consumption. BMPs, including idling limits and minimizing the amount of equipment operating at one time would further reduce temporary fuel use and avoid wasteful or inefficient consumption of energy (Air Quality BMP-8). Therefore, the Project would not result in wasteful, inefficient, or unnecessary consumption of energy. The Project would not require new energy infrastructure, utility connections, or create long-term operational energy demand. Additionally, the Project consists of vegetation management using standard mechanical equipment and does not generate ongoing energy demand and would not interfere with or obstruct state or local renewable energy or energy efficiency plans. Therefore, the Project would not result in wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.
5.5 Geology and Soils
The City’s General Plan Safety Element does not identify the Project Site is not located within an Alquist–Priolo Earthquake Fault Zone or within an area susceptible to landslides; however, the Project Site does have potential for ground shaking associated with the nearby faults and contains liquefaction-susceptible soils (City of Santee 2025a). The Project involves vegetation management activities that would be temporary in nature and would not propose structural development that would introduce new people to the Project Site that would be exposed to these risks. Therefore, the Project would not expose people to risks associated with fault zones, seismic shaking, liquefaction, landslides, and unstable geologic units or soils. 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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The Project would involve vegetation management activities that could cause localized soil disturbance and temporarily expose soils to increased erosion potential, particularly near access points and trails within the river corridor. However, the Project includes erosion and slope-stability BMPs designed to minimize soil disturbance and sediment transport (Slope Stability/Erosion BMP-1-10). The BMPs include measures such as limit heavy equipment, avoid saturated soils, and use mats, which reduce erosion potential with vegetation management activities.
The Project involves vegetation management activities and does not include development that would require wastewater disposal systems. No septic tanks or alternative wastewater disposal systems are proposed. Therefore, no impact would occur.
The Project does not propose the excavation of the Project Site and ground disturbance would be limited to the top layers of soil. Therefore, no unique geological or paleontological resources would be disturbed. Impacts would be less than significant.
5.6 Greenhouse Gas Emissions
Vegetation management activities would involve temporary, short‑term fuel use from portable equipment such as chainsaws, chippers, and small mowers. These sources would generate minor, short‑duration greenhouse gas (GHG) emissions during implementation. Ongoing maintenance activities would occur as needed based on biannual inspections and would not occur across the entire Project Site during each maintenance cycle and would generate minimal greenhouse gas emissions over a smaller area. Additionally, the Project would implement BMPs, including use of Tier 4 equipment where feasible, idling limits, and minimizing the number of pieces of equipment operating simultaneously (Air Quality BMP-2), which would further reduce temporary fuel consumption and associated GHG emissions. Additionally, vegetation management activities would reduce the likelihood, intensity, and emissions profile of future wildfire events within the San Diego River Corridor. GHG emissions from the Project would be short‑term, minor, and limited to temporary equipment use and would not conflict with state or local GHG reduction plans; impacts related to GHG emissions would be less than significant.
5.7 Land Use and Planning
The Project is located along the San Diego River Corridor within the City of Santee, which is adjacent to residential neighborhoods, commercial districts, industrial areas, and existing parks and recreational trails. Land uses within the Project Site include Park/Open Space and Public land uses (City of Santee 2017). The Project consists of public‑safety vegetation management activities within established open‑space areas. No structures, grading, or land‑use changes are proposed, and the Project would not introduce new development, population, or uses that could physically divide an established community or conflict with applicable land‑use plans. Work areas are limited to vegetation‑management zones identified in the Fuel Treatment Plan and would not alter the function or accessibility of adjacent residential, commercial, industrial, or recreational uses.
As described in Section 4.1, Biological Resources, the Draft Santee Multiple Species Conservation Program Subarea Plan has not yet been approved or permitted; however, it is used as the guidance document for projects occurring within the City of Santee. Portions of the Project Site overlap defensible space areas identified within the San Diego River Subunit as shown on Figure 4-5 of the City of Santee Draft Multiple Species Conservation Program Subarea Plan (City of Santee 2025b), and no permanent impacts to habitat are expected. As concluded in Section 4.1, the Project would not conflict with the Draft Santee Multiple Species Conservation Program Subarea Plan 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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The Project would not divide an established community or conflict with a land use plan, policy, or regulation, and impacts would be less than significant.
5.8 Mineral Resources
Portions of the Project Site lie within MRZ‑2 (areas with significant or highly likely aggregate deposits) along the San Diego River floodplain, with the remainder of the Project Site in MRZ‑3 (deposits present but significance not evaluable with available data) (City of Santee 2025c). Given the open space nature of the Project Site, adjacent residential and commercial uses, and sensitive habitat/recreation constraints, extraction would not be compatible with existing and planned in this location. The Project consists of vegetation management activities and would not alter mineral resources or interfere with reclamation. Considering the existing surrounding land uses and the incompatibility of mineral resource extraction activities in the Project area, potential significant mineral resources within the Project area are considered unavailable for extraction. Therefore, impacts associated with mineral resources would be less than significant.
5.9 Population and Housing
The Project would not introduce new people to the Project Site or existing residences. Temporary crews would be present during vegetation management activities and would not result in long-term population increases. Therefore, the Project would not introduce new permanent population or create conditions that would indirectly encourage population growth in the surrounding area.
The Project Site consist primarily of open space lands within the San Diego River Corridor. Portions of the Project Site is known to be used periodically by unhoused individuals (San Diego River Park Foundation 2026); however, no housing is present within the Project Site. The Project would not displace existing housing or require the construction of replacement of housing. Impacts related to population growth, housing, and displacement would be less than significant.
5.10 Public Services
The Santee Fire Department (SFD) provides fire protection and Emergency Medical Service to the Project Site. SFD currently operates three fire stations: two permanent fire stations (SFD Fire Station 4 and SFD Fire Station 5) and one interim fire station (SFD Fire Station 20). SFD Fire Station 4 is located approximately 1 mile south of the Project Site at 8950 Cottonwood Avenue, and SFD Station 5 is located approximately 0.06 miles north of the Project Site at 9130 Carlton Oaks Drive (City of Santee 2025a). The City opened SFD Fire Station 20, which is located at the City Operation Yard at 9530 Via Zapador, approximately 1 mile south of the Project Site, in October 2025 (City of Santee 2025a). The San Diego County Sheriff’s Department provides public safety services. The Santee Sheriff’s Station is located approximately 0.5 miles from the Project Site (County of San Diego Sheriff’s Department 2026).
The Project would include vegetation management, which would require additional support from SFD and San Diego Sheriff. Through BMPs, the Project would include advanced notice of planned activities through multiple channels, such as in-person outreach, posted signage, and collaboration with service providers to let recreational users and potential unhoused people within the Project Site (Recreational Resources BMP-6). Clear messaging shall explain the timing, purpose, and safety risks of vegetation treatment. On the day of operations, SFD or the City shall confirm that sites are clear before work begins. Representatives of the San Diego Sheriff’s Department may assist with 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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abatement of encampments under certain circumstances. This increased demand for fire and police services would be temporary and anticipated to be limited to the beginning of Project treatment activities. Ongoing maintenance activities would occur as needed based on biannual inspections and would not occur across the entire Project Site during each maintenance cycle. Project personnel would be temporarily on site during treatment activities but would not result in a long-term increase in demand for public services. Because the Project does not generate population growth, occupancy, or new built structures, it does not create additional demand for fire protection, police services, schools, or other public facilities. Impacts to public services would be less than significant.
5.11 Recreation
The Project Site includes open space areas of Mast Park and Walker Preserve. These areas contain established recreational amenities such as the San Diego River and Walker Preserve trail multi-use trails, used year-round by walkers, cyclists, and equestrians. Vegetation management activities within the Project Site would require portions of these trails to be temporarily unavailable to users. The Project would implement BMPs associated with recreational resources such as posting signage and notification of Project activities, focusing operations during weekdays when feasible, and restoring disturbed recreation-specific areas (Recreational Resources BMP-1-6). The Project would not introduce new recreational facilities and would not result in a long-term increase in demand for parks or recreational services. Temporary, localized trail closures may occur during vegetation management activities but would not substantially affect the use or availability of recreational amenities. Therefore, impacts to recreation would be less than significant.
5.12 Transportation
The Project is located entirely within the San Diego River Corridor and is not situated within an existing roadway.
The Project would use existing access routes within the San Diego River Corridor to reach vegetation management areas. As shown in Figure 3-6, Access Routes, access to the Project Site is available via public roadways, existing utility easements, maintenance paths, and disturbed land already present along the corridor. The Project would result in the temporary closure of existing trails within the San Diego River Corridor where work is occurring. The Project would not require the closure of -sidewalks, bicycle lanes, and roadways surrounding the Project Site.
Vehicle trips associated with the Project would be limited to vegetation management crews traveling to and from the Project Site. These trips would be temporary and would not generate substantial vehicle trips during implementation. Ongoing maintenance activities would occur as needed based on biannual inspections. Temporary crews would not generate consistent ongoing traffic; limited worker traffic associated with treatment and maintenance would be temporary and would not result in a measurable increase in vehicle miles traveled, congestion, or traffic on adjacent public roadways. Therefore, the Project would result in a less-than-significant impact related to trip generation.
The Project would introduce equipment to an open space area. Prior to Project initiation, notification and signage would be posted to explain the timing, purpose, and safety risks of vegetation treatment. The Project would not increase hazards due to a design feature or incompatible use.
All existing public roads and emergency response routes would remain open during implementation, and vegetation management activities are located within open space areas rather than with roadways. No closures or obstruction of emergency access routes are required as part of Project implementation. Therefore, the Project would not reduce emergency access, and impacts would be less than significant. 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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5.13 Utilities and Service Systems
The Project would include vegetation management within an open space area. Vegetation management activities would rely solely on portable equipment and would not require water, sewer, electricity, natural gas, or other utility connections.
The Project would not introduce new residents, businesses, or long-term employees. Energy and water demand for the Project would be temporary and would not require the construction or upgrading of utility infrastructure.
Vegetation management would result in the generation of biomass. Disposal methods for the Project would include off-site disposal to a green waste facility, on-site broadcast of chips, lop-and-scatter, and to a lesser extent cranes and helicopters. Biomass would be handled, transported, and processed in accordance with applicable federal, state, and local solid‑waste regulations. Compliance with these requirements ensures proper diversion and disposal. Impact would be less than significant.
The Project would not require new or expanded water, wastewater, stormwater, electricity, natural gas, telecommunication, or solid‑waste facilities. Impacts to utilities and service systems would therefore be less than significant.
5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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6 Other CEQA Considerations
6.1 Cumulative Impacts
Section 15130(a) of the State California Environmental Quality Act (CEQA) Guidelines requires a discussion of the cumulative impacts of a project when the project’s incremental effect is cumulatively considerable. Cumulatively considerable, as defined in CEQA Guidelines Section 15065(a)(3), means that the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” The State CEQA Guidelines Section 15355 defines a cumulative impact as two or more individual effects that, when considered together, are considerable or that compound or increase other environmental impacts. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.
In many cases, the impact of an individual project may not be significant, but its cumulative impact may be significant when combined with impacts from other related projects. CEQA Guidelines Section 15130(b) states that “the discussion [of cumulative impacts] need not provide as great detail as is provided for the effects attributable to the project alone.” Section 15130(b) further states that a cumulative impacts discussion “should be guided by standards of practicality and reasonableness.”
Cumulative impacts can also occur from the interactive effects of a single project. For example, the combination of noise and dust generated during construction activities can be additive and can have a greater impact than either noise or dust alone. However, substantial cumulative impacts more often result from the combined effect of past, present, and future projects located in proximity to a proposed project. Thus, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future projects, the impacts of which might compound or interrelate with those of the project under review.
Probable future projects are those in the project vicinity that have the possibility of interacting with the project to generate a cumulative impact (based on proximity and construction schedule) and either:
▪ Are partially occupied or under construction
▪ Have received final discretionary approvals but are not yet constructed ▪ Have applications accepted as complete by local agencies and are currently undergoing environmental review ▪ Are projects that have been discussed publicly by an applicant or that otherwise become known to a local agency and have provided sufficient information about the project to allow at least a general analysis of environmental impacts
CEQA Guidelines Section 15130 identifies two basic methods for establishing the cumulative environment in which a project is considered: the use of a list of past, present, and probable future projects, or the use of adopted projections from a general plan, other regional planning document, or a certified environmental impact report (EIR) for such a planning document. This cumulative analysis uses a combination of the “list” approach and the “projections” approach to identify the cumulative setting.
Geographic Scope
The geographic area that could be affected by the Project varies depending on the type of environmental resource being considered. When the effects of the Project are considered in combination with those other past, present, 6 – OTHER CEQA CONSIDERATIONS
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and probable future projects to identify cumulative impacts, the other projects that are considered may also vary depending on the type of environmental effects being assessed. Table 6-1 presents the general geographic areas associated with the different resources addressed in this analysis.
Table 6-1. Geographic Scope of Cumulative Impact Analyses Environmental Issue Geographic Scope of Cumulative Impact Analyses Biological Resources Local and regional vicinity
Cultural Resources, Tribal Cultural Resources Project Site and immediate Project vicinity Hazards and Hazardous Materials Project Site and immediate Project vicinity Hydrology and Water Quality Project Site and immediate Project vicinity Noise Project Site and immediate Project vicinity
Wildfire Project Site and immediate Project vicinity
Project List
For the analysis of cumulative impacts associated with the Project, a cumulative project list was developed through consultation with the City of Santee. Table 6-2, Cumulative Project List, provides a list of these cumulative projects and their associated land use.
Table 6-2. Cumulative Project List
City
ID1 Project Status Address Land Use/Description
1 Warmington
Townhomes
Pending Entitlement 10939 Summit
Avenue
50 residential
condominium units
2 D'Lazio Condominiums Approved 8/23/06 -
Under Construction
8439 Fanita Drive 20 residential
condominium units
3 Vactor Decanting
Station
Approved – Not Built 9534 Via Zapador Vactor truck dewatering station
4 Karl Strauss Approved 12/17/15 -
Not Built
300 Town Center
Parkway
Brewery, tasting room, &
restaurant
5 Integrated signs Pending Entitlement 10756 Rockvill St. 27,044 sq. ft. industrial building
6 Prospect Estates II
Subdivision
Approved 10/9/19 -
Under Construction
8705 Marrokal Lane 38 condos, 15 single-family
homes
7 Palazzo Villas Approved 2/12/20 -
Not Built
8842 Olive Lane 8 residential condominium
units
8 Starbucks & 7-Eleven Approved 6/10/20 -
Not Built
8606 Graves Avenue 4,800 sq. ft. coffee shop &
convenience store
9 Tyler Street Subdivision Approved 4/24/24 -
Not Built
8500 Tyler Street 14 single-family homes
10 North Palisade
Industrial Building
Approved
Not Built
10990 N. Woodside
Avenue
300,145 sq. ft. industrial
building
11 Shadowhill Commercial
Building
Pending Entitlement SW Corner Woodside
Ave. and Shadowhill
Rd.
6,197 sq. ft. commercial
building
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Table 6-2. Cumulative Project List
City
ID1 Project Status Address Land Use/Description
12 County Animal Shelter Approved – Under
Construction
Riverview Parkway 23,303 sq. ft. animal
shelter
13 Woodspring Suites
Hotel
Approved 9/18/19 -
Under Construction
8807 Mission Gorge
Road
120-guestroom, 4-story
hotel
14 Carlton Oaks Country
Club
Pending Entitlement 7200 Inwood Drive 243 residential units & hotel
15 All Right Storage Approved 4/28/21 -
Not Built
8708 Cottonwood
Avenue
RV and self-storage facility
16 Prospect Avenue
Subdivision
Pending Entitlement 8732 Prospect
Avenue
4 single-family homes
17 New West Subdivision Approved 4/10/24 -
Not Built
9463 Slope Street 11 single-family homes
18 Graves Avenue RV &
Self Storage
Approved 9/25/24 –
Not Built
8355 Graves Avenue RV and self-storage facility
19 Laurel Heights
Condominiums
Approved 8/11/21 -
Under Construction
7750 Laurel Heights
Drive
80 residential
condominium units
20 Extra Space Storage Approved 5/14/25 –
Not Built
10815 Woodside
Avenue
88,390 sq. ft. (3-story)
storage building
21 Debra Pember Pending Entitlement 11009 Summit Ave 49 Units as 44 duplexes, and 5 condos
22 Lake Canyon
Subdivision
Approved 12/14/22 -
Not Built
9210 Lake Canyon
Road
9 single-family homes
23 Atlas View Apartments Pending Entitlement 8726 Atlas View Drive 10 residential apartments 24 Fanita Drive
Townhomes
Approved 7/12/23 -
Not Built
8504 Fanita Drive 8 residential condominium
units
25 Laurel Park Pending Entitlement 7735 Mission Gorge
Rd.
Replace 67 mobile homes
with 71 twin/single-family
homes
26 Lantern Crest Approved 2/22/23 -
Under Construction
300 Lantern Crest
Way
432- unit congregate care
facility w/ density bonus
27 Fanita Ranch Planned
Development
Pending Entitlement Fanita Ranch Master-planned community w/up to 3,008 homes
28 Paseo Pending Entitlement 701 Park Center Drive 53-unit condominium units 29 Excel Hotel Approved 4/26/23 -
Not Built
381 Town Center
Parkway
97 guestroom, 4-story hotel
30 Cuyamaca Business
Center
Approved 3/12/24 –
Not Built
9745 Cuyamaca
Street
6,280 sq. ft. medical office
building
31 Ukrainian Catholic
Church
Approved 11/8/23 -
Not Built
9308 Carlton Oaks
Drive
4,400 sq. ft. church
32 Atlas Cell Phone Tower Pending Entitlement 10400-CS Fanita Parkway
74' cell phone tower at
Santee Lakes
33 Lutapaj Specialty Food
Store
Approved 1/25/2024
- Not Built
282 Town Center
Parkway
2,016 sq. ft. specialty food
& tasting facility
34 Cuyamaca/Prospect
Starbucks
Approved 6/12/2024
- Not Built
8606 Cuyamaca
Street
1,270 sq. ft. drive-through
coffee shop
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Table 6-2. Cumulative Project List
City
ID1 Project Status Address Land Use/Description
35 The Exchange (Walmart
Housing Site)
Approved 12/10/25
– Not Built
9056 Mission Gorge
Rd
3-story, 100 residential
townhomes
36 Santee Auto Center Approved 10/25/23
– Under Construction
10335 Mission Gorge
Road
Two car dealerships, auto
body shop, & car wash
37 Fordyce Construction
Office
Approved 9/22/25 –
Not Built
9735 Prospect
Avenue
11,295 sq. ft. commercial
office and warehouse
38 Habitat for Humanity
Townhomes
Approved 9/27/23 -
Not Built
8932 First Street 17 residential
condominium units
39 Super Star Car Wash Approved 3/27/24 -
Not Built
8837 Magnolia
Avenue
4,980 sq. ft. tunnel car
wash
40 Townsend Townhomes
(Aubrey Glen)
Approved 5/28/25 –
Under Construction
7737 Mission Gorge
Road
52 residential townhomes
41 Santee Community
Center
Approved – Under
Construction
10123 Riverwalk
Drive
12,500 sq. ft. Community
Center w/ event space
42 Cuyamaca St Right Turn
Pocket
Approved 3/22/23 -
Not Built
Cuyamaca St &
Mission Gorge Rd
New right-turn only lane
43 Parkvue Approved 9/24/25 –
Not Built
Cottonwood Ave. &
Park Center
258 multifamily residential
units
44 Soapy Joe's Approved 1/18/2024
- Not Built
9015 Mission Gorge
Road
Express Car Wash
conversion
45 Interim Fire Station Pending Entitlement 9532 Via Zapador Fire Station No. 20 relocation
46 AT&T Princess Joann
Tower
Pending Entitlement North of Cuyamaca
Street and west of
Princess Joann Road
Cell tower for AT&T
47 Valvoline Instant Oil
Change
Approved 1/28/26 –
Not Built
10463 Mission Gorge
Road
Valvoline Instant Oil
Change Station
48 Santee Trailslide Pending Entitlement 9185 Mission Gorge Road
New drive-thru
restaurant/quick service
eatery
N/A Land Use Element
Update
Pending Entitlement Citywide Comprehensive update to
the 2003-2020 Land Use
Element Update
N/A Santee Multiple Species
Conservation Plan Draft
Subarea Plan And Draft
Program Environmental
Report
Pending Entitlement 10,484.4-acre Plan
Area within the
jurisdiction of the City
of Santee
Multiple Species
Conservation Plan for the
City of Santee, California
Notes:
1 Corresponds with the City’s Active Projects Log, available on the City’s website: https://www.cityofsanteeca.gov/business/activeprojects-map, accessed March 2026.
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6.1.1 Cumulative Impact Analysis
Consistent with State CEQA Guidelines Section 15130, the discussion of cumulative impacts in this Draft EIR focuses on significant and potentially significant cumulative impacts. Section 15130(b) of the State CEQA Guidelines provides, in part, the following:
[t]he discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.
A proposed project is considered to have a significant cumulative effect if the following are true:
▪ The cumulative effects of development without the project are not significant and the project’s additional impact is substantial enough, when added to the cumulative effects, to result in a significant impact. ▪ The cumulative effects of development without the project are already significant and the project contributes measurably to the effect.
The term “measurably” is subject to interpretation. The standards used herein to determine measurability are that the impact must be noticeable to a reasonable person or must exceed an established threshold of significance (defined throughout the resource sections in Chapter 4, Environmental Analysis, of this Draft EIR). This cumulative analysis also assumes that all mitigation measures identified in Chapter 4 to mitigate Project impacts are adopted and implemented.
The cumulative impact analysis provided in this chapter evaluates whether the residual impacts of the Project would cause a cumulatively significant impact or would contribute considerably to existing/anticipated (without the Project) cumulatively significant effects. Where the Project would so contribute, additional mitigation is recommended where feasible.
Biological Resources
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 California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? As described in Section 4.1, Biological Resources, of this EIR, mitigation measures would reduce direct and indirect impacts to special-status plant or wildlife species to less than significant with Project implementation (refer to Section 4.1, of this EIR). There are six projects identified by the City of Santee’s Active Projects Log that are in various stages of development (i.e., under construction, approved – not built, or pending entitlement) located adjacent to the San Diego River (City ID: 4, 10 12, 14, 33, 43). Similar to the proposed Project, these cumulative projects have the potential to result in indirect impacts to specialstatus plant or wildlife species located within the San Diego River. All projects, including the proposed Project, would be required to comply with applicable federal and/or state regulations that provide protections for special-status plant and wildlife species, such as the federal Endangered Species Act or California Endangered Species Act and may require approval from the U.S. Fish and Wildlife Service and/or EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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the California Department of Fish and Wildlife. If significant impacts occur from a particular cumulative project, it is expected that project-specific mitigation measures would be implemented to avoid or minimize impacts to the extent feasible and in compliance with applicable federal and/or state regulations.
Furthermore, the Project Site is within the boundaries of the Draft Santee MSCP Multiple Species Conservation Program (MSCP) Subarea Plan. The Draft Santee MSCP Subarea Plan, once finalized, would contribute to the regional MSCP for preservation, mitigation for impacts, and conservation of sensitive biological resources within San Diego County. The Draft Santee MSCP Subarea Plan is also intended to provide cumulative mitigation for impacts to Covered Species within the City of Santee’s jurisdiction and to ensure sufficient biological resources are conserved to assist in the conservation and recovery of Covered Species under the MSCP. Therefore, projects within the City of Santee Draft MSCP Subarea Plan Area, including the proposed Project, would be required to be consistent with the Draft Santee MSCP Subarea Plan. Because cumulative projects and the proposed Project would be required to meet or exceed MSCP requirements directed toward regional conservation, and project-specific mitigation measures would be implemented, as required, to avoid or minimize potential impacts to sensitive plant and wildlife species, all projects within the boundaries of the MSCP Plan would contribute to species recovery. Therefore, the proposed Project’s contribution to adverse effects on species within the MSCP would not be cumulatively considerable.
Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? The Project would result in direct and indirect impacts to riparian habitat; however, with implementation of mitigation measures, the Project’s impacts would be reduced to less than significant. There are six projects identified by the City of Santee’s Active Projects Log that are in various stages of development (i.e., under construction, approved – not built, or pending entitlement) located adjacent to the San Diego River (City ID:
4, 10 12, 14, 33, 43). Similar to the proposed Project, these cumulative projects have the potential to result in direct and/or indirect impacts to sensitive natural communities or riparian habitat located within the San Diego River. However, similar to the Project, other cumulative projects located within the Draft Santee MSCP Subarea Plan area would be required to meet or exceed MSCP requirements directed toward regional conservation and that project-specific mitigation measures would be implemented, as required, to avoid or minimize potential direct or indirect impacts to riparian habitat or other sensitive natural communities to a less-than-significant level. Therefore, the Project’s contribution to adverse effects on riparian habitat or other sensitive natural communities with implementation of the Project’s mitigation measures would not be cumulatively considerable.
Have a substantial adverse effect on any state or federally protected wetlands (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? The Project could result in direct and indirect impacts to jurisdictional aquatic resources; however, with implementation of mitigation measures, the Project’s impacts would be reduced to less than significant.
There are six projects identified by the City of Santee’s Active Projects Log that are in various stages of development (i.e., under construction, approved – not built, or pending entitlement) located adjacent to the San Diego River. Similar to the proposed Project, these cumulative projects have the potential to result in direct and/or indirect impacts to state or federally protected wetlands located within the San Diego River.
However, similar to the Project, other cumulative projects with the potential to impact jurisdictional aquatic resources would be required to obtain regulatory permit approvals, which would require identification of EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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avoidance, minimization, and mitigation measures if necessary that would reduce potentially significant adverse impacts to below a level of significance. Therefore, the Project’s contribution to adverse effects on jurisdictional aquatic resources with implementation of the Project’s mitigation measures would not be cumulatively considerable.
Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
All projects, regardless of which local jurisdiction they occur in, would be required to comply with all applicable regional or local tree preservation policies or ordinances, such as the City of Santee Urban Forestry Ordinance. The ordinance gives the City of Santee control of all trees, shrubs, and other plantings in any street, park, public right-of-way, landscape maintenance district or easement, or other City-owned property. Project implementation would require removal of trees that are dead or decaying or non-native trees. Mitigation measures are required to ensure that only dead, decaying, or non-native trees are targeted, which would ensure compliance with the City’s Urban Forestry Ordinance. City review and approval of development plans for the proposed Project and other cumulative projects would ensure that any proposed tree removal would conform to the applicable requirements of the Urban Forestry Ordinance and/or zoning codes. Furthermore, City of Santee staff would also ensure there are no conflicts with the objectives and policies presented in the Conservation Element of the Santee General Plan and relevant urban forestry, floodway, and biological resources ordinances. Cumulative projects within the Project vicinity would similarly be required to comply with all applicable regional or local policies or ordinances as a condition of project approval. Therefore, the Project’s contribution to conflicts with any local policies or ordinances protecting biological resources would not be cumulatively considerable.
Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The Project Site is within the boundaries of the Draft Santee MSCP Subarea Plan. Although the Draft Santee MSCP Subarea Plan has not yet been approved or permitted, it is used as the guidance document for projects occurring within the City of Santee. Mitigation measures are proposed in Section 4.1 of this EIR to prevent any indirect impacts to special-status species, sensitive vegetation communities, and jurisdictional aquatic resources associated with the San Diego River Preserve. Similar to the Project, cumulative projects located adjacent to the San Diego River Preserve identified in the Draft Santee MSCP Subarea Plan have the potential to result in indirect impacts to special-status species, sensitive vegetation communities, and/or jurisdictional aquatic resources. Any project within the MSCP Subarea Plan Area, including the proposed Project, would be required to be consistent with the Subarea Plan. Because all projects within the MSCP Plan Area would be required to meet or exceed MSCP requirements directed toward regional conservation, and project-specific mitigation measures would be implemented to reduce impacts to sensitive plant and wildlife species to a level of less than significant, all projects would contribute to the attainment of conservation goals identified in regional or local Habitat Conservation Plans. Therefore, the Project’s contribution to conflicts with an adopted Habitat Conservation Plan or Natural Community Conservation Plan would not be cumulatively considerable.
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Cultural Resources, Tribal Cultural Resources
Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5? As discussed in Section 4.2, Cultural and Tribal Cultural Resources, no known built environment resources are located within the Project Site; none of the adjacent historic-age properties are listed in or determined to be eligible for listing in the National Register of Historic Places and the California Register of Historical Resources or included in a local register. Implementation of the Project would not include construction disturbance, demolition, non-compatible building or structural modifications, construction-related groundborne vibration, or property acquisitions. Project activities consist solely of vegetation management activities (hand labor, mechanical, and chemical application) that would not physically alter any building, structure, or object. Therefore, the Project would not contribute to the loss of historical resources and would not be cumulatively considerable.
Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
The South Coastal Information Center records search identified 79 cultural resources within a 1-mile radius of the Project Site. As described in Section 4.2, the records search and the Cultural Resources Pedestrian Survey for the Project Site identified a total of nine cultural resources within the Project Site. Due to resources being located on site, the numerous cultural resources previously identified in the Project vicinity, and the Project’s location within the San Diego River Corridor, there is an increased potential that Project associated ground disturbance would have the potential to impact unanticipated archaeological resources.
Implementation of the Project, in combination with cumulative projects, would involve ground-disturbing activities that could result in discovery of or damage to previously undiscovered archaeological resources as defined in State CEQA Guidelines Section 15064.5. This could result in potentially significant cumulative impacts to previously undiscovered or unrecorded archaeological sites and materials. However, when considered in combination with the impacts of other projects in the cumulative scenario, the Project would not be cumulatively considerable because implementation of MM CUL-1 and MM CUL-2 would reduce Project impacts associated with accidental damage to known and unknown resources to a less-thansignificant level. Therefore, the Project’s potential contribution to impacts related to previously undiscovered archaeological resources would not be cumulatively considerable.
Disturb any human remains, including those interred outside of dedicated cemeteries? No prehistoric or historic burials were identified within or immediately adjacent to the Project Site as a result of the CHRIS records search, NAHC Sacred Lands File search, or pedestrian survey. Moreover, the Project Site is not part of a dedicated cemetery and as such, the likelihood of disturbing human remains is low. However, the possibility of encountering human remains within the Project Site exists. Future proposed projects within the surrounding Project area could potentially disturb human remains. With incorporation of MM CUL-3, impacts associated with human remains would be less than significant. As such, the Project’s potential contribution to impacts related to potential to disturb human remains would not be cumulatively considerable.
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Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Dudek’s cultural resources inventory included a records search, NAHC Sacred Lands File request, and Native American outreach, which confirmed the presence of Native American cultural resources in the region. The Sacred Lands File returned a positive indication of cultural resources inventory in the vicinity of the Project Site; however, the City sent AB 52 letters on March 20, 2026, and no responses were received.
Therefore, no Tribal Cultural Resources have been identified within the Project Site to date through the consultation process. The newly recorded resource (SDRFM-DF-S-003) contains a bedrock milling feature that may retain Native American cultural value; however, it is recommended not eligible for listing in the California Register of Historical Resources or National Register of Historic Places.
Although no known Tribal Cultural Resources have been formally identified at this time, there remains the potential for previously unknown (buried) tribal cultural resources to be encountered or adversely changed during vegetation management activities.
Cumulative projects within the surrounding Project area could potentially contribute to cumulative adverse changes to tribal cultural resources. As tribal cultural resources are often found along waterways and many of the cumulative projects are near the river, there is a possibility that cumulative projects could affect tribal cultural resources. Implementation of MM CUL-1 and MM CUL-2 would reduce the Project’s impacts associated with accidental damage to currently unrecorded/unknown tribal cultural resources to a level of less than significant. Therefore, the Project’s potential contribution to impacts related to unknown tribal cultural resources would not be cumulatively considerable.
Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe? Dudek’s cultural resources inventory included a records search, NAHC Sacred Lands File request, and Native American outreach, which identified one newly recorded resource (SDRFM‑DF‑S‑003) containing a bedrock milling feature within the Project Site. While this feature may have Native American cultural value, it does not meet the criteria for listing in the California Register of Historical Resources or National Register of Historic Places, appears to have been relocated, and lacks associated archaeological deposits; therefore, it does not qualify as a Tribal Cultural Resource under PRC Section 21074. In addition, the City sent AB 52 letters on March 20, 2026, and no responses were received. Therefore, no Tribal Cultural Resources have been identified within the Project Site to date through the consultation process. Although no known Tribal Cultural Resources have been identified at this time, there remains potential for unknown (buried) tribal cultural resources to be adversely affected during vegetation management activities due to the moderate archaeological sensitivity of the Project Site. Cumulative projects within the San Diego River Corridor may similarly encounter tribal cultural resources, as such resources are commonly found along waterways.
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Implementation of MM‑CUL‑1 (Resource Avoidance) would avoid impacts to known cultural sites and areas of potential tribal cultural importance, and MM‑CUL‑2 (Inadvertent Discovery Procedures) would ensure appropriate treatment of any unanticipated tribal cultural resources that may be encountered. With mitigation incorporated, Project impacts would be less than significant, and the Project’s potential contribution to cumulative impacts on tribal cultural resources would not be cumulatively considerable.
Hazards and Hazardous Materials
Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
Past, present, and reasonably foreseeable future projects within the cumulative study area would involve the routine use and transport of hazardous materials typical of urban development and maintenance activities, such as fuels, lubricants, solvents, and construction materials. Similar to the proposed Project, cumulative projects would be required to comply with applicable federal, state, and local regulations governing hazardous materials storage, handling, transport, and disposal.
As evaluated in Section 4.3.4, Impacts Analysis, the proposed Project would involve temporary and intermittent use of limited quantities of hazardous materials associated with vegetation management and would implement Project design features and BMPs to prevent releases and exposure. Because the Project’s hazardous materials use would be short-term, controlled, and regulated, and because cumulative projects would be subject to similar regulatory requirements, the Project’s incremental contribution to cumulative impacts related to the routine transport, use, or disposal of hazardous materials would not be cumulatively considerable.
Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
Cumulative upset or accident conditions could result from the combined presence of multiple projects that involve construction or operational activities using fuels, lubricants, or other hazardous materials.
However, the proposed Project would implement spill prevention, containment, and cleanup BMPs that directly address foreseeable spill mechanisms, including equipment inspection, secondary containment, designated fueling areas, spill kits, and response procedures. In addition, the Project Site and adjacent areas include GeoTracker listed sites that have received regulatory closure, and no open hazardous materials cleanup sites are located within or directly adjacent to the Project Site. As a result, the Project would not introduce new exposure pathways or mobilize known contamination under cumulative conditions. Because cumulative projects would similarly be required to comply with spill prevention and response regulations, the Project’s contribution to cumulative impacts related to upset and accident conditions involving release of hazardous materials into the environment would not be cumulatively considerable.
Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school.
Schools are present within 0.25 miles of the Project Site, and cumulative development in the surrounding area could incrementally increase the presence of construction activities near school receptors. However, the proposed Project would not involve hazardous emissions or long-term hazardous materials handling EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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and would be limited to temporary vegetation management activities with controlled use of common fuels and, if needed, localized herbicide application subject to strict BMPs.
All cumulative projects involving hazardous materials within proximity to schools would be required to comply with applicable regulations intended to protect sensitive receptors, including schools. Given the Project’s limited scope, temporary duration, and implementation of BMPs that minimize off-site movement of hazardous materials, the Project’s incremental contribution to cumulative impacts related to hazardous materials’ emissions or handling near schools would not be cumulatively considerable.
Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment.
Cumulative impacts could occur if a project were located on or near a hazardous materials site that could affect public health or the environment. As discussed in Section 4.3.1, Existing Conditions, while one GeoTracker listed site is located within the Project Site and 11 sites are located directly adjacent to the Project Site, all of these sites have received regulatory closure, and no open cleanup sites are present within or adjacent to the Project Site. The Project does not involve excavation, grading, or subsurface disturbance that could create new exposure pathways.
Other cumulative projects would be evaluated individually for proximity to listed hazardous materials sites and would be subject to regulatory oversight as required. Therefore, the Project’s contribution to cumulative impacts related to hazardous materials sites compiled pursuant to Government Code Section 65962.5 would not be cumulatively considerable.
For a project located within an airport land use plan, or, where such a plan has not been adopted, whin two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
The Project Site is located within approximately 1.1 miles of Gillespie Field Airport and within the airport influence area governed by the Gillespie Field Airport Land Use Compatibility Plan (ALUCP). As discussed in Section 4.3.4(E), the proposed Project consists solely of vegetation management activities within an existing river corridor and does not include construction of occupied structures, new land uses, or features that could interfere with airport operations, navigable airspace, or safety zones.
Cumulative projects within the vicinity may include residential, commercial, or infrastructure development that could introduce new receptors within airport influence areas. However, each cumulative project would be subject to individual review for consistency with the ALUCP, Federal Aviation Administration height notification requirements, and applicable local land use compatibility standards. The proposed Project would not add new receptors, structures, or uses that could increase airport-related safety risks or noise exposure under cumulative conditions.
Because the Project would not alter land use patterns, introduce sensitive receptors, or create physical obstructions within airport safety or noise influence areas, its incremental contribution to cumulative airport-related safety hazards or excessive noise exposure would not be cumulatively considerable.
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Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
Cumulative development within the City could increase demand on emergency response services and evacuation routes. However, the proposed Project would not introduce new land uses, structures, or permanent access restrictions. Temporary access controls associated with vegetation management would be localized, short term, and coordinated with the City and emergency service providers and would not affect designated emergency evacuation routes.
All cumulative projects would be required to comply with adopted emergency response and evacuation plans, as well as applicable fire and building codes. By reducing hazardous fuel loads and wildfire risk within the San Diego River Corridor, the proposed Project would support emergency response and evacuation objectives under cumulative conditions. Accordingly, the Project’s contribution to cumulative impacts related to emergency response or evacuation would not be cumulatively considerable.
Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.
The cumulative context for wildfire hazards includes the wildland–urban interface setting of the San Diego River Corridor and surrounding Moderate, High, and Very High Fire Hazard Severity Zones. While cumulative development could increase ignition sources and exposure of people and structures to additional ignition sources, the proposed Project is a hazard mitigation project designed to reduce fuel loads, fuel continuity, and wildfire intensity.
When considered together with other projects that would be required to comply with applicable fire codes and defensible space requirements, the Project would contribute to a net reduction in wildfire hazard rather than an increase. Therefore, the Project’s contribution to cumulative wildfire risk would not be cumulatively considerable.
Hydrology and Water Quality
Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.
The Project would result in short-term water quality impacts associated with vegetation management activities, including the use of small quantities of fuels and lubricants associated with hand labor and small, low ground-pressure equipment (e.g., line trimmers, chainsaws). Limited crew access could also result in minor, localized surface disturbance. Accidental releases or erosion could allow sediment or pollutants to enter surface waters if not properly controlled. The Project would implement BMPs that would avoid herbicide application during wet conditions (Chemical BMP-3), implement erosion and sediment control measures (Slope Stability/Erosion BMP-1-10), and ensure proper maintenance of equipment (Chemical BMP-1 and Air Quality-2). With implementation of these BMPs, the potential for sediment or pollutant releases would be minimized, and the Project would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.
Similar to the Proposed Project, cumulative projects could also result in short-term water quality impacts during construction or vegetation related activities. Cumulative projects would be required to comply with applicable stormwater regulations and implement measure as required to avoid or minimize potential EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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sediment or pollutant discharges. Therefore, the Project’s contribution to cumulative water quality impacts would not be cumulatively considerable.
Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin.
The geographic area under consideration for the topic of groundwater recharge includes the Santee Groundwater Basin. Vegetation management activities under the Project would involve selective hand labor, limited mechanical access, and removal of non-native or dead vegetation. Water use would be minimal and limited to short-term activities such as dust suppression, which would be supplied by water hauled on site by the contractor. The Project would not initiate groundwater extraction, increase pumping capacity, or create any new demand on groundwater supplies. The Project would not result in any new impervious surfaces. The potential for groundwater recharge would not change with respect to existing conditions and no impacts would occur.
Cumulative projects within the Project vicinity may introduce new impervious surfaces and minor reductions in infiltration. Given that the Project would not introduce impervious services or extract groundwater, the Project’s contribution to impacts related to groundwater would not be cumulatively considerable.
Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on or off-site; ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or iv) impede or redirect flood flows?
The Project Site contains the San Diego River and adjacent wetland and floodplain areas, which is largely pervious. The Project does not propose the introduction of impervious surfaces or the alteration of the river.
The Project would involve vegetation management activities that have the potential to disturb soil through foot traffic, equipment movement, and removal of surface vegetation. The Project would implement erosion prevention BMPs, which would help prevent rutting and compaction, further reducing changes to infiltration or runoff rates. As described in Section 4.3, Hazards and Hazardous Materials, BMPs have been identified to reduce potential for pollutants to enter waterways (Hand Labor BMP-6, Water Quality BMP-1-4, Mechanical BMP-16, and Chemical BMP-1-11).
The Project would not introduce impervious surfaces, grading, or channel modifications. It would not increase the rate or volume of surface runoff, redirect flood flows, or impede the capacity of the San Diego River or its floodplain. Cumulative projects listed could involve activities that include crews, small equipment, fuels, lubricants, and other materials within the San Diego River Corridor and adjacent floodplain areas, which are subject to periodic flooding. However, none of the cumulative projects would involve placement of impervious surfaces within the active river channel or the redirection or obstruction EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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of flood flows. Potential erosion or siltation associated with development adjacent to the river would be addressed through site specific BMPs.
Cumulative projects are required to incorporate on-site water quality treatment features and velocity and volume reduction measures to avoid a net increase in runoff to the river system. With implementation of these measures, temporary vegetation management activities associated with the Project would not create polluted runoff, exceed drainage system capacity, or result in the release of pollutants during flood conditions. Therefore, the Project’s contribution to cumulative impacts related to polluted runoff or pollutant release associated with flooding would not be cumulatively considerable.
In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
The proposed Project lies within an inland river corridor and is not in a tsunami or seiche zone (CGS 2026).
Portions of the Project Site lie within the San Diego River floodplain and may experience periodic flooding during high-flow events (FEMA 2026). The proposed Project would involve temporary vegetation-management activities that would introduce crews and small equipment into the floodplain but would be designed to avoid pollutant release during flood conditions through implementation of BMPs.
The cumulative projects listed are also not in a tsunami or seiche zone. However, some of the projects adjacent to the river could introduce temporary activities, equipment, or materials within areas subject to periodic flooding, which may have the potential to contribute pollutants if unmanaged. Cumulative projects would also be required to implement appropriate project-specific measures to avoid or minimize the potential for pollutant mobilization during flood events. As described above, the Project would implement BMPs that store and handle fuels and lubricants outside of drainage features with secondary containment and spill kits; conduct refueling only in designated, contained areas with spill kits present; perform routine equipment leak inspections and maintenance; and remove cut vegetation from jurisdictional areas so floodwaters cannot mobilize debris. Work would be suspended during and after significant rainfall and would avoid saturated soils to prevent disturbance and pollutant transport. With these measures in place, temporary vegetation-management activities would not risk the release of pollutants during flood conditions. Therefore, the Project’s contribution to cumulative impacts related to flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation would not be cumulatively considerable.
Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? The Project Site is subject to the Water Quality Control Plan for the San Diego Basin (Basin Plan), which establishes beneficial uses, water quality objectives, and implementation programs for inland surface waters and groundwater in Region 9, including the San Diego River. The Project consists of vegetation management activities. The Project would include BMPs to prevent pollutants from reaching the San Diego River. These measures ensure the Project’s activities avoid introducing discharges or altering water quality.
With respect to groundwater, the Project would not extract groundwater and would not create impervious surfaces, thereby preserving infiltration and avoiding changes to recharge. Any minimal implementation of water use (e.g., dust control) is temporary and part of field operations and would not require groundwater pumping. Based on these Project elements, the Project would not include actions that would interfere with groundwater conditions or management.
Cumulative projects could involve short-term- activities that may have the potential to affect water quality or groundwater conditions if unmanaged. However, similar to the Project, cumulative projects would also EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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be required to implement appropriate project-specific measures to avoid or minimize the potential for pollutant mobilization. Cumulative projects within the Project vicinity may introduce new impervious surfaces and minor reductions in infiltration. However, the San Diego River Valley Groundwater Basin is classified as a very low priority basin with respect to the Sustainable Groundwater Management Act.
Therefore, the Project’s contribution to cumulative impacts related to the obstruction of a water quality plan or sustainable groundwater management plan would not be cumulatively considerable.
Noise
Result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
The primary factor for the cumulative noise impact analysis is the consideration of future traffic volumes.
Non-transportation noise sources (e.g., Project operation) and construction noise impacts are typically Project-specific and highly localized. Construction activities associated with anticipated development within the area would contribute temporarily to the noise levels in the cumulative ambient noise environment, but in a highly localized and transient manner. As other development occurs in the area, noise from different types of uses (e.g., traffic, aircraft, fixed noise sources) would continue to combine, albeit on a localized basis, to cause increases in overall background noise conditions within the area. As a result, such sources do not significantly contribute to cumulative noise impacts at distant locations and are not evaluated on a cumulative level.
Implementation of the Project as well as cumulative development Projects within its vicinity would all be subject to applicable noise standards (descriptions of the standards applicable within the City of Santee are described in Section 4.5, Noise, of this EIR). On this basis, and because noise impacts of the Project with respect to relevant standards would be less than significant, the Project would not contribute to cumulative exceedances of noise standards, and its incremental effect would be a less-than-significant impact.
As discussed in Section 4.5, the Project would result in temporary noise increases during vegetation management and treatment activities that could result in a potentially significant impact. The Project would implement MM NOI-1, which requires administrative noise control or temporary noise abatement if mobile or stationary heavy construction equipment would operate at distances closer than 45 feet horizontal to an off-site noise-sensitive receiver (e.g., exterior of an existing residence). With implementation of MM NOI-1, Project impacts would be reduced to less than significant.
Treatment activities associated with the Project have the potential to overlap with the construction of other development projects in the City (City ID: 4, 10, 12, 14, 33, 43). Due to the decrease in noise levels with distance and the presence of physical barriers (i.e., intervening buildings and topography), noise due to construction of other projects would not meaningfully combine with the proposed Project to produce a cumulative noise effect during construction. By way of illustration, if there are two concurrent construction projects of comparable sound emission intensity, and the activity nearest to the studied noise-sensitive receptor is compliant with the City’s applicable noise threshold, the other activity could be no closer than three times the distance of the receptor to the nearest activity and not make a EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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cumulatively measurable contribution to the total and still result in a City-compliant noise exposure level.
If two concurrent Projects were close to a receptor, the cumulative noise would be one of the following:
▪ The louder (in dBA) of the two concurrent activities
▪ A logarithmic sum of the two activity noise levels that, per acoustic principles, cannot be more than 3 dBA greater than the louder of the two individual noise-producing activities In sum, cumulative construction noise is likely to be dominated by the closest or loudest activity to the receptor, and the combination would be no more than a barely perceptible difference (i.e., up to a 3 dBA change). Based on the cumulative project list, there are no construction projects that would potentially contribute construction noise that would, in combination with the Project, result in cumulative impacts.
Thus, cumulative impacts associated with temporary increases in ambient noise levels would be considered less than significant and not cumulatively considerable.
Result in generation of excessive groundborne vibration or groundborne noise levels.
Potential cumulative construction vibration impacts would occur at separate sites specific to the cumulative projects listed in Table 6-1. Groundborne vibration attenuates rapidly over short distances, and the likelihood of two projects generating overlapping vibration levels at a common receptor is unlikely.
Furthermore, all projects would be subject to applicable regulations that limit vibration impacts. For these reasons, cumulative vibration impacts would not be cumulatively considerable.
For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the Project area to excessive noise levels.
There are no private airstrips within the vicinity of the Project Site. The closest airport to the proposed Project Site is the Gillespie Field regional airport, approximately 1.1 miles south of the Project boundary.
Several nearby Projects in the cumulative project list (Table 6-1 above) are also located within 2 miles of Gillespie Field; however, operations from the public airport do not affect the noise exposure for the Project.
Therefore, noise associated with aircraft overflights for any of the cumulative projects would be less than significant, and the Project’s contribution would not be cumulatively considerable.
Wildfire
Substantially impair an adopted emergency response plan or emergency evacuation plan.
The Project Site would not result in inadequate emergency access or substantially impair an adopted emergency response plan. Additionally, all cumulative projects would be required to avoid conflict with the County Hazard Mitigation Plan, Santee EOP, and County Emergency Operations Plan and potential emergency evacuation routes in the area. Roads for all proposed projects are required to meet minimum widths, have all-weather surfaces, and be capable of supporting the imposed loads of responding emergency apparatus. The Project and all other future development projects in the service area would be subject to review by the Santee Fire Department and would be required to comply with all applicable State and County Building, WUI, and Fire Code requirements and other applicable local codes (e.g., City of Santee Municipal Code) and regulations related to fire safety, building construction, access, fire flow, and fuel EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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modification. Therefore, the Project’s contribution to cumulative impacts related to impairment of an adopted emergency response or evacuation plan would not be cumulatively considerable.
Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.
The cumulative context considered for wildfire impacts is San Diego County, and more specifically, the San Diego River watershed, which encompasses 434 square miles. As discussed in Section 4.6, Wildfire, CAL FIRE has mapped areas of fire hazards in the state based on fuels, terrain, weather, and other relevant factors. As shown in Figure 3-4, Fire Hazard Severity Zones, portions of the Project Site are in areas designated as Moderate and High FHSZs and bordered by areas designated as Moderate, High, and Very High FHSZs to the north and south. The Project is a vegetation management plan and does not include occupants. Implementation of the Project would reduce wildfire risk at the Project Site; therefore, the Project’s contribution to impacts related to slope, prevailing wind, or other factors contributing to exacerbating wildfire risk and exposing Project occupants would not be cumulatively considerable.
Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
The Project would not result in the installation or maintenance of associated infrastructure. All other future development projects in the service area would be subject to review by the fire department and would be required to comply with the State Fire Code other applicable local codes (e.g., City of Santee Municipal Code) and regulations related to fire safety, building construction, access, fire flow, and fuel modification.
Therefore, the Project’s contribution to impacts related to maintenance or installation of associated infrastructure on fire risk would not be cumulatively considerable.
Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes The Project could result in post-erosion caused by the loss of vegetation cover that previously had intercepted rain and runoff or slowed down the velocity of rainfall and runoff. This is an especially crucial consideration as erosion within the Project Site has the potential to contribute to sedimentation of the San Diego River, resulting in turbidity and potential infill. However, the Project includes applicable BMPs that would minimize impacts related to erosion. Through implementation of BMPs, the Project would not result in an impact related to exposing people or structures to significant risks as a result of runoff, post fire instability, or drainage changes, and impacts would not be cumulatively considerable,
6.2 Growth-Inducing Impacts
As stated in Section 15126.2(e) of the CEQA Guidelines, an EIR is required to include a discussion of a project’s growth-inducing effects. The CEQA Guidelines generally describe such effects as follows: (1) fosters economic growth, population growth, or construction of additional housing in the surrounding environment; (2) removes obstacles to population growth (e.g., a major expansion of a wastewater treatment facility that allows for more construction in the service area); (3) increases in population that tax existing services requiring construction of new facilities that could cause significant environmental effects; and (4) encourages and facilitates other activities that could significantly affect the environment, either individually or cumulatively.
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The proposed Project would require a temporary workforce to perform vegetation management. The number of construction workers needed during any given period would largely depend on the type of vegetation management but would likely range from a dozen to several dozen workers on a daily basis. These jobs would be filled by the local workforce and would not result in population increase from job opportunities. In conclusion, the Project would not remove obstacles to population growth and would not cause an increase in population such that new community facilities or infrastructure would be required outside of the Project Site. Lastly, the Project is not expected to encourage or facilitate other activities that could significantly affect the environment, as explained above. For these reasons, the Project is not considered to be significantly growth inducing.
6.3 Significant Irreversible Changes
The CEQA Guidelines require that an EIR address any significant irreversible changes that would be caused by implementation of a project. According to CEQA Guidelines Section 15126.2(d), such a change would involve one or more of the scenarios discussed below.
6.3.1 Change in Land Use that Commits Future Generations to Similar Uses
According to the City’s General Plan and the City’s Zoning Map, the land use and zoning designations for the Project Site are Park/Open Space and Public land uses (City of Santee 2017). The Project would be consistent with Chapter 13.16.020 of the City’s Municipal Code, which states that the Park/Open Space land use designation “indicates areas of permanent open spaces, biological resource protection, parks and/or areas precluded from major development because of land constraints or habitat preservation. The use regulations, development standards, and criteria are intended to provide low intensity development and encourage recreational activities and the preservation and management of natural resources. Recreational uses such as golf courses with customary support facilities are considered appropriate for these areas. Agricultural uses and sand extraction operations may, under special conditions, be allowed.” The zoning is consistent with the Park/Open Space land use designation of the General Plan (City of Santee 2003). The Project would not change the use of the Project Site.
Land uses surrounding the Project Site include Planned Development, as well as Residential land uses including Low-Medium Density Residential, Medium-Density Residential, Medium-High Residential, Neighborhood Commercial, Light Industrial, and General Industrial (City of Santee 2017). Since the Project Site is located within an existing urbanized area, the Project would not result in land use changes that would commit future generations to uses that do not occur in the Project Site. Thus, implementation would not commit future generations to new uses, given that this proposed use is already found in the Project Site.
6.3.2 Irreversible Damage from Environmental Accidents
Potential environmental accidents of concern include those events that would adversely affect the environment or public due to the type and quantity of materials released and the receptors exposed to that release. Vegetation management activities associated with the Project would involve some risk of environmental accidents. However, in addition to applicable Project BMPs, these activities would be conducted in accordance with all applicable federal, state, and local regulations, and would follow professional industry standards for safety. Any materials and handling of materials associated with environmental accidents would comply with applicable federal, state, and EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN JULY 2026
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local regulations. Use of any such materials would not be expected to cause irreversible damage due to the type or quantity of materials released and the receptors exposed to that release.
6.3.3 Large Commitment of Nonrenewable Resources
Commitment of nonrenewable resources includes issues related to increased energy consumption, loss of agricultural lands, and lost access to mining reserves. The Project does not include demolition or development; rather, the Project is the implementation of fuel treatment through vegetation management in the San Diego River Corridor. Therefore, there would not be an irretrievable commitment of labor, capital, and materials used during the construction and operation of the Project. Nonrenewable resources would primarily be committed in the form of fossil fuels such as fuel, oil, natural gas, and gasoline used by equipment associated with equipment used for mechanical techniques of vegetation management.
To ensure that energy implications are considered in project decisions, CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy (California Public Resources Code Section 21100[b][3]). Energy conservation implies that a project’s cost-effectiveness be reviewed not only in dollars, but also in terms of energy requirements. For many projects, cost-effectiveness may be determined more by energy efficiency than by initial dollar costs. A lead agency may consider the extent to which an energy source serving a project has already undergone environmental review that adequately analyzed and mitigated the effects of energy production.
Consistent with California Public Resources Code Section 211009(b)(3), CEQA Guidelines Appendix G, and a ruling set forth by the court in California Clean Energy Committee v. City of Woodland, potentially significant energy implications of a project must be considered in an EIR to the extent relevant and appliable to that project.
Accordingly, based on the energy consumption thresholds set forth in both Appendix F and Appendix G of the CEQA Guidelines, the Project’s estimated energy demands (both short- and long-term vegetation management demands) were not evaluated, because the proposed Project would not result in the use of energy long-term as no development would occur and vegetation management activities and associated energy consumption would be temporary. On this basis, the Project would not result in the inefficient, wasteful, or unnecessary consumption of energy.
6.4 Significant and Unavoidable Impacts
Pursuant to CEQA Guidelines Section 15126.2(c), an EIR must address any significant environmental impacts, including those that can be mitigated but not reduced to less than significant as a result of implementation of a project. As discussed throughout Chapter 4, Environmental Analysis, Chapter 5, Effects Found Not to be Significant, and Section 6.1, Cumulative Impacts, of this EIR, the Project would result in either less-than-significant impacts with mitigation, less-than-significant impacts, or no impact for all environmental issues areas.
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7 Alternatives
7.1 Alternatives to the Proposed Project
In accordance with CEQA Guidelines Section 15126.6, this Environmental impact Report (EIR) chapter contains a comparative evaluation of the San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan (Project) with alternatives to the Project, including a No Project Alternative. Consistent with California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this chapter focuses on alternatives to the Project that are capable of avoiding or substantially reducing any significant adverse impacts associated with the Project, even if the alternatives may impede attainment of Project objectives or prove less cost efficient. In addition, implementation of a Project alternative may potentially result in new impacts that would not have resulted from the Project.
The CEQA Guidelines require that the analysis of alternatives provide sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with a proposed project. Specifically, CEQA Guidelines Section 15126.6(a) outlines the scope of alternatives to a proposed project that must be evaluated:
An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.
Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selection of a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.
Under case law and CEQA Guidelines Section 15126.6(f), the discussion of alternatives is subject to a rule of reason and need not be exhaustive. CEQA Guidelines Section 15126.6(d) states that “if an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternatives shall be discussed, but in less detail than the significant effects of the project as proposed.” Determining factors that may be used to eliminate alternatives from detailed consideration in an EIR are (a) failure to meet most of the basic project objectives, (b) infeasibility, or (c) inability to avoid significant environmental impacts. CEQA Guidelines Section 15364 defines “feasibility” as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.”
An EIR need not consider a project alternative whose effects cannot be reasonably ascertained, whose implementation is remote and speculative, or whose execution does not substantially lessen or avoid the significant effects of a proposed project.
As discussed throughout Chapter 4, Environmental Analysis, and Chapter 6, Other CEQA Considerations, of this EIR, at the project and cumulative levels, the Project would result in less-than-significant impacts with mitigation incorporated, less-than-significant impacts, or no impact. 7 – ALTERNATIVES
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7.2 Considerations for Selection of Alternatives
Project Objectives
Section 15124(b) of the CEQA Guidelines requires that an EIR include a statement of the project objectives that “include the underlying purpose of the project and may discuss the project benefits.” The following objectives have been identified for the Project:
Objective 1 – Define strategy for specific fuel treatment zones for reducing hazardous fuel loads within the San Diego River corridor.
Objective 2 – Enhance community safety within the City of Santee through the reduction of wildfire risk.
Objective 3 – Reduce horizontal and vertical continuity of fuels and hazardous fuel loads through the removal of non-native and invasive species.
Objective 4 – Reduce ignition potential and fire intensity within the San Diego River corridor.
Summary of Project Impacts
Potentially feasible alternatives were developed with consideration of avoiding or lessening the significant adverse effects of the Project identified throughout this EIR. The following is a summary of significant impacts associated with the proposed Project.
Biological Resources
Direct impacts to special-status plants located in Zones 1 to 3 would be avoided through implementation of MM BIO-1, and impacts to special-status plant species would be less than significant.
Indirect impacts to special-status plants related to decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species would be reduced to below significance through implementation of MM BIO-1, MM BIO-2, and MM BIO-3. Indirect impacts to special-status plants would be less than significant.
Direct impacts to individual special-status wildlife species would be reduced to below significance through implementation of MM BIO-3 that would ensure no special-status species would be injured or harmed during Project activities. Direct impacts to sensitive vegetation communities that support special-status species would be reduced to below significance through the implementation of MM BIO-4 that would require compensatory mitigation for unanticipated impacts to riparian habitat and coastal sage scrub habitat within Zones 1 and 2. Thus, direct impacts to sensitive vegetation would be less than significant.
Impacts to nesting habitat for special-status avian species and other nesting and migratory birds and raptors during the nesting bird breeding season would be reduced to below significance through implementation of MM BIO-5, MM BIO-6, and MM BIO-7 that would ensure impacts to nesting habitat would only occur outside the nesting bird breeding season (February 15 through September 30). Implementation of MM BIO-3 would also reduce potentially adverse impacts to nesting birds by requiring a biological monitor be present to establish nest buffers if Project 7 – ALTERNATIVES
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activities cannot avoid the avian nesting season. Thus, direct impacts to nesting and migratory birds would be less than significant.
Indirect impacts to special-status wildlife, including nesting birds, due to decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species would be avoided through implementation of MM BIO-2 and MM BIO-3. Indirect impacts to special-status wildlife species would be less than significant.
Direct Impacts to sensitive vegetation communities in Zones 1 and 2 would be reduced to below significance through implementation of MM BIO-4 that would require compensatory mitigation. MM BIO-3 that would require a biological monitor be present to ensure treatment and vegetation removal activities occur only within the designated areas and no unauthorized impacts to sensitive vegetation communities occur would further reduce impacts to sensitive vegetation. Direct impacts to trees within Zone 3 would be reduced through implementation of MM BIO-9 that would require comprehensive mapping of tree species to be removed. Direct impacts to sensitive vegetation communities would be less than significant.
Indirect impacts to sensitive vegetation communities in Zones 1 to 3 through decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. would be avoided through implementation of MM BIO-2 and MM BIO-3. Indirect impacts to sensitive vegetation communities would be less than significant.
Direct impacts within Zones 1 and 2 from native brush thinning would be reduced to below significance through implementation of MM BIO-10 that would require permitting from the appropriate resource agencies (i.e., USACE, RWQCB, and CDFW). In addition, a biological monitor shall be present in accordance with MM BIO-3 to ensure treatment and vegetation removal activities occur in accordance with the Project’s aquatic resource permits, and there are no direct impacts occurring outside the designated areas. Direct impacts to jurisdictional aquatic resources within Zones 1 and 2 would be less than significant.
No direct impacts to potentially jurisdictional resources in Zone 3 are anticipated from Project implementation.
However, implementation of MM BIO-11 that would ensure activities occurring in Zone 3 would only involve treatment or removal of dead, dying, or invasive species utilizing methods that would not adversely impact aquatic resources. A biological monitor shall also be present in accordance with MM BIO-3 to ensure treatment and vegetation removal activities do not impact any aquatic resource areas located within Zone 3. Direct impacts to protected jurisdictional aquatic resources would be less than significant.
Indirect impacts to jurisdictional aquatic resources through decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species would be avoided through implementation of MM BIO-2 and MM BIO-3. Indirect impacts to jurisdictional aquatic resources would be less than significant.
Cultural and Tribal Cultural Resources
The Project would result in potentially significant impacts with regard to a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. With incorporation of MM CUL-1 and MM CUL-2, impacts associated with archaeological resources would be less than significant (Less Than Significant with Mitigation Incorporated).
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In the unexpected event that human remains are unearthed during vegetation management activities, impacts would be potentially significant. With implementation of MM CUL-3, potential impacts associated with human remains would be less than significant (Less Than Significant with Mitigation Incorporated).
No responses to the Assembly Bill 52 outreach letters to tribal contacts were received by the City requesting consultation. Although information regarding Tribal Cultural Resources has been received by the City, the archaeological sensitivity of the Project Site is considered to be moderate. For this reason, the Project Site should be treated as potentially sensitive for archaeological and Tribal Cultural Resources, and Mitigation Measure MM CUL-1 and MM CUL-2 is required to reduce potential impacts to unanticipated discovery of cultural resources and Tribal Cultural Resources. With implementation of MM CUL-1 and MM CUL-2, potential impacts associated with any buried, currently unrecorded/unknown tribal cultural resources would be less than significant (Less Than Significant with Mitigation Incorporated).
Noise
The Project would result in potentially significant impacts with regard to generation of a substantial temporary increase in ambient noise levels when the equipment-to-receiver horizontal distances are less than 45 feet. With incorporation of MM NOI-1, potential impacts related to temporary noise increases would apply and impacts would be less than significant (Less Than Significant with Mitigation Incorporated).
7.3 Project Alternatives Considered and Rejected
An EIR is required to identify any alternatives that were considered by the lead agency but were rejected as infeasible. Among the factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in an EIR are failure to meet most of the basic objectives of the Project, infeasibility, or inability to avoid significant environmental impacts.
With respect to the feasibility of potential alternatives to a proposed project, CEQA Guidelines Section 15126.6(t)(l) states the following:
Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries... and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site.
In determining an appropriate range of Project alternatives to be evaluated in this EIR, a number of possible alternatives were initially considered and then rejected. Project alternatives were rejected because they could not accomplish the basic objectives of the Project, they would not have resulted in a reduction of significant adverse environmental impacts, or they were considered infeasible to construct or operate.
Thinning Across Entire Project Site
This Alternative would apply Zone 1 Treatment standards across the entire Project Site, which would consist of removal or treatment of all fine fuels, dead vegetation, leaf litter, and woody debris; mowing of grasses not to exceed 4 inches; thinning of shrubs to a residual surface coverage of approximately 30%; and reduction of vertical continuity beneath tree canopies to achieve a separation of three times the height of the surface vegetation. This alternative would not include removal of native species unless they are dead or dying. This alternative would achieve 7 – ALTERNATIVES
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Project Objective 2 (reduction of wildfire risk), Objective 3 (reduce continuity of fuels), and Objective 4 (reduce ignition and fire intensity). This alternative would not achieve Objective 1 because it would not include a strategy for specific zones. Due to the sensitivity of the Project Site, increased thinning activities closer to the river would result in additional impacts to sensitive species, jurisdictional features, and sensitive habitat. This alternative also would come at an increased cost to the City due to the increased amount of work required to meet the Zone 1 standards across the Project Site. Additionally, this alternative would result in increased impacts due to longer and more intensive treatment.
Alternate Sites
CEQA does not require that an analysis of alternate sites always be included in an EIR. However, if the surrounding circumstances make it reasonable to consider an alternate site, then a project alternative should be considered and analyzed in the EIR. Pursuant to CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternate site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.”
Vegetation and activities in a different location would likely have similar impacts to the Project. There are other locations within the City that represent a wildfire risk to the city. However, the San Diego River corridor uniquely is primarily owned by the city of Santee and other government agencies that allows for coordinated fuel reduction implementation. Additionally, Project funding is provided by grants from the Federal Emergency Management Agency and the San Diego River Conservancy, which has been specifically identified for this Project Site. Further, the Project Site has been identified as having high ignition potential due to the history of ignitions at the Project Site.
7.4 Project Alternatives Under Further Consideration
The following provides an analysis of the No Project (Alternative 1) and the two management alternatives: the Zone 3 standards alternative (Alternative 2), and the manual and mechanical treatment alternative (Alternative 3).
The evaluation below provides a relative comparison between the Project and each of the three Project alternatives.
The analysis considers the issue areas evaluated in Chapter 4 and the cumulative analysis in Chapter 6 of this EIR.
In many cases, the Project and a Project alternative may share the same level of significance (i.e., both scenarios would result in a less-than-significant impact). However, although they might share the same level of significance under CEQA, the actual degree of impact may be slightly different for each scenario, and this relative difference is the basis for a conclusion of greater or lesser impacts compared to the Project.
An environmentally superior alternative is identified among the alternatives evaluated in this EIR. An alternative would be environmentally superior to the Project if it would result in fewer or less significant environmental impacts while achieving most of the Project objectives.
7.4.1 No Project (Alternative 1)
Project Alternative 1
Under Alternative 1, vegetation management within the Project Site would not occur, and the existing environment would remain in its current state. The Project Site would remain unchanged, and non-native 7 – ALTERNATIVES
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vegetation would remain in the San Diego River corridor and thinning closer to existing structures would not occur. In the short term, consistent with the existing conditions, the Project Site would continue to experience frequent ignitions. Under Alternative 1, it is assumed any existing maintenance and recreational activity at the Project Site would remain unchanged from existing conditions.
Comparative Analysis of Environmental Effects
Less-than-significant impacts of the Project related to biological resources (with mitigation), cultural and tribal cultural resources (with mitigation), hazards and hazardous materials, hydrology and water quality, and noise would be lesser in magnitude under Alternative 1 overall because vegetation management would not occur. Relative to the Project, Alternative 1 would result in greater impacts related to wildfire because vegetation management activities implemented under the Project would further reduce the risk of wildfire at the Project Site compared to Alternative 1
The following analysis compares the Project’s potentially significant environmental effects with those of Alternative 1.
Biological Resources
As discussed in Section 4.1, Biological Resources, the Project would result in less-than-significant impacts with mitigation incorporated with regard to special-status species, riparian habitat, or federally protected wetlands. The proposed Project would result in less-than-significant impacts regarding impediment of a migratory wildlife corridor, conflict with local policies, or conflict with an adopted or approved local, regional, or state habitat conservation plan.
Under Alternative 1, conditions at the Project Site would remain unchanged, and no impacts to biological resources would occur. Therefore, the extent of potential impacts under Alternative 1 would be less than the Project.
Cultural and Tribal Cultural Resources
As discussed in Section 4.2, Cultural and Tribal Cultural Resources, the Project would result in ground-disturbing vegetation management activities on site that could result in a potentially significant impact related to discovery of buried archaeological resources, previously unknown or undiscovered human remains, and tribal cultural resources. However, MM CUL-1 through MM CUL-3 would reduce potential impacts to less than significant. Under Alternative 1, no vegetation management activities would occur, and therefore, the extent of potential impacts under Alternative 1 would be less than the Project.
Hazards and Hazardous Materials
As discussed in Section 4.3, Hazards and Hazardous Materials, of this EIR, the Project would result in less-thansignificant impacts related to hazards and hazardous materials; however, Alternative 1 would further lessen these impacts overall because Alternative 1 would not include any vegetation management activities. Therefore, the extent of potential impacts related to thresholds A, B, C, D, E, and F (refer to Section 4.3 of this EIR) under Alternative 1 would be less than the proposed Project. The extent of potential impacts related to threshold G of Section 4.3, which states “would the project expose people or structures, either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires?” would be greater than the impacts of the Project because implementation of Alternative 1 would increase the risk to people or structures involving wildland fires by retaining the existing vegetation in the river corridor.
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Hydrology and Water Quality
As discussed in Section 4.4, Hydrology and Water Quality, of this EIR, the Project would result in less-than-significant impacts related to hydrology and water quality; however, Alternative 1 would further lessen these impacts overall because Alternative 1 would not include any vegetation management activities. Therefore, the extent of potential impacts under Alternative 1 would be less than the Project.
Noise
As discussed in Section 4.5, Noise, of this EIR, the analysis determined that the Project would not result in exceedances of local noise standards and concluded that the Project would result in less-than-significant construction- and operation-related noise impacts with implementation of MM NOI-1. However, Alternative 1 would further lessen these impacts overall because Alternative 1 would not include any vegetation management activities.
Therefore, the extent of potential impacts under Alternative 1 would be less than the Project.
Wildfire
As discussed in Section 4.6, Wildfire, of this EIR, the implementation of the Project would reduce wildfire risk at the Project Site by removing or treating vegetation. Under Alternative 1, no vegetation management would occur, and wildfire risk at the Project Site would remain the same. The Project would result in the use of mechanical vegetation management, which requires the use of heavy machinery and could result in ignition during high-fire-hazard weather conditions. However, the Project overall would reduce fire risk in the San Diego River Corridor by creating and maintaining a defensible space and managing hazardous fuel loads. Therefore, potential impacts related to wildfire under Alternative 1 would be greater than the proposed Project.
Relationship to the Project Objectives
Alternative 1 would not meet any of the Project objectives as it would not define a strategy for specific fuel treatment zones for reducing hazardous fuel loads within the San Diego River corridor (Objective 1), enhance community safety within the City of Santee through the reduction of wildfire risk (Objective 2), reduce horizontal and vertical continuity of fuels and hazardous fuel loads through the removal of non-native and invasive species (Objective 3), or reduce ignition potential and fire intensity within the San Diego River corridor (Objective 4).
7.4.2 Zone 3 Standards Alternative (Alternative 2)
Project Alternative 2
Under Alternative 2, the Project would include treatment or removal of non-native species, dead or dying vegetation, and debris, consistent with the standard of Zone 3 across the entire Project Site. Alternative 2 would not include any thinning or mowing activities described in Zone 1 or Zone 2 standards. This alternative would have the same boundary and treatment area as the Project.
Comparative Analysis of Environmental Effects
Less-than-significant impacts of the Project related to biological resources (with mitigation), cultural and tribal cultural resources (with mitigation), hazards and hazardous materials, hydrology and water quality, and noise would be lesser in magnitude under Alternative 2 overall because vegetation management would be less invasive without 7 – ALTERNATIVES
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thinning or mowing activities. Relative to the Project, Alternative 1 would result in greater impacts related to wildfire because implementation of Alternative 1 retains more existing vegetation, which would increase the risk of wildfire at the Project Site.
The following analysis compares the Project’s potentially significant environmental effects with those of Alternative 2.
Biological Resources
Similar to the Project, Alternative 3 would cover the same ground area as the Project and result in potential direct impacts to nesting birds and/or their habitat as well as indirect impacts to special-status wildlife species. However, impacts associated with fuel treatments identified as part of the vegetation management activities allowed for Zones 1 and 2 (manual, mechanical, and chemical) could result in decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. Under Alternative 2, these vegetation management techniques would not occur. In addition, MM BIO-1 through MM BIO-11 would be implemented under Alternative 2 to reduce biological impacts to less than significant. Therefore, the extent of potential impacts under Alternative 2 would be less than the Project.
Cultural and Tribal Cultural Resources
Similar to the Project, Alternative 2 would cover the same ground area as the Project and result in the potential to impact known or unknown cultural and tribal cultural resources. However, Alternative 2 would avoid the use of the more ground-disturbing vegetation management such as thinning and mowing, and would focus on the removal of dead, dying, or invasive vegetation. Under Alternative 2, ground disturbance could still occur where vegetation management occurs outside of existing disturbed areas. However, MM CUL-1 through MM CUL-3 would be implemented under Alternative 2 to reduce the potential impacts to less significant, and the extent of ground disturbance would be less than the Project. Therefore, the extent of potential impacts under Alternative 2 would be less than the Project.
Hazards and Hazardous Materials
As discussed in Section 4.3, typical hazardous materials used for treatment activities would include fuel and lubricants for hand labor and mechanical equipment, and potentially herbicides where needed based on site conditions. In addition, the Project includes BMPs to reduce the potential for hazardous materials to create hazards during routine handling. Alternative 2 would implement all Project BMP’s consistent with treatment or removal of non-native species, dead or dying vegetation, and debris. Alternative 2 would not include any thinning or mowing activities described in Zone 1 or Zone 2 standards, and therefore, BMPs related to mechanical treatment would not apply. Overall, the extent of potential impacts related to thresholds A, B, C, D, E, and F (refer to Section 4.3 of this EIR) under Alternative 2 would be less than the proposed Project. The extent of potential impacts related to threshold G of Section 4.3, which states “would the project expose people or structures, either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires?” would be greater than the impacts of the Project because implementation of Alternative 2 would increase the risk to people or structures involving wildland fires by retaining more of the existing vegetation in the river corridor.
Hydrology and Water Quality
Alternative 2 would not include any thinning or mowing activities described in Zone 1 or Zone 2 standards. Similar to the Project, implementation of Alternative 2 would result in less-than-significant impacts to hydrology and water 7 – ALTERNATIVES
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quality, although the avoidance of thinning or mowing activities of Alternative 2 would result in a reduced extent of potential to impact hydrology and water quality. Therefore, the extent of potential impacts under Alternative 2 would be less than the Project.
Noise
As discussed in Section 4.5, of this EIR, the analysis determined that the Project would not result in exceedances of local noise standards with implementation of MM NOI-1 and concluded that the Project would result in less-than-significant construction- and operation-related noise impacts. Like the Project, Alternative 2would include new sources of temporary vegetation management activities; however, because Alternative 2 would not include any thinning or mowing activities described in Zone 1 or Zone 2 standards, mechanical equipment would not be required, and impacts regarding noise would be reduced overall. Therefore, the extent of potential impacts under Alternative 2 would be less than the Project.
Wildfire
Although Alternative 2 would include treatment or removal of non-native species, dead or dying vegetation, and debris, consistent with the standard of Zone 3 across the entire Project Site, Alternative 2 would not include any thinning or mowing activities described in Zone 1 or Zone 2 standards. Thinning and mowing requires the use of mechanical equipment, which increases the chance for an ignition to occur during Project implementation. Without these management activities, the risk from mechanical ignition sources is reduced. However, the Project would reduce hazardous vegetation and wildfire intensity within the San Diego River corridor, thereby reducing potential wildfire-related risks to existing infrastructure for the long-term. Alternative 2 would not result in the same removal or treatment as the Project, however, as only Zone 3 standards would apply and less vegetation in Zones 1 and 2 would be removed or treated. Therefore, the extent of potential wildfire impacts under Alternative 2 would be greater than the Project.
Relationship to the Project Objectives
Alternative 2 would meet Objective 2 and Objective 4; however, the objectives would be met to a lesser extent.
Specifically, Objective 1 would not be met because there would not be a specific strategy at each specific Treatment Zone. Objective 3 would not be met because without the use of thinning or mowing activities, there would still be potential for tree canopy torching, and reduction of horizontal and vertical continuity would not occur.
7.4.3 Manual and Mechanical Treatment (Alternative 3)
Project Alternative 3
Under Alternative 3, the Project would only use manual and mechanical treatment methods to implement the standards for Zones 1-3. This Alternative would not include any chemical treatments. This alternative would have the same boundary and treatment area as the Project.
Comparative Analysis of Environmental Effects
Alternative 3 would result in hazards and hazardous materials, hydrology and water quality impacts less than the Project because the avoidance of chemical treatments would reduce the chance of hazardous materials exposure from herbicidal treatments and reduce the risk of hydrology and water quality impacts that could occur from 7 – ALTERNATIVES
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herbicide use. Relative to the Project, Alternative 3 would result in similar impacts related to biological, cultural, and tribal cultural resources because the Project Site and ground disturbance area would remain the same. In addition, Alternative 3 would result in impacts similar to the Project related to noise because noise generation from mechanical equipment would still occur under Alternative 3. The extent of potential impacts related to wildfire would be greater than the impacts identified in the Project because Alternative 3 would only use mechanical and manual techniques, in which greater use of mechanical equipment would result in a greater chance of ignition to occur from equipment use. In addition, some invasive species cannot be treated with only manual and mechanical treatment, and indirect impacts to sensitive status plant and wildlife species could occur through the spread of invasive species.
The following analysis compares the Project’s potentially significant environmental effects with those of Alternative 3.
Biological Resources
Under Alternative 3, the Project Site would remain the same as the proposed Project. The use of only mechanical and manual vegetation management would not reduce the impact to biological resources, and Alternative 3 would result in the same impacts as the Project. MM BIO-1 through MM BIO-11 would still apply to Alternative 3 and would reduce impacts to less than significant. In addition, the Project’s main purpose is fuel reduction of non-native invasive species that would result in functional uplift of the native vegetation communities throughout the Project Site. This would result in improved habitat quality for both wildlife movement corridors and nursery sites.
Mechanical and manual treatments alone would not be able to treat all invasive species. Therefore, the extent of potential biological impacts under Alternative 3 would be similar to the Project.
Cultural and Tribal Cultural Resources
Similar to the Project, Alternative 3 would result in ground-disturbing construction vegetation management activities on site that could result in a potentially significant impact related to discovery of buried archaeological resources, previously unknown or undiscovered human remains, and tribal cultural resources. However, similar to the proposed Project, MM CUL-1 through MM CUL-3 would apply and be implemented under Alternative 3 to reduce the potential impacts to less than significant. Therefore, the extent of potential impacts cultural and tribal cultural resources under Alternative 3 would be similar to the Project.
Hazards and Hazardous Materials
Typical hazardous materials used for Alternative 3 would include fuel and lubricants for hand labor and mechanical equipment. As discussed in Section 4.3, under the Project, chemical (herbicidal) treatment would be a limited, secondary tool rather than a primary treatment method. Under Alternative 3, herbicidal treatment would be avoided entirely. Project BMPs require that tools/equipment be serviced and fueled only in locations that would not allow grease, oil, fuel, or other hazardous materials to pass into streams or retained vegetation (Hand Labor BMP-6, and Water Quality BMP-1); that spill kits be available (Mechanical BMP-16 and Water Quality BMP-3); fueling would occur in identified refueling areas with secondary containment; and tools, lubricants, and fuels would be stored away from watercourses with secondary containment and labeling (Water Quality BMP-1, BMP-2, and BMP-4). All of these BMPs would still apply to Alternative 3. Overall, the extent of potential impacts related to thresholds A, B, C, D, E, and F (refer to Section 4.3 of this EIR) under Alternative 3 would be less than the proposed Project. The extent of potential impacts related to threshold G of Section 4.3, which states “would the project expose people or structures, either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires?” would be 7 – ALTERNATIVES
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greater than the impacts of the Project because without herbicidal treatment, implementation of Alternative 3 would increase fuel biomass thereby increasing the risk involving wildland fires in the long-term.
Hydrology and Water Quality
Hydrology and water quality impacts from the Project would occur from the use of heavy equipment and worker activity, which could result in erosion and mobilize sediments adjacent to the San Diego River. Additionally, herbicides, animal waste, and accidental release or fuels/lubricants from equipment have the potential to enter the San Diego River and surrounding wetlands. Under Alternative 3, herbicidal treatments would be avoided, and the extent of impacts related to hydrology and water quality would be reduced compared to the Project. Therefore, Alternative 3 would result in impacts less than the Project.
Noise
As discussed in Section 4.5, of this EIR, the analysis determined that the Project would not result in exceedances of local noise standards with implementation of MM NOI-1 and concluded that the Project would result in less-thansignificant construction- and operation-related noise impacts. Like the Project, Alternative 3 would include new sources and temporarily increase noise in the area from the use of mechanical equipment and workers at the Project Site. Avoiding the use of herbicidal treatment would not reduce the noise impacts substantially, as the main sources of noise generation would come from the mechanical equipment. Therefore, the extent of potential impacts related to noise would be similar to the Project.
Wildfire
As discussed in Section 4.6, of this EIR, implementation of the Project would include vegetation removal and treatment of non-native, invasive, and dead plant material. Alternative 3 would rely only on mechanical and manual vegetation management treatment activities. Hand labor and chemical management techniques are not activities that pose a risk for wildfire ignition; however, mechanical vegetation management requires the use of heavy machinery which could result in ignition during high-fire-hazard weather conditions. Alternative 3 would still include vegetation management activities that would reduce fire risk in the San Diego River Corridor by creating and maintaining a defensible space and managing hazardous fuel loads. However, the comprehensive treatment of invasive species from chemical treatment to ensure invasive species are managed at the Project Site would not occur. Further, the use of only mechanical and manual techniques would increase the risk of wildfire ignition during the implementation of Alternative 3. Therefore, the extent of potential impacts to wildfire risk under Alternative 3 would be greater than the Project.
Relationship to Project Objectives
Alternative 3 would have the ability to meet Objective 1, Objective 2, and Objective 4 because Alternative 3 would define a strategy for specific fuel treatment zones for reducing hazardous fuel loads within the San Diego River corridor (Objective 1), enhance community safety within the City of Santee through the reduction of wildfire risk (Objective 2), and reduce ignition potential and fire intensity within the San Diego River corridor (Objective 4). Alternative 3 would reduce horizontal and vertical continuity of fuels and hazardous fuel loads through the removal of non-native and invasive species Objective 3, but to a lesser degree than the Project, because without the use of chemical treatment, Alternative 3 would be less effective in the removal invasive species. 7 – ALTERNATIVES
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7.5 Environmentally Superior Alternative
Section 15126(e)(2) of the State CEQA Guidelines requires an EIR to identify an “environmentally superior alternative.” If the No Project/No Development Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other Project alternatives.
Table 7-1 compares the Project’s potentially significant environmental effects with those of the alternatives considered above.
Alternative 1 (No Project Alternative) would be the environmentally superior alternative because all impacts of the Project implementation would be avoided, and no environmental impacts would occur. However, Alternative 1 would not meet any of the Project’s Objectives, and the risk of wildfire at the Project Site would be greater than under Alternative 1 relative to the Project. Alternative 2 (Zone 3 Standards Only Alternative) would result in the same potentially significant impacts as the Project, though impacts to biological resources and historic resources would be of a lesser magnitude compared to the Project. Alternative 2 would meet most of the Project objectives, though not to the same extent as the Project, and Alternative 2 would fall short of meeting Objective 3. However, because Alternative 2 would result in reduced environmental impact to most resources compared to the Project and Alternative 3, Alternative 2 would be considered environmentally superior. This alternative could also meet half of the Project’s objectives. It should be noted that Alternative 2 would not avoid potentially significant impacts of the Project and would require mitigation outlined throughout the EIR.
Table 7-1. Project Alternatives Environmental Impacts Comparison Environmental Issue Project
No Project
(Alternative 1)
Zone 3 Standards
Alternative
(Alternative 2)
Manual and
Mechanical
Alternative
(Alternative 3)
Biological
Resources
Less than Significant
with Mitigation
Incorporated
Lesser Lesser Greater
Cultural and Tribal
Cultural
Less than Significant
with Mitigation
Incorporated
Lesser Lesser Similar
Hazards and
Hazardous
Materials
Less than Significant Greater Greater Lesser, Greater
(threshold G)
Hydrology and Water
Quality
Less than Significant Lesser Lesser Lesser
Noise Less than Significant
with Mitigation
Incorporated
Lesser Lesser Similar
Wildfire Less than Significant Greater Greater Greater
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8 List of Preparers
8.1 Report Preparers
City of Santee (Lead Agency)
Sandi Sawa, AICP, Director of Planning & Building/City Planner Marni Borg, Principal Environmental Planner
Harley Wallace, Director of Fire & Life Safety/Fire Chief Dustin DeMatteo, Emergency Manager – Hazard Mitigation Grant Program Project Manager Dudek (Environmental Consultant)
Carey Fernandes, Practice Director
Erin Lucett, Project Manager
Celeste Sainz, Environmental Analyst
Claire Alfano, Environmental Analyst
Ashley Dulaney, Environmental Analyst
Keegan Kingsbury, Environmental Analyst
Scott Eckhart, Associate Practice Director
Noah Stamm, Fire Protection Planner
Julia Cavalli, Fire Protection Planner
Brock Ortega, Senior Biologist
Danielle Mullen, Biologist
Kimberly Narel, Biologist
Patricia Ambacher, Architectural Historian
Matthew DeCarlo, Archaeologist
Nicole Frank, Architectural Historian
Keshia Montifolca, Archaeologist
David Faith, Archaeologist
Mark Storm, Senior Acoustician
Jason Greenstein, GIS and Graphics
Jordan Conway, GIS and Graphics
Alexander Quejado, Technical Editor
Laura Reed, Publications Specialist
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INTENTIONALLY LEFT BLANK
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9 References
Chapter 1: Executive Summary
City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report.
Chapter 2: Introduction
None
Chapter 3: Project Description
CAL FIRE (California Department of Fire and Forestry). 2025a. Fire Hazard Severity Zones Maps. https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9 CAL FIRE. 2025b. 2025 Strategic Fire Plan: https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdnendpoint.azureedge.net/-/media/osfm-website/what-we-do/community-wildfire-preparedness-andmitigation/2025-san-diego-imperial-unit-fire-planwithvp_paulbisson.pdf?rev=b196aeafb31848178 fb4032e6541fd86&hash=A97DAC275C65C1B6B0BE4B01DCA0377F.
City of Santee. 2003. Santee General Plan, Introduction. Accessed January 2026. https://www.cityofsanteeca.gov/ documents/planning-building/general-plan/gp-introduction.pdf.
City of Santee. 2017. City of Santee Land Use Map. Adopted August 27, 2003. Updated July 2017. Accessed January 2026. https://www.cityofsanteeca.gov/documents/planning-building/general-plan/gp-land-use-map.pdf.
Eucalyptus Hills Fire Safe Council. 2009. Eucalyptus Hills Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2016/06/Eucalyptus-Hills-11-2009.pdf.
Lakeside Fire Safe Council. 2024. Lakeside Community Wildfire Protection Plan. Accessed November 26, 2025. https://firesafesdcounty.org/wp-content/uploads/2024/08/Lakeside_2024_CWPP_FINAL.pdf.
RCD of Greater San Diego County (Resource Conservation District of Greater San Diego County) and San Diego County Fire Safe Council. 2019. San Diego County Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2023/09/CA_SanDiego_CNTY_2019.pdf.
Chapter 4: Environmental Analysis
None
9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-2
Section 4.1: Biological Resources
CCH (Consortium of California Herbaria). 2025. Consortium of California Herbaria (CCH) occurrence records. https://cch2.org/portal/collections/map/index.php
CDFW (California Department of Fish and Wildlife). 2025. California Natural Diversity Database (CNDDB).
Biogeographic Information and Observation System; Commercial Viewer. Biogeographic Data Branch.
Version 6. Accessed January 2026. https://apps.wildlife.ca.gov/bios6.
City of San Diego. 1998. Final MSCP Plan. Prepared by MSCP Policy Committee and MSCP Working Group.
San Diego, California: MSCP Policy Committee and MSCP Working Group. August 1998. Accessed January 2026. http://www.sandiegocounty.gov/content/dam/sdc/pds/mscp/docs/SCMSCP/ FinalMSCPProgramPlan.pdf.
City of Santee. 2003. City of Santee General Plan. Accessed January 2026. https://www.cityofsanteeca.gov/ departments/city-clerk/document-central/planning-building/general-plan.
City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report.
City of Santee. 2026. San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan. Prepared by Dudek.
April 2026.
Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Game, Nongame-Heritage Program. October 1986.
Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California,” Robert F. Holland, Ph.D., October 1986.
SWRCB (State Water Resources Control Board) 2021. State Policy for Water Quality Control: State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. Adopted April 2, 2019 and Revised April 6, 2021. https://www.waterboards.ca.gov/water_issues/programs/ cwa401/docs/2021/procedures.pdf.
Unitt, P., and A.E. Klovstad. 2004. San Diego County Bird Atlas (Vol. 39). San Diego Natural History Museum.
USFWS (U.S. Fish and Wildlife Service). 2025a. Surface Waters and Wetlands Mapper. Accessed January 2026. https://www.fws.gov/wetlands/data/mapper.html.
USFWS. 2025b. Critical Habitat for Threatened and Endangered Species. Map Viewer. Accessed January 2026. https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe09893cf75b8dbfb77.
USGS (U.S. Geological Survey). 2025. National Hydrography and Watershed Boundary Dataset. USGS National Hydrography Products. Accessed January 2026. https://www.usgs.gov/core-science-systems/ ngp/national-hydrography/watershed-boundary-dataset?qt-science_support_page_related_con= 4#qt-science_support_page_related_con.
9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-3
Section 4.2: Cultural, Tribal Cultural, Paleontological Resources NETR (National Environmental Title Research LLC). 2025. Historical Aerials Viewer. NETR Online. https://www.historicaerials.com/viewer.
Section 4.3: Hazards and Hazardous Materials
CAL FIRE (California Department of Forestry and Fire Protection). 2026. Fire Hazard Severity Zone Maps. https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9.
CalGEM (California Department of Conservation, Geologic Energy Management Division). 2026. Well Finder Database. https://www.conservation.ca.gov/calgem/Pages/Wellfinder.aspx.
CalRecycle (California Department of Resources Recycling and Recovery). 2026. Solid Waste Information System (SWIS) Database. https://www2.calrecycle.ca.gov.
City of Santee. 2023. City of Santee Hazard Mitigation Plan. https://www.sandiegocounty.gov/content/ dam/sdc/oes/emergency_management/HazMit/2023/2023%20City%20of%20Santee%20Haz%20Mit% 20Annex_Final%20.pdf.
City of Santee. 2025. City of Santee General Plan. Safety and Environmental Justice Element. cityofsanteeca.gov/documents/planning-building/general-plan/gp-safety-element.pdf.
DTSC (California Department of Toxic Substances Control). 2026. EnviroStor Database. https://www.envirostor.dtsc.ca.gov.
NPMS (National Pipeline Mapping System). 2026. Public Map Viewer. U.S. Department of Transportation. https://www.npms.phmsa.dot.gov.
SDCRAA (San Diego County Regional Airport Authority). 2010. Gillespie Field Airport Land Use Compatibility Plan.
January 25, 2010 (amended December 20, 2010). https://www.san.org/wp-content/uploads/ 2025/08/Gillespie-Field-Airport.pdf.
SWRCB (State Water Resources Control Board). 2026. GeoTracker Database. https://geotracker.waterboards.ca.gov.
Section 4.4: Hydrology and Water Quality
CGS (California Geological Survey). 2026. Tsunami Evacuation Maps Viewer. Accessed March 2026. https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/.
City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/ departments/planning-building/planning..
DWR (California Department of Water Resources). 2004. San Diego River Valley Groundwater Basin. Bulletin 118.
Accessed March 2026.https://water.ca.gov/-/media/DWR-Website/Web-Pages/Programs/GroundwaterManagement/Bulletin-118/Files/2003-Basin-Descriptions/9_015_SanDiegoRiverValley.pdf. 9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-4
FEMA (Federal Emergency Management Agency). 2026. National Flood Hazard Layer Viewer. Accessed March 2026.https://hazardsfema.maps.arcgis.com/apps/webappviewer/index.html?id= 8b0adb51996444d4879338b5529aa9cd.
Project Clean Water. 2025. San Diego River Watershed Management Area – Overview. Accessed March 2026. https://projectcleanwater.org/watersheds/san-diego-river-wma/#overview.
San Diego RWQCB (California Regional Water Quality Control Board, San Diego Region). 2021. San Diego Basin Plan Map (Beneficial Uses and Water Quality Designations). Geographic Information System (GIS) web application. Accessed March 2026. Available at: https://gispublic.waterboards.ca.gov/portal/ apps/experiencebuilder/experience/?id=bce693e31fc54bb485ffdfa5db5868f1.
San Diego RWQCB 2026. San Diego RWQCB Basin Plan: Introduction. Accessed March 2026. https://www.waterboards.ca.gov/sandiego/water_issues/programs/basin_plan/docs/chapter_1.pdf SDCWA (San Diego County Water Authority). 2026. Local Water Supplies – Groundwater. Accessed March 2026. https://www.sdcwa.org/your-water/local-water-supplies/groundwater/.
SWRCB (State Water Resources Control Board). 2021. Water Quality Control Plan for the San Diego Basin – Chapter 3. Accessed March 2026. https://www.waterboards.ca.gov/sandiego/water_issues/ programs/basin_plan/.
SWRCB. 2026. SGMA GSA Map Viewer. Accessed March 2026. https://sgma.water.ca.gov/webgis/ index.jsp?appid=gasmaster&rz=true.
Section 4.5: Noise
Caltrans (California Department of Transportation). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office. Sacramento, California. September 2013.
Caltrans. 2020. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office. Sacramento, California.
April 2020.
City of Santee. 2003. “Noise Element.” Santee General Plan. Adopted August 27, 2003. Accessed March 2026. https://www.cityofsanteeca.gov/documents/planning-building/general-plan/gp-noise-element.pdf.
County of San Diego. 2010. Gillespie Field Airport Land Use Compatibility Plan. Adopted January 25, 2010, amended December 20, 2010. Accessed March 2026. https://www.san.org/wp-content/ uploads/2025/08/Gillespie-Field-Airport.pdf.
FAA (Federal Aviation Administration). 2012. Advisory Circular. Noise Levels for U.S. Certificated and Foreign Aircraft. AC No: 36-1H, Change 1. May 2012.
FHWA (Federal Highway Administration). 2006. Roadway Construction Noise Model User’s Guide. FHWA-HEP-05- 054. January 2006.
9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-5
FICON (Federal Interagency Committee on Noise). 1992. Federal Agency Review of Selected Airport Noise Analysis Issues. U.S. Environmental Protection Agency, Washington, DC.
FTA (Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment. FTA Report No. 0123.
September 2018.
ICC (International Code Council). 2019. 2019 California Building Code (CBC), California Code of Regulations, Title 24, Part 2.
OPR (California Office of Planning and Research). 2017. General Plan Guidelines: Appendix D—Noise Element Guidelines. State of California. Available at: https://lci.ca.gov/docs/OPR_Appendix_D_final.pdf.
Section 4.6: Wildfire
CAL FIRE (California Department of Forestry and Fire Protection). 2024. CAL FIRE Strategic Plan 2024. https://calfire-communications.paperturn-view.com/cal-fire-strategicplan24-web?pid=ODg8828162&v=2.
CAL FIRE. 2025a. Historical Fire Perimeters. https://www.fire.ca.gov/what-we-do/fire-resource-assessmentprogram/fire-perimeters.
CAL FIRE. 2025b. 2025 Strategic Fire Plan: https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdnendpoint.azureedge.net/-/media/osfm-website/what-we-do/community-wildfire-preparedness-andmitigation/2025-san-diego-imperial-unit-fire-planwithvp_paulbisson.pdf?rev= b196aeafb31848178fb4032e6541fd86&hash=A97DAC275C65C1B6B0BE4B01DCA0377F.
CAL FIRE. 2025c. Fire Hazard Severity Zones Maps. https://experience.arcgis.com/experience/ 5065c998b4b0462f9ec3c6c226c610a9.
City of Santee. 2025a. Fire & Life Safety Services In Santee California. https://www.cityofsanteeca.gov/ departments/fire-life-safety-services.
City of Santee. 2025b. Safety and Environmental Justice Element. https://www.cityofsanteeca.gov/ documents/planning-building/general-plan/gp-safety-element.pdf.
County of San Diego. 2022. Emergency Operation Plan Summary. https://www.sandiegocounty.gov/ content/dam/sdc/oes/emergency_management/plans/op-area-plan/2023-eop/ EOP2023_Complete%20Plan.pdf.
County of San Diego. 2023. Multi-Jurisdictional Hazard Mitigation Plan.https://www.sandiegocounty.gov/ content/dam/sdc/oes/emergency_management/HazMit/2023/MJHMP_SD%20County%20Base% 20Plan%202023.pdf.
DOI and USDA (Department of Interior and United States Department of Agriculture). 2000. Managing the Impact of Wildfires on Communities and the Environment. https://clintonwhitehouse4.archives.gov/ CEQ/firereport.html.
Eucalyptus Hills Fire Safe Council. 2009. Eucalyptus Hills Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2016/06/Eucalyptus-Hills-11-2009.pdf. 9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-6
FEMA (Federal Emergency Management Agency). 2026. National Flood Hazard Layer Viewer. Accessed March 2026.https://hazardsfema.maps.arcgis.com/apps/webappviewer/index.html?id= 8b0adb51996444d4879338b5529aa9cd.
Lakeside Fire Safe Council. 2024. Lakeside Community Wildfire Protection Plan. Accessed November 26, 2025. https://firesafesdcounty.org/wp-content/uploads/2024/08/Lakeside_2024_CWPP_FINAL.pdf.
Moench, R. and J. Fusaro. 2012. Soil Erosion Control after Wildfire. https://www.extension.colostate.edu/ docs/pubs/natres/06308.pdf.
National Wildfire Coordinating Group. 2009. Guidance for Implementation of Federal Wildland Fire Management Policy. February 13, 2009. https://www.doi.gov/sites/doi.gov/files/uploads/2009-wfm-guidance-forimplementation.pdf.
RCD of Greater San Diego County (Resource Conservation District of Greater San Diego County) and San Diego County Fire Safe Council. 2019. San Diego County Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2023/09/CA_SanDiego_CNTY_2019.pdf.
San Diego River Park Foundation. 2026. Homelessness. https://sandiegoriver.org/discover/homelessness/.
USDCESO (Unified San Diego County Emergency Services Organization) and County of San Diego. 2022.
Operational Area Emergency Operations Plan. September 2022. Accessed October 2, 2025. https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_management/plans/ op-area-plan/2023-eop/EOP2023_Complete%20Plan.pdf.
Chapter 5: Effects Not Found To Be Significant
Caltrans (California Department of Transportation). 2026. California State Scenic Highway Mapping System.
Accessed February 2026. https://caltrans.maps.arcgis.com/apps/webappviewer/ index.html?id=465dfd3d807c46cc8e8057116f1aacaa.
City of Santee. 2017. City of Santee Land Use Map. Adopted August 27, 2003; updated July 2017. Accessed January 2026.https://www.cityofsanteeca.gov/documents/planning-building/general-plan/ gp-land-use-map.pdf.
City of Santee. 2020. City of Santee General Plan. City of Santee, California. Available at:
https://www.cityofsanteeca.gov/planning-building/general-plan (accessed March 2026).
City of Santee. 2022. Draft Program Environmental Impact Report for the Housing Element Rezone Program Implementation. State Clearinghouse No. 2021100263. City of Santee, California. Available at:
https://ceqanet.lci.ca.gov/2021100263/2 (accessed March 2026).
City of Santee. 2025a. City of Santee General Plan. Safety and Environmental Justice Element. cityofsanteeca.gov/documents/planning-building/general-plan/gp-safety-element.pdf.
City of Santee. 2025b. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report. 9 – REFERENCES
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 9-7
City of Santee. 2025c. General Plan – Conservation Element. Accessed February 2026. https://www.cityofsanteeca.gov/departments/city-clerk/document-central/planning-building/generalplan/gp-conservation-element.pdf.
County of San Diego Sheriff’s Department. 2026. Santee Station Information. Accessed February 2026. https://www.sdsheriff.gov/Home/Components/FacilityDirectory/FacilityDirectory/42/34.
DOC (Department of Conservation). 2022 Important Farmland Finder. State of California. Available at:
https://maps.conservation.ca.gov/DLRP/CIFF/ (accessed March 2026).
San Diego River Park Foundation. 2026. Homelessness Along the River Corridor. Accessed February 2026. https://sandiegoriver.org/discover/homelessness/.
SDAPCD (San Diego County Air Pollution Control District) 2022. 2022 Regional Air Quality Strategy (RAQS).
Accessed February 2026. San Diego Regional Air Quality Strategy USCB (U.S. Census Bureau). 2024. QuickFacts: El Cajon city, California; Santee city, California. Retrieved March 3, 2026, from https://www.census.gov/quickfacts/fact/table/ elcajoncitycalifornia,santeecitycalifornia/PST045224.
Chapter 6: Other CEQA Considerations
CGS (California Geological Survey). 2026. Tsunami Evacuation Maps Viewer. Accessed March 2026. https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/.
City of Santee. 2003. City of Santee General Plan. Accessed January 2026. https://www.cityofsanteeca.gov/ departments/city-clerk/document-central/planning-building/general-plan.
City of Santee. 2017. City of Santee Land Use Map. Adopted August 27, 2003. Updated July 2017. Accessed January 2026. https://www.cityofsanteeca.gov/documents/planning-building/general-plan/ gp-land-use-map.pdf.
FEMA (Federal Emergency Management Agency). 2026. National Flood Hazard Layer Viewer. Accessed March 2026.https://hazardsfema.maps.arcgis.com/apps/webappviewer/index.html?id= 8b0adb51996444d4879338b5529aa9cd.
Chapter 7: Alternatives
None
Chapter 8: List of Preparers
None
9 – REFERENCES
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INTENTIONALLY LEFT BLANK
Appendix A
NOP and Public Comments
NOTICE OF PREPARATION
of a Draft Environmental Impact Report and
Notice of Public Scoping Meeting
Project: San Diego River Fire Hazard Mitigation Plan
Project Case Files: Environmental Impact Report ENV-2026-0001 Project Proponent: City of Santee
Project Location: The almost 300-acre Project Site is composed of 32 parcels along the San Diego River corridor through the center of the City of Santee as shown in Figure 1, Project Location. The Project Site extends along the river corridor from Forester Creek at the western boundary to the Lakeside boundary in the east, including Mast Park West, Mast Park Wetland Restoration Area, Mast Park East, Mission Creek, Walker Trails Open Space, and Walker Preserve. Surrounding the corridor are urban neighborhoods, commercial districts, transportation infrastructure, parks, and open space preserves, creating a landscape typical of a wildland-urban interface (WUI).
Environmental Impact Report: The City of Santee (City) is preparing an Environmental Impact Report (EIR) for the implementation of the San Diego River Fire Hazard Mitigation Plan (Project). The City will be the lead agency under the California Environmental Quality Act (CEQA) for the project. This Notice of Preparation (NOP) describes the proposed Project that will be analyzed in the EIR and identifies areas of probable environmental effects of the project.
As specified in the CEQA Guidelines, the NOP will be circulated for a 30-day scoping period. Agencies, organizations, and interested members of the public are invited to provide input on the scope of the environmental analysis. If you are a responsible or trustee agency, the views of your agency are requested as to the scope and content of the environmental information which is germane to your agency’s statutory responsibilities in connection with the proposed project. If no response or well-justified request for additional time is received by any responsible agency or trustee agency by the end of the review period, we presume that these agencies have no response. All comments concerning the scope of the EIR must be submitted in writing during the review period and addressed to:
Harley Wallace, Fire Chief
Santee
Santee, California 92071
[email protected]
(619) 258-4100 ext. 207
San Diego River Fire Hazard Mitigation Plan EIR NOP
Electronic comments whose file size exceeds 10 MB must request a link to upload the comments. The NOP comment period begins on February 6, 2026 and closes at 5:00 p.m. on March 6, 2026. The City will consider all written comments received during the noticed public scoping period in the preparation of the EIR.
Public Scoping Meeting:
The City will hold a scoping meeting to provide an opportunity to submit comments on the scope of the environmental issues to be addressed in the EIR. The public scoping meeting will be held on Wednesday, February 18, 2026 at City Hall, 10601 Magnolia Avenue, Santee, CA 92071 in the Council Chambers, from 5:00 PM to 6:30 PM. All parties are welcome to attend and are encouraged to recommend environmental issues, mitigation measures, and alternatives to the project that they believe should be addressed in the EIR.
Project Background and Description:
The City of Santee Fire Department has initiated development of the San Diego River Fire Hazard Mitigation Plan (FHMP) to reduce wildfire risk in and around high-priority sites along the San Diego River corridor. This area lies within the wildland-urban interface and includes critical public infrastructure, adjacent residential neighborhoods, and biologically sensitive habitats. The need for a targeted, ecologically conscious approach to vegetation management is underscored by increasing fire risk, invasive plant encroachment, and complex access and ownership constraints unique to the corridor.
The Santee Fire Department responded to 174 fires in or near the Project Site in 2024 and 2025. Portions of the Project Site are located within Moderate and High, Fire Hazard Severity Zones. As part of the FHMP, a Fuels Treatment Plan (FTP) will provide a framework for vegetation management that includes treatment strategies tailored to each of the parcels’ wildfire exposure, access conditions, existing vegetation, and proximity to sensitive resources. The FTP outlines defensible space creation/maintenance standards, prescribes vegetation treatments, and identifies zone boundaries to minimize wildfire risk in the wildland-urban interface. It also documents the species and quantities of vegetation to be removed, defines potential removal processes, and incorporates best management practices to minimize or avoid impacts to resources in the project site.
The objectives of the proposed project are identified below:
▪ Objective 1 – Define strategy for defined fuel treatment zones for reducing hazardous fuel loads within the San Diego River corridor. ▪ Objective 2 – Enhance community safety within the City of Santee through the reduction of wildfire risk.
▪ Objective 3 – Reduce horizontal and vertical continuity of fuels and hazardous fuel loads through the removal of non-native and invasive species. ▪ Objective 4 – Reduce ignition potential and fire intensity within the San Diego River corridor.
San Diego River Fire Hazard Mitigation Plan EIR NOP
Discretionary Actions:
The City Council actions that would be considered for the proposed project include, but would not be limited to:
• Adopt the San Diego River Fire Hazard Mitigation Plan, including the Fuels Treatment Plan
• Certify the EIR for the San Diego River Fire Hazard Mitigation Plan Project Alternatives:
The EIR will evaluate a reasonable range of project alternatives that would feasibly attain most of the project objectives but would avoid or substantially lessen any of the significant effects of the project, including the required No Project Alternative. The EIR will also identify any alternatives that were considered but rejected as infeasible and explain the rationale for this determination.
Potential Environmental Effect Areas:
The EIR will describe the reasonably foreseeable and potentially significant adverse effects of the proposed project (both direct and indirect) and identify which are found to be less than significant. The EIR will also evaluate the cumulative impacts of the project when considered in conjunction with other related past, present, and reasonably foreseeable future projects. The EIR will evaluate all of the topic areas, as follows:
• Biological Resources
• Cultural Resources
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Noise and Vibration
• Tribal Cultural Resources
• Wildfire
As environmental documentation for this project is completed, it will be available for review at the City’s Fire Department located in Building 5 and at the City Clerk’s Office in Building 3 at Santee City Hall, 10601 Magnolia Avenue, Santee CA 92071, and online at:
https://www.cityofsanteeca.gov/services/project-environmental-review San Diego River Fire Hazard Mitigation Plan EIR NOP
I hope you are both doing well. I am writing regarding the San Diego River Fire Hazard Mitigation Plan (FHMP), listed under SCH No. 2026020351.
In reviewing the Notice of Completion (Appendix C), I noted the reference to an attached Assessor’s Parcel Number (APN) list for the 32 parcels included in the project area. However, this parcel list does not appear in the publicly accessible CEQAnet documents or the NOP release. [vertikalrms.com], [arcgis.com] To properly assess how the FHMP may interface with our properties near the corridor, I am kindly requesting the following:
Requested Documents
The full APN list for all parcels included in the FHMP project area Any parcel boundary maps, shapefiles, or PDF exhibits depicting the project area Any supporting documentation describing parcel-specific involvement (ownership, access easements, treatment areas, etc.)
These materials will help us evaluate adjacency, potential impacts, and coordination needs related to operations at:
Carlton Hills Plaza
8915–9312 Carlton Hills Blvd, Santee, CA 92071
(Associated APNs include: 383‑156‑01, 383‑156‑02, 383‑156‑03, 383‑156‑04, 383‑156‑05) If there is a preferred formal process for requesting these documents, I’d be happy to follow it.
Thank you both for your time and support. We appreciate the City’s work on wildfire mitigation along 1/2
the San Diego River corridor and look forward to reviewing the additional materials.
Best regards,
Sara Kniffen
Property Manager
Carlton Hills Plaza / PPI Real Estate
1 Voice Message
Dear Harley Wallace,
You have a new voice message:
From: NEW FRONTIER (619) 449-1800
Received: Tuesday, February 10, 2026 at 10:14 AM
Length: 00:56
To: (619) 258-4100 * 202 Harley Wallace
Voicemail Preview:
"Hi, good morning, Harley. This is Randy Northcote with New Frontier Mobile Home Park. I'm the park manager and we own a sliver of property in the uh River Bottom next to the Walker Trail and I was calling regarding the um fire hazard mitigation plan and notice of preparation. And I know back in 2021 I had worked with Tom Romstad when the city got some funding to do some clearing and remove non-native species. Um but I just want to let you know that we are 100% in support of that.
So if you need a uhrelease liability or anything from us. If you guys could remove some of the dead brush out of there and the eucalyptus and other stuff, that would be great. So, if you need anything from me, um, the best phone number is our office 619-449-1800 and we're typically in Monday through Friday from 9:00 a.m. till noon. So, once again, it's Randy at New Frontier Mobile Home Park 619-449-1800. Thanks and have a great day."
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CHAIRPERSON
Reginald Pagaling
Chumash
VICE-CHAIRPERSON
Buffy McQuillen
Yokayo Pomo, Yuki,
Nomlaki
SECRETARY
Isaac Bojorquez
Ohlone-Costanoan
PARLIAMENTARIAN
Wayne Nelson
Luisefio
COMMISSIONER
Sara Dutschke
Miwok
COMMISSIONER
Stanley Rodriguez
Kumeyaay
COMMISSIONER
Bennae Calac
Pauma-Yuima Band of
Luisefio Indians
COMMISSIONER
Vacant
COMMISSIONER
Vacant
EXECUTIVE SECRETARY
Andrew Alejandre
Paskenta Band of
Nomlaki Indians
NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 9 569 l
(916) 373-3710
[email protected] .gov
STATE OF CALIFORNIA Gavin Newsom Governor
NATIVE AMERICAN HERITAGE COMMISSION
February 10, 2026
Harley Wallace
City of Santee
Santee Fire Department Administration
10601 Magnolia Avenue
Santee CA 92071
Re: 2026020351 San Diego River Fire Hazard Mitigation Plan Project, San Diego County To Whom It May Concern:
The Native American Heritage Commission (NAHC) has received the Notice of Preparation (NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project referenced above. The California Environmental Quality Act (CEQA) (Pub. Resources Code §21000 et seq.), specifically Public Resources Code §21084.1, states that a project that may cause a substantial adverse change in the significance of a historical resource, is a project that may have a significant effect on the environment. (Pub. Resources Code § 21084.1; Cal. Code Regs., tit.14, § 15064.5 (b) (CEQA Guidelines§ 15064.5 (b)). If there is substantial evidence, in light of the whole record before a lead agency, that a project may have a significant effect on the environment, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)( 1) (CEQA Guidelines§ 15064 (a) (1 )).
In order to determine whether a project will cause a substantial adverse change in the significance of a historical resource, a lead agency will need to determine whether there are historical resources within the area of potential effect (APE).
CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of 2014) (AB 52) amended CEQA to create a separate category of cultural resources, "tribal cultural resources" (Pub. Resources Code §21074) and provides that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment. (Pub. Resources Code § 21084.2). Public agencies shall, when feasible, avoid damaging effects to any tribal cultural resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice of preparation, a notice of negative declaration, or a mitigated negative declaration is filed on or after July 1, 2015. If your project involves the adoption of or amendment to a general plan or a specific plan, or the designation or proposed designation of open space, on or after March 1, 2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).
Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal consultation requirements of Section 106 of the National Historic Preservation Act of 1966 ( 154 U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.
The NAHC recommends consultation with California Native American tribes that are traditionally and culturally affiliated with the geographic area of your proposed project as early as possible in order to avoid inadvertent discoveries of Native American human remains and best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as well as the NAHC's recommendations for conducting cultural resources assessments.
Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with any other applicable laws.
1 Hello Chief Wallace,
Thank you for taking the time to meet with my husband (CC'd) and I at last week's fire hazard mitigation plan meeting. As we mentioned, our home is very close to Forester Creek (9009 Gorge Ave). Caltrans has the right of way to the land behind our house. We submit customer service requests for maintenance to clear out the hazardous brush.
Our most recent request was on 8/2/24. Jon has followed up regularly with Caltrans since then, but we are still awaiting service. At one point our ticket was erroneously closed by Caltrans and we had to reopen it. The latest communication we received states that the service might be performed this summer. They said that they had difficulty securing the money to complete the job. We feel that it wouldn't be so cumbersome or expensive if they had addressed it sooner. We have never been able to get on a regular maintenance schedule.
We are very excited about the grant secured for the fire mitigation plan and look forward to the work beginning in October. We're hopeful that some of the ongoing maintenance that's part of that plan will be done in conjunction with Caltrans to avoid this situation in the future. That said, we're looking for any assistance or insight you might be able to provide to get our current request addressed before the grant work begins.
Information about our requests:
Ticket numbers
New ticket #1136594 (supposed to be addressed this summer) Old ticket #1038607 (erroneously closed by Caltrans)
Contacts
[email protected]
[email protected]
Thank you again. We have no further input about the EIR for the fire hazard mitigation plan, but we wanted to note that we have access to the area behind our house via a gate in our backyard should anyone need it. We look forward to the next public review period for the plan.
Best,
Amy & Jon Newton
SANDIEGOCOUNTY.GOV
MARISA K. BARRIE, PE
DIRECTOR
PUBLIC WORKS
5510 OVERLAND AVENUE, SUITE 410, SAN DIEGO, CALIFORNIA 92123-1237 (858) 694-2212 KATHRYN A. STEWART, PE
ASSISTANT DIRECTOR
March 3, 2026
VIA E-MAIL
Mr. Harley Wallace, Fire Chief
Santee Fire Department Administration
10601 Magnolia Avenue
Santee, CA 92071
[email protected]
Subject: CITY OF SANTEE NOTICE OF PREPARATION OF DRAFT EIR FOR SAN
DIEGO RIVER FIRE HAZARD MITIGATION PLAN PROJECT
Public Review Comments from County of San Diego, Department of Public Works
Dear Mr. Wallace,
The County of San Diego (County), Department of Public Works staff have reviewed the Notice of Preparation of a Draft Environmental Impact Report for the San Diego River Fire Hazard Mitigation Plan Project (Project). County staff appreciate the opportunity to review the Project and offer the following comments for your consideration. Please note, none of the comments should be construed as the County’s support for the Project.
The County’s Department of Public Works, Transportation Division – Traffic Engineering strives to achieve and maintain a safe and efficient County Maintained Road system for motorists, bicyclists, pedestrians, and equestrians through traffic safety improvements such as signals, signs, striping, guard rails, etc.
Traffic Engineering has completed its review and offers the following comments:
• The IJN documents indicate that the 300-acre project site is located within the City of Santee’s (City) jurisdiction. The City should confirm that the entire project site and all areas proposed for vegetation removal are fully within the City’s jurisdiction. If any of the work were to extend into the adjacent unincorporated areas or County-maintained Right-of-Way (ROW), there could be implications for the County, such as potentially requiring ongoing, long-term vegetation maintenance.
Mr. Harley Wallace
San Diego River Fire Hazard Mitigation Plan
March 3, 2026
SANDIEGOCOUNTY.GOV
The County DPW requests that the City confirm in the EIR there will be no overlap in vegetation removal/work with the County’s property or ROW. Alternatively, please include a discussion and a visual figure in the EIR showing locations where an overlap may occur and what actions the City will take to ensure ongoing maintenance of these areas.
Let us know if you have any questions, by contacting Richard Chin, DPW Project Manager, at [email protected].
Thank you,
Ernest Bartley III, Program Manager
County of San Diego, Department of Public Works
Transportation Division, Traffic Engineering
2 Dear Mr. Wallace,
Attached please find County of San Diego, Department of Public Works’ comments to the NOP prepared for the DEIR for City of Santee’s San Diego Fire Hazard Mitigation Plan Project (https://www.cityofsanteeca.gov/departments/fire-life-safety-services/san-diego-river-hazard-mitigationgrant-program).
Let us know if you have any questions.
Thank you,
Masha Landau, Land Use/Environmental Planner III
Department of Public Works, Environmental Services Unit County of San Diego Land Use and Environment Group
C: 619-385-7591
Email: [email protected]
2 Good Morning,
My name is Kelly Debenham and I am a resident of Santee. I live along the river walk from Cuyamaca to Mast Park. This walk is lovely, green and dense with foliage. The river walk has tall trees, shrubs, pussy willows and grassy banks There is a literal symphony of birdsong that brings a smile to my face on my daily walks. Hawks have built annual nests in the tall trees, migratory birds stop over, rabbits, skunks, possum and coyotes lives in the under growth. I even saw a mule deer one evening! I am Concerned about the mitigation plan. I am afraid that the non-native plants and shrubs will be stripped away leaving a muddy river bed with a few tall native trees and, during the rainy season, refuse.
Please consider the wildlife who make this area their home and the humans who escape every day to this lovely walk to nature bathe. It is an oasis in the middle of a busy, noisy city and gives me Great joy.
Thank you for your time.
Kelly Debenham
375 Whispering Willow Drive, Unit C
Santee, CA
“Improving lives and communities through transportation.” DISTRICT 11
4050 TAYLOR STREET, MS-240
SAN DIEGO, CA 92110
(619) 985-1587 | FAX (619) 688-4299 TTY 711
www.dot.ca.gov
March 9, 2026
11-SD-52
PM 16.544
San Diego River Fire Hazard Mitigation Plan
NOP/SCH#2026020351
Mr. Harley Wallace
Fire Chief
City of Santee
Fire Department
10601 Magnolia Street
Santee, CA 92071
Dear Mr. Wallace:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the Notice of Preparation of an Environmental Impact Report (NOP) for the San Diego River Fire Hazard Mitigation Plan located near State Routes 52 (SR-52) and 67 (SR-67). The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities.
Safety is one of Caltrans’ strategic goals. Caltrans strives to make the year 2050 the first year without a single death or serious injury on California’s roads. We are striving for more equitable outcomes for the transportation network’s diverse users. To achieve these ambitious goals, we will pursue meaningful collaboration with our partners. We encourage the implementation of new technologies, innovations, and best practices that will enhance the safety on the transportation network. These pursuits are both ambitious and urgent, and their accomplishment involves a focused departure from the status quo as we continue to institutionalize safety in all our work.
Caltrans is committed to prioritizing projects that are equitable and provide meaningful benefits to historically underserved communities, to ultimately improve transportation accessibility and quality of life for people in the communities we serve.
We look forward to working with the City of Santee in areas where the City and Caltrans have joint jurisdiction to improve the transportation network and connections between various modes of travel, with the goal of improving the experience of those who use the transportation system.
Mr. Harley Wallace, Fire Chief
March 9, 2026
“Improving lives and communities through transportation.” Caltrans has the following comments:
Hauling
The California Department of Transportation (Caltrans) has discretionary authority with respect to highways under its jurisdiction and may, upon application and if good cause appears, issue a special permit to operate or move a vehicle or combination of vehicles or special mobile equipment of a size or weight of vehicle or load exceeding the maximum limitations specified in the California Vehicle Code. The Caltrans Transportation Permits Issuance Branch is responsible for the issuance of these special transportation permits for oversize/overweight vehicles on the State Highway network. Additional information is provided online at:
https://dot.ca.gov/programs/traffic-operations/transportation-permits.
Environmental
Caltrans welcomes the opportunity to be a Responsible Agency under the California Environmental Quality Act (CEQA), as we have some discretionary authority of a portion of the project that is in Caltrans’ R/W through the form of an encroachment permit process. We look forward to the coordination of our efforts to ensure that Caltrans can adopt the alternative and/or mitigation measure for our R/W. We would appreciate meeting with you to discuss the elements of the Environmental Document that Caltrans will use for our subsequent environmental compliance.
An encroachment permit will be required for any work within the Caltrans’ R/W prior to construction. As part of the encroachment permit process, the applicant must provide approved final environmental documents for this project, corresponding technical studies, and necessary regulatory and resource agency permits. Specifically, CEQA determination or exemption. The supporting documents must address all environmental impacts within the Caltrans’ R/W and address any impacts from avoidance and/or mitigation measures.
We recommend that this project specifically identifies and assesses potential impacts caused by the project or impacts from mitigation efforts that occur within Caltrans’ R/W that includes impacts to the natural environment, infrastructure including but not limited to highways, roadways, structures, intelligent transportation systems elements, on-ramps and off-ramps, and appurtenant features including but not limited to fencing, lighting, signage, drainage, guardrail, slopes and landscaping. Caltrans is interested in any additional mitigation measures identified for the project’s Final Environmental Document.
Sustainability
The City of Santee Climate Action Plan (CAP) contains several actions and strategies that align with Caltrans’ responsibilities and priorities. Caltrans recommends collaboration between our agency and the City of Santee on the proposed transportation related topics including adaptation strategies to help improve the City’s resilience to potential climate change impacts and strategies to reduce vehicle miles traveled (VMT), and off-road and on-road greenhouse gas (GHG) emissions.
The existing climate hazards discussed in this document will have an impact of the transportation system. We recommend working with Caltrans on determining the preventative Mr. Harley Wallace, Fire Chief
March 9, 2026
“Improving lives and communities through transportation.” strategies the Caltrans can take to keep roadways operational and ensure their longevity against climate stressors such as increased temperatures, changes in precipitation patterns, wildfire, and flooding. Caltrans recognizes the central role that transportation planning plays in safety and ensuring that when these natural hazards do occur, citizens have a reliable evacuation route.
Right-of-Way
Per Business and Profession Code 8771, perpetuation of survey monuments by a licensed land surveyor is required, if they are being destroyed by any construction.
Any work performed within Caltrans’ R/W will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans’ R/W prior to construction.
Additional information regarding encroachment permits may be obtained by visiting the website at https://dot.ca.gov/programs/traffic-operations/ep. Projects with the following:
• require a Caltrans Encroachment Permit
• have completed the Caltrans Local Development Review (LDR) process • have an approved environmental document
need to have documents submitted for Quality Management Assessment Process (QMAP) process via email to [email protected]. Early coordination with Caltrans is strongly advised for all encroachment permits.
If you have any questions or concerns, please contact Mark McCumsey, LDR Coordinator, at (619) 985-4957 or by e-mail sent to [email protected].
Sincerely,
Kimberly D. Dodson
KIMBERLY D. DODSON, GISP
Branch Chief
Local Development Review
STATE OF CALIFORNIA GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE MEGHAN HERTEL, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
wildlife.ca.gov
Conserving California’s Wildlife Since 1870
Via Electronic Mail Only
March 11, 2026
Harley Wallace
Santee Fire Department Administration
City of Santee
10601 Magnolia Avenue
Santee, CA 92071
[email protected]
Subject: Notice of Preparation of a Draft Environmental Impact Report for the San Diego River Fire Hazard Mitigation Plan Project, SCH No. 2026020351, San Diego County, CA
Dear Harley Wallace:
The California Department of Fish and Wildlife (CDFW) reviewed the Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) from the City of Santee (City) for the San Diego River Fire Hazard Mitigation Plan (FHMP, or Project) pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines1.
Thank you for the opportunity to provide comments and recommendations regarding Project activities that may affect California fish and wildlife. Likewise, CDFW appreciates the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.
CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)).
CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.
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management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Fish & G. Code, § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.
CDFW may also act as a Responsible Agency under CEQA (Pub. Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority (Fish & G. Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law2 of any species protected under the California Endangered Species Act (CESA; Fish & G. Code, § 2050 et seq.) or the Native Plant Protection Act (NPPA; Fish & G.
Code, § 1900 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.
CDFW also administers the Natural Community Conservation Planning (NCCP) Program, a California regional habitat conservation planning program (Fish & G.
Code, § 2800 et seq.). The City is in the process of developing an NCCP/HCP under the Multiple Species Conservation Program (MSCP) Subregional Plan. A draft MSCP Subarea Plan was circulated for public review in late summer 2025 and CDFW provided comments on the DEIR jointly with the U.S. Fish and Wildlife Service in a letter dated September 22, 2025 (SCH No. 2023030471); however, the MSCP Subarea Plan has not yet been adopted by the City and both state and federal take authorizations have not been issued to the City.
PROJECT DESCRIPTION SUMMARY
Proponent: City of Santee, Santee Fire Department Administration Objective: The objective of the Project is to reduce wildfire risk around critical public infrastructure, adjacent residential neighborhoods, and biologically sensitive habitats within the San Diego River corridor through the removal of non-native and invasive plant species. As part of the Project, a Fuels Treatment Plan (FTP) will be developed that includes treatment strategies specific to wildfire exposure, access conditions, existing vegetation, and proximity to sensitive resources. The FTP will also incorporate 2 “Take” is defined in Section 86 of the Fish and Game Code as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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best management practices to avoid or minimize impacts to natural resources within the project site.
Location: The nearly 300-acre project site encompasses 32 parcels within the San Diego River corridor where it runs through the center of the City. The project site is bound by the unincorporated community of Lakeside in the east and the confluence of the San Diego River with Forester Creek in the west.
Biological Setting: The Project site includes a roughly 3.5-mile stretch of the San Diego River bound by City park recreation facilities and residential and commercial development to the north and south. Natural vegetation communities within the project area include riparian forest and woodland, freshwater marsh, open water, and smaller areas of coastal sage scrub, grassland, and unvegetated channel.
These natural vegetation communities support a variety of sensitive plant and wildlife species. A search of the California Natural Diversity Database (CNDDB; La Mesa and El Cajon U.S.G.S. 7.5 min. quads) returned observation data for 86 special status species.
Sensitive species known to occur within or in proximity to the site include3:
Plants:
• San Diego ambrosia (Ambrosia pumila; ESA-endangered, CRPR 1B.1) • smooth tarplant (Centromadia pungens ssp. laevis; CRPR 1B.1) Invertebrates:
• Crotch’s bumble bee (Bombus crotchii; CESA candidate endangered) • Quino checkerspot butterfly (Euphydyras editha quino; ESA-endangered) • Hermes copper butterfly (Lycaena hermes; ESA-threatened) Amphibians/Reptiles:
• western spadefoot (Spea hammondii; ESA proposed threatened, SSC, proposed for CESA listing)
• California glossy snake (Arizona elegans occidentalis; SSC) Birds:
• least Bell’s vireo (Vireo bellii pusillus; ESA-endangered, CESA-endangered) 3 Nomenclature and species status follows the CNDDB Special Animals List (CDFW, January 2026) and Special Vascular Plants, Bryophytes, and Lichens List (CDFW, January 2026). ESA = Federal Endangered Species Act, CESA = California Endangered Species Act, SSC = state Species of Special Concern, CRPR = California Rare Plant Rank
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Birds (cont.):
• coastal California gnatcatcher (Polioptila californica californica; ESAthreatened, SSC) Mammals:
• big free-tailed bat (Nyctinomops macrotis; SSC)
• pallid bat (Antrozous pallidus; SSC)
The riparian corridor also provides a critical linkage for wildlife movement between open space to the east and west of the City’s boundaries.
COMMENTS AND RECOMMENDATIONS
CDFW offers the following comments and recommendations to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts to fish and wildlife (biological) resources.
Specific Comments
1) Lake and Streambed Alteration. As described in the NOP, the Project proposes activities within and adjacent to the San Diego River. CDFW has regulatory authority over activities in streams that will divert or obstruct the natural flow of water, or change the bed, channel, or bank (which may include associated riparian resources) of any river, stream, or lake or use material from a river, stream, or lake. For any such activities, the Project applicant (or “entity”) must provide written notification to CDFW pursuant to section 1600 et seq. of the Fish and Game Code. Based on this notification and other information, CDFW determines whether a Lake and Streambed Alteration Agreement (LSAA) with the applicant is required prior to conducting the proposed activities. CDFW’s issuance of a LSAA for a project that is subject to CEQA will require CEQA compliance actions by CDFW as a Responsible Agency. CDFW recommends that the City assess whether notification is appropriate. A Notification package for a LSAA may be obtained by accessing CDFW’s Lake and Streambed Alteration Program website4. 2) Potential Impacts to Listed Species. CDFW considers adverse impacts to a species protected by CESA to be significant. Take of any endangered, threatened, candidate species, or NPPA-listed plant species that results from the Project is prohibited, except as authorized by state law (Fish & G. Code §§ 2080, 2085; Cal.
Code Regs., tit. 14, §786.9). CESA-listed species with potential to occur within the project site include least Bell’s vireo and CESA candidate species Crotch’s bumble 4 http://www.wildlife.ca.gov/Conservation/LSA
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bee. Consequently, if the Project or any Project-related activity will result in take of a species designated as endangered or threatened, or a candidate for listing under CESA, CDFW recommends that the Project proponent seek appropriate take authorization prior to implementing the Project.
CDFW is aware that the City may pursue take coverage for the Project under the MSCP Subarea Plan currently in draft. However, should the Project proceed before the MSCP Subarea Plan has been finalized and approved by the City, and an NCCP Permit issued by CDFW, other take authorizations should be considered.
Appropriate authorization from CDFW may include an Incidental Take Permit (ITP) or a consistency determination in certain circumstances, among other options (Fish & G. Code, §§ 2080.1, 2081, subds. (b) and (c)). Per Figure 1 of the NOP, it appears that a portion of the Project site at the far western end extends into an area that is proposed as ‘Not a Part’ of the MSCP Subarea Plan. If accurate, that area would not be covered for incidental take under the MSCP Subarea Plan and, if determined necessary, would require separate take authorization. Early consultation is encouraged, as significant modification to a Project and mitigation measures may be required to obtain a CESA Permit. To ensure CDFW will be able to use the City’s CEQA document for the issuance of an ITP, the DEIR should address all Project impacts to CESA-listed and CESA candidate species and specify a mitigation, monitoring, and reporting program that will meet the requirements of an ITP.
3) Plant Species to Target for Removal. As described in the NOP, the Project proposes to lower wildfire risk within the San Diego River corridor through targeted removal of non-native and invasive plant species. CDFW recommends targeting non-native, invasive species listed as ‘Moderate, High, Limited, and Watch’ by the California Invasive Plant Council5.
4) Compliance with Current Land Protections. The Project site encompasses several parcels identified as existing protected open space, preserves, prior mitigation sites, and/or otherwise conserved for natural resource purposes. Several but not all the protected properties within or adjacent to the Project site have recorded Conservation Easements (i.e., Mast Park West, Lowe’s Mitigation Preserve, and the Smooth Tarplant Preserve). Others have Conservation Easements in progress (Mast Park Preserve), are protected by Restrictive Covenants (Walker Preserve) and City ordinance (Mast Park East) or provide mitigation for previous projects (Caltrans Forester Creek Mitigation Site). Some also have associated habitat management plans. The DEIR should disclose any approvals required to conduct Project activities within the protected lands and include an analysis of whether the proposed Project 5 https://www.cal-ipc.org/plants/inventory/
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activities are consistent with the various protection mechanisms and/or management plans for these properties, as well as the conservation strategy of the MSCP Subarea Plan; and if not, how any inconsistencies would be addressed.
General Comments
5) Disclosure. The DEIR should provide an adequate, complete, and detailed disclosure about the effects which a proposed project is likely to have on the environment (Pub. Resources Code, § 20161; CEQA Guidelines, § 15151). Such disclosure is necessary so CDFW may provide comments on the adequacy of proposed avoidance, minimization, or mitigation measures, as well as assess the significance of the specific impact relative to plant and wildlife species impacted (e.g., current range, distribution, population trends, and connectivity). 6) Project Description and Alternatives. To enable adequate review and comment on the proposed Project from the standpoint of the protection of fish, wildlife, and plants, CDFW recommends the following information be included in the DEIR. a. A complete discussion of the purpose and need for, and description of the proposed Project.
b. A range of feasible alternatives to the Project location to avoid or otherwise minimize direct and indirect impacts to sensitive biological resources and wildlife movement areas. CDFW recommends the City select Project designs and alternatives that would avoid or otherwise minimize direct and indirect impacts to biological resources. CDFW also recommends the City to consider establishing appropriate setbacks from sensitive and special status biological resources. Setbacks should not be impacted by ground disturbance or hydrological changes from any future Project-related construction, activities, maintenance, and development.
c. Project alternatives should be thoroughly evaluated, even if an alternative would impede, to some degree, the attainment of the Project objectives or would be more costly (CEQA Guidelines, § 15126.6). The DEIR shall include sufficient information about each alternative to allow meaningful evaluation, public participation, analysis, and comparison with the proposed Project (CEQA Guidelines, § 15126.6).
d. Where the Project may impact aquatic and riparian resources, CDFW recommends the City select Project designs and alternatives that would fully avoid impacts to such resources. CDFW also recommends an alternative that would not impede, alter, or otherwise modify existing surface flow, watercourse and meander, and water-dependent ecosystems and natural communities.
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Any modifications to a river, creek, or stream may cause or magnify upstream bank erosion, channel incision, and drop in water level, which may cause the watercourse to alter its course of flow.
7) Biological Baseline Assessment. An adequate biological resources assessment should provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the Project site and where the Project may result in ground disturbance. The assessment and analysis should place emphasis on identifying endangered, threatened, rare, and sensitive species; regionally and locally unique species; and sensitive habitats. An impact analysis will aid in determining the Project’s potential direct, indirect, and cumulative biological impacts, as well as specific mitigation or avoidance measures necessary to offset those impacts.
CDFW also considers impacts to Species of Special Concern (SSC) a significant direct and cumulative adverse effect without implementing appropriate avoidance and/or mitigation measures. The DEIR should include the following information.
a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on natural resources that are rare or unique to the region (CEQA Guidelines, § 15125(c)). The DEIR should include measures to fully avoid and otherwise protect Sensitive Natural Communities.
CDFW considers Sensitive Natural Communities as threatened habitats having both regional and local significance. Natural communities, alliances, and associations with a State-wide rarity ranking of S1, S2, and S3 should be considered sensitive and declining at the local and regional level. These ranks can be obtained by visiting the Vegetation Classification and Mapping Program - Natural Communities webpage6.
b. A thorough, recent, floristic-based assessment of special status plants and natural communities following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities7. Botanical field surveys should be comprehensive over the entire Project site, including areas that will be directly or indirectly impacted by the Project. Adjoining properties should also be surveyed where direct or indirect Project effects could occur, such as those from fuel modification, herbicide application, invasive species, and altered hydrology. Botanical field surveys should be conducted in the field at the times of year when plants will be both evident and identifiable. Usually, this is during flowering or fruiting. Botanical field survey visits should be spaced throughout the growing season to accurately determine what plants exist in the Project site. This usually involves multiple visits 6 https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities 7 https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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to the Project site (e.g., in early, mid, and late season) to capture the floristic diversity at a level necessary to determine if special status plants are present. c. Floristic alliance- and/or association-based mapping and vegetation impact assessments conducted in the Project site and within adjacent areas. The Manual of California Vegetation8, second edition, (Sawyer, Keeler-Wolf, & Evens, 2009) should also be used to inform this mapping and assessment. Adjoining habitat areas should be included in this assessment where the Project’s construction and activities could lead to direct or indirect impacts off-site. d. A complete and recent assessment of the biological resources associated with each habitat type in the Project site and within adjacent areas. A full literature review includes but is not limited to CDFW’s California Natural Diversity Database9 (CNDDB). The CNDDB should be accessed to obtain current information on any previously reported sensitive species and habitat. An assessment should include a minimum nine-quadrangle search of the CNDDB to determine a list of species potentially present in the Project site. A ninequadrangle search should be provided in the Project’s CEQA document for adequate disclosure of the Project’s potential impact on biological resources. e. A complete, recent, assessment of endangered, rare, or threatened species and other sensitive species within the Project site and adjacent areas, including SSC and California Fully Protected Species (Fish & G. Code, §§ 3511, 4700, 5050, and 5515). Species to be addressed should include all those which meet the CEQA definition of endangered, rare, or threatened species (CEQA Guidelines, § 15380). Seasonal variations in use of the Project site should also be addressed such as wintering, roosting, nesting, and foraging habitat. Focused speciesspecific surveys, conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable, may be required if suitable habitat is present. See CDFW’s Survey and Monitoring Protocols and Guidelines10 for established survey protocol. Acceptable species-specific survey procedures may be developed in consultation with CDFW and U.S. Fish and Wildlife Service.
f. A recent wildlife and rare plant survey. A lack of records in the CNDDB does not mean that rare, threatened, or endangered plants and wildlife do not occur.
Field verification for the presence or absence of sensitive species is necessary to provide a complete biological assessment for adequate CEQA review (CEQA Guidelines, § 15003(i)). CDFW generally considers biological field assessments for 8 https://vegetation.cnps.org/
9 https://wildlife.ca.gov/Data/CNDDB
10 https://wildlife.ca.gov/conservation/survey-protocols Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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wildlife to be valid for a one-year period, and assessments for rare plants may be considered valid for a period of up to three years. Some aspects of the proposed Project may warrant periodic updated surveys for certain sensitive taxa, particularly if Project implementation could occur over a protracted time frame or in phases.
8) Direct and Indirect Impacts to Biological Resources. The DEIR should provide a thorough discussion of direct and indirect impacts expected to affect biological resources with specific measures to offset such impacts. The DEIR should address the following.
a. A discussion of potential impacts from lighting, noise, temporary human activity, and exotic species, and identification of any mitigation measures. A discussion regarding Project-related indirect impacts to biological resources. These include resources in nearby public lands, open space, adjacent natural habitats, riparian ecosystems, and any designated and/or proposed or existing reserve lands (e.g., preserve lands associated with a Natural Community Conservation Plan (Fish & G. Code, § 2800 et. seq.)).
b. A discussion of both the short-term and long-term effects of the Project on species population distribution and concentration, as well as alterations of the ecosystem supporting those species impacted (CEQA Guidelines, § 15126.2(a)). c. Impacts to, and maintenance of, wildlife corridor/movement areas, including access to undisturbed habitats in areas adjacent to the Project, should be fully analyzed and discussed in the DEIR.
d. A discussion of post-Project fate of drainage patterns, surface flows, and soil erosion and/or sedimentation in streams and water bodies. The discussion should also address any potential water extraction activities and the potential resulting impacts to habitat supported by the groundwater. Measures to mitigate such impacts should be included.
e. An analysis of impacts from proposed changes to land use designations and zoning, and existing land use designation and zoning located nearby or adjacent to natural areas that may inadvertently contribute to wildlife-human interactions. A discussion of possible conflicts and mitigation measures to reduce these conflicts should be included in the DEIR.
9) Cumulative Impacts. Cumulative impacts to biological resources can result from collectively significant projects which are individually insignificant. The Project, when considered collectively with prior, concurrent, and probable future projects, may have a significant cumulative effect on biological resources. The Project may Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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March 11, 2026
substantially reduce the number or restrict the range of endangered, rare, or threatened species. Species that may be impacted by the Project include, but are not limited to, the biological resources described in this letter.
Accordingly, CDFW recommends the DEIR evaluate the Project’s potential cumulative impacts to biological resources. The Project may have a “significant effect on the environment” if the possible effects of the Project are individually limited but cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects (Pub. Resources Code, § 21083(b)). The City’s conclusions regarding the significance of the Project’s cumulative impact should be justified and supported by evidence to make those conclusions.
Specifically, if the City concludes that the Project would not result in cumulative impacts to biological resources, the City, “shall identify facts and analysis supporting the Lead Agency’s conclusion that the cumulative impact is less than significant” (CEQA Guidelines section § 15130(a)(2)).
10) Nesting Birds. To avoid impacts to nesting birds, CDFW recommends that clearing of vegetation occur outside of the peak avian breeding season, which generally runs from February 1 through September 1 (as early as January 1 for some raptors). If Project activities are necessary during the bird breeding season, a qualified biologist with experience in conducting bird surveys should conduct a nesting bird survey within three days prior to work in the area. If an active nest is identified, a buffer shall be established between the construction activities and the nest so that nesting activities are not interrupted. CDFW generally recommends a 100-foot buffer for common avian species, 300 feet for listed or highly sensitive birds, and 500 feet for raptors. An appropriate buffer should be determined by a qualified biologist and delineated by temporary fencing and remain in effect as long as project activities are occurring. No Project construction shall occur within any nest buffer zone until the young have fledged, are no longer being fed by the parents, have left the nest, and will no longer be impacted by Project activities. Reductions in nest buffer distances may be allowable depending on the avian species involved, ambient levels of human activity, screening vegetation, or possibly other factors.
11) Mitigation Measures. Public agencies have a duty under CEQA to prevent significant, avoidable damage to the environment by requiring changes in a project through the use of feasible alternatives or mitigation measures (CEQA Guidelines, §§ 15002(a)(3), 15021). Pursuant to CEQA Guidelines section 15126.4, an environmental document shall describe feasible measures which could mitigate impacts below a significant level under CEQA. Mitigation measures must be Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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March 11, 2026
feasible, effective, implementable, and fully enforceable/imposed by the lead agency through permit conditions, agreements, or other legally binding instruments (Pub. Resources Code, § 21081.6(b); CEQA Guidelines, § 15126.4). a. The DEIR should provide mitigation measures that are specific and detailed (i.e., responsible party, timing, specific actions, location) in order for a mitigation measure to be fully enforceable and implemented successfully via a mitigation monitoring and/or reporting program (Pub. Resources Code, § 21081.6; CEQA Guidelines, § 15097).
b. If a proposed mitigation measure would cause one or more significant effects, in addition to impacts caused by the proposed Project, the DEIR should include a discussion of the effects of proposed mitigation measures (CEQA Guidelines, § 15126.4(a)(1)). In that regard, the DEIR should provide an adequate, complete, and detailed disclosure about the Project’s proposed mitigation measure(s). Adequate disclosure is necessary so CDFW may assess the potential impacts of proposed mitigation measures.
12) Compensatory Mitigation. The DEIR should include compensatory mitigation measures for the Project’s significant impacts (direct and/or through habitat modification) to sensitive and special status plants, animals, and habitats.
Mitigation measures should emphasize avoidance and minimization of Projectrelated impacts. For unavoidable impacts, on-site habitat restoration or enhancement should be discussed in detail. If on-site mitigation is not feasible or would not be biologically viable and therefore inadequate to mitigate the loss of biological functions and values, off-site mitigation through habitat creation and/or acquisition and preservation in perpetuity should be proposed. Areas proposed as mitigation lands should be protected in perpetuity with a conservation easement and financial assurance and dedicated to a qualified entity for long-term management and monitoring.
13) Long-term Management of Mitigation Lands. For proposed mitigation lands, the DEIR should include measures to protect the targeted habitat values in perpetuity.
The mitigation should offset Project-induced qualitative and quantitative losses of biological resources. Issues that should be addressed include (but are not limited to) restrictions on access, proposed land dedications, monitoring and management programs, control of illegal dumping, water pollution, and increased human intrusion. An appropriate endowment should be set aside to provide for long-term management of mitigation lands.
14) Salvage, Relocation and Translocation of Plants and Animal Species. Salvage, relocation and translocation require the collection, handling, capturing or possession of wildlife and/or plants with the goal of moving or removing them from Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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one location and permanently moving them to a new location. CDFW generally does not support the use of relocation or translocation as a mitigation measure for unavoidable impacts to endangered, rare, or threatened plants and animals.
These efforts are often not monitored over the long-term and successful outcomes are dubious. CDFW has found that permanent preservation and management of habitat to support affected species is often a more effective long-term strategy for conserving plants and animals and their habitats.
15) Scientific Collecting Permit and Voucher Collecting Permit. A Scientific Collecting Permit would be necessary if Project activities necessitate capture and relocation of wildlife. Pursuant to the California Code of Regulations, title 14, section 650, qualified biologist(s) must obtain appropriate handling permits to capture, temporarily possess, and relocated wildlife to avoid harm or mortality in connection with Project-related activities. CDFW has the authority to issue permits for the take or possession of wildlife, including mammals; birds, nests, and eggs; reptiles, amphibians, fish, plants; and invertebrates (Fish & G. Code, §§ 1002, 1002.5, 1003).
A Scientific Collecting Permit is required to monitor project impacts to wildlife resources, as required by environmental documents, permits, or other legal authorizations; and, to capture, temporarily possess, and relocate wildlife to avoid harm or mortality in connection with otherwise lawful activities (Cal. Code Regs., tit. 14, § 650). For more information, please see CDFW’s Scientific Collecting Permit webpage11.
A voucher collection permit is required to collect state-listed plant species for identification purposes during field surveys, or to collect voucher specimens to document a newly discovered or previously unvouchered occurrence of a statelisted plant. There is no charge to apply for a voucher collection permit. Anyone who collects scientific plant specimens of state-listed species, or who may encounter a state-listed species during field surveys should have a plant voucher collection permit. To apply for a Voucher Collecting Permit please see CDFW’s Voucher Collecting Permit Page.
16) Use of Native Plants and Trees. If restoration is a component of the Project, CDFW recommends the DEIR include a native plant palette. The Project’s revegetation plan should be disclosed and evaluated in the DEIR. CDFW supports the use of native species found in naturally occurring plant communities within or adjacent to the Project site. In addition, CDFW supports planting native species of trees, such as willows (Salix spp.), and understory vegetation (e.g., ground cover, vines, subshrubs, and shrubs) that create habitat and provide a food source for birds as well as high insect and pollinator value.
11 https://wildlife.ca.gov/Licensing/Scientific-Collecting Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
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ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNDDB website12 provides direction regarding the types of information that should be reported and allows on-line submittal of field survey forms.
In addition, information on special status native plant populations and sensitive natural communities, should be submitted to CDFW’s Vegetation Classification and Mapping Program using the Combined Rapid Assessment and Relevé Form13.
The City should ensure data collected for the preparation of the DEIR is properly submitted.
FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)
CONCLUSION
CDFW appreciates the opportunity to comment on the NOP to assist the City in identifying and mitigating Project impacts to biological resources. Questions regarding this letter or further coordination should be directed to Heather Schmalbach14, Senior Environmental Scientist (Specialist).
12 https://wildlife.ca.gov/Data/CNDDB
13 https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities/Submit 14 Email: [email protected], Phone: 858-775-7399 Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Harley Wallace
City of Santee
March 11, 2026
Sincerely,
Glen M. Lubcke
Environmental Program Manager
South Coast Region
ec: California Department of Fish and Wildlife
Glen M. Lubcke, Environmental Program Manager
Melanie Burlaza, Senior Environmental Scientist (Supervisor) Heather Schmalbach, Senior Environmental Scientist (Specialist) U.S. Fish and Wildlife Service
Jonathan Snyder15, Assistant Field Supervisor
Susan Wynn16, Supervisory Fish and Wildlife Biologist
Samantha Padilla17, Fish and Wildlife Biologist
Office of Planning and Research
[email protected]
REFERENCES
California Department of Fish and Game. (2011). CNDDB Data Use Guidelines.
Retrieved from
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=27285&inline California Department of Fish and Wildlife. (2021). Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities.
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline California Fish and Game Commission. (2005). Miscellaneous Policies. Retrieved from https://fgc.ca.gov/About/Policies/Miscellaneous
Sawyer, J. O., Keeler-Wolf, T., & Evens, J. M. (2009). A Manual of California Vegetation (Second ed.). Sacramento, CA: California Native Plant Society. Retrieved from https://vegetation.cnps.org/
15 [email protected]
16 [email protected]
17 [email protected]
Docusign Envelope ID: BC15198D-0B0A-451D-93CE-AD5A919CE0CA Appendix B
Biological Resources Letter Report
July 24, 2026 18611
Dustin DeMatteo
City of Santee Emergency Manager
10601 Magnolia Avenue
Santee, California 92071
Subject: Biological Resources Letter Report for the San Diego River Fire Hazard Mitigation Program Project, Santee, California
Dear Dustin DeMatteo:
Dudek understands that the City of Santee must comply with the Federal Emergency Management Agencycompliant Hazard Mitigation Grant Program prior to implementing vegetation management activities within approximately 300 acres of the San Diego River channel located in the City. This biological resources letter report summarizes the methods and results of Dudek’s biological reconnaissance survey and analysis of the San Diego River Fire Hazard Mitigation Program Project (Project) Site. The report also provides recommendations to avoid and minimize potential impacts on special-status species, sensitive habitats, and wetland resources. 1 Project Location and Description
1.1 Project Location
The approximately 300-acre Project Site is located within the San Diego River corridor in the City of Santee, eastern San Diego County (Figure 1, Project Location). The Project Site is mapped within the El Cajon and La Mesa, California U.S. Geological Survey (USGS) 7.5-minute topographic quadrangles (USGS 2021, 2023). The Project Site spans wildland–urban interface lands; vegetation management/treatment areas extend from Forester Creek at the western boundary to the city limit with Lakeside in the eastern boundary, encompassing Mast Park West, Mast Park Wetland Restoration Area, Mast Park East, Mission Creek, Walker Trails Open Space, and Walker Preserve.
The Project Site is accessible via North Magnolia Avenue from the west as well as Lakeside Sports Park from the east and is approximately 0.1 miles to 1 mile north of State Route 52 (Figure 1). The Project Site consists of a portion of the San Diego River corridor. Multiple pedestrian access paths, residential and commercial developments border the Project Site. The Project Site occurs within the boundaries of the Multiple Species Conservation Program (MSCP; MSCP Plan) (City of San Diego 1998) and the City of Santee Draft MSCP Subarea Plan (City of Santee 2025). Figure 2, MSCP Lands, depicts the spatial distribution of the Project Site within the City of Santee MSCP Subarea Plan.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 2
JULY 2026
1.2 Project Purpose and Description
1.2.1 Project Purpose
The Santee Fire Department responded to 174 fires near the Project Site in 2024 and 2025, 81 of which were located at the Project Site, underscoring the need for proactive fuel reduction to reduce the risk of fire from flammable vegetation. The City of Santee, as lead agency, proposes implementation of the Project within the San Diego River corridor segment within Santee’s jurisdiction. The Project is funded by the Federal Emergency Management Agency through Hazard Mitigation Grant Program 4610-917-009, with matching funds from the San Diego River Conservancy under Grant Agreement SDRG-B21-17.
The primary objective of the Project is to reduce wildfire risk by decreasing hazardous fuel loads (flammable vegetation) and mitigating conditions that increase risk of wildfire and fire intensity should a wildfire occur within the Project Site. The Project shall incorporate the City of Santee’s San Diego River Fire Hazard Mitigation Program:
Fuels Treatment Plan (City of Santee 2026; FTP) developed to reduce wildfire risk in and around high-priority sites along the San Diego River corridor. The FTP (City of Santee 2026) is designed to balance fire risk reduction with environmental stewardship. It emphasizes selective vegetation modification techniques that support defensible space and risk reduction while preserving ecological function, minimizing soil disturbance, and protecting sensitive resources. The plan framework supports applicable California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) requirements and would inform the implementation activities.
1.2.2 Project Description
The fuel treatment goals for the Project would be achieved by reducing the overall volume of vegetation as well as disrupting the horizontal and vertical continuity of fuels across the treated area. Treatments would be focused on defensible space areas proximate to adjacent structures and on the removal of non-native and invasive species occurring within the river corridor, which in their abundance, pose a significant wildfire hazard. Sensitive environmental zones, including wetlands, riparian habitats, and parcels adjacent to developed structures within the City’s jurisdiction, would be considered during Project implementation.
Vegetation management/fuel reduction activities would include thinning brush, removing non-native invasive species, and clearing dead vegetation and debris across the wildland–urban interface, where the San Diego River corridor meets adjacent development. Treatments may employ hand labor (hand cutting tools, chainsaws), mechanical (masticators, chippers), and targeted herbicide applications using only EPA-approved herbicides, (applied to cut stumps of sprouting species) to address invasive species that elevate fire severity and threaten adjacent development and infrastructure.
Figure 3, Project Components, details the vegetation treatment zones within the Project Site. Three vegetation treatment zones have been identified to clarify the spatial application of prescriptions appropriate for each zone.
They are based on the type and condition of the flammable vegetation present, terrain, land use, and the presence of protected resources or habitat within the treatment area, as detailed in the FTP (City of Santee 2026). Specific fuel reduction activities within Zone 1 (sections of the Project Site that are 0 to 50 feet from adjacent structures) would include removal or treatment of all fine fuels, dead vegetation, leaf litter, and woody debris and shrubs will be thinned to reduce horizontal continuity to a residual surface cover of approximately 30%. Sections of the Project TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 3
JULY 2026
Site within Zone 2 (between 50 and 100 feet from adjacent structures) would include treating or removing all nonnative and dead vegetation, including invasive species and shrubs or trees with extensive dead or desiccated material, and shrubs will be thinned to reduce horizontal continuity to a residual surface coverage of approximately 50%. Zone 3 encompasses the broader vegetated areas of the San Diego River corridor outside Zones 1 and 2, including most riparian zones, floodplain terraces, and open space areas such as portions of Mast Park and Walker Preserve. Treatments in Zone 3 focus on reducing hazardous vegetation while preserving riparian canopy, hydrologic function, and recreational access. Vegetation management in Zone 3 is focused on treatment or removal of non-native species, dead vegetation, and debris, including accumulations deposited during storm events.
Removal and other treatment of live and healthy native species is not anticipated within Zone 3.
In addition to the removal of dead and invasive plants, thinning of native plants is proposed in the defensible space areas (Zones 1 and 2), live and healthy native species may be treated as allowed through additional permitting only. All trimming activities of native plants would be done to industry standards (International Society of Arboriculture [ISA], American National Standards Institute [ANSI]) to minimize likelihood of plant death. Only dead and invasive plants would be treated or removed in the remaining portions of the Project Site (Zone 3). Individual dead trees and invasive plants would be 100% removed throughout Zones 1, 2, and 3 encompassing the Project Site. The FTP (City of Santee 2026) details the specific fuel treatment methods, recommended vegetation removal methods, and best management practices to implement during Project activities.
The Project will also include ongoing maintenance of the Project Site to ensure that initial vegetation treatments continue to reduce wildfire hazard over time. Maintenance activities are intended to: (1) prevent the reaccumulation of hazardous fuels, (2) sustain desired vegetation structure and species composition, (3) protect initial treatment investments, and (4) improve firefighter access and suppression effectiveness during wildfire events. Maintenance intervals will vary depending on vegetation type, treatment zone, and treatment technique.
The Project Site will be inspected biannually by the City to determine maintenance needs. It is expected that maintenance within Zones 1 and 2 will occur at least once annually. Maintenance within Zone 3 will be determined during biannual inspections and will be based on the establishment (or re-establishment) or non-native plant species, vegetation mortality (dead plant material presence), and accumulation or deposition of combustible debris (including dead and dying non-native and native vegetation). The frequency of maintenance activities in Zone 3 will be dependent on observations made during biannual inspections. It is expected that approximately one-quarter of the total Project Site will be maintained annually to preserve reduced hazardous fuel conditions. Maintenance will use the techniques outlined in the FTP (i.e., hand labor, mechanical, and chemical; City of Santee 2026).
Any trimming of native vegetation shall occur only following acquisition of required permits. Depending on the timing of permitting, it may be necessary to phase implementation of the FTP (City of Santee 2026), with initial treatment focused on non-native species and dead or dying vegetation in Zones 1 to 3, followed by permitted native vegetation treatments in Zone 1 and Zone 2, as necessary, to achieve the intended fire protection objectives. If necessary to phase implementation, non-native regrowth or newly dead vegetation treated during the initial phase may also require follow-up treatment. In an effort to balance fire risk reduction with habitat value, removal of native vegetation is not recommended within Zone 3. Accordingly, permits associated with native vegetation removal are not anticipated for this zone. Native vegetation thinning activities associated with Zones 1 and 2 would require permits from the wildlife and aquatic resource agencies. All vegetation removal activities shall comply with the requirements of any applicable aquatic resource permits (California Department of Fish and Wildlife [CDFW] Lake and Streambed Alteration Agreements, Section 401 of the Clean Water Act for a Regional Water Quality Control Board [RWQCB] Water Quality Certification, and Section 404 of the Clean Water TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 4
JULY 2026
Act for a U.S. Army Corps of Engineers [USACE] permit) as well as any required incidental take permits through Section 7 and/or 10 of the Federal Endangered Species Act administered by the U.S. Fish and Wildlife Service (USFWS) and Section 2081 of the California Fish and Game Code administered through CDFW. These authorizations include specific conditions related to vegetation removal and protection of riparian and aquatic resources. Vegetation removal activities near channels must avoid unauthorized deposition of material, prevent the spread of invasive propagules to waterways, and maintain consistency with all permit conditions. 2 Methodology
Dudek conducted a literature review of pertinent biological data and a biological reconnaissance field survey to determine the existing biotic and abiotic conditions, and the potential presence of sensitive biological resources within the Project Site.
2.1 Literature Review
Prior to conducting the biological reconnaissance field survey, the CDFW California Natural Diversity Database (CNDDB) (CDFW 2025a) and California Native Plant Society (CNPS 2025) inventories were queried based on the USGS 7.5-minute topographic quadrangle maps for La Mesa and El Cajon, California (USGS 2023, 2021). The purpose of the literature review was to determine whether special-status plant and wildlife species are known to occur in the vicinity of or within the Project Site.
Other literature reviewed included the California Natural Community List (CDFW 2025b); State and Federally Listed Endangered, Threatened, and Rare Plants of California (CDFW 2025c); State and Federally Listed Endangered and Threatened Animals of California (CDFW 2025d); the San Diego Geographic Information Source database (SanGIS 2025), the CDFW California Wildlife Habitat Relationships Life History Accounts and Range Maps (CDFW 2025e), and data gathered to support the City’s Subarea Planning efforts.
The following available resources were reviewed to assess the potential for jurisdictional waters and wetlands:
aerial and historic photographs (Google Earth 2025; NETR 2025); the USGS La Mesa and El Cajon 7.5-minute topographic quadrangle maps (USGS 2023 and 2021, respectively); the National Hydrography Dataset and Watershed Boundary Dataset (USGS 2025); the USFWS National Wetlands Inventory (USFWS 2025a); and the U.S.
Department of Agriculture Natural Resources Conservation Service Web Soil Survey (USDA 2025a).
2.2 Biological Reconnaissance
Dudek Biologists conducted biological reconnaissance field surveys throughout November and December 2025 (Table 1). The biological reconnaissance field survey included vegetation mapping, mapping of sensitive biological resources, if present, and an evaluation of the potential for special-status species to occur. Although a formal jurisdictional aquatic resources delineation was not conducted during the biological reconnaissance, Dudek performed a preliminary assessment of wetlands on the Project Site by assessing presence of hydrophytic vegetation, riparian habitat, and existing hydrologic conditions, and mapping the extent of jurisdictional boundaries.
In addition, survey data gathered for several recent projects within the City of Santee, whose boundaries or mitigation assessments overlapped the Project Site were included (e.g., Fanita Ranch mitigation assessments, TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 5
JULY 2026
Carlton Oaks Country Club and Resort Project, Santee Community Center, Palisade Santee Commerce Center Project, Cottonwood and Park Project, and Mast Park Bioretention Swale Project).
Table 1. Schedule of Biological Reconnaissance Surveys
Date Hours Biologist(s) Weather Conditions
11/13/2025 8:15 a.m.–11:00 a.m. Anna Touchstone,
Megan Minter
70°F–77°F; 20%–0% cloud
cover; 0-3 mph wind
11/18/2025 9:00 a.m.–4:00 p.m. Erin Bergman 57°F–62°F; 80%–100% cloud cover; 2–4 mph wind
11/24/2025 10:30 a.m.–3:30 p.m. Katelin Pedersen,
Shana Carey
64°F–66°F; 50% cloud cover;
0–4 mph wind
11/25/2025 8:00 a.m.–1:30 p.m. Katelin Pedersen,
Shana Carey
62°F–85°F; 0% cloud cover;
0–4 mph wind
12/03/2025 7:45 a.m.–2:10 p.m. Katelin Pedersen,
Olivia Koziel
57°F–70°F; 10% cloud cover;
0–5 mph wind
12/04/2025 8:30 a.m.–2:15 p.m. Katelin Pedersen,
Shana Carey
53°F–70°F; 0% cloud cover;
1–8 mph wind
Notes: F = Fahrenheit; mph = miles per hour.
2.2.1 Vegetation Community and Land Cover Mapping
Vegetation communities and land cover types within the Project Site were mapped in the field using an ArcGIS mobile data collection application. Following completion of the fieldwork, all vegetation linework was finalized using ArcGIS and geographic information system coverage was created. Once in ArcGIS, the acreage of each vegetation community and land cover present within the Project Site was determined. In areas with dense vegetation or intense topography that could not be assessed via binoculars, desktop verification was conducted using aerial imagery and existing SanGIS vegetation community mapping (City of San Diego 1998).
The vegetation community and land cover mapping for the Project Site follows the Preliminary Descriptions of the Terrestrial Natural Communities of California (Holland 1986) as modified by the County and noted in Draft Vegetation Communities of San Diego County (Oberbauer et al. 2008). Some vegetation communities were added or given additional descriptions to identify unique characteristics or highly dominant species within certain communities.
2.2.2 Plants
All native and non-native plant species observed during the biological reconnaissance field surveys were identified and recorded to the extent feasible given plant phenology. The biological reconnaissance was conducted in late fall, outside the spring and summer blooming periods. Seasonal and annual species were largely absent or senescent, limiting full species richness assessment. Latin and common names for species with a California Rare Plant Rank (CRPR) follow the California Native Plant Society Online Inventory of Rare and Endangered Plants (CNPS 2025). For species without a CRPR, Latin names follow the Jepson Interchange List of Currently Accepted Names of Native and Naturalized Plants of California (Jepson Flora Project 2025), and common names follow the U.S.
Department of Agriculture Natural Resources Conservation Service Plants Database (USDA 2025b).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 6
JULY 2026
2.2.3 Wildlife
The biological reconnaissance covered 100% of the Project Site to document wildlife detected by sight, calls, tracks, scat, or other signs. Conducted in November and December, the biological reconnaissance surveys occurred outside the breeding season, and some species may have migrated; therefore, special-status species presence was based on standard database searches.
1 Binoculars (10 × 42) aided identification of species during the biological reconnaissance. Expected wildlife use was inferred from habitat preferences and distributions as well as prior surveys. No trapping or nocturnal surveys were performed. Latin and common names of animals follow Crother (2012) for reptiles and amphibians, American Ornithologists’ Society (AOS 2025) for birds, Wilson and Reeder (2005) for mammals, North American Butterfly Association (NABA 2018) for butterflies, and Moyle (2002) for fish.
2.2.4 Jurisdictional Aquatic Resources
A formal wetlands delineation was not conducted during the biological reconnaissance field survey. However, the Project Site was evaluated for the potential to support jurisdictional aquatic resources regulated under the federal Clean Water Act, California Fish and Game Code, and Porter–Cologne Water Quality Act. Any potential jurisdictional aquatic resources encountered during the biological reconnaissance field survey were mapped informally based on the presence of hydrology or hydrophytic vegetation indicators; for example, streams were mapped via aerial imagery/topographic maps and approximate dimensions of such features were recorded. The USFWS National Wetlands Inventory (NWI) and USGS National Hydrography Dataset were used as a baseline for mapping of potentially jurisdictional aquatic resources within the Project Site (USFWS 2025b; USGS 2025).
2.3 Special-Status Species Habitat Assessment
2.3.1 Special-Status Plants
Endangered, rare, or threatened plant species as defined in Section 15380(b) of the CEQA Guidelines (14 CCR 15000 et seq.) are referred to as “special-status plant species” and, as used in this report, include (1) plant species listed, proposed for listing, or candidates for listing as endangered or threatened recognized in the context of California Endangered Species Act and the federal Endangered Species Act (FESA) (CDFW 2025d); and/or (2) plant species with a CRPR 1B (plants that are rare, threatened, or endangered in California and elsewhere) or 2B (Plants rare, threatened, or endangered in California but more common elsewhere) as designated by the California Native Plant Society (CNPS 2025). CRPR list 3 (plants about which more information is needed) and 4 (plants of limited distribution) are not defined as species that are identified as a candidate, sensitive, or special-status species and are not discussed in this report. Plant species covered under the City of Santee Draft MSCP Subarea Plan (City of Santee 2025) are also considered special-status.
1 Although surveys were conducted outside the typical breeding season for most wildlife species, this document analyses all specialstatus species with moderate or high potential to occur whose geographic ranges fall within the general vicinity based on standard database searches. These databases (i.e., CNDDB and USFWS occurring in the nine U.S. Geological Survey 7.5-minute quadrangles containing and surrounding the Project Site) provide survey data from other sites within the Project Site vicinity and are used to inform baseline. Special-status species’ potential to occur within the study area were evaluated based on known species distribution, species-specific habitat preferences, field surveys conducted within the site, and Dudek biologists’ knowledge of regional biological resources. Because there were no species-specific surveys conducted and surveys were conducted outside typically breeding periods, Dudek took a very conservative approach when determining species’ potential to occur to provide an accurate evaluation of significant impacts to special-status species.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 7
JULY 2026
For each special-status plant species listed, a determination was made regarding the potential for the species to occur within the Project Site based on site-specific information gathered during the biological reconnaissance, such as the vegetation communities and soils present, current site conditions, and each species’ known range, habitat associations, preferred soil substrate, life form, elevation, and blooming period.
2.3.1.1 Protocol-Level Botanical Survey
A fall-season focused botanical survey was conducted concurrently with the biological reconnaissance surveys to map any special-status plants identified on the Project Site (Table 1). The botanical survey was conducted in November and December, outside of the spring and summer blooming periods, due to Project timing constraints.
Therefore, special-status species presence was based on standard database searches. 2 Focused special-status
plant surveys conformed to the California Native Plant Society Botanical Survey Guidelines (CNPS 2001); Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018); and the USFWS’s General Rare Plant Survey Guidelines (Cypher 2002). All plant species encountered during the field surveys were identified to subspecies or variety, if applicable, to determine sensitivity status. For target species encountered, field personnel shall record data points demarcating the edge of the polygon and assess population numbers using the Esri ArcGIS mobile application.
2.3.2 Special-Status Wildlife
Endangered, rare, or threatened wildlife species as defined in CEQA Guidelines, Section 15380(b) (14 CCR 15000 et seq.), are referred to as “special-status wildlife species” and, as used in this report, include (1) wildlife species listed, proposed for listing, or candidates for listing as endangered or threatened recognized in the context of California Endangered Species Act and FESA Act (CDFW 2025e); (2) California Species of Special Concern as designated by CDFW (2025e); and (3) mammals and birds that are fully protected species as described in the California Fish and Game Code, Sections 4700 and 3511 (CDFW 2025g). Wildlife species covered under the City of Santee Draft MSCP Subarea Plan (City of Santee 2025) are also considered special-status.
For each special-status wildlife species listed, a determination was made regarding potential use within the Project Site based on site-specific information gathered during the biological reconnaissance, such as the location of the site, vegetation communities and soils present, current site conditions, and each species’ known range, habitat preferences, and knowledge of the species’ relative distributions in the area. 2 Although surveys were conducted outside the typical blooming periods for most plant species, this document analyses all specialstatus species with moderate or high potential to occur whose geographic ranges fall within the general vicinity based on standard database searches. These databases (i.e., CNDDB, USFWS, and CNPS occurring in the nine U.S. Geological Survey 7.5-minute quadrangles containing and surrounding the Project Site) provide survey data from other sites within the Project Site vicinity and are used to inform baseline. Special-status species’ potential to occur within the study area were evaluated based on known species distribution, species-specific habitat preferences, field surveys conducted within the site, and Dudek biologists’ knowledge of regional biological resources. Because there were no species-specific surveys conducted and surveys were conducted outside typically breeding periods, Dudek took a very conservative approach when determining species’ potential to occur to provide an accurate evaluation of significant impacts to special-status species.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 8
JULY 2026
3 Environmental Setting
The Project Site is located within an urbanized portion of the City of Santee in eastern San Diego County and encompasses upland, riparian, and wetland vegetation communities associated with the San Diego River. The western end of the site begins approximately 0.25 miles north of the intersection of State Routes 52 and 125. The immediate vicinity of the Project Site includes residential development, schools, and parks to the north, commercial development and public facilities (including Las Colinas Detention Facility) to the south, Carlton Oaks Country Club to the west, and State Route 67 to the east.
3.1 Topography
The Project Site and surrounding suburbs are generally flat, with the San Diego River running east–west through the center between wetland, riparian, and disturbed vegetation. Elevations range from approximately 310 to 360 feet above mean sea level (Google Earth 2025). Historical aerial imagery from 1953 shows the Project Site surrounded by agricultural land with little riparian or wetland aerial signature; most residential development was south of the river. By 1964, four built Santee Lakes appeared north of the western end of the site, and residential development began north of the San Diego River. Between 1968 and 1971, agriculture rapidly converted to residential and commercial uses. Increased flow and riparian vegetation became evident in aerial imagery from the late 1970s to mid-1980s, likely due to urbanization, runoff, and major flood events in early 1980. Construction of State Route 52 by 2012 added runoff, but the Project Site has remained largely unchanged for the past 30 years aside from increasing urban runoff.
3.2 Soils
According to the U.S. Department of Agriculture Natural Resources Conservation Service Web Soil Survey (USDA 2025a), 10 soil map units occur within the Project Site: Fallbrook sandy loam (2% to 5% slopes); Cieneba-Fallbrook rocky sandy loams (30% to 65% slopes), eroded; Grangeville fine sandy loam (0% to 2% slopes); Greenfield sandy loam (5% to 9% slopes); Placentia sandy loam, thick surface (2% to 9% slopes); Riverwash; Tujunga sand (0% to 5% slopes); Salinas clay loam (0% to 2% slopes); Visalia sandy loam (0% to 2% slopes); and Water (USDA 2025a).
Of these, Riverwash is classified as a hydric soil in the Arid West Region (USDA 2025b). Water is a land cover type rather than a specific soil series description, so lacks a hydric soil classification. Figure 4, Soils, depicts the spatial distribution of soils on the Project Site.
4 Results
4.1 Vegetation Communities and Land Cover Types
The Project Site is characterized by a mix of natural as well as non-native vegetation communities and land cover types. A total of 19 vegetation communities (including subforms) and/or land cover types were identified in the Project Site during the biological reconnaissance surveys, consisting of 11 native vegetation communities and 8 non-native vegetation communities or land cover types. Of the 19 vegetation communities, 12 are considered wetland/riparian habitats: southern arroyo willow (Salix lasiolepis) riparian forest; southern cottonwood–willow TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 9
JULY 2026
(Populus spp. – Salix spp.) riparian forest; coastal and valley freshwater marsh; southern riparian scrub; southern willow scrub; mulefat (Baccharis salicifolia) scrub; emergent wetland; open water; disturbed wetland; non-native riparian; tamarisk (Tamarix spp.) scrub; and non-vegetated channel or floodway. The vegetation communities and land cover types on the Project Site are described below, their acreages are presented in Table 1, and their spatial distributions are presented in Figure 5, Biological Resources. Representative photos of the Project Site are included in Attachment A, Site Photographs.
Several vegetation communities within the Project Site are referenced in Table 5-13 in the Draft Santee MSCP Subarea Plan (City of Santee 2025) as sensitive; impacts to these vegetation communities typically require mitigation for consistency with the provisions of the City’s future MSCP Subarea Plan and Implementing Agreement, and applicable state and federal regulations. Table 2 details which vegetation communities and land cover types are considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025). Of the 21 vegetation communities present in the Project Site, 15 are considered sensitive according to the Draft Santee MSCP Subarea Plan. The specific vegetation communities dominated by hydrophytic plant species that may be regulated by CDFW as riparian/wetland habitat are also detailed in Table 2.
4.1.1 Native Vegetation Communities
4.1.1.1 Southern Arroyo Willow Riparian Forest
According to Oberbauer et al. (2008), southern arroyo willow riparian forest consists of winter-deciduous riparian forests dominated by moderately tall broadleafed trees, dominated by arroyo willow, and having closed or nearly closed canopies. Understories are usually shrubby willows. Characteristic species include willows (Salix ssp.), mulefat, western sycamore (Platanus racemosa), and Fremont cottonwood (Populus fremontii), and Douglas’s sagewort (Artemisia douglasiana).
Southern arroyo willow riparian forest is present throughout the Project Site along the northern and southern banks of the San Diego River (Figures 5A and 5B). Characteristic species observed include arroyo willow, red willow (Salix laevigata), sandbar willow (Salix exigua), and Douglas’s sagewort within the shrub canopy. Southern arroyo willow riparian forest is a wetland community that is typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.2 Southern Cottonwood – Willow Riparian Forest
According to Oberbauer et al. (2008), southern cottonwood–willow riparian forest consists of tall, open, broadleafed winter-deciduous riparian forests dominated by Fremont cottonwood, black cottonwood (Populus trichocarpa), and several tree willows. Understories are usually shrubby willows. Characteristic species include cottonwoods (Populus spp.), willows, mulefat, Douglas’s sagewort, and western sycamore.
Southern cottonwood–willow riparian forest is present throughout the Project Site surrounding the San Diego River (Figures 5A through 5E). Characteristic species observed include Fremont cottonwood, Goodding’s willow (Salix gooddingii), and western sycamore. Southern cottonwood–willow riparian forest is a wetland community that is typically under the jurisdiction of the aquatic resource agencies (CDFW) and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 10
JULY 2026
Table 2. Vegetation Communities and Land Cover Types in the Project Site Vegetation Community/Land Cover Type1 Project Site (Acres) Sensitive (Y/N)2 Native Vegetation Communities
Riparian and Bottomland Habitat
Southern Arroyo Willow (Salix lasiolepis) Riparian Forest 9.00 Y Southern Cottonwood–Willow (Populus spp.–Salix spp.) Riparian Forest
122.08 Y
Southern Riparian Scrub 1.22 Y
Southern Willow (Salix spp.) Scrub 17.26 Y
Mulefat (Baccharis salicifolia) Scrub 0.44 Y
Open Water 42.89 Y
Non-Vegetated Channel or Floodway 0.08 Y
Subtotal 192.97 N/A
Bog and Marsh
Coastal and Valley Freshwater Marsh 29.71 Y
Emergent Wetland 3.85 Y
Subtotal 33.56 N/A
Woodlands
Coast Live Oak (Quercus agrifolia) Woodland (Including Open Subform) 1.84 Y Scrub and Chaparral
Diegan Coastal Sage Scrub (Including Baccharis-Dominated Subform) 27.76 Y Subtotal of Native Vegetation Communities 256.13 N/A
Non-Native Vegetation Communities and Land Covers
Riparian and Bottomland Habitat
Non-Native Riparian 0.76 Y
Disturbed Wetland 2.75 Y
Tamarisk Scrub 1.49 Y
Subtotal 5.00 N/A
Woodlands
Non-Native Woodland 0.48 N
Eucalyptus Woodland 2.29 N
Subtotal 2.77 N/A
Grasslands
Non-Native Grassland 1.85 Y
Disturbed or Developed Areas
Disturbed Habitat 27.71 N
Urban/Developed 6.52 N
Subtotal 34.23 N/A
Subtotal of Non-Native Vegetation Communities/Land Covers 43.85 N/A Grand Total 299.93 N/A
Notes: N/A = Not Applicable. Totals may not sum due to rounding. 1 According to Oberbauer et al. (2008).
2 Considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 11
JULY 2026
4.1.1.3 Coastal and Valley Freshwater Marsh
According to Oberbauer et al. (2008), coastal and valley freshwater marsh consists of freshwater marsh habitat dominated by perennial, emergent monocots up to 13 to 16 feet tall, often forming completely closed canopies.
Prolonged saturation or permanently flooded areas support this vegetation community. Characteristic species include sedges (Carex spp., Schoenoplectus spp.), cattails (Typha spp.), and reeds (Phragmites spp.).
Coastal and valley freshwater marsh is present adjacent to open water throughout the Project Site (Figures 5A through 5E). Characteristic species observed include broadleaf cattail (Typha latifolia), southwestern spiny rush (Juncus acutus spp. leopoldii), and San Diego marsh-elder (Iva hayesiana). Coastal and valley freshwater marsh is a wetland community typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.4 Emergent Wetland
According to Oberbauer et al. (2008), emergent wetland is a generally persistent wetland type dominated by low-growing, perennial wetland species. These can be found in channels, seeps and springs, floodplains, margins of lakes and rivers, and various basins such as pools and ponds, palustrine lakes, montane meadows, and dune swales. These may be freshwater or alkali wetlands. In San Diego County, these are often in previously disturbed areas where wetlands are emerging but have not yet established a full suite of species; however, disturbance is not a necessary element of this vegetation community.
The emergent wetland occurs adjacent to open water throughout the Project Site (Figures 5A through 5E). The emergent wetland is dominated by southwestern spiny rush and San Diego marsh-elder. Emergent wetland is a wetland community typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.5 Southern Riparian Scrub
According to Oberbauer et al. (2008), southern riparian scrub consists of riparian zones dominated by small trees or shrubs, lacking taller riparian trees. Site factors include major river systems where flood scour occurs.
Characteristic species include willows (Salix spp.) and broom baccharis (Baccharis sarothroides).
Southern riparian scrub is present along the banks of the San Diego River in the Project Site (Figures 5A through 5E). Characteristic species observed include willows, broom Baccharis, arrowweed (Pluchea sericea) and mulefat.
Southern riparian scrub is a wetland community typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.6 Southern Willow Scrub
According to Oberbauer et al. (2008), southern willow scrub consists of dense, broad-leaved, winter-deciduous riparian thickets dominated by several willow species, with scattered emergent Fremont cottonwood and western sycamore. Site factors include loose, sandy or fine gravelly alluvium deposited near stream channels during flood flows. Characteristic species include willows (Salix spp.), western sycamore, arrowweed, and Fremont cottonwood.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 12
JULY 2026
Southern willow scrub is present along the banks of the San Diego River in the Project Site (Figures 5A through 5E).
Characteristic species observed include willows, Fremont cottonwood, western sycamore, San Diego Sagewort (Artemesia palmeri), mulefat, broom Baccharis, San Diego marsh-elder, and arrowweed. As a wetland community, southern willow scrub is typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.7 Mulefat Scrub
According to Oberbauer et al. (2008), mulefat scrub consists of a depauperate, tall, herbaceous riparian community dominated by mulefat and maintained by frequent flooding. Site factors include intermittent stream channels with fairly coarse substrate and moderate depth to the water table. Characteristic species include mulefat and willows.
Southern riparian scrub is present along the banks of the San Diego River in the Project Site (Figures 5A through 5E). Characteristic species observed include mulefat interspersed with scattered non-native tree tobacco (Nicotiana glauca) and broom Baccharis. Mulefat scrub is a wetland community typically under the jurisdiction of the aquatic resource agencies and is considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.8 Disturbed Wetland
According to Oberbauer et al. (2008), disturbed wetland consists of areas permanently or periodically inundated by water, which have been significantly modified by human activity. This includes portions of wetlands with obvious artificial structures such as concrete lining, barricades, riprap, piers, or gates. It is often unvegetated but may contain scattered native or non-native vegetation. Examples include lined channels, Arizona crossings, detention basins, culverts, and ditches. Characteristic species include giant reed (Arundo donax), tamarisk, Eucalyptus (Eucalyptus spp.), fan palms (Washingtonia spp.), pampas grass (Cortaderia spp.), and various other non-native wetland plants.
Disturbed wetland is present in the western portion of the Project (Figures 5A through 5E). Characteristic species included pampas grass (Cortaderia selloana) at approximately 40% relative cover in the herbaceous and shrub layers, interspersed with spiny rush (Juncus acutus) in the herbaceous layer. Disturbed wetlands are typically under the jurisdiction of the aquatic resource agencies and are considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.9 Non-Vegetated Channel or Floodway
According to Oberbauer et al. (2008), non-vegetated channel or floodway consists of the sandy, gravelly, or rocky fringe of waterways or flood channels, and is unvegetated on a relatively permanent basis. Variable water limits inhibit the growth of vegetation, although some weedy species of grasses may occur along the outer edges of the wash. Vegetation may exist here but it is less than 10% total cover.
Non-vegetated channel or floodway occurs in the northwestern area of the Project Site (Figures 5A through 5E). It consists of an ephemeral swale with exposed soils and ruderal herbaceous vegetation that likely conveys stormwater flows from the adjacent roadway during rain events. Non-vegetated channel is typically considered a jurisdictional resource by the resource agencies and a sensitive community in the Draft Santee MSCP Subarea Plan (City of Santee 2025).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 13
JULY 2026
4.1.1.10 Open Water
According to Oberbauer et al. (2008), open water consists of year-round bodies of fresh water (extremely low salinity) in the form of lakes, streams, ponds, or rivers. This includes portions of water bodies that are usually covered by water and contain less than 10% vegetative cover.
Open water in the Project Site consists of the unvegetated portions of the main flow channel of the San Diego River (Figures 5A through 5E). As a wetland, open water is typically under the jurisdiction of the aquatic resource agencies and is considered a sensitive vegetation community in the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.1.11 Coast Live Oak Woodland (Including Open Coast Live Oak Woodland) According to Oberbauer et al. (2008), coast live oak woodland consists of woodland dominated by coast live oak, an evergreen oak that reaches up to 30 to 80 feet in height. The shrub layer is poorly developed, but may include toyon (Heteromeles arbutifolia), laurel sumac (Malosma laurina), or elderberry (Sambucus spp.) The herb component is continuous and can include poison oak (Toxicodendron diversilobum) and introduced grasses such as bromes (Bromus spp.). Open coast live oak woodland contains a relatively sparse, open herbaceous and shrub understory.
Coast live oak woodland and open coast live oak woodland are scattered throughout, often adjacent to Southern Cottonwood–Willow Riparian Forest (Figures 5A through 5E). Characteristic species observed include coast live oak, laurel sumac, and elderberry. Oak woodland containing Engelman oak (Quercus engelmannii), as well as individual oaks with at least one trunk of 6 inches or more diameter breast height or multi-trunked native oaks with aggregate diameter of 10 inches or more, are considered a sensitive community in the Draft Santee Subarea Plan (City of Santee 2025). No Engelman oaks were identified on the Project Site during the biological reconnaissance surveys. However, mature coast live oak woodland and open coast live oak woodland on the Project Site likely contain oak trees that meet the size and multi-trunk criteria to be considered sensitive. As such, to be conservative, coast live oak woodland (including Open subform) is considered a sensitive vegetation community according to the Draft Santee MSCP Subarea Plan.
4.1.1.12 Coastal Sage Scrub (Including Baccharis-Dominated) Diegan coastal sage scrub is a native vegetation community that, according to Oberbauer et al. (2008), is composed of various soft, low, aromatic shrubs, characteristically dominated by drought-deciduous species—such as coastal sagebrush (Artemisia californica), California buckwheat (Eriogonum fasciculatum), and sages (Salvia spp.)—with scattered evergreen shrubs, including lemonade berry (Rhus integrifolia) and laurel sumac.
Diegan coastal sage scrub (Baccharis-dominated) is similar to Diegan coastal sage scrub but dominated by Baccharis species (broom baccharis and/or coyote brush [Baccharis pilularis]) (Oberbauer et al. 2008). This community typically occurs on disturbed sites or those with nutrient-poor soils and is often found within other forms of Diegan coastal sage scrub and on upper terraces of river valleys. Diegan coastal sage scrub, including Baccharisdominated coastal sage scrub, is considered a sensitive vegetation community in the Draft Santee MSCP Subarea Plan (City of Santee 2025).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 14
JULY 2026
Diegan coastal sage scrub in the Project Site is dominated by broom baccharis, California sagebrush, toyon, laurel sumac, sugar bush (Rhus ovata), Menzie’s Goldenbush (Isocoma menziesii), California buckwheat, black sage (Salvia mellifera), and white sage (Salvia apiana). It occurs along the northern and southern boundaries of the Project Site in uplands (Figures 5A through 5E). Baccharis-dominated Diegan coastal sage scrub also occurs in Project Site adjacent to emergent wetlands and in uplands, dominated by broom baccharis and Menzie’s goldenbush.
4.1.2 Non-Native Vegetation Communities and Land Cover Types
4.1.2.1 Non-Native Riparian
According to Oberbauer et al. (2008), non-native riparian habitat consists of densely vegetated riparian thickets dominated by non-native, invasive species that account for greater than 50% of the total vegetative cover.
Characteristic species include giant reed, tamarisk, Eucalyptus, fan palms, castor bean (Ricinus communis), and pampas grass.
Non-native riparian habitat is present throughout the Project Site and is dominated by giant reed (Arundo donax) and pampas grass, with scattered castor bean (Figures 5A through 5E). Non-native riparian habitat consists of non-native invasive species; however, it could be considered a disturbed wetland vegetation type as presented in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). Therefore, to be conservative, it is assumed this vegetation community is considered sensitive and may be considered a jurisdictional resource by the resource agencies.
4.1.2.2 Tamarisk Scrub
According to Oberbauer et al. (2008), tamarisk scrub consists of a weedy, virtual monoculture of any of several tamarisk species, usually supplanting native vegetation following major disturbance. Site factors include sandy or gravelly braided washes or intermittent streams. Characteristic species include tamarisk species (Tamarix chinensis, Tamarix ramosissima).
Tamarisk scrub is present in an isolated patch within the Project Site (Figure 5C). Tamarisk scrub on the Project Site consisted of non-native invasive species; however, it could be considered a disturbed wetland vegetation type as presented in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). Therefore, to be conservative, it is assumed this vegetation community is considered sensitive and may be considered a jurisdictional resource by the resource agencies.
4.1.2.3 Non-Native Grassland
Non-native grassland consists of dense to sparse cover of annual grasses with flowering culms between 0.5 to 3 feet in height (Oberbauer et al. 2008). In San Diego County, the presence of wild oat (Avena spp.), bromes, stork’s bill (Erodium spp.), and mustard (Hirschfeldia spp.) are common indicators. In some areas, depending on past disturbance and annual rainfall, annual forbs may be the dominant species; however, it is presumed that grasses will dominate.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 15
JULY 2026
Non-native grassland occurs in the central portion of the Project Site in uplands (Figures 5B and 5C). Dominant species are non-native wild oats and bromes, as well as mustards and artichoke thistle (Cynara cardunculus). Nonnative grassland is considered a sensitive community in the Draft Santee MSCP Subarea Plan (City of Santee 2025).
4.1.2.4 Eucalyptus Woodland
Eucalyptus woodland, according to Oberbauer et al. (2008), includes eucalyptus species (Eucalyptus globulus, E. camaldulensis, or E. spp.) planted as trees, groves, and windbreaks that form thickets with minimal shrubby understory to scattered trees with a well-developed understory. In most cases however, eucalyptus trees form dense stands with closed canopies where the understory is either depauperate or absent owing to shade and the possible allelopathic (toxic) properties of the eucalyptus leaf litter. Although eucalyptus woodlands are of limited value to most native plants and animals, they frequently provide nesting and perching sites for several raptor species.
Eucalyptus woodland occurs intermittently throughout the Project Site boundary in uplands (Figures 5A through 5E).
Eucalyptus trees are dominant, and the understory is mainly leaf litter. In some areas of the Project Site, eucalyptus woodland has an understory of sagebrush and broom Baccharis.
4.1.2.5 Disturbed Habitat
According to Oberbauer et al. (2008), disturbed habitat is characterized by predominantly non-native species introduced and established through human action. These areas have been physically disturbed by previous human activity and are no longer recognizable as a native or naturalized vegetation association but continue to retain a soil substrate. Typically, vegetation, if present, is nearly exclusively composed of non-native plant species such as ornamentals or ruderal exotic species that take advantage of disturbance or show signs of past or present animal usage that removes any capability of providing viable natural habitat for uses other than dispersal. Examples include areas that have been graded, repeatedly cleared for fuel management purposes, and pedestrian trails.
Disturbed habitat on the Project Site consists of dirt pedestrian hiking trails as well as an isolated, cleared and graded area with exposed soils (Figure 5A through 5E).
4.1.2.6 Urban/Developed Land
According to Oberbauer et al. 2008, urban/developed land represents areas that have been constructed upon or otherwise physically altered to an extent that native vegetation communities are not supported. This land cover type generally consists of semi-permanent structures, homes, parking lots, pavement or hardscape, and landscaped areas that require maintenance and irrigation (e.g., ornamental greenbelts). Typically, this land cover type is unvegetated or supports various ornamental plants and landscaping.
Within the Project Site, urban/developed land includes asphalt-paved public access roads (Figure 5A through 5E).
4.2 Plant Diversity
A total of 83 species of native or naturalized plants, 52 (63%) native and 31 (37%) non-native, were detected within the Project Site during the biological reconnaissance surveys. A complete list of plant species observed during the biological reconnaissance is included in Attachment B, Species Compendium. Note that the biological TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 16
JULY 2026
reconnaissance was conducted during the fall, and many spring and summer-blooming plants may not have been detectible or identifiable yet. As such, plant diversity and abundance are likely underrepresented.
4.3 Wildlife Diversity
A total of 44 wildlife species consisting of 41 native and 3 non-native birds were detected within the Project Site during the biological reconnaissance surveys. A complete list of wildlife species observed during the biological reconnaissance is included in Attachment B. Wildlife diversity was moderate during the biological reconnaissance surveys due to the presence of multiple native riparian and upland vegetation communities. However, nocturnal species, cryptic species, and fossorial species are likely underrepresented.
4.4 Special-Status Species
4.4.1 Special-Status Plants
A total of 32 plant species meet the special-status definition in Section 2.3.1, Special-Status Plants, above and have recorded occurrences in the USGS La Mesa and El Cajon 7.5-minute quadrangles (CDFW 2025h; CNPS 2025).
Each special-status plant species is assessed in Attachment C, Special-Status Plant Species with a Potential to Occur. The Project Site is not within any designated critical habitat for special-status plant species (USFWS 2025b).
Of the 32 special-status plants known to occur in the region, one species was observed present within the Project Site during field surveys: San Diego marsh-elder (CRPR 2B.2). San Diego marsh-elder populations were incidentally observed on the Project Site during the biological reconnaissance surveys within freshwater marsh habitat. A total of 7 of the 32 special-status plant species were determined to have a moderate to high potential to occur in the native vegetation communities on the Project Site. A total of 9 of the 32 special-status plants were determined to have a low potential to occur due to suitable elevation ranges but limited habitat suitability or lack of recent or nearby occurrence records; 15 of the 32 special-status plants are not expected to occur on the Project Site due to lack of suitable habitat, soils, and/or elevation range requirements. The remaining special-status plant species that are not expected to occur or were determined to have a low potential to occur on the Project Site due to lack of suitable habitat, elevation range, and/or soils are included in Attachment C but not discussed further.
Although a protocol-level botanical survey was conducted concurrently with the biological reconnaissance, it was conducted outside of the spring and summer blooming periods; therefore, only one special-status species was observed during surveys: San Diego marsh-elder. Known locations of white rabbit-tobacco (Pseudognaphalium leucocephalum) that are present immediately outside of the Project Site boundary are shown on Figure 6C, Suitable Special-Status Plant Habitats, as well as the observed San Diego marsh-elder individuals. Figures 6A through 6E depict the habitats that can support the other special-status plant species that were determined to have a moderate to high potential to occur, as described in Table 3 below.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 17
JULY 2026
Table 3. Special-Status Plant Species Present or with a Moderate to High Potential to Occur on the Project Site Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee MSCP)
Primary Habitat
Associations/Life Form/
Blooming Period/
Elevation Range (feet) Potential to Occur
Ambrosia pumila San Diego
ambrosia
FE/None/1B.1/None Chaparral, Coastal scrub,
valley and foothill
grassland, Vernal pools;
alkaline (sometimes), clay
(sometimes), disturbed
areas (often), loam
(sometimes), sandy
(sometimes)/perennial
rhizomatous herb/
Apr–Oct/65–1,360
Moderate potential to occur. The Project
Site is within the species known elevation
range; coastal scrub, non-native
grassland, and suitable substrates are
present. CNDDB occurrence records from
2006 overlap the Project Site (CDFW
2025a). However, this species prefers
vernal pools and none were detected on
the Project Site during the biological
reconnaissance.
Centromadia pungens ssp.
laevis
smooth tarplant None/None/1B.1/
None
Chenopod scrub, meadows
and seeps, playas, riparian
woodland, valley and
foothill grassland; alkaline/
annual herb/Apr–Sep/
0–2,100
Moderate potential to occur. The Project
Site is within the species known elevation
range; riparian woodland and non-native
grassland are present but the Project Site
lacks alkaline soils. CNDDB occurrence
records from 2008 to 2017 located 1
mile from the Project Site (CDFW 2025a).
Isocoma menziesii var.
decumbens
decumbent
goldenbush
None/None/1B.2/
None
Chaparral, coastal scrub
(often disturbed areas,
sandy)/perennial
shrub/Apr–Nov/35–820
Moderate potential to occur. The Project
Site is within the species known elevation
range; coastal scrub with sandy soils and
disturbed areas are present. Multiple
CNDDB occurrence records from 2005
and 2019 located 2 miles from the
Project Site (CDFW 2025a).
Iva hayesiana San Diego
marsh-elder
None/None/2B.2/
None
Marshes and swamps,
playas/perennial herb/
Apr–Oct/0–1,640
Present. Observed during the biological
reconnaissance surveys within the
freshwater marsh habitat on the Project
Site.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 18
JULY 2026
Table 3. Special-Status Plant Species Present or with a Moderate to High Potential to Occur on the Project Site Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee MSCP)
Primary Habitat
Associations/Life Form/
Blooming Period/
Elevation Range (feet) Potential to Occur
Monardella viminea willowy
monardella
FE/SE/1B.1/Covered Chaparral, Coastal scrub,
Riparian forest, Riparian
scrub, Riparian woodland;
Alluvial Terraces, Washes/
perennial herb/June–Aug/
165–740
Moderate to occur. The Project Site is
within the species known elevation range
and suitable modeled habitat occurs
within the Project Site (City of Santee
2025); however, this perennial species
was not observed during field surveys
and the site does not contain suitable
alluvial terraces. Closest CNDDB
occurrence record from 2007 is located
1 mile from the Project Site (CDFW
2025a).
Pseudognaphalium
leucocephalum
white rabbittobaccoNone/None/2B.2/
None
Chaparral, cismontane
woodland, coastal scrub,
riparian woodland; gravelly,
sandy/perennial herb/
(July) Aug–Nov (Dec)/
0–6,890
High potential to occur. Although not
detected during the biological
reconnaissance surveys, Dudek
biologists have documented this species
along sandy areas immediately adjacent
to the San Diego River while working on
other projects. The Project Site is within
the species known elevation range;
riparian woodland and sandy soils are
present. Consortium of California
Herbaria (CCH) occurrence records from
2011 are located immediately outside of
the southern Project Site boundary (CCH
2025).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 19
JULY 2026
Table 3. Special-Status Plant Species Present or with a Moderate to High Potential to Occur on the Project Site Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee MSCP)
Primary Habitat
Associations/Life Form/
Blooming Period/
Elevation Range (feet) Potential to Occur
Quercus dumosa Nuttall’s scrub
oak
None/None/1B.1/
None
Chaparral, closed-cone
coniferous forest, coastal
scrub; clay, loam, sandy/
perennial evergreen shrub/
Feb–Apr (May–Aug)/
50–1,310
High potential to occur. The Project Site
is within the species known elevation
range; coastal scrub and suitable soils
present; may occur within coast live oak
woodland on the Project Site. CNDDB
occurrence records from 2009 overlap
the Project Site (CDFW 2025a).
Stylocline citroleum oil neststraw None/None/1B.1/
None
Chenopod scrub, coastal
scrub, valley and foothill
grassland; clay/annual
herb/Mar–Apr/165–1,310
Moderate potential to occur. The Project
Site is within the species known elevation
range; coastal scrub and non-native
grassland are present along with clay
soils. Historic CNDDB occurrence records
from 1883 are 5 miles from the Project
Site and presumed extant (CDFW
2025a).
* Status Legend:
Federal
FE: Federally listed as endangered
CRPR: California Rare Plant Rank
1A: Plants presumed extirpated in California and either rare or extinct elsewhere 1B: Plants rare, threatened, or endangered in California and elsewhere 2A: Plants presumed extirpated in California but common elsewhere 2B: Plants rare, threatened, or endangered in California but more common elsewhere Threat Rank
.1 Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat) .2 Moderately threatened in California (20% to 80% occurrences threatened/moderate degree and immediacy of threat) Other Designations
MSCP: Multiple Species Conservation Program (City of Santee Draft MSCP Subarea Plan).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 20
JULY 2026
4.4.2 Special-Status Wildlife
A total of 41 wildlife species meet the special-status definition in Section 2.3.2, Special-Status Wildlife, above and have recorded occurrences in the USGS La Mesa and El Cajon 7.5-minute quadrangles (CDFW 2025h). These special-status wildlife with a potential to occur on the Project Site are included in Attachment D. Of the 41 specialstatus wildlife known to occur in the region, total of 24 species were observed or determined to have a moderate to high potential to occur based on overlapping or nearby known occurrence records, as well as suitable habitats present. The remaining 17 special-status wildlife species that are not expected to occur or were determined to have a low potential to occur due to lack of suitable habitat are included in Attachment D but not discussed in this report further.
In addition, 2 of the 41 special-status wildlife are considered present on the Project Site: yellow warbler (Setophaga petechia) (CDFW Species of Special Concern when nesting) and least Bell’s vireo (Vireo bellii pusillus) (federally and state endangered). The western portion of the Project Site is within designated critical habitat for least Bell’s vireo as shown on Figure 7A, Suitable Special-Status Wildlife Habitats, and there are recent occurrence records that overlap the Project Site (USFWS 2025b) (CDFW 2025a) (Attachment D). Multiple riparian woodlands, forests, scrubs, and emergent vegetation can support this species nesting and foraging on the Project Site. Dudek biologists have documented least Bell’s vireo along the San Diego River in Santee for other projects. Yellow warbler is also considered present since the Project Site supports suitable nesting and foraging habitat and Dudek biologists have documented it along the San Diego River in Santee for other projects.
Furthermore, coastal sage scrub habitats on the Project Site have a moderate potential to support the coastal California gnatcatcher (Polioptila californica californica) as there are recent occurrence records and designated critical habitat immediately adjacent to the Project Site. Yellow warbler, least Bell’s vireo, and coastal California gnatcatcher are all covered species under the City of Santee Draft MSCP Subarea Plan. These four special-status wildlife species are described in further detail herein. Table 4, Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site, summarizes the listing status, habitat requirements, and potential to occur determinations for the 24 special-status wildlife species. Figure 7A and 7E also depicts the suitable habitats for special-status wildlife present, considered present, or determined to have a moderate or high potential to occur on the Project Site as listed in Table 4.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 21
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
Reptiles
Anniella stebbinsi southern
California legless
lizard
None/SSC/None Coastal dunes, stabilized dunes,
beaches, dry washes, valley–
foothill, chaparral, and scrubs;
pine, oak, and riparian
woodlands; associated with
sparse vegetation and moist
sandy or loose, loamy soils
High potential to occur. Suitable habitats
present (coastal scrub, wash, oak
woodland, riparian woodland; moist sandy
soils). CNDDB occurrence record from
2012 overlap the western portion of the
Project Site (CDFW 2025a).
Arizona elegans
occidentalis
California glossy
snake
None/SSC/None Arid scrub, rocky washes,
grasslands, chaparral, open areas
with loose soil
High potential to occur. Suitable substrate
present. Historic CNDDB occurrence
records from 1973 overlap the Project
Site (CDFW 2025a).
Aspidoscelis
hyperythrabeldingi
Belding’s orangethroated whiptailNone/WL/Covered Low-elevation coastal scrub, chaparral, and valley–foothill
hardwood
High potential to occur. Suitable coastal
scrub habitat and hardwood present.
CNDDB occurrence records from 1999
border the northern Project Site boundary
(CDFW 2025a).
Aspidoscelis tigris
stejnegeri
San Diegan tiger
whiptail
None/SSC/None Hot and dry areas with sparse
foliage, including chaparral,
woodland, and riparian areas
High potential to occur. Riparian
woodland is present. CNDDB occurrence
records from 2008 are located 4 miles
from the Project Site (CDFW 2025a).
Crotalus ruber red diamondback rattlesnakeNone/SSC/None Coastal scrub, chaparral, oak and pine woodlands, rocky
grasslands, cultivated areas, and
desert flats
Moderate potential to occur. Coastal
scrub and oak woodland present could
provide suitable habitat for this species.
CNDDB occurrence record from 1998
within 1 mile of the Project Site (CDFW
2025a).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 22
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
Phrynosoma blainvillii Blainsville’s
horned lizard
None/SSC/Covered Open areas of sandy soil in
valleys, foothills, and semi-arid
mountains including coastal
scrub, chaparral, valley–foothill
hardwood, conifer, riparian, pine–
cypress, juniper, and annual
grassland habitats
Moderate potential to occur. Coastal
scrub, riparian woodland, and grassland
with sandy soils present. Historic CNDDB
occurrence records from 1937 overlap
the Project Site; however, the Project Site
is currently fairly isolated (CDFW 2025a).
Salvadora hexalepis
virgultea
coast patchnosed snakeFPT/SSC/None Brushy or shrubby vegetation; requires small mammal burrows
for refuge and overwintering sites
Moderate potential to occur. Suitable
brushy or shrubby vegetation present. A
CNDDB occurrence record from 2004 is
located 4 miles from the Project Site
(CDFW 2025a).
Thamnophis
hammondii
two-striped
gartersnake
None/SSC/None Streams, creeks, pools, streams
with rocky beds, ponds, lakes,
vernal pools
High potential to occur. San Diego River
on site provides suitable habitat. A
CNDDB occurrence record from 1998 is
within 1 mile of the Project Site (CDFW
2025a).
Birds
Athene cunicularia
(burrow sites and
some wintering sites)
burrowing owl BCC/SSC, SC/Covered Nests and forages in grassland, open scrub, and agriculture,
particularly with ground squirrel
burrows
Moderate potential to occur. Coastal
scrub and grassland present. The nearest
CNDDB occurrence record within 1 mile of
the Project Site is from 1921 and
extirpated; however, there are occurrence
records from 2024 located 2 miles from
the Project Site (CDFW 2025a).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 23
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
Coturnicops
noveboracensis
yellow rail BCC/SSC/None Nesting requires wet marsh/
sedge meadows or coastal
marshes with wet soil and
shallow, standing water
Moderate potential to occur. Suitable
nesting habitat present (freshwater
marsh, shallow standing water) along San
Diego River in the Project Site. CNDDB
occurrence records from 1998 overlap
the Project Site (CDFW 2025a).
Icteria virens
(nesting)
yellow-breasted
chat
None/SSC/None Nests and forages in dense,
relatively wide riparian woodlands
and thickets of willows, vine
tangles, and dense brush
Considered present. Suitable nesting and
foraging habitat present; San Diego River
supports relatively wide riparian thickets
of willows and dense brush throughout
the Project Site. CNDDB occurrence
record from 1994 are located 4 miles
from the Project Site (CDFW 2025a).
Polioptila californica
californica
coastal California
gnatcatcher
FT/SSC/Covered Nests and forages in various sage
scrub communities, often
dominated by California
sagebrush and buckwheat;
generally avoids nesting in areas
with a slope of greater than 40%;
majority of nesting at less than
1,000 feet above mean sea level
Considered present. Coastal sage scrub is
present within uplands along the north
and south Project Site boundaries. There
are CNDDB occurrence records from
1999 border the north Project Site
boundary (CDFW 2025a). There is
designated critical habitat for this species
approximately 1 mile north and south of
the Project Site (USFWS 2025b).
Setophaga petechia
(nesting)
yellow warbler None/SSC/None Nests and forages in riparian and oak woodlands, montane
chaparral, open ponderosa pine,
and mixed-conifer habitats
Considered present. Suitable nesting and
foraging habitat present throughout the
riparian areas along the San Diego River
in the Project Site. CNDDB occurrence
record from 1972 located 2 miles from
the Project Site (CDFW 2025a). Although
not detected during the biological
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 24
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
reconnaissance surveys, Dudek biologists
have documented this species along the
San Diego River within Santee while
working on other projects.
Vireo bellii pusillus
(nesting)
least Bell’s vireo FE/SE/Covered Nests and forages in low, dense riparian thickets along water or
along dry parts of intermittent
streams; forages in riparian and
adjacent shrubland late in nesting
season
Considered present. Suitable nesting and
foraging habitat present (riparian
woodlands, mulefat scrub, willow scrub)
along San Diego River. CNDDB
occurrence records from 2012 overlap
the Project Site (CDFW 2025a). The
western portion of the Project Site
overlaps designated critical habitat for
this species (USFWS 2025b). Although
not detected during the biological
reconnaissance surveys, Dudek biologists
have documented this species along the
San Diego River within Santee while
working on other projects.
Botaurus exilis
(nesting)
least bittern None/SSC/None Nests in freshwater and brackish marshes with dense, tall growth
of aquatic and semi-aquatic
vegetation
Moderate potential to occur. Suitable
nesting habitat present. CNDDB
occurrence record from 2007 located 2
miles from the Project Site (CDFW
2025a).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 25
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
Mammals
Antrozous pallidus pallid bat None/SSC/
None
Grasslands, shrublands,
woodlands, forests; most
common in open, dry habitats
with rocky outcrops for roosting,
but also roosts in built structures
and trees
Moderate potential to occur. Suitable
habitat (grassland, woodlands, riparian
forest) is present although the site lacks
rocky outcrops for roosting; there are
CNDDB occurrence records from 1951 that
overlap the Project Site (CDFW 2025a).
Corynorhinus
townsendii
Townsend’s bigeared batNone/SSC/
None
Mesic habitats characterized by
coniferous and deciduous forests
and riparian habitat, but also
xeric areas; roosts in limestone
caves and lava tubes, built
structures, and tunnels
Moderate potential to occur. No roosting
habitat present but may forage over San
Diego River’s riparian habitats throughout
the Project Site. CNDDB occurrence
record from 1991 located 5 miles from
the Project Site (CDFW 2025a).
Dasypterus xanthinus western yellow
bat
None/SSC/None Valley–foothill riparian, desert
riparian, desert wash, and palm
oasis habitats; below 2,000 feet
above mean sea level; roosts in
riparian and palms
High potential to occur. Suitable roosting
habitat (riparian) present. CNDDB
occurrence records from 1979 are
immediately east of the Project Site
(CDFW 2025a).
Eumops perotis
californicus
western mastiff
bat
None/SSC/None Chaparral, coastal and desert
scrub, coniferous and deciduous
forest and woodland; roosts in
crevices in rocky canyons and cliffs
where the canyon or cliff is vertical
or nearly vertical, trees, and tunnels
Moderate potential to occur. Coastal
scrub and woodlands present could
provide roosting habitat. CNDDB
occurrence records from 2003 located 4
miles from the Project Site (CDFW
2025a).
Neotoma lepida
intermedia
San Diego desert
woodrat
None/SSC/None Coastal scrub, desert scrub,
chaparral, cacti, rocky areas
Moderate potential to occur in coastal
scrub throughout the Project Site,
although rocky areas are absent. CNDDB
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 26
JULY 2026
Table 4. Special-Status Wildlife Present, Considered Present, or with a Moderate to High Potential to Occur on the Project Site
Scientific Name Common Name
Status*
(Federal/State/Draft
Santee MSCP) Habitat Potential to Occur
occurrence record from 1998 within 1
mile of the Project Site (CDFW 2025a).
Nyctinomops
femorosaccus
pocketed freetailed batNone/SSC/None Pinyon–juniper woodlands, desert scrub, desert succulent shrub,
desert riparian, desert wash,
alkali desert scrub, Joshua tree,
and palm oases; roosts in high
cliffs or rock outcrops with dropoffs, caverns, and buildings Moderate potential to occur. No roosting
habitat present; however, CNDDB
occurrence records from 1990 overlap
the Project Site and there is
riparian/wash habitat along the Project
Site that can be seasonally arid. Multiple
CNDDB occurrence records from 1983 to
2003 located 3 to 5 miles from the
Project Site (CDFW 2025a).
Nyctinomops
macrotis
Big free-tailed bat None/SSC/None Rocky areas; roosts in caves, holes in trees, buildings, and
crevices on cliffs and rocky
outcrops; forages over water
High potential to occur. May forage over
San Diego River in the Project Site. Not
expected to roost as no suitable roosting
habitat present. CNDDB occurrence
records from 1989 overlap the Project
Site (CDFW 2025a).
Lasiurus frantzii western red bat None/SSC/None Forest, woodland, riparian, mesquite bosque, and orchards,
including fig, apricot, peach, pear,
almond, walnut, and orange;
roosts in tree canopy
Moderate potential to occur. Suitable
roosting habitat present (riparian forest
and woodland). A CNDDB occurrence
record from 2003 is located 4 miles from
the Project Site (CDFW 2025a).
Invertebrates
Bombus crotchii Crotch’s bumble
bee
None/SCE/
Covered
Open grassland and scrub
communities supporting suitable
floral resources
Moderate potential to occur. Suitable
habitat present along with floral
resources for foraging. Nearest CNDDB
occurrence record is 2 miles from the
Project Site, from 2020 (CDFW 2025a).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 27
JULY 2026
* Status Abbreviations:
Federal
FE: Federally listed as endangered
FT: Federally listed as threatened
FPT: Federally proposed for listing as threatened
BCC: U.S. Fish and Wildlife Service Bird of Conservation Concern State
SSC: California Species of Special Concern
WL: California Watch List Species
SE: State listed as endangered
SC: State candidate for listing as threatened or endangered SCE: State candidate for listing as endangered
Other Designations
MSCP: Multiple Species Conservation Program (City of Santee Draft MSCP Subarea Plan).
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 28
JULY 2026
Yellow-Breasted Chat
Yellow-breasted chat (Icteria virens) is a CDFW Species of Special Concern when nesting. It nests and forages in dense, relatively wide riparian woodlands and thickets of willows, vine tangles, and dense brush. Yellow warblers breed from early May into early August. In Southern California, it nests in riparian thickets of willow and other brushy thickets associated with watercourses. Yellow-breasted chat is not a City of Santee Draft MSCP Subarea Plan Covered Species (City of Santee 2025).
Suitable nesting and foraging habitat is present throughout the riparian areas along the San Diego River in the Project Site, and historic CNDDB occurrence records from 1994 are located 4 miles from the Project Site (CDFW 2025a). Although not detected during the biological reconnaissance surveys, Dudek biologists have documented this species along the San Diego River within Santee while working on other projects and those locations are shown on Figures 7A, 7D, and 7E. As such, it is considered present in riparian vegetation communities on the Project Site.
Yellow Warbler
Yellow warbler is a CDFW Species of Special Concern when nesting. It nests and forages in riparian and oak woodlands, montane chaparral, open ponderosa pine, and mixed-conifer habitats. Yellow warblers breed from April into early August. In Southern California, it nests in lowland and foothill riparian woodlands dominated by cottonwoods, alders (Alnus spp.), or willows, and other small trees and shrubs typical of low, open canopy riparian woodland (Garrett and Dunn 1981). Yellow warbler is not a City of Santee Draft MSCP Subarea Plan Covered Species (City of Santee 2025).
Suitable nesting and foraging habitat is present throughout the riparian areas along the San Diego River in the Project Site, and historic CNDDB occurrence records from 1972 are located 2 miles from the Project Site (CDFW 2025a). Although not detected during the biological reconnaissance surveys, Dudek biologists have documented this species along the San Diego River within Santee while working on other projects and those locations are shown on Figures 7A, 7C, and 7D. As such, it is considered present in riparian vegetation communities on the Project Site.
Least Bell’s Vireo
This federal and state- endangered subspecies of the Bell’s vireo winters in the southern end of the Baja California peninsula, Mexico, and migrates north in mid-March to early April to nest in southern and coastal California, with some desert oases. Its breeding habitat is primarily willow-dominated riparian woodlands, although it sometimes forages and nests in neighboring mulefat scrub, oak woodlands, and chaparral. Least Bell’s vireo is a City of Santee MSCP Draft Subarea Plan Covered Species.
Suitable nesting and foraging habitat is present throughout the riparian areas along the San Diego River in the Project Site and USFWS designated Critical Habitat for least Bell’s vireo occurs within the western portion of the site. Although not detected during the biological reconnaissance surveys, Dudek biologists have documented this species along the San Diego River within Santee while working on other projects and those locations are shown on Figure 7A, 7C, and 7D. As such, it is considered present in riparian vegetation communities on the Project Site.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 29
JULY 2026
Coastal California Gnatcatcher
This federally threatened and CDFW Species of Special Concern is found on the coastal slopes of Southern California, from southwestern Ventura southward to Baja California, Mexico, usually below 1,640 feet in elevation.
It occurs in or near coastal sage scrub dominated by California sagebrush and California buckwheat. Breeding season extends from late February through early August. Coastal California gnatcatcher is a City of Santee MSCP Draft Subarea Plan Covered Species.
Due to the presence of suitable nesting and foraging habitat (Diegan coastal sage scrub) as well as recent occurrence records immediately adjacent to the Project Site and designated critical habitat located within 1 mile of the Project Site, this species is determined to have a moderate potential to occur within suitable habitat areas (e.g., coastal sage scrub) of the Project Site. Although not detected during the biological reconnaissance surveys, Dudek biologists have documented this species while working on other projects and those locations are shown on Figure 7E. This species is discussed further in Section 4.6, Wildlife Movement, Wildlife Corridors, and Wildlife Nursery Sites.
4.5 Potentially Jurisdictional Aquatic Resources
Although a formal jurisdictional delineation was not conducted during the biological reconnaissance field surveys, the Project Site was evaluated for the potential to support jurisdictional waters regulated under the federal Clean Water Act, California Fish and Game Code, and Porter–Cologne Water Quality Act. Baseline wetland mapping from the USFWS NWI and USGS National Hydrography Dataset were used as a basis to inform the outer limits of potentially jurisdictional waters, such as streams or wetlands, on the Project Site (USFWS 2025a; USGS 2025).
Potential non-wetland waters of the United States and State regulated by USACE and/or RWQCB and CDFW streambed/associated riparian habitat were identified in the Project Site, consisting of the San Diego River, its tributary (Forester Creek), and multiple associated riparian/wetland vegetation communities/land covers. These features were informally mapped and examined based on the observable presence of an ordinary high water mark, hydrology indicators and/or hydrophytic (wetland) vegetation. For the purposes of this review, no formal wetland determination points were taken in the Project Site.
Potentially jurisdictional aquatic resources on the Project Site are depicted on Figure 8, Potentially Jurisdictional Aquatic Resources. Table 5 summarizes the acreages of the riparian/wetland vegetation communities (all considered sensitive by the City of Santee MSCP Draft Subarea Plan) and NWI-mapped wetlands on the Project Site that would be considered potentially jurisdictional aquatic resources. Note that the acreage of jurisdictional aquatic resources on the Project Site was calculated based off the riparian/wetland vegetation communities mapping conducted during the biological reconnaissance surveys; any NWI-mapped resources that did not overlap the vegetation communities were added to the overall potential jurisdictional resources acreage to conservatively estimate the extent of potentially jurisdictional resources on the Project Site.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 30
JULY 2026
Table 5. Potentially Jurisdictional Aquatic Resources Within the Project Site Aquatic Resource Type Acreage
USACE/RWQCB/CDFW
Non-wetland Waters/Streambeds 40.18
Wetlands/Riparian Habitat 195.47
Potential Jurisdictional Aquatic Resource Total 236.65
Source: USFWS National Wetlands Inventory (USFWS 2025a).
Notes: USACE = U.S. Army Corps of Engineers; RWQCB = Regional Water Quality Control Board; CDFW = California Department of Fish and Wildlife.
Aquatic Resources Narrative
A total of 236.65 acres of riparian/wetland vegetation communities occur on the Project Site, associated with the San Diego River and Forester Creek. The San Diego River begins in uplands within the Cuyamaca mountains northwest of the town of Julian, then flows southwest through Santee and San Diego until it discharges to the Pacific Ocean, a Traditionally Navigable Water. The San Diego River bisects the center of the Project Site and flows from east to west. Forester Creek is a tributary of the San Diego River that drains the runoff from the north facing slopes of hills within the City of El Cajon and bisects the southwestern portion of the Project Site. Portions of Forester Creek and the San Diego River within the City of Santee have been partially improved to mitigate potential flood hazards or prevent localized erosion (City of Santee 2023). Based on wetland parameters observed in the field and connectivity to a Traditionally Navigable Water, the entire reach of the San Diego River and Forester Creek within the Project Site would be considered aquatic resources regulated under the jurisdiction of USACE, RWQCB, and CDFW, with CDFW also taking jurisdiction over the riparian/wetland habitats within the Project Site.
Specifically, the reaches of the San Diego River and Forester Creek within the Project Site would be regulated by USACE under Section 404 of the Clean Water Act, RWQCB under Section 401 of the Clean Water Act and Porter– Cologne Act, and riparian/wetland habitats by CDFW under Sections 1600–1616 of the California Fish and Game Code. Emergent wetland meets the definition of three-parameter wetlands and would be considered Wetlands of the State under the jurisdiction of RWQCB. Note that this preliminary assessment provides an overview of the potential jurisdictional resources in the Project Site and does not constitute a formal jurisdictional delineation.
National Wetlands Inventory and National Hydrography Dataset The Project Site supports multiple NWI-mapped aquatic features (USFWS 2025a) (Figure 8). The NWI-mapped resources on the Project Site include palustrine and riverine features, specifically the following:
PEM1F(x)- Palustrine; Emergent; Persistent; Semi-permanently Flooded; Excavated: This designation describes a palustrine persistent freshwater emergent wetland system with a semi-permanently flooded water regime and excavated areas.
PEM1C(x) – Palustrine; Emergent; Persistent; Seasonally Flooded. This designation describes a palustrine persistent freshwater emergent wetland system with a seasonally flooded water regime.
PFOC – Palustrine; Forested; Seasonally Flooded. This designation describes a palustrine freshwater forested wetland system with a seasonally flooded water regime.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 31
JULY 2026
PFOAx- Palustrine; Forested; Temporarily Flooded; Excavated. This designation describes a palustrine freshwater forested wetland system with a temporarily flooded water regime and excavated areas.
PSSC(x)- Palustrine; Scrub-Shrub; Seasonally Flooded; excavated. This designation describes a palustrine freshwater shrub wetland system with a seasonally flooded water regime and excavated areas.
PSSA- Palustrine; Scrub-Shrub; Temporarily Flooded. This designation describes a freshwater shrub wetland system with a temporarily flooded water regime.
PUBHx – Palustrine; Unconsolidated Bottom; Permanently Flooded; Excavated. This designation describes an excavated freshwater pond with a permanently flooded water regime.
PUBFx – Palustrine; Unconsolidated Bottom; Semi-permanently Flooded; Excavated. This designation describes an excavated palustrine freshwater pond with a semi-permanently flooded water regime.
PUSCx – Palustrine; Unconsolidated Shore; Seasonally Flooded; Excavated. This designation describes an excavated palustrine freshwater Pond with a seasonally flooded water regime.
R4SBC – Riverine; Intermittent; Streambed; Seasonally Flooded. This designation describes a riverine intermittent streambed with a non-tidal, seasonally flooded water regime.
R5UBF– Riverine; Unknown Perennial Class; Unconsolidated Bottom; Semi-permanently Flooded. This designation describes a riverine system with a semi-permanently flooded water regime and unknown perennial class.
The riparian/wetland vegetation communities associated with the San Diego River and Forester Creek correspond with these mapped NWI-features on the Project Site. There are also National Hydrography Dataset mapped features that overlap the Project Site. Specifically, Forester Creek is mapped as a ‘blue-line’ intermittent stream/river in the southwestern portion of the Project Site. Additionally, the San Diego River is mapped as a ‘blue-line’ intermittent stream/river with connector, pipeline, and artificial path sections (USGS 2025). Note that National Hydrography Dataset lines are not depicted on Figure 8 or included in calculations for approximate acreage of jurisdictional resources on the Project Site to avoid redundancy and duplication, as the National Hydrography Dataset lines bisected the riparian/wetland vegetation communities and NWI-mapped features.
4.6 Wildlife Movement, Wildlife Corridors, and
Wildlife Nursery Sites
The MSCP Plan (City of San Diego 1998) defines core and linkage areas as those maintaining ecosystem function and processes, including large animal movement. Each core area is connected to other core areas or to habitat areas outside of the MSCP study area either through common boundaries or through linkages. Core areas have multiple connections to help ensure that the balance in the ecosystem would be maintained. Biological core and linkage areas represent the largest remaining habitat blocks with relatively high biological value and include critical linkages connecting the habitat blocks for species dispersal and movement in San Diego County (City of San Diego 1998). Biological core and linkage areas are identified in the MSCP Plan (City of San Diego 1998) and used without revision on Figure 2-12 in the Draft Santee MSCP Subarea Plan (City of Santee 2025) as shown on Figure 2.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 32
JULY 2026
According to the City of Santee Draft MSCP Subarea Plan, the San Diego River within the Project Site provides a corridor for wildlife movement and connectivity through the urbanized portion of the City of Santee (City of Santee 2025). The western portion of the San Diego River in the Project Site from Forester Creek up to Mast Park is mapped as a San Diego County MSCP biological core and linkage area (Figure 2-12; City of Santee 2025). City of Santee MSCP Draft Subarea Plan also includes Hardlines Conservation Areas and Existing Protected Open Space (City of Santee 2025). The Project Site is outside the boundaries of a Hardline Conservation Area. However, Existing Protected Open Space is included in the Project Site (Figure 2). The Draft City of Santee MSCP Subarea Plan maps habitat connectivity and linkages throughout the City’s jurisdiction. The San Diego River segment within the Project Site is identified as a “Habitat Linkage/Wildlife Corridor” and there is a “Habitat Connectivity Connection with Surrounding Open Space” associated with the Forrester Creek portion of the site and adjacent golf course (Figure 5-3; City of Santee 2025). The Draft City of Santee MSCP Subarea Plan also maps a “Coastal California Gnatcatcher Stepping Stone Linkage” across the easternmost portion of the Project Site to connect two mapped “Coastal Sage Scrub/Gnatcatcher Habitat Blocks” that are present in uplands that border the easternmost portion of the northern and southern Project Site boundaries. Figure 9, Wildlife Corridors and Habitat Linkages, depicts the City of Santee MSCP Draft Subarea Plan San Diego River Corridor and coastal California gnatcatcher habitat blocks/linkages, mapped within and immediately adjacent to the Project Site.
The Project Site could potentially function as a wildlife habitat for local populations of common mammal species.
Species most likely to use the Project Site include coyote (Canis latrans), mule deer (Odocoileus hemionus), raccoon (Procyon lotor), striped skunk (Mephitis mephitis), and Virginia opossum (Didelphis virginiana). Larger species, such as bobcat (Lynx rufus) and mountain lion (Puma concolor) are not expected to use this highly urbanized vicinity of the San Diego River corridor due to the amount of adjacent commercial and industrial uses, large presence of human encampments, and general lack of connectivity to larger core areas of suitable habitat.
Bat roosting opportunities for multiple special-status bat species are present throughout the riparian habitats surrounding San Diego River in the Project Site but surrounding commercial and residential development causes noise disturbance. In addition, no diagnostic signs of bird rookeries (e.g., numerous nests, whitewash) or large maternal or overwintering bat roosts (e.g., large concentrations of guano or guano odors) were identified in the Project Site during the biological reconnaissance field surveys. Therefore, it is unlikely for the Project Site to support wildlife nursery sites.
The Project Site contains multiple native vegetation communities that could provide nesting habitat for birds protected under the Migratory Bird Treaty Act and California Fish and Game Code Sections 3503, 3503.5, and 3513. These include raptors and special-status wildlife species as well as common species adapted to urban environments.
4.7 Habitat Conservation Plan/Natural Community
Conservation Plan
The Project Site occurs within the boundaries of the MSCP Plan; the Project Site is also within the boundaries of the San Diego River Subunit of the Draft City of Santee MSCP Subarea Plan (Subarea Plan) (Figure 2). The Draft Santee MSCP Subarea Plan would serve as a Habitat Conservation Plan under the MSCP Plan (City of San Diego 1998) pursuant to Section 10(a)(1)(B) of the federal Endangered Species Act, and as a Natural Community Conservation Plan pursuant to the California Natural Community Conservation Planning Act of 1991. The Draft Santee MSCP TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 33
JULY 2026
Subarea Plan, once approved, would contribute to the regional MSCP for preservation, mitigation for impacts, and conservation of sensitive biological resources within San Diego County. The Draft Santee MSCP Subarea Plan is also intended to provide cumulative mitigation for impacts to Covered Species within the City of Santee’s jurisdiction, as long as projects are consistent with and covered by provisions of the Santee MSCP Subarea Plan, and to ensure sufficient biological resources are conserved to assist in the conservation and recovery of Covered Species under the MSCP. The majority of Zones 1 and 2 overlap defensible space areas identified within the San Diego River Subunit as shown on Figure 4-5 of the City of Santee Draft MSCP Subarea Plan (0 to 100 feet from structures), and Zone 3 is identified as a fuel hazard reduction area (City of Santee 2025).
4.8 Local Policies and Ordinances
In the Conservation Element of the City of Santee General Plan, biological resources are discussed, and specific objectives and policies are presented (City of Santee 2003). In addition, the City of Santee’s Urban Forestry Ordinance contains tree-related policies, regulations, and generally accepted standards for planting, trimming, and removing trees on public property and public rights-of-way (Santee Municipal Code, Section 8.06 [City of Santee 2020]). The ordinance gives the City of Santee control of all trees, shrubs, and other plantings in any street, park, public right-of-way, landscape maintenance district or easement, or other City-owned property.
The Project Site is zoned as Open Space lands (San Diego River, Forester Creek) by the City of Santee General Plan Conservation Element (City of Santee 2003). The San Diego River is recognized by the City of Santee Conservation Element as a significant central open space corridor, emphasizing its visual integrity, natural resources, and recreational opportunities (City of Santee 2003). The San Diego River corridor that overlaps the Project Site is zoned by the City of Santee General Plan as Open Space and is a generally uninterrupted band of natural floodplain, open water, and riparian/wetland vegetation communities that are considered to be significant wildlife habitat (City of Santee 2003). The City of Santee encourages maintenance of appropriate open space uses adjacent to natural watercourses (San Diego River, Forester Creek) that would reduce flood damage hazards, improve water quality, protect visual quality, and maintain use as wildlife habitats (City of Santee 2003). The Project consists of fuel reduction within the San Diego River and Forester Creek that would improve the overall habitat quality of these natural watercourses and not alter its current land use zoning as Open Space. The Project would comply with the City’s Forestry Ordinance and biological resources policies within the Conservation Element as no development is proposed, and the Project is intended to improve the San Diego River and Forester Creek through fuel reduction of mostly non-native trees and trees that are dead or decaying. Therefore, the Project is consistent with respect to the relevant City of Santee biological, floodway, and urban forestry municipal codes as well as the goals outlined in the City of Santee General Plan’s Conservation Element.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 34
JULY 2026
5 Impacts
This section addresses potential impacts (e.g., permanent, temporary, direct, and indirect) to special-status biological resources that could result from implementation of the Project. This section addresses each CEQA significance threshold, identifies potential impacts, and provides mitigation measures (MM), as applicable, to compensate for the Project’s significant impacts.
5.1 California Environmental Quality Act Significance Thresholds The following are the significance thresholds for biological resources provided in the CEQA Appendix G Environmental Checklist, which states that Project activities could potentially have a significant effect if the following occur:
Threshold BIO-1: 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.
Threshold BIO-2: 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.
Threshold BIO-3: Have a substantial adverse effect on state and federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.
Threshold BIO-4: 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.
Threshold BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
Threshold BIO-6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state Habitat Conservation Plan.
5.1.1 Threshold BIO-1: Special-Status Species
5.1.1.1 Special-Status Plants
One special-status plant species was observed within the Project Site: San Diego marsh-elder. White rabbit-tobacco has also been documented immediately outside of the Project Site boundary (CCH 2025) (Attachment C; Figures 10A through 10E, Impacts to Biological Resources). Both San Diego marsh-elder and white rabbit-tobacco are not Covered Species under the City of Santee Draft MSCP Subarea Plan. Further, the native vegetation communities within the Project Site have potential to support an additional five special-status plant species determined to have a moderate to high potential to occur on the Project Site that cannot be considered absent as the focused botanical survey was conducted outside of the spring and summer blooming period (Table 3). Direct impacts to special-status plants from Project implementation would be considered significant absent mitigation.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 35
JULY 2026
The Project consists of removing hazardous (dead or dying/diseased) non-native trees from within Zone 3 of the Project Site and native and non-native brush trimming in upland defensible space areas (Zones 1 and 2). Specialstatus plant species present or considered present (San Diego marsh-elder and white rabbit-tobacco) and the five additional special-status plant species determined to have a moderate to high potential to occur on the Project Site could be present in native habitats located in Zones 1 to 3. The Project shall completely avoid directly impacting special-status plants located in Zones 1 to 3 through implementation of MM BIO-1: Pre-Construction Survey and Special-Status Plant Species Avoidance, as described in Section 6, Mitigation Measures. As such, direct impacts to special-status plant species would be less than significant with mitigation.
Indirect impacts could occur to special-status plants through decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. These indirect impacts would be avoided through implementation of MM BIO-1: Pre-Construction Survey and Special-Status Plant Species Avoidance, MM BIO-2: Standard Best Management Practices (BMPs), and MM BIO-3: Biological Monitor as described in Section 6.
As such, indirect impacts to special-status plant species would be less than significant with mitigation.
5.1.1.2 Special-Status Wildlife
There are 25 special-status wildlife species that are known to occur within the Project Site or have a moderate to high potential to occur within the native portions of the Project Site, in both uplands (coastal sage scrub) and wetland/riparian habitats (southern arroyo willow riparian forest, southern cottonwood–willow riparian forest, mulefat scrub, southern willow scrub, emergent wetland, freshwater marsh, disturbed wetland) (Table 4). Impacts to individuals would be unlikely during Project implementation due to the mobility of these species to move out of harm’s way. However, the Project would implement MM BIO-3: Biological Monitor to ensure no special-status species would be injured or harmed during Project activities.
Suitable riparian nesting habitat for least Bell’s vireo, yellow-breasted chat, and yellow warbler is present in Zones 1 and 2 of the Project Site (Figures 7A, 7C, 7D, and 7E). Treatment activities occurring within riparian habitat are not anticipated to result in removal of habitat for these special-status species. However, it is possible that unanticipated impacts (e.g., sensitive vegetation removal) to riparian habitat could occur, which would be considered significant and require mitigation. The Project would implement MM BIO-4: Sensitive Vegetation Communities to mitigate for any unanticipated impacts to riparian habitat within Zones 1 and 2 in accordance with the mitigation ratios in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). Additionally, the Project would implement MM BIO-5: Avoidance of Listed Species Take: Least Bell’s Vireo to ensure all Project activities occur outside the least Bell’s vireo breeding season (March 15 through September 15). No impacts to native riparian habitat are anticipated within Zone 3, which would only result in the dead/dying and invasive species removal, and all Project activities would occur outside the least Bell’s vireo breeding season. If any unintended impacts occur to riparian habitat within Zone 3, then MM BIO-4 would be implemented.
Although a very limited amount is proposed, thinning of approximately 3 acres of non-contiguous areas (i.e., thinning would occur in unconnected slivers across many polygons throughout the Project Site) of coastal sage scrub has the potential to adversely impact coastal California gnatcatchers known to nest within that vegetation community.
Treatment activities occurring within coastal sage scrub are not anticipated to result in the removal of suitable habitat for coastal California gnatcatcher. However, if Project activities result in unintended impacts to coastal sage scrub, then these impacts would be considered significant and require mitigation. Impacts to coastal sage scrub habitat and coastal California gnatcatcher individuals would be considered significant. Therefore, implementation TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 36
JULY 2026
of MM BIO-4: Sensitive Vegetation Communities, would require mitigation for any unintended impacts to coastal sage scrub habitat within Zones 1 and 2 in accordance with the mitigation ratios in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). Implementation of MM BIO-6: Avoidance of Listed Species Take: Coastal California Gnatcatcher would ensure all Project activities occur outside the coastal California gnatcatcher breeding season (March 1 to August 15). No impacts to coastal sage scrub habitat are anticipated within Zone 3, which would only result in the dead/dying and invasive species removal, and all Project activities would occur outside the coastal California gnatcatcher breeding season. If any unintended impacts occur within Zone 3, then MM BIO-4 would be implemented.
Although no evidence of roost or nursery sites was identified on the Project Site during the biological reconnaissance field surveys, impacts to maternity bat roosts would be significant. The Project would avoid the native bat breeding season (i.e., April 1 through August 31), as it overlaps the nesting bird season as required by MM BIO-7: Nesting Bird Survey. Additionally, implementation of MM BIO-3: Biological Monitor would ensure no special-status bat species or native bat colonies or maternity roosts would be injured or harmed during Project activities through establishment of a buffer if these resources are observed.
The Project Site supports multiple wetland and upland habitats that contain suitable vegetation for nesting and migratory birds and raptors protected by the Migratory Bird Treaty Act and Section 3500 of the California Fish and Game Code. The Project is expected to remove invasive and hazardous trees only, which have a low potential to support nesting birds compared to the high-quality surrounding native wetland and upland habitats along the San Diego River in the Project Site. All nesting bird habitat removal or thinning shall occur outside the nesting bird breeding season (February 15 through September 30), as directed by MM BIO-7: Nesting Bird Survey.
Implementation of MM BIO-3: Biological Monitor shall also reduce potentially adverse impacts to nesting birds to a less-than-significant level by requiring a biological monitor be present to establish nest buffers if Project activities cannot avoid the avian nesting season. With implementation of these measures, potentially significant impacts to nesting and migratory birds would be reduced to less than significant.
Crotch’s bumble bee (Bombus crotchii) could occur within areas of the Project Site containing upland habitats, and impacts to this species would be considered significant. Treatment activities occurring within upland habitats are not anticipated to result in the removal of suitable habitat for Crotch’s bumble bee. However, if Project activities result in unintended impacts to upland habitats, then these impacts would be considered significant and require mitigation. Therefore, implementation of MM BIO-4 would require mitigation for impacts to sensitive upland communities within Zones 1 and 2 in accordance with the mitigation ratios in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). Implementation of MM BIO-8: Avoidance of Listed Species Take: Crotch’s Bumble Bee would require a pre-construction survey within Zones 1, 2, and 3 to ensure avoidance of impacts to individuals. No impacts to sensitive upland habitats are anticipated within Zone 3, which would only result in the dead/dying and invasive species removal, and ground disturbance activities that could impact Crotch’s bumble bee nests are not anticipated in Zones 1, 2, or 3. If any unintended impacts occur within Zone 3, then MM BIO-4 would be implemented.
There is potential for Project activities to have indirect impacts to special-status wildlife, including nesting birds, from decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. These indirect impacts would be avoided through implementation of MM BIO-2: Standard Best Management Practices (BMPs) and MM BIO-3: Biological Monitor, as described in Section 6. As such, indirect impacts to special-status wildlife species would be less than significant.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 37
JULY 2026
5.1.2 Threshold BIO-2: Riparian and Sensitive Vegetation Communities A total of approximately 31.68 acres of the Project Site shall be treated within Zones 1 and 2. Figures 10A through 10E depict the spatial distribution of the three treatment zones with the biological resources observed on the Project Site. Table 6A, Vegetation Communities and Land Cover Types in Zones 1 and 2, details the vegetation communities within Zone 1 and Zone 2 that encompass the direct treatment footprint.
A total of 18.02 acres of sensitive vegetation communities would be treated within Zones 1 and 2, including 2.88 acres of sensitive vegetation communities within Zone 1 and 15.14 acres of sensitive vegetation communities within Zone 2. Although vegetation management within Zones 1 and 2 would include activities such as shrub trimming and grass mowing, all trimming activities would be done to industry standards (ISA, ANSI) to minimize likelihood of plant death. Vegetation management in Zones 1 and 2 is not expected to result in removal of any sensitive vegetation communities. However, if Project activities result in unintended impacts to sensitive vegetation communities, then these impacts would be considered significant and would require mitigation.
Therefore, implementation of MM BIO-4: Sensitive Vegetation Communities would require mitigation for any unintended impacts to sensitive vegetation communities in accordance with the mitigation ratios in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025). A biological monitor shall be present in accordance with MM BIO-3: Biological Monitor to ensure treatment and vegetation removal activities occur only within the designated areas.
Table 6A. Vegetation Communities and Land Cover Types in Zones 1 and 2 Vegetation Community/Land Cover Type1 Project Site (Acres) Sensitive (Y/N)2 Zone 1
Native Vegetation Communities
Coast Live Oak Woodland 0.07 Y
Mulefat Scrub 0.02 Y
Southern Arroyo Willow Riparian Forest 0.01 Y
Southern Cottonwood–Willow (Populus spp.–Salix spp.) Riparian Forest
2.13 Y
Southern Riparian Scrub 0.02 Y
Southern Willow (Salix spp.) Scrub 0.14 Y
Diegan Coastal Sage Scrub (Including Baccharis-Dominated Subform)
0.50 Y
Native Vegetation Communities Subtotal 2.89 N/A
Non-Native Vegetation Communities and Land Cover Types
Eucalyptus Woodland 0.01 N
Non-Native Woodland 0.02 N
Disturbed Habitat 5.18 N
Urban/Developed1 1.06 N
Non-native Vegetation Communities Subtotal 6.27 N/A
Zone 1 Subtotal 9.15 N/A
Zone 2
Native Vegetation Communities
Coast and Valley Freshwater Marsh 0.14 Y
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 38
JULY 2026
Table 6A. Vegetation Communities and Land Cover Types in Zones 1 and 2 Vegetation Community/Land Cover Type1 Project Site (Acres) Sensitive (Y/N)2 Open Water 0.24 Y
Mulefat Scrub 0.13 Y
Southern Arroyo Willow Riparian Forest 0.13 Y
Southern Cottonwood–Willow Riparian Forest 8.78 Y
Southern Riparian Scrub 0.76 Y
Southern Willow Scrub 1.75 Y
Diegan Coastal Sage Scrub (Including Baccharis-Dominated Subform) 2.60 Y Coast Live Oak Woodland 0.61 Y
Native Vegetation Communities Subtotal 15.14 N/A
Non-Native Vegetation Communities and Land Cover Types
Eucalyptus Woodland 0.34 N
Non-Native Woodland 0.04 N
Disturbed Habitat 6.11 N
Urban/Developed1 0.90 N
Non-Native Vegetation Communities Subtotal 7.39 N/A
Zone 2 Total 22.53 N/A
Total 31.68 N/A
Notes: N/A = not applicable. Totals may not sum due to rounding. 1 Fuel treatment in Urban/Developed land consists of any ornamental plantings, maintained grass, or other landscaping. 2 Vegetation community considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
Vegetation management activities occurring in Zone 3 would only involve removal of dead, dying, or invasive species, and as such, no direct impacts to sensitive vegetation communities are anticipated in Zone 3 from Project implementation. However, if any unintended impacts occur to sensitive vegetation communities within Zone 3, then MM BIO-4 would be implemented to reduce those impacts to less than significant. A biological monitor shall be present in accordance with MM BIO-3: Biological Monitor to ensure vegetation management activities occur only for dead, dying, and invasive species. A total of 1,379 trees (or approximately 29.0 acres) are estimated for removal within Zone 3 as shown on Figures 10A through 10E. It should be noted that the data collected during field assessments is only a preliminary mapping of the potential areas slated for treatment within Zone 3. The Project would implement MM BIO-9: Tree Survey to provide comprehensive mapping, by a Certified Arborist, of the dead, dying, and invasive species that would be removed under the proposed Project. The plant species identified during field assessments for the FTP (City of Santee 2026) presented in Table 6B are located in Zone 3 and are proposed for treatment.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 39
JULY 2026
Table 6B. Plant Species Identified for Treatment or Removal in Zone 3 Non-Tree Species Tree Species Tree Species Continued
Arrowweed
Arundo donax
Bamboo
Blackberry
Bougainvillea
California sagebrush
Cape honeysuckle
Castor bean
Desert broom
Pampas grass
Prickly Russian thistle
Smilo grass
Tobacco tree
Toyon
Yucca
Aleppo pine
American sweetgum
Arizona cypress
Arroyo willow
Shamel ash
Bottlebrush (spp.)
Brazilian pepper
California fan palm
Canary island date palm
Canary island pine
Carob
Carrotwood
Chinese elm
Chinese flame tree
Coast live oak
Date palm (spp.)
Eucalyptus (spp.)
Fan palm (spp.)
Fig (spp.)
Glossy privet
Golden raintree
Italian stone pine
Laurel sumac
Mexican fan palm
Monterey pine
Olive (spp.)
Paloverde (spp.)
Pepper tree (spp.)
Pine (spp.)
Red willow
Siberian elm
Silk oak
Tree of heaven
Weeping bottlebrush
Yellowwood (spp.)
Willow (spp.)
Notes: All native tree or non-tree species listed in the table would only be removed if the individual was dead or dying.
Indirect impacts could occur to sensitive vegetation communities in Zones 1 to 3 through decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. These indirect impacts would be avoided through implementation of MM BIO-2: Standard Best Management Practices (BMPs) and MM BIO-3: Biological Monitor, as described in Section 6. As such, indirect impacts to sensitive vegetation communities would be less than significant.
5.1.3 Threshold BIO-3: Jurisdictional Waters
Table 7, Potentially Jurisdictional Aquatic Resources in Zones 1 and 2, summarizes the treatment footprint containing potentially jurisdictional aquatic resources acreages in Zones 1 and 2 on the Project Site. A total of
14.98 acres of potentially jurisdictional aquatic resources would be treated within the Project Site as result of native and non-native brush thinning located up to 100 feet from the edge of the existing development areas. The ultimate decisions on the amount and location of jurisdictional aquatic resources would be made by the resource agencies (i.e., USACE, CDFW, and RWQCB).
Table 7. Potentially Jurisdictional Aquatic Resources in Zones 1 and 2 Impact Zone
Non-Wetland Water/
Streambed Acreage
Wetland/Riparian
Habitat Acreage Total Acreage
Zone 1 0.03 2.37 2.40
Zone 2 0.68 11.90 12.58
Total 0.71 14.27 14.98
Note: Vegetation management activities occurring in Zone 3 would only involve removal of dead, dying, or invasive species, and as such, no direct impacts to potentially jurisdictional resources in Zone 3 are anticipated from Project implementation.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 40
JULY 2026
Treatment activities to jurisdictional aquatic resources occurring within Zones 1 and 2 would require regulatory resources permitting from the appropriate resource agencies (USACE, RWQCB, and CDFW) (MM BIO-10:
Jurisdictional Aquatic Resources Permitting). A biological monitor shall be present in accordance with MM BIO-3:
Biological Monitor to ensure treatment and vegetation removal activities occur in accordance with the Project’s aquatic resource permits and there are no direct impacts occurring outside the designated areas. As such, direct impacts to jurisdictional aquatic resources within Zones 1 and 2 would be less than significant. MM BIO-11:
Jurisdictional Aquatic Resources Avoidance would be implemented to further avoid impacting streams by using temporary rubber mats or pads to distribute weight and minimize vegetation trampling and soil disturbance, and helicopter and/or crane removal where equipment access is constrained and hand carry is infeasible. Treatment activities occurring within Zones 1 and 2 are not anticipated to result in the removal or filling of any jurisdictional aquatic resources. However, if Project activities result in any unintended impacts to jurisdictional aquatic resources, then these impacts would be considered significant and require mitigation. Therefore, implementation of MM BIO4 would require mitigation for any unintended impacts to jurisdictional aquatic resources within Zones 1 and 2 in accordance with the mitigation ratios in Table 5-13 of the Draft Santee MSCP Subarea Plan (City of Santee 2025).
Vegetation management activities occurring in Zone 3 would only involve removal of dead, dying, or invasive species, and as such, no direct impacts from removal or filling of potentially jurisdictional resources in Zone 3 are anticipated from Project implementation. If any unintended impacts occur to riparian habitat within Zone 3, then MM BIO-4 would be implemented. MM BIO-11: Jurisdictional Aquatic Resources Avoidance would be implemented to ensure activities occurring in Zone 3 would only involve treatment or removal of dead, dying, or invasive species.
As directed by MM BIO-11, the Project is committed to avoiding impacts to streams by using temporary rubber mats or pads to distribute weight and minimize vegetation trampling and soil disturbance, and helicopter and/or crane removal where equipment access is constrained and hand carry is infeasible. A biological monitor shall be present in accordance with MM BIO-3: Biological Monitor to ensure treatment and vegetation removal activities do not impact any aquatic resource areas located within Zone 3. As such, direct impacts to jurisdictional aquatic resources within Zone 3 would be avoided.
Indirect impacts could occur to jurisdictional aquatic resources through decreased water quality and altered hydrology, soil compaction, elevated dust levels, and the spread of invasive plant species. These indirect impacts would be avoided through implementation of MM BIO-2: Standard Best Management Practices (BMPs) and MM BIO-3: Biological Monitor, as described in Section 6. As such, indirect impacts to jurisdictional aquatic resources would be less than significant.
5.1.4 Threshold BIO-4: Wildlife Corridors/Nursery Sites The western portion of the San Diego River in the Project Site from Forester Creek up to Mast Park and the eastern portion of the Project Site are mapped as a wildlife corridors and linkage areas, as shown on Figure 9. The western portion of the site is mapped a critical habitat for the least Bell’s vireo (Figure 7A). The purpose of the Project is fuel hazard management that shall not modify the width of the San Diego River, its tributary (Forester Creek), or its land use as Open Space. Additionally, tree removal and native and non-native brush thinning would improve fuel hazard risk within the San Diego River Corridor, reducing forest fires that adversely impact the San Diego River’s function as a wildlife corridor due to habitat and species loss. Removal of non-native vegetation would improve the overall quality of the San Diego River as a wildlife corridor by reducing competition for resources from invasives that are usable for native wildlife species. Native and non-native brush thinning is not expected to adversely impact nursery sites or wildlife corridors through avoidance of the nesting bird season, and the loss of habitat is marginal compared TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 41
JULY 2026
to the net benefit of hazardous fuel reduction for fire management within the San Diego River Corridor. As a result, implementation of the Project would result in less-than-significant impacts to wildlife corridors and nursery sites.
5.1.5 Threshold BIO-5: Local Policies and Ordinances
No conflicts with local policies and ordinances are anticipated from Project implementation. The Project would comply with Section 8.06 of the Santee Municipal Code and biological resources policies within the Conservation Element as no development is proposed, and the Project is intended to improve the San Diego River and Forester Creek through fuel reduction of mostly non-native trees and trees that are dead or decaying. Therefore, the Project is consistent with respect to the relevant City of Santee biological, floodway, and urban forestry municipal codes and the goals outlined in the City of Santee General Plan Conservation Element. The Project would comply with the City of Santee’s municipal code and the biological resources policies outlined within the City of Santee General Plan Conservation Element. Furthermore, City of Santee staff shall review the Project to ensure there are no conflicts with the objectives and policies presented in the Conservation Element of the Santee General Plan and relevant urban forestry, floodway, and biological resources ordinances (City of Santee 2003, 2023).
5.1.6 Threshold BIO-6: Habitat Conservation Plans
Although the Draft Santee MSCP Subarea Plan has not yet been approved or permitted, it is used as the guidance document for projects occurring within the City of Santee. As such, BMPs included in Section 5.5 of the Subarea Plan have been incorporated into the Project-specific mitigation measures below.
The majority of Zones 1 and 2 overlap defensible space areas identified within the San Diego River Subunit as shown on Figure 4-5 of the City of Santee Draft MSCP Subarea Plan, and Zone 3 is identified as a fuel hazard reduction area (City of Santee 2025). Because this is a fuel hazard reduction project (as opposed to a development project) that is designed to target removal of non-native vegetation and treatment of native vegetation within the San Diego River Corridor wildland–urban interface, no permanent removal of habitat is anticipated. Any trimming of native vegetation shall occur only following acquisition of required permits. Project implementation would not conflict with the provisions of the San Diego County MSCP or Draft Santee MSCP Subarea Plan, nor would it prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in San Diego County.
6 Mitigation Measures
The following mitigation measures shall be implemented to avoid and reduce potentially significant impacts to sensitive and riparian vegetation communities, special-status species, and potentially jurisdictional aquatic resources to a less-than-significant level. Any trimming of native vegetation shall occur only following acquisition of required permits.
MM BIO-1 Pre-Construction Survey and Special-Status Plant Species Avoidance. No vegetation management activities occurring in Zone 3 or other native and non-native brush thinning occurring in Zones 1 and 2 shall occur within known populations of San Diego marsh-elder and white rabbit-tobacco or any other special-status plant species. Prior to initiation of Project activities, a qualified biologist (i.e., a person having at minimum a BS or BA in wildlife TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 42
JULY 2026
management, ecology, zoology, botany, biology, or other closely related field, and at least 2 years’ experience conducting field investigations in San Diego County) approved by the City of Santee shall conduct a pre-construction presence/absence survey for special-status plants within the impact footprint and flag any special-status plants, including the known locations of San Diego marsh-elder and white rabbit-tobacco. If surveys are conducted pursuant to the FEMA Programmatic Biological Opinion for federally listed plant species, the qualified biologist shall be approved by the Carlsbad Fish and Wildlife Office (CFWO) in accordance with Gen AMM
16. If a special-status plant is observed, the biological monitor shall delineate an appropriate buffer zone (a minimum of 10 feet) depending on the sensitivity of the resource and the nature of the activity being conducted. Project activities shall completely avoid impacts to any specialstatus plant species.
MM BIO-2 Standard Best Management Practices (BMPs). The following BMPs, when applicable, shall be included as part of the Project in accordance with Section 5.5.1.1 of the Draft Santee Multiple Species Conservation Program Subarea Plan (City of Santee 2025). The City of Santee shall have the right to access and inspect any treatment sites for compliance with Project approval conditions including these BMPs.
Delineation of Environmentally Sensitive Areas
▪ Prior to Project implementation, highly visible barriers (such as orange construction fencing, stakes, or flagging depending on the size of the treatment area and the sensitivity and proximity of the biological resources) shall be installed to designate environmentally sensitive areas (e.g., special-status plant locations, nesting birds, etc.) to be protected from vegetation management related activities. Environmentally sensitive areas to be avoided shall be identified during the pre-construction surveys described in MM BIO-1 and MM BIO-3 and implemented by a qualified biologist approved by the City of Santee. No Project activity of any type shall be permitted within these environmentally sensitive areas (with exceptions for removal of dead/decaying and non-native species within jurisdictional aquatic resource areas in Zone 3). In addition, heavy equipment, including motor vehicles, shall not be allowed to operate within the environmentally sensitive areas. All vegetation management equipment shall be operated in a manner so as to prevent accidental damage to environmentally sensitive areas and associated barriers. No structure of any kind, equipment staging, incidental storage of equipment or supplies, or access roads shall be allowed within these protected zones. Silt fence barriers shall be installed, as appropriate, at the environmentally sensitive area boundary to prevent accidental deposition of fill material or sediment runoff into areas where sensitive biological features are adjacent to treatment areas. Flagging and/or fencing shall be removed upon completion of the activities.
Invasive Species Control
▪ Invasive exotic plant species shall be removed from the Project work area and controlled during vegetation management periods. Project measures shall be included to ensure invasive plant material is not spread from the Project Site to other areas by disposal off site or by tracking seed on equipment, clothing, and shoes. Equipment/material imported from an area of TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 43
JULY 2026
invasive plants must be identified and measures implemented to prevent importation and spreading of non-native plant material within the Project Site. Disposal of the plant debris shall follow the regulations set by the County of San Diego agriculture commissioner. All vegetation management equipment shall be cleaned to remove dirt, seeds, vegetative material, or other debris that could contain or hold seeds of noxious weeds before arriving to and leaving from the Project Site. Eradication strategies (i.e., exotic plant abatement programs) shall be employed should an invasion occur during vegetation management activities.
Trash Control
▪ To avoid attracting predators of Covered Species and other special-status species, the Project Site shall be kept clean of debris. All food-related trash items shall be enclosed in sealed containers and regularly removed from the site(s) daily.
On-Site Training and Monitoring
▪ All personnel involved in the on-site Project activities shall be required to participate in a preactivity training and education program administered by the City, or their designee, to understand the avoidance and minimization obligations of the Project. ▪ The City shall require that a qualified biologist monitor Project activities for the duration of the Project to ensure that measures are being employed to avoid incidental disturbance of habitat, species of concern, and other sensitive biological resources. The biological monitor shall notify the City immediately of any non-compliance, and the City shall make an assessment that generates appropriate measures for the contractor to implement for remediation.
Water Quality Best Management Practices
▪ The vegetation treatment contractors shall implement BMPs to protect water quality. To minimize soil disturbance, the vegetation treatment contractors shall leave stumps from removed trees and shrubs intact, with stump heights not exceeding 6 inches, as measured from the uphill side as described in the Fuels Treatment Plan (City of Santee 2026). ▪ Actions to prevent sediment or debris from entering watercourses, aquatic areas, wetlands, and riparian areas during and after Project activities may include, but are not limited to, the following BMPs: silt fencing, fiber rolls and other erosion control blankets, gravel bag berms, sand bag barriers, tracking controls, stockpile management, dry season scheduling, preservation of existing vegetation, temporary soil stabilization, and dust and erosion control. ▪ No site personnel shall dsicharge solid or liquid materials into jurisdictional water features, wetland or riparian areas, or other sensitive habitats. Service and refueling of equipment shall only occur in areas that will not allow grease, oil, fuel, or other hazardous materials to pass into streams or retained vegetation. If discharged materials are observed during work activities, the biological monitor shall notify the City and appropriate entities immediately, including but not limited to applicable jurisdictional City or County, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and/or Regional Water Quality Control TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 44
JULY 2026
Board, and the City shall make an assessment that generates appropriate measures for the contractor to implement for remediation. Spills shall be cleaned up immediately and contaminated soils removed to approved disposal areas.
MM BIO-3 Biological Monitor. A qualified biological monitor (i.e., a person having at minimum a BS or BA in wildlife management, ecology, zoology, botany, biology, or other closely related field, and at least 2 years’ experience conducting field investigations in San Diego County) approved by the City of Santee shall be present to conduct a pre-activity sweep (i.e., pre-construction survey) of the work area prior to the commencement of work activities. Where monitoring is required pursuant to the FEMA Programmatic Biological Opinion for federally listed species, monitoring shall be conducted by or under the supervision of a CFWO-approved biologist in accordance with Gen AMM 16. The qualified monitor shall remain present during any Project activities in Zones 1 to 3 that occur in sensitive vegetation communities, as defined herein, to ensure no sensitive biological resources (i.e., sensitive vegetation communities, special-status species, and jurisdictional aquatic resources) are being adversely impacted from Project implementation in Zone 3 and that no special-status species or nesting birds are being adversely impacted from Project implementation in Zones 1 and 2. If a sensitive biological resource is observed during Project activities or during pre-construction surveys, the biological monitor shall delineate an appropriate buffer zone (a minimum of 10 feet) depending on the sensitivity of the resource and the nature of the activity being conducted.
If fencing for temporary noise abatement (i.e., 8-foot-tall [minimum height] plywood sheet barriers or acoustical blankets suspended on chain-link fencing or other support means) is required along or parallel with an extent of the Project boundary that adjoins the receiving noise-sensitive property then prior to the use of temporary noise abatement, a qualified biologist shall confirm and verify with the City that the placement of the barriers are not located within any environmentally sensitive areas (e.g., special-status plant locations, sensitive vegetation communities, or jurisdictional aquatic resources) and would not impact any wildlife species or their movement.
MM BIO-4 Sensitive Vegetation Communities. Unintended impacts (i.e. sensitive vegetation removal) to sensitive natural communities occurring from thinning or trimming activities in Zones 1 and 2 would be remedied through restoration of the affected area. This would entail restoring the disturbed area to pre-project or ecologically improved conditions typically within one year of completing activities. A restoration plan will be prepared for and approved by the City, and depending on the area affected any other appropriate regulatory agency (i.e. USFWS, CDFW, USACE, and/or RWQCB), that includes: details for the restoration activities, a description of how the proposal provides offsets for the temporal loss, success criteria and the timeline for restoration. If habitat is unable to be restored, or the restoration does not meet the success criteria, the impacts would be considered permanent and would require mitigation consistent with the ratios identified in Table 1 below. This mitigation would entail a mitigation plan outlining the enhancement or restoration of habitat within City Owned Preserve Lands or through acquisition of a conservation easement within the Upland Standards Areas or San Diego River Subunit depending on the type of habitat being impacted so that impacts will be mitigated inkind. The mitigation plan shall include at a minimum: details for the mitigation activities including the target function and services for the native plant communities established, mitigation work TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 45
JULY 2026
plan, performance standards, funding mechanism, and the timeline for completion of the mitigation program. The mitigation site would be included in the Managed Preserve and managed and monitored in perpetuity with funding for long-term management and monitoring provided through a non-wasting endowment.
Mitigation Ratios for Permanent Unintended Impacts
Vegetation Type a Habitat Criteria Mitigation Ratio
Riparian
Forest/Woodland
All riparian forest, including oak riparian 3:1
Riparian Scrub Drainages with riparian scrub 3:1
Freshwater Marsh,
Freshwater Seep,
Disturbed Wetlands,
Natural Channel, Open
Water e
Absence of native species or small (<0.25 acre)
amount of habitat
2:1 f
Presence of native species or large (>0.25 acre)
amount of habitat
3:1
Vernal Pools b Natural Vernal Pool 4:1
Man-made vernal pools with indicator plant species 3:1
Man-made pools with covered wildlife species 3:1
Oak Woodland Oak woodland containing any Engelmann oaks 3:1 Individual Oaks Trees with at least on trunk of 6” or more Dbh c or multi-trunked native oaks with aggregate diameter of
10” of more.
10:1 by tree
Coastal Sage Scrub
Coastal
Sage/Chaparral Scrub
Habitat small, isolated patches <1 acres 2:1
Habitat patches >1 acre 3:1
Chaparral All 2:1
Native Grassland All 3:1
Non-native grassland All 1:1
Disturbed lands,
Eucalyptus, agricultural
lands d
No known habitat value for Covered Species None
Habitat value for or presence of burrowing owls 1:1 as appropriate to ensure like value
Notes:
a Vegetation types based on the Holland Vegetation classification system. See Appendix E, Vegetation Communities Descriptions.
All other natural habitat types not listed in this table have a 1:1 mitigation ratio requirement. b Vernal pool mitigation must meet a ‘no net loss’ criteria through creation of new vernal pool habitat and/or restoration or enhancement of existing vernal pool habitat. Preservation of existing vernal pool alone does not provide mitigation credits. If an existing vernal pool is significantly disturbed, enhancement of the existing pool can be implemented to provide up to a 1:1 mitigation credits towards the total requirement.
c Dbh = Diameter at Breast Height. Tree diameter is measured at 4 ½ feet above ground level. This measure is known as diameter at breast height or DBH. Diameter can be measured with diameter tape d Disturbed land may include agricultural lands, ruderal, eucalyptus, and previously authorized graded areas. e Any impacts to open water areas within abandoned sand mining pits along the San Diego River should be mitigated with creation of riparian scrub or riparian woodland, as these open water areas are unnatural, are relatively common, and these same areas likely supported riparian areas before mining occurred. f Different ratios may be required under separate regulatory programs under the Clean Water Act, the Porter-Cologne Water Quality Control Act, and Section 1600 et seq. of the Fish and Game Code.
MM BIO-5 Avoidance of Listed Species Take: Least Bell’s Vireo. All riparian habitat tree trimming or thinning within Zones 1 and 2 and invasive species removal in Zone 3 shall occur outside the least TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 46
JULY 2026
Bell’s vireo breeding season (April 1 through August 153). If that is not possible then no vegetation management activities shall occur during the least Bell’s vireo breeding season until the following requirements have been met:
1. A qualified biologist shall conduct a focused pre-construction-level survey for least Bell’s vireo using the most recent protocol within all fuel reduction areas containing suitable riparian habitat including a 500-foot buffer. A minimum of three surveys shall be performed 3 days prior to Project activities.
If presence of least Bell’s vireo is determined or assumed to occur on the Project Site, the following measures shall be required to be implemented:
a. No vegetation removal shall occur within occupied habitat during the least Bell’s vireo breeding season (April 1 to August 15) or until the nest has shown to be vacated. A 500- foot buffer shall be required around the nest site. If 100% avoidance of occupied habitat is not feasible, consultation with USFWS and California Department of Fish and Wildlife (CDFW) shall be initiated prior to implementation of any activities that may impact occupied habitat, directly or indirectly.
MM BIO-6 Avoidance of Listed Species Take: Coastal California Gnatcatcher. To the maximum extent feasible, staging areas, equipment storage areas, and access routes shall be located outside coastal sage scrub, alluvial fan scrub, and other suitable coastal California gnatcatcher habitat and shall utilize existing disturbed areas and roads whenever practicable.
All coastal sage scrub thinning shall occur outside the coastal California gnatcatcher breeding season (March 15 through August 15). If that is not possible then no vegetation management activities shall occur during the coastal California gnatcatcher breeding season (February 15 through August 15) until the following requirements have been met:
1. A permitted biologist (i.e., possessing a valid Endangered Species Act Section 10(a)(1)(a) Recovery Permit) shall conduct a focused protocol-level survey (i.e., three visit survey) for coastal California gnatcatcher (Polioptila californica californica) using the most recent protocol (U.S. Fish and Wildlife Service [USFWS] 1997 Coastal California Gnatcatcher Presence/ Absence Survey Guidelines) 3 days prior to Project activities within all fuel reduction areas containing coastal sage scrub including a 500-foot buffer. If presence of coastal California gnatcatcher is determined or assumed to occur on the Project Site, the following measures shall be required to be implemented by the applicant:
a. No vegetation removal or thinning shall occur within occupied habitat during the coastal California gnatcatcher breeding season (February 15 to August 15). A minimum 500-foot buffer shall be established around occupied nests unless a larger buffer is determined necessary by the permitted biologist based on species behavior, topography, existing disturbance conditions, or other site-specific factors. b. The A 500-foot buffer shall be required around the nest site until it is shown to be vacated.
If 100% avoidance of occupied habitat is not feasible, consultation with USFWS and 3 Unitt and Klovstad (2004) states that the nesting season generally lasts from April to July and dates for fledglings ranged between 27 April to 21 August.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 47
JULY 2026
California Department of Fish and Wildlife (CDFW) shall be initiated prior to implementation of any activities that may impact occupied habitat, directly or indirectly. c. Other measures from FWS-CFWO-16B0293-18F1358; Section 7 Consultation on FEMA Disaster, Mitigation and Preparedness Programs in Imperial, Inyo, Kern, Los Angeles, Orange, Riverside, San Bernardino, and San Diego Counties, California Coastal California Gnatcatcher CAGN-1 through CAGN-4 will apply. CAGN-5 through CAGN-7 do not apply as this project is intended to enhance native habitat and species.
MM BIO-7 Nesting Bird Survey. All nesting bird habitat trimming or thinning shall occur outside the nesting bird breeding season (February 15 through September 30). If the Project requires that work be initiated during the breeding season for nesting birds, in order to avoid direct impacts on active nests, a pre-construction survey shall be conducted in the Project Site and within 500 feet of the Project Site containing suitable nesting resources, by qualified biologists for nesting birds and/or raptors within 3 days prior to Project activities. If the biologist does not find any active nests within or immediately adjacent to the impact areas (i.e., 500 feet), the vegetation clearing work shall be allowed to proceed. If the biologist finds an active nest within or immediately adjacent to the work area and determines that the nest may be impacted or breeding activities substantially disrupted, the biologist shall delineate an appropriate buffer zone. A minimum buffer ranging from 50 feet for common or disturbance-tolerant species to 500 feet for raptors and special-status species. Larger buffers may be established by the qualified biologist based on species sensitivity, nesting stage, line-of-sight conditions, topography, ambient noise levels, observed behavioral responses, or the nature of the proposed activity. (typically 300 feet for passerines and 500 feet for raptors and special-status species) or appropriate noise mitigation around the nest depending on the sensitivity of the species and the nature of the activity. The nest area and buffer zone shall be avoided until the nest is vacated and the juveniles have fledged or the nest fails. Status of the nest shall be monitored by a qualified biologist. A report shall be submitted to the City of Santee and Wildlife Agencies (i.e., U.S. Fish and Wildlife Service and California Department of Fish and Wildlife) for review prior to discontinuing the noise limits and nest buffers. The nest buffer area shall be demarcated in the field with flagging and stakes or construction fencing. Personnel, including all contractors working on site, are required to be instructed on the sensitivity of the area. No Project activities shall encroach into established buffers without the consent of a monitoring biologist. The buffer shall remain in place until it is determined that the nestlings have fledged and the nest is no longer active. Work can proceed into the buffer when the qualified biologist has determined that the nest is no longer active or if appropriate noise mitigation is in place.
MM BIO-8 Avoidance of Listed Species Take: Crotch’s Bumblebee. A pre-construction survey shall be conducted by a qualified biologist with expertise in surveying for bumble bees no more than 5 days prior to any Project activities occurring within Zones 1, 2, or 3. If a Crotch’s bumble bee nest is detected during the pre-construction survey, the Project’s biological monitor shall establish, monitor, and maintain a no-work buffer around the nest. The size and configuration of the no-work buffer shall be based on best professional judgment of the Project biologist in consultation with the Wildlife Agencies. The buffer shall provide at least 50 feet of clearance around nest entrances. Project activities shall not occur within the no-work buffer until the colony is no longer active. To determine that a nest is no longer active, the nest shall be observed for a minimum of 60 minutes each day TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 48
JULY 2026
across a minimum of 3 days during suitable flight weather (i.e., ambient air temperature between 60 and 90 degrees F, winds under 10 mph, and no precipitation higher than a drizzling rain). If no bees are seen flying in or out of the nest by the end of the observation period, it shall be determined that the nest is no longer active. If Project activities occur outside of the colony active period (April 1– August 31), then pre-construction surveys for active bee nest colonies are not required.
If Crotch’s bumble bee is observed during the pre-construction survey, the Project’s biological monitor shall ensure the individual(s) are not impacted by Project activities through establishment of a no-work area. The biological monitor shall also review the immediate vicinity to ensure no nests are present.
MM BIO-9 Tree Survey. Prior to the commencement of vegetation management activities within Zones 1 to 3, a Certified Arborist shall be present to conduct a comprehensive tree inventory to determine the exact locations for dead, dying, and invasive species slated for removal. The comprehensive tree inventory may also occur concurrently with vegetation management activities so as not to interfere with Project timing. Trees shall be marked or flagged by the Certified Arborist for the contractor and the tree inventory and removal tracking shall be provided to the City of Santee.
MM BIO-10 Jurisdictional Aquatic Resources Permitting. The City of Santee shall obtain the applicable permits for treatment activities (i.e., trimming or thinning of native or non-native vegetation within Zones 1 and 2) occurring within jurisdictional aquatic resources, such as a Section 404 permit from USACE, a Streambed Alteration Agreement from CDFW, and a 401 Water Quality Certification/Waste Discharge Requirement from the RWQCB. No native or non-native vegetation trimming or thinning in Zones 1 and 2 shall occur within any jurisdictional riparian/wetland vegetation communities on the Project Site prior to issuance of aquatic resources permits.
MM BIO-11 Jurisdictional Aquatic Resources Avoidance. Vegetation management activities occurring within Zone 3 shall only involve treatment or removal of dead, dying, or invasive species. The Project shall commit to avoid impacting streams within Zones 1, 2, and 3 by crossing them using temporary rubber mats or pads to distribute weight and minimize vegetation trampling and soil disturbance, and helicopter and/or crane removal where equipment access is constrained and hand carry is infeasible.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 49
JULY 2026
7 Conclusion
The Project involves fuel reduction activities to remove hazardous, non-native, and invasive trees in the San Diego River Corridor wildlands-urban interface within the City of Santee, San Diego County, California. The fuel reduction activities shall focus on removing non-native, dead, or decaying vegetation as well as prescribed treatment zones, with native or non-native brush thinning restricted to upland defensible space areas after required permits are obtained.
The Project is consistent with the City of Santee Draft MSCP Subarea Plan. Potentially significant impacts to specialstatus species, sensitive or riparian vegetation communities, jurisdictional waters, nesting/migratory birds and wildlife corridors/nursery sites, local policies and ordinances, or regional habitat conservation plans from Project implementation are reduced to a less-than-significant level provided the specific features and mitigation measures described in this report are incorporated. Specific features and mitigation measures include seasonal restrictions, pre-construction surveys, and best management practices to ensure compliance with CEQA, the Migratory Bird Treaty Act, and other applicable regulations. The City of Santee would be responsible for any necessary local, state, or federal permits needed to conduct the proposed work.
Sincerely,
_________________________
Brock Ortega
Principal Biologist
cc: Kimberly Narel, Dudek
Danielle Mullen, Dudek
Att: Figures 1–10
A, Site Photographs
B, Species Compendium
C, Special-Status Plant Species with a Potential to Occur D, Special-Status Wildlife Species with a Potential to Occur TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 50
JULY 2026
8 References
AOS (American Ornithologists’ Society). 2025. AOU Checklist of North and Middle American Birds (Online).
American Ornithological Society. Accessed January 2026. http://checklist.americanornithology.org/taxa.
CCH (Consortium of California Herbaria). 2025. Consortium of California Herbaria CCH2 Portal. Map Search. https://cch2.org/portal/collections/map/index.php.
CDFW (California Department of Fish and Wildlife). 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. Accessed January 2026. https://www.cnps.org/wp-content/uploads/2019/10/Bot-Cert_2018-CDFW-Plant-and-Vegetation-SurveyProtocols-LR.pdf.
CDFW. 2025a. California Natural Diversity Database (CNDDB). Biogeographic Information and Observation System; Commercial Viewer. Biogeographic Data Branch. Version 6. Accessed January 2026. https://apps.wildlife.ca.gov/bios6.
CDFW. 2025b. California Natural Community List, February 27, 2025. Accessed January 2026. https://www.wildlife.ca.gov/Data/VegCAMP/Natural-Communities.
CDFW. 2025c. State and Federally Listed Endangered, Threatened, and Rare Plants of California, April 2025.
CNDDB. Biogeographic Data Branch. Accessed January 2026. https://nrm.dfg.ca.gov/FileHandler.ashx? DocumentID=109390&inline.
CDFW. 2025d. State & Federally Listed Endangered & Threatened Animals of California, CNDDB. Biogeographic Data Branch. October 2025. Accessed January 2026. https://nrm.dfg.ca.gov/FileHandler.ashx? DocumentID=109405.
CDFW. 2025e. California Wildlife Habitat Relationships Life History Accounts and Range Maps (online). Accessed January 2026. https://wildlife.ca.gov/Data/CWHR/Life-History-and-Range.
CDFW. 2025f. Special Animals List. October 2025. CNDDB. Biogeographic Data Branch. Accessed January 2026. https://www.wildlife.ca.gov/Conservation/SSC.
CDFW. 2025g. Fully Protected Animals. Accessed January 2026. https://wildlife.ca.gov/Conservation/ Fully-Protected.
CDFW. 2025h. RareFind. Version 5.3.0. Locational Query Tool (Commercial Subscription). Sacramento, California:
CDFW, Biogeographic Data Branch. Accessed January 2026. https://apps.wildlife.ca.gov/rarefind/view/ RareFind.aspx.
City of San Diego. 1998. Final MSCP Plan. Prepared by MSCP Policy Committee and MSCP Working Group.
San Diego, California: MSCP Policy Committee and MSCP Working Group. August 1998. Accessed January 2026. http://www.sandiegocounty.gov/content/dam/sdc/pds/mscp/docs/SCMSCP/ FinalMSCPProgramPlan.pdf.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 51
JULY 2026
City of Santee. 2003. City of Santee General Plan. Accessed January 2026. https://www.cityofsanteeca.gov/ departments/city-clerk/document-central/planning-building/general-plan.
City of Santee. 2020. Santee Municipal Code. Accessed January 2026. https://ecode360.com/ 43745546#43745546.
City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/
santee-mscp-subarea-draft-plan-and-draft-program-environmental-impact-report.
City of Santee. 2026. San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan. Prepared by Dudek.
April 2026.
CNPS (California Native Plant Society). 2001. “CNPS Botanical Survey Guidelines.” Accessed January 2026. https://www.cnps.org/wp-content/uploads/2018/03/cnps_survey_guidelines.pdf.
CNPS (California Native Plant Society). 2025. Inventory of Rare and Endangered Plants. Rare Plant Program (online edition, v9.5.1). Accessed January 2026. www.rareplants.cnps.org.
Crother, B.I. 2012. Scientific and Standard English Names of Amphibians and Reptiles of North America North of Mexico, with Comments Regarding Confidence in our Understanding, edited by J.J. Moriarty. 7th ed.
Society for the Study of Amphibians and Reptiles; Herpetological Circular, no. 39. August 2012.
Cypher, E. 2002. “General Rare Plant Survey Guidelines.” https://www.sandiegocounty.gov/content/dam/ sdc/pds/ceqa/JVR/AdminRecord/IncorporatedByReference/Appendices/Appendix-D---BiologicalResources-Report/Cypher%202002.pdf.
Garrett, K., and J. Dunn. 1981. “Yellow Warbler, Dendroica petechia.” In Birds of Southern California: Status and Distribution, 310–311. Los Angeles, California: Los Angeles Audubon Society.
Google Earth. 2025. Google Earth; desktop application; centered on the project site. https://www.google.com/earth/.
Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Game, Nongame-Heritage Program. October 1986.
Jepson Flora Project. 2025. “Jepson eFlora.” https://ucjeps.berkeley.edu/eflora/.
Moyle, P.B. 2002. Inland Fishes of California. Berkeley and Los Angeles, California: University of California Press.
NABA (North American Butterfly Association). 2018. “Checklist of North American Butterflies Occurring North of Mexico.” Adapted from North American Butterfly Association (NABA) Checklist & English Names of North American Butterflies, edited by B. Cassie, J. Glassberg, A. Swengel, and G. Tudor. 2nd ed. Morristown, New Jersey: NABA. Accessed May 2025. https://www.naba.org/pubs/enames2_4.html.
NETR (National Environmental Title Research LLC). 2025. Historical Aerials Viewer. NETR Online. https://www.historicaerials.com/viewer.
TO: DUSTIN DEMATTEO
SUBJECT: BIOLOGICAL RESOURCES LETTER REPORT FOR THE SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM
PROJECT, SANTEE, CALIFORNIA
18611 52
JULY 2026
Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California,” Robert F. Holland, Ph.D., October 1986.
SanGIS. 2025. Parcel Lookup Tool and Geographic Boundary Viewer. Accessed January 2026. https://geo.sandag.org/portal/apps/experiencebuilder/experience/?id= 1d105857933641e0a8496d2769b31aec.
Unitt, P., and A.E. Klovstad. 2004. San Diego County Bird Atlas (Vol. 39). San Diego Natural History Museum.
USDA (U.S. Department of Agriculture). 2025a. Natural Resources Conservation Service. Web Soil Survey. Custom Soil Resource Report. Survey. Accessed January 2026. https://websoilsurvey.sc.egov.usda.gov/ App/HomePage.htm.
USDA. 2025b. “California.” Natural Resources Conservation Service State PLANTS Checklist. http://plants.usda.gov/dl_state.html.
USFWS (U.S. Fish and Wildlife Service). 2025a. Surface Waters and Wetlands Mapper. Accessed January 2026. https://www.fws.gov/wetlands/data/mapper.html.
USFWS. 2025b. Critical Habitat for Threatened and Endangered Species. Map Viewer. Accessed January 2026. https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe09893cf75b8dbfb77.
USGS (U.S. Geologic Survey). 2021, 2023. El Cajon and La Mesa California Quadrangles [maps]. 1:24,000. 7.5-minute Series. Washington D.C.
USGS. 2025. National Hydrography and Watershed Boundary Dataset. USGS National Hydrography Products.
Accessed January 2026. https://www.usgs.gov/core-science-systems/ngp/national-hydrography/ watershed-boundary-dataset?qt-science_support_page_related_con=4#qt-science_support_ page_related_con.
Wilson, D.E., and D.M. Reeder, eds. 2005. Mammal Species of the World: A Taxonomic and Geographic Reference. 3rd ed. Baltimore, Maryland: Johns Hopkins University Press. http://www.bucknell.edu/msw3/.
Project Boundary
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 1 Project Location Layout: Figure 1 Project Location 0 1,000 2,000
n
Feet
Temecula
Murrieta
Chula
Vista
Solana
Beach Encinitas
San
Diego
Carlsbad
Oceanside
La Mesa El Cajon
Santee
Poway
San
Marcos
Escondido
Vista
Imperial
Beach
Del Mar
Coronado
ÄÆ905
ÄÆ54
ÄÆ52
ÄÆ94
ÄÆ163
ÄÆ195
ÄÆ125
ÄÆ274
ÄÆ56
ÄÆ74
ÄÆ86
ÄÆ78
ÄÆ67
ÄÆ76 ÄÆ79
§¨¦805
§¨¦15
§¨¦8
S a n D i e g o
C o u n t y
Project Site
SOURCE: USGS 7.5-Minute Series La Mesa and El Cajon Quadrangles San Diego River Fire Hazard Mitigation Program
Project Location
FIGURE 1
Mission Gorge Rd
N
Magnolia Ave
Carlton
Hills
Blvd
N Cu
y
a
m
aca
St
Fanita Dr
Mast Blvd
Woodside Ave
Cuyamaca St
Ä125
Ä67
Ä52
LAKESIDE
SANTEE
SAN
SANTEE
DIEGO
Project Boundary
Municipal Boundaries
City of Santee Draft MSCP Subarea Plan Boundary
City of San Diego MHPA
Existing Protected Open Space
Hardline Conservation Lands
Biological Core and Linkage Areas
San Diego River Subunit (Draft Santee MSCP Subarea Plan (City of Santee 2025)) San Diego River Corridor Ordinance (Draft Santee MSCP Subarea Plan (City of Santee 2025)) Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 2 MSCP Lands Layout: Figure 2 MSCP Lands 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025; SanGIS 2025; City of Santee 2025 San Diego River Fire Hazard Mitigation Program
MSCP Lands
FIGURE 2
Fani
t
a
D
r
Mission Gorge Rd
N
Magnolia Ave
Prospect Ave
Carlton
Hills
Blvd
N Cu
y
a
m
aca
St
Mast Blvd
Woodside Ave
Cuyamaca St Ä125
Ä67
Ä52
Project Boundary
Project Components
Zone 1
Zone 2
Zone 3
Potential Invasive Species/Dead and Dying Tree Removal Areas Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 3 Project Components Layout: Figure 3 Project Components 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Project Components
FIGURE 3
Mission Gorge Rd
N
Magnolia Ave
Carlton
Hills
Blvd
N Cu
y
a
m
aca
St
Fanita Dr
Mast Blvd
Woodside Ave
Cuyamaca St
Ä125
Ä67
Ä52
Rm
VaA
CnG2
GrC
VaA
W
Rm
W
Rm
W
SbA
FaB
PfC
PfC
TuB
TuB
TuB TuB
TuB
VaA
VaA
VaA
VaA
VaA
GoA
GoA
GoA
Project Boundary
Soils
CnG2, Cieneba-Fallbrook rocky sandy loams, 30 to 65 percent s lopes, eroded FaB, Fallbrook sandy loam, 2 to 5 percent slopes
GoA, Grangeville fine sandy loam, 0 to 2 percent slopes GrC, Greenfield sandy loam, 5 to 9 percent slopes
PfC, Placentia sandy loam, thick surface, 2 to 9 percent slo pes Rm, Riverwash
SbA, Salinas clay loam, 0 to 2 percent slopes
TuB, Tujunga sand, 0 to 5 percent slopes
VaA, Visalia sandy loam, 0 to 2 percent slopes
W, Water
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 4 Soils Layout: Figure 4 Soils 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025; USGS SSURGO
San Diego River Fire Hazard Mitigation Program
Soils
FIGURE 4
Mission Gorge Rd
Fanita Dr
Carlton Hills Blvd
Fanita Pkwy
Gorge Pl
Gorge Ct
Sunwood Dr
Double M
R
d
Singing
Wood Way
Carlton Oaks Dr
Calle del Verde
Gorge Ave
Willowgrove Ave
Ä125
DW
CLOW
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DEV
DH
DH
DH DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EUC
EW
EW
EW
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
MFS
MFS
MFS
NNR
NNW
NNW
NVC
NVC
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 5 Biological Resources Layout: Figure 5 Biological Resources 0 150 300
n
Feet
Project Boundary
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation
Removal Areas
Cortaderia selloana (Uruguayan pampas grass)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Biological Resources
FIGURE 5A
N
C
u
ya
macaSt
Carlton Oaks Dr
Town Center Pkwy
Mandeville Rd
Willowgrove Pl
Cobblestone Pl
Willowbrook Way
Brookstone Pl
Wintercreek Pl
Parkside Pl
Whi
s
pering Willow Dr
River Park Dr
River Rock Ct
Brookview Ct
River Trail Pl
Willowgrove Ave
Silvercreek Dr
CLOW
CLOW
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EW
FWM
FWM
FWM
FWM
NNG
NNR
OW
OW
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS SWS
SWS
OW OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 5 Biological Resources Layout: Figure 5 Biological Resources 0 150 300
n
Feet
Project Boundary
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation
Removal Areas
Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
NNR, Non-Native Riparian
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Biological Resources
FIGURE 5B
N Magnolia Ave
Town Center Pkwy
Civic Center Rd
Eve Way Eve Ln
Leila Ln
Jim Ln
Park Center Dr
Cottonwood Ave
River
Park
Dr
Riverview Pkwy
Claudia Ave
C
h
u
bb L
a
n
e / Co
tton
wood
Av
e
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EW
EW
FWM
FWM
FWM FWM
FWM
FWM
FWM FWM
FWM
FWM
FWM
FWM
NNG
NNG
NNG
NNG
NNG
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
TS
TS
TS
TS
TS
TS
OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 5 Biological Resources Layout: Figure 5 Biological Resources 0 150 300
n
Feet
Project Boundary
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation
Removal Areas
Arundo donax (giant reed)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Biological Resources
FIGURE 5C
N Magnolia Ave
Woodside Ave
N Woodside Ave
Share Ct
Hil cl re
e
k
Way
Ra
msgate
Way
Chubb
Ln
H
ill
c
reek
Ln
Mavin Dr
Wheatlands Ct
Jeremy St
Stevens
Rd
Wheatlands Rd
Hartley Rd
Bundy Dr
Hinton Dr
Amster Dr
Abraham Way
Hillcreek Rd
Wheatlands Ave
Ä67
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
DEV
DEV
DEV
DEV
DEV DEV
DH
DH
DH
DH
DH
DH
FWM
FWM FWM
FWM
FWM
FWM
FWM FWM FWM
FWM
FWM
FWM
NNW
OW
OW
OW
OW
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF SCWRF
SCWRF
SRS SCWRF
SRS
SRS
SRS
SRS
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
SWS
SWS SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 5 Biological Resources Layout: Figure 5 Biological Resources 0 150 300
n
Feet
Project Boundary
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation
Removal Areas
Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Biological Resources
FIGURE 5D
Woodside Ave
Riverford Rd
N Woodside Ave
Calle R Tuttle
Mission Park Pl
Security Way
Los Sanderos Dr
Woodside Ter
Karerllyn Dr
Ä67
CLOW
CLOWO
CLOWO
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSSB
DEV
DEV
DH
DH
DH
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNR
NNW
NNW
NNW
OW
OW
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 5 Biological Resources Layout: Figure 5 Biological Resources 0 150 300
n
Feet
Project Boundary
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation
Removal Areas
Arundo donax (giant reed)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNR, Non-Native Riparian
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Biological Resources
FIGURE 5E
Mission Gorge Rd
Fanita Dr
Carlton Hills Blvd
Ä125
DW
CLOW
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DEV
DH
DH
DH DH
DH
DH
DH DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EUC
EW
EW
EW
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM FWM
FWM
MFS
MFS
MFS
NNR
NNW
NNW
NVC
NVC
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 6 Suitable Special-Status Plant Habitats Layout: Figure 6 Suitable Special-Status Plant Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Plant Habitat
Special-status Plants
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Plant Habitats
FIGURE 6A
N
C
u
ya
macaSt
CLOW
CLOW
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EW
FWM
FWM
FWM
FWM
NNG
NNR
OW
OW
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS SWS
SWS
OW OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 6 Suitable Special-Status Plant Habitats Layout: Figure 6 Suitable Special-Status Plant Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Plant Habitat
Special-status Plants
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
NNR, Non-Native Riparian
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Plant Habitats
FIGURE 6B
N Magnolia Ave
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNG
NNG
NNG
NNG
NNG
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SWRF
TS
TS
TS
TS
TS
TS
OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 6 Suitable Special-Status Plant Habitats Layout: Figure 6 Suitable Special-Status Plant Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Plant Habitat
White rabbit-tobacco (Pseudognaphalium
leucocephalum)
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Plant Habitats
FIGURE 6C
N Magn
olia Ave
Woodside Ave
Ä67
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
DEV
DEV
DEV
DEV
DEV DEV
DH
DH
DH
DH
DH
DH
FWM
FWM FWM
FWM
FWM
FWM
FWM FWM FWM
FWM
FWM
FWM
NNW
OW
OW
OW
OW
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SRS
SRS
SRS
SRS
SRS
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
SWS
SWS SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 6 Suitable Special-Status Plant Habitats Layout: Figure 6 Suitable Special-Status Plant Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Plant Habitat
Special-status Plants
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Plant Habitats
FIGURE 6D
Woodside Ave
Ä67
CLOW
CLOWO
CLOWO
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
DEV
DEV
DH
DH
DH
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNR
NNW
NNW
NNW
OW
OW
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 6 Suitable Special-Status Plant Habitats Layout: Figure 6 Suitable Special-Status Plant Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Plant Habitat
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNR, Non-Native Riparian
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Plant Habitats
FIGURE 6E
"J
"J
!P
!P
!P
!P
#
0#
0 0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
Mission Gorge Rd
Fanita Dr
Carlton Hills Blvd
Ä125
DW
CLOW
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DEV
DH
DH
DH DH
DH
DH
DH DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EUC
EW
EW
EW
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM FWM
FWM
MFS
MFS
MFS
NNR
NNW
NNW
NVC
NVC
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 7 Suitable Special-Status Wildlife Habitats Layout: Figure 7 Suitable Special-Status Wildlife Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Wildlife Habitat
Sensitive Species
"J Yellow warbler
!P Yellow-breasted chat
0# least Bell's vireo
USFWS Critical Habitat
Least Bell's vireo
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNG, Non-Native Grassland
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Wildlife Habitats
FIGURE 7A
N
C
u
ya
macaSt
CLOW
CLOW
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EW
FWM
FWM
FWM
FWM
NNG
NNR
OW
OW
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS SWS
SWS
OW OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 7 Suitable Special-Status Wildlife Habitats Layout: Figure 7 Suitable Special-Status Wildlife Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Wildlife Habitat
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNG, Non-Native Grassland
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Wildlife Habitats
FIGURE 7B
"J
"J
"J "J
"J
"J
0#
0#
0#
N Magnolia Ave
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNG
NNG
NNG
NNG
NNG
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SWRF
TS
TS
TS
TS
TS
TS
OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 7 Suitable Special-Status Wildlife Habitats Layout: Figure 7 Suitable Special-Status Wildlife Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Wildlife Habitat
Sensitive Species
"J Yellow warbler
0# least Bell's vireo
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNG, Non-Native Grassland
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Wildlife Habitats
FIGURE 7C
"J
"J
"J
!P
!P
0#
0#
0#
0#
0#
0#
0#
0#
N Magn
olia Ave
Woodside Ave
Ä67
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
DEV
DEV
DEV
DEV
DEV DEV
DH
DH
DH
DH
DH
DH
FWM
FWM FWM
FWM
FWM
FWM
FWM FWM FWM
FWM
FWM
FWM
NNW
OW
OW
OW
OW
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SRS
SRS
SRS
SRS
SRS
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
SWS
SWS SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 7 Suitable Special-Status Wildlife Habitats Layout: Figure 7 Suitable Special-Status Wildlife Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Wildlife Habitat
Sensitive Species
"J Yellow warbler
!P Yellow-breasted chat
0# least Bell's vireo
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNG, Non-Native Grassland
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Wildlife Habitats
FIGURE 7D
"J
!P
!P
"J
Woodside Ave
Ä67
CLOW
CLOWO
CLOWO
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
DEV
DEV
DH
DH
DH
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNR
NNW
NNW
NNW
OW
OW
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 7 Suitable Special-Status Wildlife Habitats Layout: Figure 7 Suitable Special-Status Wildlife Habitats 0 150 300
n
Feet
Project Boundary
Suitable Special-status Wildlife Habitat
Sensitive Species
!P Yellow-breasted chat
"J coastal California gnatcatcher
Vegetation Communities and Land Covers
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNG, Non-Native Grassland
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Suitable Special-Status Wildlife Habitats
FIGURE 7E
Fanita
D
r
Mission Gorge Rd
N
Magnolia Ave
Prospect Ave
Carlton
Hills
Blvd
N Cu
y
a
m
aca
St
Mast Blvd
Woodside Ave
Cuyamaca St Ä125
Ä67
Ä52
Project Boundary
Sensitive Riparian Vegetation Communities
National Wetlands Inventory
Freshwater Emergent Wetland
Freshwater Forested/Shrub Wetland
Freshwater Pond
Riverine
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 8 Potentially Jurisdictional Aquatic Resources Layout: Figure 8 Potentially Jurisdictional Aquatic Resources 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025; USGS NHD 2025; USFWS NWI 2025 San Diego River Fire Hazard Mitigation Program
Potentially Jurisdictional Aquatic Resources
FIGURE 8
$
$
$
$
$
$
$$
Fa
nita D
r
Mission Gorge Rd
N
Magnolia Ave
Prospect Ave
Carlton
Hills
Blvd
N Cu
y
a
m
aca
St
Mast Blvd
Woodside Ave
Cuyamaca St Ä125
Ä67
Ä52
Project Boundary
$
$ coastal California gnatcatcher Stepping Stone Linkage coastal California gnatcatcher Habitat Blocks
Existing Protected Open Space
Hardline Conservation Lands
San Diego River Subunit (Draft Santee MSCP Subarea Plan (City of Santee 2025)) San Diego River Corridor Ordinance (Draft Santee MSCP Subarea Plan (City of Santee 2025)) Biological Core and Linkage Areas
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 9 Wildlife Corridors and Habitat Linkages Layout: Figure 9 Wildlife Corridors and Habitat Linkages 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025; SanGIS 2025; City of Santee 2025 San Diego River Fire Hazard Mitigation Program
Wildlife Corridors and Habitat Linkages
FIGURE 9
"J
"J
!P
!P
!P
!P
#
0#
0 0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
0#
Mission Gorge Rd
Fanita Dr
Carlton Hills Blvd
Fanita Pkwy
Gorge Pl
Gorge Ct
Sunwood Dr
Double M
R
d
Singing
Wood Way
Calle del Verde
Gorge Ave
Willowgrove Ave
Ä125
DW
CLOW
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DEV
DH
DH
DH DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EUC
EW
EW
EW
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
MFS
MFS
MFS
NNR
NNW
NNW
NVC
NVC
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 10 Impacts to Biological Resources Layout: Figure 10 Impacts to Biological Resources 0 150 300
n
Feet
Project Boundary
Permanent Impacts
Zone 1
Zone 2
Zone 3
Sensitive Species
"J Yellow warbler
!P Yellow-breasted chat
0# least Bell's vireo
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation Removal Areas Cortaderia selloana (Uruguayan pampas grass)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
USFWS Critical Habitat
Least Bell's vireo
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Impacts to Biological Resources
FIGURE 10A
N
C
u
ya
macaSt
Carlton Oaks Dr
Town Center Pkwy
Mandeville Rd
Willowgrove Pl
Cobblestone Pl
Willowbrook Way
Brookstone Pl
Wintercreek Pl
Parkside Pl
Whi
s
pering Willow Dr
River Park Dr
River Rock Ct
Brookview Ct
River Trail Pl
Willowgrove Ave
Silvercreek Dr
CLOW
CLOW
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EW
FWM
FWM
FWM
FWM
NNG
NNR
OW
OW
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS SWS
SWS
OW OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 10 Impacts to Biological Resources Layout: Figure 10 Impacts to Biological Resources 0 150 300
n
Feet
Project Boundary
Permanent Impacts
Zone 1
Zone 2
Zone 3
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation Removal Areas Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
NNR, Non-Native Riparian
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Impacts to Biological Resources
FIGURE 10B
"J
"J
"J "J
"J
"J
0#
0#
0#
N Magnolia Ave
Town Center Pkwy
Civic Center Rd
Eve Way Eve Ln
Leila Ln
Jim Ln
Park Center Dr
Cottonwood Ave
River
Park
Dr
Riverview Pkwy
Claudia Ave
C
h
u
bb L
a
n
e / Co
tton
wood
Av
e
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EW
EW
FWM
FWM
FWM FWM
FWM
FWM
FWM FWM
FWM
FWM
FWM
FWM
NNG
NNG
NNG
NNG
NNG
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
TS
TS
TS
TS
TS
TS
OW
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 10 Impacts to Biological Resources Layout: Figure 10 Impacts to Biological Resources 0 150 300
n
Feet
Project Boundary
Permanent Impacts
Zone 1
Zone 2
Zone 3
Sensitive Species
"J Yellow warbler
0# least Bell's vireo
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation Removal Areas Arundo donax (giant reed)
Special-Status Plant Species
White rabbit-tobacco (Pseudognaphalium leucocephalum)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Impacts to Biological Resources
FIGURE 10C
"J
"J
"J
!P
!P
0#
0#
0#
0#
0#
0#
0#
0#
N Magnolia Ave
Woodside Ave
N Woodside Ave
Share Ct
Hil cl re
e
k
Way
Ra
msgate
Way
Chubb
Ln
H
ill
c
reek
Ln
Mavin Dr
Wheatlands Ct
Jeremy St
Stevens
Rd
Wheatlands Rd
Hartley Rd
Bundy Dr
Hinton Dr
Amster Dr
Abraham Way
Hillcreek Rd
Wheatlands Ave
Ä67
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
DEV
DEV
DEV
DEV
DEV DEV
DH
DH
DH
DH
DH
DH
FWM
FWM FWM
FWM
FWM
FWM
FWM FWM FWM
FWM
FWM
FWM
NNW
OW
OW
OW
OW
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF SCWRF
SCWRF
SRS SCWRF
SRS
SRS
SRS
SRS
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
SWS
SWS SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 10 Impacts to Biological Resources Layout: Figure 10 Impacts to Biological Resources 0 150 300
n
Feet
Project Boundary
Permanent Impacts
Zone 1
Zone 2
Zone 3
Sensitive Species
"J Yellow warbler
!P Yellow-breasted chat
0# least Bell's vireo
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation Removal Areas Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Impacts to Biological Resources
FIGURE 10D
"J
!P
!P
"J
Woodside Ave
Riverford Rd
N Woodside Ave
Calle R Tuttle
Mission Park Pl
Security Way
Los Sanderos Dr
Woodside Ter
Karerllyn Dr
Ä67
CLOW
CLOWO
CLOWO
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSSB
DEV
DEV
DH
DH
DH
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNR
NNW
NNW
NNW
OW
OW
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
Date: 4/29/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Biology\BTR\Santee SD River FHMP BTR.aprx Map: Figure 10 Impacts to Biological Resources Layout: Figure 10 Impacts to Biological Resources 0 150 300
n
Feet
Project Boundary
Permanent Impacts
Zone 1
Zone 2
Zone 3
Sensitive Species
!P Yellow-breasted chat
"J coastal California gnatcatcher
Vegetation Removal Areas
Potential Non-Native/Dead and Dying Vegetation Removal Areas Arundo donax (giant reed)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharis-dominated
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNR, Non-Native Riparian
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program
Impacts to Biological Resources
FIGURE 10E
Attachment A
Site Photographs
APPENDIX B / SITE PHOTOGRAPHS
18611 B-1
JANUARY 2026
1. Overview of the project site, facing northeast from the southern project site boundary along Cuyamaca Street
2. Overview of San Diego River within the eastern portion of the project site
3. Dense riparian forest in the eastern portion of the project site, viewed from the southern project site boundary
4. Representative defensible space area along southern project site boundary at terminus of Abraham Way.
Attachment B
Species Compendium
APPENDIX C / SPECIES COMPENDIUM
18611 C-1
JANUARY 2026
Plant Species
Angiosperms (Dicots)
AIZOACEAE—FIG-MARIGOLD FAMILY
Carpobrotus edulis—hottentot fig
ANACARDIACEAE—SUMAC FAMILY
Malosma laurina—laurel sumac
Rhus integrifolia—lemonade berry
Rhus ovata–sugarbush
Schinus molle—Peruvian pepper tree
Schinus terebinthifolia—Brazilian pepper tree
APIACEAE—CARROT FAMILY
Apium graveolens—wild celery
Foeniculum vulgare—fennel
ASTERACEAE—SUNFLOWER FAMILY
Ambrosia psilostachya—western ragweed
Artemisia californica—California sagebrush
Artemisia douglasiana — Douglas’s sagewort
Artemisia palmeri–San Diego sagewort
Baccharis pilularis—coyote brush
Baccharis salicifolia—mulefat, seep-willow, water-wally Baccharis sarothroides—desertbroom
Encelia californica—California brittle bush
Erigeron canadensis—Canadian horseweed
Glebionis coronaria—crowndaisy
Heterotheca grandiflora—telegraph weed
Isocoma menziesii—Menzies’ goldenbush
Isocoma menziesii ssp. menziesii—spreading goldenbush
Iva hayesiana—San Diego marsh-elder
Pluchea odorata—sweetscent
Pluchea sericea—arrow weed
BORAGINACEAE—BORAGE FAMILY
Heliotropium curassavicum—alkali heliotrope
BRASSICACEAE—MUSTARD FAMILY
Hirschfeldia incana—short-pod mustard
APPENDIX C / SPECIES COMPENDIUM
18611 C-2
JANUARY 2026
CACTACEAE—CACTUS FAMILY
Cylindropuntia prolifera—coastal cholla
Opuntia littoralis—coast prickly pear
CHENOPODIACEAE—GOOSEFOOT FAMILY
Atriplex canescens—fourwing saltbush
CLEOMACEAE—CLEOME FAMILY
Cleomella arborea—bladderpod
CUCURBITACEAE—GOURD FAMILY
Cupaniopsis anacardioides—carrotwood
EUPHORBIACEAE—SPURGE FAMILY
Croton californicus—California croton
Croton setiger—dove weed
Ricinus communis—castor bean
FABACEAE—LEGUME FAMILY
Acmispon glaber—deerweed
Acmispon tomentosus—Heermann’s bird’s-foot trefoil
Melilotus indicus—yellow sweetclover
Parkinsonia aculeata—Jerusalem thorn
FAGACEAE—OAK FAMILY
Quercus agrifolia—coast live oak
HYDROPHYLLACEAE—WATERLEAF FAMILY
Phacelia ramosissima—branching phacelia
LAMIACEAE—MINT FAMILY
Marrubium vulgare- horehound
Salvia apiana—white sage
Salvia mellifera—black sage
LYTHRACEAE—LOOSESTRIFE FAMILY
Lythrum portula—spatulaleaf loosestrife
MORACEAE—MULBERRY FAMILY
Ficus carica—edible fig
MYTRACEAE—MYRTLE FAMILY
Eucalyptus camaldulensis—river redgum
APPENDIX C / SPECIES COMPENDIUM
18611 C-3
JANUARY 2026
Melaleuca viminalis—weeping bottlebrush
OLEACEAE—OLIVE FAMILY
Fraxinus uhdei—evergreen ash
Olea europaea—olive
ONAGRACEAE—EVENING PRIMROSE FAMILY
Camissoniopsis cheiranthifolia—beach suncup
Oenothera elata—Hooker’s evening primrose
PLANTAGINACEAE—PLANTAIN FAMILY
Plantago lanceolata—narrowleaf plantain
PLATANACEAE—PLANE TREE, SYCAMORE FAMILY
Platanus racemosa—California sycamore
POLYGONACEAE—BUCKWHEAT FAMILY
Eriogonum fasciculatum—California buckwheat
ROSACEAE—ROSE FAMILY
Heteromeles arbutifolia—toyon
Pyracantha koidzumii—Formosa firethorn
Rosa californica—California rose
Rubus ursinus—California blackberry
SALICACEAE—WILLOW FAMILY
Populus fremontii—Fremont cottonwood
Salix exigua—sandbar willow
Salix gooddingii—Goodding’s willow
Salix laevigata -red willow
Salix lasiolepis—arroyo willow
SAURURACEAE—LIZARD’S TAIL FAMILY
Anemopsis californica—yerba mansa
SOLANACEAE—NIGHTSHADE FAMILY
Datura wrightii—jimsonweed, sacred thornapple
Nicotiana glauca—tree tobacco
TAMARICACEAE—TAMARISK FAMILY
Tamarix ramosissima—tamarisk
APPENDIX C / SPECIES COMPENDIUM
18611 C-4
JANUARY 2026
VIBURNACEAE—MUSKROOT FAMILY
Sambucus mexicana—blue elderberry
VISCACEAE—MISTLETOE FAMILY
Phoradendron leucarpum—oak mistletoe
VITACEAE—GRAPE FAMILY
Vitis californica—California wild grape
Angiosperms (Monocots)
ARECACEAE—PALM FAMILY
Phoenix canariensis—Canary Island fan palm
Washingtonia robusta—Washington fan palm
CYPERACEAE—SEDGE FAMILY
Cyperus involucratus—umbrella plant
JUNCACEAE—RUSH FAMILY
Juncus acutus ssp. leopoldii—southwestern spiny rush
POACEAE—GRASS FAMILY
Arundo donax—giant reed
Cortaderia jubata—purple pampass grass
Cortaderia selloana –Uruguayan pampass grass
Ehrharta calycina—perennial veldtgrass
Elymus condensatus—giant wild rye
Pennisetum setaceum—fountain grass
TYPHACEAE—CATTAIL FAMILY
Typha latifolia—broadleaf cattail
Gymnosperms
PINACEAE—PINE FAMILY
Pinus spp.—Pine species
APPENDIX C / SPECIES COMPENDIUM
18611 C-5
JANUARY 2026
Wildlife Species—Vertebrates
Birds
ACCIPITRIDAE—HAWKS
Buteo jamaicensis—red-tailed hawk
Buteo lineatus—red-shouldered hawk
Astur cooperii—Cooper’s hawk
AEGITHALIDAE—LONG-TAILED TITS AND BUSHTITS
Psaltriparus minimus–bushtit
APODIDAE—SWIFTS
Aeronautes saxatalis—white-throated swift
ARDEIDAE—HERONS, BITTERNS, AND ALLIES
Ardea alba—great egret
Ardea herodias—great blue heron
Egretta thula—snowy egret
BOMBYCILLIDAE—WAXWINGS
Bombycilla cedrorum—cedar waxwing
COLUMBIDAE—PIGEONS AND DOVES
Zenaida macroura—mourning dove
CORVIDAE—JAYS AND CROWS
Corvus brachyrhynchos—American crow
Corvus corax—common raven
ESTRILDIDAE—WAXBILLS
Lonchura punctulata—scaly-breasted munia
FALCONIDAE—CARACARAS AND FALCONS
Falco sparverius—American kestrel
FRINGILLIDAE—FINCHES
Carpodacus mexicanus—house finch
Carduelis psaltria—lesser goldfinch
Spinus tristis—American goldfinch
APPENDIX C / SPECIES COMPENDIUM
18611 C-6
JANUARY 2026
ICTERIDAE—BLACKBIRDS
Agelaius phoeniceus—red-winged blackbird
Quiscalus mexicanus—great-tailed grackle
MIMIDAE—MOCKINGBIRDS AND THRASHERS
Mimus polyglottos—northern mockingbird
PARULIDAE—WOOD-WARBLERS
Geothlypis trichas—common yellowthroat
Setophaga coronata—yellow-rumped warbler
Leiothlypis celata—orange-crowned warbler
PASSERELLIDAE—NEW WORLD WARBLERS
Junco hyemalis—dark-eyed junco
Melospiza melodia—song sparrow
Melozone crissalis—California towhee
Passerella iliaca—fox sparrow
Pipilo maculatus—spotted towhee
Zonotrichia leucophrys—white-crowned sparrow
PASSERIDAE—OLD WORLD SPARROWS
Passer domesticus—house sparrow
PICIDAE—WOODPECKERS AND ALLIES
Colaptes auratus—northern flicker
Melanerpes formicivorus—acorn woodpecker
Dryobates nuttallii—Nuttall’s woodpecker
POLIOPTILIDAE—GNATCATCHERS
Polioptila caerulea—blue-grey gnatcatcher
RALLIDAE—RAILS, GALLINULES, AND COOTS
Fulica americana—American coot
REGULIDAE—KINGLETS
Corthylio calendula—ruby-crowned kinglet
SITTIDAE—NUTHATCHES
Sitta carolinensis—white-breasted nuthatch
STURNIDAE—STARLINGS
Sturnus vulgaris—European starling
APPENDIX C / SPECIES COMPENDIUM
18611 C-7
JANUARY 2026
SYLVIIDAE—SYLVIID WARBLERS
Chamaea fasciata—wrentit
TROCHILIDAE—HUMMINGBIRDS
Calypte anna—Anna’s hummingbird
TROGLODYTIDAE—WRENS
Thryomanes bewickii— Bewick’s wren
TYRANNIDAE—TYRANT FLYCATCHERS
Sayornis nigricans—black phoebe
Tyrannus vociferans—Cassin’s kingbird
signifies introduced (non-native) species
Attachment C
Special-Status Plants with a Potential to Occur
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-1
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
Acanthomintha
ilicifolia
San Diego thornmintFT/SE/1B.1/Covered Chaparral, Coastal scrub, Valley and foothill grassland, Vernal pools; Clay,
Openings/annual herb/Apr–June/
35–3,150
Not expected to occur. The project
site is within the species known
elevation range; although clay soils
and coastal sage scrub are present
in the project site, there are no
vernal pools to support this species.
Adolphia californica California adolphia None/None/2B.1/None Chaparral, Coastal scrub, Valley and foothill grassland; Clay/perennial
deciduous shrub/Dec–May/35–2,430
Low potential to occur. The project
site is within the species known
elevation range; coastal scrub and
non-native grassland as well as clay
soils are on site. CNDDB occurrence
record from 1936 located 3 miles
from the project site but is possibly
extirpated (CDFW 2025).
Ambrosia monogyra singlewhorl
burrobrush
None/None/2B.2/None Chaparral, Sonoran desert scrub;
washes; Sandy/perennial shrub/Aug–
Nov/35–1,640
Low potential to occur. Although the
project site is within the species
known elevation range, it is a large
conspicuous plant that would have
likely been observed during
vegetation mapping.
Ambrosia pumila San Diego
ambrosia
FE/None/1B.1/Covered Chaparral, Coastal scrub, Valley and foothill grassland, Vernal pools;
Alkaline (sometimes), Clay
(sometimes), Disturbed areas (often),
Loam (sometimes), Sandy
(sometimes)/perennial rhizomatous
herb/Apr–Oct/65–1,360
Moderate potential to occur. The
project site is within the species
known elevation range; coastal
scrub, non-native grassland, and
suitable substrates are present.
CNDDB occurrence records from
2006 overlap the project site
(CDFW 2025). However, this
species prefers vernal pools and
none were detected on the project
site during the biological
reconnaissance.
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-2
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
Arctostaphylos
glandulosa ssp.
crassifolia
Del Mar manzanita FE/None/1B.1/None Chaparral (maritime, sandy)/perennial evergreen shrub/June–Apr/0–1,200
Not expected to occur. Although the
project site is within the species
known elevation range, there is no
suitable vegetation present.
Astragalus deanei Dean's milk-vetch None/None/1B.1/None Chaparral, Cismontane woodland, Coastal scrub, Riparian
forest/perennial herb/Feb–May/
245–2,280
Low potential to occur. The project
site is within the species known
elevation range; riparian forest and
coastal scrub are present. CNDDB
occurrence records from an
unknown date are 5 miles east
from the project site (CDFW 2025).
Bloomeria
clevelandii
San Diego
goldenstar
None/None/1B.1/
Covered
Chaparral, Coastal scrub, Valley and
foothill grassland, Vernal pools;
Clay/perennial bulbiferous herb/Apr–
May/165–1,525
Not expected to occur. The project
site is within the species known
elevation range; although nonnative grassland and coastal scrub as well as clay soils are present,
there are no vernal pools to support
this species.
Brodiaea orcuttii Orcutt's brodiaea None/None/1B.1/None Chaparral, Cismontane woodland, Closed-cone coniferous forest,
Meadows and seeps, Valley and
foothill grassland, Vernal pools; Clay,
Mesic/perennial bulbiferous
herb/May–July/100–5,550
Low potential to occur. to occur.
The project site is within the
species known elevation range.
However, non-native grassland on
site lacks clay soils or mesic
habitat. Nearest occurrence record
is from 1997, approximately 2
miles west of the project site (CCH
2025).
Ceanothus
otayensis
Otay Mountain
ceanothus
None/None/1B.2/None Chaparral (gabbroic,
metavolcanic)/perennial evergreen
shrub/Jan–Apr/1,970–3,610
Not expected to occur. The project
site is outside of the species’
known elevation range and there is
no suitable vegetation present.
Ceanothus
verrucosus
wart-stemmed
ceanothus
None/None/2B.2/None Chaparral, Coastal scrub/perennial
evergreen shrub/Dec–May/5–1,245
Low potential to occur. The project
site is within the species known
elevation range; coastal scrub is
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-3
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
present. Historic CNDDB
occurrence records from 1897 are
extirpated and located 4 miles from
the project site (CDFW 2025).
Centromadia
pungens ssp. laevis
smooth tarplant None/None/1B.1/None Chenopod scrub, Meadows and seeps, Playas, Riparian woodland, Valley and
foothill grassland; Alkaline/annual
herb/Apr–Sep/0–2,100
Moderate potential to occur. The
project site is within the species
known elevation range; riparian
woodland and non-native grassland
are present but the project site
lacks alkaline soils. CNDDB
occurrence records from 2008-
2017 located 1 mile from the
project site (CDFW 2025).
Chorizanthe
polygonoides var.
longispina
long-spined
spineflower
None/None/1B.2/None Chaparral, Coastal scrub, Meadows
and seeps, Valley and foothill
grassland, Vernal pools; Clay
(often)/annual herb/Apr–July/
100–5,020
Not expected to occur. The project
site is within the species known
elevation range; although nonnative grassland and coastal scrub as well as clay soils are present,
there are no vernal pools to support
this species.
Clarkia delicata delicate clarkia None/None/1B.2/None Chaparral, Cismontane woodland; Gabbroic (often)/annual herb/Apr–
June/770–3,280
Not expected to occur. The project
site is outside of the species’
known elevation range and there is
no suitable vegetation present.
Comarostaphylis
diversifolia ssp.
diversifolia
summer holly None/None/1B.2/None Chaparral, Cismontane
woodland/perennial evergreen
shrub/Apr–June/100–2,590
Not expected to occur. Although the
project site is within the species
known elevation range, no suitable
vegetation is present.
Dudleya variegata variegated dudleya None/None/1B.2/
Covered
Chaparral, Cismontane woodland,
Coastal scrub, Valley and foothill
grassland, Vernal pools; Clay/perennial
herb/Apr–June/10–1,905
Not expected to occur. The project
site is within the species known
elevation range; although nonnative grassland and coastal scrub as well as clay soils are present,
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-4
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
there are no vernal pools to support
this species.
Ericameria palmeri
var. palmeri
Palmer's
goldenbush
None/None/1B.1/None Chaparral, Coastal scrub;
Mesic/perennial evergreen
shrub/(July)Sep–Nov/100–1,970
Low potential to occur. The project
site is within the species known
elevation range; coastal scrub and
mesic areas are present. CNDDB
occurrence record from 1997
located 2 miles from the project site
(CDFW 2025).
Eryngium
aristulatum var.
parishii
San Diego buttonceleryFE/SE/1B.1/Covered Coastal scrub, Valley and foothill grassland, Vernal pools;
Mesic/annual/perennial herb/Apr–
June/65–2,035
Not expected to occur. The project
site is within the species known
elevation range; although nonnative grassland and coastal scrub as well as clay soils are present,
there are no vernal pools to support
this species.
Ferocactus
viridescens
San Diego barrel
cactus
None/None/2B.1/
Covered
Chaparral, Coastal scrub, Valley and
foothill grassland, Vernal
pools/perennial stem/May–June/
10–1,475
Not expected to occur. The project
site is within the species known
elevation range; although coastal
scrub is present, there are no
vernal pools to support this species.
Grindelia hallii San Diego
gumplant
None/None/1B.2/None Chaparral, Lower montane coniferous forest, Meadows and seeps, Valley and
foothill grassland/perennial
herb/May–Oct/605–5,725
Not expected to occur. Although
suitable habitat is present, the
project site is outside of the
species’ known elevation range.
Isocoma menziesii
var. decumbens
decumbent
goldenbush
None/None/1B.2/None Chaparral, Coastal scrub (often
disturbed areas, sandy)/perennial
shrub/Apr–Nov/35–820
Moderate potential to occur. The
project site is within the species
known elevation range; coastal
scrub with sandy soils and
disturbed areas are present.
Multiple CNDDB occurrence records
from 2005 and 2019 located 2
miles from the project site (CDFW
2025).
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-5
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
Iva hayesiana San Diego marshelderNone/None/2B.2/None Marshes and swamps, Playas/perennial herb/Apr–Oct/
0–1,640
Present. Observed during the
biological reconnaissance surveys
within the freshwater marsh habitat
on the project site.
Lepechinia
cardiophylla
heart-leaved
pitcher sage
None/None/1B.2/None Chaparral, Cismontane woodland,
Closed-cone coniferous
forest/perennial shrub/Apr–
July/1,705–4,495
Not expected to occur. The project
site is outside of the species’
known elevation range and there is
no suitable vegetation present.
Monardella viminea willowy monardella FE/SE/1B.1/Covered Chaparral, Coastal scrub, Riparian forest, Riparian scrub, Riparian
woodland; Alluvial Terraces,
Washes/perennial herb/June–
Aug/165–740
Moderate potential to occur. The
project site is within the species
known elevation range and suitable
modeled habitat occurs within the
project site (City of Santee 2025);
however, this perennial species was
not observed during field surveys
and the site does not contain
suitable alluvial terraces. Closest
CNDDB occurrence record from
2007 is located 1 mile from the
project site (CDFW 2025).
Navarretia prostrata prostrate vernal
pool navarretia
None/None/1B.2/None Coastal scrub, Meadows and seeps,
Valley and foothill grassland (alkaline),
Vernal pools; Mesic/annual herb/Apr–
July/10–3,970
Not expected to occur. The project
site is within the species known
elevation range; although coastal
scrub and mesic areas are present,
there are no vernal pools to support
this species.
Pogogyne abramsii San Diego mesa
mint
FE/SE/1B.1/Covered Vernal pools/annual herb/Mar–
July/295–655
Not expected to occur. Although the
project site is within the species
known elevation range, no suitable
vegetation is present.
Pogogyne
nudiuscula
Otay Mesa mint FE/SE/1B.1/None Vernal pools/annual herb/May– July/295–820
Not expected to occur. The project
site is within the species known
elevation range but there is no
suitable vegetation present.
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-6
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
Pseudognaphalium
leucocephalum
white rabbittobaccoNone/None/2B.2/None Chaparral, Cismontane woodland, Coastal scrub, Riparian woodland;
Gravelly, Sandy/perennial
herb/(July)Aug–Nov(Dec)/0–6,890
High potential to occur. The project
site is within the species known
elevation range; riparian woodland
and sandy soils are present. CCH
occurrence records from 2011 are
located immediately outside of the
southern project site boundary
(CCH 2025).
Quercus dumosa Nuttall's scrub oak None/None/1B.1/None Chaparral, Closed-cone coniferous forest, Coastal scrub; Clay, Loam,
Sandy/perennial evergreen
shrub/Feb–Apr(May–Aug)/50–1,310
High potential to occur. The project
site is within the species known
elevation range; coastal scrub and
suitable soils present; may occur
within coast live oak woodland on
the project site. CNDDB occurrence
records from 2009 overlap the
project site (CDFW 2025).
Salvia munzii Munz's sage None/None/2B.2/None Chaparral, Coastal scrub/perennial evergreen shrub/Feb–Apr/375–3,495
Low potential to occur. The project
site is within the species known
elevation range; limited coastal
scrub is present. CNDDB
occurrence records from 2016
located 2 miles from the project site
(CDFW 2025).
Senecio aphanactis chaparral ragwort None/None/2B.2/None Chaparral, Cismontane woodland, Coastal scrub; Alkaline
(sometimes)/annual herb/Jan–
Apr(May)/50–2,625
Low potential to occur. The project
site is within the species known
elevation range; coastal scrub is
present but lacks alkaline
substrate. Historic CNDDB
occurrence record from 1937
located 2 miles from the project site
(CDFW 2025).
Stemodia
durantifolia
purple stemodia None/None/2B.1/None Sonoran desert scrub (often mesic, sandy)/perennial herb/(Jan)Apr–
Dec/590–985
Low potential to occur. The project
site is outside of the species’
known elevation range. . However, it
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-7
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/CRPR/
Santee Draft MSCP)
Primary Habitat Associations/
Life Form/ Blooming Period/
Elevation Range (feet) Potential to Occur
is known to occur at Mission Trails
near the project site along riparian
habitats and washes. Nearby
occurrence records from 1992 are
approximately 3 miles west of the
project site (CCH 2025).
Stylocline citroleum oil neststraw None/None/1B.1/None Chenopod scrub, Coastal scrub, Valley and foothill grassland; Clay/annual
herb/Mar–Apr/165–1,310
Moderate potential to occur. The
project site is within the species
known elevation range; coastal
scrub and non-native grassland are
present along with clay soils.
Historic CNDDB occurrence records
from 1883 are 5 miles from the
project site and presumed extant
(CDFW 2025).
*Status Legend:
FE: Federally listed as endangered
FT: Federally listed as threatened
SE: State listed as endangered
ST: State listed as threatened
CRPR 1A: Plants presumed extirpated in California and either rare or extinct elsewhere CRPR 1B: Plants rare, threatened, or endangered in California and elsewhere CRPR 2A: Plants presumed extirpated in California but common elsewhere CRPR 2B: Plants rare, threatened, or endangered in California but more common elsewhere .1 Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat) .2 Moderately threatened in California (20–80% occurrences threatened / moderate degree and immediacy of threat) .3 Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known) MSCP: Multiple Species Conservation Program
APPENDIX D / SPECIAL-STATUS PLANT SPECIES POTENTIAL TO OCCUR 18611 D-8
JANUARY 2026
References
CCH (Consortium of California Herbaria). 2025. CCH2 Portal. Map Search. https://cch2.org/portal/ collections/map/index.php
CDFW (California Department of Fish and Wildlife). 2025. Natural Diversity Database. Biogeographic Information Observation System (BIOS). Commercial Viewer. Version 6. Wildlife.ca.gov/bios6.
City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report.
Attachment D
Special-Status Wildlife with a Potential to Occur
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-1
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Amphibians
Spea hammondi western spadefoot FPT/SSC, SC/Covered Primarily grassland and vernal pools, but also in ephemeral
wetlands that persist at least 3
weeks in chaparral, coastal scrub,
valley–foothill woodlands, pastures,
and other agriculture
Not expected to occur. Coastal sage scrub
and non-native grassland present along
the San Diego River in the project site.
However, there is no known breeding
habitat or potentially suitable breeding
habitat within the project site (City of
Santee 2025). Additionally, there are
CNDDB occurrence records that overlap
the project site; however, these
occurrences are too generalized of a
location to be considered within the
project site (CDFW 2025).
Reptiles
Actinemys pallida southwestern
pond turtle
FPT/SSC/None Slow-moving permanent or
intermittent streams, ponds, small
lakes, and reservoirs with emergent
basking sites; adjacent uplands
used for nesting and during winter
Not expected to occur. Although suitable
upland and breeding resources are
present, this species is not known to occur
in the portion of the San Diego River on
the project site.
Anniella stebbinsi southern
California legless
lizard
None/SSC/None Coastal dunes, stabilized dunes,
beaches, dry washes, valley–foothill,
chaparral, and scrubs; pine, oak,
and riparian woodlands; associated
with sparse vegetation and moist
sandy or loose, loamy soils
High potential to occur. Suitable habitats
present (coastal scrub, wash, oak
woodland, riparian woodland; moist sandy
soils). CNDDB occurrence record from
2012 overlap the western portion of the
project site (CDFW 2025).
Arizona elegans
occidentalis
California glossy
snake
None/SSC/None Arid scrub, rocky washes,
grasslands, chaparral, open areas
with loose soil
High potential to occur. Suitable substrate
present. Historic CNDDB occurrence
records from 1973 overlap the project site
(CDFW 2025).
Aspidoscelis
hyperythra
orange-throated
whiptail
None/WL/Covered Low-elevation coastal scrub,
chaparral, and valley–foothill
hardwood
High potential to occur. Suitable coastal
scrub habitat and hardwood present.
CNDDB occurrence records from 1999
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-2
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
border the northern project site boundary
(CDFW 2025).
Aspidoscelis tigris
stejnegeri
San Diegan tiger
whiptail
None/SSC/None Hot and dry areas with sparse
foliage, including chaparral,
woodland, and riparian areas.
High potential to occur. Riparian woodland
is present. CNDDB occurrence records
from 2008 are located 4 miles from the
project site (CDFW 2025).
Coleonyx variegatus
abbotti
San Diego banded
gecko
None/SSC/None Rocky areas within coastal scrub
and chaparral
Not expected to occur. No rocky areas
present within the coastal scrub on the
project site to support this species. The
nearest CNDDB occurrence record is 3
miles from the project site, from 2017
(CDFW 2025).
Crotalus ruber red diamondback
rattlesnake
None/SSC/None Coastal scrub, chaparral, oak and
pine woodlands, rocky grasslands,
cultivated areas, and desert flats
Moderate potential to occur. Coastal scrub
and oak woodland present could provide
suitable habitat for this species. CNDDB
occurrence record from 1998 within 1
mile of the project site (CDFW 2025).
Phrynosoma
blainvillii
coast horned
lizard
None/SSC/Covered Open areas of sandy soil in valleys,
foothills, and semi-arid mountains
including coastal scrub, chaparral,
valley–foothill hardwood, conifer,
riparian, pine–cypress, juniper, and
annual grassland habitats
Moderate potential to occur. Coastal
scrub, riparian woodland, and grassland
with sandy soils present. Historic CNDDB
occurrence records from 1937 overlap the
project site; however, the project site is
currently fairly isolated (CDFW 2025).
Salvadora hexalepis
virgultea
coast patch-nosed
snake
FPT/SSC/None Brushy or shrubby vegetation;
requires small mammal burrows for
refuge and overwintering sites
Moderate potential to occur. Suitable
brushy or shrubby vegetation present. A
CNDDB occurrence record from 2004 is
located 4 miles from the project site
(CDFW 2025).
Thamnophis
hammondii
two-striped
gartersnake
None/SSC/None Streams, creeks, pools, streams
with rocky beds, ponds, lakes, vernal
pools
High potential to occur. San Diego River
on site provides suitable habitat. A CNDDB
occurrence record from 1998 is within 1
mile of the project site (CDFW 2025).
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-3
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Birds
Agelaius tricolor
(nesting colony)
tricolored
blackbird
BCC/SSC, ST/None Nests near freshwater, emergent
wetland with cattails or tules, but
also in Himalayan blackberry;
forages in grasslands, woodland,
and agriculture
Not expected to occur. Suitable nesting
habitat (emergent wetland, freshwater
marsh dominated by cattails) is present.
Historic CNDDB occurrence records from
1971 overlap the project site (CDFW
2025). However, based on 2021 protocol
surveys for this species throughout San
Diego County by AECOM, nesting colonies
are only present in eastern San Diego
County and were not present in the San
Diego River (AECOM 2021a,b).
Ammodramus
savannarum
(nesting)
grasshopper
sparrow
None/SSC/None Nests and forages in moderately
open grassland with tall forbs or
scattered shrubs used for perches
Low potential to occur. The amount and
distribution of non-native grassland on the
project site is limited but could provide
low-quality nesting and foraging habitat for
this species. Nearest CNDDB occurrence
record is 2 miles from the project site,
from 2007 (CDFW 2025).
Aquila chrysaetos
(nesting and
wintering)
golden eagle None/FP, WL/None Nests and winters in hilly, open/semi-open areas, including
shrublands, grasslands, pastures,
riparian areas, mountainous canyon
land, open desert rimrock terrain;
nests in large trees and on cliffs in
open areas and forages in open
habitats
Not expected to nest and low potential to
forage. Although limited nesting and
foraging habitat is present, the project site
is surrounded by development and lacks
quality nesting resources in open/semiopen areas.
Athene cunicularia
(burrow sites and
some wintering
sites)
burrowing owl BCC/SSC, SC/Covered Nests and forages in grassland, open scrub, and agriculture,
particularly with ground squirrel
burrows
Moderate potential to occur. Coastal scrub
and grassland present. The nearest
CNDDB occurrence record within 1 mile of
the project site is from 1921 and
extirpated; however there are occurrence
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-4
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
records from 2024 located two miles from
the project site (CDFW 2025).
Buteo swainsoni
(nesting)
Swainson's hawk None/ST/None Nests in open woodland and savanna, riparian, and in isolated
large trees; forages in nearby
grasslands and agricultural areas
such as wheat and alfalfa fields and
pasture
Not expected to occur. Although open
woodland and riparian habitat is present,
this species has been extirpated from
southern California (CDFW 2016).
Campylorhynchus
brunneicapillus
sandiegensis
(San Diego and
Orange Counties
only)
coastal cactus
wren
None/SSC/Covered Southern cactus scrub patches Not expected to occur. No suitable vegetation present.
Coturnicops
noveboracensis
yellow rail BCC/SSC/None Nesting requires wet marsh/sedge meadows or coastal marshes with
wet soil and shallow, standing water
Moderate potential to occur. Suitable
nesting habitat present (freshwater
marsh, shallow standing water) along San
Diego River in the project site. CNDDB
occurrence records from 1998 overlap the
project site (CDFW 2025).
Empidonax traillii
extimus
southwestern
willow flycatcher
FE/SE/None Nests in dense riparian habitats
along streams, reservoirs, or
wetlands; uses variety of riparian
and shrubland habitats during
migration
Not expected to occur. Although suitable
nesting and foraging habitat is present,
this species is considered extirpated from
the portion of the San Diego River within
the project site according to USFWS.
Icteria virens
(nesting)
yellow-breasted
chat
None/SSC/None Nests and forages in dense,
relatively wide riparian woodlands
and thickets of willows, vine tangles,
and dense brush
High potential to occur. Suitable nesting
and foraging habitat present; San Diego
River supports relatively wide riparian
thickets of willows and dense brush
throughout the project site. CNDDB
occurrence record from 1994 are located
4 miles from the project site (CDFW
2025).
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-5
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Polioptila californica
californica
coastal California
gnatcatcher
FT/SSC/Covered Nests and forages in various sage
scrub communities, often
dominated by California sagebrush
and buckwheat; generally avoids
nesting in areas with a slope of
greater than 40%; majority of
nesting at less than 1,000 feet
above mean sea level
Moderate potential to occur. Coastal sage
scrub is present within uplands along the
north and south project site boundaries.
There are CNDDB occurrence records from
1999 border the north project site
boundary (CDFW 2025). There is
designated critical habitat for this species
approximately 1 mile north and south of
the project site (USFWS 2025).
Setophaga petechia
(nesting)
yellow warbler None/SSC/None Nests and forages in riparian and oak woodlands, montane chaparral,
open ponderosa pine, and mixedconifer habitats
Considered present. Suitable nesting and
foraging habitat present throughout the
riparian areas along the San Diego River
in the project site. CNDDB occurrence
record from 1972 located two miles from
the project site (CDFW 2025). Although
not detected during the biological
reconnaissance surveys, Dudek biologists
have documented this species along the
San Diego River within Santee while
working on other projects.
Vireo bellii pusillus
(nesting)
least Bell's vireo FE/SE/Covered Nests and forages in low, dense riparian thickets along water or
along dry parts of intermittent
streams; forages in riparian and
adjacent shrubland late in nesting
season
Considered present. Suitable nesting and
foraging habitat present (riparian
woodlands, mulefat scrub, willow scrub)
along San Diego River. CNDDB occurrence
records from 2012 overlap the project site
(CDFW 2025). The western portion of the
project site overlaps designated critical
habitat for this species (USFWS 2025).
Although not detected during the
biological reconnaissance surveys, Dudek
biologists have documented this species
along the San Diego River within Santee
while working on other projects.
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-6
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Botaurus exilis
(nesting)
least bittern None/SSC/None Nests in freshwater and brackish marshes with dense, tall growth of
aquatic and semi-aquatic vegetation
Moderate potential to occur. Suitable
nesting habitat present. CNDDB
occurrence record from 2007 located 2
miles from the project site (CDFW 2025).
Mammals
Antrozous pallidus pallid bat None/SSC/None Grasslands, shrublands, woodlands, forests; most common in open, dry
habitats with rocky outcrops for
roosting, but also roosts in manmade structures and trees Moderate potential to occur. Suitable
habitat (grassland, woodlands, riparian
forest) is present although the site lacks
rocky outcrops for roosting; there are
CNDDB occurrence records from 1951
that overlap the project site (CDFW 2025).
Choeronycteris
mexicana
Mexican longtongued batNone/SSC/None Desert and montane riparian, desert succulent scrub, desert scrub, and
pinyon–juniper woodland; roosts in
caves, mines, and buildings
Not expected to occur. No roosting or
foraging habitat present.
Corynorhinus
townsendii
Townsend's bigeared batNone/SSC/None Mesic habitats characterized by coniferous and deciduous forests
and riparian habitat, but also xeric
areas; roosts in limestone caves and
lava tubes, man-made structures,
and tunnels
Moderate potential to occur. No roosting
habitat present but may forage over San
Diego River's riparian habitats throughout
the project site. CNDDB occurrence record
from 1991 located 5 miles from the
project site (CDFW 2025).
Dasypterus
xanthinus
western yellow bat None/SSC/None Valley–foothill riparian, desert riparian, desert wash, and palm
oasis habitats; below 2,000 feet
above mean sea level; roosts in
riparian and palms
High potential to occur. Suitable roosting
habitat (riparian) present. CNDDB
occurrence records from 1979 are
immediately east of the project site (CDFW
2025).
Eumops perotis
californicus
western mastiff
bat
None/SSC/None Chaparral, coastal and desert scrub,
coniferous and deciduous forest and
woodland; roosts in crevices in rocky
canyons and cliffs where the canyon
or cliff is vertical or nearly vertical,
trees, and tunnels
Moderate potential to occur. Costal scrub
and woodlands present could provide
roosting habitat. CNDDB occurrence
records from 2003 located 4 miles from
the project site (CDFW 2025).
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-7
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Neotoma lepida
intermedia
San Diego desert
woodrat
None/SSC/None Coastal scrub, desert scrub,
chaparral, cacti, rocky areas
Moderate potential to occur in costal
scrub throughout the project site, although
rocky areas are absent. CNDDB
occurrence record from 1998 within 1
mile of the project site (CDFW 2025).
Nyctinomops
femorosaccus
pocketed freetailed batNone/SSC/None Pinyon–juniper woodlands, desert scrub, desert succulent shrub,
desert riparian, desert wash, alkali
desert scrub, Joshua tree, and palm
oases; roosts in high cliffs or rock
outcrops with drop-offs, caverns,
and buildings
Moderate potential to occur. No roosting
habitat present; however, CNDDB
occurrence records from 1990 overlap the
project site and there is riparian/wash
habitat along the project site that can be
seasonally arid. Multiple CNDDB
occurrence records from 1983-2003
located 3 to 5 miles from the project site
(CDFW 2025).
Nyctinomops
macrotis
Big free-tailed bat None/SSC/None Rocky areas; roosts in caves, holes in trees, buildings, and crevices on
cliffs and rocky outcrops; forages
over water
High potential to occur. May forage over
San Diego River in the project site. Not
expected to roost as no suitable roosting
habitat present. CNDDB occurrence
records from 1989 overlap the project site
(CDFW 2025).
Puma concolor
(southern California
Evolutionarily
Significant Unit)
Mountain lion None/SCE/None Scrubs, chaparral, riparian, woodland, and forest; rests in rocky
areas and on cliffs and ledges that
provide cover; most abundant in
riparian areas and brushy stages of
most habitats throughout California,
except deserts
Not expected to occur. The project site is
relatively flat and surrounded by urban
development, resulting in poor
connectivity and this species typically
avoids areas with human presence.
Taxidea taxus American badger None/SSC/None Dry, open, treeless areas; grasslands, coastal scrub,
agriculture, and pastures, especially
with friable soils
Low potential to occur. While coastal
scrub and grassland with friable soils are
present, the project site is surrounded by
development and habitat is marginal.
CNDDB occurrence records from an
unknown date are immediately east of the
project site (CDFW 2025).
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-8
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
Lasiurus frantzii western red bat None/SSC/None Forest, woodland, riparian, mesquite bosque, and orchards, including fig,
apricot, peach, pear, almond,
walnut, and orange; roosts in tree
canopy
Moderate potential to occur. Suitable
roosting habitat present (riparian forest
and woodland). A CNDDB occurrence
record from 2003 is located 4 miles from
the project site (CDFW 2025).
Invertebrates
Bombus crotchii Crotch's bumble
bee
None/SCE/Covered Open grassland and scrub
communities supporting suitable
floral resources.
Moderate potential to occur. Suitable
habitat present along with floral resources
for foraging. Nearest CNDDB occurrence
record is 2 miles from the project site,
from 2020 (CDFW 2025).
Branchinecta
sandiegonensis
San Diego fairy
shrimp
FE/None/Covered Vernal pools, non-vegetated
ephemeral pools
Not expected to occur. No suitable habitat
present.
Danaus plexippus
plexippus pop. 1
monarch -
California
overwintering
population
FPT/None/None Wind-protected tree groves with
nectar sources and nearby water
sources
Moderate potential to move through the
site. However, the City of Santee does not
contain any established overwintering
area for this species (Xerces Society
2025). No species-specific mitigation
would be required.
Euphydryas editha
quino
quino checkerspot
butterfly
FE/SCE/Covered Annual forblands, grassland, open
coastal scrub and chaparral; often
soils with cryptogamic crusts and
fine-textured clay; host plants
include Plantago erecta, P.
patagonica, and Antirrhinum
coulterianum, among others
Not expected to occur. No suitable soil
substrate containing host plants present.
Lycaena hermes Hermes copper FT/None/Covered Mixed woodlands, chaparral, and coastal scrub
Not expected to occur. Limited suitable
vegetation communities present. CNDDB
occurrence records from 2005 and 2007
located 3 miles from the project site
(CDFW 2025). There is designated critical
habitat for this species approximately 1
mile north of the project site (USFWS
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-9
JANUARY 2026
Scientific Name Common Name
Status*
(Federal/State/Sant
ee Draft MSCP) Habitat Potential to Occur
2025). This species requires spiny
redberry (Rhamnus crocea) near
buckwheat and no spiny redberry was
detected during the biological
reconnaissance surveys on the project
site.
Streptocephalus
woottoni
Riverside fairy
shrimp
FE/None/Covered Vernal pools, non-vegetated
ephemeral pools
Not expected to occur. No suitable habitat
present.
*Status Abbreviations:
FE: Federally listed as endangered
FT: Federally listed as threatened
FPE: Federally proposed for listing as endangered
FPT: Federally proposed for listing as threatened
FC: Federal candidate species (former Category 1 candidates) BCC: U.S. Fish and Wildlife Service Bird of Conservation Concern SSC: California Species of Special Concern
FP: California Fully Protected Species
WL: California Watch List Species
SE: State listed as endangered
ST: State listed as threatened
SC: State candidate for listing as threatened or endangered SCE: State candidate for listing as endangered
SCT: State candidate for listing as threatened
MSCP: Multiple Species Conservation Program (City of Santee Draft MSCP Subarea Plan).
APPENDIX E / SPECIAL-STATUS WILDLIFE SPECIES POTENTIAL TO OCCUR 18611 E-10
JANUARY 2026
References
AECOM. 2021a. TRBL 2021 Tricolored Blackbird Surveys Across Western San Diego County. file:///C:/Users/ knarel/Downloads/Summary%20of%202021%20SDMMP%20TRBL%20Surveys.pdf AECOM. 2021b. TRBL 2021 Tricolored Blackbird Survey Presentation. Prepared for SDMMP. March 2022. file:///C:/Users/knarel/Downloads/TRBL%20Presentation%20for%20SDMMP.V2.pdf California Department of Fish and Wildlife (CDFW). 2016. Status Review of Swainson's Hawk in California.
April 11, 2016. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=133622&inline CDFW. 2025. California Natural Diversity Database (CNDDB). Biogeographic Information Observation System (BIOS). Commercial Viewer. Version 6. https://wildlife.ca.gov/bios6 City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report.
U.S. Fish and Wildlife Service (USFWS). 2025. Critical Habitat for Threatened and Endangered Species. Map Viewer. Fws.maps.arcgis.com/home/webmap/viewer
Appendix C
Built Environment Are of Potential (APE) memorandum
MEMORANDUM
To: Dustin De Matteo, Hazard Mitigation Grant Program – Project Manager and Sandi Sawa, Director of Planning & Building/City Planner, City of Santee From: Nicole Frank, MSHP and Patricia Ambacher, MA, Dudek Subject: Recommended Cultural Area of Potential Effects for the San Diego River Fire Hazard Mitigation Plan Phase 1 Project
Date: April 2, 2026
cc: Keshia Montifolca, David Faith Erin Lucett, and Carey Fernandes, Dudek Attachment(s): Figure 1. Project Location Map; Figure 2. Recommended Area of Potential Effect 1 Introduction
This memorandum (memo) has been prepared by Dudek to provide a recommended Area of Potential Effects (APE) for cultural (archaeological and built environment) resources for the San Diego River Fire Hazard Mitigation Plan Phase 1 Project (project), which is subject to Section 106 of the National Historic Preservation Act (Section 106).
This memo includes the following components: (1) project location and description; (2) background research, which includes an analysis of historic aerials to identify the historic-age (over 45 years of age or older) properties adjacent to the proposed APE and a review of previously recorded built environment resources included in the California Historical Resources Information System (CHRIS), the Built Environment Resource Directory (BERD), and the San Diego County Historic Property List; (3) a justification for the recommended APE for Cultural Resources; and (4) references cited.
1.1 Project Location
The project site is located within the San Diego River corridor in the City of Santee, in eastern San Diego County (County). The project site is approximately 300 acres-across 64 parcels (Figure 1. Project Location). Treatment areas extend from Forester Creek at the western boundary and the eastern city limit with Lakeside, encompassing Mast Park West, Mast Park Wetland Restoration Area, Mast Park East, Mission Creek, Walker Trails Open Space, and Walker Preserve.
1.2 Project Description
The proposed project is a fuel reduction project located within the San Diego River corridor in the City of Santee.
Treatments may employ manual, mechanical, and targeted herbicide applications to address invasive species that elevate fire severity and threaten adjacent development and infrastructure. The fuel reduction activities include reducing non-native invasive species and dead vegetation and clearing debris across the wildland-urban interface (WUI) along the San Diego River. The sections of the project site, 0-50 feet from adjacent structures, will include 30% brush and vegetation removal, sections of the project site 50-100 feet from adjacent structures will include 50% removal. Individual trees and invasive plants will be 100% removed. The project is funded by the Federal Emergency Management Agency (FEMA) through the Hazard Mitigation Grant Program (HMGP-4610-917-009), with
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matching funds from the San Diego River Conservancy (SDRC) through Grant Agreement Number SDRG-B21-17 (SDRC Grant). The objective of the project is to reduce flammable vegetation, to reduce the risk of wildfire. 2 Background Research and Literature Review
2.1 Background Research
As part of due diligence effort for this memo, the following background research was conducted by Dudek Architectural Historian, Nicole Frank, MSHP, who meets the Secretary of the Interior’s Professional Qualifications Standards in architectural history and history.
Historical Aerials
Historic aerial photographs indicate that there are 78 historic-age (over 45 years of age or older) properties adjacent to the APE (NETR 2025).
Built Environment Resource Directory
The California Office of Historic Preservation (OHP) maintains the Built Environment Resource Directory (BERD), an inventory of built environment cultural resources that are processed through OHP’s office. A November 10, 2025, search of the BERD for San Diego County showed that none of the properties within the recommended APE or the historic-age properties adjacent to the APE were listed in the BERD.
San Diego County Historic Property List
On November 13, 2025, the San Diego County’s Historic Property List, which includes a list of the County’s designated historic resources from 2002 to 2024 and qualified historic unreinforced masonry buildings, was reviewed None of the properties within the recommended APE or the historic-age properties adjacent to the APE were listed as County historic properties or unreinforced masonry buildings. 3 Recommended Area of Potential Effects for
Cultural Resources
The establishment of an APE is part of the regulatory process to identify historic properties under Section 106. The APE is the study area delineated to assess the potential effects of the construction and operation of the Project for cultural resources. The APE encompasses the geographic area or areas within which the Project may directly or indirectly cause alterations in the character or use of historic properties if any such properties exist. The APE is influenced by the scale and nature of the project and may be different for different kinds of effects caused by the project (36 CFR § 800.16[d]). Project construction and implementation activities are considered significant if they would cause physical disturbance, demolition, destruction, relocation, or alteration of the resource or its immediate surroundings to the extent that the historic property would no longer be able to convey its significance. Current professional practice commonly groups activities that could cause such impacts into direct and indirect impact considerations. Direct impact considerations are commonly linked to physical project construction activities that
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might result in direct disturbance of an archaeological or historic built environment resource. This includes damage or demolition, non-compatible building or structural modifications, construction-related ground borne vibration, and property acquisitions. Impact considerations commonly considered indirect are largely related to project implementation or impacts to properties adjacent to a project site once the project is built. For example, alterations to the setting of a historically significant property, or historic district or noise considerations, or visual effects.
The proposed project does not include construction disturbance, damage or demolition, non-compatible building or structural modifications, construction-related ground borne vibration, or property acquisitions. The area of direct physical effects is shown in the project site boundary in Figure 1, Project Location, and is the proposed study area for archaeological resources. The current proposed vertical APE will not extend beyond 5 feet below ground surface.
Delineation of a recommended APE for built environment resources considered the proposed project activities in conjunction with historic-era built resources that are 45 years of age or older (those built or before 1980) that may sustain indirect impacts due to the construction or operation of the Project (Figure 2 Recommended Area of Potential Effect).1 As noted above, there are no historic-age properties or known built environment resources located within the project site. The additional considerations used to justify the delineation of the recommended APE for built environment resources include the following:
▪ The proposed project construction and implementation activities do not include any physical disturbance, demolition, destruction, relocation, or alteration of any historic resources. Additionally, there is no potential for construction-related ground borne vibration. The types of fuel treatment include manual (chainsaws, weed eaters, etc.), mechanical (masticators, chippers), and chemical (focused stump treatments on invasive species). None of these methods of fuel treatment will physically alter any building, structure, or object. Rather, the proposed project is focused on thinning and removing non-native brush and vegetation.
There is no potential for historic-era built environment resources to be directly affected based on the planned project activities.
▪ Buildings that are of historic age and adjacent to the project site include 78 residential, commercial, recreational, and industrial properties. Most of these properties were constructed circa 1960 (NETR 2025).
None of the historic age adjacent properties are listed in or determined to be eligible for listing in the National Register of Historic Places (NRHP), the California Register of Historical Resources (CRHR), or included in a local register of historical resources. Therefore, none of the adjacent properties are known historical properties.
▪ None of the 78 adjacent historic age properties’ primary elevations face toward the project site, rather their rear or side elevations face toward the San Diego River corridor. The corridor is currently densely vegetated.
If any of the adjacent historic age properties were to be evaluated under NRHP or CRHR eligibility and 1 While the 50-year threshold is generally used for listing resources in the National Register of Historic Places (NRHP) and the California Register of Historical resources (CRHR), the California Office of Historic Preservation’s (OHP) Instructions for Recording Historical Resources recommends recording “any physical evidence of human activities over 45 years . . . for the purposes of inclusion in the OHP’s filing system.” It also allows for the “documentation of resources less than 45 years . . . if those resources have been formally evaluated, regardless of the outcome of the evaluation.” Further, the guidance notes that the 45-year threshold recognizes that there is commonly a five-year lag between resource identification and the date that planning decisions are made, and thus it explicitly encourages the collection of data about resources that may become eligible for the NRHP or CRHR within that planning period. More restrictive criteria must be met before the resources included in OHP’s filing system are listed, found eligible for listing, or otherwise determined to be important in connection with federal, state, and local legal statuses and registration programs (OHP 1995: 2).
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integrity criteria, there is a low likelihood that the density of the vegetation along the rear or side of the property would be considered a character defining feature of its eligibility. The proposed project includes 30% brush and vegetation removal in sections of the project site 0-50 feet from structures and 50% removal in sections of the project site 50-100 feet from structures. The sense of open space and the viewshed of trees and the San Diego River would be retained. The proposed project would increase visibility from these properties to the San Diego River, which over time has become overgrown with vegetation. ▪ No noise or potential construction-related vibration effects are expected based on the planned project activities; as such, no geographic areas are under consideration for auditory and vibratory effects on historic properties.
▪ Since no reasonably foreseeable activities are associated with the undertaking that would occur later or be farther removed in the distance that could indirectly affect historic properties, the APE contains no geographic areas under consideration for indirect effects.
Considering these factors, the recommended APE is restricted to the proposed project site. Figure 2 Recommended Area of Potential Effects delineates and presents this APE.
In closing, this memorandum presents Dudek’s cultural resources staff recommendation for delineating the APE for this project. Dudek understands that under Section 106, the APE is delineated by the Federal Lead Agency and agreed to by the State Historic Preservation Officer (SHPO). Dudek will proceed with work on the cultural resources reporting for this project upon written approval of the APE provided by FEMA.
References
NETR (National Environmental Title Research, LLC). 2025. Historic aerial photographs: 1953, 1964, 1966, 1968, 1971, 1978, 1980, 1981, 1982, 1983, 1984, 1985, 1986, 1987, 1988, 1989, 1990, 1991, 1993, 1994, 1995, 1996, 1997, 1998, 1999, 2000, 2002, 2003, 2005, 2009, 2010, 2012, 2014, 2016, 2019, 2020, and 2022. Accessed November 10, 2025. https://www.historicaerials.com/viewer#.
OHP (Office of Historic Preservation). 1995. Instructions for Recording Historical Resources. March 1995. https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf.
ProjectBoundary
Date: 3/6/2026 User: jconway Path: Z:\Projects\j1861101\MAPDOC\Cultural\Built Environment\Santee Fire Built Environment.aprx Map: Figure 1 Project Location Layout: Figure 1 Project Location 0 1,000 2,000
n
Feet
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SOURCE: USGS 7.5-Minute Series La Mesa and El Cajon Quadrangles San Diego River Fire Hazard Mitigation Plan
Project Location
FIGURE 1
Mission Gorge Rd
N
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Recommended Area of Potential Effect
Date: 3/6/2026 User: jconway Path: Z:\Projects\j1861101\MAPDOC\Cultural\Built Environment\Santee Fire Built Environment.aprx Map: Figure 2 Recommended Area of Potential Effect Layout: Figure 2 Recommended Area of Potential Effect 0 500 1,000
n
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SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Plan
Recommended Area of Potential Effect
FIGURE 2
Appendix D
Cultural Resource Assessment Report
Cultural Resource Assessment Report
San Diego River Fire Hazard
Mitigation Program – Phase 1: Fuels
Treatment Plan
City of Santee, San Diego County, California
APRILJULY 2026
Prepared for:
CITY OF SANTEE
10601 Magnolia Avenue
Santee, California 92071
Prepared by:
David Faith, MA, RPA
Matthew DeCarlo, MA, RPA
Micah Hale, PhD, RPA
687 S. Coast Highway 101, Suite 110
Encinitas, California 92024
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National Archaeological Database
(NADB) Information
Authors: David Faith, MA, RPA, Matthew DeCarlo, MA, RPA, and Micah J. Hale, PhD, RPA Firm: Dudek
Project Proponent: City of Santee
Report Date: AprilJuly 2026
Report Title: Cultural Resource Assessment Report for the San Diego River Fire Hazard Mitigation Plan – Phase 1, City of Santee, San Diego County, California.
Type of Study: Cultural Resources Inventory and Evaluation Resources: CA-SDI-005050, CA-SDI-010148, CA-SDI-021860, SDRFM-DF-S-001, SDRFM-DF-S-002, SDRFM-DF-S-003, SDRFM-DF-I-001, SDRFM-DF-I-002, SDRFM-DF-I-003 USGS Quads: El Cajon and La Mesa, Township 15 South, Range 1West, Sections 21, 22, 23, 27, 28, and 29.
Area of Potential Effect: Approximately 300 acres
Permit Numbers: N/A
Keywords: Santee, San Diego River, Positive, intensive pedestrian survey; CA-SDI-005050, CA-SDI010148, CA-SDI-021860, SDRFM-DF-S-001, SDRFM-DF-S-002, SDRFM-DF-S-003, SDRFM-DF-I-001, SDRFM-DF-I-002, SDRFM-DF-I-003, lithic scatter, historical foundations SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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Executive Summary
Dudek was retained by the City of Santee (City) to conduct a cultural resources inventory in support of the proposed San Diego River Fire Hazard Mitigation Program - Phase 1: Fuels Treatment Plan (Project/Undertaking). The Project is a vegetative fuel reduction project located within the San Diego River corridor within the City’s boundary. The Project area is located within Township 15 South, Range 1W, Sections 21, 22, 23, 27, 28, and 29 as El Cajon and La Mesa, CA 7.5-minute USGS Quadrangle (Figure 1, Project Location Map). The primary goals of this study are the identification of archaeological, built environment, or tribal cultural resources (cultural resources) identified within the Project boundary that could be affected by ground-disturbing activities.
The City is the lead agency for the Project and would assure compliance with the California Environmental Quality Act (CEQA) and City’s regulations. The Project is funded by the Federal Emergency Management Agency (FEMA) through the Hazard Mitigation Grant Program (HMGP-4610-917-009), with matching funds from the San Diego River Conservancy (SDRC) through Grant Agreement Number SDRG-B21-17 (SDRC Grant). The California Governor’s Office of Emergency Services is acting as the lead federal agency on behalf of FEMA to assure compliance with Section 106 of the National Historic Preservation Act (NHPA) and the National Environmental Policy Act (NEPA).
The Project area of potential effect (APE) includes all areas with potential to incur ground disturbance as a result of Project implementation. This includes all areas within the San Diego River corridor where vegetative fuel reduction activities would take place. The Project APE measures approximately 300 acres (Figure 2, Area of Potential Effects Map). The current proposed vertical APE would not extend beyond 5 feet below ground surface.
A records search conducted at the South Coastal Information Center (SCIC) indicates that 43 previous studies overlap portions of the Project APE (Confidential Appendix B). The records search identified three prehistoric resources within the Project APE: CA-SDI-005050, CA-SDI-010148, and CA-SDI-021860. These three sites include a lithic scatter, a bedrock milling site with associated artifact scatter, and a habitation site deposits including fireaffected rock, lithic and ceramic artifacts, and midden soil.
On December 1, 2025, Dudek requested a search of the Sacred Lands Files from the Native American Heritage Commission (NAHC). A response letter was received via email from the NAHC on December 10, 2025, stating resources are listed in the Sacred Lands File for this area, but did not provide details on what the resource(s) are or where they are located. Dudek sent outreach letters to 17 Native American groups and individuals on December 29, 2025. To date, notwo Tribal responses have been received. Any future responses would be included in subsequent versions of this report.
Dudek archaeologists conducted an opportunistic and intensive-level pedestrian survey of the Project APE from December 8 to December 10, 2025, and on January 9, 2026. Red Tail Environmental Kumeyaay Native American monitor Justin Linton participated in the survey. Much of the Project APE was either covered in dense vegetation or standing water (the San Diego River). The survey team revisited known cultural resources CA-SDI-005050, CASDI-010148, and CA-SDI-021860, which intersect the APE. In addition, three new archaeological sites and three new isolates were identified within the Project APE including: SDRFM-DF-S-001, SDRFM-DF-S-002, SDRFM-DF-S003, SDRFM-DF-I-001, SDRFM-DF-I-002, and SDRFM-DF-I-003. These resources consist of a historic linear rock feature and refuse concentration, two historic poured concrete pads, a prehistoric bedrock milling feature, a flaked stone core, a piece of debitage, and a biface fragment.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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The current assessment evaluated CA-SDI-035815021860, SDRFM-DF-S-001, SDRFM-DF-S-002, SDRFM-DF-I001, SDRFM-DF-I-002, and SDRFM-DF-I-003 according federal criteria, CEQA, the National Register of Historic Places (NRHP), and the California Register of Historical Resources (CRHR), and were recommended not eligible for listing on the NRHP or the CRHR, are not independently significant in accordance with criteria identified in 36 CFR
60.4, and are not significant under CEQA. As such, no further archaeological review or avoidance measures are recommended.
The current assessment evaluated and recommended SDRFM-DF-S-003 not eligible for listing on the NRHP or CRHR, is not independently significant in accordance with criteria identified in 36 CFR 60.4, and is not significant under CEQA. Based on archival research and reports, it is likely that SDRFM-DF-S-003 is a milling feature that had been a transplant from another previously recorded site, due to the significant grading and development in the area. While this milling feature was likely moved to its current location, SDRFM-DF-S-003 may have some Native American cultural value. As such, Dudek recommends that damage to the milling feature itself be avoided during prescribed fuel reducing treatments.
CA-SDI-005050 has not been evaluated for listing on the NRHP or CRHR. Due to the surface scatter and features, and the potential for significant buried deposits, surficial prescribed fuel reducing treatments have the potential to impact or adversely affect this resource. Dudek recommends that this resource be treated as NRHP and CRHR eligible under criteria D/4, as formal evaluations have not been conducted, and is therefore treated as a historic property. It is recommended that the Project completely avoid the resource.
The NRHP and CRHR eligibility status of CA-SDI-010148 is inconclusive since previous testing within the current APE resulted in recommendations of no significance (Caltrans 1985, 1986) but testing in the western extension resulted in recommendations that the entire site boundary be subject to data recovery (Gallegos & Associates 1993). Further testing within the current Project APE would be required to determine the NRHP and CRHR eligibility status. Dudek recommends that this resource be treated as NRHP and CRHR eligible under criteria D/4, as formal evaluations have not been conducted, and is therefore treated as a historic property. It is recommended that the Project completely avoid the resource.
SDRFM-DF-S-002 has not been evaluated for listing on the NRHP or CRHR. Due to the historic period features, and the potential for significant buried deposits, surficial prescribed fuel reducing treatments have the potential to impact or adversely affect this resource. Dudek recommends that this resource be treated as NRHP and CRHR eligible under criteria D/4, as formal evaluations have not been conducted, and is therefore treated as a historic property. It is recommended that the Project completely avoid the resource.
The proposed mitigation measures for the project include: MM CR-1, place temporary work buffers around the following archaeological sites: CA-SDI-005050, CA-SDI-010148, SDRFM-DF-S-002, and SDRFM-DF-S-003; MM CR2, implement archaeological monitoring during the proposed vegetation fuel management (which includes Tribal monitoring and an inadvertent cultural resources discovery plan); and MM CUL-3 requires that if human remains are discovered, all work in the vicinity of the find shall stop and the County Coroner and the City shall be notified immediately.
Based on the results and recommendations provided, this study finds that, with the proposed mitigation measures, the Project would have no impact on significant resources under CEQA and no adverse effect to historic properties under Section 106 of the NHPA.
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Table of Contents
SECTION PAGE NO.
National Archaeological Database (NADB) Information...................................................................................................i Executive Summary .......................................................................................................................................................... iii 1 Introduction ..........................................................................................................................................................1
1.1 Project Location......................................................................................................................................1
1.2 Project Description .................................................................................................................................1
1.3 Project Area of Potential Effects............................................................................................................2
1.4 Project Personnel ...................................................................................................................................2 2 Regulatory Setting................................................................................................................................................7
2.1 Federal ....................................................................................................................................................7
2.1.1 Section 106 of the National Historic Preservation Act...........................................................7
2.2 State........................................................................................................................................................8
2.2.1 The California Register of Historical Resources (Public Resources Code Section 5020 et seq.)...........................................................................................................................................8
2.2.2 Native American Historic Cultural Act (California Public Resources Code Section 5097 et seq.)...........................................................................................................................................8
2.2.3 California Native American Graves Protection and Repatriation Act.....................................9
2.2.4 California Environmental Quality Act Statues and Guidelines ...............................................9
2.2.5 California Health and Safety Code........................................................................................ 12
2.3 City of Santee General Plan................................................................................................................ 13 3 Setting................................................................................................................................................................ 15
3.1 Environmental and Geological Setting............................................................................................... 15
3.2 Cultural Context................................................................................................................................... 15
3.2.1 Paleoindian (pre-5500 BC).................................................................................................... 15
3.2.2 Archaic (8000 BC–AD 500) .................................................................................................. 16
3.2.3 Late Prehistoric (AD 500–1750) .......................................................................................... 17
3.2.4 Ethnohistoric (post-AD 1750) ............................................................................................... 18
3.2.5 The Historic Period (post-AD 1542)...................................................................................... 21
3.2.6 Historical Overview of the City of Santee ............................................................................. 22 4 Methods............................................................................................................................................................. 25
4.1 Records Search Methods.................................................................................................................... 25
4.2 Native American Heritage Commission Sacred Lands File Search.................................................. 25
4.3 Cultural Resources Pedestrian Survey............................................................................................... 25 5 Results............................................................................................................................................................... 27 SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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5.1 Records Search Results...................................................................................................................... 27
5.1.1 Previously Conducted Cultural Resource Studies................................................................ 27
5.1.2 Previously Recorded Cultural Resources ............................................................................. 32
5.2 Map and Historic Aerial Photography Research................................................................................ 38
5.3 Native American Heritage Commission Sacred Lands File Search and Native American Outreach .............................................................................................................................................................. 40
5.4 Cultural Resources Survey.................................................................................................................. 40
5.4.1 Previously Identified Cultural Resources.............................................................................. 43
5.4.2 Newly Identified Cultural Resources in the Project APE ...................................................... 48 6 Findings and Recommendations ..................................................................................................................... 51
6.1 Resource Evaluation ........................................................................................................................... 51
6.2 Effects Analysis and Recommendations............................................................................................ 54
6.3 Mitigation Measures ........................................................................................................................... 56 7 References Cited............................................................................................................................................... 59 TABLES
1 Previously Conducted Technical Studies Within the APE ............................................................................... 27 2 Previously Recorded Cultural Resources Within 1.0-Mile of the Project APE ............................................... 33 3 Historic Topographic Map Review.................................................................................................................... 38 4 Aerial Photograph Review................................................................................................................................. 39 5 Milling Elements Within CA-SDI-005050......................................................................................................... 44 6 Recorded Artifacts Within CA-SDI-005050...................................................................................................... 44 7 Cultural Resources Management Recommendations.................................................................................... 55
EXHIBITS
1 View of Western Project APE; View West ......................................................................................................... 41 2 View of the Central Component of the Project APE; View West...................................................................... 42 3 View of the Eastern Component of the Project APE; View East...................................................................... 43 4 CA-SDI-005050 Site Overview; View West/Southwest................................................................................... 45 5 Overview of BRM-06/MS-02/MS-03 (All Three Milling Spots Have Flags Atop Them) at CA-SDI-005050; View Southwest................................................................................................................................................. 46 6 Quartzite Primary Flake Recorded Inside Recorded Boundary of CA-SDI-010148....................................... 47 7 CA-SDI-021860 Overview; View West.............................................................................................................. 48 SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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FIGURES
1 Project Location Map...........................................................................................................................................3 2 Area of Potential Effects Map..............................................................................................................................5
APPENDICES
A Project Personnel
B (Confidential) South Coastal Information Center Records Search Results C Native American Heritage Commission and Native American Outreach D (Confidential) Cultural Resources within APE
E (Confidential) Department of Parks and Recreation Forms SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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1 Introduction
Dudek was retained by the City of Santee (City) to conduct a cultural resources inventory in support of the proposed San Diego River Fire Hazard Mitigation Program - Phase 1: Fuel Treatment Plan (Project/Undertaking). The Project is a vegetative fuel reduction project located within the San Diego River corridor within the City’s boundary. The primary goals of this study are the identification of archaeological, built environment, or tribal cultural resources (cultural resources) identified within the Project boundary that could be affected by ground-disturbing activities. The City is the lead agency for the Project and would assure compliance with the California Environmental Quality Act (CEQA) and City regulations. The Project is funded by the Federal Emergency Management Agency (FEMA) through the Hazard Mitigation Grant Program (HMGP-4610-917-009), with matching funds from the San Diego River Conservancy (SDRC) through Grant Agreement Number SDRG-B21-17 (SDRC Grant). The California Governor’s Office of Emergency Services is acting as the lead federal agency on behalf of FEMA to assure compliance with Section 106 of the National Historic Preservation Act (NHPA) and the National Environmental Policy Act (NEPA).
1.1 Project Location
The approximately 300-acre Project siteAPE is located within the San Diego River corridor within the City’s boundaries.
The Project area is located within Township 15 South, Range 1W, Sections 21, 22, 23, 27, 28, and 29 as El Cajon and La Mesa, CA 7.5-minute USGS Quadrangle (Figure 1, Project Location Map). Treatment areas extend from Forester Creek at the western project boundary to the City border with the unincorporated Lakeside community in the east, including the open space areas of Mast Park West, Mast Park Wetland Restoration Area, Mast Park East, Mission Creek, Walker Trails Open Space, and Walker Preserve. Vehicle access to the Project is via North Magnolia Avenue, the Lakeside Sports Park, and Mast Park. Multiple pedestrian access paths as well as residential and commercial developments border the Project.
1.2 Project Description
The proposed Project is a vegetative fuel reduction project located within the San Diego River corridor in the City of Santee. Treatments may employ manual (hand tools, chainsaws), mechanical (masticators, chippers), and targeted herbicide applications (applied to cut stumps of sprouting species) to address invasive species that elevate fire severity and threaten adjacent development and infrastructure. The fuel reduction activities include reducing nonnative invasive species and dead vegetation and clearing debris across the wildland-urban interface (WUI) along the San Diego River. Zone 1 encompasses the 0 to 50-foot area immediately adjacent to structures, would include the thinning of shrubs to reduce horizontal continuity to a residual surface of approximately 30%. Zone 2 encompasses 50-100-foot areas, which lies beyond the immediate structure buffer, and the thinning of shrubs to reduce horizontal continuity to a residual surface coverage of approximately 50%. Trees with extensive dead or desiccated material and invasive plants would be 100% removed. Zone 3 encompasses the broader vegetated areas of the river corridor (outside Zones 1 and 2), including most riparian zones, floodplain terraces, and open space areas such as portions of Mast Park and Walker Preserve. Vegetation management in Zone 3 is focused on treatment or removal of non-native species, dead or dying vegetation, and debris, including accumulations deposited during storm events. Removal and other treatment of live and healthy native species would not occur within Zone 3. The objective of the project is to reduce flammable vegetation, to reduce the risk of wildfire.
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1.3 Project Area of Potential Effects
The establishment of the Project area of potential effect (APE) is part of the regulatory process to identify historic properties under Section 106. The Project APE is the study area delineated to assess the potential effects of the construction and operation of the Project for cultural resources. The APE encompasses the geographic area or areas within which the proposed vegetative fuel reduction activities may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. The APE for the Project includes all areas with potential to incur ground disturbance as a result of Project implementation. This includes all areas within the San Diego River corridor where fuel reduction activities would take place. The Project APE measures approximately 300 acres. The current proposed vertical APE would not extend beyond 5 feet below ground surface. The depth of ground disturbance is not based on zone and is instead based on a worst-case scenario where root systems would be pulled out of the ground.
1.4 Project Personnel
Matthew DeCarlo, MA, RPA served as project manager and Principal Investigator and co-authored the technical report. David Faith, MA, RPA, acted as field director and co-authored the technical report. Dudek archaeologists Makayla Murillo and Anna Mendelsohn participated in the field survey. Justin Linton from Red Tail Environmental acted as the Kumeyaay Native American Monitor and participated in the pedestrian survey. Resumes of personnel are provided in Appendix A.
Area of Potential Effects
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Figure 1
Project Location Map
San Diego River Fire Hazard Mitigation Plan
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San Diego River Fire Hazard Mitigation Plan
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FIGURE 2
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2 Regulatory Setting
The treatment of cultural resources located within the Project APE is governed by federal, state, and local laws and regulations. As a whole, the laws and regulations seek to avoid impacts to cultural resources and affects to historic properties, and, when avoidance is not feasible, to minimize or mitigate those impacts and effects.
2.1 Federal
2.1.1 Section 106 of the National Historic Preservation Act The Project requires compliance with Section 106 of the NHPA of 1966, as amended, (54 USC 306108) and its implementing regulations (36 CFR 800) because the Project is partially federally-funded.
The NHPA established the NRHP and the President’s Advisory Council on Historic Preservation (ACHP), and provided that states may establish State Historic Preservation Officers (SHPOs) to consult with federal agencies on undertakings that may affect historic properties. Most significantly for federal agencies responsible for managing cultural resources, Section 106 of the Act directs that “[t]he head of any Federal agency having direct or indirect jurisdiction over a proposed Federal or federally assisted undertaking in any State and the head of any Federal department or independent agency having authority to license any undertaking shall, prior to the approval of the expenditure of any Federal funds on the undertaking or prior to the issuance of any license, as the case may be, take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for inclusion in the NRHP.” Section 106 also affords the ACHP a reasonable opportunity to comment on the undertaking (54 USC 306108).
Title 36 Code of Federal Regulations, Part 800 (36 CFR 800)1, implements Section 106 of the NHPA (ACHP 2004).
It defines the steps necessary to identify historic properties (those cultural resources listed in or eligible for listing in the NRHP), including consultation with federally recognized Indian tribes to identify resources of concern to them; to determine whether or not they may be adversely affected by a proposed undertaking; and the process for avoiding, minimizing, or mitigating adverse effects. The content of 36 CFR 60.4 also defines criteria for determining eligibility for listing in the NRHP (NPS 2012). Cultural resources may be considered eligible for listing if they possess integrity of location, design, setting, materials, workmanship, feeling, and association. A resource may be considered historically significant and eligible for NRHP listing if it is found to meet one of the following criteria:
It is associated with events that have made a significant contribution to the broad patterns of local or regional history; or
It is associated with the lives of persons significant to our past; or It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values, or that represents a significant and distinguishable entity whose components may lack individual distinction; or It has yielded, or has the potential to yield, information important to the prehistory or history. 1 The United States Army Corps of Engineers’ Appendix C criteria for the “project review area” is subsumed within the APE defined here, see 33 C.F.R. Part 325, Appendix C, para.1.g. Notably, Appendix C is still in effect though it's been pending rescission for over a year.
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2.2 State
2.2.1 The California Register of Historical Resources (Public Resources Code Section 5020 et seq.)
In California, the term “historical resource” includes but is not limited to “any object, building, structure, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (California Public Resources Code Section 5020.1(j)). In 1992, the California legislature established CRHR “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” (California Public Resources Code Section 5024.1(a)). A resource is eligible for listing in the CRHR if the State Historical Resources Commission determines that it is a significant resource and that it meets any of the following NRHP criteria per California Public Resources Code Section 5024.1(c)):
1. Associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage.
2. Associated with the lives of persons important in our past.
3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.
4. Has yielded, or may be likely to yield, information important in prehistory or history.
Resources less than 50 years old are not considered for listing in the CRHR but may be considered if it can be demonstrated that sufficient time has passed to understand the historical importance of the resource (see 14 CCR 4852(d)(2)).
The CRHR protects cultural resources by requiring evaluations of the significance of prehistoric and historic resources. The criteria for the CRHR are nearly identical to those for the NRHP, and properties listed or formally designated as eligible for listing on the NRHP are automatically listed on the CRHR, as are the state landmarks and points of interest. The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys. The State Historic Preservation Officer maintains the CRHR.
2.2.2 Native American Historic Cultural Act (California Public Resources Code Section 5097 et seq.)
The Native American Historic Resources Protection Act (Public Resources Code Section 5097, et seq.) addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American human remains or associated burial items are discovered during construction of a Project; and establishes the NAHC to resolve disputes regarding the disposition of such remains. In addition, the Native American Historic Resource Protection Act makes it a misdemeanor punishable by up to 1 year in jail to deface or destroy a Native American historic or cultural site that is listed or may be eligible for listing in the CRHR.
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2.2.3 California Native American Graves Protection and
Repatriation Act
The California Native American Graves Protection and Repatriation Act (California Repatriation Act), enacted in 2001, requires all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and repatriation of these items to the appropriate tribes.
2.2.4 California Environmental Quality Act Statues
and Guidelines
As described further below, the following CEQA statutes and CEQA Guidelines are relevant to the analysis of archaeological and historic resources:
1. California Public Resources Code Section 21083.2(g): Defines “unique archaeological resource.”
2. California Public Resources Code Section 21084.1 and CEQA Guidelines Section 15064.5(a): Defines historical resources. In addition, CEQA Guidelines Section 15064.5(b) defines the phrase “substantial adverse change in the significance of an historical resource”. It also defines the circumstances when a Project would materially impair the significance of a historical resource.
3. California Public Resources Code Section 5097.98 and CEQA Guidelines Section 15064.5(e): These statutes set forth standards and steps to be employed following the accidental discovery of human remains in any location other than a dedicated ceremony.
4. California Public Resources Code Sections 21083.2(b)-(c) and CEQA Guidelines Section 15126.4: These statutes and regulations provide information regarding the mitigation framework for archaeological and historic resources, including options of preservation-in-place mitigation measures and identify preservationin-place as the preferred manner of mitigating impacts to significant archaeological sites.
Under CEQA, a Project may have a significant effect on the environment if it may cause “a substantial adverse change in the significance of an historical resource” (California Public Resources Code, Section 21084.1; 14 CRR 15064.5(b)). An “historical resource” is any site listed or eligible for listing in the CRHR. The CRHR listing criteria are intended to examine whether the resource in question: (a) is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; (b) is associated with the lives of persons important in our past; (c) embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or (d) has yielded, or may be likely to yield, information important in pre-history or history.
The term “historical resource” also includes any site described in a local register of historic resources or identified as significant in a historical resources survey (meeting the requirements of California Public Resources Code, Section 5024.1(q)).
CEQA also applies to “unique archaeological resources.” California Public Resources Code, Section 21083.2(g), defines a “unique archaeological resource” as any archaeological artifact, object, or site about which it can be SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.
CEQA was amended in 2014 through Assembly Bill 52, which created a new category of “tribal cultural resources” that must be considered under CEQA, and applies to all projects that file a notice of preparation (NOP) or notice of negative declaration or mitigated negative declaration on or after July 1, 2015. AB 52 requires lead agencies to provide notice to and begin consultation with California Native American tribes that are traditionally and culturally affiliated with the geographic area of a project if that tribe has requested, in writing, to be kept informed of projects by the lead agency prior to the determination whether a negative declaration, mitigated negative declaration, or environmental impact report would be prepared. If a tribe requests consultation within 30 days upon receipt of the notice, the lead agency must consult with the tribe. The bill also specifies mitigation measures that may be considered to avoid or minimize impacts on tribal cultural resources. Specifically, California Public Resources Code Section 21074 provides the following guidance
(a) “Tribal Cultural Resources are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of Cultural Resources.
(B) Included in a local register of cultural resources as defined in subdivision (k) of §5020.1. (2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of §5024.1. In applying the criteria set forth in subdivision (c) of §5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe. (b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the extent that the landscape is geographically defined in terms of the size and scope of the landscape. (c) A historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archeological resource” as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision (a).
All historical resources and unique archaeological resources – as defined by statute – are presumed to be historically or culturally significant for purposes of CEQA (California Public Resources Code, Section 21084.1; 14 CCR 15064.5(a)). The lead agency is not precluded from determining that a resource is a historical resource even if it does not fall within this presumption (California Public Resources Code, Section 21084.1; 14 CCR 15064.5(a)).
A site or resource that does not meet the definition of “historical resource” or “unique archaeological resource” is not considered significant under CEQA and need not be analyzed further (California Public Resources Code, Section 21083.2(a); 14 CCR 15064.5(c)(4)).
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Under CEQA and significant cultural impact results from a “substantial adverse change in the significance of an historical resource [including a unique archaeological resource]” due to the “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (14 CCR 15064.5(b)(2); California Public Resources Code Section 5020.1(q)).
In turn, the significance of a historical resource is materially impaired when a Project:
1. Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register; or
2. Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the Project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
3. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register as determined by a lead agency for purposes of CEQA.
CEQA Guidelines Section PRC Section 21083.2(b)
Pursuant to these sections, CEQA first evaluates whether a Project site contains any “historical resources,” then assesses whether that Project would cause an adverse effect to the significance of a historical resource.
When a Project significantly affects a unique archaeological resource, CEQA imposes special mitigation requirements. Specifically, “if it can be demonstrated that a Project will cause damage to a unique archaeological resource, the lead agency may require reasonable efforts to be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. Examples of that treatment, in no order of preference, may include, but are not limited to, any of the following:
Planning construction to avoid archaeological sites.
Deeding archaeological sites into permanent conservation easements.
Capping or covering archaeological sites with a layer of soil before building on the sites.
Planning parks, greenspace, or other open space to incorporate archaeological sites.” California Public Resources Code, Section 21083.2(b)(1)-(4).
If these “preservation in place” options are not feasible, mitigation may be accomplished through data recovery (California Public Resources Code, Section 21083.2(d); 14 CCR 15126.4(b)(3)(C)). California Public Resources Code, Section 21083.2(d) states that “excavation as mitigation shall be restricted to those parts of the unique archeological resource that would be damaged or destroyed by the Project. Excavation as mitigation shall not be required for a unique archeological resource if the lead agency determines that testing or studies already completed have adequately recovered the scientifically consequential information from and about the resource, if this determination is documented in the environmental impact report.” SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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These same requirements are set forth in slightly greater detail in CEQA Guidelines Section 15126.4(b)(3), as follows:
Preservation in place is the preferred manner of mitigating impacts to archeological sites.
Preservation in place maintains the relationship between artifacts and the archeological context. Preservation may also avoid conflict with religious or cultural values of groups associated with the site.
Preservation in place may be accomplished by, but is not limited to, the following:
1. Planning construction to avoid archeological sites;
2. Incorporation of sites within parks, greenspace, or other open space;
3. Covering the archeological sites with a layer of chemically stable soil before building tennis courts, parking lots, or similar facilities on the site[; and]
4. Deeding the site into a permanent conservation easement.
When data recovery through excavation is the only feasible mitigation, a data recovery plan, which makes provision for adequately recovering the scientifically consequential information from and about the historical resource, shall be prepared and adopted prior to any excavation being undertaken.
Note that, when conducting data recovery, “if an artifact must be removed during Project excavation or testing, curation may be an appropriate mitigation.” (Ibid.) However, “data recovery shall not be required for an historical resource if the lead agency determines that testing or studies already completed have adequately recovered the scientifically consequential information from and about the archeological or historic resource, provided that determination is documented in the EIR and that the studies are deposited with the California Historical Resources Regional Information Center” (14 CCR 15126.4(b)(3)(D)).
2.2.5 California Health and Safety Code
CEQA Guidelines Section 15064.5 assigns special importance to human remains and specifies procedures to be used when Native American remains are discovered. As described below, these procedures are detailed in California Public Resources Code, Section 5097.98.
California law protects Native American burials, skeletal remains, and associated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains. California Health and Safety Code Section 7050.5 requires that if human remains are discovered in any place other than a dedicated cemetery, no further disturbance or excavation of the site or nearby area reasonably suspected to contain human remains shall occur until the County coroner has examined the remains (Section 7050.5b). California Public Resources Code, Section 5097.98, also outlines the process to be followed in the event that remains are discovered. If the coroner determines or has reason to believe the remains are those of a Native American, the coroner must contact the Native American Heritage Commission (NAHC) within 24 hours (Section 7050.5c). The NAHC would notify the Most Likely Descendant (MLD). With the permission of the landowner, the MLD may inspect the site of discovery.
The inspection must be completed within 48 hours of notification of the MLD by the NAHC. The MLD may recommend means of treating or disposing of, with appropriate dignity, the human remains and items associated with Native Americans.
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2.3 City of Santee General Plan
Divided into nine elements, the Santee General Plan is a statement of intent by the City as to the future development of the community. This is accomplished through objectives and policies that serve as a long-term policy guide for physical, economic, and environmental growth. The Conservation Element of the Santee General Plan discusses water resources, land resources, archaeological and cultural resources, biological resources, and open space.
Section 4.3 of the Conservation Element discusses archaeological, cultural, and historic resources known to be within the City. The goal of the Conservation Element is to conserve open space, natural, and cultural resources.
The following objective and policies contained in the Conservation Element of the Santee General Plan are relevant to the analysis found in this section:
- Objective 8.0: Preserve significant cultural resources. - Policy 8.1. The City shall require either the preservation of significant historic or prehistoric sites, or the professional retrieval of artifacts prior to the development of a site, consistent with the provisions of the California Environmental Quality Act. Preservation may include various measures including avoidance, preservation in place, incorporation into open space, or covering or capping.
The type of preservation would depend upon the nature and significance of the archaeological resource and the practical requirements of the proposed land use. - Policy 8.2. The City should require curation of any recovered artifacts as a condition of any cultural resources mitigation program.
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3 Setting
3.1 Environmental and Geological Setting
The Project APE is located within an urbanized portion of the City in eastern San Diego County and encompasses upland, riparian, and wetland vegetation communities associated with the San Diego River. The western extent of the Project APE begins approximately 0.25 mile north of the intersection of State Routes 52 and 125. The immediate vicinity of the Project APE includes residential development, schools, and parks to the north, commercial development and public facilities (including Las Colinas Detention Facility) to the south, Carlton Oaks Country Club to the west, and State Route 67 to the east. The Project APE and surrounding suburbs are generally flat, with the San Diego River running east–west through the center between wetland, riparian, and disturbed vegetation.
Elevations range from approximately 310 to 360 feet above mean sea level. Vegetation within the Project APE and surrounding vicinity is characterized by a mix of natural as well as non-native vegetation communities and land cover types.
3.2 Cultural Context
Available evidence indicates that continuous human occupation in the San Diego region spans the last 10,000 years. Various attempts to parse out variability in archaeological assemblages over this broad timeframe have led to the development of several cultural chronologies; some of these are based on geologic time, most are based on temporal trends in archaeological assemblages, and others are interpretive reconstructions. Each of these reconstructions describes essentially similar trends in assemblage composition in more or less detail. This research employs a common set of generalized terms used to describe chronological trends in assemblage composition: Paleoindian (pre-5500 BC), Archaic (8000 BC–AD 500), Late Prehistoric (AD 500–1750), and Ethnohistoric (post-AD 1750). It is important to note that Kumeyaay aboriginal lifeways did not cease within San Diego County and Baja California at European contact. Protohistoric refers to the chronological trend of continued Native American aboriginal lifeways at the cusp of the recorded historic period in the Americas.
3.2.1 Paleoindian (pre-5500 BC)
Evidence for Paleoindian occupation in coastal Southern California is tenuous, especially considering the fact that the oldest dated archaeological assemblages look nothing like the Paleoindian artifacts from the Great Basin. One of the earliest dated archaeological assemblages in coastal Southern California (excluding the Channel Islands) derives from SDI-4669/W-12, in La Jolla. A human burial from SDI-4669 was radiocarbon dated to 9,590–9,920 years before present (95.4% probability) (Hector 1984). The burial is part of a larger site complex that contained more than 29 human burials associated with an assemblage that fits the Archaic profile (i.e., large amounts of groundstone, battered cobbles, and expedient flake tools). In contrast, typical Paleoindian assemblages include large-stemmed projectile points, high proportions of formal lithic tools, bifacial lithic reduction strategies, and relatively small proportions of groundstone tools. Prime examples of this pattern are sites that were studied by Davis (1978) on China Lake Naval Air Weapons Station near Ridgecrest, California. These sites contained fluted and unfluted stemmed points and large numbers of formal flake tools (e.g., shaped scrapers, blades). Other typical Paleoindian sites include the Komodo site (MNO-679)—a multicomponent fluted point site, and MNO-680—a single component Great Basined Stemmed point site (Basgall et al. 2002). At MNO-679 and MNO-680, groundstone tools were rare while finely made projectile points were common.
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Turning back to coastal Southern California, the fact that some of the earliest dated assemblages are dominated by processing tools runs counter to traditional notions of mobile hunter–gatherers traversing the landscape for highly valued prey. Evidence for the latter—that is, typical Paleoindian assemblages—may have been located along the coastal margin at one time, prior to glacial desiccation and a rapid rise in sea level during the early Holocene (pre-7500 BP) that submerged as much as 1.8 kilometer of the San Diego coastline. If this were true, however, it would also be expected that such sites would be located on older landforms near the current coastline. Some sites, such as SDI-210 along Agua Hedionda Lagoon, contained stemmed points similar in form to Silver Lake and Lake Mojave projectile points (pre-8000 BP) that are commonly found at sites in California’s high desert (Basgall and Hall 1990). SDI-210 yielded one corrected radiocarbon date of 8520–9520 BP (Warren et al. 2004). However, sites of this nature are extremely rare and cannot be separated from large numbers of milling tools that intermingle with old projectile point forms.
Warren et al. (2004) claimed that a biface manufacturing tradition present at the Harris site complex (SDI-149) is representative of typical Paleoindian occupation in the San Diego region that possibly dates between 10,365 and 8200 BC (Warren et al. 2004, p. 26). Termed San Dieguito (Rogers 1945), assemblages at the Harris site are qualitatively distinct from most others in the San Diego region because the site has large numbers of finely made bifaces (including projectile points), formal flake tools, a biface reduction trajectory, and relatively small amounts of processing tools (Warren 1964, 1968). Despite the unique assemblage composition, the definition of San Dieguito as a separate cultural tradition is hotly debated. Gallegos (1987) suggested that the San Dieguito pattern is simply an inland manifestation of a broader economic pattern. Gallegos’ interpretation of San Dieguito has been widely accepted in recent years, in part because of the difficulty in distinguishing San Dieguito components from other assemblage constituents. In other words, it is easier to ignore San Dieguito as a distinct socioeconomic pattern than it is to draw it out of mixed assemblages.
The large number of finished bifaces (i.e., projectile points and non-projectile blades), along with large numbers of formal flake tools at the Harris site complex, is very different than nearly all other assemblages throughout the San Diego region, regardless of age. Warren et al. (2004) made this point, tabulating basic assemblage constituents for key early Holocene sites. Producing finely made bifaces and formal flake tools implies that relatively large amounts of time were spent for tool manufacture. Such a strategy contrasts with the expedient flake-based tools and cobble-core reduction strategy that typifies non-San Dieguito Archaic sites. It can be inferred from the uniquely high degree of San Dieguito assemblage formality that the Harris site complex represents a distinct economic strategy from non-San Dieguito assemblages.
If San Dieguito truly represents a distinct socioeconomic strategy from the non-San Dieguito Archaic processing regime, its rarity implies that it was not only short-lived, but that it was not as economically successful as the Archaic strategy. Such a conclusion would fit with other trends in Southern California deserts, wherein hunting-related tools are replaced by processing tools during the early Holocene (Basgall and Hall 1990).
3.2.2 Archaic (8000 BC–AD 500)
The more than 1,500-year overlap between the presumed age of Paleoindian occupations and the Archaic period highlights the difficulty in defining a cultural chronology in the San Diego region. If San Dieguito is the only recognized Paleoindian component in the San Diego region, then the dominance of hunting tools implies that it derives from Great Basin adaptive strategies and is not necessarily a local adaptation. Warren et al. (2004) admitted as much, citing strong desert connections with San Dieguito. Thus, the Archaic pattern is the earliest local socioeconomic adaptation in the San Diego region (Hale 2001, 2009).
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The Archaic pattern is relatively easy to define with assemblages that consist primarily of processing tools:
millingstones, handstones, battered cobbles, heavy crude scrapers, incipient flake-based tools, and cobble-core reduction. These assemblages occur in all environments across the San Diego region, with little variability in tool composition. Low assemblage variability over time and space among Archaic sites has been equated with cultural conservatism (Byrd and Reddy 2002; Warren 1968; Warren et al. 2004). Despite enormous amounts of archaeological work at Archaic sites, little change in assemblage composition occurs until the bow and arrow is adopted at around AD 500, as well as ceramics at approximately the same time (Griset 1996; Hale 2009). Even then, assemblage formality remains low. After the bow is adopted, small arrow points appear in large quantities and already low amounts of formal flake tools are replaced by increasing amounts of expedient flake tools. Similarly, shaped millingstones and handstones decrease in proportion relative to expedient, unshaped groundstone tools (Hale 2009). Thus, the terminus of the Archaic period is equally as hard to define as its beginning because basic assemblage constituents and patterns of manufacturing investment remain stable, complimented only by the addition of the bow and ceramics.
3.2.3 Late Prehistoric (AD 500–1750)
The period of time following the Archaic and prior to Ethnohistoric times (AD 1750) is commonly referred to as the Late Prehistoric (Rogers 1945; Wallace 1955; Warren et al. 2004). However, several other subdivisions continue to be used to describe various shifts in assemblage composition, including the addition of ceramics and cremation practices. In northern San Diego County, the post-AD 1450 period is called the San Luis Rey Complex (True 1980), while the same period in southern San Diego County is called the Cuyamaca Complex and is thought to extend from AD 500 until Ethnohistoric times (Meighan 1959). Rogers (1929) also subdivided the last 1,000 years into the Yuman II and III cultures, based on the distribution of ceramics. Despite these regional complexes, each is defined by the addition of arrow points and ceramics, and the widespread use of bedrock mortars. Vagaries in the appearance of the bow and arrow and ceramics make the temporal resolution of the San Luis Rey and Cuyamaca complexes difficult. For this reason, the term Late Prehistoric is well suited to describe the last 1,500 years of prehistory in the San Diego region.
Temporal trends in socioeconomic adaptations during the Late Prehistoric period are poorly understood. This is partly due to the fact that the fundamental Late Prehistoric assemblage is very similar to the Archaic pattern but includes arrow points and large quantities of fine debitage from producing arrow points, ceramics, and cremations. The appearance of mortars and pestles is difficult to place in time because most mortars are on bedrock surfaces; bowl mortars are actually rare in the San Diego region. Some argue that the Ethnohistoric intensive acorn economy extends as far back as AD 500 (Bean and Shipek 1978). However, there is no substantial evidence that reliance on acorns, and the accompanying use of mortars and pestles, occurred prior to AD 1400. True (1980) argued that acorn processing and ceramic use in the northern San Diego region did not occur until the San Luis Rey pattern emerged after approximately AD 1450. For southern San Diego County, the picture is less clear. The Cuyamaca Complex is the southern counterpart to the San Luis Rey pattern, however, and is most recognizable after AD 1450 (Hector 1984). Similar to True (1980), Hale (2009) argued that an acorn economy did not appear in the southern San Diego region until just prior to Ethnohistoric times, and that when it did occur, a major shift in social organization followed.
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3.2.4 Ethnohistoric (post-AD 1750)
As recognized by State Assembly Joint Resolution No. 60 (2001), the Kumeyaay Nation has occupied the southern California and Baja California region, including the City of San Diego’s jurisdictional boundaries and the proposed project’s APE, far into antiquity. The history of the Kumeyaay communities prior to the mid-1700s has largely been reconstructed through later mission-period and early ethnographic accounts. The first records of the Native American inhabitants of the San Diego region come predominantly from European merchants, missionaries, military personnel, and explorers. These brief, and generally peripheral, accounts were prepared with the intent of furthering respective colonial and economic aims and were combined with observations of the landscape. They were not intended to be unbiased accounts regarding the cultural structures and community practices of the newly encountered cultural groups. The establishment of the missions in the San Diego region brought more extensive documentation of Native American communities, though these groups did not become the focus of formal and indepth ethnographic study until the early twentieth century (Boscana 1846; Fages 1937; Geiger and Meighan 1976; Harrington 1934; Laylander 2000). The principal intent of these researchers was to record the precontact, culturally specific practices, ideologies, and languages that had survived the destabilizing effects of missionization and colonialism. This research, often understood as “salvage ethnography,” was driven by the understanding that traditional knowledge was being lost due to the impacts of modernization and cultural assimilation. Alfred Kroeber applied his “memory culture” approach (Lightfoot 2005, p. 32) by recording languages and oral histories within the San Diego region. Kroeber’s 1925 assessment of the impacts of Spanish missionization on local Native American populations supported Kumeyaay traditional cultural continuity (Kroeber 1925, p. 711):
San Diego was the first mission founded in upper California; but the geographical limits of its influence were the narrowest of any, and its effects on the natives comparatively light. There seem to be two reasons for this: first, the stubbornly resisting temper of the natives; and second, a failure of the rigorous concentration policy enforced elsewhere.
In some ways this interpretation led to the belief that many California Native American groups simply escaped the harmful effects of contact and colonization all together. This, of course, is untrue. Ethnographic research by Dubois, Kroeber, Harrington, Spier, and others during the early twentieth century seemed to indicate that traditional cultural practices and beliefs survived among local Native American communities. These accounts supported, and were supported by, previous governmental decisions, which made San Diego County the location of more federally recognized tribes than anywhere else in the United States: 18 tribes on 18 reservations that cover more than 116,000 acres (CSP 2009).
The traditional cultural boundaries between the Luiseño and Kumeyaay Native American tribal groups have been well defined by anthropologist Florence C. Shipek:
In 1769, the Kumeyaay national territory started at the coast about 100 miles south of the Mexican border (below Santo Tomas), thence north to the coast at the drainage divide south of the San Luis Rey River including its tributaries. Using the U.S. Geological Survey topographic maps, the boundary with the Luiseño then follows that divide inland. The boundary continues on the divide separating Valley Center from Escondido and then up along Bear Ridge to the 2240 contour line and then north across the divide between Valley Center and Woods Valley up to the 1880-foot peak, then curving around east along the divide above Woods Valley. [1993, as summarized by the San Diego County Board of Supervisors 2007:6]
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Based on ethnographic information, it is believed that at least 88 different languages were spoken from Baja California Sur to the southern Oregon state border at the time of Spanish contact (Johnson and Lorenz 2006, p. 34).
The distribution of recorded Native American languages has been dispersed as a geographic mosaic across California through six primary language families (Golla 2007, p. 71). Ipai and Tipai, spoken respectively by the northern and southern Kumeyaay communities, are mutually intelligible. For this reason, these two are often treated as dialects of a larger Kumeyaay tribal group rather than as distinctive languages, though this has been debated (Luomala 1978; Laylander 2010).
Victor Golla has contended that one can interpret the amount of variability within specific language groups as being associated with the relative “time depth” of the speaking populations (Golla 2007, p. 80) A large amount of variation within the language of a group represents a greater time depth then a group’s language with less internal diversity.
One method that he has employed is by drawing comparisons with historically documented changes in Germanic and Romantic language groups. Golla has observed that the “absolute chronology of the internal diversification within a language family” can be correlated with archaeological dates (2007, p. 71). This type of interpretation is modeled on concepts of genetic drift and gene flows that are associated with migration and population isolation in the biological sciences.
Golla suggested that there are two language families associated with Native American groups who traditionally lived throughout the San Diego County region. The northern San Diego tribes have traditionally spoken Takic languages that may be assigned to the larger Uto–Aztecan family (Golla 2007, p. 74). These groups include the Luiseño, Cupeño, and Cahuilla. Golla has interpreted the amount of internal diversity within these language-speaking communities to reflect a time depth of approximately 2,000 years. Other researchers have contended that Takic may have diverged from Uto–Aztecan ca. 2600 BC–AD 1, which was later followed by the diversification within the Takic speaking San Diego tribes, occurring approximately 1500 BC–AD 1000 (Laylander 2010). The majority of Native American tribal groups in southern San Diego region have traditionally spoken Yuman languages, a subgroup of the Hokan Phylum. Golla has suggested that the time depth of Hokan is approximately 8,000 years (Golla 2007, p. 74). The Kumeyaay tribal communities share a common language group with the Cocopa, Quechan, Maricopa, Mojave, and others to east, and the Kiliwa to the south. The time depth for both the Ipai (north of the San Diego River, from Escondido to Lake Henshaw) and the Tipai (south of the San Diego River, the Laguna Mountains through Ensenada) is approximated to be 2,000 years at the most. Laylander contended that previous research indicates a divergence between Ipai and Tipai to have occurred approximately AD 600–1200 (Laylander 1985). Despite the distinct linguistic differences between the Takic-speaking tribes to the north, the Ipai-speaking communities in central San Diego, and the Tipai southern Kumeyaay, attempts to illustrate the distinctions between these groups based solely on cultural material alone have had only limited success (Pigniolo 2004; True 1966).
The Kumeyaay generally lived in smaller family subgroups that would inhabit two or more locations over the course of the year. While less common, there is sufficient evidence that there were also permanently occupied villages, and that some members may have remained at these locations throughout the year (Owen 1965; Shipek 1982, 1985; Spier 1923). The prehistoric village of Nipawai/Nipaguay was located at the bend in the San Diego River where Kumeyaay occupants could utilize the riverine resources and dam channels to redirect water to facilitate plant husbandry (Shipek 1993). As its epicenter is located only 0.5 miles east, there is an increased probability that cultural resources identified within the proposed projectProject APE would be associated with Nipawai/Nipaguay. Each autonomous triblet was internally socially stratified, commonly including higher status individuals such as a tribal head (Kwaaypay), shaman (Kuseyaay), and general members with various responsibilities and skills (Shipek 1982). Higher-status individuals tended to have greater rights to land resources, and owned more goods, such as shell money and beads, decorative items, and SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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clothing. To some degree, titles were passed along family lines; however, tangible goods were generally ceremonially burned or destroyed following the deaths of their owners (Luomala 1978). Remains were cremated over a pyre and then relocated to a cremation ceramic vessel that was placed in a removed or hidden location. A broken metate was commonly placed at the location of the cremated remains, with the intent of providing aid and further use after death. Should any Native American human remains be found in the City of Santee Diego’s jurisdictional boundaries, including the proposed project’s APE, the NAHC would designate a Most Likely Descendant from the Kumeyaay Nation. At maturity, tribal members often left to other bands in order to find a partner. The families formed networks of communication and exchange around such partnerships.
Areas or regions, identified by known physical landmarks, could be recognized as band-specific territories that may be violently defended against use by other members of the Kumeyaay. Other areas or resources, such as water sources and other locations that were rich in natural resources, were generally understood as communal land to be shared amongst all the Kumeyaay (Loumala 1978). The coastal Kumeyaay would have procured shellfish from three primary environments, including the sandy open coast, bay and lagoon, and rocky open coast (Luomala 1978). The availability of these marine resources changed with the rising sea levels, siltation of lagoon and bay environments, changing climatic conditions, and intensity of use by humans and animals (Gallegos and Kyle 1988; Pigniolo 2005; Warren and Pavesic 1963). Shellfish from sandy environments included Donax, Saxidomus, Tivela, and others. Rocky coast shellfish dietary contributions consisted of Pseudochama, Megastraea, Saxidomus, Protothaca, Megathura, and others. Bay environment in the distant vicinity of the Project APE would have provided Argopecten, Chione, Ostrea, Neverita, Macoma, Tagelus, and others. While marine resources were obviously consumed, terrestrial animals and other resources likely provided a large portion of sustenance. Game animals consisted of rabbits, hares (Leporidae), birds, ground squirrels, woodrats (Neotoma), deer, bears, mountain lions (Puma concolor), bobcats (Lynx rufus), coyotes (Canus latrans), and others. In lesser numbers, reptiles and amphibians may have been consumed.
A number of local plants were used for food and medicine. These were exploited seasonally, and were both traded between regional groups and gathered as a single triblet moved between habitation areas. Some of the more common of these that may have been procured locally or as higher elevation varieties would have included buckwheat (Eriogonum fasciculatum), Agave, Yucca, lemonade berry (Rhus integrifolia), sugar brush (Rhus ovata), sage scrub (Artemisia californica), yerba santa (Eriodictyon), sage (Salvia), Ephedra, prickly pear (Opuntia), mulefat (Baccharis salicifolia), chamise (Adenostoma fasciculatum), elderberry (Sambucus nigra), oak (Quercus), willow (Salix), and Juncus grass among many others (Wilken 2012).
The Kumeyaay territory expanse over several distinct ecological zones and intra-tribal trade allowed the dispersal of goods and information. The Kumeyaay usually trade between bands more often than they traded with unrelated groups outside of their territory, however, larger trail systems crossed their land from the Lower Colorado River to the Southern Californian coast (Luomala 1978). The coastal Kumeyaay exchanged a number of local goods, such as seafood, coastal plants, and various types of shell for items including acorns, agave, mesquite beans, gourds, and other more interior plants of use (Luomala 1978). Trade routes were often along trails between villages, along waterways such as the San Diego River, or, in desert terrain, between springs and water catchments (Heizer 1978). Spaniards marveled at how quickly news and goods travelled between the Colorado River and the coast along the Kumeyaay trail system (Heizer 1978). The routes of the Kumeyaay trail system were followed by wagon routes and later became major thoroughfares (Davis 1961). Interstate 8 is today aptly named the “Kumeyaay Highway” as it follows the likely path of the prehistoric trail connecting coastal and inland Kumeyaay. The proposed projectProject APE is located along the Kumeyaay Highway and the San Diego River between the prehistoric villages of Kosoi/Kosay/Kosaii/Cosoy/Kosa’aay and Nipawai/Nipaguay, the location of the now standing Old Town Presidio (approximately 124 miles southwest) and the Mission San Diego de Alcalá (approximately 7 .5 miles eastsouthwest), respectively (Kroeber 1925).
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3.2.5 The Historic Period (post-AD 1542)
European activity in the region began as early as AD 1542, when Juan Rodríguez Cabrillo landed in San Diego Bay.
Sebastián Vizcaíno returned in 1602, and it is possible that there were subsequent contacts that went unrecorded.
These brief encounters made the local native people aware of the existence of other cultures that were technologically more complex than their own. Epidemic diseases may also have been introduced into the region at an early date, either by direct contacts with the infrequent European visitors or through waves of diffusion emanating from native peoples farther to the east or south (Preston 2002). It is possible, but as yet unproven, that the precipitous demographic decline of native peoples had already begun prior to the arrival of Gaspar de Portolá and Junípero Serra in 1769.
Spanish colonial settlement was initiated in 1769, when multiple expeditions arrived in San Diego by land and sea, and then continued northward through the coastal plain toward Monterey. A military presidio and a mission were soon firmly established at San Diego, despite violent resistance to them from a coalition of local Kumeyaay native communities in 1776. In 1773, the Spanish missionaries reestablished the Mission of San Diego de Alcalá up the San Diego River to its current location in Mission Valley in order to be closer to a more reliable water source (Hill 2002). The Mission of San Diego de Alcalá was built at the location of the ethnohistoric Kumeyaay village of Nipawai/Nipaguay, located a half-mile west of the proposed projectProject APE. The missionaries relied heavily on Kumeyaay labor and resources extracted from Nipawai/Nipaguay. Private ranchos subsequently established by Spanish and Mexican soldiers, as well as other non-natives, appropriated much of the remaining coastal or nearcoastal locations (Pourade 1960–1967).
Mexico’s separation from the Spanish empire in 1821 and the secularization of the California missions in the 1830s caused further disruptions to native populations in western San Diego County. Some former mission neophytes were absorbed into the work forces on the ranchos, while others drifted toward the urban centers at San Diego and Los Angeles or moved to the eastern portions of the county where they were able to join still largely autonomous native communities. United States conquest and annexation, together with the gold rush in Northern California, brought many additional outsiders into the region. Development during the following decades was fitful, undergoing cycles of boom and bust. With rising populations in the nineteenth century throughout the Southern California region, there were increased demands for important commodities such as salt.
The American Period began in 1846 when United States military forces occupied San Diego and this period continues today. When United States military forces occupied San Diego in July 1846, the town’s residents split on their course of action. Many of the town’s leaders sided with the Americans, while other prominent families opposed the United States invasion. In December 1846, a group of Californios under Andres Pico engaged United States Army forces under General Stephen Kearney at the Battle of San Pasqual and inflicted many casualties. However, the Californio resistance was defeated in two small battles near Los Angeles and effectively ended by January 1847.
The Americans assumed formal control with the Treaty of Guadalupe-Hidalgo in 1848 and introduced Anglo culture and society, American political institutions and especially American entrepreneurial commerce. In 1850, the Americanization of San Diego began to develop rapidly.
On February 18, 1850, the California State Legislature formally organized San Diego County. The first elections were held at San Diego and La Playa on April 1, 1850, for county officers. San Diego grew slowly during the next decade. San Diegans attempted to develop the town’s interests through a transcontinental railroad plan and the development of a new town closer to the bay. The failure of these plans, added to a severe drought that crippled SAN DIEGO RIVER FIRE HAZARD MITIGATION PLAN – PHASE 1 CITY OF SANTEE, SAN DIEGO COUNTY,
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ranching and the onset of the Civil War, left San Diego as a remote frontier town. The troubles led to an actual drop in the town’s population from 650 in 1850 to 539 in 1860. Not until land speculator and developer Alonzo Horton arrived in 1867 did San Diego begin to develop fully into an active American town.
Alonzo Horton’s development of a New San Diego (modern downtown) in 1867 began to swing the community focus away from Old Town and began the urbanization of San Diego. Expansion of trade brought an increase in the availability of building materials. Wood buildings gradually replaced adobe structures. Development spread from downtown based on various factors, including the availability of potable water and transportation corridors. During the Victorian Era of the late 1800s and early 1900s, the areas of Golden Hill, Uptown, Banker’s Hill, and Sherman Heights were developed.