PROJECT DESCRIPTION:
The project consists of construction and operation of a new aboveground water storage tank (the Crown Hill Tank) and associated piping and electrical infrastructure. The purpose of the project is to improve water storage capacity and to provide proper water pressure to some higher elevation lots on the Knolls Pressure Zone. The Crown Hill Tank would be a welded steel aboveground tank approximately 74 feet in diameter and 35 feet in height, with a storage capacity of one million gallons. In addition to the tank, the project would also include installation of a 10-inch pipeline and appurtenances to connect the Crown Hill Tank to the existing Alta Vista Tanks No. 1 and 2, construction of an access roadway and retaining walls, and landscaping in the areas surrounding the project components.
APPLICATION COMPLETENESS:
Complete - from our area of concern.
ENVIRONMENTAL IMPACT ANALYSIS:
Item 31a. Flood Control Facilities/Watercourses – Ventura County Public Works Agency, Watershed Protection is deemed to be Less Than Significant.
The proposed project is situated about 1800 feet from the Black Canyon, which is a WP jurisdictional redline channel. No new or modified direct stormwater drainage connections to this WP channel, activities within WP’s easement, or activities over, under, or within the redline channel appear to be proposed or indicated on the applicant’s submitted materials.
This proposed project would result in an increase of impervious area within the subject property. It is understood that impacts from the proposed increase in impervious area and stormwater drainage design within the project site will be required to be mitigated to less than significant under the conditions imposed by County of Ventura. The mitigation requires that runoff from the proposed project site be released at no greater than the existing flow rate and in such manner as to not cause an adverse impact downstream in peak discharge, velocity, or duration.
WP staff determines that the proposed project design with the conditions mentioned above mitigates the direct and indirect project-specific and cumulative impacts to flood control facilities and watercourses. Therefore, the environmental impact is less than significant (LS) on redline channels under the jurisdiction of the Ventura County Public Works Agency - Watershed Protection.
Item 17b. Hydraulic Hazards - FEMA is deemed to be Less Than Significant.
The project site is in a location identified by the Federal Emergency Management Agency (FEMA) as an area of Minimal Flood Hazard Zone X Unshaded. This is evidenced on FEMA Map Panel 06111C0868E effective January 20, 2010. The proposed development is therefore, deemed to be Less Than Significant for Hydraulic Hazards - FEMA.
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WATERSHED PROTECTION COMMENTS:
None.
WATERSHED PROTECTION CONDITIONS:
None.
If you have any questions, please feel free to contact me by email at [email protected] or by phone at 805-654-2005.
END OF TEXT.
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City of Sim
i Valley/Ventura County Waterworks District No. 8
Knolls Zone Water Facilities Project Responses to Comments on the Draft ISMND Respo
nses to Comments
Let
ter 1
COMM
ENTER: Yunsheng Su, PWA-WP Case Reviewer, Ventura County Public Works Watershed Planning and Permits Division
DATE: November 3, 2025
Response
1.1 The co
mmenter summarizes the project’s location and description and confirms that the application is complete.
The commenter’s summary of the project is accurate. No revisions to the Draft IS-MND are required in response to this comment.
Response
1.2 The co
mmenter summarizes the analysis related to hydrology and stormwater runoff and agrees with the less-than-significant impact determination.
The commenter’s summary of the project’s impact analysis is accurate. The commenter’s agreement with the determination of less-than-significant impacts is acknowledged. No revisions to the Draft IS- MND are required in response to this comment.
Response
1.3 The co
mmenter states the project site is located in an area of Minimal Flood Hazard and therefore is deemed to be less than significant for hydraulic hazards.
The commenter’s determination of potential hydraulic hazards due to the project site location is acknowledged. No revisions to the Draft IS-MND are required in response to this comment.
Response
1.4 The comm
enter has no watershed protection comments or conditions for the project.
The commenter’s review and support of the project as proposed is acknowledged. No revisions to the Draft IS-MND are required in response to this comment.
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“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 7
100 SOUTH MAIN STREET, SUITE 100 | LOS ANGELES, CA 90012 PHONE (213) 897-0362 | FAX (213) 897-0360 TTY 711
www.dot.ca.gov
November 24, 2025
Michael Kadah
Ventura County Waterworks District No.8
2929 Tapo Canyon Road
Simi Valley, Ventura CA 93603
RE: Knolls Zone Water Facilities Project
SCH# 2025101279
GTS# 07-VEN-2025-00662
Dear Michael Kaddah,
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above -referenced project. The Ventura County Waterworks District No.8 is proposing the construction and operation of a new abovegroun d water storage tank (the Crown Hill Tank) and associated piping and electrical infrastructure. The purpose of the project is to improve water storage capacity and to provide proper water pressure to some higher elevation lots on the Knolls Pressure Zone. The Crown Hill Tank would be a welded steel aboveground tank approximately 74 feet in diameter and 35 feet in height, with a storage capacity of one million gallons. In addition to the tank, the project would also include installation of a 10 -inch pipeline and appurtenances to connect the Crown Hill Tank to the existing Alta Vista Tanks No. 1 and 2, construction of an access roadway and retaining walls, and landscaping in the areas surrounding the project components.
The nearest State facility is SR-118. After reviewing the Mitigated Negative Declaration (MND), Caltrans has the following comments:
Caltrans recommends limiting large truck travel and construction traffic to off-peak commute hours. A permit for any heavy construction equipment and or materials that require the use of oversized transport vehicles on State highways. If construction traffic is expected to cause issues on any State facilities, please submit a construction traffic control plan detailing potential impacts for Caltrans review.
Letter 2
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“Provide a safe and reliable transportation network that serves all people and respects the environment” Should you have any questions, please feel free to contact Nestor Lemus, the project coordinator, at [email protected] and refer to GTS # 07-VEN-2025-00662
Sincerely,
MIYA EDMONSON
LDR/CEQA Branch Chief
cc: State Clearinghouse
2.3 287
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region
3883 Ruffin Road
San Diego, CA 92123
wildlife.ca.gov
Conserving California’s Wildlife Since 1870
December 3, 2025
Michel Kadah
Ventura County Waterworks District No. 8
2929 Tapo Canyon Road
Simi Valley, CA 93063
[email protected]
Subject: MITIGATED NEGATIVE DECLARATION FOR THE KNOLLS ZONE WATER FACILITIES PROJECT, SCH NO. 2025101279, UNINCORPORATED
VENTURA COUNTY, CA
Dear Michel Kadah:
The California Department of Fish and Wildlife (CDFW) reviewed the Mitigation Negative Declaration (MND) from the Ventura County Water Work District No. 8 (District) for the Knolls Zone Water Facilities Project (Project) pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines1.
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project 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 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
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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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.
PROJECT DESCRIPTION SUMMARY
Proponent: Ventura County Waterworks District No. 8
Objective: The objective of the Project is to construct a welded steel aboveground tank (Crown Hill Tank) with associated piping, concrete pad, and electrical infrastructure. The tank will be approximately 74 feet in diameter and 35 feet high with a capacity of one million gallons. The objective of the tank is to improve water storage capacity and to provide more appropriate water pressure to higher elevation lots in the Knolls Pressure Zone. The Project would also include an approximately 545 foot long concrete access road (alignment can be seen as part of Figure 1), associated curbs and gutters, an 8- foot high and 13-foot wide metal gate, two retaining walls (90 feet long and 3-5 feet high; 170 feet long and 2-5 feet high), 10-inch welded steel inlet and outlet pipelines (to connect with neighboring Alta Vista Tank 2), and landscaping. The Project may also include the demolition of the Alta Vista Tank No. 1. Primary Project activities include vegetation removal, open trench excavation, grubbing, grading, demolition, and construction. Construction would occur over approximately 14 months. It is anticipated that maintenance activities will occur every five years. The tank’s lifetime is approximately 50 years.
Location: The Project site is located on Assessor’s Parcel Numbers (APN) 646-016- 207, 646-016-106, and 646-016-102 (Viewed on Ventura County View Website 2025) in the unincorporated community of Santa Susana along the southern City limits of Simi Valley. The Project site is south of Highway 118 and located within the Simi Valley Groundwater Basin. The Project site is directly surrounded by single family residences to the north, east, and west; and undeveloped areas to the south. Further out to the east, south, and northwest of the Project site are California Protected Lands3.
Biological Setting: The Project site consists of three parcels totaling approximately
1.16 acres. The Project site encompasses approximately 0.6 acre along a north facing slope. Elevations range from 1,377 feet above sea level at the northern boundary and 1,464 feet above sea level at the site’s southern boundary. The surrounding vegetation
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.”
3 Lands that are owned in fee and protected for open space purposes by public or non-profit organizations.
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communities include deerweed-silver lupine-yerba santa scrub alliance, California sagebrush scrub, and non-native wild oats and brome grassland. The deerweed-silver lupine-yerba santa scrub alliance is prominent in the southern portion of the Project site, bordering the access route and proposed tank location. The California sagebrush scrub alliance is located between the proposed tank location and the access route. Non-native wild oats and annual brome grasslands are present to the east of the access road which also bears evidence of disturbance through vegetation management practices. Soils are characterized only as loam soils in the Gaviota rocky sandy loam, 15-50% slope series.
This soil is not hydric and is well drained. There is a drainage feature directly to the east of the Project site.
Rincon Consultants, Inc. conducted a biological reconnaissance field survey on September 24, 2024. The length and timing were not specified. Sensitive species that are of potential concern for the Project include, but are not limited to:
Crotch’s bumble bee (Bombus crotchii; CESA listed-candidate endangered), coast horned lizard (Phrynosoma blainvillii; species of special concern (SSC)), western whiptail; (Aspidoscelis tigris; SSC), Blainville’s horned lizard (Phrynosoma blainvilli; SSC), coastal California gnatcatcher (Polioptila californica californica; Endangered Species Act (ESA-) listed and SSC), rufous-crowned sparrow (Aimophila ruficeps; SSC), Nevin’s barberry (Berberis nevinii; state endangered, California rare plant ranking (CRPR) 1B.1), Brauton’s milk vetch (Astragalus brauntonii, state endangered, CRPR 1B.1), Santa Susana tarplant (Deinandra minthornii; state rare, CRPR 1B.2), slender mariposa lily (Calochortus clavatus var. gracilus; CRPR 1B.2), chaparral nolina (Nolina cismontane; CRPR 1B.2), and Plummer’s mariposa lily (Calochortus plummerae; CRPR 4.2).
The MND provides mitigation measures BIO-1 to BIO-6 to protect potentially present special status plant and wildlife species. BIO-2 is a measure that can aid in the avoidance of all potentially present species by the implementation of a Worker Environmental Awareness Program (WEAP). BIO-1 and BIO-3 relate to the identification and avoidance of rare plants through delineating the work area (BIO-1) and conducting pre-construction surveys (BIO-3). Surveys under BIO-3 will utilize CNPS’s Botanical Survey Guidelines, CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities, and USFWS’s Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed, and Candidate Plants. BIO-3 also states that if rare plants are found, they will be flagged for avoidance. If avoidance is not possible, a qualified botanist will prepare salvage, relocation, or propagation and monitoring plan before construction is initiated. BIO-4 relates to the identification and avoidance of Crotch’s bumble bee through pre-construction surveys using CDFW’s guidelines for the species. If the species is found in or surrounding the Project area then buffers and consultations with agencies will be employed. BIO-5 relates to the protection and avoidance of nesting birds through avoidance of the nesting bird season or through conducting pre- construction surveys if work is anticipated within the nesting window (January 1- DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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September 15). Buffers and monitoring guidelines were also provided as part of BIO-5.
BIO-6 provides specific surveying, avoidance, and mitigation for coastal California gnatcatcher. Mitigation for coastal California gnatcatcher include mitigating at a 2:1 ratio for permanent impacts to occupied habitat or at a 1:1 ratio for temporary impacts to occupied and unoccupied habitat.
Figure 1. Project site map and elements
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COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the District in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.
Additional comments or other suggestions may also be included to improve the document.
COMMENT # 1: Impacts to Crotch’s Bumble Bee
Issue: The Project may impact suitable nesting and foraging habitat for Crotch’s bumble bee. The MND did not provide sufficient mitigation measures to minimize impacts to Crotch’s bumble bee and its associated habitat.
Specific impact: The Project may result in direct and indirect impacts to Crotch’s bumble bee. Direct impacts may result due to vegetation clearing, grading, cement pad/road installation, and overall construction. Indirect impacts may result due to increased noise, vibration, and human activity throughout the life of the Project. Project activities associated with the construction can lead to direct take of Crotch’s bumble bee.
Why impact would occur: According to CDFW’s Crotch’s Bumble Bee Range – CDFW [ds3095] dataset
4, the Project site lies within the current range for Crotch’s bumble bee (CDFW 2025a). Grassland and chaparral habitat within the Project site may provide suitable habitat to support Crotch’s bumble bee (CDFW 2025b). Crotch’s bumble bees primarily nest in late February through late October underground in abandoned small mammal burrows, although burrows were not found on site during the reconnaissance survey, the species may also nest under perennial bunch grasses or thatched annual grasses, under-brush piles, in old bird nests, and in dead trees or hollow logs (Williams et al. 2014; Hatfield et al. 2012). Likewise, within the CEQA document it was stated that reconnaissance surveys were performed; however, the weather conditions, methodology, and duration were not disclosed within the Initial Study (IS). Therefore, animal burrows may have been present but not detected as part of the survey. Given that the Project site is in the current range and has suitable habitat, there is potential for this CESA candidate species to be present.
CDFW appreciates the incorporation of MM BIO-4 to address impacts to Crotch’s bumble bee. As currently written, the measure proposes pre-construction surveys within suitable habitats at the Project site and within a 50-foot buffer. The measure also states that a no-disturbance buffer zone shall be established around the active nest colony until it is determined the nest is no longer active. Elsewhere within the document, but
4 Dataset represent the range for Crotch's Bumble Bee. The range is defined as the maximum geographic extent of B. crotchii based on occurrence records through 2024 from the Bumble Bees of North America Occurrence Record Database (Richardson 2023), California Natural Diversity Database (CNDDB), and other datasets submitted directly to CDFW.
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not included within BIO-4, it was stated that if impacts to individuals cannot be avoided that the District would seek to obtain an Incidental Take Permit (ITP).
CDFW has concerns that pre-construction surveys associated with BIO-4 are not sufficient to assess potential habitat nor prove presence or absence. Likewise, nests are often difficult to locate, and dispersal distance of the species is not yet known. Absent of protocol surveys, presence should be assumed based on the suitable nesting and foraging habitat surrounding the site. If the Project proceeds without appropriate focused surveys, the Project may result in mortality and/or injury of undetected individual Crotch’s bumble bee that may be present during Project activities. The Project’s ground and vegetation disturbance could result in potentially significant impacts to Crotch’s bumble bee, including changes in foraging behavior; burrow collapse; nest abandonment; reduced nest success; reduced health and vigor of eggs, young, and/or queens; and direct mortality.
Evidence impact may be significant: The California Fish and Game Commission accepted a petition to list the Crotch’s bumble bee as endangered under CESA, determining the listing “may be warranted” and advancing the species to the candidacy stage of the CESA listing process. Take of any endangered, threatened, candidate species that results from the Project is prohibited, except as authorized by State law (Fish & G. Code, §§ 86, 2062, 2067, 2068, 2080, 2085; Cal. Code Regs., tit. 14, § 786.9). CDFW considers impacts to species that are candidates for CESA listing to be significant, under CEQA. Accordingly, the Project may 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.
Recommended Potentially Feasible Mitigation Measure(s)
Mitigation Measure #1: Crotch’s Bumble Bee and Mitigation Measure BIO-4 CDFW recommends the District revise Mitigation Measure BIO – 4 to incorporate the underlined language and remove the language in strikethrough:
The project applicant shall retain a qualified biologist with appropriate handling permits to conduct protocol-level surveys following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023c).
Focused surveys shall also be conducted throughout the entire Project site and during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the District prior to implementing Project ground-disturbing activities. If Crotch’s bumble bee is detected on site, the Project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a copy of a fully executed take authorization to the District prior to implementing Project ground- DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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disturbing activities and vegetation removal. Pre-construction surveys for Crotch’s bumble bee, including ground nests, shall be conducted within all suitable habitats adjacent to the project site within the 50-foot buffer before initial grounddisturbing activities (e.g., grubbing/removing vegetation, excavation, grading, construction). These surveys aim to identify individuals and/or active nest colonies in areas adjacent to the site. The pre-construction surveys shall follow the methodologies set out in the CDFW Survey Considerations for CESA Candidate Bumble Bee (CDFW 2023) or other survey methodology approved by CDFW. If the pre-construction surveys identify individuals or active nest colonies adjacent to the project footprint:
• An appropriate no-disturbance buffer zone shall be established around the active nest colony to reduce the risk of disturbance or accidental take. The buffer distance shall be established by a qualified biologist. • The project proponent/operator shall consult with a qualified biologist to discuss considerations and recommendations on implementing project activities to avoid take of Crotch’s bumble bee.
If an avoidance buffer is required as described above, construction activities shall not occur within that buffer zone until a qualified biologist determines the nest to no longer be active (i.e., no Crotch’s bumble bee are seen flying in or out of the nest for three consecutive days [during suitable weather conditions when Crotch’s bumble bee are typically active] indicating the colony has completed its nesting season and the queens have dispersed from the colony), after which construction activities may resume within that buffer zone
Mitigation Measure #2 No Net Loss of Habitat
If California Fish and Game Commission does not list Crotch's bumble bee under CESA, it will still remain an invertebrate of conservation priority under the California Terrestrial and Vernal Pool Invertebrates of Conservation Priority. Thus, there shall be no net loss of suitable habitat for Crotch’s bumble bee. The District shall offset impacts on habitat for Crotch’s bumble bee at no less than 2:1, so there is no net loss of suitable habitat.
Recommendation #1: CEQA for Crotch’s Bumble Bee
CDFW’s issuance of an ITP for a Project is subject to CEQA. As a Responsible Agency, CDFW may consider the CEQA document from the lead agency/Project proponent for the Project. However, additional documentation may be required as part of an ITP application for the Project in order for CDFW to adequately develop an accurate take analysis and identify measures that would fully mitigate for take of CESA-listed species.
To minimize additional requirements by CDFW pursuant to Fish and Game Code section 2081 and/or under CEQA, the Project’s CEQA document should fully identify the potential impacts to Crotch’s bumble bee and provide adequate avoidance, mitigation, monitoring, and reporting commitments for issuance of the ITP.
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COMMENT # 2: Impacts to Santa Susana Tarplant and other Rare Plants Issue: The Project is located in a region that supports Santa Susana tarplant (CRPR 1B.2, state rare). The species was not mentioned within the CEQA document as having potential occurrence. Likewise, only one reconnaissance survey of an unknown duration and methodology was performed as part of the IS. No Biological Resource Assessment was provided as part of the CEQA submission.
Specific impact: The Project may result in direct take of Santa Susana tarplant due to Project activities (i.e. vegetation clearing, grading, and construction). Santa Susana tarplant is afforded all of the protections of CESA as a 1B.2 ranked rare plant. Take of the species is thus prohibited.
Why impact would occur: Santa Susana tarplant is endemic only to western Los Angeles County and eastern Ventura County (Calscape 2025). Santa Susana tarplant grows in coastal sage scrub and chaparral habitats and can be found on rocky outcroppings and in sandstone crevices often at elevations from 980-1,640 feet above sea level (Calscape 2025). The Project site is characterized within the CEQA document as meeting these habitat conditions. Likewise, population occurrences have been recorded in the surrounding area on the California Natural Diversity Database (CNDDB) (CDFW 2025d, Figure 2). Many observations on iNaturalist have also been recorded in the surrounding area including one observation made in 2023 less than 500 feet from the construction site of the proposed Crown Hill Tank and less than 300 feet from the Alta Vista Tank 1 demolition site (iNaturalist 2025). Given that the Project site is in the current range, has suitable habitat, and the species has been recorded by multiple databases, there is potential for this CESA-protected, rare plant to be found in and around the impact site. The nature of the proposed Project could remove rare plants and habitat supporting rare plants.
CDFW acknowledges and appreciates the incorporation of MM BIO-3 to address impacts to rare plants. As currently written, the measure proposes pre-construction surveys for rare plants specifically during May through July. Surveys will utilize CNPS’s Botanical Survey Guidelines, CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities, and USFWS’s Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants. The measure also states that if rare plants are found, they will be flagged for avoidance. If avoidance is not possible, a qualified botanist will prepare salvage, relocation, or propagation and monitoring plan before construction is initiated.
CDFW has concerns with MM BIO-3 as it specifies May through July as the target blooming period. Santa Susana tarplant has a blooming period between July and November; the above-mentioned surveying period would not be optimal for Santa Susana tarplant. Transplant relocation is also not an appropriate method of conservation for this species. In a recorded instance where transplanting was attempted DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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due to the construction of an unrelated water tank in the City of Chatsworth, only 9 of the 55 individual Santa Susana tarplants survived (LA Times 1989). Thus, CDFW would not consider salvage and relocation an appropriate or sufficient mitigation measure for the species.
Given the potential occurrence and lack of success with relocating Santa Susana tarplant, CDFW is of the opinion that BIO-3 (pre-construction surveys in conjunction with avoidance buffers and/or salvage and relocation) is not sufficient in mitigating the Project impacts below the threshold of significance. If the Project proceeds with BIO-3 as the only mitigation measure to protect Santa Susana tarplant, the Project may result in take of the species present in or around the Project site.
The Project would result in direct physical changes to the environment (i.e. grading, excavation, vegetation removal, landscaping, laying concrete foundation). The Project could also indirectly impact Santa Susana tarplant and other rare plants by introducing additional edge effects. Edge effects that could impact rare, special status, and sensitive biological resources include encroachment; introduction of non-native plants and pests (e.g. Argentine ants); and fuel modification.
Figure 2. CNDDB query of Santa Susana tarplant within the Biogeographical Information and Observation System (BIOS; CNDDB 2025e). The red dot denotes the Project site while the green cross hatched polygons denote recorded CNDDB observations of the species.
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Evidence impact may be significant: Take of any endangered, threatened, candidate species that results from the Project is prohibited, except as authorized by State law (Fish & G. Code, §§ 86, 2062, 2067, 2068, 2080, 2085; Cal. Code Regs., tit. 14, § 786.9). Plants with a CRPR of 1B are rare throughout their range, endemic to California, and are seriously or fairly threatened. Impacts to any sensitive or special status species should be considered significant under CEQA unless they are clearly mitigated below a level of significance. The Project and environmental document should be conditioned to avoid and/or mitigate for potential impacts to special-status plants if present. Inadequate avoidance, minimization, and mitigation measures for impacts to sensitive or special status species will result in the Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species by CDFW.
Recommended Potentially Feasible Mitigation Measure(s)
Mitigation Measure #3: Rare Plant Surveys
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
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appropriate species-specific identification periods for Nevin’s barberry, Brauton’s milk vetch, Santa Susana tarplant, slender mariposa lily, chaparral nolina, Plummer’s mariposa lily, and any other special status or rare plant which may occur in or around the project site, specifically, May through July when the plants are in bloom, and within one year before ground disturbance. The survey will be in accordance with CNPS’s Botanical Survey Guidelines (CNPS 2001), CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018), and USFWS’s Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants (USFWS 1996).
If the survey confirms that no special-status plant species are present on the project site, no further actions will be required. If the plant survey reveals the presence of special-status plants on the project site, individuals will be flagged for avoidance during construction all occurrences of special status species will be mapped and occurrences within 100 feet of the project activities shall be flagged in the field. A minimum 50-foot buffer shall be placed around all known locations of special-status species within 100- feet of project activities to avoid potential impacts to seed banks and microhabitats that support the species. These buffers shall be flagged/fenced and avoided during Project activities. If the individuals or populations cannot be avoided during construction any phase of the Project, the District or its contractor will retain a qualified botanist or restoration ecologist to prepare a plan to offset impacts to the species salvage, relocation, or propagation and monitoring plan for special-status plants before construction tis initiated. The plan will include restoration, management, maintenance, and monitoring plans developed by a qualified biologist and/or resource specialist and shall be reviewed and approved by CDFW before the start of Project activities and with sufficient time for CDFW to conclude their review. The plan may include methods such as salvage, relocation, or propagation and monitoring for special status plants (Santa Susana tarplant will not be salvaged and relocated). The plan will include provisions that address the techniques, location, and procedures required for the successful establishment of the plant populations. The plan will include provisions for performance that address survivability requirements, maintenance, monitoring, implementation, adaptive management, and the annual reporting requirements. All directly impacted special-status plants will be documented by a qualified botanist. Documentation of impacts special-status plants will include locations, quantity, density and percent cover; key habitat characteristics, including soil type, associated species, hydrology, and topography; and photo documentation of preconstruction conditions. Salvaged or propagated plants will be relocated and protected in perpetuity.
If state-listed endangered, threatened, or rare plants are detected in areas proposed for development, the District shall contact the CDFW to secure incidental take authorization or develop an avoidance strategy that complies with CESA.
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Recommendation #2: CEQA
The MND should be revised to provide a thorough discussion on the Project’s potential direct and indirect impacts on Santa Susana tarplant. If the Project may impact Santa Susana tarplant, the MND should be amended to incorporate more specific measures to minimize and/or mitigate potential impacts to Santa Susana tarplant as well as habitat supporting the species. The discussion should be of a depth and scope that a CESA Incidental Take Permit (ITP) can be issued based on the analysis provided in the final document.
Recommendation #3: Weed Management Plan
Weed management plans should be developed for all Project areas and implemented both during, and for at least 3 yeas post-Project. Non-native weeds including noxious weeds (as listed by the California Invasive Plant Council) (CALIPC 2025) should be prevented from becoming established to control the local spread of invasive plants, both during and after construction. Site visits should be conducted monthly and weekly during the rainy season. The Project areas should be monitored via mapping for new introductions and expansions of non-native weeds. Annual threshold limits, eradication targets, and monitoring should be included in this plan. Monitoring for spread of invasive weeds to adjacent lands should also be included.
COMMENT # 3: Impacts to Coast Live Oak
Issue: CDFW is concerned that the Project may impact individual coast live oaks, a locally important species.
Specific impact: Two coast live oaks are also present along the outer boundary of the Project site(s). It is unclear if Project impacts will cause a decline in the health of the oaks. Impacts to oaks can occur due to construction, grading, grubbing, excavation, and through placement of impermeable surfaces.
Why Impact Would Occur: The MND does not include any avoidance or minimization BIO-Measures specific to oak trees. Within the MND it states, “No ground disturbing activity is planned within 5 feet of the oak trees’ dripline or within 15 feet of the trees’ root zone from the trunk.” However, specific BIO-Measure(s) were not provided to further explain methods to ensure avoidance and minimization of impacts. The oaks individual locations/canopy cover were also not plotted within a figure in relation to the impact areas. Therefore, CDFW cannot assess whether the above proposed distances are accurate or sufficient to protect the integrity of the oaks.
The CEQA document also states, “Mature native trees, including oaks, are protected by the City of Simi Valley Mature Tree Preservation Ordinance, the Ventura County Tree Protection Ordinance, and the Ventura County Non-Coastal Zoning Ordinance.” However, the sizes were not disclosed within the CEQA document, so it is unclear if the oaks meet the requirements or definitions of “mature trees.” If the oaks described within DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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the CEQA document are exempt from local tree protection ordinances, note that the Project is not exempt from State laws and Fish and Game code. Coast live oak and coast live oak woodland is considered locally important and should be avoided by Project activities. If avoidance is not possible, coast live oak woodland and individual coast live oaks should be mitigated for to achieve a no net-loss of habitat/individuals.
Finally, an arborist report was not provided to discuss the current health of the oaks. A baseline should be taken before Project activities to inform future monitoring.
Without more specific species information CDFW is not able to adequately assess environmental impacts or the adequacy of proposed avoidance, minimization, or mitigation measures.
Evidence Impact Would Be Significant: Due to the historic and on-going loss of this ecologically important vegetation community, oak trees and woodlands are not only protected by local ordinances but State ordinances as well. CDFW considers oak woodlands a sensitive vegetation community. Oak woodlands have higher levels of biodiversity than any other terrestrial ecosystem in California. Oak trees provide nesting and perching habitat for approximately 170 species of birds (Griffin and Muick 1990).
Coast live oak and old-growth oak trees (native oak tree that is greater than 15 inches in diameter) are of importance due to increased biological values and increased temporal loss. Over 330 species of birds, mammals, reptiles, and amphibians depend on oak woodlands in California at some stage in their life cycle (CalPIF 2002). Large oak trees in oak woodland habitats are important for cover, nesting sites for cup nesting species and cavity nesting species, as well as caching sites for birds storing acorns (CalPIF 2002). Oak woodlands also serve several important ecological functions important within an ecosystem such as protecting soils from erosion and land sliding; regulating water flow in watersheds; and maintaining water quality in streams and rivers.
Impacts to sensitive natural communities should be considered significant under CEQA unless they are clearly mitigated below a level of significance. CDFW considers oak woodlands to be a sensitive plant community. Oak trees and woodlands are protected by the Oak Woodlands Conservation Act (pursuant under Fish and Game Code sections 1360-1372) and Public Resources Code section 21083.4 due to the historic and ongoing loss of these resources. Moreover, CDFW’s Areas of Conservation Emphasis – Significant Habitats dataset includes oak woodlands as a Terrestrial Significant Habitat based on its priority for conservation and acquisition planning for some counties, local jurisdictions, and the Wildlife Conservation Board (CDFW 2025f).
Recommended potentially feasible mitigation measure(s):
Mitigation Measure #4: Tree protection signs should be erected around all tree groups with canopies that fall within 20 feet of construction activities. Fencing or flagging should be placed along the dripline and an additional 5 feet (protected tree zone) in areas of potential impact. For any trees that would be encroached upon by construction activities, fencing shall be placed as far away from trunk of the tree as possible while still allowing the required construction activities to proceed.
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Mitigation Measure #5: A pre-construction tree protection training should be delivered between the contractors and arborist. The arborist will instruct the contractors on tree protection practices. All equipment operators and spotters, assistants, or those directing operators from the ground, shall provide written acknowledgement of their receiving training. This training should include information on the location and marking of protected trees, the necessity of preventing damage, and the discussion of work practices.
Mitigation Measure #6: The District should work with an arborist to conduct an Arborist study to compose a tree monitoring plan. The Arborist Study should be conducted within portions of the project footprint occurring within 20 feet of the canopy drip line of protected trees. The study should plot the location of protected trees within this zone and identify each protected tree and any trees to be impacted. Monitoring should occur during Project activities and following the Project. Monitoring should be conducted on a monthly basis. The Arborist Report should be prepared by a Certified Arborist in compliance with the County of Ventura ordinance guidelines. The Arborist Report should include the following at minimum:
• An inventory of all trees containing a canopy drip line within 20 feet of the project footprint. Inventory data should record, at minimum: diameter at breast height (DBH), height, canopy cover information/mapping, health and vigor rating. • Photographs of each regulated tree which may be encroached upon by the Project.
• Description of proposed site development activities including, but not limited to, excavation, any tree trimming, and construction access routes. • A project-specific Tree Protection Plan should be prepared which would include site plans, protective tree fencing, the designated tree protection zone (identifying an area sufficiently large enough to protect the tree and its roots from disturbance), activities prohibited/permitted within the tree protective zone, encroachment boundaries, and potential transplanting or replacement tree plantings.
Mitigation Measure #7: Replacement for individual trees with a diameter at breast height (DBH) between 12-24 inches should be mitigated for at a ratio of 5:1. Trees with a DBH greater than 24 inches should be mitigated at a 10:1 ratio.
Mitigation Measure #8: Prior to removing any oak or the understory vegetation, the District should prepare an Oak Tree Restoration Plan. The Oak Tree Restoration Plan should prescribe the following:
1) Species-specific planting methods;
2) Planting schedule;
3) Measures to control exotic vegetation and protection from herbivory; 4) Measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Measurable success criteria should be DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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based on site/habitat conditions prior to impact and/or functional local native oak shrublands/woodlands as reference sites;
5) Contingency measures if the success criteria is not met; 6) Long-term monitoring for at least 10 years, with a minimum of seven years without supplemental irrigation;
7) Adaptive management techniques, including replacement plants if necessary; and 8) Annual reporting criteria and requirements.
Mitigation Measure #9: For off-site mitigation, the District should protect mitigation lands in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage mitigation lands. An appropriate endowment should be provided for the long-term management of mitigation lands. A conservation easement and endowment funds should be fully acquired, established, transferred, or otherwise executed prior to any ground-disturbing activities and vegetation removal.
Recommendation #4: CDFW recommends avoiding impacts to natural vegetation communities or individual coast live oaks. Possible reconfiguration of Project elements or disturbance areas could lessen impacts to individual coast live oak and coast live oak communities.
ADDITIONAL COMMENTS
Recommendation #5: Coastal California Gnatcatcher and Mitigation Measure BIO- 6:
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
Before the start of construction, the District or its contractor shall retain a qualified biologist to conduct protocol coastal California gnatcatcher surveys in accordance with the guidelines issued by the USFWS (USFWS 1997). Surveys shall be conducted by a USFWS-permitted biologist before the start of construction. The results of the survey shall be provided in a report to USFWS within 45 days of completion of the survey, and no less than 30 days before the start of groundbreaking activities.
If protocol surveys determine that occupied suitable habitat is present in the project footprint plus a 300500-foot buffer where accessible, the following measures shall be implemented during project construction to avoid or minimize direct take of coastal California gnatcatcher:
1. All grubbing or grading taking place within occupied suitable habitat of the coastal California gnatcatcher (defined as within 300 500 feet of any gnatcatcher sightings) during construction shall be conducted from September 1 through February 14, which is outside the coastal California gnatcatcher breeding season.
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2. When conducting any construction activities during the coastal California gnatcatcher breeding season, February 15 through August 30, within or adjacent to occupied coastal California gnatcatcher habitat, a USFWS permitted biologist shall survey for nesting coastal California gnatcatcher approximately once per week within 300 500 feet of the construction area, where accessible, for the duration of the activity in that area during the breeding season.
3. If an active nest is located, a 300 500 foot avoidance buffer shall be established around each nest site; however, there may be a reduction of this buffer zone depending on site-specific conditions such as topography, line-of-sight to the nest, or the existing ambient level of activity. The District shall contact USFWS to determine the appropriate buffer zone. No construction shall take place within this buffer until the biologist can verify that the nest is no longer active.
4. Conspicuous construction fencing shall be maintained in place to protect all habitat outside the approved construction area until the conclusion of construction. Before commencement of grading, the project biologist shall confirm with the contractor or a licensed surveyor that the construction fencing has been placed at the outer edge of the construction area.
5. All construction activities shall take place only on the construction side (i.e., inside) of the fenced area. Grading materials shall be stored either inside the fenced development area or in an area approved by the project biologist.
6. A biological monitor familiar with coastal California gnatcatcher and its habitat shall be present during all vegetation clearing and other activities within coastal sage scrub and shall monitor the project to ensure that there are no unanticipated impacts to the species and its habitat.
7. Access to the site shall be via pre-existing access routes to the greatest extent possible.
8. All active coastal California gnatcatcher nests shall be reported within 24 hours to the USFWS upon detection.
9. The biological monitor shall halt work if it is determined that active nests would be disturbed by construction activities, until further direction or approval to work is obtained from the appropriate agencies.
10. The project site shall be kept as clean of debris as possible. All food-related trash items shall be enclosed in sealed containers and regularly removed from the site.
11. In the event that coastal California gnatcatcher individuals or occupied habitat cannot be avoided and incidental take is expected, the District or its contractor shall obtain necessary take authorization from the USFWS.
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CDFW also recommends the District incorporate the Mitigation proposal included within the MND into a BIO-6 or a separate BIO-Measure. CDFW recommends the District revise the proposal to incorporate the underlined language and remove the language in strikethrough:
Impacts requiring mitigation include permanent and temporary impacts to occupied and unoccupied habitat. Permanent and temporary impacts to occupied habitat shall require acquisition and preservation of occupied habitat off site at a location approved by USFWS. Mitigation for permanent and temporary impacts to occupied coastal California gnatcatcher shall be at a ratio of 2:1 for preserved to impacted habitat. In the event occupied habitat is not available at an off-site location, mitigation credits shall be purchased at a USFWS-approved mitigation bank. Temporary impacts to occupied habitat and Impacts to all unoccupied habitat (as determined by protocol surveys) shall be mitigated at a 1:1 ratio and can include 1:1 on-site restoration and 1:1 acquisition and preservation of occupied habitat off site.
Coastal sage scrub habitat that is not designated for removal shall be avoided and protected with appropriate buffer zones marked with high-visibility material. Project work areas shall be clearly flagged or similarly marked at the outer boundaries to define the limit of work activities. No unauthorized entry or construction disturbance shall be permitted within protective buffer zones.
Recommendation #6: Alliance-level Vegetation Mapping:
The MND states, “At the proposed Crown Hill Tank site, approximately 50 percent of existing vegetation within 10 feet of the access roadway and tank pad would be removed.” However, this vegetation removal impact area is not represented in any figures nor is there an alliance-level vegetation map which depicts areas of impact in relation to vegetation communities. Likewise, other project elements were not included within a map such as the metal gate alignment and other Project elements. CDFW recommends surveying the project footprint and fuel modification area (if applicable) to produce an alliance-level plant communities map. Vegetation surveys should be conducted following systematic field techniques outlined by CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018g). To determine the rarity ranking of vegetation communities on a specific Project site(s), CDFW utilizes vegetation descriptions found in the Manual of California Vegetation (MCV). The MCV alliance/association community names should be provided as CDFW only tracks rare natural communities using this classification system (found online at http://vegetation.cnps.org/). CDFW recommends the environmental document provide measures to fully mitigate the loss of individual ESA- and CESA-listed plants and habitat.
1. The MND should provide a detailed map (1:24,000 or larger) showing which plants or populations will be impacted and provide a table that clearly documents DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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the number of plants and acres of supporting habitat impacted, and plant composition (e.g., density, cover, abundance) within impacted habitat (e.g., species list separated by vegetation class; density, cover, abundance of each species).
2. The MND should provide species-specific measures for on-site mitigation. Each species-specific mitigation plan should adopt an ecosystem-based approach and be of sufficient detail and resolution to describe the following at a minimum: 1) identify the impact and level of impact (e.g., acres or individual plants/habitat impacted); 2) location of on-site mitigation and adequacy of the location(s) to serve as mitigation; 3) assessment of appropriate reference sites; 4) scientific [genus and species (subspecies/variety if applicable)] of plants being used for restoration; 5) location(s) of propagule source; 6) species-specific planting methods (i.e., container or seed); 7) measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover); 8) long-term monitoring, and; 9) adaptive management techniques.
3. Additionally, considerations should be made regarding timing of these field surveys to ensure accuracy in determining what plants exist on site. Adequate information about special status plants and natural communities present in a project area will enable reviewing agencies and the public to effectively assess potential impacts to special status plants or natural communities and will guide the development of minimization and mitigation measures (CDFW 2018g).
Recommendation #7: BIO-5 Nesting Bird Pre-Construction Survey and Impact Avoidance:
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
To avoid impacting active bird nests, juveniles or adults, project activities, including vegetation clearing and tree removal, shall be conducted outside of the breeding season (February 1 through September 15, and as early as January 1 for some raptors) to the extent feasible.
If project activities occur between January February 1 and September 15, a pre- construction nesting bird survey shall be conducted by a qualified biologist no more than 5 7 days prior to initiation of ground disturbance and vegetation removal. before the activity to survey for bird nests. The survey area shall include the project footprint and a 300100-foot buffer for passerine species and a 500300-foot buffer for coastal California gnatcatcher and raptor species. If construction lapses for five days or longer, the qualified biologist shall conduct another focused survey before project activities are reinitiated. Following the survey, the following shall be implemented:
• A nesting bird survey report shall be submitted to the District prior to the initiation of project activities. The report shall detail the results of the survey DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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including identification of the location of any active nests and shall describe any nest monitoring that shall be conducted and/or whether any avoidance buffers shall be established.
• If active nests are identified during the survey and/or work is scheduled to take place within 300 100 feet of active passerine nests or 500300 feet of active coastal California gnatcatcher and raptor nests, a qualified biologist shall determine appropriate avoidance buffers. The buffer shall be the minimum distance required to avoid take of the nest and shall be determined based on the species identified, activities proposed, level of existing noise, and location of the nest.
• A qualified biologist shall determine when nesting is completed and when any avoidance buffers may be removed.
• If nesting bird monitoring is conducted, a nesting bird monitoring report shall be submitted to the District detailing the results of monitoring activities and measures implemented that avoided impacts to the nest. The report shall be submitted within 30 days of the completion of the nesting bird monitoring.
Recommendation #8: BIO-Measures for Special Status Herpetofauna:
The MND does not provide any BIO-Measures specifically to avoid and minimize impacts to special status herpetofauna which may be present in or around the Project area. CDFW recommends additional BIO-Measures are added and included to minimize potential impacts. These measures may include focused surveys for species likely to occur within the Project site(s). Surveys should typically be scheduled during the summer months (June and July) when these animals are most likely to be encountered.
To achieve 100 percent visual coverage, CDFW recommends surveys be conducted with parallel transects at approximately 20 feet apart and walked on site in appropriate habitat suitable for each species. Suitable habitat consists of areas of sandy, loose, and moist soils, typically under the sparse vegetation of scrub, chaparral, and within the duff of oak woodlands.
Recommendation #9: Potential Impacts to Bat Species
It is not clear how the existing Alta Vista 1 water tank will be removed as the method of demolition was not explained within the MND. However, CDFW recommends providing BIO-Measures for bat species to protect them from utilizing the tanks at any point in the Project’s lifetime. This may include surveys before demolition and ensuring there are screens on any areas that may potentially allow bats to enter the constructed Crown Hill tank.
Recommendation #10: Tree Removal and Mitigation:
It is not clear if the proposed replacement following the removal of ten trees is sufficient to mitigate impacts. The type of trees and their DBH were not disclosed within the MND.
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proposed species. At minimum, trees should be replaced at a 1:1 ratio; however, this does not address temporal impacts. CDFW recommends that the District disclose the type of trees slated for removal, their DBH, the specific species proposed for replacement, and a planting and monitoring plan to track the success of these plantings.
CDFW also recommends increasing the number of trees to be planted to address the temporal loss of nesting habitat and to ensure impacts are mitigated below the threshold of significance.
Recommendation #11: LSA:
Within the MND it states, “No federal or state jurisdictional waters exist within the project site; as such, no impacts would occur on State or federally protected wetlands.” However, a drainage feature is present to the east/north east of the tank construction site. If any construction, vegetation removal, or fuel modification may impact the bed, bank, channel, or associated vegetation of the drainage, CDFW recommends submitting a Lake and Streambed Alteration Notification.
CDFW exercises its regulatory authority (Fish and Game Code, section 1600 et seq.) to conserve fish and wildlife resources which includes rivers, streams, or lakes and associated natural communities. Fish and Game Code, section 1602 requires any person, state or local governmental agency, or public utility to notify CDFW prior to beginning any activity that may do one or more of the following:
• Divert or obstruct the natural flow of any river, stream, or lake; • Change the bed, channel, or bank of any river, stream, or lake; • Use material from any river, stream, or lake; or
• Deposit or dispose of material into any river, stream, or lake.
Recommendation #12: Fuel Modification:
If the Project includes fuel modification, CDFW recommends that the final environmental documents include avoidance and mitigation measures for any fuel modification activities conducted within and adjacent to the Project area(s). A weed management plan should be developed for all areas adjacent to open space that will be subject to fuel modification disturbance. CDFW also recommends that any irrigation proposed in fuel modification zones do not allow for the introduction of invasive Argentine ants. Monitoring should also include parameters to identify possible introduction of Argentine ants.
Recommendation #13: Native Landscaping:
CDFW recommends the District provides a planting palette to CDFW, specifying the vegetation that will be used as landscaping for this Project. The Project proponent should use only native species found in naturally occurring vegetation communities within or adjacent to the Project site. The Project proponent should not plant, seed, or otherwise introduce nonnative, invasive plant species to areas that are adjacent to DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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and/or near native habitat areas. CDFW recommends the Project proponent restrict use of any species, particularly ‘moderate’ or ‘high’ listed by the California Invasive Plant Council. These species are documented to have substantial and severe ecological impacts on physical processes, plant and animal communities, and vegetation structure.
Recommendation #14: Invasive Pests and Diseases:
If the Project activities require remove of vegetation that could host pest species, the District should work with the certified arborist to identify all trees and species for removal from the Project site and inspect those trees for contagious tree diseases including but not limited to: thousand canker disease (USDA 2025), polyphagous shot hole borer (UCANR 2025), and goldspotted oak borer (UCIPM 2021). If invasive pests and/or diseases are detected, the District should provide an infectious tree disease management plan and describe how it will be implemented to avoid significant impacts under CEQA. To avoid the spread of infectious tree diseases, diseased trees should not be transported from the Project site(s) without first being treated using best available management practices relevant for each tree disease observed.
Recommendation #15: Mitigation and Monitoring Reporting Plan:
CDFW recommends the Project’s environmental document include mitigation measures recommended in this letter. CDFW has provided comments via a mitigation monitoring and reporting plan to assist in the development of feasible, specific, detailed (i.e., responsible party, timing, specific actions, location), and fully enforceable mitigation measures (CEQA Guidelines, § 15097; Pub. Resources Code, § 21081.6). The Lead Agency is welcome to coordinate with CDFW to further review and refine the Project’s mitigation measures. Per Public Resources Code section 21081.6(a)(1), CDFW has provided a summary of our suggested mitigation measures and recommendations in the form of an attached Draft Mitigation Monitoring and Reporting Plan (Attachment A).
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 website
5 provides direction regarding the types of
information that should be reported and allows on-line submittal of field survey forms.
5 https://wildlife.ca.gov/Data/CNDDB
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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 Form6.
The District should ensure data collected for the preparation of the MND is properly submitted.
FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document 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 environmental document filing 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 MND to assist the District in identifying and mitigating Project impacts on biological resources. CDFW requests an opportunity to review and comment on any response that the District has to our comments and to receive notification of any forthcoming hearing date(s) for the Project (CEQA Guidelines, § 15073(e)).
Questions regarding this letter or further coordination should be directed to Angela Castanon7, Environmental Scientist.
Sincerely,
Victoria Tang
Environmental Program Manager
South Coast Region
ATTACHMENTS
Attachment A: Draft Mitigation, Monitoring, and Reporting Program ec: California Department of Fish and Wildlife
Victoria Tang, Environmental Program Manager
Frederic (Fritz) Rieman, Senior Environmental Scientist (Supervisor)
6 https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities/Submit 7 Phone: 626-513-6308; Email: [email protected] DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
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Angela Castanon, Environmental Scientist
Office of Land Use and Climate Innovation
S
[email protected]
RE
FERENCES
CALIPC. 2025. Invasive Plants. Available at: Invasive Plants – California Invasive Plant Coun
cil
[
CalPIF] California Partners in Flight. 2002. Version 2.0. The oak woodland bird conservation plan: a strategy for protecting and managing oak woodland habitats and associated birds in California (S. Zack, lead author). Point Reyes Bird Observatory, Stinson Beach, CA. Available from: http://www.prbo.org/calpif/plans.html CalS
cape. 2025. Santa Susana Tarplant. Available at: Santa Susana Tarplant [
CDFW 2025a] California Department of Fish and Wildlife. 2025. Crotch’s Bumble Bee Range Dataset 3095. Available at: https://data.ca.gov/dataset/crotchs-bumble-bee- r
ange-cdfwds3095
[
CDFW 2025b] California Department of Fish and Wildlife. 2025. California Natural Diversity Database. Available from: https://wildlife.ca.gov/Data/CNDDB [
CDFW 2023c] California Department of Fish and Wildlife. 2023. Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species. Available from:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline [
CDFW 2025d] California Department of Fish and Wildlife. 2025. California Natural Diversity Database. Available from: BIOS Viewer@CDFW
[
CDFW 2025e] California Department of Fish and Wildlife. 2025. California Natural Diversity Database. Available from: https://wildlife.ca.gov/Data/CNDDB [
CDFW 2025f]. California Department of Fish and Wildlife. 2025. Areas of Conservation Emphasis. Available at: Areas of Conservation Emphasis (ACE) [
CDFW 2018g] California Department of Fish and Wildlife. 2018. CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. Available from:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959 Hatfie
ld, R, S Jepsen, E Mader, S H Black, and M Shepherd. 2012. Conserving Bumble Bees Guidelines for Creating and Managing Habitat for America's Declining Pollinators.
Portland, OR: The Xerces Society for Invertebrate Conservation Doc
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INaturalist. 2025. Santa Susana tarplant in December 2023 by Morgan Stickrod · i
Naturalist. Available from: inaturalist.org
L
A Times. 1989. Fading Fast : $16,000 and 46 dead plants later, the tar plant is still in danger. Available from: www.latimes.com
[
UCANR] UC Agriculture and Natural Science. 2025. Managing Invasive Shot Hole Borers in Southern California. Available from:
https://ucanr.edu/blogs/blogcore/postdetail.cfm?postnum=28508 [
UCIPM] UC Integrated Pest Management Program. 2021. Goldcpotted Oak Borer.
Available from: Goldspotted Oak Borer Management Guidelines--UC IPM [US
DA[. 2025. Thousand Cankers Disease. Available from:
www.invasivespeciesinfo.gov
Ve
ntura County Viewer. 2025. County View. Available from: Geocortex Viewer for HTM
L5
Doc
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ATTACHMENT A: DRAFT MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) CDFW provides the following language to be incorporated into the MMRP for the Project.
Mitigation Measure Timing Responsible
Party
Mitigation Measure #1: Crotch’s Bumble Bee and Mitigation Measure BIO- 4 CDFW recommends the District revise Mitigation Measure BIO – 4 to incorporate the underlined language and remove the language in strikethrough:
The project applicant shall retain a qualified biologist with appropriate handling permits to conduct protocol-level surveys following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023c). Focused surveys shall also be conducted throughout the entire Project site and during the appropriate flying season to ensure no missed detection of Crotch’s bumble bee occurs. Survey results, including negative findings, shall be submitted to CDFW and the District prior to implementing Project ground-disturbing activities. If Crotch’s bumble bee is detected on site, the Project proponent shall coordinate with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq). The Project proponent shall comply with the mitigation measures detailed in the take authorization issued by CDFW. The Project proponent shall provide a copy of a fully executed take authorization to the District prior to implementing Project ground-disturbing activities and vegetation removal. Pre- construction surveys for Crotch’s bumble bee, including ground nests, shall be conducted within all suitable habitats adjacent to the project site within the 50- foot buffer before initial grounddisturbing activities (e.g., grubbing/removing vegetation, excavation, grading, construction). These surveys aim to identify Prior to Project
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individuals and/or active nest colonies in areas adjacent to the site. The pre- construction surveys shall follow the methodologies set out in the CDFW Survey Considerations for CESA Candidate Bumble Bee (CDFW 2023) or other survey methodology approved by CDFW. If the pre-construction surveys identify individuals or active nest colonies adjacent to the project footprint:
• An appropriate no-disturbance buffer zone shall be established around the active nest colony to reduce the risk of disturbance or accidental take. The buffer distance shall be established by a qualified biologist. • The project proponent/operator shall consult with a qualified biologist to discuss considerations and recommendations on implementing project activities to avoid take of Crotch’s bumble bee.
If an avoidance buffer is required as described above, construction activities shall not occur within that buffer zone until a qualified biologist determines the nest to no longer be active (i.e., no Crotch’s bumble bee are seen flying in or out of the nest for three consecutive days [during suitable weather conditions when Crotch’s bumble bee are typically active] indicating the colony has completed its nesting season and the queens have dispersed from the colony), after which construction activities may resume within that buffer zone
Mitigation Measure #2 No Net Loss of Habitat
If California Fish and Game Commission does not list Crotch's bumble bee under CESA, it will still remain an invertebrate of conservation priority under the California Terrestrial and Vernal Pool Invertebrates of Conservation Priority.
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Thus, there shall be no net loss of suitable habitat for Crotch’s bumble bee. The County shall offset impacts on habitat for Crotch’s bumble bee at no less than 2:1, so there is no net loss of suitable habitat.
Mitigation Measure #3: Rare Plant Surveys
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
A qualified botanist shall be retained by the District or its contractor to conduct a preconstruction survey on the project site for special-status plant species during the appropriate species-specific identification periods for Nevin’s barberry, Brauton’s milk vetch, Santa Susana tarplant, slender mariposa lily, chaparral nolina, Plummer’s mariposa lily, and any other special status or rare plant which may occur in or around the project site, specifically, May through July when the plants are in bloom, and within one year before ground disturbance. The survey will be in accordance with CNPS’s Botanical Survey Guidelines (CNPS 2001), CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018e), and USFWS’s Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants (USFWS 1996).
If the survey confirms that no special-status plant species are present on the project site, no further actions will be required. If the plant survey reveals the presence of special-status plants on the project site, individuals will be flagged for avoidance during construction all occurrences of special status species will be mapped and occurrences within 100 feet of the project activities shall be flagged in the field. A minimum 50-foot buffer shall be placed around all known Prior to/During
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locations of special-status species within 100-feet of project activities to avoid potential impacts to seed banks and microhabitats that support the species.
These buffers shall be flagged/fenced and avoided during Project activities. If the individuals or populations cannot be avoided during construction any phase of the Project, the District or its contractor will retain a qualified botanist or restoration ecologist to prepare a plan to offset impacts to the species salvage, relocation, or propagation and monitoring plan for special-status plants before construction tis initiated. The plan will include restoration, management, maintenance, and monitoring plans developed by a qualified biologist and/or resource specialist and shall be reviewed and approved by CDFW before the start of Project activities and with sufficient time for CDFW to conclude their review. The plan may include methods such as salvage, relocation, or propagation and monitoring for special status plants (Santa Susana tarplant will not be salvaged and relocated). The plan will include provisions that address the techniques, location, and procedures required for the successful establishment of the plant populations. The plan will include provisions for performance that address survivability requirements, maintenance, monitoring, implementation, adaptive management, and the annual reporting requirements. All directly impacted special-status plants will be documented by a qualified botanist.
Documentation of impacts special-status plants will include locations, quantity, density and percent cover; key habitat characteristics, including soil type, associated species, hydrology, and topography; and photo documentation of preconstruction conditions. Salvaged or propagated plants will be relocated and protected in perpetuity.
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If state-listed endangered, threatened, or rare plants are detected in areas proposed for development, the District shall contact the CDFW to secure incidental take authorization or develop an avoidance strategy.
Mitigation Measure #4: Tree protection signs should be erected around all tree groups with canopies that fall within 20 feet of construction activities. Fencing or flagging should be placed along the dripline and an additional 5 feet (protected tree zone) in areas of potential impact. For any trees that would be encroached upon by construction activities, fencing shall be placed as far away from trunk of the tree as possible while still allowing the required construction activities to proceed.
Prior to Project
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Mitigation Measure #5: A pre-construction tree protection training should be delivered between the contractors and arborist. The arborist will instruct the contractors on tree protection practices. All equipment operators and spotters, assistants, or those directing operators from the ground, shall provide written acknowledgement of their receiving training. This training should include information on the location and marking of protected trees, the necessity of preventing damage, and the discussion of work practices.
Prior to Project
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Mitigation Measure #6: The District should work with an arborist to conduct an Arborist study to compose a tree monitoring plan. The Arborist Study should be conducted within portions of the project footprint occurring within 20 feet of the canopy drip line of protected trees. The study should plot the location of protected trees within this zone and identify each protected tree and any trees to be impacted. Monitoring should occur during Project activities and following the Project. Monitoring should be conducted on a monthly basis. The Arborist Prior to Project
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Report should be prepared by a Certified Arborist in compliance with the County of Ventura ordinance guidelines. The Arborist Report should include the following at minimum:
• An inventory of all trees containing a canopy drip line within 20 feet of the project footprint. Inventory data should record, at minimum: diameter at breast height (DBH), height, canopy cover information/mapping, health and vigor rating.
• Photographs of each regulated tree which may be encroached upon by the Project.
• Description of proposed site development activities including, but not limited to, excavation, any tree trimming, and construction access routes. • A project-specific Tree Protection Plan should be prepared which would include site plans, protective tree fencing, the designated tree protection zone (identifying an area sufficiently large enough to protect the tree and its roots from disturbance), activities prohibited/permitted within the tree protective zone, encroachment boundaries, and potential transplanting or replacement tree plantings.
Mitigation Measure #7: Replacement for individual trees with a diameter at breast height (DBH) between 12-24 inches should be mitigated for at a ratio of 5:1. Trees with a DBH greater than 24 inches should be mitigated at a 10:1 ratio.
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Mitigation Measure #8: Prior to removing any oak or the understory vegetation, the District should prepare an Oak Tree Restoration Plan. The Oak Tree Restoration Plan should prescribe the following:
1) Species-specific planting methods;
2) Planting schedule;
3) Measures to control exotic vegetation and protection from herbivory; 4) Measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Measurable success criteria should be based on site/habitat conditions prior to impact and/or functional local native oak
shrublands/woodlands as reference sites;
5) Contingency measures if the success criteria is not met; 6) Long-term monitoring for at least 10 years, with a minimum of seven years without
supplemental irrigation;
7) Adaptive management techniques, including replacement plants if necessary; and
8) Annual reporting criteria and requirements.
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Project
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Mitigation Measure #9: For off-site mitigation, the District should protect mitigation lands in perpetuity under a conservation easement dedicated to a local land conservancy or other appropriate entity that has been approved to hold and manage mitigation lands. An appropriate endowment should be provided for the long-term management of mitigation lands. A conservation easement and endowment funds should be fully acquired, established, Prior to Project
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transferred, or otherwise executed prior to any ground-disturbing activities and vegetation removal.
Recommendation #1: CEQA for Crotch’s Bumble Bee
CDFW’s issuance of an ITP for a Project is subject to CEQA. As a Responsible Agency, CDFW may consider the CEQA document from the lead agency/Project proponent for the Project. However, additional documentation may be required as part of an ITP application for the Project in order for CDFW to adequately develop an accurate take analysis and identify measures that would fully mitigate for take of CESA-listed species. To minimize additional requirements by CDFW pursuant to Fish and Game Code section 2081 and/or under CEQA, the Project’s CEQA document should fully identify the potential impacts to Crotch’s bumble bee and provide adequate avoidance, mitigation, monitoring, and reporting commitments for issuance of the ITP.
Prior to Project
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Recommendation #2: CEQA
The MND should be revised to provide a thorough discussion on the Project’s potential direct and indirect impacts on Santa Susana tarplant. If the Project may impact Santa Susana tarplant, the MND should be amended to incorporate more specific measures to minimize and/or mitigate potential impacts to Santa Susana tarplant as well as habitat supporting the species. The discussion should be of a depth and scope that a CESA Incidental Take Permit (ITP) can be issued based on the analysis provided in the final document.
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Recommendation #3: Weed Management Plan
Weed management plans shall be developed for all Project areas and implemented both during, and for at least 3 yeas post-Project. Non-native weeds including noxious weeds (as listed by the California Invasive Plant Council) (CALIPC 2025) should be prevented from becoming established to control the local spread of invasive plants, both during and after construction. Site visits should be conducted monthly and weekly during the rainy season. The Project areas should be monitored via mapping for new introductions and expansions of non-native weeds. Annual threshold limits, eradication targets, and monitoring should be included in this plan. Monitoring for spread of invasive weeds to adjacent lands should also be included.
Prior to Project
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Recommendation #4: CDFW recommends avoiding impacts to natural vegetation communities or individual coast live oaks. Possible reconfiguration of Project elements or disturbance areas could lessen impacts to individual coast live oak and coast live oak communities.
Prior to Project
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Lead Agency
Recommendation #5: Coastal California Gnatcatcher and Mitigation Measure BIO-6:
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
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Before the start of construction, the District or its contractor shall retain a qualified biologist to conduct protocol coastal California gnatcatcher surveys in accordance with the guidelines issued by the USFWS (USFWS 1997). Surveys shall be conducted by a USFWS-permitted biologist before the start of construction. The results of the survey shall be provided in a report to USFWS within 45 days of completion of the survey, and no less than 30 days before the start of groundbreaking activities.
If protocol surveys determine that occupied suitable habitat is present in the project footprint plus a 300500-foot buffer where accessible, the following measures shall be implemented during project construction to avoid or minimize direct take of coastal California gnatcatcher:
1. All grubbing or grading taking place within occupied suitable habitat of the coastal California gnatcatcher (defined as within 300 500 feet of any gnatcatcher sightings) during construction shall be conducted from September 1 through February 14, which is outside the coastal California gnatcatcher breeding season.
2. When conducting any construction activities during the California gnatcatcher breeding season, February 15 through August 30, within or adjacent to occupied coastal California gnatcatcher habitat, a USFWS permitted biologist shall survey for nesting coastal California gnatcatcher approximately once per week within 300 500 feet of the construction area, where accessible, for the duration of the activity in that area during the breeding season.
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buffer zone depending on site-specific conditions such as topography, line-of- sight to the nest, or the existing ambient level of activity. The District shall contact USFWS to determine the appropriate buffer zone. No construction shall take place within this buffer until the biologist can verify that the nest is no longer active.
4. Conspicuous construction fencing shall be maintained in place to protect all habitat outside the approved construction area until the conclusion of construction. Before commencement of grading, the project biologist shall confirm with the contractor or a licensed surveyor that the construction fencing has been placed at the outer edge of the construction area.
5. All construction activities shall take place only on the construction side (i.e., inside) of the fenced area. Grading materials shall be stored either inside the fenced development area or in an area approved by the project biologist.
6. A biological monitor familiar with coastal California gnatcatcher and its habitat shall be present during all vegetation clearing and other activities within coastal sage scrub and shall monitor the project to ensure that there are no unanticipated impacts to the species and its habitat.
7. Access to the site shall be via pre-existing access routes to the greatest extent possible.
8. All active coastal California gnatcatcher nests shall be reported within 24 hours to the USFWS upon detection.
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9. The biological monitor shall halt work if it is determined that active nests would be disturbed by construction activities, until further direction or approval to work is obtained from the appropriate agencies.
10. The project site shall be kept as clean of debris as possible. All food-related trash items shall be enclosed in sealed containers and regularly removed from the site.
11. In the event that coastal California gnatcatcher individuals or occupied habitat cannot be avoided and incidental take is expected, the District or its contractor shall obtain necessary take authorization from the USFWS.
CDFW also recommends the District incorporate the Mitigation proposal included within the MND into a BIO-6 or a separate BIO-Measure. CDFW recommends the District revise the proposal to incorporate the underlined language and remove the language in strikethrough:
Impacts requiring mitigation include permanent and temporary impacts to occupied and unoccupied habitat. Permanent and temporary impacts to occupied habitat shall require acquisition and preservation of occupied habitat off-site at a location approved by USFWS. Mitigation for permanent and temporary impacts to occupied coastal California gnatcatcher shall be at a ratio of 2:1 for preserved to impacted habitat. In the event occupied habitat is not available at an off-site location, mitigation credits shall be purchased at a USFWS-approved mitigation bank. Temporary impacts to occupied habitat and Impacts to all unoccupied habitat (as determined by protocol surveys) shall be mitigated at a 1:1 ratio and can include 1:1 on-site restoration and 1:1 acquisition and preservation of occupied habitat off-site.
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Coastal sage scrub habitat that is not designated for removal shall be avoided and protected with appropriate buffer zones marked with high-visibility material.
Project work areas shall be clearly flagged or similarly marked at the outer boundaries to define the limit of work activities. No unauthorized entry or construction disturbance shall be permitted within protective buffer zones.
Recommendation #6: Alliance-level Vegetation Mapping:
The MND states, “At the proposed Crown Hill Tank site, approximately 50 percent of existing vegetation within 10 feet of the access roadway and tank pad would be removed.” However, this vegetation removal impact area is not represented in any figures nor is there an alliance-level vegetation map which depicts areas of impact in relation to vegetation communities. Likewise, other project elements were not included within a map such as the metal gate alignment and other Project elements. CDFW recommends surveying the project footprint and fuel modification area (if applicable) to produce an alliance- level plant communities map. Vegetation surveys should be conducted following systematic field techniques outlined by CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018). To determine the rarity ranking of vegetation communities on a specific Project site(s), CDFW utilizes vegetation descriptions found in the Manual of California Vegetation (MCV). The MCV alliance/association community names should be provided as CDFW only tracks rare natural communities using this classification system (found online at http://vegetation.cnps.org/). CDFW recommends the environmental document provide measures to fully mitigate the loss of individual ESA- and CESA-listed plants and habitat.
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1. The MND should provide a detailed map (1:24,000 or larger) showing which plants or populations will be impacted and provide a table that clearly documents the number of plants and acres of supporting habitat impacted, and plant composition (e.g., density, cover, abundance) within impacted habitat (e.g., species list separated by vegetation class; density, cover, abundance of each species).
2. The MND should provide species-specific measures for on-site mitigation.
Each species-specific mitigation plan should adopt an ecosystem-based approach and be of sufficient detail and resolution to describe the following at a minimum: 1) identify the impact and level of impact (e.g., acres or individual plants/habitat impacted); 2) location of on-site mitigation and adequacy of the location(s) to serve as mitigation; 3) assessment of appropriate reference sites; 4) scientific [genus and species (subspecies/variety if applicable)] of plants being used for restoration; 5) location(s) of propagule source; 6) species-specific planting methods (i.e., container or seed); 7) measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover); 8) long-term monitoring, and; 9) adaptive management techniques.
3. Additionally, considerations should be made regarding timing of these field surveys to ensure accuracy in determining what plants exist on site.
Adequate information about special status plants and natural communities present in a project area will enable reviewing agencies and the public to effectively assess potential impacts to special status plants or natural communities and will guide the development of minimization and mitigation measures (CDFW 2018).
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Recommendation #7: BIO-5 Nesting Bird Pre-Construction Survey and Impact Avoidance:
CDFW recommends the District revise Mitigation Measure BIO – 5 to incorporate the underlined language and remove the language in strikethrough:
To avoid impacting active bird nests, juveniles or adults, project activities, including vegetation clearing and tree removal, shall be conducted outside of the breeding season (February 1 through September 15, and as early as January 1 for some raptors) to the extent feasible.
If project activities occur between January February 1 and September 15, a pre- construction nesting bird survey shall be conducted by a qualified biologist no more than 5 7 days prior to initiation of ground disturbance and vegetation removal. before the activity to survey for bird nests. The survey area shall include the project footprint and a 300100-foot buffer for passerine species and a 500300-foot buffer for coastal California gnatcatcher and raptor species. If construction lapses for five days or longer, the qualified biologist shall conduct another focused survey before project activities are reinitiated. Following the survey, the following shall be implemented:
• A nesting bird survey report shall be submitted to the District prior to the initiation of project activities. The report shall detail the results of the survey including identification of the location of any active nests and shall describe any nest monitoring that shall be conducted and/or whether any avoidance buffers shall be established.
• If active nests are identified during the survey and/or work is scheduled to take place within 300 100 feet of active passerine nests or 500300 Prior to Project
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feet of active coastal California gnatcatcher and raptor nests, a qualified biologist shall determine appropriate avoidance buffers. The buffer shall be the minimum distance required to avoid take of the nest and shall be determined based on the species identified, activities proposed, level of existing noise, and location of the nest.
• A qualified biologist shall determine when nesting is completed and when any avoidance buffers may be removed.
• If nesting bird monitoring is conducted, a nesting bird monitoring report shall be submitted to the District detailing the results of monitoring activities and measures implemented that avoided impacts to the nest.
The report shall be submitted within 30 days of the completion of the nesting bird monitoring.
Recommendation #8: BIO-Measures for Special Status Herpetofauna:
The MND does not provide any BIO-Measures specifically to avoid and minimize impacts to special status herpetofauna which may be present in or around the Project area. CDFW recommends additional BIO-Measures are added and included to minimize potential impacts. These measures may include focused surveys for species likely to occur within the Project site(s). Surveys should typically be scheduled during the summer months (June and July) when these animals are most likely to be encountered. To achieve 100 percent visual coverage, CDFW recommends surveys be conducted with parallel transects at approximately 20 feet apart and walked on site in appropriate habitat suitable for each species. Suitable habitat consists of areas of sandy, loose, and moist soils, typically under the sparse vegetation of scrub, chaparral, and within the duff of oak woodlands.
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Recommendation 9: Potential Impacts to Bat Species
It is not clear how the existing water tank slated for removal will be removed as the method of demolition was not explained within the MND. However, CDFW recommends providing BIO-Measures for bat species to protect them from utilizing the tanks at any point in the Project’s lifetime. This may include surveys before demolition and ensuring there are screens on any areas that may potentially allow bats to enter existing tanks.
Prior to Project
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Lead Agency
Recommendation #10: Tree Removal and Mitigation:
It is not clear if the proposed replacement following the removal of ten trees is sufficient to mitigate impacts. The type of trees and their DBH were not disclosed within the MND. Planting of four replacement trees is proposed; however, it does not specify the proposed species. At minimum, trees should be replaced at a 1:1 ratio; however, this does not address temporal impacts. CDFW recommends that the District disclose the type of trees slated for removal, their DBH, the specific species proposed for replacement, and a planting and monitoring plan to track the success of these plantings. CDFW also recommends increasing the number of trees to be planted to address the temporal loss of nesting habitat and to ensure impacts are mitigated below the threshold of significance.
Prior to Project
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Lead Agency
Recommendation #11: LSA:
Within the MND it states, “No federal or state jurisdictional waters exist within the project site; as such, no impacts would occur on State or federally protected Prior to Project
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wetlands.” However a drainage feature is present to the east/north east of the tank construction site. If any construction, vegetation removal, or fuel modification may impact the bed, bank, channel, or associated vegetation of the drainage, CDFW recommends submitting a Lake and Streambed Alteration Notification.
CDFW exercises its regulatory authority (Fish and Game Code, section 1600 et seq.) to conserve fish and wildlife resources which includes rivers, streams, or lakes and associated natural communities. Fish and Game Code, section 1602 requires any person, state or local governmental agency, or public utility to notify CDFW prior to beginning any activity that may do one or more of the following:
• Divert or obstruct the natural flow of any river, stream, or lake; • Change the bed, channel, or bank of any river, stream, or lake; • Use material from any river, stream, or lake; or,
• Deposit or dispose of material into any river, stream, or lake.
Recommendation #12: Fuel Modification:
If the Project includes fuel modification, CDFW recommends that the final environmental documents include avoidance and mitigation measures for any fuel modification activities conducted within and adjacent to the Project area(s).
A weed management plan should be developed for all areas adjacent to open space that will be subject to fuel modification disturbance. CDFW also recommends that any irrigation proposed in fuel modification zones do not allow for the introduction of invasive Argentine ants. Monitoring should also include parameters to identify possible introduction of
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Party
Recommendation #13: Native Landscaping
CDFW recommends the District provides a planting palette to CDFW, specifying the vegetation that will be used as landscaping for this Project. The Project proponent should use only native species found in naturally occurring vegetation communities within or adjacent to the Project site. The Project proponent should not plant, seed, or otherwise introduce nonnative, invasive plant species to areas that are adjacent to and/or near native habitat areas. CDFW recommends the Project proponent restrict use of any species, particularly ‘moderate’ or ‘high’ listed by the California Invasive Plant Council. These species are documented to have substantial and severe ecological impacts on physical processes, plant and animal communities, and vegetation structure.
Prior to Project
Initiation/During
Project
Construction
Lead Agency
Recommendation #14: Invasive Pests and Diseases:
If the Project activities require remove of vegetation that could host pest species, the District should work with the certified arborist to identify all trees and species for removal from the Project site and inspect those trees for contagious tree diseases including but not limited to: thousand canker disease (USDA 2025), polyphagous shot hole borer (UCANR 2025), and goldspotted oak borer (UCIPM 2021). If invasive pests and/or diseases are detected, the District should provide an infectious tree disease management plan and describe how it will be implemented to avoid significant impacts under CEQA. To avoid the spread of infectious tree diseases, diseased trees should not be transported from the Project site(s) without first being treated using best available management practices relevant for each tree disease observed.
Prior to Project
Initiation/During
Project
Construction
Lead Agency
DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
3.14 cont.
330
Michel Kadah
Ventura County Waterworks District No. 8
December 3, 2025
Mitigation Measure Timing Responsible
Party
Recommendation #15: Mitigation and Monitoring Reporting Plan.
CDFW recommends the Project’s environmental document include mitigation measures recommended in this letter. CDFW has provided comments via a mitigation monitoring and reporting plan to assist in the development of feasible, specific, detailed (i.e., responsible party, timing, specific actions, location), and fully enforceable mitigation measures (CEQA Guidelines, § 15097; Pub.
Resources Code, § 21081.6). The Lead Agency is welcome to coordinate with CDFW to further review and refine the Project’s mitigation measures. Per Public Resources Code section 21081.6(a)(1), CDFW has provided a summary of our suggested mitigation measures and recommendations in the form of an attached Draft Mitigation Monitoring and Reporting Plan (Attachment A).
Prior to Project
Initiation
Lead Agency
DocusignEnvelopeID:21ADE9A1-8E42-4E06-8183-4AE610255341
3.14 cont.
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sponses to Comments
Le
tter 2
COM
MENTER: Miya Edmonson, LDR/CEQA Branch Chief, California Department of Transportation
DATE: November 24, 2025
Resp
onse 2.1
The c
ommenter summarizes the project description.
The commenter’s summary of the project is accurate. No revisions to the Draft IS-MND are required in response to this comment.
Resp
onse 2.2
The
commenter states that Caltrans recommends scheduling large truck and construction traffic during off-peak commute hours, obtaining permits for oversized equipment or materials on State highways, and submitting a construction traffic control plan for review if impacts to State facilities are anticipated.
As discussed in Section 17, Transportation, of the Draft IS-MND, construction trips would account for a relatively minimal portion of existing traffic, and construction trips would be short-term and temporary. Construction traffic is not expected to cause issues on State facilities. If traffic issues arise, a construction traffic control plan would be submitted. No revisions to the Draft IS-MND are required in response to this comment.
Resp
onse 2.3
The c
ommenter provides contact information.
No revisions to the Draft IS-MND are required in response to this comment. 332
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Le
tter 3
COM
MENTER: Victoria Tang, Environmental Program Manager, California Department of Fish and Wildlife (CDFW)
DATE: December 3, 2025
Resp
onse 3.1
The
commenter summarizes CDFW’s roles as a trustee agency for the project. The commenter states CDFW may need exercise regulatory authority over the project pursuant to the Fish and Game Code, including lake and streambed alteration regulatory authority, and recommends the City/District obtain appropriate authorization for the project.
This comment is noted. If take is anticipated to occur, the City/District would obtain appropriate take authorization from CDFW under the Fish and Game Code for the project.
Resp
onse 3.2
The
commenter provides a summary of the project description and location, including the biological setting and a summary of mitigation measures. The commenter states they are offering comments and recommendations to assist City/District in avoiding and/or mitigating project impacts on biological resources.
The commenter’s summary is accurate. Please refer to Responses 3.3 through 3.14 for responses to the specific comments, recommendations, and the suggested measures provided by the commenter.
Resp
onse 3.3
The
commenter expresses concern that the project could impact Crotch’s bumble bee ( Bombus crotchii) through loss of suitable nesting and foraging habitat and potential direct mortality during ground-disturbing activities. The commenter notes that Crotch’s bumble bee is a candidate species under the California Endangered Species Act (CESA) and that impacts to candidate species are considered significant under the California Environmental Quality Act (CEQA). The comment further suggests that Mitigation Measure BIO-4 is insufficient to assess potential habitat or confirm presence/absence of the species and recommends revisions, including surveys following CDFW protocols during the appropriate season and coordination with CDFW to obtain an Incidental Take Permit (ITP).
As described on page 29 of the IS-MND, there is a high potential for Crotch’s bumble bee to occur within the project area. To address the potential for suitable habitat, Mitigation Measure BIO-4 requires pre-construction surveys in all suitable habitats within a 50-foot buffer prior to any ground- disturbing activities, following CDFW-approved methodologies. Further, if individuals or active nests are detected, a qualified biologist will establish a no-disturbance buffer and implement avoidance measures, with construction prohibited in that area until the nest is confirmed inactive for three consecutive days under suitable conditions. These measures prevent direct mortality and disturbance to active colonies, which constitute “take” under CESA.
The commenter expresses concern that pre‑construction surveys required under Mitigation Measure BIO‑4 were not sufficient to evaluate habitat or determine whether Crotch’s bumble bee is present, particularly given the difficulty of locating nests and the limited understanding of the species’ dispersal patterns. Therefore, the commenter states in the absence of protocol ‑level flight‑season 333
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su
rveys, it should be presumed the species present where suitable habitat occurs, as proceeding without appropriate focused surveys could risk harming undetected individuals during project activities. In order to address this comment, and although inactive underground nests do not contain living individuals and their disturbance does not constitute “take” or require an Incidental Take Permit, Mitigation Measure BIO‑4 has been revised to clarify seasonal survey requirements - including flight‑season protocol surveys and non ‑flight‑season overwintering habitat assessments - to ensure active individuals are avoided and to identify when additional CDFW coordination may be necessary if avoidance becomes infeasible.
In consideration of CDFW’s comments, Mitigation Measure BIO-4 has been revised as follows:
BIO-4 Crotch’s Bumble Bee Pre-Construction Survey and Impact Avoidance Pre-construction surveys for Crotch’s bumble bee, including ground nests, shall be conducted within all suitable habitats adjacent to the project site within the 50-foot buffer before initial ground disturbing activities (e.g., grubbing/removing vegetation, excavation, grading, construction). These surveys aim to identify individuals and/or active nest colonies in areas adjacent to the site. During the sp
ecies’ flight season (April to August), a qualified biologist shall conduct pre- construc
tion surveys within all suitable habitat in and adjacent to the project site, consist
ent with the CDFW Survey Considerations for CESA Candidate Bumble Bees
(CDFW 2023) or other methodology approved by CDFW. Surveys shall id
entify foraging individuals and/or active nest colonies. The preconstruction su
rveys shall follow the methodologies set out in the CDFW Survey Consid
erations for CESA Candidate Bumble Bee (CDFW 2023) or other survey me
thodology approved by CDFW.
If
the pre-construction surveys identify individuals or active nest colonies adjacent to the project footprint:
An appropriate no-disturbance buffer zone shall be established around the active nest colony to reduce the risk of disturbance or accidental take.
The buffer distance shall be established by a qualified biologist. The project proponent/operator shall consult with a qualified biologist to discuss considerations and recommendations on implementing project activities to avoid take of Crotch’s bumble bee.
If an avoidance buffer is required as described above, construction activities shall not occur within that buffer zone until a qualified biologist determines the nest to no longer be active (i.e., no Crotch’s bumble bee are seen flying in or out of the nest for three consecutive days [during suitable weather conditions when Crotch’s bumble bee are typically active] indicating the colony has completed its nesting season and the queens have dispersed from the colony), after which construction activities may resume within that buffer zone.
If construction activities are proposed outside the flight season, when protocol su
rveys cannot detect dormant individuals, a qualified biologist shall conduct an overwin
tering habitat assessment within suitable habitat in the project area. The assess
ment shall identify microhabitats with potential to support overwintering qu
eens, such as undisturbed soils, rodent burrows, leaf litter, or vegetated grou
nd cover.
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sponses to Comments
Where
suitable overwintering habitat is present and disturbance cannot be entirely
avoided, the project shall assume presence of overwintering individuals.
The
qualified biologist shall delineate temporary avoidance areas or implement ot
her minimization measures, in coordination with CDFW, to prevent disturbance of lik
ely overwintering sites.
The
commenter further states that even if Crotch’s bumble bee is not listed under CESA, it will remain a conservation ‑priority invertebrate, and the City/District must ensure no net loss of its suitable habitat by offsetting habitat impacts at a minimum 2:1 ratio. This comment has been noted. If protocol‑level surveys or pre‑ construction surveys detect Crotch’s bumble bee individuals or active nests, the avoidance requirements in Mitigation Measure BIO ‑4 would be implemented to prevent direct disturbance. With avoidance in place, no habitat loss or take of individuals would occur, and compensatory habitat replacement, such as the 2:1 ratio referenced by CDFW, would not be warranted.
Furthermore, the project footprint is small relative to the amount of suitable habitat available in the region, and Crotch’s bumble bee is a habitat generalist that utilizes a wide range of vegetation communities rather than a narrowly defined or rare habitat type. As a result, the temporary and localized disturbance associated with the project would not result in a measurable loss of habitat function for the species. Should avoidance of individuals become infeasible, the project proponent would coordinate with CDFW to determine whether additional minimization or compensatory measures are appropriate.
Resp
onse 3.4
The
commenter raises concerns that the project could adversely affect Santa Susana tarplant (Deinandra minthornii), either through direct impacts to individual plants within the project footprint or indirect impacts such as the loss of suitable habitat. The commenter asserts that the project site lies within the species’ range and notes that Santa Susana tarplant has been documented in proximity to the site and emphasize the Santa Susana tarplant is state ‑listed as Rare under the CESA, a status designated in November 1978, and that any impacts to this CESA‑listed species would be considered significant under CEQA.
The commenter states Mitigation Measure BIO-3, Pre-Construction Surveys for Special-Status Plants, is inadequate to avoid potential impacts because the measure does not identify the appropriate blooming period for Santa Susana tarplant and that transplanting or relocation would not be a viable option for this species. The commenter recommends several revisions to Mitigation Measure BIO-3, including incorporating surveys specifically targeting Santa Susana tarplant and other special-status plants; mapping and avoiding individual plants within or adjacent to the project site; conducting surveys during the appropriate season in accordance with CDFW protocols; coordinating with CDFW to obtain ITP; developing restoration, management, maintenance, and monitoring plans; and preparing a weed management plan to prevent the introduction of invasive species.
The commenter notes that several observations of Santa Susana tarplant have been recorded on iNaturalist in the surrounding area, including one observation in 2023 located less than 500 feet from the proposed Crown Hill Tank construction site and less than 300 feet from the Alta Vista Tank 1 demolition site (iNaturalist 2025). While citizen science platforms such as iNaturalist and eBird provide valuable supplemental observations and promote public engagement in biodiversity monitoring, these sources should not be considered equivalent to state-funded, peer-reviewed, or agency-vetted databases such as the California Natural Diversity Database (CNDDB) or the California 335
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N
ative Plant Society (CNPS) Inventory. Data from citizen science applications often lack standardized survey protocols, rigorous quality assurance, and regulatory oversight. Therefore, information from these platforms should be considered supplemental rather than official or authoritative. While these sources can provide useful context or help identify general patterns, they are best treated as non- authoritative and applied with discretion in formal literature reviews or regulatory decision-making.
Given the project site lies within the species’ range, contains suitable habitat, and is supported by multiple data sources, there is a reasonable potential for this CESA-protected, rare plant to occur within or near the impact area. The proposed project could result in the removal of rare plants and associated habitat.
In consideration of CDFW’s comments, Mitigation Measure BIO-3 has been revised as follows:
BIO-3 Pre-Construction Surveys for Special-Status Plants A qualified botanist shall be retained by the City/District or its contractor to conduct a two preconstruction surveys on the project site for special-status plant sp
ecies during the appropriate species-specific identification periods, the first betwe
en May and July and the second between July and November, specifically, May
through July when the plants are in bloom and within one year before grou
nd disturbance. The survey will be in accordance with CNPS’s Botanical Survey Guidelines (CNPS 2001), CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018), and USFWS’s Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants (USFWS 1996).
If the survey confirms that no special-status plant species are present on the project site, no further actions will be required. If the plant survey reveals the presence of special-status plants on the project site, individuals will be flagged for avoidance during construction. Occurrences of special ‑status species will be mapp
ed, and if any are located within 50 feet of project activities, they will be flag
ged in the field. Subsequently, a minimum 50‑foot buffer shall be established aroun
d all such occurrences to avoid impacts to seed banks and supporting micr
ohabitats. These buffers will be clearly flagged or fenced and avoided for the du
ration of project activities. If the populations cannot be avoided during construc
tion, the City/District or its contractor will retain a qualified botanist or restoration ecologist to prepare a salvage, relocation, or propagation and monitoring plan (Special-status Plant Recovery Plan) for special-status plants before construction is initiated. All occurrences of Santa Susana tarplant shall be docum
ented. Any individuals found within the development footprint shall requ
ire consultation with CDFW to determine whether an Incidental Take Permit (ITP)
is necessary, while any individuals occurring within the fuel ‑modification area
shall be fully avoided and protected in place; no salvage or relocation may occ
ur. The Special-status Plant Recovery Plan will include provisions that address the
techniques, location, and procedures required for the successful establishment of the plant populations. The plan will include provisions for perf
ormance that address survivability requirements, maintenance, monitoring, imple
mentation, adaptive management, and the annual reporting requirements.
All
directly impacted special-status plants will be documented by a qualified botani
st. Documentation of impacts special-status plants will include locations, qu
antity, density and percent cover; key habitat characteristics, including soil 336
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type,
associated species, hydrology, and topography; and photo documentation of prec
onstruction conditions.
The Sp
ecial-status Plant Recovery Plan shall include clear performance standards requ
iring:
(1) a mini
mum survivability rate for restored or transplanted individuals; (2) defi
ned maintenance activities to support successful establishment; (3) a m
onitoring schedule with measurable success criteria;
(4) imple
mentation procedures that identify responsible parties and timelines; (5) ad
aptive management triggers and corrective actions if performance stan
dards are not met; and
(6) an
nual reporting that documents progress toward meeting these standards.
The qu
alified botanist shall document all directly impacted special‑status plants, in
cluding their locations, abundance, density, percent cover, and key habitat cha
racteristics, such as soil type, associated species, hydrology, and topography, an
d shall provide photographic records of pre ‑construction conditions. If any state‑list
ed endangered or threatened plants are detected within areas proposed for de
velopment, an avoidance strategy consistent with CESA shall be developed an
d implemented.
The Sp
ecial-status Plant Recovery Plan shall include a description of the project an
d mitigation areas; an assessment of impacts on rare ‑plant habitat; clearly defi
ned objectives and success criteria; planting palettes tailored to the ap
propriate vegetation communities; an implementation and maintenance plan; a
monitoring program; and contingency measures to support adaptive manag
ement.
The
plant palette shall include not only target species (e.g., Nevin’s barberry, Brau
ton’s milk vetch, Santa Susana tarplant, slender mariposa lily, chaparral nolin
a, and Plummer’s mariposa lily) but also a diverse suite of native species represen
tative of local rare‑plant habitat conditions.
Pe
rformance standards for rare‑plant restoration shall include:
• Rest
oring at least a 2:1 acreage ratio of impacted rare‑ plant habitat within five
years.
• Ach
ieving at least 50 percent absolute cover of target rare plants and other na
tive species within the restoration area by Year 5.
• De
monstrating two consecutive years of meeting all success criteria without activ
e maintenance, aside from invasive‑species control.
An
nual monitoring and reporting to the City/District shall be required throughout imple
mentation. A final report shall be submitted in Year 5 evaluating whether the
restoration has met all performance standards. If the criteria are not met, the ap
plicant shall coordinate with the City/District to identify and implement ap
propriate remedial measures.
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If
impacts to rare‑ plant habitat are mitigated through an in ‑lieu fee, the City/Dist
rict shall provide evidence of payment prior to grading. All in ‑lieu fees sh
all be used exclusively to restore or create in‑kind rare‑plant habitat.
All
restoration, enhancement, or mitigation lands shall be placed under a conser
vation easement or another mechanism ensuring long ‑term, permanent pr
otection.
Mo
reover, the IS-MND provides an adequate CEQA-level evaluation of the project’s potential to affect Santa Susana tarplant. As described in the IS-MND, focused botanical surveys will be conducted prior to ground disturbance to determine the presence or absence of special-status plant species within the project footprint. If focused surveys confirm the absence of Santa Susana tarplant the project will not result in direct or indirect impacts to the species, and additional analysis or mitigation is not required under CEQA.
Should Santa Susana tarplant be detected, the IS-MND incorporates clear and enforceable avoidance measures, including mapping of occurrences, establishment of a minimum 50‑foot avoidance buffer, and exclusion of all ground ‑disturbing activities within the buffer for the duration of construction.
These actions are consistent with CDFW guidance for preventing take of state ‑listed plant species under CESA. Because salvage and relocation of Santa Susana tarplant is not recommended by CDFW, due to extremely low survival rates and the species’ dependence on highly specific sandstone microhabitats, avoidance remains the only biologically and regulatorily appropriate mitigation. Any Santa Susana tarplant individuals occurring within the project’s fuel‑modification area would be fully avoided and protected in place as no disturbance is anticipated, with no salvage or relocation permitted. Any Santa Susana tarplant individuals detected within the development footprint would require consultation with CDFW to determine whether ITP is necessary. With these measures in place, the MND already incorporates all feasible and effective mitigation to ensure impacts remain less than significant, and additional detail sufficient to support issuance of an ITP is not required unless avoidance proves infeasible.
The commenter recommendation for a multi-year weed management plan is also noted; however, the IS-MND contains construction-phase best management practices and standard measures that effectively minimize the potential for invasive plant establishment. The project involves vegetation clearing immediately around the tank solely to meet defensible ‑space requirements in a high fire‑hazard area, and the landscape plan will comply with Standard 515 – Defensible Space and Fuel Modification. Proposed screening trees and other plantings will undergo review and approval by the Ventura County Fire Department through the Fuel Modification process, ensuring that all vegetation used meets fire‑safety and maintenance standards. Because vegetation management in this area is driven by fire ‑hazard reduction rather than long ‑term habitat alteration, and because construction practices will include standard erosion control, equipment cleaning, and use of weed‑free materials, the potential for sustained invasive species establishment is low. Therefore, a multi ‑year, post‑construction weed monitoring and eradication program is not warranted.
Resp
onse 3.5
The
commenter is concerned the project may significantly impact two coast live oaks located along the site boundary due to inadequate avoidance measures, and is missing tree-specific BIO-Measures, and insufficient documentation of tree size, health, and precise locations relative to disturbance areas. The commenter states because the IS-MND does not include an arborist report, mapped canopy extents, or confirmation of whether the trees qualify as “mature” under local ordinances, they cannot assess whether proposed buffers are protective or whether impacts would be minimized; and 338
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given
the ecological importance of coast live oaks and oak woodlands, their protection under State law, and the recognized biodiversity supported by these communities, potential impacts are considered significant unless clearly mitigated. CDFW recommends implementing detailed tree protection fencing, pre-construction training, arborist-led monitoring and reporting, appropriate replacement ratios, restoration planning, long-term monitoring, and conservation easements for off- site mitigation, and further urges redesigning project elements to avoid impacts to oak trees and oak woodland habitat whenever feasible.
The project would not remove any coast live oak trees, and all coast live oak woodland areas would be fully avoided during project activities. No ground disturbance, staging, or construction access would occur within the dripline or root protection zones of any oak trees. Because the project avoids all oak trees and oak woodland habitat, impacts to these resources would not occur, and the mitigation measures recommended by CDFW are not required.
Resp
onse 3.6
The
commenter recommends revising Mitigation Measure BIO-5 to require USFWS-protocol coastal California gnatcatcher ( Polioptila californica californica ) surveys by a permitted biologist prior to construction, with results submitted to USFWS at least 30 days before groundbreaking, and to expand all occupancy-based buffers and survey radii from 300 to 500 feet where accessible. The commenter states if occupied habitat is confirmed, construction restrictions outside the gnatcatcher breeding season, weekly nesting surveys during the breeding season, 500-foot avoidance buffers around active nests (modifiable with USFWS approval), fencing to protect habitat outside work limits, biological monitoring during all vegetation clearing, use of existing access routes, nest reporting within 24 hours, work stoppage if nests may be disturbed, and proper site sanitation would be required. If avoidance is not possible, the commenter states the City/District must obtain USFWS take authorization. CDFW also recommends establishing a separate BIO-6 to address habitat mitigation, including 2:1 off-site preservation for permanent and temporary impacts to occupied habitat, use of approved mitigation banks when needed, and 1:1 mitigation for temporary impacts and unoccupied habitat, along with protection of all non-impacted coastal sage scrub using clearly marked buffer zones.
Vegetation removal within and around the tank site is required to meet Ventura County Fire Department (VCFD) Standard 515 – Defensible Space and Fuel Modification, as the project is located within a Very High Fire Hazard Severity Zone. While this fuel‑ modification treatment is a fire‑hazard mitigation strategy, it nonetheless results in habitat modification, including removal or thinning of coastal sage scrub immediately adjacent to the tank footprint. Therefore, the IS ‑MND appropriately identifies that such activities have the potential to affect special ‑status wildlife, including coastal California gnatcatcher, if the species were present within or near the work area.
However, the IS‑MND also documents that no suitable coastal California gnatcatcher habitat occurs within the project footprint, and that only a moderate potential for gnatcatcher presence exists within the adjacent 50 ‑foot survey buffer, not in the areas subject to vegetation removal for defensible space. The project’s vegetation management will occur only in already ‑disturbed or partially‑disturbed areas surrounding the tank, and not within intact coastal sage scrub habitat mapped in the IS‑MND.
It is important to note, Mitigation Measure BIO ‑6 requires a USFWS ‑protocol coastal California gnatcatcher survey conducted by a permitted biologist prior to any ground ‑disturbing activities, including vegetation clearing. If no gnatcatchers or occupied habitat are detected within the protocol survey area, no species ‑specific restrictions are triggered. If gnatcatchers are detected, Mitigation Measure BIO‑6 requires avoidance buffers, seasonal restrictions, nesting surveys, and coordination 339
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with
USFWS to prevent take. These measures adequately address the possibility that vegetation clearing, even for fire hazard reduction, could impact the species if present.
The proposed landscape plan, including trees used only for visual screening, will be submitted to VCFD for review and final approval of fuel ‑modification requirements. Landscape design will comply with Standard 515 and will not be used to replace or modify biologically sensitive vegetation.
Because (1) habitat potentially suitable for gnatcatcher is not located within the area of required fuel‑modification clearing; (2) protocol surveys and avoidance measures under Mitigation Measure BIO‑6 are already required; and (3) vegetation removal is limited to safety ‑mandated defensible‑space zones rather than biological resource areas, the additional revisions to Mitigation Measure BIO ‑5 and creation of new mitigation measures recommended in the comment are not necessary.
Resp
onse 3.7
The
commenter recommends that the IS-MND include a detailed, alliance-level vegetation map because the document does not depict the areas where approximately 50 percent of vegetation would be removed around the Crown Hill Tank site, nor does it map other project elements such as the gate alignment. The commenter advises conducting vegetation surveys following CDFW’s 2018 protocols and classifying all plant communities using Manual of California Vegetation (MCV) alliances to determine rarity rankings. The commenter states the IS-MND should provide a large-scale map showing impacted plants and habitat, with a table quantifying individuals, acreage, and vegetation composition. In addition, the commenter requests species-specific, ecosystem-based mitigation plans that identify impact levels, mitigation locations and reference sites, plant taxonomy and propagule sources, planting methods, measurable success criteria, and long-term monitoring and adaptive management. Finally, the commenter emphasizes that surveys must be completed at biologically appropriate times to ensure accurate detection of special-status plants and natural communities and to inform appropriate avoidance, minimization, and mitigation measures.
The IS-MND provides a detailed description of vegetation communities within and adjacent to the project footprint, specifically yerba santa–deerweed scrub, California sagebrush scrub, and non‑native brome grassland, based on a reconnaissance‑level botanical survey and classification using the MCV alliance framework. These alliance‑level communities occur outside the proposed areas of ground disturbance, which are restricted to previously disturbed surfaces around the tank pad, access road, and compacted fill.
The IS-MND discloses that vegetation removal will occur within approximately 10 feet of the tank pad and access road for construction activities and to meet fire‑safety requirements because the project is located in a Very High Fire Hazard Severity Zone. These defensible‑ space treatments constitute fuel‑modification impacts; however, they occur primarily within already disturbed or degraded vegetation and not within intact coastal sage scrub alliances mapped during the survey. No sensitive natural communities were identified within the fuel‑modification zones and, therefore, no impacts to sensitive vegetation communities would occur. However, special ‑status plants may be present, and the IS-MND includes measures to avoid, minimize, or mitigate potential impacts to these species if detected during pre‑construction surveys.
Mitigation Measures BIO ‑1 through BIO ‑3 require avoidance fencing, worker training, and pre‑construction rare‑plant surveys to ensure no special ‑status species are affected by vegetation removal in the fuel‑modification area. Should special‑status plants be detected during protocol‑level surveys, the mitigation measures require appropriate avoidance, minimization, or salvage actions, 340
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ensu
ring that any vegetation removed for fuel modification remains compliant with CDFW ‑ and CEQA‑level protections.
Although the IS-MND does not include a standalone alliance ‑level vegetation map depicting fuel‑modification boundaries, the document’s narrative descriptions, mapped survey area, and identification of vegetation alliances in relation to the disturbance footprint provide sufficient information to evaluate potential impacts to native plant communities. Because no sensitive natural communities occur within the areas subject to fuel‑modification clearing and no special‑status plants were documented during surveys, additional mapping or species ‑specific mitigation plans are not required to support the impact conclusions.
Moreover, as part of project implementation, the City/District will prepare a landscape and fuel‑modification plan for review and approval by the VCFD. This plan will identify vegetation‑management zones around the tank, ensuring compliance with defensible‑ space requirements while remaining consistent with the impact avoidance and mitigation commitments in the IS-MND.
Resp
onse 3.8
The
commenter recommends updating Mitigation Measure BIO-5 for nesting birds to clarify and strengthen requirements. The revision request emphasizes conducting vegetation clearing and other project activities outside the nesting season whenever possible. The commenter states if work must occur between January 1 and September 15, a qualified biologist must complete a nesting bird survey within 5 days before ground disturbance. The survey must cover the project area plus species specific buffers: 100–300 feet for passerines and 500 feet for coastal California gnatcatcher and raptors. If construction stops for five days or more, a new survey is required. After surveys, appropriate protective measures must be implemented.
The proposed reduction in the nesting bird pre-construction survey timeframe (from seven days prior to ground disturbance to five days prior) would not alter the level of protection afforded to nesting birds. Under Mitigation Measure BIO-5, if an active nest of a species protected under the California Fish and Game Code or the Migratory Bird Treaty Act is detected within 300 feet of the disturbance footprint, a City-approved biologist must establish an appropriate no-disturbance buffer and maintain it until the breeding cycle is complete and the young have fledged. If construction must proceed within this buffer, continuous biological monitoring is required to ensure that nesting birds are not adversely affected.
Shortening the survey window from seven days to five days would not change the level of protection afforded to nesting birds or provide any additional conservation benefit. A seven ‑day interval is already sufficient for detecting active nests prior to project activities and allows a reasonable period for survey results to be reported to, and appropriately considered by, the City/District. It is also unlikely that most bird species would initiate new nesting activity within the additional two ‑day difference between a seven‑day and five‑day survey window. Therefore, the commenter’s suggested modification is unnecessary to reduce potential impacts to a less-than-significant level. Nevertheless, in response to CDFW’s recommendation, Mitigation Measure BIO-5 has been revised as follows:
BIO-5 Nesting Bird Pre-construction Survey and Impact Avoidance To avoid impacting active bird nests, juveniles or adults, project activities, including vegetation clearing and tree removal, shall be conducted outside of the breeding season (February 1 through September 15 and as early as January 1 for so
me raptors) to the extent feasible.
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If
project activities occur between February January 1 and September 15, a pre- construc
tion nesting bird survey shall be conducted by a qualified biologist no more than 7 working days before the activity to survey for bird nests. The survey area shall include the project footprint and a 1300-foot buffer for passerine sp
ecies and a 3500-foot buffer for coastal California gnatcatcher and raptor sp
ecies. Following the survey, the following shall be implemented:
A nesting bird survey report shall be submitted to the City/District prior to the initiation of project activities. The report shall detail the results of the survey including identification of the location of any active nests and shall describe any nest monitoring that shall be conducted and/or whether any avoidance buffers shall be established.
If active nests are identified during the survey and/or work is scheduled to take place within 1300 feet of active passerine nests or 3500 feet of activ
e coastal California gnatcatcher and raptor nests, a qualified biologist shall determine appropriate avoidance buffers. The buffer shall be the minimum distance required to avoid take of the nest and shall be determined based on the species identified, activities proposed, level of existing noise, and location of the nest.
A qualified biologist shall determine when nesting is completed and when any avoidance buffers may be removed.
If nesting bird monitoring is conducted, a nesting bird monitoring report shall be submitted to the City/District detailing the results of monitoring activities and measures implemented that avoided impacts to the nest.
The report shall be submitted within 30 days of the completion of the nesting bird monitoring.
Resp
onse 3.9
The
commenter states that the IS-MND does not include specific measures for special-status herpetofauna (e.g., reptiles and amphibians). The commenter recommends adding focused surveys during summer (June–July), walked at 20-foot transect intervals in suitable sandy/moist scrub and duff habitats.
While the Draft IS ‑MND does not include herpetofauna ‑specific survey requirements, Mitigation Measure BIO ‑2 (Worker Environmental Awareness Training) already provides an appropriate mechanism to avoid potential impacts to reptiles and amphibians. Under Mitigation Measure BIO‑2, all construction personnel receive training on identifying and avoiding sensitive biological resources that may occur within or adjacent to the work area. This training can—and would—include a description of any potential special ‑status herpetofauna with the capacity to occur onsite, their general habitat associations, and the appropriate avoidance actions workers must take if an individual is encountered during construction.
Mitigation Measures BIO‑4 and BIO‑5/BIO‑6 focus on Crotch’s bumble bee and nesting birds/coastal California gnatcatcher, respectively, and therefore do not apply to herpetofauna. In contrast, Mitigation Measure BIO‑2 serves as the broad, cross‑taxa protective measure by ensuring field staff are equipped with the knowledge necessary to recognize and avoid impacts to all sensitive wildlife groups, including herpetofauna, should they be present. 342
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CDFW
requests measures ensuring bats cannot enter existing tanks and requiring bat surveys before demolition. The IS-MND explains that Alta Vista Tank No. 1 is a sealed, bolted steel potable-water reservoir with no voids suitable for bat roosting (constructed as a closed vessel; no attics, vents, or accessible cavities). No evidence of bat use was observed during the reconnaissance survey. Alta Vista Tank No. 1 demolition is limited to exterior disassembly in an open, disturbed area.
The commenter states that tree removal details are insufficient – measurements of diameter at breast height, species, replacement ratios, and monitoring should be included. The IS ‑MND already acknowledges removal of up to 10 trees for demolition and requires the City/District to obtain a Tree Removal Permit, comply with Simi Valley’s Mature Tree Preservation Ordinance, and replace removed trees with four native trees plus shrubs for screening. Consistent with local policy, the City/District will disclose diameter at breast height and species in the permit application. Adding this detail does not change the IS‑MND findings because tree removals were already analyzed and found Less Than Significant with replacement.
The commenter also notes a drainage east/northeast of the site; if any impact occurs to bed/bank/channel/associated vegetation, a Lake and Streambed Alteration Agreement is required.
No jurisdictional waters occur within the project footprint, and no hydrologic connectivity exists between the site and mapped wetlands 0.2 miles away. The project design avoids all drainage features; therefore an LSA Notification is not triggered. Still, the City/District commits to re-evaluate and file a Lake and Streambed Alteration Notification if field conditions differ during final design or construction. No IS-MND revision is required.
The commenter requests weed management, invasive species prevention, irrigation controls, and Argentine ant monitoring in fuel-modification zones. Fuel‑ modification needs for the project are limited and occur in areas required to meet VCFD standards. The project includes new landscape plantings and an associated irrigation system designed to meet Fire Department Standard 515 defensible‑space requirements. Irrigation is confined to landscaped areas immediately surrounding the tank and pump station. The City/District can incorporate a simple, low ‑risk weed‑management protocol (e.g., no planting of invasive species, periodic hand‑weeding) and will ensure that irrigation in the landscaped zones is designed and operated in a manner that does not promote conditions conducive to Argentine ant colonization. Given the limited irrigated footprint and compliance with FMZ spacing and plant ‑selection requirements, the risk of Argentine ant introduction remains extremely low. These clarifications are consistent with Mitigation Measures BIO‑1 and BIO‑2 and do not alter the biological impact conclusions in the IS‑MND.
The commenter requests use of a native-plant palette and prohibition on any Cal-IPC “Moderate” or “High” risk invasive species. The IS-MND already states that new trees and shrubs will be installed to screen the tank and that vegetation will comply with Fire Department fuel-modification requirements. During final design, the City/District shall use a native-only planting palette and will avoid all Cal-IPC Moderate- and High-risk species. This is fully compatible with the project’s existing landscape intent, including defensible-space spacing constraints, and does not change the impact conclusions in the IS-MND.
Last, the commenter recommends inspection for invasive pests (e.g., shot ‑hole borer, goldspotted oak borer), a disease ‑management plan if infestations are detected, and proper disposal of any infected biomass. As tree removal has already been disclosed, and the IS ‑MND requires compliance with local permitting and regulatory requirements. The City/District shall add language requiring a certified arborist to inspect all trees prior to removal. Any diseased or infested tree material will be handled and disposed of according to county and state best ‑management practices. Because tree 343
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rem
oval impacts were already analyzed as less ‑than‑significant with replacement planting, this refinement does not alter the IS-MND’s findings.
Resp
onse 3.10
The
commenter recommends the IS-MND includes CDFW’s recommended mitigation measures (Attachment A of Letter 3) and invites the City/District to coordinate with CDFW to further review and refine the project’s mitigation measures.
Responses to specific mitigation recommendations have been provided in Responses 3.1 through 3.9 above. As noted in those responses, Mitigation Measure BIO-3 and -5 has been revised to include CDFW’s recommendations.
Resp
onse 3.11
The c
ommenter requests that special-status species and natural communities detected during project surveys be submitted to CDFW's vegetation classification and mapping program and to the CNDDB.
Including this provision as a mitigation requirement for the project would not be appropriate, as it does not reduce or offset any biological impact. Nevertheless, if special-status species or sensitive natural communities are encountered during project construction, the City/District will consider submitting this information to the CNDDB.
Resp
onse 3.12
The c
ommenter states that payment of CDFW fees is required.
If the Final IS-MND is certified and the project is approved, the City/District would pay the required CDFW fees at the time the Notice of Determination for the Final IS-MND is filed with the Ventura County Clerk.
Resp
onse 3.13
The
commenter concludes the letter and requests the opportunity to review the response to comments and receive notification of hearing dates. This comment has been noted. The comment does not contain a substantive comment on the IS-MND and no further response is required.
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