Agenda packet — City Council and Concurrent Authorities, September 9, 2025 (part 6 of 6)

CO STARTING
TITLEONE D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc

MODELOPT DFAULT CONC
AVERTIME 1 PERIOD
URBANOPT 319543

POLLUTID OTHER

RUNORNOT RUN
ERRORFIL Construction.err

CO FINISHED
**
****************************************
** AERMOD Source Pathway
****************************************
**
**

SO STARTING
** Source Location **
** Source ID - Type - X Coord. - Y Coord. **
LOCATION CONST AREAPOLY 649691.633 4198259.576 2.130
** Source Parameters **
SRCPARAM CONST 5.8946E-06 3.048 31
AREAVERT CONST 649691.633 4198259.576 649692.491 4198220.676 AREAVERT CONST 649677.332 4198220.390 649676.760 4198155.747 AREAVERT CONST 649578.938 4198136.298 649539.752 4198121.996 AREAVERT CONST 649495.418 4198095.395 649435.924 4198049.631 AREAVERT CONST 649390.159 4198001.292 649364.131 4197971.259 AREAVERT CONST 649330.951 4197932.359 649317.222 4197919.488 AREAVERT CONST 649309.213 4197914.339 649283.757 4197910.049 AREAVERT CONST 649270.027 4197910.621 649208.817 4197911.193 AREAVERT CONST 649175.352 4197908.047 649112.425 4197902.040 AREAVERT CONST 649052.359 4197895.175 649031.193 4197894.317 AREAVERT CONST 649016.034 4197901.468 648970.841 4197996.144 AREAVERT CONST 648971.127 4197999.004 649106.705 4198259.576 AREAVERT CONST 649229.125 4198255.857 649328.949 4198257.574 AREAVERT CONST 649460.236 4198261.864 649514.868 4198264.152 AREAVERT CONST 649563.778 4198258.432 649619.840 4198255.285 AREAVERT CONST 649669.895 4198257.288
EXHIBIT 1

URBANSRC ALL
** Variable Emissions Type: "By Hour / Day (HRDOW)"
** Variable Emission Scenario: "Const"
** WeekDays:

EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 1.0 1.0 1.0 1.0 1.0
EMISFACT CONST HRDOW 1.0 1.0 1.0 1.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
** Saturday:

EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
** Sunday:

EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0
EMISFACT CONST HRDOW 0.0 0.0 0.0 0.0 0.0 0.0

SRCGROUP ALL

SO FINISHED
**
****************************************
** AERMOD Receptor Pathway
****************************************
**
**

RE STARTING
INCLUDED Construction.rou

RE FINISHED
**
****************************************
** AERMOD Meteorology Pathway
****************************************
**
**

ME STARTING
SURFFILE "D:\LSA\Met_Data\SJV\23237 - Stockton Arpt\23237_Stockton_Arpt_2020-2024.SFC" PROFFILE "D:\LSA\Met_Data\SJV\23237 - Stockton Arpt\23237_Stockton_Arpt_2020-2024.PFL" SURFDATA 23237 2020 Stockton_Arpt
UAIRDATA 72493 2020
PROFBASE 8.0 METERS

ME FINISHED
**
****************************************
** AERMOD Output Pathway
****************************************
**
**

OU STARTING
RECTABLE ALLAVE 1ST
RECTABLE 1 1ST
** Auto-Generated Plotfiles
PLOTFILE 1 ALL 1ST Construction.AD\01H1GALL.PLT 31
PLOTFILE PERIOD ALL Construction.AD\PE00GALL.PLT 32
EXHIBIT 1
SUMMFILE Construction.sum

OU FINISHED
*** Message Summary For AERMOD Model Setup ***
--------- Summary of Total Messages --------
A Total of 0 Fatal Error Message(s)
A Total of 2 Warning Message(s)
A Total of 0 Informational Message(s)
******** FATAL ERROR MESSAGES ********
*** NONE ***
******** WARNING MESSAGES ********
ME W186 97 MEOPEN: THRESH_1MIN 1-min ASOS wind speed threshold used 0.50 ME W187 97 MEOPEN: ADJ_U* Option for Stable Low Winds used in AERMET ***********************************
*** SETUP Finishes Successfully ***
***********************************
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 1
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** MODEL SETUP OPTIONS SUMMARY ***
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ** Model Options Selected:
* Model Uses Regulatory DEFAULT Options
* Model Is Setup For Calculation of Average CONCentration Values. * NO GAS DEPOSITION Data Provided.
* NO PARTICLE DEPOSITION Data Provided.
* Model Uses NO DRY DEPLETION. DDPLETE = F
* Model Uses NO WET DEPLETION. WETDPLT = F
* Stack-tip Downwash.
* Model Accounts for ELEVated Terrain Effects.
* Use Calms Processing Routine.
* Use Missing Data Processing Routine.
* No Exponential Decay.
* Model Uses URBAN Dispersion Algorithm for the SBL for 1 Source(s), for Total of 1 Urban Area(s):

Urban Population = 319543.0 ; Urban Roughness Length = 1.000 m * Urban Roughness Length of 1.0 Meter Used.
* ADJ_U* - Use ADJ_U* option for SBL in AERMET
* CCVR_Sub - Meteorological data includes CCVR substitutions * TEMP_Sub - Meteorological data includes TEMP substitutions * Model Assumes No FLAGPOLE Receptor Heights.
* The User Specified a Pollutant Type of: OTHER

**Model Calculates 1 Short Term Average(s) of: 1-HR
and Calculates PERIOD Averages

**This Run Includes: 1 Source(s); 1 Source Group(s); and 2945 Receptor(s) with: 0 POINT(s), including
0 POINTCAP(s) and 0 POINTHOR(s)
and: 0 VOLUME source(s)
and: 1 AREA type source(s)
and: 0 LINE source(s)
and: 0 RLINE/RLINEXT source(s)
and: 0 OPENPIT source(s)
and: 0 BUOYANT LINE source(s) with a total of 0 line(s) and: 0 SWPOINT source(s)

**Model Set To Continue RUNning After the Setup Testing. **The AERMET Input Meteorological Data Version Date: 24142

**Output Options Selected:

Model Outputs Tables of PERIOD Averages by Receptor
Model Outputs Tables of Highest Short Term Values by Receptor (RECTABLE Keyword) Model Outputs External File(s) of High Values for Plotting (PLOTFILE Keyword) Model Outputs Separate Summary File of High Ranked Values (SUMMFILE Keyword) EXHIBIT 1
**NOTE: The Following Flags May Appear Following CONC Values: c for Calm Hours m for Missing Hours
b for Both Calm and Missing Hours
**Misc. Inputs: Base Elev. for Pot. Temp. Profile (m MSL) = 8.00 ; Decay Coef. = 0.000 ; Rot. Angle = 0.0 Emission Units = GRAMS/SEC ; Emission Rate Unit Factor = 0.10000E+07 Output Units = MICROGRAMS/M**3
**Approximate Storage Requirements of Model = 3.8 MB of RAM. **Input Runstream File: aermod.inp
**Output Print File: aermod.out
**Detailed Error/Message File: Construction.err
**File for Summary of Results: Construction.sum
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 2
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** AREAPOLY SOURCE DATA ***
NUMBER EMISSION RATE LOCATION OF AREA BASE RELEASE NUMBER INIT. URBAN EMISSION RATE AIRCRAFT SOURCE PART. (GRAMS/SEC X Y ELEV. HEIGHT OF VERTS. SZ SOURCE SCALAR VARY ID CATS. /METER**2) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - CONST 0 0.58946E-05 649691.6 4198259.6 2.1 3.05 31 0.00 YES HRDOW NO EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 3
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** SOURCE IDs DEFINING SOURCE GROUPS ***
SRCGROUP ID SOURCE IDs
----------- ----------

ALL CONST ,
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 4
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** SOURCE IDs DEFINED AS URBAN SOURCES ***
URBAN ID URBAN POP SOURCE IDs
-------- --------- ----------
319543. CONST ,
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 5
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
* SOURCE EMISSION RATE SCALARS WHICH VARY DIURNALLY AND BY DAY OF WEEK (HRDOW) * SOURCE ID = CONST ; SOURCE TYPE = AREAPOLY :

HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - DAY OF WEEK = WEEKDAY
1 .0000E+00 2 .0000E+00 3 .0000E+00 4 .0000E+00 5 .0000E+00 6 .0000E+00 7 .0000E+00 8 .1000E+01 9 .1000E+01 10 .1000E+01 11 .1000E+01 12 .1000E+01 13 .1000E+01 14 .1000E+01 15 .1000E+01 16 .1000E+01 17 .0000E+00 18 .0000E+00 19 .0000E+00 20 .0000E+00 21 .0000E+00 22 .0000E+00 23 .0000E+00 24 .0000E+00 DAY OF WEEK = SATURDAY
1 .0000E+00 2 .0000E+00 3 .0000E+00 4 .0000E+00 5 .0000E+00 6 .0000E+00 7 .0000E+00 8 .0000E+00 9 .0000E+00 10 .0000E+00 11 .0000E+00 12 .0000E+00 13 .0000E+00 14 .0000E+00 15 .0000E+00 16 .0000E+00 17 .0000E+00 18 .0000E+00 19 .0000E+00 20 .0000E+00 21 .0000E+00 22 .0000E+00 23 .0000E+00 24 .0000E+00 DAY OF WEEK = SUNDAY
1 .0000E+00 2 .0000E+00 3 .0000E+00 4 .0000E+00 5 .0000E+00 6 .0000E+00 7 .0000E+00 8 .0000E+00 9 .0000E+00 10 .0000E+00 11 .0000E+00 12 .0000E+00 13 .0000E+00 14 .0000E+00 15 .0000E+00 16 .0000E+00 17 .0000E+00 18 .0000E+00 19 .0000E+00 20 .0000E+00 21 .0000E+00 22 .0000E+00 23 .0000E+00 24 .0000E+00 EXHIBIT 1
*** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 39
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** METEOROLOGICAL DAYS SELECTED FOR PROCESSING ***
(1=YES; 0=NO)
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
NOTE: METEOROLOGICAL DATA ACTUALLY PROCESSED WILL ALSO DEPEND ON WHAT IS INCLUDED IN THE DATA FILE. *** UPPER BOUND OF FIRST THROUGH FIFTH WIND SPEED CATEGORIES *** (METERS/SEC)

1.54, 3.09, 5.14, 8.23, 10.80,
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 40
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** UP TO THE FIRST 24 HOURS OF METEOROLOGICAL DATA *** Surface file: D:\LSA\Met_Data\SJV\23237 - Stockton Arpt\23237_Stockton_Arpt_2020-2024.SFC Met Version: 24142 Profile file: D:\LSA\Met_Data\SJV\23237 - Stockton Arpt\23237_Stockton_Arpt_2020-2024.PFL Surface format: FREE
Profile format: FREE
Surface station no.: 23237 Upper air station no.: 72493 Name: STOCKTON_ARPT Name: UNKNOWN
Year: 2020 Year: 2020
First 24 hours of scalar data
YR MO DY JDY HR H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS WD HT REF TA HT - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 20 01 01 1 01 -5.4 0.101 -9.000 -9.000 -999. 77. 17.1 0.11 0.75 1.00 1.25 81. 10.0 285.9 2.0 20 01 01 1 02 -18.6 0.191 -9.000 -9.000 -999. 201. 40.2 0.14 0.75 1.00 2.16 105. 10.0 283.1 2.0 20 01 01 1 03 -11.3 0.149 -9.000 -9.000 -999. 139. 26.7 0.19 0.75 1.00 1.59 150. 10.0 282.5 2.0 20 01 01 1 04 -11.5 0.150 -9.000 -9.000 -999. 140. 26.9 0.19 0.75 1.00 1.60 171. 10.0 282.0 2.0 20 01 01 1 05 -19.2 0.196 -9.000 -9.000 -999. 209. 42.5 0.19 0.75 1.00 2.05 154. 10.0 282.0 2.0 20 01 01 1 06 -15.7 0.174 -9.000 -9.000 -999. 174. 33.1 0.12 0.75 1.00 2.06 121. 10.0 281.4 2.0 20 01 01 1 07 -11.1 0.145 -9.000 -9.000 -999. 132. 24.7 0.11 0.75 1.00 1.76 71. 10.0 280.3 2.0 20 01 01 1 08 -16.3 0.177 -9.000 -9.000 -999. 179. 34.5 0.12 0.75 0.73 2.10 124. 10.0 280.9 2.0 20 01 01 1 09 -1.4 0.212 -9.000 -9.000 -999. 234. 617.8 0.19 0.75 0.39 2.08 153. 10.0 279.8 2.0 20 01 01 1 10 38.3 0.267 0.545 0.014 154. 331. -45.2 0.12 0.75 0.27 2.64 132. 10.0 279.2 2.0 20 01 01 1 11 68.5 0.209 0.820 0.016 293. 231. -12.2 0.14 0.75 0.23 1.72 100. 10.0 278.8 2.0 20 01 01 1 12 85.1 0.229 0.924 0.014 337. 262. -12.8 0.20 0.75 0.22 1.69 227. 10.0 278.1 2.0 20 01 01 1 13 87.2 0.195 0.967 0.014 377. 206. -7.7 0.15 0.75 0.21 1.47 287. 10.0 278.8 2.0 20 01 01 1 14 74.6 0.225 0.942 0.014 408. 256. -13.9 0.10 0.75 0.22 2.08 321. 10.0 278.8 2.0 20 01 01 1 15 48.1 0.370 0.827 0.014 427. 539. -95.5 0.10 0.75 0.26 4.00 325. 10.0 279.8 2.0 20 01 01 1 16 10.0 0.329 0.491 0.014 431. 454. -324.5 0.10 0.75 0.35 3.71 328. 10.0 279.2 2.0 20 01 01 1 17 -18.8 0.205 -9.000 -9.000 -999. 232. 46.4 0.09 0.75 0.60 2.57 352. 10.0 279.8 2.0 20 01 01 1 18 -27.2 0.270 -9.000 -9.000 -999. 336. 80.0 0.09 0.75 1.00 3.34 337. 10.0 283.1 2.0 20 01 01 1 19 -20.9 0.208 -9.000 -9.000 -999. 229. 47.7 0.09 0.75 1.00 2.61 353. 10.0 284.8 2.0 20 01 01 1 20 -18.7 0.189 -9.000 -9.000 -999. 198. 39.4 0.10 0.75 1.00 2.33 322. 10.0 286.4 2.0 20 01 01 1 21 -25.2 0.254 -9.000 -9.000 -999. 307. 71.0 0.15 0.75 1.00 2.78 285. 10.0 287.5 2.0 20 01 01 1 22 -23.5 0.238 -9.000 -9.000 -999. 279. 62.5 0.17 0.75 1.00 2.54 254. 10.0 288.8 2.0 20 01 01 1 23 -21.9 0.222 -9.000 -9.000 -999. 251. 54.3 0.10 0.75 1.00 2.71 305. 10.0 288.8 2.0 20 01 01 1 24 -21.2 0.215 -9.000 -9.000 -999. 239. 50.9 0.09 0.75 1.00 2.69 336. 10.0 288.8 2.0 First hour of profile data
YR MO DY HR HEIGHT F WDIR WSPD AMB_TMP sigmaA sigmaW sigmaV 20 01 01 01 10.0 1 81. 1.25 286.0 99.0 -99.00 -99.00
F indicates top of profile (=1) or below (=0)
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 115
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** THE SUMMARY OF MAXIMUM PERIOD ( 43848 HRS) RESULTS *** ** CONC OF OTHER IN MICROGRAMS/M**3 **

NETWORK

GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL 1ST HIGHEST VALUE IS 5.30486 AT ( 649681.31, 4198168.45, 1.83, 1.83, 0.00) DC 2ND HIGHEST VALUE IS 5.18659 AT ( 649681.31, 4198193.45, 1.91, 1.91, 0.00) DC 3RD HIGHEST VALUE IS 4.43254 AT ( 649681.31, 4198143.45, 1.83, 1.83, 0.00) DC 4TH HIGHEST VALUE IS 4.34243 AT ( 649435.44, 4197986.05, 1.62, 1.62, 0.00) DC 5TH HIGHEST VALUE IS 4.30366 AT ( 649461.92, 4198012.66, 1.54, 1.54, 0.00) DC 6TH HIGHEST VALUE IS 4.25896 AT ( 649406.73, 4197953.38, 1.60, 1.60, 0.00) DC 7TH HIGHEST VALUE IS 4.16255 AT ( 649490.86, 4198035.96, 1.53, 1.53, 0.00) DC 8TH HIGHEST VALUE IS 4.07304 AT ( 649378.02, 4197920.71, 1.78, 1.78, 0.00) DC 9TH HIGHEST VALUE IS 4.01667 AT ( 649520.12, 4198056.91, 1.55, 1.55, 0.00) DC 10TH HIGHEST VALUE IS 3.93392 AT ( 649546.46, 4198075.06, 1.62, 1.62, 0.00) DC *** RECEPTOR TYPES: GC = GRIDCART
GP = GRIDPOLR
DC = DISCCART
DP = DISCPOLR
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 116
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** THE SUMMARY OF HIGHEST 1-HR RESULTS ***
** CONC OF OTHER IN MICROGRAMS/M**3 **

DATE NETWORK

GROUP ID AVERAGE CONC (YYMMDDHH) RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ALL HIGH 1ST HIGH VALUE IS 221.42772 ON 22121308: AT ( 649681.31, 4198193.45, 1.91, 1.91, 0.00) DC *** RECEPTOR TYPES: GC = GRIDCART
GP = GRIDPOLR
DC = DISCCART
DP = DISCPOLR
EXHIBIT 1
*** AERMOD - VERSION 24142 *** *** D:\LSA\2025\20252166 Van Buskirk\Construction\Construction.isc *** 05/25/25 *** AERMET - VERSION 24142 *** *** *** 12:42:09
PAGE 117
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U*
*** Message Summary : AERMOD Model Execution ***
--------- Summary of Total Messages --------

A Total of 0 Fatal Error Message(s)
A Total of 2 Warning Message(s)
A Total of 1672 Informational Message(s)
A Total of 43848 Hours Were Processed
A Total of 713 Calm Hours Identified
A Total of 959 Missing Hours Identified ( 2.19 Percent)

******** FATAL ERROR MESSAGES ********
*** NONE ***

******** WARNING MESSAGES ********
ME W186 97 MEOPEN: THRESH_1MIN 1-min ASOS wind speed threshold used 0.50 ME W187 97 MEOPEN: ADJ_U* Option for Stable Low Winds used in AERMET ************************************
*** AERMOD Finishes Successfully ***
************************************
EXHIBIT 1
HARP2 - HRACalc (dated 22118) 5/25/2025 3:49:07 PM - Output Log GLCs loaded successfully
Pollutants loaded successfully
Pathway receptors loaded successfully
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: -0.25
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0.25
0<2 Years Bin: 1
2<9 Years Bin: 0
2<16 Years Bin: 0
16<30 Years Bin: 0
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

Inhalation: True
Soil: True
Dermal: True
Mother's milk: True
Water: False
Fish: True
Homegrown crops: True
Beef: False
Dairy: False
Pig: False
Chicken: False
Egg: False
**********************************

INHALATION
Daily breathing rate: LongTerm24HR
**Worker Adjustment Factors**
Worker adjustment factors enabled: NO
**Fraction at time at home**
3rd Trimester to 16 years: ON
16 years to 70 years: ON
**********************************
EXHIBIT 1

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Mixed
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************

FISH PATHWAY SETTINGS
Surface area (m^2): 207411.4
Volume (kg): 3.004555E+08
Volume changes per year: 5287.636
Fraction from contaminated source: 0.15
**********************************
TIER 2 SETTINGS
Tier2 adjustments were used in this assessment. Please see the input file for details.

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 1
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 1
2<9 Years Bin: 0
2<16 Years Bin: 0
16<30 Years Bin: 0
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Mixed
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Worker
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 16
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 0
2<9 Years Bin: 0
2<16 Years Bin: 0
16<30 Years Bin: 1
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

Inhalation: True
Soil: True
Dermal: True
Mother's milk: False
Water: False
Fish: False
Homegrown crops: False
Beef: False
Dairy: False
Pig: False
Chicken: False
Egg: False
**********************************

INHALATION
Daily breathing rate: Moderate8HR
**Worker Adjustment Factors**
Worker adjustment factors enabled: NO
**Fraction at time at home**
3rd Trimester to 16 years: OFF
16 years to 70 years: OFF
**********************************
EXHIBIT 1

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Mixed
**********************************
TIER 2 SETTINGS
Tier2 adjustments were used in this assessment. Please see the input file for details.

RISK SCENARIO SETTINGS
Receptor Type: Worker
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 17
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 0
2<9 Years Bin: 0
2<16 Years Bin: 0
16<30 Years Bin: 1
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 4
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 0
2<9 Years Bin: 1
2<16 Years Bin: 0
16<30 Years Bin: 0
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

INHALATION
Daily breathing rate: LongTerm24HR
**Worker Adjustment Factors**
Worker adjustment factors enabled: NO
**Fraction at time at home**
3rd Trimester to 16 years: OFF
16 years to 70 years: OFF
**********************************
EXHIBIT 1

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Mixed
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 5
Total Exposure Duration: 1
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 0
2<9 Years Bin: 1
2<16 Years Bin: 0
16<30 Years Bin: 0
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Mixed
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************

Tier2 - What was changed: ED or start age changed|
Calculating cancer risk
Cancer risk breakdown by pollutant and receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_CancerRisk.csv Cancer risk total by receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_CancerRiskSumByRec.csv Calculating chronic risk
Chronic risk breakdown by pollutant and receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_NCChronicRisk.csv Chronic risk total by receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_NCChronicRiskSumByRec.csv Calculating acute risk
Acute risk breakdown by pollutant and receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_NCAcuteRisk.csv Acute risk total by receptor saved to: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST\hra\Const_School_Year2_NCAcuteRiskSumByRec.csv HRA ran successfully
EXHIBIT 1
Water Area
sqft 2,232,558
Water Volume
Area Ft3
10,610,486
Water Volume
Flow FT3/yr 56,104,385,612
Change Outs /
Year
5,288
Liters 300,455,506
EXHIBIT 1
HARP Project Summary Report 5/25/2025 5:23:10 PM
***PROJECT INFORMATION***
HARP Version: 22118
Project Name: HARP_CONST
Project Output Directory: D:\LSA\2025\20252166 Van Buskirk\HARP_CONST HARP Database: NA
***POLLUTANT HEALTH INFORMATION***
Health Database: D:\HARP2\Tables\HEALTH17320.mdb
Health Table Version: HEALTH22013
Official: True
PolID PolAbbrev InhCancer OralCancer AcuteREL InhChronicREL OralChronicREL InhChronic8HRREL
_______________________________________________________________________________________ _________________________________________
9901 DieselExhPM 1.1 5
EXHIBIT 1

APPENDIX C

NOISE MONITORING RESULTS
EXHIBIT 1
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EXHIBIT 1
Noise Measurement Survey – 24 HR
Project Number: 20252166 Test Personnel: Dana Kwan
Project Name: Van Buskirk Park EIR Equipment: Spark 706RC (SN:18906) Site Number: LT-1 Date: 4/22/25 Time: From 3:00 p.m. To 3:00 p.m.

Site Location: 734 Houston Avenue, Stockton, CA 95206. In a tree, approximately 53 feet south of the Houston Avenue centerline and 1,244 feet west of Manthey Road.

Primary Noise Sources: Occasional cars on Houston Avenue, occasional cars entering and exiting Van Buskirk Community Center parking lot, occasional aircraft.

Comments: Light construction noise at property north of Houston Avenue.

Photo:

EXHIBIT 1
Long-Term (24-Hour) Noise Level Measurement Results at LT-1 Start Time Date Noise Level (dBA)
Leq Lmax Lmin
3:00 PM 4/22/25 62.0 90.4 42.7
4:00 PM 4/22/25 59.7 76.9 44.0
5:00 PM 4/22/25 60.7 84.6 45.1
6:00 PM 4/22/25 58.1 73.2 45.9
7:00 PM 4/22/25 58.1 75.2 44.8
8:00 PM 4/22/25 58.5 72.2 46.7
9:00 PM 4/22/25 57.2 71.5 45.4
10:00 PM 4/22/25 56.3 74.3 44.3
11:00 PM 4/22/25 53.6 70.3 43.2
12:00 AM 4/23/25 50.5 69.4 41.8
1:00 AM 4/23/25 51.2 77.7 41.5
2:00 AM 4/23/25 52.8 75.6 42.6
3:00 AM 4/23/25 53.7 80.5 43.8
4:00 AM 4/23/25 52.8 70.5 43.9
5:00 AM 4/23/25 56.4 73.6 47.4
6:00 AM 4/23/25 58.0 75.4 48.0
7:00 AM 4/23/25 60.9 75.0 49.3
8:00 AM 4/23/25 62.2 75.6 49.2
9:00 AM 4/23/25 60.4 74.5 48.4
10:00 AM 4/23/25 60.9 71.7 45.5
11:00 AM 4/23/25 60.7 77.1 47.5
12:00 PM 4/23/25 60.8 79.6 49.6
1:00 PM 4/23/25 61.2 81.5 45.7
2:00 PM 4/23/25 60.5 79.3 42.3
Source: Compiled by LSA Associates, Inc. (2025).
dBA = A-weighted decibel
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
Lmin = minimum measured sound level

0.0 10.0

20.0 30.0

40.0 50.0

60.0 70.0

80.0 90.0
100.0
3:00 PM4:00 PM5:00 PM6:00 PM7:00 PM8:00 PM9:00 PM
10:00 PM11:00 PM
12:00 AM
1:00 AM2:00 AM3:00 AM4:00 AM5:00 AM6:00 AM7:00 AM8:00 AM9:00 AM 10:00 AM11:00 AM
12:00 PM
1:00 PM2:00 PM
Noise Level (dBA Leq)
Time of Day
Long-Term (24-Hour) Noise Level Measurement
LT-1
Leq Lmax Lmin
EXHIBIT 1
Noise Measurement Survey – 24 HR
Project Number: 20252166 Test Personnel: Dana Kwan
Project Name: Van Buskirk Park EIR Equipment: Spark 706RC (SN:18907) Site Number: LT-2 Date: 4/22/25 Time: From 3:00 p.m. To 3:00 p.m.

Site Location: 2772 South Fresno Avenue, Stockton, CA 95206. In a tree, approximately 23 feet south of the Houston Avenue centerline and 4,166 feet southeast of CA-4.

Primary Noise Sources: Occasional cars on Houston Avenue and South Fresno Avenue, occasional aircraft.

Comments:

Photo:

EXHIBIT 1
Long-Term (24-Hour) Noise Level Measurement Results at LT-2 Start Time Date Noise Level (dBA)
Leq Lmax Lmin
3:00 PM 4/22/25 61.6 85.8 38.6
4:00 PM 4/22/25 56.3 76.8 42.4
5:00 PM 4/22/25 58.2 75.2 42.4
6:00 PM 4/22/25 60.9 86.8 40.3
7:00 PM 4/22/25 57.9 81.8 40.9
8:00 PM 4/22/25 57.2 76.2 43.0
9:00 PM 4/22/25 57.0 74.0 44.2
10:00 PM 4/22/25 57.8 77.1 41.5
11:00 PM 4/22/25 49.4 67.5 40.5
12:00 AM 4/23/25 48.3 69.1 39.4
1:00 AM 4/23/25 54.9 84.5 38.5
2:00 AM 4/23/25 52.8 75.2 39.4
3:00 AM 4/23/25 56.4 86.8 39.0
4:00 AM 4/23/25 51.3 78.5 40.3
5:00 AM 4/23/25 56.0 73.9 44.9
6:00 AM 4/23/25 54.3 78.4 43.7
7:00 AM 4/23/25 58.3 85.9 42.5
8:00 AM 4/23/25 57.4 75.1 41.9
9:00 AM 4/23/25 56.5 76.9 40.8
10:00 AM 4/23/25 57.6 80.4 39.5
11:00 AM 4/23/25 57.2 82.8 39.8
12:00 PM 4/23/25 55.5 80.3 39.4
1:00 PM 4/23/25 55.2 74.5 39.8
2:00 PM 4/23/25 60.5 87.1 40.2
Source: Compiled by LSA Associates, Inc. (2025).
dBA = A-weighted decibel
Leq = equivalent continuous sound level
Lmax = maximum instantaneous noise level
Lmin = minimum measured sound level

0.0 10.0

20.0 30.0

40.0 50.0

60.0 70.0

APPENDIX D

RESPONSE TO COMMENTS
EXHIBIT 1
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EXHIBIT 1

MEMORANDUM
DATE: August 14, 2025
TO: Liszet Burgueño, Junior Engineer, CIP, City of Stockton Public Works Department Shalilah Bess, Program Manager III, City of Stockon City Manager’s Office FROM: Theresa Wallace, AICP, Principal
Shanna Guiler, AICP, Associate/Senior Environmental Planner SUBJECT: Van Buskirk Park Revitalization Project Initial Study/Mitigated Negative Declaration - Response to Comments
In accordance with Section 15074 of the CEQA Guidelines, prior to approving a project, the decisionmaking body of the lead agency shall consider the proposed environmental document together with any comments received during the public review process. Although there is no legal requirement to formally respond to comments on a proposed Mitigated Negative Declaration (MND) as there is for an Environmental Impact Report (EIR), this memorandum provides a response to the written comments received on the Van Buskirk Park Revitalization Project Initial Study/Mitigated Negative Declaration (IS/MND) to aid the City of Stockton decision‐makers in their review of the Project.

The IS/MND was circulated for public review for a period of 30 days, from June 26, 2025 to July 25, 2025. Five comment letters were received during the public review period. Three comment letters were received from State/regional agencies and two were received from local organizations and individuals. In the following pages, the comments and responses are enumerated to allow for crossreferencing of CEQA-related comments. The enumerated comment letters are included in this memorandum, followed by the respective responses.

As noted above, CEQA does not require or provide guidance on responding to comments on MNDs; therefore, this memorandum follows CEQA Guidelines Section 15088, applicable to responses to comments on EIRs, which requires that agencies respond only to significant environmental issues raised in connection with the project. Therefore, this document focuses primarily on responding to comments that relate to the adequacy of the information and environmental analysis provided in the IS/MND.

Written responses to all written comments on the Draft IS/MND are provided below. A reproduction of each comment letter received on the Draft IS/MND is provided as an attachment to this memorandum (Attachment A). Mitigation measures identified in the Draft IS/MND are incorporated into the Mitigation Monitoring and Reporting Program (MMRP). The MMRP will be adopted by the City if the IS/MND is adopted.

EXHIBIT 1

COMMENTS AND RESPONSES
This section includes responses to each substantive CEQA-related comment. Each comment letter is assigned a letter (A, B, C, etc.) and individual comments within each letter are numbered consecutively. For instance, comment A-1 is the first numbered comment in Letter A. Please note that text within individual letters that has not been numbered does not raise environmental issues or relate to the adequacy of the information or analysis within the IS/MND, and therefore, no comment is enumerated or response required, per CEQA Guidelines Section 15132.

The following comment letters were submitted:

LETTER A
California Department of Fish and Wildlife, Erin Chappell, Regional Manager, Bay Delta Region, July 18, 2025

LETTER B
California Department of Conservation, Geologic Energy Management Division, May Soe, Supervising Oil & Gas Engineer
July 22, 2025

LETTER C
Central Valley Regional Water Quality Control Board, Peter G. Minkel, Engineering Geologist July 17, 2025

LETTER D
American Rivers and Restore the Delta, Teague Tran, American Rivers, Associate Director, Central Valley River Restoration and Artie Valencia, Restore The Delta, Flood and Land Restoration Manager
July 25, 2025

LETTER E
Patrisia Avelar
July 12, 2025
Where revisions to the Draft IS/MND text are called for, the page is set forth followed by the appropriate revision. Added text is indicated with double underlined text, and deleted text is shown in strikeout. As described herein, these changes have been made to clarify, amplify, or make minor edits to the IS/MND text for the proposed Project. Such changes are a result of further review of, and public comments related to, the IS/MND. The changes are generally minor changes that do not constitute significant new information, change the conclusions of the environmental analysis, or require recirculation of the document (State CEQA Guidelines Section 15073.5).

EXHIBIT 1

LETTER A
Erin Chappell, Regional Manager, Bay Delta Region, California Department of Fish and Wildlife (CDFW)
July 18, 2025
Response A-1 This comment is introductory, provides CDFW’s role as a Trustee Agency, and does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

Response A-2 This comment summarizes the proposed Project and does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

Response A-3 This comment summarizes various regulatory requirements that are under the purview of CDFW, including the California Endangered Species Act and the Native Plant Protection Act, California Fish and Game Code protection for fully protected species, raptors and nesting birds and Lake or Streambed Alteration Notification. Potential impacts to special-status species and riparian areas under the jurisdiction of the CDFW are described in Section

4.4 of the Draft IS/MND. As described in Draft IS/MND, potential impacts to biological resources would be reduced to less than significant with implementation of identified mitigation measures. This comment does not address the adequacy of the information or analysis in the Draft IS/MND.

Therefore, no further response is required.

Response A-4 This comment states that Table 4.D in the Draft IS/MND does not identify burrowing owl as a candidate species for listing under the California Endangered Species Act (CESA). Further, the comment states that Mitigation Measure BIO-4 does not adequately mitigate impacts to burrowing owl to less-than-significant.

In response to this comment, Table 4.D on page 4-17 of the Draft IS/MND has been revised as shown on the following page and page 4-37 of the Draft IS/MND has been revised as follows:

Burrowing Owl. In 2024, Bburrowing owl is a California Species of Special Concern was designated as a Candidate species under the California Endangered Species Act. As a Candidate species, the burrowing owl receives the same legal protection afforded to Endangered or Threatened species.1 Burrowing owl is a small grounddwelling owl that generally inhabits gently sloping areas characterized by low, sparse vegetation.
1 California Fish and Game Code Sections 2074.2 & 2085 (2023).

No suitable habitat.

Heartscale
Atriplex cordulata var. cordulata
None None G3T2 S2 1B.2 Shadescale scrub, valley grassland, and wetland-riparian.

No suitable habitat.

Big tarplant
Blepharizonia plumosa
None None G1G2 S1S2 1B.1 Valley and foothill grassland, and clay (usually).

No suitable habitat.

Watershield
Brasenia schreberi
None None G5 S3 2B.3 Still or slow-moving water of ponds, shallow lakes, margins of deeper lakes and manmade
reservoirs, freshwater marshes, sloughs, and
canals.

No suitable habitat, but
potential habitat is
adjacent to Project area.

Palmate-bracted bird's-beak
Chloropyron palmatum
FE CE G1 S1 1B.1 Chenopod scrub, valley and foothill
grassland, and alkaline.

No suitable habitat.

San Joaquin spearscale
Extriplex joaquinana
None None G2 S2 1B.2 Chenopod scrub, meadows and seeps, playas, valley and foothill grassland, and
alkaline.

No suitable habitat.

Woolly rose-mallow
Hibiscus lasiocarpos var.
occidentalis
None None G5T3 S3 1B.2 Marshes and swamps (freshwater); often in riprap on the sides of levees.

No suitable habitat.

Delta tule pea
Lathyrus jepsonii var. jepsonii
None None G5T2 S2 1B.2 Marshes and swamps (brackish and freshwater).

No suitable habitat.

Sanford’s arrowhead
Sagittaria sanfordii
None None G3 S3 1B.2 Marshes and swamps (shallow freshwater). No suitable habitat.

Suisun marsh aster
Symphyotrichum lentum
None None G2 S2 1B.2 Marshes and swamps (brackish and
freshwater).

No suitable habitat.

Saline clover
Trifolium hydrophilum
None None G2 S2 1B.2 Marshes and swamps, valley and foothill grassland (mesic and alkaline), and vernal
pools.

No suitable habitat.

Insects
Monarch butterfly
Danaus plexippus
FC G4 None Milkweed species (Asclepias spp.) are the
sole larval host plants.

High to moderate.

Crotch’s bumble bee
Bombus crotchii
None CC G2 S1 Open grassland and scrub habitats. Nesting occurs underground.

No suitable Suitable
habitat present. Recent
CNDDB observations near
Tracy.

Western bumble bee
Bombus occidentalis
None CC G2 S1 Open grassland and scrub habitats. Nesting occurs underground.

No suitable Suitable
habitat present, but
species was last observed
in San Joaquin County in
1962.

Fish
Steelhead (Central Valley DPS)
Oncorhynchus mykiss
FT None G5T2Q S2 Inland streams and rivers. No suitable habitat, but critical habitat is adjacent
to Project area.

Green sturgeon (Southern DPS)
Acipenser medirostris
FT None G2T1 S1 Inland streams and rivers. No suitable habitat, but critical habitat is adjacent
to Project area.

Amphibians
Western spadefoot toad
Spea hammodii
FT CT G2G3 S2S3 WL Vernal pool grasslands. No suitable habitat.

California tiger salamander
(Ambystoma californiense)
FT,
Central
California
DPS
CT,
Central
California
DPS
G2G3T3 S3 WL Vernal pool grasslands. No suitable habitat.

Reptiles
Northwestern pond turtle
Actinemys marmorata
None CC G5 S4 SSC Permanent and intermittent waters of rivers, creeks, small lakes and ponds, marshes,
irrigation ditches, and reservoirs. Turtles bask
on land or near water on logs, branches or
boulders. Nesting and overwintering in
uplands.

Suitable habitat is present;
no observations.

Swainson’s hawk
Buteo swainsoni
None CT G5 S3 Needs open habitats for foraging; adjusted well to agricultural settings (e.g., hay and
alfalfa fields, pastures, grain crops, and row
crops). Nests in riparian woodlands and
scattered stands of trees near agricultural
fields and grasslands.

Present.

Tricolored blackbird
Agelaius tricolor
None CT G1G2 S1S2 SSC Nests in wetlands with cattails, bulrushes, and willows, triticale fields, and patches of
Himalayan blackberry near stock ponds or
irrigated pastures. Foraging habitats include
cultivated fields, feedlots associated with
dairy farms, and wetlands.

No suitable habitat.

Sources: California Native Plant Society (2020), California Department of Fish and Wildlife (2020), and United States Fish and Wildlife Service (2020). 1 Federal Status Codes (USFWS): FE= Listed as Endangered (in danger of extinction) by the Federal Government; FT = Listed as Threatened (likely to become Endangered within the foreseeable future) by the Federal Government; FC = Candidate to become a proposed species; FSC = Federal Species of Concern. May be Endangered or Threatened, but not enough biological information has been gathered to support listing at this time; FC = Candidate to become a proposed species. 2 State Status Codes (CDFW): CE = Listed as Endangered by the State of California; SSC = California Species of Special Concern; CT = Listed as Threatened by the State of California; CR = California Rare; CC = State Candidate for listing as an Endangered Species; WL = Watch List. 3 Global Rank: G1: Critically Imperiled – At very high risk of extinction due to very restricted range, very few populations or occurrences, very steep declines, very severe threats, or other factors; G2: Imperiled – At high risk of extinction due to restricted range, few populations or occurrences, steep declines, severe threats, or other factors. G3: Vulnerable – At moderate risk of extinction due to a fairly restricted range, relatively few populations or occurrences, recent and widespread declines, threats, or other factors. G4: Apparently Secure – At fairly low risk of extinction due to an extensive range and/or many populations or occurrences, but with possible cause for some concern as a result of local recent declines, threats, or other factors. G5: Secure – At very low risk of extinction due to a very extensive range, abundant populations or occurrences, and little to no concern from declines or threats. 4 Taxa which are subspecies receive a taxon rank (T-rank) in addition to the G-rank. Whereas the G-rank reflects the condition of the entire species, the T-rank reflects the global status of just the subspecies. 5 State Rank: S1: Critically Imperiled – At very high risk of extirpation in the State due to very restricted range, very few populations or occurrences, very steep declines, severe threats, or other factors. S2: Imperiled – At high risk of extirpation in the State due to restricted range, few populations or occurrences, steep declines, severe threats, or other factors. S3:

Vulnerable – At moderate risk of extirpation in the State due to a fairly restricted range, relatively few populations or occurrences, recent and widespread declines, threats, or other factors. S4: Apparently Secure – At a fairly low risk of extirpation in the State due to an extensive range and/or many populations or occurrences, but with possible cause for some concern as a result of local recent declines, threats, or other factors. S5: Secure – At very low or no risk of extirpation in the State due to a very extensive range, abundant populations or occurrences, and little to no concern from declines or threats.

EXHIBIT 1
Table 4.D: Special-Status Species and Sensitive Natural Communities Occurring within 1 Mile of the Project Site Common Name/Scientific
Name
Federal
Status1
State
Status2
Global
Rank3,4
State
Rank5
Rare
Plant
Rank6
CDFW
Status Habitat Potential to Occur
6 California Native Plant Society Rare Plant Inventory: Rank 1A: Plants Presumed Extinct in California; Rank 1B: Plants Rare, Threatened, or Endangered in California and Elsewhere; Rank 2: Plants Rare, Threatened, or Endangered in California, But More Common Elsewhere; Rank 3: Plants About Which We Need More Information—A Review List; Rank 4: Plants of Limited Distribution—A Watch List.

CDFW = California Department of Fish and Wildlife
DPS = Distinct Population Segment
USFWS = United States Fish and Wildlife Service
EXHIBIT 1
In addition, Item 3 as identified in Mitigation Measure BIO-4 on pages 4-28 and 4-29 of the Draft IS/MND has been revised as follows:

Mitigation Measure BIO-4 Preconstruction and Construction Monitoring. The City shall avoid and minimize effects to special-status species during construction, habitat restoration, and maintenance activities associated with the Project. The following preconstruction and construction monitoring measures shall be implemented:

3. A qualified biologist shall conduct a burrowing owl habitat assessment and surveys, if habitat for burrowing owl is present prior to construction. The habitat assessment and surveys shall follow the Department of Fish and Game State Report on
Burrowing Owl Mitigation2 methodology and the qualified biologist shall prepare a report documenting the survey results, and submit the report to CDFW, and obtain CDFW’s written approval of the report prior to Project construction.

The habitat assessment and surveys shall encompass the
Project site and a sufficient buffer zone to detect owls nearby that may be impacted, which is up to 500 meters (1,640 feet) around the Project site pursuant to above methodology.

Habitat assessments and surveys shall occur annually for the duration of the Project, as conditions may change annually and suitable refugia for burrowing owl, such as small mammal burrows, can be created within a few hours or days. Surveys for either non-breeding or breeding burrowing owls shall be spread over four visits during the non-breeding and breeding season. Time lapses between surveys or Project activities shall trigger subsequent surveys including, but not limited to, a final survey within 24 hours prior to ground disturbance. If the habitat assessment does not identify habitat and surveys are not conducted, an additional habitat assessment shall be conducted within 14 days prior to construction. If new refugia are present such as burrows or novel Project infrastructure, surveys shall be conducted as described above. The qualified biologist shall have a minimum of two years of experience implementing the above methodology. preconstruction
surveys at the Project site to determine whether any
burrowing owls are present at the Project site or within 500 feet from planned work activities, including access roads, 2 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. Website:
nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843 (accessed July 29, 2021).

EXHIBIT 1
parking areas, and staging areas. The qualified biologist will determine, to the extent possible, the status of any owls present on or adjacent to the Project site (i.e., resident, nesting, or migrant). All preconstruction surveys shall follow standard CDFW protocols,3 including a preconstruction survey within 14 days before construction starts and a second survey 24 hours before it starts. If a lapse in Project-related construction work of 14 days or longer occurs during the nesting season, an additional preconstruction survey shall be required within 24 hours before Project work may be
reinitiated. The following measures shall be implemented for construction activities should preconstruction surveys find burrowing owls to be present:
a. The City shall immediately notify CDFW if burrowing owl is detected and implement a construction avoidance buffer
around any detected burrowing owl pursuant to the buffer distances outlined in the Department of Fish and Game
State Report on Burrowing Owl Mitigation. Any detected
owl shall be monitored by the qualified biologist to ensure it is not disturbed during construction activities. During the nonbreeding season (September 1 through January 31), a
circular exclusion zone with a radius of 250 feet shall be established around occupied burrows.
b. If the City cannot ensure burrowing owl and their burrows are fully avoided, the City shall consult with CDFW and obtain a California Endangered Species Act (CESA) take
authorization or otherwise demonstrate compliance with
CESA. Take is likely to occur and City shall obtain an
Incidental Take Permit (ITP) if burrowing owl surveys detect burrowing owl occupancy of burrows or burrow surrogates within the Project site. Occupancy of habitat may also be indicated by burrowing owl sign including molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site.If an adequate buffer cannot be established during the nonbreeding
season, resident and migrant wintering burrowing owls may be evicted from the entire construction area using passive relocation techniques and vegetation management
provided that suitable alternative burrows are located
within 330 feet of occupied burrows and can be protected 3 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. Website:
nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843 (accessed July 29, 2021).

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during Project construction. The City shall prepare an
Exclusion Plan for review and approval by CDFW.
c. If burrowing owl, or their burrows or burrow surrogates are detected within 500 meters (1,640 feet0 of the Project site, but not on the Project site, the City shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted.

During the breeding season (February 1 through August 31), a qualified biologist shall establish a circular exclusion zone with radius of 450 feet (150 meters) around each occupied burrow. No construction-related activity (e.g., site grading, staking, surveying, or any use of construction equipment) shall occur in the exclusion zone during the breeding
season. Once the breeding season is over (e.g., the young have fledged and are no longer dependent on the adults), passive relocation/eviction may proceed under a CDFWapproved Exclusion Plan. d. To prevent burrowing owl from sheltering or nesting in exposed material; all construction pipes, culverts, hoses or similar materials greater than two inches in diameter stored at the Project site shall be capped or covered before the end of each work day and shall be inspected thoroughly for wildlife before the pipe or similar structure is buried, capped, used, or moved. Construction buffer widths may
be reduced from the 450-foot-wide breeding season buffers and 250-foot-wide nonbreeding season buffers if approved by CDFW.

The revisions identified above represent a minor change to the Draft IS/MND in order to clarify the Draft IS/MND analysis. These revisions do not change the conclusions or analysis of impacts in the Draft IS/MND necessitating recirculation of the Draft IS/MND.

Response A-5 This comment states that Table 4.D in the Draft IS/MND does not identify Crotch’s bumble bees as a Candidate species for listing under the California Endangered Species Act (CESA) and indicates there is no suitable habitat at the site. Further, the comment provides recommended revisions to Mitigation Measure BIO-4 to adequately mitigation for impacts to specialstatus bee species.

In response to this comment, Table 4.D on page 4-17 of the Draft IS/MND has been revised as shown on the previous pages and Item 4 as identified in Mitigation Measure BIO-4 on pages 4-28 and 4-29 of the Draft IS/MND has been revised as follows:

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Mitigation Measure BIO-4 Preconstruction and Construction Monitoring. The City shall avoid and minimize effects to special-status species during construction, habitat restoration, and maintenance activities associated with the Project. The following preconstruction and construction monitoring measures shall be implemented:

4. Preconstruction bumble bee surveys shall be conducted in all grassland areas at least 14 days prior to construction, following nonlethal survey protocols and current State and federal guidelines. A minimum of three pre-activity surveys shall be conducted within 30 days during appropriate activity periods (i.e., March through September) prior to the start of grounddisturbing activities to identify bumble bee activity. Surveys should be repeated for each year of the Project activities. The preactivity surveys shall occur when temperatures are above 60°Fahrenheit (15.5°Celsius) and not during wet conditions (e.g., foggy, raining, or drizzling). The survey shall be conducted at least 2 hours after sunrise and 3 hours before sunset, and shall occur at least 1 hour after rain subsides. Preferably, the survey should be conducted during sunny days with low wind speeds (less than 8 miles per hour), but surveying during partially cloudy days or overcast conditions is permissible if the surveyors can still see their own shadows.

If Crotch’s or western bumble bees (since bumble bees can be difficult to identify in the field) are observed within the Project site, a plan to protect Crotch’s and/or westernspecial-status bumble bee nests and individuals shall be developed and implemented in consultation with CDFW. The plan shall include, but not be limited to, the following measures:
a. Specifications for construction timing and sequencing requirements (e.g., avoidance of mowing, tilling, or other ground disturbance until late March to protect
overwintering queen bumble bees);
b. Establishment of appropriate no-disturbance buffers for bumble bee nest sites to avoid impacts to the bees and
monitoring by a qualified biologist to ensure compliance if bumble bee nests are identified;
c. Restrictions associated with construction equipment or materials that may harm bumble bees (e.g., avoidance of pesticides/herbicides, BMPs to minimize the spread of
invasive plant species);
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d. Provisions to avoid western bumble bees, or potential western bumble bees if observed away from a bumble bee
nest during Project activity (e.g., ceasing of Project activities until the animal has left the active work area on its own volition); and
e. Prescription of an appropriate restoration seed mix targeted for the western bumble bee, including native plant species known to be visited by native bumble bee species and
containing a mix of flowering plant species with continual floral availability through the entire active season of the western bumble bee (March through September).

If Project impacts to special-status bumble bee cannot be completely avoided, the City shall apply obtain an ITP from CDFW.

If the Project will result in permanent impacts to suitable special-status bumble bee habitat, the City shall provide compensatory mitigation at a minimum ratio of 3:1. Floral resources shall be replaced as close to their original location as is feasible. If active special-status bumble bee nests have been identified and floral resources cannot be replaced within 200 meters (656 feet) of their original location, floral resources shall be planted in the most centrally available location relative to identified nests. This location shall be no more than 1.5- kilometer (4,921 feet) from any identified nest. Replaced floral resources may be split into multiple patches to meet distance requirements for multiple nests. Mitigation lands shall be protected in perpetuity under a conservation easement with an endowment established for long-term management of the
lands.

The revisions to Mitigation Measure BIO-4 do not change the significance of the environmental issue conclusions within the Draft IS/MND and do not represent significant new information such that recirculation of the Draft IS/MND is required.

Response A-6 This comment recommends that the Draft IS/MND include a thorough analysis of the short-term and long-term impacts, including cumulative impacts of the Lower San Joaquin River Project (LSJR Project), which includes 23 miles of levee improvements and two closure structures proposed by the U.S. Army Corps of Engineers. A portion of the Van Buskirk Project site is proposed for use as mitigation for impacts associated with the LSJR Project. This area is described in Section 2.3.2, Subsequent Phases, on page 2-27 of the Draft IS/MND and shown on Figure 2-3. As described in the EXHIBIT 1
Draft IS/MND, given that detailed design for subsequent phases is not known at this time, the Initial Study evaluates the conceptual elements of these subsequent phases at a programmatic level and identifies the potential environmental impacts and mitigation measures that could be required for development of these improvements by the City when funding becomes available. The City intends that future Project-specific actions pursuant to the Van Buskirk Park Revitalization Project that would implement improvements beyond those considered in the programmatic analysis in the IS/MND would be subject to project-level CEQA analysis and compliance. Prior to implementation of specific improvements, City staff will review recommended projects on a case-by-case basis to determine if any supplemental review under CEQA would be required to address potentially adverse project-specific impacts that are not mitigated through the recommended design guidelines and mitigation measures identified in the IS/MND.

The LSJR Project has undergone extensive NEPA and CEQA review, starting with preparation of the San Joaquin River Basin, Lower San Joaquin River (LSJR) Integrated Interim Feasibility Report/Environmental Impact Statement/Environmental Impact Report (State Clearinghouse No. 2010012027) (2018 LSJR FR/EIS/EIR), which was prepared by the San Joaquin Area Flood Control Agency (SJAFCA), Central Valley Flood Protection Board (CVFPB), and U.S. Army Corps of Engineers (USACE) and certified in 2018. The 2018 LSJR FR/EIS/EIR considered seven alternative plans aimed at reducing flood risk in the City of Stockton and surrounding urbanizing areas.

Alternative 7a was identified as the recommended plan and is now the authorized LSJR Project. The LSJR Project is divided into several components, which include the Smith Canal Gate structure, Tenmile Slough Reach 30 Left Bank (TS30L), and Phases A through F.

In 2023, a Supplemental EIR (2023 TS30L SEIR)4 and a Supplemental Environmental Assessment (2023 TS30L SEA)5 were prepared to evaluate the LSJR Reach TS30L Levee Improvement Project. The TS30L Levee Improvement Project includes staging areas, haul routes, mitigation sites and a final project footprint that were not analyzed in the 2018 LSJR FR/EIS/EIR. In May 2025, a Draft Supplemental Environmental Assessment (EA) II/Subsequent Environmental Impact Report (EIR) (CMP SEA II/SEIR) 4 ESA. 2023. Final Lower San Joaquin River Reach TS 30L Levee Improvement Project Supplemental Environmental Impact Report. March. Website:
https://www.sjafca.org/home/showpublisheddocument/1441/638314181951370000 (accessed July 24, 2025). 5
U.S. Army Corps of Engineers. 2023.

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was prepared for the LSJR Project’s Compensatory Mitigation Plan, 6 which
proposes the establishment of 6 mitigation sites within the project vicinity to address current estimated unavoidable project impacts to biological resources, including the Van Buskirk site.

As described in the CMP SEA II/SEIR, proposed activities at the Van Buskirk site would entail setting back the levee from its current configuration to restore hydrology, grading and planting to establish appropriate elevations for wetland and riparian habitat and removing rock from the remnant levee.

There is also a possibility to transplant elderberry to this site as the French Camp mitigation bank is just on the opposite side of French Camp Slough.

Development of this mitigation site was evaluated for CEQA at a programlevel in the 2023 TS30L SEIR7 and the CMP SEA II/SEIR determined that the analysis provided by the 2023 TS30L Final SEIR remains applicable and adequately addresses potential impacts related to the construction of the Van Buskirk mitigation site. The construction of the setback levee at the Van Buskirk Park site and a full analysis of its effects will be presented in future supplemental CEQA and NEPA documentation prior to construction. The work is anticipated to start in 2033.

As described in the 2023 TS30L SEIR, site preparation and construction of the Van Buskirk mitigation site would entail vegetation clearing; site grading to establish a construction staging/stockpile area and to create elevations that support wetland and riparian habitat; protection in place and enhancement of existing wetlands, riparian features and elderberry shrubs; planting of appropriate vegetation and transplanting of valley elderberry shrubs, where appropriate; and setting back the levee from its current configuration to restore hydrology and removing rock from the remnant levee. Operation would include monitoring and adaptively managing the mitigation site until success criteria are met as described in the Mitigation, Monitoring and Adaptive Management Plan.

As described in the 2023 TS30L SEIR, development of the Van Buskirk site as a biological mitigation site could provide approximately 10 acres of wetland and 27 acres (9,600 linear feet) of riparian habitat, as well as giant garter 6 U.S. Army Corps of Engineers, Central Valley Flood Protection Board, California Department of Water Resources, and San Joaquin Area Flood Control Agency. 2025. Draft Supplemental Environmental Assessment II/Subsequent Environmental Impact Report, San Joaquin River Basin, Lower San Joaquin River, California, Project Compensatory Mitigation Plan. May. Website:
https://www.spk.usace.army.mil/Portals/12/documents/civil_works/lower_sj_river/CMP/LSJR_CMP_Draf tSEA-SEIR_May2025.pdf?ver=JisZnjlwoNjVilKbASHR6w%3d%3d (accessed July 24, 2025). 7 ESA. 2023. Lower San Joaquin River Reach TS 30L Levee Improvement Project Supplemental Environmental Impact Report. March. Website:
https://www.sjafca.org/home/showpublisheddocument/1441/638314181951370000 (accessed July 24, 2025).

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snake, valley elderberry, and delta smelt habitat (to fulfill mitigation needs of future phases of Alternative 7a of the SLJR).

The 2023 TS30L SEIR identified potential cumulative and significant and unavoidable impacts related to Aesthetics (loss of visual quality), Agriculture and Forestry Resources conversion of farmland), Air Quality (emissions of criteria pollutants), Biological Resources (wetlands, vegetation and wildlife habitat, fisheries resources, special-status species, conflict with the San Joaquin Habitat Conversation Plan), Cultural and Paleontological Resources (cultural resources), Recreation (change in visual quality of the recreational experience), Tribal Cultural Resources, and Wildfire. Other direct impacts were determined to be limited, mitigable, or very localized, or would not cause or contribute to additional cumulative impacts.

As described in Section 4.21, Mandatory Findings of Significance, of the Draft IS/MND (pages 4-144 and 4-145), impacts relevant to the proposed Project are localized, confined to the immediate Project area, and would be less than significant. Implementation of the proposed Project would not result in impacts that are cumulatively considerable when evaluated with the impacts of other current projects or the effects of probable future projects, including the SLJR Project. As described in the Draft IS/MND and the environmental documents prepared for the SLJR Project, implementation of subsequent phases of the Van Buskirk Revitalization Project, including potential development of a portion of the park site as wetland mitigation, would be subject to project-specific CEQA and NEPA review once the design details are finalized. No changes to the Draft IS/MND are required.

Response A-7 The comment, which recommends early coordination with CDFW for the potential need for a Lake and Streambed Alteration Agreement (LSAA) prior to starting construction activities, is noted. The comment further recommends that the IS/MND analyzes all potential temporary, permanent, direct, indirect, and/or cumulative impacts to the ponds on the Project site.

As described on page 2-9 of the Draft IS/MND, this Initial Study evaluates the potential environmental effects of implementing Phase 1 of the Van Buskirk Revitalization Project at a Project level. Given that detailed design for subsequent phases is not known at this time, the IS/MND evaluates the conceptual elements of these subsequent phases at a programmatic level and identifies the potential environmental impacts and mitigation measures that could be required for development of these improvements by the City when funding becomes available. The City intends that future Projectspecific actions pursuant to the Van Buskirk Park Revitalization Project that would implement improvements beyond those considered in the programmatic analysis in the IS/MND would be subject to project-level CEQA analysis and compliance.

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As described in Section 4.4, Biological Resources, of the Draft IS/MND, at this time, the City does not propose any modifications to the existing ponds on the Project site, all of which are located outside of the Phase 1 Project area. Should subsequent phases of the proposed Project result in impacts to these features, the City would consult with CDFW and submit an application for an LSAA in compliance with regulatory requirements. No changes to the Draft IS/MND are required.

Response A-8 The comment, which requests that information regarding special-status species and natural communities be submitted to the California Natural Diversity Database (CNDDB), is noted. Consistent with CDFW requirements, all special-status species and natural communities identified during surveys of the Project site have been reported to the California Natural Diversity Database (CNDDB).

Response A-9 The comment, which describes the requirements for the payment of environmental filing fees, is noted. Consistent with State requirements, the City will pay all CDFW environmental documenting filing fees upon filing the Notice of Determination (NOD), if the Project is approved.

Response A-10 This comment concludes the letter and does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

LETTER B
May Soe, Supervising Oil & Gas Engineer, California Department of Conservation, Geologic Energy Management Division
July 22, 2025
Response B-1 This comment describes the role of the California Geologic Energy Management Division (CalGEM) in overseeing oil, gas and geothermal wells that might be affected by property development or construction activities and provides recommendations for development located in proximity to oil, gas, or geothermal wells. The enclosure provided with the comment letter determined that based on CalGEM’s Well Finder database, there are no wells in the Project area. As indicated in the comment letter, no oil, gas, or geothermal wells are located on or in the vicinity of the Project site.

Therefore, implementation of the proposed Project would not impact such wells. No changes to the Draft IS/MND are required.

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LETTER C
Peter G. Minkel, Engineering Geologist, Central Valley Regional Water Quality Control Board (RWQCB)
July 17, 2025
Response C-1 This comment summarizes the regulatory setting related to the Central Valley Regional Water Quality Control Board’s (RWQCB’s) Basin Plan as well as the Antidegradation Policy (State Water Resources Control Board Resolution 68-16) and Antidegradation Implementation Policy with which all wastewater discharges must comply. The comment further requests that the environmental review document evaluate potential impacts to both surface and groundwater quality. The potential impacts to both surface and groundwater quality are disclosed in Section 4.10, Hydrology and Water Quality, of the Draft IS/MND. As described in pages 4-87 through 4-92 of the Draft IS/MND, construction of the proposed Project is anticipated to disturb the entire 192.71-acre Project site, which could result in an increased potential for pollutants of concern to be transported via stormwater runoff into receiving surface waters (i.e., Walker Slough, French Camp Slough, San Joaquin River, Sacramento–San Joaquin River Delta, and Suisun Bay).

Construction may also require limited dewatering, resulting in discharge of extracted groundwater. The proposed Project would be required to comply with the Construction General Permit and City regulations (including preparation of a SWPPP and implementation of Construction BMPs) and the Groundwater Discharge Permit, (including testing and treating stormwater [if required] prior to discharge to surface water). Compliance with these regulatory requirements would ensure that impacts associated with the violation of water quality standards or waste discharge requirements during Project construction would be less than significant.

All stormwater would be directed to bioretention basins and swales, which would treat stormwater before it infiltrates the Project site. The proposed Project would include site design, source control, and volume reduction measures and LID and treatment control best management practices (BMPs), such as catch basins and curb inlets with storm filters to capture trash and debris, in order to reduce pollutants of concern in stormwater prior to it entering the bioretention basins and infiltrating the soil.

Furthermore, when stormwater is infiltrated, soil and plants absorb and filter pollutants and reduce the potential for pollutants of concern to reach groundwater. The proposed Project would be required to comply with the Central Valley RWQCB’s Region-wide MS4 Permit and the City’s Stormwater Quality Control Criteria Plan (SWQCCP), which require preparation of a sitespecific Final Stormwater Quality Control Plan (SWQCP) to address pollutants of concern in stormwater runoff, and preparation and implementation of a Maintenance Plan to ensure that the controls detailed in the Final SWQCP are operated and maintained as intended. Compliance EXHIBIT 1
with these regulatory requirements would ensure that potential impacts associated with the violation of water quality standards or waste discharge requirements during operation of the proposed Project would be less than significant. No changes to the Draft IS/MND are required.

Response C-2 This comment summarizes various permitting requirements related to water quality and those under the purview of the Central Valley RWQCB, including the Construction Storm Water General Permit, Clean Water Act Section 404 Permit, Clean Water Act Section 401 Permit (Water Quality Certification), Waste Discharge Requirement Permit, Dewatering Permit, Limited Threat General National Pollutant Discharge Elimination System (NPDES) Permit, and NPDES Permit. As described in Section 4.10, Hydrology and Water Quality, of the Draft IS/MND and referenced in Response C-1, construction and operation of proposed improvements could increase the potential for the release of potential contaminants into receiving waters.

The Project would comply with existing NPDES permit requirements, including the Construction General Permit, Groundwater Discharge Permit, and Region-wide MS4 Permit, and would implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff.

Compliance with these regulatory requirements would ensure that the proposed Project would not degrade or alter water quality. The Draft IS/MND determined that impacts related to water quality would be less than significant. No changes to the Draft IS/MND are required.

LETTER D
Teague Tran, American Rivers, Associate Director, Central Valley River Restoration and Artie Valencia, Restore The Delta, Flood and Land Restoration Manager July 25, 2025
Response D-1 This comment is introductory and does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

Response D-2 This comment, which expresses general support for the proposed Project and recommends that the City provide infrastructure to promote access and use of the waterways adjacent to the proposed park site, including aquatic recreation (e.g., non-motorized boating) or a levee-top trail along Walker Slough, is noted. The comment offers to assist the City to create more waterway access opportunities. This comment does not address the adequacy of the information or analysis in the Draft IS/MND; rather, it relates to the merits of the proposed Project and recommends features for inclusion in the Project design. Consideration of project merits is important, and the decision makers will consider all comments regarding the project EXHIBIT 1
merits as part of deliberations on the project application, and when choosing to prescribe project-specific conditions of approval. This comment will be considered by City decision-makers prior to making a determination regarding Project approval.

Response D-3 This comment, which expresses support for the levee setback in the northwestern portion of the Project site proposed as part of the LSJR Project described in Response A-6 above, is noted. The comment recommends that the City collaborate closely with the United States Army Corps of Engineers to integrate the proposed levee setback with the Van Buskirk Park Revitalization Project. As described in Response A-6 above, development of the northwestern portion of Van Buskirk Park as a mitigation site for the LSJR Project was evaluated for CEQA at a program-level in the 2023 TS30L SEIR.
8 As the comment correctly states, the details of the proposed levee setback and other restoration efforts are still being developed by the U.S.

Army Corps of Engineers in coordination with the San Joaquin Area Flood Control Agency (SJAFCA), Central Valley Flood Protection Board (CVFPB), and the City of Stockton. The construction of the setback levee at the Van Buskirk Park site and a full analysis of its effects will be presented in future supplemental CEQA and NEPA documentation prior to construction. The work is anticipated to start in 2033. The City will continue to coordinate with these other agencies on the design and construction of this portion of the Van Buskirk Park. This comment does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

Response D-4 The comment states that Section 4.14.b. in the Draft IS/MND is incomplete because it does not address the displacement of unhoused people that may be affected by the proposed Project. Further, the comment provides recommended best practices to minimize the impact of displacement and recommends that the City work with local non-governmental organizations to ensure that there is adequate temporary and permanent housing for displaced people. The Project site, consisting of the former Van Buskirk golf course, is currently fenced and public access is prohibited. Any encampments currently located on the Project site do not constitute permitted housing and are considered illegal under the City of Stockon Municipal Code (Section 8.100.030). Therefore, their displacement would not be considered a potential significant impact for the purposes of CEQA.

However, the City intends to follow established procedures and coordinate 8 ESA. 2023. Lower San Joaquin River Reach TS 30L Levee Improvement Project Supplemental Environmental Impact Report. March. Website:
https://www.sjafca.org/home/showpublisheddocument/1441/638314181951370000 (accessed July 24, 2025).

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with the necessary agencies to relocate unhoused individuals, as needed, prior to project implementation.

As stated in Section 4.14, Population and Housing, on page 4-116 of the Draft IS/MND, the Project site was previously developed as a golf course and development of the proposed Project would not remove existing housing, necessitating the construction of replacement housing elsewhere.

The process and timeline for removal of any unhoused persons present on the Project site prior to Project construction and implementation would be determined by the City. No changes to the Draft IS/MND are required.

Response D-5 The comment states that the proposed Project would induce population growth in the surrounding area by providing park infrastructure/amenities in the South Stockton community, thereby increasing nearby housing costs and leading to green gentrification. Further, the comment recommends that the City engage in a more robust community engagement process related to implementation of the proposed Project.

The issue of green gentrification, as described in the comment, is a social and economic impact, which is not a CEQA impact unless it results in a direct or indirect physical impact on the environment. The comment does not provide a fair argument that a physical environmental impact would result from the potential social and economic impacts related to the provision of park amenities in the Project area. As described in Section 4.14, Population and Housing on page 4-116 of the Draft IS/MND, no new housing, commercial, or industrial space would be developed as part of the proposed Project. Although implementation of the proposed Project would provide additional recreational amenities to serve the existing Stockton community, the proposed Project would renovate a former, public, municipal golf course. It would not result in the conversion of adjacent land uses, provide access to previously inaccessible areas, provide additional major infrastructure or increase the capacity of the existing water system.

Therefore, the Draft IS/MND determined that the proposed Project would have no impacts related to population and housing. No changes to the Draft IS/MND are required.

Response D-6 The comment, which encourages the City to continue engaging with the tribes beyond tribal consultation, is noted. The comment further encourages the City to develop gathering and interpretive opportunities within the Project site. As noted in Section 4.18, Tribal Cultural Resources, of the Draft IS/MND, the City will be required, in accordance with Mitigation Measures TCR-1 and TCR-2, to coordinate with the tribes for monitoring and discovery of resources during Project construction. Suggestions for Project design elements about the history and practices of the area relate to the merits of the proposed Project and not to the adequacy of the information or analysis in the Draft IS/MND. Consideration of project merits is EXHIBIT 1
important, and the decision makers will consider all comments regarding the project merits as part of deliberations on the project application, and when choosing to prescribe Project-specific conditions of approval. This comment will be considered by City decision-makers prior to making a determination regarding Project approval.

Response D-7 This comment concludes the letter and does not address the adequacy of the information or analysis in the Draft IS/MND. Therefore, no further response is required.

LETTER E
Patrisia Avelar
July 12, 2025
Response E-1 This comment raises concerns that proposed park features may result in a noticeable increase in noise that could disturb adjacent residents, but does not provide specific comments related to the adequacy of the analysis provided in the IS/MND. The potential impacts related to both construction and operational noise are disclosed in Section 4.13, Noise, of the Draft IS/MND. As described in Section 4.13, Noise, of the Draft IS/MND, Project construction would result in short-term noise impacts on the surrounding sensitive receptors with the closest off-site receptors subject to short-term construction noise levels of 65 dBA Leq and 68 dBA Leq during Phase 1 and subsequent phases, respectively. While construction-related short-term noise levels have the potential to be higher than existing ambient noise levels in the Project area under existing conditions, the noise impacts would no longer occur once Project construction is completed. Compliance with the allowed construction hours in the City’s Noise Ordinance would ensure that construction noise does not disturb residents during typical sleeping hours or during hours when ambient noise levels are likely to be lower (i.e., at night). In addition, the proposed Project would implement several best practices for reducing construction noise as required by Mitigation Measure NOI-1. With the incorporation of Mitigation Measure NOI-1, all feasible and reasonable measures to reduce construction noise would be implemented, and a less than significant impact would occur.

As described on page 4-111 of the Draft IS/MND, implementation of Phase 1 of the proposed Project could result in the shifting of noise levels in the vicinity of the Project site associated with proposed recreational improvements, including the additional basketball courts, a skate park, a community garden, a splash pad, and others. Implementation of subsequent phases of the proposed Project could result in a similar shift in noise levels in the vicinity of the Project site with implementation of proposed improvements, including the event lawn, event staging area, community building, and pickleball courts. As stated in the Draft IS/MND, typical EXHIBIT 1
activities at these facilities are not expected to generate excessive noise levels and would occur only during daytime hours. Further, Section

16.60.020 of the Stockton Municipal Code exempts activities conducted on parks and playgrounds and school grounds, between 7:00 a.m. and 10:00 p.m. (except for additional hours that may be granted by the City Manager) from noise regulations. The Draft IS/MND determined that pickleball activity noise levels could exceed the City’s exterior daytime (7:00 a.m. to 10:00 p.m.) noise standards of 55 dBA Leq. Because the design of the proposed pickleball courts is not yet known, Mitigation Measure NOI-1 would be required to ensure that the future design of the pickleball courts includes a noise barrier to reduce the noise levels generated during pickleball activities to a less than significant level. This Mitigation Measure was incorrectly numbered, such that there are two mitigation measures identified as “Mitigation Measure NOI-1.” As a result, pages 4-111 and 4-112 of the Draft IS/MND have been revised as follows:

Because the design of the proposed pickleball courts is not yet known, Mitigation Measure NOI-12 would be required to ensure that the future design of the pickleball courts includes a noise barrier to reduce the noise levels generated during pickleball activities to a less than significant level.

Mitigation Measure NOI-12 As part of the final design for the subsequent phase(s) of development,
the City of Stockton (City) shall require
installation of a noise barrier along the
northern and eastern boundaries of the
proposed pickleball courts. The noise
barrier may consist of any solid material,
without gaps or holes, that meets a
minimum density of 4 pounds/square
foot, or is sound rated and has a
minimum Sound Transmission Class
(STC) rating of 25. The noise barrier shall
provide noise reduction sufficient to
ensure that noise levels at the nearest
residential uses would not exceed the
City’s exterior daytime noise standard of
55 A-weighted decibels (dBA) equivalent
continuous sound level (Leq).

With implementation of Mitigation Measure NOI-12, which requires installation of a noise barrier around the pickleball courts, potential long-term noise levels associated with implementation of the proposed Project would be less than significant with mitigation incorporated.

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The revisions identified above represent a minor change to the Draft IS/MND in order to clarify the Draft IS/MND analysis. These revisions do not change the conclusions or analysis of impacts in the Draft IS/MND necessitating recirculation of the Draft IS/MND. No further response is required.

Response E-2 This comment raises concerns regarding potential safety and nuisance issues associated with increased use of the Project site and requests additional information on proposed security measures. As described in Section 2.3.3 (page 2-28) of the Draft IS/MND, the proposed park would be open 1 hour before sunrise to 1 hour after sunset, consistent with Section

12.650.020 of the SMC. Lighted recreation areas would be open from 6:00 a.m. to 10:00 p.m. and park hours would be clearly posted and enforced. A daily patrol of the Project site is currently provided by Allied and such patrols would continue with implementation of the proposed Project.

Additionally, it is the City’s current intention to place a wrought iron fence around the perimeter of the park to deter loitering and use of the park outside of permitted hours. This comment does not address the adequacy of the information or analysis in the Draft IS/MND; rather, it relates to the details of the proposed Project. No further response is required.

Response E-3 This comment requests information on any proposed separation between the park and nearby homes to protect resident privacy, reduce noise and discourage trespassing. As described above in Response D-2, it is the City’s current intention to place a wrought iron fence around the perimeter of the park to deter loitering and use of the park outside of permitted hours. In addition, as shown on Figures 2-3 and 2-4 in the Draft IS/MND and described in Section 2.3.1.2 of the Draft IS/MND (page 2-17), a linear park with a Class I multi-use path would be constructed along the northern park boundary parallel to Houston Avenue. This linear park would include preservation of existing trees and planting of additional landscaping that would provide screening of proposed park activities along the northern park boundary. This comment does not address the adequacy of the information or analysis in the Draft IS/MND; rather, it relates to the details of the proposed Project. No further response is required.

Response E-4 This comment indicates that the commenter appreciates the City’s investment in community spaces, but requests that the City prioritize neighborhood concerns as part of the process and consider the issues raised during the final planning stages. This comment does not address the adequacy of the information or analysis in the Draft IS/MND; rather, it relates to the merits of the proposed Project. Consideration of project merits is important, and the decision makers will consider all comments regarding the project merits as part of deliberations on the project application, and when choosing to prescribe Project-specific conditions of EXHIBIT 1
approval. This comment will be considered by City decision-makers prior to making a determination regarding Project approval.

ATTACHMENTS
A: Comment letters
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ATTACHMENT A

COMMENT LETTERS
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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
July 18, 2025
Liszet Burgueno, Junior Engineer, CIP
City of Stockton
425 North El Dorado Street
Stockton, CA 95202
[email protected]
Dear Liszet Burgueno:

Subject: Van Buskirk Park Revitalization Project, Initial Study/Mitigated Negative Declaration, SCH No. 2025061207, San Joaquin County
The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to adopt a Initial Study/Mitigated Negative Declaration (IS/MND) from the City of Stockton for the Van Buskirk Park Revitalization Project (Project) in San Joaquin County pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 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, we appreciate 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. (Id., § 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 is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s Lake and Streambed 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.

Comment Letter A
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Alteration (LSA) 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 law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the project proponent may seek related take authorization as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Stockton
Objective: The City of Stockton proposes to develop a community park on a 192.71- acre former golf course. The expanded Van Buskirk Park would include additional outdoor basketball courts, a new bike and skate park with associated amenities, a community garden, a multi-purpose lawn area, a splash pad/water play area, an 18-hole disc golf course, a golf academy, indoor facilities, an event lawn with outdoor pavilion, a playground, pickleball courts, and a dog park, as well as walking paths, restoration areas, and parking.

Location: The Project site is located at 734 Houston Avenue in the Conway neighborhood of the City of Stockton in San Joaquin County, California. The 192.71- acre Project site (APN 163-07-036) is located southwest of the center of Stockton. The Project site is bounded by Walker Slough and French Camp Slough to the south, the San Joaquin River to the west, Houston Avenue to the north, and the existing Van Buskirk Community Center and Community Park to the east. Regional vehicular access to the Project site is provided by Interstate-5, with the closest on- and off-ramps to the Project site located along Downing Avenue approximately 1.15 miles southeast of the Project site and by State Route (SR) 4 approximately 0.8 miles to the north via South Fresno Avenue. Direct local access to the Project site is via Houston Avenue.

Timeframe: The proposed Project will be constructed in phases. Phase 1 will occur over an approximately 18-month period and is anticipated to begin in June 2026.

Construction of subsequent phases will depend on available funding. However, for the purposes of the IS/MND, the environmental analysis assumes that all of the recommended facilities will be constructed in a single phase.

REGULATORY REQUIREMENTS
California Endangered Species Act and Native Plant Protection Act A CESA Incidental Take Permit (ITP) must be obtained from CDFW if the Project has the potential to result in “take” of plants or animals listed under CESA or the Native Plant Protection Act (NPPA), either during construction or over the life of the Project.

Under CESA, “take” means “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” (Fish & G. Code, § 86). CDFW’s issuance of an ITP is A-1 cont.

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subject to CEQA and to facilitate permit issuance, any project modifications and mitigation measures must be incorporated into the CEQA document analysis, discussion, and mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA permit.

Candidate species for listing under CESA are afforded the same legal protections as CESA-listed species while under review (Fish and Game Code § 2608). Candidate species which may occur within the Project area include, but are not limited to, western burrowing owl (Athene cunicularia), white sturgeon (Acipenser medirostris), and Crotch’s bumble bee (Bombus crotchii).

CEQA requires a mandatory finding of significance if a project is likely to substantially impact threatened or endangered species. Pub. Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064 & 15065.) In addition, pursuant to CEQA, the Lead Agency cannot approve a project unless all impacts to the environment are avoided or mitigated to less-than-significant levels, or the Lead Agency makes and supports Findings of Overriding Consideration (FOC) for impacts that remain significant despite the implementation of all feasible mitigation. FOC under CEQA, however, does not eliminate the Project proponent’s obligation to comply with the Fish and Game Code.

Fully Protected Species
Fully protected species, such as white-tailed kite (Elanus leucurus), may not be taken or possessed at any time and no licenses or permits may be issued for their take except as follows:
x Take is for necessary scientific research;
x Efforts to recover a fully protected, endangered, or threatened species; x Live capture and relocation of a bird species for the protection of livestock; or x They are a covered species whose conservation and management is provided for in a Natural Community Conservation Plan (Fish & G. Code, §§ 3511, 4700, 5050, & 5515).

Specified types of infrastructure projects may be eligible for an ITP for unavoidable impacts to fully protected species if certain conditions are met (Fish & G. Code § 2081.15). Project proponents should consult with CDFW early in the project planning process.

Raptors and Other Nesting Birds
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CDFW has authority over actions that may result in the disturbance or destruction of active bird nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include section 3503 (regarding unlawful take, possession, or needless destruction of the nests or eggs of any bird), section 3503.5 (regarding the take, possession, or destruction of any birds-of-prey or their nests or eggs), and section 3513 (regarding unlawful take of any migratory nongame bird).

Migratory birds are also protected under the federal Migratory Bird Treaty Act.

Lake or Streambed Alteration Agreement
CDFW requires notification for Lake and Streambed Alteration (LSA), pursuant to Fish and Game Code section 1600 et seq., for Project activities affecting river, lakes or streams and associated riparian habitat. Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank (including associated riparian or wetland resources); or deposit or dispose of material where it may pass into a river, lake, or stream. Work within ephemeral streams, drainage ditches, washes, watercourses with a subsurface flow, and floodplains is generally subject to notification requirements. In addition, infrastructure installed beneath such aquatic features, such as horizontal directional drilling, is also generally subject to notification requirements. Therefore, any impact to the mainstems, tributaries, or floodplains or associated riparian habitat caused by the proposed Project will likely require an LSA notification. CDFW may not execute a final LSA Agreement until it has considered the IS/MND and complied with its responsibilities as a responsible agency under CEQA.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City of Stockton in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

Editorial comments or other suggestions may also be included to improve the document.

COMMENT 1: Burrowing Owl Avoidance and Minimization
Section: Table 4.D: Special-Status Species and Sensitive Natural Communities Occurring within 1 Mile of the Project site Page 4-18 and Mitigation Measure BIO-4 section 3 on pages 4-27 through 4-28.

Issue: Table 4.D in the IS/MND shows burrowing owl as a State Species of Special Concern, however burrowing owl is a candidate species for CESA listing and the

table should be updated to reflect its current status. Additionally, mitigation measure BIO-4 does not adequately mitigate impacts to burrowing owl to less-than-significant.

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Specific impact: Mitigation Measure BIO-4 (Preconstruction and Construction Monitoring) section 3, is not sufficiently protective to burrowing owl. While multiple preconstruction surveys are proposed to locate burrowing owls should they be within the project site, a 250-foot no-work buffer around occupied burrows is not large enough to avoid disturbing burrowing owl and could cause nest abandonment, injury or death. Eviction using passive relocation techniques during the breeding and nonbreeding season is proposed and could also cause injury and death and is considered take of burrowing owl.

Why impact would occur: Mitigation Measure BIO-4 (Preconstruction and Construction Monitoring) section 3 includes surveys for burrowing owl, however the two preconstruction surveys described in the measure are inconsistent with the surveys recommended in the Department of Fish and Game [currently CDFW] Staff Report on Burrowing Owl Mitigation (2012) (CDFW 2012 Staff Report), which requires at least four surveys. Additionally, Mitigation Measure BIO-4 subsections b and c discuss passive relocation and the preparation of an Exclusion Plan (page 4- 28). CDFW does not consider passive relocation to be a take avoidance measure because the long-term demographic consequences of exclusion techniques have not been thoroughly evaluated, and the survival rate of excluded owls is unknown.

Burrowing owl are dependent on burrows at all times of the year for survival or reproduction, therefore eviction from nesting, roosting, overwintering, and satellite burrows or other sheltering features may lead to indirect impacts or “take” which is prohibited under CESA and Fish and Game Code section 3503.5.

Evidence impact would be significant: The Project may impact burrowing owl utilizing burrows or burrow surrogates on or within up to 500 meters (1,640 feet) of the Project site. The Project could result in burrowing owl nest abandonment, loss of young, reduced health and vigor of owlets, injury or mortality of adults, and permanent habitat loss. Burrowing owl is a candidate species for CESA listing because the species’ population viability and survival are adversely affected by risk factors such as precipitous declines from habitat loss, fragmentation, and degradation; evictions from nesting sites without habitat mitigation; human disturbance; and eradication of California ground squirrel (Otospermophilus beecheyi) resulting in a loss of suitable burrows required by burrowing owl for nesting, protection from predators, and shelter (Shuford and Gardali 2008; CDFW 2012 Staff Report). Preliminary analyses of regional patterns for breeding populations of burrowing owl have detected declines both locally in their central and southern coastal breeding areas, and statewide where the species has experienced breeding range retraction (CDFW 2012 Staff Report). Burrowing owl have been

extirpated from 16 percent of their former range and are at risk of being extirpated from another 13 percent of their range in the State (CDFW 2024). Therefore, if burrowing owl are on or within 500 meters (1,640 feet) of the Project site, the Project may result in a substantial reduction in the number of a CESA candidate species, A-4
cont.

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which is considered a Mandatory Finding of Significance pursuant to CEQA Guidelines sections 15065, subdivision (a)(1) and 15380.

Recommended Mitigation Measures: To reduce potential impacts to burrowing owl to less-than-significant and comply with CESA and Fish and Game Code section 3503 et seq., CDFW recommends including the mitigation measures below in the IS/MND:

Burrowing Owl Habitat Assessment and Surveys. A qualified biologist shall conduct a habitat assessment and surveys, if habitat is present for burrowing owl prior to construction. The habitat assessment and surveys shall follow the Department of Fish and Game Staff Report on Burrowing Owl Mitigation (2012) methodology (https://wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds) and the qualified biologist shall prepare a report documenting the survey results, and submit the report to CDFW, and obtain CDFW’s written approval of the report prior to Project construction. The habitat assessment and surveys shall encompass the Project site and a sufficient buffer zone to detect owls nearby that may be impacted, which is up to 500 meters (1,640 feet) around the Project site pursuant to the above methodology. Habitat assessments and surveys shall occur annually for the duration of the Project, as conditions may change annually and suitable refugia for burrowing owl, such as small mammal burrows, can be created within a few hours or days.

Surveys for either non-breeding or breeding burrowing owls shall be spread over four visits during the non-breeding and breeding season. Time lapses between surveys or Project activities shall trigger subsequent surveys including, but not limited to, a final survey within 24 hours prior to ground disturbance. If the habitat assessment does not identify habitat and surveys are not conducted, an additional habitat assessment shall be conducted within 14 days prior to construction. If new refugia are present such as burrows or novel Project infrastructure, surveys shall be conducted as described above. The qualified biologist shall have a minimum of two years of experience implementing the above methodology. The Project shall immediately notify CDFW if burrowing owl is detected and implement a construction avoidance buffer around any detected burrowing owl pursuant to the buffer distances outlined in the Department of Fish and Game Staff Report on Burrowing Owl Mitigation (2012). Any detected owl shall be monitored by the qualified biologist to ensure it is not disturbed during construction activities.

If the Project cannot ensure burrowing owl and their burrows are fully avoided, the Project shall consult with CDFW and obtain a CESA take authorization or otherwise demonstrate compliance with CESA. Take is likely to occur and the Project shall

obtain an ITP if burrowing owl surveys detect burrowing owl occupancy of burrows or burrow surrogates within the Project site, Occupancy of habitat may also be indicated by burrowing owl sign including molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site. If A-4
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burrowing owl, or their burrows or burrow surrogates, are detected within 500 meters (1,640 feet) of the Project site during burrowing owl surveys, but not on the Project site, the Project shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted.

Cap Pipes and Hoses: To prevent burrowing owl from sheltering or nesting in exposed material; all construction pipes, culverts, hoses or similar materials greater than two inches in diameter stored at the Project site shall be capped or covered before the end of each work day and shall be inspected thoroughly for wildlife before the pipe or similar structure is buried, capped, used, or moved.

COMMENT 2: Crotch’s Bumble Bee Avoidance and Minimization Issue: The Project area is within the current known range of Crotch’s bumble bee and suitable nesting and foraging habitat for the species may be present in the Project area. The IS/MND does consider the impact of Project activities on Crotch’s bumble bee in the Project area, however Table 4.D does not identify Crotch’s bumble bee as a candidate species and indicates there is no suitable habitat at the site. Moreover, on page 4-36 the IS/MND discusses Crotch’s bumble bee and recognizes it as a candidate species under CESA (CEQA Guidelines, §15380, subds. (c)(1)). As stated in the IS/MND as candidate species, Crotch’s bumble bee receive the same legal protections afforded to endangered or threatened species.

This section of the IS/MND also states suitable bumble bee foraging and nesting habitat and nectar plants exist within the Project site, which contradicts information provided in Table 4.D. Unauthorized take of Crotch’s bumble bee pursuant to CESA is a violation of California Fish and Game Code section 2080 et seq.

Evidence impact would be significant: Project activities, such as vegetation removal or ground-disturbing activities could result in permanent and/or temporary loss of floral resources for Crotch’s bumble bee and other native pollinator species, loss of bumble bee nesting habitat, crushing, or filling of active bumble bee colonies and hibernating cavities, and reduced reproductive success. Bumble bees are critically important because they pollinate a wide range of plants over the lifecycles of their colonies, which typically live longer than most native solitary bee species.

Recommendation: To reduce impacts to less-than-significant, CDFW recommends including the following mitigation measures in the IS/MND:

If Project impacts to Crotch’s bumble bee cannot be completely avoided, CDFW recommends the Project proponent apply for CESA take authorization under an ITP.

Crotch’s bumble bee and other bumble species are not covered by the San Joaquin County Multi-Species Open Space and Habitat Conservation Plan (SJMSCP) and therefore alternative mitigation will be required for impacts to Crotch’s bumble bee and A-4
cont.

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its habitat. If the Project will result in permanent impacts to suitable Crotch’s bumble bee habitat, CDFW recommends that the IS/MND include compensatory mitigation for the habitat loss. Bumble bee floral resources should be mitigated at a minimum of a 3:1 ratio for permanent impacts in the absence of information regarding the compensatory mitigation site. Floral resources should be replaced as close to their original location as is feasible. If active Crotch’s bumble bee nests have been identified and floral resources cannot be replaced within 200 meters (656 feet) of their original location, floral resources should be planted in the most centrally available location relative to identified nests. This location should be no more than 1.5-kilometer (4,921 feet) from any identified nest. Replaced floral resources may be split into multiple patches to meet distance requirements for multiple nests. The IS/MND should state that mitigation lands will be protected in perpetuity under a conservation easement with an endowment established for long-term management of the lands.

COMMENT 3: Coordination and Consistency with the San Joaquin River Basin, Lower San Joaquin River Compensatory Mitigation Plan
Issue: CEQA requires analysis of reasonably foreseeable future projects and cumulative impacts. The San Joaquin River Basin, Lower San Joaquin River, California, Project (LSJR Project) is a cooperative flood risk management effort intended to reduce flood risk to the City of Stockton associated with seepage, stability, overtopping, and erosion for levees along the San Joaquin River, Calaveras River, Fourteen-mile Slough, Tenmile Slough, French Camp Slough, Mosher Slough, and Duck Creek. The LSJR Project includes 23 miles of levee improvements and two closure structures. The levee improvements include cutoff walls, deep soil mixing (seismic remediation), a new levee, levee geometry improvements, and erosion protection. The mitigation strategy for the Project initially relied primarily on the purchase of mitigation bank credits to compensate for habitat impacts. However, there are no suitable mitigation banks with both a service area that covers the Project site and appropriate credits in sufficient quantities to meet the Project’s compensatory mitigation requirements. Therefore, an updated compensatory mitigation plan proposes the establishment of six mitigation sites within the Project vicinity to address current estimated unavoidable Project impacts to biological resources.

Evidence impact would be significant: A proposed mitigation site for the LSJR Project occurs at Van Buskirk Park. The proposed action for Van Buskirk Park will convert the formerly urban land that was a public golf course into riparian and wetland habitat and restore river hydrology through setback of the existing levee.

Recommendation: CDFW recommends the IS/MND include a thorough analysis of

all short-term and long-term impacts, including cumulative impacts, of the LSJR Project, a portion of which is proposed to be located within the Project area.

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COMMENT 4: Potential Waters of the US/ Lake and Streambed Alteration Program Issue: The IS/MND does not discuss the potential need to acquire an LSA Agreement from CDFW. Five ponds associated with the former golf course are present on the Project site, of which some or all may be historical oxbows associated with French Camp Slough. The existing ponds will be preserved and maintained as part of Project implementation. All ponds at the Project site are isolated from the floodplain of French Camp Slough by a levee and are considered managed water features that are jurisdictional wetlands and waters of the United States/waters of the State. Additionally, on page 4-24 in section BIO-3 the IS/MND states that the Project will conduct all in-water construction activities between May 1 and November 30. Activities described in the IS/MND, including potential maintenance activities of the ponds, may require an LSA notification.

Evidence impact would be significant: Riparian habitats, including ponds, are important to watershed integrity because they perform many ecological functions such as enhancing water quality/quantity, biodiversity, habitat connectivity, and flood capacity. Impacts to riparian habitats have potential to cause a wide range of adverse effects to fish and wildlife resources.

Ponds often support greater biodiversity than other freshwater habitats (e.g., lakes and rivers), sustain many rare and endangered aquatic taxa, and act as important “refuges” in heavily modified landscapes. Alongside aquatic species, many terrestrial species—including insect pollinators, birds, bats, and other mammals—rely on ponds for water, food, and habitat. (Hill, 2021).

Recommendation: CDFW recommends early coordination with the CDFW for the potential need of an LSA Agreement prior to starting construction activities. The IS/MND should analyze all potential temporary, permanent, direct, indirect and/or cumulative impacts to the above-mentioned features and associated biological resources.

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 field survey form can be filled out and submitted

online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

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ENVIRONMENTAL DOCUMENT 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 IS/MND to assist the City of Stockton in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Ben Huffer, Senior Environmental Scientist (Specialist), at [email protected] or (707) 815-9950; or Brenda Blinn, Senior Environmental Scientist (Supervisory), at [email protected].

Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
ec: Office of Land Use and Climate Innovation (SCH No. 2025061207)

REFERENCES
CDFW. 2024. Petition Evaluation for Western Burrowing Owl (Athene cunicularia hypugaea). Report to the Fish and Game Commission. California Department of Fish and Wildlife, P.O. Box 944209, Sacramento, CA.

CDFW. 2012. Department of Fish and Game Staff Report on Burrowing Owl Mitigation.

State of California Natural Resources Agency, Sacramento, CA.

Hill, M. J., H. M. Greaves, C. D. Sayer, C. Hassall, M. Milin, V. S. Milner, L. Marazzi, R.

Hall, L. R. Harper, I. Thornhill, R. E. Walton, J. Biggs, N. Ewald, A. Law, N.

Willby, J. C. White, R. A. Briers, K. Mathers, M. J. Jeffries, and P. J. Wood. 2021.

Pond Ecology and Conservation: Research Priorities and Knowledge Gaps.

Ecosphere 12 (12): e03853. https://doi.org/10.1002/ecs2.3853.

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Shuford, W. D., and Gardali, T., editors. 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.

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July 22, 2025

VIA EMAIL
City of Stockton Public Works Department
Liszet Burgueno
22 E. Weber Avenue, Room 301
Stockton, CA 95202
[email protected]
Assessor Parcel Number(s): 163-07-036
Property Owner: City of Stockton
Project Location Address: 1740 Houston Avenue, Stockton CA 95206 PROJECT TITLE: Van Buskirk Park Revitalization Project
Public Resources Code (PRC) section 3208.1 establishes re-abandonment responsibility when previously plugged and abandoned oil, gas or geothermal wells will be impacted by planned property development or construction activities. Local permitting agencies, property owners, and/or developers should be aware of, and fully understand, that significant and potentially dangerous issues may be associated with development near previously abandoned oil, gas, and geothermal wells.

The California Geologic Energy Management Division (CalGEM) has received the abovereferenced project dated June 25, 2025. To assist local permitting agencies, property owners, and developers in making safe and practical land use decisions regarding potential development near oil, gas, or geothermal wells, CalGEM provides a table in the attached enclosure of the wells within the parcel boundary or in its vicinity, based on CalGEM’s Well Finder database (https://maps.conservation.ca.gov/doggr/wellfinder/).

CalGEM categorically advises against building over, or in any way impeding access to, oil, gas, or geothermal wells. Impeding access to a well could result in the need to remove any structure or obstacle that prevents or impedes access including, but not limited to, buildings, housing, fencing, landscaping, trees, pools, patios, sidewalks, roadways, and decking at the landowner’s expense if there is a need to access a well. Maintaining sufficient access is considered the ability for a well servicing unit and associated necessary equipment (consisting of well servicing rig, pumping equipment, pipe trailer) to reach a well from a public street or access way, solely over the parcel on which the well is located. A well servicing unit, and any necessary equipment, should be able to pass unimpeded along and over the route, and should be able to access the well without disturbing the integrity of surrounding infrastructure. Impermeable barriers such as asphalt, concrete, and plastic may trap hazardous gases and liquids underneath and could create a safety hazard if built over a well that later develops a leak.

CalGEM recommends that any well for which access is impeded or built over, against CalGEM’s

Comment Letter B
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statutory objectives of isolating all hydrocarbon-bearing strata; protecting underground and surface waters; prevention of subsequent damage to life, health, property, and other resources; and prevention of loss of oil, gas, or reservoir energy. CalGEM recommends that wells that do not meet these standards are abandoned or re-abandoned prior to construction. The well information can be accessed through CalGEM’s Well Finder database mentioned above. PRC section 3208, subdivision (a), provides the primary statutory authority for CalGEM to oversee adequate abandonment of wells. Additionally, CalGEM has developed the regulatory guidance for operators to be followed during well abandonment, which are listed within California Code of Regulation, title 14 (CCR) section 1723 and associated sub-sections (for onshore wells), and section 1745 and associated sub-sections (for offshore wells).

There is no guarantee that a well abandoned in compliance with current Division requirements as prescribed by law will not start leaking in the future. Due to the inability to predict all subsurface conditions or changes, it always remains a possibility that any well may start to leak oil, gas, and/or water after abandonment, no matter how thoroughly the well was plugged and abandoned. CalGEM acknowledges wells plugged and abandoned to the most current Division requirements as prescribed by law have a lower probability of leaking in the future, however there is no guarantee that such abandoned wells will not leak.

CalGEM advises that all wells identified on the development parcel prior to, or during, development activities be tested for liquid and gas leakage. Surveyed locations in Latitude and Longitude, NAD 83 decimal format, and leak testing results should be provided to CalGEM.

CalGEM expects any wells found leaking to be reported to CalGEM immediately.

PRC section 3208.1 gives CalGEM the authority to order or permit the re-abandonment of any well where it has reason to question the integrity of the previous abandonment. Responsibility for re-abandonment costs may be affected by the choices made by the local permitting agency, property owner, and/or developer in considering the general advice set forth in this letter. The PRC continues to define the person or entity responsible for re-abandonment as:

1. The property owner - If the well was plugged and abandoned in conformance with Division requirements at the time of abandonment, and in its current condition does not pose an immediate danger to life, health, and property, but requires additional work solely because the owner of the property on which the well is located proposes construction on the property that would prevent or impede access to the well for purposes of remedying a currently perceived future problem, then the owner of the property on which the well is located shall obtain all rights necessary to re-abandon the well and be responsible for the re-abandonment.

2. The person or entity causing construction over or near the well - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and the property owner, developer, or local agency permitting the construction failed either to obtain an opinion from the supervisor or district deputy as to whether the previously abandoned well is required to be re-abandoned, or to follow the advice of the supervisor or district deputy not to undertake construction that impedes access, then the person or entity causing the construction over or near the well shall obtain all rights necessary to re-abandon the well and be responsible for the re-abandonment.

3. The party or parties responsible for disturbing the integrity of the abandonment - If the well was plugged and abandoned in conformance with Division requirements at the time of plugging and abandonment, and after that time someone other than the operator or an affiliate of the operator disturbed the integrity of the abandonment in the course of

advice, should be evaluated by a qualified petroleum professional for compliance with the B-1
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developing the property, then the party or parties responsible for disturbing the integrity of the abandonment shall be responsible for the re-abandonment.

Should any wells require abandonment or re-abandonment, the responsible party must submit a Notice of Intention (NOI) to CalGEM through WellSTAR. The NOI form can be accessed in the ‘Plugging and Abandonment’ section of the following link:
https://www.conservation.ca.gov/calgem/for_operators.

No well work may be performed on any oil, gas, or geothermal well without written approval from CalGEM. Well work requiring approval includes, but is not limited to, mitigating leaking gas or other fluids from abandoned wells, modifications to well casings, and/or any other reabandonment work. CalGEM also regulates the top of a plugged and abandoned well's minimum and maximum depth below final grade. CCR section1723.5 states well casings shall be cut off at least 5 feet but no more than 10 feet below the surface of the ground. If any well needs to be lowered or raised (i.e. casing cut down or casing riser added) to meet this regulation, a permit from CalGEM is required before work can start.

CalGEM makes the following additional recommendations to the local permitting agency, property owner, and developer:

1. To ensure that present and future property owners are aware of (a) the existence of all wells located on the property, and (b) potentially significant issues associated with any improvements near oil or gas wells, CalGEM recommends that information regarding the below identified well(s), and any other pertinent information obtained after the issuance of this letter, be communicated to the appropriate county recorder for inclusion in the title information of the subject real property.

2. CalGEM recommends that any soil containing hydrocarbons be disposed of in accordance with local, state, and federal laws. Please notify the appropriate authorities if soil containing significant amounts of hydrocarbons is discovered during development.

As indicated in PRC section 3106, CalGEM has statutory authority over the drilling, operation, maintenance, and abandonment of oil, gas, and geothermal wells, and attendant facilities, to prevent, as far as possible, damage to life, health, property, and natural resources; damage to underground oil, gas, and geothermal deposits; and damage to underground and surface waters suitable for irrigation or domestic purposes. In addition to CalGEM's authority to order work on wells pursuant to PRC sections 3208.1 and 3224, it has authority to issue civil and criminal penalties under PRC sections 3236, 3236.5, and 3359 for violations within CalGEM's jurisdictional authority. CalGEM does not regulate grading, excavations, or other land use issues. Should you have any questions, or if any wells are encountered that were not part of this letter, contact CalGEM at 916-322-1110 or via email at [email protected].

Sincerely,
May Soe
Supervising Oil & Gas Engineer
cc: The State Clearinghouse, [email protected] Enclosure

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Enclosure: The wells listed below are reported to be located within and nearby the parcel boundary and may have future access impeded.

There are no wells within the project area.

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EXHIBIT 1
Central Valley Regional Water Quality Control Board
17 July 2025
Liszet Burgueno
City of Stockton Public Works Department
22 East Weber Avenue, Room 301
Stockton, CA 95202
[email protected]

COMMENTS TO REQUEST FOR REVIEW FOR THE MITIGATED NEGATIVE

DECLARATION, VAN BUSKIRK PARK REVITALIZATION PROJECT,
SCH#2025061207, SAN JOAQUIN COUNTY
Pursuant to the State Clearinghouse’s 25 June 2025 request, the Central Valley Regional Water Quality Control Board (Central Valley Water Board) has reviewed the Request for Review for the Mitigated Negative Declaration for the Van Buskirk Park Revitalization Project, located in San Joaquin County.

Our agency is delegated with the responsibility of protecting the quality of surface and groundwaters of the state; therefore our comments will address concerns surrounding those issues.

I. Regulatory Setting
Basin Plan
The Central Valley Water Board is required to formulate and adopt Basin Plans for all areas within the Central Valley region under Section 13240 of the Porter-Cologne Water Quality Control Act. Each Basin Plan must contain water quality objectives to ensure the reasonable protection of beneficial uses, as well as a program of implementation for achieving water quality objectives with the Basin Plans. Federal regulations require each state to adopt water quality standards to protect the public health or welfare, enhance the quality of water and serve the purposes of the Clean Water Act. In California, the beneficial uses, water quality objectives, and the Antidegradation Policy are the State’s water quality standards. Water quality standards are also contained in the National Toxics Rule, 40 CFR Section 131.36, and the California Toxics Rule, 40 CFR Section 131.38.

The Basin Plan is subject to modification as necessary, considering applicable laws, policies, technologies, water quality conditions and priorities. The original Basin Plans were adopted in 1975, and have been updated and revised periodically as required, using Basin Plan amendments. Once the Central Valley Water Board has adopted a Basin Plan amendment in noticed public hearings, it must be approved by Comment Letter C
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the State Water Resources Control Board (State Water Board), Office of Administrative Law (OAL) and in some cases, the United States Environmental Protection Agency (USEPA). Basin Plan amendments only become effective after they have been approved by the OAL and in some cases, the USEPA. Every three (3) years, a review of the Basin Plan is completed that assesses the appropriateness of existing standards and evaluates and prioritizes Basin Planning issues. For more information on the Water Quality Control Plan for the Sacramento and San Joaquin River Basins, please visit our website:
http://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/ Antidegradation Considerations
All wastewater discharges must comply with the Antidegradation Policy (State Water Board Resolution 68-16) and the Antidegradation Implementation Policy contained in the Basin Plan. The Antidegradation Implementation Policy is available on page 74 at:
https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/sacsjr_2018

05.pdf
In part it states:

Any discharge of waste to high quality waters must apply best practicable treatment or control not only to prevent a condition of pollution or nuisance from occurring, but also to maintain the highest water quality possible consistent with the maximum benefit to the people of the State.

This information must be presented as an analysis of the impacts and potential impacts of the discharge on water quality, as measured by background concentrations and applicable water quality objectives.

The antidegradation analysis is a mandatory element in the National Pollutant Discharge Elimination System and land discharge Waste Discharge Requirements (WDRs) permitting processes. The environmental review document should evaluate potential impacts to both surface and groundwater quality.

II. Permitting Requirements
Construction Storm Water General Permit
Dischargers whose project disturb one or more acres of soil or where projects disturb less than one acre but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), Construction General Permit Order No. 2009-0009-DWQ. Construction activity subject to this permit includes clearing, grading, grubbing, disturbances to the ground, such as stockpiling, or excavation, but does not include regular maintenance activities performed to restore the original line, grade, or capacity of the facility. The Construction General Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP). For more information on the Construction General Permit, visit the State Water Resources Control Board website at:

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http://www.waterboards.ca.gov/water_issues/programs/stormwater/constpermits.sht ml
Clean Water Act Section 404 Permit
If the project will involve the discharge of dredged or fill material in navigable waters or wetlands, a permit pursuant to Section 404 of the Clean Water Act may be needed from the United States Army Corps of Engineers (USACE). If a Section 404 permit is required by the USACE, the Central Valley Water Board will review the permit application to ensure that discharge will not violate water quality standards. If the project requires surface water drainage realignment, the applicant is advised to contact the Department of Fish and Game for information on Streambed Alteration Permit requirements. If you have any questions regarding the Clean Water Act Section 404 permits, please contact the Regulatory Division of the Sacramento District of USACE at (916) 557-5250.

Clean Water Act Section 401 Permit – Water Quality Certification If an USACE permit (e.g., Non-Reporting Nationwide Permit, Nationwide Permit, Letter of Permission, Individual Permit, Regional General Permit, Programmatic General Permit), or any other federal permit (e.g., Section 10 of the Rivers and Harbors Act or Section 9 from the United States Coast Guard), is required for this project due to the disturbance of waters of the United States (such as streams and wetlands), then a Water Quality Certification must be obtained from the Central Valley Water Board prior to initiation of project activities. There are no waivers for 401 Water Quality Certifications. For more information on the Water Quality Certification, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/water_issues/water_quality_certificatio n/
Waste Discharge Requirements – Discharges to Waters of the State If USACE determines that only non-jurisdictional waters of the State (i.e., “nonfederal” waters of the State) are present in the proposed project area, the proposed project may require a Waste Discharge Requirement (WDR) permit to be issued by Central Valley Water Board. Under the California Porter-Cologne Water Quality Control Act, discharges to all waters of the State, including all wetlands and other waters of the State including, but not limited to, isolated wetlands, are subject to State regulation. For more information on the Waste Discharges to Surface Water NPDES Program and WDR processes, visit the Central Valley Water Board website at:https://www.waterboards.ca.gov/centralvalley/water_issues/waste_to_surface_wat er/
Projects involving excavation or fill activities impacting less than 0.2 acre or 400 linear feet of non-jurisdictional waters of the state and projects involving dredging activities impacting less than 50 cubic yards of non-jurisdictional waters of the state may be eligible for coverage under the State Water Resources Control Board Water Quality Order No. 2004-0004-DWQ (General Order 2004-0004). For more information on the General Order 2004-0004, visit the State Water Resources Control Board website at:

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https://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/200 4/wqo/wqo2004-0004.pdf
Dewatering Permit
If the proposed project includes construction or groundwater dewatering to be discharged to land, the proponent may apply for coverage under State Water Board General Water Quality Order (Low Threat General Order) 2003-0003 or the Central Valley Water Board’s Waiver of Report of Waste Discharge and Waste Discharge Requirements (Low Threat Waiver) R5-2018-0085. Small temporary construction dewatering projects are projects that discharge groundwater to land from excavation activities or dewatering of underground utility vaults. Dischargers seeking coverage under the General Order or Waiver must file a Notice of Intent with the Central Valley Water Board prior to beginning discharge.

For more information regarding the Low Threat General Order and the application process, visit the Central Valley Water Board website at:
http://www.waterboards.ca.gov/board_decisions/adopted_orders/water_quality/2003/ wqo/wqo2003-0003.pdf
For more information regarding the Low Threat Waiver and the application process, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/waiv ers/r5-2018-0085.pdf
Limited Threat General NPDES Permit
If the proposed project includes construction dewatering and it is necessary to discharge the groundwater to waters of the United States, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. Dewatering discharges are typically considered a low or limited threat to water quality and may be covered under the General Order for Limited Threat Discharges to Surface Water (Limited Threat General Order). A complete Notice of Intent must be submitted to the Central Valley Water Board to obtain coverage under the Limited Threat General Order. For more information regarding the Limited Threat General Order and the application process, visit the Central Valley Water Board website at:
https://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/gene ral_orders/r5-2016-0076-01.pdf
NPDES Permit
If the proposed project discharges waste that could affect the quality of surface waters of the State, other than into a community sewer system, the proposed project will require coverage under a National Pollutant Discharge Elimination System (NPDES) permit. A complete Report of Waste Discharge must be submitted with the Central Valley Water Board to obtain a NPDES Permit. For more information regarding the NPDES Permit and the application process, visit the Central Valley Water Board website at: https://www.waterboards.ca.gov/centralvalley/help/permit/ C-2
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If you have questions regarding these comments, please contact me at (916) 464-4684 or [email protected].

Peter G. Minkel
Engineering Geologist
cc: State Clearinghouse unit, Governor’s Office of Planning and Research, Sacramento
Shanna Guiler
LSA
[email protected]
EXHIBIT 1
July 25, 2025
Liszet Burgueño, Junior Engineer
CIP, Public Works Department, City of Stockton
22 E. Weber Avenue, Room 301, Stockton, CA 95202
Dear Ms. Burgueño and City of Stockton,
On behalf of American Rivers (AR), Restore the Delta (RTD), we appreciate the opportunity to review the Initial Study/Mitigated Negative Declaration for the Van Buskirk Park Revitalization Project (IS/MND) and submit comments. After reviewing the IS/MND, we have comments on the following topics: park amenities & waterway access, setback levee, unhoused community, green gentrification, community engagement & project communication, and tribal involvement.

Park Amenities and Waterway Access
We are incredibly supportive of the Van Buskirk Park Revitalization project because it creates an accessible greenspace that will allow for a plethora of opportunities in one of the most significant remaining public land parcels in South Stockton. We concur that there will be a dramatic improvement in aesthetics and recreational opportunities (Section 4.1), and climate resilience for thousands of Stockton residents upon completion. In addition to the benefits stated above, research and data have shown that communities with higher quantities of nature and trees, tend to have greater community well-being, which includes happiness, general health, lower stress, less aggression, and increased attention (Jaffe, 2015). Therefore, if done with proper community engagement and planning, the Van Buskirk Park Revitalization project will be a transformative project that will greatly benefit the community in a variety of ways. As exemplified by the support of the recent McKinley Park renovation at the 6/24 City Council Meeting, Stocktonians want improved parks and recreation infrastructure, and we want to help the City of Stockton make the Van Buskirk Park’s revitalization great for the community.

Waterways such as Walker Slough, French Camp Slough, and the San Joaquin River all border Van Buskirk Park; however, we noticed that there is no infrastructure that promotes the access and use of these public resources that are so nearby. We want to emphasize that these waterways provide an incredible opportunity for aquatic recreation, which could come in the form of nature viewing, man-powered boats, and fishing. The local community, along with other Stocktonians, are demonstrably interested in aquatic recreation. For example, fishing and fishing ponds are one of the top requested amenities of the Van Buskirk Park Master Plan Online Survey #2. Additionally, a survey conducted by RTD in collaboration with AR (survey results can be provided upon request) with the community surrounding Van Buskirk Park (2023) showed that water recreation was a top priority (35/35 Comment Letter D
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respondents), with the majority of the respondents likely to use a designated area for boating and fishing (29/35 respondents).

In addition to recreation, access to waterscapes have been shown to further promote people’s psychological resilience and promote psychological and mental health (Zhang et al. 2021). Access can also be utilized by local organizations to help educate the community on waterways. Local schools can use the waterway access as an educational resource to students of the South Stockton community on riparian habitat and how water affects their local ecosystems. The improved access can also be used to help the community learn about rivers and how they affect their lives. For example, if Walker Slough was accessible through a levee-top trail, community-based organizations, such as RTD, would have the opportunity to lead tours on the levee to educate local residents on the importance of the levee and what it means for flooding in their community. Spreading awareness and educating the community on levees and flood protection would better allow the community to engage with the City on projects, such as other phases of the Lower San Joaquin Project River Project.

We would like to continue helping the City of Stockton create more waterway access opportunities in any way we can. For example, we believe that there is a great opportunity to include Van Buskirk Park in a network of paddle sports trails that connects other sites, such as Louis Park and the potential Delta Aquatic Center at the confluence of the Calaveras River and San Joaquin River. Whether it involves brainstorming, fundraising, project management, planning, performing outreach, or any other tasks, we have the expertise and drive to support the City of Stockton to improve waterway accessibility at Van Buskirk Park.

Setback Levee
Stockton is an incredibly resilient city that has been addressing flooding since its founding. However, as of 2024, it is one of the highest flood-vulnerable cities in the United States. With 93% of residential properties at risk of flood damage within the next 30 years (Admin, 2024), it is incredibly important to build infrastructure that protects the community. That is one of the reasons why we are supportive of setting back the levee on the northwestern portion Van Buskirk Park from its current configuration to reconnect the San Joaquin River and French Camp Slough to the historic adjacent floodplain, restore hydrology, grade and plant native vegetation to establish appropriate elevations for wetland and riparian habitat, and remove rock from the remnant levee. A levee setback has multiple ecological and flood risk reduction benefits. According to the National Levee Safety Guidelines (NLSG), ecological benefits include decreased scour and erosion, improved aquatic habitat, increased wetlands, increased overbank flows and inundation areas, improved upland habitat and wildlife connection, and the development of new drainage pathways (Table 1). The new levee will reduce the flood risk to people and property; but a levee set further back from the water will decrease water velocity and erosion, placing less strain on the levee and reducing the risk of failure. By allowing the San Joaquin River to spread out across a larger floodplain, the City of Stockton will reduce flood risk to the South Stockton community, while simultaneously creating the opportunity for USACE to meet mitigation requirements.

We would like to acknowledge that the details of the environmental mitigation for the northwestern portion of the park, as well as other subsequent phases, still need to be determined. We look forward to reviewing the subsequent, project-level CEQA analyses for those phases. We also acknowledge that USACE is currently creating a conceptual design of the potential setback levee for the portion. However, none of the plans are set yet. Therefore, we would like to emphasize the importance of the City of Stockton promoting a setback levee at the northwestern portion of Van Buskirk Park and collaborating with USACE to effectively integrate the two congruent projects.

Having had communications with USACE and city employees on the Van Buskirk Park project and reviewed publicly available information, it is not apparent that the City and USACE are collaborating closely together to integrate the D-2
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potential setback levee into the other various phases of the revitalization project. Therefore, we urge the City of Stockton to work more closely with USACE to integrate both projects before USACE breaks ground in 2032. We believe that the future community meeting surrounding the proposed Van Buskirk setback levee, organized by USACE and the City of Stockton, and subsequent integration of community input into the mitigation planning at Van Buskirk Park is great for collaboration and vital to the overall success of the project.

Table 1. Levee removal and associated ecological effects table from the National Levee Safety Guidelines. Though the table title shows only ”levee removal” these benefits also apply to setback levees according to the document.

Unhoused Community
Section 4.14 Population and Housing Question B: Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? We believe that the City of Stockton’s assessment and response to Section 4.14 Question B is incomplete. Although we concur that no permanent housing is located in Van Buskirk Park, that does not mean that there are no people “existing” in the project area. People experiencing homelessness often use greenspaces, such as Van Buskirk Park and the closed golf course site as a place of refuge and rest. Often-times establishing encampments and in place of increasingly inaccessible housing. These people, who are members of the Stockton community, are incredibly vulnerable to displacement.

San Joaquin County Continuum of Care found that the number of unhoused individuals in San Joaquin County increased by 104% from 2022 to 2024 (Franco, 2024). 73% of these individuals were unsheltered at the time of their study. If this trend continues the number of people affected by the construction of Van Buskirk would likely be more substantial than it is today, putting strain on temporary shelter and other related services in the county.

Although we acknowledge that the City of Stockton has been creating new temporary housing through projects such as the Carol and Henry Zeiter Navigation Center with St. Mary’s Community Services. These projects take time, money, and might not be enough to accommodate the influx of individuals that need shelter.

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Therefore, the City of Stockton needs to have a plan to appropriately work with the unhoused community to help them transition out of the project site and prepare the city’s infrastructure in a way that safely relocates people with the resources that they need. This plan should include best practices that need to be implemented. Below are a few examples of applicable best practices that are provided in the 19 Strategies for Communities to Address Encampments Humanely and Effectively document written by the U.S. Interagency Council on Homelessness (2024):
● Create timelines for planning, outreach, engagement, notice, closure, and site restoration ● Ask encampment residents what housing and service options they need and want ● Collaborate with the agencies responsible for providing and connecting people to services and housing and connect resources to Coordinated Entry
● Secure and coordinate transportation from encampments to housing and services for every resident ● Provide encampment residents with verbal and written notices in plain and multiple languages of a closure at least 30 days in advance.
● Offer low-barrier shelter, short-term or permanent housing, or residential treatment to every person living in an encampment, and ensure availability on day of closure. ● Communicate clearly with residents early and often about the process, housing and shelter options, and storage, among other things. Provide residents at least two days to sort and pack personal items prior to closure—unless there is an environmental health or urgent safety issue It is imperative to have a plan and timeline with the unhoused community to minimize the impact of displacement.

AR strongly urges the City of Stockton to work with local NGOs such as St. Mary’s Community Service and Stockton209Cares to get a better understanding of the unhoused community at Van Buskirk, develop a plan/timeline for potential encampment closure, and ensure that there is adequate temporary and permanent housing for the displaced people.

Green Gentrification, Community Engagement, Project Communication Section 4.14 Population and Housing Question A: Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
We disagree with the City of Stockton's response to Section 4.14 Question A. Although no new housing, commercial, or industrial space will be directly constructed as the result of the project, this project is centered around building park infrastructure that expands upon amenities to the South Stockton community. Furthermore, the project would provide public access to currently-inaccessible areas. For example, this project will likely remove the gates that are currently preventing people from going into the former golf course area.

This increase of infrastructure and access to the park will very likely affect the nearby community “indirectly”. Since people want to have access to the great park infrastructure that will be built as part of this project, they are more incentivized to move to nearby communities, such as Conway Homes, increasing the demand of the area. With increased demands for housing in the surrounding communities and limited space to build housing, nearby housing costs will likely increase, leading to a phenomenon called green gentrification.

Green gentrification, the displacement of typically working-class communities of color as a result of new greenspaces that leads to increased housing costs (Anguelovski et al., 2022), would nullify the positive socioeconomic impact of the Van Buskirk Revitalization project. In many instances, urban green development projects, such as the Van Buskirk Park project have led to increased economic distress in the surrounding area.

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Buskirk Park and Calaveras River Parcel projects. It has been recorded in Atlanta, GA, with the Atlanta Beltline Project, in Brooklyn, NY with the Gowanus Canal and Prospect Park revitalizations, and many more cases around the world.

Below are some articles, that have documented this phenomenon:
● Literature Review on Green Gentrification (Jelks et al., 2021) ● Atlanta, GA: The Atlanta Beltline Project (Immergluck & Balan, T. 2017) ● Brooklyn, NY: Gowanus Canal & Prospect Park (Gould & Lewis, 2012) ● New York City: Census + Housing Analysis (Du & Zhang, 2020) ● Barcelona, Spain: Spatial Analysis of Green Gentrification (Anguelovski et al., 2017) The threat of green gentrification does not mean that the Van Buskirk Park Revitalization project should not occur; however, it means it is vital that the project team take the necessary steps to address the potential damage to the community. Figure 1 is a graphic from the Equitable Development Toolkit, written by River Network and NPS (Fullmer & Mazurek, 2024), that shows how green projects can lead to gentrification and potential ways to reduce the risk to communities throughout the process. It is important to note that all solutions to reduce the risk of green gentrification involve authentic community engagement. Endeavors, such as the 11th Street Bridge Project and other projects within the Highline Network, have utilized similar methods to address gentrification (Jacobs, 2017).

Figure 1. Cycle of Development, Gentrification, and Displacement and Ways to Interrupt the Cycle from the Equity Development Toolkit written by written by River Network and the National Park Service (Fullmer & Mazurek, 2024) D-5
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The City of Stockton has already performed projects that work towards addressing green gentrification, such as the Transformative Climate Communities project (TCC). In the TCC, the City of Stockton worked with local partners, community residents, and contractors to develop a variety of plans, including a Community Engagement Plan, to address the potential negative effects of the TCC project. The Community Engagement Plan included resident-centered programs, educational campaigns, quarterly Community Coalition meetings, Stockton Rising summits and bi-annual celebratory Block Parties. The team surrounding the TCC project will also develop a Collaborative Stakeholder Structure to provide stewardship and feedback throughout their grant term.

Currently, the Van Buskirk Park Revitalization project has no publicly-accessible plan to work alongside the community or address green gentrification. Although we greatly appreciate previous outreach efforts and the integration of the community’s feedback for the park’s design, this project currently has minimal engagement with local partners. In fact, there have been no meetings or outreach on the project since September of 2022. We understand that the TCC project had funds allowed for more robust community engagement. However, we strongly urge the City of Stockton to adopt a similar, active approach to community engagement for the Van Buskirk Revitalization Project. For successful community engagement, there should be a publicly available community engagement plan. We believe this will not only help the overall success of the project, but also secure the support infrastructure and long term funding of the revitalization beyond Phase 1. This plan can include the following:
● A timeline for the project and its phases
● A strategy to outreach to various communities
● A strategy to maintain regular communication between communities previously outreached (consistent meetings)
● A strategy to work alongside local community-based organizations ● The community engagement plan in various languages such as Spanish and Tagalog Tribal Involvement
Although we do not represent any tribal entities within Stockon, we encourage the city to continue engaging with the Northern Valley Yokuts Tribe and Nototome Cultural Preservation beyond tribal consultation for cultural resources. It is crucial to continue to coordinate and consult with those with ancestral ties to the area. As the geoarchaeological analysis revealed probable past use for resource extraction (Tule, sedge,etc.), we would also like to encourage the development of gathering opportunities within the project area and encourage the history and practices of the area be shared through interpretive means.

Conclusion
Overall, we are supportive of the Van Buskirk Revitalization Project. If done with authentic community engagement and proper communication, this project and its various phases will have the potential to provide a net benefit for the people of South Stockton that goes beyond recreation. However, it is important to work alongside the community to have an equitable result. We believe that increased access to the waterway, closer partnership with USACE, a plan/timeline of working with the unhoused community, and a community engagement plan will further improve the project and reduce the risk of detrimental effects that might result from this project.

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Sincerely,
Teague Tran, American Rivers,
Associate Director, Central Valley River Restoration
Artie Valencia, Restore The Delta,
Flood and Land Restoration Manager
Work Cited
Admin. (2024). Two California cities among most likely to experience flood damage. Insurance Journal. https://www.insurancejournal.com/news/west/2024/01/12/755477.htm Anguelovski, I., Connolly, J.J.T., Cole, H. et al. Green gentrification in European and North American cities. Nat Commun 13, 3816 (2022). https://doi.org/10.1038/s41467-022-31572-1 Anguelovski, I., Connolly, J. J. T., Masip, L., & Pearsall, H. (2017). Assessing green gentrification in historically disenfranchised neighborhoods: a longitudinal and spatial analysis of Barcelona. Urban Geography, 39(3), 458–491. https://doi.org/10.1080/02723638.2017.1349987
Franco, V. (2024, August 9). San Joaquin County sees dramatic increase in numbers of unsheltered homeless residents. Local News Matters.
https://localnewsmatters.org/2024/08/09/san-joaquin-county-sees-dramatic-increase-in-numbers-of-unshelteredhomeless-residents/ Fullmer, G., & Mazurek, R. (2024). Introducing a new Equitable Development Toolkit. River Network. https://www.rivernetwork.org/community-centered-solutions-for-green-gentrification-and-displacement/ Gould, Kenneth & Lewis, Tammy. (2012). The environmental injustice of green gentrification: the case of Brooklyn's prospect park. The World in Brooklyn: Gentrification, Immigration, and Ethnic Politics in a Global City. 113-146.

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Immergluck, D., & Balan, T. (2017). Sustainable for whom? Green Urban Development, environmental gentrification, and the Atlanta beltline. Urban Geography, 39(4), 546–562. https://doi.org/10.1080/02723638.2017.1360041
Jacobs, K. (2017, October 17). The high line network tackles gentrification. www.architectmagazine.com. https://www.architectmagazine.com/design/the-high-line-network-tackles-gentrification Jaffe, E. (2015). The (basically) complete health case for urban parks, trees, and nature - bloomberg. bloomberg.com.
https://www.bloomberg.com/news/articles/2015-10-20/the-basically-complete-health-case-for-urban-parks-treesand-nature Jelks, N. O., Jennings, V., & Rigolon, A. (2021). Green Gentrification and Health: A Scoping Review. International Journal of Environmental Research and Public Health, 18(3), 907. https://doi.org/10.3390/ijerph18030907
Mengbing Du, Xiaoling Zhang (2020). Urban greening: A new paradox of economic or social sustainability?, Land Use Policy, Volume 92, 2020, 104487, ISSN 0264-8377,
https://doi.org/10.1016/j.landusepol.2020.10487
Neild, M., & Rose, J. (2019). Addressing homelessness in public parks: Feature: Parks and Recreation Magazine.

NRPA. https://www.nrpa.org/parks-recreation-magazine/2019/january/addressing-homelessness-in-public-parks/ U.S. Interagency Council on Homelessness, 19 strategies for communities to address encampments humanely and effectively (2024). Washington, D.C.; United States Interagency Council on Homelessness.

Zhang X, Zhang Y, Zhai J, Wu Y, Mao A. Waterscapes for Promoting Mental Health in the General Population. Int J Environ Res Public Health. 2021 Nov 10;18(22):11792. doi: 10.3390/ijerph182211792. PMID: 34831547; PMCID:

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CAUTION: This email originated from outside the City of Stockton. Do not click any links or open attachments if this is unsolicited email.

From: Patrisia Avelar <[email protected]>
Sent: Saturday, July 12, 2025 6:33 PM
To: Liszet Burgueno <[email protected]>
Subject: Comment on the Van Buskirk Park Revitalization Project To the attention of Liszet Burgueño,
Public Works Department, City of Stockton:

I am writing to express my concerns regarding the Van Buskirk Park Revitalization Project, particularly around issues of noise, safety, and the park’s impact on the surrounding neighborhood.

While I support the idea of revitalizing and expanding public spaces, I am concerned that new features such as sports courts, a skate park, mini-golf, and event areas may result in a noticeable increase in noise, especially during evenings and weekends. This could disrupt the peace for those of us living nearby.

I am also concerned about the potential for people hanging out in the park after hours, which could raise safety and nuisance issues. With more amenities drawing larger crowds, it’s important to know if the City plans to implement security measures. Will there be:

Park rangers,security staff, or police patrols on-site? Gates or fencing that can be locked after hours?
Clearly posted and enforced park hours?
Measures to deter loitering or overnight presence?
In addition, I’d like to know if there will be any kind ofseparation between the park and nearby homes—such as fencing, landscaping barriers, or buffer zones—to protect resident privacy, reduce noise, and discourage trespassing.

I appreciate that the City isinvesting in community spaces, but I urge you to prioritize neighborhood concerns as part of this process. I hope these issues will be considered seriously during the final planning stages.

Thank you for your time and attention. I look forward to your response.

Comment Letter E
E-1
E-2
E-3
E-4
EXHIBIT 1

APPENDIX E

MITIGATION MONITORING AND REPORTING PROGRAM
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MITIGATION MONITORING AND REPORTING PROGRAM
This Mitigation Monitoring and Reporting Program (MMRP) is formulated based upon the findings of the Initial Study/Mitigated Negative Declaration (IS/MND) prepared for the Van Buskirk Park Revitalization Project (project). The MMRP, which is presented in Table A, lists mitigation measures recommended in the IS/MND and identifies mitigation monitoring requirements.

This MMRP has been prepared to comply with the requirements of State law (Public Resources Code Section 21081.6). State law requires the Lead Agency to adopt an MMRP when mitigation measures are required to avoid significant impacts. The MMRP is intended to ensure compliance with the mitigation measures identified in the IS/MND during implementation of the project.

The MMRP is organized in a matrix format. The first column identifies the recommended mitigation measures. The second column, entitled Implementation Actions, refers to the actions taken by the party responsible for oversight to ensure compliance. The third column, entitled Timing Requirements, refers to when the monitoring will occur to ensure that the mitigating action is completed. The fourth column, entitled Monitoring/Reporting Responsibility refers to the party responsible for oversight or ensuring that the mitigation measure is implemented. The fifth column, entitled Verified By and Date, refers to the party and date the action was verified as complete.

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Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date

BIOLOGICAL RESOURCES
BIO-1: Biological Monitor. A qualified biologist shall be present on site as a Biological Monitor to survey and monitor special-status species during all construction work within the Project site. The Biological Monitor shall conduct all preconstruction surveys and will ensure that any construction barrier fencing and work exclusion zones are established and maintained. The Biological Monitor shall furthermore supervise and monitor all Project activities to ensure that appropriate protective measures are implemented. The Biological Monitor shall conduct clearance surveys at the beginning of each day within or adjacent to suitable special-status species habitat, including wetlands and riparian habitats. The Biological Monitor shall have the authority to halt work activities that may affect special-status species at any life stage. If a special-status species enters the work site, all work shall stop until it leaves on its own volition. If the Biological Monitor finds that any special-status species are present at the work site, all Project work shall stop, and the appropriate regulatory agencies (California Department of Fish and Wildlife [CDFW], United States Fish and Wildlife Service [USFWS], and/or the National Marine Fisheries Service [NMFS]) shall be notified. If there is imminent danger of injury to special-status species from Project-related activities and the special-status species individual(s) do not move out of the work site on their own, the Biological Monitor shall relocate the animal(s) to the nearest suitable habitat outside the work zone and notify the appropriate regulatory agencies within 24 hours.
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to and
throughout the
duration of project
construction
 The City of Stockton (City)
is responsible for
incorporating this
measure into contract
specifications, hiring the
Qualified Biologist, and
for ensuring compliance
prior to and during
construction.
 The Qualified Biologist
are responsible for
implementing this
measure.

BIO-2: Worker Environmental Awareness Training (WEAT). During Project construction, before any work occurs in the Project site, including grading, vegetation removal, and equipment staging, all construction personnel shall participate in WEAT regarding specialstatus species and sensitive habitats present in the Project area. Any additional construction personnel who are employed following the initial start of construction shall receive the mandatory training before beginning work. As part of the training, an environmental  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to grounddisturbing activities
associated with project
construction.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring the
Qualified Biologist, and
for ensuring compliance
during construction.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
awareness handout shall be provided to all personnel that describes and illustrates sensitive resources (i.e., special-status species and habitat, nesting birds/raptors) to be avoided during the proposed Project construction and lists measures to be followed by personnel for the protection of biological resources.
 The Qualified Biologist
and all persons employed
or otherwise working on
the project site are
responsible for
implementing this
measure.

BIO-3: Implement General Wildlife Protection Measures During Construction. The City of Stockton (City) and its contractors’ employees and volunteers shall implement general wildlife protection measures during construction that shall include, but may not be limited to, the following:
 Limit construction activities to daylight hours to the extent feasible. Conduct all in-water construction activities between May 1 and November 30.
 Confine clearing to the minimal area necessary to facilitate construction activities.
 Clearly delineate the Action Area limits by using fencing, flagging, or other means prior to the start of construction activities.  Limit the number of new temporary access routes, number and size of staging areas, and total area of construction activities when working in or adjacent to wetlands, streams, and riparian areas. Movement of heavy equipment shall be confined to existing roadways, and excavation equipment shall be operated from the tops of banks to minimize habitat disturbance.  Keep all fueling and maintenance of vehicles and other mechanized equipment in designated areas at least 100 feet from any aquatic habitat. Each designated fueling/maintenance area shall be protected by a containment barrier designed to prevent any spilled or leaked fuel or other contaminants from running into an aquatic habitat. All workers shall be informed of the  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Throughout the
construction period.
 The City is responsible for
incorporating this
measure into contract
specifications and for
ensuring compliance
during construction.
 The Construction
Contractor is responsible
for implementing this
measure.

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Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
importance of preventing spills and of the appropriate measures to take should a spill occur.
 Reduce the risk of spreading harmful pathogens by sanitizing all vehicles and equipment before use in natural areas. All vehicular and equipment cleaning work shall be conducted in selfcontained work areas at least 100 feet from any aquatic habitat; wash water shall not be disposed of in any natural areas.  Avoid wildlife entrapment by completely covering or providing escape ramps for all excavated steep-walled holes or trenches more than 1 foot deep at the end of each work day.
 Inspect the work area and any equipment or material left on site overnight for listed species prior to the start of construction activities each day.
 Dispose of garbage in wildlife-proof containers and remove the garbage from the construction area regularly during the construction period.
 Check under equipment and in staging areas for wildlife species each morning prior to work.
 Stay within designated work areas.
 Maintain exclusion/silt fencing.
 No pets or firearms shall be allowed on site.
 Report to the supervisor on site any observed incident of death or injury to a special-status species or damage to habitat. The supervisor shall immediately notify the Qualified Biologist.

BIO-4: Preconstruction and Construction Monitoring. The City shall avoid and minimize effects to special-status species during construction, habitat restoration, and maintenance activities associated with the Project. The following preconstruction and construction monitoring measures shall be implemented:
 Include measure as
Condition of
Approval.
 Implementation
actions are
Prior to and
throughout the
duration of project
construction.
 The City is responsible for
incorporating this
measure into contract
specifications, for hiring a
Qualified Biologist,
consulting with CDFW,
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date

1. Preconstruction surveys shall be conducted for nesting Swainson’s hawk, following the “Recommended Timing and
Methodology for Swainson’s Hawk Nesting Surveys in the
California’s Central Valley” ; these surveys shall include a 0.25- mile radius outside the Project area. Nest trees shall only be removed between September 16 and February 1, when nests are unoccupied. Construction work (including grading, earthmoving, surveying, and any operation of construction equipment) shall not occur within a 0.25-mile buffer zone around an active, occupied Swainson’s hawk nest with eggs or young. Construction work may commence in the buffer zone when a qualified
biologist has confirmed that nesting activity is complete (e.g., Swainson’s hawk young have fully fledged, are capable of flight, and have left the nest, or the adults have abandoned the nest for a minimum of 7 days and there is no evidence of re-nesting activity). The size of nest site buffer zones may be reduced only under the following conditions:
a. A site-specific analysis prepared by a qualified biologist indicates that the nesting pair under consideration are not likely to be adversely affected by construction activities (e.g., the nest is located in an area where the hawks are habituated to human activity and noise levels are comparable to
anticipated construction work). CDFW must approve this
analysis before construction may begin within 0.25 mile of a nest.
b. Monitoring by a qualified biologist is conducted for a sufficient time (during all construction activities for a minimum of 10 consecutive days following the initiation of construction), and the nesting pair does not exhibit adverse reactions to
construction activities (e.g., changes in behavioral patterns, reactions to construction noise).
c. Monitoring is continued at least once per week through the nesting cycle at that nest. This longer-term monitoring may be reduced to a minimum of 2 hours in the morning and 2 hours outlined in the
measure.
obtaining any necessary
permits, and providing
compensatory mitigation,
if required.
 The Qualified Biologist is
responsible for
conducting preconstruction surveys,
conducting monitoring,
establishing avoidance
areas, and halting work, if
needed.

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Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
in the afternoon during construction activities; however, additional and more frequent monitoring may be required if any adverse reactions are noted.
d. Weekly monitoring reports shall be submitted to CDFW during construction and monitoring activities.
e. If adverse effects are identified, construction activities shall cease immediately and construction shall not resume until the qualified biologist, in consultation with CDFW, has determined that construction may continue under modified restrictions or that nesting activity is complete.

2. Preconstruction surveys for Elderberry bushes shall be conducted at least 14 days prior to any ground disturbance. All areas to be avoided during construction activities shall be fenced and/or flagged. Activities that may damage or kill an elderberry shrub (e.g., trenching, paving, etc.) may need an avoidance area of at least 6 meters (20 feet) from the dripline.

3. A qualified biologist shall conduct a habitat assessment and surveys, if habitat for burrowing owl is present prior to construction. The habitat assessment and surveys shall follow the Department of Fish and Game State Report on Burrowing Owl Mitigation1 methodology and the qualified biologist shall prepare a report documenting the survey results, and submit the report to CDFW, and obtain CDFW’s written approval of the report prior to Project construction. The habitat assessment and surveys shall encompass the Project site and a sufficient buffer zone to detect owls nearby that may be impacted, which is up to 500 meters (1,640 feet) around the Project site pursuant to above methodology. Habitat assessments and surveys shall occur annually for the duration of the Project, as conditions may change annually and suitable refugia for burrowing owl, such as 1 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. Website: nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843 (accessed July 29, 2021).

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Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
small mammal burrows, can be created within a few hours or days. Surveys for either non-breeding or breeding burrowing owls shall be spread over four visits during the non-breeding and breeding season. Time lapses between surveys or Project activities shall trigger subsequent surveys including, but not limited to, a final survey within 24 hours prior to ground disturbance. If the habitat assessment does not identify habitat and surveys are not conducted, an additional habitat assessment shall be conducted within 14 days prior to construction. If new refugia are present such as burrows or novel Project
infrastructure, surveys shall be conducted as described above.

The qualified biologist shall have a minimum of two years of experience implementing the above methodology. The following measures shall be implemented should preconstruction surveys find burrowing owls to be present:
a. The City shall immediately notify CDFW if burrowing owl is detected and implement a construction avoidance buffer
around any detected burrowing owl pursuant to the buffer distances outlined in the Department of Fish and Game State Report on Burrowing Owl Mitigation. Any detected owl shall be monitored by the qualified biologist to ensure it is not disturbed during construction activities.
b. If the City cannot ensure burrowing owl and their burrows are fully avoided, the City shall consult with CDFW and obtain a California Endangered Species Act (CESA) take authorization or otherwise demonstrate compliance with CESA. Take is likely to occur and City shall obtain an Incidental Take Permit (ITP) if burrowing owl surveys detect burrowing owl occupancy of burrows or burrow surrogates within the Project site.

Occupancy of habitat may also be indicated by burrowing owl sign including molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site.

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Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
c. If burrowing owl, or their burrows or burrow surrogates are detected within 500 meters (1,640 feet0 of the Project site, but not on the Project site, the City shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted. d. To prevent burrowing owl from sheltering or nesting in exposed material; all construction pipes, culverts, hoses or similar materials greater than two inches in diameter stored at the Project site shall be capped or covered before the end of each work day and shall be inspected thoroughly for wildlife before the pipe or similar structure is buried, capped, used, or moved.

If western bumble bees, or potential Crotch’s or western bumble bees (since bumble bees can be difficult to identify in the field) are observed within the Project site, a plan to protect specialstatus bumble bee nests and individuals shall be developed and EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
implemented in consultation with CDFW. The plan shall include, but not be limited to, the following measures:
a. Specifications for construction timing and sequencing requirements (e.g., avoidance of mowing, tilling, or other ground disturbance until late March to protect overwintering queen bumble bees);
b. Establishment of appropriate no-disturbance buffers for bumble bee nest sites to avoid impacts to the bees and
monitoring by a qualified biologist to ensure compliance if bumble bee nests are identified;
c. Restrictions associated with construction equipment or materials that may harm bumble bees (e.g., avoidance of pesticides/herbicides, BMPs to minimize the spread of invasive plant species);
d. Provisions to avoid western bumble bees, or potential western bumble bees if observed away from a bumble bee nest during Project activity (e.g., ceasing of Project activities until the animal has left the active work area on its own volition); and e. Prescription of an appropriate restoration seed mix targeted for the western bumble bee, including native plant species known to be visited by native bumble bee species and
containing a mix of flowering plant species with continual floral availability through the entire active season of the western bumble bee (March through September).

If Project impacts to special-status bumble bee cannot be completely avoided, the City shall apply obtain an ITP from CDFW.

If the Project will result in permanent impacts to suitable special-status bumble bee habitat, the City shall provide compensatory mitigation at a minimum ratio of 3:1. Floral resources shall be replaced as close to their original location as EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
is feasible. If active special-status bumble bee nests have been identified and floral resources cannot be replaced within 200 meters (656 feet) of their original location, floral resources shall be planted in the most centrally available location relative to identified nests. This location shall be no more than 1.5- kilometer (4,921 feet) from any identified nest. Replaced floral resources may be split into multiple patches to meet distance requirements for multiple nests. Mitigation lands shall be protected in perpetuity under a conservation easement with an endowment established for long-term management of the lands.

5. Preconstruction surveys shall be conducted during the monarch breeding season (March 16 through October 31) to determine if milkweed is present on site and is being used for monarch breeding. Surveys shall be conducted by a qualified biologist no more than 14 days prior to ground or vegetation disturbance activities. The biologist will search for evidence of monarch eggs, caterpillars, chrysalises, and adults.

6. Prior to any construction activities, preconstruction surveys for northwestern pond turtle shall be performed by a qualified biologist within the Project area and staging area (including a 50- foot buffer) to determine whether northwestern pond turtles or their active nests are present. Preconstruction surveys for northwestern pond turtles, shall be conducted 24 hours prior to construction activities. Surveys shall be repeated if a lapse in construction activity of 2 weeks or more occurs.

7. Preconstruction breeding bird surveys shall be conducted within 14 days prior to the start of construction. If there is a break in construction of 1 week or more, surveys shall be conducted prior to the reinitiation of construction. If birds or nests are located within this buffer, USFWS will be contacted for further guidance to ensure birds or nests are not disturbed. If surveys determine that the species is present and nesting within this area, an appropriate nest protection buffer shall be established by a EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
qualified biologist based on the species, type of construction or maintenance activities, and line of sight to the work area. Under this measure, nesting birds and offspring would not be disturbed or killed, and nests and eggs would not be destroyed. Work shall be conducted no less than 500 feet from an active raptor nest and 100 feet from an active migratory bird nest, although buffer distances for all nesting birds may differ based on consultation with CDFW and USFWS. To prevent encroachment, the
established buffer(s) shall be clearly marked by high-visibility material if it has been determined by the qualified biologist that high-visibility material would not attract predators to the nest site. No construction activities, including tree removal, shall occur within the buffer zone until the young have fledged or the nest is no longer active, as confirmed by the qualified biologist. If construction or maintenance activities must occur within established buffer zones, a qualified biologist shall establish monitoring measures, including frequency and duration, based on species, individual behavior, and type of construction activities. If birds are showing signs of distress within the established buffer(s), construction or maintenance activities shall be modified or the buffer(s) shall be expanded to prevent birds from abandoning their nests. At any time, the biologist shall have the authority to halt work if there are any signs of distress or disturbance that may lead to nest abandonment. Work shall not resume until corrective measures have been taken or it is determined that continued activity would not adversely affect nest success. The monitor shall continue monitoring the nest until construction within 0.5 mile of the nest is completed, or until all chicks have completely fledged and are no longer dependent on the nest.

BIO-5: Monarch Butterfly Avoidance. The recommended
management timing for vegetation management in the Central Valley is October 31 through March 15. If active monarch breeding is identified, any milkweed stand shall be protected from disturbance and maintenance, or until the City develops and implements a  Include measure as
Condition of
Approval.

During construction
activities
 The City is responsible for
ensuring incorporating
this measure into
contract specifications
and developing and
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
salvage and relocation plan that has been reviewed and approved by USFWS. The following general recommendations shall be implemented:
 Spot mowing shall be used and focused on areas with weeds and other target vegetation. Mowing of natural vegetation
communities (outside active recreation features) shall be limited to no more than twice per year. Milkweed mowing during the monarch breeding season (March 15 through October 31) shall be avoided and delayed as late as possible (i.e., late summer or early fall) to provide a longer period for monarch caterpillars to develop and extend the availability of nectar plants to monarchs and other pollinators into the late summer. Generally, fall mowing after the first frost is ideal to avoid mowing floral resources and host plants for breeding and migrating monarchs.

Existing milkweed patches shall be flagged, when feasible, and mowing avoided to conserve milkweed plants and avoid causing direct mortality to immature stages of monarchs. Mower
operators shall be trained to recognize milkweed plants and important native nectar plants so they can be spared during mowing. Mowing shall be at a minimum height of 10 to 12 inches to avoid cutting newly emerged milkweed plants in the spring (March through early June). Mowing should occur during the middle of the day. Monarch adults are typically most active during the warmer parts of the day, which means they are better suited to escaping a mower. If invasive nonnative and/or noxious weeds are present, the mowing equipment shall be cleaned after use and between sites to limit the spread of these weeds.  Insecticide treatments shall be planned to avoid direct exposure to both juvenile and adult monarchs. Insecticide use and subsequent impacts on pollinators shall be reduced by creating an integrated pest management plan. Conditions that allow pest populations to survive and reproduce shall be prevented. Diverse management techniques (e.g., biological, physical, and cultural) shall be employed and pesticides used only when pests pose an  Implementation
actions are
outlined in the
measure.
implementing a salvage
and relocation plan.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
economic or public health threat. Pesticides shall be selected and applied to minimize risks to nontarget organisms and applied at the lowest effective application rate specified on the product label. Pesticide applications shall be timed to avoid monarch exposure. Pesticides (especially insecticides) shall not be applied when monarchs (adult and immature) are present (March 15 through October 31). Precautions shall be taken to avoid off-site movement and reduce the risk of drift. Spray nozzles shall be carefully chosen and calibrated. Applications shall be conducted on calm days when wind speed is less than 10 miles per hour.

Application shall be avoided during a temperature inversion and when conditions are likely to cause evaporation. Using backpack sprayers and applying from the ground should be considered. On boom sprayers, the lowest effective pressure and largest droplet size possible shall be used. Nozzles shall be set low so they operate just above plant height. Aerial applications and mist blowers shall be avoided whenever possible.

BIO-6: Pollinator Habitat Restoration. To limit any potential adverse effects on pollinators, all herbaceous vegetation removal activities shall be conducted from September 1 through February 28. This includes any vegetation control with herbicides. When using herbicides, application shall be implemented by a person holding a Qualified Applicator License from the State of California. Any application of pesticides shall be completed in a manner that avoids drift and contamination of nontarget plants and areas. Ecologically invasive weeds shall be treated with spot spraying of an approved herbicide only. Targeted application of herbicides may be used in conjunction with removal of nonnative invasive weeds. Restoration of natural areas shall include establishing native seed mixes containing a diversity of native wildflowers, including milkweed, as appropriate. Native seed mixes shall be applied in bare-soil areas, including those recently cleared, graded, or disturbed. Nesting needs of ground-nesting bees and bumble bees shall be taken into consideration when restoring this habitat.
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

During and following
completion of
construction activities.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
Qualified Applicator, and
implementing this
measure.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
BIO-7: Valley Elderberry Longhorn Beetle (VELB). The following measures shall be implemented to avoid and minimize effects to VELB and/or its habitat:
 Prior to implementation of any activities that may damage or kill an elderberry shrub (e.g., trenching, paving), an avoidance area of at least 6 meters (20 feet) shall be established from the dripline, depending on the type of activity. All areas to be avoided during construction activities shall be fenced and/or flagged as close to the construction limits as feasible. All elderberry plants (with stems greater than 1 inch in diameter at ground level) occurring within the Project area shall be marked with flagging and avoided. No construction shall occur within the protected 20-foot buffer area. No elderberry shrub with one or more stems greater than 1 inch in diameter at ground level shall be removed if it is possible to avoid it (for shrubs that cannot be avoided, see the transplanting procedures below).
 A qualified biologist shall provide training for all contractors, work crews, and any on-site personnel on the status of the VELB, its host plant and habitat, the need to avoid damaging the elderberry shrubs, and the possible penalties for noncompliance (see Mitigation Measure BIO-2).
 A qualified biologist shall monitor the work area at Projectappropriate intervals to ensure that all avoidance and minimization measures are implemented. The amount and
duration of monitoring will depend on the Project specifics and should be discussed with the qualified biologist.
 All activities that could occur within 165 feet of the elderberry shrub shall be conducted outside the flight season of the VELB (March through July). Trimming of elderberry bushes may remove or destroy VELB eggs and/or larvae and may reduce the health and vigor of the elderberry shrub. In order to avoid and minimize adverse effects to VELB when trimming, trimming shall occur between November and February and shall avoid the  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to, during, and
following completion
of construction
activities
 The City is responsible for
hiring a Qualified
Biologist and ensuring
implementation of this
measure.
 The Qualified Biologist is
responsible for
establishing avoidance
areas, providing training,
and monitoring during
construction.
 The Construction
Contractor and Qualified
Biologist are responsible
for implementing erosion
control and transplanting
shrubs.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
removal of any branches or stems that are greater than or equal to 1 inch in diameter. Measures to address regular and/or largescale maintenance (trimming) shall be established in consultation with the USFWS. Mechanical weed removal within the dripline of the shrub shall be limited to the season when adults are not active (August through February) and shall avoid damaging the elderberry. No flail-type mower shall be used within an elderberry shrub dripline with one or more stems measuring more than 1 inch in diameter at ground level.
 Herbicides shall not be used within the dripline of the shrub.

Insecticides shall not be used within 30 meters (98 feet) of an elderberry shrub. All chemicals shall be applied using a backpack sprayer or similar direct application method.
 Erosion control shall be implemented, and the affected area shall be revegetated with appropriate native plants.
 In order to protect VELB larvae to the greatest extent possible, all elderberry shrubs with stems greater than 1 inch in diameter shall be transplanted if the elderberry shrub cannot be avoided or if indirect effects will result in the death of stems or the entire shrub. The removal shall either include the roots or just the removal of the aboveground portion of the plant. It is
recommended to remove the entire root ball and transplant the shrub, if possible. In order to minimize the fragmentation of VELB habitat, elderberry shrubs shall be relocated as close as possible to their original location. Elderberry shrubs may be relocated adjacent to the Project footprint if: (1) the planting location is suitable for elderberry growth and reproduction; and (2) the project proponent is able to protect the shrub and ensure the shrub becomes reestablished. If these criteria cannot be met, the shrub may be transplanted to an appropriate USFWS-approved mitigation site. Any elderberry shrub that is unlikely to survive transplanting because of poor condition or location, or any shrub that would be extremely difficult to move because of access problems, may not be appropriate for transplanting. A qualified EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
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Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
biologist shall be on site for the duration of transplanting activities to ensure compliance with avoidance and minimization measures and other conservation measures.
 Exit-hole surveys shall be completed immediately before transplanting. The number of exit holes found, the GPS location of the plant to be relocated, and the GPS location of where the plant is transplanted will be reported to the USFWS and the California Natural Diversity Database (CNDDB).
 Elderberry shrubs shall be transplanted when the shrubs are dormant (November through the first 2 weeks in February) and after they have lost their leaves. Transplanting during the nongrowing season will reduce shock to the shrub and increase transplantation success. Transplanting shall follow the most current version of the ANSI A300 (Part 6) guidelines for transplanting (http://www.tcia.org/).
 Trimming shall occur between November and February and shall minimize the removal of branches or stems that exceed 1 inch in diameter.
 Herbicides shall not be used within 100 feet of elderberry plants, but hand removal of invasive weeds may be conducted from August through February. Basal bark or foliar techniques shall be utilized when herbicide application must occur within 100 feet of the dripline of an elderberry shrub with one or more stems measuring greater than or equal to 1 inch in diameter or greater at ground level. Basal application techniques include cutting off a non-elderberry shrub and applying an oil-based herbicide directly to the stump. Foliar application techniques include hand spraying of an herbicide, with a deposition/ retention additive, to control overspray. The application of herbicides shall be completed or supervised by a certified pesticide applicator in compliance with the herbicide application prescription. Herbicide application shall occur from July through April on an as-needed basis.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
BIO-8: Northwestern Pond Turtle Avoidance. The qualified biologist shall identify all areas of northwestern pond turtle habitat to be avoided in or adjacent to the work area. If necessary, in consultation with CDFW, exclusion fencing shall be used when needed to direct the turtles and move them to an area of suitable habitat outside the construction activity. This fencing will be maintained throughout the duration of construction. The avoided areas shall be flagged, and signage stating “Environmentally Sensitive Area” shall be erected.

The Project site shall be inspected daily for the presence of northwestern pond turtles. If a northwestern pond turtle individual or nest is observed in the impact area, construction activities will stop until the Biological Monitor establishes an appropriate buffer or the turtle is no longer in the impact area. A qualified biologist (with pond turtle trapping/handling experience and holding a CDFW Scientific Collecting Permit) may relocate northwestern pond turtles to an appropriate nearby location if authorized by CDFW. Relocation areas and protocols shall be approved by CDFW prior to relocation of any turtles.
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to and during
construction activities.
 The City is responsible for
hiring a Qualified
Biologist and ensuring
implementation of this
measure.
 The Qualified Biologist is
responsible for
implementing this
measure.

BIO-9: Roosting Bat Protection Measures. Before the spring breeding season and prior to construction, a qualified biologist shall conduct a survey for roosting bat habitat. The survey shall include work areas adjacent to appropriate roosting habitat that are accessible from public or Project areas within 200 feet of a work area. For trees considered to have a high or moderate probability for bat roosting, acoustic monitoring shall be conducted before any construction activities begin during the breeding season to determine if there are any roosting sites present. Surveys shall be conducted at the appropriate times to maximize detectability. If an active roost or maternity roost is found within 100 feet of a work area, the limits of the work area will be clearly marked, and a qualified biological monitor shall remain on site during construction activities within the vicinity of the roost or maternity roost.

The biologist shall ensure that construction activities do not encroach upon the 100-foot buffer around an active roost or  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Before the spring
breeding season and
prior and during
project construction.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
Qualified Biologist, and
ensuring compliance
during construction.
 The Qualified Biologist is
responsible for surveys,
establishing buffers,
monitoring during
construction, and evicting
bats, if needed.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
maternity colony site. Buffers shall remain in place until the qualified biologist has determined that bats have vacated the occupied roost sites. If buffer reductions are requested and approved, a monthly report shall be submitted to CDFW with all the information in the buffer reduction requests, monitoring results, and effects on bats. Reports shall be submitted for the duration of construction activities within buffer areas.

Trees containing maternity roosts shall not be removed during the breeding season (March 1–August 31) to avoid disturbing females with young that cannot fly. No trees containing maternity roosts may be removed until the qualified biologist determines that breeding is complete and the young are able to fly.

If fall/winter hibernacula cannot be avoided, humane techniques may be implemented to passively vacate bats from roosts. Methods to passively evict bats from tree roosts may include incrementally trimming limbs to alter the air flow and temperature around the roost feature where slight changes to the surrounding environment of roost features encourage bats to vacate roost features on their own. If acoustic monitoring detects that bats are using trees that need to be cut down, these trees shall be removed only after it has been confirmed that roosting bats have departed.

CULTURAL RESOURCES
CUL-1a: Preparation of a Cultural Resources Management Plan.

Prior to ground disturbance, the City of Stockton (City) shall retain an archaeologist that meets the Secretary of the Interior’s (SOI) Professional Qualifications Standards in archaeology or is certified by the Register of Professional Archaeologists (RPA) to prepare (or direct the preparation of) a Cultural Resources Management Plan (CRMP) in consultation with the Confederated Villages of Lisjan Nation (CVLN), Northern Valley Yokuts Tribe and the Muwekma Tribe (Tribes). The CRMP shall include (but not be limited to) the following components:
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to ground
disturbance.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
Qualified Archaeologist,
and for reviewing the
Cultural Resources
Management Plan, and
ensuring implementation
during construction.

EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
 As survey of the entire Project area would be unproductive (due to thick, ubiquitous xeric vegetation), a controlled clear-and-grub program shall be developed for the Project in coordination with consulting tribes and the City.
 A qualified professional archaeologist (either SOI- or RPAcertified as indicated above) or an archaeologist supervised by such an archaeologist shall monitor all ground-disturbing activities prior to finish grade associated with Project implementation. Archaeological monitoring shall occur during these excavation activities until the Project Archaeologist, based on their observations, is satisfied that there is little or no potential remaining to encounter in situ archaeological resources. The Project Archaeologist may also determine that it is appropriate to reduce monitoring to a part-time or spot-check basis.
 Communication protocols for notification in the event of the identification of cultural resources shall be defined, as well as methods for treatment of such resources (e.g., avoidance, documentation, collection, identification).
 Methods of protection for cultural resources, including items such as protective fencing, securing temporary on-site storage. and protocol for notifying local authorities (i.e., law enforcement) shall be prescribed in the event looting or other resource damage occurs.

The CRMP shall also include a stipulation that, during the course of the monitoring, the frequency of archaeological and Native American monitoring may be reduced based on the conditions and only if the consulting tribes and the qualified archaeologist agree.  The Qualified
Archaeologist is
responsible for preparing
the Cultural Resources
Management Plan and
monitoring ground
disturbing activities.

CUL-1b: Cultural Resources and Tribal Cultural Resources Sensitivity Worker Environmental Awareness Program [WEAP] Training. Prior to commencement of any ground-disturbing activity, all personnel involved in Project-related ground-disturbing activities  Include measure as
Condition of
Approval.

Prior to
commencement of
ground disturbing
activities.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
(e.g., on-site construction managers, equipment operators and other crew) shall be required to participate in a workers’ environmental awareness program (WEAP) training prior to any such activities (including clear & grub and building foundation removal). The training shall include relevant information regarding cultural resources including applicable regulations and consequences of violating State laws and regulations and will also describe communication and procedural protocols (including avoidance) in the event cultural resources are encountered. The training shall be presented by a professional archaeologist (RPA or RA) and will emphasize the requirement for confidentiality and culturally appropriate treatment of all archaeological discoveries.  Implementation
actions are
outlined in the
measure.

Qualified Archaeologist,
and for ensuring
compliance prior to
construction.
 The Qualified
Archaeologist is
responsible for
implementing this
measure.

CUL-1c: Unanticipated Discovery. In the event that any precontact or historic subsurface cultural resources are discovered during ground-disturbing activities, all work within 50 feet of the resources shall be halted and the City shall consult with a qualified archaeologist to assess the significance of the find.

If any find is determined to be significant, representatives of the project proponent and/or lead agency and the qualified professional archaeologist would meet to determine the appropriate avoidance measures or other appropriate measures, with the ultimate determination to be made by the City. All significant cultural materials recovered shall be subject to scientific analysis, professional museum curation, and/or a report prepared by the qualified professional according to current professional standards.

In considering any suggested measure proposed by the qualified professional, the City shall determine whether avoidance is necessary or feasible in light of factors such as the uniqueness of the find, Project design, costs, and other considerations.

If avoidance is unnecessary or infeasible, other appropriate measures (e.g., extended documentation and/or data recovery) may be required in the event of a significant find. Work may proceed on  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

During constructionrelated ground
disturbing activities.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
Qualified Archaeologist,
and for ensuring
compliance during
construction.
 The Qualified
Archaeologist and
Construction Contractor
are responsible for
implementing this
measure.

If significant materials are recovered, the qualified professional shall include the findings in the monitoring report for submittal to the Central California Information Center.

GEOLOGY AND SOILS
GEO-1: Paleontological Resources Discovery. If paleontological resources are encountered during the course of ground disturbance, work in the immediate area of the find shall be redirected and a paleontologist contacted to assess the find for scientific significance.

If determined to be significant, the fossil shall be collected from the field. The paleontologist may also make recommendations regarding additional mitigation measures, such as paleontological monitoring.

Scientifically significant resources shall be prepared to the point of identification, identified to the lowest taxonomic level possible, cataloged, and curated into the permanent collections of a museum repository. If scientifically significant paleontological resources are collected, a report of findings shall be prepared to document the collection.
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

During constructionrelated ground
disturbing activities.
 The City is responsible for
incorporating this
measure into contract
specifications, hiring a
Qualified Paleontologist,
and for ensuring
compliance during
construction.
 The Qualified
Paleontologist and
Construction Contractor
are responsible for
implementing this
measure.

NOISE
NOI-1: Construction Noise and Vibration. Prior to the issuance of grading permits, the City of Stockton (City) Director of Community Development Department, or designee, shall verify that grading and construction plans include the following requirements:
 Ensure that the greatest distance between noise sources and sensitive receptors during construction activities has been achieved.
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

Prior to issuance of
grading permits and
throughout the
duration of
construction activities.
 The City is responsible for
verifying that grading and
construction plans
include the relevant
requirements and for
ensuring compliance
during construction.
 The Construction
Contractor is responsible
for implementing the
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
 Construction equipment, fixed or mobile, shall be equipped with properly operating and maintained noise mufflers consistent with manufacturers’ standards.
 Construction staging areas shall be located away from off site sensitive uses during the later phases of Project development.  The construction contractor shall place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the Project site whenever feasible.
 The construction contractor shall use on-site electrical sources to power equipment rather than diesel generators where feasible.  A sign, legible at a distance of 50 feet, shall also be posted at the construction site. All notices and the signs shall indicate the dates and duration of construction activities, as well as provide a telephone number for the “noise disturbance coordinator.”  A “noise disturbance coordinator” shall be established. The disturbance coordinator shall be responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of the noise complaint (e.g., starting too early, bad muffler) and shall be required to implement reasonable measures to reduce noise levels. All signs posted at the construction site shall list the telephone number for the disturbance coordinator.
identified measures
during construction.

NOI-2: As part of the final design for the subsequent phase(s) of development, the City of Stockton (City) shall require installation of a noise barrier along the northern and eastern boundaries of the proposed pickleball courts. The noise barrier may consist of any solid material, without gaps or holes, that meets a minimum density of 4 pounds/square foot, or is sound rated and has a minimum Sound Transmission Class (STC) rating of 25. The noise barrier shall provide noise reduction sufficient to ensure that noise levels at the nearest residential uses would not exceed the City’s exterior  Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

During final design. The City is responsible for
ensuring that the
appropriate noise barrier is
included in the project
design.

TRIBAL CULTURAL RESOURCES
TCR-1: Native American Monitoring. Prior to ground-disturbing activities, tribal monitor(s) from the Confederated Villages of Lisjan Nation (CVLN), the Northern Valley Yokuts Tribe, and the Muwekma Ohlone Tribe shall be retained. Native American monitoring by a representative of the North Valley Yokuts Tribe, CVLN, and the Muwekma Ohlone Tribe shall be required during all ground disturbing activities associated with project implementation.

Monitoring procedures shall follow the Cultural Resources Management Plan prepared under Mitigation Measure CUL-1a.

Tribal monitor(s) shall have the authority to halt and redirect work should any archeological or tribal cultural resources be identified during monitoring. If archaeological or tribal cultural resources are encountered during ground-disturbing activities, work within 100 feet of the find must halt and the find be evaluated for listing in the California Register of Historic Resources (California Register) and National Register of Historic Places (National Register). Monitoring may be reduced or halted at the discretion of the tribal monitor(s), in consultation with the lead agency, if site conditions indicate there is little likelihood of encountering intact deposits (e.g., encountering bedrock, sediments being excavated are fill, or negative findings for 50 percent of ground disturbance). If monitoring is reduced to spot checking, spot checking shall occur when ground-disturbing activities moves to a new location within the Project site and when ground disturbance will extend to depths not previously reached (unless those depths are within bedrock).
 Include measure as
Condition of
Approval.
 Implementation
actions are
outlined in the
measure.

During grounddisturbing activities. The City is responsible for incorporating this
measure into contract
specifications, for
contacting the Tribe and
for ensuring compliance
during construction.
 The Tribal Monitor(s) are
responsible for
implementing this
measure.

TCR-2: Unanticipated Discovery of Tribal Cultural Resources. If cultural resources of Native American origin are identified during grading or excavation of the proposed Project, all ground-disturbing activities within 100 feet must cease until a qualified professional archaeologist (either an archaeologist who meets the Secretary of  Include measure as
Condition of
Approval.
 Implementation
actions are
During grounddisturbing activities. The City is responsible for incorporating this
measure into contract
specifications, for
contacting the Tribe and
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
the Interior’s Professional Qualifications Standards for Archeology or an archaeologist supervised by such an archaeologist) has evaluated the nature and significance of the find as a cultural resource, and the City of Stockton (City) representative has consulted a representative from the CVLN, the Northern Valley Yokuts Tribe, and the Muwekma Ohlone Tribe. The archaeologist will stake the area of discovery, placing stakes no more than 10 feet apart, forming a circle with a radius of no less than 100 feet from the point of discovery. If the City, in consultation with the consulting tribe(s), determines the resource is a Tribal Cultural Resource and thus significant under the California Environmental Quality Act (CEQA) and/or to the tribe(s), the entity shall retain a qualified archeologist and a tribal monitor, at the applicant’s expense, to prepare and implement a mitigation plan, in accordance with State guidelines and in consultation with the consulting tribe(s). The mitigation plan shall include avoidance of the resource or, if avoidance of the resource is feasible, shall outline appropriate treatment of the resource in coordination with the consulting tribe(s) and, if applicable, the qualified archaeologist. Examples of appropriate mitigation for the tribal cultural resources include, but are not limited to, protecting the cultural character and integrity of the resources, protecting traditional use of the resources, protecting the confidentiality of the resources, or heritage recovery. Curation of Tribal cultural resources is not considered to be appropriate or respectful and materials shall not be permanently curated unless specifically requested by the Tribes. Any Tribal cultural resources discovered as part of the proposed Project shall be recorded in the Sacred Lands File maintained by the Native American Heritage Commission. The City and its contractor(s) shall not photograph, publicize, post, or share information about any discovered Tribal cultural resources.
outlined in the
measure.
for ensuring compliance
during construction.
 The Tribal Monitor(s), the
Qualified Archaeologist,
and the Construction
Contractor are
responsible for
implementing this
measure.

TCR-3: Halt Work/Coroners Evaluation/Impact to Previously Undiscovered Human Remains. If human remains are encountered during construction and ground disturbing activities, the City or the City’s contractor must redirect all work within 100 feet of the  Include measure as
Condition of
Approval.

During grounddisturbing activities. The City is responsible for incorporating this
measure into contract
specifications, for
EXHIBIT 1
Table A: Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Actions
Timing
Requirements
Monitoring/Reporting
Responsibility Verified By and Date
remains and immediately contact the County Coroner, the City of Stockton, and a qualified professional archaeologist (either an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archeology or an archaeologist supervised by such an archaeologist) to assess the situation. If the human remains are of Native American origin, the Coroner must notify the Native American Heritage Commission (NAHC) within 24 hours of this identification. The NAHC will identify a Native American Most Likely Descendent (MLD) to inspect the site and provide recommendations for the proper treatment of the remains and any associated funerary objects. The archaeologist shall recover scientifically valuable information, as appropriate and in accordance with the recommendations of the MLD. Upon completion of the archaeologist’s assessment, a report must be prepared documenting methods and results, as well as recommendations regarding the treatment of the human remains and any associated archaeological materials. The report must be submitted to the City, the Project proponent, the Central California Information Center (CCAIC) and the consulting tribe. Tribal representatives will rebury the Native American human remains and associated funerary objects with the appropriate dignity either in accordance with the recommendations of the MLD, if available, or in the Project vicinity at a location selected in consultation with the tribe, the professional archaeologist, and the City, where the reburial would be accessible to tribal members in perpetuity and would not be subject to further disturbance. The discovery and reburial is to be kept confidential and secure to prevent any further disturbance.
 Implementation
actions are
outlined in the
measure.
contacting the County
Coroner, and for ensuring
compliance during
construction.
 The Construction
Contractor is responsible
for stopping work and
contacting the City.
 The Qualified
Archaeologist is
responsible for examining
the find and making
recommendations.
 The MLD is responsible
for reviewing the report
and making
recommendations
regarding reburial.

Source: LSA (2025).

EXHIBIT 1
City of Stockton
Legislation Text
File #: 25-0758, Version: 1
APPROVE RESOLUTION TO ADOPT THE 2025 PARKS AND RECREATION MASTER

FACILITIES PLAN

RECOMMENDATION
It is recommended that the City Council adopt a resolution:

1. Adopting the Parks and Recreation Master Facilities Plan; and

2. Authorizing the City Manager, or designee, to take actions that are necessary and appropriate to carry out the purpose and intent of the resolution.

Summary
The Parks and Recreation Master Facilities Plan (Attachment A - copies available in the City Clerk’s Office) supports the City’s future buildout of its parkland and recreation infrastructure needs, consistent with the Envision Stockton 2040 General Plan. This plan also serves as one of the bases for the pending Public Facility Fee (PFF) Nexus Study to update development impact fees, one of which pertains to parks. The Master Plan includes an updated inventory of existing City parks, deficiencies for existing and buildout conditions based on the 2040 General Plan, identifies community needs through the use of public engagement, and provides a comparison of benchmark and model communities to inform future park and recreation development and recommendations on how to best plan and manage future park and recreation need within the City of Stockton.

Based on this Master Plan, the City will establish development impact fees to mitigate the full costs of growth in a community through new development as it relates to the need for additional parks and recreational facilities. By approving the proposed resolution, the City Council adopts the Parks and Recreation Master Facilities Plan, which must be adopted prior to the establishment of new impact fees, as it will serve as the foundational guiding document for future park and recreation amenities, improvements, and the calculation of development impact fees.

DISCUSSION
Background
The Envision Stockton 2040 General Plan was adopted on December 4, 2018, by Resolution No. 2018-12-04-1503-01. This document serves as the guiding policy document governing the City’s growth, establishing policies and actions needed to support the City’s long-term growth, including housing, infrastructure, public amenities, and economic development. To implement the policies outlined in the General Plan, updated master infrastructure plans, including the Parks and Recreation Master Facilities Plan, are required to ensure that public facilities (including parks) and services grow City of Stockton Page 1 of 3 Printed on 9/4/2025
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File #: 25-0758, Version: 1
in alignment with development and community needs.

The Master Plan is part of this broader citywide infrastructure planning initiative. It evaluates current park assets and the existing level of park service, identifies service gaps, and outlines strategic recommendations for future investment and expansion. This comprehensive review and inventory of the City’s parks and recreational programs provides a snapshot of the City’s current level of park service and insight into how the City can target future park planning.

This Master Plan will directly inform the Public Facilities Fee (development impact fee) Nexus Study, required by California Government Code section 66000 et al., , known as the Mitigation Fee Act, which mandates a clear connection or “nexus” between the collection of new development impact fees and the improvements they are intended to fund. The Master Plan will help establish this nexus by defining parkland facility needs based on Stockton’s population growth, service level standards, and land acquisition and development cost estimates.

The City of Stockton will use this Master Plan as a guiding document to quantify the park and recreational facilities appropriate for development as local conditions continue to evolve through the 2040 General Plan horizon. The information from this Plan will feed into the Public Facility Fee Nexus Study and will provide the necessary data to be analyzed and used to develop the new fee rate for the Parkland and Community Recreation Fee. The fees collected will fund park and recreation facilities at a level of service to meet the demands of Stockton residents, ensuring that new development projects pay their fair share for these facilities as the City grows. All Public Facility Fees, including the Parkland Fee, are currently under review through an effort led by the Community Development Department.

On February 23, 2021, via Resolution No. 2021-02-23-1502, City Council awarded a Professional Services Agreement to Harris & Associates, Inc. Harris & Associates submitted a proposal with subcontractor O’Dell Engineering to prepare the Master Plan.

Present Situation
The City’s consulting team (O’Dell Engineering, a sub-contractor under Harris & Associates, Inc.) completed a draft of the Parks and Recreation Master Facilities Plan, which is now being recommended for adoption by the City Council.

The Master Plan development process included a variety of community and stakeholder engagement. In developing this Master Plan, a series of public surveys, stakeholder interviews, and community meetings were conducted to gather input on current conditions, unmet needs, and future priorities. These outreach efforts ensured that the Plan reflected the values, preferences, and expectations of Stockton residents.

Initially, in April 2021 the consultant held a series of meetings with the City staff closely involved with parks use, programs, and maintenance to identify areas staff felt were strengths within the parks system or that needed improvement. Then, the consultant developed materials for outreach to the general public, including internet-based public surveys and interactive polling activities to gather public opinion during online outreach meetings.

Two initial public meetings were held in July of 2021. The goal of these meetings was to involve the City of Stockton Page 2 of 3 Printed on 9/4/2025
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public early in the process and allow sufficient time for public feedback ahead of drafting the Master Plan. The public surveys remained online and available to the public from July through early September of 2021. A total of 239 respondents filled out the survey. An additional public review meeting was held after the initial draft Plan was completed to gather further public feedback.

The feedback received through this public outreach process was used to assess service level gaps, determine priority projects, and guide recommendations for future investments. It also helped shape park classifications, amenity preferences, and equitable access strategies.

Additionally, the Plan includes a technical assessment of existing facilities and a gap analysis comparing current service levels to projected future demand. This ensures that the Master Plan remains grounded in community priorities and objective data.

This comprehensive planning effort provides the necessary foundation for the upcoming Development Impact Fee Nexus Study, which will establish an updated fee structure to ensure new development contributes its fair share toward public parks and recreation facilities. The Master Plan allows the City to remain in compliance with Government Code section 66000 et al., known as the Mitigation Fee Act, by documenting the need for citywide impact fees, estimating future needs and costs of infrastructure development, and aligning improvements with projected growth patterns. It is essential that this Plan be adopted prior to completion of the Nexus Study to ensure that impact fees are legally justified and based on clearly identified facility needs.

The public draft Master Plan was posted to the Community Development Department’s website on December 12, 2023. The Master Plan was subsequently updated to reflect an updated Stockton Pool Needs Assessment Update (June 2024) to reflect minor updates regarding the City’s pool facilities. The current version of the Master Plan was posted on the Community Development’s website on June 12, 2025.

On July 22, 2025, the draft Master Plan was reviewed with the Industry Working Group (IWG) where development costs, economies of scale, and park amenities were discussed. No significant amendments were requested or suggested by the IWG.

On July 28, 2025, the City of Stockton Parks and Recreation Commission voted to approve Resolution 2025-07-28-0601 (Attachment B), recommending the City Council adopt the Parks and Recreation Master Facilities Plan.

It is recommended that the City Council adopt the Parks and Recreation Master Facilities Plan, consistent with the Envision Stockton 2040 General Plan.

FINANCIAL SUMMARY
There is no impact on the City's General Fund or any other unrestricted fund from this action.

Attachment A - Draft Parks and Recreation Master Facilities Plan (available in the City Clerk’s Office) Attachment B - Parks and Recreation Commission Resolution 2025-07-28-0601 City of Stockton Page 3 of 3 Printed on 9/4/2025
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ATTACHMENT A
Full document is available in the City Clerk's Office.

Resolution No.
,· 2025-07-28-0601

STOCKTON PARKS & RECREATION COMMISSION
RESOLUTION RECOMMENDING THE CITY COUNCIL ADOPT THE 2025 PARKS

AND RECREATION MASTER FACILITIES PLAN
On February 23, 2021, a Professional Services contract was awarded to Harris & Associates, Inc., via Resolution No. 2021-02-23-1502, to prepare a Public Facilities Fee (PFF) Nexus Study and the development of Master Infrastructure Plans; and Harris & Associates, Inc. identified sub-contractor O'Dell Engineering to prepare the Parks and Recreation Master Facilities Plan, attached as Exhibit 1; and The Parks and Recreation Master Facilities Plan (Master Plan) is part of this broader citywide Infrastructure planning initiative that includes evaluation of current assets, levels of service, and recommendations for future investment and expansion; and The Master Plan will directly Inform the Public Facilities Fee (development impact fee) Nexus Study, required by California Government Code (AB1600), which mandates a clear connection or "nexus" between the collection of new development impact fees and the improvements they are intended to fund; and
The Maste:,r Plan will help establish this nexus by defining parkland facility needs based on Stockton's population growth, service level standards, and land acquisition and development cost estimates: and
The City of Stockton will use this Master Plan as a guiding document to quantify the park and recreational facilities (and PFF fees} appropriate for development as local conditions continue in accordance with the Envision Stocl<lon 2040 General Plan; now, therefore,

BE IT RESOLVED BY THE PARKS AND RECREATION COMMISSION OF THE CITY OF STOCKTON AS FOLLOWS:

The preparation of the 2025 Parks And Recreation Master Facilities Pl.an is exempt pursuant to the California Environmental Quality Act (CEQA) guidelines, Section 15183 (Projects Consistent with a Community Plan, General Plan, or Zoning), and no further environmental review is required. Future projects, however, will have their own environmental review to address project-specific significant effects.

The 2025 Parks and Recreation Mast�r Facilities Plan conforms with the Envision Stockton 2040 General Plan Update.

The Parks and Recreation Commission recommends City Council adoption of The

ATTACHMENT B
Parks and Recreation Master Facilities Plan, dated June 2025, attached as Exhibit 1 and incorporated by this reference.

PASSED,APPROVED,andADOPTED -�Ju=l�y=2=8,�2=0=2�5 ____ _ City of Stockton Parks and Recreation Commission
ATTEST:

ATTACHMENT B
Resolution No.

STOCKTON CITY COUNCIL
RESOLUTION ADOPTING THE 2025 PARKS AND RECREATION MASTER

FACILITIES PLAN
On February 23, 2021, a Professional Services contract was awarded to Harris & Associates, Inc., via Resolution No. 2021-02-23-1502, to prepare a Public Facilities Fee (PFF) Nexus Study and the development of Master Infrastructure Plans; and Harris & Associates, Inc. identified sub-contractor, O’Dell Engineering, to prepare the Parks and Recreation Master Facilities Plan, attached as Exhibit 1; and The Parks and Recreation Master Facilities Plan (Master Plan) is part of this broader citywide infrastructure planning initiative that includes evaluation of current assets, levels of service, and recommendations for future investment and expansion; and The Master Plan will directly inform the Public Facilities Fee (development impact fee) Nexus Study, required by California Government Code section 66000 et al., known as the Mitigation Fee Act, which mandates a clear connection or “nexus” between the collection of new development impact fees and the improvements they are intended to fund; and
The Master Plan will help establish this nexus by defining parkland facility needs based on Stockton’s population growth, service level standards, and land acquisition and development cost estimates; and
The City of Stockton will use this Master Plan as a guiding document to quantify the park and recreational facilities (and PFF fees) appropriate for development as local conditions continue in accordance with the Envision Stockton 2040 General Plan; now, therefore,

BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF STOCKTON, AS FOLLOWS:

1. The preparation of the 2025 Parks and Recreation Master Facilities Plan is exempt pursuant to the California Environmental Quality Act (CEQA) guidelines, section 15183 (Projects Consistent with a Community Plan, General Plan, or Zoning), and no further environmental review is required. Future projects, however, will have their own environmental review to address any project-specific significant effects.

2. The 2025 Parks and Recreation Master Facilities Plan conforms with the Envision Stockton 2040 General Plan Update.

3. The 2025 Parks and Recreation Master Facilities Plan is adopted by the City Council.

4. The City Manager is authorized to take whatever actions are necessary and appropriate to carry out the purpose and intent of this Resolution.

PASSED, APPROVED, and ADOPTED September 9, 2025 .

CHRISTINA FUGAZI
Mayor of the City of Stockton
ATTEST:

KATHERINE ROLAND, CMC, CPMC
City Clerk of the City of Stockton
Parks and Recreation Facilities Master Plan
City Council Meeting
September 9, 2025
Agenda Item 16.1
Purpose of the Master Plan
Supports future buildout of Stockton’s Parks and
Recreation infrastructure
Identifies current facility gaps and future
community needs
Serves as foundation for the Park Fee calculation in
the Public Facility Fee (PFF) Nexus Study
Alignment with Envision Stockton 2040 GP
Implements General Plan policies for parks and
amenities.

Ensures infrastructure keeps pace with population
growth and development.

Community driven recommendations for future
investment.

Key Components of the Master Plan
Updated inventory of existing parks and
recreation facilities.

Gap analysis between existing and
anticipated 2040 conditions.

Community engagement to identify needs
and priorities.

Benchmarking for future development and
service level goals.

Community Engagement
Stakeholder interviews
and staff consultations
began in April 2021
Public surveys (July–
Sept 2021): 239
responses
Multiple community
meetings for feedback
on needs and
preferences
Public feedback directly
shaped priorities and
policy recommendations
– 2022 to 2024
Industry Working Group
(IWG) Feedback – July
2025
Parks & Recreation
Commission Approval
Recommendation –
July 28, 2025
Technical Analysis Highlights
Recommendations tailored to projected growth and funding strategies.

Identified gaps in service coverage and future demand.

Facility inventory and service level assessment.

Role in Development Impact Fees
Required step to justify
new Parkland and
Community Recreation
PFF Fees
Complies with AB 1600
(California Gov Code) by
defining fee "nexus"
Ensures new
development pays fair
share of park
infrastructure costs
Plan adoption required
prior to finalizing the
new impact fees
Staff Recommends
Approve a Resolution:
• Adopting the Parks and Recreation Master Facilities Plan; and
• Authorizing the City Manager, or designee, to take actions that are necessary and appropriate to carry out the purpose and intent of the resolution
City of Stockton
Legislation Text
File #: 25-1008, Version: 1
REVIEW AND APPROVE RESPONSE TO 2023-24 SAN JOAQUIN CIVIL GRAND JURY REPORT - CITY OF STOCKTON CRISIS IN GOVERNMENT CASE #0123

RECOMMENDATION
It is recommended that the City Council adopt a resolution to:

1. Adopt Chapter 3.15 of the Council Policy Manual regarding Brown Act Investigations.

It is further recommended that the City Council adopt a motion to:

1. Direct staff regarding the desired response for Recommendation 3.1 concerning the Ethics Hotline process.

2. Approve the City’s third, follow-up response to the 2023-24 San Joaquin Civil Grand Jury Case Number 0123, Crisis in Government.

3. Authorize the City Attorney to submit all approved responses to the San Joaquin County Civil Grand Jury on behalf of the City and Council.

Summary
Each year it is the duty of the San Joaquin Civil Grand Jury to examine and investigate the activities of local government and agencies within San Joaquin County. The 2023-2024 Civil Grand Jury conducted a new investigation and published a report entitled “Crisis in Government,” case number 0123 (Attachment A).

This presented item is the City’s third, follow-up response to the report and must be provided to the Civil Grand Jury by October 1, 2025.

The City Council is asked to review the response and approve forwarding it to the Civil Grand Jury (Attachment B). As part of this review, the City Council is asked to adopt a new Council Policy, Chapter 3.15, regarding the submission of findings if the City Council conducts an investigation into alleged Brown Act violations (Attachment C).

DISCUSSION
Background
California Penal Code section 933 requires that “a grand jury shall provide to the affected agency a copy of the portion of the grand jury report relating to that person or entity […]” and “no later than 90 City of Stockton Page 1 of 4 Printed on 9/4/2025
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days after the grand jury submits a final report on the operations of any public agency subject to its reviewing authority, the governing body of the public agency shall comment to the presiding judge of the superior court on the findings and recommendations pertaining to matters under control of the governing body […].”
The City received the Grand Jury’s notification of this report on June 10, 2024. The City Manager, City Attorney, Interim City Clerk and staff worked through the Council Legislative Committee to develop and make recommendations to the full Council responsive to the recommendations issued in this report.

On August 20, 2024, by motion 2024-08-20-1210, the City Council approved the City’s initial 90-day response to the full 2023-24 report. That response included responses to other, older Grand Jury reports as well as the 2023/24 report regarding case number 0123, Crisis in Government,” with information available at that time. The response confirmed the timelines for the City to provide additional information, as necessary, and as required by the Grand Jury.

On October 1, 2024, by motion 2024-10-01-1205, the City Council approved the City’s second followup response to the 2023-24 San Joaquin Civil Grand Jury’s Second Look at the 2018-19 Report, Case No. 0318, Cold Cases in San Joaquin County: On the Back Burner. While that report did not include a substantive response to Case No. 0123, within that response, the City agreed to provide the Grand Jury with a second follow-up response to Case No. 0123, Crisis in Government, in April 2025.

Due to staffing changes, the follow-up response was not submitted in April 2025. On May 13, 2025, staff presented the proposed response to the City Council for consideration. By Motion 2025-05-13- 1202 the item was moved to the June City Council meeting. On June 3, 2025, via Motion 2025-06-03 -1212, the City Council authorized the submission of the second follow-up response.

A response to outstanding items is due to the Civil Grand Jury by October 1, 2025.

Present Situation
On August 25, 2025, the Legislation/Environmental Committee met and reviewed the outstanding recommendations made by the Civil Grand Jury, recommendations 1.2, 2.3 and 3.1, and proposed responses. These items and the Committee recommendations have been outlined below for the Councill’s review and consideration.

R 1.2: By October 1, 2025, the Stockton City Council should establish a policy for addressing threatening communications directed at City officials and employees. The policy should include forwarding threats to the District Attorney’s office.

Staff proposes the following response:

CITY RESPONSE:

The City Acknowledges the Grand Jury’s recommendation R1.2. City of Stockton Administrative Directive HR-64 - Workplace Violence Crisis Management Policy, addresses the procedure for handling threats received by City Official and employees. The city further developed written Workplace Violence Prevention Plans in accordance with guidance received City of Stockton Page 2 of 4 Printed on 9/4/2025
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For the City Council’s review, staff has attached Administrative Directive HR-64 - Workplace Violence Crisis Management Policy (Attachment D).

On August 25, 2025, the Legislation/Environmental Committee directed staff to forward the response to R1.2 to City Council for approval. No changes to the response have been made.

R2.3: “By October 1, 2025, the Stockton City Council shall enact a policy requiring all findings from investigations into alleged Brown Act violations to be submitted to the Civil Grand Jury within seven days of receipt by the Council.”
Staff proposes the following response:

CITY RESPONSE:

Via Resolution 2025-09-xx-xxxx the City Council has adopted Council Policy Manual Chapter

3.15, Brown Act Investigations. The policy provides: “If by majority vote the City Council orders an investigation into alleged Brown Act violation(s), all findings from the investigation regarding the alleged Brown Act violation(s) shall be submitted to the Civil Grand Jury within seven (7) days of receipt by the City Council.”
As part of its review, the City Council is asked to adopt the referenced Council Policy Manual Chapter

3.15, regarding the submission of Brown Act investigation findings (Attachment C). The proposed policy provides the recommended seven (7) day submission if the City Council conducts an investigation into alleged Brown Act violations. The policy expressly states that the City retains the right to determine if it will conduct such an investigation. It further clarifies that, regardless of the existence of any City-conducted investigation, referrals to the Civil Grand Jury can be made in accordance with its standard procedures, which remains true whether or not the City Council adopts the proposed policy.

On August 25, 2025, the Legislation/Environmental Committee directed staff to forward the proposed Council Policy to R2.3 to City Council for approval. No changes to the proposed policy have been made.

R3.1 “By October 1, 2025, the Stockton City Council shall hire an independent third party to investigate the City’s Ethics Hotline process to regain employee and public trust in the system.”
On August 25, 2025, the Legislation/Environmental Committee heard staff’s recommendation that a Request for Proposal (RFP) be issued to seek qualified applicants to conduct the recommended investigation of the City’s Ethics Hotline process. Due to concerns regarding the additional City expenditures for the RFP, the subsequent contract, and any resulting investigations, the Committee recommended an alternate response to state that an internal review will be conducted and the function will remain in-house.

In light of the Committee’s feedback, staff drafted the following response:

CITY RESPONSE:

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The City Acknowledges the Grand Jury’s recommendation R3.1 and the importance of ensuring employees have confidence in the City’s Ethics Hotline process. The Ethics Hotline is currently maintained by the Stockton City Attorney’s Office. The City of Stockton will work internally to review the current process to ensure that the Stockton City Attorney’s Office can adequately maintain the system and preserve confidence in the system. Provided the City is assured of this, the functions and review of the Ethics Hotline will be retained internal to the City.

If the City Council would like to pursue the original staff recommendation to issue an RFP, the response would read as follows:

CITY RESPONSE:

The City Acknowledges the Grand Jury’s recommendation R3.1 and the importance of ensuring employees have confidence in the City’s Ethics Hotline process. The City Council provided direction to staff during its September 23, 2025, meeting to issue an RFP for the retention of an independent third party to investigate the City’s Ethics Hotline process.

Staff asks for direction on which response to Recommendation 3.1 to include in the third response to the Civil Grand Jury. Once clarified and if approved, the City Attorney will submit the responses reflected in Attachment B to the Grand Jury on behalf of the City and Council.

FINANCIAL SUMMARY
There is no immediate financial impact by recommending this action.

Attachment A - 2024-25 Grand Jury Final Report, Case No. 0123 Attachment B - Third follow-up response to Case No. 0123, Crisis in Government Attachment C - Proposed Council Policy Chapter 3.15
Attachment D - Admin Dir HR-64
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47 2023- 2024 San Joaquin County Civil Grand Jury
City of Stockton Crisis in Government
Case #0123
Summary
The 2022–2023 Civil Grand Jury initiated an investigation into potential Brown Act violations by members of the Stockton City Council. The 2023–2024 Civil Grand Jury continued this inquiry and investigated complaints of a hostile and ineffective work environment within the Stockton City Government.

This report contains the responses to the 2023-2024 San Joaquin County Civil Grand Jury report #0123: The City of Stockton: Government in Crisis, along with the 2024-2025 Civil Grand Jury follow-up determinations to the compliance of those responses. Agency responses are italicized, followed by the 2024-2025 determinations.

The Civil Grand Jury finds that the Stockton City Council has not complied with California Penal Code Sections 933(c) and 933.05(b).

Attachment A
48 Section 933 (c) states, “No later than 90 days after the grand jury submits a final report on the operations of any public agency subject to its reviewing authority, the governing body of the public agency shall comment to the presiding judge of the superior court on the findings and recommendations pertaining to matters under the control of the governing body, and every elected county officer or agency head for which the grand jury has responsibility pursuant to Section 914.1 shall comment within 60 days to the presiding judge of the superior court, with an information copy sent to the board of supervisors, on the findings and recommendations pertaining to matters under the control of that county officer or agency head and any agency or agencies which that officer or agency head supervises or controls. In any city and county, the mayor shall also comment on the findings and recommendations. All of these comments and reports shall forthwith be submitted to the presiding judge of the superior court who impaneled the grand jury…” For purposes of 933.05 subdivision (b), each grand jury recommendation, the responding person or entity shall report one of the following actions:
(1) The recommendation has been implemented, with a summary regarding the implemented action.
(2) The recommendation has not yet been implemented, but will be implemented in the future, with a timeframe for implementation.
(3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a timeframe for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This timeframe shall not exceed six months from the date of publication of the grand jury report.
(4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefor.

In addition, the Council’s actions have obstructed the Civil Grand Jury’s efforts to evaluate public agency accountability and transparency, thereby eroding public trust in local government.

Attachment A
49 Complete copies of the original report and the agency’s responses may be found on the San Joaquin County Civil Grand Jury website at:
https://www.sjcourts.org/divisions/civil-grand-jury/
Method of Follow-up Investigation
Reviewed responses from:

• City of Stockton, Letters dated August 21, 2024, and September 4, 2024 • City of Stockton City Council Meeting Agenda for May 13, 2025 • City of Stockton Email to Civil Grand Jury dated May 20, 2025 • City of Stockton Second Grand Jury Follow-up response to the San Joaquin Grand Jury dated May 14, 2025
• City of Stockton Draft Minutes City Council Meeting dated June 3, 2025 The table below shows a summary of the responses:

Respondent # Recommendation Response Grand Jury Conclusion Stockton
City Council

1.1 Stop enabling SMP Not implemented See 2024-2025
Recommendation 1

1.2 Rules for handling
unlawful threats Not implemented See 2024-2025 Recommendation 1.2

1.3 Adopt ordinance
for election
transparency
Not implemented See 2024-2025
Recommendation 1.3

1.4 Stop agendizing
performance
reviews
Implemented No further action

1.5 Form 700 available
online to public Implemented No further action

1.6 Standardize
employment rules
in Mayor’s Office
Not implemented
Next year’s Civil Grand Jury
will follow up to ensure full
compliance

2.1 Amend closed
session policies Implemented No further action

2.2 Develop ordinance
regarding Brown
Act violators
Implemented No further action
Attachment A
50 Respondent # Recommendation Response Grand Jury Conclusion

2.3 Policy that Brown
Act violations
released to Grand
Jury within 7 days
Not implemented See 2024-2025
Recommendation 2.3

2.4 Amend policy
regarding use of
City Stationary
Implemented No further action

3.1 Investigate City’s
Ethics Hotline Not implemented See 2024-2025 Recommendation 3.1 Threatening Work Environment Recommendations
R1.1: By September 1, 2024, the City Council should stop enabling the SMP from interfering with effective city government through their continued association and/or support of individuals associated with the SMP.
8-21-24 Agency response: The City Council acknowledges the 2023-2024 Grand Jury recommendation.

F1.1: The 2024–2025 Civil Grand Jury determined the Stockton City Council did not respond in accordance with California Penal Code 933.05(b).

R1.1: By October 1, 2025, the Stockton City Council should stop allowing outside influences to interfere with city government through their ongoing association with individuals connected to them.

R1.2: By March 31, 2025, the City Council should adopt rules for handling unlawful threatening Communications received by City officials and employees. Unlawful threats, not covered under the First Amendment, should be referred to the District Attorney’s office.
8-21-24 Agency response: The City’s Charter Officers (Manager, Attorney, Auditor, and Clerk) plan to work together, in coordination with the City Council’s Audit and Legislative Committees, to discuss and prepare appropriate and relevant draft policies for review and approval by the full Council no later than March 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in April of 2025.

Attachment A
51 5-14-24 Agency response: The City’s Charter Officers (Clerk and Attorney) will work together, in coordination with the City Council’s Legislation Committee, to discuss and prepare appropriate and relevant draft policies for review and approval by the full Council no later than August 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in September 2025.

F1.2: The 2024-2025 Civil Grand Jury found the Stockton City Council did not comply with California Penal Code Sections 933(c) and 933.05(b).

R1.2: By October 1, 2025, the Stockton City Council should establish a policy for addressing threatening communications directed at City officials and employees. The policy should include forwarding threats to the District Attorney’s office.

R1.3: By March 31, 2025, the City should adopt an ordinance similar to the City of San Francisco Campaign and Governmental Conduct Code Section 1500 et seq., to strengthen election transparency. That ordinance requires political consultants and candidates to file reports directly to the City in all municipal elections listing business relationships, financial investments, and who they pay for political help or receive in-kind support from, as well as indicating whom they provide support to in elections. 8-21-24 Agency response: The Interim City Clerk brought this item to the City Council’s Legislative and Environmental Committee for an introductory discussion, on July 17, 2024, as item 3.2 (agenda). The Committee members discussed and provided to staff feedback, including consideration of the above-mentioned code language from the City of San Francisco. This item will continue to be updated under the direction of the Council Committee before being finalized to go to the full Council for approval and adoption. Supporting documents from the July 17th Committee meeting are included as Attachment R1.3.

F1.3: On July 17, 2024, the Stockton City Council’s Legislative and Environmental Committee held an introductory discussion regarding a proposed policy to strengthen election transparency, with input from the Interim City Clerk and staff. While the Committee reviewed sample language from the City of San Francisco and provided feedback, the policy is still under development. It has not yet been finalized or submitted to the full Council for adoption.

R1.3: By October 1, 2025, the Stockton City Council should develop a policy on election transparency.

Attachment A
52 R1.4: By March 31, 2025, the City should stop the practice of agendizing Chartered Officers performance reviews on an ongoing basis but set them annually or for specific situations which require notice by law.
8-21-24 Agency response: The City Council provided direction to cease the agendization of Chartered Officers performance reviews on an ongoing basis and instead set them annually and for specific situations which require notice by law.

The 2024-2025 Civil Grand Jury determined to take no further action.

R1.5: By March 31, 2025, the City should amend its policies and procedures to make all Form 700 filings available to the public online.
8-21-24 Agency response: The City agrees with this recommendation. As such, the Interim City Clerk notified staff of the updates to the public’s ability to access Form 700 information online, via memo on June 24, 2024(Attachment 1.5). Links to the Public Portal are now available on the Clerk’s webpage on the city website, under the Fair Political Practices Commission (FPPC) tab.

The 2024-2025 Civil Grand Jury determined to take no further action.

R1.6: By March 31, 2025, the City shall enact a policy that all employees of the Mayor’s office be under the same mandated employment rules and laws as the rest of the City staff.
8-21-24 Agency response: The City’s Charter Officers (Manager, Attorney, Auditor, and Clerk) plan to work together, in coordination with the City Council’s Audit and Legislative Committees, to discuss and prepare appropriate and relevant draft policies for review and approval by the full Council no later than March 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in April of 2025.
5-14-25 Agency response: The City Council acknowledges the Grand Jury’s recommendation R1.6. However, the recommendation and report do not contain sufficient information to response other than as follows:

Under City of Stockton Charter section 1102(n) all the Mayor’s appointees “shall serve at the pleasure of the Mayor in the unclassified service; and shall serve under such terms and conditions, salaries and benefits as are similar to other unclassified employees.” All unclassified, at-will employees of the City must adhere to all applicable employment rules and laws.

Attachment A
53 F1.6: The Civil Grand Jury finds the Stockton City Council did not comply with California Penal Code Sections 933(c) and 933.05(b).

The 2024-2025 Civil Grand Jury recommends the 2025-2026 Civil Grand Jury follow up to ensure full compliance.

Brown Act Recommendations
R2.1: By March 31, 2025, the City should amend its Closed Session policies and procedures to minimize the risk of revealing confidential information. There should be a requirement that no phone, electronic communication or recording devices be allowed in the room when it is a Closed Session. Additionally, each attendee should sign a pledge of secrecy on entering each meeting as an immediate and continual reminder that the rules of the Brown Act apply.

8-21-24 Agency response: The City Attorney is scheduled to introduce draft language related to use of cellphone and technology to the Council Legislative Committee meeting on August 28, 2024, for discussion and feedback. This item will continue to be updated under the direction of the Council Committee before being finalized to go to the full Council for approval and adoption before March 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in April 2025. 5-14-25 Agency response: The City Attorney brought this item to the City Council’s Legislation Committee for an introductory discussion on August 28, 2024, as item

3.8. The Committee members discussed, provided feedback, and directed staff to bring it back to the Committee for further discussion. The item was brought back on October 23, 2024, as item 3.2 and staff were directed to forward a recommendation for Council consideration. The item was presented to the full council on November 19, 2024, and was adopted under Resolution 2024-11-19-1218 (Attachment R2.2).

Additionally, each councilmember (former and current), signed closed session acknowledgement forms. Current council acknowledgments are attached (Attachment R2.1) Former council acknowledgments can be provided if needed.

The 2024-2025 Civil Grand Jury determined to take no further action.

R2.2: By March 31, 2025, the City shall develop a City Ordinance regarding Brown Act violators that includes an impartial process for determining whether the Brown Act confidentiality requirement related to Closed Session has been violated and appropriate Attachment A
54 sanctions for the violator, including but not limited to, mandatory public censure and removal from committees and commissions.
8-21-24 Agency response: The City Attorney is scheduled to introduce draft language related to censure and discipline to the Council Legislative Committee meeting on August 28, 2024 for discussion and feedback. A separate discussion will be planned related to handling Brown Act vilations[sic] or violators. These item[sic] will continue to be updated under the direction of the Council Committee before being finalized to go to the full Council for approval and adoption before March 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in April of 2025.
5-14-25 Agency response: The City Attorney brought this item to the City Council’s Legislation Committee for an introductory discussion on August 28, 2024, as item

3.8. The Committee members discussed, provided feedback, and directed staff to bring it back to the Committee for further discussion. The item was brought back on October 23, 2024, as item 3.2 and staff was directed to forward a recommendation for Council consideration. The item was presented to the full council on November 19, 2024, and was adopted under Resolution 2024-11-19-1218 (Attachment R2.2).

The 2024-2025 Civil Grand Jury determined to take no further action.

R2.3: By March 31, 2025, the City shall enact a policy that all findings of Brown Act violations investigations must be released to the Civil Grand Jury within seven days of receipt by the Council.
8-21-24 Agency response: The City’s Charter Officers (Manager, Attorney, Auditor, and Clerk) plan to work together, in coordination with the City Council’s Audit and Legislative Committees, to discuss and prepare appropriate and relevant draft policies for review and approval by the full Council no later than March 31, 2025. A progress update will be provided to the Grand Jury and Presiding Judge in April of 2025.
5-14-25 Agency response: The City’s Charter Officers (Clerk and Attorney) will work together, in coordination with appropriate City Council Committees, to discuss appropriate and relevant policies. A progress update will be provided to the Grand Jury and Presiding Judge in September 2025.

Finding 2.3: The Civil Grand Jury finds the Stockton City Council did not comply with California Penal Code Sections 933(c) and 933.05(b).

Attachment A
55 R2.3: By October 1, 2025, the Stockton City Council shall enact a policy requiring all findings from investigations into alleged Brown Act violations to be submitted to the Civil Grand Jury within seven days of receipt by the Council.

R2.4: By March 31, 2025, the City should amend their policies and procedures regarding the use of City stationery.
8-21-24 Agency response: In April of 2024, The Stockton City Council directed the City Manager and City Attorney to work with the Council Legislative Committee to draft a policy addressing concerns regarding the use of City letterhead. Stockton City Council policy 2.06- Council Communications was revised to add a new section, Policy 2.06.020 – Use of City Letterhead. This Council Policy was approved by the full Stockton City Council at its June 18, 2024 meeting as consent item 12.4, under Resolution 2024-06-18-1204. A copy of the staff report, resolution, and related attachments have been included in Attachment R2.4.

The 2024-2025 Civil Grand Jury reviewed Policy 2.06.020. It states, "City letterhead" and/or "City resources" (i.e., staff support, postage, etc.), may only be used to communicate the official policy, position, or actions of the City or City Council, not individual Councilmember positions or opinions…No Councilmember may use the City letterhead for the purpose of press release, news release, or communications with the media.”
The 2024-2025 Civil Grand Jury determined to take no further action.

Grievance Process Recommendations
R3.1: By March 31, 2025, the City shall hire an independent third party to investigate the City’s Ethics Hotline process to regain employee and public trust in the system. 8-21-24 Agency response: The City Attorney, with assistance from the City Auditor and City Manager, will engage an independent third party to assess the ethics hotline process. A progress update will be provided to the Grand Jury and Presiding Judge in April of 2025.
5-14-25 Agency response: The City Attorney, with assistance from relevant Charter Officers, will present for Council consideration, the engagement of an independent Attachment A
56 third party to monitor and reply to the City’s ethics hotline. A progress update will be provided to the Grand Jury and Presiding Judge in September 2025.

F3.1: The Civil Grand Jury finds the Stockton City Council did not comply with California Penal Code Sections 933(c) and 933.05(b).

R3.1: By October 1, 2025, the Stockton City Council shall hire an independent third party to investigate the City’s Ethics Hotline process to regain employee and public trust in the system.

Disclaimers
Civil Grand Jury reports are based on documentary evidence and the testimony of sworn or admonished witnesses, not on conjecture or opinion. However, the Civil Grand Jury is precluded by law from disclosing such evidence except upon the specific approval of the Presiding Judge of the Superior Court, or another judge appointed by the Presiding Judge (Penal Code Section 911. 924.1 (a) and 929). Similarly, the Civil Grand Jury is precluded by law from disclosing the identity of witnesses except upon an order of the court for narrowly defined purposes (Penal Code Sections 924.2 and 929).

One member of the 2024–2025 San Joaquin County Civil Grand Jury was recused from all phases of this report.

Response Requirements
Responding Agency Finding and Recommendation Respond By City of Stockton
F1.1, R1.1
October 1, 2025
F1.2, R1.2
F1.3, R1.3
F2.3, R2.3
F3.1, R3.1
California Penal Code Sections 933 and 933.05 require that specific responses to all findings and recommendations contained in this report be submitted to the Presiding Judge of the San Joaquin County Superior Court within 90 days of receipt of the report.

Attachment A
57 Note: If the responder is an elected official, the response must be sent within 60 days of receipt.

Mail or hand deliver a hard copy of the response to:

Honorable Gus C. Barrera II, Presiding Judge
San Joaquin County Superior Court
180 E Weber Ave, Suite 1306J
Stockton, California 95202
Also, please email a copy of the response to Irving Jimenez, Staff Secretary to the Civil Grand Jury, at [email protected].

Attachment A

Page 1 of 3 ends

September x, 2025 Via Email:
[email protected]
Honorable Gus C. Barrerra II, Presiding Judge
San Joaquin County Superior Court
180 E. Weber Ave, Suite 1306J
Stockton, CA 95202
CITY OF STOCKTON THIRD FOLLOW-UP RESPONSE TO 2023-24 SAN JOAQUIN COUNTY CIVIL GRAND JURY REPORT “CITY OF STOCKTON: CRISIS IN GOVERNMENT” CASE NO. 0123
The City of Stockton received the above-named Grand Jury report on Monday, June 10, 2024. In accordance with Sections 933 and 933.05 of the California Penal Code, specific responses to all findings and recommendations contained in the report are to be submitted to the Presiding Judge of the San Joaquin County Superior Court within 90 days of receipt of the report.

The City of Stockton, and the Stockton City Council accepted the 2023-24 San Joaquin County Civil Grand Jury Report titled “City of Stockton: Crisis in City Government, Case No. 0123” on August 20, 2024, and acknowledged all findings contained within: F1.1 thru F1.6, F2.1 thru F2.6, and F3.1. Initial responses were provided with a commitment to providing follow-up responses on those items still in progress.

The City and Council of the City of Stockton offer these follow-up responses, broken out by area of investigation as outlined in the report for the remaining Grand Jury recommendations not addressed in the last response.

These responses were presented to the City Council for consideration and approval during its public meeting on September x, 2025, and approved by motion 2025-09-xxxxxx. //
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ATTACHMENT B

Page 2 of 3 ends

1. Threatening Work Environment
Recommendations & Responses:

R1.2 By October 1, 2025, the Stockton City Council should establish a policy for addressing threatening communications directed at City officials and employees.

The policy should include forwarding threats to the District Attorney’s office.

CITY RESPONSE:

The City Acknowledges the Grand Jury’s recommendation R1.2. City of Stockton Administrative Directive HR-64 – Workplace Violence Crisis Management Policy, addresses the procedure for handling threats received by City Official and employees. The city further developed written Workplace Violence Prevention Plans in accordance with guidance received from Cal/OSHA.

2. Brown Act
Recommendations & Responses:

R2.3 By October 1, 2025, the Stockton City Council shall enact a policy requiring all findings from investigations into alleged Brown Act violations to be submitted to the Civil Grand Jury within seven days of receipt by the Council.

CITY RESPONSE:

Via Resolution 2025-09-xx-xxxx the City Council has adopted Council Policy Manual Chapter 3.15, Brown Act Investigations. The policy provides: “If by majority vote the City Council orders an investigation into alleged Brown Act violation(s), all findings from the investigation regarding the alleged Brown Act violation(s) shall be submitted to the Civil Grand Jury within seven (7) days of receipt by the City Council.”

3. Grievance Process
Recommendations & Responses:

R3.1 By October 1, 2025, the Stockton City Council shall hire an independent third party to investigate the City’s Ethics Hotline process to regain employee and public trust in the system.

CITY RESPONSE:

The City Acknowledges the Grand Jury’s recommendation R3.1 and the importance of ensuring employees have confidence in the City’s Ethics Hotline process. The Ethics Hotline is currently maintained by the Stockton City Attorney’s Office. The City of Stockton will work internally to review the current

ATTACHMENT B

Page 3 of 3 ends

process to ensure that the Stockton City Attorney’s Office can adequately maintain the system and preserve confidence in the system. Provided the City is assured of this, the functions and review of the Ethics Hotline will be retained internal to the City.

OR
R3.1 By October 1, 2025, the Stockton City Council shall hire an independent third party to investigate the City’s Ethics Hotline process to regain employee and public trust in the system.

CITY RESPONSE:

CITY ATTORNEY

ATTACHMENT B

ATTACHMENT C
CHAPTER 3.15
Brown Act Investigations
§ 3.15.010. Policy.

If by majority vote the City Council orders an investigation into alleged Brown Act violation(s), all findings from the investigation regarding the alleged Brown Act violation(s) shall be submitted to the Civil Grand Jury within seven (7) days of receipt by the City Council.

The City retains the sole discretion to determine whether to initiate, conduct, and finance investigations into any alleged Brown Act violation(s).

Notwithstanding the above, absent a City-conducted investigation, alleged Brown Act violation(s) may still be referred to the Civil Grand Jury in accordance with the Civil Grand Jury’s standard procedures.
§ 3.15.020. Responsibilities.

City Council: As appropriate, direct staff to retain investigation services for the investigation of alleged Brown Act violation(s) and submit findings to the Civil Grand Jury within seven (7) days of receipt of any investigation findings.
§ 3.15.030. Relevant authority.
https://www.sjcourts.org/divisions/civil-grand-jury/
§ 3.15.040. Related administrative directive, city policy, city procedure.

N/A
§ 3.15.050. Related forms, documents, or links.

N/A
§ 3.01.060. Frequently asked questions.

N/A
§ 3.01.070. Update history.

N/A

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
Subject: Directive No. HR-64 Page No.1 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A
I. PURPOSE
To describe and prohibit workplace violence; establish protocol and procedures for reducing the potential for such violence; and to identify security contacts and reporting procedures for employees to report violence, threats of violence, harassment, and intimidation in the workplace.

II. POLICY
A. The City does not tolerate violent behavior or threats of violence in the workplace. Any violent behavior related to the employee's work or work relationships, whether an employee is on or off duty, on or off City property or City work places, is strictly prohibited.

B. Employees engaging in work place violence shall be subject to the provisions of HR-08 - Discipline Policy.

III. DEFINITIONS
A. Crisis Management Team (CMT): Interdepartmental group convened to evaluate and address specific instances of violence or threats of violence in the workplace. A CMT shall consist of management personnel from Human Resources, Risk Management, the Police Department, the City Attorney's Office, and the department or departments directly impacted by the incident.

B. Intimidation: Inspiring fear in a person or inhibiting the speech or actions of a person by the display, promise, or threat of violence.

C. Threat: An expression of intent to inflict pain or injury on a person or damage to an object or property. Threats may be explicit ("I'll get you for this later" or "I'll kill you if you report me") or implied ("bad things are going to happen to him" or "that propane tank on the back of his truck could sure blow up easily"). Threats also include stalking. Conflicts and disagreements commonly occur in the workplace and do not, by themselves, represent threats of violence.

D. Third Parties: Individuals who are not City employees or volunteers, including, but not limited to, contractors and vendors, visitors, and friends or relatives of employees or volunteers.

E. Workplace: Any location, either permanent or temporary, where City business is conducted, including City buildings and property, other assigned

ATTACHMENT D

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
Subject: Directive No. HR·64 Page No. 2 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A
work locations, including off-site training locales, City vehicles, and private vehicles while used for City business.

F. Workplace Violence: Any physical assault, threatening behavior, or verbal abuse occurring in the workplace by employees, volunteers, or third parties.

Examples of behavior prohibited by this policy include, but are not limited to:

1. Physically injuring another person

2. Engaging in behavior that creates a reasonable fear of injury

3. Engaging in behavior that subjects another individual to extreme emotional distress

4. Verbally abusive or intimidating language or gestures

5. Threatening, abusive, or harassing communications

6. Possessing, brandishing, or using a dangerous or deadly weapon, unless an employee is required or authorized to do so

7. Possession of imitation weapons

8. Intentionally damaging or threatening to damage City property or property of an employee

9. Engaging in intrusive behavior, such as stalking, spying on, or harassing an individual
IV. IMPLEMENTATION
A. Employee Responsibilities
Every employee has the responsibility to report immediately to his or her supervisor or department safety representative any violations of this policy.

This includes employees who are aware of actual violence, as well as those who are aware of threats of violence that may cause a risk of harm to an employee or others in the workplace.

B. Departmental Responsibilities

1. Workplace Safety

ATTACHMENT D

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
Subject: Directive No. HR-64 Page No. 3 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A
Every department head is responsible for assessing the potential for violence and taking measures to maintain workplace safety.

Supervisors/managers are responsible for monitoring the workplace and immediately addressing any violent behavior and appropriately evaluating any threatening conduct, even if the person engaged in the behavior or conduct is not a subordinate, or even if the supervisors/managers have not received a complaint.

2. Training
The City will provide mandatory training for supervisors and managers on this policy and the prevention of violence in the workplace.

Department heads are responsible for periodically providing their staff with information about the prevention and management of violence in the workplace.

3. Department Response to Violence
When a supervisor, manager, or departmental safety representative becomes aware of a violent act or the threat of violence, he or she must make an immediate evaluation of the severity of situation and take appropriate action. (See Appendix A, "Protocol for Responding to Workplace Violence.")
a. If there is a likelihood of immediate violence or a violent act has already occurred:
(1) Call 911 and if necessary and possible under the
circumstances, evacuate.
• From a city phone, dial 9-911
• If evacuation is necessary and possible, proceed in
accordance with the building disaster plan.
(2) Notify the department head or other designated person in the chain of command. Contact Human Resources at
937-8233. Human Resources will activate the Crisis
Management Team.
(3) Participate in developing and enforcing a plan of action

ATTACHMENT D

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
SUbject: Directive No. HR-64 Page No.4 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A
with the Crisis Management Team.
(4) Conduct further investigation, as necessary, and
document incident. (See attached "Risk Assessment
Report.")
b. If there is a threat of violence that is not immediate:
(1) Notify the department head or other designated person in the chain of command. Contact Human Resources at
937-8233. If appropriate, Human Resources will
activate the Crisis Management Team. If the incident
occurs after business hours, call the Police Department at 937-8377(non-emergency number).
(2) Conduct a preliminary inquiry to ascertain the basic facts and the key persons with information about the
threat. Document findings. (See attached "Risk
Assessment Report.")
(3) If required, participate in developing and enforcing the plan of action with the Crisis Management Team.
(4) Conduct further investigation, if required by the CMT, and document investigative findings.
c. If there is no credible threat of violence:
(1) Complete necessary investigation.
(2) Document incident.

APPROVED:
::ODMAIGRPWISEICOS.CM.CM_L1BRARY:80823.1

ATTACHMENT D

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
Subject: Directive No. HR-64 Page No. 5 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A
Appendix A
Protocol for Responding 10 Workplace Violence
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Ilecessfuy Cltll,l dOl;UlIltml
incidont.

ATTACHMENT D
CITY OF STOCKTON. CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
SUbject: Directive No. HR-64 Page No. 6 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A

CONFIDENTIAL
DatelTime Completed: _
Other Factors (circle and be prepared to explain)
Finances Domestic Drug/Alcohol History of Violence/Disruptive Behavior Possession of Weapons Anxiety/Depression Behavior Changes Restraining Order Health Work Issues Death of Family Member Other
Explanation: _
Has Law Enforcement been notified: If so, whom? _

INSTRUCTIONS
Employee/Citizen Data
Enter the name of the person who is making the threat and/or has already instigated an act of violence. If the person is a City employee, fill out the remainder of this section with the appropriate information. Be sure to include the D.O.B (date of birth). If the person is not a City employee, use a separate sheet of paper to list the citizen's address, phone number, and date of birth, if known.

Threat/Act of Violence
If there is more than one witness, attach additional sheets.

Check all that apply and be specific as possible.

An act of sabotage is the willful destruction of property or other action that hinders the normal business operations of the City. Acts of violence include physical contact, such as pushing, grabbing, hitting, and inappropriate touching. Other physical actions that are threatening include hitting or throwing an object, slamming fists, violent gestures, and possession of weapons. Verbal threats may include direct threats to harm someone, threats to use a weapon, repeated references to weapons and violence, and harassing statements. If the threat was verbal, document exactly what was said. If the threat was left on voicemail, save and transcribe the message. Implied threats include indirect references to harming someone or actions that suggest the intent to harm, such as saying, "Something bad may happen to you" or showing someone a photograph depicting violence.

Other Factors
Circle all that apply and explain how they relate to the incident. Use additional sheets If necessary.

If Law Enforcement has been notified, state who (e.g., Stockton PO, Sheriff, CHP).

ATTACHMENT D
ClassificatiDn: _

CITY OF STOCKTON, CALIFORNIA

CITY MANAGER ADMINISTRATIVE DIRECTIVE
Subject: Directive No. HR-64 Page No. 7 of 7

WORKPLACE VIOLENCE CRISIS
MANAGEMENT POLICY Effective date: Revised from:
7/27/09 N/A

CONFIDENTIAL

RISK ASSESSMENT REPORT
(See instructions on reverse)
Employee/Citizen Data
Name: -=.---:-::-::-:-::--;----,- ,D.O.B. ---,-.,.----;--=----,-.,.---__ First Middle Last Month Day Year
Yrs. of City Svc: _
Department: Work Location: _
Specific Job Function(s): _
Supervisor's Name and Contact Number: _
Victim's Name: Phone: _
Classification: Department: _
Work Location(s): _
Specific Job Function(s): _
Supervisor Name and Contact Number: _
Manager Name and Contact Number: _
Threat(s)/Act(s) of Violence
Date and Time Threat Made/Act Occurred: Location: _
Name/Contact Number of Reporting Employee/Citizen: _
Name/Contact Number of Witness: _
Type of AcVThreat: 0 Act of Sabotage 0 Physical Contact 0 Other Physical Actions o Verbal Threat 0 Implied Threat 0 Other
Detailed Description of AcVThreat:

ATTACHMENT D
City of Stockton
Legislation Text
File #: 25-1005, Version: 1

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