16 Staff Report.Award of Bio Monitoring Contractwith Attachments
PREPARED BY: Nicolle Burnham
Parks and Public Works Director
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, and Finance Director
110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6832
www.losgatosca.gov
TOWN OF LOS GATOS
COUNCIL AGENDA REPORT
MEETING DATE: 08/06/2024 ITEM NO: 16
DATE: August 1, 2024
TO: Mayor and Town Council
FROM: Laurel Prevetti, Town Manager
SUBJECT: Vegetation Management – Townwide Open Spaces Project (CIP No. 832-
4508):
a. Adopt the “Vegetation Management Plan for the Town of Los Gatos,
Santa Clara County, California” Dated June 2021;
b. Adopt the Findings of the Project Specific Analysis and Addendum to the
Programmatic Environmental Impact Report for the California Vegetation
Treatment Program, Including the Mitigation and Monitoring Reporting
Program;
c. Authorize the Town Manager to Execute an Agreement for Services with
Sequoia Ecological Consulting in the Amount of $181,165 for the
Vegetation Management – Townwide Open Spaces Project (CIP No. 832-
4508); and
d. Authorize Revenue and Expenditure Budget Adjustments to the
Vegetation Management – Townwide Open Spaces Project (CIP No. 832-
4508) to Recognize Receipt and Expenditure of FEMA Hazard Mitigation
Grant Program (HMPG) Funds in the Amount of $1,591,344.75 for the 75
Percent Federal Share of the Project Costs and $35,974.97 for the 100
Percent Federal Share of Subrecipient Management Costs (SRMC).
RECOMMENDATION:
Vegetation Management – Townwide Open Spaces Project (CIP No. 832-4508):
a. Adopt the “Vegetation Management Plan for the Town of Los Gatos, Santa Clara County,
California” dated June 2021;
PAGE 2 OF 4 SUBJECT: Vegetation Management Townwide Open Spaces Project (CIP 832-4508) DATE: August 1, 2024
RECOMMENDATION (continued):
b. Adopt the Findings of the Project Specific Analysis and Addendum to the Programmatic
Environmental Impact Report for the California Vegetation Treatment Program, including
the Mitigivation and Monitoring Reporting Program;
c. Authorize the Town Manager to execute an Agreement for Services (Attachment 1) with
Sequoia Ecological Consulting in the amount of $181,165 for the Vegetation Management –
Townwide Open Spaces Project (CIP No. 832-4508); and
d. Authorize revenue and expenditure budget adjustments to the Vegetation Management –
Townwide Open Spaces Project (CIP No. 832-4508) to recognize receipt and expenditure of
FEMA Hazard Mitigation Grant Program (HMPG) funds in the amount of $1,591,344.75 for
the 75 percent Federal share of the project costs and $35,974.97 for the 100 percent
Federal share of Subrecipient Management Costs (SRMC).
BACKGROUND:
The Town of Los Gatos has been working on developing and implementing a vegetation
management program since 2020. To support this work, the Town was awarded funding
through the Federal Emergency Management Agency’s (FEMA) Hazard Mitigation Grant
Program for vegetation management in the Town-owned open spaces of La Rinconada Park,
Worcester Park, Novitiate Park, Heintz Open Space, and Santa Rosa Open Space.
The FEMA grant was awarded in two phases: Phase 1 partially funded development of a
document entitled “Vegetation Management Plan for the Town of Los Gatos, Santa Clara
County, California” (the Plan) dated June 2021 (Attachment 4) and the associated
environmental assessment which was completed in August 2023. Phase 2 funds the execution
of the Plan. While FEMA awards grants in a full amount, the funding is not available to the
grant recipient until FEMA formally “obligates” the money. FEMA obligates its grant funding by
project phase so, although the grant award was made in late 2019, the Phase 2 funds were
made available to the Town in fall of 2023. Attachment 2 is the FEMA award letter for Phase 2.
In addition to the FEMA funding, the Town has allocated matching funds for the required 25
percent match.
DISCUSSION:
While vegetation management along roadsides and in certain high fire hazard areas can be
performed under the Program Environmental Impact Report (PEIR) of the California Vegetation
Treatment Program (CalVTP). Portions of Los Gatos’ open space areas identified for fire-related
vegetation management are outside of the geographic area covered in the CalVTP. To address
this, the CalVTP has been supplemented for Los Gatos through a Project Specific Analysis (PSA)
PAGE 3 OF 4 SUBJECT: Vegetation Management Townwide Open Spaces Project (CIP 832-4508) DATE: August 1, 2024
DISCUSSION (continued):
and Addendum to the PEIR (Attachment 3). With the Plan and environmental analysis
complete, staff is recommending that Town Council formally adopt the Plan and CEQA findings.
The PEIR, PSA, and Addendum include biological monitoring of certain aspects of the vegetation
management work to protect habitats within the open space areas. The need for this
monitoring necessitated the services of a qualified biologist.
On May 31, 2024, the Town issued a Request for Proposals (RFP) seeking the services of a
qualified biologist to support environmental compliance during open space vegetation
management. The request for proposals was posted on the BidNet bidding portal where it
could be viewed by vendors nationally. The Town’s on-call list of environmental consultants
was also notified of the availability of the RFP. Proposals were due on June 27, 2024 and two
submittals were received. After staff review of the proposals, Sequoia Ecological Consulting
was found to be the most qualified company for this work. The second bidder did not provide
complete documentation and did not appear to be qualified to perform the work.
The Phase Two grant revenue could not be recognized by the Town until the FEMA obligation
was made per the letter in Attachment 2. With this Council action staff is recognizing the grant
revenue so it can be allocated to the project and used to fund future work.
CONCLUSION:
With the requested Town Council action, the Town will formally adopt its Vegetation
Management Plan and associated environmental analysis. These are key steps in the process to
implementing the wildfire management work that has been identified as a priority.
Staff recommends awarding the agreement for biological monitoring of vegetation
management in Town-owned Open Spaces to Sequoia Consulting Group and to recognize FEMA
HMGP funds for the Vegetation Management – Townwide Open Spaces Project (CIP No. 832-
4508). Awarding this contract is the next step in implementing the Vegetation Management
Plan for the Town-owned open spaces.
COORDINATION:
This project has been coordinated with the Finance Department and with the Community
Development Department.
PAGE 4 OF 4 SUBJECT: Vegetation Management Townwide Open Spaces Project (CIP 832-4508) DATE: August 1, 2024
FISCAL IMPACT:
The fiscal table below reflects the budget for Phase 2 of this project, including the requested
FEMA Hazard Mitigation Grant Program funds.
ENVIRONMENTAL ASSESSMENT:
The Project Specific Analysis and Addendum concluded that all of the effects of the proposed
project: (a) have been covered in the CalVTP PEIR; and (b) all applicable Standard Project
Requirements and mitigation measures identified in the CalVTP PEIR will be implemented. The
proposed project is, therefore, within the scope of the CalVTP PEIR. No additional CEQA
documentation is required.
Attachments:
1. Agreement for Consultant Services with Exhibit A
2. Application Approval, HMGP DR-4407-506-75R
3. Los Gatos VMP CalVTP Addendum
4. Link to the Vegetation Management Plan for the Town of Los Gatos, Santa Clara County,
California dated June 2021
Budget Costs
Phase 2 - Source of Funds
GFAR 530,448$
FEMA Hazard Mitigation Grant (Requested with this Staff Report)1,627,320$
Total Budget 2,157,768$
Costs
Phase 2 - Expenditures
Consultant Services Agreement with Sequoia Ecological Consulting
(Requested with this Staff Report)181,165$
Total Expenditures 181,165$
Total Project Balance 1,976,603$
Vegetation Management - Town-wide
CIP No. 832-4508
Agreement of Consultant Services ATTACHMENT 1
Sequoia Consulting Group Page 1 of 17
AGREEMENT FOR CONSULTANT SERVICES
PREAMBLE
THIS AGREEMENT is dated for identification on August 6, 2024 by and between TOWN OF LOS
GATOS, a California municipal corporation, (“Town”) and Sequoia Consulting Group
(“Consultant”), identified as an S Corporation and whose address is 1342 Creekside Drive, Walnut
Creek, CA 94596. This Agreement is made with reference to the following facts.
I. RECITALS
1.1 The Town desires to engage Consultant to provide environmental consulting services in
support of wildfire related vegetation management in Town owned open spaces.
1.2 The Consultant represents and affirms that it is willing to perform the desired work
pursuant to this Agreement.
1.3 Consultant warrants it possesses the distinct professional skills, qualifications,
experience, and resources necessary to timely perform the services described in this
Agreement. Consultant acknowledges Town has relied upon these warranties to retain
Consultant.
II. AGREEMENT
2.1 Scope of Services. Consultant shall provide services as described in that certain Proposal
sent to the Town on June 27, 2024 which is hereby incorporated as Exhibit A.
2.2 Term and Time of Performance. This contract will remain in effect upon execution to
June 30, 2025.
2.3 Compliance with Laws. The Consultant shall comply with all applicable laws, codes,
ordinances, and regulations of governing federal, state and local laws. Consultant
represents and warrants to Town that it has all licenses, permits, qualifications and
approvals of whatsoever nature which are legally required for Consultant to perform the
services under this Agreement. Consultant shall maintain a Town of Los Gatos business
license pursuant to Chapter 14 of the Code of the Town of Los Gatos.
2.4 Sole Responsibility. Consultant shall be responsible for employing or engaging all persons
necessary to perform the services under this Agreement.
2.5 Information/Report Handling. All documents furnished to Consultant by the Town and all
reports and supportive data prepared by the Consultant under this Agreement are the
Town’s property and shall be delivered to the Town upon the completion of services or
at the Town's written request. All reports, information, data, and exhibits prepared or
Agreement of Consultant Services ATTACHMENT 1
Sequoia Consulting Group Page 2 of 17
assembled by Consultant in connection with the performance of its services pursuant to
this Agreement are confidential until released by the Town to the public, and the
Consultant shall not make any of these documents or information available to any
individual or organization not employed by the Consultant or the Town without the
written consent of the Town before such release. The Town acknowledges that the
reports to be prepared by the Consultant pursuant to this Agreement are for the purpose
of evaluating a defined project, and Town's use of the information contained in the
reports prepared by the Consultant in connection with other projects shall be solely at
Town's risk, unless Consultant expressly consents to such use in writing. Town further
agrees that it will not appropriate any methodology or technique of Consultant which is
and has been confirmed in writing by Consultant to be a trade secret of Consultant.
2.6 Compensation: Compensation for services in the amount not to exceed $181,165,
inclusive of all costs. Payment shall be based upon Town approval of each task and fees
for each task shall not be exceeded without written authorization from the Town.
2.7 Billing. Billing shall be monthly by invoice within thirty (30) days of the rendering of the
service and shall be accompanied by a detailed explanation of the work performed by
whom at what rate and on what date. Also, plans, specifications, documents or other
pertinent materials shall be submitted for Town review, even if only in partial or draft
form.
Payment shall be net thirty (30) days of receipt of the invoice. All invoices and statements
to the Town shall be addressed as follows:
Invoices:
Town of Los Gatos
Attn: Accounts Payable
P.O. Box 655
Los Gatos, CA 95031-0655
Email (preferred): AP@losgatosca.gov
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 3 of 17
2.8 Availability of Records. Consultant shall maintain the records supporting this billing for
not less than three years following completion of the work under this Agreement.
Consultant shall make these records available to authorized personnel of the Town at the
Consultant offices during business hours upon written request of the Town.
2.9 Assignability and Subcontracting. The services to be performed under this Agreement are
unique and personal to the Consultant. No portion of these services shall be assigned or
subcontracted without the written consent of the Town.
2.10 Independent Contractor. It is understood that the Consultant, including each of
Consultant’s employees, agents, subcontractors, or others under Consultant’s supervision
or control, in the performance of the work and services agreed to be performed, shall act
as and be an independent contractor and not an agent or employee of the Town. As an
independent contractor he/she shall not obtain any rights to retirement benefits or other
benefits which accrue to Town employee(s). With prior written consent, the Consultant
may perform some obligations under this Agreement by subcontracting, but may not
delegate ultimate responsibility for performance or assign or transfer interests under this
Agreement. Consultant agrees to testify in any litigation brought regarding the subject of
the work to be performed under this Agreement. Consultant shall be compensated for its
costs and expenses in preparing for, traveling to, and testifying in such matters at its then
current hourly rates of compensation, unless such litigation is brought by Consultant or is
based on allegations of Consultant's negligent performance or wrongdoing.
2.11 Conflict of Interest. Consultant understands that its professional responsibilities are solely
to the Town. The Consultant has and shall not obtain any holding or interest within the
Town of Los Gatos. Consultant has no business holdings or agreements with any individual
member of the Staff or management of the Town or its representatives nor shall it enter
into any such holdings or agreements. In addition, Consultant warrants that it does not
presently and shall not acquire any direct or indirect interest adverse to those of the Town
in the subject of this Agreement, and it shall immediately disassociate itself from such an
interest, should it discover it has done so and shall, at the Town's sole discretion, divest
itself of such interest. Consultant shall not knowingly and shall take reasonable steps to
ensure that it does not employ a person having such an interest in this performance of
this Agreement. If after employment of a person Consultant discovers it has employed a
person with a direct or indirect interest that would conflict with its performance of this
Agreement Consultant shall promptly notify Town of this employment relationship, and
shall, at the Town's sole discretion, sever any such employment relationship.
2.12 Intentionally omitted.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 4 of 17
III. INSURANCE AND INDEMNIFICATION
3.1 Minimum Scope of Insurance:
i. Consultant agrees to have and maintain, for the duration of the
Agreement, General Liability insurance policies insuring him/her and
his/her firm to an amount not less than: two million dollars ($2,000,000)
combined single limit per occurrence and in the aggregate for products and
completed operations, personal and advertising injury, bodily injury,
personal injury and property damage.
ii. Consultant agrees to have and maintain for the duration of the Agreement,
an Automobile Liability insurance policy ensuring him/her and his/her staff
for any, hired, or non-owned vehicles in an amount not less than one
million dollars ($1,000,000) combined single limit per accident for bodily
injury and property damage.
iii. Consultant shall provide to the Town all certificates of insurance, with
original endorsements affecting coverage. Consultant agrees that all
certificates and endorsements are to be received and approved by the
Town before work commences.
General Liability:
i. The Town, its elected and appointed officials, employees, and agents are
to be covered as additional insureds as respects: liability arising out of
activities performed by or on behalf of the Consultant; products and
completed operations of Consultant, premises owned or used by the
Consultant.
ii. The Consultant's insurance coverage shall be primary insurance as respects
the Town, its elected and appointed officials, employees, and agents. Any
insurance or self-insurances maintained by the Town, its officers, officials,
employees or volunteers shall be excess of the Consultant's insurance and
shall not contribute with it.
iii. Any failure to comply with reporting provisions of the policies shall not
affect coverage provided to the Town, its officers, officials, employees or
volunteers.
iv. The Consultant's insurance shall apply separately to each insured against
whom a claim is made or suit is brought, except with respect to the limits
of the insurer's liability.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 5 of 17
3.2 All Coverages. Each insurance policy required in this item shall be endorsed to state that
coverage shall not be suspended, voided, cancelled, reduced in coverage or in limits
except after thirty (30) days' prior written notice by certified mail, return receipt
requested, has been given to the Town. Current certification of such insurance shall be
kept on file at all times during the term of this agreement with the Town Clerk.
3.3 Workers’ Compensation. In addition to these policies, Consultant shall have and maintain
Workers' Compensation insurance as required by California law and shall provide
evidence of such policy to the Town before beginning services under this Agreement.
Further, Consultant shall ensure that all subcontractors employed by Consultant provide
the required Workers' Compensation insurance for their respective employees. As
required by the State of California, with Statutory Limits, and Employer’s Liability
Insurance with limit of no less than one million dollars ($1,000,000) per accident for bodily
injury or disease.
3.4 Indemnification. The Consultant shall save, keep, hold harmless and indemnify and
defend the Town its elected and appointed officials, officers, agents, employees, and
volunteers (“Indemnitees”) from all damages, liabilities, penalties, costs, attorneys’ fees,
or expenses (“Losses”) in law or equity that may at any time arise or be set up because of
damages to property or personal injury or other received by reason of, or in the course of
performing work which may be occasioned by a willful or negligent act or omissions of
the Consultant, or any of the Consultant's officers, employees, or agents or any
subcontractor. The Consultant’s duty to indemnify and hold harmless the Indemnitees
shall not apply to the extent such Losses are caused by the sole or active negligence or
willful misconduct of Indemnitees. Consultant’s obligation to defend shall arise regardless
of any claim or assertion that Indemnitees caused or contributed to the Losses.
IV. GENERAL TERMS
4.1 Waiver. No failure on the part of either party to exercise any right or remedy hereunder
shall operate as a waiver of any other right or remedy that party may have hereunder,
nor does waiver of a breach or default under this Agreement constitute a continuing
waiver of a subsequent breach of the same or any other provision of this Agreement.
4.2 Governing Law. This Agreement, regardless of where executed, shall be governed by and
construed to the laws of the State of California. Venue for any action regarding this
Agreement shall be in the Superior Court of the County of Santa Clara.
4.3 Termination of Agreement. The Town and the Consultant shall have the right to terminate
this agreement with or without cause by giving not less than sixty days (60) written notice
of termination. In the event of termination, the Consultant shall deliver to the Town all
plans, files, documents, reports, performed to date by the Consultant. In the event of such
termination, Town shall pay Consultant an amount that bears the same ratio to the
maximum Agreement price as the work delivered to the Town bears to completed
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 6 of 17
services contemplated under this Agreement, unless such termination is made for cause,
in which event, compensation, if any, shall be adjusted in light of the particular facts and
circumstances involved in such termination.
4.4 Amendment. No modification, waiver, mutual termination, or amendment of this
Agreement is effective unless made in writing and signed by the Town and the Consultant.
4.5 Disputes. In any dispute over any aspect of this Agreement, the prevailing party shall
be entitled to reasonable attorney's fees, including costs of appeal.
4.6 Notices. Any notice required to be given shall be deemed to be duly and properly given
if mailed postage prepaid, and addressed to
Town of Los Gatos
Attn: Town Clerk
110 E. Main Street
Los Gatos, CA 95030
Sequoia Ecological Consulting Inc
Attn: Debie Montana
1342 Creekside Drive,
Walnut Creek, CA 94596
or personally delivered to Consultant to such address or such other address as Consultant
designates in writing to Town.
4.7 Order of Precedence. In the event of any conflict, contradiction, or ambiguity between
the terms and conditions of this Agreement in respect of the Products or Services and any
attachments to this Agreement, then the terms and conditions of this Agreement shall
prevail over attachments or other writings.
4.8 Entire Agreement. This Agreement, including all Exhibits, constitutes the complete and
exclusive statement of the Agreement between the Town and Consultant. No terms,
conditions, understandings or agreements purporting to modify or vary this Agreement,
unless hereafter made in writing and signed by the party to be bound, shall be binding on
either party.
4.9 California Public Records Act. Town is a public agency subject to the disclosure
requirements of the California Public Records Act (“CPRA”). If Consultant’s proprietary
information is contained in documents or information submitted to Town, and Consultant
claims that such information falls within one or more CPRA exemptions, Consultant must
clearly mark such information “Confidential and Proprietary,” and identify the specific
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 7 of 17
lines containing the information. In the event of a request for such information, Town will
make best efforts to provide notice to Consultant prior to such disclosure. If Consultant
contends that any documents are exempt from the CPRA and wishes to prevent
disclosure, it is required to obtain a protective order, injunctive relief, or other
appropriate remedy from a court of law in Santa Clara County before the Town is required
to respond to the CPRA request. If Consultant fails to obtain such remedy within the time
the Town is required to respond to the CPRA request, Town may disclose the requested
information without any liability. Consultant further agrees that it shall defend, indemnify
and hold Town harmless against any claim, action or litigation (including but not limited
to all judgments, costs, and attorney’s fees) that may result from denial by Town of a
CPRA request for information arising from any representation, or any action (or inaction),
by the Consultant.
4.10 Force Majeure. Neither party hereto shall be considered in default in the performance of
its obligation hereunder to the extent that the performance of any such obligation is
prevented or delayed by an act of God, natural disaster, pandemic, acts of terrorism, war,
a strike, lockout or other labor difficulty, or other peril, which is beyond the reasonable
control of the affected party and without the negligence of the respective Parties. Each
party hereto shall give notice promptly to the other of the nature and extent of any Force
Majeure claimed to delay, hinder or prevent performance of the services under this
Agreement. Each Party will, however, make all reasonable efforts to remove or eliminate
such a cause of delay or default and will, upon the cessation of the cause, diligently pursue
performance of its obligations in this Agreement. In the event either party is prevented
or delayed in the performance of its respective obligation by reason of such Force
Majeure, the only remedy is that there may be an equitable adjustment of the schedule
based on Town’s sole discretion.
4.11. Severability. The unenforceability, invalidity or illegality of any provision(s) of this
Agreement shall not render the other provisions unenforceable, invalid or illegal.
4.12 Contract Interpretation. Each party acknowledges that it has reviewed this Agreement
and that the normal rule of construction to the effect that any ambiguities are to be
resolved against the drafting party shall not be employed in the interpretation of this
Agreement.
4.13 Counterparts. The Parties may execute this Agreement in two or more counterparts,
which shall, in the aggregate, be deemed an original but all of which, together, shall
constitute one and the same instrument. A scanned, electronic, facsimile or other copy of
a party’s signature shall be accepted and valid as an original.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 8 of 17
V. FEMA CONTRACT TERMS
5.1 Remedies. Refer to Section IV of this agreement.
5.2 Termination for Cause and Convenience. Refer to Section 4.3 of this agreement.
5.3 Equal Opportunity Employment. During the performance of this contract, the contractor
agrees as follows:
(1) The contractor will not discriminate against any employee or applicant for
employment because of race, color, religion, sex, sexual orientation, gender identity,
or national origin. The contractor will take affirmative action to ensure that applicants
are employed, and that employees are treated during employment without regard to
their race, color, religion, sex, sexual orientation, gender identity, or national origin.
Such action shall include, but not be limited to the following:
Employment, upgrading, demotion, or transfer; recruitment or recruitment
advertising; layoff or termination; rates of pay or other forms of compensation; and
selection for training, including apprenticeship. The contractor agrees to post in
conspicuous places, available to employees and applicants for employment, notices
to be provided setting forth the provisions of this nondiscrimination clause.
(2) The contractor will, in all solicitations or advertisements for employees placed by or
on behalf of the contractor, state that all qualified applicants will receive
consideration for employment without regard to race, color, religion, sex, sexual
orientation, gender identity, or national origin.
(3) The contractor will not discharge or in any other manner discriminate against any
employee or applicant for employment because such employee or applicant has
inquired about, discussed, or disclosed the compensation of the employee or
applicant or another employee or applicant. This provision shall not apply to instances
in which an employee who has access to the compensation information of other
employees or applicants as a part of such employee's essential job functions discloses
the compensation of such other employees or applicants to individuals who do not
otherwise have access to such information, unless such disclosure is in response to a
formal complaint or charge, in furtherance of an investigation, proceeding, hearing,
or action, including an investigation conducted by the employer, or is consistent with
the contractor’s legal duty to furnish information.
(4) The contractor will send to each labor union or representative of workers with which
he has a collective bargaining agreement or other contract or understanding, a notice
to be provided advising the said labor union or workers' representatives of the
contractor's commitments under this section, and shall post copies of the notice in
conspicuous places available to employees and applicants for employment.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 9 of 17
(5) The contractor will comply with all provisions of Executive Order 11246 of September
24, 1965, and of the rules, regulations, and relevant orders of the Secretary of Labor.
(6) The contractor will furnish all information and reports required by Executive Order
11246 of September 24, 1965, and by rules, regulations, and orders of the Secretary
of Labor, or pursuant thereto, and will permit access to his books, records, and
accounts by the administering agency and the Secretary of Labor for purposes of
investigation to ascertain compliance with such rules, regulations, and orders.
(7) In the event of the contractor's noncompliance with the nondiscrimination clauses
of this contract or with any of the said rules, regulations, or orders, this contract may
be canceled, terminated, or suspended in whole or in part and the contractor may
be declared ineligible for further Government contracts or federally assisted
construction contracts in accordance with procedures authorized in Executive Order
11246 of September 24, 1965, and such other sanctions may be imposed and
remedies invoked as provided in Executive Order 11246 of September 24, 1965, or
by rule, regulation, or order of the Secretary of Labor, or as otherwise provided by
law.
(8) The contractor will include the portion of the sentence immediately preceding
paragraph (1) and the provisions of paragraphs (1) through (8) in every subcontract
or purchase order unless exempted by rules, regulations, or orders of the Secretary
of Labor issued pursuant to section 204 of Executive Order 11246 of September 24,
1965, so that such provisions will be binding upon each subcontractor or vendor. The
contractor will take such action with respect to any subcontract or purchase order as
the administering agency may direct as a means of enforcing such provisions,
including sanctions for noncompliance:
Provided, however, that in the event a contractor becomes involved in, or is
threatened with, litigation with a subcontractor or vendor as a result of such direction
by the administering agency, the contractor may request the United States to enter
into such litigation to protect the interests of the United States.
The applicant further agrees that it will be bound by the above equal opportunity
clause with respect to its own employment practices when it participates in federally
assisted construction work: Provided, that if the applicant so participating is a state
or local government, the above equal opportunity clause is not applicable to any
agency, instrumentality or subdivision of such government which does not participate
in work on or under the contract.
The applicant agrees that it will assist and cooperate actively with the administering
agency and the Secretary of Labor in obtaining the compliance of contractors and
subcontractors with the equal opportunity clause and the rules, regulations, and
relevant orders of the Secretary of Labor, that it will furnish the administering agency
and the Secretary of Labor such information as they may require for the supervision
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 10 of 17
of such compliance, and that it will otherwise assist the administering agency in the
discharge of the agency's primary responsibility for securing compliance.
The applicant further agrees that it will refrain from entering into any contract or
contract modification subject to Executive Order 11246 of September 24, 1965, with
a contractor debarred from, or who has not demonstrated eligibility for, Government
contracts and federally assisted construction contracts pursuant to the Executive
Order and will carry out such sanctions and penalties for violation of the equal
opportunity clause as may be imposed upon contractors and subcontractors by the
administering agency or the Secretary of Labor pursuant to Part II, Subpart D of the
Executive Order. In addition, the applicant agrees that if it fails or refuses to comply
with these undertakings, the administering agency may take any or all of the following
actions: Cancel, terminate, or suspend in whole or in part this grant (contract, loan,
insurance, guarantee); refrain from extending any further assistance to the applicant
under the program with respect to which the failure or refund occurred until
satisfactory assurance of future compliance has been received from such applicant;
and refer the case to the Department of Justice for appropriate legal proceedings
5.4 Intentionally omitted.
5.5 Copeland Anit-Kickback Act. Contractor. The contractor shall comply with 18 U.S.C. § 874,
40 U.S.C. § 3145, and the requirements of 29 C.F.R. pt. 3 as may be applicable, which are
incorporated by reference into this contract.
Subcontracts. The contractor or subcontractor shall insert in any subcontracts the clause
above and such other clauses as the federal agency may by appropriate instructions
require, and also a clause requiring the subcontractors to include these clauses in any
lower tier subcontracts. The prime contractor shall be responsible for the compliance by
any subcontractor or lower tier subcontractor with all of these contract clauses.
Breach. A breach of the contract clauses above may be grounds for termination of the
contract, and for debarment.
5.6 Intentionally omitted
5.7 Rights to Inventions Made Under a Contract or Agreement. Any inventions made related
to this Agreement and associated work is subject to the provisions of 37 CFR Part 401, as
applicable.
5.8 Clean Air Act and Federal Water Pollution Control Act.
Clean Air Act
The contractor agrees to comply with all applicable standards, orders or regulations
issued pursuant to the Clean Air Act, as amended, 42 U.S.C. § 7401 et seq.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 11 of 17
The contractor agrees to report each violation to the (insert name of non-federal entity
entering into the contract) and understands and agrees that the (insert name of the non-
federal entity entering into the contract) will, in turn, report each violation as required to
assure notification to the Federal Emergency Management Agency (FEMA), and the
appropriate Environmental Protection Agency Regional Office.
The contractor agrees to include these requirements in each subcontract exceeding
$150,000 financed in whole or in part with federal assistance provided by FEMA.
Federal Water Pollution Control Act
The contractor agrees to comply with all applicable standards, orders, or regulations
issued pursuant to the federal Water Pollution Control Act, as amended, 33 U.S.C. § 1251
et seq.
The contractor agrees to report each violation to the (insert name of the non-federal
entity entering into the contract) and understands and agrees that the (insert name of
the non- federal entity entering into the contract) will, in turn, report each violation as
required to assure notification to the (insert name of the pass-through entity, if
applicable), Federal Emergency Management Agency (FEMA), and the appropriate
Environmental Protection Agency Regional Office.
The contractor agrees to include these requirements in each subcontract exceeding
$150,000 financed in whole or in part with federal assistance provided by FEMA.”
5.9 Debarment and Suspension. This contract is a covered transaction for purposes of 2 C.F.R.
pt. 180 and 2 C.F.R. pt. 3000. As such the contractor is required to verify that none of the
contractor, its principals (defined at 2 C.F.R. § 180.995), or its affiliates (defined at 2 C.F.R.
§ 180.905) are excluded (defined at 2 C.F.R. §180.940) or disqualified (defined at 2 C.F.R.
§ 180.935).
The contractor must comply with 2 C.F.R. pt. 180, subpart C and 2 C.F.R. pt. 3000, subpart
C and must include a requirement to comply with these regulations in any lower tier
covered transaction it enters into.
This certification is a material representation of fact relied upon by the Town of Los Gatos.
If it is later determined that the contractor did not comply with 2 C.F.R. pt. 180, subpart
C and 2 C.F.R. pt. 3000, subpart C, in addition to remedies available to the Town of Los
Gatos the Federal Government may pursue available remedies, including but not limited
to suspension and/or debarment. The Town will insure the Contractor and any lower
participants are not debarred by checking the government’s System Award Management
(SAM).
The Bidder or proposer agrees to comply with the requirements of 2 C.F.R. pt. 180,
subpart C and 2 C.F.R. pt. 3000, subpart C while this offer is valid and throughout the
period of any contract that may arise from this offer. The Bidder or proposer further
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 12 of 17
agrees to include a provision requiring such compliance in its lower tier covered
transactions.
5.10 Byrd Anti-Lobbying Amendment. Contractors who apply or bid for an award of more than
$100,000 shall file the required certification. Each tier certifies to the tier above that it
will not and has not used federally appropriated funds to pay any person or organization
for influencing or attempting to influence an officer or employee of any agency, a
Member of Congress, officer or employee of Congress, or an employee of a Member of
Congress in connection with obtaining any federal contract, grant, or any other award
covered by 31 U.S.C. § 1352. Each tier shall also disclose any lobbying with non-federal
funds that takes place in connection with obtaining any federal award. Such disclosures
are forwarded from tier to tier up to the recipient who in turn will forward the
certification(s) to the federal awarding agency
5.11 Procurement of Recovered Materials. In the performance of this contract, the Contractor
shall make maximum use of products containing recovered materials that are EPA-
designated items unless the product cannot be acquired:
(1) Competitively within a timeframe providing for compliance with the contract
performance schedule;
(2) Meeting contract performance requirements; or
(3) At a reasonable price.
Information about this requirement, along with the list of EPA-designated items, is
available at EPA’s Comprehensive Procurement Guidelines webpage:
https://www.epa.gov/smm/comprehensive- procurement-guideline-cpg-program.
The Contractor also agrees to comply with all other applicable requirements of Section
6002 of the Solid Waste Disposal Act
5.12 Prohibition on Contracting for Covered Telecommunications Equipment or Services.
(a) Definitions. As used in this clause, the terms backhaul; covered foreign country;
covered telecommunications equipment or services; interconnection
arrangements; roaming; substantial or essential component; and
telecommunications equipment or services have the meaning as defined in FEMA
Policy 405-143-1, Prohibitions on Expending FEMA Award Funds for Covered
Telecommunications Equipment or Services (Interim), as used in this clause.
(b) Prohibitions.
(1) Section 889(b) of the John S. McCain National Defense Authorization Act for
Fiscal Year 2019, Pub. L. No. 115-232, and 2 C.F.R. § 200.216 prohibit the head
of an executive agency on or after Aug.13, 2020, from obligating or expending
grant, cooperative agreement, loan, or loan guarantee funds on certain
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 13 of 17
telecommunications products or from certain entities for national security
reasons.
(2) Unless an exception in paragraph (c) of this clause applies, the contractor and
its subcontractors may not use grant, cooperative agreement, loan, or loan
guarantee funds from the Federal Emergency Management Agency to:
(i) Procure or obtain any equipment, system, or service that uses covered
telecommunications equipment or services as a substantial or essential
component of any system, or as critical technology of any system;
(ii) Enter into, extend, or renew a contract to procure or obtain any
equipment, system, or service that uses covered telecommunications
equipment or services as a substantial or essential component of any
system, or as critical technology of any system;
(iii) Enter into, extend, or renew contracts with entities that use covered
telecommunications equipment or services as a substantial or essential
component of any system, or as critical technology as part of any system;
or
(iv) Provide, as part of its performance of this contract, subcontract, or other
contractual instrument, any equipment, system, or service that uses
covered telecommunications equipment or services as a substantial or
essential component of any system, or as critical technology as part of any
system.
(c) Exceptions.
(1) This clause does not prohibit contractors from providing—
(i) A service that connects to the facilities of a third-party, such as backhaul,
roaming, or interconnection arrangements; or
(ii) Telecommunications equipment that cannot route or redirect user data
traffic or permit visibility into any user data or packets that such equipment
transmits or otherwise handles.
(2) By necessary implication and regulation, the prohibitions also do not apply to:
(i) Covered telecommunications equipment or services that:
i. Are not used as a substantial or essential component of any
system; and
ii. Are not used as critical technology of any system.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 14 of 17
(ii) Other telecommunications equipment or services that are not considered
covered telecommunications equipment or services.
(d) Reporting requirement.
(1) In the event the contractor identifies covered telecommunications equipment
or services used as a substantial or essential component of any system, or as
critical technology as part of any system, during contract performance, or the
contractor is notified of such by a subcontractor at any tier or by any other
source, the contractor shall report the information in paragraph (d)(2) of this
clause to the recipient or subrecipient, unless elsewhere in this contract are
established procedures for reporting the information.
(2) The Contractor shall report the following information pursuant to paragraph
(d)(1) of this clause:
(i) Within one business day from the date of such identification or notification:
The contract number; the order number(s), if applicable; supplier name;
supplier unique entity identifier (if known); supplier Commercial and
Government Entity (CAGE) code (if known); brand; model number (original
equipment manufacturer number, manufacturer part number, or
wholesaler number); item description; and any readily available
information about mitigation actions undertaken or recommended.
(ii) Within 10 business days of submitting the information in paragraph (d)(2)(i)
of this clause: Any further available information about mitigation actions
undertaken or recommended. In addition, the contractor shall describe the
efforts it undertook to prevent use or submission of covered
telecommunications equipment or services, and any additional efforts that
will be incorporated to prevent future use or submission of covered
telecommunications equipment or services.
(e) Subcontracts. The Contractor shall insert the substance of this clause, including
this paragraph (e), in all subcontracts and other contractual instruments,
5.13 Domestic Preferences for Procurements. As appropriate, and to the extent consistent
with law, the contractor should, to the greatest extent practicable, provide a preference
for the purchase, acquisition, or use of goods, products, or materials produced in the
United States. This includes, but is not limited to iron, aluminum, steel, cement, and other
manufactured products.
For purposes of this clause:
Produced in the United States means, for iron and steel products, that all manufacturing
processes, from the initial melting stage through the application of coatings, occurred in
the United States.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 15 of 17
Manufactured products mean items and construction materials composed in whole or in
part of non-ferrous metals such as aluminum; plastics and polymer-based products such
as polyvinyl chloride pipe; aggregates such as concrete; glass, including optical fiber; and
lumber.
5.14 Access to Records. The Contractor agrees to provide the Town, the FEMA Administrator,
the Comptroller General of the United States, or any of their authorized representatives
access to any books, documents, papers, and records of the Contractor which are directly
pertinent to this contract for the purposes of making audits, examinations, excerpts, and
transcriptions.
The Contractor agrees to permit any of the foregoing parties to reproduce by any means
whatsoever or to copy excerpts and transcriptions as reasonably needed.
The Contractor agrees to provide the FEMA Administrator or his authorized
representatives access to construction or other work sites pertaining to the work being
completed under the contract.
In addition to the reports specified in this Agreement, Contractor shall retain the records
required by the applicable provisions of 2 CFR § 200.333, no less than three (3) years after
Town’s final payment to Consultant under this Agreement and provide the Town with the
reports required pursuant to 2 CFR §§ 200.328 and 200.343, and such other records and
reports as the Town may reasonably require in the administration of this Agreement.
Contractor shall keep all other necessary books and records, including property,
personnel, loan documentation and financial records, in connection with the operation
and services performed under this Agreement, in accordance with 2 CFR §200.333.
5.15 Changes in Scope of Work or Work Schedule.
(a) Any change in the scope of work to be done, method of performance, nature of
materials or price thereof, work schedule changing the number of working days, or to
any other matter materially affecting the performance or nature of the services will not
be paid for or accepted unless such change, addition or deletion is approved in advance
by the Town, in a written amendment or Contract Change Order.
(b) The changes will be set forth in an amendment or written Contract Change Orders
which specify the work to be done in connection with the changes, the basis of
compensation for the work, and any adjustments to the work schedule or work
completion date. Such Change Orders shall be approved by the Town. Upon receipt of an
approved Contract Change Order, or of a written authorization from the Town setting
forth a description of the change and agreed upon changes in contract price, the
Contractor shall proceed with the work so ordered.
(c) In the absence of an approved amendment or Contract Change Order or written
authorization, the Contractor shall not be entitled to payment for any changed or extra
work or any adjustment to the work schedule or work completion date.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 16 of 17
(d) When the changes increase or decrease the cost of the work, an adjustment of
the Contract price will be made as set forth in the Change Order. Contractor shall receive
compensation at the fees and rates previously agreed upon in writing.
(e) Contractor shall not be entitled to an adjustment in the compensation or work
schedule for delay, disruption, or interference caused by or within the control of
Contractor. Delay, disruption, and interference attributable to and within the control of a
subcontractor or supplier shall be deemed to be within the control of contractor.
5.16 DHS Logo, Seal and Flags. The contractor shall not use the DHS seal(s), logos, crests, or
reproductions of flags or likenesses of DHS agency officials without specific FEMA pre-
approval. The contractor shall include this provision in any subcontracts.
5.17 Compliance with Federal Law, Regulations, and Executive Orders and Acknowledgement
of Federal Funding. This is an acknowledgement that FEMA financial assistance will be
used to fund all or a portion of the contract. The contractor will comply with all applicable
federal law, regulations, executive orders, FEMA policies, procedures, and directives.
5.18 No Obligation by Federal Government. The Federal Government is not a party to this
contract and is not subject to any obligations or liabilities to the non-Federal entity,
Consultant, or any other party pertaining to any matter resulting from the contract.
5.19 Program Fraud and False or Fraudulent Statements of Related Acts. The contractor
acknowledges that 31 U.S.C. Chap. 38 (Administrative Remedies for False Claims and
Statements) applies to the contractor’s actions pertaining to this contract.
5.20 Affirmative Socioeconomic Steps. If subcontracts are to be let, the prime contractor is
required to take all necessary steps identified in 2 C.F.R. § 200.321(b)(1)-(5) to ensure that
small and minority businesses, women’s business enterprises, and labor surplus area
firms are used when possible.
5.21 License and Delivery of Works Subject to Copyright and Data Rights. The Contractor
grants to the Town, a paid-up, royalty-free, nonexclusive, irrevocable, worldwide license
in data first produced in the performance of this contract to reproduce, publish, or
otherwise use, including prepare derivative works, distribute copies to the public, and
perform publicly and display publicly such data. For data required by the contract but not
first produced in the performance of this contract, the Contractor will identify such data
and grant to the Town or acquires on its behalf a license of the same scope as for data
first produced in the performance of this contract. Data, as used herein, shall include any
work subject to copyright under 17 U.S.C. § 102, for example, any written reports or
literary works, software and/or source code, music, choreography, pictures or images,
graphics, sculptures, videos, motion pictures or other audiovisual works, sound and/or
video recordings, and architectural works. Upon or before the completion of this contract,
the Contractor will deliver to the Town data first produced in the performance of this
contract and data required by the contract but not first produced in the performance of
this contract in formats acceptable by the Town of Los Gatos.
Agreement of Consultant Services ATTACHMENT 1 Sequoia Consulting Group Page 17 of 17
IN WITNESS WHEREOF, the Town and Consultant have executed this Agreement.
Town of Los Gatos by:
Laurel Prevetti, Town Manager
Consultant by:
Debie Montana, Chief Executive Officer
Recommended by:
_____________________________________
Nicolle Burnham
Director of Parks and Public Works
Approved as to Form:
____________________________________
Gabrielle Whelan, Town Attorney
Attest:
___________________________________
Wendy Wood, CMC, Town Clerk
June 27, 2024proposal
TOWN OF LOS GATOS DEPARTMENT OF PARKS AND PUBLIC WORKSProfessional Environmental Monitoring Services for Vegetation Management Risk Reduction Project (Open Space)
EXHIBIT A TO ATTACHMENT 1
Sequoia biologist facilitating fire crew training as part of the Tunnel East Bay Hills Shaded Fuel Break Project
A crew chips felled trees while a biological monitor provides assistance from a safe distance away during the North Orinda Shaded Fuel Break project.
"The team at Sequoia was critical to effective hazardous fuel reduction for the North Orinda Shaded Fuel Break. By having their
biologists evaluate sites before work began we could avoid potential environmental impacts and accelerate the project. Their
staff’s expertise continued to guide field crews throughout the work, giving the whole project team confidence that we could
adjust the project to meet the best management practices and comply with the myriad of environmental requirements, while
reducing the potential of wildfire."
Cheryl Miller, Executive Coordinator
Diablo FireSafe Council
A contractor clears vegetation in a portion of Claremont Canyon Regional Park which has been identified both as high-risk for wildfire, and highly sensitive habitat for Alameda whipsnake.
Cover Letter
99 South Almaden Boulevard, Suite 600 San Jose, CA 95113 925.855.5500 www.sequoiaeco.com
June 27, 2024
Town of Los Gatos
Department of Parks and Public Works
41 Miles Avenue
Los Gatos, CA 95030
RE: Proposal for the Town of Los Gatos Department of Parks and Public Works
Professional Environmental Monitoring Services for Vegetation Management Risk Reduction
Project (Open Space), Town Project 832-4508; Federal Project #4407-PJ0506
Members of the Selection Committee,
The Town of Los Gatos carries a profound responsibility in safeguarding its residents and preserving its
cherished parks and open spaces, which face escalating threats from wildfires. The Town’s natural
landscapes not only serve as vital recreational areas, but also harbor diverse ecosystems and protected
natural resources. To proactively mitigate these risks, the Los Gatos Open Space Vegetation Management
Plan (VMP) defines the approach and guidelines that the Town will use for fuel reduction work, in
accordance with the California Vegetation Treatment Program (CalVTP) Project Specific Analysis (PSA) and
Addendum to the Program Environmental Impact Report (PEIR). The PEIR identifies standard treatment
activities and associated environmental protection measures in and around Wildland Urban Interface (WUI)
areas in general, while the VMP specifically prioritizes fuel treatments throughout Town parks to enhance
public safety. We understand that the Town has carefully weighed the benefits of removing fuels versus the
effects of a potentially destructive wildfire, as well as the environmental impacts of initial clearing work and
follow-up maintenance. With treatments planned across five open space areas, we understand that the
Town seeks an environmental consultant who can provide support and expert planning to facilitate timely
completion of the VMP implementation efforts, in compliance with the PEIR.
With more than a decade of experience supporting wildfire mitigation efforts, Sequoia Ecological
Consulting, Inc. (Sequoia) has worked extensively with agencies throughout the Bay Area to expedite
implementation of their fuel management programs. We have teamed with our frequent partner Montrose
Environmental Group (Montrose) to provide cultural resources services as needed. Sequoia and Montrose
having collaborated with similar roles on wildland fuel management efforts for clients including San Mateo
County RCD, East Bay Municipal Utility District, Sonoma County Parks, the State of California Department of
General Services, Contra Costa County Fire Protection District, and the Moraga-Orinda Fire District, among
many other public agency clients.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
2
We are uniquely qualified to support the Town in meetings its VMP goals and long-term objectives because:
Sequoia has worked extensively under the CalVTP, leading planning and PSA development
activities (5 approved PSAs in the last 3 years), as well as implementation of projects throughout
the Bay Area.
Our staff are experts and permit-holders for the project’s focal species, including western bumble
bee, foothill yellow-legged frog, California red-legged frog, and California tiger salamander.
With a staff of more than 50 biologists, we provide a deep bench of environmental monitors who
can meet any scheduling need or concurrent efforts. All of these staff have supported Sequoia’s
fuels management projects, and have a deep level of understanding of the unique requirements
and hazards associated with the full range of prescribed treatments. We have a number of staff
who live within 5 miles of the project area.
As our references will attest, Sequoia helps our clients expedite fuel reduction projects while
avoiding costly permitting requirements and project delays. The value we provide allows agencies
to redirect their time and resources to other high-priority areas.
Sequoia offers a menu of optional services that can be scaled and deployed as requested to meet
the Town’s specific needs.
Sequoia has prioritized our fuel management work support above all other work on our client list because
we understand the urgent need to mitigate our region’s vulnerabilities when it comes to wildfire. This
region is our home, and we appreciate the opportunity to play a role in reducing the threat of wildfire here,
while also enhancing the habitats of the diverse species that share these lands with us. Sequoia has never
failed to fulfill a request, even urgent same-day requests, to support the fuel reduction programs we
support. C
We have carefully reviewed the Town’s RFP and our team will meet all requirements, terms, and conditions
described therein. Thank you for this opportunity to present our team's approach and qualifications. As
Principal at Sequoia Ecological Consulting, Inc., I am authorized to sign and negotiate on behalf of our firm.
Please contact me directly at (925) 989-7011 or via e-mail at dmontana@sequoiaeco.com should you have
any questions or requests for clarification on this proposal.
Sincerely,
SEQUOIA ECOLOGICAL CONSULTING, INC.
Debie Montana Bill Montana
Chief Executive Officer and Principal Biologist Chief Financial Officer
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
3
Scope of Services
Project Understanding
The Town is proactively protecting open space, the public, and sensitive natural resources by developing
management plans to mitigate wildfire risk. The planning effort centers around targeted fuel reduction in
densely vegetated areas, with aims to enhance both firefighter access and public evacuation routes. Plans
are guided by CAL FIRE measures and Town ordinances and encompass nearly 5,000 acres of open space
and parkland. The overall purpose is to minimize both wildfire risk and negative environmental impacts.
The VMP defines the approach and guidelines that the Town will use for fuel reduction work. The VMP was
designed to address critical open space areas and emergency/evacuation routes and support local and
regional goals in reducing wildfire risk. The VMP was prepared in accordance with the CalVTP PSA and
Addendum to the PEIR, which identifies standard treatment activities and associated environmental
protection measures in and around Wildland Urban Interface (WUI) areas in general. The VMP specifically
prioritizes fuel treatments in these parks to enhance public safety; the Town has weighed carefully the
benefits of removing fuel versus both the effects of a potentially destructive wildfire and environmental
impacts of initial clearing work and follow-up maintenance.
Treatments are planned across approximately 200 acres, distributed among five open space areas,
including Heintz, Santa Rosa Open Space, Novitiate, Worcester and La Rinconada Park(s). Three of the parks
included in the VMP are within the WUI and are also within the Very High Fire Hazard Area, between
forested mountain regions to the southwest of the Town and higher-density population areas to the north,
closer to the San Francisco Bay. Approximately 3,000 homes are within the WUI, a highly vegetated region
with limited access for firefighters or public evacuation in general.
We understand that the Town seeks an environmental consultant who can provide support and expert
planning to facilitate the VMP implementation efforts.
Sequoia’s first action item in wildland fuel reduction planning and implementation happens long before
contract execution. During the proposal process, our team focuses on novel approaches and mining
potential cost efficiencies and identifying potential project-specific and schedule roadblocks that can be
addressed proactively. While we are a small firm, Sequoia has completed and implemented the second
highest number of approved PSAs in California. Our team will apply our deep understanding of the
CalVTP process, coupled with a thorough comprehension of species phenology, patterns and
distributions, to develop the most cost-efficient option while also maximizing natural resource
protection. We recognize that clients are often operating under tight grant budgetary limits. We do our due
diligence in environmental review, contractor oversight and compliance, and species avoidance. We
understand that while effective senior oversight is an essential part of project management and quality
control, the balance of the budget should be where the boots hit the ground to accomplish as much fuel
reduction as possible.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
4
Overall Approach to Managing the Scope of Work
Sequoia regularly assists with the planning and implementation of multi-site fuel reduction projects with
simultaneous treatment activities and complex scheduling demands. Through this experience, we have
developed this approach to projects of this nature: we will focus on the ability to foresee issues, and the
adaptability to respond to project changes as they arise. We will ensure that communications with the
Town, its contractors, and stakeholders to be ongoing and frequent, and our continuous environmental
training program will be thorough to ensure crews are mindful of and vigilant in protecting sensitive
environmental resources while performing their work. We will develop and identify roles and
responsibilities and conduct a thorough safety planning effort to mitigate risk during implementation.
We have found that when it comes to facilitating work on a robust vegetation management program like
the Town’s, schedules are often dependent on the availability of contractors, red-flag warnings, wildfires,
permit measures, wildlife ecology, and public relations concerns. With all these variable conditions, last-
minute scheduling changes and biological monitoring requests are inevitable. Sequoia staff understand the
challenges that this program faces, and we will address the Town’s needs quickly and with the highest level
of professionalism.
Potential Challenges and Solutions
From experience in implementing fuel treatment projects under the CalVTP, Sequoia understands that
there are several potential challenges with timing and schedule. Fortunately, we have honed our adaptive
approach in this regard and developed solutions that save budget and enhance efficiency. Sequoia can work
with the Town and implementation contractor to:
• Assign staff that thoroughly understand the nature of on-call work and pivoting based on dynamic
conditions and variables;
• Ensure built-in staff redundancy in our management team to ensure that team leaders, such as
Sequoia’s project manager, have seamless back-up support during vacations and sick time. With
fuel treatment implementation projects, we understand that last-minute changes due to
environmental conditions or the dynamic nature of the work make communication a critical
component of project management. By communicating with the Town about secondary and
tertiary contacts and establishing roles in terms of the hierarchy of notifications, Sequoia intends
to address any last-minute concerns, changes or questions as quickly and thoroughly as possible;
• Schedule work outside of the nesting bird season or botanical survey season to save on treatment
monitor cost;
• Find schedule efficiencies around crew availability with regard to Red Flag workdays/shutdowns
and/or availability during the height of fire season (e.g., finding project areas or treatment
methodologies that can be performed despite restrictions on spark-generating equipment)
• Conduct crew refresher training at no additional cost during the pre-treatment or spot-check
survey activities;
• Assisting the Town with grant-required quarterly reporting as necessary.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
5
Task 1 – Meetings and Project Documentation
After the contract is awarded, Sequoia will organize an initial, project kickoff in-field team meeting to start
the project and ensure that the project’s goals are fully understood, and will be met within the required
timeframes. The meeting will serve as an opportunity to discuss and define project parameters, schedule,
team member roles, and communication protocols. Periodically throughout the project, Sequoia will attend
meetings with the Town and project stakeholders to ensure that project needs are met in a timely manner.
Sequoia will conduct a contractor meeting at the project onset as well. Later, during the course of the
implementation phase, Sequoia will also conduct regular progress check-in meetings over time (described
in more detail below).
At the kickoff meeting, Sequoia will provide a project schedule (similar to the example below) to the Town.
It is important to provide this at the onset of the project to facilitate prioritization, tracking, and
documentation of deliverables and major milestones. Then, during the meeting, the Town will be able to
weigh-in on the schedule itself, in real-time, and provide feedback as to major decision-points or
checkpoints.
Kickoff Meeting. At project commencement, Sequoia will meet with Town staff to review the Scope of
Services and Proposed Work Plan. This initial meeting is intended to confirm the parameters of the scope,
project scheduling, and overall communication protocols. By listening and ensuring a shared understanding,
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
6
we will endeavor to anticipate and prioritize the Town’s needs as we serve as your eyes and ears on the
ground during work. Upon completion of the kickoff meeting, Sequoia will prepare Meeting Minutes that
summarize items discussed, and detail action items. In our experience, having the kickoff meeting in person
is an excellent means to spark side-conversations, dig deeper into details, and explore alternative
perspectives. Visiting one of the project sites just following the kickoff meeting could add even more
benefit – reviewing roles and responsibilities and work expectations, with the project landscape as a
contextual backdrop, could inspire the team at the onset. We strongly encourage the Town to consider an
in-person approach to collaborating at the first kickoff meeting.
Contractor Meeting. Once the Town selects an implementation contractor to perform fuel treatments,
Sequoia will meet with the Town and the contractor to learn the approach and sequencing intended for the
creation of the defensible space around the subject parks and facilities. When starting a project at a new
work location, we will immediately establish lines of communication between the project manager and all
involved parties, including the contractor foreman, fire crews, and Town staff. As above, an in-person
approach to meeting with crews, with the surrounding landscape as context, is an important way to assess
scope, review tasks-at-hand, and it is also a critical element in addressing logistics or safety questions prior
to work-start.
Project Meetings. Sequoia project manager and staff biologist(s) will attend up to six follow-up virtual
progress meetings with the Town and implementation contractor during execution of the work. Follow-up
meetings are critical to continued calibration and managing expectations/deliverables throughout the
course of the project. Follow-up meetings are an opportunity for the Town and Sequoia to discuss budget
projections, to plan logistics, and to re-visit compliance issues as necessary. By establishing a set schedule
of check-in meetings, Sequoia creates a consistent framework to manage the project. At the onset of the
project, the Sequoia project manager will develop a framework schedule of when meetings will occur and
will set relevant agenda items for all to review and weigh-in on prior to actual meeting dates. The Sequoia
project manager will attend all progress meetings. The Sequoia program manager will attend the kickoff
meeting, and a portion of the follow-up meetings depending on project stage and whether their technical
support or input is needed. It is Sequoia’s intent to limit the amount of overhead management time on this
project in order to keep budget with the field biologists and treatment efforts.
Monthly Work and Project Summary. Each month, Sequoia will provide a one-page summary for each of
the 18 expected working months. Summaries will document environmental work completed in the
preceding month and the scope of work planned for the next month. Sequoia will work with the Town to
determine the best format and delivery of this summary over the course of the project.
Task 1 Deliverables
• Kickoff meeting agenda and detailed memorandum, identifying information needs and a
framework for the meeting
• Meeting minutes
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
7
• Monthly work summaries
Task 1 Assumptions
• Kickoff meeting and fuel treatment team meetings will be in-person, on-site, and will include site
walks.
• All follow-up project progress meetings will be virtual/via phone.
Task 2 – Data Collection and Review
Sequoia will thoroughly review all project environmental documents and previously performed survey
findings.
Based on this review, Sequoia’s team will develop an outline summary of work. Sequoia will develop a
compliance matrix and reference guide for implementation crews based on the compliance documents. The
reference guide will be an efficient way for both field biologists and crews to refer to relevant measures,
methods and protocols, as well as timing of the requirements, and clear guidance and timing for the crews.
Sequoia has already developed such tables for other clients on fuel reduction projects – because these clear
templates already exist in our database, adapting them for this project will be efficient and save on cost.
Additionally, Sequoia will share all project related resources, buffers and layers with the crew via a mapping
tool such as Avenza or Google Earth. By sharing these mapping resources, the implementation contractor
will have the same level of detail for real-time resources in the field as the Sequoia staff biologists. Sequoia
will develop detailed field instructions for their biologists in general. Field instructions will focus on safety,
access-related issues, coordinating correct and up-to-date mapping resources, and other site-specific
details. By conducting this analysis and creating this documentation up-front, before implementation
begins, Sequoia will set up both field biologists and implementation crews for success. It will also establish a
standard of collaboration and communication between the team.
Review Environmental Documents. Sequoia will review and assess all environmental documents pertaining
to the proposed open space vegetation management; including the Avoidance and Minimization Measures
outlined in the PSA.
Matrix/Table of Minimization and Mitigation Requirements. Sequoia will provide a matrix/table of all
minimization and mitigation requirements for the project, split by where they occur in the project time
(before, during, after) so that it is very clear to both the Town and contractor when measures are
implemented and who the responsible parties are. Sequoia has generated this table before for other clients
– re-using the template will save on effort and cost for this project.
Task 2 Deliverables
• Matrix/table of measures, work and studies required for environmental compliance.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
8
• Quick reference guides or guidance documents for biologists and crews. Sequoia will use existing
templates for guidance documents which will save time and management cost.
Task 2 Assumptions
• The Town will provide all relevant existing project documents, including GIS shapefile layers, for
Sequoia’s use and development-of-reference-guide purposes.
Task 3 - Pretreatment Surveys
Sequoia will rely on the existing documentation and mapping performed by others, to perform
pretreatment surveys of the work areas. Pretreatment surveys are a critical step in the CalVTP process.
They are used to determine whether species-specific mitigation measures are required, and they are
performed to document conditions before treatment so that a post-treatment analysis can be conducted.
Post-treatment surveys are meant to adequately determine whether any habitat type-conversion has
occurred because of the work performed. Since it has been determined that there is suitable habitat for
special status species present, and project areas have potential to be affected by a treatment activity,
pretreatment surveys will be performed, and if those species are detected and documented, further
species-specific mitigation measures will be applied.
Sequoia recognizes that working in remote wild areas requires attention to detail regarding both our own
team and members of the larger project team. Prior to beginning any survey efforts, Sequoia field biologists
will perform a safety analysis of the work in general. This will guide daily safety discussions, and safety plan
elements will be constantly updated as the project progresses (i.e., as new areas are added to the survey,
new assessments are made about relevant hazards).
Sequoia biologists will conduct focused pretreatment surveys no more than 14 days prior to the beginning
of treatment activities as mitigation measures determine that suitable habitat for special status species is
present and has potential to be directly or indirectly affected by a treatment activity. The survey area will
be determined by a qualified biologist based on the species and habitats and any recommended buffer
distances in agency protocols.
Nesting Bird Surveys. Sequoia’s biologists will conduct surveys for nesting avian species in compliance with
the CalVTP PEIR if implementation of the project is to occur during the nesting season for birds (February 1
– August 31). A Sequoia biologist will conduct nesting bird surveys no earlier than 7 days prior to the
commencement of work activities during the nesting season. The biologist will survey all areas on foot that
may provide suitable nesting habitat within 300 feet of the project site for passerines and within 500 feet
for nesting raptors, as access allows. The survey will be conducted during the morning hours for peak avian
activity and will not take place during periods of excessive or abnormal cold, heat, wind, rain, or other
inclement weather that may reduce the likelihood of detection. If nesting birds are discovered during the
initial survey, we will establish a suitable “no work” buffer around all active nests. Buffers will remain in
place for the duration of the breeding season or until it has been confirmed by a qualified biologist that all
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
9
chicks have fledged and are independent of their parents. Results from the nesting bird surveys will be
provided as a map layer to implementation contractors to enable them to plan work around buffers in real-
time, in the field, using a phone or tablet.
Perform Native American consultation for the project as required. Per our understanding of Standard
Project Requirement CUL-2 of the PSA, geographically affiliated Native American tribes on the Native
American Heritage Commission (NAHC) list have already been contacted and notified. From our vantage,
SPR CUL-8 (Cultural Resource Training) will need to be conducted prior and during initial treatments – we
assume the Town has this scope covered by others as well.
However, if these elements were not already previously completed, Sequoia has preemptively enlisted the
support of our long-trusted partner Montrose. In addition to working with Sequoia on numerous wildfire
mitigation efforts, Montrose has experience in watershed, stream, and open space projects, and many
years of experience with vegetation and watershed management to reduce fire risks. On this project,
Montrose will serve as the lead on contacting, coordination with, and performing all required Native
American consultation during the implementation phase. Montrose' proposed staff are also experts in
CEQA/NEPA, environmental laws including the Clean Water Act (CWA) and the Endangered Species Act
(ESA), as well as other regulatory requirements and permitting, particularly for complex efforts that include
a variety of fuel reduction treatment methods. While AB 52 compliance has been satisfied for projects
found to be within the scope of the CalVTP Program EIR with a PSA or project approval with a
PSA/Addendum, in accordance with SPR CUL-2, Montrose’s cultural resources specialist will obtain the
most current Native American Heritage Commission (NAHC) Native Americans Contact list and contact the
geographically affiliated Native American tribes. Montrose will prepare the notification letter and request
information regarding potential impacts to cultural resources from the proposed project.
Native American consultation will generally consist of the following process, pending which tasks have
already been completed or still need to be addressed before implementation begins:
• Reach out to tribes in the Los Gatos project area (if this has not already been performed)
• Inform them of the Town’s planned work;
• Respond to questions from Native American tribes;
• Provide guidance and consultant on potential site visitor work observation days;
• Potentially join tribe(s) for a site visit too, if requested by Town; and
• Document this outreach for the general administrative record/project file.
Cultural resources work will be overseen by Janis Offermann, who meets the U.S. Secretary of Interior’s
professional standards in archaeology. Montrose will work with the Town as needed, to meet all standards
for Native American consultation relative to the project study area based on the expected area of
disturbance that will be identified as an area of potential effects (APE) for the purposes of compliance with
Section 106 of the National Historic Preservation Act (NHPA).
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
10
If needed and as required, Montrose will assist the Town to satisfy the requirements of Native American
consultation pursuant to AB 52, chaptered as Public Resources Code Section 21080.3.1(b), which is the
responsibility of the CEQA lead agency, as needed. Montrose will contact the NAHC on behalf of the Town
to determine whether Native American sacred sites are known to be located in or near the project, and for
a list of tribes that have a traditional and cultural affiliation with the project area and who may have
information about significant Native American resources. Once the list is received from the NAHC,
Montrose will draft a letter for review and signature by the Town, and send letters to the identified tribes
to notify them about the project and the opportunity to consult under AB 52, along with a request of
concerns or knowledge about significant Native American resources within the APE. We will mail the letter
to the tribes via certified U.S. mail with a return receipt. Follow-up emails will be to letter recipients about
2 weeks after the initial contact to verify that the letter has been received. The federal lead agency, if
applicable, will retain responsibility for Native American consultation pursuant to 36 Code of Federal
Regulations (CFR) 800.2(c)(2)(ii).
Bumble bee Surveys. Four bumble bee species are candidates for listing under the California Endangered
Species Act (CESA), and therefore require protocol surveys. Sequoia’s team includes two of the first
biologists to have their Memorandum of Understanding (MOU) from California Department of Fish and
Wildlife (CDFW) to conduct these protocol surveys. Bumble bee habitat suitability assessments (HSAs) can
be performed concurrently with the pretreatment surveys, and must be performed during the Colony
Active Period, which is approximately between April and September.
Pretreatment Surveys. Sequoia will conduct pretreatment surveys of each work location and will identify
any relevant mitigation requirements.
Pretreatment Findings and Reports. Sequoia will develop pretreatment report based on survey results.
Results will be incorporated into the real time mapping so that crews can see buffers. Sequoia biologists
will be flagging specific buffers or resources for avoidance as they are found.
Task 3 Deliverables
Written summary of field survey observations (Daily Monitoring Report)
List of mitigation requirements and recommendations for each work location
Pretreatment survey report detailing the survey efforts and results. The report will include an
introduction to the project, survey methods, results, and a discussion of the project.
Report detailing avian species observed, areas surveyed, details on active nests found, and buffer zones
implemented, as applicable
Nesting Bird Survey results will be valid for seven (7) days.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
11
Task 3 Assumptions
A full desktop review and mapping resources that was conducted and/or generated by the authors of
the PSA will be made available to Sequoia for purposes of orienting the pretreatment, or any, biological
resources surveys.
While protocol level rare plant surveys are required ahead of treatments by the CalVTP, the RFP did not
list this as a task, however Sequoia can provide this service for additional costs not included in this
proposal effort.
Any necessary landowner notifications will be provided by Town prior to fieldwork. Sequoia can assist
the Town with right-of-entry (ROE) permits and notifications ahead of all field efforts, if requested.
Safe access will be provided to Sequoia at the time of the survey.
Notice to proceed will constitute permission for Sequoia to be present on the property to conduct the
field survey at a time agreed upon by Town and Sequoia.
Digital maps will be made available to crews; costs of app to utilize maps on their phones is not
included in this scope.
Town will provide Sequoia with geodata of Project and survey areas as GIS Shapefile or Google Earth
.kmz file, including the following layers:
o Park boundaries with roads and trails
o Park Habitat types
Task 4 –Environmental Awareness Training
Before work begins, an experienced Sequoia biologist will provide
environmental training to all crew members. Environmental awareness
training is a critical step in establishing communication between the
Town, its fuel reduction crews, and resource specialists. Trainings led by
Sequoia staff are open-ended and interactive, and foster a positive
relationship among the project team members. Training will include an
overview of the ecology and identification of each sensitive species with
potential to occur, nesting bird buffer protocols, and all Avoidance
Minimization and Mitigation (AMMs) and Best Management Practices
(BMPs). If needed, training may also include a demonstration of rare
plants, sudden oak death, and noxious weed decontamination protocols.
Brief, informal refresher trainings may also be also presented
periodically, as needed to remind crews of the various measures in place.
Sequoia will design and distribute
program-specific hardhat stickers
to crews completing environmental
training on the Town’s vegetation
management projects. This is a
recent example of one of our crew
environmental training stickers.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
12
Sequoia will perform additional refresher training at no additional cost during treatment activities, in
conjunction with surveys or other on-site responsibilities.
Note that to be cost efficient, Sequoia will budget one (1) standalone environmental training at the
beginning of the implementation phase for all contractor crews. Any follow-up training, as either refresher
or to train new crew members as they are assigned to the project, will be performed concurrently with
pretreatment surveys and/or treatment monitoring. The versatility of our biologists in this regard (e.g.,
performing the training and then proceeding with monitoring work) is a testament to their
multifunctionality and this will benefit the project as a cost savings measure.
Our biologists regularly receive accolades and are acknowledged for their exemplary communication with
crews and clients throughout treatment activities.
If requested, Sequoia can provide bilingual staff to perform environmental training in both English and
Spanish, as well as bilingual brochures.
Task 4 Deliverables
Draft training pamphlets for Town review (in both English and Spanish, if requested)
Final materials for the training session, edited to reflect Town comments
Hardhat stickers designed and printed for crew use
Sign in sheet for training session
Task 4 Assumptions
Delivery of the on-site environmental trainings will be included in the costs for pretreatment surveys or
biological monitoring, and the training will be provided to any new crew members, as requested.
Costs include preparation of environmental training materials, including one round of comments and
edits from the Town.
Costs include 50 printed environmental awareness training pamphlets.
Refresher trainings for new crew members can be provided to crews while biologists are onsite for
pretreatment surveys at no additional cost.
Cost for stand-alone environmental trainings is provided for project initiation.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
13
Task 5 –Fuel Reduction Compliance Monitoring
Fuel Reduction Compliance Monitoring. Sequoia’s highly
qualified and agency-approved biologists and/or botanists will
provide on-site observation and monitoring to the level
required to comply with the project environmental documents
as they pertain to biological resources. Sequoia biologists will
monitor fuel reduction work in the field. Depending on park
unit and habitat type, monitoring may either be half- or full
days. Sequoia has already reviewed the project documents and
we understand which areas specifically provide suitable habitat
for special status species (e.g., Foothill yellow legged frog) and
will therefore require full-time monitoring, versus those work
areas that only need spot checks or partial days to survey and
protect resources.
Sequoia’s project manager will communicate with the Town and
implementation crews on a regular basis to assess project
schedule demands and progress over time. They will brief
biologists’ on the extent of work, access, safety considerations
and monitoring scope on a regular basis to ensure consistency
of understanding. Staff biologists will continually check-in with
Town and contractors, and will submit daily reporting logs and
safety analyses during the course of work. Sequoia will open multiple layers of communication (Slack,
email, text) in order to fully cover logistics demands – in our experience, providing several means of
communication allows for flexibility among the team, as personal preferences may shift over time. The
most important element of monitoring is to establish clear roles and responsibilities both at the onset but
also over time (in the form of re-calibration points among the team). By continually checking and re-
checking compliance documents, and refreshing the team on the hierarchy of communication, Sequoia will
create an efficient and supportive project structure, with very little room for misaligned expectations or
lapses in judgment.
Task 5 Deliverables
Daily reports of field activities including photographs as appropriate, and observations of regulated
species, if applicable
Task 5 Assumptions
Fencing and signage will be provided and installed by the contractor or the Town. The biologist can
assist the onsite team with demarcation of areas where fencing will be required if necessary.
Sequoia staff know that open communication
and mutual respect are essential to address
potential compliance concerns and sensitive
species impacts during monitoring or
treatment activities. Through cooperation
and communication with crews, Sequoia staff
encourage crews to remain vigilant to
maintain compliance.
When issues arise on site that require prompt
communication, such as scheduling changes
or compliance issues, these are reported to
the appropriate team members immediately.
Sequoia’s team has a thorough
understanding of the Project, and we will
constantly work to improve our planning,
surveying, reporting, and general project
support to better meet the Town’s needs.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
14
Task 6 – Project Environmental Reporting
Project Environmental Reporting. Sequoia’s experienced biologists excel at documenting project activities.
We understand that a post-project implementation report (referred to by CAL FIRE as a Completion report)
is required by the PSA under SPR AD-7. The report includes information about the size of treated area
(acres), treatment types and activities, dates of work, a list of SPRs and mitigation measures implemented,
and relevant explanations about the measures themselves. Sequoia will develop the report at project
conclusion with a statement on compliance with the environmental requirements of the project. The report
will include any/all results from post-treatment surveys, as well as all GIS data. The report will be delivered
in a timely manner, and in the case of compliance concerns, our staff will follow strict communications
protocols with Town staff for immediate incident reporting. Sequoia will make use of several layers of
senior technical review during the drafting process.
Task 6 Deliverables
Project summary report
Task 6 Assumptions
The project summary report will include one round of edits by the Town.
Optional Services
Sequoia can provide the following optional/additional services to the Town at their request, on a time and
materials basis. Our team is highly qualified to offer these services as means to supplement and enhance
the successful completion of the project.
Contractor Cultural Resources Training. As required by the PEIR, and if not already completed/planned for
by others by the Town in general, the Sequoia team (via our partner Montrose) can develop and provide
cultural resource training with a focus on potential cultural resources on-site, avoidance measures, best
management practices, and pertinent regulatory guidance for treatments.
Assistance with Request for Bids and Contractor Oversight. Sequoia can assist the Town with developing
Request(s) for Bid, contracting strategies and efficiencies, reviewing contract specifications and work
descriptions/orders, and providing implementation or inspection support on a high-level, as needed.
Sequoia performed this service as part of the La Honda Shaded Fuel Project with San Mateo County
Resource Conservation District. Sequoia is unique among consulting firms in that its Climate Resiliency &
Restoration Program Manager (Will Johnson) has a background in the implementation side of fuel
reduction and restoration and has managed projects from both contractor and consultant perspectives.
Will oversaw coordination and logistics for contractor crews and heavy equipment operations for more
than a decade prior to joining Sequoia. His extensive industry knowledge has proven to be a powerful tool
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
15
in soliciting cost-efficient bids, writing specifications, and reviewing potential implementation crews’
qualifications.
Invasive Plant Mapping. Sequoia can perform invasive plant mapping as populations are found and provide
data to the Town using Cal-IPC guidelines/protocols. By mapping invasive plant populations, Sequoia will
supplement Town data to help inform land management decision-making during PSA treatments, or when
performing standard Park maintenance and stewardship operations over-time. Invasive plant mapping can
be performed at minimal cost during the pretreatment survey effort.
Mapping and Documenting Other Pests. Preventing the spread of plant pathogens (e.g., pitch canker,
goldspotted oak borer, etc.) is an important part of the SPR’s for the PSA (SPR BIO-6). Aside from sanitizing
equipment and providing thorough training, it is critical to better understand where pathogens occur or are
likely to occur. Sequoia has botanists specifically trained in identifying plant pathogens and are certified
arborists. Sequoia will document or map other pests (e.g., bore beetle) as they occur throughout survey
areas. Pests can be critical indicator species for larger-scale ecosystem health and trends. By mapping other
types of pests, Sequoia can support future treatment planning efforts, and Town’s VMP, and ongoing park
and land management responsibilities.
GIS Services. Sequoia’s GIS experts can create an internal GIS database and Esri ArcGIS Online website to
track fuels treatments in real time for the Town. The GIS service can be utilized across a wide array of
platforms and can track all wildfire resiliency work. Coupled with a thoughtful approach to community
outreach above, this is an effective tool to connect the public with the work and communicate updates and
progress over time. Additional GIS database management, data collection, and cartography services can be
provided upon request. As described further in our description of the Tunnel Fuel Break project on page 26,
Sequoia provides these service to Moraga-Orinda Fire District. The web tool Sequoia created can be found
at this link.
Drone Surveys. Sequoia can offer drone services to assess project progress, document site conditions, and
develop aerial imagery for publications and presentations. Sequoia staff are Federal Aviation
Administration (FAA) Part 107 Remote Pilot-licensed. Drone assessments will provide digital orthophoto,
digital surface model (DSM), digital elevation model (DEM), and point cloud data products. Drone use will
be carefully planned in accordance with airspace restrictions, sensitivity to surrounding landowners and
agencies’ regulations (e.g., East Bay Regional Park District), and Sequoia will hold drone insurance through
Verifly. Drone footage can be a powerful tool in assessing treatment effectiveness, but also enhancing
transparency with the local community about the Town’s efforts in fire risk mitigation (see below Public
Outreach optional task for more context).
Habitat Monitoring. The Town’s responsibilities for managing treated work areas do not end at project
conclusion. The changed landscape will need to be continually managed to maintain progress made on fuel
reduction objectives. Sequoia's biologists can perform longer-term post-treatment monitoring to record
species numbers, assess changes in habitat, and will develop subsequent data analysis if necessary.
Biologists will monitor reproductive seasons of wildlife throughout the project timeline. Various levels of
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
16
technical memoranda and presentations can be developed with data to supplement public outreach
efforts.
Public Outreach Support and Public Presentations. Sequoia understands that public perception and buy-in
are essential parts of the wildfire risk management process. On past projects, Sequoia has assisted with the
preparation and implementation of public outreach support, including stakeholder meetings,
presentations, and/or site field trips. Given that work under the VMP will occur on public parks and open
spaces with regular pedestrian use and recreational activities, Sequoia could work together with the Town
to develop consistent messaging when members of the public inevitably ask about the changing landscape.
Sequoia can assist preparation and implementation of public outreach support, including stakeholder
meetings, public meetings, presentations, and/or site field trips. Meetings could present the project
information to interested parties and gather feedback and concerns that can be addressed. Other public
meetings could include a walk-down with the agencies to ensure they agree with the approach and
compliance with the CalVTP. A slideshow could be developed to present the project and the various aspects
of CEQA compliance. Sequoia can design and provide project signage (to post for public information
purposes) to increase awareness of treatment activities in general.
Shown at Left:
Sequoia has
worked
extensively
throughout Santa
Clara County and
the greater
region. With
offices in San Jose
and numerous
staff within just
miles of the
project area,
Sequoia brings
unmatched local
expertise.
2024-2028
HOURLY RATE SCHEDULE
Environmental Services 2024 2025 2026 2027 2028 Env. Project Mgm’t. 2024 2025 2026 2027 2028
Field Technician 1 $90 $95 $99 $104 $109 Assistant Project Manager 1 $165 $173 $182 $191 $201
Field Technician 2 $105 $110 $116 $122 $128 Assistant Project Manager 2 $170 $179 $187 $197 $207
Field Technician 3 $115 $121 $127 $133 $140 Assistant Project Manager 3 $175 $184 $193 $203 $213
Staff Biologist 1 $120 $126 $132 $139 $146 Project Manager 1 $180 $189 $198 $208 $219
Staff Biologist 2 $125 $131 $138 $145 $152 Project Manager 2 $185 $194 $204 $214 $225
Staff Biologist 3 $130 $137 $143 $150 $158 Project Manager 3 $190 $200 $209 $220 $231
Associate Biologist 1 $135 $142 $149 $156 $164 Project Manager 4 $200 $210 $221 $232 $243
Associate Biologist 2 $140 $147 $154 $162 $170 Project Manager 5 $210 $221 $232 $243 $255
Associate Biologist 3 $145 $152 $160 $168 $176 Project Manager 6 $220 $231 $243 $255 $267
Project Biologist 1 $150 $158 $165 $174 $182 Senior Project Manager 1 $230 $242 $254 $266 $280
Project Biologist 2 $155 $163 $171 $179 $188 Senior Project Manager 2 $240 $252 $265 $278 $292
Project Biologist 3 $160 $168 $176 $185 $194 Senior Project Manager 3 $250 $263 $276 $289 $304
Resource Specialist 1 $165 $173 $182 $191 $201 Program Manager 1 $260 $273 $287 $301 $316
Resource Specialist 2 $170 $179 $187 $197 $207 Program Manager 2 $270 $284 $298 $313 $328
Resource Specialist 3 $175 $184 $193 $203 $213 Program Manager 3 $280 $294 $309 $324 $340
Senior (Sr.) Biologist 1 $180 $189 $198 $208 $219 Principal 1 $290 $305 $320 $336 $352
Sr. Biologist 2 $185 $194 $204 $214 $225 Principal 2 $300 $315 $331 $347 $365
Sr. Biologist 3 $190 $200 $209 $220 $231 Principal 3 $310 $326 $342 $359 $377
Sr. Scientist 1 $200 $210 $221 $232 $243 Senior Principal 1 $320 $336 $353 $370 $389
Sr. Scientist 2 $210 $221 $232 $243 $255 Senior Principal 2 $330 $347 $364 $382 $401
Sr. Scientist 3 $220 $231 $243 $255 $267 Senior Principal 3 $340 $357 $375 $394 $413
Sr. Technical Specialist 1 $230 $242 $254 $266 $280 Geographic Information Services (GIS)
Sr. Technical Specialist 2 $240 $252 $265 $278 $292 GIS Technician 1 $135 $142 $149 $156 $164
Sr. Technical Specialist 3 $250 $263 $276 $289 $304 GIS Technician 2 $145 $152 $160 $168 $176
Sr. Regulatory Specialist 1 $260 $273 $287 $301 $316 GIS Technician 3 $155 $163 $171 $179 $188
Sr. Regulatory Specialist 2 $270 $284 $298 $313 $328 GIS Analyst 1 $165 $173 $182 $191 $201
Sr. Regulatory Specialist 3 $280 $294 $309 $324 $340 GIS Analyst 2 $175 $184 $193 $203 $213
Botanist/Arborist Services GIS Analyst 3 $185 $194 $204 $214 $225
Botanist/Arborist 1 $135 $135 $142 $149 $156 GIS Project Manager 1 $200 $210 $221 $232 $243
Botanist/Arborist 2 $150 $150 $158 $165 $174 GIS Project Manager 2 $210 $221 $232 $243 $255
Botanist/Arborist 3 $165 $165 $173 $182 $191 GIS Project Manager 3 $220 $231 $243 $255 $267
Sr. Botanist/Arborist 1 $185 $185 $194 $204 $214 GIS Specialist 1 $230 $242 $254 $266 $280
Sr. Botanist/Arborist 2 $200 $200 $210 $221 $232 GIS Specialist 2 $240 $252 $265 $278 $292
Sr. Botanist/Arborist 3 $215 $215 $226 $237 $249 GIS Specialist 3 $250 $263 $276 $289 $304
Administrative Support Services GIS Program Manager 1 $260 $273 $287 $301 $316
Clerical $110 $116 $121 $127 $134 GIS Program Manager 2 $270 $284 $298 $313 $328
Project Administrator $135 $142 $149 $156 $164 GIS Program Manager 3 $280 $294 $309 $324 $340
Technical Editor I $150 $158 $165 $174 $182
Technical Editor II $160 $168 $176 $185 $194
Technical Editor III $170 $179 $187 $197 $207
Senior Technical Editor $195 $205 $215 $226 $237
Sequoia Ecological Consulting, Inc. Hourly Rate Schedule Page 2 of 2
Other Direct Costs
Regular Vehicle (GSA Rate) $0.67/mile
Submeter GPS $100/day
UTV and Trailer $95/day
Fleet Vehicle $95/day
iPad $10/day
Wildlife Remote Camera $20/ day
Acoustic Bat Monitor $35/day
Kayak Kit $75/day
Survey Flashlight (Streamlight) $12.50/day
Aquatic Survey Sampling Kit $25/person/day
Drone/sUAS $250/day
Wetsuit $70/week
Drysuit $195/week
YSI ProDSS Water Quality
Meter $125/day
Expense Reimbursement/Other:
1. Computer, facsimile, and telephone are included in the billing rates, and there is no additional charge.
2. Reproduction, equipment, and other direct expenses are reimbursed at cost plus a 15% administrative handling charge
(excluding mileage).
3. Subconsultants will be billed at their indicated rate plus a 15% administrative handling charge; or the Sequoia labor category
commensurate with their role.
4. Depending upon location, Per Diem may be charged where overnight stays are required.
5. Weekly or monthly equipment rates at a reduced amount may be available on a contract-specific basis.
6. Expert Witness Testimony, including Depositions, is billed at the time and half.
7. Non-standard invoice processing will be billed at standard hourly rates for support personnel.
8. Sequoia will review our hourly rates annually and may choose to escalate our rate sheet depending on changes to the
cost- of living- index and other factors.
9. Hours beyond 8 hours per day are charged at an overtime rate of 1.5 times our standard hourly rates for qualifying personnel.
To comply with California Labor Code 512 and California Code of Regulations 11040, if on-site conditions prohibit personnel
from taking required breaks, one additional hour of time will be billed per day for qualifying staff covered under the regulations.
Montrose Environmental Solutions
2024 Billing Rates
Staff Labor Rates
Classification Hourly Rate
Principal $262
Director II $240
Director I $230
Senior Associate II $218
Senior Associate I $208
Associate II $200
Associate I $191
Analyst II $180
Analyst I $170
Surveyor $148
Technician II $136
Technician I $120
GIS Analyst/CAD Technician $153
Technical Editor $131
Publication Specialist $114
Administrative Assistant $114
Direct Expenses
(10% markup; includes subconsultants)
Item Rate
Mileage Current 2024 IRS Rate ($0.655/mile)
Printing (in‐house)
‐ Black/white prints $0.15 per page
‐ Color prints $1.00 per page
‐ CDs (including label and envelope) $1.50 each
Equipment rental
‐ GIS mapping $30/hour
‐ GPS unit or Auger $100.00/day
Outside vendors; including
At cost plus markup ‐ Equipment rentals
‐ Document production and supplies
Note: Rates are subject to 3% escalation each year.
1 Kaiser Plaza, Suite 340, Oakland CA 94612
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
20
Relevant Experience
About Sequoia
Founded in 2011, Sequoia is a Bay Area-based, Woman-owned Small business with local offices in San Jose.
We provide environmental consulting services to public agencies and private entities throughout northern
California. With a full-time local staff of more than 50 biologists and a history of successfully managing
environmental compliance efforts for local agencies' fuel management efforts, Sequoia is positioned to
quickly mobilize planners, biologists and species experts, botanists, arborists, foresters, and qualified
scientists whose expertise facilitate successful and expedited planning and implementation of critical
wildfire mitigation and restoration projects.
Sequoia has been supporting vegetation management efforts since our inception, and as our firm has
grown, we built on that foundation as we have worked with city and county agencies, fire districts,
landowners, and regulatory agencies to provide consultation, planning and permitting, site assessments,
compliance monitoring services, and surveys and habitat assessments for sensitive species. We understand
the unique challenges associated with these efforts and our staff are able to tackle critical project
objectives alongside responsible agency staff, firefighters, and contractors. Working on these types of
projects has instilled in us a profound sense of teamwork and purpose, and enabled us to serve as a
flexible, seamless extension of our clients’ staff.
MK will add a full-width photo with caption here.
Sequoia biologists providing training to fire crews in
preparation for shaded fuel break treatments.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
21
Project Experience
La Honda Shaded Fuel Break and On-Call Environmental
Support | SAN MATEO COUNTY | SAN MATEO RESOURCE
CONSERVATION DISTRICT
The Sequoia team (Sequoia and Montrose) has been supporting the San Mateo Resource Conservation
District (RCD) with planning and implementation of the La Honda Shaded Fuel Break, a 19-mile fuel break
surrounding the community of La Honda in unincorporated San Mateo County.
With implementation slated for November 2023 per funding requirements, the RCD engaged Sequoia to
help meet project’s CEQA requirements under the CalVTP PEIR. To meet the aggressive schedule and all
regulatory requirements for implementation, the Sequoia team designed a CalVTP treatment plan to avoid
the need for additional regulatory permitting from other agencies, and to balance environmental
protection with the needs of the RCD, the La Honda community, and its stakeholders. Sequoia worked with
the RCD to define methodology and phasing of specific treatment prescriptions; and provided detailed
recommendations for tree pruning specifications, understory vegetation and shrub treatments,
management of cut biomass, timing of treatments, aesthetics, and future maintenance and invasive species
considerations.
Sequoia submitted the CalVTP Project-Specific Analysis (PSA) and Addendum for that project, as well as a
Biological Resource Report and Cultural Resources Report after preparing and sending project
notification letters to NAHC tribes. Upon agency submittal and approval of the PSA, Sequoia will assist with
the request for bids and contractor oversight during implementation.
Reference Contact San Mateo Resource Conservation District
Timothy Federal, Program Manager, Forest Health and Fire Resilience
Phone: 650.712.7765 x124
Email: timothy@sanmateorcd.org
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
22
East Bay Regional Park District Fuels Reduction Program
| ALAMEDA AND CONTRA COSTA COUNTIES | EBRPD
From 2016-2021, Sequoia assisted the East Bay Regional Park District with system-wide implementation of
the Wildfire Hazard Reduction and Resource Management Plan, as well as interpretation of a Biological
Opinion, Incidental Take Permit, and Environmental Impact Report for the District’s fuels reduction project.
This project extends throughout EBRPD property in Alameda and Contra Costa counties. Sequoia
coordinated communication and monthly update meetings with the District, and managed performance of
the biomonitoring effort. Sequoia's biologists and technical specialists performed pre-and post-construction
surveys, pre-activity surveys, biological monitoring, and long-term monitoring. A large group of Sequoia
staff are approved by both the USFWS and CDFW to work with sensitive species on site. Sequoia staff also
performed habitat assessments for AWS, identify signs of infection by Phytophthora cinnamomi, facilitated
decontamination protocols to prevent the spread of Phytophthora species, and implemented AMMs during
fuels treatment activities.
Approved staff members survey, monitor for, assess habitat quality, and conduct environmental trainings
for special status species, including Alameda whipsnake, Pallid manzanita, California red-legged frog,
Western pond turtle, San Francisco dusky-footed woodrat, California tiger salamander, and Western
leatherwood.
Reference Contact East Bay Regional Park District Kristen Van Dam, Resource Analyst/Ecologist Phone: 510.544.2324 Email: kvandam@ebparks.org
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
23
Forest Health and Fire Resiliency Project in Huddart &
Wunderlich Parks | SAN MATEO COUNTY | SAN MATEO RCD
San Mateo Resource Conservation District (RCD), in collaboration with CAL FIRE and San Mateo County
Parks developed high priority fuel reduction treatment projects on county lands in the northern Santa Cruz
Mountains for forest health purposes. The collaboration resulted in the development of a forest health fuel
reduction project at Huddart and Wunderlich, San Mateo County Parks encompassing 402.1 acres of
vegetative treatments and a goal to enhance and restore a forest system challenged by changing climates, a
lack of fire, and many homes in close proximity. Project activities primarily included mechanical thinning of
vegetation up to 8” in diameter and pest management (Sudden Oak Death), which further improved forest
health, fuel reduction, and carbon sequestration goals. These landscape level vegetation treatments have
successfully reduced wildfire risk while increasing wildfire management opportunities.
Sequoia was contracted to support the project vegetation treatment prescriptions by conducting special
status species and habitat surveys in scheduled work areas. Sequoia biologists conducted nesting bird
surveys, assessed trees for bat roosting habitat, and visually searched for wood rat middens. The biologist
flagged resources in accordance with RCD flagging conventions, communicated the locations of flagged
resources to vegetation treatment crews, and provided the RCD with a daily survey report. Sequoia worked
closely with the RCD to provide seamless environmental support aiding in early completion of the project.
Reference Contact David Cowman, Forest Ecologist
San Mateo Resource Conservation District
Office: 650.712.7765 x 107
Email: david@sanmateorcd.org
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
24
Various San Mateo County Fuel Breaks and Vegetation
Management Support | SAN MATEO COUNTY | CAL FIRE & SAN
MATEO COUNTY PARKS
Supporting CAL FIRE’s work on the 70-acre Kings Mountain Road Emergency Shaded Fuel Break Project,
Sequoia met with CAL FIRE staff and project representatives to plan for project implementation, special
protection measures, and potential operational constraints. Treatments included mechanical treatments
(masticators) to create a shaded fuel break along with utilization of hand crews with chippers and burn
piles. Sequoia provided focused endangered species and botanical surveys to ensure environmental
compliance and adherence to CAL FIRE’s fuel reduction (AMMs). We provided environmental training to
CAL FIRE crews, and conducted pre-treatment assessments, collecting data on species cover, composition,
and presence of invasive species. Sequoia will conduct post-treatment assessments to determine
maintenance intervals for the fuel break. As part of the same project, Sequoia supported the San Mateo
County Parks Department, performing focused surveys under our on-call contract to determine the
presence of rare plants, primarily Kings Mountain manzanita. Sequoia’s botanists surveyed more than 1,900
acres of park land for this project.
Sequoia worked with CAL FIRE in support of the El Granada-Quarry Park Emergency Shaded Fuel Break
Project. This 170-acre project restored a system of access roads and perimeter fuel breaks within a 500-
acre eucalyptus stand near Half Moon Bay. Sequoia assisted with project implementation, special
protection measures, and potential operational (biological) constraints. Sequoia’s biologists conducted
preliminary surveys and mapping of proposed work areas focusing on the presence of nesting birds,
sensitive species and their habitat, existing erosion or signs of other work already competed, and safety
hazards; as well as biological monitoring and environmental training.
Reference Contact CAL FIRE Sarah Collamer, CZU Forester I – VMP
Phone: 831.254.1792
Email: Sarah.Collamer@fire.ca.gov
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
25
Countywide Wildfire Prevention/Hazard Mitigation
Projects | MARIN COUNTY | MARIN WILDFIRE PREVENTION AUTHORITY
Sequoia is supporting the Marin Wildfire Prevention Authority (MWPA) under a second consecutive
contract to permit and implement a large number of fire prevention projects throughout Marin County.
Sequoia provides biological services during environmental planning and implementation of the 40+
projects within the work plan. Our biologists conduct literature reviews of biological resources, field
assessments, prepare and present environmental trainings, conduct specialized nesting bird and sensitive
plant surveys, and provide ongoing specialized expertise to assist the MWPA. We have also assisted in
the preparation of Environmentally Sensitive Habitat Area (ESHA) mapping to conform with the Marin
County Coastal Zone's Local Coastal Plan, and we prepared a Project-specific Checklist (PSA) in
compliance with the CalVTP in support of various MWPA projects.
Sequoia’s early involvement during the planning phase allowed us to assist in designing projects to avoid
environmental impacts and maximize available funds. Sequoia biologists performed specialized surveys
including nesting bird surveys, sensitive plant surveys, and protocol-level northern spotted owl surveys;
as well as invasive species mapping.
This programmatic effort spans all of Marin County and addresses potential impacts to many sensitive
species and various sensitive plants. Sequoia meets each month with project stakeholders, including
members of the public, to assist MWPA in providing transparency to the public and interested parties
regarding environmental compliance and avoidance of resource impacts.
Reference Contact Anne Crealock Planning and Program Manager
Marin Wildfire Prevention Authority Tel: (707) 332-0866
Email: acrealock@marinwildfire.org
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
26
Tunnel East Bay Hills Shaded Fuel Break Project | CONTRA
COSTA COUNTY, CA
Sequoia is supporting the Moraga-Orinda Fire District (MOFD) on its CAL FIRE-funded Tunnel East Bay Hills
Shaded Fuel Break Project, an 1,110-acre expansion of the 2019 North Orinda Shaded Fuel Break (NOSFB)
project. The project is subject to the California State and Federal Endangered Species Act, the Migratory Bird
Treaty Act, and other species protections regulated by USFWS, CDFW, and local agencies.
Sequoia worked with MOFD throughout the planning process, preparing a Project-specific Analysis (PSA)
checklist and Addendum to secure permitting under the CalVTP, and performing biological and cultural
resource assessments, agency coordination, communication with the public, mapping, and contractor
coordination. Before work commenced, Sequoia performed detailed preliminary surveys of proposed work
areas, and will also conduct post-treatment surveys of treated areas. Surveys focused on the presence of
nesting birds, sensitive species and their habitat, existing erosion or signs of other work already completed,
and safety hazards. Data collected during these surveys will help MOFD to document permit compliance as
well as inform the need for future maintenance work and assess post-treatment fire risk.
Similar to the work Sequoia conducted for the original NOSFB project, our biologists are currently supporting
implementation, performing daily monitoring of work and close communication with the crews to ensure that
the project is conducted in compliance with project permits. We present environmental training to all crew
members, including intensive training on decontamination of equipment, boots, and vehicles to stop the
spread of Phytopthora. Treatments monitored have included hand treatment, mastication, controlled burns,
pile burning, lop and scatter, chip and haul out, and prescribed herbivory.
Reference Contact Jeff Isaacs, Fire Marshal
Moraga-Orinda Fire District
Tel: (925) 258-4513
Email: jisaacs@mofd.org
Pictured here:
Last month, Sequoia staff were invited to greet
members of the public during the City of Orinda's 2nd
Annual Wildfire Safety and Preparedness Fair (shown
at top left). Sequoia shared the Landowner Look Up
Tool (bottom left) and Best Practices for Home
Hardening Guide (shown at right) we prepared with the
Moraga-Orinda Fire District, and answered questions
about environmental protection measures applied on
the various shaded fuel breaks managed by the
Moraga-Orinda Fire District and Contra Costa County
Fire Protection District in the area.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
27
At Sequoia, our team is our greatest asset. Our highly qualified and experienced staff are the backbone of
our successful project delivery. Our approach and the diversified experience of the staff we have selected
to work on the project will allow for combined efforts and cost savings, to maximize the Town’s allocated
funds and efforts.
Our Principal-in-Charge, Debie Montana, will serve as primary contact for the Town for the duration of the
proposal and contracting process, while Project Manager Kyle Verblauuw will be your point of contact
throughout the performance period.
Debie Montana
Principal-in-Charge
Debie Montana will provide project oversight,
managerial support, and assurance that Sequoia
will provide the dedicated resources required to
meet the Town’s needs on this project. Mrs.
Montana feels deeply privileged to lead Sequoia
in supporting wildfire mitigation efforts, playing a
small role in stewarding the land that provides a
retreat and a home to our staff and our families,
and protecting the habitats and species that
inspired her to become a biologist.
Certified in Project Management by the
University of California at Davis, Mrs. Montana
oversees large-scale fuels treatment projects
spanning diverse regions and habitats. She leads
Sequoia's efforts including:
• San Mateo RCD La Honda Shaded Fuel Break
PSA and Addendum preparation, and
implementation support
• San Mateo County Parks Department and CAL
FIRE focused species and rare plant surveys
for fuel reduction activities covering more
than 2,000 acres of park land throughout San
Mateo County
• Marin Wildfire Prevention Authority planning
and implementation of >40 wildfire
mitigation projects
• Contra Costa County Fire District’s on-call
consultant for planning and implementation
of its programmatic fuels efforts, including
work under the CalVTP
• On-call contract with the East Bay Regional
Park District for biological support on fuel
management projects including more than 30
FEMA-funded projects
• Planning and implementation services for
more than 3,000 acres of fuel break for the
Moraga-Orinda Fire District
Debie’s background and certifications:
20 years of experience in the environmental
industry
M.S., Biological Sciences with Concentration in
Organismal Biology, Conservation and Ecology,
San Jose State University •
B.S., Biological Sciences with Concentration in
Conservation and Organismal Biology, San Jose
State University •
Certificate, Project Management, University of
California, Davis
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
28
Kyle Verblaauw
Project Manager
Kyle Verblaauw is a project manager and biologist
specializing in Northern California’s special-status
species. With a Master’s degree in Environmental
Management from the University of San
Francisco, Kyle oversees some of Sequoia’s
largest programmatic fuels management
implementation compliance efforts, including
management and coordination of staff
performing protocol-level surveys, pre-
construction surveys, rare plant surveys, and
biological compliance monitoring.
Kyle has worked extensively with species such as
the California tiger salamander, California red-
legged frog, and western burrowing owl. He holds
a USFWS Recovery Permit and California permits
for these species, and has experience with PIT
tagging, burrow excavations, and amphibian
surveys. His experience with Sequoia includes:
• Biological Project Manager for Marin Wildfire
Prevention Authority during planning and
implementation of >40 wildfire mitigation
projects
• San Mateo County Parks, Edgewood Shaded
Fuels Break, Redwood City, CA
• San Mateo County Parks, Quarry Park Shaded
Fuels Break, El Granada, CA
• Butano State Park Forest Health Project;
Pescadero, CA
• Midpeninsula Regional Open Space District,
Bear Creek Redwood Preserve Phase II Trails
Project; Los Gatos, CA
• Napa County RCD’s CalVTP Project-Specific
Analysis and Addendum for Las Posadas
Forest
• Novato Fire Protection District’s Wildfire
Resiliency Technical Coordinator
• San Rafael Open Space Defensible Fuel
Reduction
• Sonoma County Regional Parks: Hood
Mountain Vegetation Management Planning
Kyle’s background and certifications:
10 years of experience in the environmental
consulting industry
MS, Environmental Management (Ecology),
University of San Francisco
BA, Environmental Studies (Biology), University of
California Santa Barbara
UC Education Abroad Program, (Marine Biology
and Terrestrial Ecology), University of
Queensland, Australia•
USFWS 10(a)(1)(A) Recovery Permit
#ESPER0045160 for California Tiger Salamander
and California Red-legged Frog
CDFW Scientific Collecting Permit #S-211500002-
21363-001 and MOU for California Tiger
Salamander, and California Red-legged Frog
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
29
Will Johnson
Program Manager
Will Johnson has 16 years of experience in habitat
restoration, mitigation planning, natural resource
monitoring, and project management. Over the
past decade, he has worked on various projects
throughout northern California, serving as a field
biologist, site superintendent, manager, crew
leader, and equipment operator. Will is adept at
managing projects from proposal to closeout,
ensuring compliance with standard specifications,
plans, and permit requirements.
He has authored site management and long-term
maintenance plans, cost proposals, budgets, and
technical write-ups. Will has collaborated with
and contracted for a diverse range of clients,
including county, state, and federal agencies,
consulting firms, non-profits, special districts, and
private landowners. His work has involved
numerous special status species in Northern
California, and he has conducted rare plant
surveys and managed projects involving species
like the western burrowing owl and Swainson’s
hawk.
Kelyn McGuire
Surveys and Monitoring,
Environmental Training
Kelyn McGuire is an enthusiastic biologist with
more than 2 years of experience in
environmental consulting and biological field
work. With exquisite attention to detail and
ability to coordinate among all parties, Kelyn
serves as Sequoia’s field lead for fuels treatment
monitoring, surveys, and environmental training
for projects with the Contra Costa County Fire
Protection District, as well as the Moraga-Orinda
Fire District. She is experienced at coordinating
and conducting surveys for nesting birds and
special status species including California tiger
salamander, California red-legged frog, Alameda
whipsnake, western pond turtle, and San
Francisco dusky-footed woodrat, among many
others. Kelyn also assists with rare plant surveys
and California spotted owl surveys under the
supervision of senior biologists/botanists, and
bumble bee surveys with a permitted biologist.
Will’s background and certifications:
16 years of experience in habitat restoration,
mitigation planning, inspection and compliance
support, natural resource monitoring, and both
project and program-level administration and
management
MS, Biological Sciences, University of Rhode Island
BS, Biological Sciences, University of Rhode Island
California Contractors State License Board – C-27
Landscape Construction License, 1086577, exp.
2026
California Department of Pesticide Regulation –
Qualified Applicator License, 162032, exp.
12/2024
Kelyn’s background and certifications:
2+ years of field experience
BA Environmental Studies (Anthropology),
University of California, Santa Barbara
UC Education Abroad Program, (Anthropology)
University of Edinburgh, Scotland
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
30
Brian Nissen
Surveys and Monitoring,
Environmental Training
More than 6 years of professional experience
working with private industry consulting, federal
and state agencies compliance, and volunteer
research projects
Brian Nissen is a restoration ecologist and field
biologist with over 6 years of experience. He has
worked on ecological restoration and biological
surveys across the San Francisco Bay Area,
focusing on special status species and habitat
restoration. Brian is skilled in project design,
implementation, invasive plant management,
native plant propagation, and irrigation systems.
He holds permits for surveying California tiger
salamander and California red-legged frog and
has extensive experience with these species on
construction projects. Brian has also conducted
surveys for other special status species, including
nesting birds, raptors, burrowing owls, and rare
plants like Santa Cruz robust spineflower.
Additionally, he has over 100 hours of passerine
banding experience with the San Francisco Bay
Bird Observatory.
Nicolas Anderson
Surveys and Monitoring,
Environmental Training, and GIS
Nicolas Anderson has 5 years of experience in
wildlife and vegetation surveys, habitat
restoration, construction monitoring, forestry
management, and geographic information
systems (GIS). His surveying skills include point-
count, mark-recapture for small mammals and
fish, electrofishing, mist netting, spotlighting, dip
netting, seining, hoop netting, telemetry, and
herpetological surveys for wetland IBI
assessments.
Nicolas has conducted threatened and
endangered species surveys across the Midwest,
Southeast U.S., and California. Species he has
worked with include the western pond turtle,
California red-legged frog, Indiana bat, Henslow’s
sparrow, loggerhead sea turtle, northern long-
eared bat, and greater prairie-chicken. His
vegetation surveys have covered species such as
beaked spikerush, slender rush, and western
prairie fringed orchid.
Brian’s background and certifications:
5+ years of field experience
BS, Natural Resources, Fisheries and Wildlife
Science, Oregon State University
10(a)(1)(A) Recovery Permit (PER0011950),
California tiger salamander, California red-legged
frog
CDFW Scientific Collection Permit (SC-190180001)
Nick’s background and certifications:
7+ years of field experience
Wildland Firefighter Type II
BS in Fisheries, Wildlife, and Conservation
biology, University of Minnesota, Twin Cities
NPDES Construction Stormwater Inspector
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
32
Attachment A - Other Information
Why Choose Sequoia?
Experience with Federally Funded Fuels Management Efforts
Sequoia is deeply familiar with the variety of funding mechanisms for California’s fuels management
projects. We have worked on dozens of FEMA-funded projects for clients including East Bay Regional Park
District, the RCD, and numerous projects through CAL FIRE. We understand the requirements of these
projects including invoicing, reporting, and the importance of meeting deadlines and milestones set forth
by grants.
Demonstrated Experience with Fire Crews
Sequoia and its staff have coordinated and worked closely with fire crews and agencies including but not
limited to:
• CAL FIRE
• Moraga-Orinda Fire District
• Novato Fire District (Full-time staff augmentation)
• Mt. Diablo Fire Safe Council
• California Conservation Corps
• East Bay Regional Park District's Fire Department
• Contra Costa County Fire Protection District
Qualified Biologists with Certifications and Permits to Handle and Survey
for Listed Species
Sequoia's staff have all the requisite certifications and permits to provide the range of expertise required to
implement the Town’s VMP. Our staff includes GIS Specialists, TRAQ Certified Personnel, a Certified
Consulting Botanist, Certified Arborist, and numerous individuals with 10(a)1(A) recovery permits and/or
Memorandums of Understanding (MOUs) for sensitive species including: Western bumble bee, California
tiger salamander, California red-legged frog, San Francisco garter snake, Foothill yellow-legged frog,
California Ridgway’s rail, Western snowy plover, Vernal pool branchiopods, and other sensitive species.
A table showing our team's certifications and licensing is provided below.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
33
Table. Sequoia Permitted and Certified Staff
Stephen Gergeni MOU attached to SCP; S-201190005-21059-001, Covers 4 CESA-Candidate Bumble Bee Species,
Western bumble bee, Crotch's bumble bee, Franklin's bumble bee and Suckley's Cuckoo
bumble bee
USFWS 10(a)(1)(A) Recovery Permit #TE-84156D-0, Giant garter snake, California tiger
salamander, California red-legged frog
CDFW Scientific Collecting Permit #SC-2011900005, Giant garter snake, California tiger
salamander, California red-legged frog, Foothill yellow-legged frog, amphibians, reptiles, small
mammals, San Francisco dusky-footed woodrat, California giant salamander, Santa Cruz black
salamander, Northern red-legged frog, Western spadefoot toad; Northern alligator lizard
Northern pond turtle, Southwestern pond turtle, terrestrial and vernal pool inverts
Andrew Ford MOU attached to SCP; S-201190005-21059-001, Covers 4 CESA-Candidate Bumble Bee
Species, Western bumble bee, Crotch's bumble bee, Franklin's bumble bee and Suckley's
Cuckoo bumble bee
USFWS 10(a)(1)(A) Recovery Permit #TE-66228D-0, California tiger salamander and California
red-legged frog
Certified Consulting Botanist CCB-0029
California Endangered Species Act Plant Voucher Collecting Permit 2081 1(a)-19-101-V
ISA Tree Risk Assessment Qualification (ISA TRAQ)
ISA Certified Arborist, WE-13284A
Ari Rogers USFWS 10(a)(1)(A) Recovery Permit #TE 41340D-0, California tiger salamander and California
red-legged frog
CDFW MOU SC-13818, California tiger salamander (under Woodruff for CTS as an authorized
individual)
Certified Ecological Restoration Practitioner-in-Training (CERPIT) CERPIT #0678, Society for
Ecological Restoration
California Endangered Species Act Plant Voucher Collecting Permit 2081 1(a)-18-081-V
Aurelie Hening Sub-permittee USFWS 10(a)(1)(A) Recovery Permit #TE-34570A-3.2, western snowy plover
Brendan Champlin ISA Certified Arborist (WE-13739AU)
Brett Hanshew USFWS 10(a)(1)(A) Recovery Permit #TE-67570A-0, California tiger salamander (Sonoma
County-Distinct Population Segment and Santa Barbara County-Distinct Population Segment),
California red-legged frog, San Francisco Garter Snake, Vernal pool branchiopods
CDFW MOU: SC-009343, California tiger salamander, Foothill yellow-legged frog, and San
Francisco Garter Snake
Brian Nissen 10(a)(1)(A) Recovery Permit (PER0011950), California tiger salamander, California red-legged
frog
CDFW Scientific Collection Permit (SC-190180001)
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
34
Jesse Reebs USFWS 10(a)(1)(A) Recovery Permit #TE-01769B-3, California tiger salamander, San Francisco
Garter Snake, Alameda whipsnake, California Ridgway’s rail
CDFW MOU: SC-010272, California tiger salamander, San Francisco Garter Snake, Alameda
whipsnake, California Ridgway’s rail
Julie Woodruff USFWS 10(a)(1)(A) Recovery Permit #TE-71409C-0, California red-legged frog, California tiger
salamander, and Sierra Nevada yellow-legged frog
CDFW MOU: SC-13782, California tiger salamander, foothill yellow-legged frog, and Sierra
Nevada yellow-legged frog
USGS Bird Banding Lab Master Bander #24106, Northern saw-whet owl, western screech-owl,
and
burrowing owl
Kyle Verblaauw USFWS 10(a)(1)(A) Recovery Permit #ESPER0045160, California tiger salamander, California
red-legged frog
SCP# S-211500002-21363-001, California tiger salamander, California red-legged frog, Pacific
treefrog, American bullfrog, Foothill yellow-legged frog, California newt, Redbellied newt,
Rough-skinned newt
Ability to Respond Quickly to Changes in Schedule
The nature of these projects lends itself to last-minute schedule changes due to weather, fire risk, and
other unpredictable conditions. Sequoia’s team of cross-trained local biologists are already approved by the
CDFW and USFWS to survey and monitor for the sensitive species found within the Project area. Because
our staff are deployed from our offices in San Jose and Walnut Creek, we require minimal mobilization and
travel time. This allows us to hit the ground running at project kickoff, and to rapidly mobilize fully qualified
staff, accommodating concurrent work and changing project needs. Sequoia will respond to Town requests
within 30 minutes, and we can schedule qualified biologists for field surveys and monitoring efforts within
24 hours of requests, or less.
Full Understanding of PSA Implementation under the CalVTP
Sequoia has deep experience in both development and implementation of the PSA process. In addition to
supporting clients and contractors during the implementation phase, and monitoring fuel reduction in
accordance with environmental measures of the CalVTP, Sequoia has also authored several approved PSAs.
Because we bring this experience, the Town can be assured that Sequoia understands the process
thoroughly and can find ways of streamlining certain parts of the process to better benefit species, cost and
timelines. Recent Sequoia PSAs can be found (here and here) and Sequoia has contributed to the
development of several PSA’s under the Marin Wildfire Prevention Authority (here). As part of past PSA
processes, Sequoia has also developed PSA addenda as necessary.
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
35
Client Testimonials and Letters of Recommendation
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
36
East Bay Regional Park District
Kristen Van Dam, Resource Analyst/Ecologist
“Sequoia has provided biological monitoring support for my program for nearly five years. Our program is
large and complex, and involves potential impacts to several threatened species. Sequoia is always on top of
it. Sequoia’s project managers are sharp, communicative, and thorough. Their biologists are great with the
crews, and largely due to their guidance we rarely see compliance issues. They are experts on the species we
work with, and leverage their expertise to ensure the least possible risk to them. My project manager
provides prompt weekly updates, and monitoring reports arrive complete and clearly organized. Any
questions and issues that come up with project compliance are communicated promptly and resolved easily.
One of the most impressive things about Sequoia is that the staff are not there merely to provide a service;
staff actively engage in collaborative problem-solving with the client, which has saved my agency money
and time. Their staff are highly qualified scientists, but the best kind of scientists – with a keen eye toward
communication and customer service. I know that my project manager has my project’s best interests at
heart, and I trust them completely. I would recommend Sequoia for any biological compliance project
without hesitation.”
Diablo FireSafe Council
Cheryl Miller, Executive Coordinator
“The team at Sequoia Ecological Consulting was critical to effective hazardous fuel reduction for the North
Orinda Shaded Fuel Break. By having their biologists evaluate sites before work began we could avoid
potential environmental impacts and accelerate the project. Their staff’s expertise continued to guide field
crews throughout the work, giving the whole project team confidence that we could adjust the project to
meet the best management practices and comply with the myriad of environmental requirements, while
reducing the potential of wildfire.”
San Mateo RCD
David Cowman, Forest Ecologist
“I’d like to echo the gratitude for the great communication in addition to the level of flexibility you all have
provided throughout the project. These types of projects are tricky to coordinate with all the moving pieces,
and I greatly appreciate your willingness to send bios when necessary to fill in when our own staff and
County Parks staff weren’t available.”
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
37
California State Parks, Bay Area District
Natural Resource Program Environmental Scientist
“Sequoia staff were professional, friendly and flexible, even while working in difficult post-wildfire
environments with a variety of challenges. The assessments and survey methodologies paid exceptional
attention to detail and the resulting deliverables were top notch.”
City of Suisun City Public Works
Nick Lozano, Associate Engineer/Project Manager
“Because my emails and phone calls are promptly returned, I always feel that I am Sequoia’s only client. Our
projects come with their own unique challenges relating to field conditions and permit restrictions, and
Sequoia’s knowledgeable staff has always arrived at feasible and cost-effective solutions that were readily
approved by the City and the regulatory agencies. Sequoia’s staff are well-versed on regulatory permits,
permitting strategy, and how to complete projects in compliance with regulatory requirements.“
Attachment B - Required Forms
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms
CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-1
ATTACHMENT B - PROPOSAL FORMS
(To be returned with Proposal. Also See Request for Proposal
Section 6 for Additional Required Information)
PROPOSER
Name:
Address:
1st Contact person (Name):
Title: Office Tel:
Direct/Cell: Fax:
Email:
2nd Contact person (Name):
Title: Office Tel:
Direct/Cell: Fax:
Email:
BUSINESS TYPE:
Proposer, if selected, intends to carry on the business as (check one):
Individual
Joint Venture
Partnership
Corporation
Year incorporated? In what state?
When authorized to do business in California?
Other (explain):
Sequoia Ecological Consulting, Inc.
99 South Almaden Boulevard, Suite 600, San Jose, CA 95113
Debie Montana
CEO and Principal Biologist 925-855-5500
925-989-7011
dmontana@sequoiaeco.com
Kyle Verblaauw
Project Manager 925-855-5500
201-787-1738
kverblaauw@sequoiaeco.com
x
2011 California
2011
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-2
ADDENDA
To assure that all Proposers have received each addendum, check the appropriate box(es) below.
Failure to acknowledge receipt of an addendum/addenda may be considered an irregularity in
the Proposal:
Addendum number(s) received (check and initial):
____1
____2
____3
____4
____5
____Other
____No Addendum/Addenda Were Received
ADDITIONAL INFORMATION
Number of years providing the specified service: ______________________________________
Names and titles of all officers and directors:
_____________________________________________________________________________
_____________________________________________________________________________
If an individual or partnership, provide the following information:
Formation date of company: ______________________________________________________
Name and address of all partners, indicating whether they are general or limited partners:
______________________________________________________________________________
_____________________________________________________________________________
11
Debie Montana, CEO and Principal Biologist; Bill Montana, Secretary/CFO
Tashi MacMillen, Principal Director - Technical Services; Sarah Blanchfield, Principal Director -
Operations in Management; Melissa Krause, Marketing Director
N/A - S Corporation
N/A - owned 100% by Debie Montana, CEO - 1342 Creekside Drive, Walnut Creek, CA 94596
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-3
List the names, titles, and qualifications of the key personnel who will perform work under this
Agreement as well as their roles in relation to the Agreement. Identify the primary biologist to
be designated for the Town. Include their certifications, experience, and training.
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
Indicate whether Proposer has ever failed to complete any Agreement awarded to it. If so, note
when, where, and why. Attach additional sheets, if necessary.
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
Indicate whether Proposer has been or is the subject of a bankruptcy or insolvency proceeding
or subject to assignment for the benefit of creditors.
______________________________________________________________________________
______________________________________________________________________________
Principal Biologist - Debie Montana.
All resumes are included in the proposal Appendix.
Sequoia has never failed to complete any agreement in its history.
Sequoia has never been the subject of a bankruptcy or insolvency proceeding.
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-4
SUBCONTRACTORS
Attached hereto and incorporated herein is the complete and entire list of subcontractors to be
employed by the undersigned in the performance of the work.
Company__________________________________________________________________
Location___________________________________________________________________
Describe work to be contracted_________________________________________________
__________________________________________________________________________
Company__________________________________________________________________
Location___________________________________________________________________
Describe work to be contracted: _______________________________________________
__________________________________________________________________________
Company__________________________________________________________________
Location___________________________________________________________________
Describe work to be contracted: ________________________________________________
_________________________________________________________________________
Montrose Environmental Group
266 Grand Ave #210, Oakland, CA 94610
Cultural Resources support (if needed)
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-5
REFERENCES
List three (3) references for work of a similar nature to the Services performed within the last
five (5) years. References should be from a California municipality, county or a state or federal
agency if possible. Preference will be given for references whose work was similar in scope and
character to the Project.
Reference 1
Name of Agency:
Agency Address:
Contact Name and
Title:
Contact Telephone:
Contact Email:
Contract Amount:
Description of
Services Provided:
Date Services Were
Provided:
Reference 2
Name of Agency:
Agency Address:
Contact Name and
Title:
Contact Telephone:
Contact Email:
Contract Amount:
Moraga-Orinda Fire District
120 Moraga Way, Moraga, CA 94556
Jeff Isaacs, Fire Marshal
(925) 258-4513
jisaacs@mofd.org
Sequoia has provided environmental compliance support to MOFD on its vegetation management and shaded fuel break projects since 2019. Our role has spanned the full process including providing grant application support and mapping, habitat assessments,
project planning, PSA and associated document preparation under the CalVTP, treatment
prescriptions, public outreach, and implementation compliance.
2019 – Present
CAL FIRE
059 Highway 9, Felton, CA 95018
Sarah Collamer, CZU Forester I – VMP
(831) 254-1792 (cell)
Sarah.Collamer@fire.ca.gov
$1,316,268.93 to date
$32,322
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-6
Description of
Services Provided:
Date Services Were
Provided:
Reference 3
Name of Agency:
Agency Address:
Contact Name and
Title:
Contact Telephone:
Contact Email:
Contract Amount:
Description of
Services Provided:
Date Services Were
Provided:
RESERVATION
It is understood that the Town reserves the right to reject this Proposal, but that this Proposal
shall not be withdrawn for a period of 45 days from the date prescribed for its opening.
DISCLOSURE
The undersigned declares that this Proposal is not made in the interest of or on behalf of any
undisclosed person, partnership, company, association, organization or corporation; that the
Proposal is genuine and not collusive or sham; that the undersigned has not directly or
indirectly induced or solicited any other Proposer to put in a false or sham Proposal and has not
directly or indirectly colluded or agreed with any Proposer or anyone else to put in a sham
Proposal or to refrain from bidding; that the undersigned has not directly or indirectly sought
by agreement, communication or conference with anyone to fix his/her Proposal price or the
Proposal price of any other Proposer, or to fix any overhead, profit or cost element of such
Proposal price or of that of any other Proposer, or to secure any advantage against the Town of
Sequoia provided focused endangered species and botanical surveys to ensure
environmental compliance in advance of fuel reduction activities and adherence to
CAL FIRE’s Fuel Reduction Avoidance and Minimization Measures (AMMs).
July 2019
San Mateo Resource Conservation District
80 Stone Pine Road, Suite 100 Half Moon Bay, CA 94019
David Cowman, Forest Ecologist
650.712.7765 x 107
david@sanmateorcd.org
Sequoia has supported programmatic vegetation treatment activities for the RCD on an as-needed basis, conducting nesting bird and special-status species surveys, habitat and
tree assessments, bat roosting habitat assessments, and visual searches for woodrat
middens. We recently submitted a PSA for the La Honda Fuel Break project, which
recently started implementation, which Sequoia is monitoring.
June 2021 – Present
$323,471.79 to date
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-7
Los Gatos or anyone interested in the proposed Contract; that the only persons or parties
interested in this Proposal as principals are those named herein; that all statements contained
in this Proposal are true; that the undersigned has not directly or indirectly, submitted his/her
Proposal price or any breakdown thereof, or the contents thereof, or divulged information or
data relative thereto, to any other persons, partnership, corporation, or association except to
such person or persons as have a direct financial interest in Proposer’s general business; and
that the undersigned has not accepted any Proposal from any subcontractor or vendor through
any Proposal depository, the Bylaws, Rules or Regulations of which prohibit or prevent the
undersigned from considering any Proposal from any subcontractor or vendor, which is not
processed through said Proposal depository, or which may prevent any subcontractor or
vendor from bidding to any general contractor who does not use the facilities of or accept bids
from or through such Proposal depository; and that the undersigned has not paid, and will not
pay, any fee to any corporation, partnership, company, association, organization, Proposal
depository, or to any member or agent thereof to effectuate a collusive or sham Proposal.
WORDS AND PHRASES
Wherever in this Proposal an amount is stated in both words and figures, in case of discrepancy
between words and figures, the words shall prevail; if all or any portion of the Proposal is
required to be given in unit prices and totals and a discrepancy exists between any such unit
prices and totals so given, the unit prices shall prevail.
CERTIFICATION
The undersigned certifies that the Proposal Documents have been thoroughly read and
understood and that, except as may be specifically noted and contained in addenda, there are
no discrepancies or misunderstandings as to the meaning, purpose or intent of any provision in
the Proposal Documents or as to the interpretation of the same. The undersigned hereby
incorporates by reference, the same as though set out in full, all provisions of Request for Bids
published by the Town and pertaining to the work described in this Proposal.
The names of all persons Interested in the foregoing Proposal as principals are as follows:
____________________________________________________________________________
Important Notice: If Proposer or other interested person is a corporation, give legal name of
corporation, state where incorporated and names of the president and secretary thereof; if a
partnership, give name of the firm, also names of all individual co-partners composing firm; if
Proposer or other interested person is an individual, give first and last names in full.
PROPOSER’S SIGNATURE
No Proposal shall be accepted which has not been signed in ink in the appropriate space below:
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-8
By signing below, the submission of a Proposal shall be deemed a representation and
certification by the Proposer that they have investigated all aspects of the RFP, that they are
aware of the applicable facts pertaining to the RFP process, its procedures and requirements,
and they have read and understand the RFP. No request for modification of the Proposal shall
be considered after its submission on the grounds that the Proposer was not fully informed as
to any fact or condition.
(1)If Proposer is INDIVIDUAL,
sign here:
Proposer’s Signature
Proposer’s typed name and title
Date:
(2)If Proposer is PARTNERSHIP or
JOINT VENTURE, at least (2) Partners
or each of the Joint Venturers
shall sign here:
Partnership or Joint Venture Name
(type or print)
Signature
Name of Member of the Partnership or Joint
Venture (type or print)
Date:
Signature
Name of Member of the Partnership or Joint
Venture Name (type or print)
Date:
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-9
(3) If Proposer is a CORPORATION,
the duly authorized officer(s) shall
sign as follows:The undersigned certify that they are respectively:
(Title)
and (Title)
of the corporation named below; that they are
designated to sign the Proposal Cost Form by
resolution (attach a certified copy, with corporate
seal, if applicable, notarized as to its authenticity or
Secretary’s certificate of authorization) for and on
behalf of the below named CORPORATION, and that
they are authorized to execute same for and on
behalf of said CORPORATION.
Corporation Name (type or print)
Signature
Name and Title (type or print)
Date:
Signature
Name and Title (type or print)
Date:
Corporation – 2 officer signatures required (one from each group, unless person
signing holds officer positions in both Group 1 and 2):
Group 1: Chief Executive Officer, Chairman of the Board, President, or Vice
President
Group 2: Secretary, Assistant Secretary, Chief Financial Officer, Treasurer,
Assistant Treasurer
Chief Executive Officer
Chief Financial Officer
Sequoia Ecological Consulting, Inc.
Debie Montana, CEO and Principal Biologist
June 27, 2024
Bill Montana, Chief Financial Officer
June 27, 2024
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-10
CONFLICT OF INTEREST STATEMENT
This form must be printed out, completed, and submitted with the Bid.
The undersigned declares:
I/We ___________________________ (Insert Name) have the following financial, business, or
other relationship with Town of Los Gatos that may have an impact upon the outcome of the
contract. If none, please specify that no other relationships may have an impact on this contract
or Project.
I/We (Insert Name) have the following current clients who may have a financial interest
in the outcome of this contract. If none, please specify that no other clients may have a financial
interest with an impact on this contract or Project.
Pursuant to Government Code section 1090 and any other laws, rules and regulations that may
apply, the Proposer covenants that neither it, its subcontractors nor employees presently have
an interest, and shall not acquire any interest, direct or indirect, financial or otherwise that would
conflict in any manner or degree with contract awarded from this Request for Bids. Proposer
certifies that to the best of its knowledge, no one who has or will have any financial interest in
the contract awarded from this RFB is an officer or employee of the Town. Through its submittal
of a Bid, Proposer acknowledges that it is familiar with Section 87100 et seq. and Section 1090 et
seq. of the Government Code of the State of California and will immediately notify the Town if it
becomes aware of any facts concerning the contract to be awarded that constitute a violation of
said provisions.
Furthermore, if there is reason to believe that collusion exists among the Proposers, the Town
may refuse to consider Proposals from participants in such collusion. No person, firm, or
corporation under the same or different name, shall make, file, or be interested in more than
one Proposal for the same work unless alternate Proposals are called for. A person, firm, or
corporation who has submitted a sub-proposal to a Proposer, or who has quoted prices on
materials to a Proposer, is not thereby disqualified from submitting a sub-proposal or quoting
prices to other Proposers. Reasonable ground for believing that any Proposer is interested in
more than one Proposal for the same work will cause the rejection of all Proposals for the work
in which a Proposer is interested. If there is reason to believe that collusion exists among the
Proposers, the Town may refuse to consider Proposals from participants in such collusion.
Proposers shall submit as part of their Proposal documents the completed Non-Collusion
Declaration provided herein.
Not Applicable
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-11
I, on behalf of the Proposer, declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct and that this declaration is executed on
_________________ [date], at ___________________[Town], _______________[state].
Proposer Name (Person, Firm, Corp.)
Address
______________________________________________________________________________
Town, State, Zip
_________________________________ ___________________________________
Title of Authorized Representative Name of Authorized Representative
________________ ___________________________________
(Date) (Signed)
June 27, 2024 California
Sequoia Ecological Consulting, Inc.
1342 Creekside Drive Walnut Creek, CA 94596
CEO and Principal Biologist Debie Montana
JUne 27, 2024
Walnut Creek
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-12
BYRD ANTI-LOBBYING AMENDMENT 31 U.S.C. § 1352
(AS AMENDED)
This form must be printed out, completed, and submitted with the Bid.
The undersigned certifies, to the best of his or her knowledge and belief, that:
(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the
undersigned, to any person for influencing or attempting to influence an officer or
employee of an agency, a Member of Congress, an officer or employee of Congress, or an
employee of a Member of Congress in connection with the awarding of any Federal
contract, the making of any Federal grant, the making of any Federal loan, the entering
into of any cooperative agreement, and the extension, continuation, renewal,
amendment, or modification of any Federal contract, grant, loan, or cooperative
agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid to any
person for influencing or attempting to influence an officer or employee of any agency, a
Member of Congress, an officer or employee of Congress, or an employee of a Member
of Congress in connection with this Federal contract, grant, loan, or cooperative
agreement, the undersigned shall complete and submit Standard Form-LLL, “Disclosure
Form to Report Lobbying,” in accordance with its instructions.
(3) The undersigned shall require that the language of this certification be included in the
award documents for all subawards at all tiers (including subcontracts, subgrants, and
contracts under grants, loans, and cooperative agreements) and that all subrecipients
shall certify and disclose accordingly.
This certification is a material representation of fact upon which reliance was placed when this
transaction was made or entered into. Submission of this certification is a prerequisite for
making or entering into this transaction imposed by section 1352, title 31, U.S. Code. Any
person who fails to file the required certification shall be subject to a civil penalty of not less
than $10,000 and not more than $100,000 for each such failure.
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-13
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration is executed on
________[date], at ______________[Town], ___[state]
By: __________________________________________
Name: __________________________________________
Title: __________________________________________
June 27, 2024 CA
Debie Montana
CEO and Principal Biologist
Walnut Creek
Vegetation Management Risk Reduction Project (Open Space) Project Exhibit B – Proposal Forms CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page B-14
NON-COLLUSION DECLARATION
This form must be printed out, completed, and submitted with the Bid.
The undersigned declares:
I am the ______________________ [Insert Title] of ____________________________,[Insert
name of company, corporation, LLC, partnership or joint venture] the party making the foregoing
Proposal.
The Proposal is not made in the interest of, or on behalf of, any undisclosed person, partnership,
company, association, organization, or corporation. The Proposal is genuine and not collusive or
sham. The Proposer has not directly or indirectly induced or solicited any other proposer to put
in a false or sham Proposal. The Proposer has not directly or indirectly colluded, conspired,
connived, or agreed with any Proposer or anyone else to put in a sham Proposal, or to refrain
from responding. All statements contained in the Proposal are true.
Any person executing this declaration on behalf of a Proposer that is a corporation, partnership,
joint venture, limited liability company, limited liability partnership, or any other entity, hereby
represents that he or she has full power to execute, and does execute, this declaration on behalf
of the Proposer.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration is executed on
________[date], at ______________[Town], ___[state]
By: __________________________________________
Name: __________________________________________
Title: __________________________________________
CEO and Principal Biologist Sequoia Ecological Consulting, Inc.
JUne 27, 2024 CA
Debie Montana
CEO and Principal Biologist
Walnut Creek
Vegetation Management Risk Reduction Project (Open Space) Project Attachment D – Proposal Price Sheet
CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page D-1
ATTACHMENT D - PROPOSAL PRICE SHEET
The quantities shown on the Proposal forms are approximate only, being given as a basis for the
comparison of Proposals, and the Town does not, expressly or by implication agree that the
actual amount of work will correspond therewith, but reserves the right to increase or decrease
the amount or class or portion of the work as may be deemed necessary or advisable by the
Director of Parks & Public Works. This Proposal will be rejected if Proposer fails to provide a
Proposal for each item.
The Town reserves the right to make a comparison of Proposals based on any combination of the
above alternate Proposal items.
For all services described in the Proposer’s Scope of Services, unless excluded by the Town in
description of services below, the Town shall consider unit prices below to include all labor,
equipment, fees of any kind, overhead, insurance, fuel, materials, surcharges, disposal fees, and
any other costs associated with and necessary for the Proposer to perform such service. No
qualifications, exemptions, or alterations of services described below will be allowed. Failure to
comply will result in disqualification of Proposal.
Proposed Cost Per Task for All Locations
Task Description Cost ($)
Task 1: Meetings and Project Documentation
Task 2: Data Collection and Review
Task 3: Preconstruction Surveys
Task 4: Environmental Awareness Training
Task 5: Field Monitoring of Construction Activities
Task 6: Project Environmental Reporting
TOTAL PROJECT COST
Work will be paid hourly Not to Exceed the values listed above. Proposers must attach a rate
sheet to this Proposal Price Sheet.
$15,585
$2,090
$50,540
$3,529
$76,240
$34,181
$181,165
Vegetation Management Risk Reduction Project (Open Space) Project Attachment D – Proposal Price Sheet
CIP 832-4508 / Federal Project No. HMGP DR-4407-506-75R Page D-2
SIGNATURE
_____________________________________ ____________________________________
Signature Title
_____________________________________ ____________________________________
Name (printed or typed) Date
_____________________________________ ____________________________________
Telephone Fax
_____________________________________ ____________________________________
Tax ID Number Los Gatos Business License Number
19114593
CEO and Principal Biologist
Debie Montana June 27, 2024
(925) 989-7011
454136627
N/A
Sequoia Ecological Consulting, Inc.
Proposal for Town of Los Gatos - Environmental Monitoring Services for
Vegetation Management Risk Reduction Project (Open Space)
Resumes
Debie Montana, M.S., Certified Project Manager
President and Principal Biologist
AREAS OF EXPERTISE
Program and Project
Management
Fuels Management Strategy,
Planning, and
Implementation
CalVTP Implementation
Stakeholder Engagement
Technical Team Development
and Management
EDUCATION
M.S., Biological Sciences with
Concentration in Organismal
Biology, Conservation and
Ecology, San Jose State
University
B.S., Biological Sciences with
Concentration in Conservation
and Organismal Biology, San
Jose State University
Certificate, Project
Management, University of
California, Davis
SELECT TRAININGS
CEQA/NEPA Workshop
Habitat Conservation Planning
and Implementation
Land Use in California
Debie Montana is a Project Management Professional and the President of
Sequoia Ecological Consulting, a small, woman-owned business enterprise. As
President she is responsible for the corporate operation and fulfillment of
contractual obligations for the firm. Since founding Sequoia in 2011, Mrs.
Montana has grown her Company to a full-time staff of 45 qualified biologists,
planners, project managers and regulatory specialists providing large-scale wildfire
mitigation program support, project management, CEQA/NEPA compliance,
CalVTP Support, pre- and post-fire surveys and analysis, and regulatory compliance
support at the state and federal levels Certified in Project Management by the
University of California at Davis, Mrs. Montana oversees large-scale fuels
treatment projects spanning diverse regions and habitats. She serves as Principal-
in-Charge on Sequoia's fuels treatment efforts for numerous Moraga-Orinda Fire
District efforts, as well as planning and implementation of more than 40 projects
for the Marin Wildfire Prevention Authority. She served in the same capacity on
projects including the Caldor Fire Restoration efforts with El Dorado RCD, dozens
of projects under East Bay Regional Park District's Fuel Management Program, and
she also worked closely with the San Mateo County Parks Department and CAL
FIRE to provide focused species and rare plant surveys for fuel reduction activities
covering more than 2,000 acres of park land.
With more than 20 years of experience in the environmental industry, Mrs.
Montana has developed a resume with extensive program management
experience within both the private and public sectors. She oversees complex
environmental compliance efforts that apply her conservation and organismal
biology and fisheries background with her strong an understanding of all aspects
of environmental analysis, and her extensive knowledge of environmental
permitting through federal, state and local agency processes.
As a wildlife biologist, Mrs. Montana has worked on projects and with technical
scientific experts throughout California. Her duties have ranged from authoring
biological assessments and Natural Environmental Studies, to performing resource
management and mitigation plans, to overseeing large-scale fuels treatment,
utility, and development projects spanning regions, a variety of habitats, and
numerous permitting agencies. Mrs. Montana’s main strength is providing
oversight, quality assurance, budget control, schedule adherence, and technical
review on large-scale projects. She has built and managed multi-disciplinary teams
of technical experts, to successfully complete projects across the state.
Resume
Debie Montana, M.S., Certified Project Manager
Page
2 of 5
RELEVANT EXPERIENCE
San Mateo Resource Conservation District La Honda Fuel Break Project
San Mateo Resource Conservation District (RCD) is preparing to implement the La Honda Shaded Fuel Break, which
constitutes an approximately 19-mile fuel break surrounding the community of La Honda in unincorporated San Mateo
County. Sequoia’s team is designing a CalVTP treatment plan that will balance the needs of the RCD, the La Honda
community, stakeholders, and environmental protection while reducing dense vegetation and ladder fuels to provide
safe access for firefighting personnel and potentially slow the spread of lower-intensity fires. Because portions of the
project area include land outside of the State Responsibility Area (SRA), Sequoia is preparing a Project Specific Analysis
and Addendum to the CalVTP PEIR. Sequoia will support the RCD with implementation of the project by developing
contracting strategies and efficiencies, reviewing contract specifications and work descriptions/orders, and providing
inspection support.
Sonoma County Regional Parks Hood Mountain Regional Park & Open Space Preserve Vegetation
Management Planning for Ecosystem Resilience, Fire Hazard Reduction, and Climate Adaptation
Following heavy impacts to the area by the 2017 Nuns Fire and the 2020 Glass Fire, Sequoia is providing consultant
services for vegetation management planning throughout the 950-acre Hood Mountain Regional Park and Open Space
Preserve. Sequoia performed a thorough review of existing vegetation management documents and past management
activities from the 1990s, and visited the site to complete a current condition assessment. Based on the information
gathered, Sequoia is preparing a draft Vegetation Management Report that integrates prior plans and evaluations, and
includes GIS mapping to prioritize management recommendations. The Vegetation Management Report will undergo
levels of review with stakeholders for input into the final document.
Moraga-Orinda Fire District, Tunnel Hills East Bay Shaded Fuel Break Project
Sequoia provided vegetation mapping services and support for MOFD’s grant application, and we are assisting with
planning and implementation. Permitted under the CalVTP, this project required a Project-Specific Analysis (PSA)
checklist and CalVTP addendum. Sequoia supported MOFD with the PSA process, preparing a full PSA Addendum. We
managed biological and cultural resource assessments, SPR implementation, environmental training for crews,
environmental compliance monitoring, agency coordination, communication with the public, mapping, and contractor
coordination. Protocol-level surveys for sensitive plants and Alameda whipsnake are anticipated, and if needed Sequoia
may also provide protocol or reconnaissance-level surveys for other species, wetland delineations, and agency
coordination. Sequoia conduct detailed preliminary surveys of proposed work areas before commencement of work,
and will also conduct post-treatment surveys of treated areas. The data collected during these surveys will help MOFD to
document permit compliance as well as inform the need for future maintenance work and assess post-treatment fire
risk.
Moraga-Orinda Fire District, North Orinda Shaded Fuel Break Project
Divided into a total of 55 “treatment units”, this 1,900-acre fuel break project employed a variety of specific fuel
management techniques including understory clearing, tree pruning, brush clearing, chipping, mowing, and select tree
removal. Mrs. Montana participated in a series of meetings with Moraga-Orinda Fire Department, members of the
public, and agencies including CAL FIRE, EBMUD, EBRPD, CDFW, and CNPS. Sequoia compiled BMPs to satisfy the
requirements of existing habitat conservation plans, incidental take permits, and biological opinions which had already
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undergone the CEQA process for projects nearby. Sequoia identified suitable Avoidance and Minimization Measures that
would satisfy the existing Habitat Conservation Plan for Fuel Reduction Projects, and the EIR, Biological Opinion and
Wildfire Hazard Mitigation Plan. We collaborated with CDFW and USFWS on field methods, crew training, and biological
monitoring that would be implemented. Sequoia collaborated closely with fire crews to develop fire prescriptions, and
performed permit interpretation and recommendations for communication with USFWS and CDFW. Sequoia also helped
determine the appropriate treatment type (hand tools vs mastication) for various work areas based on quality of habitat
for AWS, legal restrictions of the site (private vs EBMUD vs EBRPD property) and safety/slope concerns.
Diablo Fire Safe Council/Moraga Orinda Fire Department, Canyon Shaded Fuels Break
The Diablo Fire Safe Council provided the Moraga Orinda Fire Department with a grant to conduct fuels thinning
activities in a critical fire break area of Pinehurst Road in Canyon, California. Sequoia was asked to provide biological
services in support of the fuels reduction project including nesting bird surveys in advance of fuels treatment activities,
and consulting services for environmental compliance.
San Mateo County Parks Fuel Break Projects, Huddart and Wunderlich County Parks
San Mateo County Parks is planning on implementing fuels reduction work spanning over 70 acres of chaparral,
redwood forest, and oak woodland habitat starting in 2021. In support of this effort to prepare for forest health
treatments and to avoid impacting sensitive plant species and natural communities within the Project area, Sequoia
assisted the Parks District by performing three rounds of targeted rare plant surveys in both Huddart and Wunderlich
County Parks. Focal species included: Kings Mountain manzanita, western leatherwood, and Michael’s rein orchid.
Georgetown Divide Resource Conservation District Georgetown Fuel Reduction Project
Working collaboratively with the Georgetown Divide Resource Conservation District (GDRCD), Sequoia provided
environmental planning and compliance services for this project which reduced understory ladder and surface fuels by
managing and removing vegetation on and within 200 feet of BLM land in the South Fork American River Watershed.
The project minimizes the risk of wildfire damage to forest resources, communities, and infrastructure in the project
area. Sequoia’s ensured project compliance with the Migratory Bird Treaty Act, Federal Endangered Species Act, and
California Endangered Species Act. Our approved biologists were on-site throughout the project to conduct surveys for
nesting birds, plants, and other sensitive species and resources. The biologists delineated and flagged no-disturbance
buffers wherever the presence of a sensitive/special-status species (e.g., nesting birds, western pond turtle, California
red-legged frog, Yuma myotis, Red Hills soaproot) and/or their nests are detected. Sequoia mapped out the project area
to keep the contractor aware of the locations of any biologically sensitive resources to protect these resources during
project activities.
Caldor Fire Recovery, Forest Restoration Action Plan
The El Dorado County Resource Conservation District (RCD) played a lead role in post-fire recovery effort for area
effected by the Caldor Fire. This pilot project was established to create a scalable, efficient, and effective process for
future use by future fire recovery efforts. Under the Caldor Fire Recovery Plan, Sequoia has been tasked with providing
environmental and cultural compliance to aid in post fire restoration of fire-impacted non-industrial private lands within
the Caldor burn area of El Dorado County. Sequoia has worked closely with the El Dorado Resource Conservation District
to develop appropriate regulatory pathways for various communities affected by the fire. Through a Categorical
Exemption for the Grizzly Flat subdivision, and use of the Cal-VTP PEIR for the remainder of the non-industrial private
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lands, Sequoia has provided project design and management, development of the Categorical Exemption and
implementation of the Cal-VTP PEIR, and environmental compliance surveys and monitoring of protected resources
including (rare plants, aquatic features, California red-legged frog, foothill yellow-legged frog, Sierra Nevada yellow-
legged frog, western pond turtle, great gray owl, California spotted owl).
El Dorado Resource Conservation District-Fire Adapted 50 Phase 1B – Wildland Fire Protection Program
The Fire Adapted 50 Phase IB - Wildland Fire Protection Program is Phase B of a series of projects identified by CAL FIRE,
the U.S. Forest Service, El Dorado Resource Conservation District, and the Georgetown Divide Resource Conservation
District. The project will conduct vegetation treatments on both private and USFS lands designed to interrupt potential
wildfire behavior by reducing the rate of spread and intensity of fire. Sequoia is providing environmental consulting
services to ensure Project compliance with all Federal, State, and local regulations and project permits; including but not
limited CEQA/NEPA compliance (evaluation, surveys, consultations, communications, information exchange, reporting,
monitoring, mapping and document management, etc.).
East Bay Regional Park District’s Wildlife Hazard Reduction Program and Resource Management Plan
Since 2014, Mrs. Montana has worked with the East Bay Regional Park District (EBRPD) on planning and implementation
of their FEMA-funded Wildfire Hazard Reduction and Resource Management Plan. The program extends throughout
more than 40 sites on EBRPD property in Alameda and Contra Costa Counties. Sequoia’s work includes interpretation of
their Biological Opinion, Incidental Take Permit, and Environmental Impact Report. Sequoia worked with the District to
create standard operating procedures for programmatic work, submitting annual reports to USFWS and CDFW, and
coordinates communication and meetings with the District, manages and supervises field activities, performs focused
surveys, conducts environmental training for field and Park personnel, and provides biological monitoring services for
implementation of Avoidance and Minimization Measures during fuels treatment activities.
Marin Wildfire Prevention Authority Environmental Compliance Consulting Services for Wildfire
Prevention/Hazard Mitigation Projects
The Marin Wildfire Prevention Authority is working to permit a large number of fire prevention projects throughout
Marin County. The projects use a wide variety of fuels reduction treatments to achieve their goals, from goat grazing to
creating large fuel breaks using mechanical mastication. Sequoia is providing biological services during planning and
implementation each of the 40-plus projects within the MWPA work plan. Sequoia’s early involvement during the
planning phase allows us to assist in designing projects that avoid environmental impacts and maximize available funds.
As projects are approved and fully permitted, Sequoia biologists assist with specialized surveys including nesting bird
surveys, sensitive plant surveys, invasive species mapping, protocol-level northern spotted owl surveys, and biological
monitoring of work, when required.
CAL FIRE’s Kings Mountain Road and Quarry Park Fuel Reduction Projects
Mrs. Montana oversaw biological support efforts on CAL FIRE’s King’s Mountain Road Fuel Break project in San Mateo
County Parks Department’s Huddart County Park. Sequoia’s technical specialists provided focused endangered species
and botanical surveys ensure AMM compliance in advance of fuel reduction activities and adherence to CAL FIRE’s Fuel
Reduction Avoidance and Minimization Measures. Work included pre-treatment assessments were conducted,
collecting data regarding species cover, composition, and invasive species present. Post-treatment assessments will be
conducted within a year to treatment to determine maintenance intervals for the fuel break.
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Sequoia also provided environmental consulting services to the San Mateo Santa Cruz unit of CAL FIRE for the Quarry
Park Emergency Shaded Fuel Break Project. Sequoia assisted CAL FIRE with special protection measures and potential
operational (biological) constraints. Sequoia’s biologists conducted preliminary surveys of proposed work areas focusing
on the presence of nesting birds, sensitive species and their habitat, existing erosion or signs of other work already
competed, and safety hazards such as wasp nests or access issues.
PG&E’s Wildfire Safety Inspection Program Throughout PG&E Territory
Following the 2017 and 2018 wildfires, PG&E’s Wildfire Safety Inspection Program (WSIP) has been implemented in
addition to routine inspection and maintenance programs, to further reduce wildfire risk. As part of this program, Mrs.
Montana is overseeing permit compliance support, technical studies, endangered and sensitive species studies, surveys,
and data collection, and project reviews at various sites throughout PG&E’s service territory, from Humboldt to
Bakersfield.
U.S. Bureau of Reclamation (USBR) Battle Creek Salmon and Steelhead Restoration Project
Sequoia is currently leading the environmental compliance support team for the Bureau of Reclamation’s Battle Creek
Salmon and Steelhead Restoration Project, which will restore about 48 miles of salmonid habitat. Sequoia is providing
technical expertise to the USBR and is supporting fish and wildlife and regulatory issues. Planning and implementation
includes extensive terrestrial and aquatic surveys, permit reviews and applications, vegetation plans, fish and other
resource management plans, and environmental compliance monitoring and reporting during construction.
Sugarloaf Ridge State Park Post-Wildfire Northern Spotted Owl Surveys
Following the October 2017 wildfires, northern spotted owl surveys were requested at Sugarloaf Ridge State Park to
document owl presence within the park during the 2018 field season. Mrs. Montana oversaw performance of surveys
satisfying the USFWS 1-year protocol requirement. Sequoia biologists conducted a desktop review of prior northern
spotted owl territories and habitat within the park, mapped suitable habitat and placing survey points, and prepared the
year-end survey report and submitting it to State Parks.
Kyle Verblaauw, MS
Assistant Project Manager | Biologist
AREAS OF EXPERTISE
Biological monitoring
Special-status species surveys
Amphibian dip net surveys
Burrow excavations
Vegetation mapping
EDUCATION
MS, Environmental
Management (Ecology),
University of San Francisco
BA, Environmental Studies
(Biology), University of California Santa Barbara
UC Education Abroad Program,
(Marine Biology and Terrestrial
Ecology), University of
Queensland, Australia
PERMITS/CERTIFICATIONS
USFWS 10(a)(1)(A) Recovery
Permit #ESPER0045160 for
California Tiger Salamander and
California Red-legged Frog
CDFW Scientific Collecting
Permit #S-211500002-21363-
001 and MOU for California
Tiger Salamander, and
California Red-legged Frog
MEMBERSHIPS AND
PROFESSIONAL ASSOCIATIONS
The Wildlife Society
Golden Gate Audubon Society
Kyle Verblaauw is an experienced field biologist with more than 9 years of
professional experience. Kyle has extensive monitoring and special-status species
experience within California. While completing a Master’s degree in
Environmental Management at the University of San Francisco, Kyle has worked as
in the consulting industry with experience conducting pre-construction surveys,
seine and dip-net surveys, biological and regulatory compliance monitoring, rare
plant surveys, non-native vegetation mapping, nesting bird surveys, providing
worker environmental awareness training (WEAP), and managing/coordinating
projects.
He has experience working on projects with special-status species including the
California tiger salamander, California red-legged frog, foothill yellow-legged frog,
Alameda whipsnake, salt marsh harvest mouse, western burrowing owl, giant
kangaroo rat, Pacific herring, western snowy plover, San Francisco garter snake,
San Francisco dusky-footed woodrat, nesting birds, and marine mammals. Special
status plant species observed include fountain thistle and Crystal Springs lessingia.
Kyle specializes in California tiger salamander and California red-legged frog work
and has experience implanting PIT tags, conducting/overseeing burrow
excavations, checking pitfall traps, cover boards, and exclusion fences, and
conducting amphibian dip-net surveys. He possesses a USFWS 10(a)1(A) Recovery
Permit for California tiger salamander and California red-legged frog, and a
California SCP and MOU for California tiger salamander. He has also attended
various professional workshops focusing on California red-legged frog, foothill
yellow-legged frog, California tiger salamander, western pond turtle, salt marsh
harvest mouse, western burrowing owl, western snowy plover, Ridgway’s rail,
California least tern, Alameda whipsnake, as well as Pacific herring and salmonids.
RELEVANT EXPERIENCE
Marin Wildfire Prevention Authority (MWPA) – Environmental Services for
Wildfire Prevention/Hazard Mitigation Projects; Marin County, CA
April 2022 - Ongoing
The Marin Wildfire Prevention Authority (MWPA) is working to permit a large
number of fire prevention projects throughout Marin County. The projects use a
wide variety of fuels reduction treatments to achieve their goals, from goat
grazing to creating large fuel breaks using mechanical mastication. Sequoia is
providing biological services during planning and implementation for each of the
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40-plus projects within the MWPA work plan. Sequoia’s biologists conduct literature reviews of biological resources and
field assessments, prepare and present environmental trainings, and provide ongoing specialized expertise to assist the
MWPA. Mr. Verblaauw’s role includes:
Project management and coordination, client communications, coordination of biologists for preconstruction
surveys, nesting bird surveys, and botanical surveys
Develop Biological Resources Report and prepare other deliverables for client
Conducting northern spotted owl survey using call back survey method (1 adult male observed)
Conducting nesting bird, woodrat, and rare plant surveys ahead of vegetation clearing crews
Identified nesting great horned owl, Anna’s hummingbirds (2), and bushtits (2)
San Mateo County Parks, Edgewood Shaded Fuels Break, Redwood City, CA
May 2022 – August 2022
San Mateo County Parks (SMCP) is conducting fuels reduction activities in Edgewood County Park to provide a defensible
space buffer against potential wildfires for nearby homes. As project coordinator for this effort, Mr. Verblaauw’s roles
included:
Providing project support and oversight for field biologists
Quality control and assurance of weekly deliverables
Communications and coordination with Parks staff
Conducting surveys for special status species and nesting birds
San Mateo County Parks, Quarry Park Shaded Fuels Break, El Granada, CA
June 2022 - September 2022
San Mateo County Parks (SMCP) is conducting fuels reduction activities and habitat restoration at Quarry Park. The goal
of the project is to reduce flammable vegetation onsite, including removal of numerous eucalyptus trees and clearing
the understory of dense brush. As the project coordinator for this effort, Mr. Verblaauw’s roles included:
Providing project support and oversight for field biologists
Quality control and assurance of deliverables
Communications and coordination with Parks staff
Conducting pre-activity surveys for San Francisco dusky-footed woodrat, California red-legged frog, and nesting
birds, as well as flagging resources and communicating survey results to crews on the ground
US Bureau of Reclamation - B.F. Sisk Dam SOD Modifications - Phase I; Gustine, CA
August 2022 – Ongoing
The B.F. Sisk Dam Safety of Dams Modification Project is a joint venture by the United States Bureau of Reclamation
(BOR) and California Department of Water Resources (DWR). Sequoia is contracted by NW Construction and the BOR to
provide environmental compliance support during Phase 1 of the B.F. Sisk Dam Safety of Dams Modification Project,
which will improve public safety by increasing the height of the dam and adding stability berms and other safety
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features to reduce the likelihood of the dam overtopping during an earthquake. Our role involves special-status species
monitoring and surveys, burrow excavation, and management of the tule elk herd present onsite. Species known to
occur or with potential to occur on the project include tule elk, San Joaquin kit fox, California tiger salamander, California
red-legged frog, American badger, burrowing owl, Swainson’s hawk, and bald eagle. Mr. Verblaauw’s roles include:
Conduct monthly CRLF visual encounter surveys (day and night) in occupied CRLF habitat within the Project area
Conducting exclusion fence checks for CTS and CRLF
Surveying for suitable burrow habitat for SJKF and CTS
Maintenance on Thule elk camera traps
Monitoring construction activities
East Bay Regional Park District McCosker Sub-Area Creek Restoration and Recreational Improvements
Project; Montclair, CA
August 2020 - Ongoing
The East Bay Regional Park District has been restoring ecological function to two existing culverted creeks in the
McCosker sub-area of Sibley Regional Park. Working under a CDFW Incidental Take Permit (No. 2081-2018-070-03),
USFWS Biological Opinion (#08ESMF00-2019-F-015), USACE and RWQCB 401/404 permits, and CDFW 1600 Lake and
Streambed Alteration Agreement. Mr. Verblaauw’s duties include:
Conducting long-term vegetation monitoring to determine success of restoration plantings
Conducting biological monitoring work activities for special-status species: nesting birds and raptors, Alameda
whipsnake, California red-legged frog, and San Francisco dusky-footed woodrat
Developing the 2022 annual status report summarizing covered project activities and describing project
compliance with permits
Bourdet Ranch Conservation Banking; Santa Clara County, CA
May 2023 - Present
Sequoia Ecological Consulting, Inc. is assisting the Bourdet Family to establish a conservation bank on their 3,354-acre
property in Santa Clara County, CA. Sequoia is tasked with all necessary biological surveys to determine
absence/presence of listed species within the property, including pond sampling for California tiger salamander and
California red-legged frog. Once biological resources are evaluated, Sequoia is conducting a bank feasibility analysis and
designing the conservation bank. Sequoia is directly coordinating with the agencies on behalf of the Bourdet family and
drafting all required documents for establishing a conservation bank including a draft prospectus, prospectus, and
additional documents based on agency evaluation of resources on-site. Mr. Verblaauw supported this project by:
Performing aquatic surveys for amphibian surveys, including California tiger salamander and California red-
legged frog
Performing eDNA sampling for CTS and CRLF
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Upper Llagas Creek Flood Protection Project; Gilroy, San Martin, and Morgan Hill, CA
September 2019 - Ongoing
Under contract with the Santa Clara Valley Water District, several contractors are conducting channel improvements on
existing creek reaches and constructing new creek channels to reduce or prevent flooding during major storm events.
Sequoia has performed work for the contractor as well as owner to assist in meeting habitat preservation, restoration,
and improvement goals as stipulated by the project plan. Kyle’s responsibilities include:
Conducting pre-construction surveys and construction monitoring for nesting birds, and general special-status
species under CDFW and USFWS permits.
Identifying habitats and suitable breeding locations for federally and state special-status species
Monitoring turbidity, dissolved oxygen, temperature, pH, and erosion within the watercourses
Special-status species: California red-legged frog, California tiger salamander, western pond turtle
San Mateo County Parks, Sawyer Camp Trail Culvert Replacement Project, San Mateo County, CA
July 2022 - September 2022
San Mateo County Parks (SMCP) is replacing 16 failed or badly degraded culverts along the Sawyer Camp Trail near the
Crystal Springs Reservoir. Prior to construction implementation, special-status species surveys are required, including
surveys for: nesting birds, San Francisco dusky-footed woodrat, California red-legged frog, San Francisco garter snake,
and western leatherwood. Biological monitoring during all ground-disturbing activities is also required. Mr. Verblaauw
supported SMCP on this project as Sequoia’s project coordinator by:
Providing project support and oversight for field biologists
Quality control and assurance of deliverables
Communications and coordination with Parks staff
Conducted biological monitoring
East Bay Regional Park District Routine Maintenance Projects; Alameda and Contra Costa Counties, CA
September 2020 – Ongoing
Sequoia Ecological is supporting EBRPD with an on-call contract to conduct pre-activity surveys, water quality
monitoring, and biological compliance monitoring for routine maintenance projects under their regulatory permits.
Species to be avoided include: Alameda whipsnake, California red-legged frog, California tiger salamander, giant garter
snake, Ridgway’s rail, California least tern, salt marsh harvest mouse, San Joaquin kit fox, vernal pool branchiopods,
snowy plover, pallid manzanita, nesting birds, and San Francisco dusky-footed woodrat. Mr. Verblaauw’s duties
included:
Providing environmental awareness training to construction crews
Conducting nesting bird surveys and preconstruction surveys for special status species
Biological monitoring during work activities and ensuring project’s compliance with regulatory permits
Will Johnson
Climate Resiliency and Restoration Program Manager
AREAS OF EXPERTISE
Restoration
Construction management &
QA/QC
Invasive Plant Management
Planning & Implementation
Natural Resource
Management & Monitoring
Mitigation Planning
Compliance Management
Plant/Wildlife Surveys
EDUCATION
MS, Biological Sciences,
University of Rhode Island
BS, Biological Sciences,
University of Rhode Island
PERMITS/CERTIFICATIONS
California Contractors State
License Board – C-27 Landscape
Construction License, 1086577,
exp. 2026
California Department of
Pesticide Regulation – Qualified
Applicator License, 162032,
exp. 12/2024
Will Johnson has 16 years of experience in habitat restoration, mitigation
planning, inspection and compliance support, natural resource monitoring, and
both project and program-level administration and management. Mr. Johnson has
provided services on a variety of projects throughout northern California for the
past 10 years. He has worked as a field biologist, site superintendent, manager,
crew leader, and equipment operator. He has extensive experience in reviewing
and implementing work from proposal phase to closeout based on standard
specifications, plans and permit requirements. Mr. Johnson has authored site
management and long-term maintenance plans, cost proposals, budgets, technical
write-ups and project approaches. He has both partnered with and contracted for
a diverse number of clients including County, State, Federal-level groups as well as
consulting firms, non-profit organizations, special districts, and private
landowners.
Mr. Johnson has conducted project work in the vicinity of numerous special status
species including California Ridgway’s rail, California black rail, salt marsh harvest
mouse, San Francisco garter snake, giant garter snake, California red-legged frog,
and California tiger salamander. Mr. Johnson has conducted rare plant surveys
and managed projects which had the following species: western burrowing owl,
Swainson’s hawk, northern goshawk, golden eagle, foothill yellow-legged frog,
Alameda whipsnake, western pond turtle, dusky-footed woodrat.
RELEVANT EXPERIENCE
Mount Tamalpais Fuel Reduction (Various Phases); Mill Valley, CA
2020 - 2023
Mr. Johnson supported Marin Municipal Water District (MMWD) in implementing
various fire fuel reduction work, including understory mastication, and hand-crew
clearing and thinning work. The work fell under MMWD’s Biodiversity, Fire, and
Fuels Integrated Plan (BFFIP). Crews worked in and around sensitive watershed
areas and habitat. The entirety of the project was located in steep, wildland
terrain. Mr. Johnson served as the project manager.
Developed cost proposal and technical approach to various restoration
activities
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
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Quarry Park Shaded Fuel Break; El Granada, CA
2023
Mr. Johnson supported San Mateo County Parks (SMCP) in implementing fuels reduction, including removing eucalyptus
trees and understory vegetation. The work occurred in and around habitat for San Francisco dusky-footed woodrat,
California red-legged frog, and nesting birds. Mr. Johnson served as the project manager (contractor).
Developed cost proposal and technical approach to construction
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
Green Oaks Restoration; Pescadero, CA
2023
San Mateo County Resource Conservation District (SMCRCD) worked in conjunction with California State Parks to
implement a riparian and grassland drainage restoration project. The project included site preparation, grading, log
placement, spoils management, and revegetation post equipment work. Mr. Johnson was the project manager for
construction (contractor).
Developed cost proposal and technical approach to restoration and maintenance
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
Kitteridge Wetland Restoration; Los Gatos, CA
2023
Mr. Johnson worked to support the restoration of a retention pond drainage feature for San Jose Water Company
(SJWC). The creation of wetlands at Lake Kittredge was designed to provide habitat for California red-legged frogs,
western pond turtles, and nesting olive-sided flycatchers. The scope included re-grading and earthmoving of seasonally
flooded depressions, channels and general re-contouring, followed by revegetation and re-seeding of stabilized areas.
Will oversaw construction activities and worked with the client to develop approaches to work, erosion control and re-
seeding efforts. Mr. Johnson was the project manager for construction (contractor).
Developed cost proposal and technical approach to construction
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
Arroyo de la Laguna Creek Restoration; Pleasanton, CA
2022 – 2023
The City of Pleasanton’s Arroyo de la Laguna project included site preparation, invasive plant management, restoration
planting and long-term maintenance. Mr. Johnson served as the project manager for construction (contractor) and
worked alongside Sequoia (consultant).
Developed cost proposal and technical approach to restoration
Coordinated with City and consulting biologist
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Performed project management and permit compliance
San Rafael Creek Restoration & Maintenance; San Rafael, CA
2021 - 2023
Sonoma Marin Area Rail Transit’s (SMART) San Rafael Creek project included site preparation, invasive plant
management, restoration planting and long-term maintenance. Mr. Johnson served as the project manager for
construction (contractor) and worked alongside Sequoia (consultant).
Developed cost proposal and technical approach to restoration
Coordinated with SMART and consulting biologist
Performed project management and permit compliance
McCosker Creek Restoration and Improvements; Orinda, CA
2022 - 2023
East Bay Regional Park District’s (EBRPD) McCosker Creek project included invasive plant management and long-term
maintenance of native plants and site infrastructure. Mr. Johnson served as the project manager for maintenance
(contractor) and worked alongside Sequoia (consultant).
Oversaw crew logistics and scheduling
Coordinated with EBRPD and consulting biologist
Performed project management and permit compliance
Special-status species: nesting birds and raptors, Alameda whipsnake, California red-legged frog, and San
Francisco dusky-footed woodrat
Bioregional Habitat Restoration; Sunol, CA
2017 - 2023
San Francisco Public Utilities Commission (SFPUC) manages watershed areas throughout Alameda County. The project
included several years of invasive plant management in wildland areas. Treatments were targeted to support native
plant establishment and achieve SFPUC’s mitigation and management objectives. Work occurred in and around areas
with sensitive species. Mr. Johnson served as a project manager.
Developed cost proposal and technical approach to restoration and maintenance
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
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NASA Ames Research Center Wetland Restoration & Mitigation; Santa Clara, CA
2018
As part of mitigation, NASA was required to investigate soils at a site at Moffett Field in Santa Clara County. Mr. Johnson
led a construction team that provided native habitat and erosion control services to a consulting firm for the duration of
the soil investigation across the several acre site. The project scope included brush and vegetation clearing ahead of
drilling/soil sampling; silt/exclusion fence installation, maintenance and removal; harvesting and transplanting wetland
and marsh plant species including pickleweed and saltgrass; hydroseeding and hand-broadcast seeding of native
lowland, upland and transitional marsh species; hand-watering and non-chemical weed control to facilitate plant
establishment.
Developed cost proposal and technical approach to construction and invasive plant work
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
On-Call Restoration & Maintenance; Various East Bay Regional Park properties, CA
2022 - 2023
Mr. Johnson supported East Bay Regional Park District (EBRPD) in implementing various stages of restoration and
construction work at several different park units/locations. Work included invasive plant management, erosion control,
site maintenance, irrigation troubleshooting and repair, and fence building. Mr. Johnson served as the project manager
and lead contract point of contact for all on-call task orders.
Developed cost proposal and technical approach to various restoration activities
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
Tilden Nature Area Restoration; Berkeley, CA
2018-2023
Mr. Johnson supported East Bay Regional Park District (EBRPD) in restoring pond features, installing native riparian
vegetation, constructing trails, fencelines and park amphitheater. Work occurred in and around sensitive creek habitat.
Project included 5 years of follow-up maintenance and stewardship of the site. Mr. Johnson served as the project
manager (contractor).
Developed cost proposal and technical approach to construction
Oversaw crew logistics and scheduling
Performed project management and coordination with consultants
Kelyn McGuire
Staff Biologist
AREAS OF EXPERTISE
Nesting bird surveys
Biological monitoring
Pre-construction surveys
EDUCATION
BA Environmental Studies
(Anthropology), University of
California, Santa Barbara
UC Education Abroad Program,
(Anthropology) University of
Edinburgh, Scotland
MEMBERSHIPS AND
PROFESSIONAL ASSOCIATIONS
The Wildlife Society
Golden Gate Audubon Society
Kelyn McGuire is an enthusiastic biologist with more than a year of experience.
Kelyn has experience conducting nesting bird surveys and special-status species
surveys for California tiger salamander, California red-legged frog, Alameda
whipsnake, western pond turtle, San Francisco dusky-footed woodrat. She has
assisted in rare plant surveys under the supervision of a senior botanist. Kelyn also
has performed California spotted owl surveys under the direction of experienced
biologists. She has also assisted with bumble bee surveys under the guidance of a
permitted biologist. Kelyn has experience performing pre-construction surveys,
daily biological monitoring, and delivering environmental awareness trainings.
RELEVANT EXPERIENCE
Moraga Orinda Fire District, Tunnel East Bay Hills Fuel Break; Orinda, CA
April 2023 – Ongoing
The Moraga-Orinda Fire District is conducting a fuels reduction project along key
access roads in the cities of Moraga and Orinda, CA to minimize the impact of
wildfires on local communities by developing fuel breaks and keep roads
accessible for evacuation and emergency response. Sequoia is providing biological
support on the project to ensure environmental compliance with the fuels
reduction work. In support of this project, Kelyn’s role has included:
Conduct pre-construction surveys for special-status species: California
tiger salamander, California red-legged frog, western pond turtle,
Alameda whipsnake, San Francisco dusky-footed woodrat
Perform pre-treatment surveys prior to work being done
Environmentally train fuel reduction crews regarding sensitive species
in a high-risk work environment
Monitor and provide insight to work crews to preserve sensitive
species habitat such as core-scrub for Alameda whipsnake and nesting
birds
Carrying out rare plant surveys under the supervision of Senior
Botanists
Providing active monitoring during all pile burning done by fire
officials
Set up trail cameras to track animal activity and behaviors
Place coverboards outside of the project area to provide refuge
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Special-status species: Western pond turtle, California red-legged frog, California tiger salamander, Alameda
whipsnake, San Francisco dusky-footed woodrat, Northern spotted owl
Contra Costa County Fire Protection District (ConFire) - Lafayette/Walnut Creek Shaded Fuel Break, Contra
Costa County, CA
May 2023 – Ongoing
This shaded fuel break project extends about 7 miles surrounding the community of Rossmoor and is expected to treat
approx. 250 acres through the reduction of dense vegetation and removal of ladder fuels. Sequoia is providing
reconnaissance and plant surveys ahead of vegetation removal, then daily monitoring during implementation. Kelyn’s
responsibilities as lead biologist include:
Helped project kickoff by conducting environmental training for all working crew members
Executed pre-treatment surveys of all project areas before commencement of any work
Organized pre and post treatment
Managed project coordination and assisted project manager with scheduling, client communication and
daily/weekly reporting
Accompanied Senior Biologist on bumble bee surveys targeting sensitive bumble bee species
Maintained strong communication between client, crew and Sequoia staff
Conduct daily pre-construction surveys for special status species ahead of days work
Recording and mapping rare plant sensitive vegetation communities
Performed reconnaissance surveys prior to implementation phase
Special-status species: Alameda whipsnake, California red-legged frog, California tiger salamander, San Francisco
dusky-footed woodrat, western pond turtle, Crotch’s bumble bee, California newt, sensitive bat species
Marin Wildfire Prevention Authority (MWPA) –Environmental Services for Wildfire Prevention/Hazard
Mitigation Projects, Marin County, CA
April 2023 – Ongoing
The Marin Wildfire Prevention Authority (MWPA) is working to permit a large number of fire prevention projects
throughout Marin County. The projects use a wide variety of fuels reduction treatments to achieve their goals, from goat
grazing to creating large fuel breaks using mechanical mastication. Sequoia is providing biological services during planning
and implementation each of the 40-plus projects within the MWPA work plan. Sequoia’s biologists conduct literature
reviews of biological resources and field assessments, prepare and present environmental trainings, and provide ongoing
specialized expertise to assist the MWPA. Kelyn’s role included:
Performing pre-activity surveys for special-status wildlife and plants, as well as nesting birds
Setting up acoustic monitors to record bird activity
Analyzing acoustic monitor data and providing concise data collection for the client
Conducting nesting bird surveys
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Special- status species: Northern spotted owl, California red-legged frog, foothill yellow-legged, Ridgway’s rail,
black rail, burrowing owl, Western snowy plover, salt marsh harvest mouse, Western bumblebee, monarch
butterfly, anadromous fish, various sensitive bat species
Bourdet Ranch Conservation Banking; Santa Clara County, CA
April 2024
Sequoia Ecological Consulting, Inc. is assisting the Bourdet Family to establish a conservation bank on their 3,354-acre
property in Santa Clara County, CA. Sequoia is tasked with all necessary biological surveys to determine
absence/presence of listed species within the property, including pond sampling for California tiger salamander and
California red-legged frog and special-status bumble bees. Once biological resources are evaluated, Sequoia is
conducting a bank feasibility analysis and designing the conservation bank. Sequoia is directly coordinating with the
agencies on behalf of the Bourdet family and drafting all required documents for establishing a conservation bank
including a draft prospectus, prospectus, and additional documents based on agency evaluation of resources on-site.
Kelyn supported this project by:
Field assistant for protocol level surveys for candidate bumble bee species (Crotch’s bumble bee)
Safe handling, catch and release of crotch’s bumble bee and other bumble bee species
Successfully identifying Crotch’s bumble bee and other bumble bee species
Assisting in data and mapping management
California State Parks, Mt. Diablo State Park Vegetation Treatment, Pretreatment Biological Surveys and
Monitoring; Contra Costa County, CA
April 2023 – May 2023
The Mt. Diablo State Park Vegetation Treatment project involves Cal State Parks identifying key areas in the park that
are at risk for wildfires. Multiple different vegetation removal companies are subcontracted to reduce fuel debris that
can pose a risk incidents of fire outbreaks. Sequoia biologists provide pretreatment surveys to identify rare plants,
special status species, and nesting birds to ensure that fuel removal is within environmental compliance. Kelyn’s duties
include:
Providing pre-construction surveys for special status species and nesting birds
Identifying habitat that can be suitable for special status species such as California red-legged Frog, Western
Pond Turtle and Alameda whipsnake
Providing biological monitoring and reporting
Mariposa Peak Ranch Long-Term Management; Merced and Santa Clara Counties, CA
April – May 2024
Sequoia Ecological Consulting is working to establish a conservation easement for Caltrans and a residential
development project on private land near Gilroy in order to offset impacts to California tiger salamander and California
red-legged frog. Kelyn’s responsibilities on this project included:
Assisting permitted biologists with pond sampling surveys for California red-legged frogs and California tiger
salamanders
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Aiding in eDNA collection from each pond
Taking measurements and data collection of California red-legged frog and California tiger salamanders
Conducting visual encounter surveys for western pond turtle, California red-legged frog, California tiger
salamander and bullfrogs
Perform VES eye-shine surveys for bullfrogs
Use dip net and seine net for protocol level surveys for special-status species
Anderson Dam Tunnel Water Quality Monitoring; Morgan Hill, CA
October 2023 – Ongoing
This project includes environmental compliance and biological support for heavy civil construction in habitat suitable for
several sensitive animal species. Under federal compliance orders, multiple regulatory agency permitting and technical
recommendations, and under the Santa Clara Valley Habitat Conservation Plan/Natural Community Conservation Plan,
Kelyn is responsible for:
Performing biological monitoring
Collecting water-quality data from Multi-Parameter Sondes located at different sites both upstream and
downstream from the project location
Ensuring proper equipment maintenance and calibration to acquire high quality data
Providing daily monitoring summaries to project managers
Special-status species: California tiger salamander, California red-legged frog, western pond turtle, steelhead,
coyote ceanothus, nesting birds, golden eagle, bald eagle, pallid bat
California State Parks, Northgate Road Emergency Repair Project; Contra Costa County, CA
June 2023 – October 2023
Mount Diablo State Park is conducting emergency repair work for culvert and road failures within the park. As a
subconsultant to ECORP, Sequoia is providing biological and compliance support for project implementation, including
pre-construction surveys for rare plants and biological monitoring during ground-disturbing activities. Species monitored
during this project include Alameda whipsnake, California red-legged frog, California tiger salamander, Peregrine falcon
and nesting birds. Kelyn supported this project by:
Providing biological monitoring and reporting to crews
Providing environmental training for crews
Special-status species: California tiger salamander, California red-legged frog, Alameda whipsnake, Peregrine
falcon, nesting birds, rare plants.
Nicolas Anderson
Biologist / Assistant Project Manager
AREAS OF EXPERTISE
Biological surveys
Habitat restoration
Construction monitoring
Forestry management
EDUCATION
BS, Fisheries, Wildlife, and
Conservation Biology,
University of Minnesota –
Twin Cities
PERMITS/CERTIFICATIONS
Wildland Firefighter Type II
National Pollutant Discharge
Elimination System (NPDES)
Construction Stormwater
Inspector
Nicolas Anderson has 5 years of experience in wildlife and vegetation surveys,
habitat restoration, construction monitoring, forestry management, and
geographic information systems (GIS). His surveying experience includes point-
count, mark-recapture for small mammals and fish, electrofishing, mist netting,
spotlight, dip netting, seining, hoop netting, telemetry, and herpetological surveys
for wetland index of biological integrity (IBI) assessments.
Nic’s threatened and endangered (T&E) biological surveys conducted in the
Midwest, Southeast U.S., and California include but are not limited to western pond
turtle, California red-legged frog, Indiana bat, Henslow’s sparrow, loggerhead sea
turtle, northern long-eared bat, greater prairie-chicken, loggerhead shrike, bald
eagle, Karner blue butterfly, Dakota skipper, and southern bog lemming.
Additionally, his T&E vegetation surveys have included but are not limited to
beaked spikerush, slender rush, sterile sedge, western prairie fringed orchid,
whorled nutrush, and stream parsnip.
RELEVANT EXPERIENCE
Marin Wildfire Prevention Authority, Environmental Compliance
Consulting Services for Wildfire Prevention/ Hazard Mitigation Projects;
Marin County, CA
October 2022 – Ongoing
The Marin Wildfire Prevention Authority (MWPA) is working to permit numerous
fire prevention projects throughout Marin County. The projects use a wide variety
of fuels reduction treatments to achieve their goals, from goat grazing to creating
large fuel breaks using mechanical mastication. Sequoia is providing biological
services during the planning and implementation on upwards of 40 projects within
the MWPA work plan. Sequoia’s biologists conduct literature reviews of biological
resources and field assessments, prepare and present environmental trainings,
and provide ongoing specialized expertise to assist the MWPA. Mr. Anderson’s
role included:
Performing GIS services to provide detailed figures for project
management and planning - GIS analyses include, but are not limited to,
determining total impacts per vegetation community, proximity and
impact analyses on T&E wildlife, plants, and critical habitats, impacts to
aquatic habitats, summaries of soil characteristics within project
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boundaries and surrounding areas, and depiction of on-the-ground environmental observations
Managing and updating GIS databases
Special- status species: Northern spotted owl, California red-legged frog, foothill yellow-legged, Ridgway’s rail,
black rail, burrowing owl, Western snowy plover, salt marsh harvest mouse, Western bumblebee, monarch
butterfly, anadromous fish, various sensitive bat species
Moraga-Orinda Fire District, Tunnel East Bay Hills Fuel Break Project; Orinda, CA
October 2022 – Ongoing
The Moraga-Orinda Fire District (MOFD) is conducting a fuels reduction project within Contra Costa County to create
large fuel breaks to reduce impacts from wildfire events. To assist with the implementation of this project, Nic is
responsible for:
Performing GIS services to provide detailed figures for project management and planning. GIS analyses include,
but are not limited to, determining total impacts per vegetation community, proximity and impact analyses on
T&E wildlife, plants, and critical habitats, impacts to aquatic habitats, summaries of soil characteristics within
project boundaries and surrounding areas, and depiction of on-the-ground environmental observations
Managing and updating GIS databases
San Mateo County Parks, Edgewood Shaded Fuel Break; Redwood City, CA
June 2022
In support of San Mateo County Parks in this fuel break project, Nic was responsible for:
Performing pre-construction surveys for special-status species and nesting birds
Conducting biological monitoring during work activities for nesting birds
Assisting with daily routine data collection and work activity summaries
Special-status species: California tiger salamander, California red-legged frog, Western pond turtle, Alameda
whipsnake, San Francisco dusky-footed woodrat
Anderson Dam Tunnel Water Quality Monitoring; San Jose, CA
April 2023 – Ongoing
This project includes environmental compliance and biological support for heavy civil construction in habitat suitable for
several sensitive animal species. Under federal compliance orders, multiple regulatory agency permitting and technical
recommendations, and under the Santa Clara Valley Habitat Conservation Plan/Natural Community Conservation Plan,
Nic is responsible for:
Performing pre-construction surveys for biological resources
Collecting water-quality data from MultiParameter Sondes located at different sites both upstream and
downstream from the project location
Ensuring proper equipment maintenance and calibration to acquire high quality data
Performing biological monitoring of sensitive habitats and species during construction when required by permits
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Providing daily monitoring summaries to project managers
Creating master Excel sheets to process collected water quality data for compliance evaluation
Writing soil sample reuse and monthly project update reports for client
Special-status species: California tiger salamander, California red-legged frog, Western pond turtle, DPS
steelhead, coyote ceanothus, nesting birds, golden eagle, bald eagle, pallid bat
San Mateo County Parks Department, Sawyer Camp Trail Culvert Replacement; Burlingame, CA
August 2022 – Ongoing
Supporting San Mateo County Parks for this culvert replacement project, Nic is responsible for:
Conducting pre-construction surveys for special-status species and nesting birds
Monitoring construction activities to ensure minimal impacts to special-status species and their habitats
Inspecting finalized work sites to ensure proper escape pathways for wildlife trapped in trenched areas
Conducting biological monitoring during work activities for nesting birds and special-status species
Completing daily routine data collection and work activity summaries
Special-status species: western pond turtle, San Francisco dusky-footed woodrat, California red-legged frog, San
Francisco garter snake
Valley Water, Cross Valley Pipeline Extension Project Fish Rescue; Coyote, CA
August 2022
In support of this pipeline extension project, Nic was responsible for:
Performing electrofishing surveys within the project area to minimize construction activity impacts on fish
populations
Identifying native fish species for relocation and invasive species for inventory
Assisting with daily monitoring reports and data collection
Special-status species: San Francisco dusky-footed woodrat, American badger, California red-legged frog,
California tiger salamander, Western pond turtle, roosting bats
City of San Jose, Storm Drain System Improvements; San Jose, CA
July 2022
Contributing to improvements in this storm drain project, Nic was responsible for:
Conducting worker environmental awareness program (WEAP) training for incoming contractors to identify
special-status species (specifically Western burrowing owls) within the prospective project area
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Valley Water, Upper Llagas Creek Flood Protection Project Phase 2A; Morgan Hill, CA
June 2022
Under contract with the Santa Clara Valley Water District, several contractors are conducting channel improvements on
existing creek reaches and constructing new creek channels to reduce or prevent flooding during major storm events.
Sequoia has performed work for the contractor as well as owner to assist in meeting habitat preservation, restoration,
and improvement goals as stipulated by the project plan. Nic’s responsibilities include:
Conducting pre-construction surveys and construction monitoring for nesting birds, and general special-status
species under CDFW and USFWS permits
Identifying habitats and suitable breeding locations for federally and state special-status species
Monitoring turbidity, dissolved oxygen, temperature, pH, and erosion within the watercourses
Special-status species: California red-legged frog, California tiger salamander, Western pond turtle
TRAININGS/CERTIFICATIONS
Storm Water Best Management Practices, Sequoia Ecological Consulting, 2022
Nesting Bird Ecology and Survey Practices, Sequoia Ecological Consulting, 2022
Identification of Hydraulic Features, Sequoia Ecological Consulting, 2022
Alameda Whipsnake Ecology and Identification, Sequoia Ecological Consulting, 2022
Construction Stormwater Inspector, National Pollutant Discharge Elimination System, 2020
Rosgen Level 1 Principles of Fluvial Geomorphology, 5 Smooth Stones, LLC, 2019
RiverMorph, 5 Smooth Stones, LLC, 2019
AutoCAD Civil 3D for Stream Restoration, 5 Smooth Stones, LLC, 2019
Culvert Design for Stream Connectivity and Aquatic Organism Passage, University of Minnesota – Twin Cities, 2019
S-130 Firefighter Training, S-190 Introduction to Wildland Fire Behavior, L-180 Human Factors in the Wildland Fire
Service, and IS-100 Introduction to Incident Command System, Wildland Firefighter Type II (FFT2), National Wildfire
Coordinating Group, 2018
Brian Nissen
Project Biologist
AREAS OF EXPERTISE
Field identification of
California flora and fauna
Ecological restoration project
oversight
Land management
Regulatory permitting
EDUCATION
BS, Natural Resources, Fisheries
and Wildlife Science, Oregon
State University
PERMITS/CERTIFICATIONS
10(a)(1)(A) Recovery Permit
(PER0011950), California tiger
salamander, California red-
legged frog
CDFW Scientific Collection
Permit (SC-190180001)
Brian Nissen is a restoration ecologist and field biologist with more than 6 years of
professional experience working with private industry consulting, federal and
state agencies compliance, and volunteer research projects. Brian has experience
providing permit oversight as well leading numerous ecological restoration
projects biological surveys across the greater San Francisco Bay Area including
special status species mitigation, riparian, oak woodland and savannah, and
grassland habitats restoration.
Skilled background in restoration ecology, land management, and rangeland
management/ecology. Areas of knowledge and expertise include restoration
project design, implementation, and upkeep, invasive plant management, native
plant propagation and establishment, grazing and mow regime management and
establishment, and irrigation systems.
Mr. Nissen holds 10(a)(1)(A) permits for conducting presence/absence surveys for
both California tiger salamander and California red-legged frog in Marin, Sonoma,
Lake, Napa, Solano, Contra Costa, Alameda, Santa Clara and San Mateo counties.
Additionally, Brian has extensive experience conducting biological monitoring for
these two species on construction projects across the greater Bay Area.
In addition to working with the California tiger salamander and California red-
legged frog Mr. Nissen has experience conducting surveys and working with other
special-status species including: nesting birds and raptors, burrowing owl,
Swainson’s hawk, western pond turtle, San Francisco dusky-footed woodrat, fairy
shrimp, giant garter snake, Alameda whipsnake, and San Joaquin kit fox.
Experience with rare plants includes Santa Cruz robust spineflower, Congdons
tarplant, San Joaquin spearscale, and Santa Clara dudleya.
Mr. Nissen has 100+ hours of passerine banding experience using mist nets at the
Coyote Creek Field Station with San Francisco Bay Bird Observatory (SFBBO).
RELEVANT EXPERIENCE
Santa Clara Valley Water District, Anderson Dam Tunnel Project; Morgan
Hill, CA
February 2024 - Present
Sequoia is providing biological support for the Anderson Dam Tunnel Project.
Sequoia’s biologists are supporting environmental compliance for heavy civil
construction in habitat suitable for California red-legged frog, California tiger
salamander, western pond turtle, steelhead salmon Central California Coast
Distinct Population Segment, coyote ceanothus, nesting birds, pallid bat, and bald
eagle. This project is being conducted under Federal Energy Regulatory
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Commission emergency compliance orders with technical recommendations from the US Fish and Wildlife Service
(USFWS) and National Marine Fisheries Service, and permitting through the US Army Corps of Engineers, State Water
Resources Control Board, California Department of Fish and Wildlife (CDFW), and Santa Clara Valley Habitat
Conservation Plan/Natural Community Conservation Plan. Brian’s roles include:
Ensuring water quality permit measures were met using data collected while checking water quality monitoring
sondes and equipment
Conducting soil sampling ensuring soil quality parameters are recorded and met
Conducting nesting bird surveys ensuring the project is within compliance with the Migratory Bird Treaty Act
and other environmental and legal constraints.
County of San Mateo, Half Moon Bay Landfill Stormwater Mgmt Emergency Repair; Half Moon Bay, CA
February 2024 – March 2024
The stormwater drainpipe failure occurred on a coastal bluff next to the closed Half Moon Bay Landfill. An ephemeral,
unnamed drainage flows through the drainpipe. The drainage was conveying water during a site visit on January 25,
2024. Rerouting the runoff may be anticipated; however, this is dependent on timing of the start of repair work. The
failed drainpipe is currently not functioning, and the revetment is at risk of further collapse. The repairs are intended to
address stormwater discharge and limit erosion caused by stormwater runoff as a result of the damage caused by
previous excessive stormwater discharge. Work will be conducted in accordance with BMPs detailed in the County of
San Mateo Routine Maintenance Program Manual. A biologist will be onsite to actively monitor all work. Project
activities are anticipated to begin in February 2024. The full duration of the project is expected to be approximately 3
weeks. As a staff biologist on this effort, Brian’s roles include:
Provide biological monitoring for nesting birds and specials status species
Fairview Residential Development; Hollister, CA
February 2020 – May 2022
Residential housing development located in Hollister, California. Performed preconstruction surveys and daily biological
monitoring of construction activates to ensure protection of wildlife species. Administered environmental training to
crew members and interfaced with construction crews on environmental issues. As a biological monitor Brian’s duties
included:
Performing pre-construction surveys for nesting birds and other biological resources
Preforming burrow excavations of potential CTS burrows prior to ground disturbance activities
Performing biological monitoring of sensitive habitats and species during construction when required by permits
Performing biological monitoring of permit conditions such as exclusionary fence and escape ramp installation.
West of Fairview Residential Development; Hollister, CA
March 2022 – May 2022
Residential housing development located in Hollister, California. Performed preconstruction surveys and daily biological
monitoring of construction and restoration activities to ensure protection of wildlife species and permit condition
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compliance. Administered environmental training to crew members and interfaced with construction crews on
environmental issues. As a biological monitor Brian’s duties included:
Performing pre-construction surveys for nesting birds and other biological resources
Preforming burrow excavations of potential CTS burrows prior to ground disturbance activities
Performing biological monitoring of sensitive habitats and species during construction when required by permits
Performing biological monitoring of permit conditions such as exclusionary fence and escape ramp installation.
Communication Hill Residential Development; San Jose, CA
June 2021
Large scale mix-use residential development. Site was formerly home to one of the largest populations of Santa Clara
Valley dudleya (Dudleya setchellii), which is a low growing perennial succulent with pale yellow flowers that grows in
rocky outcrops in serpentine grasslands. Santa Clara dudleya is found only in the Coyote Valley area of Santa Clara
County, California, from San Jose south about 25 miles to Gilroy. As a biologist on this project Brian’s duties included:
Conducting rare plant surveys for Santa Clara Valley dudleya
Contra Costa Water District – Rock Slough Fish Screen Vegetation Management; Oakley, CA
June 2019 and June 2020
Aquatic vegetation management at the Contra Costa Water District Rock Slough Fish Screen. Biological monitors
provided salvage and documentation for aquatic biological resources during annual aquatic vegetation removal at the
Rock Slough Fish Screen facility. As a biological monitor Brian’s duties included:
Performing biological monitoring of sensitive habitats and species during maintenance activities
Performing pre-construction surveys for nesting birds and other biological resources
species, native plant cover, and restoration plant survivorship. As the land manager of the property and staff biologist
Mr. Nissen’s duties included:
Assisting and leading annual CTS and CRLF surveys
Assisting and leading annual plant survivorship counts
Annual long term resource management and monitoring, including invasive plant management, restoration
planting management, pond maintenance, grazing management, and erosion prevention and mitigation
U.S. Department of Homeland Security
Region 9
1111 Broadway, Suite 1200
Oakland, California 94607
www.fema.gov
November 13, 2023
Nancy Ward, Director Governor’s Authorized Representative California Governor’s Office of Emergency Services 3650 Schriever Avenue Mather, CA 95655
Reference: Application Approval, HMGP DR-4407-506-75R Town of Los Gatos, California Vegetation Management Risk Reduction Mitigation Project, Phase 2 FIPS Code: 085-44112, Supplement 259
Dear Nancy Ward:
We approve and issue Hazard Mitigation Grant Program (HMGP) funds for the Town of Los Gatos, HMGP
DR-4407-506-75R, Vegetation Management Risk Reduction Mitigation Project, Phase 2.
The total project cost for Phase 2 is $2,121,793.00. As shown in the enclosed Obligation Report - Supplement
259, we are obligating $1,591,344.75 for the 75 percent Federal share; the 25 percent non-Federal share is $530,448.25. We are obligating $35,974.97 for the 100 percent Federal share of Subrecipient Management Costs (SRMC). These funds are available in SmartLink for immediate and eligible disbursements. The following is a summary of the approved funding:
Approvals: Federal Share: Non-Federal Share: Total Project Cost:
Phase 1, Supplement 61 $64,188.00 $21,396.00 $85,584.00
Phase 2, Supplement 259 $1,591,344.75 $530,448.25 $2,121,793.00
Management Cost $35,974.97 $0.00 $35,974.97
This HMGP project approval and obligation of funds are subject to the following conditions:
1. Scope of Work (SOW) – The project is to perform hazardous fuels reduction in Santa Clara County,California. Work will occur in five project areas: 1) Heintz Open Space, 2) La Rinconada Park, 3)Novitiate Park, 4) Santa Rosa Park, and 5) Worcester Park.
2.Project Completion Date – The work schedule included in the project application indicates that
Phase 2 will take 18 months to complete; therefore, the project completion date is May 13, 2025.Please inform the sub-recipient that work completed after this date is not eligible for federal funding,and that federal funds may be de-obligated for work completed outside the completion date when there
is no approved time extension.
ATTACHMENT 2
Nancy Ward November 13, 2023 Page 2 of 2 3. Project Closeout – Within 120 days of project completion, all project funds must be liquidated and final closeout documentation for the project must be submitted to FEMA. Please note the project must comply with Code of Federal Regulations Title 2, Part 200 reporting requirements at the time of closeout. 4. Record of Environmental Considerations (REC) – FEMA has determined that the Proposed Action is covered by the Region 9 Programmatic Environmental Assessment (PEA) under Section 2.5, Vegetation Management. This category covers the removal of vegetation and hazardous fuels, therefore, the Proposed Action is consistent with these PEA categories. A list of Typical BMPs is attached. Compliance with the BMPs appropriate for this scope of work is a condition of funding. Failure to comply with these conditions may jeopardize federal assistance including funding. Please reference the enclosed REC for further information. 5. Extraordinary Circumstances – This project approval has requested "extraordinary circumstance" provision pursuant to 44 CFR 20 l .6(a)(3) for the Town of Los Gatos to complete the local hazard mitigation plan. We approve the request for "extraordinary circumstances" to complete the hazard
mitigation plan. The hazard mitigation plan must be completed within 12 months of the award date. If the plan is not approved within this timeframe, the project grant will be terminated, and any costs incurred after notice of the grant's termination will not be reimbursed. 6. Standard Conditions – This project approval is subject to the enclosed Standard Mitigation Grant Program (HMGP) Conditions, amended August 2018. Please note that federal funds may be de-obligated for work that does not comply with these conditions. If you have any questions or need further assistance please contact Aaron Lim¸ Hazard Mitigation Assistance Specialist, by email at aaron.lim@fema.dhs.gov, or phone (510) 627-7036. Sincerely,
Kathryn Lipiecki
Director, Mitigation Division FEMA Region 9 Enclosures (5): Obligation Report - Supplement 259 Project Management Report Record of Environmental Considerations (REC) Best Management Practices (BMP) Standard Mitigation Grant (HMGP) Conditions cc: Ron Miller, Acting State Hazard Mitigation Officer, California Governor’s Office of Emergency Services
Robyn Fennig, Co-Acting California State Hazard Mitigation Officer, California Governor’s Office of Emergency Services Robert McCord, Chief, Hazard Mitigation Assistance Branch, FEMA Region 9
Obligation
HAZARD MITIGATION GRANT PROGRAM
FEDERAL EMERGENCY MANAGEMENT AGENCY HMGP-OB-01
State Recipient
DisasterNo SupplementalNoActionNoStateApplication IDAmendmentNoFEMAProject No
4407 -2 506 4 259 CA Statewide
Project Title :Los Gatos, Vegetation Management Risk Reduction ProjectLos GatosSubrecipient:
Subrecipient FIPS Code:085-44112
75 R
11:03 AM
11/09/2023
FYSubrecipient Management
Cost AmountProject Amount Total Obligation IFMIS Date IFMIS Status
$35,974.97$1,591,344.75 2024$1,627,319.72 11/09/2023 Accept
Comments
Comment:Approve funding of Federal Share $1,591,344.75 and SRMC $35,974.97, totaling $1,627,319.72 for DR-4407-506-75R-Town of Los
Gatos-Vegetation Management Mitigation Project (Phase 2).
User Id:Date:11/09/2023 RHIRST
REILLY HIRST
AARON LIM
Authorization
Preparer Name:
HMO Authorization Name:
Preparation Date:11/09/2023
HMO Authorization Date:11/09/2023
Total AmountPreviously Allocated Total AmountPreviously Obligated Total Amount Pending Obligation Total Amount Availablefor New Obligation
$0.00$0.00$1,655,532.75$1,655,532.75
Page 1 of 1
FEMA
Project Number State RecipientAmendment
Number App IDDisaster
Number
75-R
Los Gatos
085-44112
Subrecipient:
FIPS Code:Project Title :Los Gatos, Vegetation Management Risk Reduction Project
CA Statewide25064407
HMGP-AP-01FEDERAL EMERGENCY MANAGEMENT AGENCY
HAZARD MITIGATION GRANT PROGRAM
11/09/2023
11:02 AM
Project Management Report
Approved Amounts
Total Approved
Net Eligible
Total Approved
Non-Fed Share Amount
Federal
Share Percent
Non-Federal
Share Percent
Total Approved
Federal Share Amount
$551,844.25$2,207,377.00 75.000000000 $1,655,532.75 25.00000000
Work Schedule Status
Description Amend # Time Frame Due Date Revised Date Completion Date
Kick-off 2 Months 00/00/0000 00/00/0000 00/00/00002
Kick-off 2 Months 00/00/0000 00/00/0000 00/00/00000
Kick-off 2 Months 00/00/0000 00/00/0000 00/00/00001
Ecological Assessment 3 Months 00/00/0000 00/00/0000 00/00/00001
Ecological Assessment 3 Months 00/00/0000 00/00/0000 00/00/00002
Ecological Assessment 3 Months 00/00/0000 00/00/0000 00/00/00000
Request for Proposals 2 Months 00/00/0000 00/00/0000 00/00/00001
Request for Proposals 2 Months 00/00/0000 00/00/0000 00/00/00002
Request for Proposals 2 Months 00/00/0000 00/00/0000 00/00/00000
Open Bids and Award Contract 3 Months 00/00/0000 00/00/0000 00/00/00001
Open Bids and Award Contract 3 Months 00/00/0000 00/00/0000 00/00/00002
Open Bids and Award Contract 3 Months 00/00/0000 00/00/0000 00/00/00000
Construction - Vegetation Removal 5 Months 00/00/0000 00/00/0000 00/00/00001
Construction - Vegetation Removal 5 Months 00/00/0000 00/00/0000 00/00/00002
Construction - Vegetation Removal 5 Months 00/00/0000 00/00/0000 00/00/00000
Project Close-out 2 Months 00/00/0000 00/00/0000 00/00/00001
Project Close-out 2 Months 00/00/0000 00/00/0000 00/00/00000
Project Close-out 2 Months 00/00/0000 00/00/0000 00/00/00002
Grant Closeout 3 Months 00/00/0000 00/00/0000 00/00/00000
Grant Closeout 3 Months 00/00/0000 00/00/0000 00/00/00001
Grant Closeout 3 Months 00/00/0000 00/00/0000 00/00/00002
Approved
Project Title :
Recipient Place Code :
Recipient Place Name :
Recipient County Code :
Recipient County Name :
Recipient :
Project Closeout Date :
85
Santa Clara
Statewide
Los Gatos
0
00/00/0000
Los Gatos, Vegetation Management Risk Reduction Project
Subrecipient Place Code :
Subrecipient Place Name :
Subrecipient County Code :
Subrecipient County Name :
Subrecipient :
44112
Los Gatos
Santa Clara
85
Los Gatos
Approval Status:Approved
Mitigation Project Description
Amendment Status :
Page 1 of 2
FEMA
Project Number State RecipientAmendment
Number App IDDisaster
Number
75-R
Los Gatos
085-44112
Subrecipient:
FIPS Code:Project Title :Los Gatos, Vegetation Management Risk Reduction Project
CA Statewide25064407
HMGP-AP-01FEDERAL EMERGENCY MANAGEMENT AGENCY
HAZARD MITIGATION GRANT PROGRAM
11/09/2023
11:02 AM
Project Management Report
FY
Allocations
Allocation Number IFMISStatus Proj Alloc Amount
Fed Share
IFMIS Date Submission
Date
ES/DFSC
Support Req
ID
ES/DFSC
Amend Nr
Total
Alloc Amount
Subrecipient
Management Cost
20 $64,188.00A10/23/2020 202110/23/2020 3271424 0 $8,380,446.00$0.00
56 $0.00A12/29/2021 202212/29/2021 4925242 4 $1,004,530.50$2,289.00
131 $1,591,344.75A11/07/2023 202411/06/2023 18934766 $12,501,736.94$35,974.97
Total $1,655,532.75 $21,886,713.44$38,263.97
Obligations
Action Nr IFMISStatus IFMIS Date SFS
Amend
Number
Submission
Date FY
SFS
Support
Req ID
Project Obligated
Amt - Fed Share
Total Obligated
Amount
Subrecipient
Management Cost
Suppl
Nr
10/23/2020 010/23/2020 2021 3273862 $64,188.001A $64,188.00$0.0061
01/13/2022 101/13/2022 2022 7406490 $0.002A $2,289.00$2,289.00147
11/07/2023 211/07/2023 2024 18936048 $1,591,344.753R $1,627,319.72$35,974.97257
11/09/2023 211/09/2023 2024 18938118 $1,591,344.754A $1,627,319.72$35,974.97259
Total $3,246,877.50 $3,321,116.44$74,238.94
Law Entered By
Monitoring
Required Date
Environmental Conditions Required Monitoring
By
Monitoring Completed
Endangered Species Act (ESA)Allison N. Miller Simonds 00/00/0000
Conditions
Required (4000)
The Subapplicant is responsible for implementing the General Avoidance and Minimization Measures (GEN AMM) and
species-specific measures listed in the Biological Opinion and included as an attachment to this REC.
Page 2 of 2
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Non Compliant Flag:
Level:
EA Draft Date:EA Final Date:
EA Public Notice Date:EA Fonsi
EIS Notice of Intent EIS ROD Date:
No
EA
10/21/2014 03/01/2019
03/01/2019 03/08/2019
Comment The Town of Los Gatos proposes to perform hazardous fuels reduction in Santa Clara County,
California. Work would occur in five project areas: 1) Heintz Open Space, latitude/longitude: 37.230089,
-121.928621, 2) La Rinconada Park, latitude/longitude: 37.2573057, -121.9803139, 3) Novitiate Park,
latitude/longitude: 37.214091, -121.986386, 4) Santa Rosa Park, latitude/longitude: 37.227097, -
121.919619, and 5) Worcester Park, latitude/longitude: 37.221746, -121.966959. The staging area
(37.217793, -121.913229) is on the north side of Shannon Road, immediately west of the Hicks Road
intersection.
The project would occur through a combination of hand tools, mechanized equipment, herbicides, and
prescribed grazing and would treat approximately 193.9 acres. Each of the five project areas is
accessible by existing access roads.
The Proposed Action is not likely to result in potential direct impacts that would adversely affect the
natural values and function of floodplains, nor is it likely to increase the risk of flood loss. The Proposed
Action would not impact wetlands.
FEMA has determined that the Proposed Action is covered by the Region 9 Programmatic
Environmental Assessment (PEA) under¿Section 2.5, Vegetation Management. This category covers
the removal of vegetation and hazardous fuels, therefore, the Proposed Action is consistent with these
PEA categories. A list of Typical BMPs is attached. Compliance with the BMPs appropriate for this
scope of work is a condition of funding. - eargirof - 09/19/2023 22:17:31 GMT
NEPA DETERMINATION
Description Selected ?Extraordinary Circumstance Code
No Extraordinary Circumstances were selected
EXTRAORDINARY
Environmental Law/
Executive Order Description CommentStatus
Clean Air Act (CAA)Project will not result in permanent air
emissions - Review concluded
The project is in Santa Clara County, which is
not in attainment for the following criteria
pollutants: PM2.5 and 8-hour Ozone
(https://www3.epa.gov/airquality/greenbook/ancl.
html#CA). Based on the scope of work, the
potential emissions from project activities would
be below de minimis thresholds for the General
Conformity Rule. Therefore, the project is
exempt from a conformity determination. -
eargirof - 09/19/2023 21:41:54 GMT
Completed
Coastal Barrier Resources Act
(CBRA)
Project is not on or connected to CBRA Unit
or otherwise protected area - Review
concluded
Completed
Clean Water Act (CWA)Project would not affect any water of the U.S.
- Review concluded
Based on the National Wetlands Inventory
Mapper, two out of the five project areas include
riverine habitats. The La Rinconada Park
includes 12.03 acres of an unnamed
Completed
ENVIRONMENTAL LAW / EXECUTIVE ORDER
Page 1 of 6NOTE: All times are GMT using a 24-hour clock.
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Environmental Law/
Executive Order Description CommentStatus
intermittent streambed that is seasonally flooded.
The Santa Rosa Park includes 31.44 acres of an
unnamed intermittent streambed that is
seasonally flooded. Proposed project activities
would not occur within or negatively impact
nearby surface waters; therefore, coordination
with the U.S. Army Corps of Engineers (USACE)
is not required for the project. - eargirof -
09/19/2023 21:41:17 GMT
Coastal Zone Management Act
(CZMA)
Project is not located in a coastal zone area
and does not affect a coastal zone area -
Review concluded
Completed
Executive Order 11988 -
Floodplains
Located in floodplain or effects on
floodplain/flood levels
The project areas are primarily within shaded
Zone X, areas with a 0.2 percent annual chance
flood, and Zone D, areas of undetermined flood
hazard. There are areas of Zone AE, special
flood hazard areas subject to the 1 percent
annual chance flood, including some areas of
associated regulatory floodways, located in La
Rinconada Park. These zones are shown on
FEMA Flood Insurance Rate Map (FIRM) panels
06085C0238J dated February 19, 2014,
06085C0381H dated May 18, 2009,
06085C0377H dated May 18, 2009, and
06085C0380H dated May 18, 2009. The
Proposed Action is not likely to result in potential
direct impacts that would adversely affect the
natural values and function of floodplains, nor is
it likely to increase the risk of flood loss. An Initial
Public Notice was published on 12/9/2021. Per
44 CFR Part 9.5(d)(4), the 8-step Process was
completed, and the determination was the
project is the only practicable alternative. A Final
Public Notice was published on July 19, 2023. -
eargirof - 09/19/2023 22:01:29 GMT
Completed
No adverse effect on floodplain and not
adversely affected by the floodplain - Review
concluded
Completed
Executive Order 11990 -
Wetlands
No effects on wetlands and project outside
wetlands - Review concluded
Based on a review of the USFWS National
Wetlands Inventory database (reviewed January
24, 2023), project activities are not within nor
would they affect wetland resources. The 8-Step
process for wetlands is not required. - eargirof -
09/19/2023 22:03:54 GMT
Completed
Executive Order 12898 -
Environmental Justice for Low
Income and Minority Populations
No Low income or minority population in,
near or affected by the project - Review
concluded
According to the Environmental Protection
Agency's Environmental Justice Screening and
Mapping Tool (Version 2020), no low income
and minority populations are within 0.5 mile of
the project sites. This project would not result in
Completed
Page 2 of 6NOTE: All times are GMT using a 24-hour clock.
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Environmental Law/
Executive Order Description CommentStatus
disproportionately high and adverse impacts on
low income or minority populations. - eargirof -
09/19/2023 22:04:18 GMT
Endangered Species Act (ESA)Listed species and/or designated critical
habitat present in areas affected directly or
indirectly by the federal action
The project was reviewed by Murray Wade, a
qualified biologist with CDM Smith, under the
Programmatic Biological Opinion from the
Sacramento Fish and Wildlife Office Jurisdiction
in California. The project may affect, but is not
likely to adversely affect the Foothill Yellow-
legged Frog (FYLF), the California red-legged
frog (CRLF) and the California tiger salamander
(CTS). The project area does not overlap any
designated critical habitat. The potential for
FYLF to occur within the project area is very low
because no known breeding habitats are
present. CRLF has not been recently detected
within the project area; however, the project area
contains suitable nonbreeding aquatic and
upland dispersal habitat. The potential for CTS to
occur within the project area is very low because
no known breeding habitats are present in the
immediate vicinity and long-distance movement
to the project area from surrounding occupied
sites is hindered by residential development and
roads. Impacts to FYLF could occur from noise
and vibration from fuel reduction activities that
could disrupt normal foraging and sheltering
behavior. FYLFs could be injured or killed from
being crushed by equipment or worker foot
traffic, collisions with project-related vehicles and
equipment on access roads and staging areas,
or exposure to herbicides. CRLFs occurring
within the project area during implementation
could be displaced, harassed, injured, or killed
during activities involving work in suitable CRLF
habitat. If CTSs were to occur within the AA,
noise and vibration from fuel reduction activities
could disrupt normal foraging and sheltering
behavior, and individuals could be injured or
killed from being crushed by equipment or
worker foot traffic or exposure to herbicides.
Implementation of general and species-specific
avoidance and minimization measures and
species-specific conservation measures would
minimize potential adverse effects. No impacts
on any other federally listed species would
occur. FEMA received concurrence from
USFWS on July 17, 2023. - eargirof - 09/19/2023
21:32:29 GMT
Completed
Likely to adversely affect species or
designated critical habitat
Completed
Page 3 of 6NOTE: All times are GMT using a 24-hour clock.
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Environmental Law/
Executive Order Description CommentStatus
Formal consultation concluded. (Biological
Assessment and Biological Opinion attached)
- Review concluded
Completed
Farmland Protection Policy Act
(FPPA)
Project does not affect designated prime or
unique farmland - Review concluded
According to the California important farmland
mapper
(https://maps.conservation.ca.gov/DLRP/CIFF/),
the project areas are in Los Gatos and are
designated urban and built up land, or land
designated as other. The project would not result
in the conversion of, or other adverse impacts
on, prime or unique farmland or farmland of
statewide or local importance. - eargirof -
09/19/2023 21:45:34 GMT
Completed
Fish and Wildlife Coordination
Act (FWCA)
Project does not affect, control, or modify a
waterway/body of water - Review concluded
Completed
Migratory Bird Treaty Act (MBTA)Project located within a flyway zone The project area is within the Pacific Flyway and
includes the removal of vegetation that may
serve as nesting habitat for migratory birds.
Vegetation removal would comprise mostly
invasive species and ladder fuels in native trees
and bushes. The staging area would be on
paved ground and no vegetation removal would
occur there. Vegetation management activities
would be short-term and would result in open
spaces with vegetation remaining to provide
nesting habitat for migratory bird species. The
Subapplicant would comply with state and
federal laws pertaining to migratory birds and
has stated that, if vegetation removal activities
occur in the bird breeding season, a qualified
biologist will be retained to conduct nesting bird
surveys prior to the start of work. Therefore,
potential effects on migratory birds would be
minimized. - eargirof - 09/19/2023 21:47:59 GMT
Completed
Project does not have potential to take
migratory birds - Review concluded
Completed
Magnuson-Stevens Fishery
Conservation and Management
Act (MSA)
Project located in or near Essential Fish
Habitat
Based on a review of the NMFS Species List
Tool and the NMFS essential fish habitat (EFH)
mapper completed on September 14, 2021, the
project area is within mapped boundaries of EFH
for Chinook salmon (Oncorhynchus
tshawytscha) and Coho salmon (Oncorhynchus
kisutch). Because there would be no in-water
work and no impacts on aquatic resources as a
result of this project, there would be no impact
on EFH. - eargirof - 09/19/2023 21:59:46 GMT
Completed
Page 4 of 6NOTE: All times are GMT using a 24-hour clock.
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Environmental Law/
Executive Order Description CommentStatus
Project does not adversely affect Essential
Fish Habitat - Review concluded
Completed
National Historic Preservation Act
(NHPA)
Applicable executed Programmatic
Agreement (enter date in comments).
The Undertaking was reviewed by archaeologist
Hannah Ballard with Pacific Legacy, Inc., who
meets the applicable Secretary of the Interior's
Professional Qualification in accordance with
Stipulation I.B.1.a of the October 2019
Programmatic Agreement (Programmatic
Agreement) among the Federal Emergency
Management Agency, the California State
Historic Preservation Office (SHPO), and the
California Governor's Office of Emergency
Services. FEMA conducted a pedestrian
archaeological survey and evaluated sites for
NRHP eligibility. All archeological survey findings
lacked meaningful data potential and are
considered not eligible for listing in the NRHP.
By letter to the SHPO dated July 27, 2022,
FEMA determined that the project would have
No Historic Properties Affected. By letter dated
September 21, 2022, the SHPO indicated no
objection to FEMA's determination. - eargirof -
09/19/2023 21:30:38 GMT
Completed
Historic Buildings and StructuresCompleted
No properties in the project area are 50 years
or older or listed on the National Register -
Review concluded
Completed
Archeological ResourcesCompleted
Project affects undisturbed groundCompleted
Project area has potential for presence of
archeological resources
Completed
Determination of no historic properties
affected (FEMA finding/SHPO/THPO
concurrence attached) - Review concluded
Completed
Wild and Scenic Rivers Act
(WSR)
Project is not along and does not affect Wild
and Scenic River - Review concluded
The National Wild and Scenic Rivers system
website (https://www.rivers.gov/arizona.php)
does not identify any federally designated wild
and scenic rivers near the project area. The
closest wild and scenic river segment is the Big
Sur Wild and Scenic River, which is more than
64 miles south of the project area. Based on the
distance to the project,
Completed
Page 5 of 6NOTE: All times are GMT using a 24-hour clock.
09/21/2023 REC-01FEDERAL EMERGENCY MANAGEMENT AGENCY
18:39:03
RECORD OF ENVIRONMENTAL CONSIDERATION (REC)
Project
Title:
HMGP-4407-0075-CA (4407-506-75) (2)
Town of Los Gatos Vegetation Management (Phase 2)
Environmental Law/
Executive Order Description CommentStatus
implementation of this project would have no
direct or adverse impacts on Wild and Scenic
Rivers. - eargirof - 09/19/2023 22:00:02 GMT
Special Conditions required on implementation of Projects:
Clean Air Act (CAA)
The Subapplicant is responsible for complying with all applicable subparts of the Clean Air Act. Failure to comply with this condition may
jeopardize federal assistance, including funding. Any change to the approved scope of work will require re-evaluation for compliance with
the Clean Air Act.
NoSource of condition:Monitoring Required:
Endangered Species Act (ESA)
The Subapplicant is responsible for implementing the General Avoidance and Minimization Measures (GEN AMM) and species-specific
measures listed in the Biological Opinion and included as an attachment to this REC.
YesSource of condition:Monitoring Required:
National Historic Preservation Act (NHPA)
The Subapplicant must conduct cultural resources awareness training in advance of project ground-disturbing activities.
NoSource of condition:Monitoring Required:
NEPA Determination
The Subapplicant is responsible for implementing BMPs appropriate for this scope of work. A list of Typical BMPs from the Region 9
Programmatic Environmental Assessment is attached. Any changes to this scope of work must be resubmitted to FEMA for review prior to
initiation of any work. Noncompliance with this requirement may jeopardize federal funding.
NoSource of condition:Monitoring Required:
Standard Conditions:
Any change to the approved scope of work will require re-evaluation for compliance with NEPA and other Laws and Executive Orders.
This review does not address all federal, state and local requirements. Acceptance of federal funding requires recipient to comply with all
federal, state and local laws. Failure to obtain all appropriate federal, state and local environmental permits and clearances may
jeopardize federal funding.
If ground disturbing activities occur during construction, applicant will monitor ground disturbance and if any potential archeological
resources are discovered, will immediately cease construction in that area and notify the State and FEMA.
CONDITIONS
Page 6 of 6NOTE: All times are GMT using a 24-hour clock.
Appendix C List of Typical Best Management Practices
1
During construction, Best Management Practices (BMPs) are normally employed to reduce
potential adverse effects to resource areas from construction and operation of proposed projects.
BMPs are outlined below for resource areas where impact may occur due to project activities.
BMPs for resource areas like socioeconomics and public safety, land use and planning and visual
resources are not outlined, as construction and operation measures to protect those resource areas
vary by jurisdiction and state/local regulations. Further, overlap between resource areas BMPs
exists. This list represents sample general construction BMPs; project specific BMPs should be
implemented on a case by case basis. The table below outlines general construction BMPs.
Table 1 – General Construction BMPs
General
Principles
Fit grading to the surrounding terrain.
Time grading operations to minimize soil exposure.
Retain existing vegetation whenever feasible.
Vegetate and mulch or otherwise stabilize disturbed areas.
Direct runoff away from disturbed areas.
Minimize the length and steepness of slopes.
Keep runoff velocities low.
Prepare drainage ways and outlets to handle concentrated runoff until permanent drainage
structures are constructed.
Trap sediment on site.
Inspect and maintain control measures frequently.
Do not dispose of plant material in a creek or drainage facility or leave it in a roadway where it
can clog storm drain inlets.
Avoid disposal of plant material in trash dumpsters or mixing it with other wastes.
Compost plant material or take it to a landfill or other facility that composts yard waste (check
with the local planning or building department for more information).
Structural
Control
Measures
Where possible maintain runoff water within its natural course and direction of flow.
Design and maintain access roads to prevent ponding and damage from water flow.
Limit cut and fill slopes to an inclination of 2:1 or flatter, and include benching to reduce slope
length on longer slopes.
Direct concentrated flow to stabilized channels and drains.
Roughen slope surfaces to slow down flow velocities and enhance water infiltration, which in
turn will enhance vegetation establishment
Divert stormwater away from denuded areas and use properly installed temporary berms, earth
dikes, silt fences, sediment traps, inlet protection, and sediment basins to limit the discharge of
sediment and pollutants from the site.
Stormwater
Management
Controls
Wherever possible, stormwater runoff from undeveloped areas should be kept separate from
runoff from developed areas, and should be retained in natural conveyances or routed through
properly lined drainage conveyances.
Discharge locations should be provided with appropriate energy dissipation to prevent scour.
2
Geology and Soils
The following BMPs for geology and soils were developed using local and state guidelines. The
BMPs are geared towards preventing soil erosion. BMPs for geological hazards must be
developed in accordance with federal, state and local building codes and project area specific
geological conditions.
1. Plan the development to fit the topography, soils, drainage pattern and natural vegetation
of the site.
2. Delineate clearing limits, easements, setbacks, sensitive or critical areas, trees, drainage
courses, and buffer zones to prevent excessive or unnecessary disturbances and exposure.
3. Phase grading operations to reduce disturbed areas and time of exposure.
4. Avoid excavation and grading during wet weather.
5. Use berms and drainage ditches to divert runoff around exposed areas. Place diversion
ditches across the top of cut slopes.
6. Plant vegetation on exposed slopes. Where replanting is not feasible, use erosion control
blankets (e.g., jute or straw matting, glass fiber or excelsior matting, mulch netting).
7. Consider slope terracing with cross drains to increase soil stability.
8. Cover stockpiled soil and landscaping materials with secured plastic sheeting and divert
runoff around them.
9. As a back-up measure, protect drainage courses, creeks, or catch basins with fiber rolls,
silt fences, sand/gravel bags and/or temporary drainage swales.
10. Once grading is completed, stabilize the disturbed areas using permanent vegetation as
soon as possible. Use temporary erosion controls until vegetation is established.
11. Conduct routine inspections of erosion control measures especially before and
immediately after rainstorms, and repair if necessary.
Air Quality and Greenhouse Gas Emissions
The following BMPs are extracted from state sources and they represent general construction
BMPs for minimizing air quality and greenhouse gas emissions from project construction. The
following BMPs can also be implemented to reduce project impacts on Climate Change.
1. All exposed unpaved surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day.
2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet
power vacuum street sweepers at least once per day. The use of dry power sweeping is
prohibited.
4. All vehicle speeds on unpaved roads shall be limited to 15 mph.
5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as
possible. Building pads shall be laid as soon as possible after grading unless seeding or
soil binders are used.
6. Idling times shall be minimized either by shutting equipment off when not in use or
reducing the maximum idling time to 5 minutes.
7. Clear signage shall be provided for construction workers at all access points.
3
8. All construction equipment shall be maintained and properly tuned in accordance with
manufacturer’s specifications. All equipment shall be checked by a certified visible
emissions evaluator.
9. Post a publicly visible sign with the telephone number and person to contact at the lead
agency regarding dust complaints. This person shall respond and take corrective action
within 48 hours. The Air District’s phone number shall also be visible to ensure
compliance with applicable regulations.
10. All trucks and equipment, including their tires, shall be washed off prior to leaving the
site.
11. Sandbags or other erosion control measures shall be installed to prevent silt runoff to
public roadways from sites with a slope greater than one percent.
12. Minimizing the idling time of diesel powered construction equipment to two minutes.
13. Use low Volatile Organic Compound (VOC) (i.e., ROG) coatings beyond the local
requirements.
14. Requiring that all construction equipment, diesel trucks, and generators be equipped with
Best Available Control Technology for emission reductions of NOx and PM.
15. Monitor dust-generating activities and implement appropriate measures for maximum
dust control.
Water Resources
The following BMPs are extracted from sources such as the US Fish and Wildlife Service
(USFWS) and Regional Water Quality Boards (RWQCB). These BMPs could be implemented
when working near waters of the US or wetlands.
1. No work within 50 feet of a wetland or waterbody.
2. For work between 50 and 200 feet of a wetland or waterbody:
Herbicides would be restricted to glyphosate-based herbicides that are approved by
the EPA for use around water (e.g., Rodeo).
Hand tools (chainsaws, brush cutters, and other hand tools) would be used to create a
gradation of vegetation density by removing approximately 50 percent of the
vegetation farthest from wetlands and perennial waterbodies, and 33 percent of the
vegetation at closer distances to wetlands and perennial waterbodies.
No equipment fueling would occur.
3. Never wash down pavement or surfaces where materials have spilled. Use dry cleanup
methods whenever possible.
4. Protect all storm drain inlets using filter fabric cloth or other best management practices
to prevent sediments from entering the storm drainage system during construction
activities.
5. Keep materials out of the rain — prevent runoff pollution at the source. Schedule clearing
or heavy earth moving activities for periods of dry weather. Cover exposed piles of soil,
construction materials and wastes with plastic sheeting or temporary roofs. Before it
rains, sweep and remove materials from surfaces that drain to storm drains, creeks, or
channels.
4
6. Prior to construction, wetlands located in the project area will be fenced off using ESA
fencing. The fencing will be placed 5 feet away from each wetland feature.
7. Appropriate erosion control measures will be used to reduce siltation and runoff of
contaminants into wetlands and adjacent, ponds, streams, or riparian woodland/scrub.
The contractor will not be allowed to stockpile brush, loose soils, or other debris material
on stream banks.
8. Native plant species should be used in erosion control or revegetation seed mix. Any
hydroseed mulch used for revegetation must also be certified weed-free. Dry-farmed
straw will not be used, and certified weed-free straw will be required where erosion
control straw is to be used. Filter fences and mesh will be of material that will not entrap
reptiles and amphibians. Erosion-control measures will be placed between water or
wetland and the outer edge of the project site.
9. All off-road construction equipment will be cleaned of potential noxious weed sources
(mud, vegetation) before entry into the project area. Equipment will be considered free of
soil, seeds, and other such debris when a visual inspection does not disclose such
material. Disassembly of equipment components or specialized inspection tools is not
required.
10. Vehicles and equipment will be parked on pavement, existing roads, or specified staging
areas.
11. Trash generated by covered activities should be promptly and properly removed from the
site.
12. Equipment storage, fueling, and staging areas will be sited on disturbed areas or on non-
sensitive nonnative grassland land cover types, when these sites are available, to
minimize risk of direct discharge into riparian areas or other sensitive land cover types.
13. All temporarily disturbed areas, such as staging areas, will be returned to pre-project or
ecologically improved conditions as required by responsible agencies.
14. Do not over-apply pesticides or fertilizers and follow manufacturer’s instructions for
mixing and applying materials.
15. Dispose of all wastes properly. Materials that cannot be reused or recycled must be taken
to an appropriate landfill or may require disposal as hazardous waste. Never throw debris
into channels, creeks or into wetland areas. Never store or leave debris in the street or
near a creek where it may contact runoff.
Biological Resources
These BMPs have been extracted from USFWS and should be applied when working in areas
that have been identified to contain Special Status Species and migratory birds.
Special Status Species
1. Construction should generally occur during the dry season (April 15 to October 15).
2. No more than two days prior to the start of ground disturbing activities, focused
preconstruction surveys for Special Status Species will be completed by a USFWS-
approved biologist in all suitable upland dispersal habitat areas, if Special Status Species
have been previously identified in the area. If Special Status Species are found during
focused preconstruction surveys, the USFWS will be contacted within one working day,
and a suitable protocol shall be approved by USFWS for relocation.
5
3. Exclusion fencing such as Ertec E-fenceTM or an equivalent will be installed around
Special Status species habitat prior to any construction during the dry season (April 1
through October 15), when Special Status Species are not actively dispersing or foraging.
The fencing will remain in place until all project activities in the vicinity of suitable
upland dispersal habitat are completed.
4. To prevent Special Status Species from becoming entangled or trapped in erosion control
materials, plastic monofilament netting (erosion control matting) or similar material will
not be used for erosion control. Acceptable substitutes include coconut coir matting or
tackified hydroseeding compounds.
5. Prior to any construction where Special Status Species have been detected a USFWS-
qualified biologist will conduct an education program for construction personnel. At a
minimum, the training will include a description of Special Status Species and their
habitats; the potential occurrence of these species in the project area; the measures to be
implemented to conserve listed species and their habitats as they relate to the work site;
and boundaries in which construction may occur. A fact sheet conveying this information
will be prepared and distributed to all construction crews and project personnel entering
the project area. Upon completion of the program, personnel will sign a form stating that
they attended the program and understand all of the avoidance and minimization
measures for the Special Status Species.
6. All construction-related trenches and holes in the ground will be covered at the end of
each work day to prevent entrapment of Special Status Species. A USFWS-approved
biologist will survey the holes at the beginning of each work day to check for trapped
Special Status Species. If a Special Status Species is observed, the USFWS-approved
biologist will capture and relocate them to a suitable area outside the project area.
7. All organic matter should be removed from nets, traps, boots, vehicle tires and all other
surfaces that have come into contact with ponds, wetlands, or potentially contaminated
sediments. Items should be washed with a 5 percent bleach solution and rinsed with clean
water before leaving each study site. Used cleaning materials (liquids, etc.) should be
disposed of safely, and if necessary, taken off site for proper disposal. Used disposable
gloves should be retained for safe disposal in sealed bags.
8. Implement measures to minimize the spread of disease and non-native species based on
current Wildlife Agency protocols and other best available science.
Migratory Birds BMPs
Raptors
1. Preconstruction surveys for raptors, other special-status birds, and appropriate nesting
habitat will be conducted within 50 feet of the construction area no more than three days
prior to ground disturbing activities. If an active nest is found, the state agency (ex.
CDFW) will be consulted to determine the appropriate buffer area to be established
around the nesting site and the type of buffer to be used, which typically is ESA fencing.
If establishment of a buffer is not feasible, the appropriate agency will be contacted for
further avoidance and minimization guidelines.
2. A qualified biologist will conduct weekly monitoring during construction, to evaluate the
identified nest for potential disturbances associated with construction activities.
Construction within the buffer is prohibited until the qualified biologist determines the
nest is no longer active.
6
3. If an active nest is found after construction begins, construction activities in the vicinity
of the nest will stop until a qualified biologist has evaluated the nest and established the
appropriate buffer around the nest. If establishment of the buffer is not feasible, the
appropriate agency will be contacted for further avoidance and minimization guidelines.
Migratory Birds
The measures below would be implemented for construction work during the nesting season
(February 15 through August 31).
1. A qualified biologist will conduct preconstruction surveys for nesting migratory birds in
the project area no more than three days prior to the start of ground disturbing activities.
If preconstruction surveys indicate the presence of any migratory bird nests where
activities would directly result in bird injury or death, a buffer zone of 50 feet will be
placed around the nest.
2. Buffers will be established around active migratory bird nests where project activities
would directly result in bird injury or death. The size of the buffer may vary for different
species and will be determined in coordination with the responsible agency. A qualified
biologist will delineate the buffer using ESA fencing, pin flags, and/or yellow caution
tape.
3. Buffer zones will be maintained around all active nest sites until the young have fledged
and are foraging independently. In the event that an active nest is found after the
completion of preconstruction surveys and after construction begins, all construction
activities within a 50-foot radius will be stopped until a qualified biologist has evaluated
the nest and erected the appropriate buffer around it.
4. If an active nest is found in an area after construction begins, construction activities in the
vicinity of the nest will stop until a qualified biologist has evaluated the nest and
established the appropriate buffer around the nest. If establishment of the buffer is not
feasible, the responsible agency will be contacted for further avoidance and minimization
guidelines.
Historic Properties
The following BMPs were developed to be used if cultural resources are present. Further BMPs
must be developed based on Federal and State guidelines.
Prehistoric or Historic Subsurface Resources: In the event that any prehistoric or historic
subsurface cultural resources, as defined by the responsible agency, are discovered during
ground disturbing activities all work within 50 feet of the resources should be halted and the
project applicant should consult with a qualified archaeologist or paleontologist to assess the
significance of the find. If any find is determined to be significant, representatives of the
proponent and the qualified archaeologist would meet to determine the appropriate course of
action. All significant cultural materials recovered shall be subject to scientific analysis,
professional museum curation, and a report prepared by the qualified archaeologist according to
current professional standards.
Unanticipated Paleontological Resources: The project proponent shall notify a qualified
paleontologist of unanticipated discoveries, made by either the cultural resources monitor or
construction personnel and subsequently document the discovery as needed. In the event of an
7
unanticipated discovery of a breas, true, and/or trace fossil during construction, excavations
within 50 feet of the find shall be temporarily halted or diverted until the discovery is examined
by a qualified paleontologist. The paleontologist shall notify the appropriate agencies to
determine procedures that would be followed before construction is allowed to resume at the
location of the find.
Discovery of Human Remains: In the unlikely event of the discovery of human remains, the
following BMPs can be implemented as follows:
1. There shall be no further excavation or disturbance of the site or any nearby area
reasonably suspected to overlie adjacent human remains until:
2. The Coroner of the county in which the remains are discovered must be contacted to
determine that no investigation of the cause of death is required, and
3. If the coroner determines the remains to be Native American:
The coroner shall contact the responsible agency within 24 hours.
The responsible shall identify the person or persons it believes to be the most
likely descended from the deceased Native American.
The most likely descendent may make recommendations to the landowner or the person
responsible for the excavation work, for means of treating or disposing of, with appropriate
dignity, the human remains and any associated grave goods.
Transportation
The following BMPs were developed based on state and local jurisdictions guidelines. Further
BMPs must be developed depending on local jurisdiction traffic control requirements.
1. When possible construction crews would travel outside of peak hour traffic times,
therefore minimizing peak traffic times impacts.
2. All vehicles related to project constructions, including contractor vehicles and trucks,
would use designated Truck Routes, where those are available.
3. Detour signs shall be used when necessary for vehicles, bicycle and pedestrian ways.
4. All detour signs during construction would be designed to meet the responsible agency
standards.
5. A Traffic Control Plan shall be implemented if the project is expected to require road
closures.
Noise
The following BMPs for noise have been developed by surveying a variety of local noise
guidelines, as there are no state or federal guidelines regarding acceptable noise limits. Noise
BMPs will vary based on local noise ordinances and land uses surrounding the project area.
1. Provide advance notification to surrounding land uses disclosing the construction schedule,
including the various types of activities that would be occurring throughout the duration of the
construction period.
2. Noise-generating construction activities, including truck traffic coming to and from the
site for any purpose, shall be limited to the hours of 7:00 a.m. to 7:00 p.m. during
8
weekdays and 8:00 a.m. to 5:00 p.m. on Saturday and Sunday, or as specified in the
Noise Ordinance of the local municipality.
3. All noise-producing project equipment and vehicles using internal combustion engines shall
be equipped with mufflers, air-inlet silencers where appropriate, and any other shrouds,
shields, or other noise-reducing features in good operating condition that meet or exceed
original factory specification. Mobile or fixed "package" equipment shall be equipped with
shrouds and noise control features that are readily available for that type of equipment.
4. Contractor shall be responsible for maintaining equipment in best possible working
condition.
5. Mobile equipment staging, parking, and maintenance areas shall be located as far as
practicable from noise-sensitive receivers.
6. Locate construction equipment as far as possible from nearby noise-sensitive receptors.
7. The use of noise-producing signals, including horns, whistles, alarms, and bells shall be for
safety warning purposes only. No project-related public address or music system shall be
audible at any adjacent noise-sensitive receptor.
8. The contractor shall notify adjacent property owner, property managers, and business
owners of adjacent parcels of the construction schedule in writing and in advance of the
work. The notification shall include the name and phone number of a project
representative or site supervisor.
9. The on-site construction supervisor shall have the responsibility and authority to receive and
resolve noise complaints. A clear appeal process to the Owner shall be established prior to
construction commencement that shall allow for resolution of noise problems that cannot be
immediately solved by the site supervisor.
Hazardous Materials
The following BMPs were developed using state guidelines as well as a variety of local
jurisdiction guidelines. The BMPs apply to handling of regular hazardous substances as well as
the discovery of unknown or undocumented contamination.
1. Vehicles and equipment would be inspected and approved before use to ensure that they
will not leak hazardous materials such as oil, hydraulic fluid, or fuel.
2. Fueling would take place in designated staging areas, outside native vegetation or
wetlands.
3. The contractor would have emergency cleanup gear for spills (spill containment and
absorption materials) and fire-suppression equipment available onsite at all times. The
gear and equipment would be inspected before treatment begins.
4. Leaks, drips, and other spills would be cleaned up immediately to avoid soil or
groundwater contamination. Cleanup of a spill on soil would include removing the
contaminated soil using the emergency spill cleanup gear. Contaminated soil and
disposable gear used to clean up a hazardous materials spill would be properly disposed
of following State and Federal hazardous material disposal regulations.
5. Major vehicle maintenance and washing would be done offsite.
6. Spent fluids including motor oil and radiator coolant and used vehicle batteries would be
collected, stored, and recycled as hazardous waste offsite.
7. Spilled dry materials would be swept up immediately.
9
Unknown and Undocumented Contamination
If hazardous materials are encountered during construction or accidentally released as a result of
construction activities the following procedures shall be implemented:
1. Work shall stop in the vicinity of any discovered contamination or release.
2. The scope and immediacy of the problem shall be identified.
3. Coordination with the responsible agencies shall take place.
4. The necessary investigation and remediation activities shall be conducted to resolve the
situation before continuing construction work.
The following measures shall be implemented if unknown or undocumented contamination is
discovered during construction to avoid potentially significant impacts to hydrology and water
resources in the project area.
1
Standard Mitigation Grant Program (HMGP) Conditions
FEMA Region IX, August, 2018
The following list applies to Recipients and Subrecipients accepting HMGP funds from the Federal
Emergency Management Agency (FEMA) of the Department of Homeland Security (DHS):
1. Applicable Federal, State, and Local Laws and Regulations. The Recipient/Subrecipient must
comply with all applicable Federal, State, and Local laws and regulations, regardless of whether they
are on this list or other project documents. DHS financial assistance Recipients and Subrecipients are
required to follow the provisions of the State HMGP Administrative Plan, applicable Hazard
Mitigation Assistance Uniform Guidance, and Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards located in Title 2 of the Code of Federal
Regulations (CFR) Part 200, adopted by DHS in 2 CFR 3002.
2. Financial Management Systems. The Recipient and Subrecipient must maintain financial
management systems to account for and track funds, as referenced in 2 CFR 200.302.
3. Match or Cost Share. Non-federal match or cost share must comply with 2 CFR 200.306, the scope
of work (SOW), and any agreements among the Subrecipient, the Recipient, and FEMA.
4. Budget Changes. Unanticipated adjustments are permitted within the approved total cost. However,
if costs exceed the federal share, the Subrecipient must notify the Governor’s Authorized
Representative (GAR) of overruns before implementation. The GAR shall submit a written request
for approval to FEMA Region IX. The subaward must continue to meet HMGP requirements,
including cost effectiveness and cost share. Refer to 2 CFR 200.308 for additional information.
5. Real Property and Land. The acquisition, use, and disposition must comply with 2 CFR 200.311.
6. Equipment. The acquisition, use, and disposition must comply with 2 CFR 200.313.
7. Supplies. Upon project completion, FEMA must be compensated for unused supplies, exceeding
$5,000 (fair market value), and not needed for other federal programs. Refer to 2 CFR 200.314.
8. Procurement. Procurement procedures must be in conformance with 2 CFR 200.318-320.
9. Monitoring and Reporting Program Performance. The Recipient and Subrecipient must submit
quarterly progress reports, as referenced in the 2 CFR 200.328 and State HMGP Administrative Plan.
10. Records Retention. In accordance with 2 CFR 200.333, financial/ programmatic records related to
expenditures must be maintained at least 3 years after the date of Recipient’s final expenditure report.
11. Enforcement and Termination. If the Recipient or Subrecipient fails to comply with the award or
subaward terms, whether stated in a Federal statute or regulation, the State HMGP Administrative
Plan, subpplication, a notice of award, an assurance, or elsewhere, FEMA may take one or more of
the actions outlined in 2 CFR 200.338, including termination or partial termination of the award or
subaward outlined in 2 CFR 200.339.
12. Allowable Costs. Funds are to be used for allowable costs in compliance with 2 CFR 200.403, the
approved SOW, and any agreements among the Subrecipient, Recipient, and FEMA.
2
13. Non-Federal Audit. The Recipient and Subrecipient are responsible for obtaining audits in
accordance with the Single Audit Act of 1984, in compliance with 2 CFR 200.501.
14. Debarred and Suspended Parties. Recipients and Subrecipients are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, and 2 CFR
180. These regulations restrict federal financial assistance awards, subawards, and contracts with
parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in the
federal assistance programs or activities.
15. Equipment Rates. Rates claimed for use of Subrecipient-owned equipment in excess of the FEMA-
approved rates must be approved under State guidelines issued by the State Comptroller's Office or
must be certified by the Recipient to include only those costs attributable to equipment usage less any
fixed overhead and/or profit.
16. Duplication of Funding between Public Assistance (PA) and HMGP. Funding for PA Section 406
and HMGP Section 404 are permitted on the same facility/location, but the activities identified under
each program must be distinct with separately accounted funds. At closeout, FEMA may adjust the
funding to ensure the Subrecipient was reimbursed for eligible work from only one funding source.
17. Historic Properties and Cultural Resources. In compliance with 2 CFR 800, if a potential historic
property or cultural resource is discovered during construction, the Subrecipient must cease work in
the area and take all reasonable measures to avoid or minimize harm to the discovered
property/resource. During construction, the Subrecipient will monitor ground disturbance activity,
and if any potential archeological resources are discovered, will immediately cease work in that area,
and notify the Recipient and FEMA. Construction in the area may resume with FEMA’s written
approval after FEMA’s consultation, if applicable, with the State Historic Preservation Officer
(SHPO).
18. NEPA and Changes to the Scope of Work (SOW). To comply with the National Environmental
Policy Act (NEPA), and other Laws and Executive Orders, any change to the approved SOW shall be
re-evaluated before implementation. Construction associated with a SOW change, prior to FEMA
approval, may be ineligible for funding. Acceptance of federal funding requires environmental
permits and clearances in compliance with all appropriate federal, state and local laws, and failure to
comply may jeopardize funding.
Within their authority, the Recipient and Subrecipient must use of all practicable means, consistent
with other essential policies, to create and maintain productive harmony for people and nature, and
fulfill the social, economic, and other needs of present and future generations of Americans.
\\R9li8a1\mitdata$\05. HMA Grants Management\02. HMGP\HMGP Standard Conditions\Standard HMGP Conditions, August 2018.docx
CalVTP Project-Specific Analysis and
Addendum to the PEIR for the
Town of Los Gatos Open Space
Vegetation Management Plan,
Santa Clara County, California
AUGUST 2023
PREPARED FOR
Town of Los Gatos
PREPARED BY
SWCA Environmental Consultants
ATTACHMENT 3
CALVTP PROJECT-SPECIFIC ANALYSIS AND
ADDENDUM TO THE PEIR FOR THE
TOWN OF LOS GATOS
OPEN SPACE VEGETATION MANAGEMENT PLAN,
SANTA CLARA COUNTY, CALIFORNIA
Prepared for
Town of Los Gatos Department of Public Works
41 Miles Avenue
Los Gatos, CA 95030
Prepared by
SWCA Environmental Consultants
60 Stone Pine Road, Suite 100 Half Moon Bay, CA 94019
(650) 440-4160 www.swca.com
August 2023
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
i
CONTENTS
1 Project Overview .................................................................................................................................. 1
1.1 CEQA Lead Agency and Proposed Project ............................................................................... 1
1.2 Purpose of this Document ......................................................................................................... 1
2 Project Description ............................................................................................................................... 3
2.1 Project Background ................................................................................................................... 3
2.2 Purpose and Need ...................................................................................................................... 4
2.3 Project Activities ....................................................................................................................... 4
3 Environmental Checklist ................................................................................................................... 21
4 Project-Specific Analysis.................................................................................................................... 24
4.1 Aesthetics and Visual Resources ............................................................................................. 24
4.2 Agriculture and Forestry Resources ........................................................................................ 27
4.3 Air Quality ............................................................................................................................... 29
4.4 Archaeological, Historical, and Tribal Cultural Resources ..................................................... 34
4.5 Biological Resources ............................................................................................................... 38
4.6 Geology, Soils, Paleontology, and Mineral Resources ............................................................ 52
4.7 Greenhouse Gas Emissions ..................................................................................................... 54
4.8 Energy Resources .................................................................................................................... 56
4.9 Hazardous Materials, Public Health, and Safety ..................................................................... 58
4.10 Hydrology and Water Quality ................................................................................................. 61
4.11 Land Use and Planning, Population and Housing ................................................................... 66
4.12 Noise ........................................................................................................................................ 68
4.13 Recreation ................................................................................................................................ 70
4.14 Transportation ......................................................................................................................... 72
4.15 Public Services, Utilities, and Service Systems ...................................................................... 75
4.16 Wildfire ................................................................................................................................... 77
5 List of Preparers ................................................................................................................................. 79
6 References ........................................................................................................................................... 80
Appendices
Appendix A. CalVTP PEIR Addendum Project-Specific Mitigation Monitoring and Reporting Program
Appendix B. Open Space VMP Treatment Activities Maps
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
ii
Figures
Figure 1. Proposed VMP Project Treatment Areas. ...................................................................................... 2
Tables
Table 1. Proposed VMP Treatments and CalVTP Treatment Types ............................................................ 7
Table 2. Site- and Work-Specific Avoidance and Minimization Measures ................................................ 17
Table 3. Species with Potential to Occur in the Project Area ..................................................................... 42
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
iii
Acronyms and Abbreviations
ABAG Association of Bay Area Governments
ACM asbestos-containing material
AMMs Avoidance and Minimization Measures
BAAQMD Bay Area Air Quality Management District
BMP best management practice
CAAQS California Ambient Air Quality Standards
Cal-IPC California Invasive Plant Council
Cal/OSHA California Division of Occupational Health and Safety Administration
CalEPA California Environmental Protection Agency
CAL FIRE California Board of Forestry and Fire Protection
Caltrans California Department of Transportation
CalVTP California Vegetation Treatment Program
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CGS California Geologic Survey
CHRIS California Historical Resources Information System
CHSC California Health and Safety Code
CNDDB California Natural Diversity Database
CNPS California Native Plant Society
CO carbon monoxide
County County of Santa Clara
CWPP Community Wildlife Protection Plan
dbh diameter at breast height
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
GHG greenhouse gas
HCP Habitat Conservation Plan
HWCA Hazardous Waste Control Act
LOS level of service
LRA Local Responsibility Area
Midpen Midpeninsula Regional Open Space District
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
iv
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NO2 nitrogen dioxide
NOA naturally occurring asbestos
NOx nitrogen oxides
NWI National Wetlands Inventory
NWIC Northwest Information Center
OPR California Governor’s Office of Planning and Research
PEIR Program Environmental Impact Report
PM2.5 particulate matter less than 2.5 microns in diameter
PM10 particulate matter less than 10 microns in diameter
PRC Public Resources Code
proposed project Town of Los Gatos Undeveloped Parks and Open Space Areas
Vegetation Management Plan
PSA Project-Specific Analysis
ROG reactive organic gases
RWQCB Regional Water Quality Control Board
SCS Sustainable Communities Strategy
SENL single event [impulsive] noise level
SO2 sulfur dioxide
SPR Standard Project Requirement
SR State Route
SRA State Responsibility Area
Town Town of Los Gatos
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
VHFHSZ Very High Fire Hazard Severity Zone
VMP Vegetation Management Plan
VMT vehicle miles traveled
WUI wildland-urban interface
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
1
1 PROJECT OVERVIEW
The California Vegetation Treatment Program (CalVTP) Program Environmental Impact Report (PEIR)
evaluates the potential environmental effects of implementing qualifying vegetation treatments to reduce
the risk of wildfire throughout the State Responsibility Area (SRA) in California (CAL FIRE 2019a). It
was designed for use by many state and local agencies and special districts to accelerate vegetation
treatment project approvals by finding them to be within the scope of the PEIR.
The Town of Los Gatos (Town) proposes to implement a Vegetation Management Plan (VMP)
throughout its Town-owned and maintained undeveloped parks and open space areas within the Very
High Fire Hazard Severity Zone (VHFHSZ) (Figure 1; Town of Los Gatos 2019b). The Town is seeking
California Environmental Quality Act (CEQA) compliance for the Town of Los Gatos Undeveloped Parks
and Open Space Areas Vegetation Management Plan (proposed project) through preparation of this
CalVTP Project-Specific Analysis (PSA) and addendum to the PEIR.1
1.1 CEQA Lead Agency and Proposed Project
Serving as the Lead Agency under CEQA, the Town proposes to implement fuel reduction treatments on
approximately 193.91 acres within Local Responsibility Areas (LRAs) in the Town of Los Gatos, Santa
Clara County, California (see Figure 1). The Town is seeking CEQA compliance for the proposed project
as a later activity covered by the PEIR using its PSA checklist. The proposed treatment types (i.e.,
wildland-urban interface [WUI] fuel reduction and fuelbreaks) and the treatment activities (i.e., manual
treatments, mechanical treatments, prescribed herbivory, and chemical treatments) are consistent with
those evaluated in the PEIR. Ongoing maintenance of the proposed vegetation treatments would involve
the same treatment activities as the original treatments (i.e., manual treatments, mechanical treatments,
prescribed herbivory, and chemical treatments). The treatment areas are partially outside the CalVTP
treatable landscape.
1.2 Purpose of this Document
This document serves as the PSA to evaluate whether the proposed project is within the scope of the
PEIR. As described above, the treatment types and activities are consistent with the CalVTP. Among the
other criteria for determining whether a treatment project is within the scope of the PEIR is whether it is
within the CalVTP treatable landscape (i.e., the geographic extent of analysis covered in the PEIR). If a
proposed vegetation treatment project is covered by the evaluation of environmental effects in the PEIR,
it may be approved using a finding that the project is within the scope of the PEIR for its CEQA
compliance, consistent with State CEQA Guidelines Section 15168(c)(2).
The majority of the proposed project treatment areas extend outside of the CalVTP treatable landscape
within an LRA. Portions of the Santa Rosa and Heintz Open Spaces are within the treatable landscape,
but the remainder of the open spaces and three Town parks are scattered throughout the Town and are
outside of the treatable landscape. However, the southern and southwestern border of the Town are
adjacent to the CalVTP treatable landscape and there are scattered polygons of treatable landscape
through the southern and southeastern parts of the Town.
1 The roadway portions of the VMP project qualified for a CEQA Statutory Exemption under Article 18, Section 15269(c) -
Emergency Projects exemption. Article 18, Section 15269(b) addresses emergency repairs necessary to maintain services
essential to public health, safety, or welfare. These emergency repairs include those that require a reasonable amount of planning
to address an anticipated emergency. Article 18, Section 15269(c) applies to specific actions necessary to mitigate an emergency,
including “activities such as fire or catastrophic risk mitigation or modifications to improve facility integrity.”
Los Gatos Open Space Vegetation Management Plan CalVTP Project-Specific Analysis and Addendum to the PEIR 2 Figure 1. Proposed VMP Project Treatment Areas.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
3
If the areas of the proposed project outside of the CalVTP treatable landscape have essentially the same,
or at least substantially similar, landscape conditions as the treatable landscape, the environmental
analysis in the PEIR would be applicable.
An Addendum to an Environmental Impact Report (EIR) is appropriate when a previously certified EIR
has been prepared and some changes or revisions to the project are proposed, or the circumstances
surrounding the project have changed, but none of the changes or revisions would result in new or
substantially more severe significant environmental impacts, consistent with CEQA Section 21166 and
State CEQA Guidelines Sections 15162, 15163, 15164, and 15168. In this case, there is a proposed
revision to or change in the project, compared to the PEIR, which is the inclusion of areas outside of the
CalVTP treatable landscape. The PSA checklist (refer to Section 4, Project-Specific Analysis/Addendum)
includes the criteria to support an Addendum to the CalVTP PEIR for the inclusion of proposed treatment
areas outside the CalVTP treatable landscape. The checklist evaluates each resource in terms of whether
the later treatment project, including the “changed condition” of additional geographic area, would result
in significant impacts that would be substantially more severe than those covered in the CalVTP PEIR
and/or would result in any new impacts that were not covered in the PEIR.
This document serves as both a PSA and an Addendum to the CalVTP PEIR to provide CEQA
compliance for the proposed vegetation treatments within and outside of the treatable landscape. The
Project-Specific Mitigation Monitoring and Reporting Program (MMRP), which identifies the CalVTP
Standard Project Requirements (SPRs) and Mitigation Measures (MMs) applicable to the proposed
project, is presented in Appendix A. The SPRs identified in the MMRP have been incorporated into the
proposed vegetation treatments as a standard part of treatment design and implementation.
2 PROJECT DESCRIPTION
2.1 Project Background
The Town houses a complex wildfire environment (e.g., narrow, winding roads; combustible vegetation)
that presents a significant risk to both residents and firefighters. The Town is included as a community at
risk from wildfires on the federal and California Fire Alliance list of communities at risk in Santa Clara
County (California Board of Forestry and Fire Protection [CAL FIRE] 2020).
The Town WUI planning area includes approximately 4,740 acres of primarily VHFHSZ areas, as defined
by CAL FIRE and the Town Fire Prevention and Protection Ordinance (CAL FIRE 2007 Town of Los
Gatos 1996, 2019a, 2020a). Approximately a quarter of the Town’s residences are located within the
WUI. Of an estimated 2018 total of 13,299 residences, the WUI contains approximately 3,091 (Town of
Los Gatos 2022a). A Community Wildfire Protection Plan (CWPP) was prepared for the County of Santa
Clara (County) in 2016 (County of Santa Clara 2016). The Town of Los Gatos Annex (Annex 9) of the
CWPP addressed specific wildfire prevention and mitigation needs for the Town and identified the need
for the following that pertain to the Town’s parks and open spaces:
Community outreach and prioritizing treatments along existing trails that could help to provide a
more substantial fuel break and break up the continuity of fuels (Strategic Goal FR-1).
Prioritize treatments along existing trails to provide fuel breaks and break up continuity of fuels
(Strategic Goal FR-1).
Establish maintenance program in WUI areas where fire behavior and evacuation timing are
problematic (Strategic Goal FC-2; County of Santa Clara 2019).
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The VMP was prepared to address those needs and outlines a strategy for managing fuel loads and
vegetation along roadways in the Town’s VHFHSZ (Phase 1) and on Town-owned open space
lands/undeveloped parks (Phase 2). Phase 1 of the VMP, which included vegetation management along
roadways, was determined to be exempt from CEQA and is not considered in this PSA. This PSA will
include Phase 2 of the VMP, which includes vegetation management in Town-owned open space lands
and undeveloped parks.
The goal of the Open Space VMP is to manage vegetation and create fuel breaks along trails in the Town-
owned open space/undeveloped park lands through modification of vegetation to reduce crown overlap
and ignition points with overhead powerlines, reduce ladder fuels and combustible surface fuels, enhance
and maintain trails for efficient and effective evacuations, and create defensible space for fighting fires.
Vegetation management in the Town will provide defensible space around structures and assets where
these zones extend onto Town open space/undeveloped parks and create strategic fuel breaks to decrease
intensity and duration of fires reducing their ability to accelerate and spread.
The VMP includes fire management strategies to reduce the potential for catastrophic wildfires to occur
within the Town. The goals, objectives, and recommendations identified in the VMP are based on
existing field conditions and accepted CAL FIRE, County, and Town vegetation management guidelines
for wildfire hazard reduction (CAL FIRE 2019b; Town of Los Gatos 2020a). This VMP also identifies
best management practices (BMPs) to be implemented during vegetation management activities to reduce
or avoid impacts to the Town’s valuable natural resources and maintain important wildlife habitat.
2.2 Purpose and Need
The overarching purpose of the Open Space VMP is to provide a framework for reducing and managing
vegetative fuel loads on Town-owned open spaces/undeveloped parks within the Town’s VHFHSZ to
minimize wildfire hazard while avoiding or minimizing negative environmental effects. The Open Space
VMP follows the vegetation management treatments for reducing wildfire hazard described in the
CalVTP.
The Open Space VMP identifies and prioritizes fuel reduction treatments to remove hazardous vegetation
from 193.91 acres of Town-owned open space lands and undeveloped parks, including the Santa Rosa
and Heintz Open Spaces and La Rinconada, Novitiate, and Worcester Parks (see Figure 1). The Open
Space VMP also discusses fire safety of land uses bordering the Town’s undeveloped parks and open
space areas and identifies recommended measures that private landowners can take to reduce wildfire risk
and ignition potential throughout the VMP Area.
The Town will avoid and minimize potential negative environmental effects of vegetation management to
the greatest extent feasible, but also acknowledges that vegetation management is essential to public
safety and that environmental impacts of a catastrophic wildfire and post-fire effects within the Town
could greatly exceed the impacts of routine maintenance activities.
2.3 Project Activities
2.3.1 Project Area
The proposed project consists of fuel reduction treatments over approximately 193.91 acres within five
Town-owned and managed open space and undeveloped park areas (Town of Los Gatos 2008), including
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two open space areas and three undeveloped parks within the VHFHSZ.2 These parks and open spaces are
also adjacent to WUI areas that are identified as VHFHSZ (Association of Bay Area Governments
[ABAG] 2019).3
SANTA ROSA OPEN SPACE
The Santa Rosa Open Space area is located on approximately 76 acres of Town-owned land on the east
side of the Town adjacent to and east of Heintz Open Space. Its northern boundary is adjacent to WUI
lands that are also VHFHSZ, and its southern and eastern boundaries are adjacent to scattered WUI areas,
some of which are also VHFHSZ. The Santa Rosa Open Space has a canopy primarily composed of oak
woodland forest, including valley oak (Quercus lobata), coast live oak (Quercus agrifolia), and
California buckeye (Aesculus californica), with an understory dominated by non-native annual
grasslands, including slender oat (Avena barbata), and California natives, including coyote brush
(Baccharis pilularis), poison oak (Toxicodendron diversilobum), California sage (Artemisia californica),
elderberry (Sambucus nigra), California rose (Rosa californica), and snowberry (Symphoricarpos albus).
Dominant invasive species include Italian thistle (Carduus pycnocephalus), star thistle (Centaurea
solstitialis), stinkwort (Dittrichia graveolens), and cotoneaster. Several eucalyptus (Eucalyptus spp.) trees
and ornamental tree species were observed adjacent to the Santa Rosa Open Space. There are areas of
canopy connectivity across fire roads, mostly composed of oaks, areas with dense understories, and areas
of minor powerline entanglement. Woody slash and debris were observed stockpiled in concentrated
areas. These woody slash and debris areas are currently periodically removed but may also be chipped
and left in place as part of the Open Space VMP.
HEINTZ OPEN SPACE
The Heintz Open Space is located on approximately 88 acres of Town-owned land near the Summerhill
Homes development in the Heritage Grove neighborhood in the Town. The Heintz Open Space connects
to the Shannon Valley Open Space, Belgatos Park, and Santa Rosa Open Space. Similar to the Santa Rosa
Open Space, its northern border is comprised of WUI lands that are also VHFHSZ. Its southern and
western borders are adjacent to scattered WUI lands. The Heintz Open Space is dominated by oak
woodland and California buckeye. Vegetation is overall consistent with the Santa Rosa Open Space, as
described above. Areas of canopy connectivity occur within this open space and will require maintenance
for fire truck access.
LA RINCONADA PARK
La Rinconada Park is an approximately 9-acre forested creekside park located at 151 Granada Way. It
includes a 4-mile trail along Smith Creek, an unlit tennis court, a playground, and picnic areas. La
Rinconada Country Club golf course is located adjacent to La Rinconada Park along the park’s eastern
boundary near Smith Creek. Residential properties are located to the west of the park along Granada Way.
The nearest WUI, which includes some VHFHSZ, is 0.3 mile south and connected by the Smith Creek
riparian corridor. Valley oak and coast live oak dominate along the riparian area, which bisects the park.
The understory is sparse and contains invasive species, including English ivy (Hedera helix), French
broom (Genista monspessulana), acacia, and privet near the southern park boundary. Large patches of ivy
are dominant at the northern boundary adjacent to the public tennis courts (Town of Los Gatos 2020c).
2 La Rinconada Park is not within the VHFHSZ; however, it is included because it contains an area of mature trees and dense
vegetation in close proximity to a residential area.
3 La Rinconada Park is 0.3 mile north of the nearest WUI area, however, the intervening land includes a creek with continuous
riparian vegetation. Such watercourses are capable of providing a conduit for wildfire (North 2012).
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NOVITIATE PARK
Novitiate Park is located at 300 Jones Road and includes approximately 10 acres of former vineyard, now
minimally developed with trails and coast live oak woodland. It is a gateway to the Midpeninsula
Regional Open Space District (Midpen) St. Joseph Hill Open Space and is surrounded by WUI lands that
are also VHFHSZ. Los Gatos Creek borders the western boundary of Novitiate Park and is dominated by
California bay (Umbellularia californica), coast live oak, and sycamore. A dense understory of French
broom along the eastern park boundary and an infestation of Italian thistle along the northern park
boundary are present within this park. Coast live oak savannah and non-native annual grassland are
consistent throughout the area with elderberry and poison oak interspersed towards the center of the park.
Excess woody debris and slash occupy areas of the understory in northern and western portions of the
park (Town of Los Gatos 2020c).
WORCESTER PARK
Worcester Park is located at 140 Worcester Loop. It consists of approximately 11 acres of oak woodland
with three trails and is surrounded on all sides by residences that are located in the WUI and VHFHSZ
(ABAG 2019). Worcester Park is dominated primarily by coast live oak woodland. A dense understory
composed of French broom, olive (Olea europaea), elderberry, ivy, Italian thistle, tree of heaven
(Ailanthus altissima), and woody debris is interspersed. A small irrigation-fed seep with hydrophytic
vegetation, including nut sedge (Cyperus eragrostis), occurs on the western park boundary. Sparse areas
of ivy, vinca (Vinca major), and acacia occur throughout the park and may require management to
prevent future infestations. Dense mats of English ivy and broom are growing along the fence on the
western edge of the park in the understory and will require management (Town of Los Gatos 2020c).
2.3.2 Treatment Type: Wildland-Urban Interface Fuel Reduction
The proposed project includes fuel reduction activities within LRA areas that are adjacent to WUI areas in
the Town. Strategic fuel reduction activities would be conducted to reduce dead and dying trees and
understory brush that pose a threat of wildfire to nearby neighborhoods within the proposed treatment
areas. This proposed treatment type is consistent with the PEIR for modifications of landscape to reduce
losses and improve resiliency to wildfire (SWCA Environmental Consultants [SWCA] 2020).
The focus of WUI fuel reduction treatments is to strategically reduce vegetation density and remove fuel
to directly protect communities from wildfires originating in adjacent open space areas and protect open
space areas from wildfire starting in or near development. These treatments also serve as emergency
access points and staging areas for firefighters and equipment. WUI fuel reduction would also address
areas where habitat is degraded by infestation of non-native plant species and in need of fuel reduction.
Activities implemented within the WUI fuel reduction treatment type would occur within the 100-foot
defensible space requirements on Town-owned open space, as well as within the open space areas and
undeveloped parks, to reduce the overall risk of ignition and slow the rate of wildfire if it occurs within
the Town. Proposed treatment activities include removing hazardous trees, thinning understory trees and
brush, reducing ladder fuels, and removing fuels along trails throughout proposed treatment areas to
reduce potential wildfire fuels within and adjacent to the WUI. Appendix B identifies the specific areas
where WUI fuel reduction (i.e., defensible space and fuel reduction area treatments) and non-native
species removal will occur within the Open Space VMP Area.
2.3.3 Treatment Type: Fuel Break
There are two types of fuel break treatment types: non-shaded fuel breaks and shaded fuel breaks. Non-
shaded fuel breaks are typically created where there is a natural change in vegetation type, such as from
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forest to grassland. Heavy equipment is typically used to remove all vegetation from this type of fuel
break, although manual removal or prescribed burning may be used on slopes steeper than 50% to 60%.
Shaded fuel breaks are used in forest settings. The tree canopy is thinned to reduce the potential for crown
fire to move through the canopy, but large trees remain. The shade of the retained canopy helps reduce
regrowth of shrubs and sprouting hardwoods. Shaded fuel breaks are used instead of non-shaded fuel
breaks in areas where habitat needs to be retained for sensitive species, there is potential for erosion, there
is potential for visual impacts, or the fuel type allows this type of treatment. The proposed project would
create shaded fuel breaks that will be 100-feet wide and will be located along open space/undeveloped
park boundaries, and along fire roads and trails. Appendix B identifies the specific areas where fuel
breaks will occur within the Open Space VMP Area.
2.3.4 Treatment Activities
As described in Table 1, proposed treatment activities include mechanical thinning, mechanical mowing,
manual thinning, prescribed herbivory, and herbicide application over approximately 193.91 acres of
proposed treatment areas within the Town. Each of these activities are included as vegetation treatments
in the PEIR and are described in detail below.
Table 1. Proposed VMP Treatments and CalVTP Treatment Types
CalVTP
Treatment
Type Treatment Description
CalVTP
Treatment
Activity
Treatment
Size
(acres)
Equipment Used
for Treatments
Timing of
CalVTP Treatments
WUI Fuel Reduction/ Fuel Break
Use of motorized equipment to grade, mow, disk, cut, masticate,
and grub existing vegetation to reduce fuel loads within the WUI, including in the Defensible Space areas or create zone of vegetation removal that support
fire suppression.
Mechanical Treatment Up to 194 acres Bobcats, chippers, tractors,
masticators, skid steers, dozers, and mowers
Mechanical treatment may be conducted
year-round. Nesting bird Avoidance and Minimization Measures (AMMs) would apply March through August.
Use of hand tools and hand-operated power tools to cut,
clear, or prune herbaceous or woody species to avoid impacts to sensitive habitats while reducing fuel loads within the WUI.
Manual Treatment Up to 194 acres Shovels, wrenches,
chainsaws, handsaws, pruning shears, trimmers, weed whackers, and loppers
Manual treatment may be conducted year round depending on the growth patterns of the species. Nesting bird AMMs would apply March through August.
Use of livestock to consume grasses forbs and emerging shrubs and trees, to reduce
understory and herbaceous fuel loads.
Prescribed Herbivory Up to 137 acres Livestock, such as cattle, goats, sheep, or horses
Prescribed herbivory would be conducted year round, but
primarily in late spring through late summer.
Herbicide application is typically performed by hand and can
include sponging, spraying (e.g., backpack hand applicator, boom sprayers), hand placement of pellets, or dusting chemicals onto targeted vegetation. Herbicide
application would be used for invasive species removal.
Herbicide Treatment Up to 10 acres Backpack hand applicator, boom
sprayers
Chemical applications may be conducted
January through September, depending on the invasive species growth patterns.
Total Project
Acres
193.91 acres*
Source: SWCA (2021); CAL FIRE (2019c, Town of Los Gatos (2020c)
* Please note that more than one treatment may be applied at each location; therefore, the total acreage of treatments exceeds the total acreage in the project area.
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MECHANICAL VEGETATION TREATMENT
Mechanical treatments involve the use of heavy machinery or equipment rather than hand or manual
equipment to remove or alter vegetation and woody debris. Generally, this treatment option is used to
create fire roads and/or breaks. Grading, mowing, disking, cutting, masticating, and grubbing are all
examples of mechanical treatments. Mechanical treatments can be used on all vegetation types; however,
access for machinery needs to be considered (e.g., slope, terrain, vegetation, seedbed preparation and
revegetation needs, climate conditions, soil) before implementing this treatment type. Some areas may
require more than one type of machinery to operate at once. For example, one machine may be cutting or
removing vegetation and placing it in a stockpile for another machine to then chip in place or haul off-
site. Vegetation removed during mechanical treatment would be disposed of by one or a combination of
the following methods: lopping debris to a specified maximum length and scattering it within the
treatment boundary to a specified depth to reduce flame lengths in the event of a wildfire, piling and
leaving piles for wildlife habitat, chipping and blowing chips onto the ground as mulch or into piles for
later removal, cutting large woody material into lengths for firewood, removing large wood material by
hand, or hauling off-site to an appropriate facility.
This treatment option works best in areas with one uniform vegetation type. Operators of heavy
machinery and equipment do not have the same ability as hand removal treatments to selectively remove
species. However, it is possible with guidance for machinery to navigate around sensitive areas. Operators
should be specifically trained to operate heavy machinery and supervised while conducting vegetation
removal to limit impacts. Examples of heavy machinery and equipment include bobcats, chippers,
tractors, and mowers. Mechanical treatments require ongoing monitoring and maintenance since residual
weed or shrub seed in the soil or resprouting of shrubs may revegetate treated areas with undesired plants.
Most mechanical treatment occurs in late spring, summer, or fall.
MANUAL VEGETATION TREATMENT
Manual treatment involves the use of hand tools and hand-operated power tools to cut, clear, or prune
herbaceous or wood species. Hand removal is an effective but labor-intensive treatment option. Activities
include hand pulling, trimming, pruning, cutting, and removal of trees, shrubs, or dead vegetation using
only your hands or handheld equipment. Hand tools, including shovels, wrenches, chainsaws, handsaws,
pruning shears, trimmers, weed whackers, and loppers, are used to trim and remove vegetation. This
treatment requires less ground disturbance than mechanical treatment. Hand removal is a good treatment
technique in areas with a vegetation mosaic, meaning multiple vegetation types in one area, where
removal needs to be more selective. Solarizing and mulch application can also be placed on top of
vegetation to reduce or stop growth through a combination of heat and lack of sunlight. These methods
can take anywhere between 2 weeks and 6 months to treat vegetation, depending on the type and size of
the vegetation and the treatment area size. This treatment option is most effective for spot treatments, not
for widespread infestations. Vegetation that accumulates during manual treatments would be disposed of
as described above for mechanical treatments.
PRESCRIBED HERBIVORY
Grazing or prescribed herbivory involves using livestock, such as cattle, goats, sheep, or horses, to reduce
understory and herbaceous fuel loads. Livestock consume grasses, forbs, and emerging trees and shrubs
that contribute to the overall hazardous fuel load. Livestock do not effectively create fuel breaks; this
treatment should be used to maintain vegetative growth to reduce fuel loads in grasslands, in brushlands,
and beneath tree canopies. Livestock can also be used to remove non-native species infestations.
Grazing typically occurs late in spring when certain vegetation growth starts to slow and continues
through the late summer. Some livestock are better suited to specific habitat and terrain types. For the
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open space areas/undeveloped parks, goats are the recommended livestock choice due to their ability to
traverse a diverse range of terrains; consume large areas of vegetation including woody shrubs, vines, and
trees over a short time-period; and remove materials up to 6 feet above the ground.
It is important that livestock are managed and remain only in designated grazing areas, which may require
a herder, fencing, mineral block, and/or watering site. A site-specific grazing management plan should be
prepared and implemented by a qualified contractor to prevent grazing or disturbance of sensitive
resources. This grazing plan should clearly identify livestock containment methods such as portable or
fixed fencing and/or herders, as well as timing of grazing activities, and movement of grazing animals to
new locations. A target vegetation removal goal should also be identified in the grazing management plan
to determine the amount of vegetation (usually expressed in pounds per acre) to prevent overgrazing.
Grazing does not need to occur on an annual basis for hazardous fuel reduction if the goal is to simply
maintain fuel load in a specific area. If the goal is to reduce fuels, then grazing should occur on an annual
basis and can be adjusted as needed. Consultation with a Certified Rangeland Manager is advised when
conducting prescribed herbivory.
HERBICIDE
Herbicides are chemicals that damage or kill plants, and can be classified by their mode of action, that
interfere with plant metabolism in different ways. Herbicides include growth regulators, amino acid
inhibitors, grass meristem destroyers, cell membrane destroyers, root and shoot inhibitors, and amino acid
derivatives. Herbicide treatments are also either selective (i.e., they kill only a specific type of plant) or
non-selective (i.e., they kill any type of plant). There are multiple factors to consider before applying
herbicide treatments. These factors include the type or species of plant and the life stage, size, density,
and location of the species. Herbicide treatments are only suited for specific vegetation types and
densities. For example, larger species in low densities that are more difficult to remove, such as
eucalyptus, could be treated with herbicides as secondary spot treatments while broom species that
generally occur in high densities should be removed using hand tools, such as a broom wrench.
Application of herbicide treatments directly on plant tissues is one of the most effective methods. All
herbicide treatments must be conducted from the ground and no aerial applications would be allowed as
part of this VMP. Herbicide application is typically performed by hand and can include sponging,
spraying (e.g., backpack hand applicator, boom sprayers), hand placement of pellets, or dusting chemicals
onto targeted vegetation.
Herbicide treatments are optional as part of the Open Space VMP, on an as-needed basis, but are not to be
used in areas with sensitive biological resources, including riparian habitat. Consistent with the CalVTP,
the Open Space VMP would allow for the use of the following herbicides in the open space/undeveloped
parks areas: borax (tetraborate decahydrate), clopyralid (monethanolamine salt), glyphosate
(ispropylamine salt, potassium salt, dimethylamine salt, diammonium salt), hexazinone, imazapyr
(isopropylamine salt), sulfometron methyl, triclopyr (butoxyethyl ester and triethylamine salt),
nonylphenol 9 ethoxylates (NP9E), cleantraxx (penoxsulam and oxyfluorfen), velpar (hexazinone), and
indaziflam.
Herbicide treatments can be highly effective in reducing the number of live species but require extra
measures, such as training and certification to handle chemicals/pesticides, equipment, and storage.
Certification is required to apply herbicides in the State of California through the California Department
of Pesticide Regulation and requires the certified party to obtain appropriate personal protective
equipment (PPE), including, but not limited to, masks or respirators, safety goggles, gloves, protective
clothing, hard hats, and boots. In addition, after herbicide application, dead species still need to be
removed so that dry woody debris does not add to fuel loads. Herbicide treatments require ongoing
monitoring and maintenance. Herbicide treatments must be performed in accordance with federal and
state regulations by a licensed Pest Control Advisor.
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2.3.5 Vegetation Management and Maintenance Standards and
Areas
Vegetation management for wildfire hazard reduction is an ongoing, cyclical process. Given the dynamic
nature of vegetation, a single management prescription cannot be assigned to any location and be
effective in perpetuity. Additionally, management prescriptions intended for initial treatments may differ
from those intended for future maintenance of the same area. As a result, the management and
maintenance standards presented in this section have been broken down by specific vegetation types
known to occur within the overall Open Space VMP Area. In addition, certain vegetation community/land
cover types found in the Open Space VMP Area (i.e., urban) do not present a wildfire hazard due to
noncombustible condition and are not included in the VMP.
Vegetation management treatments outlined in the previous section will be selected based on the needs of
each Open Space VMP location as conditions change over time. The management and maintenance
standards outlined in this section are intended to modify fuel arrangements to reduce the potential for
ignitions, rapid fire spread, crown fires, and extreme fire behavior in accordance with state and local
regulations. These standards have ultimately been developed to reduce fuel loads, eliminate ladder fuels,
disrupt the horizontal continuity of vegetation, remove non-native species, minimize ignition potential,
and prioritize retention of non-combustible plants.
The Town will work with private contractors annually to inspect and clear vegetation (as needed) within
the Town-owned open space and undeveloped park areas. Clearing activities in these areas will include
the following management standards:
Establish a defensible space zone around buildings on adjacent private properties. The Town will
remove or treat vegetation on identified Town-owned property within 100 feet of adjacent
buildings to create a 100-foot defensible space perimeter. The Town will not remove or treat any
vegetation on private property.
Within 30 feet of a habitable structure on Town-owned properties, grasses (annual or perennial),
weeds, and thistles will be treated such that heights do not exceed 3 inches. Grasses will not be
pulled from the ground to avoid soil erosion. 4
Beyond 30 feet of a habitable structure, grasses (annual or perennial), weeds, and thistles will be
treated such that heights do not exceed 18 inches.
All dead trees and dead or dying ground cover, brush/scrub, twigs, branches, limbs, vines, or
other vegetation will be removed from within the 100-foot defensible space area.
Dead trees will strategically be removed from open spaces areas outside the 100-foot defensible
space area within the areas identified as fuel reduction area and shaded fuel break.
Dead or dying growth will be strategically removed from brush/scrub and trees from open space
areas outside the 100-foot defensible space area within the areas identified as fuel reduction area
and shaded fuel break.
Dead or dying ground cover, woody slash and debris, brush/scrub, twigs, branches, limbs, vines,
or other vegetation will strategically be removed from open space areas outside the 100-foot
defensible space area within the areas identified as fuel reduction area and shaded fuel break.
Alternatively, any removed wood could be chipped and spread on-site as mulch.
Areas within the shaded fuel break and fuel reduction areas will be thinned by removing trees and
shrubs or chipping them and spreading them on-site as mulch. Treatments for these areas should
4 Cut grass may be left on the ground surface to protect soil as long as it does not exceed 6 inches in height.
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follow standards discussed in Standards for Vegetation Communities within the VMP Area, for
the appropriate vegetation community.
Non-native/invasive species will be removed and hauled off site. Treatments within these areas
should follow standards for invasive species discussed in Standards for Vegetation Communities
within the VMP Area.
Eucalyptus and acacia trees will be removed.
Areas where defensible space, fuel reduction areas, shaded fuel breaks, mowing/grazing, and invasive
species are proposed to be implemented within each Open Space VMP location is included in
Appendix B.
STANDARDS FOR VEGETATION COMMUNITIES WITHIN THE VMP AREA
The following section describes specific treatment standards for vegetative fuels present within the Open
Space VMP Area. All vegetation removed from Open Space VMP management areas should be chipped
in place and spread as mulch or transported and disposed of in accordance with Town codes and
standards. All treatment activities will follow the appropriate recommendations for fuel reduction
according to vegetation type within the open space/undeveloped park areas, consistent with CalVTP and
CAL FIRE recommendations. Avoidance and Minimization Measures (AMMs) and BMPs are listed in
Section 2.3.7 Avoidance and Minimization Implementation. In addition, the proposed project would
implement applicable CalVTP SPRs, which are further described in the individual resources sections
included in Section 4, Project-Specific Analysis.
Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates.
Non-native annual grassland and herbaceous understories are present throughout the Open Space VMP
Area. Recommendations for grassland/herbaceous areas follow:
In areas where grassland transitions to woodland habitat, a fuel break should be maintained to
prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance
should be maintained between grassland and woodland habitat.
Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or
chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and
should be evenly distributed to prevent a buildup of debris.
Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in
height, grass cuttings can be left in place to protect ground soils from erosion.
Grazing is allowed in this habitat and can occur year-round in certain areas, although it is
recommended and most effective in late spring through late summer. Grazing should follow the
grazing plan provided by the hired grazing management company.
Chaparral/Scrub
Chaparral, scrub, and brush occur throughout the VMP Area and include species like California sage
scrub and coyote brush. This vegetation type generally occurs in dense clusters with some tree species
interspersed. Recommendations for chaparral/scrub areas follow:
Dead and dying debris should be cut and trimmed or removed. Roots can be left in place in order
to maintain soil stability if necessary.
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All vegetative debris should be hauled off-site or chipped in place. Vegetative materials chipped
in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup
of debris.
If trees are growing among this community, a minimum distance of three times the height of the
scrub should be cleared between the lowest lying branches and the chaparral/scrub species.
Horizontal separation should be two to three times the height of the chaparral/scrub.
Oak Woodland
Oak woodland dominates the Open Space VMP Area and includes a combination of coast live oak, valley
oak, California bay, California buckeye, and walnut. As previously mentioned, this is a sensitive
vegetation community and work in this habitat type should be minimal and conducted in accordance with
AMMs and BMPs outlined below in Section 2.3.7 Avoidance and Minimization Implementation.
Canopies in this community are intermittent to continuous. In areas with breaks in the canopy,
understories are generally composed of grassland and brush and scrub species. Recommendations for oak
woodland areas follow:
In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree
branches. In areas where shrubs and scrub occupy the understory, a horizontal distance of at least
three times the size of the scrub should be maintained. If grassland or herbaceous fuels are
present in understories, a minimum distance of three times the vertical height of surface fuels
should be maintained.
Duff and leaf litter should not exceed 3 feet above ground level.
If highly flammable species are present in oak woodland habitat, they should be removed and
hauled off-site.
Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than
20% of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no more than 20
acres will be converted to thin or create the shaded fuel break).
Acacia, Eucalyptus, and Privet
Acacia, eucalyptus, and privet are highly invasive and highly flammable species that contain flammable
resins and oils. These species occurs throughout the Open Space VMP Area in small, concentrated stands
mostly along roadways and adjacent to private properties. Recommendations for areas with acacia,
eucalyptus, and privet follow:
Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and
maintain 10 to 20 horizontal feet, depending on the slope, between mature trees.
Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings
and resprouts and chemical treatments for stumps.
A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared
between the lowest-lying branches and any scrub species.
Cut and treat larger sapling and mature tree species with herbicides.
Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas,
see Section 2.3.7 Avoidance and Minimization Implementation below.
Acacia, eucalyptus, and privet can be chipped in place so long as no plant material is left adjacent
to sensitive riparian features and does not cover other plants.
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Tree of Heaven
Tree of heaven is a highly invasive and flammable species that is commonly found in disturbed areas and
along riparian corridors within the Open Space VMP Area. Recommendations for tree of heaven areas
follow:
Pull seedlings and small saplings while soils are moist and loose. Remove taproots by digging
around the base of the plant to remove all roots and prevent resprouts.
Cut the stems of mature trees at the beginning of spring and once more in June or July to reduce
seed production and deplete energy reserves.
Cut and treat trunks or stems of large trees (i.e., greater than 4 inches diameter at breast height
[dbh]) with chainsaws and apply herbicides.
Broom Species
Broom is common in Open Space VMP Area understories and can grow in grasslands, scrub, and
woodland habitats. Recommendations for broom species areas follow:
Pull shrubs by hand using a weed wrench.
Cut shrubs to just above ground level using loppers or brush cutters during the dry season in areas
sensitive to ground disturbance.
English Ivy
English ivy is a woody vine generally found in moist areas with dense canopies and good shade cover.
Recommendations for English ivy areas follow:
Pull vines that are climbing trees and on the ground by hand or using rakes.
Cut stems with pruners or loppers and dig up roots using shovels to prevent resprouts.
Utilize prescribed herbivory, as appropriate, to remove ivy.
Italian Thistle
Italian thistle is an invasive species commonly found in disturbed areas, grasslands, and riparian areas.
This species occurs in concentrated patches throughout the Open Space VMP Area. Recommendations for
Italian thistle areas follow:
Smaller infestations can be removed by hand by pulling, digging, and cutting. Digging may be
restricted in areas that contain sensitive habitat, including riparian, chaparral, and oak woodland
especially in areas upslope of aquatic resources and in areas with steep slopes due to the high
level of soil disturbance.
Pull plants by hand once the plant has bolted but prior to flower production.
Cut plants by hand or brush cutters before the thistle flowers and again in early summer to reduce
energy reserves. This treatment is best used in the dry season when soils are hard and hand
pulling is more difficult.
Graze infestations in the early spring when individual plants are approximately 4 to 6 inches high.
Grazing should continue for about 2 to 3 weeks, or in coordination with the contracted grazing
manager.
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Treat plants with herbicides in mid-spring before they spread seed. Restrictions apply to sensitive
habitat areas as detailed below in Section 2.3.7 Avoidance and Minimization Implementation.
Riparian Woodland
Riparian woodlands generally contain dense canopies with intermittent to continuous understories.
Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to
reduce surface fuel. Riparian areas are sensitive and vegetation management activities should be minimal
to protect and avoid impacts to sensitive resources per the AMMs and BMPs below in Section 2.3.7
Avoidance and Minimization Implementation. Recommendations for riparian areas follow:
Downed branches, woody slash, and debris should be removed adjacent to stream and creek
channels to reduce surface fuel.
Target climbing and ladder fuels, such as poison oak and giant reed (Arundo donax). Three feet of
separation should be maintained between surface fuels and low-lying canopy branches.
Remove highly flammable species.
Monitor canopy continuation and connectivity. In areas with gaps in the canopy, understory
growth, including ladder fuels, is more prevalent. These gaps, if present, should maintain three
times the vertical distance of the height of surface fuels, which should be trimmed or removed to
ensure no highly flammable pockets of dense vegetation forms.
2.3.6 Area-Specific Treatments
As previously mentioned, the Open Space VMP is consistent with the CalVTP created by CAL FIRE.
CalVTP separates the state into ecoregions and treatable landscapes. The Open Space VMP Area is part
of the 261A Central California Coast Ecoregion. Ecoregions are generally characterized as areas with
similar or recurring patters of physical and biological characteristics that may include geology, soils,
geomorphology, hydrology, climate, vegetation types, animal species composition, biodiversity, and land
use history (CAL FIRE 2019a). This method helps identify the range of biological resources and sensitive
biological resources near or adjacent to implementation areas, provides a relevant scale for analyzing
potential impacts, and demonstrates that potentially affected resources and impacts of treatments were
considered prior to implementation. The following sections describe wildfire hazards, if present, and
specific treatment activities for the Open Space VMP in accordance with CalVTP treatment standards.
Appendix B shows the areas within Open Space VMP location for each treatment type and summarizes
the treatment activities, timing, and standards for each open space area.
SANTA ROSA/HEINTZ OPEN SPACE
The Santa Rosa/Heintz combined open space areas will require a combination of fuel modification
treatments and treatment activities to manage wildfire risk, including grazing or mowing, creating shaded
fuel breaks adjacent to the open space boundary and along trails and fire roads, and pruning and thinning
of trees and shrubs to reduce ladder fuels.
The Santa Rosa Open Space is one of the steepest and largest open space areas in the Open Space VMP
Area along with the Heintz Open Space, which sits due west of Santa Rosa Open Space. Sixty-one
percent of slopes are categorized as gently sloped (0%–20% sloped) and 39% are categorized as
moderately steep (20%–40% sloped). Both the size and steepness of slopes in this open space area create
a high wildfire risk. Although the vegetation is well managed in most areas, there are areas of canopy
connectivity, stockpiled woody debris, dense understories, and minor powerline entanglement. All these
factors contribute to a high wildfire risk. In general, the steeper the slope the greater the rate of wildfire
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spread, as flames from below heat and dry fuels above, making them more available for combustion.
Strong winds funneled through the hillside could cause a wildfire to spread at a more rapid rate through
open space area towards residences and other infrastructure, which is most dense north and south of the
open space boundary. Neighboring properties contain ornamental and landscaped vegetation, including
eucalyptus trees, which are highly flammable. Fuels in the Santa Rosa Open Space are predicted to burn
with flame lengths in an excess of 12 feet and rates of spread of 20 chains/hour or higher. Under these
conditions, suppression strategies would be limited to indirect attack and use of mechanized equipment.
Santa Rosa Open Space is also difficult for emergency and fire access because of the scale and steeply
sloped fire roads that weave through the open space. If a wildfire were to occur, it may take longer for
response teams to access the site and contain the fire.
The Heintz Open Space has similar conditions to the Santa Rosa Open Space. The two open spaces are
connected and are both steeply sloped. Within the Heintz Open Space, 54% of slopes are categorized as
gently sloped and 46% are categorized as moderately steep. It is very likely that if a wildfire were to start
in one of the open spaces, it would easily spread to the other. Due to the overall aspect of both the Santa
Rosa and Heintz Open Space areas, vegetation and ground warming from prolonged sun exposure could
also cause wildfire to spread upslope more quickly than it would in flatter, cooler areas. Canopy
connectivity and proximity and density of residences and infrastructure surrounding the open space area
also contribute to the high-risk designation of this open space. Heintz Open Space is also subject to strong
winds, which could cause rapid and unpredictable wildfire dispersion. Flame length and rate of spread
within Heintz Open Space are also consistent with the Santa Rosa Open Space. These factors create
additional constraints for fire response teams. This area is more difficult for emergency and fire access
because of the scale and steeply sloped fire roads that weave through the open space. Just as in the Santa
Rosa Open Space, if a wildfire were to occur, it may take longer for response teams to access the site and
contain the wildfire.
LA RINCONADA PARK
La Rinconada Park will require a combination of fuel modification treatments and treatment activities to
manage wildfire risk, including grazing or mowing, creating shaded fuel breaks adjacent to the park
boundary and along trails and fire roads, pruning and thinning of trees and shrubs to reduce ladder fuels,
and removing invasive species. Standards for riparian and oak woodland for pruning and reducing ladder
fuels along Scott Creek should be followed, as detailed above in Standards for Vegetation Communities
within the VMP Area. Invasive plants, including ivy, broom, acacia, and privet, should be managed, and
AMMs and BMPs for ephemeral/intermittent drainages should be implemented, as seen below in Section
2.3.7 Avoidance and Minimization Implementation.
La Rinconada Park has a low wildfire risk and priority level of three, making it the lowest-priority area of
the Open Space VMP. This park is mostly flat with 90% of slopes categorized as gently sloped and 10%
are categorized as moderately sloped. This park is adjacent to the La Rinconada Country Club and golf
course to the east, which is dominated by irrigated and regularly mowed turf that acts as a fuel break. In
addition, approximately 70% of the western park boundary is also composed of mowed turf, which also
acts as a fuel break. Although there are highly flammable species present, these species are currently only
present in low quantities and do not pose a serious threat. These species should be removed to maintain a
low wildfire risk but are not a high priority at this time. Since La Rinconada Park is small and flat, it
would likely have a slower dispersal rate and overall risk. Fuels are predicted to burn with flame lengths
of 0 to 4 feet and rates of spread of 0 to 2 chains/hour. Under these conditions, multiple wildfire
suppression strategies are readily available, including direct attack. Adjacent multi-lane roadways also
provide easy access for emergency vehicles.
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WORCESTER PARK
Worcester Park will require a combination of fuel modification treatments and treatment activities to
manage wildfire risk, including grazing or mowing, creating shaded fuel breaks adjacent to the park
boundary and along trails and fire roads, pruning and thinning of trees and shrubs to reduce ladder fuels,
and removing invasive species. Standards for fuel reduction within Oak Woodland habitat should be
followed, as detailed above in Standards for Vegetation Communities within the VMP Area. Ladder and
surface fuels should be reduced and invasive plants, including dense broom, ivy, vinca, Italian thistle,
acacia, and tree of heaven, should be managed.
Worcester Park is a priority level two, moderate risk park within the VMP Area. The park is gently
sloping with 99% of slopes categorized as gently sloped and 1% are categorized as moderately sloped.
Concentrated areas of highly flammable vegetation and woody debris are interspersed in the understory.
Almost the entire park boundary is surrounded by high-density residences and other infrastructure. This
park is small and gently sloped and will likely have a slow wildfire dispersal rate and low overall risk.
Fuels predicted to burn with flame lengths of 0 to 4 feet, with small pockets with potential to burn with
8-foot flame lengths, and rates of spread of 0 to 5 chains/hour or higher. Under these conditions,
suppression strategies include direct attack, with some indirect attack. Access for fire response via fire
roads, trails, or adjacent roadways allows for prompt containment of the fire. In addition, adjacent multi-
lane roadways provide easy access for emergency vehicles and large apparatus.
NOVITIATE PARK
Novitiate Park will require a combination of fuel modification treatments and treatment activities to
manage wildfire risk, including grazing or mowing, creating shaded fuel breaks adjacent to the park
boundary and along trails and fire roads, pruning and thinning of trees and shrubs to reduce ladder fuels,
and removing invasive species.
Novitiate Park is a moderate-risk park within the VMP Area. This park is categorized as 83% gently
sloped and 17% moderately sloped, which is along the northern portions of the park boundary. Overall,
vegetation is dense but well maintained except for a dense area of French broom along the eastern park
boundary. In addition, excess fuels, including woody debris and slash, are present in the understory and
require management. This park is small and gently sloped and will likely have a slow wildfire dispersal
rate and low overall risk. Fuels are predicted to burn with flame lengths of 0 to 4 feet and rates of spread
of 0 to 5 chains/hour or higher. Under these conditions, suppression strategies include direct attack, with
some indirect attack. This park is also an accessible area to emergency vehicles, although the streets are
narrow and often congested with cars from park users.
2.3.7 Avoidance and Minimization Implementation
Table 2 outlines practices intended to avoid and minimize potential impacts to sensitive resources
associated with implementation of vegetation treatment or removal.
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Table 2. Site- and Work-Specific Avoidance and Minimization Measures
ID # Avoidance and Minimization Measure
General Measures
1 The boundaries of the treatment area and protected resources will be clearly defined on maps and with highly visible flagging or other clear, existing landscape demarcations (e.g., edge of a roadway) prior to beginning any treatment to avoid disturbing the resource. “Protected Resources” refers to environmentally sensitive places within or adjacent to the treatment areas that would be avoided or protected to the extent feasible during planned treatment activities to sustain their natural qualities and processes. This work will be performed by a qualified person, as defined for the specific resource (e.g., qualified Registered Professional Forester or biologist).
2 During project activities, all trash that may attract predators shall be properly contained, removed, and disposed of regularly. Following vegetation management activities, trash and debris shall be removed from work areas.
Visual Resources Measures
3 All treatment-related materials, including vehicles, vegetation treatment debris, and equipment, will be stored outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. Materials staging and
storage areas will be located outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible.
4 Sufficient vegetation within, at the edge of, or adjacent to treatment areas will be preserved to screen views from public trails, parks, recreation areas, and roadways as reasonable or appropriate for vegetation conditions.
5 When possible, project activities will ensure that fuel breaks or tree removals are blended into the surrounding environment.
Air Quality Measures
6 Idling of construction vehicles and equipment shall be minimized to no more than 3 minutes to the extent feasible.
Construction foremen shall include briefing crews on vehicle use as part of pre-construction site meetings. These briefings shall include discussion of “common sense” vehicle use.
7 To minimize dust control during vegetation management activities, the following measures will be implemented:
a. Speed limits will be limited to 15 miles per hour on unpaved areas.
b. If the use of unpaved roads creates excessive dust, water trucks will be used, as necessary.
c. Visible dust, silt, or mud tracked-out on to public paved roadways will be removed.
Cultural Resource Measures
9 Cultural research will be conducted prior to implementing treatments as part of a cultural resource investigation. The purpose of this research is to properly inform survey design, based on the types of resources likely to be encountered
within the treatment area, and to be prepared to interpret, record, and evaluate these findings within the context of local history and prehistory. The qualified archaeologist and/or archaeologically trained resource professional will review records; review study maps; read pertinent ethnographic, archaeological, and historical literature specific to the area being studied; and conduct other tasks to maximize the effectiveness of the survey.
10 An archaeologically trained resource professional and/or qualified archaeologist will conduct a site-specific survey of the treatment area. The survey methodology (e.g., pedestrian survey, subsurface investigation) depends on whether the area has a low, moderate, or high sensitivity for resources, which is based on whether the records search, pre-field research, and/or Native American consultation identifies archaeological or historical resources near or within the treatment area. A survey report will be completed for every cultural resources survey completed.
11 If during any phase of the project, cultural and/or paleontological resources or human remains are discovered, work will be stopped until the find has been evaluated and the potential significance determined by a qualified professional archaeologist and an appropriate course of action has been recommended.
12 A training will be conducted for all crew members and contractors implementing treatment activities on the protection of sensitive archaeological, historical, or tribal cultural resources. Workers will be trained to halt work if archaeological resources are encountered on a treatment site and the treatment method consists of physical disturbance of land surfaces (e.g., soil disturbance).
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ID # Avoidance and Minimization Measure
Biological Resources Measures
13 Project activities will be designed to avoid significant effects on special-status species that are listed as rare, threatened, or endangered under federal law or are listed as rare, threatened, endangered, candidate, fully protected, or species of special concern under state law. A desktop review of the California Natural Diversity Database (CNDDB) and U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation system has been conducted and a reconnaissance survey of the roadways and parks was completed by SWCA in June and July 2020.
a. A qualified biologist will be retained to conduct a training for field personnel on sensitive habitat and species prior to vegetation management work. The training will include the identification, relevant life history information, and avoidance of pertinent special-status species; identification and avoidance of sensitive natural communities and habitats with the potential to occur in the treatment area; impact minimization procedures; and reporting requirements. The training will instruct workers when it is appropriate to stop
work and allow wildlife encountered during treatment activities to leave the area unharmed and when it is necessary to report encounters to a qualified biologist.
b. A qualified biologist will be engaged prior to all work to review the work locations. The biologist will be retained to survey the project area for special-status plant and wildlife species if work occurs adjacent to suitable habitat. All surveys will be conducted in the appropriate season.
c. A qualified biologist will be retained to conduct a nesting bird survey if work occurs during the nesting bird season (generally March 1–September 15). If a nesting bird is found, the biologist will provide measures to avoid impacting the species, such as implementing an appropriate no disturbance buffer.
d. A qualified biologist will be retained to conduct surveys for roosting bats prior to any tree trimming or tree removal. If a roosting bat is found, the biologist will provide measures to avoid impacting the species, such
as an appropriate no disturbance buffer or exclusion.
14 If special-status wildlife is encountered during project activities, it will be unharmed, it will be allowed to leave the area on its own volition, or the appropriate regulatory agency (i.e., USFWS or California Department of Fish and Wildlife [CDFW]) will be contacted to determine the appropriate action to relocate the species.
15 If sensitive natural communities are determined to be present in the treatment area as part of Measure 13, a qualified biologist will perform a protocol-level survey following the CDFW Protocols for Surveying and Evaluating Impacts to
Special Status Native Plant Populations and Sensitive Natural Communities of the treatment area prior to the start of treatment activities to map sensitive natural communities and sensitive habitats in the treatment area.
16 Treatments in chaparral habitats will implement the following in consultation with a qualified biologist:
a. Develop a treatment design that avoids conversion of the chaparral vegetation alliance, including evaluating and determining the appropriate spatial scale at which the proponent would consider the chaparral alliance converted. Demonstrate with substantial evidence that the habitat function of chaparral
would not be converted. Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, spatial needs of sensitive species, presence of sufficient seed plants and nurse plants, light availability, and edge effects may inform the determination of an appropriate spatial scale.
b. Maintain a minimum percent cover of mature native shrubs within the treatment area to maintain habitat function. Mature native shrubs that are retained will be distributed contiguously or in patches within the
stand. If the stand consists of multiple age classes, patches representing a range of middle to old age classes will be retained to maintain and improve heterogeneity, to the extent needed to avoid vegetation conversion.
17 To minimize impacts to natural resources, the area of ground disturbance will be limited to the minimum footprint necessary to meet the goals and objectives of vegetation management activities.
18 Project activities will be conducted to avoid introducing or spreading invasive plant species. The following are California Invasive Plant Council (Cal-IPC) BMPs to prevent the spread of invasive species (Cal-IPC 2012):
a. Provide prevention training to staff and contractors prior to starting work.
b. Schedule activities to minimize potential for introduction and spread of invasive plants.
c. Designate waste disposal areas for invasive plant materials and contain invasive plant material during transport.
d. Plan travel routes to avoid areas infested with invasive plants.
e. Clean tools, equipment, vehicles, and animals before transporting materials and before entering and leaving worksites.
f. Clean clothing, footwear, and gear before leaving infested areas.
g. Carry portable cleaning tools that can be used without water.
h. Prepare worksites to limit the introduction and spread of invasive plants.
i. Minimize soil and vegetation disturbance.
j. After activities, monitor worksites for invasive plants.
k. Prevent invasive plant contamination of project materials when stockpiling and during transport.
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ID # Avoidance and Minimization Measure
19 Prevent the risk of pathogens spread in sensitive natural communities by implementing the following BMPs:
a. Include training on Phytopthora diseases and other plant pathogens in the worker awareness training.
b. Clean and sanitize vehicles, equipment, tools, footwear, and clothes before arriving at a treatment site or a site where contamination is a risk.
c. Minimize soil disturbance as much as possible by limiting the number of vehicles, avoiding off-road travel
as much as possible, and limiting use of mechanized equipment.
d. Minimize movement of soil and plant material within the site, especially between areas with high and low risk of contamination.
e. Clean soil and debris from equipment and sanitize hand tools, buckets, gloves, and footwear when moving from high-risk to low-risk areas or between widely separated portions of a treatment area.
f. Follow the procedures listed in Guidance for plant pathogen prevention when working at contaminated restoration sites or with rare plants and sensitive habitat (CA Oak Mortality Task Force 2016).
20 If temporary fencing is used for prescribed herbivory, it will be wildlife friendly, and a qualified biologist will review and approve the design prior to installation.
Aquatic Resources Measures
21 If work will impact riparian vegetation, the Town will consult the CDFW and Regional Water Quality Control Board (RWQCB), as appropriate.
24 Treatments in riparian habitats will be designed to retain or improve habitat functions by implementing the following:
a. Retain at least 75% of the overstory and 50% of the understory canopy of native riparian vegetation within the limits of mapped riparian habitat (see Measure 15). Native riparian vegetation will be retained in a well-distributed multi-storied stand composed of a diversity of species similar to that found before the start of treatment activities.
b. Limit treatments to removal of uncharacteristic fuel loads (e.g., removing dead or dying vegetation), trimming/limbing of woody species as necessary to reduce ladder fuels, and select thinning of vegetation to restore densities that are characteristic of healthy stands of the riparian vegetation types characteristic of the region. This includes hand removal (or mechanized removal where topography allows) of dead or dying riparian trees and shrubs, invasive plant removal, selective thinning, and removal of encroaching upland
species.
c. Limit removal of large, native riparian hardwood trees (e.g., willow, ash, oak, maple, alder, sycamore, cottonwood).
d. Fell removed trees away from adjacent streams or waterbodies and pile outside the mapped riparian area.
e. Avoid removing vegetation that could reduce stream shading and increase stream temperatures.
f. Limit ground disturbance to the minimum necessary to implement effective hazardous fuel reduction.
25 Herbicide use in riparian areas associated with the Open Space VMP will be applied by hand application only. Only herbicides approved for aquatic environments will be used.
26 Herbicide application will occur outside the wet season (generally November 1–April 14) when seasonal streams are low flow or dry.
27 Herbicide treatments must be performed in accordance with federal and state regulations by a licensed Pest Control Advisor. Applicators will follow all herbicide label requirements and refer to all other BMPs regarding mandatory measures to protect sensitive resources and employee and public health during herbicide application.
28 No work will occur in standing water associated with a stream or creek in the VMP Area.
29 During VMP implementation, fuel and hazardous materials will be kept at 100 feet from waterbodies to provide protection from accidental leaks or spills.
30 All fueling and maintenance of vehicles and other equipment and staging areas shall occur at least 100 feet from potentially jurisdictional drainages.
31 Prior to the onset of work, the Contractor shall ensure that there is a plan to allow a prompt and effective response to any accidental spills. All workers shall be informed of the importance of preventing spills, and of the appropriate measures to take should a spill occur.
32 Soil and trimmed or chipped vegetation will not be placed where it could enter a waterbody or cover vegetation.
33 If grazing occurs adjacent to riparian features, livestock will be excluded from the area using exclusion fencing or
methods approved by the project biologist and grazing manager.
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ID # Avoidance and Minimization Measure
Geology/Soils Measures
34 Suspend mechanical treatments, prescribed herbivory, and herbicide treatments if the National Weather Service forecast is a “chance” (30% or more) of rain within the next 24 hours. Activities that cause soil disturbance may resume when precipitation stops and soils are no longer saturated (i.e., when soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur).
35 Heavy equipment operations will not be conducted on slopes greater than 50% or in any slide or unstable areas.
36 Limit heavy equipment use in areas that could cause soil disturbance or compaction when soils are wet and saturated to avoid compaction and/or damage to soil structure.
37 Erosion control measures will be installed, as necessary to minimize erosion, according to manufacturers’ specifications. Appropriate erosion control measures include, but are not limited to, the following:
silt fences
straw bale barriers
brush or rock filters
storm drain inlet protection
sediment traps
sediment basins
erosion control blankets and mats
soil stabilization (e.g., tackified straw with seed, jute, or geotextile blankets, broadcast and hydroseeding)
Erosion control measures will be inspected prior to the rain season and immediately repaired, as necessary. All temporary construction-related erosion control methods (e.g., silt fences) shall be removed at the completion of the project.
Noise Measures
38 Per the Town of Los Gatos Noise Ordinance (Section 16.20.035), vegetation management activities will be limited to the hours between 8:00 a.m. and 6:00 pm Monday through Friday, and 9:00 a.m. to 4:00 p.m. on Saturday (Town of Los Gatos 1991).
39 All power equipment and power tools will be used and maintained according to manufacturer specifications. All diesel- and gasoline-powered equipment will be properly maintained and equipped with noise-reduction intake and exhaust mufflers and engine shrouds, in accordance with manufacturers’ recommendations.
Traffic Control Measures
40 Prepare and implement a Traffic Control Plan to describe procedures to guide traffic (e.g., signage, flaggers),
safeguard construction workers, provide safe passage of traffic, and minimize traffic impacts, as necessary, through the duration of the vegetation management project. Coordinate with work with local emergency services providers, as necessary, to ensure that emergency vehicle access and response is not impeded.
Public Health and Safety Measures
41 The project will maintain fire-safe working conditions BMPs. These will include:
a. All work vehicles will be required to carry fire suppression equipment. Workers will be trained in the use of equipment for incipient stage fire suppression.
b. No smoking is allowed in any areas of vegetation management activities along Town roadways or in Town open spaces or parks. All vehicle parking will be restricted to paved or graveled surfaces.
c. Require spark arrestors on all off-road equipment.
d. Monitor weather and fire danger on a daily basis. During Red Flag Warnings, a crew member will be assigned to fire watch for each separate and distinct active work area.
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3 ENVIRONMENTAL CHECKLIST
Vegetation Treatment Project Information
1. Project Title: Los Gatos Open Space Vegetation Management Plan
2. Project Proponent’s Name and
Address:
Town of Los Gatos
Department of Public Works
1422 Monterey Street
Los Gatos, CA 93401
3. Contact Person Information and
Phone Number:
Stefanie Hockemeyer
(408) 399-5761
shockemeyer@losgatosca.gov
4. Project Location: Town of Los Gatos undeveloped parks and open space
(see Section 2, Project Description, and Figure 1)
5. Total Area to be Treated (Acres): Approximately 193.91 acres
Description of Project: The project would perform fuel reduction treatments to remove hazardous
vegetation from 193.91 acres of Town-owned open space lands and undeveloped parks, including Santa
Rosa Open Space (75.89 acres), Heintz Open Space (88.12 acres), Worcester Park (11.33 acres), La
Rinconada Park (8.64 acres), and Novitiate Park (9.93 acres) (see Figure 1).
a. Initial Treatment
Initial treatments would include primarily mechanical treatments and prescribed herbivory for fuel
reduction treatments and to create strategically located fuel breaks within and surrounding five
undeveloped parks and open space areas adjacent to WUI areas. In addition to mechanical treatment
and prescribed herbivory, application and manual activities would be used for invasive species
removal, and manual activities would be used for work in sensitive areas including riparian corridors.
See Section 2, Project Description.
Treatment Types
☒ Wildland-Urban Interface Fuel Reduction
☒ Fuel Break
☐ Ecological Restoration
Treatment Activities
☒ Prescribed Herbivory, up to 137 acres
☒ Mechanical Treatment, up to 194 acres
☒ Manual Treatments, up to 194 acres
☒ Herbicide Treatments, up to 10 acres
☐ Prescribed Burning (Pile Burning), 0 acres
☐ Prescribed Burning (Broadcast), 0 acres
Fuel Type
☒ Grass Fuel Type
☒ Shrub Fuel Type
☒ Tree Fuel Type
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b. Treatment Maintenance
Treatment maintenance methods would involve the same vegetation treatment activities used in the
original treatment, including mechanical treatment, manual treatment, prescribed herbivory, and
chemical application. Maintenance treatments would include similar equipment and would be
required annually after initial treatments for Defensible Space areas and every 3 years for all other
areas. Treatment maintenance activities would be subject to the identified Project Design Features
and CalVTP SPRs.
6. Regional Setting and Surrounding Land Uses:
The proposed project is located in the Town of Los Gatos, in the San Francisco Bay Area,
approximately 43 miles south of San Francisco. The Town is in the southwestern part of Santa Clara
County at the base of the Sierra Azul mountain range, where the Santa Clara Valley meets the lower
slopes of the Santa Cruz Mountains. The Town is bounded by the City of San Jose to the north and
east, the City of Campbell to the north, the Cities of Monte Sereno and Saratoga to the west, and
unincorporated areas of Santa Clara and Santa Cruz Counties to the south (Town of Los Gatos
2022a). The proposed project area encompasses a wide variety of terrain, ranging from flat
topography at the edge of the valley floor to densely wooded hillsides. All five undeveloped parks
and open space areas are surrounded, at least in part, by residential areas of the Town, and are in or
near areas in the WUI and VHFHSZ.
7. Other Public Agencies Whose Approval is Required (e.g., permits):
None
Coastal Act Compliance
☒ The proposed project is NOT within the Coastal Zone
☐ The proposed project is within the Coastal Zone (check one of the following boxes)
☐
A coastal development permit been applied for or obtained from the local Coastal
Commission district office or local government with a certified Local Coastal Plan, as
applicable
☐
The local Coastal Commission district office or local government with a certified Local
Coastal Plan (in consultation with the local Coastal Commission district office) has
determined that a coastal development permit is not required
8. Native American Consultation. For treatment projects that are within the scope of the CalVTP
PEIR, Assembly Bill (AB) 52 consultation for AB 52 compliance has been completed. The Board of
Forestry and Fire Protection conducted consultation pursuant to Public Resources Code Section
21080.3.1 during preparation of the PEIR. For treatment projects with impacts not within the scope
of the PEIR, pursuant to Public Resources Code Sections 21080.3.1, 21080.3.2, and 21082.3, project
partners preparing a new negative declaration, mitigated negative declaration, or EIR must notify
any California Native American tribe who has submitted written request for notification of a project
in the area of the treatment site. Upon written request for consultation by a tribe, the project partners
must begin consultation before the release of the environmental document and must follow the
requirements of the cited Public Resources Code sections.
The proposed project is within the scope of the PEIR; therefore, Assembly Bill (AB) 52 compliance
has been completed. Pursuant to CalVTP SPR CUL-2, the project proponent would be required to
obtain the latest Native American Heritage Commission (NAHC)-provided Native Americans
Contact List to coordinate with geographically associated Native American tribe(s), which would
identify locations of any known resources/areas with a high likelihood of finding archaeological or
historical resources and would require protection or avoidance.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
23
Environmental Determination
On the basis of this PSA and the substantial evidence supporting it:
☑ I find that all of the effects of the proposed project (a) have been covered in the CalVTP PEIR,
and (b) all applicable Standard Project Requirements and mitigation measures identified in the
CalVTP PEIR will be implemented. The proposed project is, therefore, WITHIN THE SCOPE of
the CalVTP PEIR. NO ADDITIONAL CEQA DOCUMENTATION is required.
☐ I find that the proposed project will have effects that were not covered in the CalVTP PEIR.
These effects are less than significant without any mitigation beyond what is already required
pursuant to the CalVTP PEIR. A NEGATIVE DECLARATION will be prepared.
☐ I find that the proposed project will have effects that were not covered in the CalVTP PEIR or
will have effects that are substantially more severe than those covered in the CalVTP PEIR.
Although these effects may be significant in the absence of additional mitigation beyond the
CalVTP PEIR’s measures, revisions to the proposed project or additional mitigation measures
have been agreed to by the project partners that would avoid or reduce the effects so that clearly
no significant effects would occur. A MITIGATED NEGATIVE DECLARATION will be
prepared.
☐ I find that the proposed project will have significant environmental effects that are (a) new and
were not covered in the CalVTP PEIR and/or (b) substantially more severe than those covered in
the CalVTP PEIR. Because one or more effects may be significant and cannot be clearly
mitigated to less than significant, an ENVIRONMENTAL IMPACT REPORT will be prepared.
Signature Date
Printed Name Title
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
24
4 PROJECT-SPECIFIC ANALYSIS
4.1 Aesthetics and Visual Resources
Impact in the PEIR Project-Specific Checklist
Environmental
Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact AES-1: Result in Short- Term, Substantial Degradation of a
Scenic Vista or Visual Character or Quality of Public Views, or Damage to Scenic Resources in a State
Scenic Highway from Treatment Activities
LTS Impact AES-1
pages 3.2-16 to 3.2-19
Yes AES-2/ AMM-3 NA LTS No Yes
Impact AES-2: Result in Long- Term,
Substantial Degradation of a Scenic Vista or Visual Character or Quality of Public Views, or
Damage to Scenic Resources in a State Scenic Highway from Wildland Urban Interface Fuel
Reduction, Ecological Restoration, or Shaded Fuel Break Treatment Types
LTS Impact AES-2
pages 3.2-20
to 3.2-22
Yes AES-1/ AMM-5
AES-3/ AMM-4
NA LTS No Yes
Impact AES-3: Result in Long- Term Substantial Degradation of a Scenic Vista or Visual
Character or Quality of Public Views, or Damage to Scenic Resources in a State Scenic Highway from
the Nonshaded Fuel Break Treatment Type
LTS Impact AES-3
pages 3.2-25 to 3.2-27
No -- -- -- -- --
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Aesthetic and Visual Resources Impacts: Would the treatment result in other impacts to aesthetics
and visual resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
25
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT AES-1
The proposed project area encompasses approximately 193.91 acres within five open space and
undeveloped park areas within an LRA in the Town of Los Gatos (see Figure 1). These open space and
park areas contain public hiking trails that pass through or in close proximity to some areas proposed for
treatment. There are also two state roadways that are adjacent to or near the treatment areas, including
State Route (SR)-17 and SR-85, as well as other local roadways (California Department of Transportation
[Caltrans] 2022). Due to the dispersed geographical range of the proposed project, there are numerous
public areas that provide views of the proposed treatment areas. There are two eligible scenic highways
located in the vicinity of the proposed project area, including a portion of SR-17, which extends from the
junction of SR-9 south to the City of Santa Cruz, and SR-9, which extends from the junction of SR-17
northwest towards the City of Monte Serreno. Past Monte Serreno, SR-9 becomes a designated scenic
highway (Caltrans 2022). SR-9 is approximately 0.5 mile from proposed treatment areas in Worcester
Park at its closest point. Proposed treatments would not be visible from SR-9 due to distance and
intervening topography. However, SR-17 runs approximately 200 feet west of Novitiate Park and may
provide public views of proposed vegetation treatments if they were to occur within its viewshed.
Because the speed limit on SR-17 is 55 miles per hour and SR-17 is lined with trees that shield views of
Novitiate Park, views from SR-17 would be fleeting and mostly shielded by existing vegetation.
The proposed project includes vegetation treatments over approximately 193.91 acres. The potential for
these treatment types to result in short-term degradation of visual character was evaluated in the PEIR.
Consistent with the PEIR, proposed vegetation treatments would result in the short-term presence of large
trucks and mechanical equipment that could contrast with the natural environment. However, visibility of
proposed treatments would be temporary, would not dominate or impede any views from scenic vistas or
scenic highways, and would not introduce a new feature to the landscape. The proposed project includes
AMMs that are integrated into the Open Space VMP to protect viewsheds. In addition, the PEIR includes
SPRs to reduce visibility of proposed treatments from public viewing areas. SPR AES-2 and AMM-3
would require equipment storage and staging areas to be located outside of viewsheds from public trails,
parks, recreation areas, and roadways as feasible to minimize visual impacts from the presence of
equipment. Manual and mechanical treatment activities would be temporary in nature and minimized
from public viewing areas. The potential for the proposed project to result in short-term substantial
degradation of the visual character of the project area is within the scope of the PEIR, because the
proposed treatment activities and types of equipment proposed for use are consistent with those analyzed
in the PEIR. This impact of the proposed project is consistent with the PEIR and would not constitute a
substantially more severe significant impact than what was covered in the PEIR.
IMPACT AES-2
The proposed project includes removing hazardous trees, thinning understory trees and brush, reducing
ladder fuels, and removing fuels along trails and fire roads throughout proposed treatment areas to reduce
potential wildfire fuels within the WUI. Consistent with the PEIR, proposed vegetation treatments would
not require all vegetation to be cleared and large healthy trees would remain at the discretion of the Town
and its contractors; therefore, vividness, intactness, and unity of views would remain high, and the
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
26
proposed project would not permanently affect views from a scenic vista or state scenic highway. The
proposed project includes AMMs that are integrated into the Open Space VMP to limit impacts to views.
SPRs AES-1 and AES-3 and AMM-4 and AMM-5 would be implemented, as feasible, to break up or
screen linear edges of a clearing, achieve a natural transitional appearance, and screen views from public
areas, as feasible. Therefore, proposed treatment activities would not result in adverse long-term impacts
related to aesthetic resources and project-specific impacts would be less than significant, which is
consistent with the level of impact examined in the PEIR.
IMPACT AES-3
Impact AES-3 does not apply because the proposed project does not include implementation of a non-
shaded fuelbreak.
NEW AESTHETIC AND VISUAL RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.2.1, Regulatory Setting, and Section 3.2.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to aesthetics present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the
same and, for the reasons described above, impacts of the proposed treatment project are consistent with
those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of
the CalVTP treatable landscape would not give rise to any new significant impact. Therefore, no new
impact related to aesthetics would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
27
4.2 Agriculture and Forestry Resources
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact AG-1: Directly
Result in the Loss of Forest Land or Conversion of Forest Land to a Non-Forest Use or Involve Other
Changes in the Existing Environment Which, Due to Their Location or Nature, Could Result in Conversion of Forest
Land to Non-Forest Use
LTS Impact AG-1
pages 3.3-7 to 3.3-8
Yes NA NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Agriculture and Forestry Resources Impacts: Would the treatment result in other impacts to
agriculture and forestry resources that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT AG-1
The project area includes 193.91 acres within five managed open space and undeveloped park areas in the
Town of Los Gatos within Santa Clara County. Treatment activities within the project area would only
modify the landscape to reduce wildfire risk through tree thinning and removal. Target trees would
include highly flammable invasive species and dying or declining trees. Native, healthy trees within the
project area would be retained and protected. Per Public Resources Code (PRC) Section 12220(g), forest
land is defined as land that can support 10% native tree cover of any species under natural conditions.
Vegetation management and maintenance standards, as discussed in Section 2.3.5, Vegetation
Management and Maintenance Standards and Areas, would be implemented to avoid impacts and retain
the integrity of forest and woodland within the proposed treatment area. The implementation of the
proposed treatment activities would continue to support more than 10% of native tree cover per PRC
Section 12220(g). Therefore, the proposed project would not directly result in the loss of forest land,
convert forest land to a non-forest use, or involve other changes in the existing environment that could
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
28
result in conversion of forest land to non-forest use. Project impacts would be less than significant,
consistent with the impacts analyzed in the PEIR.
NEW AGRICULTURE AND FORESTRY RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.3.1, Regulatory Setting, and Section 3.3.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to agriculture and forestry resources present in the
areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the impacts are the same and, for the reasons described above, impacts of the proposed
treatment project are consistent with those covered in the PEIR. No changed circumstances are present,
and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new
significant impact. Therefore, no new impact related to agriculture and forestry resources would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
29
4.3 Air Quality
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
and AMMs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact AQ-1: Generate
Emissions of Criteria Air Pollutants and Precursors During Treatment Activities that would exceed CAAQS
or NAAQS
SU Impact AQ-1
pages 3.4-26 to 3.4-32
Appendix AQ-1
Yes AQ-1
AQ-4/AMM-7
MM AQ-1
LTSM No Yes
Impact AQ-2: Expose People to Diesel Particulate Matter
Emissions and Related Health Risk
LTS Impact AQ-2
pages 3.4-33 to
3.4-34
Yes AQ-1
HAZ-1
NOI-4
NOI-5
AMM-6
MM AQ-1
LTS No Yes
Impact AQ-3: Expose People to Fugitive Dust
Emissions Containing Naturally Occurring Asbestos and Related Health Risk
LTS Impact AQ-3
pages
3.4-34 to 3.4-35
Yes AQ-4/ AMM-7
AQ-5
NA LTS No Yes
Impact AQ-4: Expose People to Toxic Air Contaminants Emitted by Prescribed Burns and Related Health Risk
PSU Impact AQ-4
pages 3.4-35 to 3.4-37
No -- -- -- -- --
Impact AQ-5: Expose People to Objectionable Odors from Diesel
Exhaust
LTS Impact AQ-5
pages 3.4-37 to
3.4-38
Yes AQ-1
HAZ-1
NOI-4
NOI-5
AMM-6
NA LTS No Yes
Impact AQ-6: Expose People to Objectionable
Odors from Smoke During Prescribed Burning
PSU Impact AQ-6
pages
3.4-36
No -- -- -- -- --
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Air Quality Impacts: Would the treatment result in other impacts to air quality that are not evaluated
in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
30
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT AQ-1
The proposed project area is under the authority of the Bay Area Air Quality Management District
(BAAQMD). It is located in the San Francisco Bay Area Air Basin, which is in state non-attainment for
ozone and particulate matter less than 10 and 2.5 microns in diameter (PM10 and PM2.5); and federal non-
attainment for ozone and PM10, and unclassifiable for PM2.5 (BAAQMD 2023). The use of heavy vehicles
and equipment during vegetation treatments would likely result in emissions of criteria pollutants (i.e.,
ozone, carbon monoxide [CO], nitrogen dioxide [NO2], sulfur dioxide [SO2], PM10, PM2.5, and lead) and
ozone precursor emissions (reactive organic gases [ROG] and nitrogen oxides [NOx]). Criteria air
pollutant and ozone precursor emissions have the potential to exceed BAAQMD emission thresholds and
contribute to the nonattainment status with respect to the National Ambient Air Quality Standards
(NAAQS) or California Ambient Air Quality Standards (CAAQS) in the Bay Area Air Basin. The
potential for emissions of criteria pollutants to exceed CAAQS or NAAQS thresholds was examined in
the PEIR.
Mechanical and Manual Treatments
Mechanical treatments would require the use of heavy machinery or equipment rather than hand or
manual equipment. Grading, mowing, disking, cutting, masticating, and grubbing are all examples of
mechanical treatments. The scope of the proposed project is consistent with the scope of the PEIR in
regard to crew sizes and equipment use. Each individual treatment area would be relatively small,
requiring between approximately one to three vehicles and a crew of less than 10 workers. The proposed
project would treat a maximum of 193.91 acres per year, which is much less than the geographical scope
(250,000 acres per year) evaluated in the CalVTP PEIR. There is potential for the proposed project to
generate ROG and NOx emissions from equipment and vehicle use and PM10 and PM2.5 emissions from
crew transport along unpaved roadways. AMM-7 includes dust control measures. In addition, the PEIR
includes SPRs to further reduce the potential for excessive emissions from proposed treatment activities.
SPR AQ-1 requires proposed project compliance with all applicable BAAQMD air quality requirements.
SPR AQ-4 would limit vehicle speeds on unpaved roads and require treatment crews to wet unpaved
roads if excessive dust is created during road use, that vehicles be cleaned prior to leaving treatment sites
to reduce the inadvertent transport of dust from unpaved areas onto paved roads, and the suspension of
ground-disturbing activities when they result in visible dust transport outside the boundary of treatment
areas. Implementation of SPRs AQ-1 and AQ-4 and AMM-7 would reduce potential criteria pollutant
emissions, including PM10 and PM2.5 emissions during proposed treatment activities. In addition, PEIR
MM AQ-1 would require the implementation of on-road vehicle and off-road equipment exhaust emission
reduction techniques during treatment activities to further reduce criteria air pollutant and ozone precursor
emissions from individual treatments. Due to the dispersed geographical scope of the proposed project,
there is potential for multiple treatments to occur within the project area at one time. However, due to the
small geographic scope of the project area and with implementation of AMMs, SPRs, and MMs, it is
unlikely that there will be an exceedance of established emissions thresholds. Overall, there is unlikely to
be a short-term increase in criteria air pollutants that could exceed NAAQS, CAAQS, and/or BAAQMD
thresholds and this impact would be less than significant. Even if the proposed project did exceed
NAAQS, CAAQS, and/or BAAQMD thresholds, this impact would be consistent with the PEIR.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
31
Prescribed Burns
The proposed project does not include prescribed burns. No impact related to prescribed burns would
occur.
Conclusion
Proposed project activities are not expected to temporarily exceed established NAAQS, CAAQS, and/or
BAAQMD thresholds and would be consistent with emission reduction strategies and air quality plans
adopted by the BAAQMD. Due to the relatively small geographical scope and the lack of prescribed
burns in the proposed project, the project is unlikely to result in a short-term increase in criteria air
pollutants that may exceed NAAQS, CAAQS, and/or BAAQMD thresholds. Therefore, impacts related to
the proposed project would be less than significant related to an increase in pollutant emissions from
proposed treatment activities. Even if the project did exceed standards, it would be consistent with the
evaluation and determination of the PEIR. No new or more severe significant impacts would occur as a
result of the proposed project.
IMPACT AQ-2
Proposed treatment areas encompass approximately 193.91 acres of undeveloped parks and open spaces
within the Town and would be located near numerous sensitive receptors. The PEIR evaluates the
potential for CalVTP vegetation management activities to expose sensitive receptors to substantial short-
and long-term diesel particulate matter (DPM) emissions in a manner that could increase cancer risk
greater than 10 in one million to a Hazard Index of 1.0 or greater. Consistent with the evaluation included
in the PEIR, the proposed project would require the use of heavy vehicles and equipment and crew
transportation, which would increase DPM emissions in the project area. However, proposed treatment
activities are not anticipated to expose sensitive receptors to substantial DPM emissions because
treatment activities would progress across treatment sites; therefore, DPM emissions generated by
treatment activities would not take place near any single sensitive receptor for an extended period of time.
In addition, treatment activities would be short term and intermittent and would not result in a new long-
term source of DPM emissions in the project area.
SPRs and MMs were included in the PEIR to further reduce the potential for public exposure to DPM
emissions during proposed activities. SPR HAZ-1 requires that all diesel- and gasoline-powered
equipment be properly maintained to comply with all federal and state emissions requirements, which
would prevent excessive emissions of DPM due to poorly functioning equipment. SPR NOI-4 requires
vegetation treatment activities and staging areas be located as far as possible from human receptors, and
SPR NOI-5 and AMM-6 restrict equipment idling time. SPR AQ-1 requires proposed project compliance
with all applicable BAAQMD air quality requirements. Since the proposed project is not anticipated to
expose people to substantial DPM emissions and implementation of SPRs would further reduce potential
exposure, further mitigation would not be necessary; however, PEIR MM AQ-1, which is required for
Impact AQ-1, would further reduce potential impacts through the implementation of on-road vehicle and
off-road equipment exhaust emission reduction techniques during treatment activities. Since proposed
treatment activities would be short term and intermittent and would not expose any sensitive receptors to
DPM for an extended period of time, proposed treatment activities would not expose any person to an
incremental increase in cancer risk associated with DPM greater than 10 in one million to a Hazard Index
of 1.0 or greater, and impacts would be less than significant. Implementation of SPRs HAZ-1, NOI-4,
NOI-5, and AQ-1; PEIR MM AQ-1; and AMM-6 would further reduce the potential for substantial
exposure to any sensitive receptor. Therefore, impacts would be less than significant, which is consistent
with the determination of the PEIR, and no new or more severe impacts would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
32
IMPACT AQ-3
According to the U.S. Geological Survey (USGS) and California Geological Survey (CGS) maps, there
are mapped ultramafic rock outcrops containing asbestos in the vicinity of the proposed treatment areas
(USGS 2011; CGS 2000; CGS 2011a; CGS 2011b). There is potential for naturally occurring asbestos
(NOA) to be present within or near these areas of ultramafic rock. The proposed project does not include
the demolition of any buildings or structures that may contain asbestos-containing material (ACM). The
PEIR evaluates the potential for vegetation treatment activities to generate dust emissions that may
expose people to NOA, if present within disturbance areas. AMM-7, included in Section 2, Project
Description (see Table 2), requires keeping speed limits to 15 miles per hour, using water trucks to
control dust, and removed track out to control dust. The PEIR includes SPRs to reduce fugitive dust
emissions that may contain NOA. Based on the potential for NOA to be present within the Open Space
Areas, SPRs AQ-4 and AQ-5 have been included for the proposed project. SPR AQ-4 requires treatment
crews to reduce the amount of dust generated by vehicle and equipment use on unpaved roads and SPR
AQ-5 requires the preparation and implementation of an Asbestos Dust Control Plan and/or avoidance of
ground disturbance in areas where NOA is likely to occur. With implementation of SPRs AQ-4 and AQ-5
and AMM-7, the proposed project would not expose people to fugitive dust emissions containing NOA.
Therefore, project-specific impacts would be less than significant, which is consistent with the
determination of the PEIR.
IMPACT AQ-4
Impact AQ-4 does not apply because the proposed project does not include implementation of prescribed
burns.
IMPACT AQ-5
As described in Impact AQ-2, the use of diesel-powered equipment has the potential to expose people to
objectionable odors from diesel exhaust. Consistent with the PEIR, diesel exhaust emissions from the
proposed project would be short term and intermittent, progress across treatment sites such that odors
from diesel exhaust would not be generated in a single location for an extended period, and dissipate
rapidly from the source. Therefore, the proposed project is not anticipated to expose people to odors from
diesel exhaust. Additionally, SPRs have been included to further reduce the potential for exposure to
substantial diesel exhaust emissions, including SPRs HAZ-1, NOI-4, NOI-5, and AQ-1 and AMM-6, as
described in Impact AQ-2. Therefore, project-specific impacts would be less than significant, which is
consistent with the determination of the PEIR. No new or more severe impacts would occur.
IMPACT AQ-6
Impact AQ-6 does not apply because the proposed project does not include the implementation of
prescribed burns.
NEW AIR QUALITY IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.4.1, Regulatory Setting, and Section 3.4.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to air quality present in the areas outside the treatable
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
33
landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the
same and, for the reasons described above, impacts of the proposed treatment project are consistent with
those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of
the CalVTP treatable landscape would not give rise to any new significant impact. Therefore, no new
impact related to air quality would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
34
4.4 Archaeological, Historical, and Tribal Cultural
Resources
Impact in the PEIR Project-Specific Checklist
Environmental
Impact Covered in
the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact CUL-1: Cause a Substantial Adverse Change in the Significance of Built
Historical Resources
LTS Impact CUL-1
pages 3.5-14 to 3.5-15
Yes CUL-1
CUL-7
CUL-8/ AMM-12
AMM-10
NA LTS No Yes
Impact CUL-2: Cause a Substantial Adverse Change in the
Significance of Unique Archaeological Resources or Subsurface Historical Resources
SU Impact CUL-2
pages 3-5.15 to 3.5-16
Yes CUL-1
CUL-2
CUL-3/
AMM-9
CUL-4/ AMM-10
CUL-5
CUL-8/
AMM-12
AMM-11
CUL-2 LTSM No Yes
Impact CUL-3: Cause a Substantial Adverse Change in the Significance of a Tribal Cultural Resource
LTS Impact CUL-3
page 3.5-17
Yes CUL-1
CUL-2
CUL-3/ AMM-9
CUL-4/ AMM-10
CUL-5
CUL-6/ AMM-11
CUL-8/ AMM-12
NA LTS No Yes
Impact CUL-4: Disturb Human Remains LTS Impact CUL-4
page 3.5-18
Yes AMM-11 NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Archaeological, Historical, and Tribal Cultural Resources Impacts: Would the treatment result in
other impacts to archaeological, historical, and tribal cultural resources that are not evaluated in the
CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
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Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT CUL-1
The proposed project includes vegetation treatments over approximately 193.91 acres within five open
space and undeveloped park areas. Consistent with the PEIR, proposed vegetation treatment activities
may occur in areas that contain built historical resources and could potentially result in damage to these
structures located adjacent to treatment areas. A California Historical Resources Information System
(CHRIS) search through the Northwest Information Center (NWIC) was performed for previously
recorded cultural resources within 0.25 mile of the proposed project area (NWIC 2020). Two historical
structures were recorded within 0.16 mile of Worcester Park and within 0.25 mile of Novitiate Park. No
historical resources were recorded within any of the treatment areas and all adjacent structures would be
avoided during treatment implementation.
The proposed project would implement AMM-9 through AMM-12, included in Section 2, Project
Description (see Table 2), during treatment activities in order to avoid impacts to built environment,
historical resources. In addition, SPRs CUL-1, CUL-7, and CUL-8, included in the PEIR, would be
implemented to avoid any substantial adverse change to any built historical resources. AMM-9 and
SPR CUL-1, which require that a recent records search for archaeological and historical resources, has
already been implemented. AMM-10 requires that a qualified archaeologist conduct a site-specific survey
of the treatment area. SPR CUL-7 and AMM-11 require the avoidance of known built historical resources
and the avoidance of built environment structures that have not yet been evaluated for historical
significance. SPR CUL-8 and AMM-12 require that workers be trained regarding protection of historical
resources and to stop work if any resources are found. Therefore, project-specific impacts related to built
environment historical resources would be less than significant, consistent with the PEIR, and would not
result in any new or more severe impacts.
IMPACT CUL-2
The proposed project includes vegetation treatments over approximately 193.91 acres within five open
space and undeveloped park areas. Consistent with the PEIR, the proposed project primarily includes
treatment types that either require no soil disturbance or very shallow soil disturbance. However, it is
possible unique archaeological or subsurface historical resources could be disturbed during treatment
activities, especially where mechanical treatments could result in churning the ground surface during
vegetation removal.
The proposed project would implement AMM-9 through AMM-12, included in Section 2, Project
Description (see Table 2), during treatment activities in order to ensure the avoidance and protection of
archaeological resources present within the proposed project area. In addition, SPRs CUL-1 through
CUL-5 and CUL-8, included in the PEIR, would be implemented to further minimize the risk of
damaging known or unknown subsurface archaeological and historical resources during treatment
activities. SPR CUL-1 and AMM-9 require that a recent records search for archaeological and historical
resources has already been completed. SPR CUL-2 requires coordination with geographically associated
Native American tribe(s), which would identify locations of any known resources/areas with a high
likelihood of finding archaeological or historical resources and would require protection or avoidance.
Los Gatos Open Space Vegetation Management Plan
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SPR CUL-3 and AMM-9 require pre-field research to become familiar with the area and potential
resources. SPR CUL-4 and AMM-10 require an archaeological survey of the treatment area to identify
archaeological resources. SPR CUL-5 requires working with the geographically affiliated tribe(s) to avoid
and protect any resources identified. SPR CUL-8 and AMM-12 require that workers be trained regarding
protection of historical resources and to stop work if any resources are found. In addition, AMM-11 and
PEIR MM CUL-2 would require the protection of inadvertently discovered unique archaeological and/or
subsurface historical resources by requiring all work stop, evaluation of the significance of the find, and
development of an appropriate course of action.
The scope of the PEIR considers this impact to be significant and unavoidable based on the large
geographical scope, which increases the likelihood for unknown resources to be present within treatment
areas, and the wide variety of resource types present throughout the state. However, the proposed project
only encompasses approximately 193.1 acres and would be conducted on a much smaller scale than what
is analyzed in the PEIR. AMMs, SPRs, and MMs would be implemented to ensure the protection of
archaeological or subsurface historical resources. Therefore, due to the small scale and low level of
ground disturbance that would be generated during project treatments, project-specific impacts would be
less than significant and would not result in any new or more severe impacts.
IMPACT CUL-3
The proposed project includes treatment activities that have the potential to impact tribal cultural
resources if present within or adjacent to treatment areas. The proposed project would implement AMM-9
through AMM-12, discussed above and included in Section 2, Project Description (see Table 2), during
treatment activities in order to avoid any substantial adverse change to tribal resources. In addition, SPRs
CUL-1 through CUL-5 and CUL-8, as described in Impact CUL-2 above, and SPR CUL-6 would be
implemented to avoid or minimize the potential to disturb cultural resources that may be present within
the project area. SPR CUL-6 requires consulting with the geographically affiliated tribes to avoid or
protect any identified tribal cultural resources. AMMs and SPRs would be implemented to avoid or
reduce the potential to disturb tribal cultural resources that may be present within proposed treatment
areas. Therefore, project-specific impacts would be less than significant and would not result in any new
or more severe impacts.
IMPACT CUL-4
Per the PEIR, prehistoric or historic-era marked or unmarked interments and cremated remains are
present throughout California. The proposed project includes ground-disturbing treatment activities such
as mechanical treatments that could potentially uncover previously unknown human remains. Consistent
with the PEIR, the proposed project would be subject to California Health and Safety Code (CHSC)
Sections 7050.5 and 7052 and PRC Section 5097, which identified the procedures for the treatment of
Native American human remains. Compliance with CHSC Sections 7050.5 and 7052 and PRC Section
5097 requires avoiding or minimizing disturbance of human remains, and following the appropriate
protocols if remains are unearthed. Therefore, project-specific impacts would be less than significant,
which is consistent with the PEIR. No new or more severe impacts would occur.
NEW ARCHAEOLOGICAL, HISTORICAL, AND TRIBAL CULTURAL RESOURCES
IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.5.1, Regulatory Setting, and Section 3.5.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
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the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to archaeological, historical, and tribal cultural
resources present in the areas outside the treatable landscape are essentially the same as those within the
treatable landscape; therefore, the impacts are the same and, for the reasons described above, impacts of
the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances
are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to
any new significant impact. Therefore, no new impact related to archaeological, historical, and tribal
cultural resources would occur.
Los Gatos Open Space Vegetation Management Plan
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4.5 Biological Resources
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact BIO-1:
Substantially Affect Special-Status Plant Species Either Directly or Through Habitat Modifications
LTSM Impact
BIO-1
pages 3.6-132 to 3.6-139
Yes BIO-2/
AMM-13
BIO-3/ AMM-15
BIO-7
BIO-9/
AMM-18
BIO-1a
BIO-1b
BIO-1c
LTSM No Yes
Impact BIO-2: Substantially Affect Special-Status Wildlife
Species Either Directly or Through Habitat Modifications
LTSM (all wildlife species
except bumble bees)
SU (bumble bees)
Impact BIO-2
pages
3.6-139 to 3.6-187
Yes BIO-2/ AMM-13
BIO-3/
AMM-15
BIO-4/ AMM-24
BIO-5/ AMM-16
BIO-10/ AMM-13
BIO-11/ AMM-20
BIO-12/
AMM-13
HAZ-5/ AMM-31
HAZ-6
HYD-1/
AMM-21
HYD-4/ AMM-1, AMM-30
BIO-2a
BIO-2b
BIO-3a
BIO-3b
BIO-3c
LTSM No Yes
Impact BIO-3: Substantially Affect Riparian Habitat or Other Sensitive Natural Community Through
Direct Loss or Degradation That Leads to Loss of Habitat Function
LTSM Impact BIO-3
pages 3.6-186 to 3.6-191
Yes BIO-2/ AMM-13
BIO-3/ AMM-15
BIO-4
BIO-5/ AMM-16
BIO-6/ AMM-19
BIO-9/
AMM-18
HYD-4/ AMM-1, AMM-30
AMM-17,
AMM-20, and
BIO-3a
BIO-3b
BIO-3c
BIO-4
LTSM No Yes
Los Gatos Open Space Vegetation Management Plan
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Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
AMM-24 through AMM-28
Impact BIO-4: Substantially Affect State or Federally Protected Wetlands
LTSM Impact BIO-4
pages 3.6-191 to
3.6-192
Yes BIO-1
HYD-1
HYD-3
HYD-4
AMM-21 through AMM-37
BIO-4 LTSM No Yes
Impact BIO-5: Interfere Substantially with Wildlife Movement Corridors or Impede Use of Nurseries
LTSM Impact BIO-5
pages 3.6-198 to 3.6-199
Yes BIO-1
BIO-4
BIO-5
BIO-10
BIO-11
BIO-12
HYD-1
HYD-4
AMM-21 through AMM-37
BIO-5
LTSM No Yes
Impact BIO-6: Substantially Reduce Habitat or Abundance of
Common Wildlife
LTS Impact BIO-6
pages
3.6-192 to 3.6-196
Yes BIO-1
BIO-2/ AMM-13
BIO-3/ AMM-15
BIO-4/ AMM-24
BIO-5
BIO-12/ AMM-13
AMM-20
AMM-33
NA LTS No Yes
Impact BIO-7: Conflict with Local Policies or Ordinances Protecting Biological Resources
LTS Impact BIO-7
pages 3.6-198 to 3.6-199
Yes BIO-1 through BIO-5
BIO-10 through
BIO-12
HYD-1
HYD-4
AD-3
AMM-13
through AMM-33
BIO-2a
BIO-2b
BIO-3a
BIO-3b
BIO-3c
BIO-4
BIO-5
LTSM No Yes
Impact BIO-8: Conflict with the Provisions of an NI Impact BIO-8 No -- -- -- -- --
Los Gatos Open Space Vegetation Management Plan
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Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Adopted Natural Community Conservation Plan,
Habitat Conservation Plan, or Other Approved Habitat Plan
pages 3.6-199 to 3.6-200
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Biological Resources Impacts: Would the treatment result in other impacts to biological resources
that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
The project area includes a total of approximately 193.91 acres within five Town-owned and managed
open space and undeveloped park areas, including two open space areas and three undeveloped parks
within the Town. The project area is comprised of five distinct locations, including Santa Rosa Open
Space, Heintz Open Space, La Rinconada Park, Novitiate Park, and Worcester Park. The Open Space
VMP Area is dominated primarily by urban land, hardwood woodland, and herbaceous and shrub cover.
Urban land is present throughout the Open Space VMP Area and concentrated mainly around roadways
and in gently sloping and flat areas. As the terrain steepens, urban development mostly consists of homes,
infrastructure, and developed parks surrounding open space and undeveloped park boundaries. Oak
woodland is present throughout the Open Space VMP Area but dominates in the foothills and canyons
along the southern Town boundary along with other hardwood woodland species, described in more detail
below. California oak woodland is a sensitive vegetation community. Herbaceous and shrub species are
interspersed in understories and canopy openings throughout the southern portion of the VMP Area.
Vegetation communities and individual vegetation species observed at each location in the VMP Area are
described in more detail in Section 2, Project Description. Additional details on aquatic resources and
special-status species in the Open Space VMP Area follow.
STREAMS AND WATER RESOURCES
The Town contains several creeks, ponds, and reservoirs. The natural hydrology of the area has been
altered over time due to urban development and flood control infrastructure. Waterways within the Town
include a mixture of perennial and ephemeral rivers and creeks, including the Guadalupe River and Los
Gatos, Ross, and Smith Creeks. Los Gatos and Smith Creeks flow south to north, the Guadalupe River
and Ross Creek flow southwest to northeast, and all drainages in the Open Space VMP Area enter San
Los Gatos Open Space Vegetation Management Plan
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Francisco Bay. The Vasona Reservoir is the largest open water habitat within the Town (Town of Los
Gatos 2008); however, the reservoir is not within the Open Space VMP Area. Los Gatos Creek is one of
the major creeks in the Open Space VMP Area, flowing south to north into and out of the Vasona
Reservoir. Santa Rosa Open Space, La Rinconada Park, and Novitiate Park are adjacent to and/or contain
ephemeral riparian features. Novitiate Park is bisected by Los Gatos Creek, and Santa Rosa Open Space
and La Rinconada Park both contain unnamed water features identified by the National Wetland
Inventory (NWI) as stream/river and lake/pond resources.
SPECIAL-STATUS SPECIES
In compliance with SPR BIO-1, SWCA biologists conducted a data review and reconnaissance-level
survey in June and July 2020 to identify and document sensitive biological resources within the treatment
areas and to assess potential habitat suitability for special-status plants and animals. SWCA biologists
documented site conditions throughout the proposed project area.
Special-Status Plant Species
The following special-status plant species have potential to occur or are known to occur within the Open
Space VMP Area and are described in more detail in Table 3.
Loma Prieta hoita (Hoita strobilina)
Most beautiful jewel flower (Streptanthus albidus)
Robust monardella (Monardella villosa ssp. villosa)
Western leatherwood (Dirca occidentalis)
Woodland woollythreads (Monolopia gracilens)
Special-Status Animal Species
The following special-status animal species have potential to occur or are known to occur within the Open
Space VMP Area and are described in more detail in Table 3:
Western pond turtle (Emys marmorata)
Santa Cruz black salamander (Aneides flavipunctatus niger)
Steelhead (Oncorhynchus mykiss irideus pop. 8)
California red-legged frog (Rana draytonii)
Foothill yellow-legged frog (Rana boylii)
Pallid bat (Antrozous pallidus)
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Table 3. Species with Potential to Occur in the Project Area
Species Name1 General Habitat Description2
Legal Status
Federal/State/
CRPR Status3,4
Rationale for Potential Occurrence
Special-Status Plant Species
Loma Prieta hoita
(Hoita strobilina)
Perennial herb endemic to California that occurs in chaparral, cismontane
woodland, and riparian woodland. Elevation: 1–95 meters. Blooming period: May–July.
1B.2 Potential to Occur: Suitable habitat exists in the Open Space VMP Area.
Six California Natural Diversity Database (CNDDB) occurrences have been recorded (2002, 2009, 2014, 2018) approximately 0.36 mile southwest of the nearest Open Space VMP location.
Most beautiful jewel flower
(Streptanthus albidus)
Annual herb endemic to California that occurs in chaparral, valley
grassland, and foothill woodland habitats. Elevation: 0–207 meters. Blooming period: April–September.
1B.2 Unlikely to Occur: Suitable habitat exists in the Open Space VMP Area
but is limited to the hills above Lexington Reservoir. Two CNDDB occurrences have been recorded (1995, 2001) approximately 0.3 mile southwest of the nearest Open Space
VMP location.
Robust monardella
(Monardella villosa ssp.
villosa)
Perennial herb endemic to California that occurs in chaparral and foothill woodland. Elevation: 0–240 meters.
Blooming period: June–August.
- Potential to Occur: Suitable habitat exists in the Open Space VMP Area. No CNDDB occurrences have been
recorded in the Open Space VMP Area; however, this species has been identified as known to occur in the
Town of Los Gatos 2040 General
Plan.
Western leatherwood
(Dirca occidentalis)
Shrub endemic to California that occurs in chaparral, foothill woodland, mixed evergreen forest, closed-cone pine forest, north
coastal coniferous forest, and wetland riparian habitat. Elevation: 25–425 meters. Blooming period: January–March (or April).
1B.2 Potential to Occur: Suitable habitat exists in the Open Space VMP Area. No CNDDB occurrences have been recorded in the Open Space VMP
Area; however, this species has been identified as known to occur in the Town’s General Plan.
Woodland woollythreads
(Monolopia gracilens)
Annual herb that occurs in broad-leaved upland forest openings, chaparral openings, cismontane woodland, and north coast coniferous forest openings.
Elevation: 100–1,200 meters. Blooming period: February–July.
1B.1 Potential to Occur: Suitable habitat exists in the Open Space VMP Area. Three CNDDB occurrences have been recorded (2018) approximately 0.25 mile south of the nearest Open
Space VMP location.
Special-Status Wildlife
Amphibians
California red-legged frog
(Rana draytonii)
Inhabits permanent and temporary
pools, streams, freshwater seeps, and marshes in lowlands and foothills occurring from sea level to 6,500 feet. Uses adjacent upland habitat for foraging and refuge.
Breeds during wet season from December to March. Lays between 300 and 4,000 eggs in a large cluster that are attached to plants near water surface. Eggs hatch after
about 4 weeks and undergo metamorphosis in 4 to 7 months.
FT/SSC/-- Potential to Occur: Suitable habitat
exists in the Open Space VMP Area. No CNDDB occurrences have been recorded in the Open Space VMP Area; however, this species has been identified as known to occur in the
Town’s General Plan and has been observed in Los Gatos Creek.
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Species Name1 General Habitat Description2 Legal Status Federal/State/
CRPR Status3,4
Rationale for Potential Occurrence
Foothill yellow-legged
frog
(Rana boylii)
Found in or near rocky streams and
rivers with open, sunny banks in forest, chaparral, and woodland habitats occurring from sea level to 6,000 feet. Breeds from April to early July in streams or rivers. Lays between 300 to 2,000 eggs in large cluster on downstream side of rocks in slow-moving water. Eggs hatch after 5 to 37 days and undergo metamorphosis in 3 to 4 months.
--/SSC/-- Potential to Occur: Suitable habitat
exists in the Open Space VMP Area. No CNDDB occurrences have been recorded in the Open Space VMP Area; however, this species has been identified as known to occur in the Town’s General Plan.
Santa Cruz black salamander
(Aneides flavipunctatus
niger)
Occurs in mixed deciduous woodland, coniferous forest, and coastal grasslands. Usually found under rocks, near streams, in talus,
under damp logs, and in soils along wet streams. Terrestrial species that forage during wet nights and stay underground during dry weather. Breeds between July and August
laying between 8 and 25 eggs below ground. May remain streamside year-round.
--/SSC/-- Unlikely to Occur: Three CNDDB occurrences (1931, 1973, 1985) have been recorded within 1 mile of the Open Space VMP Area, with no new
occurrences recorded. The closest recorded CNDDB occurrence is approximately 0.86 mile south of the nearest Open Space VMP Area along the Lexington Reservoir. The parcels
separating the occurrence from the Open Space VMP Area are disked and contain steep terrain.
Fish
Steelhead – Central
California Coast Distinct Population Segment (DPS)
(Oncorhynchus mykiss
irideus)
Occurs in clear, cool water with
abundant in-stream cover, well-vegetated stream margins, relatively stable water flow, and 1:1 pool-to-riffle ratio. Requires cool, deep pools with overhead cover to protect from
predators.
FT/--/-- Potential to Occur: The closest
recorded CNDDB occurrence (2017) is approximately 0.1 mile from the nearest roadway. This species has recorded occurrences in Guadalupe Creek, which runs adjacent to
Shannon and Hicks Roads, and Los Gatos Creek near Vasona Reservoir, which runs alongside the Santa Cruz Highway adjacent to Novitiate Park. Supporting tributaries include
Alamitos, Hicks, and Pheasant Creeks.
Mammals
Pallid bat
(Antrozous pallidus)
Occurs in grasslands, shrublands, woodlands, and forests in semi-arid
and arid landscapes. Most common in open, dry habitats with rocky outcroppings for roosting. Day roosts in caves, crevices, mines, and hollow trees. Night roosts in open sites such
as open buildings. Forages at ground level with open vegetation. Breeds from October to February with litters between one and three.
--/SSC/-- Potential to Occur: The closest recorded CNDDB occurrence (2004 is approximately 0.5 mile from the nearest Open Space VMP Area at Santa Rosa Open Space. Suitable habitat occurs on-site. One CNDDB occurrence (2004) was recorded from
a nearby roosting site in a barn, which has since been developed and the species removed. Suitable habitat occurs in the Open Space VMP Area, and it is possible that this species
could roost and forage within open space areas.
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Species Name1 General Habitat Description2 Legal Status Federal/State/
CRPR Status3,4
Rationale for Potential Occurrence
Reptiles
Western pond turtle
(Emys marmorata)
Occurs in permanent and intermittent rivers, creeks, small lakes or ponds,
marshes, irrigation ditches, and reservoirs. Basks on land, logs, branches, or boulders in and around water. Can migrate more than 0.5 mile. May return to same site each year during overwintering period. Breeds from April to May but can be year-round. Leave aquatic habitat to travel upland to nests and lay eggs. Nests in sandy banks near water or
in fields with sunny openings within few hundred feet from water. Forages and feeds in aquatic habitats only.
--/SSC/-- Potential to Occur: The closest recorded CNDDB occurrence (2012 is
approximately 0.5 mile from the nearest priority roadway and 1.25 miles from La Rinconada Park. Four CNDDB occurrences (1998, 2001) are recorded near the Vasona Reservoir
and County Park. Suitable habitat exists near La Rinconada Park at the La Rinconada Country Club in the existing ponds, but the reservoir is separated by two major roadways.
¹ List of plant species based on California Native Plant Society (CNPS) and CNDDB results from searches of Los Gatos, California USGS 7.5-minute quadrangle and the Town of Los Gatos 2040 General Plan. List of animal species based on CNDDB searches of the Los Gatos, California USGS 7.5-minute quadrangle and Town’s General Plan.
2 Listing status based on California Department of Fish and Wildlife (CDFW) CNDDB State & Federally Listed Endangered & Threatened Animals of California List (CDFW 2023). Habitat associations and blooming periods based on the Jepson Online Interchange for California Floristics (Jepson 2020). Other sources include CalFish (2020), CAL Herps (2020), Center for Biological Diversity (CBD 2020), Calflora (2020), and CNPS (2020).
3 Listing status based on CNDDB and CNPS data (queried in July 2020). Status Codes: -- = no status, FT = Federally Listed Threatened, SSC = California Species of Special Concern.
4 California Rare Plant Ranking: 1B = Plants rare, threatened, or endangered in California and elsewhere CRPR Threat Ranks: 0.1 = Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat); 0.2 = Moderately threatened in California (20-80% of occurrences threatened / moderate degree and immediacy of threat) Potential for Occurrence Ratings: Unlikely to Occur. The species is not likely to occur in the VMP Open Space area based on the following considerations: lack of suitable habitat and features that are required to satisfy the life history requirements of the species or presence of invasive species that inhibit survival or occupation. Potential to Occur. There is a possibility that the species can be found in the VMP area based on the following conditions: the VMP Open Space area falls within the range of the species, suitable habitat is present, but no records of sighting are located within or near (2 miles) the VMP Area, or the records are old and unreliable, and it is undetermined whether the habitat is currently occupied.
IMPACT BIO-1
Proposed treatment and maintenance activities could result in direct or indirect impacts to special-status
plant species with suitable habitat within the treatment area. Based on a desktop-level review, there is
potential for five special-status plant species to occur in the Open Space VMP Area. These species
include Loma Prieta hoita, most beautiful jewel flower, robust monardella, western leatherwood, and
woodland woollythreads (California Department of Fish and Wildlife [CDFW] 2022). The proposed
project will implement manual and mechanical treatments, grazing or prescribed herbivory, and chemical
treatments which, per the PEIR, have the potential to impact special-status plant species that may be
present within the project area.
To minimize and/or avoid impacts to special-status plant species, AMM-1, AMM-13, AMM-15,
AMM-18, and AMM-33, included in Section 2, Project Description (see Table 2), and SPRs BIO-2,
BIO-3, BIO-7, and BIO-9, included in the PEIR, would be implemented to reduce potential impacts to
special-status plant species or their habitats due to treatment activities. AMM-13, AMM-15, and SPR
BIO-7 require surveys for special-status plants be conducted during the appropriate blooming period if
they have potential to occur in a proposed treatment area. AMM-13 and SPR BIO-2 require biological
resource training for workers to inform them of the presence of special-status plants and the mitigation
measures, work practices, and laws and regulations that protect these resources. AMM-1 and SPR BIO-3
require project-specific surveys to identify and map the limits of sensitive natural communities and other
sensitive habitats. AMM-18 and SPR BIO-9 require BMPs be implemented to prevent the spread of
invasive plants and noxious weeds that could have indirect adverse effects on special-status plants
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45
through competition for resources and habitat degradation. In addition to the SPRs, PEIR MMs BIO-1a
through BIO-1c would be implemented as needed to further reduce potentially significant impacts to
special-status plant species. If special-status plants are present within the project area, MMs BIO-1a and
BIO-1b would require disturbance buffers of a minimum of 50 feet around these species. This area would
be marked using high-visibility flagging, stakes, or clear, existing landscape demarcations such as the
edge of a roadway. If implementation of MMs BIO-1a and BIO-1b is not possible due to site limitations,
MM BIO-1c would require the preparation and implementation of a Compensatory Mitigation Plan that
identifies the significant impacts and implementation strategy to mitigate for loss of special-status plants.
The potential for treatment activities to result in adverse effects on special-status plants was examined in
the PEIR. This impact on special-status plants is within the scope of the PEIR because the treatment
activities and intensity of disturbance from implementing treatment activities are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP
treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within
the boundary of the treatment area, general habitat characteristics are essentially the same within and
outside the treatable landscape (e.g., no resource is affected outside the treatable landscape that would not
also be similarly affected within the treatable landscape); therefore, the potential impact on special-status
plants is also the same, as described above. Therefore, no new or severe impacts would occur, and
impacts related to project activities would be less than significant with the implementation of appropriate
AMMs, SPRs, and PEIR MMs BIO-1a through BIO-1c, if necessary.
IMPACT BIO-2
The proposed project includes treatment and maintenance activities that could result in direct or indirect
impacts to special-status animals with suitable habitat within the treatment area, as described below.
Special-Status Amphibians, Fish, and Reptiles
There is potential for California red-legged frog, foothill yellow-legged frog, Santa Cruz black
salamander, Central California Coast steelhead Distinct Population Segment (DPS) pop. 8, and western
pond turtle to occur within the proposed project area. Per the PEIR, treatment activities, including manual
and mechanical treatments, prescribed herbivory, and herbicide treatment, could affect special-status
amphibians and reptiles through habitat modification. AMM-1, AMM-13 through AMM-15, AMM-20,
and AMM-24, included in Section 2, Project Description (see Table 2), would be implemented to avoid
impacts to special-status amphibians and reptiles or their habitat. In addition, SPRs BIO-2 through BIO-5,
BIO-10, BIO-11, HAZ-5, HAZ-6, HYD-1, and HYD-4, included in the PEIR, would be implemented to
further minimize impacts to special-status amphibians and reptiles. SPR BIO-1 requires a data review and
reconnaissance surveys to identify habitat for special-status species and has already been implemented.
AMM-13 and SPR BIO-2 requires biological resources training for workers by a qualified biologist to
inform them of the presence of special-status wildlife species and the mitigation measures, work
practices, and laws and regulations that protect these resources. AMM-15, AMM-16, AMM-24, and SPRs
BIO-3 through BIO-5 reduce potential impacts to special-status species through avoidance of their
habitat. AMM-16 and SPR BIO-3 require project-specific surveys to identify and map the limits of
sensitive natural communities and other sensitive habitats. AMM-24 and SPR BIO-4 require treatments to
be designed to avoid loss or degradation of riparian habitat functions and values. AMM-16 and SPR
BIO-5 require treatments to avoid environmental effects of type conversion and maintain habitat function
in chaparral and coastal sage scrub habitats. AMM-15 and SPR BIO-10 require surveys for special-status
wildlife and nursery sites. AMM-20 and SPR BIO-11 require the installation of wildlife-friendly fencing
for prescribed herbivory and the establishment of exclusion zones. AMM-31 and SPR HAZ-5 require the
preparation of a Spill Prevention and Response Plan and that a spill kit be kept and maintained on-site.
AMM-21 and SPR HYD-1 require the proposed project to comply with all state and regional water
quality regulations, including conditions of waste discharge requirement waivers that are applicable to
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fuel reduction and fire prevention activities. AMM-1 and SPR HYD-4 require identification and
protection of protected resource areas. AMM-30 and SPR HYD-4 require equipment to be fueled and
serviced outside of protected resource areas and wet areas that may provide habitat for special-status
amphibians, fish, and reptiles. In addition, PEIR MMs BIO-2a and BIO-2b, BIO-3a through BIO-3c, and
BIO-4, included in the PEIR, would be implemented, as needed. PEIR MMs BIO-2a and BIO-2b require
the avoidance of special-status wildlife species identified as occurring within the project area. PEIR MM
BIO-3a would reduce potentially significant impacts on sensitive natural communities and oak woodland
habitat which may provide habitat for these species by requiring activities be designed to avoid loss of
sensitive natural communities, to the extent feasible. If avoidance of sensitive natural communities is not
feasible, PEIR MMs BIO-3b and BIO-3c would require compensation for unavoidable impacts. In
addition, PEIR MM BIO-4 would reduce potentially significant impacts on federally and state-protected
wetlands that may provide habitat to identified wildlife species by requiring the delineation and avoidance
of any wetlands identified within the project area. With the implementation of identified SPRs, AMMs,
and MMs, project-specific impacts would be less than significant.
Special-Status Bats
There is potential for pallid bat to occur within the proposed project area. Per the PEIR, treatment
activities, including manual and mechanical treatments and herbicide application, conducted in suitable
habitat for bats or during the bat maternity season (April 1–August 31) could result in the loss of young or
abandonment of roosts from auditory and visual disturbances (e.g., heavy equipment, vehicles, chainsaws,
etc.). Suitable habitat for special-status bats is present within the proposed project area.
AMM-13 through AMM-15 and AMM-24, included in Section 2, Project Description (see Table 2), and
described above would be implemented to avoid impacts to special-status and roosting bats. In addition,
SPRs BIO-2 through BIO-5, BIO-10, HAZ-5, and HYD-4 would also be implemented to avoid impacts to
special-status bats. PEIR MMs BIO-2a and BIO-2b would also be implemented, as needed. With the
implementation of AMMs, SPRs, and MMs, project-specific impacts would be less than significant.
Special-Status, Nesting, and Migratory Birds
No special-status bird species were determined to have potential to occur within the proposed project
area. However, the presence of nesting and migratory birds is anticipated to occur. Per the PEIR,
treatment activities conducted during the nesting bird season (February 1–August 31) could result in the
loss of active nests or disturbance of nests from auditory and visual disturbances (e.g., heavy equipment,
vehicles, chainsaws, etc.). In the event that special-status or nesting birds are discovered within the
treatment area, a qualified biologist will establish suitable buffers, depending on the species, around nests.
Nests would be monitored, and buffers would be maintained until the chicks have fledged as determined
by a qualified biologist. AMM-13 through AMM-15 and AMM-24, included in Section 2, Project
Description (see Table 2), and described above, as well as SPR BIO-10, which protects habitat and
nursery sites, and SPR BIO-12, which protects common nesting birds and raptors, would also be
implemented. Following implementation of AMMs and SPRs, project-specific impacts would be less than
significant.
Conclusion
The potential for treatment activities to result in adverse effects on special-status wildlife was examined
in the PEIR. This impact on special-status wildlife is within the scope of the PEIR because the treatment
activities and intensity of disturbance due to implementing treatment activities are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP
treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within
the boundary of the treatment area, general habitat characteristics are essentially the same within and
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outside the treatable landscape (e.g., no resource is affected outside the treatable landscape that would not
also be similarly affected within the treatable landscape); therefore, the potential impact on special-status
wildlife is also the same, as described above. Therefore, no new or severe impacts would occur, and
impacts related to project activities would be less than significant with the implementation of appropriate
AMMs, SPRs, and PEIR MMs BIO-2a and BIO-2b, BIO-3a through BIO-3c, and BIO-4, if necessary.
IMPACT BIO-3
Riparian and other sensitive natural communities are present within the proposed project area. Per the
PEIR, vegetation treatment activities could result in the loss or degradation of sensitive habitats, including
designated sensitive natural communities, riparian habitats, and oak woodlands. Data review and
reconnaissance-level surveys of the treatment areas and associated biological resources were conducted in
compliance with SPR BIO-1. Sensitive natural communities with potential to occur within the proposed
treatment areas were compiled through searches conducted through a California Natural Diversity
Database (CNDDB) nine-quadrangle search (CDFW 2022) and cross referenced against Table 3.6-22
(pages 3.6-83–3.6-85), in Volume II of the PEIR, for sensitive natural communities that could occur in the
Central California Coast ecoregion. Based on this information, sensitive natural communities with
potential to occur in the California Wildfire Habitat Relationship habitat types within the treatment area
include oak woodland, chaparral, and riparian woodland. The presence of these habitat types was verified
during the reconnaissance-level surveys. Within designated sensitive natural communities, vegetation
treatment standards, included in Section 2, Project Description, have been established to reduce impacts
to these communities.
Riparian habitat is present within the proposed treatment area. Three of the treatment areas—Santa Rosa
Open Space, La Rinconada Park, and Novitiate Park—are adjacent to and/or contain ephemeral riparian
features. Novitiate Park is bisected by Los Gatos Creek and Santa Rosa Open Space and La Rinconada
Park both contain unnamed water features identified by the NWI as stream/river and lake/pond resources.
SPR BIO-3 requires site-specific surveys to identify and map the limits of sensitive natural communities
and other sensitive habitats using standard field protocols. No ground disturbance or grazing would be
allowed in these buffer areas. In addition, prescribed burning is not proposed as a treatment method and
no chemical treatments would be permitted adjacent to stream and water resources. The use of herbicides
in riparian areas would be limited to those approved in the PEIR, as discussed in Section 4.9 Hazardous
Materials, Public Health, and Safety, under Impact HAZ-2.
AMMs included in Section 2, Project Description (see Table 2), will be implemented to avoid impacts
from treatment activities to riparian habitat and other sensitive natural communities. SPRs BIO-2 through
BIO-6, BIO-8, BIO-9, and HYD-4, from the PEIR, will be implemented to reduce potential direct and
indirect impacts to riparian habitat and sensitive natural communities. SPR BIO-2 requires biological
resource training for workers so that they can identify and avoid sensitive natural communities and
habitats. AMM-1, AMM-13, AMM-15, and SPR BIO-3 require site-specific surveys to identify and map
the limits of sensitive natural communities and other sensitive habitats using standard field protocols.
AMM-17, AMM-20, AMM-24 through AMM-28, and SPR BIO-4 require treatments be designed to
avoid loss or degradation of riparian habitat functions and values. AMM-16 and SPR BIO-5 require
treatments be designed to avoid environmental effects of type conversion of chaparral habitats. AMM-19
and SPR BIO-6 require BMPs be implemented to prevent the spread of plant pathogens. AMM-18 and
SPR BIO-9 require BMPs be implemented to prevent the spread of invasive plants and noxious weeds
that could degrade the quality of sensitive habitats and sensitive natural communities. SPR HYD-4
requires identification of environmentally sensitive areas, such as aquatic resources.
In addition, implementation of PEIR MM BIO-3a and BIO-4 would reduce potentially significant impacts
by requiring treatments to be designed to avoid loss of sensitive natural communities and the delineation
of wetlands and waters as well as the establishment of disturbance buffers to avoid impacts to state and/or
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federally protected wetlands. If impacts to sensitive natural communities are unavoidable, PEIR MMs
BIO-3b and BIO-3c, which require compensation for loss of natural communities, oak woodlands, and
unavoidable loos of riparian habitat, would be implemented. However, no unavoidable impacts are
anticipated.
The potential for treatment activities to result in adverse effects on riparian habitat or other sensitive
natural communities was examined in the PEIR. This impact on riparian habitat or other sensitive natural
communities is within the scope of the PEIR because the treatment activities and intensity of disturbance
as a result of implementing treatment activities are consistent with those analyzed in the PEIR. The
inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes
a change to the geographic extent presented in the PEIR. However, within the boundary of the treatment
area, general habitat characteristics are essentially the same within and outside the treatable landscape
(e.g., no resource is affected outside the treatable landscape that would not also be similarly affected
within the treatable landscape); therefore, the potential impact on riparian habitat or other sensitive
natural communities is also the same, as described above. Therefore, no new or severe impacts would
occur, and impacts related to project activities would be less than significant with the implementation of
appropriate AMMs, SPRs, and PEIR MMs BIO-3a through BIO-3c and BIO-4, if necessary.
IMPACT BIO-4
The U.S. Fish and Wildlife Service (USFWS) NWI database identifies multiple features within the project
area (USFWS 2022). The Town contains several creeks, ponds, and reservoirs; however, the natural
hydrology of the area has been altered over time due to urban development and flood control
infrastructure. Waterways within the Town include a mixture of perennial and ephemeral rivers and
creeks, including the Guadalupe River and Los Gatos, Ross, and Smith Creeks. Santa Rosa Open Space,
La Rinconada Park, and Novitiate Park are adjacent to and/or contain ephemeral riparian features.
Novitiate Park is bisected by Los Gatos Creek and Santa Rosa Open Space and La Rinconada Park both
contain unnamed water features identified by NWI as stream/river and lake/pond resources. No NWI
waters or wetlands have been mapped within Heintz Open Space and Worcester Park. The presence or
absence of waters and wetlands was verified in the field and confirmed NWI features. Treatment activities
may occur in riparian areas; however, grazing or prescribed herbivory and chemical treatments will be
regulated in riparian areas consistent with the PEIR.
AMM-21 through AMM-37, included in Section 2, Project Description (see Table 2), will be
implemented to avoid impacts from treatment activities to aquatic resources and riparian areas and reduce
the potential for erosion or hazardous spills in sensitive habitat areas. SPRs BIO-1 and HYD-1, HYD-3,
and HYD-4, from the PEIR, will be implemented to identify potential resources on-site and protect water
quality. In addition, implementation of PEIR MM BIO-4 would reduce potentially significant impacts by
requiring the delineation of wetlands and waters as well as the establishment of disturbance buffers to
avoid impacts to federally and/or state-protected wetlands.
The potential for treatment activities to result in adverse effects on federally or state-protected wetlands
was examined in the PEIR. This impact on protected wetlands is within the scope of the PEIR because the
treatment activities and intensity of disturbance as a result of implementing treatment activities are
consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is
outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the
PEIR. However, within the boundary of the treatment area, general habitat characteristics are essentially
the same within and outside the treatable landscape (e.g., no resource is affected outside the treatable
landscape that would not also be similarly affected within the treatable landscape); therefore, the potential
impact on federally and state-protected wetlands is also the same, as described above. Therefore, no new
or severe impacts would occur, and impacts related to project activities would be less than significant
with the implementation of appropriate AMMs, SPRs, and PEIR MM BIO-4.
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IMPACT BIO-5
The project area consists of five distinct undeveloped parks and open space areas within the Town with
varying degrees of wildlife connectivity. La Rinconada and Worcester Parks are located in dense urban
areas surrounded primarily by residential uses. Santa Rosa and Heintz Open Space Areas and Novitiate
Park have connectivity to adjacent open space areas and likely experience greater use from terrestrial
species. The PEIR recognizes that treatment activities, including those that generate noise, temporary
fencing for prescribed herbivory, and other disturbances, may cause temporary changes to wildlife
movement and potentially disrupt nursery sites. In addition, treatment activities that remove cover and
impact habitat structures could result in long-term effects that may result in habitat loss or degradation.
However, no known wildlife nursery sites were identified during the implementation of SPR BIO-1.
Implementation of AMM-21 through AMM-37, included in Section 2, Project Description (see Table 2),
will reduce impacts to wildlife movement corridors and nurseries by avoiding work in sensitive habitat
areas. Additionally, implementing vegetation management standards included in Section 2, Project
Description, ensures vegetation retention for wildlife. SPRs HYD-1, HYD-4, BIO-1, BIO-4, BIO-5, and
BIO-10 through BIO-12 will be implemented to reduce potential impacts to aquatic and riparian habitat;
see Impacts BIO-1 through BIO-4 for detailed descriptions of these SPRs and AMMs. Wildlife nurseries
could be impacted if the habitats or areas where these nurseries occur are in habitats that are not covered
in the SPRs. If nursery sites are identified in areas not included in the SPRs, the PEIR requires that PEIR
MM BIO-5 be implemented to retain nursery habitat and implement buffers to avoid nursery sites.
Nursery sites, if present, should be identified through the implementation of SPR BIO-10.
The potential for treatment activities to result in adverse effects on wildlife movement corridors and the
impeded use of nurseries was examined in the PEIR. This impact on wildlife movement and nurseries is
within the scope of the PEIR because the treatment activities and intensity of disturbance as a result of
implementing treatment activities are consistent with those analyzed in the PEIR. The inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the treatment area, general
habitat characteristics are essentially the same within and outside the treatable landscape (e.g., no
resource is affected outside the treatable landscape that would not also be similarly affected within the
treatable landscape); therefore, the potential impact on wildlife movement corridors and nurseries is also
the same, as described above. Therefore, no new or severe impacts would occur, and impacts related to
project activities would be less than significant with the implementation of appropriate AMMs, SPRs, and
PEIR MM BIO-5, if necessary.
IMPACT BIO-6
The proposed project would include treatment methods that could result in the reduction of habitat or
abundance of common wildlife, including nesting birds, due to the presence of suitable habitat throughout
the project area. Proposed treatment activities conducted during the nesting bird season could result in the
loss or disturbance of active nests due to noise impacts and could potentially result in abandonment and
loss of chicks.
Treatment activities would include the removal of vegetation, dead trees, and woody debris to reduce fuel
loads and fire risk within the Town. However, focused nesting bird surveys would be conducted prior to
the implementation of treatment activities in accordance with the AMMs and SPRs. AMM-13, included
in Section 2, Project Description (see Table 2), would provide protection of nesting birds in congruence
with the Migratory Bird Treaty Act. AMM-13 through AMM-15 require a qualified biologist to conduct
surveys for special-status species, to conduct environmental awareness training for crew members, and
establish protocols for special-status species encounters. AMM-24 requires that treatments in riparian
habitat be designed to retain or improve habitat functions. Additionally, AMM-20 and AMM-33 also
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provide exclusion areas and treatment standards for sensitive habitat areas to protect long-term habitat for
wildlife.
In addition to the AMMs above which provide protection for wildlife and their habitat, and provide
exclusion areas, SPRs BIO-1 through BIO-5 and BIO-12 would be implemented to reduce impacts to less
than significant. SPRs BIO-1 through BIO-5 limit the loss or degradation of high-quality breeding
habitats for special-status wildlife that would also benefit common species and protect sensitive natural
communities, including wetland and riparian habitat. SPR BIO-12 provides protection for common
nesting birds and raptors, if treatment activities need to occur during the nesting season, by requiring pre-
treatment nesting bird surveys and implementation of feasible impact avoidance strategies, including
protective buffers, treatment modifications, and raptor nest monitoring. Overall, proposed treatments are
occurring within small portions of species’ overall habitat range and would not substantially reduce the
overall abundance of any common wildlife.
The potential for treatment activities to result in adverse effects on the reduction of habitat or abundance
of common wildlife was examined in the PEIR. This impact is within the scope of the PEIR because the
treatment activities and intensity of disturbance as a result of implementing treatment activities are
consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is
outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the
PEIR. However, within the boundary of the treatment area, general habitat characteristics are essentially
the same within and outside the treatable landscape (e.g., no resource is affected outside the treatable
landscape that would not also be similarly affected within the treatable landscape); therefore, the potential
impact on common wildlife, including nesting birds, is also the same, as described above. Therefore, no
new or severe impacts would occur, and impacts related to project activities would be less than significant
with the implementation of appropriate AMMs and SPRs.
IMPACT BIO-7
The proposed project is compliant with the Town of Los Gatos 2040 General Plan Open Space, Parks,
and Recreation Element (Element 7) and Environment and Sustainability Element (Element 8), which
require the protection of biological and water resources, including special-status species, sensitive habitat
communities, and aquatic resources. AMM-13 through AMM-33, discussed in Impacts BIO-1 through
BIO-6, would be implemented to protect and reduce impacts to special-status species, sensitive habitat
communities, and aquatic resources. SPR AD-3 would be implemented to ensure consistency with local
plans, policies, and ordinances, as applicable to the proposed project. In addition, SPR AD-3, which
requires that the project proponent design and implement the treatment in a manner that is consistent with
applicable local plans, policies, and ordinances to the applicable extent, would be implemented to provide
additional protection for special-status species, sensitive biological habitats, and aquatic resources,
consistent with the Town’s General Plan. Further, SPRs BIO-1 through BIO-12, HYD-1, HYD-4, and
HAZ-5 and PEIR MMs BIO-2a through BIO-2b, BIO-3a through BIO-3c, BIO-4, and BIO-5, identified
in Impacts BIO-1 through BIO-6, would be implemented to further protect special-status species, riparian
areas, and water resources, which is consistent with the Town’s General Plan. With implementation of
AMMs, SPRs, and MMs, project-specific impacts would be less than significant, which is consistent with
the determination of the PEIR.
The potential for treatment activities to comply with local policies or ordinances protecting biological
resources was examined in the PEIR. This impact on biological resources is within the scope of the PEIR
because the treatment activities and intensity of disturbance as a result of implementing treatment
activities are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment
area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent
presented in the PEIR. However, within the boundary of the treatment area, general habitat characteristics
are essentially the same within and outside the treatable landscape (e.g., no resource is affected outside
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the treatable landscape that would not also be similarly affected within the treatable landscape); therefore,
the potential impact on biological resources from conflicts with local policies or ordinances is also the
same, as described above. Therefore, no new or severe impacts would occur, and impacts related to
project activities would be less than significant with the implementation of appropriate SPRs.
IMPACT BIO-8
The implementation of the proposed project and treatment activities would not conflict with adopted
habitat conservation plans (HCPs) or natural community conservation plans (NCCPs) because the
treatment area is not within an adopted HCP or NCCP. Therefore, project-specific impacts would be less
than significant and would not result in any new or more severe impacts.
NEW BIOLOGICAL RESOURCES IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.6.1, Regulatory Setting, and Section 3.6.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to biological resources present in the areas outside the
treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts
are the same and, for the reasons described above, impacts of the proposed treatment project are
consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to biological resources would occur.
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4.6 Geology, Soils, Paleontology, and Mineral Resources
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact GEO-1: Result in
Substantial Erosion or Loss of Topsoil
LTS Impact
GEO-1
pages 3.7-27 to 3.7-30
Yes GEO-1/
AMM-34
GEO-2/ AMM-36
GEO-3
GEO-4
GEO-5
GEO-7/ AMM-37
GEO-8/ AMM-35
AD-3
HYD-4
AQ-4
NA LTS No Yes
Impact GEO-2: Increase
Risk of Landslide
LTS Impact
GEO-2
pages 3.7-30 to 3.7-31
Yes GEO-3
GEO-4
GEO-7/ AMM-37
GEO-8/ AMM-35
NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Geology, Soils, Paleontology, and Mineral Resources Impacts: Would the treatment result in other
impacts to geology, soils, paleontology, and mineral resources that are not evaluated in the CalVTP
PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT GEO-1
The proposed project includes grazing or prescribed herbivory, mechanical, manual, and herbicide
treatments over 193.91 acres in the Town of Los Gatos within Santa Clara County. Treatment activities
would occur on a phased schedule throughout the year. The proposed treatment areas include five
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managed open space and undeveloped park areas. Per the PEIR, these treatment activities have the
potential to cause soil disturbance, increased runoff, increased fluvial erosion, increased mass wasting,
and impacts to water quality. The reduction or removal of vegetation has the potential to result in short-
term erosion or loss of topsoil. However, the proposed project does not include treatment activities such
as prescribed burns, which could cause water repellency or non-shaded fuelbreaks, that would result in
the removal of all vegetation, and would retain vegetation to the greatest possible extent. Consistent with
the PEIR, SPRs GEO-1 through GEO-8, AQ-4, and HYD-4, as well as AMM-35 through AMM-37,
would be implemented to further prevent or reduce potential impacts to soil and topsoil during treatment
activities. In addition, SPR AD-3 requires consistency with local plans, policies, and ordinances with
respect to all treatment activities and maintenance. With the implementation of AMMs and SPRs, project
impacts would be less than significant, consistent with the PEIR, and no new or more severe significant
impacts would occur as a result of proposed activities.
IMPACT GEO-2
No steep slopes occur in the treatment areas and prescribed burns are not included as a treatment method
for this project. The proposed treatment areas vary between gently to moderately sloped. Treatment
activities would reduce and remove vegetation in moderately sloped areas, which has the potential to
increase the risk of landslides if treatments affect the vegetation root structure, reducing soil water uptake
and transpiration which can cause the water content in the slopes to destabilize and increase the chance of
a landslide. Vegetation management and maintenance standards, as discussed in Section 2.3.5, Vegetation
Management and Maintenance Standards and Areas, will be implemented to reduce the risk of landslides
caused by treatment activities. Aside from specific invasive species, roots will be left in place, to the
maximum extent possible, to support soil structure. In addition, consistent with the PEIR, SPRs GEO-3,
GEO-4, GEO-7, and GEO-8, as well as AMM-35 and AMM-37, would be implemented to prevent
landslides. With the implementation of vegetation management and maintenance standards, AMMs, and
SPRs, project impacts would be less than significant, consistent with the PEIR, and no new or more
severe significant impacts would occur as a result of proposed activities
NEW GEOLOGY, SOILS, PALEONTOLOGY, AND MINERAL RESOURCES
IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.7.1, Regulatory Setting, and Section 3.7.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to geology, soils, paleontology, and mineral resources
present in the areas outside the treatable landscape are essentially the same as those within the treatable
landscape; therefore, the impacts are the same and, for the reasons described above, impacts of the
proposed treatment project are consistent with those covered in the PEIR. No changed circumstances are
present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any
new significant impact. Therefore, no new impact related to geology, soils, paleontology, and mineral
resources would occur.
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54
4.7 Greenhouse Gas Emissions
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact GHG-1: Conflict
with Applicable Plan, Policy, or Regulation of an Agency Adopted for the Purpose of Reducing the Emissions
of GHGs
LTS Impact
GHG-1
pages 3.8-10 to 3.8-11
Yes None NA LTS No Yes
Impact GHG-2: Generate GHG Emissions through
Treatment Activities
PSU Impact GHG-2
pages
3.8-11 to 3.18-17
Yes None NA SU No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Greenhouse Gas Emissions Impacts: Would the treatment result in other impacts to greenhouse gas
emissions that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT GHG-1
The overall goal of the CalVTP is to reduce the risk of wildfire, which would likely result in greenhouse
gas (GHG) emissions caused by large wildfire events and would increase long-term carbon sequestration
through the preservation of trees. Fuel reduction treatments that were evaluated in the PEIR were
determined to be consistent with California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan),
California Forest Carbon Plan, and Draft California 2030 Natural and Working Lands Climate Change
Implementation Plan (CARB 2017; 2018; 2019). These plans acknowledge the importance of fuel
reduction treatments in managing natural and working lands to reduce long-term GHG emissions. Project-
specific fuel reduction treatments for the proposed project would not include prescribed burns and would
be consistent with the fuel reduction treatments evaluated in the PEIR; therefore, as evaluated in the
PEIR, short-term GHG emissions from equipment and vehicle use are anticipated to be offset by the long-
term benefits of reducing wildfire risk within the state. The proposed project would be consistent with the
analysis of the PEIR and would not conflict with applicable GHG reduction plans, regulations, or
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55
policies; therefore, project-specific impacts would be less than significant, which is consistent with the
impact determination included in the PEIR. Therefore, no new or more severe significant impacts would
occur as a result of proposed activities.
IMPACT GHG-2
Proposed manual and mechanical treatment activities would result in GHG emissions generated by the
use of on- and off-road vehicles and equipment (e.g., masticators, chippers, bulldozers, etc.), machine-
powered hand tools (e.g., chainsaws), and crew and equipment transportation. Consistent with the PEIR,
treatment activities implemented under the proposed project would result in GHG emissions directly
generated by equipment, vehicles, and hauling of equipment and materials associated with manual and
mechanical treatment activities. However, unlike under the CalVTP, no prescribed burning, which results
in substantially more GHG emissions than manual or mechanical treatments, would occur under the
proposed project. PEIR MM GHG-2 would not be applicable to the proposed project because it requires
GHG emissions reduction techniques to be implemented during prescribed burning, which is not a
proposed treatment activity. This impact is within the scope of the PEIR because the proposed activities,
as well as the associated equipment and duration of use, are consistent with those analyzed in the PEIR. In
addition, the intent of the proposed vegetation treatments is to reduce wildfire risk and GHG emissions
related to wildfire. The proposed project encompasses a much smaller treatment area and would not
include prescribed burns; therefore, the proposed project would generate a substantially reduced amount
of GHG emissions compared to what was evaluated in the PEIR. This impact of the proposed project is
consistent with the PEIR and would not constitute a substantially more severe significant impact than
what was covered in the PEIR. Within the boundary of the project area, the climate conditions present in
the areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the GHG impact is also the same, as described above. This determination is consistent with the
PEIR and would not constitute a substantially more severe significant impact than what was covered in
the PEIR.
NEW GREENHOUSE GAS EMISSIONS IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.8.1, Regulatory Setting, and Section 3.8.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to GHGs present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the
same and, for the reasons described above, impacts of the proposed treatment project are consistent with
those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of
the CalVTP treatable landscape would not give rise to any new significant impact. Therefore, no new
impact related to GHG emissions would occur.
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4.8 Energy Resources
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact ENG-1: Result in
Wasteful, Inefficient, or Unnecessary Consumption of Energy
LTS Impact
ENG-1
pages 3.9-7 to 3.9-8
Yes NA NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Energy Resources Impacts: Would the treatment result in other impacts to energy resources that are
not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT ENG-1
As described in the PEIR, proposed treatment activities would result in the short-term consumption of
energy resources in the form of gasoline, diesel, and fuels during the use of heavy-duty vehicles and
equipment and crew transportation to and from the site. Long-term impacts related to energy consumption
would likely be beneficial because proposed treatment activities would reduce the threat of large-scale
wildfire events that would require immediate emergency response personnel and vehicle mobilization.
Consistent with the PEIR, treatment activities would require the short-term consumption of energy
resources; however, by reducing wildfire risk, the inefficient use of energy resources during catastrophic
wildfire events could also be reduced. Proposed treatment activities are consistent with the equipment and
treatment types included in the PEIR. Therefore, the proposed project is consistent with the determination
of the PEIR, and project-specific impacts would be less than significant.
NEW ENERGY RESOURCES IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.9.1, Regulatory Setting, and Section 3.9.2, Environmental Setting,
in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
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geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to energy use present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts are the
same and, for the reasons described above, impacts of the proposed treatment project are consistent with
those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of
the CalVTP treatable landscape would not give rise to any new significant impact. Therefore, no new
impact related to energy would occur.
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58
4.9 Hazardous Materials, Public Health, and Safety
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact HAZ-1: Create a
Significant Health Hazard from the Use of Hazardous Materials
LTS Impact
HAZ-1
pages 3.10-14 to 3.10-15
Yes HAZ-1
HAZ-5/ AMM-31
HYD-4/ AMM-1, AMM-30
NA LTS No Yes
Impact HAZ-2: Create a Significant Health Hazard from the Use of Herbicides
LTS Impact HAZ-2
pages 3.10-15 to
3.10-18
Yes HAZ-5/ AMM-31
HAZ-6
HAZ-7
HAZ-8
HAZ-9
NA LTS No Yes
Impact HAZ-3: Expose the Public or
Environment to Significant Hazards from Disturbance to Known Hazardous Material Sites
LTSM Impact HAZ-3
pages 3.10-18 to 3.10-19
Yes NA NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Hazardous Materials, Public Health, and Safety Impacts: Would the treatment result in other impacts
to hazardous materials, public health, and safety that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT HAZ-1
Consistent with the PEIR, certain treatment activities require the use of vehicles and equipment that
require fuels, oils, and lubricants to function. The use of these materials has the potential to result in
accidental exposure to hazardous materials that may cause health hazards. AMM-1, AMM-30, and
AMM-31, included in Section 2, Project Description (see Table 2), would reduce the potential for
hazardous materials to enter environmentally sensitive areas, prevent accidental spills, and implement a
spill response plan in case of spills. The proposed project would also implement SPR HAZ-1, which
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CalVTP Project-Specific Analysis and Addendum to the PEIR
59
requires routine maintenance on all equipment; SPR HAZ-2, which requires all mechanized equipment to
be equipped with spark arrestors; SPR HAZ-3, which requires crews to carry one fire extinguisher per
chainsaw used; and SPR HAZ-4, which prohibits smoking in vegetated areas. A Spill Prevention and
Response Plan consistent with SPR HAZ-5 would also be implemented and a spill kit would be kept on-
site. In addition, the proposed project would be subject to state rules and regulations, including the
Hazardous Waste Control Act (HWCA), California Department of Toxic Substance Control (DTSC),
California Division of Occupational Health and Safety Administration (Cal/OSHA), and California
Environmental Protection Agency (CalEPA) regulations for the use, transport, storage, and disposal of
hazardous materials. Project impacts would be less than significant, consistent with the PEIR, and would
not result in any new or more significant environmental impacts.
IMPACT HAZ-2
Per the PEIR, herbicide application requires increased transportation, use, storage, and disposal of
herbicides, which could result in risks related to human exposure when applied near public areas or if
accidental spills occur. The proposed project includes the optional, as-needed use of herbicides as a
treatment option to remove target vegetation. Herbicides proposed are consistent with those analyzed in
the PEIR and include borax (tetraborate decahydrate), clopyralid (monethanolamine salt), glyphosate
(ispropylamine salt, potassium salt, dimethylamine salt, diammonium salt), hexazinone, imazapyr
(isopropylamine salt), sulfometron methyl, triclopyr (butoxyethyl ester and triethylamine salt),
nonylphenol 9 ethoxylates (NP9E), cleantraxx (penoxsulam and oxyfluorfen), valpar (hexazinone), and
indaziflam.
Certification is required to apply herbicides in the State of California through the California Department
of Pesticide Regulation and requires the certified party to obtain appropriate PPE, including, but not
limited to, masks or respirators, safety goggles, gloves, protective clothing, hard hats, and boots.
Herbicide treatments would be performed in accordance with federal and state regulations and conducted
by a licensed Pest Control Advisor. In addition, the proposed project would limit the use and type of
herbicides and restrict treatment in areas adjacent to the public and environmentally sensitive areas,
consistent with the PEIR. AMM-31, included in Section 2, Project Description (see Table 2), would
reduce potential health hazards that could result from the use of herbicides by requiring hand application
of herbicides and limiting herbicide use adjacent to sensitive environmental areas including, waters and
wetlands. In addition, the proposed project would implement SPRs HAZ-5 through HAZ-9, from the
PEIR. AMM-31 and SPR HAZ-5 require the preparation of a Spill Prevention and Response Plan and that
a spill kit be kept and maintained on-site. SPR HAZ-6 requires compliance with herbicide application
regulations, including coordinating pesticide use with the applicable County Agricultural
Commissioner(s) and obtaining all required licenses and permits. SPR HAZ-7 requires that herbicide
containers be triple rinsed with clean water at an approved site and disposed of by placing it in a batch
tank. SPR HAZ-8 requires minimization of herbicide drift to public areas during herbicide application,
and SPR HAZ-9 requires the public be notified of herbicide use prior to applications in areas adjacent to
public areas (e.g., recreation areas, residential areas, schools, etc.) within 500 feet. Project impacts would
be less than significant, consistent with the PEIR, and would not result in any new or more significant
environmental impacts.
IMPACT HAZ-3
Mechanical treatments have the potential to cause soil disturbance and may expose workers, members of
the public, and the environment to hazardous materials in the treatment areas. Mechanical treatments
would be implemented as part of the project, however, there are no hazardous material sites within the
proposed treatment areas (DTSC 2022; Regional Water Quality Control Board [RWQCB] 2022). Project
impacts would be less than significant, consistent with the PEIR, and would not result in any new or more
significant environmental impacts.
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CalVTP Project-Specific Analysis and Addendum to the PEIR
60
NEW HAZARDOUS MATERIALS, PUBLIC HEALTH, AND SAFETY IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.10.1, Regulatory Setting, and Section 3.10.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to hazardous materials, public health, and
safety present in the areas outside the treatable landscape are essentially the same as those within the
treatable landscape; therefore, the impacts are the same and, for the reasons described above, impacts of
the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances
are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to
any new significant impact. Therefore, no new impact related to hazardous materials, public health, and
safety would occur.
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4.10 Hydrology and Water Quality
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact HYD-1: Violate
Water Quality Standards or Waste Discharge Requirements, Substantially Degrade
Surface or Ground Water Quality, or Conflict with or Obstruct the Implementation of a Water Quality Control
Plan Through the Implementation of Prescribed Burning
LTS Impact
HYD-1
pages 3.11-25 to 3.11-27
No -- -- -- -- --
Impact HYD-2: Violate
Water Quality Standards or Waste Discharge Requirements, Substantially Degrade
Surface or Ground Water Quality, or Conflict with or Obstruct the Implementation of a Water Quality Control
Plan Through the Implementation of Manual or Mechanical Treatment Activities
LTS Impact
HYD-2
pages 3.11-27 to 3.11-29
Yes BIO-1
HYD-1/ AMM-21
HYD-4/ AMM-1, AMM-30
GEO-1/ AMM-34
GEO-2/ AMM-36
GEO-3/
AMM-35
GEO-4/ AMM-37
GEO-7
HAZ-1
HAZ-5/ AMM-31
AMM-21
AMM-41
NA LTS No Yes
Impact HYD-3: Violate Water Quality Standards or Waste Discharge Requirements,
Substantially Degrade Surface or Ground Water Quality, or Conflict with or Obstruct the Implementation of a
Water Quality Control Plan Through Prescribed Herbivory
LTS Impact HYD-3
page 3.11-29
Yes HYD-3
AMM-33
NA LTS No Yes
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62
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Impact HYD-4: Violate Water Quality Standards or Waste
Discharge Requirements, Substantially Degrade Surface or Ground Water Quality, or
Conflict with or Obstruct the Implementation of a Water Quality Control Plan Through the Ground Application of
Herbicides
LTS Impact HYD-4
pages
3.11-29 to 3.11-31
Yes BIO-4/ AMM-25
HYD-5
HAZ-5/ AMM-31
HAZ-6/ AMM-27
HAZ-7
AMM-26
NA LTS No Yes
Impact HYD-5: Substantially Alter the Existing Drainage
Pattern of a Treatment Site or Area
LTS Impact HYD-5
page
3.11-31
Yes HYD-1/ AMM-21
HYD-4/
AMM-1, AMM-30
HYD-6
GEO-1/ AMM-34
GEO-2
NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Hydrology and Water Quality Impacts: Would the treatment result in other impacts to hydrology and
water quality that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT HYD-1
The proposed project does not include prescribed burning. Therefore, this impact does not apply to the
proposed project.
IMPACT HYD-2
The proposed project includes manual and mechanical vegetation treatments over approximately 193.91
acres within open space areas and undeveloped park areas. Consistent with the PEIR, these treatment
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63
activities would result in ground disturbance and may cause soil erosion. Disturbed soil could enter
environmentally sensitive areas, including adjacent watercourses. In addition, fuel required for the use
and operation of mechanical equipment and transport of manual equipment could potentially enter
watercourses and degrade water quality through accidental spills. The proposed project would implement
AMMs included in Section 2, Project Description (see Table 2), during treatment activities to reduce the
potential for erosion, runoff, and accidental spills, and to avoid impacts to environmentally sensitive
areas, such as aquatic habitat. In addition, the proposed project would also implement SPRs included in
the PEIR to reduce impacts to watercourses from erosion and runoff. SPR BIO-1 requires a qualified
biologist to conduct a data review and reconnaissance-level surveys within proposed treatment areas in
order to identify and document sensitive resources, including riparian habitat, wetlands, and special-status
species habitat and establish an avoidance buffer area to protect resources during project activities.
AMM-34 and AMM-36 and SPRs GEO-1 and GEO-2 limit ground disturbance during precipitation or
heavy equipment operation over saturated soils, when such activities could produce ruts and runoff could
concentrate. AMM-37 and SPR GEO-3 requires highly disturbed areas be stabilized with mulch and SPR
GEO-4 requires treatment areas to be inspected for erosion prior to and following the first large rainfall
event. AMM-35 and SPRs GEO-7 and GEO-8 would limit equipment operation on steep or unstable
slopes to reduce the potential for erosion. AMM-21 and SPR HYD-1 require the proposed project to
comply with all state and regional water quality regulations, including conditions of waste discharge
requirement waivers that are applicable to fuel reduction and fire prevention activities. AMM-30 and
SPR HYD-4 require equipment to be fueled and serviced outside of environmentally sensitive areas.
AMM-41 and SPR HAZ-1 require all equipment to be maintained and regularly inspected for leaks.
AMM-31 and SPR HAZ-5 require the preparation of a Spill Prevention and Response Plan and that a spill
kit be kept and maintained on-site. Implementation of AMMs and SPRs would reduce the potential for
erosion, runoff, and/or accidental spills into adjacent environmentally sensitive areas. Therefore, project-
specific impacts would be less than significant, consistent with the PEIR, and would not result in any new
or more severe impacts.
IMPACT HYD-3
The proposed project includes grazing/prescribed herbivory as a treatment method. The use of prescribed
herbivory has potential to impact water quality, especially in riparian areas where livestock tend to
congregate. Consistent with the PEIR, the proposed project would require a grazing management plan to
be prepared and exclusion fencing to be installed to prevent impacts to water quality as a result of grazing
activities. The proposed project would implement AMM-33, included in Section 2, Project Description
(see Table 2), to prevent grazing in environmentally sensitive areas and reduce the risk of substantial
degradation to surface or groundwater quality from prescribed herbivory. AMM-33 and SPR HYD-3
exclude grazing in sensitive areas, require livestock movement if erosion is observed, require alternative
water sources, and limit stream access points and crossings, which would avoid and minimize water
quality degradation and be implemented to further minimize potential impacts to surface or groundwater
quality. Therefore, project-specific impacts would be less than significant, consistent with the PEIR, and
would not result in any new or more severe impacts.
IMPACT HYD-4
As discussed in Section 4.9, Hazardous Materials, Public Health, and Safety, the proposed project
includes the optional, as-needed use of herbicides as a treatment option to remove target vegetation.
Herbicides proposed are consistent with those analyzed in the PEIR and include borax (tetraborate
decahydrate), clopyralid (monethanolamine salt), glyphosate (ispropylamine salt, potassium salt,
dimethylamine salt, diammonium salt), hexazinone, imazapyr (isopropylamine salt), sulfometron methyl,
triclopyr (butoxyethyl ester and triethylamine salt), nonylphenol 9 ethoxylates (NP9E), cleantraxx
(penoxsulam and oxyfluorfen), valpar (hexazinone), and indaziflam. Per the PEIR, the use of herbicides
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64
has the potential to impact water quality through off-site movement of herbicides from runoff, leaching,
drift, and misapplication or spills. Other factors, including site conditions, chemical characteristics, and
application techniques, increase the likelihood of an herbicide to degrade water quality.
Certification is required to apply herbicides in the State of California through the California Department
of Pesticide Regulation and requires the certified party to obtain appropriate PPE, including, but not
limited to, masks or respirators, safety goggles, gloves, protective clothing, hard hats, and boots.
Herbicide treatments would be performed in accordance with federal and state regulations and conducted
by a licensed Pest Control Advisor. In addition, the proposed project would limit the use and type of
herbicides and restrict treatment in environmentally sensitive areas, consistent with the PEIR. AMM-25
through AMM-27 and AMM-31, included in Section 2, Project Description (see Table 2), would reduce
and minimize the risk of impacts to surface or groundwater quality from herbicide application.
In addition, the proposed project would also implement SPRs from the PEIR, including SPR BIO-4, SPR
HAZ-5 through 7, and SPR HYD-5 to further reduce the risk of substantial degradation to surface or
groundwater quality from herbicide application. SPR HYD-5 prohibits spray application of herbicides
when wind speeds are 7 miles per hour or greater and prohibits herbicide application within 50 feet of
surface waters or wet meadows for non-aquatic formulations. AMM-25 and SPRs HYD-5 and BIO-4
allow only hand application of herbicides in riparian areas. AMM-26 requires herbicide application to
occur outside of the wet season. AMM-31 and SPR HAZ-5 require the preparation of a Spill Prevention
and Response Plan and that a spill kit be kept and maintained on-site. AMM-27 and SPR HAZ-6 require
compliance with herbicide application regulations, including coordinating pesticide use with the
applicable County Agricultural Commissioner(s) and obtaining all required licenses and permits. SPR
HAZ-7 requires that herbicide containers be triple rinsed with clean water at an approved site and
disposed of by placing it in a batch tank to protect water resources. Therefore, project-specific impacts
would be less than significant, consistent with the PEIR, and would not result in any new or more
significant environmental impacts.
IMPACT HYD-5
Consistent with the PEIR, the proposed project includes ground-disturbing treatment activities that could
intersect existing drainage infrastructure at treatment locations. The proposed project does not include
non-shaded fuel breaks, but includes a combination of manual, mechanical, and prescribed herbivory
treatment methods over 193.91 acres within the Open Space VMP Area, which have the potential to
temporarily disturb existing drainage patterns within the project area. Consistent with the PEIR,
prescribed herbivory, and most methods of mechanical treatments, would have minor effects on site
drainage. The implementation of AMMs, included in Section 2, Project Description (see Table 2), and
SPRs, included in Impacts HYD-2 through HYD-4, would reduce impacts to existing drainages in the
treatment areas. Therefore, project-specific impacts would be less than significant, consistent with the
PEIR, and would not result in any new or more significant environmental impacts.
NEW HYDROLOGY AND WATER QUALITY IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.11.1, Regulatory Setting, and Section 3.11.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to hydrology and water quality present in the
areas outside the treatable landscape are essentially the same as those within the treatable landscape;
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
65
therefore, the impacts are the same and, for the reasons described above, impacts of the proposed
treatment project are consistent with those covered in the PEIR. No changed circumstances are present,
and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new
significant impact. Therefore, no new impact related to hydrology and water quality would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
66
4.11 Land Use and Planning, Population and Housing
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact LU-1: Cause a
Significant Environmental Impact Due to a Conflict with a Land Use Plan, Policy, or Regulation
LTS Impact LU-1
pages 3.12-13 to 3.12-14
Yes AD-3 NA LTS No Yes
Impact LU-2: Induce Substantial Unplanned Population Growth
LTS Impact LU-2
pages 3.12-14 to 3.12-15
Yes NA NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Land Use and Planning, Population and Housing Impacts: Would the treatment result in other
impacts to land use and planning, population and housing that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT LU-1
The project area encompasses approximately 193.91 acres of parks and open space within the Town of
Los Gatos. SPR AD-3, included in the PEIR, requires proposed projects to be consistent with applicable
local plans, policies, and ordinances. Applicable local plans, policies, and ordinances include the Town of
Los Gatos 2040 General Plan (Town of Los Gatos 2022a), Town of Los Gatos Municipal Code, Los
Gatos Hillside Specific Plan (Town of Los Gatos 1978), Town of Los Gatos Tree Protection Ordinance
(Town of Los Gatos 2022b), and Santa Clara County Fire Department Road Standards (SCCFD 2009;
2020a; 2020b). These plans require the protection of biological resources, water resources, air quality, and
other environmental resources. In addition, the Town of Los Gatos 2040 General Plan Hazards and Safety
Element (Element 9) identifies the need to protect the community from potential threats, including
wildfire (Town of Los Gatos 2022a). The proposed project includes AMMs (see Section 2, Project
Description [see Table 2]) to reduce potential impacts related to air quality, special-status species and
other biological resources, soil stability, and water resources. Consistent with the analysis of the PEIR,
implementation of AMMs, SPRs, and MMs included in each resource section would avoid or reduce
impacts and ensure consistency with applicable local plans, policies, and regulations. Additionally, the
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
67
proposed project would reduce the risk for wildfire to occur, which is consistent with the Hazards and
Safety Element (Element 9). Since AMMs, SPRs, and MMs are required to be implemented in individual
resource sections, the proposed project would have less-than-significant impacts related to land use and
planning; therefore, the proposed project would be consistent with the evaluation and determination
included in the PEIR, and no new or more significant environmental impacts would occur.
IMPACT LU-2
Due to the relatively small geographical scope of the PEIR, it is anticipated that the increase in proposed
vegetation treatments would be unlikely to generate new employment opportunities that could marginally
increase population growth in the project area. The proposed project is expected to include less than 10
crew members per treatment area to conduct proposed vegetation treatments over approximately 193.91
acres of parks and open space within the Town of Los Gatos. Therefore, the proposed project would only
result in short-term increases in the demand for workers, which is within the scope of the PEIR. The
proposed project would not result in a substantial population increase and impacts would be less than
significant. Therefore, project-specific impacts would be consistent with the analysis and determination of
the PEIR.
NEW LAND USE AND PLANNING, POPULATION AND HOUSING IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.12.1, Regulatory Setting, and Section 3.4.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to land use and planning present in the areas
outside the treatable landscape are essentially the same as those within the treatable landscape; therefore,
the impacts are the same and, for the reasons described above, impacts of the proposed treatment project
are consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to land use and planning would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
68
4.12 Noise
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact NOI-1: Result in
a Substantial Short-Term Increase in Exterior Ambient Noise Levels During Treatment
Implementation
LTS Impact
NOI-1
pages 3.13-9 to 3.13-12
Appendix
NOI-1
Yes AD-3/
AMM-38
NOI-1
NOI-2/ AMM-39
NOI-3
NOI-4
NOI-5/ AMM-6
NOI-6
NA LTS No Yes
Impact NOI-2: Result in a Substantial Short-Term Increase in Truck-Generated Single-Event Noise Levels During
Treatment Activities
LTS Impact NOI-2
page 3.13-12
Yes NOI-1 NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Noise Impacts: Would the treatment result in other noise-related impacts that are not evaluated in the
CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT NOI-1
Vehicle and equipment use for proposed vegetation treatment activities have the potential to increase
ambient noise levels within the vicinity of proposed treatment areas. SPR AD-3 included in the PEIR
requires proposed projects to be consistent with local plans, policies, and ordinances. The Town of Los
Gatos Code of Ordinances (Section 16.20.035) prohibits construction noise between the hours of 6:00
p.m. and 8:00 a.m. on weekdays and 4:00 p.m. and 9:00 a.m. on Saturdays, and any time on Sundays.
Under AMM-38, included in Section 2, Project Description (see Table 2), proposed vegetation treatments
would be limited to the hours in the Noise Ordinance. The Noise chapter on the Town of Los Gatos 2040
General Plan Environment and Sustainability Element (Chapter 8.11) includes policies and
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
69
implementation measures to ensure that equipment noise does not adversely affect land uses and to
actively enforce noise standards. Proposed vegetation treatments would occur in public parks and open
space areas. However, noise generated by proposed treatments would be temporary, would be
intermittent, and would not create a new permanent source of noise in the area, which is consistent with
the Noise Chapter of the Environment and Sustainability Element (Chapter 8.11). Additionally, the
proposed project would be subject to noise-specific SPRs included in the PEIR and project AMMS to
reduce short-term increases in ambient noise levels. SPR NOI-1 restricts vegetation treatment activities to
daytime hours. SPR NOI-2 and AMM-39 require all equipment to be maintained appropriately and
equipped with the proper intake and exhaust shrouds. SPR NOI-3 requires all equipment engine shrouds
to be closed during operation. SPR NOI-4 would require vegetation treatment activities and staging areas
be located away from sensitive receptors to the extent feasible to minimize noise exposure. SPR NOI-5
and AMM-6 restrict equipment idling time. Additionally, SPR NOI-6 requires notification to be provided
to nearby sensitive receptors when heavy equipment would be used for a treatment. With implementation
of required SPRs and AMMs, the proposed project would have a less-than-significant impact related to
increases in ambient noise and would be consistent with the determination of the PEIR.
IMPACT NOI-2
As described in the PEIR, single event (impulsive) noise level (SENL) describes a receiver’s cumulative
noise exposure from a single impulsive noise event (e.g., an automobile passing by, an aircraft flying
overhead). The proposed project has the potential to increase SENL within proposed treatment areas
through heavy equipment and vehicle trips. SPR NOI-1, included in the PEIR, would be implemented to
restrict vegetation treatment activities to daytime hours, which would reduce the potential for an increase
in heavy vehicle and equipment trips to increase SENLs during noise-sensitive evening and nighttime
hours. The increase in heavy vehicle and equipment trips would be temporary and would not result in a
permanent increase in trips along public roadways. The proposed project would be consistent with the
PEIR because vehicle and equipment trips would be limited to daylight hours and would not result in a
long-term increase in SENL. Therefore, project-specific impacts would be less than significant, and no
new or more severe impacts than what was evaluated in the PEIR would occur.
NEW NOISE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.13.1, Regulatory Setting, and Section 3.13.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to noise present in the areas outside the
treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts
are the same and, for the reasons described above, impacts of the proposed treatment project are
consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to noise would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
70
4.13 Recreation
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact REC-1: Directly
or Indirectly Disrupt Recreational Activities within Designated Recreation Areas
LTS Impact
REC-1
pages 3.14-6 to 3.14-7
Yes REC-1 NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Recreation Impacts: Would the treatment result in other impacts to recreation that are not evaluated
in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT REC-1
Consistent with the PEIR, the proposed project could result in potential conflicts with recreationists and
recreation areas. The proposed project includes treatment activities across 193.91 acres within five open
space areas and undeveloped park areas. Therefore, proposed treatment activities could result in conflicts
with recreationists including access restrictions or nuisance impacts such as degradation of views, dust
emissions, and increased traffic. SPR REC-1, included in the PEIR, would be implemented to minimize
recreational nuisances that could result due to treatment activities. SPR REC-1 requires the project
proponent to notify the public before the implementation of treatment activities. Potential nuisance
impacts would be temporary and would not result in long-term disruption or conflicts with recreational
land uses. Therefore, project-specific impacts would be less than significant, consistent with the PEIR,
and would not result in any new or more severe impacts.
NEW RECREATION IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.14.1, Regulatory Setting, and Section 3.14.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
71
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to recreation present in the areas outside the
treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts
are the same and, for the reasons described above, impacts of the proposed treatment project are
consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to recreation would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
72
4.14 Transportation
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact TRAN-1: Result
in Temporary Traffic Operations Impacts by Conflicting with a Program, Plan, Ordinance, or Policy
Addressing Roadway Facilities or Prolonged Road Closures
LTS Impact
TRAN-1
pages 3.15-9 to 3.15-10
Yes AD-3
TRAN-1
AMM-40
NA LTS No YES
Impact TRAN-2:
Substantially Increase Hazards due to a Design Feature or Incompatible Uses
LTS Impact
TRAN-2
pages 3.15-10 to 3.15-11
Yes AD-3
TRAN-1
AMM-40
NA LTS No Yes
Impact TRAN-3: Result in a Net Increase in VMT for the Proposed CalVTP
PSU Impact TRAN-3
pages 3.15-11 to 3.15-13
Yes NA NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Transportation Impacts: Would the treatment result in other impacts to transportation that are not
evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT TRAN-1
The Town of Los Gatos 2040 General Plan Mobility Element (Element 5) evaluates existing roadway
conditions using levels of service (LOS), which are categorized according to the flow of traffic. Within
the Town, LOS D is considered an acceptable LOS (Town of Los Gatos 2022a). There are several state
and county roadways that traverse the Town in the vicinity of the treatment areas, including, but not
limited to, SR-17 and SR-9, in addition to local roadways. In addition, there are numerous local roadways
located within the project area.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
73
The proposed project has the potential to slow the flow of traffic through an increase of heavy vehicles
and equipment traveling on nearby roadways and through implementation of temporary traffic controls.
AMM-40, included in Section 2, Project Description (see Table 2), would require the project to prepare
and implement a Traffic Control Plan in order to coordinate with nearby land uses in regard to potential
road closures or other necessary controls. Temporary traffic controls on public roadways would be subject
to SPR TRAN-1, included in the PEIR, which requires coordination with local agencies to develop a
traffic management plan as necessary. In addition, vehicle and equipment transportation would be
temporary and would not permanently impede the flow of traffic on public roadways. The proposed
project would be consistent with SPR AD-3 because it would be consistent with the Town of Los Gatos
2040 General Plan Mobility Element (Element 5). Therefore, project-specific impacts would be less than
significant, which is consistent with the analysis and determination included in the PEIR.
IMPACT TRAN-2
The proposed project does not include the construction of any new roads; therefore, the proposed project
would not substantially increase hazards due to hazardous road design. The PEIR also identifies an
increase in congestion as a potential roadway hazard. AMM-40, included in Section 2, Project
Description (see Table 2), would require preparation of a Traffic Control Plan to foster coordination with
nearby land uses in regard to potential road closures or other necessary controls. Temporary traffic
controls would be subject to SPR TRAN-1 to avoid unnecessary hazards associated with implementation
of traffic controls. Additionally, the proposed project would be consistent with SPR AD-3 because traffic
controls are not anticipated to increase long-term congestion along public roadways. Therefore, project-
specific impacts would be less than significant and would not constitute a new or more severe impact than
what was evaluated in the PEIR.
IMPACT TRAN-3
According to the Technical Advisory on Evaluating Transportation Impacts in CEQA, projects that do not
indicate substantial evidence that a project would generate a potentially significant level of vehicle miles
traveled (VMT), that are consistent with a Sustainable Communities Strategy (SCS) or general plan, or
that would generate or attract fewer than 110 trips per day generally may be assumed to cause a less-than-
significant transportation impact (California Governor’s Office of Planning and Research [OPR] 2018).
One to three vehicles per treatment area would be used for crew transportation to proposed treatment
areas. Although there is potential for concurrent treatment activities to occur, vehicle and equipment trips
would be temporary and the project is not anticipated to result in more than 110 trips per day; therefore,
project-specific impacts related to VMT would be less than significant. The PEIR evaluates the potential
impacts of an increase in vegetation treatments throughout the state; therefore, this impact area was
identified as having a potentially significant and unavoidable impact related to VMT. The PEIR also notes
that individual treatment projects are reasonably expected to generate less than 110 trips per day, which is
consistent with the determination of the proposed project. Project-specific impacts would be less than
significant; therefore, the proposed project would not result in any new or more severe impacts than what
was included in the PEIR.
NEW TRANSPORTATION IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.15.1, Regulatory Setting, and Section 3.15.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
74
existing environmental and regulatory conditions pertinent to transportation present in the areas outside
the treatable landscape are essentially the same as those within the treatable landscape; therefore, the
impacts are the same and, for the reasons described above, impacts of the proposed treatment project are
consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to transportation would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
75
4.15 Public Services, Utilities, and Service Systems
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact UTIL-1: Result in
Physical Impacts Associated with Provision of Sufficient Water Supplies, Including Related
Infrastructure Needs
LTS Impact
UTIL-1
page 3.16-9
No -- -- -- -- --
Impact UTIL-2: Generate Solid Waste in Excess of State
Standards or Exceed Local Infrastructure Capacity
PSU Impact UTIL-2
pages
3.12-10 to 3.16-12
No -- -- -- -- --
Impact UTIL-3: Comply
with Federal, State, and Local Management and Reduction Goals, Statutes, and Regulations Related to
Solid Waste
LTS Impact
UTIL-3
page 3.16-12
No -- -- -- -- --
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Public Services, Utilities, and Service Systems Impacts: Would the treatment result in other impacts
to public services, utilities, and service systems that are not evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT UTIL-1
The proposed project does not include prescribed burning or non-shaded fuel breaks and would not
require the use of on-site water supplies. Therefore, this impact does not apply to the proposed project.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
76
IMPACT UTIL-2
The proposed project includes treatment methods that generate solid organic waste during mechanical and
manual vegetation removal in the form of organic woody biomass. Biomass generated during treatment
activities would be disposed of through chipping and mastication. The proposed project does not include
the transport of biomass to off-site waste facilities for processing. Therefore, this impact does not apply to
the proposed project as it would not generate solid waste exceeding state or local standards or
infrastructure capacity.
IMPACT UTIL-3
As described in Impact UTIL-2, the proposed project does not include the transport of biomass to local
waste providers; therefore, this impact does not apply to the proposed project.
NEW PUBLIC SERVICES, UTILITIES, AND SERVICE SYSTEMS IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.16.1, Regulatory Setting, and Section 3.16.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to public services, utilities, and service
systems present in the areas outside the treatable landscape are essentially the same as those within the
treatable landscape; therefore, the impacts are the same and, for the reasons described above, impacts of
the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances
are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to
any new significant impact. Therefore, no new impact related to public services, utilities, and service
systems would occur.
Los Gatos Open Space Vegetation Management Plan
CalVTP Project-Specific Analysis and Addendum to the PEIR
77
4.16 Wildfire
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This
Be a
Substantially
More Severe
Significant
Impact than
Identified in
the PEIR?
Is This
Impact
Within
the
Scope
of the
PEIR?
Would the project:
Impact WIL-1:
Substantially Exacerbate Fire Risk and Expose People to Uncontrolled Spread of a Wildfire
LTS Impact
WIL-1
pages 3.17-13 to 3.17-14
Yes HAZ-2
HAZ-3
HAZ-4
AMM-41
NA LTS No Yes
Impact WIL-2: Expose People or Structures to Substantial Risks Related to Postfire
Flooding or Landslides
LTS Impact WIL-2
pages 3.17-14 to
3.17-15
Yes GEO-3
GEO-4/ AMM-37
GEO-5
GEO-8/ AMM-35
AMM-34
AMM-36
NA LTS No Yes
1 NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Wildfire Impacts: Would the treatment result in other impacts related to wildfire that are not
evaluated in the CalVTP PEIR?
☐ Yes ☒ No If yes, complete row(s) below and discussion.
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less than
Significant
☐ ☐ ☐
Discussion
IMPACT WIL-1
The proposed project includes manual, mechanical, and prescribed herbivory treatments within areas
identified as high risk for wildfire potential. Consistent with the PEIR, proposed treatment activities have
the potential to result in temporary risks associated with uncontrolled fire from the use of vehicles and
heavy machinery in the treatable landscape due to the risk of accidental wildfire ignition. AMM-41,
included in Section 2, Project Description (see Table 2), would reduce the potential for proposed
treatment activities to ignite a wildfire. In addition, SPRs HAZ-1 through HAZ-4, included in the PEIR,
would be implemented to further reduce the risk of uncontrolled spread of a wildfire from treatment
activities. AMM-41 encompasses the following SPRs: HAZ-1, which requires routine maintenance on all
equipment; HAZ-2, which requires all mechanized equipment to be equipped with federally and state-
approved spark arrestors to prevent the emission of flammable debris; HAZ-3, which requires vegetation
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78
treatment crews to carry one fire extinguisher per chainsaw used, one long-handle shovel, and one axe or
Pulaski to quickly respond to an ignition should one occur; and HAZ-4, which prohibits smoking outside
of designated smoking areas. In addition, AMM-41 requires crews to monitor weather and fire danger on
a daily basis and a designated crew member at each treatment area to monitor for fires during Red Flag
Warnings. Implementation of proposed treatment activities would not substantially exacerbate fire risk
that could result in the uncontrolled spread of wildfire. The proposed project would ultimately reduce the
fuel load and result in a long-term reduction in wildlife risk of uncontrolled spread of wildfire. Therefore,
project impacts would be less than significant, consistent with the PEIR, and would not result in any new
or more significant environmental impacts.
IMPACT WIL-2
Consistent with the PEIR, the proposed project does not include the construction of new structures that
could place people or structures in an area with risks related to post-wildfire flooding or landslides. In
addition, the proposed project does not include prescribed burning as a treatment option. However,
treatment activities have the potential to result in soil disturbance. AMM-34 through AMM-37, included
in Section 2, Project Description (see Table 2), and SPRs GEO-3 through GEO-5 and GEO-8 would be
implemented to stabilize disturbed soils and reduce the risk of post-fire flooding or landslides. SPR
GEO-3 requires highly disturbed treatment areas to be stabilized following mechanical or prescribed
herbivory treatments with mulch. AMM-36 limits the use of heavy equipment in areas that could cause
compaction of or damage to soils when they are wet or saturated. AMM-34 limits treatment activities
during rain, and SPR GEO-4 requires treatment areas to be inspected for erosion prior to and following
the first large rainfall event. SPR GEO-5 requires the project proponent to drain compacted and/or bare
linear treatment areas capable of generating stormwater runoff through the use of water breaks. AMM-35
and SPR GEO-8 would limit equipment operation on steep or unstable slopes to reduce the potential for
erosion. The overall goal of the proposed project is to implement treatments in order to reduce fuel loads
and the risk of wildfire and associated flooding or landslides that could impact surrounding communities.
Therefore, project impacts would be less than significant, consistent with the PEIR, and would not result
in any new or more significant environmental impacts.
NEW WILDFIRE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP
PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments
and determined they are consistent with the applicable regulatory and environmental conditions presented
in the CalVTP PEIR (refer to Section 3.17.1, Regulatory Setting, and Section 3.17.2, Environmental
Setting, in Volume II of the Final PEIR). The project proponent has also determined that the inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to
the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing environmental and regulatory conditions pertinent to wildfire present in the areas outside the
treatable landscape are essentially the same as those within the treatable landscape; therefore, the impacts
are the same and, for the reasons described above, impacts of the proposed treatment project are
consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of
areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to wildfire would occur.
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5 LIST OF PREPARERS
Town of Los Gatos, Department of Public Works
(Lead Agency)
Nicolle Burnham, Director of Parks and Public Works
SWCA Environmental Consultants
(CEQA Compliance)
Juliet Bolding, Associate Project Environmental Planner
Mark Brandi, Principal Restoration Ecologist and Landscape Architect
Lauren Huff, Northern California Ecological Restoration and Natural Resources Planning Director
Jaimie Jones, Technical Editor
Laura Moran, Northern and Central California Vice President
Charlotte Soergel, Project Restoration Ecologist
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6 REFERENCES
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https://mtc.maps.arcgis.com/apps/webappviewer/index.html?id=4a6f3f1259df42eab29b35dfcd0
86fc8. Accessed on September 22, 2020.
Bay Area Air Quality Management District (BAAQMD). 2023. Air District Air Quality Data. Available
at: https://www.baaqmd.gov/about-air-quality/current-air-quality/air-monitoring-data/#/.
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Calflora. 2020. Search for Plants. Available at: https://www.calflora.org/. Accessed July 22, 2022.
California Air Resources Board (CARB). 2017. 2017 Climate Change Scoping Plan. Available at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2017-scoping-
plan-
documents#:~:text=This%20Scoping%20Plan%20for%20Achieving,goal%20to%20reduce%20
GHG%20emissions. Accessed September 20, 2020.
______. 2018. California Forest Carbon Plan. Available at:
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______. 2019. Draft California 2030 Natural and Working Lands Climate Change Implementation Plan.
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September 20, 2020.
California Board of Forestry and Fire Protection (CAL FIRE). 2007. Frequently Asked Questions About:
Fire Hazard Severity Zoning and New Building Codes for California’s Wildland-Urban
Interface. Available at: https://osfm.fire.ca.gov/divisions/community-wildfire-preparedness-and-
mitigation/wildfire-preparedness/fire-hazard-severity-zones/fire-hazard-severity-zones-map/ .
Accessed September 22, 2020.
———. 2019a. California Vegetation Treatment Program Final Program Environmental Impact Report.
Available at: https://bof.fire.ca.gov/projects-and-programs/calvtp/calvtp-implementation/.
Accessed December 8, 2020.
———. 2019b. California Vegetation Treatment Program Final Program Environmental Impact Report:
Chapter 1 Introduction. Available at: https://bof.fire.ca.gov/media/9725/01-
introduction_ada.pdf. Accessed December 8, 2020.
———. 2019c. California Vegetation Treatment Program Final Program Environmental Impact Report:
Chapter 2 Program Description. Available at: https://bof.fire.ca.gov/media/9726/02-program-
description_ada.pdf. Accessed December 8, 2020.
———. 2020. Communities at Risk. Available at: https://osfm.fire.ca.gov/divisions/community-wildfire-
preparedness-and-mitigation/fire-plan/communities-at-risk/. Accessed December 8, 2020.
California Department of Fish and Wildlife (CDFW). 2022. California Natural Diversity Database.
Available at: https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data#43018408-cnddb-in-bios.
Accessed January 28, 2022.
———. 2023. State and Federally Listed Endangered and Threatened Animals of California. Available
at: State and Federally Listed Endangered and Threatened Animals of California. Accessed July
30, 2019.
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California Fish (CalFish). 2020. Species Programs. Available at:
https://www.calfish.org/ProgramsData/Species.aspx. Accessed on September 22, 2020.
California Herps (CAL Herps). 2020. Reptiles and Amphibians of the San Francisco Bay Area. Available
at: https://californiaherps.com/identification/bayareaherps.html. Accessed on September 22,
2020.
California Native Plant Society (CNPS). 2020. Rare Plant Inventory. Available at:
https://rareplants.cnps.org/Search/Advanced. Accessed July 30, 2020.
California Department of Toxic Substance Control (DTSC) 2022. EnviroStor. Available at:
https://www.envirostor.dtsc.ca.gov/public/. Accessed January 28, 2022.
California Department of Transportation (Caltrans). 2022. California State Scenic Highway System Map.
Available at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e80571
16f1aacaa. Accessed January 27, 2022.
California Geological Survey (CGS). 2000. Naturally-Occurring Asbestos in California. Available at:
Naturally-Occurring Asbestos in California. Accessed January 28, 2022.
———. 2011a. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural
Occurrences of Asbestos in California Map.
———. 2011b. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural
Occurrences of Asbestos in California Data Set.
California Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluation
Transportation Impacts in CEQA. December. Available at:
https://www.opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. Accessed January 2022.
California Invasive Plant Council (Cal-IPC). 2012. BMPs for Non-Chemical Weed Control. Available at:
BMPs for Non-Chemical Weed Control – California Invasive Plant Council (cal-ipc.org).
Accessed September 22, 2020.
California Oak Mortality Task Force. (California Oak Mortality Task Force). 2016. Working Group for
Phytoptheras in Native Habitats. Available at: https://www.suddenoakdeath.org/wp-
content/uploads/2016/04/Restoration.Nsy_.Guidelines.final_.092216.pdf. Accessed on July 22.
2020.
Center for Biological Diversity (CBD). 2020. Species. Available at: Species (biologicaldiversity.org).
Accessed September 22, 2020.
County of Santa Clara. 2016. Santa Clara County Community Wildfire Protection Plan. Available at:
https://www.sccfd.org/wp-
content/uploads/documents/fire_prevention/CWPP/CWPP_Strategic_Countywide_Document_0
8_29_16.pdf. Accessed January 28, 2022.
———. 2019. Santa Clara County Community Wildfire Protection Plan Annex 9. Available at:
https://www.sccfd.org/wp-
content/uploads/documents/fire_prevention/CWPP/Annex_9_Town_of_Los_Gatos_2019.pdf.
Accessed January 28. 2022.
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The Jepson Herbarium (Jepson). 2020. The Jepson Online Interchange for California Floristics.
Available at: https://ucjeps.berkeley.edu/interchange/. Accessed July 22, 2020.
North, Malcolm. 2007. Riparian Zones Pose Severe Wildfire Threat. Published in California Forests.
Spring 2012. Available at: https://northlab.faculty.ucdavis.edu/wp-
content/uploads/sites/195/2019/03/Riparian-zone-severe-wildfire-California-Forests.pdf.
Accessed June 10, 2022.
Northwest Information Center (NWIC). 2020. California Historical Resources Information System,
Record Search, File No. 20-0332. Northwest Information Center, Sonoma State University.
Accessed September 18, 2018.
Regional Water Quality Control Board (RWQCB). 2022. GeoTracker.
https://geotracker.waterboards.ca.gov/. Accessed January 28, 2022.
Santa Clara County Fire Department (SCCFD). 2009. Standard Details & Specifications: Fire
Department Apparatus Access. Available at: https://www.sccfd.org/wp-
content/uploads/documents/fire_prevention/standards/2.4.6_fire_department_apparatus_access.p
df. Accessed July 28, 2020.
———. 2020a. Fire Suppression & Rescue. Available at: https://www.sccfd.org/emergency-response-
overview/fire-suppression-rescue. Accessed October 28, 2020.
———. 2020b. Facilities and Fire Stations. Available at: https://www.sccfd.org/about-sccfd/facilities-
and-fire-stations. Accessed October 28, 2020.
SWCA Environmental Consultants (SWCA). 2021. Vegetation Management Plan for the Town of Los
Gatos, Santa Clara County, California.
Town of Los Gatos. 1978. Los Gatos Hillside Specific Plan. Available at:
https://www.losgatosca.gov/1146/Los-Gatos-Hillside-Specific-Plan. Accessed October 21, 2020.
———. 1991. Town of Los Gatos Municipal Code: Chapter 16 - Noise. Available at:
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH16NO.
Accessed July 28, 2020.
———. 1996. Town of Los Gatos Municipal Code: Chapter 9 - Fire Prevention and Protection. Available
at:
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances?nodeId=CO_CH9FIPRPR.
Accessed July 28, 2020.
———. 2008. Town of Los Gatos Parks, Open Space and Trails Inventory. May 16. Available at:
https://www.losgatosca.gov/DocumentCenter/View/1072/Recreation-Inventory--Reduced-File-
Size?bidId=. Accessed December 1, 2020.
———. 2019a. Town of Los Gatos 2040 General Plan, Background Report. Public Draft. March.
Available at: http://losgatos2040.com/images/docs/lggpu_br_prd_web.pdf. Accessed September
18, 2020.
———. 2019b. Town of Los Gatos Very High Fire Hazard Areas Map. Available at:
https://www.losgatosca.gov/DocumentCenter/View/24122/Los-Gatos-WUI-and-State-VHFHA-
Map?bidId=. Accessed July 28, 2020.
Los Gatos Open Space Vegetation Management Plan
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83
———. 2020a. Ordinance 2301. Ordinance of the Town of Los Gatos Amending Chapter 9 (Fire
Prevention and Protection) of the Town Code Regarding Weed Abatement Regulations.
Available at: https://www.losgatosca.gov/DocumentCenter/View/24284/Ord-2301---Amend-
Chapter-9-Fire-Prevention-_-Protection-regarding-Weed-Ab. Accessed August 21, 2020.
______. 2020b. Town of Los Gatos Bike, Parks, and Trails Map & Guide. Town of Los Gatos Parks and
Public Works Department. Available at:
https://www.losgatosca.gov/DocumentCenter/View/13803/Bike-Parks-and-Trails-Map-
FINAL?bidId=. Accessed September 15, 2020.
______. 2022a. Town of Los Gatos 2040 General Plan. Available at:
http://losgatos2040.com/documents.html. Accessed August 10, 2023.
______. 2022b. Ordinance 2331. Town of Los Gatos Tree Protection Ordinance. Available at:
https://library.municode.com/ca/los_gatos/ordinances/code_of_ordinances?nodeId=1148802.
Accessed September 15, 2020.
______. 2023. Town of Los Gatos Code of Ordinances. Available at:
https://library.municode.com/ca/los_gatos/codes/code_of_ordinances. Accessed September 15,
2020.U.S. Fish and Wildlife Service (USFWS). 2022. National Wetland Inventory. Available at:
Wetlands Mapper | U.S. Fish & Wildlife Service (fws.gov). Accessed on July 22, 2020.
U.S. Geological Survey (USGS). 2011. Web Soil Survey. Available at: Web Soil Survey (usda.gov).
Accessed September 22. 2020.
APPENDIX A
CalVTP PEIR Addendum
Project-Specific
Mitigation Monitoring and Reporting Program
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-1
INTRODUCTION
The California Environmental Quality Act (CEQA) Guidelines require public agencies “to adopt a
reporting and monitoring program for changes to the project which it has adopted or made a condition of
project approval to mitigate or avoid significant effects on the environment.” A mitigation monitoring and
reporting program (MMRP) is required for approval of the proposed project outlined in the Project-
Specific Analysis (PSA). Standard Project Requirements (SPRs) and Mitigation Measures (MMs), which
are part of the program description, outlined in the California Vegetation Treatment Program (CalVTP)
Program Environmental Impact Report (PEIR), have been adopted. These SPRs and MMs have been
designed to avoid or mitigate significant environmental effects that were identified in the PEIR.
PURPOSE OF THE MMRP
This MMRP has been prepared to monitor the implementation of SPRs and MMs. The attached table
presents the text of each SPR and mitigation measure, the timing of its planned implementation, the
implementing entity, and the entity with monitoring responsibility. The numbering of SPRs and MMs
follows the numbering used in the PEIR. SPRs and MMs that are referenced more than once in the PSA
are not duplicated in the MMRP.
ROLES AND RESPONSIBILITIES
The project proponent (the Town of Los Gatos [Town]) is responsible for taking all actions necessary to
implement the SPRs and MMs described in this document. The project proponent is responsible for
administration of the project, including timing of mitigations, monitoring, and all project requirements.
The CEQA lead agency (the Town), will be responsible for verification of all mitigations and monitoring
efforts.
REPORTING
The project proponent will document the compliance of the proposed project with the required SPRs and
mitigation measures either by adapting the project-specific MMRP table or preparing a separate post-
project implementation report.
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-2
STANDARD PROJECT REQUIREMENTS AND MITIGATION
MEASURES CHECKLIST
• Applicable Standard Project Requirements and Mitigation Measures. The SPR or MMs
listed below are applicable to the initial treatment and/or treatment maintenance. A yes/no is
placed next to the initial treatment and treatment maintenance to indicate if it is applicable to that
stage of treatment. SPRs and MMs not applicable to initial or maintenance treatments were
removed from the table.
• Timing. This column identifies the time frame in which the SPR or MM will be implemented
(e.g., prior to treatment, during treatment, etc.).
• Implementing Entity. The implementing entity is the agency or organization responsible for
carrying out the requirement.
• Verifying/Monitoring Entity. The verifying/monitoring entity is the agency or organization
responsible for ensuring that the requirement is implemented. The verifying/monitoring entity
may be different from the implementing entity.
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-3
Standard Project Requirements Applicable? (Y/N) Timing
Implementing
Entity
Verifying/
Monitoring Entity
Compliance
Reporting
Administrative Standard Project Requirements
SPR AD-2 Delineate Protected Resources.
The project proponent will clearly define the boundaries of the treatment area and protected resources on maps for the treatment area and with highly-visible flagging or clear, existing landscape demarcations (e.g., edge of a roadway) prior to beginning any treatment to avoid disturbing the resource. “Protected Resources” refers to environmentally sensitive places within or adjacent to the treatment areas that would be avoided or protected to the extent feasible during planned treatment activities to sustain their natural qualities and processes. This work will be performed by a qualified person, as defined for the specific resource (e.g., qualified Registered Professional Forester or biologist). This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los
Gatos
Town of Los
Gatos
SPR AD-3: Consistency with Local Plans, Policies, and Ordinances.
The project proponent will design and implement the treatment in a manner
that is consistent with applicable local plans (e.g., general plans, Community Wildfire Protection Plans, CAL FIRE Unit Fire Plans), policies, and ordinances to the extent the project is subject to them. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos
SPR AD-5 Maintain Site Cleanliness.
If trash receptacles are used on-site, the project proponent will use fully covered trash receptacles with secure lids (wildlife proof) to contain all food, food scraps, food wrappers, beverages, and other worker generated miscellaneous trash. Remove all temporary non-biodegradable flagging, trash, debris, and barriers from the project site upon completion of project
activities. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los
Gatos
Town of Los
Gatos
SPR AD-6: Public Notifications for Treatment Projects.
One to three days prior to the commencement of a treatment activity, the
project proponent will post signs in a conspicuous location near the treatment area describing the activity and timing, and requesting persons in the area to contact a designated representative of the project proponent (contact information will be provided with the notice) if they have questions or concerns. This SPR applies to all treatment activities and all treatment types,
including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
1 to 3 days prior to the treatment
activities
Town of Los Gatos Town of Los Gatos
SPR AD-7: Provide Information on Proposed, Approved, and Completed
Treatment Projects.
For any vegetation treatment project using the CalVTP PEIR for CEQA
compliance, the project proponent will provide the information listed below to the Board or CAL FIRE during the proposed, approved, and completed
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to, during, and following treatment Town of Los Gatos Town of Los Gatos
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-4
Standard Project Requirements Applicable? (Y/N) Timing
Implementing
Entity
Verifying/
Monitoring Entity
Compliance
Reporting
stages of the project. The Board or CAL FIRE will make this information
available to the public via an online database or other mechanism.
Information on proposed projects (PSA in progress):
GIS data that include project location (as a point);
project size (typically acres);
treatment types and activities; and
contact information for a representative of the project proponent.
The project proponent will provide information on the proposed project to the Board or CAL FIRE as early as feasible in the planning phase. The project proponent will provide this information to the Board or CAL FIRE with sufficient lead time to allow those agencies to make the information available to the public no later than two weeks prior to project approval. The project proponent may also make information available to the public via other mechanisms (e.g., the proponent’s own website).
Information on approved projects (PSA complete):
A completed PSA Environmental Checklist;
A completed Mitigation Monitoring and Reporting Program (using Attachment A to the Environmental Checklist);
GIS data that include a polygon(s) of the project area, showing the extent of each treatment type included in the project (ecological restoration, fuel break, WUI fuel reduction).
Information on completed projects:
GIS data that include a polygon(s) of the treated area, showing the extent of each treatment type implemented (ecological restoration, fuel break, WUI fuel reduction)
A post-project implementation report (referred to by CAL FIRE as a
Completion Report) that includes
Size of treated area (typically acres);
Treatment types and activities;
Dates of work;
A list of the SPRs and mitigation measures that were implemented
Any explanations regarding implementation if required by SPRs and mitigation measures (e.g., explanation for feasibility determination required by SPR BIO-12; explanation for reduction of a no-disturbance buffer below the general minimum size described in Mitigation
Measures BIO-1a and BIO-2b).
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-5
Standard Project Requirements Applicable? (Y/N) Timing
Implementing
Entity
Verifying/
Monitoring Entity
Compliance
Reporting
Aesthetic and Visual Resource Standard Project Requirements
SPR AES-1 Vegetation Thinning and Edge Feathering.
The project proponent will thin and feather adjacent vegetation to break up or screen linear edges of the clearing and mimic forms of natural clearings as reasonable or appropriate for vegetation conditions. In general, thinning and feathering in irregular patches of varying densities, as well as a gradation of tall to short vegetation at the clearing edge, will achieve a natural transitional
appearance. The contrast of a distinct clearing edge will be faded into this transitional band. This SPR only applies to mechanical and manual treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During mechanical
and manual treatment activities
Town of Los Gatos Town of Los Gatos
SPR AES-2: Avoid Staging within Viewsheds.
The project proponent will store all treatment-related materials, including vehicles, vegetation treatment debris, and equipment, outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. The project proponent will also locate materials staging and storage
areas outside of the viewshed of public trails, parks, recreation areas, and roadways to the extent feasible. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR AES-3 Provide Vegetation Screening.
The project proponent will preserve sufficient vegetation within, at the edge of, or adjacent to treatment areas to screen views from public trails, parks, recreation areas, and roadways as reasonable or appropriate for vegetation conditions. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During design of treatment Town of Los Gatos Town of Los Gatos
Air Quality Standard Project Requirements
SPR AQ-1: Comply with Air Quality Regulations.
The project proponent will comply with the applicable air quality requirements of air districts within whose jurisdiction the project is located. This SPR applies to all treatment activities and all treatment types, including treatment
maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR AQ-4 Minimize Dust.
To minimize dust during treatment activities, the project proponent will implement the following measures:
Limit the speed of vehicles and equipment traveling on unpaved areas to
15 miles per hour to reduce fugitive dust emissions, in accordance with the California Air Resources Board (CARB) Fugitive Dust protocol.
If road use creates excessive dust, the project proponent will wet appurtenant, unpaved, dirt roads using water trucks or treat roads with a
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
Town of Los Gatos Vegetation Management Plan Project CalVTP Project-Specific Analysis
A-6
Standard Project Requirements Applicable? (Y/N) Timing
Implementing
Entity
Verifying/
Monitoring Entity
Compliance
Reporting
non-toxic chemical dust suppressant (e.g., emulsion polymers, organic
material) during dry, dusty conditions. Any dust suppressant product used will be environmentally benign (i.e., non-toxic to plants and will not negatively impact water quality) and its use will not be prohibited by ARB, EPA, or the State Water Resources Control Board (SWRCB). The project proponent will not over-water exposed areas such that the water results in
runoff. The type of dust suppression method will be selected by the project proponent based on soil, traffic, site-specific conditions, and air quality regulations.
Remove visible dust, silt, or mud tracked-out on to public paved roadways where sufficient water supplies and access to water is available. The project proponent will remove dust, silt, and mud from vehicles at the conclusion of each workday, or at a minimum of every 24 hours for continuous treatment activities, in accordance with Vehicle Code Section 23113.
Suspend ground-disturbing treatment activities, including land clearing
and bulldozer lines, when there is visible dust transport (particulate pollution) outside the treatment boundary, if the particulate emissions may “cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or
have a natural tendency to cause, injury or damage to business or property,” per Health and Safety Code Section 41700.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
SPR AQ-5: Avoid Naturally Occurring Asbestos.
The project proponent will avoid ground-disturbing treatment activities in areas identified as likely to contain naturally occurring asbestos (NOA) per maps and guidance published by the California Geological Survey, unless an Asbestos Dust Control Plan (17 CCR Section 93105) is prepared and
approved by the air district(s) with jurisdiction over the treatment area. Any NOA-related guidance provided by the applicable air district will be followed. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos
Archaeological, Historical, and Tribal Cultural Resources Standard Project Requirements
SPR CUL-1: Conduct Record Search.
An archaeological and historical resource record search will be conducted per the applicable state or local agency procedures. Instead of conducting a new search, the project proponent may use recent record searches containing the treatment area requested by a landowner or other public agency in accordance applicable agency guidance. This SPR applies to all
treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los
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SPR CUL-2: Contact Geographically Affiliated Native American Tribes.
The project proponent will obtain the latest Native American Heritage Commission (NAHC) provided Native Americans Contact List. Using the appropriate Native Americans Contact List, the project proponent will notify the California Native American Tribes in the counties where the treatment activity is located. The notification will contain the following:
A written description of the treatment location and boundaries. Brief narrative of the treatment objectives.
A description of the activities used (e.g., mastication) and associated acreages.
A map of the treatment area at a sufficient scale to indicate the spatial extent of activities.
A request for information regarding potential impacts to cultural resources from the proposed treatment.
A detailed description of the depth of excavation, if ground disturbance is expected.
In addition, the project proponent will contact the NAHC for a review of their Sacred Lands File. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los
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SPR-CUL-3: Pre-field Research.
The project proponent will conduct research prior to implementing treatments as part of the cultural resource investigation. The purpose of this research is to properly inform survey design, based on the types of resources likely to be encountered within the treatment area, and to be prepared to interpret, record, and evaluate these findings within the context of local history and
prehistory. The qualified archaeologist and/or archaeologically-trained resource professional will review records, study maps, read pertinent ethnographic, archaeological, and historical literature specific to the area being studied, and conduct other tasks to maximize the effectiveness of the survey. This SPR applies to all treatment activities and treatment types,
including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los
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SPR CUL-4: Archaeological Surveys.
The project proponent will coordinate with an archaeologically-trained resource professional and/or qualified archaeologist to conduct a site-specific
survey of the treatment area. The survey methodology (e.g., pedestrian survey, subsurface investigation) depends on whether the area has a low, moderate, or high sensitivity for resources, which is based on whether the records search, pre-field research, and/or Native American consultation identifies archaeological or historical resources near or within the treatment
area. A survey report will be completed for every cultural resource survey completed. The specific requirements will comply with the applicable state or
Initial Treatment: Y
Treatment
Maintenance: Y
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local agency procedures. This SPR applies to all treatment activities and
treatment types, including treatment maintenance.
SPR CUL-5: Treatment of Archaeological Resources.
If cultural resources are identified within a treatment area, and cannot be avoided, a qualified archaeologist will notify the culturally affiliated tribe(s)
based on information provided by NAHC and assess, whether an archaeological find qualifies as a unique archaeological resource, an historical resource, or in coordination with said tribe(s), as a tribal cultural resource. The project proponent, in consultation with culturally affiliated tribe(s), will develop effective protection measures for important cultural
resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging effects to cultural resources will not occur. These protection measures will be written in clear, enforceable language, and will be included in the survey report in
accordance with applicable state or local agency procedures. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to and during treatment Town of Los Gatos Town of Los Gatos
SPR CUL-6 Treatment of Tribal Cultural Resources.
The project proponent, in consultation with the culturally affiliated tribe(s), will develop effective protection measures for important tribal cultural resources located within treatment areas. These measures may include adjusting the treatment location or design to entirely avoid cultural resource locations or changing treatment activities so that damaging effects to cultural resources
will not occur. The project proponent will provide the tribe(s) the opportunity to submit comments and participate in consultation to resolve issues of concern. The project proponent will defer implementing the treatment until the tribe approves protection measures, or if agreement cannot be reached after a good-faith effort, the proponent determines that any or all feasible
measures have been implemented, where feasible, and the resource is either avoided or protected. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to and during treatment Town of Los Gatos Town of Los Gatos
SPR CUL-7: Avoid Built Historical Resources.
If the records search identifies built historical resources, as defined in
Section 15064.5 of the State CEQA Guidelines, the project proponent will avoid these resources. Within a buffer of 100 feet of the built historical resource, there will be no mechanical treatment activities Buffers less than 100 feet for built historical resources will only be used after consultation with and receipt of written approval from a qualified archaeologist. If the records search does not identify known historical resources in the treatment area, but structures (i.e., buildings, bridges, roadways) over 50 years old that have not been evaluated for historic significance are present in the treatment area,
Initial Treatment: Y
Treatment Maintenance: Y
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they will similarly be avoided. This SPR applies to all treatment activities and
treatment types, including treatment maintenance.
SPR CUL-8: Cultural Resource Training.
The project proponent will train all crew members and contractors implementing treatment activities on the protection of sensitive
archaeological, historical, or tribal cultural resources. Workers will be trained to halt work if archaeological resources are encountered on a treatment site and the treatment method consists of physical disturbance of land surfaces (e.g., soil disturbance). This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to and during treatment Town of Los Gatos Town of Los Gatos
Biological Resources Standard Project Requirements
SPR BIO-1: Review and Survey Project-Specific Biological Resources.
The project proponent will require a qualified RPF or biologist to conduct a data review and reconnaissance-level survey prior to treatment, no more than one year prior to the submittal of the PSA, and no more than one year between completion of the PSA and implementation of the treatment project.
The data reviewed will include the biological resources setting, species and sensitive natural communities tables, and habitat information in this PEIR for the ecoregion(s) where the treatment will occur. It will also include review of the best available, current data for the area, including vegetation mapping data, species distribution/range information, CNDDB, California Native Plant
Society (CNPS) Inventory of Rare and Endangered Plants of California, relevant BIOS queries, and relevant general and regional plans.
Reconnaissance-level biological surveys will be general surveys that include visual and auditory inspection for biological resources to help determine the environmental setting of a project site. The qualified surveyor will 1.) identify
and document sensitive resources, such as riparian or other sensitive habitats, sensitive natural community, wetlands, or wildlife nursery site or habitat (including bird nests), and 2.) assess the suitability of habitat for special-status plant and animal species. The surveyor will also record any incidental wildlife observations. For each treatment project, habitat
assessments will be completed at a time of year that is appropriate for identifying habitat and no more than one year prior to the submittal of the PSA, unless it can be demonstrated in the PSA that habitat assessments older than one year remain valid (e.g., site conditions are unchanged and no treatment activity has occurred since the assessment). If more than one year
passes between completion of the PSA and initiation of the treatment project, the project proponent will verify the continued accuracy of the PSA prior to beginning the treatment project by reviewing for any data updates and/or visiting the site to verify conditions. Based on the results of the data review and reconnaissance-level survey, the project proponent, in consultation with
Initial Treatment: Y
Treatment Maintenance: Y
Conduct data review and reconnaissance-level survey prior to treatment projects
and no more than 1 year prior to submittal of the PSA for each treatment project
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a qualified RPF or biologist, will determine which one of the following best characterizes the treatment:
1. Suitable Habitat Is Present but Adverse Effects Can Be Clearly
Avoided. If, based on the data review and reconnaissance-level survey,
the qualified RPF or biologist determines that suitable habitat for sensitive biological resources is present but adverse effects on the suitable habitat can clearly be avoided through one of the following methods, the avoidance mechanism will be implemented prior to initiating treatment and will remain in effect throughout the treatment:
a. by physically avoiding the suitable habitat, or
b. by conducting treatment outside of the season when a sensitive resource could be present within the suitable habitat or outside the season of sensitivity (e.g., outside of special-status bird nesting season, during dormant season of sensitive annual or geophytic plant species, or outside of maternity and rearing season at wildlife nursery sites).
c. Physical avoidance will include flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway) to delineate the boundary of the avoidance area around the suitable habitat. For physical avoidance, a buffer may be implemented as determined
necessary by the qualified RPF or biologist.
2. Suitable Habitat is Present and Adverse Effects Cannot Be Clearly
Avoided. Further review and surveys will be conducted to determine presence/absence of sensitive biological resources that may be affected, as described in the SPRs below. Further review may include contacting USFWS, NOAA Fisheries, CDFW, CNPS, or local resource agencies as necessary to determine the potential for special-status species or other sensitive biological resources to be affected by the treatment activity. Focused or protocol-level surveys will be conducted as necessary to determine presence/absence. If protocol surveys are conducted, survey
procedures will adhere to methodologies approved by resource agencies and the scientific community, such as those that are available on the CDFW webpage at: https://www.wildlife.ca.gov/Conservation/Survey-Protocols. Specific survey requirements are addressed for each resource type in relevant SPRs (e.g., additional survey requirements are presented
for special-status plants in SPR BIO-7).
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
SPR BIO-2: Require Biological Resource Training for Workers.
The project proponent will require crew members and contractors to receive training from a qualified RPF or biologist prior to beginning a treatment project. The training will describe the appropriate work practices necessary to effectively implement the biological SPRs and mitigation measures and to comply with the applicable environmental laws and regulations. The training
Initial Treatment: Y
Treatment Maintenance: Y
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will include the identification, relevant life history information, and avoidance
of pertinent special-status species; identification and avoidance of sensitive natural communities and habitats with the potential to occur in the treatment area; impact minimization procedures; and reporting requirements. The training will instruct workers when it is appropriate to stop work and allow wildlife encountered during treatment activities to leave the area unharmed
and when it is necessary to report encounters to a qualified RPF, biologist, or biological technician. The qualified RPF, biologist, or biological technician will immediately contact CDFW or USFWS, as appropriate, if any wildlife protected by the California Endangered Species Act (CESA) or Federal Endangered Species Act (ESA) is encountered and cannot leave the site on its own (without being handled). This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Sensitive Natural Communities and Other Sensitive Habitats
SPR BIO-3: Survey Sensitive Natural Communities and Other Sensitive
Habitats.
If SPR BIO-1 determines that sensitive natural communities or sensitive
habitats may be present and adverse effects cannot be avoided, the project proponent will:
require a qualified RPF or biologist to perform a protocol-level survey following the CDFW “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural
Communities” (current version dated March 20, 2018) of the treatment area prior to the start of treatment activities for sensitive natural communities and sensitive habitats. Sensitive natural communities will be identified using the best means possible, including keying them out using the most current edition of A Manual of California Vegetation (including
updated natural communities data at http://vegetation.cnps.org/), or referring to relevant reports (e.g., reports found on the VegCAMP website).
map and digitally record, using a Global Positioning System (GPS), the limits of any potential sensitive habitat and sensitive natural community
identified in the treatment area.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos
SPR BIO-4: Design Treatment to Avoid Loss or Degradation of Riparian
Habitat Function.
Project proponents, in consultation with a qualified RPF or qualified biologist, will design treatments in riparian habitats to retain or improve habitat functions by implementing the following within riparian habitats:
Retain at least 75 percent of the overstory and 50 percent of the understory canopy of native riparian vegetation within the limits of riparian
Initial Treatment: Y
Treatment Maintenance: Y
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habitat identified and mapped during surveys conducted pursuant to SPR BIO-3. Native riparian vegetation will be retained in a well distributed multi-storied stand composed of a diversity of species similar to that found before the start of treatment activities.
Treatments will be limited to removal of uncharacteristic fuel loads (e.g., removing dead or dying vegetation), trimming/limbing of woody species as necessary to reduce ladder fuels, and select thinning of vegetation to restore densities that are characteristic of healthy stands of the riparian vegetation types characteristic of the region. This includes hand removal (or mechanized removal where topography allows) of dead or dying riparian trees and shrubs, invasive plant removal, selective thinning, and removal of encroaching upland species.
Removal of large, native riparian hardwood trees (e.g., willow, ash, maple, oak, alder, sycamore, cottonwood) will be minimized to the extent feasible
and 75 percent of the pretreatment native riparian hardwood tree canopy will be retained. Because tree size varies depending on vegetation type present and site conditions, the tree size retention parameter will be determined on a site-specific basis depending on vegetation type present and setting; however, live, healthy, native trees that are considered large
for that type of tree and large relative to other trees in that location will be retained. A scientifically-based, project-specific explanation substantiating the retention size parameter for native riparian hardwood tree removal will be provided in the Biological Resources Discussion of the PSA. Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, presence of sufficient seed trees, light
availability, and changes in stream shading may inform the tree size retention requirements.
Removed trees will be felled away from adjacent streams or waterbodies and piled outside of the riparian vegetation zone (unless there is an
ecological reason to do otherwise that is approved by applicable regulatory agencies, such as adding large woody material to a stream to enhance fish habitat, e.g., see Accelerated Wood Recruitment and Timber Operations: Process Guidance from the California Timber Harvest Review Team Agencies and National Marine Fisheries Service).
Vegetation removal that could reduce stream shading and increase
stream temperatures will be avoided.
Ground disturbance within riparian habitats will be limited to the minimum necessary to implement effective treatments. This will consist of the minimum disturbance area necessary to reduce hazardous fuels and return the riparian community to a natural fire regime (i.e., Condition Class 1) considering historic fire return intervals, climate change, and land use constraints.
Only hand application of herbicides approved for use in aquatic environments will be allowed and only during low-flow periods or when
seasonal streams are dry.
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The project proponent will notify CDFW when required by California Fish and Game Code Section 1602 prior to implementing any treatment activities in riparian habitats. Notification will identify the treatment activities, map the vegetation to be removed, identify the impact
avoidance identification methods to be used (e.g., flagging), and appropriate protections for the retention of shaded riverine habitat, including buffers and other applicable measures to prevent erosion into the waterway.
In consideration of spatial variability of riparian vegetation types and condition and consistent with California Forest Practice Rules Section 916.9(v) (February 2019 version), a different set of vegetation retention standards and protection measures from those specified in the above bullets may be implemented on a site-specific basis if the qualified RPF and the project proponent demonstrate through substantial evidence that
alternative design measures provide a more effective means of achieving the treatment goals objectives and would result in effects to the Beneficial Functions of Riparian Zones equal or more favorable than those expected to result from application of the above measures. Deviation from the above design specifications, different protection measures and design
standards will only be approved when the treatment plan incorporates an evaluation of beneficial functions of the riparian habitat and with written concurrence from CDFW.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
SPR BIO-5: Avoid Environmental Effects of Type Conversion and
Maintain Habitat Function in Chaparral and Coastal Sage Scrub.
The project proponent will design treatment activities to avoid type conversion where native coastal sage scrub and chaparral are present. An ecological definition of type conversion is used in the CalVTP PEIR for assessment of environmental effects: a change from a vegetation type
dominated by native shrub species that are characteristic of chaparral and coastal sage scrub vegetation alliances to a vegetation type characterized predominantly by weedy herbaceous cover or annual grasslands. For the PEIR, type conversion is considered in terms of habitat function, which is defined here as the arrangement and capability of habitat features to provide
refuge, food source, and reproduction habitat to plants and animals, and thereby contribute to the conservation of biological and genetic diversity and evolutionary processes (de Groot et al. 2002). Some modification of habitat characteristics may occur provided habitat function is maintained (i.e., the location, essential habitat features, and species supported are not
substantially changed).
During the reconnaissance-level survey required in SPR BIO-1, a qualified RPF or biologist will identify chaparral and coastal sage scrub vegetation to the alliance level and determine the condition class and fire return interval
Initial Treatment: Y
Treatment Maintenance: Y
During design of
treatment
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departure of the chaparral and/or coastal sage scrub present in each treatment area.
For all treatment types in chaparral and coastal sage scrub, the project proponent, in consultation with a qualified RPF or qualified biologist will:
Develop a treatment design that avoids environmental effects of type conversion in chaparral and coastal sage scrub vegetation alliances, which will include evaluating and determining the appropriate spatial scale
at which the proponent would consider type conversion, and substantiating its appropriateness. The project proponent will demonstrate with substantial evidence that the habitat function of chaparral and coastal sage scrub would be at least maintained within the identified spatial scale at which type conversion is evaluated for the specific treatment project.
Consideration of factors such as site hydrology, erosion potential, suitability of wildlife habitat, spatial needs of sensitive species, presence of sufficient seed plants and nurse plants, light availability, and edge effects may inform the determination of an appropriate spatial scale.
The treatment design will maintain a minimum percent cover of mature
native shrubs within the treatment area to maintain habitat function; the appropriate percent cover will be identified by the project proponent in the development of treatment design and be specific to the vegetation alliances that are present in the identified spatial scale used to evaluate type conversion. Mature native shrubs that are retained will be distributed
contiguously or in patches within the stand. If the stand consists of multiple age classes, patches representing a range of middle to old age classes will be retained to maintain and improve heterogeneity, to the extent needed to avoid type conversion.
These SPR requirements apply to all treatment activities and all treatment
types, including treatment maintenance.
Additional measures will be applied to ecological restoration treatment types:
For ecological restoration treatment types, complete removal of the mature shrub layer will not occur in native chaparral and coastal sage scrub vegetation types.
Ecological restoration treatments will not be implemented in vegetation types that are within their natural fire return interval (i.e., time since last burn is less than the average time listed as the fire return interval range in Table 3.6-1) unless the project proponent demonstrates with substantial evidence that the habitat function of chaparral and coastal sage scrub
would be improved.
A minimum of 35 percent relative cover of existing shrubs and associated native vegetation will be retained at existing densities in patches distributed in a mosaic pattern within the treated area or the shrub canopy will be thinned by no more than 20 percent from baseline density (i.e., if
baseline shrub canopy density is 60 percent, post treatment shrub canopy density will be no less than 40 percent). A different percent relative cover
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can be retained if the project proponent demonstrates with substantial evidence that alternative treatment design measures would result in
effects on the habitat function of chaparral and coastal sage scrub that are equal or more favorable than those expected to result from application of the above measures.
Biological considerations that may inform a deviation from the minimum 35 percent relative cover retention include but are not limited to soil
moisture requirements, increased soil temperatures, changes in light/shading, presence of sufficient seed plants and nurse plants, erosion potential, and site hydrology.
If the stand within the treatment area consists of multiple age classes, patches representing a range of middle to old age classes will be retained
to maintain and improve heterogeneity.
These SPR requirements apply to all treatment activities and only the ecosystem restoration treatment type, including treatment maintenance.
A determination of compliance with the SB 1260 prohibition of type conversion in chaparral and coastal sage scrub is a statutory issue separate
from CEQA compliance that may involve factors additional to the ecological definition and habitat functions presented in the PEIR, such as geographic context. It is beyond the legal scope of the PEIR to define SB 1260 type conversion and statutory compliance. The project proponent, acting as lead agency for the proposed later treatment project, will be responsible for
defining type conversion in the context of the project and making the finding that type conversion would not occur, as required by SB 1260. The project proponent will determine its criteria for defining and avoiding type conversion and, in making its findings, may draw upon information presented in this PEIR.
SPR BIO-6: Prevent Spread of Plant Pathogens.
When working in sensitive natural communities, riparian habitats, or oak woodlands that are at risk from plant pathogens (e.g., Ione chaparral, blue oak woodland), the project proponent will implement the following best
management practices to prevent the spread of Phytopthora and other plant pathogens (e.g., pitch canker (Fusarium), goldspotted oak borer, shot hole borer, bark beetle):
clean and sanitize vehicles, equipment, tools, footwear, and clothes before arriving at a treatment site and when leaving a contaminated site,
or a site in a county where contamination is a risk;
include training on Phytopthora diseases and other plant pathogens in the worker awareness training;
minimize soil disturbance as much as possible by limiting the number of vehicles, avoiding off-road travel as much as possible, and limiting use of
mechanized equipment;
Initial Treatment: Y
Treatment Maintenance: Y
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minimize movement of soil and plant material within the site, especially
between areas with high and low risk of contamination;
clean soil and debris from equipment and sanitize hand tools, buckets, gloves, and footwear when moving from high risk to low risk areas or between widely separated portions of a treatment area; and
follow the procedures listed in Guidance for plant pathogen prevention
when working at contaminated restoration sites or with rare plants and sensitive habitat (Working Group for Phytoptheras in Native Habitats 2016).
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Special-Status Plants
SPR BIO-7: Survey for Special-Status Plants.
If SPR BIO-1 determines that suitable habitat for special-status plant species is present and cannot be avoided, the project proponent will require a qualified RPF or botanist to conduct protocol-level surveys for special-status plant species with the potential to be affected by a treatment prior to initiation
of the treatment. The survey will follow the methods in the current version of CDFW’s “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities.”
Surveys to determine the presence or absence of special-status plant species will be conducted in suitable habitat that could be affected by the
treatment and timed to coincide with the blooming or other appropriate phenological period of the target species (as determined by a qualified RPF or botanist), or all species in the same genus as the target species will be assumed to be special- status.
If potentially occurring special-status plants are listed under CESA or ESA,
protocol-level surveys to determine presence/absence of the listed species will be conducted in all circumstances, unless determined otherwise by CDFW or USFWS.
For other special-status plants not listed under CESA or ESA, as defined in Section 3.6.1 of this PEIR, surveys will not be required under the following
circumstances:
If protocol-level surveys, consisting of at least two survey visits (e.g., early blooming season and later blooming season) during a normal weather year, have been completed in the 5 years before implementation of the treatment project and no special- status plants were found, and no
treatment activity has occurred following the protocol-level survey, treatment may proceed without additional plant surveys.
If the target special-status plant species is an herbaceous annual, stump-sprouting, or geophyte species, the treatment may be carried out during the dormant season for that species or when the species has completed
Initial Treatment: Y
Treatment Maintenance: Y
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its annual lifecycle without conducting presence/absence surveys provided the treatment will not alter habitat or destroy seeds, stumps, or roots, rhizomes, bulbs and other underground parts in a way that would make it unsuitable for the target species to reestablish following
treatment.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Environmentally Sensitive Habitat Areas
Invasive Plants and Wildlife
SPR BIO-9: Prevent Spread of Invasive Plants, Noxious Weeds, and
Invasive Wildlife.
The project proponent will take the following actions to prevent the spread of invasive plants, noxious weeds, and invasive wildlife (e.g., New Zealand
mudsnail):
clean clothing, footwear, and equipment used during treatments of soil, seeds, vegetative matter, other debris or seed-bearing material, or water (e.g., rivers, streams, creeks, lakes) before entering the treatment area or when leaving an area with infestations of invasive plants, noxious weeds,
or invasive wildlife;
for all heavy equipment and vehicles traveling off road, pressure wash, if feasible, or otherwise appropriately decontaminate equipment at a designated weed-cleaning station prior to entering the treatment area from an area with infestations of invasive plants, noxious weeds, or invasive wildlife. Anti-fungal wash agents will be specified if the equipment has been exposed to any pathogen that could affect native species;
inspect all heavy equipment, vehicles, tools, or other treatment- related materials for sand, mud, or other signs that weed seeds or propagules could be present prior to use in the treatment area. If the equipment is not
clean, the qualified RPF or biological technician will deny entry to the work areas;
stage equipment in areas free of invasive plant infestations unless there are no uninfested areas present within a reasonable proximity to the treatment area;
identify significant infestations of invasive plant species (i.e., those rated
as invasive by Cal-IPC or designated as noxious weeds by California Department of Food and Agriculture) during reconnaissance-level surveys and target them for removal during treatment activities. Treatment methods will be selected based on the invasive species present and may include herbicide application, manual or mechanical treatments, and/or herbivory, and will be designed to maximize success in killing or removing the invasive plants and preventing reestablishment based on the life
Initial Treatment: Y
Treatment Maintenance: Y
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history characteristics of the invasive plant species present. Treatments will be focused on removing invasive plant species that cause ecological harm to native vegetation types, especially those that can alter fire cycles;
treat invasive plant biomass onsite to eliminate seeds and propagules and
prevent reestablishment or dispose of invasive plant biomass offsite at an appropriate waste collection facility (if not kept on site); transport invasive plant materials in a closed container or bag to prevent the spread of propagules during transport; and
implement Fire and Fuel Management BMPs outlined in the “Preventing the Spread of Invasive Plants: Best Management Practices for Land Mangers” (Cal-IPC 2012, or current version).
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Wildlife
SPR BIO-10: Survey for Special-Status Wildlife and Nursery Sites.
If SPR BIO-1 determines that suitable habitat for special-status wildlife species or nurseries of any wildlife species is present and cannot be avoided, the project proponent will require a qualified RPF or biologist to conduct focused or protocol-level surveys for special-status wildlife species or nursery sites (e.g., bat maternity roosts, deer fawning areas, heron or
egret rookeries, monarch overwintering sites) with potential to be directly or indirectly affected by a treatment activity. The survey area will be determined by a qualified RPF or biologist based on the species and habitats and any recommended buffer distances in agency protocols.
The qualified RPF or biologist will determine if following an established protocol is required, and the project proponent may consult with CDFW
and/or USFWS for technical information regarding appropriate survey protocols. Unless otherwise specified in a protocol, the survey will be conducted no more than 14 days prior to the beginning of treatment activities. Focused or protocol surveys for a special-status species with potential to occur in the treatment area may not be required if presence of the species is assumed.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
No more than 14 days prior to
treatment projects
Town of Los Gatos Town of Los Gatos, CDFW,
and/or USFWS
SPR BIO-11: Install Wildlife-Friendly Fencing (Prescribed Herbivory).
If temporary fencing is required for prescribed herbivory treatment, a wildlife-friendly fencing design will be used. The project proponent will require a qualified RPF or biologist to review and approve the design before installation to ensure that minimize the risk of wildlife entanglement is low. The fencing design will meet the following standards:
Initial Treatment: Y
Treatment Maintenance: Y
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Minimize the chance of wildlife entanglement by avoiding barbed wire, loose or broken wires, or any material that could impale or snag a leaping animal; and, if feasible, keeping electric netting-type fencing electrified at all times or laid down while not in use.
Charge temporary electric fencing with intermittent pulse energizers; continuous output fence chargers will not be permitted.
Allow wildlife to jump over easily without injury by installing fencing that can flex as animals pass over it and installing the top wire low enough (no more than approximately 40 inches high on flat ground) to allow adult ungulates to jump over it. The determination of appropriate fence height will consider slope, as steep slopes are more difficult for wildlife to pass.
Be highly visible to birds and mammals by using high-visibility tape or wire, flagging, or other markers.
This SPR applies only to prescribed herbivory and all treatment types, including treatment maintenance.
SPR BIO-12: Protect Common Nesting Birds, Including Raptors.
The project proponent will schedule treatment activities to avoid the active nesting season of common native bird species, including raptors, that could be present within or adjacent to the treatment site, if feasible. Common
native birds are species not otherwise treated as special status in the CalVTP PEIR. The active nesting season will be defined by the qualified RPF or biologist.
If active nesting season avoidance is not feasible, a qualified RPF or biologist will conduct a survey for common nesting birds, including raptors.
Existing records (e.g., CNDDB, eBird database, State Wildlife Action Plan) should be reviewed in advance of the survey to identity the common nesting birds, including raptors, that are known to occur in the vicinity of the treatment site. The survey area will encompass reasonably accessible areas of the treatment site and the immediately surrounding vicinity viewable from
the treatment site. The survey area will be determined by a qualified RPF or biologist, based on the potential species in the area, location of suitable nesting habitat, and type of treatment. For vegetation removal or project activities that would occur during the nesting season, the survey will be conducted at a time that balances the effectiveness of detecting nests and
the reasonable consideration of potential avoidance strategies. Typically, this timeframe would be up to 3 weeks before treatment. The survey will occur in a single survey period of sufficient duration to reasonably detect nesting birds, including raptors, typically one day for most treatment projects (depending on the size, configuration, and vegetation density in the
treatment site), and conducted during the active time of day for target species, typically close to dawn and/or dusk. The survey may be conducted concurrently with other biological surveys, if they are required by other SPRs. Survey methods will be tailored by the qualified RPF or biologist to site and habitat conditions, typically involving walking throughout the survey area,
Initial Treatment: Y
Treatment Maintenance: Y
Conduct a survey for common nesting birds (if needed) at a time that
balances the effectiveness of detecting nests and the reasonable consideration of
potential avoidance strategies (typically, up to 3 weeks before treatment); if an active nest is
observed, implement avoidance strategies prior to and during
treatment projects
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visually searching for nests and birds exhibiting behavior that is typical of
breeding (e.g., delivering food).
If an active nest is observed (i.e., presence of eggs and/or chicks) or determined to likely be present based on nesting bird behavior, the project proponent will implement a feasible strategy to avoid disturbance of active nests, which may include, but is not limited to, one or more of the following:
Establish Buffer. The project proponent will establish a temporary, species-appropriate buffer around the nest sufficient to reasonably expect that breeding would not be disrupted.
Treatment activities will be implemented outside of the buffer. The buffer location will be determined by a qualified RPF or biologist. Factors to be considered for determining buffer location will include: presence of natural buffers provided by vegetation or topography, nest height above ground, baseline levels of noise and human activity, species sensitivity, and expected treatment activities. Nests of common birds within the buffer need not be monitored during treatment. However, buffers will be
maintained until young fledge or the nest becomes inactive, as determined by the qualified RPF, biologist, or biological technician.
Modify Treatment. The project proponent will modify the treatment in the vicinity of an active nest to avoid disturbance of active nests (e.g., by implementing manual treatment methods, rather than mechanical
treatment methods). Treatment modifications will be determined by the project proponent in coordination with the qualified RPF or biologist.
Defer Treatment. The project proponent will defer the timing of treatment in the portion(s) of the treatment site that could disturb the active nest. If this avoidance strategy is implemented, treatment activity will not
commence until young fledge or the nest becomes inactive, as determined by the qualified RPF, biologist, or biological technician.
Feasible actions will be taken by the project proponent to avoid loss of common native bird nests. The feasibility of implementing the avoidance strategies will be determined by the project proponent based on whether
implementation of this SPR will preclude completing the treatment project within the reasonable period of time necessary to meet CalVTP program objectives, including, but not limited to, protection of vulnerable communities.
Considerations may include limitations on the presence of environmental and atmospheric conditions necessary to execute treatment prescriptions. If it is
infeasible to avoid loss of common bird nests (not including raptor nests), the project proponent will document the reasons implementation of the avoidance strategies is infeasible in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any change in the feasibility of avoidance strategies from those explained in the PSA, this will
be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).
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The following avoidance strategies may also be considered together with or
in lieu of other actions for implementation by a project proponent to avoid disturbance to raptor nests:
Monitor Active Raptor Nest During Treatment. A qualified RPF, biologist, or biological technician will monitor an active raptor nest during treatment activities to identify signs of agitation, nest defense, or other
behaviors that signal disturbance of the active nest is likely (e.g., standing up from a brooding position, flying off the nest). If breeding raptors are showing signs of nest disturbance, one of the other avoidance strategies (establish buffer, modify treatment or defer treatment) will be implemented or a pause in the treatment activity will occur until the disturbance behavior ceases.
Retention of Raptor Nest Trees. Trees with visible raptor nests, whether occupied or not, will be retained.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Geology, Soils, and Mineral Resource Standard Project Requirements
SPR GEO-1: Suspend Disturbance during Heavy Precipitation.
The project proponent will suspend mechanical, prescribed herbivory, and herbicide treatments if the National Weather Service forecast is a “chance” (30 percent or more) of rain within the next 24 hours. Activities that cause mechanical soil disturbance may resume when precipitation stops and soils
are no longer saturated (i.e., when soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur). Indicators of saturated soil conditions may include, but are not limited to: (1) areas of ponded water, (2) pumping of fines from the soil or road surfacing, (3) loss of bearing strength resulting in the deflection of soil or road surfaces under a
load, such as the creation of wheel ruts, (4) spinning or churning of wheels or tracks that produces a wet slurry, or (5) inadequate traction without blading wet soil or surfacing materials. This SPR applies only to mechanical, prescribed herbivory, and herbicide treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment projects, if there is a “chance” (30% or more) of rain within the next 24 hours
Town of Los Gatos Town of Los Gatos
SPR GEO-2: Limit High Ground Pressure Vehicles.
The project proponent will limit heavy equipment that could cause soil disturbance or compaction to be driven through treatment areas when soils are wet and saturated to avoid compaction and/or damage to soil structure.
Saturated soil means that soil and/or surface material pore spaces are filled with water to such an extent that runoff is likely to occur. If use of heavy equipment is required in saturated areas, other measures such as operating on organic debris, using low ground pressure vehicles, or operating on frozen soils/snow covered soils will be implemented to minimize soil
compaction. Existing compacted road surfaces are exempted as they are
Initial Treatment: Y
Treatment Maintenance: Y
During treatment projects, if there is a “chance” (30% or more) of rain within
the next 24 hours
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already compacted from use. This SPR applies only to mechanical treatment
activities and all treatment types, including treatment maintenance.
SPR GEO-3: Stabilize Disturbed Soil Areas.
The project proponent will stabilize soil disturbed during mechanical and prescribed herbivory treatments that result in exposure of bare soil over 50
percent or more of the treatment area with mulch or equivalent immediately after treatment activities, to the maximum extent practicable, to minimize the potential for substantial sediment discharge. If mechanical or prescribed herbivory treatment activities could result in substantial sediment discharge from soil disturbed by machinery, animal hooves, or being bare, organic
material from mastication or mulch will be incorporated onto at least 75 percent of the disturbed soil surface where the soil erosion hazard is moderate or high, and 50 percent of the disturbed soil surface where soil erosion hazard is low to help prevent erosion. Where slash mulch is used, it will be packed into the ground surface with heavy equipment so that it is
sufficiently in contact with the soil surface. This SPR only applies to mechanical and prescribed herbivory that result in exposure of bare soil over 50 percent of the project area treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
During manual, mechanical, and prescribed
herbivory, activities that result in exposure of bare soil over 50% or more of the
treatment area
Town of Los Gatos Town of Los Gatos
SPR GEO-4: Erosion Monitoring.
The project proponent will inspect treatment areas for the proper implementation of erosion control SPRs and mitigations prior to the rainy season. If erosion control measures are not properly implemented, they will be remediated prior to the first rainfall event per SPR GEO-3 and GEO-8.
Additionally, the project proponent will inspect for evidence of erosion after the first large storm or rainfall event (i.e., ≥ 1.5 inches in 24 hours) as soon as is feasible after the event. Any area of erosion that will result in substantial sediment discharge will be remediated within 48 hours per the methods stated in SPRs GEO-3 and GEO-8. This SPR applies only to mechanical and
prescribed herbivory treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Inspect treatment areas for the proper implementation of erosion control SPRs and MMs
prior to the rainy season; if erosion control measures are not properly implemented,
remediate prior to the first rainfall event; inspect for evidence of erosion after the first large
storm or rainfall event (i.e., greater than or equal to 1.5 inches in 24 hours) as soon as is
feasible after the event; any area of erosion that will result in substantial sediment discharge
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will be remediated
within 48 hours
SPR GEO-5: Drain Stormwater via Water Breaks.
The project proponent will drain compacted and/or bare linear treatment areas capable of generating storm runoff via water breaks using the spacing
and erosion control guidelines contained in Sections 914.6, 934.6, and 954.6(c) of the California Forest Practice Rules (February 2019 version). Where waterbreaks cannot effectively disperse surface runoff, including where waterbreaks cause surface run-off to be concentrated on downslopes, other erosion controls will be installed as needed to maintain site productivity
by minimizing soil loss. This SPR applies only to mechanical and manual treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
During mechanical, manual, and prescribed
herbivory treatment activities
Town of Los Gatos Town of Los Gatos
SPR GEO-7: Minimize Erosion.
To minimize erosion, the project proponent will:
(1) Prohibit use of heavy equipment where any of the following conditions are present:
(i) Slopes steeper than 65 percent.
(ii) Slopes steeper than 50 percent where the erosion hazard rating is
high or extreme.
(iii) Slopes steeper than 50 percent that lead without flattening to sufficiently dissipate water flow and trap sediment before it reaches a watercourse or lake.
(2) On slopes between 50 percent and 65 percent where the erosion hazard rating is moderate, and all slope percentages are for average slope steepness based on sample areas that are 20 acres, or less, heavy equipment will be limited to:
(i) Existing tractor roads that do not require reconstruction, or
(ii) New tractor roads flagged by the project proponent prior to the treatment activity.
(3) Prescribed herbivory treatments will not be used in areas with over 50 percent slope.
This SPR applies to all treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR GEO-8: Steep Slopes.
The project proponent will require a Registered Professional Forester (RPF) or licensed geologist to evaluate treatment areas with slopes greater than 50
percent for unstable areas (areas with potential for landslide) and unstable soils (soil with moderate to high erosion hazard). If unstable areas or soils are identified within the treatment area, are unavoidable, and will be
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to and during treatment projects with slopes greater
than 50%
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potentially directly or indirectly affected by the treatment, a licensed geologist
(P.G. or C.E.G.) will determine the potential for landslide, erosion, of other issue related to unstable soils and identity measures (e.g., those in SPR GEO-7) that will be implemented by the project proponent such that substantial erosion or loss of topsoil would not occur. This SPR applies only to mechanical treatment activities and WUI fuel reduction, non- shaded fuel
breaks, and ecological restoration treatment types, including treatment maintenance.
Hazardous Material and Public Health and Safety Standard Project Requirements
SPR HAZ-1: Maintain All Equipment.
The project proponent will maintain all diesel- and gasoline-powered equipment per manufacturer’s specifications, and in compliance with all state
and federal emissions requirements. Maintenance records will be available for verification. Prior to the start of treatment activities, the project proponent will inspect all equipment for leaks and inspect everyday thereafter until equipment is removed from the site. Any equipment found leaking will be promptly removed. This SPR applies to all treatment activities and treatment
types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
Inspect all equipment for leaks prior to treatment
projects; inspect everyday thereafter until equipment is removed from the site; promptly
remove any leaking equipment; maintain all diesel- and gasoline-powered equipment
per manufacturer’s specifications and in compliance with all federal and state emissions
requirements during treatment projects
Town of Los Gatos Town of Los Gatos
SPR HAZ-2: Require Spark Arrestors.
The project proponent will require mechanized hand tools to have federal- or
state-approved spark arrestors. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During manual treatment activities Town of Los Gatos Town of Los Gatos
SPR HAZ-3: Require Fire Extinguishers.
The project proponent will require tree cutting crews to carry one fire
extinguisher per chainsaw. Each vehicle would be equipped with one long-handled shovel and one axe or Pulaski consistent with PRC Section 4428. This SPR applies only to manual treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During manual treatment activities Town of Los Gatos Town of Los Gatos
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SPR HAZ-4: Prohibit Smoking in Vegetated Areas.
The project proponent will require that smoking is only permitted in designated smoking areas barren or cleared to mineral soil at least 3 feet in diameter (PRC Section 4423.4). This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los
Gatos
Town of Los
Gatos
SPR HAZ-5: Spill Prevention and Response Plan.
The project proponent or licensed Pest Control Advisor (PCA) will prepare a Spill Prevention and Response Plan (SPRP) prior to beginning any herbicide treatment activities to provide protection to onsite workers, the public, and the environment from accidental leaks or spills of herbicides, adjuvants, or
other potential contaminants. The SPRP will include (but not be limited to):
a map that delineates staging areas, and storage, loading, and mixing areas for herbicides;
a list of items required in an onsite spill kit that will be maintained throughout the life of the activity;
procedures for the proper storage, use, and disposal of any herbicides, adjuvants, or other chemicals used in vegetation treatment.
This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prepare SPRP prior to beginning any herbicide treatment activities; during herbicide treatment
Town of Los Gatos Town of Los Gatos
SPR HAZ-6: Comply with Herbicide Application Regulations.
The project proponent will coordinate pesticide use with the applicable County Agricultural Commissioner(s), and all required licenses and permits will be obtained prior to herbicide application. The project proponent will prepare all herbicide applications to do the following:
Be implemented consistent with recommendations prepared annually by a licensed PCA.
Comply with all appropriate laws and regulations pertaining to the use of pesticides and safety standards for employees and the public, as governed by the EPA, DPR, and applicable local jurisdictions.
Adhere to label directions for application rates and methods, storage, transportation, mixing, container disposal, and weather limitations to application such as wind speed, humidity, temperature, and precipitation.
Be applied by an applicator appropriately licensed by the State.
This SPR applies only to herbicide treatment activities and all treatment
types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During herbicide treatment Town of Los Gatos Town of Los Gatos
SPR HAZ-7: Triple Rinse Herbicide Containers.
The project proponent will triple rinse all herbicide and adjuvant containers with clean water at an approved site, and dispose of rinsate by placing it in the batch tank for application per 3 CCR Section 6684. The project
Initial Treatment: Y
Treatment Maintenance: Y
During herbicide treatment Town of Los Gatos Town of Los Gatos
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proponent will puncture used containers on the top and bottom to render
them unusable, unless said containers are part of a manufacturer’s container recycling program, in which case the manufacturer’s instructions will be followed. Disposal of non-recyclable containers will be at legal dumpsites. Equipment will not be cleaned, and personnel will not be washed in a manner that would allow contaminated water to directly enter any body of
water within the treatment area or adjacent watersheds. Disposal of all herbicides will follow label requirements and waste disposal regulations. This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.
SPR HAZ-8: Minimize Herbicide Drift to Public Areas.
The project proponent will employ the following herbicide application parameters during herbicide application to minimize drift into public areas:
application will cease when weather parameters exceed label specifications or when sustained winds at the site of application exceeds
7 miles per hour (whichever is more conservative);
spray nozzles will be configured to produce the largest appropriate droplet size to minimize drift;
low nozzle pressures (30-70 pounds per square inch) will be utilized to minimize drift; and
spray nozzles will be kept within 24 inches of vegetation during spraying.
This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During herbicide treatment Town of Los Gatos Town of Los Gatos
SPR HAZ-9: Notification of Herbicide Use in the Vicinity of Public
Areas.
For herbicide applications occurring within or adjacent to public recreation areas, residential areas, schools, or any other public areas within 500 feet, the project proponent will post signs at each end of herbicide treatment areas and any intersecting trails notifying the public of the use of herbicides. The
signs will include the signal word (i.e., Danger, Warning or Caution), product name, and manufacturer; active ingredient; EPA registration number; target pest; treatment location; date and time of application; restricted entry interval, if applicable per the label requirements; date which notification sign may be removed; and a contact person with a telephone number. Signs will be
posted prior to the start of treatment and notification will remain in place for at least 72 hours after treatment ceases. This SPR applies only to herbicide treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los
Gatos
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Hydrology and Water Quality Standard Project Requirements
SPR HYD-1: Comply with Water Quality Regulations.
Project proponents must also conduct proposed vegetation treatments in conformance with appropriate RWQCB timber, vegetation and land disturbance related Waste Discharge Requirements (WDRs) and/or related Conditional Waivers of Waste Discharge Requirements (Waivers), and appropriate Basin Plan Prohibitions. Where these regulatory requirements
differ, the most restrictive will apply. If applicable, this includes compliance with the conditions of general waste discharge requirements (WDR) and waste discharge requirement waivers for timber or silviculture activities where these waivers are designed to apply to non-commercial fuel reduction and forest health projects. In general, WDR and Waivers of waste discharge requirements for fuel reduction and forest health activities require that
wastes, including but not limited to petroleum products, soil, silt, sand, clay, rock, felled trees, slash, sawdust, bark, ash, and pesticides must not be discharged to surface waters or placed where it may be carried into surface waters; and that Water Board staff must be allowed reasonable access to the property in order to determine compliance with the waiver conditions. The specifications for each WDR and Waiver vary by region. Regions 2 (San Francisco Bay), 4 (Los Angeles), 8 (Santa Ana), and 7 (Colorado River) are highly urban or minimally forested and do not offer WDRs or Waivers for fuel reduction or vegetation management activities. The current applicable WDRs and Waivers for timber and vegetation management activities are included in Appendix HYD-1. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR HYD-3: Water Quality Protections for Prescribed Herbivory.
The project proponent will include the following water quality protections for
all prescribed herbivory treatments:
Environmentally sensitive areas such as waterbodies, wetlands, or riparian areas will be identified in the treatment prescription and excluded from prescribed herbivory project areas using temporary fencing or active herding. A buffer of approximately 50 feet will be maintained between
sensitive and actively grazed areas.
Water will be provided for grazing animals in the form of an on-site stock pond or a portable water source located outside of environmentally sensitive areas.
Treatment prescriptions will be designed to protect soil stability. Grazing
animals will be herded out of an area if accelerated soil erosion is observed.
This SPR applies to prescribed herbivory treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
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SPR HYD-4: Identify and Protect Watercourse and Lake Protection
Zones.
The project proponent will establish Watercourse and Lake Protection Zones (WLPZs) on either side of watercourses as defined in the table below, which is based on 14 CCR Section 916 .5 of the California Forest Practice Rules (February 2019 version). WLPZ’s are classified based on the uses of the stream and the presence of aquatic life. Wider WLPZs are required for steep
slopes.
Procedures for Determining Watercourse and Lake Protection Zone
(WLPZ) widths
Water Class Class I Class II Class III
Water Class Characteristics or Key Indicator Beneficial Use
1) Domestic supplies, including springs, on site and/or within
100 feet downstream of the operations area and/or
2) Fish always or
seasonally present onsite, includes habitat to sustain fish migration and
spawning.
1) Fish always or seasonally present offsite within 1000 feet downstream
and/or
2) Aquatic habitat for nonfish aquatic species.
3) Excludes Class
III waters that are tributary to Class I waters.
No aquatic life present, watercourse showing evidence of being capable
of sediment transport to Class I and II waters under normal high- water flow
conditions after completion of timber operations.
WLPZ Width (ft) – Distance from top of bank to the edge of
< 30% Slope 100 50 Sufficient to prevent the degradation of downstream
beneficial uses of water.
Determined on a site-specific basis.
30–50%
Slope
100 75
>50% Slope 100 100
Initial Treatment: Y
Treatment Maintenance: Y
Establish WLPZs during design of
treatment projects; implement WLPZ protections during treatment projects
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Source: 14 CCR Section 916.5 [936.5, 956.5] (February 2019 version)
The following WLPZ protections will be applied for all treatments:
Treatment activities with WLPZs will retain at least 75 percent surface cover and undisturbed area to act as a filter strip for raindrop energy dissipation and for wildlife habitat. If this percentage is reduced a qualified RPF will provide the project proponent with a site- and/or treatment activity-specific explanation for the percent surface cover reduction, which will be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced percent as explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL
FIRE as a Completion Report). This requirement is based on 14 CCR Section 916.4 [936.4, 956.4] Subsection (b)(6) (February 2019 version) and 14 CCR Section 916.5 (February 2019 version).
Equipment, including tractors and vehicles, must not be driven in wet areas or WLPZs, except over existing roads or watercourse crossings
where vehicle tires or tracks remain dry.
Equipment used in vegetation removal operations will not be serviced in WLPZs, within wet meadows or other wet areas, or in locations that would allow grease, oil, or fuel to pass into lakes, watercourses, or wet areas.
WLPZs will be kept free of slash, debris, and other material that harm the
beneficial uses of water. Accidental deposits will be removed immediately.
Burn piles will be located outside of WLPZs.
No fire ignition (nor use of associated accelerants) will occur within WLPZs however low intensity backing fires may be allowed to enter or spread into WLPZs.
Within Class I and Class II WLPZs, locations where project operations expose a continuous area of mineral soil 800 square feet or larger shall be treated for reduction of soil loss.
Treatment shall occur prior to October 15th and disturbances that are created after October 15th shall be treated within 10 days. Stabilization
measures shall be selected that will prevent significant movement of soil into water bodies and may include but are not limited to mulching, rip-rap, grass seeding, or chemical soil stabilizers.
Where mineral soil has been exposed by project operations on approaches to watercourse crossings of Class I, II, or III within a WLPZ,
the disturbed area shall be stabilized to the extent necessary to prevent the discharge of soil into watercourses or lakes in amounts that would adversely affect the quality and beneficial uses of the watercourse.
Where necessary to protect beneficial uses of water from project operations, protection measures such as seeding, mulching, or replanting
shall be used to retain and improve the natural ability of the ground cover
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within the WLPZ to filter sediment, minimize soil erosion, and stabilize banks of watercourses and lakes.
Equipment limitation zones (ELZs) will be designated adjacent to Class III and Class IV watercourses with minimum widths of 25 feet where side-slope is less than 30 percent and 50 feet where side-slope is 30 percent or greater. An RPF will describe the limitations of heavy equipment within the ELZ and, where appropriate, will include additional measures to
protect the beneficial uses of water.
This SPR applies to all treatment activities and treatment types, including treatment maintenance.
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SPR HYD-5: Protect Non-Target Vegetation and Special-status Species
from Herbicides.
The project proponent will implement the following measures when applying herbicides:
Locate herbicide mixing sites in areas devoid of vegetation and where there is no potential of a spill reaching non-target vegetation or a
waterway.
Use only herbicides labeled for use in aquatic environments when working in riparian habitats or other areas where there is a possibility the herbicide could come into direct contact with water. Only hand application of herbicides will be allowed in riparian habitats and only during low-flow periods or when seasonal streams are dry.
No terrestrial or aquatic herbicides will be applied within WLPZs of Class I and II watercourses, if feasible. If this is not feasible, hand application of herbicides labeled for use in aquatic environments may be used within the WLPZ provided that the project proponent notifies the applicable regional
water quality control board no fewer than 15 days prior to herbicide application. The feasibility of avoiding herbicide application within WLPZ of Class I and II watercourses will be determined by the project proponent and may be based on whether doing so will preclude achieving CalVTP program objectives, including, but not limited to, protection of vulnerable
communities. The reasons for infeasibility will be documented in the PSA.
No herbicides will be applied within a 50-foot buffer of ESA or CESA listed plant species or within 50 feet of dry vernal pools.
For spray applications in and adjacent to habitats suitable for special-status species, use herbicides containing dye (registered for aquatic use
by DPR, if warranted) to prevent overspray.
Application will cease when weather parameters exceed label specifications or when sustained winds at the site of application exceeds 7 miles per hour (whichever is more conservative);
No herbicide will be applied during precipitation events or if precipitation is
forecast 24 hours before or after project activities.
This SPR applies to herbicide treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During herbicide
treatment
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SPR HYD-6: Protect Existing Drainage Systems.
If a treatment activity is adjacent to a roadway with stormwater drainage infrastructure, the existing stormwater drainage infrastructure will be marked prior to ground disturbing activities. If a drainage structure or infiltration system is inadvertently disturbed or modified during project activities, the project proponent will coordinate with owner of the system or feature to
repair any damage and restore pre-project drainage conditions. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Mark existing
stormwater drainage infrastructure prior to ground-disturbing activities; if a
drainage structure or infiltration system is inadvertently disturbed or modified during
treatment, coordinate with owner to repair damage and restore pre-project
drainage conditions
Town of Los
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Noise Standard Project Requirements
SPR NOI-1: Limit Heavy Equipment Use to Daytime Hours.
The project proponent will require that operation of heavy equipment associated with treatment activities (heavy off-road equipment, tools, and delivery of equipment and materials) will occur during daytime hours if such
noise would be audible to receptors (e.g., residential land uses, schools, hospitals, places of worship). Cities and counties in the treatable landscape typically restrict construction-noise (which would apply to vegetation treatment noise) to particular daytime hours. If the project proponent is subject to local noise ordinance, it will adhere to those to the extent the
project is subject to them. If the applicable jurisdiction does not have a noise ordinance or policy restricting the time-of- day when noise-generating activity can occur noise-generating vegetation treatment activity will be limited to the hours of 7:00 a.m. to 6:00 p.m., Monday through Saturday, and between 9:00 a.m. and 6:00 p.m. on Sunday and federal holidays. If the project
proponent is not subject to local ordinances (e.g., CAL FIRE), it will adhere to the restrictions stated above or may elect to adhere to the restrictions identified by the local ordinance encompassing the treatment area. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR NOI-2: Equipment Maintenance.
The project proponent will require that all powered treatment equipment and power tools will be used and maintained according to manufacturer specifications. All diesel- and gasoline-powered treatment equipment will be
properly maintained and equipped with noise-reduction intake and exhaust mufflers and engine shrouds, in accordance with manufacturers’
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
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recommendations. This SPR applies to all activities and all treatment types,
including treatment maintenance.
SPR NOI-3: Engine Shroud Closure.
The project proponent will require that engine shrouds be closed during equipment operation. This SPR applies only to mechanical treatment
activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR NOI-4: Locate Staging Areas Away from Noise-Sensitive Land
Uses.
The project proponent will locate treatment activities, equipment, and
equipment staging areas away from nearby noise- sensitive land uses (e.g., residential land uses, schools, hospitals, places of worship), to the extent feasible, to minimize noise exposure. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment
Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR NOI-5: Restrict Equipment Idle Time.
The project proponent will require that all motorized equipment be shut down when not in use. Idling of equipment and haul trucks will be limited to 5 minutes. This SPR applies to all treatment activities and all treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
SPR NOI-6: Notify Nearby Off-Site Noise-Sensitive Receptors.
For treatment activities utilizing heavy equipment, the project proponent will notify noise-sensitive receptors (e.g., residential land uses, schools, hospitals, places of worship) located within 1,500 feet of the treatment activity. Notification will include anticipated dates and hours during which
treatment activities are anticipated to occur and contact information, including a daytime telephone number, of the project representative. Recommendations to assist noise-sensitive land uses in reducing interior noise levels (e.g., closing windows and doors) will also be included in the notification. This SPR applies only to mechanical treatment activities and all
treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to mechanical treatment activities within 1,500 feet of noise-sensitive receptors
Town of Los Gatos Town of Los Gatos
Recreation Standard Project Requirements
SPR REC-1: Notify Recreational Users of Temporary Closures.
If a treatment activity would require temporary closure of a public recreation area or facility, the project proponent will coordinate with the owner/manager of that recreation area or facility. If temporary closure of a recreation area or
facility is required, the project proponent will work with the owner/manager to post notifications of the closure at least 2 weeks prior to the commencement of the treatment activities. Additionally, notification of the treatment activity will be provided to the Administrative Officer (or equivalent official responsible for distribution of public information) of the county(ies) in which
Initial Treatment: Y
Treatment Maintenance: Y
Approximately 2 weeks prior to treatment projects requiring temporary
closure of public recreation areas or facilities
Town of Los Gatos Town of Los Gatos and Santa Clara County Administrative
Officer (or equivalent official responsible for distribution of public information)
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the affected recreation area or facility is located. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Transportation Standard Project Requirements
SPR TRAN-1: Implement Traffic Control during Treatments.
Prior to initiating vegetation treatment activities the project proponent will
work with the agency(ies) with jurisdiction over affected roadways to determine if a Traffic Management Plan (TMP) is needed. A TMP will be needed if traffic generated by the project would result in obstructions, hazards, or delays exceeding applicable jurisdictional standards along access routes for individual vegetation treatments. If needed, a TMP will be prepared to provide measures to reduce potential traffic obstructions, hazards, and service level degradation along affected roadway facilities. The scope of the TMP will depend on the type, intensity, and duration of the specific treatment activities under the CalVTP. Measures included in the TMP could include (but are not be limited to) construction signage to provide motorists with notification and information when approaching or traveling along the affected roadway facilities, flaggers for lane closures to provide temporary traffic control along affected roadway facilities, treatment schedule restrictions to avoid seasons or time periods of peak vehicle traffic, haul-trip, delivery, and/or commute time restrictions that would be implemented to
avoid peak traffic days and times along affected roadway facilities. If the TMP identifies impacts on transportation facilities outside of the jurisdiction of the project proponent, the TMP will be submitted to the agency with jurisdiction over the affected roadways prior to commencement of vegetation treatment projects. This SPR applies to all treatment activities and treatment types, including treatment maintenance.
Initial Treatment: Y
Treatment Maintenance: Y
If needed, prepare TMP prior to treatment projects and implement during project treatments
Town of Los Gatos Town of Los Gatos and agency(ies) with jurisdiction over affected roadways
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Air Quality
Mitigation Measure AQ-1: Implement On-Road Vehicle and Off-Road
Equipment Exhaust Emission Reduction Techniques.
Where feasible, project proponents will implement emission reduction techniques to reduce exhaust emissions from off-road equipment. It is acknowledged that due to cost, availability, and the limits of current technology, there may be circumstances where implementation of certain emission reduction techniques will not feasible. The project proponent will document the emission reduction techniques that will be applied and will explain the reasons other techniques that could reduce emissions are infeasible.
Techniques for reducing emissions may include, but are not limited to, the following:
Diesel-powered off-road equipment used in construction will meet EPA’s Tier 4 emission standards as defined in 40 CFR 1039 and comply with the exhaust emission test procedures and provisions of 40 CFR Parts 1065 and 1068. Tier 3 models can be used if a Tier 4 version of the
equipment type is not yet produced by manufacturers. This measure can also be achieved by using battery-electric off-road equipment as it becomes available. Prior to implementation of treatment activities, the project proponent will demonstrate the ability to supply the compliant equipment. A copy of each unit’s certified tier specification or model year specification and operating permit (if applicable) will be available upon
request at the time of mobilization of each unit of equipment.
Use renewable diesel fuel in diesel-powered construction equipment. Renewable diesel fuel must meet the following criteria:
meet California’s Low Carbon Fuel Standards and be certified by
CARB Executive Officer;
be hydrogenation-derived (reaction with hydrogen at high temperatures) from 100 percent biomass material (i.e., non-petroleum sources), such as animal fats and vegetables;
contain no fatty acids or functionalized fatty acid esters; and
have a chemical structure that is identical to petroleum-based diesel
and complies with American Society for Testing and Materials D975 requirements for diesel fuels to ensure compatibility with all existing diesel engines.
Electric- and gasoline-powered equipment will be substituted for diesel-powered equipment.
Workers will be encouraged to carpool to work sites, and/or use public transportation for their commutes.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los
Gatos
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Gatos
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Off-road equipment, diesel trucks, and generators will be equipped with Best Available Control Technology for emission reductions of NOX and PM.
Archaeological, Historical, and Tribal Cultural Resources
Mitigation Measure CUL-2: Protect Inadvertent Discoveries of Unique
Archaeological Resources or Subsurface Historical Resources.
If any prehistoric or historic-era subsurface archaeological features or deposits, including locally darkened soil (“midden”), that could conceal cultural deposits, are discovered during ground-disturbing activities, all ground-disturbing activity within 100 feet of the resources will be halted and a qualified archaeologist will assess the significance of the find. The qualified archaeologist will work with the project proponent to develop a primary records report that will comply with applicable state or local agency procedures. If the archaeologist determines that further information is needed to evaluate significance, a data recovery plan will be prepared. If the find is determined to be significant by the qualified archaeologist (i.e., because the find constitutes a unique archaeological resource, subsurface historical resource, or tribal cultural resource), the archaeologist will work with the project proponent to develop appropriate procedures to protect the integrity of the resource.
Procedures could include preservation in place (which is the preferred manner of mitigating impacts to archaeological sites), archival research, subsurface testing, or recovery of scientifically consequential information from and about the resource. Any find will be recorded standard DPR Primary Record forms (Form DPR 523) will be submitted to the appropriate regional information center.
Initial Treatment: Y
Treatment Maintenance: Y
During treatment Town of Los Gatos Town of Los Gatos
Biological Resources
Mitigation Measure BIO-1a: Avoid Loss of Special-Status Plants Listed
under ESA or CESA.
If listed plants are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent will avoid and protect these
species by establishing a no-disturbance buffer around the area occupied by listed plants and marking the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway), exceptions to this requirement are listed later in this measure. The no-disturbance buffers will generally be a minimum of 50 feet from listed plants, but the size and shape of the buffer zone may be adjusted if a
qualified RPF or botanist determines that a smaller buffer will be sufficient to avoid killing or damaging listed plants or that a larger buffer is necessary to sufficiently protect plants from the treatment activity. The appropriate buffer size will be determined based on plant phenology at the time of
Initial Treatment: Y
Treatment Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos
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treatment (e.g., whether the plants are in a dormant, vegetative, or flowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain. For example, paint-on or wicking application of herbicides to invasive plants may be
implemented within 50 feet of listed plant species without posing a risk, especially if the listed plants are dormant at the time of application. Consideration of factors such as site hydrology, changes in light, edge effects, and potential introduction of invasive plants and noxious weeds may inform the determination of buffer width. If a no-disturbance buffer is reduced below 50 feet from a listed plant, a qualified RPF or botanist will provide the project proponent with a site- and/or treatment activity-specific explanation for the buffer reduction, which will be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from the reduced buffer as explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report) with a science-based justification for the deviation. No fire ignition (and associated use of accelerants) will occur within 50 feet of listed plants.
For species listed under ESA or CESA, if the project proponent cannot
avoid loss by implementing no-disturbance buffers, the project proponent will implement Mitigation Measure BIO-1c.
The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or botanist, in consultation with CDFW and USFWS, as appropriate depending on species status and location, that the listed plants would benefit from treatment in the occupied habitat area even though some of the listed plants may be lost during treatment activities. For a treatment to be considered beneficial to listed special-status plants, the qualified RPF or botanist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific studies demonstrating that the species (or similar species) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to listed plants, no compensatory mitigation for loss of individuals will be
required.
Mitigation Measure BIO-1b: Avoid Loss of Special-Status Plants Not
Listed Under ESA or CESA.
If non-listed special-status plant species (i.e., species not listed under ESA or CESA, but meeting the definition of special-status as stated in Section 3.6.1 of the Program EIR) are determined to be present through application of SPR BIO-1 and SPR BIO-7, the project proponent will implement the
following measures to avoid loss of individuals and maintain habitat function of occupied habitat:
Initial Treatment: Y
Treatment Maintenance: Y
Prior to and during treatment Town of Los Gatos Town of Los Gatos
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Physically avoid the area occupied by the special-status plants by establishing a no-disturbance buffer around the area occupied by species and marking the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of
a roadway). The no-disturbance buffers will generally be a minimum of 50 feet from special-status plants, but the size and shape of the buffer zone may be adjusted if a qualified RPF or botanist determines that a smaller buffer will be sufficient to avoid loss of or damaging to special-status plants or that a larger buffer is necessary to sufficiently protect plants from the treatment activity. The appropriate size and shape of the buffer zone will be determined by a qualified RPF or botanist and will depend on plant phenology at the time of treatment (e.g., whether the plants are in a dormant, vegetative, or flowering state), the individual species’ vulnerability to the treatment method being used, and environmental conditions and terrain. Consideration of factors such as site hydrology, changes in light, edge effects, and potential introduction of invasive plants and noxious weeds may inform an appropriate buffer size and shape.
Treatments may be conducted within this buffer if the potentially affected
special-status plant species is a geophytic, stump- sprouting, or annual species, and the treatment can be conducted outside of the growing season (e.g., after it has completed its annual life cycle) or during the dormant season using only treatment activities that would not damage the stump, root system or other underground parts of special-status plants or destroy the seedbank.
Treatments will be designed to maintain the function of special-status plant habitat. For example, for a fuel break proposed in treatment areas occupied by special-status plants, if the removal of shade cover would degrade the special-status plant habitat despite the requirement to physically or seasonally avoid the special-status plant itself, habitat function would be diminished and the treatment would need to be modified or precluded from implementation.
No fire ignition (nor use of associated accelerants) will occur within the special-status plant buffer.
A qualified RPF or botanist with knowledge of the special-status plant
species habitat and life history will review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual effects of the treatment would be significant under CEQA because implementation of the treatment would not maintain habitat function of the special-status plant habitat (i.e., the habitat would be rendered unsuitable) or because the loss of special-status plants would substantially reduce the number or restrict the range of a special- status plant species. If the project proponent determines the impact on special-status plants would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status plants or degradation of occupied habitat would be
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significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-1c will be implemented.
The only exception to this mitigation approach is in cases where it is
determined by a qualified RPF or botanist that the special-status plants would benefit from treatment in the occupied habitat area even though some of the non-listed special-status plants may be killed during treatment activities. For a treatment to be considered beneficial to non-listed special-status plants, the qualified RPF or botanist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific studies demonstrating that the species (or similar species) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to special-status plants, no compensatory mitigation will be required.
Mitigation Measure BIO-1c: Compensate for Unavoidable Loss of
Special-Status Plants.
If significant impacts on listed or non-listed special-status plants cannot
feasibly be avoided as specified under the circumstances described under Mitigation Measures BIO-1a and 1b, the project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant impacts that require compensatory mitigation and describes the compensatory mitigation strategy being implemented and how unavoidable losses of
special-status plants will be compensated. The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan. If the special-status plant taxa are listed under ESA or CESA, the plan will be
submitted to CDFW and/or USFWS (as appropriate) for review and comment.
The first priority for compensatory mitigation will be preserving and enhancing existing populations outside of the treatment area in perpetuity, or if that is not an option because existing populations that can be
preserved in perpetuity are not available, one of the following mitigation options will be implemented by the project proponent instead:
creating populations on mitigation sites outside of the treatment area through seed collection and dispersal (annual species) or transplantation (perennial species);
purchasing mitigation credits from a CDFW- or USFWS-approved conservation or mitigation bank in sufficient quantities to offset the loss of occupied habitat; and
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos
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if the affected special-status plants are not listed under ESA or CESA, compensatory mitigation may include restoring or enhancing degraded
habitats so that they are made suitable to support special-status plant species in the future.
If relocation efforts are part of the Compensatory Mitigation Plan, the plan will include details on the methods to be used, including collection, storage, propagation, receptor site preparation, installation, long-term protection and
management, monitoring and reporting requirements, success criteria, and remedial action responsibilities should the initial effort fail to meet long-term monitoring requirements. The following performance standards will be applied for relocation:
the extent of occupied area will be substantially similar to the affected
occupied habitat and will be suitable for self-producing populations. Re-located/re-established populations will be considered suitable for self-producing when:
habitat conditions allow for plants to reestablish annually for a minimum of 5 years with no human intervention, such as supplemental seeding;
and
reestablished habitats contain an occupied area comparable to existing occupied habitat areas in similar habitat types in the region.
If preservation of existing populations or creation of new populations is part of the mitigation plan, the Compensatory Mitigation Plan will include a
summary of the proposed compensation lands and actions (e.g., the number and type of credits, location of mitigation bank or easement, restoration or enhancement actions), parties responsible for the long-term management of the land, and the legal and funding mechanisms (e.g., holder of conservation easement or fee title). The project proponent will
submit evidence that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory plant populations will be preserved in perpetuity.
If mitigation includes dedication of conservation easements, purchase of mitigation credits, or other offsite conservation measures, the details of
these measures will be included in the mitigation plan, including information on responsible parties for long-term management, conservation easement holders, long-term management requirements, funding assurances, and success criteria such as those listed above and other details, as appropriate to target the preservation of long term viable populations.
If mitigation includes restoring or enhancing habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties
responsible for long-term management and monitoring of the restored habitat.
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If the loss of occupied habitat cannot be offset (e.g., if preservation of existing populations or creation of new populations through relocation
efforts are not available for a certain species), and as a result, treatment activities would substantially reduce the number or restrict the range of listed plant species, then the treatment will not qualify as within the scope of this PEIR.
Compensatory mitigation may be satisfied through compliance with permit
conditions, or other authorizations obtained by the project proponent (e.g., incidental take permit for state-listed plants), if these requirements are equally or more effective than the mitigation identified above.
Mitigation Measure BIO-2a: Avoid Mortality, Injury, or Disturbance and
Maintain Habitat Function for Listed Wildlife Species and California
Fully Protected Species (All Treatment Activities).
If California Fully Protected Species or species listed under ESA or CESA are observed during reconnaissance surveys (conducted pursuant to SPR BIO-1) or focused or protocol-level surveys (conducted pursuant to SPR
BIO-10), the project proponent will avoid adverse effects to the species by implementing the following.
Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent will implement one of the following 2 measures to avoid mortality, injury, or disturbance of individuals:
1. Treatment will not be implemented within the occupied habitat. Any treatment activities outside occupied habitat will be a sufficient distance from the occupied habitat such that mortality, injury, or disturbance of the species will not occur, as determined by a qualified RPF or biologist using the most current and commonly-accepted science and considering
published agency guidance; OR
2. Treatment will be implemented outside the sensitive period of the species’ life history (e.g., outside the breeding or nesting season) during which the species may be more susceptible to disturbance, or disturbance could result in loss of eggs or young. For species present
year-round, CDFW and/or USFWS/NOAA Fisheries will be consulted to determine if there is a period of time within which treatment could occur that would avoid mortality, injury, or disturbance of the species.
For species listed under ESA or CESA, if the project proponent cannot avoid mortality, injury or disturbance by implementing one of the two
options listed above, the project proponent will implement Mitigation Measure BIO-2c.
Injury or mortality of California Fully Protected Species is prohibited pursuant to Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code and will be avoided.
Initial Treatment: Y
Treatment Maintenance: Y
Prior to and
during treatment
Town of Los
Gatos
Town of Los
Gatos, CDFW, and/or USFWS/ NOAA Fisheries
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Maintain Habitat Function
The project proponent will design treatment activities to maintain the habitat function, by implementing the following:
While performing review and surveys for SPR BIO-1 and SPR BIO- 10, a qualified RPF or biologist will identify any habitat features that are necessary for survival (e.g., habitat necessary for breeding,
foraging, shelter, movement) of the affected wildlife species (e.g., trees with complex structure, trees with large cavities, trees with nesting platforms; dens; tree snags; large raptor nests [including inactive nests]; downed woody debris; food sources). These habitat features will be marked and treatments applied to the features will be designed to minimize or avoid the loss or degradation of suitable habitat for listed species during treatments. Identification and treatment of these features will be based on the life history and habitat requirements of the affected species and the most current, commonly accepted science.
If it is determined during implementation of SPR BIO-1 and SPR BIO-10 that listed or fully protected wildlife with specific requirements for high canopy cover (e.g., Humboldt marten, fisher, spotted owl, coastal California gnatcatcher, riparian woodrat) are present within a treatment area, then tree or shrub canopy cover within existing
suitable areas will be retained at the percentage preferred by the species (as determined by expert opinion, published habitat association information, or other documented standards that are commonly accepted [e.g., 50 percent for coastal California
gnatcatcher]) such that habitat function is maintained.
A qualified RPF or biologist will determine if, after implementation of the impact avoidance measures listed above, the habitat function will remain for the affected species after implementation of the treatment. Because this measure pertains to species listed under CESA or ESA or are fully protected, the qualified RPF or biologist will consult with CDFW and/or
USFWS/NOAA Fisheries regarding the determination that habitat function is maintained. If consultation determines that the treatment will not maintain habitat function for the special-status species, the project proponent will implement Mitigation Measure BIO-2c.
Mitigation Measure BIO-2b: Avoid Mortality, Injury, or Disturbance and
Maintain Habitat Function for Other Special-Status Wildlife Species
(All Treatment Activities).
If other special-status wildlife species (i.e., species not listed under CESA or ESA or California Fully Protected, but meeting the definition of special status as stated in Section 3.6.1 of the Program EIR) are observed during
reconnaissance surveys (conducted pursuant to SPR BIO-1) or focused or protocol-level surveys (conducted pursuant to SPR BIO-10), the project
Initial Treatment: Y
Treatment Maintenance: Y
Prior to and
during treatment
Town of Los
Gatos
Town of Los
Gatos, CDFW, and/or USFWS
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proponent will avoid or minimize adverse effects to the species by implementing the following.
Avoid Mortality, Injury, or Disturbance of Individuals
The project proponent will implement the following to avoid mortality, injury, or disturbance of individuals:
For all treatment activities except prescribed burning, the project proponent will establish a no-disturbance buffer around occupied
sites (e.g., nests, dens, roosts, middens, burrows, nurseries). Buffer size will be determined by a qualified RPF or biologist using the most current, commonly accepted science and will consider published agency guidance; however, buffers will generally be a minimum of 100 feet, unless site conditions indicate a smaller buffer would be
sufficient for protection or a larger buffer would be needed. Factors to be considered in determining buffer size will include, but not be limited to, the species’ tolerance to disturbance; the presence of natural buffers provided by vegetation or topography; nest height; locations of foraging territory; baseline levels of noise and human
activity; and treatment activity. Buffer size may be adjusted if the qualified RPF or biologist determines that such an adjustment would not be likely to adversely affect (i.e., cause mortality, injury, or disturbance to) the species within the nest, den, burrow, or other occupied site. If a no-disturbance buffer is reduced below 100 feet
from an occupied site, a qualified RPF or biologist will provide the project proponent with a site- and/or treatment activity-specific explanation for the buffer reduction, which will be included in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any deviation (e.g., further reduction) from
the reduced buffer as explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).
No-disturbance buffers will be marked with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge
of a roadway). No activity will occur within the buffer areas until the qualified RPF or biologist has determined that the young have fledged or dispersed; the nest, den, or other occurrence is no longer active; or reducing the buffer would not likely result in disturbance, mortality, or injury. A qualified RPF, biologist, or biological technician
will be required to monitor the effectiveness of the no-disturbance buffer around the nest, den, burrow, or other occurrence during treatment. If treatment activities cause agitated behavior of the individual(s), the buffer distance will be increased, or treatment activities modified until the agitated behavior stops. The qualified
RPF, biologist, or biological technician will have the authority to stop any treatment activities that could result in mortality, injury or disturbance to special- status species.
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Maintain Habitat Function
For all treatment activities, the project proponent will design treatment
activities to maintain the habitat function by implementing the following:
While performing review and surveys for SPR BIO-1 and SPR BIO- 10, a qualified RPF or biologist will identify any habitat features that are necessary for survival (e.g., habitat necessary for breeding, foraging, shelter, movement) of the affected wildlife species (e.g.,
trees with complex structure, trees with large cavities, trees with nesting platforms; tree snags; large raptor nests [including inactive nests]; downed woody debris). These habitat features will be marked and treatments applied to the features will be designed to minimize or avoid the loss or degradation of suitable habitat for listed species
during treatments. Identification and treatment of these features will be based on the life history and habitat requirements of the affected species and the most current, commonly accepted science.
If it is determined during implementation of SPR BIO-1 and SPR BIO-10 that special-status wildlife with specific requirements for high
canopy cover (e.g., northern goshawk, Sierra Nevada snowshoe hare) are present within a treatment area, then tree or shrub canopy cover within existing suitable areas will be retained at the percentage preferred by the species (as determined by expert opinion, published habitat association information, or other documented standards that
are commonly accepted) such that the habitat function is maintained.
A qualified RPF or biologist will determine if, after implementation of the impact avoidance measures listed above, the habitat function will remain for the affected species after implementation of the treatment. The qualified RPF or biologist may consult with CDFW and/or
USFWS for technical information regarding habitat function.
A qualified RPF or biologist with knowledge of the special-status wildlife species habitat and life history will review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual effects of the treatment
would be significant under CEQA because implementation of the treatment will not maintain habitat function of the special-status wildlife species’ habitat or because the loss of special-status wildlife would substantially reduce the number or restrict the range of a special-status wildlife species. If the project proponent determines the impact on special-status wildlife
would be less than significant, no further mitigation will be required. If the project proponent determines that the loss of special-status wildlife or degradation of occupied habitat would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-2c will be
implemented.
The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or biologist that the non-listed special- status
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wildlife would benefit from treatment in the occupied habitat area even though some of the non-listed special-status wildlife may be killed, injured,
or disturbed during treatment activities. For a treatment to be considered beneficial to non-listed special-status wildlife, the qualified RPF or biologist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific studies demonstrating that the species (or similar
species) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to special-status wildlife, no compensatory mitigation will be required. The qualified RPF or
biologist may consult with CDFW and/or USFWS for technical information regarding the determination that a non- listed special-status species would benefit from the treatment.
Mitigation Measure BIO-3a: Design Treatments to Avoid Loss of
Sensitive Natural Communities and Oak Woodlands.
The project proponent will implement the following measures when working in treatment areas that contain sensitive natural communities identified during surveys conducted pursuant to SPR BIO-3:
Reference the Manual of California Vegetation, Appendix 2, Table A2,
Fire Characteristics (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/) or other best available information to determine the natural fire regime of the specific sensitive natural community type (i.e., alliance) present. The condition class and fire return interval departure of the vegetation
alliances present will also be determined.
Design treatments in sensitive natural communities and oak woodlands to restore the natural fire regime and return vegetation composition and structure to their natural condition to maintain or improve habitat function of the affected sensitive natural community. Treatments will be designed
to replicate the fire regime attributes for the affected sensitive natural community or oak woodland type including seasonality, fire return interval, fire size, spatial complexity, fireline intensity, severity, and fire type as described in Fire in California’s Ecosystems (Van Wagtendonk et al. 2018) and the Manual of California Vegetation (Sawyer et al. 2009 or current version, including updated natural communities data at http://vegetation.cnps.org/). Treatments will not be implemented in sensitive natural communities that are within their natural fire return interval (i.e., time since last burn is less than the average time required for that vegetation type to recover from fire) or within Condition Class 1.
To the extent feasible, no fuel breaks will be created in sensitive natural communities with rarity ranks of S1 (critically imperiled) and S2 (imperiled).
Initial Treatment: Y
Treatment Maintenance: Y
Prior to and
during treatment
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To the extent feasible, fuel breaks will not remove more than 20 percent
of the native vegetation relative cover from a stand of sensitive natural community vegetation in sensitive natural communities with a rarity rank of S3 (vulnerable) or in oak woodlands. In forest and woodland sensitive natural communities with a rarity rank of S3, and in oak woodlands, only shaded fuel breaks will be installed, and they will not be installed in more
than 20 percent of the stand of sensitive natural community or oak woodland vegetation (i.e., if the sensitive natural community covers 100 acres, no more than 20 acres will be converted to create the fuel break).
Time prescribed herbivory to occur when non-target vegetation is not susceptible to damage (e.g. non-target vegetation is dormant or has completed its reproductive cycle for the year). For example, use herbivores to control invasive plants growing in sensitive habitats or sensitive natural communities when sensitive vegetation is dormant but invasive plants are growing. Timing of herbivory to avoid non-target vegetation will be determined by a qualified botanist, RPF, or biologist
based on the specific vegetation alliance being treated, the life forms and life conditions of its characteristic plant species, and the sensitivity of the non-target vegetation to the effects of herbivory.
The feasibility of implementing the avoidance measures will be determined by the project proponent based on whether implementation of this
mitigation measure will preclude completing the treatment project within the reasonable period of time necessary to meet CalVTP program objectives, including, but not limited to, protection of vulnerable communities. If the avoidance measures are determined by the project proponent to be infeasible, the project proponent will document the reasons implementation
of the avoidance strategies are infeasible in the PSA. After completion of the PSA and prior to or during treatment implementation, if there is any change in the feasibility of avoidance strategies from those explained in the PSA, this will be documented in the post-project implementation report (referred to by CAL FIRE as a Completion Report).
A qualified RPF or botanist with knowledge of the affected sensitive natural community will review the treatment design and applicable impact minimization measures (potentially including others not listed above) to determine if the anticipated residual effects of the treatment would be significant under CEQA because implementation of the treatment will not
maintain habitat functions of the sensitive natural community or oak woodland. If the project proponent determines the impact on sensitive natural communities or oak woodlands would be less than significant, no further mitigation will be required. If the project proponent determines that the loss or degradation of sensitive natural communities or oak woodlands
would be significant under CEQA after implementing feasible treatment design alternatives and impact minimization measures, then Mitigation Measure BIO-3b will be implemented.
The only exception to this mitigation approach is in cases where it is determined by a qualified RPF or botanist that the sensitive natural
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community or oak woodland would benefit from treatment in the occupied
habitat area even though some loss may occur during treatment activities. For a treatment to be considered beneficial to a sensitive natural community or oak woodland, the qualified RPF or botanist will demonstrate with substantial evidence that habitat function is reasonably expected to improve with implementation of the treatment (e.g., by citing scientific
studies demonstrating that the community (or similar community) has benefitted from increased sunlight due to canopy opening, eradication of invasive species, or otherwise reduced competition for resources), and the substantial evidence will be included in the PSA. If it is determined that treatment activities would be beneficial to sensitive natural communities or oak woodlands, no compensatory mitigation will be required.
Mitigation Measure BIO-3b: Compensate for Loss of Sensitive Natural
Communities and Oak Woodlands.
If significant impacts on sensitive natural communities or oak woodlands
cannot feasibly be avoided or reduced as specified under Mitigation Measure BIO-3a, the project proponent will implement the following actions:
Compensate for unavoidable losses of sensitive natural community and oak woodland acreage and function by:
restoring sensitive natural community or oak woodland functions and
acreage within the treatment area;
restoring degraded sensitive natural communities or oak woodlands outside of the treatment area at a sufficient ratio to offset the loss of acreage and habitat function; or
preserving existing sensitive natural communities or oak woodlands
of equal or better value to the sensitive natural community lost through a conservation easement at a sufficient ratio to offset the loss of acreage and habitat function.
The project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant effects on sensitive natural communities
or oak woodlands that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects, and:
1. For preserving existing habitat outside of the treatment area in perpetuity, the Compensatory Mitigation Plan will include a summary
of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., holder of conservation easement or fee title). The project proponent will submit evidence
that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory habitat will be preserved in perpetuity.
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to treatment Town of Los Gatos Town of Los Gatos, CDFW, and/or any other
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2. For restoring or enhancing habitat within the treatment area or
outside of the treatment area, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements, success criteria that demonstrate the performance standard of maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the
restored or enhanced habitat.
The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan in order to satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan.
Mitigation Measure BIO-3c: Compensate for Unavoidable Loss of
Riparian Habitat.
If, after implementation of SPR BIO-4, impacts to riparian habitat remain significant under CEQA, the project proponent will implement the following:
Compensate for unavoidable losses of riparian habitat acreage and function by:
restoring riparian habitat functions and acreage within the treatment area;
restoring degraded riparian habitat outside of the treatment area;
purchasing riparian habitat credits at a CDFW-approved mitigation bank; or
preserving existing riparian habitat of equal or better value to the riparian habitat lost through a conservation easement at a sufficient ratio to offset the loss of riparian habitat function and value.
The project proponent will prepare a Compensatory Mitigation Plan that identifies the residual significant effects on riparian habitat that require compensatory mitigation and describes the compensatory mitigation strategy being implemented to reduce residual effects, and:
1. For preserving existing riparian habitat outside of the treatment area
in perpetuity, the Compensatory Mitigation Plan will include a summary of the proposed compensation lands (e.g., the number and type of credits, location of mitigation bank or easement), parties responsible for the long-term management of the land, and the legal and funding mechanism for long-term conservation (e.g., holder of
conservation easement or fee title). The project proponent will submit evidence that the necessary mitigation has been implemented or that the project proponent has entered into a legal agreement to implement it and that compensatory plant populations will be preserved in perpetuity.
2. For restoring or enhancing riparian habitat within the treatment area or outside of the treatment area, the Compensatory Mitigation Plan will include a description of the proposed habitat improvements,
Initial Treatment: Y
Treatment Maintenance: Y
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success criteria that demonstrate the performance standard of
maintained habitat function has been met, legal and funding mechanisms, and parties responsible for long-term management and monitoring of the restored or enhanced habitat.
The project proponent will consult with CDFW and/or any other applicable responsible agency prior to finalizing the Compensatory Mitigation Plan to
satisfy that responsible agency’s requirements (e.g., permits, approvals) within the plan. Compensatory mitigation may be satisfied through compliance with permit conditions, or other authorizations obtained by the project proponent (e.g., Lake and Streambed Alteration Agreement), if these requirements are equally or more effective than the mitigation identified above.
Mitigation Measure BIO-4: Avoid State and Federally Protected
Wetlands.
Impacts to wetlands will be avoided using the following measures:
The qualified RPF or biologist will delineate the boundaries of federally protected wetlands according to methods established in the USACE wetlands delineation manual (Environmental Laboratory 1987) and the appropriate regional supplement for the ecoregion in which the treatment is being implemented.
The qualified RPF or biologist will delineate the boundaries of wetlands that may not meet the definition of waters of the United States, but would qualify as waters of the state, according to the state wetland procedures (California Water Boards 2019 or current procedures).
A qualified RPF or biologist will establish a buffer around wetlands and
mark the buffer boundary with high-visibility flagging, fencing, stakes, or clear, existing landscape demarcations (e.g., edge of a roadway). The buffer will be a minimum width of 25 feet but may be larger if deemed necessary. The appropriate size and shape of the buffer zone will be determined in coordination with the qualified RPF or biologist and will
depend on the type of wetland present (e.g., seasonal wetland, wet meadow, freshwater marsh, vernal pool), the timing of treatment (e.g., wet or dry time of year), whether any special-status species may occupy the wetland and the species’ vulnerability to the treatment activities, environmental conditions and terrain, and the treatment activity being
implemented.
A qualified RPF or biological technician will periodically inspect the materials demarcating the buffer to confirm that they are intact and visible, and wetland impacts are being avoided.
Within this buffer, herbicide application is prohibited.
Within this buffer, soil disturbance is prohibited. Accordingly, the following activities are not allowed within the buffer zone: mechanical
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to and during treatment activities
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treatments, prescribed herbivory, equipment and vehicle access or
staging.
Mitigation Measure BIO-5: Retain Nursery Habitat and Implement
Buffers to Avoid Nursery Sites.
The project proponent will implement the following measures while working
in treatment areas that contain nursery sites identified in surveys conducted pursuant to SPR BIO-10:
Retain Known Nursery Sites. A qualified RPF or biologist will identify the important habitat features of the wildlife nursery and, prior to treatment activities, will mark these features for avoidance and retention
during treatment.
Establish Avoidance Buffers. The project proponent will establish a non-disturbance buffer around the nursery site if activities are required while the nursery site is active/occupied. The appropriate size and shape of the buffer will be determined by a qualified RPF or biologist,
based on potential effects of project-related habitat disturbance, noise, visual disturbance, and other factors. No treatment activity will commence within the buffer area until a qualified RPF or biologist confirms that the nursery site is no longer active/occupied. Monitoring of the effectiveness of the non-disturbance buffer around the nursery site
by a qualified RPF, biologist, or biological technician during and after treatment activities will be required. If treatment activities cause agitated behavior of the individual(s), the buffer distance will be increased, or treatment activities modified until the agitated behavior stops. The qualified RPF, biologist, or biological technician will have the authority to
stop any treatment activities that could result in potential adverse effects to special-status species.
Initial Treatment: Y
Treatment
Maintenance: Y
Prior to and during treatment activities
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APPENDIX B
Open Space VMP Treatment Activities Maps
January February March April May June July August September October November December
Habitat Communities
Grassland/Herbaceous
Chaparral/Scrub
Oak Woodland
Riparian Woodland
Invasive Species
French Broom
English Ivy
Italian thistle Pulling
Tree of Heaven
Privet
Eucalyptus
Acacia
*Treatment timing should be the same each year.
**Nesting bird season occurs from March through August. AMMs apply.
Grazing
Grazing
Chemical
Pulling
Mowing / Cutting
Masticating / Cutting
Cutting / Chipping
Cutting
Cutting / PullingChemical
Pulling
Cutting
Cutting
Cutting
Grazing
PullingPullingCutting
Chemical
Chipping
Chemical
Cutting
Pulling
Pulling
Worcester Park - Moderate Risk Priority 2
Total Acres Treatment Standards Treatment Activity AMMs
Defensible Space 2.90
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Shaded Fuel Break 4.82
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Trails (lf)2698.35
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fuel Reduction Area 2.33
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Invasive Species Removal 3.01 See Section 10.1.3.4 - 10.1.3.8 Manual, Mechanical,*Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Mowing/Grazing 0.38 See Section 10.1.3.1 Mechanical, Prescribed Herbivory/Grazing Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Woody Slash & Debris Removal 1.25 See Section 10.1.2 Mechanical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Invasive Species
French Broom 0.09 See Section 10.1.3.6 Manual (Pulling), Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Acacia 0.57 See Section 10.1.3.4 Manual (Pulling), *Chemical, Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
English Ivy 1.25 See Section 10.1.3.7
Manual (Pulling), Mechanical (Cutting), Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Tree of Heaven 1.10 See Section 10.1.3.5 Manual (Pulling), *Chemical, Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Sensitive Habitat
Oak Woodland
8.68 See Section 10.1.3.3 Mechanical (Cutting)
Delineate work, treatment, and protected resource area boundaries (General Measure 1).Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody (Aquatic Resources Measure 32).
*Restrictions apply in riparian habitat. Seasonal and quantitative restrictions may apply to sensitive habitats. Nesting bird season occurs from March through August. See AMMs.
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous understories are present throughout the
Open Space VMP area. Recommendations for grassland/herbaceous areas follow:
· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height
and should be evenly distributed to prevent a buildup of debris.
· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils from erosion.
· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late summer. Grazing should follow the
grazing plan provided by the hired grazing management company.
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned, this is a sensitive vegetation
community and work in this habitat type should be minimal and conducted in accordance with AMMs and BMPs outlined in Section 11, Practices to Avoid or Minimize Impacts. Canopies in
this community are intermittent to continuous. In areas with breaks in the canopy understories are generally composed of grassland and brush and scrub species. Recommendations for oak
woodland areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub occupy the understory, a
horizontal distance of at least three times the size of the scrub should be maintained, as shown in Figure 10-3. If grassland or herbaceous fuels are present in understories, a minimum
distance of three times the vertical height of surface fuels should be maintained.
· Duff and leaf litter should not exceed 3 feet above ground level.
· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.
· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no
more than 20 acres will be converted to thin or create the shaded fuel break).
10.1.3.4 Acacia, Eucalyptus & Privet
Acacia and eucalyptus are highly invasive and highly flammable species that contains flammable resins and oils. This species occurs throughout the VMP Area in small, concentrated stands
mostly along roadways and adjacent to private properties. Recommendations for acacia areas follow:
· Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and maintain 10 to 20 horizontal feet, depending on the slope, between mature trees (Figure 10-3).
· Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings and resprouts and chemical treatments for stumps.
· A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared between the lowest lying branches and any scrub species (Figure 10-2).
· Cut and treat larger sapling and mature tree species with herbicides.
· Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.· Acacia and eucalyptus can be chipped in place so long as no plant material is left adjacent to sensitive riparian features and does not cover other plants.
10.1.3.5 Tree of Heaven
Tree of heaven is a highly invasive and flammable species that is commonly found in disturbed areas and along riparian corridors within the VMP Area. Recommendations for tree of heaven
areas follow:
· Pull seedlings and small saplings while soils are moist and loose. Remove taproots by digging around the base of the plant to remove all roots and prevent resprouts.
· Cut the stems of mature trees at the beginning of spring and once more in June or July to reduce seed production and deplete energy reserves.
· Cut and treat trunks or stems of large trees (i.e., greater than 4-inches diameter at breast height [dbh]) with chainsaws and apply herbicides.
10.1.3.6 Broom Species
Broom is common in VMP Area understories and can grow in grasslands, scrub, and woodland habitats. Recommendations for tree of heaven areas follow:
· Pull shrubs by hand using a weed wrench.
· Cut shrubs to just above ground level using loppers or brush cutters during the dry season in areas sensitive to ground disturbance.
10.1.3.7 English Ivy
English Ivy is a woody vine generally found in moist areas with dense canopies and good shade cover. Recommendations for tree of heaven areas follow:· Pull vines climbing trees and on the ground by hand or using rakes.
· Cut stems with pruners or loppers and dig up roots using shovels to prevent resprouts.
· Utilize prescribed herbivory, as appropriate, to remove ivy.
Worcester Treatment Standards
Santa Rosa Open Space Preserve - High Risk Priority 1
Total Acres Treatment Standards Treatment Activity AMMs
Defensible Space 3.83 See Section 10.1.3.3 Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Shaded Fuel Break 32.40
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Trails (lf)6041.67
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fire Road (lf)2961.86
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fuel Reduction Area 33.55
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Invasive Species Removal 0.25 See Section 10.1.3.4 Manual, Mechanical,*Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Mowing/Grazing 6.13 See Section 10.1.3.1 Mechanical, Prescribed Herbivory/Grazing Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Invasive Species
Eucalyptus 0.25 See Section 10.1.3.4 *Chemical, Mechanical (Cutting & Chipping)
Sensitive Habitat
Riparian 3.03 See Section 10.1.3.9 Manual, Mechanical (Cutting)
Delineate work, treatment, and protected resource area boundaries (General Measure 1).
Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).All AMMs in the Aquatic Resources Section apply.
Oak Woodland
46.43 See Section 10.1.3.3 Mechanical (Cutting)
Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody
(Aquatic Resources Measure 32).
Chaparral/Scrub 16.60 See Section 10.1.3.2 Mechanical (Cutting), Prescribed Herbivory/Grazing
Activities will avoid areas with special-status species (Biological Resources Measure 13).
Treatments in chaparral habitat require consultation with a qualified biologist (Biological Resources Measure 16).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody
(Aquatic Resources Measure 32).
*Restrictions apply in riparian habitat. Seasonal and quantitative restrictions may apply to sensitive habitats. Nesting bird season occurs from March through August. See AMMs.
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous understories are present throughout the Open Space VMP area. Recommendations for grassland/herbaceous areas follow:· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup of
debris.· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils from erosion.· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late summer. Grazing should follow the grazing plan provided by the hired grazing management company.
10.1.3.2 Chaparral/Scrub
Chaparral, scrub, and brush occur throughout the VMP Area and include species like California sage scrub and coyote brush. This vegetation type generally occurs in dense clusters with some tree species interspersed. Recommendations for chaparral/scrub areas follow:· Dead and dying debris should be cut and trimmed or removed. Roots can be left in place in order to maintain soil stability if necessary.· All vegetative debris should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup of debris.
· If trees are growing among this community, a minimum distance of 3 times the height of the scrub should be cleared between the lowest lying branches and the chaparral/scrub species (Figure 10-2).
· Horizontal separation should be 2 to 3 times the height of the chaparral/scrub (Figure 10-3).
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned, this is a sensitive vegetation community and work in this habitat type should be minimal and conducted in accordance with AMMs and BMPs outlined in Section 11, Practices to Avoid or Minimize Impacts. Canopies in this community are intermittent to continuous. In areas with breaks in the canopy understories are generally composed of grassland and brush and scrub species. Recommendations for oak woodland areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub occupy the understory, a horizontal distance of at least three times the size of the scrub
should be maintained, as shown in Figure 10-3. If grassland or herbaceous fuels are present in understories, a minimum distance of three times the vertical height of surface fuels should be maintained.· Duff and leaf litter should not exceed 3 feet above ground level.· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no more than 20 acres will be converted to thin or create the
shaded fuel break).
10.1.3.4 Acacia, Eucalyptus & Privet
Acacia and eucalyptus are highly invasive and highly flammable species that contains flammable resins and oils. This species occurs throughout the VMP Area in small, concentrated stands mostly along roadways and adjacent to private properties.
Recommendations for acacia areas follow:
· Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and maintain 10 to 20 horizontal feet, depending on the slope, between mature trees (Figure 10-3).· Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings and resprouts and chemical treatments for stumps.· A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared between the lowest lying branches and any scrub species (Figure 10-2).· Cut and treat larger sapling and mature tree species with herbicides.
· Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.
· Acacia and eucalyptus can be chipped in place so long as no plant material is left adjacent to sensitive riparian features and does not cover other plants.
10.1.3.9 Riparian Woodland
Riparian woodlands generally contain dense canopies with intermittent to continuous understories. Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel. Riparian areas are sensitive and vegetation management activities should be minimal to protect and avoid impacts to sensitive resources per the AMMs and BMPs in Section 11, Practices to Avoid or Minimize Impacts. Recommendations for riparian areas follow:· Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel.· Target climbing and ladder fuels, such as poison oak and giant reed (Arundo donax). Three feet of separation should be maintained between surface fuels and low-lying canopy branches.
· Remove highly flammable species (Section 10.4.2).
· Monitor canopy continuation and connectivity. In areas with gaps in the canopy, understory growth, including ladder fuels, is more prevalent. These gaps, if present, should maintain 3 times the vertical distance of the height of surface fuels which should be trimmed or removed to ensure no highly flammable pockets of dense vegetation forms (Figure 10-2).
Santa Rosa Treatment Standards
Heintz Open Space Preserve - High Risk Priority 1
Total Acres Treatment Standards Treatment Activity AMMs
Defensible Space 2.04
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Shaded Fuel Break 26.67
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Trails (lf)8428.98
See Section 10.1.3.3 & See Section 10.1.3.1 Mechanical (Cutting & Chipping) & Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fuel Reduction Area 49.10 See Section 10.1.3.3 Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Mowing/Grazing 10.29 See Section 10.1.3.1 Mechanical, Prescribed Herbivory/Grazing Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Sensitive Habitat
Oak Woodland
64.72 See Section 10.1.3.3 Mechanical (Cutting)
Delineate work area/treatment area boundary (General Measure 1).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody
(Aquatic Resources Measure 32).
Chaparral/Scrub
20.30 See Section 10.1.3.2 Mechanical (Cutting), Prescribed Herbivory/Grazing
Activities will avoid areas with special-status species (Biological Resources Measure 13). Treatments in chaparral habitat require consultation with a qualified biologist (Biological Resources Measure
16).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody
(Aquatic Resources Measure 32).
*Restrictions apply in riparian habitat. Seasonal and quantitative restrictions may apply to sensitive habitats. Nesting bird season occurs from March through August. See AMMs.
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous
understories are present throughout the Open Space VMP area. Recommendations for grassland/herbaceous areas follow:
· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum
break of 10 feet of horizontal distance should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must
not exceed 6 inches in height and should be evenly distributed to prevent a buildup of debris.
· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils
from erosion.
· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late
summer. Grazing should follow the grazing plan provided by the hired grazing management company.
10.1.3.2 Chaparral/Scrub
Chaparral, scrub, and brush occur throughout the VMP Area and include species like California sage scrub and coyote brush. This vegetation type generally
occurs in dense clusters with some tree species interspersed. Recommendations for chaparral/scrub areas follow:
· Dead and dying debris should be cut and trimmed or removed. Roots can be left in place in order to maintain soil stability if necessary.
· All vegetative debris should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be
evenly distributed to prevent a buildup of debris.
· If trees are growing among this community, a minimum distance of 3 times the height of the scrub should be cleared between the lowest lying branches
and the chaparral/scrub species (Figure 10-2).
· Horizontal separation should be 2 to 3 times the height of the chaparral/scrub (Figure 10-3).
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned,
this is a sensitive vegetation community and work in this habitat type should be minimal and conducted in accordance with AMMs and BMPs outlined in Section
11, Practices to Avoid or Minimize Impacts. Canopies in this community are intermittent to continuous. In areas with breaks in the canopy understories are
generally composed of grassland and brush and scrub species. Recommendations for oak woodland areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub
occupy the understory, a horizontal distance of at least three times the size of the scrub should be maintained, as shown in Figure 10-3. If grassland or
herbaceous fuels are present in understories, a minimum distance of three times the vertical height of surface fuels should be maintained.
· Duff and leaf litter should not exceed 3 feet above ground level.
· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.
· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak
woodland covers 100 acres, no more than 20 acres will be converted to thin or create the shaded fuel break).
Heintz Treatment Standards
Novitiate Park - Moderate Risk Priority 2
Total Acres Treatment Standards Treatment Activity AMMs
Defensible Space 2.27
See Section 10.1.3.3 & See Section 10.1.3.1 Mechanical (Cutting & Chipping) & Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Shaded Fuel Break 1.77 See Section 10.1.3.3 Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Trails (lf)1698.16
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fuel Reduction Area 0.18 See Section 10.1.3.3 Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Invasive Species Removal 7.90 See Section 10.1.3.4 - 10.1.3.8 Manual, Mechanical,*Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Mowing/Grazing 4.58 See Section 10.1.3.1 Mechanical, Prescribed Herbivory/Grazing Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Woody Slash & Debris Removal 1.29 See Section 10.1.2 Mechanical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Invasive Species
French Broom 0.77 See Section 10.1.3.6 Manual (Pulling), Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
English Ivy 1.16 See Section 10.1.3.7 Manual (Pulling), Mechanical (Cutting), Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Privet 1.16 See Section 10.1.3.4 Manual (Pulling), *Chemical, Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Italian thistle 0.41 See Section 10.1.3.8 Manual (Pulling), *Chemical, Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Tree of Heaven (and non-native grassland)5.56
See Section 10.1.3.5 &
See Section 10.1.3.1
Manual (Pulling), *Chemical, Mechanical (Cutting) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Sensitive Habitat
Riparian 0.62 See Section 10.1.3.9 Manual, Mechanical (Cutting)
Delineate work, treatment, and protected resource area boundaries (General Measure 1).Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
All AMMs in the Aquatic Resources Section apply.
Oak Woodland
6.09 See Section 10.1.3.3 Mechanical (Cutting)
Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody (Aquatic Resources Measure 32).
*Restrictions apply in riparian habitat. Seasonal and quantitative restrictions may apply to sensitive habitats. Nesting bird season occurs from March through August. See AMMs.
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous understories are present throughout the Open Space VMP area.
Recommendations for grassland/herbaceous areas follow:· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to
prevent a buildup of debris.
· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils from erosion.· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late summer. Grazing should follow the grazing plan provided by the hired grazing management company.
10.1.3.2 Chaparral/Scrub
Chaparral, scrub, and brush occur throughout the VMP Area and include species like California sage scrub and coyote brush. This vegetation type generally occurs in dense clusters with some tree species interspersed.
Recommendations for chaparral/scrub areas follow:
· Dead and dying debris should be cut and trimmed or removed. Roots can be left in place in order to maintain soil stability if necessary.· All vegetative debris should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup of debris.
· If trees are growing among this community, a minimum distance of 3 times the height of the scrub should be cleared between the lowest lying branches and the chaparral/scrub species (Figure 10-2).
· Horizontal separation should be 2 to 3 times the height of the chaparral/scrub (Figure 10-3).
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned, this is a sensitive vegetation community and work in this habitat
type should be minimal and conducted in accordance with AMMs and BMPs outlined in Section 11, Practices to Avoid or Minimize Impacts. Canopies in this community are intermittent to continuous. In areas with breaks in the
canopy understories are generally composed of grassland and brush and scrub species. Recommendations for oak woodland areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub occupy the understory, a horizontal distance of at least three times the size of the scrub should be maintained, as shown in Figure 10-3. If grassland or herbaceous fuels are present in understories, a minimum distance of three times the vertical height of surface fuels should be maintained.
· Duff and leaf litter should not exceed 3 feet above ground level.
· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.
· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no more than 20 acres will be converted to
thin or create the shaded fuel break).
10.1.3.4 Acacia, Eucalyptus & Privet
Acacia and eucalyptus are highly invasive and highly flammable species that contains flammable resins and oils. This species occurs throughout the VMP Area in small, concentrated stands mostly along roadways and adjacent to private properties. Recommendations for acacia areas follow:· Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and maintain 10 to 20 horizontal feet, depending on the slope, between mature trees (Figure 10-3).
· Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings and resprouts and chemical treatments for stumps.
· A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared between the lowest lying branches and any scrub species (Figure 10-2).
· Cut and treat larger sapling and mature tree species with herbicides. · Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.· Acacia and eucalyptus can be chipped in place so long as no plant material is left adjacent to sensitive riparian features and does not cover other plants.
10.1.3.6 Broom Species Broom is common in VMP Area understories and can grow in grasslands, scrub, and woodland habitats. Recommendations for tree of heaven areas follow:· Pull shrubs by hand using a weed wrench.
· Cut shrubs to just above ground level using loppers or brush cutters during the dry season in areas sensitive to ground disturbance.
10.1.3.7 English Ivy
English Ivy is a woody vine generally found in moist areas with dense canopies and good shade cover. Recommendations for tree of heaven areas follow:· Pull vines climbing trees and on the ground by hand or using rakes.
· Cut stems with pruners or loppers and dig up roots using shovels to prevent resprouts.
· Utilize prescribed herbivory, as appropriate, to remove ivy.
10.1.3.8 Italian Thistle
Italian thistle is an invasive species commonly found in disturbed areas, grasslands, and in riparian areas. This species occurs in concentrated patches throughout the VMP Area. Recommendations for Italian thistle areas follow:
· Smaller infestations can be removed by hand by pulling, digging, and cutting. Digging may be restricted in areas that contain sensitive habitat including riparian, chaparral, and oak woodland especially in areas upslope of aquatic resources and in areas with steep slopes due to the high level of soil disturbance.
· Pull plants by hand once the plant has bolted but prior to flower production.
· Cut plants by hand or brush cutters before the thistle flowers and again in early summer to reduce energy reserves. This treatment is best used in the dry season when soils are hard and hand pulling is more difficult.
· Graze infestations in the early spring when individual plants are approximately 4 to 6 inches high. Grazing should continue for about 2 to 3 weeks, or in coordination with the contracted grazing manager.
· Treat plants with herbicides in mid-spring before they spread seed. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.
10.1.3.9 Riparian Woodland
Riparian woodlands generally contain dense canopies with intermittent to continuous understories. Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel. Riparian areas are sensitive and vegetation management activities should be minimal to protect and avoid impacts to sensitive resources per the AMMs and BMPs in Section 11, Practices to Avoid or Minimize Impacts. Recommendations for riparian areas follow:
· Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel.
· Target climbing and ladder fuels, such as poison oak and giant reed (Arundo donax). Three feet of separation should be maintained between surface fuels and low-lying canopy branches.
· Remove highly flammable species (Section 10.4.2).· Monitor canopy continuation and connectivity. In areas with gaps in the canopy, understory growth, including ladder fuels, is more prevalent. These gaps, if present, should maintain 3 times the vertical distance of the height of surface fuels which should be trimmed or removed to ensure no highly flammable pockets of dense vegetation forms (Figure 10-2).
Novitiate Treatment Standards
La Rinconada Park - Low Risk Priority 3
Total Acres Treatment Standards Treatment Activity AMMs
Defensible Space 0.83
See Section 10.1.3.3 & See Section 10.1.3.1 Mechanical (Cutting & Chipping) & Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Shaded Fuel Break 6.84 See Section 10.1.3.3 Mechanical (Cutting)
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
All Aquatic Resources Measures apply.
Trails (lf)1321.83
See Section 10.1.3.3 &
See Section 10.1.3.1
Mechanical (Cutting & Chipping) &
Prescribed Herbivory/Grazing
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Fuel Reduction Area 0.80 See Section 10.1.3.3 Mechanical (Cutting)
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
All Aquatic Resources Measures apply.
Invasive Species Removal 0.48 See Section 10.1.3.4 - 10.1.3.8 Manual, Mechanical,*Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Mowing/Grazing 0.29 See Section 10.1.3.1 Mechanical, Prescribed Herbivory/Grazing Livestock will be excluded from riparian areas using exclusion fencing (Aquatic Resources Measure 33).
Invasive Species
English Ivy 0.33 See Section 10.1.3.7 Manual (Pulling), Mechanical (Cutting), Prescribed Herbivory/Grazing Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
French Broom 0.15 See Section 10.1.3.6 Manual (Pulling), Mechanical (Cutting)Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Acacia -See Section 10.1.3.4 Manual (Pulling), Mechanical (Cutting)*Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
Privet -See Section 10.1.3.4 Manual (Pulling), Mechanical (Cutting), *Chemical Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Sensitive Habitat
Riparian 3.28 See Section 10.1.3.9 Manual, Mechanical (Cutting)
Delineate work, treatment, and protected resource area boundaries (General Measure 1).Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).
All AMMs in the Aquatic Resources Section apply.
Oak Woodland
3.24 See Section 10.1.3.3 Mechanical (Cutting)
Activities will avoid areas with special-status species (Biological Resources Measure 13).
Limit the risk of pathogens spread through BMPs (Biological Resources Measure 19).Soil and trimmed/chipped vegetation will not be placed where it covers other vegetation or near a waterbody (Aquatic Resources Measure 32).
*Restrictions apply in riparian habitat. Seasonal and quantitative restrictions may apply to sensitive habitats. Nesting bird season occurs from March through August. See AMMs.
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous understories are present throughout the Open
Space VMP area. Recommendations for grassland/herbaceous areas follow:
· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance
should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and
should be evenly distributed to prevent a buildup of debris.· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils from erosion.
· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late summer. Grazing should follow the
grazing plan provided by the hired grazing management company.
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned, this is a sensitive vegetation
community and work in this habitat type should be minimal and conducted in accordance with AMMs and BMPs outlined in Section 11, Practices to Avoid or Minimize Impacts. Canopies in this
community are intermittent to continuous. In areas with breaks in the canopy understories are generally composed of grassland and brush and scrub species. Recommendations for oak woodland
areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub occupy the understory, a horizontal
distance of at least three times the size of the scrub should be maintained, as shown in Figure 10-3. If grassland or herbaceous fuels are present in understories, a minimum distance of three times
the vertical height of surface fuels should be maintained.· Duff and leaf litter should not exceed 3 feet above ground level.
· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.
· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no more
than 20 acres will be converted to thin or create the shaded fuel break).
10.1.3.4 Acacia, Eucalyptus & Privet
Acacia and eucalyptus are highly invasive and highly flammable species that contains flammable resins and oils. This species occurs throughout the VMP Area in small, concentrated stands mostly
along roadways and adjacent to private properties. Recommendations for acacia areas follow:· Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and maintain 10 to 20 horizontal feet, depending on the slope, between mature trees (Figure 10-3).
· Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings and resprouts and chemical treatments for stumps.
· A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared between the lowest lying branches and any scrub species (Figure 10-2).
· Cut and treat larger sapling and mature tree species with herbicides.
· Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.
· Acacia and eucalyptus can be chipped in place so long as no plant material is left adjacent to sensitive riparian features and does not cover other plants.
10.1.3.6 Broom Species
Broom is common in VMP Area understories and can grow in grasslands, scrub, and woodland habitats. Recommendations for tree of heaven areas follow:
· Pull shrubs by hand using a weed wrench.
· Cut shrubs to just above ground level using loppers or brush cutters during the dry season in areas sensitive to ground disturbance.
10.1.3.7 English Ivy
English Ivy is a woody vine generally found in moist areas with dense canopies and good shade cover. Recommendations for tree of heaven areas follow:
· Pull vines climbing trees and on the ground by hand or using rakes.· Cut stems with pruners or loppers and dig up roots using shovels to prevent resprouts.
· Utilize prescribed herbivory, as appropriate, to remove ivy.
10.1.3.9 Riparian Woodland
Riparian woodlands generally contain dense canopies with intermittent to continuous understories. Downed branches, woody slash, and debris should be removed adjacent to stream and creek
channels to reduce surface fuel. Riparian areas are sensitive and vegetation management activities should be minimal to protect and avoid impacts to sensitive resources per the AMMs and BMPs
in Section 11, Practices to Avoid or Minimize Impacts. Recommendations for riparian areas follow:· Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel.
· Target climbing and ladder fuels, such as poison oak and giant reed (Arundo donax). Three feet of separation should be maintained between surface fuels and low-lying canopy branches.
· Remove highly flammable species (Section 10.4.2).
· Monitor canopy continuation and connectivity. In areas with gaps in the canopy, understory growth, including ladder fuels, is more prevalent. These gaps, if present, should maintain 3 times
the vertical distance of the height of surface fuels which should be trimmed or removed to ensure no highly flammable pockets of dense vegetation forms (Figure 10-2).
La Rinconada Treatment Standards
Acacia
• Pulling•Chemical•Cutting
Eucalyptus
•Chemical
•Cutting•Chipping
Grassland
•Mowing / Cutting
• Grazing
Italian Thistle
• Pulling
• Grazing•Chemical
French Broom
• Pulling
•Cutting
Tree of Heaven
• Pulling
•Chemical•Cutting
English Ivy
•Cutting
• Pulling• Grazing
Privet
•Cutting
Oak Woodland
•Mechanical (Cutting / Chipping)
Chaparral/Scrub
•Prescribed Herbivory/Grazing•Mechanical (Masticating / Cutting)
Riparian
•Mechanical (Cutting)
Grassland
•Prescribed Herbivory/Grazing
•Mechanical (Mowing / Cutting)
10.1.3.1 Grassland/Herbaceous
Grassland and certain herbaceous species are flash fuels with quick ignition, burn, and dispersal rates. Non-native annual grassland and herbaceous understories are present throughout the Open Space VMP area. Recommendations for grassland/herbaceous areas follow:
· In areas where grassland transitions to woodland habitat, a fuel break should be maintained to prevent ignition of surrounding vegetation. A minimum break of 10 feet of horizontal distance should be maintained between grassland and woodland habitat.
· Woody slash and debris created by dead herbaceous vegetation should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup of debris.
· Cut grass must be removed if it exceeds 6 inches of vertical height. If it is below 6 inches in height, grass cuttings can be left in place to protect ground soils from erosion.· Grazing is allowed in this habitat and can occur year-round in certain areas, although it is recommended and most effective in late spring through late summer. Grazing should follow the grazing plan provided by the hired grazing management
company.
10.1.3.2 Chaparral/Scrub
Chaparral, scrub, and brush occur throughout the VMP Area and include species like California sage scrub and coyote brush. This vegetation type generally occurs in dense clusters with some tree species interspersed. Recommendations for
chaparral/scrub areas follow:· Dead and dying debris should be cut and trimmed or removed. Roots can be left in place in order to maintain soil stability if necessary.
· All vegetative debris should be hauled off-site or chipped in place. Vegetative materials chipped in place must not exceed 6 inches in height and should be evenly distributed to prevent a buildup of debris.
· If trees are growing among this community, a minimum distance of 3 times the height of the scrub should be cleared between the lowest lying branches and the chaparral/scrub species (Figure 10-2).· Horizontal separation should be 2 to 3 times the height of the chaparral/scrub (Figure 10-3).
10.1.3.3 Oak Woodland
Oak woodland dominates the VMP Area and includes a combination of coast live oak, valley oak, California bay, buckeye, and walnut. As previously mentioned, this is a sensitive vegetation community and work in this habitat type should be minimal
and conducted in accordance with AMMs and BMPs outlined in Section 11, Practices to Avoid or Minimize Impacts. Canopies in this community are intermittent to continuous. In areas with breaks in the canopy understories are generally composed of grassland and brush and scrub species. Recommendations for oak woodland areas follow:
· In canopy breaks, maintain a vertical distance of 3 feet between surface fuels and low-lying tree branches (Figure 10-2). In areas where shrubs and scrub occupy the understory, a horizontal distance of at least three times the size of the scrub
should be maintained, as shown in Figure 10-3. If grassland or herbaceous fuels are present in understories, a minimum distance of three times the vertical height of surface fuels should be maintained.· Duff and leaf litter should not exceed 3 feet above ground level.
· If highly flammable species (Section 10.4.2) are present in oak woodland habitat, they should be removed and hauled off-site.· Only shaded fuel breaks or thinning will be used in oak woodland and will not remove more than 20 percent of oak woodland vegetation (i.e., if the oak woodland covers 100 acres, no more than 20 acres will be converted to thin or create the
shaded fuel break).
10.1.3.4 Acacia, Eucalyptus & Privet
Acacia and eucalyptus are highly invasive and highly flammable species that contains flammable resins and oils. This species occurs throughout the VMP Area in small, concentrated stands mostly along roadways and adjacent to private properties.
Recommendations for acacia areas follow:· Pull seedlings and small saplings by hand or with a weed wrench. Thin dense clusters and maintain 10 to 20 horizontal feet, depending on the slope, between mature trees (Figure 10-3).
· Regulate and control stump sprouts, resprouts, and sapling growth using hand pulling for saplings and resprouts and chemical treatments for stumps.· A minimum vertical distance of 3 times the height of resprouts and saplings shall be cleared between the lowest lying branches and any scrub species (Figure 10-2).
· Cut and treat larger sapling and mature tree species with herbicides.
· Drill and inject with herbicide in applicable areas. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.· Acacia and eucalyptus can be chipped in place so long as no plant material is left adjacent to sensitive riparian features and does not cover other plants.
10.1.3.5 Tree of Heaven
Tree of heaven is a highly invasive and flammable species that is commonly found in disturbed areas and along riparian corridors within the VMP Area. Recommendations for tree of heaven areas follow:
· Pull seedlings and small saplings while soils are moist and loose. Remove taproots by digging around the base of the plant to remove all roots and prevent resprouts.· Cut the stems of mature trees at the beginning of spring and once more in June or July to reduce seed production and deplete energy reserves.
· Cut and treat trunks or stems of large trees (i.e., greater than 4-inches diameter at breast height [dbh]) with chainsaws and apply herbicides.
10.1.3.6 Broom Species Broom is common in VMP Area understories and can grow in grasslands, scrub, and woodland habitats. Recommendations for tree of heaven areas follow:· Pull shrubs by hand using a weed wrench.
· Cut shrubs to just above ground level using loppers or brush cutters during the dry season in areas sensitive to ground disturbance.
10.1.3.7 English Ivy
English Ivy is a woody vine generally found in moist areas with dense canopies and good shade cover. Recommendations for tree of heaven areas follow:· Pull vines climbing trees and on the ground by hand or using rakes.
· Cut stems with pruners or loppers and dig up roots using shovels to prevent resprouts.
· Utilize prescribed herbivory, as appropriate, to remove ivy.
10.1.3.8 Italian Thistle
Italian thistle is an invasive species commonly found in disturbed areas, grasslands, and in riparian areas. This species occurs in concentrated patches throughout the VMP Area. Recommendations for Italian thistle areas follow:
· Smaller infestations can be removed by hand by pulling, digging, and cutting. Digging may be restricted in areas that contain sensitive habitat including riparian, chaparral, and oak woodland especially in areas upslope of aquatic resources and in areas with steep slopes due to the high level of soil disturbance.
· Pull plants by hand once the plant has bolted but prior to flower production.· Cut plants by hand or brush cutters before the thistle flowers and again in early summer to reduce energy reserves. This treatment is best used in the dry season when soils are hard and hand pulling is more difficult.
· Graze infestations in the early spring when individual plants are approximately 4 to 6 inches high. Grazing should continue for about 2 to 3 weeks, or in coordination with the contracted grazing manager.· Treat plants with herbicides in mid-spring before they spread seed. Restrictions apply to sensitive habitat areas, see Section 11, Practices to Avoid or Minimize Impacts.
10.1.3.9 Riparian Woodland
Riparian woodlands generally contain dense canopies with intermittent to continuous understories. Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel. Riparian areas are
sensitive and vegetation management activities should be minimal to protect and avoid impacts to sensitive resources per the AMMs and BMPs in Section 11, Practices to Avoid or Minimize Impacts. Recommendations for riparian areas follow:· Downed branches, woody slash, and debris should be removed adjacent to stream and creek channels to reduce surface fuel.
· Target climbing and ladder fuels, such as poison oak and giant reed (Arundo donax). Three feet of separation should be maintained between surface fuels and low-lying canopy branches.
· Remove highly flammable species (Section 10.4.2).· Monitor canopy continuation and connectivity. In areas with gaps in the canopy, understory growth, including ladder fuels, is more prevalent. These gaps, if present, should maintain 3 times the vertical distance of the height of surface fuels which
should be trimmed or removed to ensure no highly flammable pockets of dense vegetation forms (Figure 10-2).
VMP Treatment Standards
ATTACHMENT 4
Attachment 4 - Link to the Vegetation Management Plan for the Town of Los
Gatos, Santa Clara County, California dated June 2021:
http://www.losgatosca.gov/DocumentCenter/View/36713/Los-Gatos-Veg-Mgmt-
Plan_20210616
SUNGARD PENTAMATION PAGE NUMBER: 1DATE: 07/18/2024 TOWN OF LOS GATOS AUDIT11TIME: 12:33:24 EXPENDITURE TRANSACTION ANALYSISSELECTION CRITERIA: transact.key_orgn like ’%832-4508’ACCOUNTING PERIOD: 1/25FUND - 411 - GFAR PROGRAM - 411-832-4508 - VEGETATION MANAGEMENT ACCOUNT DATE T/C PO REFERENCE VENDOR BUDGET EXPENDITURES ENCUMBRANCES DESCRIPTION82105 BLUEPRINT/COPY/POSTAGE 13/21 08/16/21 19 P13053 2,357.01 CC-MAILER 13/21 08/16/21 11 .00 SETUP TOTAL BLUEPRINT/COPY/POSTAGE .00 2,357.01 .0082405 PROJECT CONSTRUCTION 10/19 04/15/19 11 .00 SETUP 1 /20 07/01/19 11 200,000.00 POSTED FROM BUDGET SYSTEM2 /20 08/20/19 13 300,707.00 BA-20-02 CIPR FUNDING 12/20 06/19/20 17 20200343-01 5711 SWCA INC 199,828.00 CONSULTATION ON VEGETATIO12/20 06/30/20 17 20200354-01 5693 FIRE SAFETY SUPP 77,129.00 DESIGN & INSTALL FIRE SUP12/20 06/30/20 17 20200354-02 5693 FIRE SAFETY SUPP 15,426.00 UNANTICIPATED REPAIRS, NO1 /21 07/12/20 11 .00 POSTED FROM BUDGET SYSTEM2 /21 08/27/20 21 142532 1752 SANTA CLARA COUN 50.00 .00 CEQA-VEG MGMT PROJ 13/20 09/02/20 21 20200343-01 142668 5711 SWCA INC 13,519.50 -13,519.50 061520-070220 SERVICE 13/20 09/18/20 18 20200354-01 5693 FIRE SAFETY SUPP -77,129.00 CO#1-UPDATE FUNDING 13/20 09/18/20 18 20200354-02 5693 FIRE SAFETY SUPP -15,426.00 CO#1-UPDATE FUNDING 1 /21 09/22/20 17 20200343-01 5711 SWCA INC 186,308.50 ENCUMB CARRIED FORWARD 1 /21 09/22/20 17 20200354-02 5693 FIRE SAFETY SUPP .00 ENCUMB CARRIED FORWARD 1 /21 09/22/20 17 20200354-01 5693 FIRE SAFETY SUPP .00 ENCUMB CARRIED FORWARD 13/20 09/22/20 18 20200354-02 5693 FIRE SAFETY SUPP .00 PRIOR YEAR ENCUMBRANCE 13/20 09/22/20 18 20200343-01 5711 SWCA INC -186,308.50 PRIOR YEAR ENCUMBRANCE 13/20 09/22/20 18 20200354-01 5693 FIRE SAFETY SUPP .00 PRIOR YEAR ENCUMBRANCE 3 /21 09/23/20 21 20200343-01 142824 5711 SWCA INC 31,882.38 -31,882.38 SERVICES THRU 080120 13/20 09/28/20 13 -487,187.50 FY20 CARRYFORWARD TO FY214 /21 10/23/20 21 20200343-01 5711 SWCA INC .00 -154,426.12 CONSULTATION ON VEGETATIO5 /21 11/13/20 17 20210178-01 5711 SWCA INC 154,426.12 CONSULTATION ON VEGETATIO5 /21 11/13/20 21 20210178-01 143240 5711 SWCA INC 19,524.50 -19,524.50 SERVICES THRU 100320 5 /21 11/13/20 21 20210178-01 143240 5711 SWCA INC 39,689.97 -39,689.97 SERVICES THRU 082920 2 /21 12/01/20 13 487,187.50 FY20 CARRYFORWARD CIP 4 /21 12/07/20 19 OCT032 611.10 CC-NOTICE POSTCARDS 8 /21 02/10/21 21 20210178-01 143979 5711 SWCA INC 21,480.50 -21,480.50 SERVICES THRU 120520 8 /21 02/10/21 21 20210178-01 143979 5711 SWCA INC 19,265.75 -19,265.75 SERVICES THRU 103120 8 /21 02/16/21 13 -250,000.00 BA-21-14 MDYR TO 812-01309 /21 03/18/21 21 20210178-01 144442 5711 SWCA INC 3,733.75 -3,733.75 SERVICES THRU 030621 10/21 04/29/21 21 20210178-01 144683 5711 SWCA INC 16,482.50 -16,482.50 SERVICES THRU 041021 10/21 04/29/21 21 20210178-01 144609 5711 SWCA INC 710.00 -710.00 SERVICES THRU 020621 10/21 04/29/21 21 20210178-01 144609 5711 SWCA INC 14,524.27 -14,524.27 SERVICES THRU 010921 11/21 05/26/21 21 20210178-01 144982 5711 SWCA INC 13,035.00 -13,035.00 SERVICES THRU 050821 1 /22 07/01/21 11 .00 POSTED FROM BUDGET SYSTEM13/21 08/11/21 18 20210178-01 5711 SWCA INC 26,000.00 CO#1-1ST AMENDMENT 13/21 08/11/21 21 20210178-01 145581 5711 SWCA INC 10,116.25 -10,116.25 SERVICES THRU 060521 13/21 08/13/21 21 20210178-01 145581 5711 SWCA INC 4,086.94 -4,086.94 060721-071021 P13 SVC 1 /22 08/20/21 17 20210178-01 5711 SWCA INC 17,776.69 ENCUMB CARRIED FORWARD 1 /22 08/20/21 17 20200354-01 5693 FIRE SAFETY SUPP .00 ENCUMB CARRIED FORWARD 1 /22 08/20/21 17 20200354-02 5693 FIRE SAFETY SUPP .00 ENCUMB CARRIED FORWARD 13/21 08/20/21 18 20210178-01 5711 SWCA INC -17,776.69 PRIOR YEAR ENCUMBRANCE RUN DATE 07/18/2024 TIME 12:33:30 SUNGARD PENTAMATION - FUND ACCOUNTING V4.3
SUNGARD PENTAMATION PAGE NUMBER: 2DATE: 07/18/2024 TOWN OF LOS GATOS AUDIT11TIME: 12:33:24 EXPENDITURE TRANSACTION ANALYSISSELECTION CRITERIA: transact.key_orgn like ’%832-4508’ACCOUNTING PERIOD: 1/25FUND - 411 - GFAR PROGRAM - 411-832-4508 - VEGETATION MANAGEMENT ACCOUNT DATE T/C PO REFERENCE VENDOR BUDGET EXPENDITURES ENCUMBRANCES DESCRIPTION82405 PROJECT CONSTRUCTION (cont’d)13/21 08/20/21 18 20200354-02 5693 FIRE SAFETY SUPP .00 PRIOR YEAR ENCUMBRANCE 13/21 08/20/21 18 20200354-01 5693 FIRE SAFETY SUPP .00 PRIOR YEAR ENCUMBRANCE 2 /22 08/20/21 21 20210178-01 145656 5711 SWCA INC 1,669.31 -1,669.31 THRU 071021 P1 SVC 1 /22 10/20/21 13 39,637.58 FY21 EXP CARRYFORWARD 13/21 10/26/21 13 -39,637.58 FY21 EXP CARRYFORWARDS 5 /22 11/23/21 21 20210178-01 146579 5711 SWCA INC 785.75 -785.75 SERVICES THRU 110621 7 /22 01/26/22 21 20210178-01 146995 5711 SWCA INC 1,289.50 -1,289.50 SERVICES THRU 120421 1 /23 07/01/22 11 .00 POSTED FROM BUDGET SYSTEM13/22 07/06/22 21 20210178-01 148512 5711 SWCA INC 3,272.00 -3,272.00 SERVICES THRU 060422 13/22 08/18/22 21 20210178-01 148953 5711 SWCA INC 7,978.25 -7,978.25 P13 SVCS THRU 070922 1 /23 08/23/22 17 20210178-01 5711 SWCA INC 2,781.88 ENCUMB CARRIED FORWARD 13/22 08/23/22 18 20210178-01 5711 SWCA INC -2,781.88 PRIOR YEAR ENCUMBRANCE 2 /23 08/25/22 21 20210178-01 149015 5711 SWCA INC 2,330.00 -2,330.00 P1 SVCS THRU 070922 1 /23 09/07/22 17 20200354-02 5693 FIRE SAFETY SUPP .00 ENCUMB CARRIED FORWARD 13/22 09/07/22 18 20200354-02 5693 FIRE SAFETY SUPP .00 PRIOR YEAR ENCUMBRANCE 13/22 11/09/22 13 -24,642.77 EXP CARRYFWD TO FY23 2 /23 11/09/22 13 24,642.77 EXP CARRYFWD FR FY22 7 /23 01/31/23 17 20230191-01 5711 SWCA INC 21,855.00 VEGETATION MANAGEMENT PLA7 /23 01/31/23 21 20210178-01 5711 SWCA INC .00 -451.88 CONSULTATION ON VEGETATIO9 /23 03/01/23 21 20230191-01 150819 5711 SWCA INC 1,787.75 -1,787.75 SERVICES THRU 021123 10/23 04/18/23 21 20230191-01 151152 5711 SWCA INC 10,768.75 -10,768.75 SERVICES THRU 031123 11/23 05/16/23 21 20230191-01 151429 5711 SWCA INC 734.00 -734.00 SERVICES THRU 041523 11/23 05/25/23 21 20230191-01 151683 5711 SWCA INC 922.75 -922.75 SERVICES THRU 051323 1 /24 07/01/23 11 100,000.00 POSTED FROM BUDGET SYSTEM2 /24 07/01/23 13 5,880.77 FY23 CIP EXP CARRYFORWARD13/23 07/11/23 21 20230191-01 151933 5711 SWCA INC 1,043.75 -1,043.75 SERVICES THRU 061023 13/23 08/23/23 21 20230191-01 152299 5711 SWCA INC 1,175.00 -1,175.00 SERVICES THRU 063023 1 /24 09/11/23 17 20230191-01 5711 SWCA INC 5,423.00 ENCUMB CARRIED FORWARD 13/23 09/11/23 18 20230191-01 5711 SWCA INC -5,423.00 PRIOR YEAR ENCUMBRANCE 3 /24 09/12/23 21 20230191-01 152487 5711 SWCA INC 1,309.00 -1,309.00 SERVICES THRU 071523 4 /24 10/03/23 21 20230191-01 152890 5711 SWCA INC 4,082.75 -4,082.75 SERVICES THRU 090923 13/23 10/26/23 13 -5,880.77 FY23 CIP EXP BUDGET TO CF5 /24 11/21/23 13 -3,000.00 CM 11/21/23 #13 6 /24 12/05/23 17 20240205-01 3571 OPENGOV INC 3,000.00 PPW CLOUD BASED PROCUREME6 /24 12/13/23 19 DEC043 -3,000.00 RECLASS OPENGOV INV11722 6 /24 12/13/23 21 20240205-01 153467 3571 OPENGOV INC 3,000.00 -3,000.00 PPW CLOUD BASED PROCUREME9 /24 03/08/24 21 20230191-01 5711 SWCA INC .00 -31.25 VEGETATION MANAGEMENT PLA1 /25 07/03/24 11 432,959.23 POSTED FROM BUDGET SYSTEMTOTAL PROJECT CONSTRUCTION 780,666.23 247,860.97 .00TOTAL VEGETATION MANAGEMENT 780,666.23 250,217.98 .00TOTAL GFAR 780,666.23 250,217.98 .00TOTAL REPORT 780,666.23 250,217.98 .00 RUN DATE 07/18/2024 TIME 12:33:31 SUNGARD PENTAMATION - FUND ACCOUNTING V4.3
SUNGARD PENTAMATION PAGE NUMBER: 1DATE: 07/24/2024 TOWN OF LOS GATOS AUDIT31TIME: 17:22:56 REVENUE TRANSACTION ANALYSISSELECTION CRITERIA: transact.key_orgn like ’%832-4508’ACCOUNTING PERIOD: 1/25FUND - 411 - GFAR PROGRAM - 411-832-4508 - VEGETATION MANAGEMENT ACCOUNT DATE T/C RECEIVE REFERENCE PAYER/VENDOR BUDGET RECEIPTS RECEIVABLES DESCRIPTION43219 HAZARD MITIGATION GRANT 4 /23 10/28/22 19 OCT036 57,769.20 RECLASS FR 812-0130 4 /23 10/28/22 19 OCT036 2,289.00 RECLASS FR 812-0130 6 /23 12/12/22 12 .00 SETUP 8 /23 02/28/23 19 FEB034 -60,058.20 TO 421-832-4508 43219 1 /24 07/01/23 12 .00 POSTED FROM BUDGET SYSTEM 1 /25 07/03/24 12 .00 POSTED FROM BUDGET SYSTEMTOTAL HAZARD MITIGATION GRANT .00 .00 .0049111 FR GENERAL FUND 1 /20 07/01/19 12 .00 SETUP 2 /20 08/20/19 19 AUG033 300,707.00 BA-20-02 CIPR FUNDING 2 /20 08/20/19 14 300,707.00 BA-20-02 CIPR FUNDING 1 /21 07/12/20 12 .00 POSTED FROM BUDGET SYSTEM 1 /22 07/01/21 12 .00 POSTED FROM BUDGET SYSTEM 1 /23 07/01/22 12 .00 POSTED FROM BUDGET SYSTEM 1 /24 07/01/23 12 .00 POSTED FROM BUDGET SYSTEM 1 /25 07/03/24 12 .00 POSTED FROM BUDGET SYSTEMTOTAL FR GENERAL FUND 300,707.00 300,707.00 .00TOTAL VEGETATION MANAGEMENT 300,707.00 300,707.00 .00TOTAL GFAR 300,707.00 300,707.00 .00 RUN DATE 07/24/2024 TIME 17:23:02SUNGARD PENTAMATION - FUND ACCOUNTING V4.3
SUNGARD PENTAMATION PAGE NUMBER: 2DATE: 07/24/2024 TOWN OF LOS GATOS AUDIT31TIME: 17:22:56 REVENUE TRANSACTION ANALYSISSELECTION CRITERIA: transact.key_orgn like ’%832-4508’ACCOUNTING PERIOD: 1/25FUND - 421 - GRANT FUNDED PROGRAM - 421-832-4508 - VEGETATION MANAGEMENT ACCOUNT DATE T/C RECEIVE REFERENCE PAYER/VENDOR BUDGET RECEIPTS RECEIVABLES DESCRIPTION43219 HAZARD MITIGATION GRANT 8 /23 02/28/23 19 FEB034 60,058.20 FR 411-832-4508 43219 9 /23 03/15/23 12 .00 1 /24 07/01/23 12 .00 POSTED FROM BUDGET SYSTEM 1 /25 07/03/24 12 .00 POSTED FROM BUDGET SYSTEMTOTAL HAZARD MITIGATION GRANT .00 60,058.20 .00TOTAL VEGETATION MANAGEMENT .00 60,058.20 .00TOTAL GRANT FUNDED .00 60,058.20 .00TOTAL REPORT 300,707.00 360,765.20 .00 RUN DATE 07/24/2024 TIME 17:23:02SUNGARD PENTAMATION - FUND ACCOUNTING V4.3
Budget
Phase 2 - Source of Funds
GFAR 530,448$
FEMA Hazard Mitigation Grant (Requested with this Staff Report)1,627,320$
Total Budget 2,157,768$
Phase 2 - Expenditures
Consultant Services Agreement with Sequoia Ecological Consulting
(Requested with this Staff Report)
Total Expenditures
Total Project Balance
FOR INTERNAL USE:
Budget
Phase 2 - Source of Funds
GFAR 530,448$
FEMA Hazard Mitigation Grant (Requested with this Staff Report)1,591,344$
Total Budget 2,121,792$
Phase 2 - Expenditures
GFAR
FEMA Hazard Mitigation Grant - Consultant Services Agreement with
Sequoia Ecological Consulting (Requested with this Staff Report)
Total Expenditures
Available Balance GFAR
Available Balance FEMA Hazard Mitigation Grant
Total Project Balance
Vegetation Management - Town-wide
CIP No. 832-4508
Vegetation Management - Town-wide
CIP No. 832-4508
Costs
Project Costs $ 1,591,344.75
Subrecipient Management Costs $ 35,974.97
$ 1,627,319.72
Costs
181,165$
181,165$
1,976,603$
Costs
Costs
-$
181,165$
181,165$
530,448$
1,410,179$
1,940,627$
Vegetation Management - Town-wide
CIP No. 832-4508
Vegetation Management - Town-wide
CIP No. 832-4508
Prior GFAR Funding
244,826$
5,423$
97,458$
347,707$ as of 6/30/24
347,707$ Prior Funding
432,959$ 24/25 Add'l funding for Phase 2
780,666$
832-4508 Vegetation Management Risk Reduction (Open Space)*Original subapplication signed 7/3/19 shows $2,002,828 as Total Project Cost for Phase 1 & 2
Signed Subapplication DR4407.pdf
PHASE 1
Approval Federal Share Non-Federal Share Total Project Cost
Phase 1, Supplement 61 $64,188 $21,396 $85,584
(75% of total Project cost)(25% of total project cost)
Phase 1, Management Cost $2,289.00 $0.00 $2,289.00
HMGP-4407-506-75R Approval Package.pdf
Phase 1
Total Project Cost
Notification of SRMC Obligation.pdf $87,873.00
PHASE 2
Approval Federal Share Non-Federal Share Total Project Cost
Phase 2, Supplement 259 $1,591,344.75 $530,448.25 $2,121,793
(75% of total Project cost)(25% of total project cost)
Phase 2, Management Cost $35,974.97 $0.00 $35,974.97
Total Federal Share
$1,627,319.72
HMGP-4407-506-75R Approval Package.pdf
Phase 2
Total Project Cost
$2,157,767.97 Signed Match Letter showed Town Match as $500,707 - this is incorrect; s/b $530,448.25
Local Match Fund Letter Signed Copy Revised.pdf
$ 530,448.25 Town Match
Total Amount Phase
1 & 2
$ 97,489.02 in 411-832-4508 $2,245,640.97 FYI - Cost estimate spreadsheet shows estimates for Phase 1 - $81,855 and Phase 2 - $2,121,793 -- Total = $2,207,377
$432,959.23 additional GFAR funding added to budget in 24/25 for Phase 2 Cost Estimate SpreadsheetLGv2.xlsx