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Attachment 16H. T. HARVEY & ASSOCIATES ECOLOGICAL CONSULTANTS 28 September 2011 Town of Los Gatos Town Council 110 E. Main Street Los Gatos, California 95031 SUBJECT: Riviera Terrace Apartments- Riparian Corridor Dear Town of Los Gatos Planning Staff: RECEIVED Cf rl 2011 TOWI OF LOS GATOS PLANNING DIVISION During the September 14 Planning Commission hearing for the Riviera Terrace Apartment Project the applicant presented a number of additional enhancements proposed to occur on the project site and also within the riparian habitat along Los Gatos Creek that is within the property boundaries. These enhancements included: the addition of 6,690 square feet of permeable pavers; exterior and landscape indirect lighting; native vines plantings along the rear fence; native tree plantings in tree pockets within the proposed expanded parking area, and; up to 10,000 square feet of native tree and shrub plantings within the riparian habitat. During the hearing, one of the members of the Town Planning Commission requested that additional detailed information be supplied regarding the 10,000 square feet of additional planting. The purpose of this correspondence is to provide the requested information. To place the applicant - proposed enhancements in context we feel it important to first review those measures contained within the Initial Study specific to the riparian habitat along Los Gatos Creek. As background, the Town's biological consultant, Wood Biological Consulting, concluded that "the proposed encroachment upon the riparian corridor is not likely to result in significant adverse effects on biological resources or the creek environment pursuant to CEQA Guidelines." Their report and the project Initial Study, goes on to conclude that "the Town of Los Gatos may make the determination that the basic goals and objectives of the SCVWRPC [Santa Clara Valley Water Resources Protection Collaborative] Guidelines can still be achieved if certain conditions are incorporated into the project design. Such conditions should include the following measures, at a minim to reduce the project's potential direct and indirect effects on the riparian zone: No new construction or the removal of any native vegetation shall be permitted beyond the existing chain -link fence. 2. Removal of native trees within the riparian zone shall be minimized. 3. Construction of new impervious surfaces within the riparian zone shall be reduced as much as is feasible. 983 University Avenue, Building D • Los Gatos, CA 95032 • Ph: 408.458.3200 • F: 408.458.3210 4. Best Management Practices (BMP's) to pre -treat storm runoff from the project prior to release into Los Gatos Creek shall be incorporated into the project design. 5. BMP's shall be implemented during construction to prevent creek bank erosion and the release of any contaminant into Los Gatos Creek. 6. All recommendations identified in the arborist's report (Babby 2010) shall be implemented. The Town of Los Gatos' Tree Protection Ordinance specifies that a permit is required for the removal of any tree with a diameter of four inches or greater located on a vacant lot or undeveloped property. Based on the recorded size of tree 4118 (western sycamore, spread = 50'), six 24" box trees are to be planted. Replacement trees are to be planted on the subject property. As an alternative, permission may be sought from the Santa Clara Valley Flood Control District to see if the replacement trees may be planted off site in the Los Gatos Creek channel. If replacement trees cannot be reasonably placed on the subject property or on the banks of the creek channel, the value of the trees to be removed shall be paid to the Town Forest Fund to add or replace trees on public property. 8. As additional compensation for construction within the riparian zone, the following measures shall be incorporated into the project design: a. An invasive species eradication program shall be implemented for the segment of Los Gatos Creek (both banks) in line with the upstream and downstream property boundaries. b. A qualified Restorationist shall be retained at the applicant's expense to survey the creek segment to identify invasive species to be eradicated. A qualified Contractor shall be hired at the applicant's expense to implement the Restorationist's recommendations. It is anticipated that the effort would target giant reed, eucalyptus, privet, Himalayan blackberry, smilo grass, and sweet fennel, or any other species identified by the Restorationist. c, The Restorationist shall provide guidance to the Contractor regarding appropriate eradication techniques. d. Upon completion of the work, the Restorationist shall conduct an inspection and submit a report to the Director of Community Development. If the Contactor's work was incomplete or unsatisfactory, Contractor shall continue his /her work until the Restorationist signs off. e. The Restorationist shall conduct an annual inspection of the creek section for a period not less than five years. If significant recolonization by invasive species is identified, the applicant shall be responsible for implementing further eradication efforts. f At the end of five years, if the applicant's efforts have be satisfactory as report by the Restorationist, the applicant's obligations shall be deemed complete. If the applicant's efforts are deemed unsatisfactory by the Town, the invasive species eradication program shall be continued for an additional five years. H. T. HARVEY & ASSOCIATES In addition to these measures recommended by the Town's consultant, we present here for your consideration the requested additional detailed information regarding planting native trees and shrubs within the riparian habitat along Los Gatos Creek. Many of the elements provided below could ultimately be included in a formal Riparian Habitat Enhancement and Monitoring Plan (Plan) for the project. It is anticipated that such a Plan would be developed in close consultation with staff of the Santa Clara Valley Water District and biologists from the California Department of Fish and Game as part of the discretionary approval process with those agencies. More detail than is presented here can only be completed after site - specific technical studies are conducted to investigate factors such as soils, hydrology, topography, etc. Such additional studies can be conducted within the timeframe presented below. Based on our current level of knowledge regarding the riparian habitat and the proposed enhancements we provide the additional following information regarding enhancement implementation, maintenance and monitoring methods. I. ENHANCEMENT IMPLEMENTATION The proposed Riviera Terrace riparian enhancements are proposed to take place in the existing Los Gatos Creek riparian habitat that occurs within the property boundaries. This area occurs south of the existing chain link fence in a portion of the parcel that has not been developed nor is it proposed to be developed. This area is currently in very low ecological condition that presently supports few native trees and very little riparian canopy. For reference, the figure presented at the right shows the proposed locations of Buildings 3 and 4. The proposed enhancement area is shown in color. ENHANCEMENT SITE CONSTRUCTION SCHEDULE Riparian vegetation installation is expected to begin in fall of 2013. Collection and propagation of plant material should commence in fall 2012 so that plants will be ready for fall 2013 planting. The order of events for construction of the enhancement site is roughly as follows: 1. Prepare revegetation enhancement plan, and plans and specifications with sufficient lead time to allow for agency review and approval, and bidding of work prior to fall 2013 site installation; H. T. HARVEY & ASSOCIATES 2. Install Environmentally - Sensitive Area (ESA) fencing to protect existing vegetation to be preserved; 3. Remove non - native, invasive species within enhancement planting areas; 4. Perform soil investigation in enhancement planting areas to confirm horticultural suitability; 5. Install irrigation system; 6. Plant native vegetation in areas as described in the planting plan below; 7. Seed and mulch all disturbed soil areas. SITE PREPARATION All native riparian species within and immediately adjacent to the enhancement areas will be identified prior to site preparation by a qualified biologist. All native riparian habitat will be protected during installation of the enhancement plantings. The ESA fencing will be installed along the perimeter of the enhancement areas to prevent disturbance to adjacent riparian habitat. The soils on site are anticipated to be suitable for successful establishment of the enhancement plantings. However, soils within the riparian enhancement areas will be sampled and analyzed at a qualified laboratory to confirm horticultural suitability. if any soil amendments are recommended they are likely to be minimal (e.g., organic matter) and will be incorporated directly into the planting holes at the time of plant installation. EXOTIC PLANT SPECIES ERADICATION As this part of Los Gatos Creek supports extensive areas of non - native vegetation and virtually no mature riparian canopy, the removal of some non- native vegetation in order to replant with native species will substantially increase the overall habitat quality in this reach of the creek. In addition to manually removing non- native shrubs and trees, all non - native understory plants (shrubs and herbaceous plants) within the enhancement areas will be removed by hand, to limit disturbance to the soil, prior to installing the plantings. As part of the project's overall maintenance plan, invasive species will be controlled through hand removal and kept below 5% total cover within the enhancement areas for the first 5 years following installation of the plantings. The Santa Clara Valley Water District is currently controlling (pers. comtn. Rick Austin, Vegetation Program Specialist, SCVWD) giant reed (Arundo donax) that has become established within the proposed enhancement areas and it is anticipated that the removal effort will continue. PLANTING PLAN There is sufficient area along Los Gatos Creek within the property boundaries to install the proposed enhancement plantings (up to 10,000 square feet). Planting guidelines should be adhered to in order to assure the viability of the plantings. In general, understory shrub plantings should be interspersed between upper- and mid - canopy tree species to form a matrix that will mature into high - quality habitat. Tree species in particular should be planted with sufficient K T. HARVEY & ASSOCIATES space to allow them to develop into mature trees. Given the open nature of the existing tree canopy within the enhancement area plenty of space is available for tree growth. Species spacing details can be found in Table 1. Riparian Vegetation. The target species may include, white alder, California bay, and coast live oak. Mid - canopy and shrub species will include, California buckeye, blue elderberry, snowberry (Symphoricarpos albus), and California blackberry (Rubus ursinus). Table 1. Enhancement Plant Palette COMMON NAME SCIENTIFIC NAME ON- CENTER SPACING (ft) CONTAINER SIZE* black cottonwood Po ulus trichocar a 12 tree of -4 white alder Alms rhombifolia 12 tree of -4 California bay Unrbellularia tali ornica 16 tree of -4 Coast live oak uercus a ri olio 16 tree of -4 California buckeye Aesculus tali ornica 12 tree of -4 blue elderberry Sambucus niexicana 12 tree of -4 Total Trees snowberry S m horicar os albus 8 dee of California blackberry Rubus ursinus 8 dee of fr treepot -4 = 4 -inch wide x 14 -inch deep, deepot = 2.5 -inch wide x 6 -inch deep The tree species selected for planting at the enhancement site are based on the riparian species typically found along riparian corridors within the Los Gatos Creek watershed and in Santa Clara County. The existing vegetation on site is dominated by non - native shrubs and vines. Conversion of this area to native - dominated riparian forest represents an enormous improvement in the overall habitat values of the site. Plant Procurement. The enhancement plants will be contract grown by a qualified native plant nursery. Plants will originate from propagules (seeds, acorns, cuttings) collected from the project vicinity, preferably within the watershed of Los Gatos Creek. If sufficient numbers of propagules are not available from the immediate vicinity, other creeks in Santa Clara County will be considered suitable collection sites. A restoration ecologist will approve all propagule harvest locations. Timing of Propagation. After plant propagules are collected, 8 -12 months of growing time is generally required before the plants are ready for installation. Therefore, the nursery contract will be established 12 months prior to the time of plant installation. Native Seed Mix All disturbed areas and bare soil within the enhancement planting areas will be seeded with a native seed mix to provide erosion control as well as add to the quality of the herbaceous vegetative layer. Table 2 provides the species and applications rates for the native seed mix. H. T. HARVEY & ASSOCIATES Table 2. Native Seed Mix COMMON NAME SCIENTIFIC NAME APPLICATION RATE (PLS /1000 sq ft Meadow barley Hordeum brachyantheruni 3.5 oz /1000 s . ft. Blue wildrye EI nnus glaucus 3.0 oz /1000 s . ft. California brome Broncos carinalus 3.0 oz /1000 s . ft. Total 9.5 oz/1000 s . ft. Plant Installation Container -grown plants will be installed between October and February when rainfall has saturated the soils at the enhancement sites. The planting holes for container -grown woody vegetation should be at least 2 ft in diameter and 2 ft deep. All stones greater than 3 inches in diameter will be removed from the excavated soils. The sides and bottom of each hole should be scarified and each planting hole should be irrigated before planting and again immediately following planting. The plants will be installed so that their root crowns are at or slightly above (up to' /2 inch) grade following soil settlement after irrigation. A 3 -ft diameter irrigation basin with a 4 -inch high, 4 -inch wide berm will be constructed around each plant. The basins will be kept weed free to reduce competition. Mulch. Coarse woodchip mulch will be spread in each planting basin to a minimum depth of three inches. The mulch will serve to control weeds, reduce loss of soil moisture, and help to condition the soils. Mulch shall be installed so that there is a 2 -3 inch gap around the plant stern. Weed Control. Weeds around individual plants will be controlled primarily by placing woodchip mulch within each irrigation basin. However, all weeds that do germinate within the planting basins shall be removed by hand. Weeds throughout the site will be controlled as described in the site maintenance plan. Irrigation Irrigation will need to be provided to each planting basin. A number of irrigation methods could be used to irrigate the plantings. The preferred method would be a drip or bubbler system connected to a water mainline. This method allows for a controller to be installed insuring the proper volume and frequency of watering. However, due to the relatively small, localized enhancement sites and limited number of plantings, hand watering from a water truck or bucket watering from the creek, are options as well. The irrigation method/system will be determined during development of the project's plans and specifications. Schedule The work is scheduled to begin in the late summer /fall 2012 with propagule collection. Ideally, the riparian plants will be installed between October 2013 and December 2013. H. T. HARVEY & ASSOCIATES 2. MAINTENANCE MEASURES OVERVIEW The enhancement plantings will require initial maintenance during the first 5 years (plant establishment period) to establish and become self - sustaining. Maintenance will include dead plant replacement, irrigation, and weed control. Additional maintenance including weed control of non - native and exotic plants will be required to ensure that the enhancement areas remain free of invasive, non - native species, such as giant reed, Himalayan blackberry, periwinkle, and other invasives on the Cal -IPC - California Invasive Plant Inventory Database. Monitoring data shall be collected by a qualified biologist will be used to evaluate the success of the enhancement sites. Information from this monitoring program will provide feedback to direct necessary maintenance, and help ensure the success of the enhancement site. Dead Plant Replacement During the first 4 years all dead plants shall be replaced. In Year 5, if plant survival for any individual species or the site as a whole falls below 75 %, then replanting will occur. If a particular species continuously does not meet the required survival criterion, then with agency concurrence, those species that are most well adapted to the site and have high health and vigor will be used to replace the dead plants. Irrigation The riparian plantings will require irrigation during the 5 -year plant establishment period. The irrigation frequency will be gradually reduced during this period to facilitate plant acclimation to the site's natural moisture regime. In Year 1, the plantings will be irrigated approximately 2 -4 times per month from March through October. Each irrigation period will provide a sufficient amount of water to encourage the development of taproots. The irrigation schedule in Year 2 will be based on the water requirements of the plants and is anticipated to be substantially less (approximately 1 -2 times per month), while in Year 3, little irrigation (0 -1 time per month) will be required. Irrigation may not be required in Years 4 and 5. However, depending on the timing and number of replants installed during Years 1 -3, some irrigation may be needed beyond Year -3. The irrigation schedule may be modified based on climatic conditions to ensure vigorous plant growth during the summer months and/or times of drought. If a drip or bubbler irrigation system is used it will be regularly maintained during the plant establishment period. Any component of the system not functioning properly will be subsequently repaired as part of regular site maintenance. The maintenance will include a provision that the irrigation, system will be continuously checked and kept in good working order. If plantings show signs of severe drought stress at any point beyond the plant establishment period, supplemental irrigation will be required. It is unlikely that this irrigation will be needed, although if necessary, it is likely that hand watering one or two times will be sufficient. 7 H. T. HARVEY & ASSOCIATES Weed Control Weeds within the riparian enhancement site will be controlled within the irrigation basins for each plant and throughout the site as a whole. The irrigation basin around each installed tree and shrub will be kept weed free by maintaining the mulch layer and manually removing the weeds that become established in the mulch. Care will be taken to avoid the removal of naturally recruiting native vegetation. Invasion of the riparian enhancement site by invasive, non - native species can significantly impede the development of the plantings, and therefore, will need to be monitored and controlled. During the first 5 years, the presence of non - native, invasive species (particularly species in the Cal -IPC - California Invasive Plant Inventory Database) will be assessed during each site maintenance visit and the project proponent will be responsible for removing species that could affect site performance. All non - native, invasive species listed in the Cal -IPC database will be manually removed from within the enhancement site. In addition, any giant reed that establishes within the enhancement site during the entire 10 year monitoring period will be manually removed immediately. If needed, a qualified restoration ecologist will assist the maintenance contractor in identifying non - native, invasive species to be removed. Natural Recruitment Measures will be taken to protect native woody plant species that have established through natural recruitment. At a minimum, these species will be identified and protected prior to and during weed control activities. If needed, a qualified restoration ecologist will assist the maintenance contractor in identifying naturally recruited native species. Pruning Enhancement plants will not be pruned unless specifically required to maintain the health and vigor of the plants. Plants with a substantial insect or disease infestation may require pruning. Debris Removal Inorganic, unnatural debris and trash deposited in the enhancement site will be removed on a regular basis until the sites' long -term success criteria have been met. Schedule The riparian enhancement sites will be maintained regularly during the 5 -year plant establishment period. Maintenance activities will occur approximately 2 -4 times per month (may decrease annually according to irrigation schedule and need for weed control) during the growing season (March- October) and approximately once per month from November - February. H. T. HARVEY & ASSOCIATES 3. MONITORING MEASURES Monitoring data will be collected and used to evaluate the success of the enhancement site. Information from this monitoring program will provide feedback to direct necessary maintenance and potential remedial measures to ensure the success of the enhancements. The enhancement site will be monitored over a 10 -year period, occurring in Years 1 -3, 5, 7 and 10. A qualified restoration ecologist will monitor to ensure that the enhancement site is installed as described in this plan. Performance and final success criteria will be based on percent native vegetation survival and tree height. Additionally, percent cover of non - native, invasive plants within the planted enhancement areas will not exceed 5% during the first 5 years following installation and giant reed shall be fully eradicated over the entire 10 year monitoring period. By Year 10, the enhancement site should be sufficiently established to determine if it will eventually reach the long -term goals with little chance of failure. If the final success criteria of the plantings have not been met at Year 10, monitoring will continue until they have been met. AS -BUILT PLANS Within S weeks of the completion of enhancement site installation, marked -up as -built plans will be prepared and submitted to the Town of Los Gatos. These plans will show all significant deviations from the construction as described in this document, such as, changes to the enhancement area configurations and/or any features added to the site that were not included in this plan. Future analysis of the site will be based on these plans. PERFORMANCE AND SUCCESS CRITERIA Performance Criteria This section contains the performance criteria for the enhancement site. Site monitoring measurements will be compared to the performance criteria below to evaluate the extent to which the enhancement areas are incrementally developing high quality riparian habitat values. Riparian Habitat Acreage. The enhancement work will provide up to 10,000 sq ft of restored/enhanced riparian habitat dominated by a mixture of native riparian tree and shrub species. This acreage will be delineated and documented in the as -built plans. Percent Survival for Riparian Trees and Shrubs. Percent survival of the planted riparian trees and shrubs will be monitored during Years 1 -3, 5, 7, and 10. During the first four years all dead plants will be replaced (100% survival criterion). At the end of the fifth year of monitoring, native riparian species shall attain a performance criterion of 75% survival on a per species basis. If survival falls below 75% in Year -5 all dead plants will be replaced. At the end of the tenth year of monitoring, native riparian tree species shall meet a final success criterion of 65% survival on a per species basis. H. T. HARVEY& ASSOCIATES Average Tree Height. Average tree height will be monitored in Years 1 -3, 5, 7, and 10. For average tree height, the trees will show a steady increasing trend in height over the 10 year monitoring period. Trend Characteristics Trend characteristics to be monitored include plant health and vigor and natural recruitment. The results of the trend characteristics monitoring will aid in the assessment of the sites' progress. Site Maintenance Site maintenance is included in the performance criteria because of the critical importance of proper maintenance during the plant establishment period. Site maintenance monitoring will assess the need for plant replacement, weed control, and irrigation. Site maintenance will be monitored during the three -year plant establishment period. The following are the performance criteria for site maintenance: Plant Replacement. All dead plants will be replaced, as needed, between October 15 and March 15. The plants must originate from Santa Clara County, preferably within the watershed of Los Gatos Creek. If sufficient plant materials are not available from the local watershed, propagules form other creeks in Santa Clara County may be acceptable for use, with approval of a qualified restoration ecologist. A written summary of replanting dates, locations, species, and numbers will be included in each monitoring report. Weed Control. Weeds that establish within the 3 -ft diameter planting basins will manually removed. Cover of invasive weeds (particularly species in the Cal -IPC - California Invasive Plant Inventory Database) within the enhancement site will be less than 5% at all times. The maximum height for all weeds within the enhancement site, at any time, will be 24 inches and will be below 12 inches during the growing season (March- October). During the entire 10 year monitoring period, all giant reed that establishes within the enhancement site will be manually removed. Irrigation. Irrigation of the enhancement plantings will be assessed to determine if they are being irrigated with sufficient regularity to achieve the plant survival success criteria. Final Success Criteria Monitoring of the enhancement site by a qualified restoration ecologist will determine if the work has met its enhancement obligation. The final success criteria for riparian habitat acreage, plant survival, tree height and non - native, invasive species control will be used to determine if the enhancement requirements have been met. Attainment of the final success criteria will indicate that the site is well on its way towards meeting the long -tern habitat goals with little chance of failure. The final success criteria will be evaluated in the last year of the 10 year monitoring period. The Year 10 final success criteria define enhancement success and will be used to obtain sign -off from the permitting agencies. 10 . HT. HARVEY & ASSOCIATES MONITORING METHODS The following provides details about the methodology that will be used during annual site monitoring. Plant Survival The survivorship of plantings will be determined by field counts of all trees and shrubs installed. Percent survival will be calculated at follows: Percent Survival of Species A = (Number of Individuals of Species A Alive During Monitoring Period /Total Number of Species A Installed) * 100. Average Tree Height All planted trees will be measured for tree height using a stadia rod, clinometer or laser range finder. Average tree height will be calculated by species and will be tracked between years to determine if there is an increasing trend. Health and Vigor A qualitative assessment of the overall plant health and vigor of all planted trees and shrubs will be made by considering such factors as plant color, bud development, new growth, herbivory, drought stress, fungaUinsect infestation, and physical damage. The overall health and vigor of all planted trees and shrubs will be monitored in Years 1 -3, 5, 7, and 10. Plant health and vigor will be measured using the numerical and qualitative scale shown in Table 3. Health and vigor for each tree and shrub species will be ascertained by averaging the numerical values for each species. Plant health and vigor will be assessed for all woody plants installed and compared between species and years. Table 3. Plant Health and Vigor Ratings. QUALITATIVE VALUES NUMERICAL VALUES OBSERVATIONS High health and vigor 3 67 -100% healthy foliage Medium health and vigor 2 34 -66% healthy foliage Low health and vigor 1 1 -33% healthy foliage Dead 0 Dead Natural Recruitment Natural reproduction and recruitment will be monitored throughout the enhancement site in Years 1 -3, 5, 7, and 10. The number of stems of native and non - native woody plant species observed within the site will be counted and reported by species. Photo - Documentation Photo - documentation of the enhancement site will be conducted from at least four fixed locations in Years 1 -3, 5, 7, and 10. Photographs will also be taken to record any event that may significantly affect the success of the enhancement, such as flood, fire, or vandalism. The 11 H. T. HARVEY & ASSOCIATES locations of photo - documentation points will be selected when the as -built plans are developed for the site. MONITORING SCHEDULE The monitoring schedule is presented in Table 4. Monitoring will be conducted at the enhancement site between July and October of each monitoring year. Table 4. Monitorin¢ Schedule MONITORING TASK YR -1 YR -2 YR -3 YR -5 YR -7 YR -10 As -built Plans Percent Survival RWKS X X X X X X Tree Hei ht X X X X X X Plant Health and Vi or X X X X X X Natural Recruitment X X X X X X Photo - documentation X X X X X X REPORTING Annual data collection will take place in July- October of each monitoring year. Annual monitoring reports will be submitted to the Town of Los Gatos by December 31st of each monitoring year. Maps showing monitoring locations and copies of photo- documentation will be provided along with reports. Field data sheets will be available for review upon request. COMPLETION OF ENHANCEMENTS At a minimum, monitoring will be conducted over a 10 year period at the enhancement site. At the end of the monitoring period, a final monitoring report will be prepared to establish whether the enhancement site has achieved the final success criteria. If the enhancement site has successfully met the success criteria, a letter will be sent to the Town of Los Gatos acknowledging the condition of the site. The project will be considered a success when the Town of Los Gatos "signs off' on the enhancements. AND REMEDIAL ACTIONS If annual performance criteria or final success criteria are not met, the project proponent shall prepare an analysis of the cause(s) of failure, and propose remedial actions to the permitting agencies. The project proponent shall provide funding for the planning, implementation, and monitoring of any remedial actions that may be requested by the Town of Los Gatos to meet the goals of the enhancement. STATEMENT OF FINANCIAL COMMITMENT The Sobrato Development Company is financially responsible for the successful enhancement for impacts to riparian habitat resulting from the Riviera Terrace Apartments Project, including long -term monitoring and any proposed remedial actions. 12 K T. HARVEY & ASSOCIATES We look forward to discussing the proposed enhancements with you in preparation for the upcoming Council hearing and will be happy to answer any questions you may have at that time. Please don't hesitate to contact me at 408.458.3204 or pboursier @harveyecology.com. Sincerely, �c Patrick J. Boursier, Ph.D. Principal, Senior Plant Ecologist 13 H. T. HARVEY & ASSOCIATES This Page Intentionally Left Blank