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Home My WebLink AboutBaker Industrial Project - MSHCP Consistency Analysis (3)Western Riverside County Multiple Species Habitat Conservation Plan Consistency Analysis Baker Industrial Project Permittee City of Lake Elsinore Applicant Ecosystem Investment Partners 1505 Bridgeway, Suite 107 Sausalito, California 94965 Contact: Glen Williams Phone: (415) 465-4423 Consultant Glenn Lukos Associates, Inc. 1940 E. Deere Avenue, Suite 250 Santa Ana, California 92705 Phone: (949) 340-2562 Contact: David Moskovitz February 28, 2024 Revised, February 5, 2025 MSHCP Consistency Analysis i Table Of Contents 1.0 EXECUTIVE SUMMARY ........................................................................................... 1 2.0 INTRODUCTION ....................................................................................................... 4 2.1 Project Description and Area.............................................................................. 4 2.2 Covered Roads ................................................................................................ 10 2.3 Covered Public Access Activities ..................................................................... 11 2.4 General Setting ................................................................................................ 11 3.0 RESERVE ASSEMBLY ANALYSIS ......................................................................... 12 3.1 Reserve Assembly Background ....................................................................... 12 3.2 Public Quasi-Public Lands ............................................................................... 12 3.3 MSHCP Criteria Area and Reserve Assembly Requirements .......................... 13 4.0 VEGETATION MAPPING AND SPECIES COMPENDIA ......................................... 16 5.0 PROTECTION OF SPECIES ASSOCIATED WITH RIPARIAN/ RIVERINE AREAS AND VERNAL POOLS (SECTION 6.1.2) ................................................................ 20 5.1 Riparian/Riverine .............................................................................................. 20 5.2 Vernal Pools ..................................................................................................... 26 5.3 Fairy Shrimp ..................................................................................................... 33 5.4 Riparian Birds ................................................................................................... 35 5.5 Other Section 6.1.2 Species............................................................................. 41 6.0 PROTECTION OF NARROW ENDEMIC PLANT SPECIES (SECTION 6.1.3) ....... 42 6.1 Methods ........................................................................................................... 42 6.2 Existing Conditions and Results ....................................................................... 43 6.3 Impacts ............................................................................................................ 43 6.4 Mitigation .......................................................................................................... 44 7.0 ADDITIONAL SURVEY NEEDS AND PROCEDURES (SECTION 6.3.2) ............... 45 7.1 Criteria Area Plant Species .............................................................................. 46 7.2 Amphibians ...................................................................................................... 49 7.3 Burrowing Owl .................................................................................................. 49 7.4 Mammals.......................................................................................................... 51 8.0 INFORMATION ON OTHER SPECIES ................................................................... 52 8.1 Delhi Sands Flower-Loving Fly......................................................................... 52 8.2 Coastal California Gnatcatcher ........................................................................ 52 8.3 Species Not Adequately Conserved ................................................................. 52 9.0 GUIDELINES PERTAINING TO THE URBAN/WILDLANDS INTERFACE (SECTION 6.1.4) ........................................................................................................................ 52 9.1 Drainage .......................................................................................................... 53 9.2 Toxics ............................................................................................................... 54 9.3 Lighting ............................................................................................................ 54 MSHCP Consistency Analysis ii 9.4 Noise ................................................................................................................ 54 9.5 Invasive Species .............................................................................................. 55 9.6 Barriers ............................................................................................................ 55 9.7 Grading/Land Development ............................................................................. 55 10.0 CONSTRUCTION GUIDELINES (SECTION 7.5.3) .............................................. 55 11.0 BEST MANAGEMENT PRACTICES (MSHCP VOLUME I, APPENDIX C) ........... 57 12.0 CONCLUSION ...................................................................................................... 58 13.0 CERTIFICATION ................................................................................................... 58 TABLES Table 2-1. Summary of Project Components ................................................................. 6 Table 3-1. Criteria Cell Acreages for the Project Site ................................................... 12 Table 4-1. Summary of Vegetation/Land Use Types for the Project Site ..................... 17 Table 5-1. MSHCP Riparian/Riverine Areas at the Project site .................................... 22 Table 5-2. Impacts to MSHCP Riverine Areas ............................................................. 25 Table 5-3. MSHCP Vernal Pools at the Project site ..................................................... 27 Table 5-4. Impacts to Vernal Pools .............................................................................. 28 Table 5-5. Summary of Least Bell’s Vireo Surveys ...................................................... 37 Table 5-6. Summary of Southwestern Willow Flycatcher Surveys ............................... 38 Table 7-1. Summary of Burrowing Owl Surveys ........................................................... 50 EXHIBITS Exhibit 1 Regional Map Exhibit 2 Vicinity Map Exhibit 3 Project Components Map Exhibit 4A MSHCP Overlay Map Exhibit 4B MSHCP Species Survey Area Map Exhibit 4C MSHCP Covered Roads Map Exhibit 5 MSHCP Reserve Assembly Map Exhibit 6 Vegetation Map Exhibit 7 Soils Map Exhibit 8 MSHCP Riparian/Riverine Areas and Vernal Pools Exhibit 9 Rare Plants Map Exhibit 10 Plant Restoration Map Exhibit 11 Burrowing Owl Survey Map Exhibit 12 Site Photographs Exhibit 13 LBV Habitat with LTCV MSHCP Consistency Analysis iii APPENDICES Appendix A Conceptual Grading Plan – Baker Industrial Project Appendix B Report of 2023 Dry Season Fairy Shrimp Surveys Appendix C Report of 2023/2024 Wet Season Fairy Shrimp Surveys Appendix D Report of 2020 Southwestern Willow Flycatcher and Least Bell’s Vireo Surveys Appendix E Baker Industrial Hydrology Memorandum MSHCP Consistency Analysis 1 1.0 EXECUTIVE SUMMARY Glenn Lukos Associates, Inc. (GLA) has prepared this report to document consistency of the Baker Industrial Project (the “Project”) with the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), including the Project’s relationship to Reserve Assembly, Section 6.1.2 (Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools), Section 6.1.3 (Protection of Narrow Endemic Plant Species), Section 6.1.4 (Guidelines Pertaining to the Urban/Wildlands Interface), and Section 6.3.2 (Additional Survey Needs and Procedures). A majority of the Project site (71.27 acres) is located within Subunit 3 (Elsinore) of the Elsinore Area Plan, specifically Criteria Cell 4166 [Exhibit 4A – MSHCP Map]. Another 7.70 acres of the Project site is located within Subunit 2 (Alberhill) of the Elsinore Area Plan, including Cell 4157 (1.61 acres) and Cell Group W (6.09 acres). The remainder of the Project site (45.63 acres) is outside of the Criteria Area. Projects occurring within the Criteria Area are subject to the Habitat Evaluation and Acquisition Negotiation Strategy (HANS) process to determine if portions of the sites may be needed for inclusion in the MSHCP Conservation Area. The Project will conserve approximately 32.66 acres of land, the majority of which (30.14 acres) is located in the central and northern portions of Cell 4166 and consists predominantly of grassland habitat adjacent to Alberhill Creek, but which also contains riparian areas, playa habitat and vernal pools. The conserved lands would be dedicated to the RCA and managed and protected in perpetuity. Regardless of whether project lands are to be acquired for inclusion in the MSHCP Conservation Area, projects located within the Criteria Area are subject to the Joint Project Review (JPR) process for the RCA to review projects for consistency with the MSHCP. MSHCP Reserve Assembly is further addressed in Section 3.0 below. The proposed Project will impact approximately 0.50 acre of MSHCP riverine areas. The Project will not remove habitat with long-term conservation value for the least Bell’s vireo (Vireo bellii pusillus), southwestern willow flycatcher (Empidonax traillii extimus), or western yellow-billed cuckoo (Coccyzus americanus occidentalis). Due to the proximity to riparian habitat within Alberhill Creek, GLA biologists performed focused surveys for the least Bell’s vireo and southwestern willow flycatcher. GLA biologists did not detect the southwestern willow flycatchers but did detect a single male least Bell’s vireo (presumed nesting based on behavior) in Alberhill Creek during multiple visits within proximity to Nichols Road and the Project’s proposed conservation. The Project will impact up to 0.17 acre of vernal pools, associated with the edges of two vernal pools that will otherwise be avoided. Dry season and wet season fairy shrimp surveys were completed for four ponded features, including three vernal pools and one non-vernal pool impoundment. The versatile fairy shrimp (Branchinecta lindahli) was detected in all three vernal pools, but not in the fourth feature. No listed fairy were detected. A Determination of Biologically Equivalent or Superior Preservation (DBESP) must be approved by the wildlife agencies (USFWS and CDFW) for impacts to the MSHCP Consistency Analysis 2 riverine areas and vernal pools. Subject to the approval of a DBESP, the Project will be consistent with MSHCP Volume I, Section 6.1.2 of the MSHCP. Volume I, Section 6.1.3 of the MSHCP requires that within identified Narrow Endemic Plant Species Survey Areas (NEPSSA), site-specific focused surveys for Narrow Endemic Plants Species will be required for all public and private projects where appropriate soils and habitat are present. The Project site occurs within the NEPSSA for the following target species: · Munz’s onion (Allium munzii) · San Diego ambrosia (Ambrosia pumila) · Slender-horned spineflower (Dodecahema leptoceras) · Many-stemmed dudleya (Dudleya multicaulis) · Spreading navarretia (Navarretia fossalis) · California Orcutt grass (Orcuttia californica) · San Miguel savory (Clinopodium chandleri) · Hammitt’s clay-cress (Sibaropsis hammittii) · Wright’s trichocoronis (Trichocoronis wrightii var. wrightii). The Project will impact San Diego ambrosia in several locations, including in the southern portion of the Industrial footprint (onsite) and within the proposed offsite road improvements along Pierce Street and Nichols Road. Because the Project site is within the NEPSSA for San Diego ambrosia, the Project is required by the MSHCP to identify habitat with long-term conservation value for the species and to avoid at least 90 percent of the habitat. GLA has identified 0.44 acre of habitat with long-term conservation value for the ambrosia within the Project footprint, all of which will be impacted by the Project. As such, a DBESP must be approved to authorize impacts to San Diego ambrosia. Pursuant to MSHCP Volume I, Section 6.3.2, the MSHCP requires habitat assessments and focused surveys (within areas of suitable habitat) for certain species as determined by a project’s occurrence in a designated survey area, including Criteria Area Plant Species Survey Area (CAPSSA), burrowing owl survey area, amphibian survey area, and mammal survey area. The Project site occurs within the CAPSSA for the following target species: · Thread-leaved brodiaea (Brodiaea filifolia) · Davidson’s saltscale (Atriplex serenana var. davidsonii) · Parish’s brittlescale (Atriplex parishii) · Smooth tarplant (Centromadia pungens spp. laevis) · Round-leaved filaree (California macrophylla) · Coulter’s goldfields (Lasthenia glabrata ssp. coulteri) · Little mousetail (Myosurus minimus ssp. apus) MSHCP Consistency Analysis 3 The Project will impact Coulter’s goldfields associated with the one of the vernal pools adjacent to the proposed Baker Street improvements due to the proposed storm drain outlets and proposed maintenance area. GLA has identified 2.61 acres of habitat with long-term conservation value for Coulter’s goldfields associated with the three vernal pools. The proposed Project will directly impact 0.50 acre of the habitat (20 percent) of the habitat at the edge of one of the vernal pools. As such, a DBESP must be approved to authorize impacts to Coulter’s goldfields. It is assumed that the Project might impact little mousetail based on a prior public record of detection. Impacts are assumed up to 0.07 acre of habitat with long-term conservation value based on proposed impacts to Vernal Pool 3. As such, a DBESP must be approved to authorize impacts to little mousetail. The Project site is within the MSHCP burrowing owl survey area. To comply with MSHCP survey requirements pursuant to Volume I, Section 6.3.2, focused burrowing owl surveys were performed for the Project site. Burrowing owls were confirmed absent from the site. However, because of the potential suitability to support burrowing owls, consistent with the MSHCP burrowing owl survey guidelines and MSHCP objectives for the burrowing owls, pre-construction surveys will be conducted no more than 30 days prior to ground disturbance within all areas of suitable habitat. The MSHCP Urban/Wildland Interface Guidelines are intended to address indirect effects associated with locating development in proximity to the MSHCP Conservation Area. As the MSHCP Conservation Area is assembled, development is expected to occur adjacent to the Conservation Area. Future development in proximity to the MSHCP Conservation Area may result in edge effects with the potential to adversely affect biological resources within the Conservation Area. To minimize such edge effects, the guidelines shall be implemented in conjunction with review of individual public and private development projects in proximity to the MSHCP Conservation Area and address the following: · Drainage; · Toxics; · Lighting; · Noise; · Invasives; · Barriers; and · Grading/Land Development. As discussed in Section 9.0 of this document, the Project will implement applicable measures to minimize adverse indirect impacts on special-status resources within Conserved Lands. The proposed Project will be consistent with Volume I, Section 6.1.4 of the MSHCP. MSHCP Consistency Analysis 4 2.0 INTRODUCTION The purpose of this Consistency Analysis is to summarize the biological data for the proposed Baker Industrial Project and to document the project’s consistency with the goals and objectives of the Western Riverside County Multiple Species Habitat Conservation Plan. This Analysis incudes a review of consistency with Reserve Assembly, Covered Roads, Section 6.1.2 (Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools), Section 6.1.3 (Protection of Narrow Endemic Plant Species), Section 6.1.4 (Guidelines Pertaining to the Urban/Wildlands Interface), and Section 6.3.2 (Additional Survey Needs and Procedures), as well as other aspects of MSHCP consistency. 2.1 Project Description and Area 2.1.1 Project Location The Project site comprises approximately 124.60 acres in the City of Lake Elsinore, Riverside California [Exhibit 1 – Regional Map] and is located within an un-sectioned portion of Township 5 South, Range 5 West, of the U.S. Geological Survey (USGS) 7.5- minute quadrangle map Lake Elsinore, California [Exhibit 2 – Vicinity Map]. The Project site is located southwest of Interstate-15, the Lake Elsinore Outlet Center and Temescal Creek/Collier Marsh. The Project site includes the following Assessor’s Parcel Numbers (APNs): Onsite 378-020-014 378-020-015 378-020-016 378-020-028 378-020-029 378-020-030 378-020-031 378-020-036 378-020-037 378-020-048 Offsite 378-020-012 378-020-038 378-020-039 378-020-042 378-020-043 378-114-064 389-080-058 MSHCP Consistency Analysis 5 389-080-013 RCA Conserved Land 378-020-024 378-020-033 378-020-034 378-020-040 378-020-041 378-020-054 2.1.2 General Description The overall Project site totals 124.60 acres and is presented here in five distinct components: 1. The Industrial Project development footprint (referred to as the “onsite” portion of the Project) 2. Baker Street Improvements (offsite) 3. A proposed City Maintenance Area (offsite) – to be located along the edge of Baker Street 4. Additional Street Improvements (offsite) – includes improvements to Pierce Street and Nichols Road 5. RCA Conserved Lands – includes 33.66 acres of lands to be conserved by the Project located northeast of the proposed City Maintenance Area and southeast of Pierce Street/Nichols Road All impacts will be permanent. There will be no temporary impacts. All construction staging will occur within the development footprint and/or the offsite improvements areas. The Project will not require additional impacts outside of the development footprint for staging. All fuel modification/weed abatement zones will be contained within the impact limits for both the onsite and offsite project components. The five Project components are depicted on Exhibit 3 [Project Components Map]. Table 2-1 summarizes the acreages of these five components, broken out for portions inside versus outside of Criteria Cells. MSHCP Consistency Analysis 6 Table 2-1. Summary of Project Components Project Component Inside Criteria Cells (Acres) Outside Criteria Cells (Acres) Total (Acres) Industrial Project 34.25 31.56 65.81 Baker Street Improvements 4.45 1.66 6.11 City Maintenance Area 2.44 0.29 2.73 Additional Street Improvements 5.83 10.46 16.29 RCA Conserved Lands 32.00 1.66 33.66 Total 78.97 45.63 124.60 2.1.3 Industrial Project (Onsite) The Baker Industrial Project (Project) is proposing two industrial buildings for a total of approximately 1,002,000 square feet of industrial space [Appendix A – Conceptual Grading Plan]. The proposed site plan provides adequate standard vehicle parking fields and an additional trailer parking field along the southern end of the property. The Project grading consists of a development pad graded to convey onsite and offsite storm water northerly while maintaining the hydrologic regime of the property and surrounding tributaries. Larger slopes and associated retaining walls are located along the southerly property line. The Project will accept offsite flows from the southern tributaries (developed) through two flow-by basins also located along the southerly property line. Storm flows are then conveyed through the Project storm system and discharged in flow and quantity at their historical locations along the northern side of Baker Street. Onsite flows are collected through inlets/catch basins and conveyed through the proposed storm drain system to one of three underground storm chambers. With limited opportunities to infiltrate onsite storm flows, each chamber system will treat the pollutants of concern and discharge all treated flows consistent with historical quantities and flow characteristics along the northerly right-of-way of Baker Street. The Project includes the preparation of a Preliminary Hydrology Study to analyze the existing condition storm flows across the property as well as the proposed condition conveyances to existing discharge locations. The hydrology study will confirm flow values based on standard storm intensities and discharge volumes, flow rates, and velocities. The Project also includes a Preliminary Water Quality Management Plan (WQMP) that identifies the Best Management Practices (BMPs) proposed to be implemented to treat project related pollutants for onsite and offsite impervious improvements. The WQMP will identify the post-construction treatment control and site design BMPs to treat specific pollutants from onsite impervious areas as well as the MSHCP Consistency Analysis 7 public right-of-way prior to discharge at historical locations on the northern side of the proposed Baker Street corridor improvements. BMPs located within the public right-of- way of Baker Street and Nichols Road will treat roadway specific pollutants within bio- retention/modular wetland facilities upstream of the specified discharge locations. A Storm Water Pollution Prevention Plan (SWPPP) will be prepared and implemented prior to onsite and offsite project construction disturbance. The SWPPP will focus on the design, installation, and treatment of construction related pollutants. The SWPPP document will be approved through the State of California and the Project will be registered as required by the Construction General Permit. The Project will be monitored before, during and after rain events to ensure BMP implementation and effectiveness in protecting downstream habitats and receiving water bodies. The Project proposes to construct an 8-inch sewer pipeline within Baker Street to convey wastewater flows northwesterly to the existing Nichols Road Lift Station. The pipeline is proposed at standard depth and will connect to the existing Elsinore Valley Municipal Water District (EVMWD) 15-inch sewer line constructed within the Pierce and Baker intersection. The Nichols Lift Station will require an upgrade to its ultimate build- out capacity. The lift station upgrades will occur within the existing EVMWD parcel and will also require an upsized force main between the lift station and the discharge manhole within the Nichols and Collier intersection. EVMWD has master planned a new force main from the permanent lift station to convey flow south in Baker Street to Turnbull Avenue. From there a new gravity sewer line is identified in Turnbull Avenue and south to the Regional Wastewater Treatment Plant. The gravity sewer alignment would require construction of many sections of the gravity sewer line in private streets and private property where easements would need to be acquired. The EVMWD Master Plan exhibit in Attachment 2 provides the proposed alignment of the force main and downstream gravity sewer. An alternative sewer force main alignment was studied by KWC Engineers in 2015 that would route the force main in Collier Avenue. The force main and downstream gravity sewer improvements under the revised alignment would keep all improvements within existing public right-of-way. The Collier Avenue alignment would also allow the improvements to be phased by constructing a force main with the first phase of the permanent lift station and then constructing a parallel or replacement force main when the lift station is expanded to its ultimate capacity. The Collier Avenue alignment alternative was reviewed with EVMWD staff recently and they take no objection to proceeding with that alignment. EVMWD did, however, note that they will need to evaluate the downstream impacts of flows routed down Collier Avenue and that depending on the extent of required downstream improvements, not all the improvements may be eligible for fee credits. Once the capacity study currently being reviewed by EVMWD is approved, KWC will initiate the PDR for the lift station and coordinate with EVMWD on the downstream sewer system analysis. For water service, an EVMWD 36-inch 1434 Zone CIP line is proposed to be installed in Nichols Road from Terra Cotta Road to Baker Street and in Baker Street to the existing 20-inch line that supplies the Baker Reservoir. The Project proposes to receive water MSHCP Consistency Analysis 8 service by making two connections to the proposed transmission line in Baker Street and constructing a looped piping system onsite between the two connections. EVMWD does not allow fire hydrants to be served off private systems so the onsite loop will need to be public. The onsite line will be located in an easement and be located in accordance with EVMWD requirements which includes not locating the line beneath landscaped medians or parking stalls. The 1434 Zone has a large surplus of reservoir storage capacity and additional storage is not required to provide service to the Project. The 1434 Zone has a large surplus of reservoir storage capacity and additional storage is not required to provide service to the Project. 2.1.4 Baker Street (Offsite) Existing Baker Street is an unimproved dirt road with a 60-foot-wide right-of-way. The Project proposes to dedicate four feet on each side of Baker Street to the ultimate 68 feet right-of-way required by the City of Lake Elsinore’s (City) Collector roadway designation and as listed within the City’s circulation element. The Project will also be realigning Baker Street for a direct connection and new intersection with Nichols Road, which is discussed below under “Additional Street Improvements”. The Baker Street Collector section consists of a six-inch curb and gutter, a five-foot-wide sidewalk within a 10-foot parkway and 22 feet of pavement from centerline to lip of gutter on each side of the street. Baker Street is proposed to be elevated an average of five feet above its existing elevations to support drainage conveyance and flood protection of the public right-of-way. The northeast parkway of Baker Street will slope down from the proposed five-foot sidewalk to daylight within the northerly properties. The Project proposes to elevate the road surface of Baker Street to support drainage protection and conveyance. Along the northern edge of Baker Street, a graded and landscaped slope will daylight to existing ground within the parcels north of existing Baker Street right-of-way. The proposed slope will provide areas to safely construct storm drain outlets that will convey historical storm flows to existing flow lines and environmentally sensitive areas identified within the Project studies of these properties. The storm outlets will include energy dissipation improvements to control the storm water outlet depth and velocity to mimic existing conditions. 2.1.5 City Maintenance Area (Offsite) As noted above, the Project proposes to elevate the road surface of Baker Street to support drainage protection and conveyance. Along the northern edge of Baker Street, a graded and landscaped slope will daylight to existing ground within the parcels north of existing Baker Street right-of-way. The proposed slope will provide areas to safely construct storm drain outlets that will convey historical storm flows to existing flow lines and environmentally sensitive areas identified within the Project studies of these properties. The storm outlets will include energy dissipation improvements to control the storm water outlet depth and velocity to mimic existing conditions. Specifically, the Project proposes to construct three water spreading structures that are designed to mimic the existing sheet flow conditions into the adjacent open space [Sheets 1 and 2 of MSHCP Consistency Analysis 9 Appendix E]. The spreading structures will be constructed on the northeastern side of Baker Street adjacent to each of the three vernal pools described below. The pre- and post-Project hydrology relative to the three vernal pools are summarized below in the impact analysis as well as being presented in Appendix E. A maintenance access road is proposed along the toe-of-slope for ongoing maintenance of the slope, the associated landscaping, any required fencing, and the outlet structures. Where sensitive environmental areas exist (vernal pools identified within the Project environmental studies), the improvements are proposed to be scaled back to minimize or eliminate impacts in and adjacent to the defined zones. Construction buffers will be implemented to reduce accidental disturbance and the areas will be clearly delineated and recognizable to construction crews/personnel. 2.1.6 Additional Street Improvements (Offsite) In addition to the Baker Street improvements described above, the Project will also improve Pierce Street and Nichols Road. The Project will realign Baker Street for a direct connection and new intersection with Nichols Road. The intersection design will likely consist of signal pole placement consistent with the ultimate build-out of Nichols Road (Urban Arterial Highway – 120’ right-of-way). Nichols Road improvements will likely consist of an interim intersect with appropriate pavement tapering to the east and west leading away from the new intersection with Baker Street. Minor roadway resurfacing may be required along the existing Nichols Road segment between the Baker Street intersection and the Collier Avenue intersection. The Nichols and Collier intersection may also include minor surface improvements, revised lane striping and potential traffic control/signage improvements. Existing Pierce Street varies in right-of-way width along the Project’s frontage. The Project proposes to construct Pierce Street to its ultimate 60-foot width between Baker Street and Hoff Avenue. The ultimate street section will include a six-inch curb, standard gutter, five-foot-wide sidewalk within an overall 10-foot parkway and 18 feet of pavement from centerline to lip-of-gutter on each side of the street. Other project related street improvements beyond the Project frontage will be assessed with the traffic impact analysis. 2.1.7 RCA Conserved Land The Project is conserving 33.66 acres of lands bordered by the Baker Street, Pierce Street and Nichols Road improvements. As described below, the Project is proposing several types of mitigation within with the Conserved Lands, including San Diego ambrosia (Ambrosia pumila) translocation, vernal pool expansion/restoration, and mitigation for other MSHCP plants, including Coulter’s goldfields (Lasthenia glabrata ssp. coulteri). If the long-term management of these mitigation areas will exceed that which the RCA receives funding for through the MSHCP, it is acknowledged that the Project would provide an endowment to fund supplemental management. MSHCP Consistency Analysis 10 2.2 Covered Roads Section 7.3.5 of the MSHCP addresses planned roads within the Criteria Area, also referred to as “Covered Roads”. Planned roadways are defined as either existing facilities that require improvements (i.e., widening) or as new facilities to be constructed as identified as part of County’s General Plan circulation element (MSHCP Figure 7-1). The Project proposes to improve sections of Nichols Road, which is depicted on MSHCP Figure 7-1, as well as portions of Baker Street and Pierce Street. 2.2.1 Baker Street As described above, existing Baker Street is an unimproved dirt road with a 60-foot- wide right-of-way. The Project proposes to dedicate four feet on each side of Baker Street to the ultimate 68 feet right-of-way required by the City’s Collector roadway designation and as listed within the City’s circulation element. The Project will also be realigning Baker Street for a direct connection and new intersection with Nichols Road. The Baker Street Collector section consists of a six-inch curb and gutter, a five-foot- wide sidewalk within a 10-foot parkway and 22 feet of pavement from centerline to lip of gutter on each side of the street. Baker Street is proposed to be elevated an average of five feet above its existing elevations to support drainage conveyance and flood protection of the public right-of-way. The northeast parkway of Baker Street will slope down from the proposed five-foot sidewalk to daylight within the northerly properties. The Project proposes to elevate the road surface of Baker Street to support drainage protection and conveyance. Along the northern edge of Baker Street, a graded and landscaped slope will daylight to existing ground within the parcels north of existing Baker Street right-of-way. The proposed slope will provide areas to safely construct storm drain outlets that will convey historical storm flows to existing flow lines and environmentally sensitive areas identified within the Project studies of these properties. The storm outlets will include energy dissipation improvements to control the storm water outlet depth and velocity to mimic existing conditions. The Project will improve (widen) approximately 4,000 linear feet of Baker Street from the southeastern extent of the improvements to Pierce Street, of which approximately 2,900 linear feet is in Criteria Cell 4166 and 1,100 linear feet is outside of Criteria Cells. Although Baker Street is identified by the City’s circulation element, Baker Street is not depicted in the County’s General Plan Circulation Element, and therefore Baker Street is not regarded as a Covered Road by the MSHCP. It has not yet been determined how the City of Lake Elsinore will resolve the lack of road coverage for Baker Street, or whether the additional road right-of-way and adjacent maintenance area will be transferred to the City upon completion of the Project. However, the Baker Street alignment is not within areas of conservation described for Cell 4166; and therefore, as MSHCP Consistency Analysis 11 described below in Section 3.0 of this document, the proposed improvements to Baker Street will not conflict with Reserve Assembly. 2.2.2 Pierce Street The Project proposes to construct Pierce Street to its ultimate 60-foot width between Baker Street and Hoff Avenue. The ultimate street section will include a six-inch curb, standard gutter, five-foot-wide sidewalk within an overall 10-foot parkway and 18 feet of pavement from centerline to lip-of-gutter on each side of the street. Pierce Street is not within Criteria Cells and therefore the MSHCP Covered Road requirements do not apply to Pierce Street. 2.2.3 Nichols Road Nichols Road is identified as an “expressway” in the General Plan Circulation Element, with a 184-foot ROW, and therefore the MSHCP allowable covered width for permanent impacts for Nichols Road within the Criteria Area is 184 feet, encompassing all road elements, including the road shoulder. The Project proposes minor roadway resurfacing along the existing Nichols Road segment between the proposed Nichols Road/Baker Street intersection and Collier Avenue. The Nichols and Collier intersection may also include minor surface improvements, revised lane striping and potential traffic control/signage improvements. The proposed improvements will not exceed the maximum allowable covered width. 2.3 Covered Public Access Activities The Project will not construct any public access facilities and therefore this section does not apply to the Project. 2.4 General Setting The overall Project site varies in topography from slightly hilly to flat, sloping from southwest to northeast. The onsite portion of the Project site (industrial component) consists of several small hills and ridges sloping from the southwest down to the existing dirt road of Baker Street, with the site being flatter on the northern end near the Baker Street/Pierce Street intersection. Northeast of Baker Street, the landscape is flat with a very gradual change in elevation to the northeast towards Alberhill Creek/Collier Marsh. Elevations at the Project site range from approximately 1,400 feet above mean sea level (AMSL) at the southwestern boundary of the development footprint to 1,250 feet AMSL at the northeastern limits of the proposed RCA Conserved Lands. Soils within the onsite portion of the Project site consist mainly Lodo Rocky Loam and Willows Silty Clay (saline-alkali). The Willows soils occur in the lower portions of site, with the rocky loam soil occurring in the higher elevation areas. The Willows soils extend into the site from the adjacent Collier Marsh area. These alkaline soils are strongly associated with the plant species that occur in the vernal pools immediately MSHCP Consistency Analysis 12 northeast of Baker Street. The offsite (undeveloped) portions of the Project site predominantly consist of fine sandy loam soils. The proposed RCA Conserved Lands consist of Willows silty clay soils as well as the fine sandy loam soils. 3.0 RESERVE ASSEMBLY ANALYSIS This section analyzes the Project’s consistency with MSHCP Reserve Assembly goals. 3.1 Reserve Assembly Background A majority of the Project site (71.27 acres) is located within Subunit 3 (Elsinore) of the Elsinore Area Plan, specifically Criteria Cell 4166 [Exhibit 4A – MSHCP Map]. Another 7.70 acres of the Project site is located within Subunit 2 (Alberhill) of the Elsinore Area Plan, including Cell 4157 (1.61 acres) and Cell Group W (6.09 acres). The remainder of the Project site (45.63 acres) is outside of the Criteria Area. Table 3-1 provides a breakdown of Project site acreages for those portions within the Criteria Area. Reserve Assembly requirements for each independent Cell and Cell Group are described below. Table 3-1. Criteria Cell Acreages for the Project Site Criteria Cell Onsite Development (Acres) Offsite Development (Acres) RCA Conserved Land (Acres) Total (Acres) 4157 0 1.61 0 1.61 4166 34.25 6.91 30.11 71.27 4060 (Cell Group W) 0 1.26 0 1.26 4067 (Cell Group W) 0 2.94 1.89 4.83 Total 34.25 12.72 32.00 78.97 3.2 Public Quasi-Public Lands 3.2.1 Public Quasi-Public Lands in Reserve Assembly Analysis The Project site is not within or adjacent to PQP Lands. 3.2.2 Project Impacts to Public Quasi-Public Lands The proposed Project will not impact PQP Lands. MSHCP Consistency Analysis 13 3.3 MSHCP Criteria Area and Reserve Assembly Requirements 3.3.1 Criteria Cell #4157 Approximately 1.61 acres of the Project site is within Criteria Cell #4157, consisting of a portion of existing Nichols Road that will be improved by the Project. The MSHCP Criteria for the Cell states the following: Conservation within this Cell will contribute to assembly of Proposed Core 1. Conservation within this Cell will focus on coastal sage scrub, chaparral and grassland habitat. Areas conserved within this Cell will be connected to coastal sage scrub and chaparral habitat proposed for conservation in Cell #4156 to the west and to chaparral and grassland habitat proposed for conservation in Cell #4057 to the north. Conservation within this Cell will range from 45%-55% of the Cell focusing in the western half of the Cell. The portion of the Project that is in Cell #4157 is in the northeastern portion of the Cell and outside of the portion described for conservation. Furthermore, the portion of the Project within the Cell is the western limits of proposed improvements to Nichols Road, which is a Covered Road. Improvements to the portion of Nichols Road will consist of pavement re-surfacing tapering away from the proposed intersection at Nichols Road and Baker (outside of Criteria Cells). The Project will be consistent with Reserve Assembly requirements for Cell #4157. 3.3.2 Criteria Cell #4166 Approximately 71.27 acres of the Project site is within Criteria Cell #4166, consisting of the central portions of the onsite Industrial component, offsite Baker Street improvements and the offsite proposed City Maintenance Area, and a very small portion of the proposed Nichols Road/Baker Street intersection. The MSHCP Criteria for the Cell states the following: Conservation within this Cell will contribute to assembly of Proposed Linkage 2. Conservation within this Cell will focus on meadow, marsh, riparian scrub, woodland and forest habitat along Alberhill Creek and adjacent grassland habitat. Areas conserved within this Cell will be connected to riparian scrub, woodland, forest and grassland habitat proposed for conservation in Cell Group W to the north and to meadow, marsh and grassland habitat proposed for conservation in Cell #4169 to the east. Conservation within this Cell will range from 15%-25% of the Cell focusing in the northeastern portion of the Cell. Criteria Cell #4166 is approximately 161.77 acres, with a described conservation range of 25 to 41 acres. The proposed Project is in the southwestern 40% of the Cell, whereas the Cell Criteria describes the northeastern portion of the Cell, focusing on habitats associated with Alberhill Creek and Collier Marsh. The Project will conserve approximately 32.66 acres of land, the majority of which (30.14 acres) is located in the MSHCP Consistency Analysis 14 central and northern portions of the Cell and consists predominantly of grassland habitat adjacent to Alberhill Creek, but which also contains riparian areas, playa habitat and vernal pools. Besides the portion of the proposed Project in the Cell, approximately 3.72 acres of the Cell consists of existing Additional Reserve Land (ARL); 4.61 acres consist of MSHCP Covered Road area for Collier Avenue and 17.46 acres of additional existing development (the Lake Elsinore Outlets and Interstate-15); 56.48 acres consist of undeveloped lands potentially available for conservation, consisting predominantly of Alberhill Creek and Collier Marsh; and 8.22 acres consist of undeveloped lands in the southwestern corner of the Cell (opposite side of the proposed Project from Alberhill Creek) that would not contribute to Reserve Assembly goals for Cell 4166. The proposed and existing conservation (33.86 acres) is in the middle of the range described for Cell 4166. The remaining undeveloped lands available for conservation consist of Alberhill Creek, its adjacent floodplain and Collier Marsh. Most of these areas are not likely to be developed. Cell 4166 is expected to exceed its goal with future conservation in the Cell and additional lands are not needed from the Project besides what is being proposed for conservation. The Reserve Assembly analysis for Cell #4166 is summarized below in Table 3-2 and is depicted on Exhibit 5. Table 3-2. Summary of Reserve Assembly for Cell 4166 Feature Acres Comment Total Area of Cell 4166 161.77 Described 15 to 25% (25 to 41 acres) in the northeastern portion Proposed Project, Existing Development, Existing/Planned Roadways, Exempt Lands Proposed Project 41.15 In the southwestern portion of the Cell Existing Development 17.46 In the northeastern corner of the Cell opposite Alberhill Creek Covered Roads 4.61 Collier Avenue Subtotal – Cell 4166 63.22 ARL Conserved Lands (Existing and Pending) Proposed; Dedicated as part of the Project 30.14 Central and northern portions of the Cell Existing 3.72 Adjacent to Collier Avenue at eastern edge of the Cell Subtotal – ARL Conserved Lands in Cell 4166 33.86 Undeveloped Lands Potentially Available for Conservation Undeveloped land northeast of the Project’s proposed conservation 56.48 Includes the majority of Alberhill Creek and Collier Marsh that is not yet conserved Subtotal – Undeveloped 56.48 MSHCP Consistency Analysis 15 Lands in Cell 4166 Undeveloped Lands that would not Contribute to Reserve Assembly Goals Undeveloped land southwest of the Project’s onsite development footprint 8.22 Opposite side of the Project site from the Project’s proposed conservation and the described lands for the Cell. Would not support Reserve Assembly goals for the Cell. Subtotal – Undeveloped Lands in Cell 4166 8.22 Cell 4166 = Total Conserved + Undeveloped and Available for Conservation (does not include PQP Lands) 90.34 Proposed and existing conservation (33.86 acres) is in the middle of the range described for Cell 4166. The remaining undeveloped lands available for conservation consists of Alberhill Creek, its adjacent floodplain and Collier Marsh. Most of these areas are not likely to be developed. Cell 4166 is expected to exceed its goal with future conservation and additional lands are not needed from the Project. 3.3.3 Cell Group W Approximately 6.09 acres of the Project site is within Cell Group W (1.26 acres in Cell# 4060 and 4.83 acres in Cell# 4067), consisting of offsite improvements to Nichols Road from the proposed intersection with Baker Street on the west to the existing Collier Road intersection on the east. The MSHCP Criteria for the Cell Group states the following: Conservation within this Cell Group will contribute to assembly of Proposed Core 1. Conservation within this Cell Group will focus on riparian scrub, woodland and forest habitat associated with Alberhill Creek and adjacent coastal sage scrub and grassland habitat. Areas conserved within this Cell Group will be connected to coastal sage scrub, riparian scrub, woodland and forest habitat proposed for conservation in Cell #3964 to the north, to coastal sage scrub habitat proposed for conservation in Cell #4057 to the west, and to grassland, riparian scrub, woodland and forest habitat proposed for conservation in Cell #4166 to the south. Conservation within this Cell Group will range from 80%-90% of the Cell Group focusing in the northwestern portion of the Cell Group. The improvements within Cell Group W will occur to existing portions of Nichols Road, which is a MSHCP Covered Road. As noted above, Nichols Road is identified as an “expressway” in the General Plan Circulation Element, with a 184-foot ROW, and therefore the MSHCP allowable covered width for permanent impacts for Nichols Road within the Criteria Area is 184 feet, encompassing all road elements, including the road shoulder. The Project proposes minor roadway resurfacing along the existing Nichols Road segment between the proposed Nichols Road/Baker Street intersection and MSHCP Consistency Analysis 16 Collier Avenue. The Nichols and Collier intersection may also include minor surface improvements, revised lane striping and potential traffic control/signage improvements. The proposed improvements will not exceed the maximum allowable covered width. The Project will be consistent with Reserve Assembly requirements for Cell Group W. 4.0 VEGETATION MAPPING AND SPECIES COMPENDIA This document includes vegetation mapping to reflect the existing conditions [Exhibit 7]. The 2012 MSHCP baseline identifies the majority of the Project site as Agricultural Land, with the San Jacinto River and portions of the offsite areas as Developed/Disturbed Land. However, the MSHCP requires that project-level vegetation mapping be conducted for projects that (1) need to demonstrate consistency with Criteria, (2) are subject to the Protection of Species Associated with Riparian/Riverine and Vernal Pools policies included in Section 6.1.2 of the MSHCP, (3) are subject to the Narrow Endemic Plant Species policies included in Section 6.1.3 of the MSHCP, (4) are subject to the Additional Survey Needs and Procedures described in Section 6.3.2 of the MSHCP, (5) are seeking criteria refinements as described in Section 6.5 of the MSHCP, and/or (6) need to demonstrate support of Reserve Assembly. Since one or more of these apply to the Project, GLA performed updated vegetation mapping for the Project site, including both onsite and offsite improvements. The RCA’s MSHCP Consistency Analysis template states that vegetation community classification should utilize current industry standard practices (e.g., A Manual of California Vegetation, 2nd Edition, Sawyer et al. 2009). Given the generally disturbed and developed nature of the Project site, and for most areas the dominance of mixed non-native vegetation, identifying vegetation series following the Manual of California Vegetation was not practical. Furthermore, a portion of the proposed conservation area contained vegetation that was more appropriate to classify as Playas and Vernal Pools in keeping with the MSHCP baseline. GLA mapped nine distinct vegetation/land use types for the Project site, including Akali Grassland, Akali Playa, Disturbed/Developed, Open Water, Riversidean Sage Scrub, Semi-Natural Herbaceous Grassland, Disturbed Semi-Natural Herbaceous Grassland, Southern Willow Scrub and Vernal Pool. Table 4-1 provides a summary of the vegetation types and their corresponding acreage. Descriptions of each vegetation type follow the table. A Vegetation Map is attached as Exhibit 6. Photographs depicting the Project site are shown in Exhibit 12. MSHCP Consistency Analysis 17 Table 4-1. Summary of Vegetation/Land Use Types for the Project Site Vegetation/Land Use Type Inside Criteria Cells (acres) Outside Criteria Cells (acres) Total (acres) Alkali Grassland 3.59 0 3.59 Alkali Playa 0.73 0 0.73 Disturbed/Developed 9.62 8.72 18.34 Open Water 0.09 0 0.09 Riversidean Sage Scrub 2.49 0.52 3.01 Semi-Natural Herbaceous Grassland 38.88 30.83 69.71 Disturbed Semi-Natural Herbaceous Grassland 20.71 5.56 26.27 Southern Willow Riparian Scrub 1.14 0 1.14 Vernal Pool 1.72 0 1.72 Total 78.97 45.63 124.60 Alkali Grassland Alkali grassland covers 3.59 acres of the Project site on the northeast side of Baker Street, primarily surrounding and/or associated with the vernal pools. Soil within these areas is mapped as Willows silty clay, which consists of well-drained, moderately slow permeable soils. Alkali grassland within the Project site includes alkali adapted plant species as well as rare plants. Dominant species within the meadow and marsh vegetation community include alkali weed (Cressa truxillensis), silverscale saltbush (Atriplex argentea), alkali mallow (Malvella leprosa), Harding grass (Phalaris aquatica), neckweed (Veronica peregrina), and foxtail barley (Hordeum murinum). This vegetation category also supports a variety of special-status plants including Coulter's goldfields (Lasthenia glabrata ssp. coulteri), San Jacinto valley crownscale (Atriplex coronata var. notatior), and vernal barley (Hordeum intercedens). Alkali Playa The Project site contains 0.73 acre of alkali playa, all of which occurs within the proposed RCA Conserved Land. Alkali playas are also dry lakes or edges of dry lakes that typically undergo periods of temporary inundation during the wet season and have high concentrations of alkali salts (Holland 1986). As such, alkali playas are dominated by plant species adapted to a salty substrate. The disturbed alkali playa within the Project site is located within the Alberhill Creek floodplain. Dominant species include alkali weed, alkali heath (Frankenia salina), salt grass, silverscale saltbush, and bush seepweed (Suaeda nigra). The alkali playa MSHCP Consistency Analysis 18 vegetation community within the Project site supports several rare plant species including Coulter’s goldfields, San Jacinto Valley crownscale, and vernal barley. Disturbed/Developed The Project site contains 18.34 of disturbed/developed land consisting of paved roads, unpaved access roads, and former residential lots. The disturbed/developed areas occur primarily along Baker Street, both within RCA conserved land and impact areas. The disturbed/developed portions of the site remain generally unvegetated, although ruderal species occur intermittently within and along the edges of these areas. Dominant species include coastal heron’s bill (Erodium cicutarium), Russian thistle (Salsola tragus), London rocket (Sisymbrium irio), cheeseweed (Malva parviflora), and summer mustard (Hirschfeldia incana). Open Water The Project site contains open water, covering approximately 0.09 acre. This land use type consists of a perennial portion of Alberhill Creek which flows through the northern limit of RCA conserved lands. Riversidean Sage Scrub A 3.01-acre patch of California Buckwheat Scrub occurs in the southwestern portion of the Project site. This intact vegetation community occurs on a steep slope, contains clay soils, and exhibits environmental characteristics typical of sage scrub communities such as spaced apart shrubs providing an open canopy to allow for interspersed growth of grasses and forbs. The Riversidean Sage Scrub vegetation community is dominated by shrub species including brittlebush (Encelia farinosa), California sagebrush (Artemisia californica), black sage (Salvia mellifera), and California buckwheat (Eriogonum fasciculatum). The understory consists of lower growing shrubs and perennial and annual herbs such as common sandaster (Corethrogyne filaginifolia), clustered tarweed (Deinandra fasciculata), blue dicks (Dichelostemma capitatum), wild cucumber (Marah macrocarpa), California plantain (Plantago erecta), and splendid mariposa (Calochortus splendens). Non-native grasses also occur in the understory including common Mediterranean grass (Schismus barbatus) and various brome species (Bromus spp.). Semi-Natural Herbaceous Grassland The majority of the Project site consists of semi-natural herbaceous grassland. This vegetation community comprises 69.71 acres and occurs throughout the entirety of the site, in both RCA conserved lands and impact areas. Although these areas currently remain largely undisturbed, the overall plant community exhibits significant historic disturbance that removed the mosaic of native plants that would have otherwise been present and replaced it with exotic species. As such, due to the current predominance MSHCP Consistency Analysis 19 of non-native species, the term “semi-natural” is used to describe this herbaceous grassland. In early spring, before annual grasses emerge, this vegetation community is dominated with common fiddleneck (Amsinckia intermedia), London rocket, cheeseweed, and coastal heron’s bill. Also present in early spring are sporadically occurring patches of native wildflowers including lupine (Lupinus bicolor), chick lupine (Lupinus microcarpus), goldfields (Lasthenia californica), and red maids (Calandrinia menziesii). Then, in late spring and early summer, this vegetation community is almost entirely dominated with non-native grass species including red brome (Bromus rubens), ripgut brome (Bromus diandrus), foxtail barley, and slim oat (Avena barbata). Disturbed Semi-Natural Herbaceous Grassland The Project site contains 26.27 acres of land mapped as disturbed semi-natural herbaceous grassland. This vegetation community occurs in the central portion of the site, bordering Baker Street on both sites, and also occurs in both RCA conserved lands and impact areas. It is nearly identical to the vegetation community described above (semi-natural herbaceous grassland); however, these areas currently experience more disturbance in the form of routine mowing and disking. As such, the disturbed semi- natural herbaceous grassland excludes pockets of native wildflowers and any semblance of a historic native plant community. The disturbed semi-natural herbaceous grassland is dominated with a variety of weedy, annual species including summer mustard, stinknet (Oncosiphon piluliferum), prickly lettuce (Lactuca serriola), London rocket, cheeseweed, coastal heron’s bill, red brome, ripgut brome, foxtail barley, and slim oat. Southern Willow Riparian Scrub The Project site contains 1.14 acres of southern willow riparian scrub as part of RCA conserved land, within and adjacent to Alberhill Creek. Southern willow riparian scrub consists of dense, broadleaved, winter-deciduous stands of trees dominated by shrubby willows (Salix spp.) in association with mule fat (Baccharis salicifolia). This vegetation community contains an assortment of young and mature trees, with willows ranging from 15- to 50-feet tall and is dominated by black willow (Salix gooddingii), red willow (Salix laevigata), and arroyo willow (Salix lasiolepis). Other species sporadically observed in association with this plant community include mule fat (Baccharis salicifolia), tamarisk (Tamarix ramosissima), western ragweed (Ambrosia psilostachya), big saltbush (Atriplex lentiformis), saltgrass (Distichlis spicata), and yerba mansa (Anemopsis californica). Vernal Pools Three vernal pools occur within the Project site on the northeast side of Baker Street, accounting for 1.72 acres. Vernal pools are ephemeral wetlands that form in shallow depressions underlain by a substrate near the surface that restricts the downward MSHCP Consistency Analysis 20 percolation of water. Depressions in the landscape fill with rainwater and runoff from adjacent areas during the winter and may remain inundated until spring or early summer, sometimes drying more than once during the wet season. Smaller pools can fill, and dry, and larger pools can hold water longer and may, in the deeper portions, support species that are more representative of freshwater marshes. Vernal pools are well-known for their high level of endemism (Stone, 1989) and abundance of rare, threatened, or endangered species (Sawyer and Keeler-Wolf, 1995). Vernal pools are dominated by native annual plants, with low to moderate levels of perennial herbaceous cover (MSHCP 2023). Within the Project site, the northernmost seasonal pool (Vernal Pool #3) is partially supported by runoff from an adjacent ephemeral drainage, while the remaining two pools (Vernal Pool #1 and 2) are depressional features that inundate from direct rainfall and runoff from the immediate local watershed. Dominant plant species within the pools include alkali plagiobothrys (Plagiobothrys leptocladus), alkali weed, alkali mallow, common toad rush (Juncus bufonius), and Harding grass (Phalaris aquatica). This vegetation category also supports a variety of special-status plants within the Project site including Coulter's goldfields, small-flowered microseris (Microseris douglasii ssp. platycarpha), San Jacinto Valley crownscale, and vernal barley. 5.0 PROTECTION OF SPECIES ASSOCIATED WITH RIPARIAN/ RIVERINE AREAS AND VERNAL POOLS (SECTION 6.1.2) Section 6.1.2 of the MSHCP establishes procedures through which the protection of Riparian/Riverine Areas and Vernal Pools would occur. The purpose of these procedures is to ensure that the biological functions and values of the riparian/riverine and vernal pool habitat areas throughout the MSHCP Plan Area are maintained such that habitat values for species inside the MSHCP Conservation Area are maintained. 5.1 Riparian/Riverine 5.1.1 Methods The MSHCP defines riparian areas as “lands which contain habitat dominated by trees, shrubs, persistent emergent mosses and lichens, which occur close to or which depend upon soils moisture from a nearby fresh water source. In the absence of riparian habitat, the MSHCP defines riverine areas as areas with fresh water flow during all or a portion of the year.” The MSHCP defines vernal pools as “seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation, and hydrology) during the wetter portion of the growing season but normally lack wetland indictors of hydrology and/or vegetation during the drier portion of the growing season.” MSHCP Consistency Analysis 21 With the exception of wetlands created for the purpose of providing wetlands habitat or resulting from human actions to create open waters or from the alteration of natural stream courses, areas demonstrating characteristics as described above which are artificially created are not included in these definitions. Furthermore, the MSHCP requires habitat assessments/focused surveys for certain species identified under Section 6.1.2, including riparian birds and fairy shrimp. Birds requiring assessments include the least Bell’s vireo (Vireo bellii pusillus, LBV), southwestern willow flycatcher (Empidonax traillii extimus), and western yellow-billed cuckoo (Coccyzus americanus occidentalis). Fairy shrimp requiring assessments include listed species such as the vernal pool fairy shrimp (Branchinecta lynchi) and Riverside fairy shrimp (Streptocephalus woottoni), as well as the Santa Rosa Plateau fairy shrimp (Linderiella santarosae). Although not directly referenced by Section 6.1.2, assessments also should consider the San Diego fairy shrimp (Branchinecta sandiegonensis) where appropriate. For fairy shrimp, habitat assessments should consider all non-vernal pool features that could sufficiently hold water, including stock ponds, ephemeral pools, road ruts, and other human made depressions. GLA surveyed the Project site for riparian/riverine areas. GLA biologists Jillian Stephens and David Moskovitz initially evaluated the site in April 2020, with follow-up visits conducted by GLA regulatory specialists Chris Waterston and Lesley Lokovic- Gamber on February 9, 2021, and April 20 and July 29, 2022. 5.1.2 Existing Conditions and Results The Project site contains approximately 3.03 acres of MSHCP riparian/riverine areas, including 2.36 acres of riparian habitats associated with Alberhill Creek, and 0.67 acre associated with six drainage features (Drainage A through F) [Exhibit 8 – MSHCP Riparian/Riverine Areas and Vernal Pools]. Approximately 2.58 acres of riparian/riverine areas are inside Criteria Cells and 0.45 acre of riverine areas are outside Criteria Cells. The 2.36 acres associated with Alberhill Creek includes 1.14 acres of Southern Willow Riparian Scrub, 0.73 acre of Alkali Playa, 0.09 acre of Open Water, and 0.40 acre of Semi-Natural Herbaceous Grassland. Table 5-1 below summarizes the riparian/riverine areas at the Project site. MSHCP Consistency Analysis 22 Table 5-1. MSHCP Riparian/Riverine Areas at the Project site Inside Criteria Cells Outside Criteria Cells Drainage Riverine (acres) Riparian (acres) Riverine (acres) Riparian (acres) Total (acres) Alberhill Creek 0 2.36 0 0 2.36 Drainage A 0.15 0 0.03 0 0.18 Drainage B 0 0 0.13 0 0.13 Drainage C 0.03 0 0 0 0.03 Drainage D 0 0 0.09 0 0.09 Drainage E 0.04 0 0 0 0.04 Drainage F 0 0 0.20 0 0.20 Total 0.22 2.36 0.45 0 3.03 Alberhill Creek Alberhill Creek enters the Project’s RCA Conserved Land from the southeast and extends in a northwesterly direction before exiting the conserved parcels just before the Nichols Road crossing. Alberhill Creek is dominated by southern willow scrub riparian habitat with an alkali playa component occurring in the abutting floodplain. A majority of the alkali playa component in the northeastern portion of the site exhibits at least some degree of soil disturbance and alterations to the hydrologic regime as evidenced by the presence of tire tracks, road ruts, and unauthorized dumping. Most of the riparian habitat (1.08 acres) associated with Alberhill Creek identified for the Project site is within the proposed open space. Approximately 0.06 acre of riparian habitat is mapped within the footprint for Nichols Road, consisting of willow limbs overhanging the roadway. As is described below, improvements to Nichols Road consisting of re-surfacing the existing roadway will not require the trimming of the overhanging willow limbs. Dominant riparian/wetland vegetation associated with Alberhill Creek includes salt cedar (Tamarix ramosissima), black willow (Salix gooddingii), arroyo willow (Salix lasiolepis), and mulefat (Baccharis salicifolia), with alkali bulrush (Bolboschoenus maritimus), common toad rush (Juncus bufonius), and cattail (Typha spp.). Other common plants include common nettle (Urtica dioica), summer mustard (Hirschfeldia incana), silverscale saltbush (Atriplex argentea), San Jacinto Valley crownscale (Atriplex coronata var. notatior), western ragweed (Ambrosia psilostachya), saltgrass (Distichlis spicata), and annual rabbitsfoot grass (Polypogon monspeliensis). MSHCP Consistency Analysis 23 Drainage A Drainage A originates offsite to the southwest, extending through the onsite portion of the Project to Baker Street where it crosses under Baker Street through a pipe culvert continuing in a northeasterly direction before its confluence with Alberhill Creek. The lower portion of Drainage A in the parcel boundary drains into one of three seasonal ponds (described separately below) before continuing its course towards Alberhill Creek. Drainage A ranges from two to six feet in width as evidenced by water marks, changes in soil characteristics, and bent vegetation. Vegetation associated with Drainage A includes foxtail barley (Hordeum murinum), soft chess (Bromus hordeaceus), ripgut brome (Bromus diandrus), red brome (Bromus madritensis ssp. rubens), rattail fescue (Festuca myuros), common Mediterranean grass (Schismus barbatus), cheeseweed (Marva parviflora), wild oats (Avena fatua), common fiddleneck (Amsinckia intermedia), stinknet (Oncosiphon piluliferum), annual mustard (Brassica ssp.), shortpod mustard, goldenbush (Isocoma menziesii), London rocket (Sisybrium irio), alkali heliotrope (Heliotropium curassavicum), and a single tamarisk. Additional species observed in the downstream reach include salt grass, alkali weed, ragweed, and a single tamarisk. This feature flows only in direct response to precipitation and was completely dry during the field investigations. Drainage B Drainage B is an earthen ephemeral drainage that enters the Baker parcel from the west along the edge of a former residential property and extends in a northeasterly direction towards Baker Street. Drainage B conveys storm water flows and receives irrigation runoff from the adjacent rural residence. The drainage extends up to ten feet in width as evidenced by changes in soil characteristics and bent vegetation. Vegetation associated with Drainage B consists primarily of semi-natural herbaceous grassland that includes foxtail barley, soft chess, ripgut brome, red brome, rattail fescue, common Mediterranean grass, cheeseweed, wild oats, common fiddleneck, stinknet, annual mustard, summer mustard, goldenbush, heliotrope, and London rocket. Drainage C Drainage C is an erosional ephemeral drainage that originates offsite from the adjacent hillsides and extends a northerly direction towards Baker Street. Drainage C averages two feet in width as evidenced by changes in soil characteristics and eroded channel banks in the upstream reach. The drainage bottom contains cobbles and was completely dry during the field investigations. Vegetation associated with Drainage C consists primarily of semi-natural herbaceous grassland that includes foxtail barley, soft chess, ripgut brome, red brome, rattail fescue, common Mediterranean grass, cheeseweed, wild oats, common fiddleneck, stinknet, annual mustard, summer mustard, goldenbush, heliotrope, and London rocket. Areas MSHCP Consistency Analysis 24 adjacent to the drainage contain patches of California buckwheat (Eriogonum fasciculatum), bush sunflower (Encelia californica), and California sagebrush (Artemisia californica). Drainage D Drainage D is an erosional drainage that occurs in the southwestern portion of the Baker parcel. The drainage originates offsite from the southwest and meanders in a northeasterly direction before exiting the parcel boundary at an existing rural residence. Drainage D ranges between two and six feet in width and contains eroded banks and cobbles. This feature conveys flow only in direct response to precipitation and was completely dry during the field investigation. Vegetation associated with Drainage D consists primarily of semi-natural herbaceous grassland that includes foxtail barley, soft chess, ripgut brome, red brome, rattail fescue, common Mediterranean grass, cheeseweed, wild oats, common fiddleneck, stinknet, annual mustard, summer mustard, goldenbush, heliotrope, and London rocket. Areas adjacent to the drainage contain patches of California buckwheat, bush sunflower, and California sagebrush. Drainage E Drainage E is an earthen ephemeral drainage that originates as run-off from Nichols Road. This feature extends in an easterly direction before dissipating as sheet flow. The drainage averages three feet in width, and depending on rainfall amounts, conveys a surficial connection to Alberhill Creek. Vegetation associated with the drainage is limited to non-native upland grasses and weeds including foxtail barley, soft chess, ripgut brome, red brome, rattail fescue, common Mediterranean grass, cheeseweed, wild oats, common fiddleneck, stinknet, annual mustard, summer mustard, heliotrope, and London rocket. This drainage lacks hydrophytic vegetation and was completely dry during the field investigations. Vegetation associated with Drainage E consists primarily of semi-natural herbaceous grassland that includes foxtail barley, soft chess, ripgut brome, red brome, rattail fescue, common Mediterranean grass, cheeseweed, wild oats, common fiddleneck, stinknet, annual mustard, summer mustard, goldenbush, heliotrope, and London rocket. Drainage F Drainage F consists of a roadside drainage channel along the northern edge of Nichols Road. This feature extends in an easterly direction. The drainage averages six feet in width and is generally unvegetated. MSHCP Consistency Analysis 25 5.1.3 Impacts The proposed Project will permanently (directly) impact approximately 0.50 acre of MSHCP riverine areas but will not impact any riparian habitat. Impacts will occur to five drainage features (A, B, C, D and F). Table 5-2 summarizes impacts to riverine features. Table 5-2. Impacts to MSHCP Riverine Areas Drainage Inside Criteria Cells (acres) Outside Criteria Cells (acres) Total Impacts (acres) Drainage A 0.02 0.03 0.05 Drainage B 0 0.13 0.13 Drainage C 0.03 0 0.03 Drainage D 0 0.09 0.09 Drainage F 0 0.20 0.20 Total 0.05 0.45 0.50 The drainage features to be impacted by the Project are vegetated with semi-natural herbaceous grassland, which is dominated by a mix of non-native grasses and native and non-native forbs. As such, the drainages to not support biological functions for the MSHCP Section 6.1.2 species. The functions of the drainage features are limited to hydrologic functions, specifically conveyance downstream towards the Alberhill Creek floodplain. The drainage features collect runoff from the southwest and generally convey flows to the northeast. As documented in the Project’s Hydrology Memorandum (Appendix E), the Project is designed to collect the runoff and mimic the existing hydrologic conditions to the three vernal pools and the downstream Alberhill Creek/Temescal Wash resources to the maximum extent feasible, such that the Project is not expected to adversely affect the hydrologic functions of the vernal pool and riparian/riverine resources. The Project will not impact riparian habitat associated with Alberhill Creek. Most of the riparian habitat is within the proposed open space. Approximately 0.06 acre of riparian habitat is mapped within the footprint for Nichols Road, consisting of willow limbs overhanging the roadway. Improvements to Nichols Road consisting of re-surfacing the existing roadway will not require the trimming of the overhanging willow limbs. 5.1.4 Mitigation The Project will mitigate impacts to 0.50 acre of riverine areas offsite through the purchase of mitigation credits from the Riverpark Mitigation Bank. The mitigation credits will include a minimum 1:1 of re-establishment and 2:1 of re-establishment and/or re- habilitation. Since the Riverpark Mitigation Bank involves the restoration of areas MSHCP Consistency Analysis 26 adjacent to the San Jacinto River, the mitigation bank lands provide hydrologic functions to the San Jacinto River floodplain similar to the functions provided by drainage features to be impacted at the Project site that are tributary to the Alberhill Creek floodplain. As a matter of habitat replacement, the purchase of 1.50 acres of mitigation credits (1:1 of re-establishment and 2:1 of re-establishment and/or re-habilitation) will be biologically superior compared with the impacts. 5.2 Vernal Pools 5.2.1 Methods The MSHCP defines vernal pools as “seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation, and hydrology) during the wetter portion of the growing season but normally lack wetland indictors of hydrology and/or vegetation during the drier portion of the growing season.” GLA surveyed the Project site for vernal pools as part of the jurisdictional delineation to identify seasonal wetlands. GLA biologists evaluated the topography of the site, including whether the site contained depressional features/topography with the potential to become inundated; whether the site contained soils associated with vernal/seasonal pools; and whether the site supported plants that suggested areas of localized ponding. The site was evaluated on multiple occasions during the rainfall season, including in 2020, 2021, 2022 and 2024. GLA biologists Jillian Stephens and David Moskovitz initially evaluated the site in April 2020, with follow-up visits conducted on February 9, 2021, and April 20, 2022. The 2024 monitoring corresponded with the wet season fairy shrimp surveys. 5.2.2 Existing Conditions and Results The Project site contains three areas on the northeastern side of Baker Street that pond seasonally and exhibit the three wetland parameters to meet the definition of MSHCP Vernal Pools. These areas are referenced herein as Vernal Pools 1, 2, and 3, all of which are inside Criteria Cells. Vernal Pools 1 and 2 are in proximity to, but do not directly abut, Alberhill Creek. Vernal Pool 3 is connected to Drainage A, which connects with Alberhill Creek. All three vernal pools are in areas mapped as containing Willows Silty Clay soils [Exhibit 7 – Soils Map]. Each of the vernal pools, as described below, are unique in terms of their hydrology, soils appearance, relationship to the ecosystem and vegetation assemblage. Table 5-3 summarizes vernal pools at the Project site. MSHCP Consistency Analysis 27 Table 5-3. MSHCP Vernal Pools at the Project site Vernal Pool Total Pool Area (acres) Vernal Pool 1 0.45 Vernal Pool 2 0.41 Vernal Pool 3 0.86 Total 1.72 Vernal Pool 1 Vernal Pool 1 is approximately 0.45 acre. The vernal pool is in an area mapped as containing Willow Silty Clay soils (saline-alkali) and the strong alkaline component is evident in the white color of the spoils. The main ponding area does not become heavily vegetated due to the alkalinity; however, the areas surrounding the ponding basin supports species such as salt grass, Coulter’s goldfields, vernal barley, and San Jacinto Valley crownscale. Adjacent to the area of Vernal Pool 1, the floodplain of the Alberhill Creek/Collier Marsh bows out and is proximal to the vernal pool, such that it appears that this vernal pool is more directly influenced hydrologically and historically in its formation by the creek. Vernal Pool 2 Vernal Pool 2 is approximately 0.41 acre. As with Vernal Pool 1, this vernal pool is in an area mapped as containing Willow Silty Clay soils (saline-alkali). However, Vernal Pool 2 has a different appearance than Vernal Pool 1 in the soils and the resulting vegetative makeup. All three vernal pools at the Project site have been disturbed in the past and it is possible that soils underlying Vernal Pool 2 have been modified, possible with in-fill soils. Regardless, the vernal pool contains a strong alkaline component. A few individuals of Coulter’s goldfields were observed on the edge of the pool; however, the other species associated with Vernal Pools 1 and 3 were not detected in Vernal Pool 2. Vernal Pool 3 Vernal Pool 3 is approximately 0.86 acre. As with Vernal Pools 1 and 2, this vernal pool is in an area mapped as containing Willow Silty Clay soils (saline-alkali). However, the appearance (color) of the soils associated with Vernal Pool 3 suggests a lesser alkaline component than with Vernal Pool 1, which is also reflected in the denser vegetation within Vernal Pool 3, including a sizeable population of Coulter’s goldfields. Additional vernal pool plant species noted in Vernal Pool 3 includes vernal barley and woolly MSHCP Consistency Analysis 28 marbles (Psilocarphus brevissimus var. brevissimus) and alkali popcorn flower (Plagiobothrys leptocladus). Hydrologically, Vernal Pool 3 is different than the other two vernal pools. Drainage A is connected to the downslope end of the pool and runoff from Drainage A helps to feed the pool along with runoff from Baker Street, and vertical rainfall falling on the pool and from the immediate watershed. 5.2.3 Impacts Direct Impacts The Project will permanently impact up to 0.17 acre of vernal pools including 0.01 acre of Vernal Pool 2 and 0.16 acre of Vernal Pool 3 along the southern edge because of constructing the storm drain outlets along the edge of the Baker Street improvements, although much if not all of the impacts might be temporary. As described below the southern edge of Vernal Pool 3 will be recontoured following the completion of construction of the Baker Street improvements and the storm drain outlets/spreading structures, and the vernal pool will be part of the Project’s proposed RCA Conserved Land. The potential impact to Vernal Pool 2 is limited to 0.01 acre at the southern edge. The Project will avoid direct impacts to Vernal Pool 1, and both Vernal Pools 1 and 2 will also be part of the RCA Conserved Land. Impacts to vernal pools are summarized in Table 5-4 below. Table 5-4. Impacts to Vernal Pools Vernal Pool Vernal Pool Impacts (acres) Vernal Pool 1 0 Vernal Pool 2 0.01 Vernal Pool 3 0.16 Total 0.17 Indirect Effects The Project is designed to avoid or otherwise minimize indirect effects to sensitive MSHCP resources. The focus of the analysis is on hydrologic effects to the three vernal pools located in the adjacent proposed RCA Conserved Land, and downstream aquatic resources in the Alberhill Creek/Temescal Wash, as well as the effects of noise and lighting on adjacent RCA Conserved Land. The Project is part of the overall watershed for Alberhill Creek/Temescal Wash. The Project’s Hydrology Memorandum [Appendix E] describes the Project site as being part of four smaller drainage areas (Watersheds A, B, C and D) that each drain a specific area. Three of these watersheds each contain one of the three vernal pools that are described above. Each of these smaller MSHCP Consistency Analysis 29 watersheds are described below in detail, including the acreage of each watershed in the existing condition, the flows associated with each watershed for the 2-, 5-, and 10- year rainfall events, and the resources that each watershed drains to. The Hydrology Memorandum includes an exhibit (Appendix B) depicting each watershed in the existing condition. The Hydrology Memorandum evaluates the potential hydrologic effects of the Project on the vernal pools and associated plant resources, and Alberhill Creek by modelling the flow rates for the same rainfall events after Project implementation. The goal of the Project is to ensure that the same or similar amounts of water reach the adjacent Conserved Lands to mimic the existing condition. However, through the modification of the site drainage, the four watersheds vary from the existing condition in where the water is drawn from that feeds the different open space areas adjacent to the Project. For example, the sheet flows from Watershed C in the existing condition that originate from direct rainfall onto the site and flow towards Vernal Pool 1 will, in the post-Project condition, drain towards Vernal Pool 3. To mimic the existing hydrologic condition for Vernal Pool 1, the water draining into the modified Vernal Pool 1 watershed will come entirely from the improved sections of Pierce Street and Baker Street to re-create what came from the original Watershed C. The proposed condition is provided in Appendix C of the Hydrology Memorandum. Watershed A – Watershed A is located on the southeastern side of the Project and has an existing-condition tributary of approximately 165.20 acres, corresponding with Drainage D (described above). The tributary watershed originates offsite to the south and west, extending northeast to Baker Street and eventually to Alberhill Creek/ Temescal Wash. Watershed A does not contribute to either of the three vernal pools, but instead sheet flows directly to the offsite creek floodplain. Table 5-5 below summarizes the flow rates for the 2-, 5- and 10-year rainfall events. In the proposed condition, the Project will decrease the total watershed acreage slightly to 163.30 acres. The flows that originate offsite will be directed towards a proposed flow-by basin along the edge of the Project site. Flows will then bypass the Project through a public storm drain that discharges on the northern side of Baker Street and continue down to Alberhill Creek/Temescal Wash as they have done historically. In the proposed condition, the flow rates will increase slightly for each of the three rainfall events modelled, including from 84.20 cfs to 88.07 cfs in the 2-year event (4.6 percent), 132.10 cfs to 136.99 cfs in the 5-year event (3.7 percent), and from 197.60 cfs to 202.45 cfs in the 10-year event (2.5 percent). These increases are negligible from an engineering standpoint and are not expected to adversely affect downstream resources in Alberhill Creek/Temescal Wash. Watershed B – Watershed B is located north of Watershed A and has an existing- condition tributary of approximately 27.79 acres. Watershed B originates offsite to the southwest although the majority of watershed onsite. Sheet flows from the watershed cross Baker Street and contribute to the hydrology of Vernal Pool 2. In the proposed condition, the Project will increase the total watershed acreage slightly to 28.54 acres. Once the sheet flows from Watershed B (and C) will be collected and treated via BMPs, they are discharged into a proposed trough system. As concentrated flows leave each pipe from the BMP structures, the flows will hit the splash wall of the trough and spread MSHCP Consistency Analysis 30 out across the entire length of the trough system. The northern side of the trough system will have six-inch openings every five feet that will help create a sheet flow condition towards Vernal Pool 2 (and towards Vernal Pool 1) that mimics existing condition. In the proposed condition, the flow rates will increase for each of the three rainfall events modelled, including from 25.16 cfs to 27.27 cfs in the 2-year event (8.4 percent), 36.51 cfs to 38.77 cfs in the 5-year event (6.2 percent), and from 45.19 cfs to 47.41 cfs in the 10-year event (4.9 percent). These increases are negligible from an engineering standpoint and are not expected to adversely affect Vernal Pool 2. Furthermore, as noted above, Vernal Pool 2 will be enhanced (including a slight increase in size) with the increase in hydrology expecting to benefit the proposed enhancement of the vernal pool. As also noted above, Vernal Pool 2 will be monitored for at least five years as part of the enhancement effort to document ponding metrics of the pool (total basin area, depth and ponding duration). Watershed C – Watershed C is located north of Watershed B and south of Watershed D. Watershed C comprises 6.40 acres, nearly all of which is contained within the Project site. Vernal Pool 1 is within Watershed C. The watershed begins at the top of a hill and then flattens out as it approaches Baker Street. Sheet flows from the watershed slow down as the flows reach the flatter area, with some proportion of the flows reaching and crossing over Baker Street, some flows percolating into the ground and continuing subsurface under Baker Street towards the vernal pool, and some of the water not reaching vernal pool. The amount and proportion of water reaching the vernal pool varies depending on the level of storm event. The vernal pool is also heavily dependent on direct vertical rainfall for the pool to inundate, requiring multiple rainfall events for the soil particles to charge and the substrate to seal up allowing the pool to hold water for a longer term. As part of GLA’s wet season fairy shrimp surveys conducted in 2024, GLA began monitoring Vernal Pool 1 after initial measurable rainfall in the middle of January 2024; however, the vernal pool did not exhibit prolonged inundation to initiate fairy shrimp sampling for another two weeks. On February 2, 2024, the vernal pool was measured as 8 m by 6 m with a depth of 10 cm. By the following week, the pool was measured as 50 m by 27 m with a depth of 30 cm, and then because of off-and-on rain events, the vernal pool generally maintained those dimensions until the middle of April. GLA biologists did not observe clear evidence of sheet flows over the top of Baker Street and there are no road culverts at that location. As such, it is GLA’s opinion that a higher proportion of the vernal pool hydrology is due to direct vertical rainfall, while additionally supported (at least based on the rainfall events observed in 2024) by a proportion of sheet flows that mostly (if not entirely) reach the immediate vernal pool watershed via subsurface flow. In the proposed condition, the portion of Watershed C that is southwest of Baker Street will be become part of the new Watershed D that feeds Vernal Pool 3. In its place, a new Watershed C will be created, drawing from the newly developed portions of Pierce Street and Baker Street. The total acreage of the new Watershed C will be 6.20 acres. This represents a slight decrease compared with the existing Watershed C, but the acreage is less relevant when compared with the new source of water that will feed into the remaining portions of the Vernal Pool 1 watershed northeast of Baker Street. The MSHCP Consistency Analysis 31 water collected from the road rights-of-way will be collected and treated via BMPs, and then discharged into the proposed trough system located adjacent to the immediate Vernal Pool 1 watershed. As concentrated flows leave each pipe from the BMP structures, the flows will hit the splash wall of the trough and spread out across the entire length of the trough system. The northern side of the trough system will have six- inch openings every five feet that will create a sheet flow condition towards Vernal Pool 1, mimicking the existing condition. However, the trough system will be constructed on the side of Baker Street facing the vernal pool, providing a more direct sheet flow release towards the immediate vernal pool watershed. Whereas in the existing condition, most of the sheet flows do not reach the vernal pool side of Baker Street as surface flows. In the proposed condition, the flow rates will slightly decrease for each of the three rainfall events modelled, including from 5.46 cfs to 5.06 cfs in the 2-year event (7.3 percent), 7.84 cfs to 7.30 cfs in the 5-year event (6.9 percent), and from 9.64 cfs to 9.01 cfs in the 10-year event (6.5 percent). However, when considering the nature of the existing condition, by constructing the trough system in closer proximity to the immediate vernal pool watershed, the relative amount of surface and subsurface flows reaching the pool basin might increase by a small margin, or at least will represent less of a decrease than has been modelled. As part of the Project’s mitigation activities, the hydrology of Vernal Pool 1 will be monitored post-project for at least five years to document the ponding metrics of the vernal pool compared with what was observed in 2024. Watershed D – Watershed D is located on the northwestern part of the Project and has an existing-condition tributary of approximately 217.79 acres, corresponding with Drainages A, B and C described above. The portion of the watershed feeding Drainage A originates offsite from a basin at the Terracina development tract into Drainage A, conveying flows towards and through the Project site before entering Vernal Pool 3 on the northern side of Baker Street. Flows feeding Drainage B onsite become sheet flows that cross Baker Street in the proposed open space located west of Vernal Pool 3. Flows feeding Drainage C also enter Vernal Pool 3 after crossing Baker through a separate culvert pipe. In the proposed condition, the Project will increase the total watershed acreage slightly to 220.06 acres. Flows originating offsite from the Terracina tract will enter a proposed debris basin at western edge of the Project site and then flow through the Project site through a public storm that discharges into a separate trough system that is like what is described above for Watersheds B and C (Vernal Pools 2 and 1). The trough system will also accept onsite runoff generated within the watershed. This separate trough system will mimic the existing condition flows to Vernal Pool 3 by providing both a point source and supportive sheet flow. The trough system is designed to let larger flows during high storm events continue down the existing flowline that leads to Alberhill Creek/Temescal Wash, while still operating returning concentrated flows to sheet flow during smaller storm events. In the proposed condition, the flow rates will increase for each of the three rainfall events modelled, including from 154.14 cfs to 178.18 cfs in the 2-year event (15.6 percent), 230.40 cfs to 244.60 cfs in the 5- year event (6.2 percent), and from 284.45 cfs to 290.89 cfs in the 10-year event (2.3 percent). These increases are not expected to adversely affect Vernal Pool 3, nor downstream resources associated with Alberhill Creek/Temescal Was. Furthermore, as MSHCP Consistency Analysis 32 noted above, Vernal Pool 3 will be enhanced (expanded in size) with the increase in hydrology benefitting the proposed enhancement of the vernal pool. As also noted above, Vernal Pool 3 will be monitored for at least five years as part of the enhancement effort to document ponding metrics of the pool. Table 5-5. Comparison of Existing and Proposed Hydrologic Conditions Watershed A Condition Acreage Q2 (cfs) Q5 (cfs) Q10 (cfs) Existing 165.20 84.20 197.59 332.50 Proposed 163.30 88.07 178.35 299.61 Change +4.6 % +3.7 % +2.5 % Watershed B (Vernal Pool 2) Condition Acreage Q2 (cfs) Q5 (cfs) Q10 (cfs) Existing 27.79 25.16 36.51 45.19 Proposed 28.54 27.27 38.77 47.41 Change +8.4 % +6.2 5 +4.9 % Watershed C (Vernal Pool 1) Condition Acreage Q2 (cfs) Q5 (cfs) Q10 (cfs) Existing 6.40 5.46 7.84 9.64 Proposed 6.20 5.06 7.30 9.01 Change -7.3 % -6.9% -6.5% Watershed D (Vernal Pool 3) Condition Acreage Q2 (cfs) Q5 (cfs) Q10 (cfs) Existing 217.79 154.14 230.40 284.45 Proposed 220.06 178.18 244.60 290.89 Change +15.6 % +6.2 % + 2.3 % 5.2.4 Mitigation As noted above, up to 0.17 acre of the vernal pools (0.01 acre of Vernal Pool 2 and 0.16 acre of Vernal Pool 3) will be directly impacted to construct the Baker Street improvements and spreading structures/storm drain outlets. Following the completion of construction, the southern edge of Vernal Pool 3 will be re-contoured and any portion of the 0.16-acre impacts that are temporary will be restored, including a revegetation coinciding with the Coulter’s goldfields mitigation (discussed below). Permanent impacts to the vernal pools will be mitigated by expanding Vernal Pool 3 on the opposite side from the impacts through recontouring and revegetating. In addition, Vernal Pool 2 MSHCP Consistency Analysis 33 will be expanded and enhanced. The vernal pools will be expanded by at least a 3:1 ratio versus the permanent impacts. Assuming up to 0.17-acre of permanent impacts, the vernal pool(s) will be expanded by at least 0.51 acre. A Habitat Mitigation and Monitoring Plan (HMMP) will be prepared to address the vernal pool mitigation. The HMMP will, at a minimum, include details about the type of mitigation, acreages, when the mitigation would be implemented, plant palettes, site preparation, weeding plan, success criteria, monitoring plan (e.g., years/duration, frequency, etc.), reporting, the proposed management entity, and contingency measures in the event the mitigation is not successful. The monitoring will include hydrologic monitoring to confirm that the recontoured areas inundate sufficiently to support seasonal ponding/wetland conditions. The type of contingency measures would depend on which success criteria have not been met. If the vernal pools are not meeting plant coverage and/or non-native criteria, then additional plant remediation/maintenance efforts would be implemented, and the monitoring period would be extended. If the expanded vernal pools are not meeting inundation criteria, then possibly the pools would be regraded, or the soils remediated to address hydrology. Additional details will be provided in the HMMP. The HMMP will be provided to the RCA and Wildlife Agencies for review and approval. The proposed mitigation will be subject to approval through the DBESP process, in addition to JPR. 5.3 Fairy Shrimp The Project site contains four seasonally ponding features with a potential to support listed fairy shrimp, including one stock pond feature (Pool 4) within the Industrial portion of the Project, and three vernal pools that either overlap with the offsite improvements and maintenance area associated with Baker Street or are immediately adjacent in the proposed RCA Conserved Lands. All four features require protocol surveys (dry season and wet season) to determine the presence or absence of listed fairy shrimp. To complete the survey protocol for all four features, dry season surveys were completed in 2023 [Appendix B – 2023 Dry Season Fairy Shrimp Report] and wet season surveys were completed for the 2023-2024 rainfall season [Appendix C – 2023/2024 Wet Season Fairy Shrimp Report]. 5.3.1 Methods Dry Season Surveys Soil sample collection followed the USFWS Survey Guidelines for the Listed Large Branchiopods (Survey Guidelines).1 GLA biologist David Moskovitz (PER0010680-0) supervised the collection of soil samples along with GLA biologists Stephanie Cashin and Chris Waterston in October 2023. Soil samples were collected when the pools were dry using a hand trowel to collect intact chunks of soil from the top 1–3 cm of pool sediment. The number of soil samples collected from each of features was based on feature size according to the Survey Guidelines. Starting at the edge of each depression, samples were taken from equidistant points along the longest transect and 1 USFWS. Survey Guidelines for the Listed Large Branchiopods, Revised: November 13, 2017. MSHCP Consistency Analysis 34 widest transect of each depression. Additional samples were taken at the deepest part of each feature. Soil samples of approximately 100 milliliters (ml) each were removed at each sub- sample location using a hand trowel and were combined into a labeled bag for each feature with the collection date, location and feature ID, and name of collector for future processing. Samples were stored in a dry location out of direct sunlight until delivery for processing. The soil samples were processed by D. Christopher Rogers (TE796284-7). Soil samples were labelled with the numbers on their respective bags and prepared for examination by dissolving the clumps of soil in water and sieving the material through 300- and 150- µm pore size screens. The small size of these screens ensures that the eggs from the shrimp species will be retained. The portion of each sample retained in the screens was dissolved in a brine solution to separate the organic material from the inorganic material. The organic fraction was then examined under a microscope. Counts were made by estimating the number of eggs per 100ml of soil, because not all samples had the same volume of soil collected originally. Isolated eggs from each sample were cultured separately. Adult shrimps were reared from the recovered eggs using methods following Martin, Rogers & Olesen (2016). Hatched shrimps were fed a standard Daphnia food that includes; fish food, fish oil, baker’s yeast, and the alga Selenastrum capricornutum. The shrimp were reared to maturity. Adult Branchinecta reared from culture were killed in 90% ethyl alcohol and examined under a stereo dissection microscope. Identifications were made based upon comparisons with specimens in our collections, the original species descriptions, and professional experience. Wet Season Surveys Wet season fairy shrimp surveys were performed for the four seasonal pond features for the 2023-2024 rainfall season, as a follow up to the dry season surveys. The surveys were performed by GLA biologists Stephanie Cashin (TE-20280D-0) and Chris Waterston (ESPER-2380694). In accordance with the USFWS Survey Guidelines for the Listed Large Branchiopods (Survey Guidelines) dated November 13, 2017, site visits were conducted following measurable rainfall events to determine whether any of the features contained a minimum of three centimeters (cm) of ponding after 24 hours from the rainfall event. Storms in late December 2023 and early January 2024 initiated hydrologic monitoring of the pools. Pool 3 began to sustain ponding after storms between January 19 - 23, 2024, with sampling in Pool 3 initiated beginning January 26, 2024. Pools 1 and 4 began to sustain ponding beginning February 2, 2024. After a multiple day storm in early February 2024, all pools reached the maximum extent of MSHCP Consistency Analysis 35 ponding. Pool 1 remained ponded until May 9, 2024. Pool 3 remained ponded until May 14, 2024. Pool 2 and 4 remained ponded until May 22, 2024. Sampling for the presence of fairy shrimp was performed using a dip net within representative portions of the depression bottom, edges, and vertical water column when there was adequate ponding. Specimens were placed into vials, with unique depression information, containing 95% ethanol solution. Specimens were identified through microscopy and using the “Key to California Fairy Shrimps” found in Eriksen and Belk (1999, Revised 2016). 5.3.2 Existing Conditions and Results Dry Season Surveys Cysts belonging to the genus Branchinecta were isolated from soil samples in Pools 1, 2 and 3, but not from Pool 4. Adult B. lindahli were reared from cultures in Pools 1, 2 and 3. No suspected hybrids between B. lindahli and the federally listed B. sandiegonensis were identified. Wet Season Surveys The versatile fairy shrimp (B. lindahli) was detected in Pools 1, 2 and 3, but not in Pool 4. These results are consistent with the findings of the preceding dry season surveys. No listed fairy shrimp species were detected. The western spadefoot (Spea hammondii) was detected in Pools 1, 2 and 3. 5.3.3 Impacts The Project will not impact listed fairy shrimp, although it will impact populations of the non-listed versatile fairy shrimp. 5.3.4 Mitigation Mitigation is not required for impacts to the non-listed versatile fairy shrimp. 5.4 Riparian Birds 5.4.1 Methods The MSHCP requires habitat assessments and focused surveys (if suitable habitat) for least Bell’s vireo (Vireo bellii pusillus), southwestern willow flycatcher (Empidonax traillii extimus), and western yellow-billed cuckoo (Coccyzus americanus occidentalis). The proposed development areas of the Project do not contain suitable habitat for these species; however, Alberhill Creek contains suitable habitat for the vireo and flycatcher, and because the proposed improvements to Nichols Road are adjacent to the creek, focused surveys were conducted for both species. GLA performed protocol surveys for MSHCP Consistency Analysis 36 least Bell’s vireo and southwestern willow flycatcher in 2020. The survey methods and results are summarized here. A separate survey report is included as Appendix D. Least Bell’s Vireo GLA biologists Stephanie Cashin, Jeff Ahrens and April Nakagawa conducted focused surveys for the least Bell’s vireo (LBV) within the portions of Alberhill Creek in proximity to the Project site. Surveys were conducted in accordance with the 2001 USFWS survey guidelines, which stipulate that eight surveys should be conducted between April 10 and July 31, with a minimum of ten days separating each survey visit. The survey guidelines state that surveyors should not survey more than three linear kilometers or more than 50 hectares (about 120 acres) of habitat on any given survey day. There is no suitable habitat for LBV within the onsite portion of the Project. The only suitable habitat relative to the Project is the portion of Alberhill Creek that is adjacent to a portion of Nichols to be improved and coincides with the northern portion of the proposed conservation lands. As such, GLA’s survey area for LBV comprised less then 1,000 linear feet and less than five acres, representing a small fraction of the maximum area allowed for a single survey visit. Focused surveys were conducted on April 13, May 5, 18 and 28, June 8 and 19, and July 15 and 28, 2020. As is described below, a single LBV was first detected during the May 5 survey by Jeff Ahrens and confirmed again during subsequent visits. Mr. Ahrens performed the first survey for the southwestern willow flycatcher on May 18, 2020, with the first half of the morning dedicated to the flycatcher, walking upstream through Alberhill Creek, and then surveying for LBV walking downstream through the creek. Furthermore, because LBV had already been confirmed present on May 5, the May 18 visit re-confirmed LBV presence. Pursuant to the survey guidelines, the surveys were conducted between sunrise and 11:00 a.m. Weather conditions during the surveys were conducive to a high level of bird activity. Table 5-5 summarizes the vireo survey visits. MSHCP Consistency Analysis 37 Table 5-5. Summary of Least Bell’s Vireo Surveys Survey Date Biologist(s) Start/End Time Start/End Temperature (°F) Start/End Wind Speed (mph) Cloud Cover 4/13/20 SC 0620/1000 60/68 0-1/0-1 100/100 5/5/20 JA 0550/0920 56/75 1-2/0-2 0/0 5/18/20 JA 0550/1100 57/69 1-2/1-2 80/50 5/28/20 AN 0600/1100 62/84 0-1/0-1 0/0 6/8/20 AN 0645/1100 58/75 8-10/8-10 0/0 6/19/20 SC 0615/1015 59/67 0-2/0-1 100/50 7/15/20 AN 0645/1100 62/77 0-1/0-1 100/0 7/28/20 AN 0700/1100 62/88 0-1/4-5 0/0 SC = Stephanie Cashin; JA = Jeff Ahrens; AN = April Nakagawa Southwestern Willow Flycatcher GLA biologist Jeff Ahrens conducted focused surveys for the southwestern willow flycatcher for all suitable habitat areas within the Project site. Surveys were conducted in accordance with the 2010 USFWS survey guidelines, which stipulate five survey visits between May 15 and July 17, divided into three survey periods. The southwestern willow flycatcher is one of three subspecies of willow flycatcher that occur within southern California but is the only subspecies that breeds in southern California. The other subspecies may occur in southern California as they migrate through the area onwards to northern breeding areas but will not breed in southern California. If present, these subspecies may be detected during the first and/or second survey periods. The presence of the southwestern willow flycatcher is determined by willow flycatchers that remain in southern California during the third survey period. Focused surveys were conducted on May 18, June 9 and 23, and July 1 and 16, 2020. As noted above, Mr. Ahrens’ visit on May 18 was also counted as a LBV survey visit, but the survey efforts were divided, first surveying for the flycatcher while walking upstream through Alberhill Creek and then surveying for LBV while walking downstream through the creek. Pursuant to the survey guidelines, the surveys were conducted between one hour prior to sunrise and 10:00 a.m. Weather conditions during the surveys were conducive to a high level of bird activity. Table 5-6 summarizes the flycatcher survey visits. MSHCP Consistency Analysis 38 Table 5-6. Summary of Southwestern Willow Flycatcher Surveys Survey Date Biologist(s) Start/End Time Start/End Temperature (°F) Start/End Wind Speed (mph) Cloud Cover 5/18/20 JA 0550/1100 57/69 1-2/1-2 80/50 6/9/20 JA 0600/0940 53/73 1-2/1-2 0/0 6/23/20 JA 0555/1000 58/68 0-1/0-1 100/0 7/1/20 JA 0555/0930 60/66 1-2/1-2 100/100 7/16/20 JA 0550/0930 59/72 1-2/0-1 30/0 JA = Jeff Ahrens 5.4.2 Existing Conditions and Results GLA biologists did not detect the southwestern willow flycatcher during the focused surveys. A male LBV (presumed nesting based on behavior) was detected within Alberhill Creek during multiple visits within close proximity to Nichols Road and the Project’s proposed conservation, with the LBV first detected during the May 5, 2020, survey visit. All subsequent visits were used to confirm the extent of use of the presumed nesting pair. Based on the detections, the habitat with Alberhill Creek between Nichols Road and the proposed conservation would be considered occupied and have long-term conservation value for least Bell’s vireo, with approximately 1.08 acres of the habitat occurring within the proposed conservation area, and approximately 0.06 acre of habitat consisting of willow canopy overhanging Nichols Road. 5.4.3 Impacts The Project will not directly impact riparian birds, including least Bell’s vireo. The Project will not remove any riparian habitat, including habitat with LTVC for the vireo. Riparian habitat is located adjacent to Nichols Road with approximately 0.06 acre of canopy overhanging into the roadway; however, proposed improvements adjacent to Alberhill Creek will be limited to road re-surfacing and re-striping, with no additional widening. Furthermore, the road improvements will not require the removal of the overhanging willow limbs. The riparian habitat within the Project site is included in the proposed RCA Conserved Land. The Industrial (onsite) component of the Project will not indirectly impact riparian birds. The onsite portion of the Project is nearly one- quarter mile from Alberhill Creek and therefore construction and operation of the industrial facility will not have edge effects on habitat within the Creek, including from noise and lighting. Because a portion of Nichols Road to be improved is adjacent to riparian habitat that had been previously determined to be occupied by LBV, there is a potential for indirect effects due to construction noise, if LBV were to be present during construction activities. If feasible, construction activities will avoid the LBV breeding season (March MSHCP Consistency Analysis 39 15 to September 30). However, if the Nichols Road improvements adjacent to Alberhill Creek cannot avoid the LBV breeding season, then the following measures are proposed to address noise effects: · Avoidance Buffer – If Nichols Road improvements adjacent to the Alberhill Creek riparian habitat will occur during the LBV breeding season (March 15 to September 30), then applicable measures will be implemented for any work within 300 feet of the habitat to avoid indirect impacts to LBV. The measures may include the installation of sound barriers, pre-construction surveys and/or clearance surveys. The Project proponent will implement an Environmental Awareness Training program prior to the start of construction to advise workers of sensitive biological areas within Alberhill Creek adjacent to the Nichols Road. · Sound Barriers – The Project proponent may install sound barriers along Nichols Road adjacent Alberhill Creek to prevent any adverse noise effects to LBV during construction. If utilized, the sound barriers will be installed prior to any work conducted after March 15 and will remain in place until August 31, unless it is first determined through surveys that LBV are not occupying habitat in the adjacent creek. To confirm the effectiveness of the sound barriers, a qualified biological monitor will measure noise levels within the creek on the opposite side of the sound barriers from the Nichols Road. The monitor will determine the existing ambient noise level, and then whether noise levels exceed 60 dB (or the ambient noise levels) due to construction activities. For areas where pre-construction ambient noise levels exceed 60 dB, pre-construction, ambient noise measurements can be taken by a qualified entity during the full daylight period (sunrise to sunset), and subsequently, the median average ambient noise level can be used as the baseline in lieu of 60 dB. For any nighttime construction activities, the same would be done as above but with measurements taken during the full nighttime period (sunset to sunrise). If construction noise levels exceed 60 dB or the ambient noise level, whichever is greater, then the sound barrier will be adjusted, and measurements will be re- taken. If construction noise levels are determined to be under 60 dB or the ambient noise level, whichever is greater, then construction activities will continue without any additional noise monitoring. · Pre-Construction and Clearance Surveys – At least three pre-construction surveys and/or clearance surveys will be conducted for LBV in riparian habitat within Alberhill Creek that is within 300 feet of construction activities. The number of surveys will depend on when the surveys commence and whether LBV individuals are detected during the surveys. The survey visits will be conducted by a qualified biologist familiar with songs, whisper songs, calls, scolds, and plumage characteristics of adult and juvenile vireos. Surveys will be conducted between sunrise and 11:00 am. Surveys will not be conducted during periods of excessive or abnormal cold, heat, wind, rain, or other inclement weather that individually or collectively may reduce the likelihood of detection. Any detections of LBV are to be mapped with behavior tracked across MSHCP Consistency Analysis 40 detections/sightings. The qualified biologist must have experience with nesting ecology and behavior of LBV to determine pre-nesting/nesting behavior. o If construction activities within the 300-foot buffer begin prior to March 15, then weekly surveys will be conducted by a qualified biologist starting on March 15 (or on the following Monday, if the 15th occurs during a weekend) and will continue until one or more individuals are detected, or until May 1 if no LBV are detected. o If construction activities within the 300-foot buffer begin after March 15 but before May 1, then at least three weekly surveys will be conducted starting one week prior to the initiation of activities and will continue until May 1, or later to complete the minimum three surveys, unless one or more LBV individuals are detected. o If sound barriers are installed prior to the initiation of construction activities, and one or more LBV individuals are detected within the 300- foot buffer, then noise monitoring will be conducted as described in the Sound Barrier measure. If the sound barriers are demonstrated to be effective at reducing noise below the stated thresholds, then additional noise monitoring will not be required. However, the monitoring biologist will inspect the sound barriers weekly to ensure the barriers are intact and will advise the Project proponent if repairs are needed to the sound barriers. · Noise Monitoring – If sound barriers are not installed prior to the start of construction activities, then daily noise monitoring will be conducted between March 15 and September 30 if LBV are detected at any point during the pre- construction/clearance surveys. A qualified biological monitor will measure noise levels at the edge of the occupied habitat and work shall cease if, at any time, noise levels exceed 60 dB due to construction activities, or the existing ambient level if that is over 60 dB. Work will re-start if sound barriers are installed and are demonstrated to effectively reduce monitoring. If it is determined that the sound barriers are not sufficiently reducing noise levels, then the work will remain halted, and the Project proponent will contact CDFW and USFWS to discuss if other methods are available to reduce noise levels below the stated threshold. · Lighting – Any night lighting needed during construction within 300 feet of occupied vireo habitat will be down shielded or directed away from the vireo habitat to prevent the illumination of the adjacent habitat. · Dust Emissions – The Project, as a part of standard best management practices (BMPs) pursuant to South Coast Air Quality Management District Rule MSHCP Consistency Analysis 41 403, will introduce dust control measures for the duration of construction activities to minimize any dust-related effect on adjacent vireos. 5.4.4 Mitigation The Project will not impact habitat for riparian birds, including habitat with LTCV for least Bell’s vireo. Therefore, mitigation for habitat loss will not be required for riparian birds. However, the measures are included above to avoid or minimize impacts to LBV during improvements to the portion of Nichols Road that abuts the Alberhill Creek habitat. 5.5 Other Section 6.1.2 Species In addition to fairy shrimp and riparian birds described above, MSHCP Section 6.1.2 includes other plant and wildlife species. As the purpose of Section 6.1.2 is to ensure that the biological functions and values of riparian/riverine areas and vernal pools are maintained such for all Section 6.1.2 species, then other applicable species are to be addressed. The additional Section 6.1.2 wildlife addressed under the “purpose” portion of Section 6.1.2 do not have a potential to be impacted by the Project. However, the three vernal pools support the western spadefoot (Spea hammondii), which is identified as an “additional species” that would benefit from the Section 6.1.2 procedures. Although there are no species-specific mitigation requirements for the western spadefoot, the conservation of the vernal pools and the proposed vernal pool expansion will benefit the western spadefoot. The Project site contains two plant species (San Jacinto Valley crownscale and vernal barley) that are not NEPSSA or CAPSSA target species relative to the Project, but that will be impacted and should be addressed in this analysis. As is discussed above (Section 5.2) and below (Section 7.1), both plant species were detected in association with the onsite vernal pools. Vernal barley was observed in Vernal Pool 3 and San Jacinto Valley crownscale was observed in Vernal Pool 1. As discussed below, although the crownscale is a Criteria Area Plant Species, it is not a target species of the Survey Area that the Project is in, and therefore, there are no species-specific requirements for the Project pertaining to the crownscale pursuant to Section 6.3.2. However, the crownscale is a plant that MSHCP Section 6.1.2 identifies as one that is linked to the conservation of vernal pools through the MSHCP. The Project will conserve Vernal Pool 1 and therefore nearly all the crownscale population. Although the Project will not directly impact the ponding basin of Vernal Pool 1, the proposed improvements to Baker Street and the implementation of the City Maintenance Area will remove habitat within the Vernal Pool 1 watershed that supports the crownscale. The Project’s HMMP will describe proposed procedures to collect seed from crownscale plants within the affected habitat prior to site grading and disperse the seed into and around the Vernal Pool 1 ponding basin. MSHCP Consistency Analysis 42 The Project will impact vernal barley through the modification of Vernal Pool 3. The proposed expansion and conservation of Vernal Pool 3 will benefit vernal barley. The Project’s HMMP will describe procedures for collection of soil inoculum from the affected areas of Vernal Pool 3, which will be transferred to expanded portion of the vernal pool. 6.0 PROTECTION OF NARROW ENDEMIC PLANT SPECIES (SECTION 6.1.3) Volume I, Section 6.1.3 of the MSHCP requires that within identified Narrow Endemic Plant Species Survey Areas (NEPSSA), site-specific focused surveys for Narrow Endemic Plants Species will be required for all public and private projects where appropriate soils and habitat are present. The Project site occurs within the NEPSSA for the following target species: · Munz’s onion (Allium munzii) · San Diego ambrosia (Ambrosia pumila) · Slender-horned spineflower (Dodecahema leptoceras) · Many-stemmed dudleya (Dudleya multicaulis) · Spreading navarretia (Navarretia fossalis) · California Orcutt grass (Orcuttia californica) · San Miguel savory (Clinopodium chandleri) · Hammitt’s clay-cress (Sibaropsis hammittii) · Wright’s trichocoronis (Trichocoronis wrightii var. wrightii). 6.1 Methods GLA biologists performed general and focused plant surveys for the Project site in both 2020 and 2022. GLA biologists Jillian Stephens and David Moskovitz performed plant surveys for most of the onsite part of the Project on April 13, and 23, and May 5 and 20, 2020, as well as for the proposed RCA Conserved Land. In 2022, GLA biologists Jillian Stephens and Wanisa Jaikwang repeated surveys for the onsite portion, including expanded areas that were not surveyed in 2020, as well as the offsite components. The 2022 surveys were conducted on March 14, April 4 and 6, and May 3, 2022. Surveys were conducted in accordance with accepted botanical survey guidelines (CDFW 2018, CNPS 2001, Nelson 1984, USFWS 2000). As applicable, surveys were conducted at appropriate times based on precipitation and flowering periods. An aerial photograph, a soil map, and/or a topographic map were used to determine the community types and other physical features that may support sensitive and uncommon taxa or communities within the Project site. Surveys were conducted by following meandering transects within target areas of suitable habitat. All plant species encountered during the field surveys were identified and recorded following the above-referenced guidelines. Scientific nomenclature and common names used in this report follow Baldwin et al. (2012), and Munz (1974). MSHCP Consistency Analysis 43 In addition to performing focused plant surveys within the Project site, GLA reviewed species databases, including the California Natural Diversity Database (CNDDB) and the Consortium of California Herbaria, to identify prior records of Narrow Endemic Plants know from within and/or adjacent to the Project site. 6.2 Existing Conditions and Results One Narrow Endemic Plant species (San Diego ambrosia) was detected at the Project site. San Diego ambrosia was detected in several locations, including two locations in the southern end of the site (most of the plants within the Project site), one location in the central portion of the site, three small locations adjacent to Pierce Street, and one small location adjacent to Nichols Road [Exhibit 9 – Rare Plants Map]. GLA biologists estimated 9,000 plants over 0.44 acre of habitat with long-term conservation value for the species. These locations of San Diego ambrosia within the Project site have been previously documented in the public record by other botanists, including by Steve Boyd (1997), Mitch Provance (2005), and A.C. Sanders (2014 and 2015). Three other prior records of San Diego ambrosia are within the proposed RCA Conserved Land, including by F.M. Roberts (1997), D.E. Bramlet (1997), and Mitch Provance (2005). GLA surveyed the areas of these prior records but did not detect San Diego ambrosia at those locations. However, as these other locations are within the Project’s proposed Conserved Lands, these locations will be protected by the Project. Additional San Diego ambrosia known from the vicinity of the Project include one location northwest of the Project site on the northern side of Nichols Road (2011 A.C Sanders) and two locations to the southeast (2015) A.C. Sanders). Neither of these locales will be affected by the Project. Besides the San Diego ambrosia, one other Narrow Endemic Plant species (Munz’s onion) is known from the vicinity of the Project site based on prior records. Both locations are southeast of the Project site, including one record by Scott D. White (2000) and another by S. Mashayehki (2010). Neither of these locales will be affected by the Project. 6.3 Impacts The Project will directly impact San Diego ambrosia that, as noted above in Section 6.2, was detected in several locations at the Project site, including in the southern portion of the Industrial footprint (onsite) and within the proposed offsite road improvements along Pierce Street and Nichols Road. Because the Project site is within the NEPSSA for San Diego ambrosia and the species was detected, the Project is required by the MSHCP to identify habitat with long-term conservation value for the species and to avoid at least 90 percent of the habitat. GLA has identified 0.44 acre of habitat with long-term conservation value for the ambrosia within the Project footprint, all of which will be MSHCP Consistency Analysis 44 impacted by the Project. As such, a DBESP must be approved to authorize impacts to San Diego ambrosia. 6.4 Mitigation All impacts to San Diego ambrosia habitat with long-term conservation value will be mitigated within the proposed RCA Conserved Lands. To mitigate the loss of 0.44 acre of habitat with long-term conservation value for San Diego ambrosia, the Project will develop and implement a San Diego Ambrosia Translocation Plan (Ambrosia Plan). The Ambrosia Plan will identify proposed receiver sites within the Project’s Conserved Lands were ambrosia stems and soils will be translocated to. The receiver sites will be located within a minimum of 1.32 acres of contiguous degraded habitat in the Alberhill Creek floodplain to be restored by the Project [Exhibit 10 – Plant Restoration Map]. The proposed restoration area consists of an area dominated by non-native grasses and forbs where San Diego ambrosia was detected in the past (per public records), but due to overgrowth by invasive vegetation, San Diego ambrosia was not detected during plant surveys for the Project. The general components of the Ambrosia Plan will include the salvage and collection of individual ambrosia stems from the donor sites. Approximately 10-percent of the stems would be salvaged and stored at a nursery facility for propagation, to be held as a contingency source. Another 20-percent of the stems would be translocated directly to the receiver sites, where the stems will be transplanted into study plots. The remaining stems will be collected along with the soils, which will be bulk transferred to the receiver sites. The expectation is that through rhizome spread, both within the plots and between the plots, the number of stems will increase. The Ambrosia Plan will identify proposed salvage and translocation methods from the donor sites, site preparation methods of the receiver sites, plant palettes, success criteria, maintenance/long-term monitoring procedures, and contingency measures. The Ambrosia Plan will be submitted to the RCA and Wildlife Agencies for review and approval prior to implementation. GLA met with the RCA and Wildlife Agencies on September 26, 2024, to discuss the ambrosia mitigation concept. The RCA and Wildlife Agencies addressed an expectation of restoring habitat with long-term conservation value at a minimum 3:1 ratio (1.32 acres) versus the impacts (0.44 acres) and that stem counts after a minimum of five years would be three times the number of stems salvaged and translocated to the receiver site. GLA proposes to translocate the 20-percent of stems to study plots that would be distributed throughout out the receiver habitat, with soil from the remaining impacted habitat to be spread in the areas surrounding the plots. The stems (and rhizomes) salvaged as part of the 20-percent collection would be planted in the study plots with some minimum spacing (to be determined) that would allow the rhizomes to spread in multiple directions from each source “stem”, theoretically allowing the rhizomes to fill in the spaces between the translocated stems over time, which in turn would produce a proportional number of new stems. Although this would theoretically provide the space to produce at least three times the number of stems compared with what is translocated, GLA is concerned how long it would take to achieve this MSHCP Consistency Analysis 45 performance standard, and whether it is reasonable to expect that the restoration site will produce at least three times the number of translocated stems. Provided that the receiver site soils are compatible, the site is prepared properly, the plots are established as approved, the stem counts are deemed accurate prior to salvage and the salvage is performed properly, and site maintenance is deemed successful, then everything will have been done to support the translocation efforts. Furthermore, as propagation through seed is not an option, then the efforts will be limited to the stems that can be translocated. The MSHCP requirement in mitigating the impacts to habitat and species is to result in preservation that is at least biologically equivalent, if not superior, to the existing condition. The proposed restoration area of 1.32 acres would replace the impacted 0.44 acre of existing habitat at a minimum 3:1 ratio. Furthermore, the proposed 1.32 acres of habitat would consist of one larger and contiguous block of habitat, compared with 0.44 acre of existing habitat consisting of six smaller patches of habitat scattered throughout the Project site. The restoration site will be managed to minimize invasive plant species at maximum levels of percent cover to be described in the Ambrosia Plan. As noted above, the conditions will have been created with the restored receive habitat to theoretically achieve stem numbers at a ratio of 3:1 (or greater). However, if in a minimum timeframe of five years the stem numbers reach at least a 2:1 ratio versus the existing condition, then combined with a 3:1 increase in habitat with long-term conservation value, attaining stem numbers at least two times greater should be considered at least biologically equivalent (if not superior). As such, this is the minimum standard that GLA proposes. If the mitigation achieves a minimum 2:1 ratio of stems in at least five years following translocation but does not reach the 3:1 ratio expected by the RCA/Wildlife Agencies, then GLA proposes that the 10-percent stem collection that will have been propagated in a nursery, will be translocated to the mitigation site, which would further increase the population within the mitigation site. GLA recently collected soil samples from the donor and proposed receiver sites, and the soil samples were analyzed for compatibility to support the proposed translocation efforts. The locations of the soil samples are included on Exhibit 10. The Project proponent will provide the results of the soils analysis to the RCA and Wildlife Agencies as part of the review process for the Translocation Plan. 7.0 ADDITIONAL SURVEY NEEDS AND PROCEDURES (SECTION 6.3.2) Pursuant to MSHCP Volume I, Section 6.3.2, the MSHCP requires habitat assessments and focused surveys (within areas of suitable habitat) for certain species as determined by a project’s occurrence in a designated survey area, including Criteria Area Plant Species Survey Area (CAPSSA), burrowing owl survey area, amphibian survey area, and mammal survey area. MSHCP Consistency Analysis 46 7.1 Criteria Area Plant Species The Project site occurs within the CAPSSA for the following target species: · Thread-leaved brodiaea (Brodiaea filifolia) · Davidson’s saltscale (Atriplex serenana var. davidsonii) · Parish’s brittlescale (Atriplex parishii) · Smooth tarplant (Centromadia pungens spp. laevis) · Round-leaved filaree (California macrophylla) · Coulter’s goldfields (Lasthenia glabrata ssp. coulteri) · Little mousetail (Myosurus minimus ssp. apus) 7.1.1 Methods GLA biologists performed general and focused plant surveys for the Project site in both 2020 and 2022. GLA biologists Jillian Stephens and David Moskovitz performed plant surveys for most of the onsite part of the Project on April 13, and 23, and May 5 and 20, 2020, as well as for the proposed RCA Conserved Land. In 2022, GLA biologists Jillian Stephens and Wanisa Jaikwang repeated surveys for the onsite portion, including expanded areas that were not surveyed in 2020, as well as the offsite components. The 2022 surveys were conducted on March 14, April 4 and 6, and May 3, 2022. Surveys were conducted in accordance with accepted botanical survey guidelines (CDFW 2018, CNPS 2001, Nelson 1984, USFWS 2000). As applicable, surveys were conducted at appropriate times based on precipitation and flowering periods. An aerial photograph, a soil map, and/or a topographic map were used to determine the community types and other physical features that may support sensitive and uncommon taxa or communities within the Project site. Surveys were conducted by following meandering transects within target areas of suitable habitat. All plant species encountered during the field surveys were identified and recorded following the above-referenced guidelines. Scientific nomenclature and common names used in this report follow Baldwin et al. (2012), and Munz (1974). In addition to performing focused plant surveys within the Project site, GLA reviewed species databases, including the CNDDB and the Consortium of California Herbaria, to identify prior records of Criteria Area Plants know from within and/or adjacent to the Project site. 7.1.2 Existing Conditions and Results GLA biologists detected one Criteria Area Plant species (Coulter’s goldfields) that is described for the CAPSSA associated with the Project site. GLA also detected the San Jacinto Valley crownscale, which is a Criteria Area Plant species, but not one that is described for the applicable CAPSSA. However, the crownscale is associated with Vernal Pool 1, and so the crownscale is relevant to the Project pursuant to the MSHCP Riparian/Riverine and Vernal Pool Policies (Section 6.1.2). MSHCP Consistency Analysis 47 Coulter’s goldfields was detected in several locations within the Project site, including the three vernal pools as well as locations within the proposed RCA Conserved Lands nearer to Alberhill Creek. The majority of Coulter’s goldfields are associated with Vernal Pool 1 and 3 [Exhibit 9 – Rare Plants Map]. GLA biologists mapped approximately 9,000 plants and based on those detections identified approximately 2.70 acres of total habitat with long-term conservation value, the majority of which will not be directly impacted by the Project. The locations of Coulter’s goldfields within the Project site have been previously documented in the public record by other botanists, including by A.C. Sanders (2008), D.E. Bramlet, R.L. Allen and F.M. Roberts (2011), and Mitch Provance (2005 and 2017)2. As noted above, the San Jacinto Valley crownscale is associated with Vernal Pool 1. Crownscale individuals were most abundant in and around the vernal pool basin within the proposed Conservation Land, but a smaller number of individuals (approximately 10) were mapped outwards from the pool basin closer to Baker Street. These individuals occur in similar alkaline soils associated with the broader watershed of the vernal pool. GLA did not detect any other Criteria Area Plants besides Coulter’s goldfields and the San Jacinto Valley crownscale. However, the Consortium of California Herbaria has one University of California, Riverside (UCR) Herbarium record for little mousetail, which was documented by Mitch Provance in 2017. The UCR record describes mousetail occurring with other vernal pool indicator plants in a pool adjacent to Baker Street. Based on the associated species noted by the record, it was presumably associated with Vernal Pool 3, but again the presence of little mousetail was not confirmed during GLA’s plant surveys. The only other Criteria Area Plant species known from the vicinity of the Project site is round-leaved filaree. There are two records of the species located southeast of the Project site, although neither of these records are within the CAPSSA. One record is within about 150 feet of the Project site (A.C. Sanders 2011), while the second record (Mitch Provance 2017) is about 450 feet from the Project site. 7.1.3 Impacts The Project will impact Coulter’s goldfields associated with Vernal Pool 3 due to the construction and maintenance of the adjacent spreading structure. Because the Project site is within the CAPSSA for Coulter’s goldfields, the Project is required by the MSHCP to identify habitat with long-term conservation value for the species and to avoid at least 90-percent of the habitat. GLA has identified 2.70 acres of habitat with long-term conservation value for Coulter’s goldfields, including 2.61 acres associated with the three vernal pools. The proposed Project will directly impact 0.50 acre of the habitat (20 2 CCH2 Portal. 2023. https://cch2.org/portal/index.php. Accessed on 12/11/23. University of California, Riverside Herbarium Record. MSHCP Consistency Analysis 48 percent) of the habitat at the edge of Vernal Pool 3. As such, a DBESP must be approved to authorize impacts to Coulter’s goldfields. The Project will directly impact approximately 10 individuals (based on GLA’s plant surveys) of San Jacinto Valley crownscale outside of the Vernal Pool 1 ponding basin, but within the broader watershed of the pool. As noted above in Section 5.2.3, hydrologic modelling indicates an approximately 7 percent decrease in flows from the Vernal Pool 1 watershed over the 2-, 5, and 10-year rainfall events. However, when considering the nature of the existing condition, by constructing the trough system in closer proximity to the immediate vernal pool watershed, the relative amount of surface and subsurface flows reaching the pool basin is likely to increase. Therefore, what is modelled as a hydrologic decrease at Baker Street is likely to be closer to, if not slightly exceeding, the existing hydrologic condition that supports the vernal pool. As part of the Project’s mitigation activities, the hydrology of Vernal Pool 1 will be monitored post-project for at least five years to document the ponding metrics of the vernal pool compared with what was observed in 2024. Although little mousetail was not detected within any of the vernal pools during GLA’s plant surveys, based on the 2017 record of little mousetail at the property it is possible that the record is associated with Vernal Pool 3 and that the partial impacts to Vernal Pool 3 might impact little mousetail. If present, impacts would be up to 0.16 acre of habitat with long-term conservation value, as that is the acreage of the vernal pool that would be impacted by the Project. 7.1.4 Mitigation To mitigate the loss of 0.50 acre of habitat with long-term conservation value for Coulter’s goldfields, the Project will restore/expand Coulter’s goldfields habitat in two areas. The first area consists of the expansion of Vernal Pool 3 by approximately 0.75 acre [Exhibit 10 – Plant Restoration Map]. The second area consists of the expansion of another 0.75-acre area in the Alberhill Creek floodplain adjacent to an existing population of Coulter’s goldfields and vernal barley. If little mousetail presently occurs in Vernal Pool 3, then the expansion of the vernal pool would mitigate those impacts, as it would address all vernal pool flora associated with Vernal Pool. However, because there was no confirmation of little mousetail during GLA’s surveys, there will not be any performance standards specific to little mousetail, as there is no guarantee of little mousetail propagules being present in the edge portion of the vernal pool to be impacted where soil inoculum would be collected prior to impact. The Project will develop a HMMP to address the mitigation efforts. The HMMP will, at a minimum, include details about the type of mitigation, acreages, when the mitigation would be implemented, plant palettes, site preparation, weeding plan, success criteria/performance standards, monitoring plan (e.g., years/duration, frequency, etc.), reporting, the proposed management entity, and contingency measures in the event the mitigation is not successful. The type of contingency measures would depend on which success criteria/performance standards have not been met. If the mitigation areas are MSHCP Consistency Analysis 49 not meeting plant coverage and/or non-native criteria, then additional plant remediation/maintenance efforts would be implemented, and the monitoring period would be extended. The HMMP will be submitted to the RCA and Wildlife Agencies for review and approval. Although the Project is not subject to the Criteria Area Plant policies relative to the San Jacinto Valley crownscale, because the Project site is not in the CAPSSA for the crownscale the Project is subject to the Section 6.1.2 policies pertaining to vernal pools. Because the crownscale occurs within Vernal Pool 1 and its immediate watershed, impacts to the crownscale within the watershed will require mitigation. Specifically, seed will be collected from crownscale individuals prior to any disturbance of the site, and that seed will be transferred directly to Vernal Pool 1 to supplement the existing flora of the pool. This seed collection/transfer will also be addressed in the HMMP. 7.2 Amphibians The Project site is not located within an amphibian survey area. As such, focused surveys are not required for designated amphibian species and there are no other requirements applicable to the Project for amphibians. 7.3 Burrowing Owl The Project site is within the survey area for the burrowing owl (Athene cunicularia). As such, the MSHCP requires that the Project evaluate impacts to the burrowing owl through habitat assessments/focused surveys. 7.3.1 Methods Focused surveys are required to be conducted pursuant to the 2006 MSHCP Burrowing Owl Survey Instructions. The Burrowing Owl Survey Instructions are divided into three components, including Step I (habitat assessment), Step II-A (focused burrow survey), and Step II-B (focused burrowing owl survey). The guidelines stipulate four focused survey visits (Step II-B) be conducted on separate dates between March 1 and August 31. GLA initially evaluated most of the proposed development footprint for burrowing owls in 2020, including the Step I habitat assessment and preliminary burrow mapping (Step II- A). GLA biologist David Smith performed visits on April 16 and 28, 2020. The entire Project site was evaluated for burrowing owls in 2022, including approximately 75 acres of potentially suitable habitat that was subject to focused burrowing owl surveys (Step II- B). As described above in Section 2.1, the total area of proposed development is 90.94 acres, including 65.81 acres associated with the Industrial Facility (onsite), 6.11 acres of Baker Street improvements, 2.73 acres identified as the City Maintenance Area northeast of Baker Street, and Additional Street Improvements (16.29 acres). Initial transects were walked within the onsite portion of the Project and along the various offsite alignments to identify all suitable burrows. Burrows were limited to the onsite