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Appendix E-Biological Resources Part 2
APPENDIX E.2 Froom Ranch Specific Plan-2019 Rare Plant Update and Wetland Impact Analysis Memorandum This Page Intentionally Left Blank. 1 KMA KEVIN MERK ASSOCIATES, LLC P.O. BOX 318 SAN LUIS OBISPO, CA 93406 805-748-5837 Environmental Consulting Services MEMORANDUM Date: July 23, 2019 To: John Madonna Organization: JM Development Group, Inc. From: Kevin Merk Email: kmerk@kevinmerkassociates.com cc: Tim Walters, RRM Design Group Re: Froom Ranch Specific Plan–2019 Rare Plant Update and Wetland Impact Analysis At your request, Kevin Merk Associates (KMA) conducted a botanical survey on the Froom Ranch project site during the spring and early summer 2019 to update the special status plant information provided in the Biological Resources Inventory report (BRI; KMA, revised November 2018). We also reviewed the proposed Froom Creek realignment design developed by RRM Design Group to help the City of San Luis Obispo assess potential impacts to the Calle Joaquin wetland habitat that may occur post-construction. As part of the Calle Joaquin wetland impact assessment, we reviewed project plans and hydrology and sediment reports prepared by RRM Design Group (2018 and 2019), the Froom Ranch Development Groundwater Impacts Assessment (Cleath-Harris Geologists, 2018), and the Hydrologic Monitoring Plan for Sustaining a Separated Wetland Near Calle Joaquin (Balance Hydrologics, 2005) to help characterize the Calle Joaquin wetland area and identify potential impacts that may result from construction of the proposed project. This memorandum summarizes the results of the botanical surveys conducted in 2019, and provides our assessment of potential affects to the Calle Joaquin wetland area from construction of the proposed project and realignment of Froom Creek. 2019 Botanical Survey Update KMA conducted a series of surveys during the spring and early summer of 2019 to provide an updated assessment of special status plant distribution within the Froom Ranch study area compared to those surveys conducted in 2015. The results of the 2015 surveys were reported in the BRI and occurrence data illustrat ed on Figure 7 , the Special Status Plant Occurrences Map. Methods of the botanical survey followed those described in the BRI, which included the site being walked using meandering transects to identify all species observed to the level necessary to determine rarity. When rare plant occurrences were encountered, the boundaries of the occurrence were identified and the limits were delineated using a Trimble GeoXH 6000 GPS unit. The GPS data were imported into ARC GIS software and Figure 7A was prepared to show the special status plant observations on the site in 2019 in relation to those occurrences observed in 2015 (see attached). The surveys covered the entire study area, including the Basin Study Area on the Mountainbrook Church property. Surveys occurred on April 27, May 4, May 7, and June 6, 2019. A follow up survey was Froom Ranch Specific Plan Project 2019 Rare Plant Update and Calle Joaquin Wetland Impacts Analysis 2 conducted on June 25, 2019 to evaluate Chorro Creek bog thistle (Cirsium fontinale var. obispoense) occurrences previously mapped onsite. Of importance, a newly described species, the Irish Hills spineflower (Chorizanthe aphanantha), was observed and reported from higher elevations in the neighboring Irish Hills Natural Reserve since the 2015 surveys were conducted on the subject site. Two species of spineflower, Palmer’s spineflower (Chorizanthe palmeri) and Brewer’s spineflower (C. breweri), were observed in the study area during the 2015 surveys, and the 2019 survey effort also determined if Irish Hills spineflower was present onsite. As part of this survey effort, several known occurrences of Irish Hills spineflower on the City of San Luis Obispo’s Waddell property were visited to review key identification features and habitat elements where occurrences of this species were documented. Irish Hills spineflower was not observed on the Froom Ranch study area in 2019, nor was it observed on the portion of Irish Hills Natural Reserve immediately adjacent to the site. Overall, species observations made in 2019 were consistent with those reported in the BRI, and special status plants identified onsite were in the same general locations as shown on Figure 7 in that report. Please refer to the attached Figure 7A for a comparison of the 2015 and 2019 survey data. No CRPR 1B species were observed in the Basin Study Area. Given the above average rainfall experienced during the 2018/2019 rain season, the non-serpentine endemic San Luis Obispo owl’s clover (Castilleja densiflora ssp. obispoensis) was observed covering much larger areas of the grassland habitat on the upper terrace in the southwest part of the site compared to the 2015 observations. Serpentine endemic species that were observed on rock outcroppings and thin soiled areas in 2015, such as Brewer’s spineflower, San Luis Obispo serpentine dudleya (Dudleya abramsii ssp. murina), and Jones’ layia (Layia jonesii), were observed in the same general locations without much expansion or contraction. A previously documented occurrence of Congdon’s tarplant (Centromadia parryi ssp. congdonii) growing in the Home Depot temporary basin was reduced in size as the basin had been removed since the 2015 surveys. Still, two patches of Congdon’s tarplant were observed persisting in this area. The small occurrence of chaparral ragwort (Senecio aphanactis) observed on a serpentine rock outcrop in 2015 was not relocated in 2019. Two species not observed in 2015 were identified on the steep upper slopes within the study area during the survey update, and included adobe yampah (Perideridia pringlei; CRPR 4.3) and most beautiful jewel flower (Streptanthus albidus ssp. peramoenus; CRPR 1B.2). Adobe yampah is on a watch list, and is not very rare or threatened in the project area. It was observed in steeper rocky areas co-mingling with previously mapped CRPR 1B species in the upper southwest corner of the site outside the proposed development footprint. The most beautiful jewelflower is a rare species that is moderately threatened throughout its range. This species was observed in a small grassy opening on a steep rocky slope above a large larkspur (Delphinium parryi ssp. eastwoodiae) patch where the grassland segues into coastal scrub/chaparral in the southwest portion of the site (see Figure 7A). The occurrences are outside any proposed development. Searches of the neighboring Irish Hills Natural Reserve outside the project study area located numerous occurrences of both species, as well as the other serpentine endemics observed on the Froom Ranch. Chorro creek bog thistle occurrences mapped in 2015 were also revisited. 2019 survey effort confirmed Chorro Creek bog thistle plants were still present along the upper reach of Drainage 1 and at a seep in Drainage 2. The occurrence at the seep in Drainage 2 had expanded slightly as compared to the observations made in 2015, but the Drainage 1 occurrences were still confined to the channel. Calle Joaquin Wetland Impact Assessment The proposed Froom Creek realignment would route the new channel in an easterly direction towards Los Osos Valley Road (LOVR). The creek bottom would generally be on the existing grade and the site would be built up around it using fill material to raise the site out of the current FEMA floodplain. A low Froom Ranch Specific Plan Project 2019 Rare Plant Update and Calle Joaquin Wetland Impacts Analysis 3 flow channel would be created during the realignment process and top-dressed with the select placement of cobble, rock and boulders salvaged from the old creek alignment. Near LOVR, the channel would arc to the south and parallel LOVR until it reaches the north end of the Calle Joaquin wetland area. The turn of the creek at LOVR would require bank armoring, and the LOVR stormwater ditch would also join the creek in this location. Once the creek channel is in the vicinity of the Calle Joaquin wetland, the eastern fill slope constructed to separate the channel from LOVR would flatten out and the low flow channel would continue along the toe of the western fill slope. In this area, the creek would open up into a wide floodplain area that is the Calle Joaquin wetland. The low flow channel would be designed to handle normal flow events, but it is envisioned that any larger flow event (i.e., greater than the 2-year storm) would be allowed to spread laterally, ultimately flooding the vegetated wetland area. The upland area to the southeast of the wetland would be graded during the creation of the low flow channel to create the connection to the Froom Creek channel at the Mountainbrook Church property line. Based on discussions with RRM Design Group, flowing water in the creek would be moving very slowly, estimated at less than one foot per second, by the time it parallels LOVR and is in proximity to the Calle Joaquin wetland area. Surface water associated with large storm events would gradually fill up the Calle Joaquin wetland area with a depth of approximately three to four feet. Water would continue to flow in a southeasterly direction towards the connection with the creek channel at the Mountainbrook Church property line. The erosive flow velocity and sediment/bed load transport would not be present in this area, and flows would not be expected to erode the densely vegetated wetland zone. By the time any flowing water within the creek would reach the Calle Joaquin wetland, it will have slowed substantially and sediment dropped out in the upper reach since the new channel will be much wider than the current alignment and include vegetation, cobble, gravel, and boulders. Concerns were raised by the EIR consultant about the southerly topographic aspect present where the realigned Froom Creek will interface with the Calle Joaquin wetland. A potential impact was identified that the low flow channel could erode and then migrate towards the topographic low area immediately adjacent to Calle Joaquin that currently supports perennial surface water and a patch of tules. While channel migration may be possible, this area is in fact quite flat with only minor change from the proposed low flow channel to the toe of fill slope associated with Calle Joaquin. The cross section provided as Figure 3.7 in the RRM Hydrology Report is shown at an exaggerated scale for clarity and graphically may appear that the change in topography from the proposed low flow channel to the topographic low point at the base of the Calle Joaquin road prism is more severe than the actual gentle slope. It would seem that with the estimated flow velocity reported in the RRM hydrology and sediment studies that surface water will gradually fill the low flow channel, overtop the small southern bank defining the low flow channel and then gradually fill the flat wetland area. The non-erosive nature of the flow, estimated at 0.7 foot per second, would not be expected to strip the densely rooted wetland vegetation or erode the small southern bank. Once the high water recedes, flows would reduce and then again be contained in the low flow channel. It is also possible that a more braided channel could form through this flat zone overtime. The densely rooted, rhizomatous wetland vegetation characteristic of the area would prevent erosion given this part of the site is so flat and flows would be slow. Select planting of willows and use of appropriate biotechnical erosion controls at the creek-wetland interface would also be used to further minimize the erosion potential and promote proper drainage and maintenance of the low flow channel. As relayed to KMA by RRM Design Group’s engineering team, the lengthening and widening of the Froom Creek channel compared to its existing morphology will reduce flow velocity and subsequent erosion potential for the lower flatter reach of the realigned creek. Select bank armoring and use of vegetation, native cobble and boulders in the channel will reduce the erosion potential through the parts of the creek that may experience swifter flowing water. The low flow channel in the Calle Joaquin wetland area interface would be a shallow swale-like feature excavated upwards of two feet in depth. The densely rooted wetland vegetation in this area along with grassy species composition should be maintained Froom Ranch Specific Plan Project 2019 Rare Plant Update and Calle Joaquin Wetland Impacts Analysis 4 overtime with a similar herbaceous vegetation layer due to shallow groundwater. The constructed low flow channel would be seeded and planted with native vegetation, but it is likely that the wetland plants will recolonize the area due to the prolonged saturated conditions from shallow groundwater. Even if deposition of sediment was to occur when the Calle Joaquin wetland area is submerged, the wetland and riparian plant composition would be expected to regrow through the sediment layer. The planting of riparian trees and shrubs on the banks and buffer areas, and the removal of grazing from the site will also increase the vegetation structure throughout the Calle Joaquin wetland area, and trees and shrubs like willows and cottonwoods are expected to colonize the wetland zone. The project proposes to have stormwater that was directed to the Irish Hills Plaza basin now enter the site in an open channel feature that will treat and direct the water to the extension of the LOVR ditch and then connect to the new Froom Creek channel. It is highly likely that wetland habitat will be created in this channel up to its connection with the LOVR ditch given the amount of stormwater that would be going to this feature compared to the Irish Hills Plaza basin. As proposed, the stormwater drainage features would be planted with a mix of wetland and riparian plants to create a natural looking riparian corridor with wetland habitat to be established in portions of the channel bed with prolonged saturation. Froom Creek in its current alignment on the property contains flowing water for a short period of time, and does not contain areas of prolonged standing water or saturated soils sufficient for wetland plant growth. It is incised with steep banks and no significant vegetation structure such as trees or shrubs is present. The increased water input to the realigned Froom Creek channel from the Irish Hills Plaza and closer proximity to groundwater will likely be expressed by an increase in wetland vegetation throughout the new channel bottom, especially along LOVR near the Calle Joaquin wetland where groundwater is near the surface. The proximity to shallow groundwater in concert with seasonal flow in Froom Creek coupled with stormwater from the Irish Hills Plaza and onsite development are expected to expand the areas of wetland habitat throughout the onsite drainage features providing a substantial increase in wetland surface area and resulting functions and values post construction. As detailed in the Cleath-Harris report and Balance Hydrologics study, groundwater upward leakage is the primary hydrologic influence supporting wetland habitat in the Calle Joaquin area. The perimeter French drain surrounding the Irish Hills Plaza basin is apparently capturing subsurface flow and directing it around the basin to the discharge ditch (refer to Figure 1 in the Cleath-Harris Geologists 2018 report). Stormwater drainage out of the basin is also contributing to the wetland hydrology as it is directed to this same ditch which drains toward the LOVR and Calle Joaquin intersection. Water has been observed flowing out of the pipe into this ditch, even during the prolonged drought when water was not present in the basin. The steady flow of water at the ditch downstream of the Irish Hills Plaza basin during the summer months indicates groundwater is consistently present in this area. The artesian well in the isolated wetland to the south side of Calle Joaquin also confirms that groundwater pressure is significant in this part of the site, and shows that the wetland area is expected to persist even with the relocation of stormwater discharge from the Irish Hills Plaza basin to the proposed drainage feature adjacent to the Irish Hills Plaza. Wetland habitat was present in this part of the site prior to the construction of the Irish Hills Plaza basin, and it is reasonable to expect it to persist with its removal. Conclusions in the Cleath-Harris report state that the proposed project is not expected to significantly impact groundwater, and that groundwater levels in the project area may rise if the detention basin drains are removed along with the basins. Rising groundwater would increase wetland habitat, consistent with the project goal of increasing wetland and riparian habitat onsite. With the proposed creek realignment, the longer reach and flatter grade of the realigned stream channel would allow for a greater surface area and longer duration of wetted stream channel, increasing groundwater recharge when stream flow occurs. Froom Ranch Specific Plan Project 2019 Rare Plant Update and Calle Joaquin Wetland Impacts Analysis 5 Based on this analysis, no adverse impacts to wetland habitat are expected to occur from the creek realignment and removal of the Irish Hills Plaza basin. Allowing periodic high flows in the creek to spread over the large flat wetland area would not be expected to have the channel migrate substantially or affect the overall integrity of the wetland area. The area is very flat with a minor taper to Calle Joaquin and is densely vegetated with wetland plants. The area would flood periodically and wetland habitat will be maintained post construction by these periodic flows and shallow groundwater. Seasonal flows in Froom Creek and stormwater from the project site and Irish Hills Plaza will continue to be directed to this general area, which is more or less consistent with the current hydrologic condition. Even if the low flow channel braids or migrates into the center of the Calle Joaquin wetland, a dynamic equilibrium will be found in the area and any wetland vegetation that could be temporarily displaced by open water would be expected to re-establish once flows subside. Wetland vegetation cover on the site would also be expanded in other areas such as the stormwater drainage features constructed next to the Irish Hills Plaza and in the new Froom Creek channel. Wetland species present onsite and proposed for use in the habitat restoration efforts are adapted to drought, and would be expected to persist during periods of prolonged drought, which are anticipated to occur in the future. The goal of the creek realignment effort will be to minimize impacts to the existing wetland habitat during construction, and maintain sufficient post construction hydrology to emulate the current condition . Consistent with the Cleath-Ha rris 2018 report, the current distribution of wetland habitat at Calle Joaquin is primarily supported by groundwater with secondary support from seasonal flows in the LOVR ditch and Irish Hills Plaza drainage, and Froom Creek. Clearly, Froom Creek has not reached overbank conditions in a number of years, and the overbank location identified in past studies is no longer present. Cleath’s characterization of the Froom Ranch valley floor area is that it has shallow groundwater and during the most recent drought period, groundwater levels remained in close proximity to the surface over most of the site. The realigned creek is anticipated to increase the period of time during the winter when standing water is present along LOVR and in the Calle Joaquin wetland area, which will increase habitat area for aquatic species. In addition, groundwater levels are likely to be higher for a longer period of time after the rainy season due to the flatter groundwater gradient resulting from the realigned creek channel morphology and removal of the basin (Cleath-Harris Geologists, 2018). For the Clean Water Act and California Fish and Game Code permitting effort that will be required for the realignment effort, a detailed Habitat Mitigation and Monitoring Plan (HMMP) will be prepared for the final project design. The HMMP will identify the site preparation and planting activities, monitoring requirements and adaptive management strategies to be employed in order to meet final success criteria that will include a stable channel with an overall increase in wetland area, functions and values. The final creek geometry and mitigation and monitoring requirements will be developed in collaboration with the U.S. Army Corps of Engineers, Regional Water Quality Control Board and California Department of Fish and Wildlife through their review and issuance of their respective permits. The U.S. Fish and Wildlife Services and NOAA Marine Fisheries Service will also be involved in the final design. The overarching concept for the Froom Ranch creek realignment project is that the creek corridor will be a native, self-sustaining riverine system with a mix of woody riparian and herbaceous wetland plant assemblages. By having a wide corridor for the realigned Froom Creek channel, a dynamic equilibrium will be met within the confines of the fill slopes. The use of native vegetation, cobbles and boulders along with a suite of biotechnical erosion controls and rigorous monitoring and adaptive management program will ensure the realigned creek is of better function and value than currently exists in its present location. The stormwater drainage features and realigned Froom Creek will be managed to achieve the desired outcome of having a natural creek system that has enough space to be dynamic while increasing the extent of wetland and riparian habitat onsite, protecting property and structures from flooding, and enhancing the human interface and connection with the natural environment. JM Development Group, Inc.2019 Special Status Plant Occurrences Map Froom Ranch Figure 7A!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!(!( Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community .0 250 500125Feet 1 inch = 350 feet Mountainbrook Church Irish Hills Natural Reserve Irish Hills Plaza Basin Study Area Froom Ranch Study Area Boundary 2019 CRPR 1B Observations Occurrence Area !(Individual Occurrence 2016 Chorro Creek Bog Thistle Occurrence 2016 CDFW List 1B Species Occurrence Ca de ob = Castilleja densiflora ssp. obispoensis Ca ob = Calochortus obispoensis Ce pa co = Centromadia parryi ssp. congdonii Ch br = Chorizanthe breweri De pa ea = Delphinium parryi ssp. eastwoodiae Du ab mu = Dudleya abramsii ssp. murina Du bl = Dudleya blochmaniae La jo = Layia jonesii Se ap = Senecio aphanactis St al pe = Streptanthus albidus ssp. peramoenus Ca de ob Ca de ob Ca de ob Ca de ob Ca de ob Ca de ob Ca de obDe pa ea Ch br De pa eaSt al pe Ca de ob De pa ea Ca de ob Ca de ob Ca de ob Ca de ob Ca de ob Ca de obCa obCa de ob Ca de ob La jo Du bl Du ab muSe ap Ci fo ob Du ab mu Du bl Ch br Du bl Ca de ob Du ab muCh brLa joCa de ob Du ab mu De pa eaCa de obLa jo La jo Ca de ob Ca de ob Ch br Ce pa co La jo De pa eaLa jo Ca de ob Ca de ob Du ab mu Du bl Ca de ob Ci fo ob = Cirsium fontinale var. obispoense Ce pa co Du blLa jo La jo La jo 3-11 Section C: Section C is intended to represent a typical cross section where Froom Creek is proposed adjacent to the existing wetlands. The Channel Bottom is proposed to be configured so that the creek overbank will flow into the adjacent existing wetlands during storm larger than 2-year events. Figure 3.7: Section C 3.8 Conclusion The Froom Creek Restoration program, as proposed, conforms to guidelines for creek design and planting as outlined by the City of San Luis Obispo’s Waterway Management Plan and the California Salmonid Stream Habitat Restoration Manual. The restored lower reach of the Froom Creek corridor will protect and enhance creek, riparian, fish, and wetland habitats in the Froom Ranch Specific Plan area. Figure 1 Location Map Froom Ranch Cleath-Harris Geologists Wells and Borings Cross Section Lines Specific Plan Area Detention Basin Drains Wetlands Pit with Water Level (9/20/18) Explanation 0 250 500 750 ft A' B' A B Los O so s Va l ley RoadCalle JoaquinHwy. 101Ranch Headquarters Prefumo CreekFroom Creek Forebay Basin Vineyard Church Property Detention Basin APPENDIX E.3 Site Assessment for the California Red-Legged Frog This Page Intentionally Left Blank. FROOM RANCH SPECIFIC PLAN PROJECT (APNs 067-241-030, 067-241-031) SAN LUIS OBISPO, CALIFORNIA SITE ASSESSMENT for the CALIFORNIA RED-LEGGED FROG (Rana draytonii) Prepared for: Mr. John Madonna JM Development Group, Inc. P.O. Box 5310 San Luis Obispo, California 93403 Prepared by: Kevin Merk Associates, LLC P.O. Box 318 San Luis Obispo, California 93406 December 18, 2017 KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. i TABLE OF CONTENTS Page 1.0 INTRODUCTION .............................................................................................................................................................. 1 1.1 Site Location and Description ....................................................................................................................... 1 1.2 Proposed Project Description ....................................................................................................................... 4 2.0 METHODS .......................................................................................................................................................................... 4 2.1 Background Research ...................................................................................................................................... 4 2.2 Site Assessment Surveys ................................................................................................................................. 4 2.3 Qualifications of Surveyor .............................................................................................................................. 5 3.0 RESULTS ............................................................................................................................................................................ 5 3.1 Known Occurrences of California Red-legged Frogs in Region ..................................................... 5 3.2 Habitat Characterization of the Study Area ............................................................................................ 7 3.2.1 Froom Ranch ............................................................................................................................................ 7 3.2.2 Areas Within One Mile of the Property ..................................................................................... 10 3.2.3 Critical Habitat Designation ........................................................................................................... 12 4.0 CONCLUSION ................................................................................................................................................................ 12 5.0 REFERENCES ................................................................................................................................................................ 13 LIST OF FIGURES Figure 1 – Site Location Map ................................................................................................................................................. 2 Figure 2 – Aerial Overview Map .......................................................................................................................................... 3 Figure 3 - CNDDB CRLF Occurrence Map ....................................................................................................................... 6 Figure 4 – Land Cover/Existing Conditions Map ...................................................................................................... 11 APPENDICES Appendix A – Site Assessment Data Sheets Appendix B – Photo Plate Appendix C – Habitat Map from Biological Resources Inventory Appendix D – Wetland Delineation Map with Photo Point Locations KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 1 1.0 INTRODUCTION Kevin Merk Associates, LLC (KMA) conducted a California red-legged frog (Rana draytonii; CRLF) site assessment for the Froom Ranch Specific Plan project located just outside the current southwest city limits of the City of San Luis Obispo. The investigation covered the Froom Ranch (APNs 067-241-030, 067-241-031), and a small portion of property owned by the Mountainbrook Church, which generally includes areas at the southwest side of Los Osos Valley Road (LOVR) and north of Calle Joaquin, in San Luis Obispo County, California. This assessment followed the U.S. Fish and Wildlife Service (USFWS) Revised Guidance on Site Assessments and Field Surveys for the California Red-legged Frog (USFWS 2005), and is a compilation of information received from regulatory agencies, literature reviews, and field work on the study area conducted by KMA over a two year period. A Biological Resources Inventory Report (BRI) prepared by KMA in January 2016 for the project provides background information referenced herein including a characterization of existing conditions, plant community mapping, and results of floristic and tree inventories. A special status species evaluation was also included in the BRI, and special status wildlife that could potentially occur onsite were identified based on a habitat suitability analysis. The BRI concluded that Froom Creek and the tributary drainage onsite do not appear to support suitable aquatic habitat with a sufficient hydroperiod for CRLF breeding, but that this species could potentially move onto the site from known occurrences in the region during periods of above average rainfall when seasonal aquatic habitat persists into the summer and fall months. As part of the ongoing regulatory agency consultation process, the USFWS in an August 14, 2017 letter from Ms. Julie Vanderwier to Ms. Shawna Scott with the City of San Luis Obispo’s Community Development Department, requested that a Site Assessment for CRLF be completed for the property. The purpose of the Site Assessment is to determine whether suitable aquatic habitat capable of supporting the federal threatened CRLF is present onsite, and if protocol-level surveys are warranted to accurately determine presence or absence to support the proposed project’s environmental review process. The following report details the methods and results of the site assessment, and is intended to build on the information contained in the BRI for the USFWS to make a determination if additional surveys are warranted. 1.1 Site Location and Description The Froom Ranch Specific Plan Area consists of two parcels located at 12165 and 12393 Froom Ranch Way, totaling approximately 111 acres (APN 067-241-030 and 067-241-031) currently within unincorporated San Luis Obispo County adjacent to City of San Luis Obispo city limits (please refer to Figures 1 and 2). It also includes a southern “spur” where a flood control basin would be constructed on neighboring property owned by the Mountainbrook Church. The site is located immediately west of Los Osos Valley Road between Highway 101 and the Irish Hills Plaza. It is currently a working cattle/horse ranch that supports a variety of habitat types including: grasslands (both native bunchgrass and non-native annual), oak woodland (with California bay trees), coastal scrub/chaparral, serpentine outcrops, and seasonal and perennial wetlands that are primarily associated with drainage features. Ruderal or disturbed areas are also present and consist of existing developed areas as well as constructed stormwater basins that are part of the Irish Hills Plaza development. Froom Creek, which flows to San Luis Obispo Creek via a culvert under Calle Joaquin and Highway 101, and three unnamed tributary drainages are also present onsite. Site Location ^_ ²1 in = 10,000 ft 0 1 20.5 Miles Figure 1 Site Location Site Location ^_ 1 in = 1,000,000 ft JM Development Group, Inc. Froom Ranch Source: ESRI 2017 £¤101 L o s O s o s V a l l e y R o a d Prefumo Creek San Luis Obispo Creek Froom Creek Laguna Lake ²1 in = 2,000 ft 0 1,300 2,600650Feet Figure 2 Aerial Overview JM Development Group, Inc. Froom Ranch Approximate Study Area Boundary National Wetland Inventory (USFWS) Estuarine and Marine Deepwater Estuarine and Marine Wetland Freshwater Emergent Wetland Freshwater Forested/Shrub Wetland Freshwater Pond Lake Other Riverine KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 4 The region is characterized by a Mediterranean climate, with cool, moist winters and warm, dry summers moderated by the close proximity to the Pacific Ocean. Average annual precipitation in the region of the site is approximately 22 inches, most of which falls between November and April. On-site elevations range from approximately 110 feet above mean sea level (MSL) at the lowest point near the intersection of Calle Joaquin and LOVR, to approximately 410 feet MSL on the upper western hillslopes adjacent to the Irish Hills Natural Reserve. Soils are primarily Cropley clay in the lower elevations of the site, with large areas of serpentine outcrops and serpentine influenced soils present in the higher elevations of the property to the west. 1.2 Proposed Project Description The proposed Froom Ranch development is envisioned as a residential project with some commercial development in the northeast corner of the site closest to the adjacent Irish Hills Plaza. Permanent open space is proposed to occupy about 51% of the Froom Ranch site. The project is divided into two main components: The Madonna Froom Ranch and The Life Plan Community (also known as the Villaggio). The Madonna Froom Ranch would be situated in the northern portion of the Specific Plan Area, just south of the Irish Hills Plaza. It will contain a mix of commercial and residential land uses, and include a hotel and trailhead park. The park will provide a staging area and connection to open space trails within the City’s Irish Hills Natural Reserve. The Villaggio project would provide a variety of different unit types for independent senior housing and include access to assisted living, memory care, and skilled nursing. A recreational facility, restaurants, and movie theater are also planned in this community. For a detailed project description, please refer to the Froom Ranch Specific Plan prepared by RRM Design Group. 2.0 METHODS 2.1 Background Information The study area for this CRLF Site Assessment included the approximately 111-acre Froom Ranch property, and an additional plus or minus 15 acres on the adjacent Mountain Brook Church where a future storm water detention basin would be constructed. Aquatic habitat features within a one- mile radius of the property were also included and generally evaluated in the assessment. As part of the BRI, KMA biologists reviewed site-specific aerial photographs and maps from studies in the region (Google Earth and ESRI, the U.S. Geological Survey San Luis Obispo and Pismo 7.5-minute quadrangles, and the City of San Luis Obispo Irish Hills Natural Area Conservation Plan Update from 2011). The California Department of Fish and Wildlife Natural Diversity Data Base (CNDDB; 2017) was queried for CRLF records within five miles of the site, with increased focus within a one- mile (1.6-kilometer) radius of the site. Museum records (Santa Barbara Museum of Natural History, California Polytechnic State University San Luis Obispo, and University of California at Berkley) were also searched online, and other available biological reports from studies conducted in the region such as the LOVR and Highway 101 Interchange project were reviewed. Please refer to the literature cited in the BRI for further detail. In addition, City of San Luis Obispo Natural Resources Manager, Robert Hill, and Biologist, Freddy Otte, were consulted regarding ongoing herpetological field work on the Waddell property located in the headwaters of Froom Creek to the south of the study area. 2.2 Site Assessment Surveys KMA conducted extensive field work on the Froom Ranch over a two year period that spanned from 2015 to 2017. All drainage features onsite were walked on numerous occassions and areas of KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 5 instream seasonally ponded of flowing water were assessed and mapped to aid in determining the site’s potential to support CRLF and other special status aquatic species. Aquatic habitats encountered on the property were characterized (water body type, estimated persistence of water, vegetation, water depth, bank full depth, stream gradient, substrate, and description of banks) as indicated in the protocol site assessment datasheet. Potentially suitable areas were examined for presence of American bullfrogs (Lithobates catesbeianus) and other aquatic predators such as crayfish (likely the genus Pacifastacus). For the BRI, vegetation communities were mapped following the Sawyer, Keeler-Wolf and Evens (2009) habitat classification system in association with Holland’s 1986 classification system. As part of the CRLF site assessment, habitats/vegetation communities within the one-mile radius around the study area were characterized using aerial photographs, topographic maps, and visual surveys conducted from public roads and public open space areas. Aquatic habitats, land uses, and any potential barriers to CRLF movement were noted. 2.3 Qualifications of Surveyor Kevin Merk conducted the site assessment with support from other KMA biologists, and was the primary author of this report. He has hundreds of hours conducting site assessments and protocol level surveys over the last 25 years, and is able to identify all life stages of CRLF. Mr. Merk has also been authorized by the USFWS under Section 7 of the Endangered Species Act (via specific biological opinions) to capture and handle CRLF for various construction/development projects in the Central Coast region of California. 3.0 RESULTS 3.1 Known Occurrences of California Red-legged Frogs in the Region The study area is within the historic range of the CRLF (Jennings and Hayes 1994, Stebbins 2003), but is located outside USFWS designated CRLF critical habitat. Critical Habitat Unit SLO-3 is located to the north of the site (USFWS Critical Habitat Mapper, 2017). Please refer to Figure 3, the CRLF Occurrence Map for CNDDB records in the project area as well as the location of critical habitat. The results of the CNDDB query and consultation with the City of San Luis Obispo revealed one CRLF occurrence within one (1) mile (1.6-kilometer) of the property. This record is dated 2006, and documents one CRLF observed within the City of San Luis Obispo’s wastewater treatment pond located on the east side of the Highway 101 corridor (Occurrence No. 895). The next closest record is from 2017 biological surveys on the City of San Luis Obispo’s recently aquired Waddel property. The observation location is approximately 2.3 miles to the west of the study area boundaries within the upper Froom Creek watershed. Other documented occurrences in the project region are on the southern flank of the Santa Lucia Mountains from 1939 in Brizzolari Creek, approximately 3.8 miles to the north of the property (Occurrence No. 1341), and from 1998 at the Avila Beach Golf Resort, approximately 4.6 miles to the south (Occurrence No. 303). Please refer to Figure 3 for the locations of these and other occurrences within one and five mile radii of the site. CRLF Occurrence #895, 2006 Lopez MountainSan Luis ObispoMorro Bay South North East Arroyo GrandePismo BeachPort San Luis Occurrence #258 Occurrence #453, 2008 Occurrence #1065, 1998 Occurrence #156, 1995 Occurrence #245, 1996 Occurrence #157, 1995 Occurrence #303, 1998 Occurrence #1341, 1939 Approximate location where2 adult and 4 juvenile CRLFwere observed in upper FroomCreek on Waddell property.(City of San Luis Obispo, 2017) ²1 in = 8,000 ft 0 1.5 30.75 Miles Figure 3 Regional Location/CRLF Occurrence JM Development Group, Inc. Froom Ranch Approximate Study Area Boundary CNDDB California Red-Legged Frog Occurrence California Red-Legged Frog Critical Habitat (Unit SLO-3) Study Area One Mile Buffer Additional Five Mile Buffer Source: ESRI 2017, CNDDB 2017 KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 7 3.2 Habitat Characterization of the Study Area 3.2.1 Froom Ranch The Froom Ranch consists primarily of grassland habitat with serpentine-based soils and rock outcrops present in the higher elevation areas. The property is situated on the northeastern flank of the Irish Hills, with developed urban areas on the north, east and south boundaries. To the west is undeveloped open space in the City’s Irish Hills Natural Reserve. Seasonal drainage features present include Froom Creek and three small tributary drainages, and the LOVR roadside ditch. The site contains the Irish Hills Plaza Storm Water Basin that handles surface runoff from neighboring development to the north. The basin is located in upland areas between the Froom Creek channel and Los Osos Valley Road, and a small ditch directs drainage water when present into the LOVR roadside ditch, which terminates into the Calle Joaquin wetland further south. As detailed in the BRI, the dominant habitat types observed within the study area included annual (non-native) grassland, serpentine bunchgrass grassland on the higher elevation hillsides, coastal scrub/chaparral on steeper rocky slopes, coast live oak woodland on north facing slopes and along drainages, arroyo willow riparian scrub along the LOVR ditch, and developed/disturbed areas primarily in the northern part of the property. Areas of non-native tree plantings, including blue gum eucalyptus (Eucalyptus globulus) and pepper trees (Schinus molle) are also present. Site assessment data sheets were prepared for the Froom Ranch property to characterize potentially suitable habitat areas (please refer to Appendix A). Photographs of the potential habitat areas described herein are provided in the Photo Plate included as Appendix B. The Habitat Map from the BRI is included as Appendix C, and the Wetland Delineation Overview Map (KMA, 2015) is included as Appendix D to help identify location of drainage features, as well as photo point locations. The following provides a summary and brief characterization of the areas that were the focus of the assessment. Froom Creek, an episodic drainage feature, traverses the site generally from north to south, and ultimately passes beneath Calle Joaquin and Highway 101 through a concrete box culvert (over 300 linear feet) before joining San Luis Obispo Creek to the south. The section of Froom Creek within the site is sparsely vegetated, and was composed of a dry cobble bed with bare soil banks and patchy occurrences of grassland species. It was completely dry during the 2015 and 2016 surveys. Flowing water was present in January 2017 following a series of large storm events, and then flow subsided and dried by March into April 2017. No willows or other riparian vegetation is present within this portion of the channel, but a small area (less than 12 inches deep) of instream ponding was observed near the Froom Ranch property southern line near the Drainage 1 confluence. Due to the lack of persistent water (i.e., it did not have any water with a depth of 24 inches for longer than 10 weeks) and any vegetative cover, it does not appear to provide suitable habitat for CRLF. Three ephemeral tributary drainage features are present in the southern portion of the study area that are hydrologically connected to Froom Creek. Small areas of ponded water with adjacent wetland vegetation were observed in the lower reach of the southernmost tributary drainage (Drainage 1 near the confluence with Drainage 2). At this location, a narrow in-channel, seasonal ponded area was observed that appears to be supported by springs or seeps originating on adjacent hillsides. The ponded area consisted of two connected pools less than 16 inches in depth, and covered a total area of approximately 150 square feet (6 feet wide by approximately 25 feet long). The canopy cover was high and consisted of large coast live oak (Quercus agrifolia) and California bay (Umbellularia californica) trees, with no low overhanging willows or emergent vegetation KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 8 present. Ponded areas were dominated by bare mud/silt and rock, with vegetated areas perched in the flatter area beyond the Drainage 1 top of bank along the lower reach of Drainage 2. Wetland vegetation observed in this flat area included spike-rush (Eleocharis macrostachya), tall flatsedge (Cyperus eragrostis), seep monkeyflower (Mimulus guttatus), water parsley (Oenanthe sarmentosa), rabbitsfoot grass (Polypogon monspeliensis), and Bermuda grass (Cynodon dactylon). Some common duckweed (Lemna minor) was present in the Drainage 1 channel below ponded areas. The ponded areas at bank full conditions could be as much as six (6) feet deep, but this condition would be unlikely due to the small watershed feeding the tributary, and steep nature of this feature leading towards Froom Creek. Due to the presence of shallow ponding, and limited water duration through early summer months, the ponded areas identified along Drainage 1 are considered to provide low to marginal quality habitat for CRLF. The shallow depth of the instream ponding and lack of emergent vegetation would not be expected to provide suitable refuge habitat for CRLF, and any individuals that potentially found this site, would likely be subject to predation since racoon (Procyon lotor) tracks were regularly observed in this area. If the site was close to a more permanent water body that provided potential breeding habitat, the surrounding oak woodland and bay tree habitats could provide refugia for estivation during the summer but that is highly unlikely given the limited aquatic resources on the site. While not completely isolated from San Luis Obispo Creek where CRLF were observed previously, individuals would have to traverse the over 300 foot long concrete culvert and move up the dry cobble Froom Creek channel to find seasonal water at this location. If a breeding population was near by, Drainage 1 could possibly be used by frogs during dispersal, but no suitable habitat for this species is present to the west, making it unlikely that CRLF would move back and forth into or through this area. Further, ponded water in Drainage 1 would not be expected to provide suitable breeding habitat due to lack of sufficient hydroperiod (water during most years does not persist for over 10 weeks). Calle Joaquin Wetland. Calle Joaquin and Los Osos Valley Road impound surface water alongside the roadways’ eastern and southern sides on a seasonal basis. While culverts were installed to drain high flows under Calle Joaquin into a riparian drainage area across the street and then toward San Luis Obispo Creek to the south, soils remain saturated for a long enough duration to support perennial wetland habitat. The ponded area observed along Calle Joaquin in the winters of 2015 and 2016 were less than 12 inches deep, but contained a predominance of wetland vegetation and several dense clumps of bulrush (Schoenoplectus acutus). By the summers of 2015 and 2016 the areas contained marginal surface water ranging in depth from one to four inches in small pockets. During the winter rain season of 2017, ponded water observed in this area for a much longer time period (water was present through September 1, 2017) and averaged approximately 12 to 24 inches in depth. The deepest location observed in the spring 2017 supported upwards of 28 inches of standing water. As stated above, culverts in this area direct water under Calle Joaquin into a triangular riparian drainage area on the south side of Calle Joaquin, that is separated from San Luis Obispo Creek by a hotel, parking lot and Highway 101. It appears that the maximum depth of ponded water in the Calle Joaquin wetland would be approximately three feet before overtopping the curb and spilling onto the street. Adjacent upland areas to the Calle Joaquin wetland area consist of seasonal wetland habitat being overtaken by reed fescue (Festuca arundinacea) planted as forage. Due to the presence of sufficient water depth and emergent vegetation (primarily bulrush), this area would be considered potentially suitable habitat for CRLF. While it is less than 1,000 feet away from the observed CRLF occurrence in the City’s wastewater pond on the eastside of San Luis Obispo Creek, the Calle Joaquin wetland is separated from potentially suitable habitat within the San Luis Obispo Creek KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 9 corridor by urban development including Highway 101, an onramp, hotel, parking lot and Calle Joaquin. It is unlikely that CRLF could disperse overland across Highway 101, Los Osos Valley Road and Calle Joaquin onto the site. The triangular drainage area with riparian habitat on the south side of Calle Joaquin could also potentially be used by CRLF based on the presence of dense riparian and wetland vegetation and seasonal ponded water, eventhough it is primarily road runoff with unknown pollutants. Several biological and hydrologic studies have been completed in this general location for other projects, including the Calle Joaquin Road realignment, and the LOVR/Highway 101 interchange project. Focused protocol level surveys for listed branchiopods were also conducted for the Calle Joaquin Road realignment, and these surveys, even though focused on sampling for invertebrates, did not observe CRLF in the wetland area prior to the construction of Calle Joaquin. During this site assessment, Pacific tree frogs and one crayfish were observed in the Calle Joaquin wetland area. The dominance of perennial wetland vegetation, observed surface ponding into September, as well as review of historical aerial photographs obtained from Google Earth, suggests that the Calle Joaquin wetland site functions as a semi-perennial to perennial wetland, and therefore, contains potentially suitable habitat to support CRLF. The proposed project would not affect this area, and the Froom Creek realignment would be situated to maintain the hydrology to support wetland habitat in this part of the property. Irish Hills Plaza Stormwater Detention Basins. Construction of the Irish Hills Plaza included two large stormwater detention basins, immediately adjacent to each other and separated by an earthen berm. The basins were constructed between mid-2006 and mid-2007. The drainage basins release overflow water to the LOVR Roadside Ditch via a storm drain outfall into a constructed swale. During large storm events, the basin is designed to discharge water into the wetland/meadow area along Calle Joaquin via a concrete spillway on the south side of the main basin. Otherwise, water leaves the basin through evaporation and ground percolation. A large french drain system was also constructed around the perimeter of the basin to help maintain wetland vegetation along Calle Joaquin (personal communication with John Madonna). Google Earth historical aerial imagery indicates that these basins have been actively managed, with grading of the basins performed between April and August 2013, disturbing soil and removing vegetation. Under the proposed Froom Ranch development plan, these drainage basins would be removed, and runoff would be redirected into new constructed features including a larger basin proposed on the neighboring Mountainbrook Church property adjacent to Froom Creek. During the August and September 2017 site assessment field visits, the north basin featured shallow ponding (average 4-8 inches in depth) throughout much of the basin floor. Vegetation was dominated by obligate wetland plants such as cattail, spikerush and small fruited bulrush (Scirpus microcarpus) along with brown-headed rush and rabbitsfoot grass. The south basin was densely vegetated, but did not have ponded water or the predominance of obligate wetland plants, though signs of recent seasonal ponding were evident in the form of algal mats, cracked soil and surface salt deposits. Dominant vegetation included facultative wetland species such as creeping rye (Elymus triticoides), brown-headed rush, and reed fescue with patches of cattails present in several areas where saturation appears to persist In the more barren patches exhibiting salt crust and/or algal mats from recent drying, prickly sow thistle (Sonchus asper; a facultative wetland species) frequently occurred. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 10 Historic aerial photos reviewed on Google Earth show that the north and south basins both dry out seasonally in most years. The high rainfall in 2017 may be responsible for the continued ponding seen in the north basin into early September 2017, as well as ponding that appears to have lasted into the early summer in the south basin, based on presence of algal mats and salt deposits. The wetland plant species currently dominating both basins suggest semi-perennial wetland hydrology, but aerial photos taken as recently as September 2016 show the vegetation in both basins as almost entirely brown, with no visible surface ponding. The seasonal drying pattern coupled with the physical separation from known occurrences (i.e., the basin was constructed in an upland grassland area away from Froom Creek and the Calle Joaquin wetland) makes it unlikely that CRLF would find the stormwater basins even if they could disperse across Highway 101 and urban areas from San Luis Obispo Creek. Furthermore, with the shallow ponded water present in the basins, it would be unlikely to support breeding habitat for the species since they would be easily preyed upon by larger animals, and a regular hydroperiod of at least 10 weeks does not appear to be present. The fact that the basins were constructed as recently as 2006-07, and then graded for maintenance in 2013, and are not naturally connected to areas of potential habitat in San Luis Obispo Creek, also make it unlikely that CRLF would be able to locate and utilize the basins for seasonal foraging or breeding habitat. Clearly the features do not have the necessary aquatic habitat required to maintain a sustained breeding population of CRLF since they are constructed features with periodic soil disturbance from grading to remove vegetation and accumulated debris and sediment. If the basins were constructed immediately adjacent to suitable habitat (such as the case for the City’s wastewater pond where the CRLF was observed in 2006), were not regularly maintained, and did not have significant movement barriers such as Highway 101 and LOVR in place, it is possible that CRLF could use it on a seasonal basis. 3.2.2 Areas Within One Mile of the Property The area surrounding the subject property consists primarily of developed urban lands to the north and south, and the Irish Hills Natural Reserve to the north and west. Please refer to Figure 4 for existing conditions and land cover types within the one mile study area. Commercial development along LOVR and Highway 101 to the east and south create a formidable barrier for CRLF should they be present in San Luis Obispo Creek or other nearby water bodies and drainage features such as Laguna Lake and Prefumo Creek. While one individual was observed at the City’s wastewater treatment facility on the east side of Highway 101, other focused surveys in the area, and in San Luis Obispo Creek, have been unable to locate CRLF in San Luis Obispo Creek (personal communication with Sage Institute, 2017). If a healthy breeding population was present in San Luis Obispo Creek, it is possible that CRLF could disperse from breeding sites and move through the Froom Creek concrete box culvert under Calle Joaquin and Highway 101 and onto the property. However, it is a very long culvert (measured at over 300 linear feet) which likely would preclude small amphibian movement onto the site. It is also important to note that even if a CRLF were to use the culvert for movement, Froom Creek is a dry episodic drainage feature with no prolonged pools in the vicinity of the culvert. The first seasonal pool is not encountered until further onto the property near the confluence of Drainage 1 and Froom Creek. Even that seasonal in channel pond is short lived, does not have any vegetative cover, and any frog that found the feature would likely be preyed upon by racoon or other birds observed foraging in the area. As stated above, the Highway 101 corridor, LOVR, Calle Joaquin and associated commercial development present a significant barrier to CRLF dispersal from the north, south and east. As Froom Creek Laguna Lake Prefumo Creek East Fork San Luis Obispo Creek San Luis Obispo Creek Dry Creek CRLF Occurrence #895 (2006) Prefumo Creek Seasonally Ponded Areasalong Drainage 1 andFroom Creek Seasonally PondedAreas along Calle Joaquin S. Higuera St.L o s O s o s V a l l e y R d .Highway 101Highway 101Approximate Study Area Boundary Study Area 1 Mile Buffer Wastewater Treatment Pond Retention Basin (Seasonally Ponded) Creek/Drainage Feature Agriculture Grassland Coastal Scrub/Chaparral Oak Woodland Open Water Urban JM Development Group, Inc..0 870 1,740 2,610 3,480435 Feet Habitat and Land Cover Map Source(s): (c) ESRI 2017: CDFW, CNDDB, September 2017; County of San Luis Obispo Froom Ranch Figure 4 Buckley Rd. Tank Farm Rd. B r o a d S t . 1 in = 1,500 ft KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 12 stated above, given past studies in the region, it appears that CRLF occur in low numbers in the San Luis Obispo Creek corridor due to the lack of suitable breeding habitat. Recent study on the City-owned Waddell Property, identified what appears to be a breeding CRLF population in the upper reaches of Froom Creek to the northwest of the project site (personal communication with Robert Hill, 2017). At this location perennial or prolonged, slow moving water sources are available. This is roughly 2.3 miles from the edge of the northern proerty line, and the portion of Froom Creek between the site and observed CRLF occurrences is a highly ephemeral drainage channel with much of the channel and surrounding uplands covered in chaparral habitat that would not be easily traversed by dispersing individuals. Still it is possible that a CRLF could be washed downstream during the high flow events, such as those observed during January 2017. But as discussed herein, the portion of Froom Creek on the study area does not contain the necessary habitat attributes such as long lived, deep pools (24 inches or greater) of slow moving water with thickets of riparian shrubs, trees and emergent wetland vegetation to support foraging or CRLF breeding activities. While seasonal foraging could be supported onsite or in relatively close proximity to the site, it appears that suitable habitat in the immediate project area is limited, and if CRLF are in fact present in San Luis Obispo Creek, they occur at low numbers. 3.2.3 Critical Habitat Designation The U.S. Fish and Wildlife Service designated critical habitat for CRLF in the region (Unit SLO-3). This unit is outside the study area, and no critical habitat attributes were observed within the study area. 4.0 CONCLUSION Typically, adult CRLF require dense, shrubby or emergent riparian vegetation closely associated with deep (greater than 24 inches) still or slow-moving water for breeding habitat. Well-vegetated terrestrial areas within a riparian corridor can provide important sheltering habitat during winter months when high flows are present. The 2015 and 2016 surveys were conducted during below average rainfall years, following severe drought conditions during the previous two years. The drought conditions experienced in the region likely had a significant impact on local amphibian populations and further restricted breeding and dispersal activities. The winter and spring of 2017 was an above average precipitation year, and flowing water was present in Froom Creek in January. In addition, areas of ponded water in onsite features identified on attached data sheets persisted longer than previously observed, but still, vegetation conditions did not change significantly. Based on the results of the site assessment, the most suitable habitat identified on the project site is located in the Calle Joaquin wetland. While we cannot completely rule out CRLF presence from this area, based on the high number of survey hours onsite to date coupled with the major dispersal barriers (i.e., Highway 101, LOVR and surrounding commercial development), CRLF are unlikely to move from San Luis Obispo Creek onto the site. Further, the Froom Creek culvert is very long, and would be a major undertaking for a CRLF to disperse over 300 linear feet through this culvert to access the site. Once onsite, the dispersing individual would need to locate suitable aquatic habitat to persist, and the site assessment confirmed there are no prolonged pools with appropriate depth and vegetative structure in the immediate area of the culvert or within Froom Creek and Drainage 1 on the project site that could support this species. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 13 The portion of Froom Creek on the property does not provide suitable aquatic habitat for the CRLF due to lack of regularly ponded water with a sufficient hydroperiod to support breeding or even foraging activities. Seasonal flows with regularity to support dispersal from nearby breeding areas (such as the upper Froom Creek observation on the Waddell Property), and suitable riparian and wetland vegetation along the channel also appear to be absent. The section of Froom Creek south of the Froom Ranch property on Mountainbrook Church property extending to Calle Joaquin also lacks sufficient hydroperiods, pool structure, and instream vegetation. The southern tributary channel identified as Drainage 1 contained marginally suitable habitat since it has some prolonged surface water present in a channel with a relatively high canopy of coast live oak and California bay. However, the water depth was not suitable since it was regularly observed at less than 18 inches, and dense shrubby vegetation cover such as overhanging willows and emergent wetland plants needed for refuge and cover from predators was also not present. The in stream ponding observed and shown in the attached photo plate, shows an open channel that would be easily accessed by predators such as racoon and other birds present in the area. The Irish Hills Storm Water Basin is a constructed feature in an upland area with an ephemeral ponding regime. In drought years such as 2015 and 2016, no ponding was observed. In 2017, prolonged surface water was present in the north basin into September, and a dense carpet of wetland vegetation was present. The periodic grading and removal of vegetation and sediment from this constructed feature, as well as the water source being from polluted parking lot runoff, also reduces the potential for CRLF presence. The heavily traveled Highway 101 and LOVR corridors create a significant barrier to dispersal from the north and east, including from the 2006 occurrence at the City’s wastewater facility. While CRLF have now been confirmed in the upper Froom Creek watershed, the site is roughly 2.3 miles from this occurrence and the creek corridor and surrounding chaparral vegetation would be challenging for dispersal of CRLF onto the property, especially when considering no suitable pool habitat is present within the study area boundaries. In addition, the areas of marginal CRLF habitat comprised of the lower reach of Drainage 1 did not have a suitable hydroperiod to support CRLF. While the Calle Joaquin wetland contained potentially suitable habitat for CRLF based on the presence of prolonged surface water and dense emergent vegetation. Based on the results of this assessment, it appears unlikely that CRLF could utilize any portion of the site based on its isolation from San Luis Obispo Creek and separation from known occurrences in the region by urban development and unsuitable habitat, and the landscape around the project site is not conducive to CRLF movement. The Calle Joaquin wetland contained potentially suitable habitat, and represents the only location onsite with a higher potential to support the species. Of importance, this area would be avoided by the future project, and maintained as permanent open space. The realignment of Froom Creek has been designed to increase areas of instream ponding on the site and maintain the wetland hydrology of the Calle Joaquin wetland. As such, future development of the Froom Ranch Specific Plan is unlikely to affect CRLF, especially with the incorporation of avoidance measures such as pre-construction clearance surveys and other best management practices implemented during construction of the new Froom Creek channel. 5.0 REFERENCES Bulger, J.B., N.J. Scott, and R.B. Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs, Rana aurora draytonii, in coastal forests and grasslands. Biological conservation 110 (2003): 85-95. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 14 Baldwin, B. G., D. H. Goldman, D. J. Keil, R. Patterson, T. J. Rosatti, Editors. 2012. The Jepson Manual, Vascular Plants of California, Second Edition Thoroughly Revised and Expanded. University of California Press. California Department of Fish and Wildlife (CDFW). 2017. Natural Diversity Data Base of recorded occurrences of special-status species. Accessed September 2017. Cowardin, L.M., V. Carter V., F.C. Golet, E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service Report No. FWS/OBS/-79/31. Washington, D.C. Ferren, W.R., Jr., P.L. Fiedler, and R.A. Leidy. 1996a. Wetlands of California, Part I: History of Wetland Habitat Classification. Madroño 1996 43(1):105-124. Ferren, W.R., Jr., P.L. Fiedler, R.A. Leidy, et al. 1996b. Wetlands of California, Part II: Classification and Description of Wetlands of the Central and Southern California Coast and Coastal Watersheds. Madroño 1996 43(1):125-182. Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Wildlife Nongame-Heritage Program. Hoover, R. 1970. Vascular Plants of San Luis Obispo County, California. Jennings, M. R., and M. P. Hayes. 1994. Amphibian and reptile species of special concern in California, 1 November 1994. California Department of Fish and Game, Inland Fisheries Division, Rancho Cordova, California. 255 pp. Kevin Merk Associates, LLC. 2015. Froom Ranch, San Luis Obispo, California: Delineation of Waters of the United States and State of California. _______ 2016. Froom Ranch Project, San Luis Obispo County: Biological Resources Inventory. Marine Research Specialists. 2013. Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (FEIR). Prepared for the City and County of San Luis Obispo. Natural Resources Conservation Service (NRCS). 2017. Web Soil Survey. National Cooperative Soil Survey, U.S. Department of Agriculture. Accessed via: http://websoilsurvey.nrcs.usda.gov/app. Rathbun, G.B., and J. Schneider. 2001. Translocation of California red-legged frogs (Rana aurora draytonii). Wildlife Society Bulletin 29:1300-1303. Sawyer, J. O., T. Keeler-Wolf, and J. M. Evens. 2009. A Manual of California Vegetation, 2nd Edition. California Native Plant Society, Sacramento, CA. Stebbins, R. C. 2003. A field guide to western reptiles and amphibians. Third edition, revised edition. Houghton Mifflin Company, Boston, Massachusetts. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. 15 U.S. Fish and Wildlife Service. 2005. Revised Guidance on Site Assessments and Field Surveys for the California Red-legged Frog. U.S. Fish and Wildlife Service. 2002. Recovery plan for the California red-legged frog (Rana aurora draytonii). Portland, Oregon. U. S. Fish and Wildlife Service. 2010. Endangered and threatened wildlife and plants; Revised critical habitat for the California red-legged frog; Final Rule. 17 March 2010. Federal Register 75(51):12815-12864. Spatial data accessed through the Critical Habitat Portal via http://criticalhabitat.fws.gov/crithab/. APPENDIX A CRLF Site Assessment Data Sheets KMA APPENDIX B Photo Plate KMA KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Appendix B - Photo Plate Photo 1. Southerly view of Froom Creek on the project site, looking downstream. Photo from spring 2016. Note dry, cobble channel with no pool or riffle structure visible since no recent flow. Photo 2. Southerly view of Froom Creek during winter of 2017 showing high flows following series of storm events in early January. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 3. Northeasterly overview of the middle reach of Froom Creek onsite. Channel does not support woody riparian or wetland habitats. Constructed retention basin is visible in the distance. Photo 4. Northerly view of downstream reach of Froom Creek on project site. Photo taken on January 26, 2017. High flows had receded and suspended sediment had dropped out producing clear, cool water averaging 2-6 inches deep. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 5. Another northerly view of downstream reach of Froom Creek at the confluence of Drainage 1, which is visible at the bottom of the photo. Photo 6. Westerly view of Drainage 1 as it connects with Froom Creek near the property boundary. Banks are steeply incised at this location and water depth ranged from 2-6 inches deep with 12 inches present at thalweg location. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 7. Southerly view of downstream reach of Froom Creek on the project site from March 2017 and no ponded water was present following high flows in January. Photo 8. Westerly view of the southern end of Froom Creek at the confluence with Drainage 1 from showing location of instream seasonal ponding that occurs periodically at the base of steep bank in center of photo. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 9. Close up view of seasonally ponded water present in Froom Creek just downstream from the confluence of Drainage 1. Photo taken on September 1, 2017 showing approximately water 2-4 inches deep. Photo 10. Southeasterly view of high flows within Froom Creek entering concrete box culvert under Calle Joaquin. Note approximately two feet of free board within the culvert. Photo taken in early January 2017 following series of large rain events. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 11. Froom Creek reach on the Mountainbrook Church property in the spring 2017 showing dry channel conditions. Photo 12. Drainage 1 confluence with Froom Creek, looking west or upstream toward oak woodland with California bay. One small willow is visible in the channel downstream of oaks. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 13. View of small in stream pool in Drainage 1 below a California bay tree. Size was approximately 25 feet long by 5 feet wide with a water depth between 4 and 16 inches. Photo 14. Downstream view of in stream pool in Drainage 1 at confluence of Drainage 2 as shown on Wetland Delineation Map. Water depth ranged from approximately 4-16 inches. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 15. Northerly view of wetland vegetation at the confluence of Drainage 2 with Drainage 1. Soil was saturated with cattle hoof prints supporting one to two inches of ponded water. Photo 16. Southerly view of wetland vegetation present in the lower reach of Drainage 2 near the confluence with Drainage 1. Seasonal in stream ponding present under the oak and bay trees visible in the distance. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 17. View of Calle Joaquin wetland at the southeastern corner of the site. LOVR ditch and stormwater basin drain to this area before culverts direct water offsite toward San Luis Obispo Creek. Emergent vegetation was present and water depth ranged from approximately 4-18 inches. Photo 18. Northerly view (looking towards LOVR) of the ponded water and emergent vegetation along Calle Joaquin. Area searched for amphibians during surveys and only Hyla regilla observed. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 19. Close up view of ponded water along Calle Joaquin, looking southeast at culvert that drains this area under Calle Joaquin to a riparian area between Calle Joaquin, Hotel, LOVR and Highway 101. Photo 20. View of seasonally ponded water at second culvert under Calle Joaquin. Culvert is approximately 36-inches and drains water from the site under Calle Joaquin to the southwest corner of riparian area next to hotel. Water depth was approximately 6 inches on September 1, 2017. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 21. Westerly overview of the forebay (north basin) in the Irish Hills Plaza Storm Water Basin. Cattails and tules are present in areas of prolonged saturation along with herbaceous wetland species. Photo 22. Easterly view of forebay. Basins contained wetland vegetation in bottom lands with upland grasses on earthen berms. KMA Froom Ranch Specific Plan Project California Red-Legged Frog Site Assessment JM Development Group, Inc. Photo Plate Photo 23. Easterly view of main basin with spillway visible in the distance. Main basin was considerably drier and had less dense cattail and tule occurrences. Photo 24. Easterly view of ditch leading from Storm Water Basin towards LOVR Ditch and the Calle Joaquin Wetland. Crayfish, a known predator of CRLF, was observed at this location. APPENDIX C Habitat Map from Biological Resources Inventory (KMA 2016) KMA Irish Hills Plaza Mountainbrook Church Los Osos Valley RdHWY 101 Calle J o a q u i n Irish Hills Natural Reserve Froom Creek Drainage 1 Drainage 2 Drainage 3 Study Area Boundary Storm Water Basin (5.21 ac) Sycamore Trees (0.13 ac) Developed/Disturbed (8.88 ac) Eucalyptus Trees (0.61 ac) Arroyo Willow Riparian Scrub (1.87 ac) Wetland (7.25 ac) Drainage Feature (2.66 ac) Coast Live Oak/CA Bay Woodland (3.23 ac) Serpentine Rock Outcrop (1.96 ac) Serpentine Bunchgrass Grassland (13.46 ac) Coastal Scrub/Chaparral (6.52 ac) Annual Grassland (59.22 ac) 0 230 460 690 920115Feet Habitat Map Figure 4Froom Ranch Source(s): ESRI and its data providers; San Luis Obispo County Parcel Information John Madonna Construction, Inc. 1 in = 400 ft APPENDIX D Wetland Delineation Overview Map (KMA 2015) KMA APPENDIX E.4 Vernal Pool Habitat Assessment This Page Intentionally Left Blank. FROOM RANCH SPECIFIC PLAN PROJECT (APNs 067-241-030, 067-241-031) SAN LUIS OBISPO, CALIFORNIA VERNAL POOL HABITAT ASSESSMENT Prepared for: Mr. John Madonna JM Development Group, Inc. P.O. Box 5310 San Luis Obispo, California 93403 Prepared by: Kevin Merk Associates, LLC P.O. Box 318 San Luis Obispo, California 93406 November 28, 2017 KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. i TABLE OF CONTENTS Page 1.0 INTRODUCTION ............................................................................................................................................................. 1 1.1 Project Description ............................................................................................................................................... 1 2.0 VERNAL POOL HABITAT AND VERNAL POOL FAIRY SHRIMP .................................................................. 4 3.0 METHODS .......................................................................................................................................................................... 7 3.1 Background Research .......................................................................................................................................... 7 3.2 Vernal Pool Habitat Field Assessment ......................................................................................................... 8 3.3 Qualifications of Surveyors ............................................................................................................................... 9 4.0 RESULTS ............................................................................................................................................................................ 9 4.1 Vernal Pool Habitat Assessment ..................................................................................................................... 9 4.1.1 Calle Joaquin Wetland ....................................................................................................................... 10 4.1.2 Stormwater Detention Basins ....................................................................................................... 14 4.1.3 Critical Habitat Designation ........................................................................................................... 15 5.0 CONCLUSION ................................................................................................................................................................ 15 6.0 REFERENCES ................................................................................................................................................................ 15 LIST OF FIGURES Figure 1 – Site Location Map ................................................................................................................................................. 2 Figure 2 – Aerial Overview Map .......................................................................................................................................... 3 Figure 3 - CNDDB Map ............................................................................................................................................................ 5 Figure 4 – Wetland Delineation Overview Map ......................................................................................................... 11 Figure 5 – Soils Map ............................................................................................................................................................... 12 APPENDICES Appendix A – Historic Aerial Photograph Review Appendix B – Photo Plate KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 1 1.0 INTRODUCTION Kevin Merk Associates, LLC (KMA) conducted a vernal pool habitat assessment for the Froom Ranch Specific Plan project located just outside the current southwest city limits of the City of San Luis Obispo. A Biological Resources Inventory Report (BRI) prepared by KMA in January 2016 for the project provided background information referenced herein including a characterization of existing conditions, and results of floristic and tree inventories. A special status species evaluation was also included, and special status wildlife that could potentially occur onsite were identified based on a habitat suitability analysis. The analysis concluded that since no vernal pool or suitable seasonal wetland habitat was present, and past focused surveys for listed branchiopods in the Calle Joaquin wetland area produced negative findings, species such as the federally threatened vernal pool fairy shrimp (Branchinecta lynchi; VPFS) were unlikely to occur onsite. Populations of VPFS have been identified to the east of the Froom Ranch property, primarily on the former Chevron Tank Farm property, which is within two miles of the study area. A 2013 recorded occurrence was also identified off Vachell Lane within one mile of the property. All occurrences are located to the east of Highway 101 in isolated wetlands and gentle swale complexes. As part of the ongoing regulatory agency consultation process, the U.S. Fish and Wildlife Service (USFWS) in an August 14, 2017 letter from Ms. Julie Vanderwier to Ms. Shawna Scott with the City of San Luis Obispo’s Community Development Department, requested that a vernal pool habitat assessment be completed for the property. The purpose of the vernal pool habitat assessment is to determine whether suitable seasonal pool habitat capable of supporting federal listed vernal pool branchiopods such as VPFS are present onsite that could potentially be impacted by future project development. This report details the methods and results of the vernal pool habitat assessment conducted on the proposed Froom Ranch Specific Plan project site. 1.1 Project Description The Froom Ranch Specific Plan Area consists of two parcels located at 12165 and 12393 Froom Ranch Way, totaling approximately 111 acres (APN 067-241-030 and 067-241-031) currently within unincorporated San Luis Obispo County adjacent to City of San Luis Obispo city limits (please refer to Figures 1 and 2). It also includes a southern “spur” where a flood control basin would be constructed on neighboring property owned by the Mountainbrook Church. The site is located immediately west of Los Osos Valley Road between Highway 101 and the Irish Hills Plaza. It is currently a working cattle/horse ranch that supports a variety of habitat types including: grasslands (both native bunchgrass and non-native annual), oak woodland (with California bay trees), coastal scrub/chaparral, serpentine outcrops, and seasonal and perennial wetlands that are primarily associated with drainage features. Ruderal or disturbed areas are also present and consist of existing developed areas as well as constructed stormwater basins that are part of the Irish Hills Plaza development. Froom Creek, which flows to San Luis Obispo Creek via culverts under Calle Joaquin and Highway 101, and three unnamed tributary drainages are also present onsite. The proposed Froom Ranch development is envisioned as a residential project with some commercial development in the northeast corner of the site closest to the adjacent Irish Hills Plaza. Permanent open space is proposed to occupy about 51% of the Froom Ranch site. The project is divided into two main components: The Madonna Froom Ranch and The Life Plan Community (also known as the Villaggio). The Madonna Froom Ranch would be situated in the northern portion of the Specific Plan Area, just south of the Irish Hills Plaza. It will contain a mix of commercial and Site Location ^_ ²1 in = 10,000 ft 0 1 20.5 Miles Figure 1 Site Location Site Location ^_ 1 in = 1,000,000 ft JM Development Group, Inc. Froom Ranch Source: ESRI 2017 £¤101 L o s O s o s V a l l e y R o a d Prefumo Creek San Luis Obispo Creek Froom Creek Laguna Lake ²1 in = 2,000 ft 0 1,300 2,600650Feet Figure 2 Aerial Overview JM Development Group, Inc. Froom Ranch Approximate Study Area Boundary National Wetland Inventory (USFWS) Estuarine and Marine Deepwater Estuarine and Marine Wetland Freshwater Emergent Wetland Freshwater Forested/Shrub Wetland Freshwater Pond Lake Other Riverine KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 4 residential land uses, and include a hotel and trailhead park. The park will provide a staging area and connection to open space trails within the City’s Irish Hills Natural Reserve. The Villaggio project would provide a variety of different unit types for independent senior housing and include access to assisted living, memory care, and skilled nursing. A recreational facility, restaurants, and movie theater are also planned in this community. For a detailed project description, please refer to the Froom Ranch Specific Plan prepared by RRM Design Group. 2.0 VERNAL POOL HABITAT AND VERNAL POOL FAIRY SHRIMP Vernal pools are shallow topographic depressions underlain by an impervious soil layer, such as a claypan or hardpan that fill with water during winter rains and dry in spring, creating seasonal aquatic habitat. Vernal pools typically have high levels of native biodiversity, and some pools provide habitat for protected plant, crustacean, and amphibian species (Platenkamp 1998). Vernal pools and seasonal wetlands frequently tend to be small features, often 0.125 acre or smaller, and generally cannot be easily identified on aerial imagery unless the image is high resolution and the pools are filled with water at the time the aerial photograph is taken. Naturally formed vernal pools may occur singly or in complexes, with a series of depressions in close proximity, often connected by swales. Depending on the size of the pool and other environmental factors, a vernal pool may be inundated for a week or upwards of several months before completely drying. This seasonal ponding allows a suite of native flora and fauna that are highly specialized to persist in an area with a wide range of hydrologic conditions. While Holland (1986; Holland and Iain 1988) was historically the primary source for vernal pool taxonomy in the state of California, more recent studies have refined vernal pool classification based on the hydrogeomorphology and dominant vegetation (Ferren et al. 1996; Sawyer, Keeler-Wolf and Evens, 2009). Among the fauna that may utilize vernal pools are a group of small crustaceans in the class Branchiopoda, which includes the invertebrates commonly known as fairy shrimp and tadpole shrimp. Within the state of California, over 25 species of fairy shrimp and tadpole shrimp have been recorded, including five fairy shrimp and one tadpole shrimp that are federally protected as threatened or endangered under the federal Endangered Species Act (FESA). San Luis Obispo County is known to host several species of fairy shrimp, with most occurrences in the drier inland areas east of Paso Robles and onto the Carrizo Plain. Within and adjacent to the City of San Luis Obispo, two species of fairy shrimp have been recorded: Linderiella occidentalis (California linderiella), and Branchinecta lynchi (“vernal pool fairy shrimp” or VPFS). California linderiella is a state Species of Concern, and VPFS is federally listed as threatened (USFWS 1994). Populations of VPFS have been recorded at two sites within two miles of the Froom Ranch property, and include the former Chevron Tank Farm property and an adjacent parcel off Buckley Road and Vachell Lane (please refer to Figure 3, the CNDDB Occurrence Map). Although VPFS were once thought to occur only in the Central Valley of California, populations have now been identified as far north as the Agate Desert of southern Oregon and as far south as the Santa Rosa Plateau near Riverside in southern California. The VPFS has the widest geographic range of the federally-listed vernal pool crustaceans, but it is seldom abundant where found, especially where it co-occurs with other species of fairy shrimp (USFWS 2003; Ericksen and Belk 1999). VPFS Occurrence 11/08/2013 San Luis Obispo Lopez Mountain North East Arroyo Grande Port San Luis Pismo Beach Text Morro Bay South Copyright:© 2013 National Geographic Society, i-cubed ²1 in = 6,000 ft 0 1 20.5 Miles Figure 3 Regional Location/VPFS Occurrence JM Development Group, Inc. Froom Ranch Approximate Study Area Boundary CNDDB Vernal Pool Fairy Shrimp Occurrence Study Area One Mile Buffer Additional Five Mile Buffer Source: ESRI 2017, CNDDB 2017 KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 6 As with other California freshwater fairy shrimp species, VPFS have unique biological adaptations enabling them to survive long drought seasons, as described in the excerpt below from Vernal Pool Fairy Shrimp (Branchinecta lynchi) 5-Year Review: Summary and Evaluation (USFWS 2007): “The vernal pool fairy shrimp has an ephemeral life cycle and exists only in vernal pools or vernal pool-like habitats; the species does not occur in riverine, marine, or other permanent bodies of water…. Like most other fairy shrimps, the vernal pool fairy shrimp lacks any substantial anti-predator defenses and does not persist in waters with fish (King et al. 1996; Eriksen and Belk, 1999). When the temporary pools dry, offspring persist in suspended development as desiccation-resistant embryos (commonly called cysts) in the pool substrate until the return of winter rains and appropriate temperatures allow some of the cysts to hatch (Eriksen and Belk, 1999). Vernal pool habitats form in depressions above an impervious substrate layer, or claypan/duripan, usually in alluvial fans and terraces (Vollmar, 2002).” “…The thermal and chemical properties of vernal pool waters are two of the primary factors affecting the distributions of specific fairy shrimp species (including the vernal pool fairy shrimp), or their appearance from year to year. Different species may appear in pools from one year to the next, depending on whether the pools fill at a different time of the year. Based on hatching and life history requirements, species may also appear in succession during one season as conditions change within the pool (Simovich and Fugate 1992; Eriksen and Belk 1999)… Active vernal pool fairy shrimp die off when water temperatures get too warm (Helm 1998). In years with low amounts of precipitation or atypical timing of precipitation, (or in substandard habitat) vernal pool species may die off before reproducing (Eriksen and Belk 1999). Adult VPFS are usually less than one (1) inch in length, and are very fragile. Their cysts are tiny, from 0.15 to 0.4 mm in diameter, and are very resilient, especially when dry (Eriksen and Belk 1999). Animals moving through vernal pools, drinking and feeding from them, may aid in dispersing VPFS to new locations: “Long-distance dispersal of anostracan cysts is thought to be enabled by waterfowl and other migratory birds that ingest cysts, and by animals that provide for movement of mud and cysts in feathers, fur, and hooves…” (USFWS 2007) VPFS populations can exist in many types of topographic depressions that pond water seasonally, including ponds that are not naturally-formed vernal pools, if the conditions provide the hydrologic regime, thermal and chemical properties the species requires. A study which sampled over 4,000 California seasonal wetlands identified endemic fairy shrimp and tadpole shrimp in wetlands ranging in type from natural freshwater and alkaline vernal pools to rock outcrop pools to percolation test pits, pools formed in dirt and gravel-based railroad rights of way by vehicular traffic, roadside ditches, stock ponds and more (Helm 1996). In northern San Luis Obispo County, at Camp Roberts National Guard Training Installation, VPFS monitoring programs recorded recurring populations of VPFS in old mortar holes and tank ruts on claypan soils (U.S. DOD and CA ARNG 1998). Simovich’s 1998 paper on “Crustacean Biodiversity and Endemism in California’s Ephemeral Wetlands” summarized characteristics specific to ephemeral water bodies that are missing in more perennial water bodies. The key characteristics identified that restrict or limit anostracans, such as VPFS, to ephemeral water bodies include: lack of fish; predation pressure from other species being KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 7 delayed until after VPFS reproduction is largely complete; and the cyst storage bank in the ephemeral pool, with VPFS cysts hatching at different times and different years, improving the species’ chances of survival (Simovich 1998). Conversely, the following characteristics are indications that the location generally will not provide suitable habitat for listed large branchiopods: “Habitats that swiftly flow water (e.g., creeks, streams, and ephemeral drainages) or habitats that are semi-to-permanently inundated and support perennial populations of predators (e.g. bullfrogs, fish, and crayfish).” (USFWS 2015) 3.0 METHODS 3.1 Background Research Prior to conducting field work, KMA’s Principal Biologist, Kevin Merk, and Senior Biologist Julie Thomas reviewed pertinent background information from the general area. This included previous biological studies in the region and on the subject site, as well as the recently completed Biological Resources Inventory (KMA 2016). Numerous field hours were spent on the study area during the winter and spring months of 2015/2016 and 2016/2017 to characterize the nature and extent of drainage and wetland features subject to Clean Water Act and California Fish and Game Code requirements, which provided direct observation of onsite hydrology. Several Environmental Impact Reports, biology studies and wetland delineations completed for nearby development projects were also reviewed. Hydrologic studies, wetland mitigation plans and subsequent mitigation monitoring reports completed for the Home Depot project, which included portions of the study area, were also reviewed as part of the investigation. Local studies and documents reviewed for this vernal pool habitat assessment included the following: ¥ Madonna Eagle Hardware Environmental Impact Report (1998); ¥ Biological Resources Analysis Letter of Findings for the Los Osos Valley Road Improvement Project (Olberding Environmental, 2001); ¥ Wetland Restoration and Mitigation Plans Relating to the Froom Ranch/Home Depot Project (Olberding Environmental, 2002); ¥ San Luis Obispo Creek Watershed Enhancement Plan (Land Conservancy of San Luis Obispo County, 2002); ¥ Year 1 Wetland Monitoring Report for the Froom Ranch/Boysen Ranch Mitigation Sites (Olberding Environmental, 2003); ¥ Calle Joaquin Realignment Wetland Delineation (Morro Group, 2004); ¥ Irish Hills Plaza II Wetland Delineation Map (Morro Group, 2004); ¥ Hydrologic Monitoring Plan for Sustaining a Separated Wetland Near Calle Joaquin (Balance Hydrologics, 2005); ¥ 90-Day Report of Wet Season Fairy Shrimp Surveys, Calle Joaquin Site, San Luis Obispo (Thomas, 2005); ¥ Irish Hills Plaza Detention Basin Report (Wallace Group, 2006); ¥ Year 5 Wetland Monitoring Report for the Froom Ranch/Home Depot Site (Olberding Environmental, 2007); ¥ Los Osos Valley Road/U.S. 101 Interchange Improvements Project Biological Assessment for Central California Coast Steelhead (2008); ¥ Irish Hills Natural Area Conservation Plan Update (City of San Luis Obispo, 2011); KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 8 ¥ Madonna Enterprises Vachell Lane Property 2013 Wet Season Vernal Pool Branchiopod Survey 90-Day Report (Sage Institute, Inc., 2013); ¥ Madonna Enterprises Vachell Lane Property 2013 Dry Season Vernal Pool Branchiopod Survey 90-Day Report (Sage Institute, Inc., 2014); ¥ Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (Marine Research Specialists, 2013); and ¥ Froom Ranch Delineation of Waters of the United States and State of California (Wetland Delineation; KMA, 2015). Other reports from the project area including the VPFS survey findings (both wet season and dry season) for the Calle Joaquin Road Realignment project (conducted by Ms. Thomas), which included the project site, and the Vachell Lane Property (Sage II, 2013) were also reviewed. Conversations with other local branchiopod experts (pers. comm. Mitch Dallas and David Wolff) regarding their recent studies also occurred. Historical aerial photographs obtained from Google Earth were reviewed to further aid in the existing conditions characterization, and were compiled and included as an appendix to this report. The California Natural Diversity Database maintained by the California Department of Fish and Wildlife (CNDDB, 2017) was searched for listed branchiopod species that have been documented within the United States Geological Survey’s (USGS) 7.5-minute topographic quadrangle maps centered on and surrounding the site. This included the Morro Bay South, San Luis Obispo, Lopez Mountain, Port San Luis, Pismo Beach and Arroyo Grande Northeast quads. Given the project site’s proximity to the Pacific Ocean and geographic setting on the northern flank of the Irish Hills of the San Luis Range in close proximity to San Luis Obispo, the focus on these six quads was deemed a sufficient search area to identify listed branchiopod species occurring in the vicinity of the site for inclusion in the study. To support the Vernal Pool Habitat Assessment, the Natural Resources Conservation Service (NRCS) Web Soil Survey was reviewed to determine the soil mapping units present within the study area (U.S. Department of Agriculture 2017). The U. S. Fish and Wildlife Service’s online Wetland and Critical Habitat Mapper (http://www.fws.gov/wetlands/Data/Mapper.html; http://criticalhabitat.fws.gov/crithab/) were also reviewed to evaluate the extent of documented wetlands and designated critical habitat in the region. 3.2 Vernal Pool Habitat Field Assessment As part of field work for the 2015 Wetland Delineation and 2016 Biological Resources Inventory, KMA’s Principal Biologist Kevin Merk conducted monthly surveys starting in January 2015 through October 2015 to track rain storms and characterize the hydrology of onsite drainage features (i.e., Froom Creek, its tributary drainages and the Los Osos Valley Road Ditch), constructed detention basins and the Calle Joaquin road impoundment. Additional site visits were conducted by Mr. Merk and other KMA biologists during the 2016-17 rain season to further map and define the extent of regulatory agency jurisdiction over the drainages and wetland areas onsite. During the site visits, KMA biologists explored the site extensively on foot and by four-wheel drive vehicle. All areas of hydrologic significance, including Froom Creek, its tributary drainages and associated seeps/springs and the LOVR ditch were visited. Any areas with ponded water or topographic swales or seeps/springs, which appeared to have the potential to pond water or maintain prolonged soil saturation were mapped and assessed for the presence of the three federal wetland criteria (i.e., hydric soils, predominance of wetland vegetation, and wetland hydrology). Please KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 9 refer to the 2015 Wetland Delineation Report and the 2016 Biological Resources Inventory prepared by KMA for further discussion. The Wetland Delineation Overview Map is included in this report. For the vernal pool habitat assessment, two additional site visits were conducted in September 2017 by Mr. Merk and Ms. Thomas to identify and survey areas with ponded water or the potential to contain pond water on a seasonal basis. The surveys searched for potential seasonal ponding indicators such as subtle changes in topography, predominance of wetland vegetation, accumulated sediment, dried mud, cracked clay soils or surface saline deposits. All drainage features, swales, ditches, basins, and topographic depressions were examined to assess the potential of supporting ponding water (at least 3 cm) with little flowing water during the wet season for sufficient duration (estimated at a minimum of two weeks) to allow a fairy shrimp population to complete a reproductive cycle. Aerial photographs of the property, wetland delineation maps, and a Trimble GeoXH 6000 GPS unit were used to record the locations of areas considered potential habitat. Photographs were taken of these locations, and record made of the vegetation present. Plant species were recorded following the Jepson Manual, second addition (Baldwin et al., 2012). Robert Hoover’s The Vascular Plants of San Luis Obispo County, California (1970) and the California Consortium of Herbaria accessed online were also used to identify plants observed onsite. 3.3 Qualifications of Surveyors KMA biologists Kevin Merk and Julie Thomas conducted this vernal pool habitat assessment survey. Both Mr. Merk and Ms. Thomas are familiar with vernal pool habitat and associated vegetation in the San Luis Obispo County area. Mr. Merk has worked extensively throughout California in vernal pool regions conducting wetland delineations and surveying for listed branchiopods and amphibians such as the California tiger salamander (Ambystoma californiense). In addition, Ms. Thomas has over 15 years of experience conducting protocol surveys for vernal pool fairy shrimp and assessing potential habitat throughout Central California, including San Luis Obispo County, and holds a valid USFWS 10(a)(1)(A) recovery permit for listed branchiopods (#TE834492-5). 4.0 RESULTS 4.1 Vernal Pool Habitat Assessment VPFS have been recorded at two sites located within two miles of the proposed Froom Ranch project site: ¥ At the former Chevron Tank Farm on Tank Farm Road in San Luis Obispo, multiple surveys have identified VPFS populations in remnant tank rings, former earthen bermed oil reservoirs, drainage ditches with little to no flowing water and other altered landscape features and topographic depressions on the property (Marine Research Specialists, 2013). Linderiella occidentalis (California linderiella), a more common fairy shrimp, has also been recorded on this property, and in some instances co-occurs with VPFS. ¥ A population of VPFS was more recently recorded in a seasonal pond/swale feature on the east side of Vachell Lane between South Higuera Street and Buckley Road in the County of San Luis Obispo during wet season surveys in 2004-05, and again with dry season sampling in 2013. Linderiella occidentalis was also recorded in this location (SII; 2013, 2014). KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 10 The above VPFS sites and the Froom Ranch property are not connected via surface hydrology, but the proximity of these VPFS populations suggests the possibility that cysts could be transported to the Froom Ranch property via birds and other wildlife that could cross urban areas and Highway 101. However, even if viable VPFS cysts were introduced by migrating wildlife, a population could only be established on Froom Ranch if suitable habitat were present. On the Froom Ranch property, KMA identified three features with potential to pond water with a depth and duration sufficient to potentially support listed branchiopod species: two constructed earthen drainage basins that are part of the Irish Hills Plaza infrastructure (“north drainage basin” and “south drainage basin”), and a wetland area adjacent to the intersection of Calle Joaquin and Los Osos Valley Road (“Calle Joaquin wetland”). Please refer to Figures 4 and 5 for location information. Other wetland, creek and drainage features in the Froom Ranch survey area do not provide potential habitat for listed branchiopod species, either because they periodically experience scouring flows, do not exhibit the topography to pond water at the required depth and duration to support the species, or because they are perennially moist seeps. Both the north and south drainage basins, as well as the Calle Joaquin wetland, occur on the NRCS soil map unit Cropley clay, 0-2% slopes (Figure 6), described as follows: Cropley clay 0-2 % slopes. Cropley clay consists of a dark gray or black (10YR 4/1, 3/1, 2/1 moist) clay horizon about 36 inches thick, underlain by a light brown calcareous clay loam to 60 inches or more. Permeability of this soil is slow and the available water capacity is high. Cropley soils formed in alluvium developed from sedimentary rocks. An unnamed component of Cropley clay is listed as a hydric soil when present in drainageways. This inclusion is typically very dark gray throughout, with mottles present in the lower horizons. Mapped inclusions within this series include Diablo clay, Los Osos loam, and Salinas silty clay loam. (NRCS 2015) The Cropley clay soil as described has the characteristics that would enable it to provide a claypan substrate that could pond water on a seasonal basis. Discussion of the VPFS habitat potential of the north and south drainage basins and the Calle Joaquin wetland follows below. Also, please refer to the historic aerial photographs included as Appendix A and site photographs in Appendix B for further detail. 4.1.1 Calle Joaquin Wetland The southwest side of the intersection of Los Osos Valley Road and Calle Joaquin contains a wetland community associated with the LOVR roadside drainage ditch, which was likely created or enlarged by alteration of natural topography when the roads were constructed, resulting in increased impoundment of surface and subsurface flow. Under the proposed Froom Ranch plan, this wetland would be in the portion of the property to remain as protected open space. A number of biological and hydrologic studies have been completed at this location for prior projects, including the Calle Joaquin Road realignment, and the LOVR/Highway 101 interchange project. Focused protocol level surveys for VPFS for the Calle Joaquin Road realignment did not locate the species in the wetland area. The 2015 wetland delineation completed by KMA reported that this area exhibited a dense cover of perennial wetland plants trending toward coastal and valley freshwater marsh habitat, Los Osos Valley RoadCalle J o a q u i n Irish Hills PlazaDrainage 1 Drainage 2 Drainage 3 Froom Creek Figure 4a Figure 4b MountainbrookChurch Irish Hills Natural Reserve Study Area Boundary CDFW Jurisdiction (5.41 acres) USACE Wetlands (7.25 acres) USACE Other Waters (2.66 acres) John Madonna Construction, Inc.0 200 400 600 800100Feet Wetland Delineation Overview Source(s): RRM Design Froom Ranch Figure 41 in = 350 ft £¤101 L o s O s o s V a l l e y R o a d ²1 in = 800 ft 0 530 1,060265Feet Figure 5 Soil Map JM Development Group, Inc. Froom Ranch Approximate Study Area Boundary Soil Type (NRCS Soil Survey) Cropley Clay, 0 to 2 percent slopes Diablo and Cibo clays, 9 to 15 percent slopes Diablo and Cibo clays, 15 to 30 percent slopes Los Osos-Diablo complex, 5 to 9 percent slopes Los Osos-Diablo complex, 15 to 30 percent slopes Obispo-Rock outcrop complex, 15 to 75 percent slopes Salinas silty clay loam, 0 to 2 percent slopes Xererts-Xerolls-Urban land complex, 0 to 15 percent slopes Corducci-Typic Xerofluvents, 0 to 5 percent slopes, occasionally flooded Source: ESRI 2017, USDA 2017 KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 13 indicating prolonged saturated soil conditions. The vegetation in the Calle Joaquin wetland area was: “…dominated by clustered field sedge, and included distinct areas of silverweed (Potentilla anserina - OBL), brown-headed rush (Juncus phaeocephalus - FACW), round-leaf leather root (Hoita orbicularis - OBL), and rough sedge (Carex senta - OBL). Ponded areas containing California bulrush (Schoenoplectus californicus - OBL), were present along portions of the property edge along Calle Joaquin.” (KMA 2015) The September 2017 field visits conducted for this vernal pool habitat assessment recorded these same dominant vegetation species, and surface ponding of between four and 18 inches was present in the area dominated by California bulrush. The 2015 wetland delineation concluded that this non-riparian wet meadow area dominated by wetland vegetation would be classified as Palustrine Emergent Wetland per Cowardin, and met the federal wetland criteria and falls under regulatory jurisdiction of the U.S. Army Corps of Engineers (KMA 2015; Cowardin et al. 1979; USACE 2008). The dominance of perennial wetland vegetation, observed surface ponding into September, as well as review of historical aerial photographs obtained from Google Earth, suggests that the Calle Joaquin wetland site functions as a semi-perennial to perennial wetland. In addition, during the field visits, a crayfish carcass between the south basin and the Calle Joaquin wetland ponded area provided supporting evidence of the semi-perennial ponding regime (USFWS 2015). If fairy shrimp cysts were introduced into the Calle Joaquin wetland by migrating wildlife or birds, and the pool was inoculated during a period when the pond went intermittently dry, the fairy shrimp population, if established, would likely be eventually decimated by predator species during subsequent wetter years with longer periods of ponding. Although there are exceptions, generally fairy shrimp species such as VPFS are absent from habitats supporting the abundance of predators expected in more permanent waters such as dragonfly larvae, notonectids, dysticid beetles, fish, crayfish; this includes the later stages of temporary habitats when the abundance of predators is usually at a maximum (Keeley and Zedler, 1998; USFWS 2015). Prior fairy shrimp surveys at this site that produced negative results support the conclusion that the Calle Joaquin wetland does not provide suitable fairy shrimp habitat. The 2004-05 protocol fairy shrimp surveys (wet and dry season) conducted at the Calle Joaquin wetland area as part of the Calle Joaquin Realignment Project found no VPFS or other listed vernal pool branchiopod species present (Thomas 2005). Although the footprint of the Calle Joaquin wetland as sampled in 2004-05 was somewhat altered by the subsequent road realignment project, the area continues to function as a semi-perennial to perennial wetland. 4.1.2 Stormwater Detention Basins Construction of the Irish Hills Plaza included two large stormwater detention basins, immediately adjacent to each other and separated by an earthen berm. The basins were constructed between mid-2006 and mid-2007. A temporary basin was also constructed to handle construction runoff before the larger basins were fully operable. After completion of construction of the Home Depot and surrounding areas, surface runoff from the Irish Hills Plaza development is now directed into the larger drainage basins, and the temporary basin was filled in and recontoured, and no longer has the capacity to pond water. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 14 The two currently active drainage basins, referred to here as “north basin” and “south basin” release overflow water to the LOVR Roadside Ditch via a storm drain outfall into a constructed swale. During large storm events, they are designed to discharge water into the wet meadow area along Calle Joaquin via a concrete spillway on the south side of the south drainage basin. Otherwise, water leaves the basins through evaporation and ground percolation. Google Earth historical aerial imagery indicates that these basins have been actively managed, with grading of the basins performed between April and August 2013, disturbing soil and removing vegetation (Appendix A: August 23, 2013). Under the proposed Froom Ranch development plan, these drainage basins would be removed, and runoff would be redirected into new constructed features including a larger basin proposed on the neighboring Mountainbrook Church property adjacent to Froom Creek. During the September 2017 habitat assessment field visits, the north basin featured shallow ponding (average 4-8 inches in depth) throughout much of the basin. Vegetation was dominated by obligate wetland plants such as cattail (Typha latifolia), spikerush (Eleocharis macrostachya) and small fruited bulrush (Scirpus microcarpus) along with brown-headed rush (Juncus phaeocephalus) and rabbitsfoot grass (Polypogon monspeliensis). The south basin was densely vegetated, but did not have ponded water or the predominance of obligate wetland plants, though signs of recent seasonal ponding were evident in the form of algal mats, cracked soil and surface salt deposits. Dominant vegetation included facultative wetland species such as creeping rye (Elymus triticoides), brown-headed rush, and reed fescue (Festuca arundinacea) with patches of cattails were present in several areas where saturation persists In the more barren patches exhibiting salt crust and/or algal mats from recent drying, prickly sow thistle (Sonchus asper; FAC) frequently occurred. Neither Congdon’s tarplant (Centromadia parryi ssp. congdonii) nor Hoover’s button celery (Eryngium aristulatum var. hooveri), which are both indicators of vernal pool or seasonal wetland habitat, were observed in either drainage basin. Historical aerial photos reviewed on Google Earth show that the north and south basins both dry out seasonally in most years. The high rainfall of 2016-17 may be responsible for the continued ponding seen in the north basin in early September 2017, as well as for ponding that appears to have lasted into the summer in the south basin, based on presence of algal mats and salt deposits. The wetland plant species currently dominating both basins suggest semi-perennial wetland hydrology, but aerial photos taken as recently as September 2016 show the vegetation in both basins as almost entirely brown, with no visible surface ponding. The pattern of seasonal drying shown in the historic aerial photos suggests that it is possible that the basins might have a hydrologic regime in many years that would provide suitable fairy shrimp habitat, even though the current year’s vegetation community is more typical of a semi-perennial wetland, which would be unsuitable habitat. The fact that the basins were constructed as recently as 2006-07, and then graded for maintenance in 2013, and are not hydrologically connected to existing fairy shrimp habitat, makes it unlikely that there has been time for fairy shrimp to be inoculated into the basins and to develop into a sustained population, even if a suitable hydrologic regime exists. Soil disturbance such as grading can easily bury or remove fairy shrimp cysts, and is generally considered incompatible with presence of a persistent fairy shrimp population. Based on the recent construction and management history of these two drainage basins, and the lack of direct connectivity with other fairy shrimp habitat, it is very unlikely that the basins support a population of listed branchiopods. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 15 4.1.3 Critical Habitat Designation The U.S. Fish and Wildlife Service designated critical habitat for VPFS in the region (Units 29C and 30, designated in 2006), but outside the five mile buffer around the study area. The proposed project area is not situated within a critical habitat unit, and no critical habitat attributes were observed within the study area. 5.0 CONCLUSION Based on field surveys and review of relevant background documents of the Froom Ranch site, three features were initially identified as having characteristics of a seasonal ponding and drying regime with the potential to support listed branchiopods: the north and south drainage basins, and the Calle Joaquin wetland. The north and south drainage basins were dominated by wetland vegetation at the time of field surveys in September 2017. Much of the north basin was still ponded with water, averaging four (4) to eight (8) inches in depth. The south basin was not ponded, but showed signs of recent drying in the form of salt deposits on the substrate surface, and much of the basin was dominated by wetland vegetation. These factors could suggest that the drainage basins have a semi-permanent wetland hydrologic regime; however, historic aerial photos show that, in most years since the basins were constructed, the basin vegetation was brown by end of summer, and no ponding is evident. It’s likely that the extent of wetland vegetation and ponding observed in September 2017 is an anomaly resulting from the exceptionally wet 2016-17 rain season, and that in most years the basins do dry out for a number of months, and in general have a seasonal ponding regime. However, both of the drainage basins were constructed within the past 11 years, and since they are not hydrologically connected to known fairy shrimp habitat, there has been limited time and opportunity for inoculation of the basins through wildlife transfer of cysts. In addition, the basins are actively managed to maintain holding capacity and, based on aerial photos, were subject to maintenance activities including grading in 2013. Inoculation and population establishment of fairy shrimp would therefore have had to occur after the 2013 grading. Given the lack of immediate proximity to existing fairy shrimp habitat and the ongoing maintenance activities in the drainage basins, it is considered very unlikely that the drainage basins provide habitat for listed species of branchiopods such as VPFS. The Calle Joaquin wetland had been sampled for listed branchiopods during 2004-05 and no fairy shrimp species were found to occur there. Historic aerial photos suggest that the Calle Joaquin wetland area remains moist or ponded throughout most years. KMA field surveys for this assessment found wetland vegetation dominant in the area subject to ponding, as well as hydric soils and evidence of presence of aquatic predator species generally considered incompatible with listed branchiopod populations. Based on these factors, the Calle Joaquin wetland is not considered potential habitat for listed species of branchiopods. 6.0 REFERENCES Baldwin, B. G., D. H. Goldman, D. J. Keil, R. Patterson, T. J. Rosatti, Editors. 2012. The Jepson Manual, Vascular Plants of California, Second Edition Thoroughly Revised and Expanded. University of California Press. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 16 California Department of Fish and Wildlife (CDFW). 2017. Natural Diversity Data Base of recorded occurrences of special-status species. Accessed September 2017. Cowardin, L.M., V. Carter V., F.C. Golet, E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service Report No. FWS/OBS/-79/31. Washington, D.C. Ericksen, C.H. and D. Belk. 1999. Fairy Shrimps of California’s Puddles, Pools, and Playas. Mad River Press. Eureka, California. Ferren, W.R., Jr., P.L. Fiedler, and R.A. Leidy. 1996a. Wetlands of California, Part I: History of Wetland Habitat Classification. In Madroño 1996 43(1):105-124. Ferren, W.R., Jr., P.L. Fiedler, R.A. Leidy, et al. 1996b. Wetlands of California, Part II: Classification and Description of Wetlands of the Central and Southern California Coast and Coastal Watersheds. In Madroño 1996 43(1):125-182. Helm, B. P. 1998. Biogeography of Eight Large Branchiopods Endemic to California. In Ecology, Conservation, and Management of Vernal Pool Ecosystems: Proceedings from a 1996 Conference. Witham, C.W., et. al., Editors. CNPS. Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Wildlife Nongame-Heritage Program. Holland, R. F., and S. lain. 1988. Vernal pools. Pages 515-533 in M. B. Barbour and I. Major, eds. Terrestrial vegetation of California, new expanded edition. California Native Plant Society, Special Publication Number 9, Sacramento, California. Hoover, R. 1970. Vascular Plants of San Luis Obispo County, California. Keeler-Wolf, Todd et al. 1998. California Vernal Pool Assessment Preliminary Report. Unpublished report prepared for the California Department of Fish and Game. Keeley, J.E., and P.H. Zedler. 1998. Characterization and Global Distribution of Vernal Pools. In Ecology, Conservation, and Management of Vernal Pool Ecosystems: Proceedings from a 1996 Conference. Witham, C.W., et. al., Editors. CNPS. Kevin Merk Associates, LLC. 2015. Froom Ranch, San Luis Obispo, California: Delineation of Waters of the United States and State of California. _______ 2016. Froom Ranch Project, San Luis Obispo County: Biological Resources Inventory. Marine Research Specialists. 2013. Chevron Tank Farm Remediation and Development Project Final Environmental Impact Report (FEIR). Prepared for the City and County of San Luis Obispo. Natural Resources Conservation Service (NRCS). 2015. Web Soil Survey. National Cooperative Soil Survey, U.S. Department of Agriculture. Accessed via: http://websoilsurvey.nrcs.usda.gov/app. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 17 Platenkamp, G. A. J. 1998. Patterns of Vernal Pool Biodiversity at Beale Air Force Base. In: C. W. Witham, E. T. Bauder, D. Belk, W. R. Ferren Jr., and R. Orduff (eds.). Ecology, Conservation, and Management of Vernal Pool Ecosystems − Proceedings from a 1996 Conference. Sacramento, CA: California Native Plant Society, Sacramento, CA. Pages 151–160. Sage Institute, Inc. 2013. Madonna Enterprises Vachell Lane Property 2013 Wet Season Vernal Pool Branchiopod Survey 90-Day Report. Sage Institute, Inc. 2014. Madonna Enterprises Vachell Lane Property 2013 Dry Season Vernal Pool Branchiopod Survey 90-Day Report. Sawyer, J. O., T. Keeler-Wolf, and J. M. Evens. 2009. A Manual of California Vegetation, 2nd Edition. California Native Plant Society, Sacramento, CA. Simovich, M.A. 1998. Crustacean Biodiversity and Endemism in California’s Ephemeral Wetlands. In Ecology, Conservation, and Management of Vernal Pool Ecosystems: Proceedings from a 1996 Conference. Witham, C.W., et. al., Editors. CNPS. United States Army Corps of Engineers. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0). ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-08-28. Vicksburg, MS: U.S. Army Engineer Research and Development Center. United States Department of Defense (U.S. DOD) National Guard Bureau and State of California Army National Guard. 1998. Protection and Monitoring of Vernal Pool Fairy Shrimp at Camp Roberts Army National Guard Installation: 1997-98 Annual Report. Submitted to U.S. Department of Interior Fish and Wildlife Service, Ventura, CA United States Fish and Wildlife Service (USFWS). 1994. Endangered and threatened wildlife and plants; Determination of Endangered Status for the Conservancy Fairy Shrimp, Longhorn Fairy Shrimp, and Vernal Pool Tadpole Shrimp, and Threatened Status for the Vernal Pool Fairy Shrimp. Federal Register, 59: 48136 48153 _______ 2003. Endangered and threatened wildlife and plants; Final Designation of Critical Habitat for Four Vernal Pool Crustaceans and Eleven Vernal Pool Plants in California and Southern Oregon. Federal Register 68: 46684 46732. _______ 2007. Vernal Pool Fairy Shrimp (Branchinecta lynchi) 5-Year Review: Summary and Evaluation. Sacramento Fish and Wildlife Service Office, Sacramento, CA. _______ 2015. Survey Guidelines for the Listed Large Branchiopods. Pacific Southwest Region, Sacramento, CA. APPENDIX A Historic Aerial Photograph Review KMA KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. APPENDIX A Historic Aerial Photos (Source: Google Earth) August 4, 2006 Before construction of drainage basins and Calle Joaquin Road reconstruction. Froom Creek visible to left. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. July 30, 2007 Newly constructed drainage basins. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. September 17, 2011 Vegetation cover and possible ponding visible in north basin; south basin well-vegetated with possible salt deposits on soil surface. Ponding visible in Calle Joaquin wetland. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. April 9, 2013 Both drainage basins well-vegetated. Calle Joaquin wetland ponded. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. August 23, 2013 Both drainage basins were recently graded, removing most vegetation from the basin floors, and disturbing soil. At Calle Joaquin wetland, no surface ponding is apparent. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. April 2, 2015 No ponding visible in either of the basins or the Calle Joaquin wetland. Approx. 50% vegetation cover visible in drainage basins. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. September 29, 2016 The north and south drainages are dry, with vegetation dry/dormant. Possible small area of ponding in the Calle Joaquin wetland. APPENDIX B Photo Plate KMA KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 1 APPENDIX B - PHOTO PLATE Photo 1. North drainage basin: Overview of basin, facing northeast. Photo 2. North drainage basin: View to northwest, taken from berm between north and south drainage basins, showing stand of cattails (Typha latifolia) on basin floor. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 2 Photo 3. North drainage basin: Transition from upland plant species such as coast golden bush (Hazardia squarrosa) growing on the berm to dominantly wetland vegetation on basin floor, including stand of cattails (Typha latifolia), as well as ponded water. Photo 4. South drainage basin: facing east from midpoint of berm between basins. Upland vegetation on the berm between the two drainage basins is in foreground, with greener basin floor vegetation below. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 3 Photo 5. South drainage basin: Overview facing south taken from approximate middle of berm between basins. Photo 6. South drainage basin: Example of representative vegetation on basin floor, primarily creeping ryegrass (Elymus triticoides). KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 4 Photo 7. South drainage basin: brown-headed rush (Juncus phaeocephalus), surrounding dried mud with salt deposits and prickly sow thistle (Sonchus asper). Photo 8. South drainage basin: small stand of cattails at northeast end in a dense carpet of creeping ryegrass. KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 5 Photo 9. South drainage basin: cracked mud and salt deposits indicate past ponding. Photo 10. Calle Joaquin wetland: southwesterly view of ponded water and stand of California bulrush (Schoenoplectus californicus) in shallow surface water. Area is surrounded by a mix of wetland vegetation with the non-native reed fescue (Festuca arundinacea). KMA Froom Ranch Specific Plan Project Vernal Pool Habitat Assessment JM Development Group, Inc. 6 Photo 11. Ditch from north basin draining water into the LOVR Roadside Ditch adding to surface water in the Calle Joaquin wetland. Photo 12. Crayfish carcass, a known predator of branchiopods and other native amphibians, on ground between south drainage basin and Calle Joaquin wetland. APPENDIX E.5 Wetland Delineation This Page Intentionally Left Blank. KMA Kevin Merk Associates, LLC P.O. Box 318, San Luis Obispo, California 93406 805.748.5837(o)/439.1616(f) Environmental Consulting Services August 4, 2015 Dr. Aaron Allen North Coast Branch Chief U.S. Army Corps of Engineers, Los Angeles District Regulatory Branch – Ventura Field Office 2151 Alessandro Drive, Suite 110 Ventura, California 93001 Subject: Request for Preliminary Jurisdictional Determination for the Froom Ranch Project, San Luis Obispo, California Dear Dr. Allen: On behalf of John Madonna Construction, Inc., Kevin Merk Associates is submitting this request to confirm the extent of U.S. Army Corps of Engineers (Corps) Section 404 (Clean Water Act) jurisdiction on the Froom Ranch project site located in San Luis Obispo, California. Enclosed please find one hard copy and one electronic copy of the report titled, Froom Ranch (APNs 067-‐241-‐030, 067-‐241-‐031) San Luis Obispo, California Delineation of Waters of the United States and State of California. In summary, the majority of potential Corps jurisdictional areas onsite are ephemeral drainage features located throughout the site. In addition, impoundment of surface and subsurface flow has created wetland features along both Los Osos Valley Road and Calle Joaquin. We are currently working with John Madonna Construction, their design team and the City of San Luis Obispo in planning future development of the site. We met with Ms. Erin Hanlon of your staff recently to introduce her to the proposed project. It is our hope to get your concurrence with the findings included in the delineation report so we may work with you to assess final impacts to Corps jurisdictional features resulting from future development, and apply for the appropriate Section 404 permit. Thank you in advance for your assistance with this project. Please don’t hesitate to contact me if you have any questions during your review. I will follow up within the next few days to schedule a field visit so you or your designated staff member may review this information first hand. Sincerely, Kevin Merk Associates, LLC Kevin Merk Principal Biologist Enclosed: Delineation of Waters of the United States and State of California for the Froom Ranch Project, San Luis Obispo, California (one hard copy and one electronic copy on CD) FROOM RANCH (APNs 067-‐241-‐030, 067-‐241-‐031) SAN LUIS OBISPO, CALIFORNIA DELINEATION OF WATERS OF THE UNITED STATES AND STATE OF CALIFORNIA Prepared for: Mr. John Madonna John Madonna Construction, Inc. P.O. Box 5310 San Luis Obispo, California 93405 Prepared by: KMA Kevin Merk Associates, LLC P.O. Box 318 San Luis Obispo, California 93406 August 2015 KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. i TABLE OF CONTENTS Page 1.0 INTRODUCTION ............................................................................................................................................................. 1 2.0 REGULATORY OVERVIEW AND DEFINITIONS ................................................................................................. 4 2.1 Federal Regulatory Authority ....................................................................................................................... 4 2.2 State Regulatory Authority ............................................................................................................................ 5 2.3 Criteria for Wetlands and Other Waters .................................................................................................. 5 3.0 METHODS .......................................................................................................................................................................... 6 4.0 RESULTS ............................................................................................................................................................................ 8 4.1 Site Overview ....................................................................................................................................................... 8 4.2 Vegetation .......................................................................................................................................................... 10 4.3 Soils ....................................................................................................................................................................... 12 4.4 Hydrology ........................................................................................................................................................... 15 4.5 Jurisdictional Determination Summary ................................................................................................ 16 5.0 CONCLUSION ................................................................................................................................................................ 21 5.1 Federal Waters ................................................................................................................................................. 21 5.2 CDFW Jurisdictional Areas .......................................................................................................................... 22 6.0 REFERENCES ................................................................................................................................................................ 23 LIST OF FIGURES Figure 1 – Site Location Map ................................................................................................................................................ 2 Figure 2 – Aerial Overview Map ......................................................................................................................................... 3 Figure 3 – Soils Map .............................................................................................................................................................. 14 Figure 4 – Wetland Delineation Overview Map ........................................................................................................ 18 Figure 4a – Wetland Delineation Map ........................................................................................................................... 19 Figure 4b – Wetland Delineation Map ........................................................................................................................... 20 LIST OF TABLES Table 1 – Sample Point Results Summary .................................................................................................................... 17 Table 2 – Summary of Jurisdictional Waters of the U.S. ......................................................................................... 22 Table 3 – Summary of CDFW Jurisdictional Areas ................................................................................................... 22 APPENDICES Appendix A – Wetland Determination Data Forms Appendix B – Photo Plate KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 1 1.0 INTRODUCTION Kevin Merk Associates, LLC (KMA) conducted a delineation of potential waters of the United States for the Froom Ranch in San Luis Obispo County, California. Located at the edge of the City of San Luis Obispo at the southwest side of Los Osos Valley Road (LOVR) near the intersection with Highway 101, the study area covers approximately 111 acres and is comprised of two parcels (APN 067-‐241-‐030, 067-‐241-‐031). It is composed primarily of undeveloped open space used primarily as grazing lands, and also contains existing buildings and an active mine in the northwestern part of the site. Existing development in the Irish Hills Plaza forms the northern site boundary. LOVR forms the eastern study area boundary and Calle Joaquin forms the southern boundary along with existing development including Mountainbrook Church and several hotels. Steep terrain that is part of the Irish Hills Natural Reserve forms the western boundary. Please refer to Figure 1, the Site Location Map, and Figure 2, the Aerial Overview Map for additional information. The delineation was conducted to determine the location and extent of features that meet the jurisdictional criteria for the following federal and state agencies: ¥ U.S. Army Corps of Engineers (Corps) criteria as waters of the United States, including wetlands, pursuant to Section 404 of the Clean Water Act (1972). ¥ Regional Water Quality Control Board (RWQCB) jurisdiction under Section 401 of the Clean Water Act, and under the Porter-‐Cologne Water Quality Act. ¥ California Department of Fish and Wildlife (CDFW) jurisdiction, under the California Fish and Game Code Section 1600 et seq. The preliminary jurisdictional determination used standard Corps methodology as detailed in Section 3.0. KMA also reviewed relevant background documents, recent and historic aerial photographs of the site, regional and site-‐specific topographic maps, Federal Emergency Management Agency Flood Maps, and U.S. Department of Agriculture soils data to better characterize the nature and extent of potential regulatory agency jurisdiction. This report is subject to review by the affected agencies and should be submitted to the Corps, CDFW, and RWQCB for verification during the permitting phase of the project. Portions of the site have been the subject of several environmental studies over the years, including wetland delineation efforts. Previous documents referenced during preparation of this report include: ¥ Madonna Eagle Hardware Environmental Impact Report (1998); ¥ Wetland Restoration and Mitigation Plans Relating to the Froom Ranch/Home Depot Project (Olberding Environmental, 2002); ¥ Calle Joaquin Realignment Wetland Delineation (Morro Group, 2004); ¥ Irish Hills Plaza II Wetland Delineation Map (Morro Group, 2004); ¥ Froom Ranch Wetland Assessment (Morro Group, 2005); ¥ Hydrologic Monitoring Plan for Sustaining a Separated Wetland Near Calle Joaquin (Balance Hydrologics, 2005); ¥ Irish Hills Plaza Detention Basin Report (Wallace Group, 2006); and ¥ Year 5 Wetland Monitoring Report for the Froom Ranch/Home Depot Site (Olberding Environmental, 2007). Site Location Froom Ranch Figure 1 0 2.5 5 7.5 101.25 Kilometers Sources: Sources: National Geographic, Esri, DeLorme, HERE, UNEP-WCMC, USGS, NASA, ESA, METI, NRCAN, GEBCO, NOAA, increment P Corp.© 2013 National Geographic Society, i-cubed 1 inch = 10,000 feet Site Location 0 100 20050 Kilometers John Madonna Construction, Inc.Site Location Froom Ranch John Madonna Construction, Inc. Figure 2 Aerial Overview Sources: (c) ESRI and its data providers; City of San Luis Obispo Study Boundary 0 125 250 37562.5 Meters 1 inch = 1,500 feet KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 4 2.0 REGULATORY OVERVIEW AND DEFINITIONS 2.1 Federal Regulatory Authority The U.S. Army Corps of Engineers (Corps), under provisions of Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act, has jurisdiction over “waters of the United States” and authorization to issue permits for the discharge of dredged or fill material into “waters of the U.S.” “Waters of the U.S.” are defined to include: all waters used in interstate or foreign commerce, including all waters subject to the ebb and flow of the tide; all interstate waters and wetlands; all other waters such as intrastate lakes, rivers, streams, mudflats, sandflats, wetlands, sloughs, wet meadows, playa lakes, or natural ponds, that could affect interstate or foreign commerce; all impoundments of waters otherwise defined as “waters of the U.S.”; tributaries of waters otherwise defined as “waters of the U.S.”; territorial seas; and wetlands adjacent to “waters of the U.S.” Waters generally not considered to be Corps-‐jurisdictional include non-‐tidal drainage and irrigation ditches excavated on dry land, artificially-‐irrigated areas, artificial lakes or ponds excavated on dry land used for irrigation or stock watering, small artificial water bodies such as swimming pools, and water filled depressions (51 Fed. Reg. 41, 217 1986). In 2001, the Supreme Court (Solid Waste Agency of Northern Cook County v. U.S. Army Corps of Engineers) ruled that the Corps exceeded its statutory authority by asserting Clean Water Act jurisdiction over “an abandoned sand and gravel pit in northern Illinois, which provides habitat for migratory birds.” The Supreme Court determined that “non-‐navigable, isolated, intrastate” waters were not subject to federal jurisdiction based solely on the use of such waters by migratory birds (i.e., solely invoking the “Migratory Bird Rule” was insufficient justification) (Guzy/Anderson 2001). The Supreme Court further addressed the extent of the Corps’ jurisdiction in the consolidated cases Rapanos v. United States and Carabell v. United States (June 19, 2006), referred to as “Rapanos.” In Rapanos, a sharply-‐divided Court issued multiple opinions, none of which garnered the support of a majority of Justices. This created substantial uncertainty as to which jurisdictional test should be used in routine jurisdictional determinations. The Ninth Circuit Court of Appeal, which encompasses California, answered this in Northern California River Watch v. City of Healdsburg (August 11, 2006). In this case, the Court held that Justice Kennedy’s opinion in Rapanos provided the controlling rule of law. Under that rule, wetlands or other waters that are not in fact navigable are subject to Corps jurisdiction if they have “a (significant nexus) to waters that are navigable in fact.” Presence of a “significant nexus” must be decided on a case-‐by-‐case basis, depending on site-‐ specific circumstances. The U.S. Environmental Protection Agency (EPA) and Corps subsequently developed an instructional guidebook on how to apply these rulings for all future jurisdictional determinations (U.S. Army Corps of Engineers and U.S. EPA 2007), and a memorandum providing guidance to implement the Supreme Court’s decision in Rapanos (Grumbles and Woodley 2007). Waters of the U.S. determined by KMA to be under the jurisdiction of the EPA and Corps under the Clean Water Act have thus conformed to the instructional guidebook and memorandum providing guidance to implement the U.S. Supreme Court’s decision in Rapanos. Delineated wetland features that are not adjacent to (i.e., bordering, contiguous, or neighboring) a traditional navigable water (TNW) or abutting a relatively permanent water (RPW) that is tributary to a TNW are not likely to be subject to federal jurisdiction and are thus determined to not be subject to federal jurisdiction. It KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 5 is advised to note that the U.S. Supreme Court determined that jurisdictional waters of the U.S. shall be determined on a case-‐by-‐case basis, by the Corps (and EPA), based on a determination of whether a particular wetland or “other water” has a “significant nexus” to a TNW. To summarize, the jurisdictional status determination for each potential water of the U.S. feature was evaluated individually in accordance with the Rapanos guidance as follows. If the feature did not have a hydrologic surface connection to a TNW (e.g., a seasonally inundated wetland abuts an RPW and subject RPW conveys surface water to a TNW) or did not demonstrate a “significant nexus” to a TNW, it was not considered subject to federal jurisdiction. This report describes the features on the property that exhibit the physical characteristics of wetlands or other waters and documents the maximum areal extent of such features that may qualify as “waters of the United States” and be subject to Corps jurisdiction. The aforementioned federal rulings do not alter the extent of State jurisdiction over “waters of the State” (which are subject to Regional Water Quality Control Board [RWQCB] jurisdiction), or “rivers, lakes or streams” subject to California Department of Fish and Wildlife (CDFW) jurisdiction. State regulatory authority over wetlands and other waters are discussed in the following section. 2.2 State Regulatory Authority The State Water Resources Control Board and nine Regional Water Quality Control Boards (RWQCB) regulate discharges of fill and dredged material in California, under Section 401 of the Clean Water Act, and under the State Porter-‐Cologne Water Quality Control Act, through the State Water Quality Certification Program. State Water Quality Certification is necessary for all projects that require a Corps permit, or fall under other federal jurisdiction, and have the potential to impact waters of the State. Waters of the State are defined by the Porter-‐Cologne Act as: “. . . any surface water or groundwater, including saline waters, within the boundaries of the state.” In order for a Section 404 (Corps) permit to be valid, Section 401 of the Clean Water Act requires a Water Quality Certification or waiver to be obtained. The Water Quality Certification (or waiver) determines that the permitted activities will not violate water quality standards individually or cumulatively over the term of the action. Water quality certification must be consistent with the requirements of the Federal Clean Water Act, California Environmental Quality Act (CEQA), California Endangered Species Act, and Porter-‐Cologne Act. The CDFW has regulatory authority over any work within rivers, lakes and streams in the State of California (California Fish and Game Code Sections 1601-‐1603) on public, private and agricultural lands. Features that are regulated by the CDFW include all rivers, streams, or lakes including man-‐ made watercourses with or without wetlands, if they contain a definable bed and bank and support fish or wildlife resources or contribute to that support. The riparian vegetation associated with rivers, streams, and lakes is also typically included within the CDFW jurisdiction. 2.3 Criteria for Wetlands and Other Waters Hydrophytic vegetation occurs in areas where frequency and duration of inundation and/or soil saturation exerts a primary controlling influence on plant species composition. Plant species are assigned a wetland indicator status according to the probability of occurrence in wetlands. More KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 6 than fifty percent of the dominant plant species must have a wetland indicator status of Facultative, Facultative Wetland, or Obligate Wetland to meet the hydrophytic vegetation criterion. The National Wetland Plant List: 2014 Update of Wetland Ratings (NWPL), separates vascular plants into the following four basic categories based on plant species frequency of occurrence in wetlands: ¥ Obligate wetland (OBL). Occur almost always (estimated probability >99%) under natural conditions in wetlands. ¥ Facultative Wetland (FACW). Usually occur in wetlands (estimated probability 67%-‐99%), but occasionally found in non-‐wetlands. ¥ Facultative (FAC). Equally likely to occur in wetlands or non-‐wetlands (estimated probability 34%-‐66%). ¥ Facultative Upland (FACU). Usually occur in non-‐wetlands (estimated probability 67%-‐ 99%), but occasionally found in wetlands (estimated probability 1%-‐33%). ¥ Obligate Upland (UPL). May occur in wetlands in another region, but occur almost always (estimated probability >99%) under natural conditions in non-‐wetlands in the region specified. An area is considered to have hydrophytic vegetation when greater than 50 percent of the dominant species in each vegetative stratum (tree, shrub, and herb) are assigned with the FAC, FACW, and/or OBL status categories. Any species not appearing on the NWPL is assumed to be an upland species. Hydric soils occur in areas that are saturated and/or inundated for a sufficient duration during the growing season to develop anaerobic or reducing conditions. Sufficient duration cannot be defined due to the vast differences in chemistry and mineral composition in soils from site to site and region to region, but can be as short as two weeks during the growing season. Field indicators of hydric soils include, but are not limited to observation of redoximorphic features (e.g., concentrations of oxidized minerals such as iron) and detection of hydrogen sulphide gas. Documentation of a soil as hydric must be verified in the field. Wetland hydrology typically occurs in areas subject to inundation and/or soil saturation with a frequency and duration long enough to cause the development of hydric soils and plant communities dominated by hydrophytic vegetation. If direct observation of wetland hydrology is not possible (as in seasonal wetlands) or records of wetland hydrology are not available (such as stream gauges), assessment of wetland hydrology is frequently supported by primary and secondary indicators such as surface soil cracks and drainage patterns. Ordinary High Water Mark (OHWM) is the line on the shore or bank of an other waters feature that is established by fluctuations and/or flow of water. The OHWM is located through examination of physical characteristics such as a clear natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, and other appropriate physical characteristics that consider the nature of the surrounding area. 3.0 METHODS KMA principal biologist Kevin Merk and senior biologist Bob Sloan conducted the delineation of potential Corps “waters of the United States,” RWQCB “waters of the State,” and CDFW jurisdictional areas on the study area during February and March, 2015. The delineation used the routine methodology as detailed in the Corps of Engineers Wetlands Delineation Manual (Environmental KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 7 Laboratory 1987) and refined in the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0; U.S. Army Corps of Engineers 2008). The Classification of Wetlands and Deepwater Habitats of the United States (Cowardin 1979) and Wetlands of the Central and Southern California Coast and Coastal Watershed: A Methodology for Their Classification (Ferren et al. 1995) were also utilized to assist in characterizing on-‐site wetlands, other waters, and other potential jurisdictional areas. KMA biologists also reviewed recent and historical aerial photographs depicting the study area (ESRI and Google Earth 2015), the U.S. Geological Survey (USGS) San Luis Obispo, California 7.5-‐minute topographic quadrangle (U.S. Geological Survey 1993), the Soil Survey for San Luis Obispo County, California (National Resources Conservation Service), and the Hydric Soils List for San Luis Obispo County, California to better determine the nature and extent of Corps, RWQCB, and CDFW jurisdictional areas on the site. All potential waters of the U.S. on the study area were mapped based on the presence of positive indicators for hydrophytic vegetation, hydric soils and wetland hydrology for wetlands, and presence of an OHWM pursuant to Corps regulations (33 CFR 328.3 and 33 CFR 328.4) for other waters. The final determination of potential waters of the U.S. within the site was based on the presence of connectivity to a TNW. CDFW jurisdiction was determined based on the extent of the bed and bank or riparian canopy associated with Froom Creek, it’s tributary channels, and the LOVR roadside channel. Data observation points were placed in representative potential wetland features and adjacent upland areas to characterize the extent of federal and State jurisdiction (i.e., identify the wetland edge). Information recorded at each data point location included plant species composition (to determine the presence/absence of hydrophytic vegetation), presence/absence of indicators of wetland hydrology, and in areas containing potential wetland habitat, indicators of hydric soils in accordance with Field Indicators of Hydric Soils in the United States (U.S. Department of Agriculture, Natural Resources Conservation Service 2006). A soil pit was excavated at each data observation point, to examine the soil for positive indicators of hydric soils and wetland hydrology. Soil pits were excavated to a depth of 14-‐18 inches during the delineation. Hydric soils were presumed absent in areas devoid of hydrophytic vegetation and lack of direct observation of any hydrologic indicators. Positive evidence of wetland hydrology was evaluated in the field, and included observable indicators, such as drainage patterns, saturated soils in the upper 18 inches and the presence of oxidized rhizospheres. Colors of moist soils and redoximorphic features were compared with the Munsell® soil color chart and recorded on wetland determination data forms. Transect locations across the Los Osos Valley Road and Calle Joaquin wetland and meadow areas were based on data point locations documented in the Calle Joaquin Realignment Wetland Delineation (Morro Group, 2004); and Froom Ranch Wetland Assessment (Morro Group, 2005). A data point was considered to be within a Corps-‐defined wetland (an “in” point) if the area contained all three wetland parameters or criteria, which included a dominance of wetland plant species, positive wetland hydrology indicators, and presence of hydric soil indicators. If one or more of these parameters was not met, the point was considered to not be within a Corps-‐defined wetland (an “out” point) and a line was drawn between the two data points. Federal and State jurisdictional areas were delineated in the field using a Trimble GEOXH 6000 capable of decimeter accuracy. Data collected in the field was plotted on a site specific topographic map provided by RRM Design Group. Area calculations of waters of the U.S. and state of California, as well as CDFW jurisdictional areas, were made using ARC GIS 10 (ESRI). KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 8 4.0 RESULTS A total of 24 data observation points were established to document potential waters of the U.S. and State of California on the site. Approximately 7.25 acres of wetlands (Palustrine Emergent Wetland) and 2.66 acres of other waters (Riverine Intermittent Streambed) were determined to fall under the jurisdiction of the Corps and RWQCB pursuant to the Clean Water Act. A total of 5.41 acres of the site were determined to fall under CDFW jurisdiction. Figure 3 is a soils map illustrating the soil map units present onsite and the immediate surrounding area. Figures 4, 4a and 4b are the wetland delineation map that show data point locations and illustrates the extent of Corps, RWQCB, and CDFW jurisdictional areas onsite. Appendix A contains the Wetland Determination Data Forms and Appendix B is a photo plate with representative photographs of the study area. 4.1 Site Overview The study area consists primarily of grassland habitat on heavy clay soils in the flatter portions of the site between Froom Creek and LOVR and Calle Joaquin. Serpentine-‐based soils and rock outcrops are present in the higher elevation areas. Seasonal drainage features including Froom Creek and several small tributary drainages, the LOVR roadside channel, seasonal and perennial wetlands, coast live oak woodland with California bay trees, areas of coastal scrub/serpentine chaparral, and non-‐native eucalyptus trees are also present. The study area contains two man-‐ made stormwater detention/retention basins present between the Froom Creek channel and the mapped seasonal wetland areas along LOVR. The larger basin was constructed to receive surface runoff from the Irish Hills Plaza development to the northwest, and the smaller retention basin was constructed as a temporary feature during construction of Home Depot. Froom Creek Froom Creek is an intermittent stream with a relatively small watershed that originates in the Irish Hills to the southwest of the study area. The creek channel bisects the study area in a generally north to south direction, and ultimately passes beneath Calle Joaquin and U.S. Highway 101 via two concrete box culverts, heading to its confluence with San Luis Obispo Creek. San Luis Obispo Creek flows in a westerly direction ultimately connecting to the Pacific Ocean at Avila Beach. Due to the lack of dominant wetland vegetation within or adjacent to the channel, Froom Creek was classified as Riverine Intermittent Streambed per Cowardin, and as non-‐wetland waters of the U.S. and state of California subject to Corps, RWQCB and CDFW jurisdiction. Froom Creek Tributaries Three small ephemeral drainage features (identified as Drainages 1, 2, and 3) are present in the southwestern portion of the study area that are tributaries to Froom Creek. Due to the presence of a defined bed and bank, OHWM, and hydrologic connectivity to Froom Creek, these small features were classified as Riverine Intermittent Streambed per Cowardin, and constitute jurisdictional non-‐ wetland waters of the U.S. and state of California. While these drainages were mostly comprised of upland vegetation, areas of wetland and riparian habitat were observed and mapped in specific locations. In addition, several seeps or springs were observed originating on adjacent hillsides and were hydrologically connected to the drainage feature. In-‐channel areas and abutting areas dominated by wetland vegetation are classified as Palustrine Emergent Wetland per Cowardin, and are expected to constitute wetlands under Corps, RWQCB and CDFW jurisdiction. The federally KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 9 protected Chorro Creek bog thistle (Cirsium fontale var. obispoense) was also identified in two of the tributary drainages. LOVR Roadside Channel The LOVR Roadside Channel is located along the northern property boundary, and contains a dense willow canopy and wetland understory, along a narrow and shallow constructed channel area. The willow canopy has developed over the last 10 years since the 2005 Wetland Delineation was completed by Morro Group, and the channel appears to have lost capacity due to vegetative growth and sediment accumulation. Current channel dimensions in this area ranged from six inches to two feet deep, and one to four feet wide. Willow canopy and wetland vegetation extended beyond the channel banks into the meadow area, apparently the result of the constructed roadways impounding seasonal surface and subsurface water. Because the majority of in-‐channel and abutting areas are dominated by wetland vegetation, the LOVR channel is classified as Palustrine Emergent Wetland per Cowardin, and is expected to constitute wetlands under Corps, RWQCB and CDFW jurisdiction. Jurisdictional boundaries in this area extend into the LOVR right-‐of way to the road shoulder, which was outside the Froom Ranch property line. Wet Meadow Areas The low-‐lying portion of the site between Froom Creek and the LOVR Roadside Channel/Calle Joaquin is relatively flat, composed of heavy clay soils, and contains areas of annual grassland and perennial grassland dominated by non-‐native species such as Italian ryegrass and reed fescue. Patches of wetland plants were present indicating seasonal impoundment of surface and groundwater by the constructed roadways. Based on aerial photograph interpretation and review of soils, Froom Creek likely traversed through this part of the site prior to connecting with Prefumo Creek and then joining San Luis Obispo Creek in the vicinity of the LOVR Interchange. While areas near LOVR consisted primarily of seasonally moist areas dominated by annual grassland species, areas mapped as wetland along the realigned portion of Calle Joaquin exhibited a more dense cover of perennial wetland plants trending more toward coastal and valley freshwater marsh habitat, which indicates prolonged saturated soil conditions compared to areas along LOVR. Non-‐riparian wet meadow areas dominated by wetland vegetation, are classified as Palustrine Emergent Wetland per Cowardin, and are expected to constitute wetlands under Corps jurisdiction. Detention Basins The northern basin is an approximately one-‐acre temporary basin constructed in upland grassland areas to receive runoff during the construction of Home Depot. During construction of the Irish Hills Plaza, a swale and culverts were installed behind the current Whole Foods and TJ Max buildings to direct surface runoff into this basin and then let it spread overland to support the historic wetland feature in the area. Seasonally ponded water was evident in the basin during aerial photograph review, and patchy occurrences of seasonal wetland vegetation were noted during recent field work confirming some wetland habitat attributes are still present. However, it is our understanding that once the Home Depot and surrounding areas were constructed, surface runoff from this development was directed into the larger basins constructed further south. As a result, this temporary basin was not identified as a potential jurisdictional feature since it was constructed in an upland as a temporary basin to support construction of the neighboring project. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 10 The approximately 3.2-‐acre southern basin is a permanent feature constructed in upland grassland habitat to receive runoff from the Plaza Hills I development fronting LOVR. Following development of the Home Depot project, surface runoff was then directed into this basin. It consists of two basins and a spillway, and was sized to contain runoff from any future Phase II development within the study area (Wallace Group, 2006). This basin releases water to the LOVR Roadside Channel by a storm drain and swale. During large storm events, it was designed to discharge water into the wet meadow area along Calle Joaquin via a concrete spillway. Otherwise, water leaves the basin through evaporation and percolation into the ground. This feature was also not identified as a potential jurisdictional feature since it was constructed in an upland area and is part of the neighboring project’s storm drainage system. Both basins are man-‐made structures constructed in uplands, fed primarily by concentrated hardscape runoff from neighboring development. Removing the water source to either basin would likely result in the loss of wetland hydrology, indicating that both basins function as "spigot wetlands", not as natural features. As such, these basins and associated swales are not expected to be subject to Clean Water Act or California Fish and Game Code requirements, and were not delineated in this report. Previously Restored Wetland Areas As mapped by Morro Group in 2005 and as discussed in the Olberding Environmental 2007 Final Mitigation report, a total of 0.62-‐acre of seasonal wetland habitat was restored to pre-‐impact conditions within the northern portion of the study area, following unauthorized grading and stockpiling of soils during construction activities associated with Home Depot. The restoration areas consist of a 0.36-‐acre swale located along the Ranch House road between the temporary basin and the LOVR Roadside Channel, and a 0.26-‐acre area between the Ranch House road and the Irish Hills Plaza parking lot. Please refer to Data Points 16 and 17, respectively. These areas were restored to original contours following removal of unauthorized fill materials, and were then allowed to return to natural conditions. Based on our understanding, no seeding, revegetation, or other enhancement actions were performed, and no conservation easement or other restrictions were placed on the sites. The two sites were included in the mitigation monitoring program required by the Wetland Restoration and Mitigation Plans Relating to the Froom Ranch/Home Depot Project (Olberding Environmental, 2002), and following a verification visit conducted on February 12, 2015, the Corps determined that both sites had met all required performance standards. Currently, both restoration sites are dominated by grassland habitat, and do not exhibit wetland vegetation, soils, or hydrology. However, as stated in the Corps Determination of Compliance letter dated February 19, 2015, the sites are still subject to long-‐term management requirements per the 2002 Mitigation Plan. 4.2 Vegetation Froom Creek and Tributaries The Froom Creek channel was mostly unvegetated, and where present, vegetation consisted primarily of annual grasses, forbs and shrubs common to grassland, coastal scrub and serpentine influenced areas. The smaller tributary channels to Froom Creek in the southwestern part of the site were dominated primarily by grassland species such as Italian rye grass with patches of wetland vegetation. Drainages 1 and 2 also contained areas of coast live oak (Quercus agrifolia) and KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 11 California bay (Umbellularia californica) trees. Wetland indicator species present in this area included brown-‐headed rush (Juncus phaeocephalus -‐ FACW), clustered field sedge (Carex praegracilis -‐ FACW), and common rush (Juncus effusus -‐ FACW). A small seep in Drainage 3, and a larger spring fed wetland area at the confluence of Drainages 1 and 2, contained dominant cover of water parsley (Oenanthe sarmentosa -‐ OBL), spike rush (Eleocharis macrostachya – OBL), and brown-‐headed rush, along with seep spring monkeyflower (Mimulus guttatus -‐ OBL), and western vervain (Verbena lasiostachys -‐ FAC). Upper reaches of Drainages 1 and 2 also contained occurrences of the federally protected Chorro Creek bog thistle (Cirsium fontinale var. obispoense), which is an obligate wetland species. A large seep area extends north from Drainage 2 along a hillside, and is dominated by clustered field sedge and spike rush. Portions of this area demonstrated tussock formation resulting from grazing impacts. The upland areas associated with the Froom tributaries were dominated by annual and perennial grasses and forbs, and included areas of native serpentine bunchgrass composed of purple needlegrass (Stipa pulchra). Other native species observed in upland grassland areas included red maids (Calandrinia ciliata), star lily (Zigadenus fremontii), hayfield tarweed (Hemizonia congesta ssp. luzulifolia), and blue dicks (Dichelostemma capitatum). Wet Meadow Areas Wet meadow areas adjacent to the LOVR channel were dominated by clustered field sedge, Italian ryegrass (Lolium perenne ssp. multiflorum -‐ FAC), saltgrass (Distichlis spicata -‐ FAC), meadow barley (Hordeum brachyantherum -‐ FACW), brown headed rush, spikerush, birdsfoot trefoil (Lotus corniculatus -‐ FAC), curly dock (Rumex crispus -‐ FAC), bristly ox tongue (Helminthotheca echioides -‐ FACU), and Bermuda grass (Cynodon dactylon -‐ FACU). Meadow areas upslope from the LOVR channel were dominated by Italian rye grass, foxtail (Hordeum marinum -‐ FACU), ripgut brome (Bromus diandrus -‐ UPL), mayweed (Anthemis cotula -‐ FACU), slender wild oat (Avena barbata -‐ UPL), storksbill (Erodium botrys -‐ FACU), perennial mustard (Hirschfeldia incana-‐ UPL), and red brome (Bromus madritensis ssp. rubens -‐ FACU). Areas adjacent to Calle Joaquin were dominated by clustered field sedge, and included distinct areas of silverweed (Potentilla anserina -‐ OBL), brown-‐headed rush, round-‐leaf leather root (Hoita orbicularis -‐ OBL), and rough sedge (Carex senta -‐ OBL). Ponded areas containing California bulrush (Schoenoplectus californicus -‐ OBL), were present along portions of the property edge along Calle Joaquin. Meadow areas upslope from Calle Joaquin were dominated by clustered field sedge, tall fescue (Festuca or Schedonorus arundinaceae -‐ FACU), Italian ryegrass, meadow barley, prickly lettuce (Lactuca serriola -‐ FACU), and red maids (Calandrinia ciliata -‐ FACU). Many areas of the site contained the introduced annual Italian ryegrass, which is classified as a facultative plant (equally likely to occur within wetland or upland). The California Invasive Plant Council (Cal-‐IPC) Inventory Rating for Italian ryegrass is Moderate (having substantial and apparent—but generally not severe—ecological impacts on physical processes, plant and animal communities, and vegetation structure). Italian ryegrass is widespread in California due to use as a planted forage species and for erosion control, and is found in coastal valley and foothill grasslands throughout the state. It germinates and grows in seasonally moist soil conditions, but also grows strongly in dry conditions on clay soils. It is never found in long-‐term saturated soil conditions with strong hydrophytic indicator KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 12 species, but is sometimes found in or near the upper edge of seasonally wet areas. Because of these characteristics, reliance on the dominance of Italian ryegrass to determine wetland presence could result in an erroneous interpretation of wetland status. Several Sample Points located in the upper meadow areas documented Italian ryegrass as a co-‐dominant species with clustered field sedge, resulting in 100 percent hydrophytic vegetation cover in locations with no wetland hydrology features. In several cases the Data Form Prevalence Index worksheet results confirmed that these Italian ryegrass-‐dominated areas were functioning as upland habitat, despite having passed the Dominance Test. LOVR Roadside Channel The LOVR roadside channel contained a dense band of riparian habitat consistent with the Central Coast Arroyo Willow Riparian Scrub plant described by Holland (1986), and the arroyo willow thickets described by Sawyer et al. (2009). The riparian woodland habitat is dominated by arroyo willow (Salix lasiolepis -‐ FACW). Understory plants present within the riparian area included California blackberry (Rubus ursinus -‐ FAC), tall flatsedge (Cyperus eragrostis -‐ FACW), water speedwell (Veronica anagallis-‐aquatica -‐ OBL), Italian thistle (Carduus pycnocephalus -‐ UPL), Fuller’s teasel (Dipsacus fullonum -‐ FAC), and poison hemlock (Conium maculatum -‐ FACW). The roadside ditch had a relatively consistent understory cover that continued into the wet meadow areas. 4.3 Soils The NRCS identified eight soil map units as occurring on the study area (refer to Figure 3). Of these map units, Riverwash, and Xererts-‐Xerolls are listed as hydric soils by the NRCS California Hydric Soils List for San Luis Obispo County. An unnamed component of Cropley clay, 0-‐2 % slopes, is also considered hydric, when present in drainageways. Cropley clay 0-‐2 % slopes. Cropley clay consists of a dark gray or black (10YR 4/1, 3/1, 2/1 moist) clay horizon about 36 inches thick, underlain by a light brown calcareous clay loam to 60 inches or more. Permeability of this soil is slow and the available water capacity is high. Cropley soils formed in alluvium developed from sedimentary rocks. An unnamed component of Cropley clay is listed as a hydric soil when present in drainageways. This inclusion is typically very dark gray throughout, with mottles present in the lower horizons. This dark gray soil was not observed on-‐ site. Mapped inclusions within this series include Diablo clay, Los Osos loam, and Salinas silty clay loam. Diablo and Cibo clays 9-‐15 and 15 -‐ 30 % slopes. Diablo clay consists of a 0 to 23 inch, black (10YR 2/1) clay formed in residual material weathered from sandstone, shale, or mudstone, commonly displaying fine roots to four inches. The structure is granular to 4 inches, and coarse, angular, and blocky to 23 inches. This moderately to steeply sloping soil is very poorly drained. The soil has moderate erodibility and high shrink-‐swell characteristics, and has potential septic system constraints due to steep slopes and slow percolation. Cibo clay consists of a 0 to 31 inch, dark brown (7.5YR 3/2) clay formed in residual material weathered from hard metasedimentary rocks, and commonly displaying fine roots. The structure is coarse and angular blocky. This moderately to steeply sloping soil is considered very poorly drained. The soil has moderate erodibility and high shrink-‐swell characteristics, and potential septic system constraints due to steep slopes, shallow depth to bedrock, and slow percolation. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 13 Los Osos-‐Diablo Complex 5-‐9 and 15-‐30 percent slopes. Los Osos-‐Diablo Complex consists of about 40 percent Los Osos soil, and 35 percent Diablo soil, found on foothills and mountain ridge tops. These soils are moderately deep, well drained, and have low permeability. Typical Los Osos-‐Diablo Complex soil (moist) consists of a very dark grayish brown (10YR 3/2) loam or black (10YR 2/2) clay, 40-‐60 inches thick. Permeability of Los Osos-‐Diablo Complex soil is rapid, and the available water capacity is low. The available water capacity of Los Osos-‐Diablo Complex soil is low to very high, while surface runoff is rapid. Obispo-‐Rock outcrop 15-‐75% slopes. Obispo-‐Rock outcrop consists of about 50 percent Obispo soil and 30 percent Rock outcrop. Obispo soils are shallow, well drained, slowly permeable soils formed in residual materials weathered from serpentine rock. Typical Obispo soil (moist) consists of a black (10YR 2/1) clay to a depth of about 18 inches, underlain by serpentine rock. The available water capacity of Obispo-‐Rock outcrop soil is low, while surface runoff is rapid or very rapid. Riverwash includes soils found in active stream and river channels, and consists of excessively drained, water deposited sand, loamy sand, and sandy loam with varying amounts of gravel and cobbles present. Riverwash soils located in and along stream channels are generally subject to flooding during and immediately after every storm. Riverwash soils are typically excessively drained, but can be somewhat poorly drained in low lying areas. Permeability is very rapid, surface runoff is very slow, and the erosion hazard is variable. Typical inclusions include Psamments and Fluvents, and Corralitos soils. Riverwash and Psamments and Fluvents located in drainageways are listed as hydric soils. These soils have a Hydric Criteria Code of 4: soils that are frequently flooded for long or very long duration during the growing season. Xererts-‐Xerolls-‐Urban land complex 0-‐15% slopes. The Xererts-‐Xerolls-‐Urban land complex consists of nearly level to strongly sloping soils and miscellaneous areas that are covered by urban structures. Most areas of these soils are used for urban development. The soil materials have been modified by earthmoving equipment or covered by urban structures so that much of their original shape and physical characteristics have been altered. The Xererts of this complex are Cropley or Los Osos-‐Diablo soils. The percentage of the various soils in this complex and the degree of urbanization vary from place to place (SCS 1984). An unnamed inclusion of the Xererts-‐Xerolls-‐ Urban land complex associated with depressions has a Hydric Criteria Code of 2A: soils in Aquic suborder that are somewhat poorly drained and have a frequently occurring water table less than 0.5 feet from the surface for a significant period (usually 14 consecutive days or more) during the growing season. Observed Soil Conditions The upper 14-‐18 inches of the soil profile were examined at 24 sample points to determine presence or absence of positive indicators for hydric soils, and to determine if the soil map units mapped and described by the NRCS were consistent with observed soil characteristics. In addition to the 24 soil pits dug at sample points, three backhoe pits were dug above, below, and adjacent to the hillside seep area between Drainage 2 and Drainage 3, to examine subsoil conditions and assess hydrology and connectivity with the abutting drainage feature. Study Area Boundary Soil Type Cropley clay, 0 to 2 percent slopes Diablo and Cibo clays, 15 to 30 percent slopes Diablo and Cibo clays, 9 to 15 percent slopes Los Osos-Diablo complex, 15 to 30 percent slopes Los Osos-Diablo complex, 5 to 9 percent slopes Obispo-Rock outcrop complex, 15 to 75 percent slopes Riverwash Salinas silty clay loam, 0 to 2 percent slopes Xererts-Xerolls-Urban land complex, 0 to 15 percent slopes 0 230 460 690 920115Feet Soils Map Figure 3Froom Ranch Source(s): (c) Microsoft Corporation and its data suppliers (2010): NRCS, SLO County Soils Data (2008) John Madonna Construction, Inc. 1 in = 400 ft KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 15 Soils observed on the site were generally clayey and often gravelly, with moist and saturated clays present within portions of Drainages 1, 2, and 3, and near the LOVR roadside channel and Calle Joaquin. Areas identified as wetlands occurred in Los Osos-‐Diablo, Cropley, and Diablo and Cibo soils. Non-‐wetland waters were found associated with all soil types present in the study area. Hydric soil criteria per the 2008 Arid West Manual were observed in most of the soil pit locations with dominant wetland vegetation. Several additional pits exhibited redoximorphic features that were either too faint, or too deep to meet one of the Arid West criteria. Previous delineations conducted in 2004 and 2005 classified soils as hydric if redoximorphic features were observed anywhere within the profile. This lower standard for hydric soil criteria, combined with wetter conditions and more vegetative diversity, may have influenced the larger wetland boundary lines mapped in the meadow areas along LOVR in 2004 and 2005. 4.4 Hydrology Froom Creek flows east and then south through the site, before entering San Luis Creek on the south side of Highway 101. Three small ephemeral tributaries drain the southwestern portion of the site, and join Froom Creek near the southern property boundary. The LOVR roadside channel parallels LOVR along the eastern property boundary, and also drains to San Luis Creek. Most of the eastern portion of the property between Froom Creek and LOVR/Calle Joaquin is within the FEMA 1% flood zone (100-‐year base flood area). The section of Froom Creek within the property consists of an incised channel, confined by a man-‐ made earthen berm along the eastern bank. The examination identified bed and bank structure with a defined OHWM four to 15 feet wide, consisting of Riverwash and cobble/gravel deposits. The channel was dry during the investigation with no signs of flow over the last two years. The tributary channels exhibited defined bed and bank structure, and were mostly dry, except for a small seep in Drainage 3 (Sample Point #20), and a larger spring fed wetland area at the confluence of Drainages 1 and 2 (Sample Point #19). A large seep area extends north from Drainage 2 along the adjacent hillside (Sample Point #22). The LOVR roadside channel contained saturated soils, drift lines and debris racks, and was dominated by arroyo willow, brown-‐headed rush, and other hydric vegetation. Low elevation meadow areas adjacent to the LOVR channel and along Calle Joaquin exhibited hydric soil indicators and dominant wetland vegetation, but no obvious hydrology indicators. These areas are within the 100-‐year flood zone, and are flooded periodically during high rainfall events. In addition, these areas have exhibited high ground water levels during high rainfall years, and are hydrologically connected to the LOVR Roadside channel by groundwater flows. Upper meadow areas are flooded less often, and groundwater flows may have been reduced by construction of the Irish Hills Plaza to the west. Stormwater collected from the Plaza hardscape now is directed into the LOVR channel or into the detention basins, which has changed groundwater flow patterns and hydrologic connectivity in the area. Large portions of the site along LOVR and Calle Joaquin are within the 100-‐year flood zone, and as such could be inundated by flood waters during large rainfall events. Due to ongoing drought conditions in the region, the meadow areas examined in this report have not flooded in several years, and groundwater levels are lower than years with normal or above normal precipitation. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 16 In 2014, a total of eight shallow monitoring wells were installed on the LOVR/Calle Joaquin meadow areas to document groundwater levels within the top 18 inches of the soil (refer to Figure 4b for well locations). Data was recorded by HOBO U20L water level loggers through the 2014-‐ 2015 rainy season. The shallow wells found no groundwater present within 18 inches of the surface during the 2013/2014 rainfall year, which produced 10.6 inches of rainfall for the San Luis Obispo area (Cal Poly ITRC Weather Station). 4.5 Jurisdictional Determination Summary The boundary lines between potential wetlands and other waters of the U.S. identified in this report are based on the methodology presented in the Arid West Manual, and reflect the conditions currently present on the site. The natural drainage features including Froom Creek and its tributary drainages (Drainages 1, 2, and 3) were delineated based on the extent of an OHWM or areas containing all three wetland criteria. The wet meadow areas are apparently the result of LOVR and Calle Joaquin (and surrounding development) impounding surface flow and groundwater. While large areas of Italian ryegrass are present in the grassland in this portion of the site, detailed analysis of the soil profile was used to determine if the specific area was in fact a wetland. The two restored areas in the northern part of the site referenced in previous studies did not meet Arid West wetland criteria, and are functioning as upland grassland. The reduced wetland areas reflect the new normal conditions, including changes in surface and subsurface hydrology from adjacent development, changes in plant composition, and current drought conditions, as documented through application of the Arid West guidelines. Due to the large number of sample points examined in this study, the collected information was summarized in the following tables to assist during review. Please refer to Figures 4, 4a and 4b for the location of the sample points, and the associated jurisdictional boundary lines. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 17 Table 1. Sample Point Results Summary Sample Point # Hydrophytic Vegetation Hydric Soil Wetland Hydrology Jurisdictional Determination 1 NO NO NO Upland 2 YES YES YES Wetland 3 YES YES YES Wetland 4 NO NO NO Upland 5 YES YES YES Wetland 6 YES NO NO Upland 7 YES YES YES Wetland 8 YES YES YES Wetland 9 NO NO NO Upland 10 YES YES YES Wetland 11 YES NO NO Upland 12 YES YES YES Wetland 13 YES YES NO Upland 14 YES YES YES Wetland 15 YES NO NO Upland 16 NO NO NO Upland 17 NO NO NO Upland 18 YES NO NO Upland 19 YES YES YES Wetland 20 YES YES YES Wetland 21 NO NO NO Upland 22 YES YES YES Wetland 23 YES NO NO Other Waters 24 NO NO NO Upland Los Osos Valley RoadCalle J o a q u i n Irish Hills PlazaDrainage 1 Drainage 2 Drainage 3 Froom Creek Figure 4a Figure 4b MountainbrookChurch Irish Hills Natural Reserve Study Area Boundary CDFW Jurisdiction (5.41 acres) USACE Wetlands (7.25 acres) USACE Other Waters (2.66 acres) John Madonna Construction, Inc.0 200 400 600 800100Feet Wetland Delineation Overview Source(s): RRM Design Froom Ranch Figure 41 in = 350 ft Drainage 1 Drainage 2 Drainage 3 Froom Creek Froom Creek23 24 22 21 19 18 20 Match Line Wetland Seep Wetland Seep Wetland Sample Points Study Area Boundary CDFW Jurisdiction (5.41 acres) USACE Wetlands (7.25 acres) USACE Other Waters (2.66 acres) John Madonna Construction, Inc.0 110 220 330 44055Feet Wetland Delineation Map Source(s) : RRM Design (Froom Ranch Topographic Basemap) Froom Ranch Figure 4a1 in = 200 ft 24 MountainbrookChurch Irish Hills Natural Reserve Froom Creek 15 14 13 12 11 7 6 5 4 1 2 10 8 9 3 16 17 48" Storm DrainLos Osos Valley RoadCalle Jo a q u i n Irish Hills PlazaStorm Water Basin Temporary Retention Basin Drainage 1 Drainage 2 Drainage 3 18 19 20 Irish Hills Plaza HWY 101 Irish Hills Natural Reserve Wetland Wetland Seep Sample Points Culvert Inlet/Outlet Monitoring Well Location Study Area Boundary CDFW Jurisdiction (5.41 acres) USACE Wetlands (7.25 acres) USACE Other Waters (2.66 acres) John Madonna Construction, Inc.0 110 220 330 44055Feet Wetland Delineation Map Froom Ranch Figure 4b1 in = 200 ft 24 Match Line Source(s) : RRM Design (Froom Ranch Topographic Basemap) KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 21 Of interest, observed changes to area hydrology over the last 10 years include: ¥ construction of the adjacent Costco, Home Depot, and Irish Hills Plaza developments; ¥ transport of the resulting hardscape runoff to the LOVR channel or the detention basins; and ¥ Calle Joaquin construction and associated drainage alterations, resulting in the separated wetland area between the site and Highway 101. Observed changes to on-‐site vegetation over the last 10 years include : ¥ increased presence of clustered field sedge (FACW) in wet meadow areas; ¥ disappearance of creek clover (Trifolium wormskjoldii -‐ FACW), and rabbitsfoot grass (Polypogon monspeliensis -‐ FACW) from Calle Joaquin wet meadow; ¥ appearance of reed fescue (FACU) as a dominant in the Calle Joaquin wet meadow; ¥ growth of arroyo willow shrubs (FACW) along the LOVR roadside channel; and ¥ appearance of round leaved leather root (OBL) along Calle Joaquin. Rainfall patterns and amounts (rainfall data from the Cal Poly ITRC Weather Station, compiled by rainfall year) were similar despite current drought conditions, as documented below: ¥ 2001-‐2005 had 2 years of at or above normal rainfall (22.9, and 29.8 inches), and 3 years below average (14.79, 15.3, and 16.02 inches). ¥ 2009-‐2013 had 2 years well above normal rainfall (31.7, 31.5), and 3 years below average (14.6, 14.3, and 10.6 inches). 5.0 CONCLUSION This report identifies potential federal and state jurisdictional boundaries within the property, as determined by KMA following a field investigation conducted in winter and spring of 2015. Waters of the U.S. and State of California identified within this report are subject to verification by the Corps and other agencies. As shown on Figures 4a and 4b, Froom Creek, its tributary channels, the LOVR Roadside channel and the abutting wet meadow areas along LOVR and Calle Joaquin are considered to be potentially jurisdictional Waters of the U.S. under the Clean Water Act. Portions of these areas also fall under the jurisdiction of the RWQCB and CDFW as waters of the state. 5.1 Federal Waters The areas that are considered potentially jurisdictional by the Corps consist of wetlands and other waters as mapped on Figures 4a and 4b. The majority of Froom Creek and the associated tributary channels experience a seasonal flow regime and lack dominant wetland vegetation within the OHWM, and such areas are mapped as non-‐wetland other waters habitat (Riverine Intermittent Streambed). Wet meadow areas and spring or seep fed portions of the tributary channels that contain dominant perennial wetland vegetation are mapped as wetland habitat (Palustrine Emergent Wetland). Acreage of the identified jurisdictional areas is presented below. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 22 The delineation identified a total of approximately 9.90 acres of Corps-‐jurisdictional waters of the U.S. including wetlands within the site (refer to Table 2). This area calculation is approximate, and has not been confirmed by the Corps. All Corps-‐jurisdictional areas listed in Table 2 also fall under the jurisdiction of the RWQCB as waters of the State of California. No isolated waters were identified within the study area. Table 2. Summary of Jurisdictional Waters of the U.S. Waters of the U.S. Total Area (square feet / acre) Total Linear Feet Wetlands Wetland within OHWM 62,420 / 1.43 1,764 Wet Meadow 253,170 / 5.81 N/A Other Waters Intermittent Streambed within OHWM 115,736 / 2.66 8,176 Total Waters of the U.S. 431,326 / 9.90 9,940 5.2 CDFW Jurisdictional Areas As shown on Figures 4a and 4b, Froom Creek and its tributaries, the LOVR channel, and the Calle Joaquin ponding zone fall under CDFW regulatory authority per the California Fish and Game Code. The wet meadow areas are not directly associated with bed and bank features or riparian habitat, and therefore are not expected to be regulated by CDFW. The delineation identified a total of approximately 5.41 acres of CDFW jurisdictional area (refer to Table 3). CDFW jurisdiction includes all Waters of the U.S. within the OHWM listed in Table 2, and additional areas extending to the outer edge of associated riparian vegetation or the property boundaries. Table 3. Summary of CDFW Jurisdictional Areas CDFW Jurisdictional Areas* Total Area (square feet/acre) Total Linear Feet Froom Creek and tributary channels, LOVR roadside channel, Calle Joaquin 235,528 / 5.41 9,841 Total CDFW Jurisdictional Area 235,528 / 5.41 9,841 * Channel width at top of bank or outer extent of associated riparian vegetation. These jurisdictional areas and boundaries are subject to review and verification by the Corps, RWQCB, and CDFW, and this report should be submitted to these agencies as part of any permit applications associated with the proposed project. During the permit review process, the Corps and other agencies may conduct a site visit to verify the jurisdictional boundaries identified in this report, and may approve the report or request amendments to the report based on their findings. KMA advises all interested parties to treat the information contained herein as preliminary pending written verification of jurisdictional boundaries by the Corps. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. 23 6.0 REFERENCES Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, editors. 2012. The Jepson Manual: vascular plants of California, second edition. University of California Press, Berkeley. Cowardin, Lewis M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of wetlands and deepwater habitats of the United States. Prepared for the U.S. Fish and Wildlife Service. FWS/OBS-‐79/31. Environmental Laboratory. 1987. Corps of Engineers wetlands delineation manual. U.S. Army Engineer Waterways Experiment Station. Vicksburg, Mississippi. Grumbles, Benjamin H., and John Paul Woodley, Jr. 2007. Clean water act jurisdiction following the U. S. Supreme Court's decision in Rapanos v. United States & Carabell v. United States, June 5, 2007. U.S. Environmental Protection Agency and Department of the Army. Guzy, G. S., and R. M. Anderson. 2001. Memorandum: Supreme Court ruling concerning CWA jurisdiction of isolated waters. U.S. Environmental Protection Agency and Army Corps of Engineers. Hickman, J. Ed. 1993. The Jepson Manual: Higher Plants of California. University of California Press: Berkeley, California. Holland, Robert. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. Department of Fish and Game. Lichvar, R.W., M. Butterwick, N.C. Melvin, and W.N. Kirchner. 2014. The National Wetland Plant List: 2014 Update of Wetland Ratings. Phytoneuron 2014-‐41: 1-‐42. Munsell Color. 2000. Munsell Soil Color Charts. Year 2000 Revised. GretagMacbeth, New York. Sawyer, John, Todd Keeler-‐Wolf and Julie Evens. 2009. Manual of California Vegetation, Second Edition. California Native Plant Society. Sacramento, California. U.S. Army Corps of Engineers. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0), ed. J.S. Wakely, R.W. Lichvar, and C.V. Noble. ERDC/EL TR-‐08-‐28. Vicksburg, MS. U. S. Army Engineer Research and Development Center. U.S. Department of Agriculture, Natural Resources Conservation Service. 2006. Field indicators of hydric soils in the United States, version 6.0, edited by G. W. Hurt and L. M. Vasilas. USDA, NRCS in cooperation with the National Technical Committee for Hydric Soils. Fort Worth, TX. U.S. Department of Agriculture, Natural Resources Conservation Service. 2015. Web soil survey. U.S. Department of Agriculture, Natural Resources Conservation Service. Available at: http://websoilsurvey.nrcs.usda.gov. U.S. Fish and Wildlife Service National Wetlands Inventory available at: http://www.fws.gov/wetlands/ APPENDIX A Wetland Determination Data Forms KMA APPENDIX B Photo Plate KMA KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Appendix B -‐ Photo Plate Photo 1. View of the upper portion of Froom Creek, looking southeasterly (downstream). Note broad, dry, cobbled channel with no pool or riffle structure. Photo 2. View of the middle portion of Froom Creek, grasslands, the permanent detention basin, and wet meadow areas along LOVR and Calle Joaquin, looking east. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 3. View of the upper portion of the site and Drainage 2, looking east. Photo 4. View of the LOVR roadside channel, looking east along LOVR from the northeast corner of the Study Area. Note lack of defined channel structure in foreground, and dense willow canopy in the distance along lower section of the channel. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 5. View of ponded water and bulrush occurrences along Calle Joaquin, looking southeast. Photo 6. View of Sample Points 1 (black arrow) and 2 (white arrow), looking east toward LOVR. Sample Point 3 is located in the LOVR channel to the right of 2. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 7. View of Sample Points 4 (shovel) and 5 (white arrow), looking east toward LOVR. Photo 8. View of Sample Points 6 (shovel) and 7 (white arrow), looking east toward LOVR. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 9. View of Sample Points 9 (foreground) and 8 (white arrow), looking east toward the LOVR / Calle Joaquin intersection. Photo 10. View of Sample Points 10 (shovel) and 11 (white arrow), looking west toward the permanent detention basin. Note dominant cover of OBL species at 10, and upland grasses at 11. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 11. View of Sample Points 13 (foreground) and 12 (white arrow), looking east toward the LOVR / Calle Joaquin intersection. Photo 12. View of Sample Points 15 (shovel) and 14 (white arrow), looking east toward the LOVR / Calle Joaquin intersection. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 13. View of Sample Point 19, in wetland area near confluence with Drainage 1. Photo 14. View of Sample Point 20 at the edge of the small seep on the bank of Drainage 3. KMA Froom Ranch Delineation of Waters of the U.S. and State of California John Madonna Construction, Inc. Photo Plate Photo 15. View of Sample Points 22 (arrow) and 21 (shovel) in the hillside seep area near Drainage 2, looking south. Photo 16. View of Sample Points 23 (arrow) and 24 (shovel) in and adjacent to Drainage 1, looking west. APPENDIX E.6 Preliminary Jurisdiction Determination This Page Intentionally Left Blank. APPENDIX E.7 Wood Environment & Infrastructure Site Reconnaissance Field Notes This Page Intentionally Left Blank. 1 Re: Froom Ranch Peer Review Site Reconnaissance Field Notes The following field notes and attached map (Figure 1) are based on observations made by botanist John Chesnut during the January 18, 2018 Froom Ranch Project site reconnaissance. The observations refer mainly to the upper slope of the Froom Ranch project site. During the site reconnaissance visit, several species including Eastwood’s delphinium (Delphinium parryi ssp. eastwoodiae); San Luis Obispo dudleya (Dudleya abramsii ssp. murina); and Chorro Chreek bog thistle (Cirsium fontinale var. obispoense) (Figure 1) were discovered to be located well outside the previously mapped polygons of these species as detailed in the Biological Resources Inventory report by Merk (2016). The new observations made during the January 2018 site reconnaissance indicate that a non-drought year survey would likely show currently occupied polygons have expanded. As shown in the attached Figure 1, a nearly continuous occurrence of Chorro Creek bog thistle (Cirsium fontinale var. obispoense) exists for approximately 400 meters along a dry stream drainage. This currently mapped footprint is much larger than the previously documented reported population size (Merk 2016). Just north of the Chorro Creek bog thistle polygon, is a small area where approximately 50 to 100 individuals were observed. These individuals and were noted to have been subjected to severe damage from horse grazing, as the uprooted rosettes were evidence of herbivory. Chorro Creek bog thistle (CNPS CRPR 1B.2) is federally listed as Endangered and State of California listed Endangered. The herbivory observed from horse grazing and also the potential for encroachment of weeds associated with development is of great concern- as this species is both state and federally listed endangered. Evaluation and mitigation of the Chorro Creek bog thistle on this site is recommended to maintain the integrity and increase sustainability of these populations San Luis Obispo dudleya (Dudleya abramsii ssp. murina; CNPS CRPR 1B.3) was observed south of the drainage in a group of serpentine rock outcroppings. No San Luis Obispo dudleya were documented or mapped in this area by the Merk report. It is assumed that any Serpentine rocky slopes within the site will support more extensive occurrences of this species than were mapped in this area, and should be considered during evaluation and mitigation. Blochman’s dudleya (Dudleya blochmaniae; CNPS CRPR 1B.1) was observed in rosette stage at eastern head of the disturbed area. Per communication with John Madonna by Wood botanist John Chestnut, these disturbed lines are attributed to excavations that were completed to determine the location and age of a fault trace that occurs along this hill slope. This rosette is located close to a polygon of Blochman’s dudleya that was documented in the Merk report. Some of this population was most likely lost to the excavation activity that occurred in that area. A Delphinium rosette was found to be occurring on the slope well below the previously mapped extent. This indicates the resources providing necessary nutrients to the Delphiniums are highly underestimated, and most likely in co-existence with the perennial serpentine grassland extent. In addition to the Delphinium rosette, a single spineflower (Chorozanthe sp.) observation was made among the abundant bog thistle polygon along the drainage. Due to its stage of development, it is unknown if this species is a local sensitive species or a common species. In addition to these sensitive plant sightings and recommendations, further habitat mapping is also recommended as the perennial bunchgrass observed in the field during the 2018 site reconnaissance is dominant- spread over much larger polygons than previously mapped in the Merk report. Four separate locations outlined on Figure 1 show the approximate areas of observed serpentine grassland. The two approximate highest concentrations of the perennial grasses, Calochortus and dudleya that are characteristic of serpentine grassland habitats are to the southwest of the site. This high concentration runs north and south of the drainage that holds a large polygon of Chorro Creek bog thistle. These perennial serpentine grasslands will support serpentine associate species, and therefore, a more accurate and less conservative effort for habitat mapping is necessary. F I G U R E PacificOcean Site Reconnaissance Observations (01/18/2018)Froom RanchSan Luis Obispo, Ca. Path: Q:\3551_Planning\FroomRanch_1755100034\MXD\ReportFigures\Memo20180418\Fig1_FroomRanchObs_v3.mxd, herbert.mendes 4/25/2018 11 inch = 500 feet o0500250Feet Service Layer Credits: Esri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributors,and the GIS user communitySource: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS,AeroGRID, IGN, and the GIS User Community Legend Project Boundary Species Observations !.Blochman's Dudleya (Dudleya blochmaniae) !.Chorro Creek Bog Thistle (Cirsium fontinale var. obispoense) !.Delphinium Rosette !.San Luis Obispo Dudleya (Dudleya abramsii ssp. murina) !.Spineflower (Chorozanthe sp.) Serpentine Grassland !. !. !. !.!. !.!.!.!.!.!. !. !. !. !. !.!. !. !. !. !. !.!. !. !. !.