HomeMy WebLinkAboutARCH-0587-2020_BiologicalSurveyAddendum_5.20.2David Wolff Environmental, LLC
P.O. Box 7019
Los Osos, CA 93402
DavidW.Enviro@gmail.com
805) 235-5223
Biological & Wetland Resources Assessments – Regulatory Compliance Specialist
May 17, 2021
Michael B. Burke
Director of Construction and Development
Housing Authority of San Luis Obispo
487 Leff Street
San Luis Obispo, CA 93401
SUBJECT: Biological Resources Assessment Addendum for the 279 Bridge Street
Affordable Housing Project, City of San Luis Obispo, CA (ARCH-0587-2020)
Dear Michael:
David Wolff Environmental (DWE) is providing this Biological Resources Assessment
Addendum (2021 BRA Addendum) to the Sage Institute, Inc., July 9, 2014 Gallagher – Bridge
Street Project Biological Resources Assessment (2014 BRA) for your use in the
environmental review and project approval process with the City of San Luis Obispo,
California. The 2014 BRA is hereby incorporated by reference into this 2021 BRA
Addendum. The purpose of this addendum is to document current site conditions with the
completed bridge construction over Meadow Creek and installed mitigation plantings, and to
evaluate the consistency of the 2014 BRA analysis of project impacts on biological resources
with the current project design. I have prepared this 2021 BRA Addendum based the
information you provided, on my previous work on the project site, annual mitigation
monitoring surveys since 2018, and a site visit on April 4, 2021.
1.0 2014 BRA BACKGROUND INFORMATION
The 2014 BRA evaluated a proposed project that included the construction of a bridge
crossing over Meadow Creek and development of the 2.73-acre lot into a storage yard and
future mixed-use development with commercial and residential land uses. The Meadow
Creek corridor was to remain in open space in accordance with the City of San Luis Obispo
creek setback policy.
The 2014 BRA established existing conditions of the site as predominantly composed of a
non-native annual grassland habitat bordered by the Meadow Creek riparian corridor along
the north, and an ephemeral swale along the southern border of the site. Surrounding land
uses included approved residential development to the south, and developed residential,
industrial, and commercial uses. The 2014 existing conditions were based on field
reconnaissance surveys on November 20, 2013, April 17, 2014, and May 20, 2014 that
included a thorough and complete springtime floristic inventory and rare plant survey.
David Wolff Environmental HASLO 279 Bridge Street 2021 BRA Addendum |2
Biological & Wetland Resources Assessments – Regulatory Compliance Specialist
The 2014 BRA documented two primary plant communities on the site. Disturbed non-native
annual grassland habitat was the dominant habitat type over approximately 2.09-acres
observed to be very low in species diversity and dominated by a near pure stand of wild oats
Avena barbata). Arroyo willow riparian woodland formed a corridor along the northern
border of the project site along Meadow Creek dominated by arroyo willow (Salix lasiolepis)
along with California black walnut (Juglans californica).
The 2014 BRA search and review of the California Natural Diversity Database (CNDDB)
revealed numerous historic and extant (presumed existing) occurrences of special-status
plant and wildlife species within the five-mile search radius of the project site. The botanical
surveys resulted in no observations of any rare, threatened, or endangered plant species
within the project site. The 2014 BRA determined the urban setting with a limited extent of
grassland and riparian habitats, and the seasonal nature of Meadow Creek did not support
suitable habitat for any special-status wildlife species.
Recommended mitigation measures in the 2014 BRA included nesting bird impact avoidance
and ground dwelling wildlife impact minimization measures during vegetation removal for
initial project construction, and regulatory compliance permitting for the bridge construction
through the Meadow Creek riparian corridor.
The 2014 BRA concluded that based on the existing conditions of biological resources within
the project site and incorporation of the recommended mitigation measures, implementation
of the proposed project would not result in any substantial adverse effects on biological,
botanical, wetland habitat resources, and both direct and indirect project impacts on
biological resources would be considered to be less than significant.
2.0 2021 EXISTING CONDITIONS AND PROJECT EVALUATION
Bridge Construction – Permits were issued for the bridge construction by the U.S. Army
Corps of Engineers (Corps) under Nationwide Permit authorization SPL-2015-00866-EMH,
the Regional Water Quality Control Board (RWQCB) Water Quality Certification No.
34015WQ018, and approved by Operation of Law by the California Department of Fish and
Wildlife (CDFW) Notification 1600-2015-0074-R4 (collectively “permits”). Obtaining the
permits satisfied 2014 BRA mitigation measure MM BIO-3. The bridge construction was
initiated on September 26, 2016 with a work window amendment and rain event action plan
approved by the RWQCB for bridge work to continue until December 1, 2016. The creek
channel flow line and banks were restored to pre-project contours on November 18, 2016
with all bridge construction within the creek completed on November 18, 2016. Regular
storm water pollution prevention plan (SWPPP) inspections were conducted throughout the
rainy season.
Compensatory Mitigation and Monitoring Plan (CMMP) – The permits required a CMMP for
creek and riparian habitat impacts from bridge construction. The overall goal of the CMMP
is to establish a diverse native riparian plant habitat enhancement along Meadow Creek
David Wolff Environmental HASLO 279 Bridge Street 2021 BRA Addendum |3
Biological & Wetland Resources Assessments – Regulatory Compliance Specialist
within the City required creek setback zone. The main objective of the CMMP is to establish
native riparian tree and shrub cover within the creek setback zone to increase the habitat
values with species and structural diversity (trees/shrubs) over existing non-native and
generally weedy grassland habitat. The CMMP planting was initiated in January 2018 and
completed with mulch and irrigation by May 2018 along with 32 volunteer coast live oak
saplings being maintained in the planting zone to increase the habitat enhancement values.
Initial plantings were approximately 40 percent over the CMMP quantities to facilitate
meeting the success criteria. Tree and shrub growth is robust with flowering and fruiting
with 2021 survivorship almost double the plan amount including volunteer oak and walnut
trees. Supplemental irrigation will continue through the 2021 growing season with weaning
expected through the next rainy season to meet the success criteria in 2022. A Biological
Open Space Easement Agreement to preserve the CMMP creek setback mitigation area was
granted by the owner to the City of San Luis Obispo on September 16, 2016.
Proposed Development Project – The 2014 BRA evaluated a project that would construct a
bridge, implement a CMMP within the required creek setback, and develop the remainder of
the non-native annual grassland habitat with a mixed-use project. No special-status plant or
wildlife species were observed or expected to occur. Mitigation measures were recommended
to protect nesting birds and common ground dwelling wildlife during initial ground
disturbing construction, and regulatory compliance permitting for the bridge construction.
These mitigation measures were implemented and satisfied for the bridge construction. As
noted above the CMMP was implemented and is meeting success criteria milestones.
DWE Principal Ecologist David Wolff conducted a field survey of the 279 Bridge Street
project site on April 9, 2021 to affirm site conditions are the same as that evaluated in the
2014 BRA. Given the time of year (springtime) and 2021 annual rainfall pattern, the DWE
field survey was conducted during peak expression of the onsite flora that was sufficient for a
rare plant survey to affirm the negative findings from the 2014 BRA rare plant surveys. The
2021 DWE field survey confirmed the onsite non-native annual grassland was dominated by
a dense cover of oats, with other non-native grasses and forbs. As such, conditions of the
mixed-use development area are unchanged from that evaluated in the 2014 BRA. Attached
Figure 1 provides a set of representative photographs of the current site conditions.
Based on the above findings, implementation of the nesting bird and ground dwelling
wildlife impact avoidance and minimization measures for the mixed-use development project
construction are still appropriate and included below for reference. The 2014 BRA regulatory
compliance mitigation measures have been fully implemented and no longer apply to the
remainder of site development (except permit compliance CMMP success monitoring and
reporting). As such, the proposed project would not have any significant direct or indirect
impact on biological or wetland recourses, or any rare, threatened, or endangered plant or
wildlife species.
David Wolff Environmental HASLO 279 Bridge Street 2021 BRA Addendum |4
Biological & Wetland Resources Assessments – Regulatory Compliance Specialist
RECOMMENDED MITIGATION MEASURES
Nesting Birds–The proposed new access road crossing of Meadow Creek and
conversion of the annual grassland may impact ground nesting and/or tree nesting
bird species if activities are conducted during the nesting season typically February 1st
to August 31st. To reduce potential impacts to nesting birds to a less than significant
level, the following mitigation measures are recommended:
MM BIO-1: Vegetation removal and initial site disturbance for any project elements
shall be conducted between September 1st and January 31st outside of
the nesting season for birds. If vegetation removal is planned for the
bird nesting season (February 1st to August 31st), then preconstruction
nesting bird surveys shall be required to determine if any active nests
would be impacted by project construction. If no active nests are found,
then no further mitigation shall be required.
If any active nests are found that would be impacted by construction,
then the nest sites shall be avoided with the establishment of a non-
disturbance buffer zone around active nests as determined by a
qualified biologist. Nest sites shall be avoided and protected with the
non-disturbance buffer zone until the adults and young of the year are
no longer reliant on the nest site for survival as determined by a
qualified biologist. As such, avoiding disturbance or take of an active
nest would reduce potential impacts on nesting birds to a less-than-
significant level.
Ground Dwelling Animal Impacts – While impacts on common ground dwelling
wildlife and the loss of less than 2.0 acres of non-native grassland is not considered a
significant impact, the following mitigation measure is recommended to further
reduce the level of this less-than-significant impact on common ground dwelling
wildlife species.
BIO MM-2: Prior to ground disturbing activities, a qualified biologist shall conduct
a pre-construction survey within 30 days of initial ground disturbance
to identify whether any upland wildlife species are using any portion of
the project areas where ground disturbance is proposed. If ground
dwelling wildlife species are detected, a biological monitor shall be
present during initial ground disturbing and/or vegetation removal
activities to attempt salvage and relocation efforts for the wildlife that
may be present such as common reptiles and small mammals. The
salvage and relocation effort for non-listed wildlife species would
further reduce the level of this less than significant impact.
David Wolff Environmental HASLO 279 Bridge Street 2021 BRA Addendum |5
Biological & Wetland Resources Assessments – Regulatory Compliance Specialist
3.0 CONCLUSIONS
Based on the findings described in this 2021 BRA Addendum affirming the existing
conditions of biological resources within the remaining development area of the project site
are unchanged from that documented in the 2014 BRA, and incorporation of the
recommended mitigation measures, implementation of the proposed project would not result
in any substantial adverse effects on biological, botanical, wetland habitat resources.
Therefore, with mitigation measures incorporated into the project, direct and indirect project
impacts on biological resources would be considered to be less than significant.
Thank you very much for using DWE for your environmental consulting services. Please
contact me directly if you have any questions or need any additional information.
Very truly yours,
David K. Wolff
Principal Ecologist
ATTACHMENT: FIGURE 1 – 2021 REPRESENTATIVE PHOTOGRAPHS
DAVID WOLFF ENVIRONMENTAL, LLC HASLO 279 Bridge Street Project
2021 Biological Resources Assessment Addendum
Figure 1 – 2021 Representative Photographs
Page 1 of 2
Photo 1: View south across completed bridge over Meadow Creek to access the project site.
Newly constructed adjacent development across ephemeral swale in background. 4/9/2021
Photo 2: View north across completed bridge over Meadow Creek towards Bridge Street.
Existing riparian habitat upstream and downstream of bridge. 4/9/2021
Photo 3: View east from bridge at CMMP plantings in creek setback open space adjacent to
exiting Meadow Creek riparian habitat. Adjacent residences in background. 4/9/2021
Photo 4: View west from NE project corner at CMMP plantings in creek setback open space.
Newly constructed adjacent development in background. 4/9/2021
DAVID WOLFF ENVIRONMENTAL, LLC HASLO 279 Bridge Street Project
2021 Biological Resources Assessment Addendum
Figure 1 – 2021 Representative Photographs
Page 2 of 2
Photo 5: View west from bridge at CMMP plantings in creek setback open space. Newly
constructed adjacent development in background. 4/9/2021
Photo 6: View southwest from NE project corner at oats dominated non-native annual
grassland throughout. Newly constructed adjacent development in background. 4/9/2021
Photo 7: View south from bridge access driveway at oats dominated non-native annual
grassland throughout. Newly constructed adjacent development in background. 4/9/2021
Photo 8: View southeast from NW project corner at oats dominated non-native annual
grassland throughout mixed-use development area. Adjacent residential. 4/9/2021