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AUGUSTIN BERNAL MOUNTAIN BIKE TRAIL PROJECT DRAFT INITIAL STUDY D. Prohibit the attachment of wires,signs and ropes to any heritage tree. E. Design utility services and irrigation lines to be located outside of the dripline when feasible. F. Retain the services of a certified consulting arborist for periodic monitoring of the project site and the health of those trees to be preserved. The certified consulting arborist shall be present whenever activities occur which pose a potential threat to the health of the trees to be preserved (for example,when work occurs within the dripline of trees to be preserved). G. The director shall be notified of any damage that occurs to a tree during construction so that proper treatment may be administered. Impact Discussion a) Would the project have a substantial adverse effect, either directly or through habitat modifications,on anyspecies identified as a candidate,sensitive,orspecial status species in local or regional plans,policies,or regulations,or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Special-Status Plants The project would be constructed in coast live oak woodland and scrub communities that contain suitable habitat for four California Rare Plant Rank 113 species: bent-flowered fiddleneck (Amsinckia lunaris), Hospital Canyon larkspur (Delphinium californicum ssp. interius), fragrant fritillary(Fritillaria liliacea), and Diablo helianthella (Helianthella castanea).Although there are no known occurrences of these species near the project site, and habitat suitability adjacent to existing informal trails is low due to the prevalence of non-native species (e.g., vetch, non-native annual grasses)and disturbance from unofficial mountain bike use,their presence cannot be ruled out without a focused survey by a qualified botanist, which would be conducted as part of the project under the Special Status Plants AMM that is incorporated in the project design and construction methodology. Clearing and grubbing of shrubs and ground vegetation and grading could result in the removal of special-status plant occurrences if any are found during the botanical survey required under the Special Status Plants AMM and cannot be avoided by project construction.Such direct impacts on special-status plants would be a significant impact before mitigation because the removal of undocumented occurrences would further contribute to statewide declines. Mitigation Measure (MM) 13I0-1 requires that the City provide compensatory mitigation for any effects to special status plants through seed/propagule collection, planting, and conducting adaptive management, maintenance and monitoring for 5 years to attain identified species-specific success criteria. Implementation of MM 13I0-1 would reduce this impact to less than significant.Therefore, impacts would be less than significant with mitigation incorporated. 12956 DUDEK 42 April 2022