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<br />Sequoia Ecological Consulting, Inc. <br />CalVTP Project-Specific Analysis and Addendum <br />Augustin Bernal Community Park Fuel Reduction <br />November 2025 <br />4-70 <br /> <br /> <br />fencing where natural barriers are not present. The use of temporary water facilities for the livestock and <br />guard animals and/or shepherd, as well as other temporary infrastructure (e.g., tanks, corrals, wildlife-safe <br />fences), may be required with the use of prescribed herbivory as a treatment method. The CalVTP PEIR <br />determined that prescribed herbivory poses a less than significant impact to water quality because it <br />involves minimal soil disturbance, is carefully managed, and is subject to protective measures under SPRs. <br />Because the proposed prescribed herbivory treatments align with those evaluated in the PEIR, potential <br />impacts to water quality are considered within the scope of the CalVTP and have been fully addressed. <br />SPRs applicable to this treatment are AD-3, BIO-1, BIO-4, BIO-5, GEO-1, GEO-3, GEO -4, GEO-7, HYD -1, HYD - <br />2, HYD-3, HYD-4, HYD-6, and HAZ-1. All applicable SPRs listed, except SPRs BIO-4, GEO-3, and HYD-3, are <br />described in Impact HYD-1 and Impact HYD-2. SPR BIO-4 requires that treatment design avoid loss of <br />riparian habitat function. SPR GEO-3 requires stabilization of soil disturbed during prescribed herbivory <br />treatments, and HYD-3 requires various water quality protections for prescribed herbivory treatments. <br />These SPRs avoid and minimize the risk of substantial water quality degradation by implementation of <br />prescribed herbivory treatment, making the impact less than significant. <br />The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the <br />proposed treatment area constitutes a change to the geographic extent presented in the PEIR. As <br />mentioned in Impact HYD-1, a few segments of the project treatment areas that are located outside the <br />CalVTP treatable landscape are in close proximity to waterbodies entirely or partially outside the treatable <br />landscape boundary. However, within the boundary of the project area, the surface water conditions are <br />essentially the same within and outside the treatable landscape; therefore, the water quality impact from <br />prescribed herbivory treatments is also the same, as described above. This determination is consistent <br />with the PEIR and would not constitute a substantially more severe significant impact than what was <br />covered in the PEIR. <br />4.10.1.4. Impact HYD-4 <br />Project treatments could include targeted herbicide application to kill, or prevent regrowth of, invasive <br />plants and noxious weeds. No aerial spraying of herbicides would occur. Herbicides would be applied in <br />adherence with all USEPA, CalEPA, and California DPR guidelines. Even so, the use of herbicides has the <br />potential to violate water quality standard regulations or degrade water quality. The CalVTP PEIR found <br />that the use of herbicides has a less-than-significant impact on water quality because herbicide application <br />is tightly regulated, applied in accordance with label instructions and legal requirements, and subject to <br />SPRs that include buffer zones, timing restrictions, and site-specific planning to prevent contamination of <br />water bodies. Because the proposed herbicide treatments are consistent with those evaluated in the PEIR, <br />potential impacts to water quality are considered within the scope of the CalVTP and have been fully <br />addressed through regulatory safeguards and SPRs. The SPRs applicable to this treatment are AD-3, BIO- <br />1, BIO-4, GEO-1, HAZ-1, HAZ-5, HAZ-6, HAZ-7, HYD-1, HYD-4, and HYD-5. All applicable SPRs listed, except