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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 />4-28 <br /> <br /> <br />Even with implementation of the above SPRs, impacts could be potentially significant per the CalVTP PEIR. <br />MMs BIO-1a and BIO-1b would be required when the following conditions are met: <br />• Where sensitive species are known to occur <br />• When treatments cannot be completed in the dormant season, or the species are persistent year- <br />round due to its lifecycle (woody or non-dormant) <br />• When treatments would be implemented during the growing period of sensitive annual and <br />geophyte species <br />• Where protocol-level surveys are required (per SPR BIO-7) and special-status plants are identified <br />during these surveys <br />Following implementation of MMs BIO-1a and BIO-1b, special-status plants identified during protocol- <br />level surveys would be given a no-disturbance buffer of 50 feet, within which vegetation treatment <br />activities would not occur unless a qualified RPF or biologist determines that the species would benefit <br />from treatment in the occupied habitat area. The size and shape of the generally 50-foot buffer would be <br />adjusted if a qualified RPF or biologist determines that a smaller or larger buffer would be sufficient to <br />avoid impacts on listed plants. Additionally, all state- and federally protected wetlands would be avoided <br />(MM BIO-4) by a standard buffer of 25 feet and would be adjusted if slopes or other conditions warrant <br />an increased buffer. Mitigation of the 15 special-status plant species with potential to occur is considered <br />based on persistence of detection throughout their lifecycle. <br />• MM BIO-1a: Avoid Loss of Special-Status Plants Listed under Federal Endangered Species Act (ESA) <br />or California Endangered Species Act (CESA) <br />• MM BIO-1b: Avoid Loss of Special-Status Plants Not Listed under ESA or CESA <br />• MM BIO-2a: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Listed <br />Wildlife Species and California Fully Protected Species (All Treatment Activities) <br />• MM BIO-2b: Avoid Mortality, Injury, or Disturbance and Maintain Habitat Function for Other <br />Special-Status Wildlife Species (All Treatment Activities) <br />• MM BIO-3a: Design Treatments to Avoid Loss of Sensitive Natural Communities and Oak <br />Woodlands <br />• MM BIO-4: Avoid State- and Federally Protected Wetlands <br />Impacts to Sensitive Natural Communities <br />To avoid impacts on sensitive natural communities, focused botanical surveys would be performed (MM <br />BIO-1a and MM BIO-1b). If identified, sensitive natural communities would be recorded using a GPS device <br />and mapped. No project-related ground disturbance would occur within 50 feet of these sensitive natural <br />communities (MM BIO-3a). <br />With implementation of all SPRs and MMs listed above, including survey protocols and preoperational <br />meetings, impacts to special-status plant species would be reduced to less than significant.