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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 />4-32 <br /> <br /> <br />targeting removal of invasive vegetation, protecting native milkweed, protecting overwintering sites, and <br />restricting prescribed burning activities in suitable monarch habitat when the species is observed to avoid <br />direct impacts to individuals. If monarch butterfly, monarch larvae host plants (e.g., Asclepias californica, <br />A. fascicularis, A. speciosa), or overwintering roost trees are identified during focused surveys (conducted <br />pursuant to SPR BIO-10), or the species is assumed to be present in lieu of conducting surveys, the project <br />proponent would avoid or minimize adverse effects on the species by avoiding treatment activities in <br />suitable monarch habitat during overwintering or larval periods. If monarch overwintering groups or <br />larvae are detected, a buffer determined appropriate by a qualified RPF or biologist would be established. <br />The project proponent would flag avoidance buffers, within which no treatment activities would occur, a <br />qualified biologist or RPF would be available to provide guidance as needed, and/or other measures <br />recommended by CDFW would be followed as necessary to avoid injury to or mortality of these species or <br />impacts to the population. If work occurs within occupied monarch habitat, MM BIO-2b requires flagging <br />areas for avoidance and establishing no-work buffers. MM BIO-2b also states: “A qualified RPF, biologist, <br />or biological technician will be required to monitor the effectiveness of the no-disturbance buffer around <br />the nest, den, burrow, or other occurrence during treatment.” Because the Project proposes to remove <br />invasive species through various treatments, the results of project implementation may improve habitat <br />quality for monarch butterfly. With these additional focused MMs, impacts to monarch butterfly would be <br />reduced to less than significant. This impact is consistent with the CalVTP PEIR. <br />Impacts to Alameda Whipsnake <br />Direct impacts to Alameda whipsnake could occur through crushing the animals with vehicles, collapsing <br />occupied burrows, or burning occupied piles. Indirect impacts could occur from habitat type conversion <br />of scrub and chaparral. Within Alameda whipsnake habitat, treatment methods would primarily include <br />manual methods, and in adjacent habitat, grazing and prescribed burning. Mechanical equipment would <br />not be operated within suitable Alameda whipsnake habitat. <br />The Project does not impact chaparral or coastal sage scrub and is designed to avoid creation of new roads <br />(SPR HYD-2). SPR GEO-1 would suspend treatment activities during heavy precipitation until soils are no <br />longer saturated, reduce the potential for project activities to disturb ground-supporting burrows, and <br />reduce the potential for impacts to this species. Within suitable Alameda whipsnake habitat, pre- <br />treatment surveys would be combined with a focused survey (SPR BIO-1, SPR BIO-3, SPR BIO-10) <br />to identify individuals and burrow sites within the project footprint. Crew members and cont ractors would <br />be trained to identify individuals and burrows (SPR BIO-2), and a biological monitor would be present on- <br />site within Alameda whipsnake habitat to provide guidance as needed. If individuals are encountered, they <br />would be protected with an appropriate avoidance buffer (SPR AD-2) and would be allowed to leave the <br />work area of their own volition. To protect habitat, a Spill Prevention and Response Plan (SPR HAZ-5) would