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City of Pleasanton—Hidden Canyon Residences and Preserve Project CEQA Findings of Fact and Statement of Overriding Considerations 24 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480016/FOF/21480016 Pleasanton Hidden Canyon Residences and Preserve Project FOF.docx dissimilarity of the proposed activity with background activities) to minimize the potential to affect the reproductive success of the owls. Compensation To ensure that mitigation habitat meets or exceeds the value of habitat lost to development, Focal Species Impact/Mitigation Scoring Sheets located in Appendix E of the EACCS were used as part of the assessment for suitability of mitigation lands for the burrowing owl. Standardized mitigation ratios for the burrowing owl, according to Table 3-10 in the EACCS, is 3:1 within the East Bay Hills Mitigation Area where the project and associated conservation land is sited. Facts in Support of Findings: Congdon’s Tarplant Congdon’s tarplant was observed on the project site during field and focus surveys. (Draft EIR, p. 3.3- 25). Although four new populations identified in 2023 would be located within the proposed conservation area and would thus not be affected by project construction activities, the proposed project would still result in significant harm or removal of Congdon’s tarplant during project construction. (Draft EIR, p. 3.3-25). Therefore, the proposed project would be required to implement MM BIO-1a which would involve the preservation of Congdon’s tarplant at an 8:1 ratio and preparation of a sitewide Resource Management Plan (RMP) to manage the 104.6 acres of open space for all potentially sensitive species, including Congdon’s tarplant. Through implementation of MM BIO-1a, the proposed project would reduce potential impacts on Congdon’s tarplant during grading and habitat modification to a less than significant level. California Red-legged Frog Approximately 104.6 acres of open space west of the project site within Parcel B is proposed for conservation purposes and is classified as Critical Habitat Unit ALA-1b for the California Red-legged Frog (CRLF). (Draft EIR, p. 3.3-25; Errata, p. 5-3). According to the results of the site-specific habitat assessment, aquatic features on the project site lack suitable hydrology to provide breeding habitat for the species. (Draft EIR, Appendix C) However, the CRLF may also occur within riparian corridors on-site or in their immediate vicinity during movement and foraging activities. (Draft EIR, p. 3.3-25). Although the proposed project would use clustering and siting features to reduce impacts on riparian corridors that would qualify as potential CRLF foraging habitat to the extent feasible, the proposed project would implement MM BIO-1b out of an abundance of caution to further reduce these impacts. Through implementation of MM BIO-1b, the proposed project would reduce potential impacts on the CRLF to less than significant. Alameda Whipsnake The project site is located almost entirely within Critical Habitat for the Alameda whipsnake. (Draft EIR, p. 3.3-26). As a result, the proposed project would result in the loss of approximately 24 acres of upland habitat suitable for all life stages of the whipsnake, which includes potential impacts to Alameda Whipsnake habitat located adjacent to the proposed project’s boundaries. Therefore, the