HomeMy WebLinkAboutCalifornia Department of Forestry and Fire Protection (CAL FIRE) 2026-04-03STATE OF CALIFORNIA, NATURAL RESOURCES AGENCY
DEPARTMENT OF FORESTRY AND FIRE PROTECTION
BENEFICIAL FIRE STANDARD AGREEMENT
RM-75 (REV. 01/26) AGREEMENT NUMBER
REGISTRATION NUMBER
1.This Agreement is entered between the State Agency and Cooperator named below:
STATE AGENCY'S NAME
The California Department of Forestry and Fire Protection
COOPERATOR’S NAME
2 The term of this through
Agreement is:
3.The maximum
of this Agreement is:
4. The parties agree to comply with the terms and conditions of the following exhibits which are by
this reference made a part of the Agreement.
Exhibit A – Contact Information page(s)
Exhibit B – Terms and Conditions page(s)
Exhibit C – Project Plan, Description, and Specifications page(s)
Exhibit D – Environmental Documentation page(s)
Exhibit E – Liability Matrix (optional if not used) page(s)
COOPERATOR
COOPERATOR’S NAME
BY (Authorized Signature) DATE SIGNED
PRINTED NAME AND TITLE OF PERSON SIGNING
ADDRESS
STATE OF CALIFORNIA
AGENCY NAME
The California Department of Forestry and Fire Protection
BY (Authorized Signature) DATE SIGNED
PRINTED NAME AND TITLE OF PERSON SIGNING
ADDRESS
1
4
04/03/2026
Shannon Riley, Deputy City Manager
Name of Project: ________________________
Agreement number:______________________
v.01/08/2026 Page 1 of 1
EXHIBIT A
Beneficial Fire Standard Agreement – RM 75)
CONTACT INFORMATION
1.Cooperator and State Agency agree to provide labor, equipment, or services as
described in the Prescribed Burn Plan attached as part of Exhibit C – Project Plan,
Description and Specification.
2. The services shall be performed at the location identified in the Prescribed Burn Plan
attached as part of Exhibit C – Project Plan, Description and Specification.
3.The services shall be provided at such times as are mutually agreeable to Cooperator
and State Agency, subject to the operational needs of State Agency and compliance
with all federal, state, or local restrictions as to the timing of the conduct of the work.
4.The project representatives during the term of this agreement will be:
State Agency: CAL FIRE Cooperator:
Name: Name:
Phone: ( ) - Phone: ( ) -
Email address: Email address:
Direct all inquiries to:
State Agency: CAL FIRE Cooperator:
Section/Unit: Section/Unit:
Attention: Project Manager for CAL FIRE Attention:
Address: Address:
Phone: ( ) - Phone: ( ) -
Email address: Email address:
5.A detailed description of work to be performed and the duties of all parties is contained
in the Exhibit C – Project Plan, Description and Specification which the Prescribed Burn
Plan may be incorporated into the Exhibit C.
Name of Project: Ukiah West Hills VTP
Agreement number: RX-North-107-MEU.08
EXHIBIT B
(Beneficial Fire Standard Agreement -RM 75)
TERMS AND CONDITIONS
1.APPROVAL: This Agreement is of no force or effect until signed by both parties.
Cooperator may not commence performance until such approval has been obtained.
2.AMENDMENT: No amendment or variation of the terms of this Agreement shall be
valid unless made in writing, signed by both parties and approved as required. No oral
understanding or Agreement not incorporated in the Agreement is binding on any of the
parties.
3.ASSIGNMENT: This Agreement is not assignable by either party without the consent
of the other party in the form of a formal written amendment.
4.INCIDENT COMMANDER/FIRE BOSS: The Unit Chief which approves the Prescribed
Burn Plan for this project will designate an Incident Commander (IC). The Unit Chief will
designate an officer of the department or a burn boss certified pursuant to Public
Resources Code (PRC) Section 4477 as the burn boss with final authority to approve and
amend the plan and formula applicable to a prescribed burning operation, to determine
that the site has been prepared and the crew and equipment are ready to commence the
operation, and to supervise the work assignments of departmental employees and all
personnel furnished by the person contracting with the department until the prescribed
burning is completed and all fire is declared to be out. The Unit Chief for this project is:
Brandon Gunn
(Name)
5.OWNERSHIP AND OPERATION. Cooperator represents and warrants that it is the
sole owner of, or otherwise holds all necessary rights to control and permit access to, the
Property for purposes of this Agreement. Cooperator will operate, manage, and maintain
the Property in a reasonably prudent manner and in accordance with applicable laws and
regulations throughout the term of this Agreement. Upon the State's notification to the
Cooperator that a beneficial fire executed pursuant to this Agreement is controlled and
contained, Cooperator shall assume all responsibility and liability for the condition,
operation, and use of the Property.
6.AUDIT: Cooperator agrees that the awarding department, the Department of General
Services, the Bureau of State Audits, or their designated representative shall have the
right to review and to copy any records and supporting documentation pertaining to the
performance of this Agreement. Cooperator agrees to maintain such records for possible
audit for a minimum of three (3) years after completion of the Prescribed Burn Plan,
unless a longer period of records retention is stipulated. Cooperator agrees to allow the
auditor(s) access to such records during normal business hours and to allow interviews of
any employees who might reasonably have information related to such records. Further,
Cooperator agrees to include a similar right of the State to audit records and interview
v.01/08/2026 Page 1 of 4
Name of Project: ________________________
Agreement number:______________________
v.01/08/2026 Page 2 of 4
staff in any subcontract related to performance of this Agreement. (Gov. Code §8546.7,
Pub. Contract Code §10115 et seq., CCR Title 2, Section 1896).
7.INDEMNIFICATION:
a. State’s Indemnification Obligations: State Agency agrees to defend and indemnify
the Cooperator as allowed by Public Resources Code section 4476, as follows:
i.State will defend Cooperator against any claim, demand, government
investigation, or legal proceeding made or brought by a third party against
Cooperator to the extent arising out of the State’s performance of this Agreement.
ii.State will indemnify Cooperator against all amounts to the third party making a
claim, demand, government investigation, or legal proceeding against Cooperator,
and all penalties, fines, and third-party costs (including legal fees) paid by the
Cooperator arising out of or relating to any claim, demand, government
investigation, or legal proceeding made or brought by a third party to the extent it
arises out of the State’s performance of this Agreement.
iii.The State’s obligation to defend and indemnify the Cooperator pursuant to this
section shall not extend to any claim arising after the State’s notification to the
Cooperator that a beneficial fire executed pursuant to this Agreement is controlled
and contained.
b. Cooperator’s Indemnification Obligations: Because CAL FIRE may not own or control
the lands on which this Agreement takes place, Cooperator agrees to defend and
indemnify the State as follows:
i.Defend the State against any claim, demand, government investigation, or legal
proceeding made or brought by a third party against the State to the extent it
arises out of or relates to any breach of this Agreement by Cooperator or the
negligence or willful misconduct of Cooperator.
ii.Indemnify the State against all amounts awarded to the third party making a claim,
demand, government investigation, or legal proceeding against the State, and all
penalties, fines, and third-party costs (including legal fees) paid by the State
arising out of or relating to any claim, demand, government investigation, or legal
proceeding made or brought by a third party to the extent it arises out of or relates
to any breach of this Agreement by Cooperator or the negligence or willful
misconduct of Cooperator.
8.TERMINATION: Either party may cancel this Agreement thirty days (30) days after
providing written notice to the other party, provided that if Cooperator cancels this
Agreement pursuant to this section, Cooperator shall be liable to the State for all planning
and site preparation costs incurred by the State prior to termination of the Agreement by
Cooperator.
9.BUDGET CONTINGENCY CLAUSE: It is mutually agreed that if the Budget Act of the
current year and/or any subsequent years covered under this Agreement does not
appropriate sufficient funds for the program, this Agreement shall be of no further force
and effect. In this event, the State shall have no liability to furnish any other
considerations under this Agreement and Cooperator shall not be obligated to perform
any provisions of this Agreement.
Name of Project: ________________________
Agreement number:______________________
v.01/08/2026 Page 3 of 4
10.INDEPENDENT CONTRACTOR: Cooperator, and the agents and employees of
Cooperator, in the performance of this Agreement, shall act in an independent capacity
and not as officers or employees or agents of the State.
11.POTENTIAL SUBCONTRACTORS: Nothing contained in this Agreement or
otherwise, shall create any contractual relation between the State and any
subcontractors, and no subcontract shall relieve the Cooperator of his responsibilities and
obligations hereunder. The Cooperator agrees to be as fully responsible to the State for
the acts and omissions of its subcontractors and of persons either directly or indirectly
employed by any of them as it is for the acts and omissions of persons directly employed
by the Cooperator. The Cooperator's obligation to pay its subcontractors is an
independent obligation from the State's obligation to make payments to the Cooperator.
As a result, the State shall have no obligation to pay or to enforce the payment of any
moneys to any subcontractor.
12.REQUIRED CERTIFICATION OF STATE: The State certifies that the Project
contemplated by this Agreement, when successfully completed, will accomplish a
purpose enumerated in PRC 4475 and that the State has determined that the anticipated
public benefit from the proposed project will exceed the foreseeable damage that could
result from the Project.
13.WORKERS COMPENSATION: All personnel similarly provided by the Cooperator
shall be agents of the Cooperator for purposes of Worker's Compensation. Cooperator
shall indemnify the State and hold harmless for any claims from the above agents. The
State is likewise responsible for its equipment and personnel.
14.EQUIPMENT: Any equipment used and maintained for the project by the Cooperator
is the responsibility of the Cooperator.
15.NON-DISCRIMINATION CLAUSE: During the performance of this Agreement,
Cooperator and its subcontractors shall not deny the agreement’s benefits to any person
on the basis of race, religious creed, color, national origin, ancestry, physical disability,
mental disability, medical condition, genetic information, marital status, sex, gender,
gender identity, gender expression, age, sexual orientation, or military and veteran
status, nor shall they discriminate unlawfully against any employee or applicant for
employment because of race, religious creed, color, national origin, ancestry, physical
disability, mental disability, medical condition, genetic information, marital status, sex,
gender, gender identity, gender expression, age, sexual orientation, or military and
veteran status. Cooperator shall insure that the evaluation and treatment of employees
and applicants for employment are free of such discrimination. Cooperator and
subcontractors shall comply with the provisions of the Fair Employment and Housing Act
Gov. Code §12900 et seq.), the regulations promulgated thereunder (Cal. Code Regs.,
tit. 2, §11000 et seq.), the provisions of Article 9.5, Chapter 1, Part 1, Division 3, Title 2 of
the Government Code (Gov. Code §§11135-11139.5), and the regulations or standards
adopted by the awarding state agency to implement such article. Cooperator shall permit
Name of Project: Ukiah West Hills VTP
Agreement number: RX-North-107-MEU.08
access by representatives of the Department of Fair Employment and Housing and the
awarding state agency upon reasonable notice at any time during the normal business
hours, but in no case less than 24 hours' notice, to such of its books, records, accounts,
and all other sources of information and its facilities as said Department or Agency shall
require to ascertain compliance with this clause. Cooperator and its subcontractors shall
give written notice of their obligations under this clause to labor organizations with which
they have a collective bargaining or other agreement. (See Cal. Code Regs., tit. 2,
§11105.) Cooperator shall include the nondiscrimination and compliance provisions of
this clause in all subcontracts to perform work under the Agreement.
16.CERTIFICATION CLAUSES: The CONTRACTOR CERTIFICATION CLAUSES
contained in the document CCC 04/2017 are hereby incorporated by reference and made
a part of this Agreement by this reference as if attached hereto.
17.GOVERNING LAW: This Agreement is governed by and shall be interpreted in
accordance with the laws of the State of California.
18.UNENFORCEABLE PROVISION: In the event that any provision of this Agreement is
unenforceable or held to be unenforceable, then the parties agree that all other
provisions of this Agreement have force and effect and shall not be affected thereby.
19.SMALL BUSINESS PARTICIPATION AND DVBE PARTICIPATION REPORTING
REQUIREMENTS:
a.If for this Agreement Cooperator made a commitment to achieve small business
participation, then Cooperator must within 60 days of receiving final payment under this
Agreement (or within such other time period as may be specified elsewhere in this
Agreement) report to the awarding department the actual percentage of small business
participation that was achieved. (Govt. Code§ 14841.)
b.If for this Agreement Cooperator made a commitment to achieve disabled veteran
business enterprise (DVBE) participation, then Cooperator must within 60 days of
receiving final payment under this Agreement (or within such other time period as may be
specified elsewhere in this Agreement) certify in a report to the awarding department: (1)
the total amount the prime Contractor received under the Agreement; (2) the name and
address of the DVBE(s) that participated in the performance of the Agreement; (3) the
amount each DVBE received from the prime Contractor; (4) that all payments under the
Agreement have been made to the DVBE; and (5) the actual percentage of DVBE
participation that was achieved. A person or entity that knowingly provides false
information shall be subject to a civil penalty for each violation. (Mil. & Vets. Code§
999.5(d); Govt. Code§ 14841.)
20.LOSS LEADER: If this Agreement involves the furnishing of equipment, materials, or
supplies then the following statement is incorporated: It is unlawful for any person
engaged in business within this state to sell or use any article or product as a "loss
leader" as defined in Section 17030 of the Business and Professions Code. (PCC
10344(e).)
v.01/08/2026 Page 4 of 4
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
SECTION 1: PROJECT PLAN, DESCRIPTION & SPECIFICATIONS
1.1 Project Identification
A.DATE: August 15, 2025
B.PROJECT NUMBER: RX-NORTH-107-MEU
C.PROJECT NAME: Ukiah West Hills VTP
D.REGION: North
UNIT: Mendocino
COUNTY: Mendocino
BATTALION: 3
E.PROJECT SPECIFICATIONS PREPARED BY:
Monica Morris, MEU Environmental Scientist
Julie Rhoads, MEU VMP Forester I, RPF #2815
Alex Leonard, MEU Battalion Chief – Battalion 3
Todd McMahon, RPF #2746, Principal, NCRM, Inc.
Kate Cahill, RPF #3031, Senior Forester, NCRM, Inc.
Madeline Green, RPF #3069, Senior Forester, NCRM, Inc.
Stephanie Martin, Project Manager/Senior Ecologist, NCRM, Inc.
Laura Moreno, Botanist, NCRM, Inc.
Kevin Britton, GIS Specialist, NCRM, Inc.
F.PROJECT ENVIRONMENTAL CHECKLIST (Section 3) PREPARED BY:
Stephanie Martin, Project Manager/Senior Ecologist, NCRM, Inc.
Kate Cahill, RPF #3031, Senior Forester, NCRM, Inc.
Laura Moreno, Botanist, NCRM, Inc.
G.LIST OF PARTICIPATING AGENCIES SIGNATORY TO INTERAGENCY AGREEMENT FOR PRESCRIBED
BURNING: N/A
H.LIST OF PARTICIPATING AGENCIES NOT SIGNATORY TO INTERAGENCY AGREEMENT FOR
PRESCRIBED BURNING: N/A
I.LIST OF PARTICIPATING PROPERTY OWNERS OR CONTROLLERS:
OWNER 1: Tawny Bailey
ADDRESS: 801 SPANISH CANYON DR
Ukiah, CA 95482
OWNER 2: Howard & Patricia Bridges
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Exhibit C
(Beneficial Fire Standard Agreement - RM 75
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
ADDRESS: 1650 Oak Knoll Road
Ukiah, CA 95482
OWNER 3: Claude & Janice Brooke
ADDRESS: 910 White Cottage Rd
Agnwin, CA 94508
OWNER 4: David Brooks
ADDRESS: 4942 Timbercreek Way
Sacramento, CA 95841
OWNER 5: Valerie Capri
ADDRESS: 1220 W Standley Ave
Ukiah, CA 95482
OWNER 6: Gaetan Caron
ADDRESS: 705 N State St #641
Ukiah, CA 95482
OWNER 7: Shawn Church
ADDRESS: 750 Boonville Rd
Ukiah, CA 95482
OWNER 8: City of Ukiah
ADDRESS: City of Ukiah Civic Center
300 Seminary Avenue
Ukiah, CA 95482
OWNER 9: Crown Castle GT Company LL
ADDRESS: 2000 Corporate Dr
Mcmurray, PA 15317
OWNER 9: D & J Investments
ADDRESS: PO Box 837
Ukiah, CA 95482
OWNER 10: Stephen Dangler
ADDRESS: 1550 Oak Knoll Rd
Ukiah, CA 95482
OWNER 11: Mathew & Amy Eiffert
ADDRESS: 1305 W Standley St
Oakland, CA 95482
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
OWNER 12: Cesare Galtieri TTEE
ADDRESS: 6901 Snake Rd
Ukiah, CA 94611
OWNER 13: Rick Garzini TTEE
ADDRESS: PO Box 333
Talmage, CA 95481
OWNER 14: Stephen Graves TTEE
ADDRESS: 133 Acacia Way
Vallejo, CA 94591
OWNER 15: Dean Guilfoyle TTEE
ADDRESS: 160 N Court Rd
Ukiah, CA 95482
OWNER 16: Leslie Hensley
ADDRESS: 9450 SW Gemini Dr
Beaverton, OR 97008
OWNER 17: Lisa Hillegas
ADDRESS: 1455 Oak Knoll
Ukiah, CA 95482
OWNER 18: Jemery Gould
ADDRESS: 1431 Oak Knoll Rd
Ukiah, CA 95482
OWNER 19: Martin Kamp TTEE
ADDRESS: 18 Orange Ave
Larkspur, CA 94939
OWNER 20: Efrain Lopez
ADDRESS: 201 Rosemary Ln
Ukiah, CA 95482
OWNER 21: Wendy & Greg Mackinnon TTE
ADDRESS: 1370 Boonville Rd
Ukiah, CA 95482
OWNER 22: Madrone & Suni Maltas
ADDRESS: 1575 Oak Knoll Rd
Ukiah, CA 95482
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
OWNER 23: Mathew & Tali Minor
ADDRESS: 1551 Oak Knoll Rd
Ukiah, CA 95482
OWNER 24: Miranda Jazmin Gonzalez
ADDRESS: PO Box 1379
Ukiah, CA 95482
OWNER 25: Jesus & Juanita Moreno
ADDRESS: 1501 Oak Knoll Rd
Ukiah, CA 95482
OWNER 26: Nui Rising Moon Trust
ADDRESS: PO Box 1780
Mountain View, CA 94042
OWNER 27: Lynette Rose TTEE
ADDRESS: 11201 Burris Ln
Potter Valley, CA 95469
OWNER 28: Andres Sandoval
ADDRESS: 1480 Woodway Ln
Redwood Valley, CA 95470
OWNER 29: Paul Scheller TTEE
ADDRESS: 1025 Simmons Ln
Novato, CA 94945
OWNER 30: Donald & Caro Strickland
ADDRESS: 486 Kennwood Dr
Ukiah, CA 95482
OWNER 31: Jerry Stutsman
ADDRESS: 1430 Boonville Rd
Ukiah, CA 95482
OWNER 32: Jun Takeda
ADDRESS: 705 N State St #205
Ukiah, CA 95482
OWNER 33: Raymon & Eloise Threde
ADDRESS: 850 Boonville Rd
Ukiah, CA 95482
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
OWNER 34: Meli & Christopher Walls
ADDRESS: PO Box 366
Ukiah, CA 95482
OWNER 35: Bonnie Wilderberger
ADDRESS: 230 Highland Ave
Ukiah, CA 95482
OWNER 36: Brain Wilsey TTEE
ADDRESS: 13750 Mountain House Rd
Hopland, CA 95449
OWNER 37: Barbara Yonkow
ADDRESS: PO Box 43
Fairfax, CA 94979
OWNER 38: City of Ukiah, Mendocino County
OWNER’S AGENT: Mendocino County
ADDRESS: City of Ukiah Civic Center
300 Seminary Avenue
Ukiah, CA 95482
1.2 Burn Area Description
A. PROJECT LOCATION:
The project is located on the western side of the Ukiah Valley, referred to as West Hills. This
project starts at the city foothills and consists of various private and public (City and County) and
is 16 miles northwest of Hopland, 20 miles northeast of Boonville, and 23 miles south of Willits,
CA. The project is bound by Orrs Creek on the north, Robinson Creek on the south, the city of
Ukiah and State Highway 101 on the east and the Eel River on the west.
USGS 7.5-min Quadrangles: Orr Springs, Boonville, Elledge Peak, Ukiah
Legal Description: T14N, R12W, Sections 5 and 6;
T14N, R13W, Section 1;
T15N, R12W, Sections 18, 19, 29-32;
T15N, R13W, Sections 13, 14, 23-26, 35 and 36; MDB&M
B. PARCEL ZONING AND LAND USE DESCRIPTION:
The project area is utilized for rural living and recreation, wildlife and watershed values.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
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C. CFES WILDLAND RESPONSE AREA OR WITHIN THE SRA: I-16, I-19a, I-19hz, I-27
D. PROJECT AREA TOTAL: 5,961 acres
E. PROJECT AREA NET: 998 treatment acres are currently scheduled for the first phase of
operations compromising of three main components: previously burned areas spanning 263
acres, areas designated for future controlled burns spanning 282 acres, and past/present fuel
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
break control lines covering 453 acres utilizing manual and mechanical treatments . The
ownerships are considered the Project Area, which is 5,961 acres.
F. UNIT FIRE PLAN HAZARD RATING: High and Very High
1.3 Environmental Setting and Impacts
A. In 2019, Governor Newsom included the Ukiah Emergency Fuels Reduction Project as one of 35
priority projects to implement immediately to reduce public safety risks for the most wildfire -
vulnerable communities. Under a State of Emergency, the requirements of CEQA were
suspended and environmental protections are built into the project design. CAL FIRE currently
proposes to implement Phase I vegetation treatments, including maintenance and retreatment,
on up to 998 acres of land on the western side of Ukiah Valley in Mendocino County. This
treatment would ultimately protect approximately 5,961 acres within the Project Influence
Zone, also considered the total Project Area. This includes property owned by the City of Ukiah,
Mendocino County, and privately owned lands within the Russian River watershed, specifically
on slopes west of the City. The project area is utilized for rural residence, agriculture, recreation,
and wildlife management.
This VTP project will be completed using prescribed fire as Wildland-Urban Interface (WUI)
treatment for grasslands, chaparral, and understory vegetation within oak woodlands and
mixed conifer habitats to create a mosaic of variously burned vegetation and islands of
unburned habitat. Treating vegetation around the community of Ukiah will help to build wildfire
resilience, while also improving the overall quality of the local ecosystem. Planned treatment
areas are stratified across the project area. The prescribed burning conducted under this VTP
will be done to meet objectives conducted under specific climatic conditions to ensure control
and minimize air quality and biological impacts. These conditions will mimic air, soil, and
vegetation moisture, and other conditions under which natural wildfires occur to maximize
beneficial effects on the plant and wildlife communities.
The primary goal of this prescribed burn is to reduce overall fuel loading to decrease the chance
of catastrophic wildfires in the future. A second goal is to reintroduce fire as a natural element
of the ecosystem. A third goal is to improve wildlife habitat by inducing new shoots from
sprouting species to increase forage production in chaparral, with islands of unburned fuel left
within burn units to provide shelter for small mammals. Grassland units will benefit from
increased growth of native perennial grasses and a decrease in noxious weeds.
Portions of the project site have remained fire-free for over two decades, allowing fuel
accumulation to reach maximum levels. Consequently, wildlife movement within the area has
been significantly reduced, and the flow of water from creeks and springs has been curtailed.
All native vegetative and wildlife species present within the project area are fire -adapted. The
reintroduction of fire into this ecosystem is part of the natural process.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Vegetation communities across the entirety of the West Hills are characterized by grasslands,
dense chaparral (chamise and manzanita), and mixed hardwood-conifer woodlands. Chaparral
coverage varies from nearly continuous to sparse, with grassy openings and areas featuring a
mixture of hardwood tree species and grasses. The chamise component ranges from pure stands
to a 50/50 mix with ceanothus, manzanita, and other chaparral species along with minor
amounts of herbaceous vegetation. Prescribed fire eliminates or reduces the ladder fuels that
connect ground vegetation to tree canopies, making them less susceptible to severe, crown -
consuming fires. It can result in a mosaic of differing successional stages of habitat that
promote plant and animal diversity.
Historically, chaparral fuel beds experienced fire every 15 to 20 years. These fuels attain
maximum volume with a high dead fuel component when fire is absent. The presence of
decadent fuels also reduces the ability of wildlife to move through the area and reduces the flow
of water from creeks and springs. All vegetative and wildlife species present within the project
area are adapted to fire. The introduction of fire, as part of a mosaic burn treatment of the
area, will return the chaparral ecosystem to a more natural process.
The project area is located within the Northern California Coast Ranges Ecological Section
(M261B), and ranges in elevation from 1,140 to 3,500 feet and consists primarily of Montane
Hardwood, Montane Hardwood-Conifer, grazed and un-grazed Annual Grassland, Mixed
Chaparral, and Chamise-Redshank Chaparral. Areas of oak woodland are present between
chapparal stands. A mosaic burn pattern in the chaparral fuel type is planned with a fuel
consumption rate of approximately 60-70%. Ignitions in burn units will include both interior and
perimeter ignitions. With multiple ignition sources, fire will spread at different rates and
intensities and will result in mosaic burns. Where applicable, perimeter ignitions at ridgetops
will be allowed to burn until spread is no longer carried by fuels and ground moisture conditions
no longer support fire. This will result in ridgetop fuel breaks. The terrain consists of slopes that
range from broad valleys with moderate to steep side slopes and gently sloped ridgelines.
Control lines are preplanned and will be established utilizing an existing road network as much
as feasible. A bulldozer may be employed to construct new control lines, fuel breaks, or re-
scrape overgrown roads and skid trails down to mineral soil to ensure functionality prior to
ignition. Handlines will be constructed in areas inaccessible to heavy equipment or where such
use is prohibited to avoid impacts to pre-identified sensitive resources (e.g., biological, cultural,
geological or other). Grading and other mechanical manipulations will be minimized. Minor
road maintenance such as grading, and brushing will need to be conducted to allow access by a
Type 3 Wildland Fire Engine. Mechanical vegetation removal (including the potential for
mastication) and pile burning may be necessary to avoid prescribed fire impacts to resources
identified for retention, especially where fuel loading i s high. Hazard tree removal and fuel
reduction along roadsides may be done with hand crews or mechanically prior to burning .
Targeted ground application of herbicides is also proposed.
CAL FIRE will administer burn operations, except on the City of Ukiah parcels. The Ukiah Valley
Fire Authority’s fuels crew will conduct operations on City-owned lands. An Incident Commander
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(IC) will be identified by the Unit Chief to supervise the entire burn operation. The perimeters
and interiors of burn units will be fired utilizing a combination of heli-torch (aerial), terra-torch
(mobile) and drip-torch (on-foot). The perimeters and majority of burn units will be fired utilizing
drip torches. Specific environmental parameters must be met prior to the initiation of burning
and must be maintained within predefined limits (i.e. burn specifications) for burning to
continue. Hourly weather reports will be conducted during the burn or as necessary if conditions
change to ensure operations are within specifications otherwise the burn may be extinguished
for safety reasons. Wind, fuel moisture, topography, control lines, and placement of holding
resources will determine the sequence of ignitions. Backing and flanking fire will be utilized
within units to ensure sufficient burned area is created for controlling a more intense head fire
that may be needed to adequately consume some fuel types. Ignitions shall not occur within
watercourses, and control lines will be maintained around pre -identified sensitive resources at
all times. Prescribed burning is a management tool that the City of Ukiah, Mendocino County,
and private landowners would like to employ with the assistance of a professional fire
department.
The Prescribed Fire IC will supervise holding resources and will designate a crew to monitor and
patrol the burn area to ensure that spread is contained within control lines . Necessary
suppression activities shall be focused on all fire outside of control lines and/or areas where fire
behavior poses an escape risk. The IC may also require monitoring, patrol, and holding
resources overnight.
• AESTHETICS - The project area is located outside any scenic views of California’s North Coast
that reside along SH 101, thus those scenic vistas will not be impacted. The proposed
treatments would not occur on lands adjacent , however, public viewpoints of the project
area are available from public recreation trails, adjacent residences and wineries, and SR 20.
The project, including the fuel breaks, is visible from Ukiah, and since it maintains the 2019
footprint, it will not increase aesthetic impacts. Visibility of treatment areas would be limited
from the highway and no vegetation would be removed immediately adjacent to the
highway. Short-term vegetation charring will be noticeable but will be replaced by new plant
growth during the next growing season. The degree of vegetation change is expected to be
minimal and not impact the natural aesthetics or character of the landscape. The
equipment, vehicles, and any vegetation treatment debris associated with the activities
proposed in this project will not block or disrupt views. Although some burn units may be
noticeable after treatment, the degree of vegetation change is expected to be minimal and
not impact the natural aesthetics or character of the landscape. No effects anticipated.
• AGRICULTURAL and FORESTRY RESOURCES – The project area consists primarily of Montane
Hardwood, Douglas fir-Hardwood woodlands, Chamise Chaparral and Manzanita Chaparral.
The treatment areas are primarily comprised of brush and shrub species intermixed to a
lesser extent with conifer and hardwood species. No part of this project will constitute
commercial timber operations.
• AIR QUALITY – Burning will be performed in accordance with a Smoke Management Plan
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approved by the Mendocino County Air Quality Management District (MCAQMD). This
document contains provisions for reducing the amount and duration of potential smoke
impacts. Venting height will be a minimum of 500 feet. Good atmospheric mixing and
adequate transfer winds to disperse the smoke column will be necessary for a successful
burn. The Smoke Management Plan also contains public notification procedures and
requirements. CAL FIRE will terminate if the planned convective lift and/or planned dispersal
cannot be achieved.
• BIOLOGICAL RESOURCES – A query of CDFW’s Natural Diversity Database (CNDDB) was
performed by the RPF consultant in June of 2022. GIS data available through BIOS website
was used to extract information on listed/sensitive species containing and surrounding the
project area. Data review was conducted of the project-specific biological resources,
including habitat and vegetation types, and special -status plants, special-status wildlife, and
sensitive habitats (i.e., sensitive natural communities and riparian habitats) with potential to
occur in the project area. Based on the CNDDB query and local knowledge of the project
area, biological scoping was conducted for each of the species shown as occurrences. Refer
to the Environmental Checklist in Section III for scoping and subsequent impact analysis
summaries.
Most species of plants and animals, including listed or sensitive species, will benefit from
habitat improvements that will likely result from the disturbance caused by the proposed
burning. The proposed burning will mimic the disturbance caused by natural fire in this fire
dependent landscape. Substantial evidence shows that habitat function of forest and
woodland is reasonably expected to improve with implementation of the treatment.
Historically, prior to fire suppression and logging, Douglas-fir-tanoak forests in the North
Coast Range experienced fire return intervals between 4 to 6 years, which likely promoted
open forests with greater cover of understory plant species. The benefit of prescribed
burning on the habitat of special -status species outweighs the cost of a severe, stand -
altering wildfire that would kill the forest and woodland habitat in the project area.
Common species of animals that use the area include black-tailed deer, quail, turkeys,
mountain lions, coyotes, squirrels, and raptors. This project should improve wildlife habitat
overall for these species by improving forage through the regeneration of shrubs and an
increase of native grass and forb dominated areas.
The objective is to use fire in a controlled manner during appropriate weather conditions to
reduce the risk of a large, intense, damaging fire that could cause significant impacts to soil,
vegetation, animals, air quality, etc. General operating practices incorporated into the
design of the burn plan that maintain or improve habitat function for listed wildlife species
include: 1) the burn prescription shall create a mosaic of burned and unburned habitat
within treatment units; 2) treatment units will occu py a small percentage of the landscape
and are dispersed over a large area such that unburned refugia are maintained close to
treatment units; 3) key habitat structures and locations such as nests, snags, cavity trees,
basal hollows, rock caves, large and course woody debris, and overstory trees, shall be
retained (and protected if necessary when the prescription would significantly alter or
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destroy them). Fire is valuable in rare plant conservation both directly, by fostering
emergence and regeneration of rare species, and indirectly, by cont rolling invasive species.
Native vegetation, including endangered plants, need fire to thrive and maintain resilience.
Prescribed burning is a positive management tool toward habitat recovery.
A notification letter was email ed to Kate Belville of CDFW on February 19, 2024, with project
description, protection measures, and project map. She was invited to share information or
any concerns. A response was received from Kate Belville on February 28, 2024, with no
concerns on the project. A revised letter was mailed to Merissa Hanisko of CDFW on May 20,
2025; questions and comments were received through multiple emails, which were clarified
and incorporated into the project design.
• CULTURAL RESOURCES – This project includes the entire City of Ukiah, County of Mendocino
and private landowner’s ownerships which total 5,961 acres. This project will utilize a
phased Archaeological process. An Archeological Survey Report (ASR) was completed for the
currently scheduled treatment units by Kate Cahill Senior Forester, RPF #3031, NCRM, Inc.
and was reviewed by Julie Rhoads MEU Forester II, RPF #2815 and CAL FIRE Archaeologist
Geoffrey Hughes. A cultural records search for the Project Area (ownership) was submitted
three separate times (as the project area expanded) and was received from the Northwest
Information Center (NWIC) at Sonoma State University on March 09, October 27 and
November 30 of 2023. There is one previously recorded historic resource site and no
previously recorded prehistoric resources site. Attachment B of the ASR provides copies of
correspondence with Native American tribes. The current survey effort resulted in the
identification of 1 previously unrecorded isolate.
If operations are planned on any additional areas during the life of this project, survey efforts
will be conducted through a second phase of archaeological review. Survey methods and
results will be added in an addendum to the ASR. A consultation with CAL FIRE Archeology
Program will occur if sites are identified within any additional units. No impacts to cultural
resources area expected.
• GEOLOGY and SOILS – There are no known unstable areas or geologic hazards within the
project area. Control line construction and non-shaded fuel breaks will result in the removal
of all vegetation down to bare mineral soil. Non-shaded fuel breaks will range from 100-
150ft pending slope, terrain and fuels. Some or all root systems will be removed during
control line construction. Control lines are long, linear features, ranging between 1 and 12
Feet in width. These long, linear features would not cause enough destabilization of an area
to cause landslides, as the root systems adjacent to the control lines would remain intact. No
impact is expected.
A notification letter was emailed to Kevin Doherty (Senior Engineering Geologist) of the
California Geological Survey-Forest and Watershed Geology Program on January 23, 2026,
with project description, protection measures, and project maps. He was invited to share
information or any concerns regarding potential impacts from geological hazards . As of
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February 19, 2026, CGS recommends that if ground disturbing activities occur in areas
identified as likely to contain naturally occurring asbestos (NOA) that CAL FIRE contact
Mendocino County AQMD to develop an Asbestos Dust Control Plan consistent with the
requirements of SPR AQ-5.
• HAZARDS and HAZARDOUS MATERIALS – This project involves control line
construction/maintenance, the use of prescribed fire as a treatment type, and fire
suppression. These activities will employ vehicles, fire engines, chainsaws, heavy equipment,
possibly helicopters, and fire ignition systems and accelerants that rely on a variety of
petroleum products (e.g., gasoline, diesel, jet fuel, oil and other lubricants) which pose a
health hazard to humans and the environment. CAL FIRE requires daily safety inspections
and a regular maintenance plan for all equipment to ensure that equipment is safe,
functional, and free of leaks. Spill kits are also kept with vehicles and equipment to contain
fuel and/or hydraulic leaks should they occur. Locations used for fueling the helicopter or
servicing fire ignition systems are established in areas where spills can be easily and rapidly
contained (i.e., level ground) that are also outside of Watercourse and Lake Protection Zones
(WLPZ) and other sensitive areas. Most fueling activities for the project will occur offsite at
CAL FIRE stations. Herbicide application to target plant species will employ ground-based
methods, such as using a UTV or backpack sprayer or painting herbicide onto cut stems. No
aerial spraying of herbicides would occur. Herbicides will not be utilized within WLPZs or
EEZs. In addition, herbicides would be applied by licensed applicators in compliance with all
laws, regulations, and herbicide label instructions. No impacts are anticipated.
• HYDROLOGY and WATER QUALITY – The project area lies primarily within the Gibson Creek
planning watershed, with portions in the Orrs Creek, Upper Robinson Creek, and Lower
Robinson Creek planning watersheds, all of which drain into the Russian River. Riparian
habitat is present within the project area adjacent to streams, lakes, and ponds . All
watercourses and wet areas will receive protection from ignitions and control line
construction with heavy equipment. Watercourse and Lake Protection Zones (WLPZs)
ranging from 50-150ft will be implemented for Class I and Class II stream s for ignitions,
manual and mechanical treatments. These areas will retain at least 75% of the overstory
and 50% of the understory canopy and would largely be limited to removal of
uncharacteristic fuel loads (i.e., dead or dying vegetation, invasive plants). No fire ignition
will occur within WLPZs, however, low intensity backing fires may enter or spread through.
There will be no debris or slash generated from prescribed burn treatment s deposited into
watercourses or wet areas. Equipment will not be driven in wet areas or WLPZs, except over
existing roads or watercourse crossings where vehicle tires or tracks remain dry. Equipment
will not be serviced in WLPZs or other wet areas that would allow grease, oil, or fuel to pass
into watercourses or wet areas. Equipment limitation zones will be designated adjacent to
Class III and Class IV watercourses with minimum widths of 25ft where side -slope is less than
30% and 50ft where side-slope is 30% or greater. Heavy equipment will be prohibited from
traversing slopes steeper than 50%; any slopes greater than 50% that require a control line
shall be constructed by hand crews. Existing roads and trails will be used as control lines as
much as possible. Where lighter fuel loads exist, mow and disk lines may be used to create
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control lines. Root systems will generally remain intact. Heavy equipment use will not occur
on wet saturated soils. Minor road maintenance such as grading, improving drainage and
brushing will need to be conducted to allow access by a Type 3 Wildland Fire Engine. All road
maintenance will occur within the existing road prism and there will be no creation of new
roads. Erosion control BMP’s will be implemented as needed for any ground disturbance in
the vicinity that has the potential to transport sediment. Where mineral soil has been
exposed on approaches to watercourse crossings of Class I, II, or III, the disturbed area will
be stabilized to prevent the discharge of soil. Water breaks will be installed to prevent runoff
from roads or fire lines reaching a watercourse where deemed necessary. Vegetation will be
burned in a mosaic pattern which will prevent riling and channeling and those unburned
areas between the project and creeks will buffer any minor runoff. Treatment areas will be
monitored for erosion control and mitigations prior to the rainy season. The broadcast burn
prescription will be designed to minimize soil burn severity by excluding burning in
conditions that would result in a high severity fire. Project activities will not violate any
water quality standards, deplete groundwater, or substantially alter the existing drainage
pattern. Impacts to hydrology and water quality are expected to be less than significant.
A notification letter was emailed to Jim Burke (Senior Engineering Geologist) of the North
Coast Regional Water Quality Control Board on February 19, 2024, with project description,
protection measures, and project map. He was invited to share information or any concerns
the Board might have regarding potential impacts to water quality. A response was received
from Youzhu Wang (ES Forestry and Wildfire Resiliency Unit Division of Water Quality) on
March 26, 2024, with a letter highlighting a few standard project requirements for the
project.
B. PROJECT TOPOGRAPHY:
The project area lies primarily within the Gibson Creek planning watershed, with portions in the
Orrs Creek, Upper Robinson Creek, and Lower Robinson Creek planning watersheds, all of which
drain into the Russian River. This area is within the Mendocino County interior region of hot, dry
summers and cool, wet winters. The mean annual precipitation is 39 inches and primarily occurs
from October to May.
The terrain generally consists of moderately steep slopes (50-70%), along with moderately
sloping ridgelines and benches (20-50%). Elevations range from 587 feet up to 2,766 feet.
Trending ridgeline aspects generally face south or north on either side of east/west running
drainages, while some smaller western and eastern -facing slopes are also distributed across
most of the units.
C. SOILS DESCRIPTION AND SENSITIVITY TO PROJECT ACTIVITIES:
Refer to “Geology and Soils” discussion in Section 1.3 A above.
D. VEGETATION COMMUNITY AND DOMINANT SPECIES:
The project area is located within the Northern California Coast (263A) and Northern California
Coast Ranges Ecological Section (M261B), and ranges in elevation from 587 feet up to 2,766
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feet. Vegetation within the project areas consists primarily of dense chaparral, predominantly
comprised of chamise, mixed hardwood -conifer woodlands, evergreen shrubs and native and
non-native grasses and forbs. There are a few areas of oak woodland present within montane
hardwood on the outskirts of the project area . The vegetation types targeted for treatment in
this plan, as classified in the CWHR habitat classification scheme, include annual grassland,
mixed chaparral, chamise-redshank chaparral, and understory vegetation in montane hardwood
and montane hardwood-conifer. Hardwood-pine overstory is not targeted for burning. Many of
the dominant plant species in these habitat types have evolved adaptations for surviving and
thriving after fire. Treatment units contain a mixture of grassland and chaparral, integrated
with patches of woodland vegetation types. Prescribed burning will enhance native plant species
that have evolved with fire, while simultaneously reducing non -native invasive plants where
possible. The frequency and intensity of burning is designed to avoid type -conversion of native
vegetation.
Prescribed burns are generally beneficial to wildlife by stimulating herbaceous plant diversity.
They are also used to stimulate growth of forbs, legumes and native grasses that are beneficial
as food and cover for a variety of wildlife species. For a chaparral ecosystem, the deep roots of
associated species help to stabilize slopes and allow them to thrive. Chaparral plant
communities depend upon fire as an integral part of their life cycle and periodic burning is
essential in order for these communities to rejuvenate, either from burl forming or seed
sprouting species. As unburned plants grow older, the amount of dead material increases. The
elimination of unnatural accumulations of dead and down vegetative debris will reduce the fire
intensity of a wildfire occurring during peak burning conditions during the summer or fall
months. Where chaparral plants are uniformly old, and cover a broad area, fires tend to be
large and devastating. The use of low -intensity prescribed fire will improve nutrient cycling and
serve to re-establish natural vegetative seral stages and fuel loadings. Certain species of wildlife
will benefit from younger stages while others, dependent on mature chaparral or dense
woodland understory, could be adversely affected by such changes. However, the effect is not
substantial given the adaptability of many species and the fact that the vegetation burns at
various intensities depending upon aspect, slope percent, slope position, and ignition
sequence/duration. This results in a mosaic effect, of burned and unburned areas, with the
overall impact generating habitat diversity, both in structure and plant species, supporting
numerous wildlife species.
Regeneration of chaparral species occurs through both the sprouting and reseeding process. Fire
removes shade that would otherwise hinder seedling success as well as allelopathic germination
inhibitors found in both the decaying organic material and the soil. Germination may also be
induced by heat shock or scarification of hard seed coats, nitrates released during combustion,
smoke, or a combination of these factors.
Research and experience have shown that fire can be used as a major management practice for
native and introduced grasslands, hay meadows, and establishing and managing new native
grass stands. Fire improves nutrients availability in the ecosystem by releasing nutrients tied up
in woody material, stimulates tillering, controls many woody and herbaceous plants, improve
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grazing distribution, and reduces wildfire hazards. Many undesirable grass, broadleaf, and
woody species can invade and reduce forage production and availability of native grasslands.
Prescribed burning can be used to reduce the invasion of these plants and maintain healthy
grasslands.
E. WILDLIFE/FISHERIES HABITAT AND SENSITIVITY TO PROJECT ACTIVITIES:
Refer to “Biological Resources” discussion in Section 1.3 A above.
F. CULTURAL RESOURCES AND SENSITIVITY TO PROJECT ACTIVITIES:
Refer to “Cultural Resources” discussion in Section 1.3 A above.
G. SMOKE AND COMMUNITY SENSITIVITY TO PROJECT:
The Ukiah West Hills project is situated atop the hills directly west of Ukiah, CA and the
surrounding parcel zoning ranges from Rural Residential to the City and the County. The West
Hills area remains predominantly undeveloped, excluding existing firebreaks, private access
roads, and an operational communication tower with its associated infrastructure. The area
serves various purposes, including rural and remote residences, agricultural activities, wildlife
management, and unsanctioned recreational use. The City of Ukiah borders a portion of the
project area on the east. Most of the developed parcels are located east of the project area. The
east portion of the West Hills is bounded by the highly populated City of Ukiah. The ideal wind
direction for prescribed burns will be from the southeast-east-northeast, driving smoke in a
west-northwest direction, away from the closest most populated area. The burn prescription has
been designed to mitigate the effects smoke on adjacent properties.
Also reference Smoke Management Plan (below).
H. GREENHOUSE GAS:
Greenhouse Gas (GHG) Emissions Calculations
The potential for generation of GHG emissions was evaluated for this project. The First Order
Fire Effects Model (FOFEM) was used to determine the amount and type of emissions likely to
occur through project implementation. Emission calculations are based on factors including fuel
models, fuel conditions, and expected fuel consumption in tons per acre. Calculations were
made for a maximum burn acreage of each Fuel Model below. Refer to the attached FOFEM
calculations for Fuel Models 4, and 8 and 9.
FOFEM CO2 Emissions:
Fuel
Model
FOFEM
CO2
Emissions
lbs/ac
Fuel Load
Tons/Ac
Acres Total CO2
Emissions
(MT)
FM 1 n/a n/a 1 n/a
FM 4 38,413 17.14 278 4,765
FM 8 66,932 29.88 48 1,464
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FM 9 29,621 13.22 220 2,909
Total CO2 emissions: 9,138
First Order Fire Effects Model (FOFEM) estimates that the planned prescribed burning will emit
an annual average of 9,138 metric tons of carbon dioxide for 545 acres (burn units) and 27 tons
of CO2 from motorized exhaust as a result of this project. Carbon dioxide that is released into the
atmosphere by this project will be sequestered by growth of new vegetation following the
prescribed burn. One objective of this project is to reduce the overall fire hazard in the area
which will lessen the chances of a large damaging wildfire. Large wildfires can cause significant
impacts to the environment including the emission of huge quantities of “greenhouse” gasses.
Reducing the wildfire threat through focused fuel treatments, including prescribed burns, will
lead to the long-term reduction in the number and size of large fires. Reducing this threat will
benefit the environment in a number of ways including the reduction of greenhouse gas
emissions.
One of the VTP objectives is to inhibit/prevent the spread of a wildfire moving through these
watersheds under severe fire weather conditions. The weather and fuel moisture parameters
prescribed in this burn plan will result in a rapid moderate intensity burn in grass with minor
effects on trees. In chamise and mixed chaparral fuel types where dead woody material is
present fire will move through at a higher intensity but overall, it will generally be a moderate
intensity burn through all units. Fuel type conversion will not occur. A mosaic burn pattern in the
chaparral fuel type is planned with a fuel consumpti on rate of approximately 60-70%. FM 4 will
have a higher rate of consumption while FM 8 and 9 will have lower rates of consumption. This
is lower than would occur under a high intensity wildfire. The lower the fire intensity, the lower
the CO2 emissions.
Fuel reduction projects that do not change the vegetation type are carbon neutral over time.
The planned mosaic burn pattern will lower the overall fuel consumption rate. The time needed
to sequester the carbon released by this prescribed fire project will be determined by the
subsequent regeneration of the vegetation.
ARB, 2010. http://www.climatechange.ca.gov/inventory/index.html
Bolsinger, Charles L. 1989. Shrubs of California's Chaparral, Timberland, and Woodland: Area,
Ownership, and Stand Characteristics
Conard, Susan G., and David R. Weise. 1998. Management of fire regime, fuels, and fire effects
in southern California chaparral: lessons from the past and thoughts for the future.
Helms, J.A. 2007. Thoughts on managing forests for carbon sequestration. The Forestry Source.
Mader, S. 2007. Climate Project: Carbon Sequestration and Storage by California Forests and
Forest Products. [Technical Memorandum prepared for California Forests for the Next Century]
CH2M HILL, Sacramento, CA.
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I. PROJECT MAPS: See attached.
1.4 Burn Prescription
A. SCHEDULE:
Burn Days: Monday through Friday, and weekends if conditions are favorable
Burn Months: August 15 through March 15 for mosaic ecological burning
March 15 through June 30 for wildfire hazard reduction
June through August for grassland burns.
Burning will be conducted when fuels are within prescription and the burning will achieve the
desired treatment objectives for both wildlife fuel mosaic and wildfire hazard reduction of fuels.
Wildlife fuel mosaic burning consists of perimeter and interior ignition at a level sufficient to
obtain a target fuels consumption of approximately 60 -70%. Fire will be allowed to back into
burn units until spread is no longer possible due to fuel and ground moisture conditions.
B. FUEL DESCRIPTION:
Vegetation communities across the entirety of the West Hills are characterized by dense
chaparral, predominantly comprised of chamise, and mixed hardwood -conifer woodlands. The
vegetation within the cleared control lines primarily consists of native and non -native grasses
and forbs, interspersed with patches of mixed hardwood -conifer trees and evergreen shrubs.
Vegetation types in the vicinity of the project area encompass grasslands, chamise chaparral,
manzanita chaparral, mixed hardwood forest, and Douglas -fir – hardwood forest. Chaparral
coverage varies from nearly continuous to sparse, with grassy openings and areas featuring a
mixture of hardwood tree species and grasses. The chamise component ranges from pure stands
to a 50/50 mix with ceanothus, manzanita, and other chaparral species along with minor
amounts of herbaceous vegetation. The application of prescribed fire within this project will be
confined to grassland, chamise, and mixed chaparral fuel types. Estimated fuel type composition
of the burn units is 5% grass (mixed herbaceous), 55% chamise/mixed chaparral, and 40%
conifer/hardwood forest (Doug-fir, Pacific madrone, tanoak).
1) FUEL TYPE AND CHARACTERISTICS:
a. FUEL MODEL(s): model number based on Hal Anderson’s Aids to Determining Fuel
Models, General Technical Report INT-122.
FM 1 - This fuel type consists of 1-hour fuels and is characteristic of the grassland in
scattered openings found through the project area. This area includes oak woodland.
Fire is expected to burn through cured surface fuels rapidly with little residual burning
and minimal effect on oaks. There are areas of grassland intermixed throughout the
project area.
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FM 4 - This is the primary chaparral model found scattered throughout the project area.
Fire spreads with high intensity and rapid spread through the foliage and the live/dead
fine woody material in the crowns of shrubs. The primary species is chamise, with the
balance consisting of mixed chaparral stands of ceanothus and manzanita species,
toyon, and poison oak. Dead woody material in parts of the stand will significantly
contribute to fire intensity. Most of the proposed project area and burn units are
composed of mixed chaparral. Chamise chaparral is commonly found on the south -
facing, xeric slopes within the project area.
FM 8 - This is a timber litter model. Dead foliage litter is primarily tightly compacted
hardwood or conifer litter. As fire extends into these areas from chamise/chaparral
stands, slow-burning ground fires with low flame heights should prevail, although fire
may encounter an occasional "jackpot" or heavy fuel concentration that can flare up.
Some species in this model have ladder fuels associated with them but fire is not
expected into the canopy under the target burn prescription. The main conifers present
in the project area are Doug-fir, pine, and redwood. Areas of mixed hardwoods and
Douglas-fir forests are present on north-facing slopes and along drainages in the project
area; hardwoods typically include tanoak and Pacific madrone.
FM 9 - This is a timber model consisting of dense stands of conifers and mostly
hardwoods located on north-facing slopes and within ravines. The primary fuel is dead
foliage consisting of tightly compacted hardwood or conifer litter. Under the weather
and fuel conditions prescribed for this project, it is expected that surface fire will be
minimal.
b. VEGETATION 1” to 24" TALL:
This vegetation includes annual grasses, which are expected to be fully cured when the
burn is conducted. Perennial grasses and herbaceous fuels are present in various burn
units.
c. VEGETATION 24” PLUS:
Vegetation includes FM 4 chamise, ceanothus spp., manzanita, and other chaparral
fuels. Chamise has a live component ranging from 60-80%. At the time of the burn, the
chamise will have a live fuel moisture between 60-80%. Vegetation in the project area
greater than 6-ft tall includes conifer and hardwood stands.
d. FUEL ARRANGEMENT :
The fuel component ranges from annual and perennial grassland, oak woodland,
chaparral, pine, and some mixed conifer. FM 1 fuels are arranged vertically. FMs 4, and 8
are primarily arranged vertically with a horizontal component including a duff layer. FM
4 consists of chamise and mixed chaparral. Closed canopy hardwood/conifer stands and
/or stands interspersed with chaparral species characterize FM 8 and closed canopy
montane hardwood characterizes FM9.
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Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
e. FUEL CONTINUITY :
FM 1: Continuous
FM 4: Nearly continuous. Canopy cover ranges from 80-90%.
FM 8: Nearly continuous. Canopy cover ranges from 50-80%.
FM 9: Continuous. Canopy cover 95% or higher.
Fuel continuity is similar for fuel models both within and outside of the project area. Fire
will be used in a manner (within a specified range of environmental conditions) to target
the primary fuel type in each unit. In many instances, units are a heterogenous mixture
of grassland and chaparral, but may also contain overstory tree species not part of the
burn prescription.
f. SURFACE FUEL DEPTH :
Annual and perennial grasses: 1-2 ft.
Chamise and mixed chaparral: 3-6 ft.
Conifer or mixed hardwood stands: 4”-3 ft.
g. DUFF DEPTH:
The FM 4 understory fuels consist primarily of leaf litter and duff, ranging from 1 -in. to 4-
in. depth. Where the FM 8 and 9 hardwood/conifer overstory is dense, there is a light-
to-moderate component of 100 and 1000-hour fuels.
2) FUEL LOADING:
FM 1: Total fuel load is generally less than 1 ton/acre. Fuel is expected to be cured at time of
ignition.
FM 4: Total fuel load ranges from 8-12 tons/acre, dead fuel load estimated at approximately
4-5 tons/acre.
FM 8: Total fuel load ranges from 2-6 tons/acre, includes both live and dead woody
material.
FM 9: Total fuel load ranges from 3-4 tons/acre, dead fuel load estimated at approximately
2-3 tons/acre.
3) FUEL CONSUMPTION PLANNED:
FM 1: 70-90%
FM 4: 60-70%
FM 8: 40-60%
FM 9: 20-40%
4) FUEL TREATMENT PLANNED:
Fire lines may be constructed as necessary to secure unit perimeters by bulldozers or hand
crews. A masticator may be used from the road to pretreat control lines.
5) NARRATIVE:
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Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Target fuel for burning range from grass to chamise and mixed chaparral to timber
understory.
a. FIRING/IGNITION PROCEDURES:
Firing will typically begin uphill and upwind and proceed down slope and into the wind,
until sufficient black line is created to assist in containing the fire at the prescribed
intensity. Ignition devices include, but are not limited to: drip-torch, terra-torch, PSDs,
and helitorch. The IC, Operations Chief, and/or Burn Boss will determine the timing and
location of the different firing tools and methods.
b. PROVISIONS FOR TEST FIRE & RECORDING RESULTS:
The test burn will be conducted on the day of the burn in a representative location within
the project area. The test burn will be adequately sized to determine whether the project
burn is feasible under ambient temperature, humidity, wind conditions, if smoke
dispersal and direction are acceptable and within planned constraints, if fuel
consumption is adequate to meet objectives, and if fire behavior will produce results
within acceptable parameters. These results will be used to proceed with the Go/No Go
decision.
c. HOLDING PROCEDURES:
The primary objective for holding resources is to keep the prescribed fire within
established control lines. The Holding Group Supervisor will provide direction to all
holding resources assigned. Efforts will concentrate on mitigating possible threats to
burn plan objectives, protection of sensitive features and to reduce any potential risk
identified by the Holding Group Supervisor, Division Group Supervisors, Operation
Section Chief, or the Incident Commander.
d. OTHER PROJECT MANAGEMENT CONCERNS:
Communications Needs
All ignition personnel, holding personnel and assigned overhead will be equipped with HT
radios. All personnel will be briefed on communication procedures and frequencies
assigned to the project. Frequencies assigned to the project are defined in the
Communications Plan (ICS 205) found in the Incident Action Plan (IAP).
Medical Facility
Medical facilities are outlined in the Medical Plan (ICS 206) found in the IAP.
Safety and Health/Job Hazard Analysis
SAFETY IS THE NUMBER ONE PRIORITY. All participants will utilize appropriate personal
protective equipment (PPE). Refer to the IAP Safety Message and Job Hazard Analysis for
additional safety concerns. All participants will receive a safety tailgate briefing (IIPP6)
by their assigned supervisor. Direct fire line supervision will be utilized by Division Group
Supervisors if necessary.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Helicopter Operations
A CAL FIRE helicopter may be utilized for firing operations. In the event of an escape the
helicopter will deploy the water dropping bucket for suppression activities. All
appropriate aircraft safety policies will be reviewed, and personnel will be briefed prior
to operations.
Escaped Fire Procedures
The Incident Commander (IC) is responsible for declaring an escaped fire. In the event of
an escaped fire, the IC will make required notifications and request additional resources
as needed.
Post Burn Summary and Documentation
Upon completion of the burn, a post burn evaluation will be completed using a
Prescribed Burn Completion Report. The evaluation will be used to determine if the burn
plan objectives were met.
C. WEATHER AND FUEL MOISTURE:
General information: The VTP burn prescription is a combination of desired weather and fuel
conditions needed to accomplish various burn objectives, such as to reduce h igh fire hazard fuels
by 50%, to improve wildlife habitat forage, and to maintain/increase the balance of native plant
species. The burn objectives will dictate how hot or cool the fire should burn, when and where to
burn, and what equipment to employ for best results. The results can be obtained from
nomograms but preferably are obtained from a recent BehavePlus (a computer model of fire
behavior outputs that require weather and fuel moisture numbers for input , current version 6
Beta was released on February 7, 2018 ).
The opportunity to burn is referred to as a "burn window ” and is dependent on the range of
weather and fuel moisture tolerances allowed in the prescription. The window should be wide
enough to achieve objectives without jeopardizing personnel safety. A narrow burn window
limits the statistical probability that the conditions will be met and assumes that specified
personnel and equipment are readily available .
1) WEATHER DATA COLLECTION:
a. LOCATION(S) /METHOD(S) OF DATA COLLECTION:
Information regarding local weather and wind speeds may be obtained from a portable
RAWS station placed at the project site prior to and during project burn implementation.
Additional information regarding weather and wind speeds will be obtained from the
Ukiah Municipal Airport NWS/FAA station:
ID: KUKI
Latitude: 39.12783°
Longitude: -123.20011°
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Elevation: 597-ft
Location: Ukiah Municipal Airport
MNET: NWS/FAA
IMS ID:
Accessible at:
https://mesowest.utah.edu/cgi-bin/droman/meso_base_dyn.cgi?stn=KUKI
Personnel will be assigned to monitor the site before ignition and hourly until the fire is
declared out by the incident commander. Personal data collection will utilize Kestrels
and/or sling psychrometers w/NOAA National Weather Service Relative Humidity/Dew
Point Tables to obtain dry/wet bulb temperatures & relative humidity. Wind speeds will
be obtained using Kestrels.
Other weather-related sites such as www.nws.noaa.gov, and http://www.arb.ca.gov .
Local news media weather forecasts may be used as needed.
b. DATA TO BE COLLECTED:
Location
Elevation
Time
Wind speed/direction
Temperature
Wet bulb
RH
Dew Point
Sky/weather
c. SAMPLING PERIOD:
The RAWS platform provides for hourly sampling. Data can be retrieved online or via
radio as necessary. A record of the Ukiah Municipal Airport NWS/FAA will be obtained
for 1 week prior to the burn, with this record included in post -burn documentation. Data
collection will begin when personnel arrive on site on the day of the burn and will
continue until mop-up operations are complete. Weather will be taken hourly or anytime
a significant atmospheric change is observed.
d. FORECASTS:
Spot weather forecasts will be obtained prior to and on the day of the burn. Primary
forecast elements will be sky/weather summary, temperature, humidity, eye level winds,
20-foot winds, chance of wetting rain, marine layer and lightning activity level. Weather
discussions will also be evaluated to determine the possibility of approaching frontal
systems. General weather forecasts will be obtained locally as available.
e. FORECASTING ENTITY:
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Spot weather forecast - National Weather Service (NWS) Forecast Office at:
http://www.wrh.noaa.gov/firewx/?wfo=eka (Eureka Office)
Other resources available- Digital Fire Weather Point Forecast Matrix Interface available
at:
http://www.wrh.noaa.gov/firewx/fwpfm/fwpfm.php?wfo=eka&interface=firewx .
Spot weather forecast will be requested for 48 hours prior, 24 hours prior and day of the
burn. Additional information pertaining to estimated smoke mixing heights and upper
level smoke transport winds, as well as Spot Weather Forecasts are available from the
NWS Predictive Services Unit in Redding at:
http://gacc.nifc.gov/oncc/predictive/weather/
Prescribed burn planning, smoke management, and reporting is coordinated with the
MCAQMD through the Prescribed Fire Information Reporting System (PFIRS), managed
by the California Air Resources Board. Public dashboard: https://ssl.arb.ca.gov/pfirs/
f. SPECIFICATIONS, WARNINGS:
No adverse changes in weather patterns predicted over the project area during or
immediately following burning operations. The burn will not be implemented should any
adverse weather event be predicted that will exceed prescription parameters or threaten
burn plan objectives. Approval and shutdown of burning operations are subject to
determination by the Mendocino County Air Quality Management District (AQMD).
Consultation may also occur with the Lake County Air Quality Management District
(LCAQMD) and the Glenn County Air Pollution Control District (GCAPCD).
g. PROBABILITY OF ADVERSE WEATHER:
Based upon pre-burn monitoring of meteorological conditions and spot forecasts to be
received from the NWS, as well as discussions with the M CAQMD, it is estimated that
there is less than a 10% chance that unpredicted adverse conditions will occur on site
during the burn and within 24-hours following completion of the burn.
h. ADDITIONAL COMMENTS: n/a
2) PRESCRIPTION FOR FUEL MOISTURE, WEATHER, AND SOILS:
TARGET MIN MAX
a. RELATIVE HUMIDITY 25 15 90
b. AIR TEMPERATURE (DRY BULB °F) 75 40 90
c. WIND DIRECTION NE, E, SE
d. WIND SPEED (MPH, MID FLAME) Any 0 10
e. FUEL MOISTURE - LIVE (%) 60-70 100 200
FUEL MOISTURE - DEAD (%)
1 hr 6 5 8
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Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
10 hr 8 7 10
100 hr 10 9 12
f. SOIL/DUFF MOISTURE N/A
g. DUFF MOISTURE N/A
h. PRECIPITATION AND DAYS SINCE LAST RAIN N/A
1.5 Fire Behavior Predictions
A. Outputs from BEHAVEPLUS 6.0.0 were generated using values for the maximum allowable
prescription conditions listed above.
Fuel PIG
Model
head flanking backing head flanking backing head flanking backing head flanking backing
1 297 15 8 504 19 13 8 2 2 46 1 1 68
4 222 8 4 10,968 299 212 33 6 5 595 27 19 68
8 6 <1 <1 21 1 0 2 <1 <1 1 0 0 68
9 32 1 <1 227 6 5 6 <1 <1 20 0 0
Scorch Height
(ft)
Fire Line Intensity
BTUs/ft/sec
Rate of Spread
(chains/hr)
Flame Length
(ft)
1) PROBABILITY OF IGNITION:
Target: 50%
Acceptable: 30-70%
2) BURNOUT TIME:
Target: 2-4 hours
Acceptable: 4-6 hours
3) BEHAVIOR NARRATIVE:
The burn will be initiated as a flanking and backing fire until sufficient burned area can
safely accommodate a head fire within control lines. Sufficient resources will be onsite to
pick up spot fires. Aggregations of Fuel Models 8 and 9 within treatment unit boundaries
may carry fire during burns implemented in June -July. Under target prescription, fire will be
limited to surface fuels (< 6-ft height). Reference attached BehavePlus 6.0.0 fire behavior
prediction worksheets.
1.6 Smoke Management Plan
A. AFFECTED AREAS AND CONDITIONS:
1) AIR POLLUTION CONTROL DISTRICT (AIR QUALITY MGMT DISTRICT):
Mendocino County Air Quality Management District
306 East Gobbi Street
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
Ukiah, California 95482
Phone: 707-463-4354
Email: mcaqmd@mendocinocounty.org
The project area is located within central Mendocino County and not adjacent to any other
air district.
2) AIR BASIN: North Coast
3) SMOKE SENSITIVE AREAS:
The community/city of Ukiah, and associated rural development area, and Highway 101 are
the most smoke sensitive areas. Other communities include Redwood Valley, Hopland and
Navarro which are not expected to be impacted by smoke.
Distances:
Ukiah: Directly east bordering the edge of the community
Redwood Valley: 10.7 miles northeast
Boonville: 21 miles southwest
Hopland: 15 miles south
4) AIR QUALITY CONDITIONS:
Burn only on a permissive burn day unless otherwise approved by MCAQMD. Visibility
impacts are unlikely due to the low population density surrounding the project area. Smoke
may impact a small number of residents within the vicinity, but those impacts are expected
to be transitory and insignificant. Any unanticipated smoke impacts would follow measures
outlined in the smoke management plan.
B. SMOKE DISPERSAL PLAN:
1) WIND DIRECTION:
NE, E, SE would be preferable, any direction would be acceptable given enough venting and
mixing.
2) VENTING ELEVATION:
Minimum of 500 feet.
3) SMOKE DISPERSAL AREA(S):
None
Smoke Travel Projections - Although planned downwind areas are largely rural, there are
smoke sensitive areas such as the communities listed above. Smoke travel during project
implementation will depend upon prevailing surface and gradient winds. The target wind
projection of NE/E/SE will result in a smoke projection of SW/W/NW. This information is
based on prevailing wind data collected from the Ukiah Municipal Airport NWS/FAA station.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
4) VISIBILITY FACTORS:
Project Site: None
Smoke Dispersal Area: None
5) NARRATIVE:
All burning shall be conducted in accordance with direction from the MCAQMD. It is not
expected that smoke from this burn will affect air quality outside of the county. Smoke
receptors for the project are the nearby communities as noted above, city of Ukiah, as well
as vehicle traffic on Highway 101 and residences located along the Highway 101 corridor,
and along nearby rural roads.
Burn conditions specified in the prescription will mitigate adverse smoke impacts. A n
easterly wind pattern will move smoke away from most populated areas. Smoke columns
will be visibly monitored for direction and lift in order to evaluate smoke dispersal/transport
predictions. Personnel will be assigned to observe smoke dispersal as necessary. The burn
will be curtailed if the planned convective lift and/or planned dispersal cannot be achieved.
Smoke dispersal conditions will be evaluated in the morning, at the test burn, and
continually monitored throughout the duration of the project. On site monitoring will
include weather, smoke and fire behavior observations. Additional Information will be
collected from the CAL FIRE Portable RAWS located at the project area. Estimated mixing
heights and upper level transport winds will be obtained from the Redding Interagency
Fire/Forecast Warning Unit internet site at: www.fs.fed.us/r5/fire/north/fwx/smok.txt or at
the National Weather Service-Eureka spot forecast internet site at:
http://www.wrh.noaa.gov/eka/.
In an effort to minimize daily and cumulative air quality impact to the regional area, the
project will be scheduled in coordination with the MCAQMD and any other local ag ency
prescribed fire projects.
1.7 Public Information Plan
CAL FIRE Mendocino Unit will issue a county-wide press release 24-hours prior to the burn. This
press release will include contact information for a public information officer who can answer
questions regarding burn activities. CAL FIRE will also notify surrounding residents one to three days
prior to the planned burn date.
On the day of the burn, the following agencies will be notified :
MCAQMD: (707) 463-4354
CAL FIRE Howard Forest Command Center: (707) 459-7403
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Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
1.8 Project Implementation Task Schedule
Tasks Responsible Party Time of Completion
Any required pre-operative
surveys for specific areas Environmental Coordinator Prior to operations (new
control lines and ignition)
Burn unit layout and
flagging of protected areas Environmental Coordinator Prior to operations (new
control lines and ignition)
Construction of fuel
breaks/control lines Landowner/CAL FIRE Prior to ignition
Road grading/repair for
access Landowner/CAL FIRE Prior to ignition
MCAQMD Smoke
Management Plan IC Prior ignition
Public Information Plan IC See 1.7 Public Information
Plan
MCAQMD Burn
Authorization Plan IC Day prior to ignition
Prepare Incident Action Plan
(IAP) IC Day prior to ignition
Prepare Go/No Go Checklist IC Day of ignition
Obtain burn approval from
CAL FIRE MEU ECC, Duty
Chief, Unit Chief, and Region
Chief
IC Day of ignition
Conduct test fire IC and Ground Resources Day of ignition
Prescribed fire ignition IC and Ground Resources Day of ignition
Extinguish and Mop-up IC and Ground Resources IC discretion
Post-burn evaluation and
response of vegetation,
assessment of protected
areas
Environmental
Coordinator/Archaeologist/VTP
Forester
At least several months
after the burn
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Ukiah West Hills VTP Section 1 – Project Plan RX NORTH-107 MEU
1.9 List of Attachments
Section 2: PROJECT COST SUMMARY
Apportionment of Benefits
CALFIRE Resources Cost Analysis Worksheet
Section 3: ENVIRONMENTAL CHECKLIST
Section 4: INCIDENT ACTION PLAN
Plan attached
Plan to be submitted with first activity report
Smoke Management Plan
OTHER ATTACHMENTS
RM-75 Agreements for Prescribed Burning
Project Maps
BEHAVE outputs
FOFEM outputs
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
UKIAH WESTERN HILLS VEGETAT
CALVTP PROJECT SPECIFIC ANALYSIS
AND ADDENDUM FOR THE
ION
TREATMENT PROJECT
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
Exhibit D
(Beneficial Fire Standard Agreement - RM 75)
TABLE OF
CONTENTS
LIST OF ABBREVIATIONS .............................................................................................................................. III
1 INTRODUCTION 1
1.1 PROJECT OVERVIEW & DOCUMENT PURPOSE 1
1.1.1 Proposed Project 1
1.1.2 Lead Agency 2
1.1.3 Purpose of This Project-Specific Analysis/Addendum 2
2 TREATMENT DESCRIPTION 2
2.1 PROJECT SITE DESCRIPTION 3
2.1.1 West Hills 4
2.2 PROPOSED TREATMENTS 4
2.2.1 Treatment Types 4
2.2.2 Treatment Activities 5
2.3 RETREATMENT/TREATMENT MAINTENANCE 9
3 ENVIRONMENTAL CHECKLIST 11
4 PROJECT-SPECIFIC ANALYSIS/ADDENDUM 16
4.1 AESTHETICS & VISUAL RESOURCES 17
4.1.1 Aesthetics & Visual Resources Discussion 18
4.2 AGRICULTURE & FORESTRY RESOURCES 20
4.2.1 Agriculture & Forestry Resources Discussion 20
4.3 AIR QUALITY 22
4.3.1 Air Quality Discussion 23
4.4 ARCHAEOLOGICAL, HISTORICAL & TRIBAL CULTURAL RESOURCES 26
4.4.1 Archaeological, Historical & Tribal Cultural Resources Discussion 26
4.5 BIOLOGICAL RESOURCES 30
4.5.1 Biological Resources Discussion 31
4.6 GEOLOGY, SOILS, PALEONTOLOGY & MINERAL RESOURCES 57
4.6.1 Geology, Soils, Paleontology & Mineral Resources Discussion 57
4.7 GREENHOUSE GAS EMISSIONS (GHG) 62
4.7.1 Greenhouse Gas Emissions (GHG) Discussion 62
4.7.2 GHG Emissions Summary 65
4.8 ENERGY RESOURCES 66
4.8.1 Energy Resources Discussion 66
4.9 HAZARDOUS MATERIALS, PUBLIC HEALTH & SAFETY 67
4.9.1 Hazardous Materials, Public Health & Safety Discussion 67
4.10 HYDROLOGY & WATER QUALITY RESOURCES 70
4.10.1 Hydrology & Water Quality Resources Discussion 71
4.11 LAND USE & PLANNING, POPULATION & HOUSING 74
4.11.1 Land Use & Planning, Population & Housing Discussion 74
4.12 NOISE 76
4.12.1 Noise Discussion 76
4.13 PUBLIC SERVICES, UTILITIES & SERVICE SYSTEMS 78
4.13.1 Public Services, Utilities & Service Systems Discussion 78
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4.14 RECREATION 80
4.14.1 Recreation Discussion 80
4.15 TRANSPORTATION 81
4.15.1 Transportation Discussion 81
4.16 WILDFIRE 83
4.16.1 Wildfire Discussion 83
5 LIST OF PREPARERS 85
6 REFERENCES 86
Attachments
A Mitigation Monitoring and Reporting Program
B Archaeological Survey Report- Confidential Information Attached Separately
C Observed Plant Species List
D Hazardous Materials
E CNDDB Summary Table
F Soils Report
Tables
Table 2-1 Proposed Treatment Size by Site............................................................................................................ 4
Table 2-2 Proposed CalVTP Treatments ............................................................................................................... .9
Table 2-3 Retreatment/Treatment Maintenance Activities ............................................................................................. 10
Table 4.5-1 Special-Status Plant and Wildlife Species That May Occur in the Treatment Areas ................................ 35
Table 4.5-2 Sensitive Natural Communities Documented or with Potential to Occur in the Treatment
Areas .................................................................................................................................................. 52
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
LIST OF ABBREVIATIONS
Board California Board of Forestry and Fire Protection
CAAQS California ambient air quality standards
CAL FIRE California Department of Forestry and Fire Protection
Cal-IPC California Invasive Plant Council
CalVTP California Vegetation Treatment Program
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
City City of Ukiah
CNDDB California Natural Diversity Database
CRHR California Register of Historical Resources
DBH diameter at breast height
EPA U.S. Environmental Protection Agency
FRA
GHG
Federal Responsibility Area
greenhouse gas
IPaC Information for Planning and Consultation
LRA Local Responsibility Area
MCAQMD Mendocino County Air Quality Management District
MCFSC Mendocino County Fire Safe Council
MEU CAL FIRE’s Mendocino Unit
MMRP mitigation monitoring and reporting program
NAAQS national ambient air quality standards
NAHC Native American Heritage Commission
NWIC Northwest Information Center
PEIR Program Environmental Impact Report
PIZ
PSA
Project Impact Zone
Project-Specific Analysis
SENL single event noise levels
SPR standard project requirements
SR state route
SRA State Responsibility Area
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UTV utility task vehicle
VMT vehicle miles traveled
WLPZ
WUI
Watercourse and Lake Protection Zones
Wildland Urban Interface
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
1
1 INTRODUCTION
1.1 PROJECT OVERVIEW & DOCUMENT PURPOSE
The significant toll that wildfires have imposed on communities in northern California is noteworthy, and the size and severi ty
of large-scale fires, like those experienced in California over the last decade, show no signs of diminishing. Several factors
have contributed to the current conditions, including but not limited to substantial development in the Wildland Urban Interface
(WUI), the impact of climate change, years of severe drought, and the overall suppression of naturally occurring fires. The
goal, with the help of this document, is to treat lands around the community of Ukiah to help build resilience against wildland
fire, while also improving the overall quality of the local ecosystem.
The Final Program Environmental Impact Report (PEIR) of the California Vegetation Treatment Program (CalVTP; State
Clearinghouse #2019012052) evaluated potential environmental consequences associated with the implementation of
qualifying vegetation treatments aimed at reducing the risks of wildfire throughout the State Responsibility Areas (SRAs) in
California. The PEIR was designed for use by many State, special district, regional, and local agencies to expedite the approval
process for vegetation treatment projects falling within the same scope of the PEIR. When needed, the PEIR is supplemented with
minor technical details concerning a proposed project, presented in the form of an addendum, as is the case with this document.
This document addresses technical details for the treatments surrounding the City of Ukiah (referred to as “the City”).
To assist with this effort, the California Board of Forestry and Fire Protection (referred to as “the Board”) supports the
preparation of Project-Specific Analysis (PSA) documents. These documents are intended to establish a repository of
exemplary projects that can assist both State and local agencies in creating their PSAs under the CalVTP PEIR. Furthermore,
they facilitate compliance with the California Environmental Quality Act (CEQA) for the proposed projects. The Board selected
the Mendocino County Fire Safe Council (MCFSC) proposed vegetation treatment project under the California Climate
Investments Fire Prevention Grants Program, and this PSA provides CEQA-compliance for the approval and implementation
under the CalVTP PEIR, thus streamlining the approval process for the Ukiah West Hills VTP.
1.1.1 Proposed Project
In 2019, Governor Newsom included the Ukiah Emergency Fuels Reduction Project as one of 35 priority projects to implement
immediately to reduce public safety risks for the most wildfire-vulnerable communities. Under a State of Emergency, the
requirements of CEQA were suspended and environmental protections are built into the project design. CAL FIRE currently
proposes to implement vegetation treatments including maintenance and retreatment on up to 998 acres of land on the western side
of Ukiah Valley in Mendocino County (Figure 1.1-1). This treatment would ultimately protect approximately 5,961 acres within
the Project Influence Zone, also considered the total Project Area. This includes property owned by the City of Ukiah,
Mendocino County (referred to as “the County”), and privately owned lands within the Russian River watershed, specifically
on slopes west of the City. The project area is utilized for rural residence, agriculture, recreation, and wildlife management .
This project is the result of a Wildfire Prevention Grant that was awarded to the Mendocino County Fire Safe Council
(MCFSC), CAL FIRE Grant Project 21-CNR-MEU-024.
The proposed treatment methods (commonly known as “fuel breaks”) and the associated activities (involving prescribed
burning, manual and mechanical treatments, as well as herbicide application) are consistent with those evaluated in the CalVTP
PEIR. Ongoing maintenance of initial treatments (referred to as “retreatment/treatment maintenance” or “maintenance” in this
PSA) would employ the same types of vegetation treatment and activities used in the original treatment.
The primary goal of the prescribed burn is to reduce the overall fuel load, thereby diminishing the likelihood of future
catastrophic wildfires within the Project Impact Zone (PIZ). This will be accomplished by reintroducing fire as a natural
component of the ecosystem. A secondary goal involves enhancing wildlife habitat by encouraging new growth from sprouting
species to increase forage production. Within burn units, pockets of unburned fuel will undoubtedly remain to provide shelter
for small mammals.
Portions of the project site have remained fire-free for over two decades, allowing fuel accumulation to reach maximum levels.
Consequently, wildlife movement within the area has been significantly reduced, and the flow of water from creeks and springs
has been curtailed. All native vegetative and wildlife species present within the project area are fire -adapted. The reintroduction
of fire into this ecosystem is part of the natural process. The perimeters and interiors of burn units will be ignited using a
combination of methods: heli-torch (aerial), terra-torch (mobile), and drip-torch (on-foot). Chemical management of
undesirable species would not accomplish any of the objectives listed above, would not be economically feasible, and may also
have negative environmental impacts. Prior to burning, mechanical treatment of fuels (such as crushing, bunching, and the use
of a ball and chain) may occur in select portions of the burn units.
The prescribed burning conducted as part of this project will be carefully planned to achieve specific goals and will be
conducted under specific climatic conditions to ensure control and minimize impacts on air quality and the environment. These
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conditions will mimic air, soil, and vegetation moisture, and other parameters present during natural wildfires, thereby
maximizing the positive impacts of fire on vegetation.
1.1.2 Lead Agency
For the purposes of the CalVTP PEIR and this PSA, a project proponent is defined as a public agency that provides funding
for vegetation treatment, possesses land ownership, land management, or other regulatory responsibility within the treatable
landscape, and aims to finance, authorize, or execute vegetation treatments consistent with the CalVTP. This document is being
prepared for CAL FIRE, the County, and the City to ensure compliance with CEQA for the implementation of vegetation
treatments that require discretionary action by a State or local agency. The CEQA lead agency is CAL FIRE. CAL FIRE will
establish a partnership with MCFSC, the County, and the City to carry out the proposed treatments. The partnership may involve
providing resources to the MCFSC, the County, and the City including equipment, staffing, and technical input. In this PSA,
the CAL FIRE is referred to as the “implementing entity,” underscoring its role as the primary executor of the treatments. The
Ukiah Valley Fire Authority’s fuels crew will conduct operations on City-owned lands.
1.1.3 Purpose of This Project-Specific Analysis/Addendum
This document functions as the PSA, aimed at evaluating whether the proposed treatments fall within the scope of the CalVTP
PEIR. As stated above, the types of treatments and their associated activities are consistent with the CalVTP. One of the
additional criteria used to determine whether a treatment project aligns with the CalVTP PEIR pertains to its inclusion within
the CalVTP treatable landscape - defined as the geographical extent covered by the PEIR analysis. If a proposed vegetation
treatment project undergoes evaluation for environmental effects within the PEIR, it could receive approval based on a
determination that the project falls within the PEIR’s scope for CEQA compliance, consistent with CEQA Guidelines Section
15168(c)(2).
If a proposed project includes a substantial portion of the State Responsibility Area (SRA) treatable landscape while also
extending partially beyond the SRA, it may still rely on the environmental analysis within the PEIR, if the environmental
conditions of the outside landscape and the foreseeable environmental impacts of proposed treatments are consistent with the
descriptions in the PEIR, as discussed below. The proposed project is in the SRA, but not entirely within the CalVTP treatable
landscape (Figure 1.1-2). There are 78 acres within the PIZ that are identified as being within the Federal Responsibility Area
(FRA), but there are no treatments planned for these acres. Additionally, there are 624 acres that fall within the Local
Responsibility Area (LRA).
The portions of the project treatment areas that extend beyond the treatable landscape (SRA), as outlined in the CalVTP PEIR.
In total, these areas encompass approximately 73 acres within the LRA. Nonetheless, they are dispersed across small sections
of treatment areas (refer to Chapter 2, “Treatment Description”). The scattered arrangement of acres beyond the CalVTP
treatable landscape is attributed to the method by which the CalVTP treatable landscape was digitally developed, as well as the
resulting mapping resolution. Using desktop applications to apply buffers around geographic and topographic features and
demarcate jurisdictional boundaries (i.e., SRA and LRA), the method resulted in some treatable landscape areas appearing
disjoined and scattered on the maps, while others existed as inholdings within the SRA. If the areas of the proposed project
located outside of the CalVTP treatable landscape exhibit essentially identical or substantially similar landscape conditions as
the adjacent areas within the treatable landscape, the environmental information in the PEIR would be relevant and applicable .
An addendum to an Environmental Impact Report (EIR) is warranted when a previously certified EIR has been prepared and
proposed changes or revisions to the project, or shifts in project circumstances, do not introduce new or considerably more
significant adverse environmental impacts. This is consistent with CEQA Section 21166 and CEQA Guidelines Sections 15162,
15163, 15164, and 15168. In this case, while there are no altered circumstances, the proposed revision or change in the project,
compared to the PEIR, involves incorporating some small areas outside of the CalVTP treatable landscape. The PSA checklist
(refer to Section 4, “Project-Specific Analysis/Addendum”) includes the criteria supporting an Addendum to the CalVTP PEIR
for the inclusion of treatment areas outside the CalVTP treatable landscape. The checklist evaluates each resource in terms of
whether the subsequent treatment project, including the “changed condition” of additional geographic area, would result in
significant impacts that would be substantially more severe than those covered in the PEIR or introduce new impacts not
covered in the PEIR.
This document serves as both the PSA and an addendum to the CalVTP PEIR for review and analysis under CEQA for the
proposed Ukiah West Hills vegetation treatments within and outside the CalVTP treatable landscape. The project-specific
mitigation monitoring and reporting program (MMRP), which outlines the CalVTP standard project requirements (SPRs) and
the mitigation measures applicable to the proposed project, is presented in Attachment A. The SPRs identified in the MMRP
have been incorporated into the proposed vegetation treatments as a standard part of treatment design and implementation.
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2 TREATMENT DESCRIPTION
The main proposed treatment type is the creation of fuel breaks. Proposed treatment activities include manual and mechanized
treatments, prescribed burning, and herbicide application. The locations for these treatment types are shown in Figures 2.0-1
and 2-2. Tables 2-1 and 2-2 provide treatment summaries. The proposed vegetation treatments would occur in one main area,
referred to as the West Hills area. This area consists of various private and public (City and County) lands situated on the
western side of the Ukiah Valley. The total potential treatment footprint of this project is 5,961 acres in size.
2.1 PROJECT SITE DESCRIPTION
The aim of this project is to reduce wildfire risk in strategic areas around and to the west of the City of Ukiah, which is
Mendocino County’s capital and most populous city by far. These are as are particularly important for community protection
because prevailing winds come from the west and the Ukiah Valley is bounded by substantial fuel-rich wildlands that pose a
substantial wildfire threat. With CEQA in place, CAL FIRE’s MEU will implement fuel-reduction work and prescribed burning
to establish and maintain these critical fuel breaks surrounding the Ukiah Valley. The treatment within the West Hills area will
help protect approximately 13,000 threatened homes, essential services, and critical communication infrastructure within the
City and unincorporated neighborhoods in the Ukiah Valley, totaling approximately 20,822 acres.
Ukiah is the Mendocino County seat and center for government services. It contains the County’s largest medical center, as
well as schools, water treatment plant, extensive retail development, and other infrastructure. Ukiah also has a high density of
homes and structures adjacent to steep, undeveloped wildlands identified as Very High Fire Hazard Zones. The West Hills of
Ukiah also contain hundreds of homes scattered throughout heavy fuel loads in WUI areas contiguous with urban
neighborhoods, increasing the risk of wildfire spreading to homes and infrastructure throughout the Ukiah Valley.
The Ukiah Valley is surrounded by mainly steep, undeveloped, mountainous terrain with high fuel loads. The need for this fuel
reduction work is based on the high likelihood of wildland fire moving west towards the Ukiah Valley (due to prevailing
westerly winds throughout the region). Implementation will impede the spread of wildland fires at strategic locations above
the Ukiah Valley and continue improved defensible space and evacuation routes to homes in the WUI.
The PIZ lies primarily within the Gibson Creek planning watershed, with portions in the Orrs Creek, Upper Robinson Creek,
and Lower Robinson Creek planning watersheds, all of which drain into the Russian River. The Russian River watershed
primarily covers eastern Mendocino County, extending south through Sonoma County, and ultimately draining into the Pacific
Ocean near Jenner, CA. Encompassing an area of approximately 1,485 square miles (950,400 acres), the Russian River
watershed area is used for activities like grazing, agriculture, timber harvesting, recreation, urban development, and residences.
Located within a region of Mediterranean climate, the Russian River watershed typically experiences hot, dry summers and
cool, wet winters, with an average annual precipitation of 39 inches, primarily occurring from October to May.
The Ukiah West Hills VTP area generally consists of moderately steep slopes (50-70%), along with moderately sloping
ridgelines and benches (20-50%). Elevations range from 587 feet up to 2,766 feet. Trending ridgeline aspects generally face
south or north on either side of east/west running drainages, while some smaller western and eastern-facing slopes are also
distributed across most of the units.
All fuel-reduction activities proposed under this project directly target residences within the WUI, situated in high-risk areas
prone to wildfire, and are characterized by dense vegetation and heavy fuel buildup. The primary objective of this project is to
protect lives and property. Strategically placed fuel breaks, which slow the advance of wildfires and improve access for
emergency responders, have the potential to prevent substantial losses of vulnerable homes and vital infrastructure, including
regional high-voltage PG&E power lines and cell towers.
The City is identified as a Community at Risk due to its proximity to extensive wildland fuels and the presence of numerous
neighborhoods located in the WUI. Current conditions are characterized by high fuel loads in neighborhoods with limited
accessibility for emergency vehicles and resident evacuations. To address these conditions, fuel break management in the hills
around the Ukiah Valley has been identified as a crucial wildfire mitigation strategy by Mendocino County, CAL FIRE, and
local fire chiefs. Implementation of this project will improve public safety, enhance emergency response capabilities and
establish effective suppression opportunities by allowing firefighting crews to anchor suppression lines and prevent wildfires
from encroaching into the sub-basin toward Ukiah.
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2.1.1 West Hills
The PIZ is situated atop the hills directly west of Ukiah, CA. It comprises three main components: previously burned areas
spanning 263 acres, areas designated for future controlled burns spanning 282 acres, and past/present control lines covering
453 acres. The previously burned areas were a result of the Ukiah Fuel Reduction Vegetation Management Plan (Project
Number: RX NORTH-100 MEU) in March 2020, aimed at reducing overall fuel loads (see Figure 2.2-1).
The land within the West Hills is owned by a mix of private landowners, the City, and the county. Currently, the West Hills
area remains predominantly undeveloped, excluding existing firebreaks, private access roads, and an operational
communication tower with its associated infrastructure. The area serves various purposes, including rural and remote
residences, agricultural activities, wildlife management, and unsanctioned recreational use. One of the control lines on the ridge
above Low Gap Park serves as an extension of the trail system, breaching private property boundaries up to the iconic Ukiah
"U" landmark at the hill's summit.
The City has recently proposed the acquisition and annexation of approximately 707 acres within the West Hills area, with the
primary goal of preserving open space. This initiative may also allow for potential low-density residential development in the
future, along with infrastructure improvements like utility extensions, road enhancements, and the construc tion of water tanks.
The Ukiah West Hills VTP is the first phase of a multi-phase project.
The Pomo Indians were the first inhabitants of the Ukiah Valley and its’ surrounding hills. The name “Ukiah” originates from a
mistranslation of a Pomo word, “yokoyo” meaning “deep valley” (Preservation 2010). Native people stewarded the land for
centuries, utilizing a variety of methods to support life and daily functions. Indigenous stewardship included wildlife habitat
enhancement for hunting, maintenance of native grasses for baskets, and the use of wildland burning for other agricultural and
vegetation management needs. In the mid to late 1800’s settlers of European descent came to the Ukiah Valley and displaced
and/or destroyed native people and their land management practices. By the mid-1900’s fire suppression and exclusion became
the standard practice, leading to densely vegetated landscapes and an overaccumulation of hazardous fuels.
The West Hills span two distinct ecoregions: the Outer North Coast Ranges, which predominate in the northernmost portion
of the project area, and the Sonoma-Mendocino Mixed Forest, which encompasses the southern part of the project area,
stretching from the Crestview Drive ridge to Oak Knoll Road. The Napa -Sonoma-Russian River Valley region does not directly
intersect with the project area but borders the lower foothills to the east. For detailed descriptions of each ecoregion, ple ase
refer to Section 4.6.
The vegetation within the cleared control lines primarily consists of native and non -native grasses and forbs, interspersed with
patches of mixed hardwood-conifer trees and evergreen shrubs. Vegetation communities across the entirety of the West Hills
are characterized by dense chaparral, predominantly comprised of chamise, and mixed hardwood -conifer woodlands.
2.2 PROPOSED TREATMENTS
The proposed project involves two treatment types: (1) fuel breaks in critical defensive locations determined by CAL FIRE,
which shall not exceed 300-feet in width; and (2) Wildland-Urban Interface fuel reduction (WUI) located within 1,000 feet of
the interface layer mapped in the CAL FIRE WUI layer (WUI25_1). The vegetation treatment activities proposed to implement
each of these treatment types are prescribed burning, mechanical treatment, manual treatment, and targeted ground application
of herbicides. The treatment types and treatment activities are described below. Table 2-1 provides the proposed acres of
treatment activities, and Table 2-2 provides a summary of the different treatment types. Refer to Figure 2.2-1 for the location
of each of the existing or proposed treatment activities within the areas.
2.2.1 Treatment Types
Table 2-1 Proposed Treatment Size by Area
Treatment Areas CalVTP Treatment Type Maximum Treatment Area
within CalVTP Treatable
Landscape (acres)
Maximum Treatment Area
Outside CalVTP Treatable
Landscape (acres)
Maximum Total
Treatment Area (acres)
West Hills Fuel breaks 391 62 453
Wildland-Urban
Interface
545 0 545
Total acres (approximately) 998
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FUEL BREAKS
In strategic locations, fuel breaks create zones of vegetation removal, often in a linear layout, that reduce wildfire risk and
support fire suppression by providing responders with a staging area or access to a remote landscape for fire control actions.
They can also provide safe emergency egress during wildfires. Control lines will be preplanned and will be established utilizing
an existing road and dozer trail network as much as feasible. Bulldozers may be employed to construct new control lines or re-
scrape overgrown roads and skid/dozer trails down to mineral soil to ensure functionality prior to ignition. Control lines that
employ the complete removal of vegetation will serve as fuel breaks. Handlines will be constructed in areas inaccessible to heavy
equipment or where such use is necessary to avoid impacts to pre-identified sensitive resources (e.g., biological, cultural,
geological, or other).
Shaded fuel break prescriptions will be utilized adjacent to control lines that are adjacent to dense forested conditions . In
forested areas, the tree canopy would be thinned to reduce the potential for a crown fire to move through the canopy; however,
larger trees would remain. The shade of the retained canopy also helps reduce the potential for rapid regrowth of shrubs and
sprouting hardwoods and may reduce rill and gully erosion. The shaded fuel breaks also provide important control lines for
prescribed fire activities.
Linear non-shaded fuel breaks (bulldozer control lines) will be utilized adjacent to shaded fuel breaks and range from 100-150
feet pending slope and terrain. Non-shaded fuel breaks are already established (but to be maintained) in some areas and any
new ones would be established in areas along strategic topographic locations (e.g., on ridge tops); adjacent to roads, skid trails,
and existing fuel breaks; and near high-use areas (e.g., cabins, infrastructure, parking areas, ranch roads), as shown in Figure
2.2-1. All shaded fuel breaks will occur within 100 feet of existing roads, skid trails, existing fuel breaks, and historic bulldozer
lines. To create shaded fuel breaks, shrubs and understory trees would be removed to reduce surface and ladder fuels and create
safer places for firefighters to stage equipment and fight wildfire. Live trees up to 1 2 inches diameter at breast height (DBH)
would be felled; live trees greater than 12 inches DBH would be limbed up to 10–15 feet; and spaces of 15–20 feet width would
be created between trees. In oak woodlands, treatment would focus on removing encroaching conifers and bay trees to promote
protection of tree health in native oak woodland.
WILDLAND-URBAN INTERFACE
This project proposes a WUI treatment type to reduce hazardous fuels and lower wildfire risk in areas adjacent to residential
neighborhoods, critical infrastructure, and evacuation routes. Implementing mechanical and manual vegetation removal, pile
burning, prescribed fire, and selective herbicide application will modify existing fuels, reducing the likelihood of high-intensity,
stand-replacing wildfires.
WUI treatments will focus on thinning small-diameter trees from overstocked forest units and post-fire resprouts, removing
dense understory vegetation, and eliminating excessive standing dead wood. Encroaching conifers, nonnative trees, and shrubs
in oak woodlands may also be removed where they contribute to hazardous fuel conditions. Three to five snags per acre may
be retained where they do not conflict with fuel -reduction objectives.
The project area is located within the “Very High” hazard influence zone, as identified in the CAL FIRE WUI map (WUI25_1),
and has experienced multiple large fires in recent decades. High fuel loads and limited egress make these areas particularly
vulnerable to fast-moving wildfires. Implementing WUI treatments will reduce fire behavior, moderate wildfire spread, and
protect life, property, and critical infrastructure.
2.2.2 Treatment Activities
The proposed vegetation treatment activities are prescribed burning, pre-treatments of fuels (mechanical and manual), and
targeted ground application of herbicides. Each of these treatment activities is described in more detail below and consisten t
with the treatment activities described in the CalVTP. All treatment activities will occur in both areas. Table 2-1 provides the
maximum acres of treatment types both within the SRA and the additional acres in the LRA, and a further breakdown and
description of the proposed treatment types can be found in Table 2-2. Treatment activities could occur during any time of year,
although the nesting bird season would be avoided when feasible. Although there is the potential for prescribed burning to occur
during nighttime and weekend hours, all treatment activities using equipment would be limited to daytime hours on Monday
through Friday.
PRESCRIBED BURNING
Prescribed burning consists of two general types, pile burning and broadcast burning (under burning). Pile and burn treatments
are designed to reduce fuel continuity and intensity, thereby lowering wildfire severity and improving defensible space in hi gh-
risk WUI settings.
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These treatments will promote a more natural, sustainable, and wildfire resilient native landscape.
Pile burning: Biomass from manual and mechanical treatment would be piled using equipment (e.g., skid steer, tractor,
bulldozer, or excavator) or hand crews and burned appropriately. Typically, dozers are equipped with a brush rake to reduce
soil displacement and create “clean” piles. Pile burning would occur in an understory or in areas with little to no live overstory,
including areas that have experienced previous wildfire. Broadcast burning may be used as a fuel-reduction treatment within
WUI and fuel break treatment types to reduce hazardous biomass and fuel continuity. Treatments may occur in areas with
grassland, shrub, woodland, or forest vegetation, or where fuel conditions warrant presc ribed fire. Mechanical, manual, or
herbicide pretreatments may be implemented to facilitate safe and effective burning. Broadcast burning reduces fine and surface
fuels and limits potential wildfire intensity and rate of spread near developed areas and strategic fuel break locations. Prescribed
burning in the grassland areas would help control nonnative plant species and reduce fine fuels.
CAL FIRE will implement an understory burn to partially remove understory and groundcover vegetation during periods when
weather and vegetation conditions allow to conduct a low intensity burn to meet treatment objectives. Prescribed burning may
require the construction of new control lines or enhancement of existing control lines using manual or mechanical treatments,
primarily through mowing or using hand tools, but use of a skid steer may be required.
Prescribed burning would require between 10 and 50 crew members, depending on size and site characteristics of the burn unit.
Typically, each burn would last one day to one week. Equipment could include water trucks, fire engines, and chainsaws. The
project proponent will comply with all applicable air quality requirements and procedures outlined by the Mendocino County
Air Quality Management District. A Burn Plan has been developed for use on all prescribed burns for this project.
PRE-TREATMENT OF FUELS /MECHANICAL VEGETATION TREATMENT
Mechanical treatments would primarily include masticating target vegetation and chipping biomass from manual and mechanical
treatment activities in addition to crushing and chaining dense brush in preparation for controlled burning. Equipment would
include tracked equipment, such as tractors/skidders, chippers, masticators, and dozers equipped with a ball and chain. Up to
four crew members may operate at the same time across the project area. Typically, treatments would require several days to
several months to complete. Equipment would be operated on or within 100 feet of roads or skid trails in fuel break treatment areas
and on existing roads or skid trails or on flat to moderate slopes in WUI treatment areas.
Small-diameter trees, downed woody debris, and woody shrubs would be masticated to increase tree spacing and reduce fire
fuel loads in targeted areas. The biomass would be disposed of via the process of mastication (which essentially mulches the
vegetation). Resulting mastication will leave a layer of mulch behind to minimize any erosion and suppress weed invasion,
while also allowing the existing seedbank below to germinate and give root systems the opportunity to resprout. In some areas
where the chips are too great, prescribed burning may be used to dispose of chipped and masticated materials. Generally,
mechanical treatments would:
• Target and masticate live woody shrubs and trees up to 12 inches DBH;
• Remove limbs of large trees up to 15 feet high;
• Prune trees with multiple stems (e.g., madrone) to two or three stems per tree;
• A dozer pulling a ball and chain behind to crush brush, altering the fuel composition to help prepare an area for a future
controlled burn;
• Masticate standing dead trees/shrubs and downed woody debris up to 24 inches in diameter, while retaining at least
three to five snags per acre;
• Maintain at least 35 percent relative final density of chaparral vegetation;
• To the extent feasible, retain buckeye, mature madrone, true oaks, redwood, big-leaf maple, native shrubs (e.g.,
gooseberry and snowberry) and other desirable species; and
• Target successional tree species, including tanoak, bay laurel, sprouting madrone, and Douglas fir, for thinning.
Proposed activities consist of approximately 453 acres of mechanical treatments, including maintenance treatments within the
265 acres of previously existing shaded fuel break. Masticators will be used to treat dense stands of understory vegetation and
ladder fuels and maintain a healthy overstory. Bulldozers equipped with ball and chains will be utilized in areas where dense
brush requires pre-treatment fuel alterations to prepare an area for safe and effective controlled burning.
As stated in the CalVTP PEIR Section 2.5.2, mechanical treatments may cut, uproot, crush/compact, or chop existing vegetation
using masticators and other methods of application. This project proposes to limit mastication to the cutting or chopping of
above-ground vegetation with the intent of keeping masticating heads out of duff layers and minimizing direct disturbance to
subsurface soil layers, allowing intact root systems to resprout. Understory debris would be masticated or chipped on -site
within the treated areas or piled and subsequently burned during wet periods of the year to dispose of accumulated biomass,
pursuant to the standards defined in the PEIR (CalVTP Final PEIR Volume II Section 2.5.2, 22 -24). Mechanical treatments are
efficient in removing dead, dying, and diseased trees and understory fuels over large areas of land to help mimic disturbance
necessary for natural regeneration. The mechanical treatment crew may utilize a chainsaw and/or various other mechanized
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tools or hand tools to buck downed debris and prune ladder fuels and vegetation.
PRE-TREATMENT OF FUELS /MANUAL VEGETATION TREATMENT
As described in the CalVTP PEIR Section 2.5.2, manual treatments consist of the use of hand tools and hand -operated power
tools to cut, clear, or prune herbaceous or woody species. Ground disturbance during manual treatments is typically less than
that of mechanical treatments, allowing for treatments to be carried out in sensitive habitats, wet areas, and riparian corridors
or areas where mechanical, herbicide, or prescribed burning treatments are not feasible or appropriate. Vegetation debris
accumulated after manual treatments would be lopped and scattered on-site within the treated areas or piled and subsequently
burned during wet periods of the year to dispose of accumulated biomass, pursuant to the standards defined in the PEIR
(CalVTP Final PEIR Volume II Section 2.5.2, 22-25).
To implement manual treatments, physical labor crews of approximately eight to 20 members would use hand tools and hand-
operated power tools, including chainsaws, hand saws, brush cutters, and loppers, to cut, clear, and/or prune trees, herbaceo us
vegetation, and woody shrubs and increase space betwee n trees. Typically, treatments would require several days to several
months to complete, depending on the treatment size, steepness of terrain, and type and density of vegetation. Trees would be
removed, thinned, and pruned and woody shrubs would be cut and cleared. In forested areas, the focus would be on
thinning/cutting dense standing dead wood, including dead trees up to 24 inches DBH, while retaining three to five snags per
acre for wildlife habitat. In oak woodland habitat, the focus would be on the removal of Douglas fir trees to reduce oak tree
shading and therefore promote oak woodland habitat.
Where feasible, treatments would focus on removing nonnative and invasive species. Manual treatment activities may also be
implemented in sensitive areas, such as within 100 feet of Class II or III streams to improve habitat and reduce undesirable
wildfire hazards, in areas with steeper slopes (greater than 40%), or near cultural resources. Manual treatment within 100 feet
of Class II or III streams would also occur outside of bird nesting season if feasible. Only manual treatments will be conducted
in Class III Equipment Exclusion Zones (EEZs).
Cut vegetation will be left on site by lopping or chipping and scattering on the landscape. In some areas, removed vegetation
would be piled for later pile burning or broadcast burning. The same general guidelines for tree and vegetation removal and
retention would be followed as described above for mechanical treatments.
HERBICIDE APPLICATION
Herbicides would be used sparingly to control vegetation that threatens the native biodiversity and/or increases wildfire haz ards.
Post-wildfire invasive plant and noxious weed infestations may need to be treated to prevent their establishment such that
limited herbicide application may be considered where invasive species are present or expected to occur within the treatment
areas to promote regeneration of native species and reduce the spread of invasive vegetation. Herbicide treatment is expected
to occur near roads and trails where increased sunlight is present, which will significantly reduce the actual acreage to which
herbicide is applied. Herbicides will not be utilized within WLPZs or EEZs and will be predominantly focused where invasive
plants (such as French broom and yellow star thistle) are expected to occur (e.g., sunlight openings).
Consistent with the definitions applied in the CalVTP, invasive species are those plant species identified as invasive by the
California Invasive Plant Council (Cal-IPC) or defined as noxious weeds under California law by the California Department
of Food and Agriculture. The occasional use of herbicides to treat invasive plant species and to control regrowth of native tree
species (e.g., resprouting, multiple-stemmed tanoak, bay laurel, and madrone) may be implemented to promote native
biodiversity.
The CalVTP PEIR Section 2.5.2 indicates that herbicide application may only be implemented at ground -level from equipment
on vehicles or by manual application devices and must comply with the U.S. Environmental Protection Agency directions, as
well as California Environmental Protection Agency and Department of Pesticide Regulation label standards. While herbicide
application is not anticipated to be a primary treatment activity for this project, it may be used in conjunction with other
treatment activities to control the colonization and spread of invasive plants following initial treatments. More detailed
information on herbicide activities can be found in the Environmental Checklist below.
The following herbicides, which are consistent with those considered for use in the CalVTP, may be applied:
• Glyphosate, and
• other species-specific herbicides analyzed and included in the CalVTP PEIR.
Only ground-level application would occur; no aerial spraying of herbicides would occur. The least impactful method would
be used at any given site. Several herbicide application methods are available for use by on -the-ground personnel, including
paint-on stems and using backpack hand-applicators. For large treatment areas, herbicide treatments would typically use a one-
to five-person crew, a 4x4 pickup truck, a porta-potty, a passenger vehicle to transport crew, a utility task vehicle (UTV) with
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a sprayer/reservoir tank, and backpack sprayers. Treatment would involve removing invasive plant species (e.g., French broom,
leafy spurge) and noxious weeds through herbicide application. All herbicide applications would be performed by certified and
licensed pesticide applicators in accordance with all local, state, and federal regulations.
BIOMASS DISPOSAL
The proposed vegetation treatments described above would be disposed of primarily by the following means:
• Masticating (mulching) vegetative debris and placing it on the ground concurrently with vegetation removal
(approximately ten percent of biomass), and the biomass remaining after mastication would be no more than six inches
deep;
• Chipping (approximately 20 percent of biomass); materials within 100 feet on either side of a road, and chipped
biomass would be spread over treatment areas and would not exceed six inches in depth;
• Lopping and scattering within the treatment boundaries (approximately 20 percent) and would be left within 18 inches
of the ground to promote decomposition;
• Pile burning (approximately 20 percent of biomass), which may be used to dispose of slash, chipped, and masticated
materials; or
• Broadcast burning (approximately 30 percent of the biomass).
Invasive plant and noxious weed biomass would be treated onsite to eliminate seeds and propagules or would be disposed of
off-site at an appropriate waste collection facility to prevent re-establishment or spread of invasive plants and noxious weeds.
Invasive plants and noxious weeds would not be chipped and spread, scattered, or mulched on-site.
These kinds of treatments create an opportunity for CAL FIRE to stop or manage a wildfire, potentially reducing ground
disturbing emergency actions such as creating control lines with bull dozers which create additional environmental impacts.
Techniques such as minimum impact suppression (e.g., “back burning”; which is setting a fire in controlled conditions to reduce
fuel loading before the head of the fire arrives) may be utilized in areas where strategic fuels reduction treatments have occurred
years ahead of a wildfire.
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Table 2-2 Proposed CalVTP Treatments
CalVTP
Treatment
Type Treatment Description CalVTP Treatment Activity Equipment used for
Treatments
Typical Duration of
Treatments
Fuel break
Non-shaded fuel
break and shaded fuel
breaks along existing
roads and skid trails.
Mechanical (mastication,
biomass chipping, ball and
chain brush crushing); manual
(cutting, clearing, piling);
broadcast and pile burning;
herbicide (stump application,
backpack sprayer, mobile
sprayer behind UTV).
Tractor/skidder, dozers, ball
and chain, skid steer,
masticators, chippers,
chainsaws, loppers, hand
saws, fire engines, water
tender, backpack sprayer,
UTV with sprayer, pickup
truck.
1 week to 6 months
WUI
Prescribed burning. Broadcast burning.
Heli torch, fire engines, water
tender, terra torch, drip torch,
chainsaws.
1 day to 1 week
Prescribed burning
for biomass disposal. Pile burning.
Chainsaws; pickup truck
with water tank & pump;
skid steer, tractor, excavator
and/or bulldozer for
biomass piling.
1 day to 1 week
Forest habitat
improvement/fire
resiliency
treatments.
Mechanical (mastication,
biomass chipping, ball and chain
brush crushing) manual (cutting,
clearing, piling).
Chippers, masticators,
dozers, ball and chain,
chainsaws, hand saws,
brush cutters.
1-6 months
Herbicide control of
invasive species and
undesirable
resprouting tree
species.
Herbicide (stump application,
backpack sprayer, mobile
sprayer behind UTV).
Backpack sprayer, UTV with
sprayer, pickup truck.
Several days to
weeks
2.3 RETREATMENT/TREATMENT MAINTENANCE
Retreatment for maintenance of desired vegetation conditions (referred to as “treatment maintenance” in the CalVTP PEIR and
referred to as “retreatment/treatment maintenance” or “maintenance” in this PSA/Addendum) in the areas initially treated for
the proposed project would follow the existing general land management practices and would be based on real -time monitoring
of site conditions (see Table 2-3). In forested and woodland areas, retreatment is anticipated to occur every 2-5 years. In areas
where initial treatment included removing multiple stems from stump-sprouting vegetation (e.g., madrone, California bay)
retreatment would occur every 2-5 years. Retreatment/treatment maintenance methods would involve the same vegetation
treatment activities used in the original t reatment; however, the City anticipates the use of more hand crews than mechanical
equipment in comparison to initial treatments.
Retreatment/treatment maintenance would typically be implemented between approximately August and January, outside of
the nesting bird season, if feasible. Periodic retreatment/treatment maintenance will occur as needed, determined by qualifie d
staff who would monitor vegetation growth conditions over time.
Retreatment/treatment maintenance could occur in a variety of methods and management activities. Each of these activities
may have a distinct timeline dictated by the intent of the activity, its effectiveness at managing vegetation growth and
establishment, and the overall impact on other environmental resources. The following table describes retreatment/treatment
maintenance activities that have the potential to take place in the lifespan of this project.
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Table 2-3 Retreatment/Treatment Maintenance Activities
Retreatment/Treatment
Maintenance Activity Treatment Description Implementation Timeline Rate of Retreatment
Vegetation thinning
and/or removal to
maintain shaded fuel
breaks
Manual – Hand crews with
chainsaws, weed-whackers, loppers,
and other hand tools would remove
vegetation that has grown into the
understory of the shaded fuel break
and into the operable space of the
dozer and control lines. Mechanical
masticators, skidders, and dozers are
used to thin/completely remove
unwanted vegetation in the dozer
control lines and in the understory of
the shaded fuel breaks.
Manual and Mechanical – ideally
occurs August – January (outside
of the nesting bird season),
however if work occurs February
– July, nesting bird surveys will be
completed ahead of operations.
Mechanical – Any use of heavy
equipment during the Winter
Period (November 15th – April 1st)
shall NOT occur during saturated
soil conditions.
2-5 years
Pile burning
Larger material that is removed
during thinning/removal treatments
may be piled and burned.
Burning shall take place after
CAL FIRE has lifted the burn
ban in Mendocino County and
after a Smoke Management Plan
has been attained from the
Mendocino County ACQB.
2-5 years, if
necessary, at all.
Herbicide application
to prevent unwanted
brush growth,
sprouting, and
establishment of
invasive species.
Herbicide application will occur in
the form of foliar application and
stump applications.
Herbicide application is most
effective when done in the fall
months (September-November).
The herbicide application should
be done on dry days with no or low
wind speeds.
Annually for the first
two years, and
sporadically if
invasive species
begin to reestablish.
As previously stated, the need for retreatment/treatment maintenance activities will be determined using on -site monitoring in
the months and years following the implementation of this project. Retreatment/treatment maintenance activities will be
deemed necessary when the intent of the project is no longer being met. In other words, if vegetation regrowth is negatively
impacting fuel loading and the ability to maintain defensible space, then retreatment/treatment maintenance activities are
necessary.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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3 ENVIRONMENTAL CHECKLIST
VEGETATION TREATMENT PROJECT INFORMATION
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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THE CALIFORNIA VEGETATION
TREATMENT PROGRAM
ENVIRONMENTAL CHECKLIST
PROJECT INFORMATION
1. Project Title: Ukiah West Hills
2. CAL FIRE Project Number
RX-North-107-MEU
3. CalVTP I.D. Number 2024-25
4. Project Proponent Name and Address:
CAL FIRE MEU
17501 North Highway 101
Willits, CA 95490
5. Contact Person Information and
Phone Number:
Julie Rhoads
MEU – VMP Forester
julie.rhoads@fire.ca.gov
(707) 671-3357
6. Project Location: Ukiah Valley, Mendocino County
7. Total Area to be Treated (acres)
5,961 acres of which 998 acres (545 broadcast burn and
manual/mechanical treatments and 453 acres fuel break
maintenance) are currently scheduled. Additional units within the
project area may be included over the life of this project.
8. Description of the Project: (Describe the whole action involved, including any phasing of initial treatments
as well as planned treatments, including equipment to be used and planned duration of treatments, but not limited to
later phases (e.g., maintenance) of the project, and any secondary, support, or off-site features necessary for its
implementation. Attach additional sheets if necessary.)
Treatments would involve prescribed burning, mechanical and manual treatments, and herbicide application. See Section
2.2, above for additional details.
9. Treatment Types: [see description in CalVTP PEIR Section 2.5.1, check every applicable category; provide detail
in Description of Project]
☒ Wildland-Urban Interface Fuel Reduction
☒ Fuel Break
☐ Ecological Restoration
10. Treatment Activities: [see description in CalVTP PEIR Section 2.5.2, check every applicable category; include
number of acres subject to each treatment activity, provide detail in Description of Project]
Prescribed Burning (Broadcast), up to 5,961 acres
Prescribed Burning (Pile Burning), 100 acre
Mechanical Treatment, up to 5,961 acres
Manual Treatment, up to 5,961 acres
Prescribed Herbivory, 0 acres
Herbicide Application, up to 5,000 acres
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11. Fuel Type: [see description in CalVTP PEIR Section 2.4.1, check every applicable category; provide detail in
Description of Project]
☒ Grass Fuel Type
☒ Shrub Fuel Type
☒ Tree Fuel Type
Retreatment/Treatment Maintenance
Treatments would involve prescribed burning, mechanical and manual treatments, and herbicide application. See Section
2.3, above for additional details.
12. Geographic Scope [Refer to [to be determined] for a map of the CalVTP treatable landscape, check one box]
☐ The treatment site is entirely within the CalVTP treatable landscape.
☒ The treatment site is NOT entirely within the CalVTP treatable landscape .
Approximately 702 acres of the 5,961-acre project area is mapped outside of the treatable landscape polygon associated
with the CalVTP PEIR. The areas not encompassed by the treatable landscape polygon include 78 acres within the FRA
(but are not proposed for treatment under this VTP) and 624 acres that are within the LRA and are proposed for treatment
under this VTP. After onsite field evaluation and environmental analysis of the project area consistent with the CalVTP
PEIR, it was determined that the entire project area is within the treatable landscape because the existing environmental
conditions in the areas outside the treatable landscape are essentially the same as those within the treatable landscape.
The vegetation, geology, and slopes are representatively the same as those sections of the project area within the treatable
landscape. There are no changes in vegetation type, composition and structure nor changes in fuel load/conditions relative
to the adjacent areas of treatable landscape.
13. Regional Setting and Surrounding Land Uses: (Briefly describe the project’s surroundings)
The proposed CalVTP treatments would occur on the City of Ukiah lands as well as private ownership lands in Mendocino
County. Pole The project is in the Russian River Watershed near the headwaters; the area has a long history of ranching
and logging and contains areas of scattered residences.
14. Other Public Agencies Whose Approval Is Required: (e.g., permits)
A pesticide application permit would be obtained from the Mendocino County Agricultural Commissioner.
Legend
Treatable Areas
VTP Treatment Area
0 0.45
0.9 1.8
Miles
California Board of Forestry, CAL FIRE Fire and Resource Assessment Program
(FRAP), Source: Esri, Maxar, Earthstar Geographics, and the GIS User
Community
Treatable Landscape in the Ukiah Western Hills VTP
³
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Smoke management plans would be prepared for the Mendocino County Air Quality Management District, as required.
Burn permits would be obtained from CAL FIRE and the Mendocino County Air Quality Management District, as
required.
Coastal Act Compliance:
The proposed project is NOT within the Coastal Zone.
The proposed project is within the Coastal Zone (check one of the following boxes)
A coastal development permit has been applied for or obtained from the local Coastal Commission district
office or local government with a certified Local Coastal Plan, as applicable.
The local Coastal Commission district office or local government with a certified Local Coastal Plan (in
consultation with the local Coastal Commission district office) has determined that a coastal development
permit is not required.
15. Native American Consultation. Pursuant to PRC Sections 21080.3.1, 21080.3.2, and 21082.3, lead agencies
undertaking CEQA review must, upon written request of a California Native American tribe, begin consultation
before the release of an environmental impact report, negative declaration, or mitigated negative declaration. For
treatment projects that require additional CEQA review and documentation, have California Native American
tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public
Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the
determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Note: For treatment projects that are within the scope of this PEIR, AB 52 consultation has been completed. The
Board of Forestry and Fire Protection and CAL FIRE completed consultation pursuant to Public Resources Code
section 21080.3.1 in preparation of the PEIR.
As the MCFSC pursues its mission of helping residents of Mendocino County protect their families and homes from
wildfire, we recognize that we stand upon the unceded ancestral lands of many Indigenous peoples. We honor their
knowledge, care, and stewardship of this special place across the ages and acknowledge the deep and lasting damage that
colonization has inflicted on them. We embrace our responsibility to learn from and protect their cultural and traditional
connections to the land. Pursuant to CalVTP SPR CUL-2, Native American tribal contacts in Mendocino were contacted
on February 1, 2024, and included every Native American contact provided on the September 20th, 2023,. A discussion
regarding specific cultural resources and a list of proposed protection measures are in the 2024 confidential
Archaeological Survey Report for this project. If additional treatment units are scheduled, another phase of archaeological
review will be conducted.
16. Use of PSA for Treatment Maintenance:
[Prior to implementing a maintenance treatment, the project proponent would verify that the expected site conditions as
described in the PSA are present in the treatment area. As time passes, the continued relevance of the PSA would be
considered by the project proponent in light of potentially changed conditions or circumstances. Where the project
proponent determines that the PSA is no longer sufficiently relevant, the project proponent would determine whether a
new PSA or other environmental analysis is warranted. In addition to verifying that the PSA continues to provide relevant
CEQA coverage for treatment maintenance, the project proponent would update the PSA at the time a maintenance
treatment is needed when more than 10 years have passed since the approval of the PSA or the latest PSA update. For
example, the project proponent may conduct a reconnaissance survey to verify that conditions are substantially similar
to those anticipated in the PSA. Updated information should be documented.]
Prior to retreating any area within the project boundary, the project proponent will verify that site conditions described in
the PSA are still relevant. CAL FIRE’s contract with the landowners is for 10 years. After 10 years, the landowner can
enter into a new agreement with CAL FIRE, and the project proponent will re-evaluate environmental conditions and
prepare a new PSA if necessary. If a new contract is not initiated, it is at the discretion of the landowners to maintain the
project area if desired.
17. Standard Project Requirements and Mitigation Measures. [Refer to Attachment A to identify which SPRs
and Mitigation Measures apply to the project. Complete Attachment A to document the responsible party for
each applicable SPR and Mitigation Measure. Check one box below.]
All applicable SPRs and Mitigation Measures are feasible and will be implemented
There is NO new information which would render mitigation measures previously considered
infeasible or not considered in the CalVTP PEIR now feasible OR such mitigation measures have been
adopted. [Guidelines Sec.15162(a)(3); PRC Sec. 21166(c)]
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All applicable SPRs and Mitigation Measures are NOT feasible or will NOT be implemented (provide
explanation)
DETERMINATION
On the basis of this initial evaluation:
I find that all of the effects of the proposed project (a) have been analyzed adequately in the CalVTP PEIR,
(b) have been avoided or mitigated pursuant to the CalVTP PEIR, and (c) all applicable mitigation
measures and Standard Project Requirements identified in the CalVTP PEIR will be implemented. The
proposed project is therefore WITHIN THE SCOPE of the CalVTP PEIR. NO ADDITIONAL CEQA
DOCUMENTATION is required.
I find that the proposed project will have effects that were not examined in the CalVTP PEIR. These
effects are less than significant without any mitigation beyond what is already required pursuant to the
CalVTP PEIR. A NEGATIVE DECLARATION will be prepared.
I find that the proposed project will have effects that were not examined in the CalVTP PEIR. Although
these effects might be significant in the absence of additional mitigation beyond what is already required
pursuant to the CalVTP PEIR, revisions to the proposed project or additional mitigation measures have
been agreed to by the project proponent that would avoid or reduce the effects so that clearly no significant
effects would occur. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project will have environmental effects that were not examined in the CalVTP
PEIR. Because these effects are or may be significant and cannot be clearly mitigated, an
ENVIRONMENTAL IMPACT REPORT will be prepared.
Signature: Date:
Printed Name: George Morris III Title: Northern Region Chief
CALIFORNIA DEPARTMENT OF
FORESTRY AND FIRE PROTECTION
CAL FIRE
Agency
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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4 PROJECT-SPECIFIC ANALYSIS/ADDENDUM
EVALUATION OF ENVIRONMENTAL IMPACTS
A brief explanation is included for each Impact and Standard Project Requirements (SPRs) and Mitigation Measures (MMs)
are identified in the Project-Specific Analysis Checklist (PSA Checklist). The details of the SPRs and MMs can be found in
Attachment A. The information included should provide clarity for review the and/or provide direction to the field staff that
will implement the project utilizing the checklist. Information included considers whether the proposed project would result in
new or more substantial environmental effects than described in the CalVTP PEIR, after incorporation of applicable SPRs and
MMs required by the CalVTP PEIR. All answers considered the whole action involved, including off-site as well as on-site,
cumulative as well as project-level, indirect as well as direct, and short-term as well as long-term impacts.
Once the environmental effects that may occur were evaluated, the checklist indicates the weight of the impact. Weight of
impact was characterized utilizing the definitions located in Chapter 3 – “Environmental Settings, Impacts, and Mitigation
Measures, 3.1.4 – Terminology Used In the PEIR” and are as follows:
- Less Than Significant (LTS) - An impact either on its own or with incorporation of SPRs, does not exceed the defined
thresholds of significance (no mitigation required), or that is potentially significant and can be reduced to less than
significant through implementation of feasible mitigation measures.
- Less Than Significant with Mitigation (LTSM) - An impact was identified within the PEIR which was viewed in
totality as potentially significant and/or significantly unavoidable and the mitigation measures and SPRs and MMs
provided in the PEIR will be implemented mitigating to a point of less than significance.
- Potential Significant (PS) - An impact treated as if it were a significant impact. “Potentially” is used to convey that
not every qualifying treatment will result in impacts to the reasonably maximum degree that they are disclosed in this
PEIR.
- Potentially Significant and Unavoidable (PSU) - An impact is considered significant and unavoidable if it would
result in a substantial adverse change in the environment that cannot be feasibly avoided or mitigated to a less-than-
significant level. “Potentially” is used to convey that not every qualifying treatment will result in impacts to the
reasonably maximum degree that they are disclosed in this PEIR.
- Significantly Unavoidable (SU) - An impact is considered significant and unavoidable if it would result in a substantial
adverse change in the environment that cannot be feasibly avoided or mitigated to a less-than-significant level.
- Not applicable (N/A)
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4.1 AESTHETICS & VISUAL RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact AES-1: Result in Short-
Term, Substantial Degradation
of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from Treatment
Activities.
LTS Impact AES-1
pp. 3.2-16 –19 Yes
AD-4
AD-6
AES-1
AES-2
AES-3
AQ-2
AQ-3
REC-1
NA LTS No Yes
Impact AES-2: Result in Long-
Term, Substantial Degradation
of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from Wildland Urban
Interface Fuel Reduction,
Ecological Restoration, or
Shaded Fuel Break Treatment
Types.
LTS Impact AES-2
pp. 3.2-20 –25 Yes
AD-4
AES-1
AES-2
AES-3
REC-1
NA LTS No Yes
Impact AES-3: Result in Long-
Term Substantial Degradation
of a Scenic Vista or Visual
Character or Quality of Public
Views, or Damage to Scenic
Resources in a State Scenic
Highway from the Nonshaded
Fuel Break Treatment Type.
SU Impact AES-3
pp. 3.2-25 –27 Yes
AD-3
AD-4
AES-1
AES-2
AES-3
AQ-2
AQ-3
REC-1
MM
AES-3 SU No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact. None: there are SPRs and/or MMs identified in the PEIR for this
impact, but none are applicable to the treatment project.
New Aesthetic and Visual Resource Impacts: Would the treatment result in other
impacts to aesthetics and visual resources that are not evaluated in the CalVTP
PEIR?
Yes
No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
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4.1.1 Aesthetics & Visual Resources Discussion
IMPACT AES-1
Initial and maintenance treatments would include prescribed burning, mechanical treatment, manual treatment, and targeted
ground application of herbicides implemented as part of a critical wildfire safety project focused on WUI fuel reduction and
fuel break establishment surrounding the City of Ukiah. The potential for these treatment activities to result in short-term
degradation of the visual character of a treatment area was examined in the PEIR. The eligible state scenic highway nearest to
the project area is SR 20 (Caltrans 2023). The proposed treatments would not occur on lands adjacent; however, public
viewpoints of the project area are available from public recreation trails, adjacent residences and winerie s, Highway 101, and
SR 20. Visibility of treatment areas would be limited from the highways and no vegetation would be removed immediately
adjacent to the highways. However, smoke from prescribed burning could be visible from public viewpoints, Highway 101,
and SR 20. Although some burn units may be noticeable after treatment, the degree of vegetation change is expected to be
minimal and not impact the natural aesthetics or character of the landscape over the long term. Short-term vegetation charring
will be noticeable but will be replaced by new plant growth during the next growing season. Prescribed burning will occur
under ideal conditions for a low intensity, controlled mosaic burn; thus, activities would be temporary. Smoke generated from
prescribed burning will be short-term, and burning will adhere to a Smoke Management Plan (SMP) (SPR AQ-2) and a Burn
Plan (SPR AQ-3). The equipment, vehicles, and any vegetation treatment debris associated with the activities proposed in this
project will not block or disrupt views.
The potential for the project to result in short-term substantial degradation of the visual character of the project area is within
the scope of the PEIR because the proposed treatment activities are consistent with those analyzed in the PEIR. The inclusion
of land in the proposed treatment area that is outside the CalVTP treatable landscape cons titutes a change to the geographic
extent presented in the PEIR. However, within the boundary of the project area, the existing scenic resources are essentially
the same within and outside of the treatable landscape; therefore, the short- term aesthetic impact is also the same, as described
above. SPRs applicable to the proposed treatments are AD-4, AD-6, AES-1, AES-2, AES-3, AQ-2, AQ-3, and REC-1. This
determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what
was covered in the PEIR.
IMPACT AES-2
Initial and maintenance treatments would include shaded and non-shaded fuel break, and WUI treatment types. The potential
for these treatment types to result in long-term degradation of the visual character of an area was examined in the PEIR. Public
viewpoints of the project area include public recreation trails, adjacent residences, and wineries. The project area is visible
from SR 20; however, visibility of treatment areas would be limited from the highway and no vegetation would be removed
immediately adjacent to the highway.
The potential for the project to result in long-term substantial degradation of the visual character of the project area is within
the scope of the PEIR because the proposed treatment activities are consistent with those analyzed in the PEIR. The inclusion
of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic
extent presented in the PEIR. However, within the boundary of the project area, the existing visual character is essentially the
same within and outside of the treatable landscape; therefore, the long-term aesthetic impact is also the same, as described
above. SPRs applicable to the proposed treatments are AD-4, AES-1, AES-2, AES-3, and REC-1. This determination is
consistent with the PEIR and would not constitute a more severe impact than what was covered in the PEIR. This determination
is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in
the PEIR.
IMPACT AES-3
Initial and maintenance treatments would include the non-shaded fuel break treatment type in the form of reestablishing and
maintaining existing dozer/control line infrastructure. The potential for non-shaded fuel breaks to result in long-term
degradation of the visual character of an area was examined in the PEIR. Public viewpoints of the project area include public
recreation trails, adjacent residences, and wineries. The project area is visible from SR 20; however, visibility of treatment
areas would be limited from the highway and no vegetation would be removed immediately adjacent to the highway. Non-
shaded fuel breaks have been installed and will continue to be maintained in strategic locations along ridgelines. Non -shaded
fuel breaks meander topographically along ridgelines, helping them to blend into the natural topography of the landscape.
Furthermore, because of the strategic nature of non-shaded fuel break locations, it is infeasible to relocate these non-shaded
fuel breaks to avoid public visibility per Mitigation Measure AES-3.
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Non-shaded fuel breaks already exist on the landscape from past emergency fire suppression operations. These dozer lines,
while visible from Ukiah, have become a part of the landscape and CAL FIRE has not received pushback from the local
community regarding their existence. This project proposes to maintain these past control lines as part of a strategic fuel break
network adjacent to the city of Ukiah. The potential for the project to result in long-term substantial degradation of the visual
character of the project area is within the scope of the PEIR because the proposed treatment activities are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape
constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the
existing visual character is essentially the same within and outside of the treatable landscape; therefore, the long-term aesthetic
impact is also the same, as described above. SPRs applicable to the proposed treatments are AD-3, AD-4, AES-1, AES-2, AES-
3, AQ-2, AQ-3, and REC-1. This determination is consistent with the PEIR and would not constitute a more severe impact
than what was covered in the PEIR. As was previously stated, Mitigation Measure AES-3 is not applicable due to the fact that
the non-shaded fuel break infrastructure is already in place, therefore the location of these fuel breaks cannot be changed. As
much as is feasible, vegetation adjacent to the non-shaded fuel breaks will be feathered to break up the linear edges of the fuel
break and strategically preserve vegetation at the edge of the fuel break to help screen public views and minimize the contra st
between fuel break and surrounding vegetation.
NEW AESTHETIC & VISUAL RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.2.1, “Environmental
Setting,” and Section 3.2.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has also determined
that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions pertinent to aesthetics and visual resources that are present in the areas outside the treatable landscape are essentially
the same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described above,
impacts of the proposed treatment project are consiste nt with those covered in the PEIR. No changed circumstances are present,
and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to aesthetics and visual resources would occur.
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4.2 AGRICULTURE & FORESTRY RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact AG-1: Directly Result in
the Loss of Forest Land or
Conversion of Forest Land to a
Non-Forest Use or Involve
Other Changes in the Existing
Environment Which, Due to
Their Location or Nature,
Could Result in Conversion of
Forest Land to Non-Forest Use.
LTS Impact AG-1 Yes NA NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Agriculture and Forestry Resource Impacts: Would the treatment result in
other impacts to agriculture and forestry resources that are not evaluated in the
CalVTP PEIR?
Yes
No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.2.1 Agriculture & Forestry Resources Discussion
The project area is primarily comprised of chapparal, brush, and scrub land with some scattered concentrations of hardwoods
and conifers (particularly in the drainages). The project area parcels are primarily zoned as “Agricultural” or “Residential” and
are not zoned for timber production. Initial and maintenance treatments will encourage healthier ecosystem conditions by
removing competing vegetation. The treatments will protect adjacent forest and woodland from stand-replacing wildfire.
IMPACT AG-1
Vegetation treatment activities within the project area would include manual, mechanical, prescribed burning, and limited
herbicide treatments implemented as Wildland-Urban Interface (WUI) and fuel break treatments. The project is a critical
wildfire safety project located around the City of Ukiah and is designed to protect critical infrastructure, residential area s, and
other values at risk from wildfire.
Shaded fuel breaks would be established by thinning tree canopies in forested areas through removal of live trees up to 12
inches DBH, limbing of larger trees to approximately 10 to 15 feet and increasing spacing between trees to reduce canopy
continuity. Fuel breaks would be strategically located within approximately 100 feet of existing roads, skid trails, existing fuel
breaks, or historic dozer lines to minimize new ground disturbance and avoid effects to adjacent land uses.
WUI treatments would focus on reducing hazardous fuels, including thinning small-diameter trees and post-fire resprouts, to
improve fire behavior conditions near developed areas and infrastructure. Prescribed burning would be implemented primarily
in brush and shrub-dominated areas, with limited conifer and hardwood presence, under controlled conditions that would not
result in conversion of forestland. Where overstory trees occur, prescribed fire may improve their resilience by reducing
competing vegetation and surface fuels.
Both initial and maintenance treatments are designed to reduce the risk of stand -replacing wildfire, maintain existing forest
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
21
cover where present, and support long-term wildfire protection objectives for the Ukiah area. As a result, the project would not
result in the conversion of forestland or agricultural land and is consistent with the CalVTP PEIR analysis for Impact AG -1.
The potential for any of the proposed treatment types and treatment activities to result in the loss of forestland or conversion
of forestland to non-forest use was examined in the PEIR. The treatment activities proposed in this project occur primarily in
chapparal, brush, and scrub land ecosystems with some scattered concentrations of hardwoods and conifer. The shaded
fuelbreak treatments in the forested portions of the project area are aimed at reducing ladder fuels and hazardous fuel l oading
so that wildfire spread, and severity is less likely and lower intensity/severity overall . The goal of this project is to protect and
enhance existing ecosystems both within and adjacent to the project area. Treatments are aimed at increasing resilience and
resistance of these ecosystems to catastrophic wildfire. Therefore, conversion is not a goal, nor will it be a product of this
project. Consistent with the PEIR, the vegetation remaining after treatments would meet the definition of forestland as defined
in Public Resources Code Section 12220(g), which defines “forest land” as land that can support 10-percent native tree cover
of any species under natural conditions. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable
landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project
area, the composition of forested land as defined in Public Resources Code Section 12220(g) is essentially the same within an d
outside the treatable landscape; therefore, the impact to forest land is also the sam e, as described above. No SPRs are applicable
to this impact. Therefore, the potential for the project to result in the loss or conversion of forestland is within the scope of the
PEIR. This impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe
significant impact than what was covered in the PEIR.
NEW AGRICULTURE & FORESTRY RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.3.1,
“Environmental Setting,” and Section 3.3.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as thos e
within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with those covered
in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would
not give rise to new significant impacts not addressed in the PEIR. Therefore, no new impact related to agriculture and forestry
resources would occur that is not covered in the PEIR.
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4.3 AIR QUALITY
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact Analysis
in the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be a
Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact AQ-1: Generate
Emissions of Criteria Air
Pollutants and Precursors
During Treatment Activities
that would exceed CAAQS
or NAAQS.
PSU
Impact AQ-1,
pp. 3.4-26–
3.4-32
Yes
AD-4
AQ-1
AQ-2
AQ-3
AQ-4
AQ-5
AQ-6
MM
AQ-1 LTSM No Yes
Impact AQ-2: Expose
People to Diesel
Particulate Matter
Emissions and Related
Health Risk.
LTS
Impact AQ-2,
pp. 3.4-33 –
3.4-34
Yes
HAZ-1
NOI-2
NOI-4
NOI-5
MM
AQ-1 LTS No Yes
Impact AQ-3: Expose
People to Fugitive Dust
Emissions Containing
Naturally Occurring
Asbestos and Related
Health Risk.
LTS
Impact AQ-3,
pp. 3.4-34 –
3.4-35
Yes
AQ-1
AQ-4
AQ-5
HAZ-1
NOI-4
NOI-5
MM
AQ-1
AQ-4
LTS No Yes
Impact AQ-4: Expose
People to Toxic Air
Contaminants Emitted by
Prescribed Burns and
Related Health Risk.
PSU
Impact AQ-4,
pp. 3.4-35 –
3.4-37
Yes
AD-4
AQ-2
AQ-3
AQ-6
NA (No
feasible
mitigation
available)
PSU No Yes
Impact AQ-5: Expose
People to Objectionable
Odors from Diesel Exhaust.
LTS
Impact AQ-5,
pp. 3.4-37 –
3.4-38
Yes
HAZ-1
NOI-4
NOI-5
NA LTS No Yes
Impact AQ-6: Expose
People to Objectionable
Odors from Smoke During
Prescribed Burning.
PSU Impact AQ-6,
pp. 3.4-38 Yes
AD-4
AQ-2
AQ-6
NA (No
feasible
mitigation
available)
PSU No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact. None: there are SPRs and/or MMs identified in the PEIR for this
impact, but none are applicable to the treatment project.
New Air Quality Impacts: Would the treatment result in other impacts to air quality
that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
23
4.3.1 Air Quality Discussion
All burning shall be conducted in accordance with direction from the Mendocino County AQMD. It is not expected that smoke
from this burn will affect air quality in either Lake or Sonoma County. Primary smoke receptors for the project are the nearb y
communities of Ukiah, Talmage, Calpella, as well as residences located in Yokayo Valley and along HWY 101. Burning under
conditions specified in the prescription will mitigate adverse smoke impacts. Smoke columns will be visibly monitored for
direction and lift to evaluate smoke dispersal/transport predictions. Personnel will be assigned to observe smoke dispersal as
necessary. The burn will be curtailed if the planned convective lift and/or planned dispersal cannot be achieved.
Smoke dispersal conditions will be evaluated in the morning, at the test burn, and continually monitored throughout the durat ion
of the project. On-site monitoring will include weather, smoke, and fire behavior observations. Additional information will be
collected from the Ukiah, Hopland, and Boonville RAWS located southwest and southeast of the project area. Estimated
mixing heights and upper level transport winds will be obtained from the Redding Interagency Fire/Forecast Warning Unit
internet site at: www.fs.fed.us/r5/fire/north/fwx/smok.txt or at the National Weather Service-Eureka spot forecast internet site
at: http://www.wrh.noaa.gov/eka/.
To minimize daily and cumulative air quality impact to the regional area, the project will be scheduled in coordination with the
Mendocino County AQMD, Northern Sonoma County NSCAPCD, the Lake County AQMD, and any other local private or
agency prescribed fire projects.
Pursuant to SPR AQ-2, CAL FIRE will prepare a smoke management plan and submit it to the air district with jurisdiction
over the treatment area(s) where prescribed burning is proposed before implementing a prescribed burning treatment, if
required. Pursuant to SPR AQ-3, a burn plan will be prepared for broadcast burning, will include fire behavior modeling, and
will be implemented by a state-certified burn boss, as required. An Incident Action Plan, which identifies burn dates, burn
hours, weather limitations, specific burn prescription, the communication plan, the medical plan, the traffic plan, and other
special instructions will also be prepared by CAL FIRE for all proposed prescribed burning treatments. The Incident Action
Plans will also identify the contact personnel with the applica ble air district to coordinate on-site briefings, posting notifications,
and weather monitoring during burning.
IMPACT AQ-1
Use of vehicles, mechanical equipment, and prescribed burning during initial and maintenance treatments would result in
emissions of criteria pollutants that could exceed California ambient air quality standard (CAAQS) or national ambient air
quality standard (NAAQS) thresholds. The potential for emissions of criteria pollutants to exceed CAAQS or NAAQS
thresholds was examined in the PEIR. Emissions of criteria air pollutants related to the proposed treatments are within the
scope of the PEIR because the associated equipment and duration of use are consistent with those analyzed in the PEIR. The
SPRs applicable to this treatment project are AD-4, AQ-1 through AQ-4, AQ-5, and AQ-6. Additionally, the emission reduction
techniques included in Mitigation Measure AQ-1 would be implemented. The project proponent will reduce exhaust emissions
from vehicles and equipment by only using the necessary amount of holding resources, encouraging carpooling to the project
area, and using Best Available Control Technology for emission reductions for off-road equipment and diesel trucks. This
determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what
was covered in the PEIR, and with MM AQ-1 the impact is considered less than significant with the mitigation measure.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the air quality conditions present
and air basins in the areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the air quality impact is also the same, as described above. This determination is consistent with the PEIR and would
not constitute a substantially more severe significant impact than what was covered in the PEIR.
IMPACT AQ-2
Use of vehicles and mechanical equipment during initial and maintenance treatments could expose people, such as hikers in
the project area, to diesel particulate matter emissions. However, treatment activities would not take place near the same people
for an extended period. The potential to expose people to diesel particulate matter emissions was examined in the PEIR. Diesel
particulate matter emissions from the proposed treatments are within the scope of the PEIR because the exposure potential is
the same as analyzed in the PEIR, and the types and amount of equipment that would be used, as well as the duration of use,
during proposed treatments are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment
area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR.
However, within the boundary of the project area, the air quality conditions and sensitive receptors (i.e., exposure potential)
present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore,
the air quality impact is also the same, as described above. SPR HAZ-1 and NOI-2, NOI-4, and NOI-5 are applicable to this
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
24
treatment. Additionally, MM AQ-1 will mitigate further the diesel particulate emissions. This determination is consistent with
the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
IMPACT AQ-3
Use of mechanical equipment during treatments would involve ground-disturbing activities. Pile and broadcast burning would
not involve ground disturbance although preparation for burning could require some disturbance, such as when dragging
vegetation around or implementing control lines. The potential to expose people to naturally occurring asbestos containing
fugitive dust emissions was examined in the PEIR (CalVTP Final PEIR Volume II Section 3.4.3, pages 3.4 -34–3.4-35). This
impact would apply to the project area because there are two small pockets of serpentinite/ultramafic rock mapped in the
treatment area by CGS in 2020 and 2022. Please see Section 4.6 Geology, Soils, Paleontology, and Mineral Resources for a
discussion on serpentine and geologic background. There is a disjointed band of serpentine that runs northwest at the base of
the hills along the Ukiah Valley. The first area within the PIZ is in the northeastern corner and the second is along Oak Knoll
Road, as shown in Figure 4.6-2. Most of the project area is mapped as graywacke sandstone (slightly metamorphosed) with
mélange to the north and south. These units are parts of the Franciscan Complex, which could contain smaller unmapped bodies
of serpentine outcroppings or other lithologies favorable for presence of NOA. The larger landslide feature to the west of the
Oak Knoll Road occurrence of serpentine has a higher potential for metals and NOA than the other surrounding landslide
deposits, however the amount and concentration would depend on the source of the debris. Both serpentine locations contain
existing control lines from previous fire suppression activities and additional ground disturbance is not proposed to maintain
these areas. The soils mapped by The Soil Conservation Service do not have serpentine in their descriptions, however
Mendocino County does identify some soils on the main trending ridge as possibly serpentine soils.
As discussed in the PEIR, pile burning and ground disturbing activities such as vehicle and heavy equipment usage could resul t
in naturally occurring asbestos becoming airborne. In accordance with SPR AQ-1, project proponents will comply with the
rules and regulations laid out by the Mendocino County Air Quality Management District (MCAQMD) of the California North
Coast Air Basin. Consultation with California Geological Survey (CGS) during project design identified se veral areas within
the project area that may contain naturally occurring Asbestos (NOA). Per SPR AQ-5, no ground-disturbing activities would
occur in these areas unless an Asbestos Dust Control Plan is prepared and approved by MCAQMD. The proposed project
would also implement SPR AQ-4, which minimizes fugitive dust emissions during treatment activities. Potential naturally
occurring asbestos exposure from the proposed treatments would be less than significant and is within the scope of the activities
and impacts addressed in the PEIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a minor chang e
to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape
because they are immediately adjacent each other and are underlain by the same type of serpentine soils and would involve
similar or the same types of ground-disturbing activities. Therefore, the air quality impact is also the same, as described above,
and would also be less than significant with the implementation of the same SPRs. This determination is consistent with the
PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
IMPACT AQ-4
Prescribed burning during initial and maintenance treatments could expose people to toxic air contaminants, which was
examined in the PEIR. The duration and parameters of the prescribed burns are within the scope of the activities addressed in
the PEIR, and within the North Coast Air Basin, air quality conditions are consistent with those analyzed in the PEIR for
Mendocino County. Therefore, the potential for exposure to toxic air contaminants is also within the scope the PEIR. SPRs
applicable to these treatment activities are AD-4, AQ-2, AQ-3, and AQ-6. All feasible measures to prevent and minimize smoke
emissions, as well as exposure to smoke, are included in SPRs. No additional mitigation measures are feasible, and this impact
would remain significant and unavoidable, as explained in the PEIR. The inclusion of land in the proposed treatment area that
is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within
the boundary of the project area, the air quality conditions present and air basins in the areas outside the treatable landscape are
essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as described
above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact
than what was covered in the PEIR.
IMPACT AQ-5
Use of vehicles and mechanical equipment during initial and maintenance treatments could expose people, such as hikers
in/around the project area, to objectionable odors from diesel exhaust. However, treatment activities would not take place near
the same people for an extended period. The potential to expose people to objectionable odors from diesel exhaust was examined
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
25
in the PEIR. This impact is within the scope of the PEIR because the exposure potential and the proposed activities, as well as
the associated equipment and duration of use, are consistent with those analyzed in the PEIR. The inclusion of land in the
proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented
in the PEIR. However, within the boundary of the project area, the air quality conditions, and sensitive receptors present in the
areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the air quality
impact is also the same, as described above. SPR HAZ -1 and NOI-4 and NOI-5 are applicable to this treatment. This determination
is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the
PEIR.
IMPACT AQ-6
Prescribed burning during initial and maintenance treatments could expose people to objectionable odors. The potential to
expose people to objectionable odors from prescribed burning was examined in the PEIR. The duration and parameters of the
prescribed burn and the exposure potential are consistent with the activities addressed in the PEIR. Therefore, the resultant
potential for exposure to objectionable odors from smoke is also within the scope of impacts covered in the PEIR. SPRs that
are applicable to this treatment project are AD-4, AQ-2, and AQ-6. All feasible measures to prevent and minimize smoke odors,
as well as exposure to smoke odors, are included in SPRs. No additional mitigation measures are feasible, and this impact
would remain significant and unavoidable, as explained in the PEIR. The inclusion of land in the proposed treatment area that
is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within
the boundary of the project area, the air quality conditions present and sensitive receptors in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the air quality impact is also the same, as
described above. This determination is consistent with the PEIR and would not constitute a substantially more severe signific ant
impact than what was covered in the PEIR.
NEW AIR QUALITY IMPACTS
The proposed treatments are consistent with the treatment types and activities covered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable regulatory and environmental conditions presented in the CalVTP PEIR (refer to Section 3.4.1, “Regulatory
Setting,” and Section 3.4.2, “Environmental Setting,” in Volume II of the Final PEIR). The project proponent has also
determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the p roject area, the existing
environmental and regulatory conditions pertinent to air quality that are present in the areas outside the treatable landscap e are
essentially the same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described
above, impacts of the proposed treatment project are consistent with those covered in the PEIR. No changed circumstances are
present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impact.
Therefore, no new impact related to air quality would occur.
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4.4 ARCHAEOLOGICAL, HISTORICAL & TRIBAL CULTURAL
RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact CUL-1: Cause a
Substantial Adverse Change in
the Significance of Built
Historical Resources?
LTS
Impact CUL-1,
pp. 3.5-14 –
3.5-15
Yes
CUL-1
CUL-7
CUL-8
NA LTS No Yes
Impact CUL-2: Cause a
Substantial Adverse Change in
the Significance of Unique
Archaeological Resources or
Subsurface Historical
Resources?
SU
Impact CUL-2,
pp. 3.5-15 –
3.5-16
Yes
CUL-1
through
CUL-8
MM
CUL-2 LTSM No Yes
Impact CUL-3: Cause a
Substantial Adverse Change in
the Significance of a Tribal
Cultural Resource?
LTS Impact CUL-3,
p. 3.5-17 Yes
CUL-1
through
CUL-8
NA LTS No Yes
Impact CUL-4: Disturb Human
Remains? LTS Impact CUL-4,
p. 3.5-18 Yes NA NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Archaeological, Historical, and Tribal Cultural Resource Impacts: Would the
treatment result in other impacts to archaeological, historical, and tribal cultural
resources that are not evaluated in the CalVTP PEIR?
Yes
No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.4.1 Archaeological, Historical & Tribal Cultural Resources Discussion
Consistent with SPR CUL-1, an updated records search of the PIZ was performed by the Northwest Information Center (NWIC)
at Sonoma State university (SSU). Three separate Archaeological Records Check Requests were made, as the PIZ expanded in
total size and acreage as more stakeholders became involved. The entire area submitted to NWIC for a records check (the sum
of all three records check results) will be referred to here as the PIZ. The first NWIC Archaeological Records Check was
completed on March 27, 2023 (NWIC File No. 22-1392). The area submitted under this information request included the West
Hills of Ukiah. A second NWIC Archaeological Records Check was completed on October 27, 2023 (NWIC File No. 233 -
0491). The third and final NWIC Archaeological Records Check was completed on November 30, 2023 (NWIC File No. 23-
0674). The area submitted under the second and third information requests included the majority of the parcels to the east of
the first information request, butting up against the higher density residential neighborhoods at the base of the western hills.
RESULTS OF NWIC INFORMATION REQUESTS: The NWIC results for the three information requests can be found in the
Confidential Archaeological Survey Report (ASR) which was prepared for the Treatment Units within the PIZ.
Consistent with SPR CUL-2, a Native American contact list was obtained from The CAL FIRE Native American Contact List
(revised September 20, 2023) published on their website. On February 1, 2024, letters or emails inviting the tribes to consult
were mailed to the 32 different tribal representatives as disclosed on the Native American Contact List. No responses were
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received from any Native American tribes as of Ma y 23, 2025.
Consistent with SPR CUL-3, pre-field research was conducted. Archaeologically trained resource professionals reviewed
historic and contemporary maps, aerial photographs, records, ethnographic literature, and historical literature. This information
can be found in the Archaeological Survey Report (ASR) in Attachment B.
Consistent with SPR CUL-4, archaeological surveys (cursory, general, and complete surveys) were conducted by
archaeologically trained resource professionals for the identified and planned treatment Units including approximately 453
acres of dozer/control lines and 545 acres of burn units. High probability areas were determined and received a higher degree
of survey intensity. Survey coverage intensity and results are disclosed in the Archaeological Survey Report (ASR).
Additionally, the project area has been subject to several previous cultural resource surveys conducted within and adjacent to
it, as documented in the ASR. Of these efforts, four archaeological investigations occurred within or adjacent to the currently
planned treatment units. The surveys identified no prehistoric resources within the treatment units and documented one
previously recorded historic resource (Wildberger Orchard) within the treatment unit. Three additional previously recorded
historic sites are located outside of, but adjacent to, the project area. Consistent with SPR CUL-7, the previously recorded
historic-period resource, Wildberger Orchard, will be protected mainly through avoidance. A small portion of an existing
control/dozer line intersects the site boundary at the northeastern edge of the site where the control line meets an existing
seasonal road that traverses downslope through the site. This existing seasonal road and control/dozer line will likely be needed
for ingress and egress of heavy equipment and vehicles associated with the fuels reduction grant project. All vehicles and
equipment shall be restricted to ingress/egress along the existing dirt road/control line within the site boundaries. Vegetat ion
removal along the existing road and control/dozer line shall consist of ONLY what is required to maintain safe and efficient
access to and from the project area. A CAL FIRE Archaeologist or a CAL FIRE Forester with current CAL FIRE Certified
Archaeological Surveyor training shall be onsite the day that equipment and vehicles are accessing the project area through t he
Wildberger Orchard site.
Consistent with SPR CUL-8, a CAL FIRE Archaeologist or a CAL FIRE Forester with current CAL FIRE Certified
Archaeological Surveyor training shall train all crew members and contractors implementing treatment activities on the
protection of sensitive archaeological, historical, or tribal cultural resources. Workers will be trained to halt work if
archaeological resources are encountered on a treatment site and the treatment method consists of physical disturbance of land
surfaces.
IMPACT CUL-1
Proposed treatment activities within the Treatment Units include mechanical treatments, manual treatments, and prescribed
burning, which could damage historical resources. Although the NWIC records search revealed one historic feature , this has
not been evaluated for eligibility for listing in the California Register of Historical Resources (CRHR). Therefore, it is not
known whether this site is considered to be a resource under CEQA. Nevertheless, historic features (i.e., homestead sites, refuse
piles) over 50 years old that have not been evaluated for historical significance and are present in the treatment areas will be
avoided pursuant to SPR CUL-7. The potential for these treatment activities to result in disturbance, damage, or destruction of
built-environment structures that have not yet been evaluated for historical significance was examined in the PEIR. This impact
is within the scope of the PEIR, because treatment activities and the intensity of ground disturbance of the treatment projec t
are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP
treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the
treatment area, the potential to encounter built -environment structures that have not yet been evaluated for historical
significance in areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore,
the potential impact to historical resources is also the same, as described above. SPRs applicable to this impact are CUL-1,
CUL-7, and CUL-8. This determination is consistent with the PEIR and would not constitute a substantially more severe
significant impact than what was covered in the PEIR.
IMPACT CUL-2
Vegetation treatment would include mechanical treatments using heavy equipment that could churn up the surface of the ground
during treatment as vegetation is removed; this may result in damage to known or previously unknown archaeological resources.
The NWIC records search revealed one historical site within the Treatment Units/PIZ. The NWIC records search revealed no
prehistoric resources within the Treatment Units/PIZ. Surveys have been conducted prior to treatment pursuant to SPR CUL-4
to identify any previously unrecorded archeological resources and identified resources will be avoided according to the provisions
of SPR CUL-5.
The potential for these treatment activities to result in inadvertent discovery and subsequent damage of unique archaeological
resources or subsurface historical resources during vegetation treatment was examined in the PEIR. This impact was identified
as significant and unavoidable in the PEIR because of the large geographic extent of the treatable landscape and the possibility
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that there could be some rare instances where inadvertent damage of unknown resources may be extensive. For the Ukiah West
Hills Vegetation Treatment Units, SPRs and Mitigation Measure CUL-2 would require identification and protection of resources,
and it is reasonably expected that implementation of these measures would avoid a substantial adverse change in the significance
of any unique archaeological resources or subsurface historical resources. Therefore, this impact would be less than significant.
This impact is within the scope of the PEIR, because treatment activities and intensity of ground disturbance of the treatment
project are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the
CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary
of the treatment area, the potential for discovery of archaeological resources is essentially the same within and outside the treatable
landscape; therefore, the potential impact to unique archaeological resources or subsurface historical resources is also the same,
as described above. SPRs applicable to this treatment include CUL-1 through CUL-8. Mitigation Measure CUL-2 would also
apply to this treatment to protect any inadvertent discovery. If any prehistoric or historic-era subsurface archaeological features
or deposits, including locally darkened soil (“midden”), that could conceal cultural deposits, are discovered during ground -
disturbing activities, all ground-disturbing activity within 100 feet of the resources will be halted and a qualified archaeologist
will work with the project proponent to develop a site record and protection measures. Local tribes will be contacted and
consulted regarding protection measures. This determination is consistent with the PEIR and would not constitute a
substantially more severe significant impact than what was covered in the PEIR.
IMPACT CUL-3
Native American contacts in Mendocino County were contacted via letter and email on February 1, 2024. The Native American
contact list was obtained from the CAL FIRE Native American Contact List (revised September 20, 2023) published on their
website. No responses were received from any Native American tribes as of May 23, 2025. The potential for the proposed
treatment activities to cause a substantial adverse change in the significance of a tribal cultural resource during implementation
of vegetation treatment was examined in the PEIR. This impact is within the scope of the PEIR, because the intensity of groun d
disturbance of the treatment project is consistent with that analyzed in the PEIR. As explained in the PEIR, while tribal cultural
resources may be identified within the treatable landscape during development of later treatment projects, implementation of
SPRs would avoid any substantial adverse change to any tribal cultural resource. The inclusion of land in the proposed treatment
area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR.
However, within the boundary of the project area, the tribal cultural affiliations present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the potential impact to tribal cultura l
resources is also the same, as described above. SPRs applicable to this treatment include CUL -1 through CUL-8. This
determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what
was covered in the PEIR.
IMPACT CUL-4
Vegetation treatment activities would include mechanical treatments using heavy equipment; these treatments may use skid
steers, excavators, dozers, and masticators, which could uncover human remains. The NWIC records search did not reveal any
burials or sites containing human remains. The potential for treatment activities to uncover human remains was examined in
the PEIR. This impact is within the scope of the PEIR, because the treatment activities and intensity of ground disturbance a re
consistent with those analyzed in the PEIR. Additionally, consistent with the PEIR, the project would co mply with California
Health and Safety Code Section 7050.5 and PRC Section 5097 in the event of a discovery. The inclusion of land in the proposed
treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent p resented in the
PEIR. However, within the boundary of the treatment area, the potential for uncovering human remains during implementation
of the treatment project is essentially the same within and outside the treatable landscape and treatment activities; therefore, the
impact related to disturbance of human remains is also the same, as described above. No SPRs or MMs are applicable to this
impact. This determination is consistent with the PEIR and would not constitute a substantially more severe significa nt impact
than what was covered in the PEIR.
NEW ARCHAEOLOGICAL, HISTORICAL & TRIBAL CULTURAL RESOURCE
IMPACTS
The proposed treatment is consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.5.1,
“Environmental Setting,” and Section 3.5.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the treatment area, the existing
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environmental and regulatory conditions pertinent to archaeological, historical, or tribal cultural resources that are presen t in
the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the im pacts
of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances are present,
and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts.
Therefore, no new impact related to archaeological, historical, or tribal cultural resources would occur.
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4.5 BIOLOGICAL RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in
the PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable
to the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for Treatment
Project
Would This Be a
Substantially
More Severe
Significant Impact
than Identified in
the PEIR?
Is This
Impact
within the
Scope of the
PEIR?
Would the project:
Impact BIO-1:
Substantially Affect
Special-Status Plant
Species Either Directly or
Through Habitat
Modifications?
LTS
Impact BIO-
1, pp 3.6-
131–3.6.138
Yes
AQ-3
BIO-1
BIO-2
BIO-6
BIO-7
BIO-9
GEO-1
GEO-3
GEO-4
GEO-5
GEO-7
HYD-4
HYD-5
MM
BIO-1a
BIO-1b
BIO-1c
LTSM No Yes
Impact BIO-2: Substantially
Affect Special-Status
Wildlife Species Either
Directly or Through Habitat
Modifications?
LTSM (all
wildlife
species
except
bumble
bees)
PSU
(bumble
bees)
Impact BIO-
2, pp 3.6-
138–3.6-
184
Yes
BIO-1
through
BIO-7
BIO-9
through
BIO-12
GEO-1
HYD-1
HYD-3
HYD-4
HYD-5
HAZ-5
HAZ-6
MM
BIO-2a
through
BIO-2h
BIO-3a
BIO-3b
BIO-3c
LTSM No Yes
Impact BIO-3: Substantially
Affect Riparian Habitat or
Other Sensitive Natural
Community Through Direct
Loss or Degradation That
Leads to Loss of Habitat
Function?
LTS
Impact BIO-
3, pp 3.6-
186–3.6-
191
Yes
BIO-1
through
BIO-6
BIO-9
GEO-1
GEO-3
GEO-4
GEO-5
GEO-7
HAZ-5
HAZ-6
HYD-4
HYD-5
MM
BIO-3a
BIO-3b
BIO-3c
LTSM No Yes
Impact BIO-4: Substantially
Affect State or Federally
Protected Wetlands?
LTS
Impact BIO-
4, pp 3.6-
191–3.6-
192
No
SPR BIO-
1 through
SPR BIO-
4, SPR
BIO-9,
SPR
GEO-1,
SPR
GEO-3,
NA NA No Yes
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SPR
through
SPR
GEO- 5,
SPR
GEO-7,
SPR
HAZ-5,
SPR
HAZ-6,
SPR
HYD-1,
SPR
HYD-4,
and SPR
HYD-5.
Impact BIO-5: Interfere
Substantially with Wildlife
Movement Corridors or
Impede Use of Nurseries?
LTS
Impact BIO-
5, pp 3.6-
192–3.6-
196
Yes
BIO-1
BIO-3
BIO-4
BIO-5
BIO-10
BIO-11
HYD-1
HYD-4
MM
BIO-5 LTS No Yes
Impact BIO-6: Substantially
Reduce Habitat or
Abundance of Common
Wildlife?
LTS
Impact BIO-
6, pp 3.6-
197–3.6-198
Yes
BIO-1
through
BIO-4
BIO-12
NA LTS No Yes
Impact BIO-7: Conflict
with Local Policies or
Ordinances Protecting
Biological Resources?
NI
Impact BIO-
7, pp 3.6-
198–3.6-199
Yes AD-3 NA NI No Yes
Impact BIO-8: Conflict with
the Provisions of an
Adopted Natural
Community Conservation
Plan, Habitat Conservation
Plan, or Other Approved
Habitat Plan?
NI
Impact BIO-
8, pp 3.6-
199–3.6-
200
No -- NA NI No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Biological Resources Impacts: Would the treatment result in other impacts
to biological resources that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.5.1 Biological Resources Discussion
In accordance with SPR BIO-1, a qualified botanist conducted a comprehensive data review of biological resources specific to the
project, including habitat and vegetation types, special-status plants, special-status wildlife, and sensitive habitats (e.g., sensitive
natural communities and wetlands) that have the potential to occur in the treatment areas. The identification of habitat and vegetation
types within these treatment areas was accomplished through both vegetation mapping and on-site assessments. The combined
acreage of the treatment areas totals approximately 1,350 acres.
An agency (in this case only CDFW) notification letter was mailed out on February 19, 2024, as part of the compliance for PRC
§4123 communications. A response from CDFW was received on February 28, 2024, and no comments were noted. A revised letter
was emailed to CDFW on May 20, 2025, and a response received the same day with questions/comments. Through email
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correspondence, the questions were clarified and incorporated into the project design.
A list of special-status plant and wildlife species with the potential to occur in the project area was compiled by completing a review
of the California Department of Fish and Wildlife's (CDFW) California Natural Diversity Database (CNDDB) and California Native
Plant Society (CNPS) Rare Plant Inventory database records for the 12 U.S. Geological Survey (USGS) quadrangles (referred to as
quads) containing and surrounding the project area (CDFW 2024a; CNPS 2024a), the U.S. Fish and Wildlife Service (USFWS)
Information for Planning and Consultation (IPaC) tool (USFWS 2024); and Appendix BIO-3 (Table 9b, Table 10a) in the PEIR for
special-status plants and wildlife that could occur in the Northern California Coast (263A) and Coast Ranges (M261B) Ecological
Sections. The search parameters encompassed the following quads: Ukiah, Orrs Springs, Elledge Peak, Purdys Gardens, Potter
Valley, Redwood Valley, Laughlin Range, Greenough Ridge, Bailey Ridge, Boonville, Cow Mountain, and Philo (Figure 4.5-1
CNDDB Map). A list of sensitive natural communities with the potential to occur in the project area (see Table 4.5-2) was compiled
by completing a CNDDB search of the quads (CDFW 2024a), reviewing Tables 3.6-16 and 3.6-18 in the PEIR for sensitive natural
communities that could occur in the Northern California Coast and Coast Ranges Ecological Sections in the habitat types mapped
in the project area, and based on professional experience in similar landscapes of Mendocino County.
FIELD SURVEYS
NCRM, Inc. biologists conducted reconnaissance surveys on 6/30/22, 7/21/22, 7/26/22, 8/5/22, 8/25/22, 4/5/23, 4/28/23,
5/12/23, 6/26/23, 10/3/2023, 4/18/24, 6/20/24, 7/8/42, 8/9/24, 5/12/25 to identify and document sensitive resources (i.e.,
special-status plant species, sensitive natural communities) and to assess the suitability of habitat in the treatment areas for
special-status plant and wildlife species. These surveys were conducted for the Treatment Units in three different coverage
levels for both plant and wildlife species: cursory, complete, and none (Figure 4.5-2) and prioritized areas in habitats that may
support special status species and where ground-disturbing activities may occur (i.e., dozer lines). Surveys were conducted
throughout the fuel breaks along the eastern boundary (except where landowner permission was not granted), in the southern
pocket of the project area, and in some areas on the eastern boundary of the project . Vegetation communities and soil
characteristics were identified, and incidental wildlife observations were recorded.
Based on the implementation of SPR BIO-1, a complete list of all special-status species and habitats with the potential to occur
in the vicinity of the proposed project was assembled (Table 4.5-1). Twenty-four special-status plant species, 1 sensitive habitat,
and 14 special-status wildlife were determined to have the potential to occur in the treatment areas (Table 4.5 -1). Species are
discussed in detail under Impact BIO-1 (special-status plants) and Impact BIO-2 (special-status wildlife), and sensitive habitats
are discussed under Impact BIO-3.
GENERAL HABITAT DISCUSSION
Prescribed burn treatments mimic natural disturbance and may offer benefits for wildlife, such as promoting herbaceous plant
growth and diversity. Following a prescribed burn, abundant growth of forbs, legumes, and native grasses serve as vital sources
of food and cover for diverse wildlife populations. In chaparral ecosystems, like the one found within the Ukiah West Hills
project area, the deep-rooted flora plays a crucial role in stabilizing slopes and in general wildlife health. Fire is an integral
component of the life cycle of chaparral plant communities, necessitating periodic burning to rejuvenate these ecosystems. As
unburned plants age, the accumulation of dead material increases, reaching an estimated 30-50% within the project area. In
cases where chaparral plants are uniformly mature and widespread, wildfires tend to be stand replacing extensive and highly
destructive.
The deliberate burning of vegetation stands to benefit wildlife species that rely on younger vegetation stages. While certain
wildlife species thrive in these younger stages, others, dependent on mature chaparral or dense woodland understory, may be
adversely affected by such transformations. Overall, the impact is not deemed significant due to the adaptability of many
species and the variation in vegetation burn intensities, which are influenced by factors such as aspect, slope percentage, a nd
slope position. This results in a mosaic effect, contributing to a wider range of habitats that can support a diverse array of
wildlife.
Chaparral species regenerate through both sprouting and reseeding processes. Fire eliminates shading that would hinder
seedling success and reduces allelopathic germination inhibitors present in decaying organic material and soil. Additionally,
combustion byproducts can induce germination, with smoke acting as a crucial chemical st imulant, as observed in Emmenanthe
penduliflora, a California chaparral annual (Keeley and Fotheringham 1998).
The decadent grass and shrub cover throughout the Ukiah West Hills project area corresponds with the loss of sub-dominant
and herbaceous habitat essential for sustaining specific wildlife species. By removing this cover and reducing ground litter
through moderate surface fire, dormant seed-based herbaceous species can germinate and thrive, given adequate light and
moisture. The use of low-intensity prescribed fires also promotes nutrient cycling and contributes to the restoration of natural
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vegetative seral stages and fuel levels. Eliminating unnatural accumulations of dead and downed vegetative debris reduces the
intensity of wildfires during the summer months.
Winter burning in chaparral stands does not contribute to the maintenance or establishment of forbs and nonsprouting shrubs.
To mitigate this, strategic ignition/burnout is employed to create a mosaic pattern of burned and unburned areas, thereby
ensuring a seed source for the burned regions. This mosaic pattern enhances the edge effect, increases plant diversity, and aids
in restoring plant and wildlife habitat that is threatened by dense shrub growth.
Vegetation types in the vicinity of the project area (Figure 4.5-3, Vegetation Cover Types Map) encompass grasslands, chamise
chaparral, manzanita chaparral, mixed hardwood forest, and Douglas-fir – hardwood forest. The coastal sage scrub community
type, addressed in SPR BIO-5 does not exist in the project area. Chaparral coverage varies from nearly continuous to sparse,
with grassy openings and areas featuring a mixture of hardwood tree species and grasses. The chamise component ranges from
pure stands to a 50/50 mix with ceanothus, manzanita, and other chaparral species along with minor amounts of herbaceous
vegetation. The application of prescribed fire within this project will be confined to grassland, chamise, and mixed chaparral
fuel types.
ANNUAL GRASSLAND
There are areas of grassland intermixed throughout the project area. Species include introduced and native annual grasses suc h
as brome (Bromus spp.), bluegrass (Poa spp.), wild oats (Avena spp.), fescue (Vulpia spp.), dogtail (Cynosurus spp.), barley
(Hordeum murinum), needlegrass (Nassella spp.), and oatgrass (Danthonia spp.). Additionally, Oregon white oak (Quercus
garryana) may be present adjacent to grasslands.
CHAMISE CHAPARRAL
Chamise chaparral is commonly found on south-facing, xeric slopes within the project area. The root crown of chamise
(Adenostoma fasciculatum) sprouts vigorously following ground disturbances, such as intense fires. Chaparral species such as
wedgeleaf ceanothus (Ceanothus cuneatus), shrub canyon live oak (Quercus chrysolepis subsp. nana), and manzanitas
(Arctostaphylos spp.) may may occur on less xeric microsites, such as north-facing slopes or canyon drainages, where slightly
more moisture is available.
MIXED CHAPARRAL
Most of the proposed project area and burn units are composed of mixed chaparral. Present species include varying mixtures
of chamise (Adenostoma fasciculatum), wedgeleaf ceanothus (Ceanothus cuneatus), deerbrush (C. integerrimus), common and
whiteleaf manzanita (Arctostaphylos manzanita, A. viscida), birchleaf mountain mahogany (Cercocarpus betuloides), and
toyon (Heteromeles arbutifolia).
Hardwoods that are present, interspersed with areas of chaparral, include canyon live oak (Quercus chrysolepsis), dwarf interior
live oak (Quercus wislezinii subsp. frutences), California scrub oak (Quercus berberidifolia), California buckeye (Aesculus
californica), bigleaf maple (Acer macrophyllum), California bay (Umbellularia californica), and Pacific madrone (Arbutus
menziesi).
MIXED HARDWOOD FOREST / DOUGLAS -FIR - HARDWOOD FOREST
Areas of mixed hardwoods and Douglas-fir forest are present on north-facing slopes and along drainages in the project area.
Hardwoods typically include tanoak (Lithocarpus densiflorus) and Pacific madrone (Arbutus menziesi). Douglas-fir
(Pseudotsuga menziesii), pine (Pinus spp.), and redwood (Sequoia sempervirens) are the main conifer species present. No late-
seral stage forests are present within the project area.
ECOREGIONS
The PIZ encompasses two distinct ecoregions. The predominant ecoregion within the area is the Outer North Coast Ranges,
characterized by high rainfall and mixed evergreen and hardwood forests including Douglas-fir, tanoak, Oregon white oak, and
some needlegrass grasslands. Some redwood patches were observed in the project area. Mountain peaks in this region are lower
in elevation than those in the High North Coast Ranges ecoregion to the east. Soil temperature regimes are predominantly
mesic and soil moisture regimes are xeric. Landslides occur frequently in this region, and high sediment loads occur in streams
and rivers. By the end of the summer season, all but the larger streams have typically dried up.
Moving southward, the landscape gradually transitions into the Sonoma-Mendocino Mixed Forest ecoregion. In this region the
dominant feature is a mixed hardwood forest, including tanoak, black oak, madrone, Oregon white oak, Douglas -fir, with only
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a few small pockets of redwoods. Annual grasslands and chaparral also occur in the mosaic. The geological composition
comprises Tertiary sandstone and shale, alongside some Cretaceous and Jurassic Franciscan Complex metasedimentary rocks.
Most streams in this area flow eastward, ultimately joining the Russian River (Griffith et al. 2016).
Notably, the Napa-Sonoma-Russian River Valley region does not directly intersect with the project area but does border the
lower foothills to the east. This region is characterized by its lower, flatter terrain, higher population density, and greater
presence of cropland, vineyards, and orchards compared to its surroundings. The part of this region closest to the PIZ
experiences less maritime influence and fog compared to valleys further south. Predominantly, Quaternary alluvium covers
extensive portions of the area, with occasional pockets of older, loosely consolidated sedimentary material.
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Table 4.5-1 Potential for Special-Status Plant & Wildlife Species to Occur in the Treatment Areas
Species
Listing
Status1
Federal
Listing
Status1
State
Listing
Status1
CRPR
Habitat Potential for Occurrence
Special-status plants
Allium peninsulare subsp.
franciscanum
Franciscan onion - - 1B. 2
Cismontane woodland, valley, and foothill
grassland. Clay and serpentinite (often);
volcanic. 170 - 1000 feet in elevation. Blooms
(April) May-June.
Not likely to occur. Reported observations of A.
peninsulare subsp. franciscanum generally occurred south
of Santa Rosa. The nearest observation was in 1999,
approximately 4 miles northwest of Cloverdale.
Arctostaphylos stanfordiana subsp.
raichei
Raiche's manzanita - - 1B. 1
Chaparral, lower montane coniferous forest
(openings). Rocky, serpentinite (often). 1475 -
3395 feet in elevation. Blooms February-
April.
Present within the project area. A. stanfordiana subsp.
raichei was documented in 2017 along the control line,
north of Gibson creek, near the “U” landmark.
Astragalus agnicidus
Humboldt County milk-vetch - Endangered 1B.1
Broad-leafed upland forest, North Coast
coniferous forest. Disturbed areas, Openings,
Roadsides (sometimes). 120-800 meters in
elevation. Blooms April-September.
Not likely to occur. The nearest observations of A.
agnicidus were reported in 2007, approximately 14 miles
from Ukiah, near the Little North Fork of the Navarro
River.
Blennosperma bakeri
Sonoma sunshine Endangered Endangered 1B. 1
Valley and foothill grassland (mesic) vernal
pools. 35 - 360 feet in elevation. Blooms
March-May.
No potential to occur. The habitable elevation range for B.
bakeri is lower than the project area.
Brasenia schreberi
watershield - - 2B. 3 Marshes and swamps (freshwater). 0 - 7220
feet in elevation. Blooms June-September.
No potential to occur. Marsh and swamp habitats are not
present within the project area.
Carex comosa
bristly sedge - - 2B. 1
Coastal prairie, marshes, and swamps (lake
margins) valley and foothill grassland. 0 -
2050 feet in elevation. Blooms May-
September.
Not likely to occur. The nearest observations of C. comosa
were reported in 2003, approximately 12 miles from Ukiah,
within the Hopland Research Station property. Valley and
foothill grassland habitat, potentially suitable for this
species are present within the project area. Coastal prairie,
marsh, and swamp habitats are not present.
Ceanothus confusus
Rincon Ridge ceanothus - - 1B. 1
Chaparral, cismontane woodland, closed-cone
coniferous forest. Serpentinite (sometimes)
volcanic (sometimes). 245 - 3495 feet in
elevation. Blooms February-June.
Not likely to occur. The nearest observation of C. confusus
was reported in 2021, approximately 28.5 miles from
Ukiah, in Clear Lake Riviera. Chaparral and cismontane
woodland habitats, suitable for this species, are present
within the project area. Volcanic substrates are not.
Serpentine substrates are likely present as species with
strong ultramafic affinities have been observed within the
project area.
*Entosthodon kochii
Koch's cord moss - - 1B. 3 Cismontane woodland (soil). 590 - 3280 feet
in elevation. No blooming period.
May occur. The nearest observations of E. kochii were
reported in 2002, approximately 12.5 miles south-southeast
of Ukiah, near Hopland. Cismontane woodland habitat
suitable for this species is present within the project area.
Erythronium revolutum
coast fawn lily - - 2B.2
Bogs and fens, Broad-leafed upland forest,
North Coast coniferous forest. Mesic,
Streambanks. 0-1600 meters in elevation.
Blooms March-July (August).
Not likely to occur. The nearest observation was reported
in 2020, approximately 15 miles east-northeast of Ukiah,
near Bailey Summit.
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Species
Listing
Status1
Federal
Listing
Status1
State
Listing
Status1
CRPR
Habitat Potential for Occurrence
Fissidens pauperculus
minute pocket moss - - 1B.2
North Coast coniferous forest (damp coastal
soil). 10-1024 meters in elevation. No
blooming period.
Not likely to occur. The nearest observation was reported
in 2002, approximately 12 miles northwest of Ukiah,
within the Montgomery Woods State Natural Reserve.
Damp coastal soil is not present within the project area.
*Fritillaria roderickii
Roderick's fritillary - Endangered 1B. 1
Coastal bluff scrub, coastal prairie, valley, and
foothill grassland. 50 - 1310 feet in elevation.
Blooms March-May.
May occur. The nearest documented observation of F.
roderickii was reported approximately 10 miles from
Ukiah, near Montgomery Woods State Natural Reserve.
Valley and foothill grassland habitat, potentially suitable
for this species, are present within the project area.
Gratiola heterosepala
Boggs Lake hedge-hyssop - Endangered 1B. 2
Marshes and swamps (lake margins) vernal
pools. Clay. 35 - 7790 feet in elevation.
Blooms April-August.
No potential to occur. Marsh, swamp, and vernal pool
habitats are not present within the project area.
*Grimmia torenii
Toren's grimmia - - 1B. 3
Chaparral, cismontane woodland, lower
montane coniferous forest. Boulder and rock
walls. Carbonate, openings, rocky, volcanic.
1065 - 3805 feet in elevation. No blooming
period.
May occur. The nearest observation of G. torenii was
reported within the Elledge Peak quad (specific location
unknown) in 2019. Chaparral, cismontane woodland, and
lower montane coniferous forest habitats suitable for this
species are present within the project area, however
volcanic substrates are not present.
*Hesperolinon adenophyllum
glandular western flax - - 1B. 2
Chaparral, cismontane woodland, valley, and
foothill grassland. Serpentinite (usually). 490
- 4315 feet in elevation. Blooms May-August.
May occur. The nearest and most recent observation of H.
adenophyllum was reported approximately 20 miles
southeast of Ukiah, near Highland Springs Rd. Chaparral,
cismontane woodland, and valley and foothill grassland
habitats, suitable for this species, are present within the
project area. Serpentine substrates are likely present as
species with strong ultramafic affinities have been
observed within the project area.
Horkelia bolanderi
Bolander's horkelia - - 1B. 2
Chaparral, lower montane coniferous forest,
meadows and seeps, valley, and foothill
grassland. Edges and vernally mesic areas.
1475 - 3610 feet in elevation. Blooms (May)
June-August.
May occur. The nearest observations of H. bolanderi were
reported off Mill Creek Rd., approximately 12 miles from
Ukiah. Chaparral, lower montane coniferous forest, valley,
and foothill grassland habitats, suitable for this species, are
present within the project area.
*Kopsiopsis hookeri
small groundcone - - 2B. 3
North coast coniferous forest. Open woodland,
mixed conifer forest, generally on Gaultheria
shallon, occasionally on Arbutus menziesii
and Arctostaphylos uva-ursi. 295 - 2905 feet
in elevation. Blooms April-August.
May occur. The nearest observations of K. hookeri were
reported at the Hopland Research Station in 1976. Open
woodland and mixed conifer forest habitat, suitable for this
species, are present within the project area. Arbutus
menziesii, a potential host plant, also occurs within the
project area.
Lasthenia burkei
Burke's goldfields Endangered Endangered 1B. 1 Meadows and seeps (mesic) vernal pools. 50
- 1970 feet in elevation. Blooms April-June.
Not likely to occur. The nearest observation of L. burkei
was reported in 2010 near Lake Mendocino, within the
U.S. Army Corps of Engineers area, approximately 4 miles
from the project area. Meadows, seeps, and vernal pool
habitats are not present within the project area.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Listing
Status1
CRPR
Habitat Potential for Occurrence
*Layia septentrionalis
Colusa layia - - 1B. 2
Chaparral, cismontane woodland, valley, and
foothill grassland. Sandy, serpentinite. 330 -
3595 feet in elevation. Blooms April-May.
May occur. The nearest observations of L. septentrionalis
were reported approximately 12 miles southeast of Ukiah,
near the Hopland Research station. Chaparral, cismontane
woodland, valley and foothill grassland, and sandy soils,
suitable for this species, are present within the project area.
Serpentine substrates are likely present as species with
strong ultramafic affinities have been observed within the
project area.
Limnanthes bakeri
Baker's meadowfoam - Rare 1B. 1
Marshes and swamps (freshwater) meadows
and seeps, valley, and foothill grassland
(vernally mesic) vernal pools. 575 - 2985 feet
in elevation. Blooms April-May.
Not likely to occur. The nearest observation of L. bakeri
was reported approximately 3 miles northeast of the project
area, near Lake Mendocino. Although, valley and foothill
grassland habitats, suitable for this species, are present
within the project area; marsh, swamp, meadow, vernal
pool, and seep habitats are not present.
Malacothamnus mendocinensis
Mendocino bush-mallow - - 1A Chaparral. Roadsides, rocky. 1395 - 1885 feet
in elevation. Blooms May-June.
Not likely to occur. The nearest observation of M.
mendocinensis was reported approximately 6 miles
northeast of the project area, near Lake Mendocino.
Chaparral and roadside habitats, as well as rocky
substrates, suitable for this species, are present within the
project area. However, this species was thought to be
extinct until this population was observed in 2022.
*Navarretia leucocephala subsp.
bakeri
Baker's navarretia
- - 1B. 1
Cismontane woodland, lower montane
coniferous forest, meadows and seeps, valley,
and foothill grassland, vernal pools. Mesic. 15
- 5710 feet in elevation. Blooms April-July.
Likely to occur. The nearest observation of N.
leucocephala subsp. bakeri was reported in 2010
approximately 3 miles northeast of Ukiah, near Lake
Mendocino. Cismontane woodland, lower montane
coniferous forest, as well as valley and foothill grassland
habitats, suitable for this species, are present within the
project area. Vernal pool habitat is not.
Northern Interior Cypress Forest - - - Closed-cone coniferous forest.
No potential to occur. The nearest observation of Northern
Interior Cypress Forest was reported approximately 8 miles
southeast of Ukiah, around Red Mountain Quarry Road.
Piperia candida
white-flowered rein orchid - - 1B. 2
Broad-leafed upland forest, lower montane
coniferous forest, north coast coniferous
forest. Serpentinite (sometimes). 100 - 4300
feet in elevation. Blooms (March-April) May-
September.
Likely to occur. The nearest observations of P. candida
were reported approximately 8 miles west of Ukiah, close
to the project area. Broad-leafed upland forest, lower
montane coniferous forest and north coast coniferous forest
habitats, suitable for this species, are present within the
project area. Serpentine substrates are likely present as
species with strong ultramafic affinities have been
observed within the project area.
Plagiobothrys lithocaryus
Mayacamas popcornflower - - 1A
Chaparral, cismontane woodland, valley, and
foothill grassland. Mesic. 985 - 1475 feet in
elevation. Blooms April-May.
Not likely to occur. The nearest observation of P.
lithocaryus was reported approximately 12 miles northeast
of Ukiah, near Potter Valley, however, these observations
are considered historic (1899).
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Listing
Status1
CRPR
Habitat Potential for Occurrence
*Pleuropogon hooverianus
North Coast semaphore grass - Threatened 1B. 1
Broad-leafed upland forest, meadows and
seeps, North Coast coniferous forest. Mesic,
openings. 35 - 2200 feet in elevation. Blooms
April-June.
May occur. The nearest observations of P. hooverianus
were reported approximately 5 miles east-northeast of
Ukiah. Broad-leafed upland forest, meadows and seeps,
and north coast coniferous forest habitats, suitable for this
species, are present within the project area.
Ramalina thrausta
angel's hair lichen - - 2B. 1
North Coast coniferous forest. On dead twigs
and other lichens. 245 - 1410 feet in elevation.
No blooming period.
May occur. The nearest observations of R. thrausta (2021)
were reported approximately 10.5 miles northwest of
Ukiah, near the Montgomery Woods State Natural
Reserve. North coast coniferous forest habitat, suitable for
this species, is present within the project area.
Calamagrostis ophitidis
serpentine bunchgrass - - - Valley and foothill grassland.
Likely to occur. The nearest observation of Serpentine
Bunchgrass grassland was reported approximately 8 miles
southeast of Ukiah, around Lost Valley. Valley and foothill
grassland habitat, suitable for this species, are present
within the project area. Serpentine substrates are likely
present as species with strong ultramafic affinities have
been observed within the project area.
Silene bolanderi
Bolander's catchfly - - 1B. 2
Chaparral (edges), cismontane woodland,
lower montane coniferous forest, meadows
and seeps, north coast coniferous forest.
Usually grassy openings, sometimes dry rocky
slopes, canyons, or roadsides. Openings
(usually) roadsides (sometimes) rocky
(sometimes) serpentinite (sometimes). 1380 -
3775 feet in elevation. Blooms May-June.
May occur. The nearest observations of S. bolanderi
would be considered historical. The nearest and most
recent observation occurred 61 miles northwest of Ukiah,
near Island Mountain, in 2022. Chaparral, cismontane
woodland, lower montane coniferous forest, and north
coast coniferous forest habitats, as well as dry rocky slopes
and roadsides, suitable for this species, are present within
the project area. Canyon habitat is not. Serpentine
substrates are likely to present as species with strong
ultramafic affinities have been observed within the project
area.
*Streptanthus glandulosus subsp.
hoffmanii
Hoffman's bristly jewelflower
- - 1B. 3
Chaparral, cismontane woodland, valley, and
foothill grassland (often serpentinite). Rocky.
395 - 1560 feet in elevation. Blooms March-
July.
May occur. The nearest and most recent observation of S.
glandulosus subsp. hoffmanii was reported approximately
13 miles south-southeast of Ukiah, near Hopland.
Chaparral, cismontane woodland, and valley and foothill
grassland habitats, as well as rocky substrates, suitable for
this species, are present within the project area. Serpentine
substrates are likely present as species with strong
ultramafic affinities have been observed within the project
area.
*Tracyina rostrata
beaked tracyina - - 1B. 2
Chaparral, cismontane woodland, valley, and
foothill grassland. 295 - 4165 feet in
elevation. Blooms May-June.
May occur. The nearest observations of T. rostrata were
reported approximately 9 miles northeast of Ukiah, near
Black Bart Trail, as well as southeast of Ukiah, off Trail 4
near the South Cow Mountain OHV staging area.
Chaparral, cismontane woodland, as well as valley and
foothill grassland habitats, suitable for this species, are
present within the project area.
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Species
Listing
Status1
Federal
Listing
Status1
State
Listing
Status1
CRPR
Habitat Potential for Occurrence
*Trifolium buckwestiorum
Santa Cruz clover - - 1B. 1
Broad-leafed upland forest, cismontane
woodland, coastal prairie. Margins. Gravelly.
115 - 2000 feet in elevation. Blooms April-
October.
May occur. The nearest observation of T. buckwestiorum
was reported approximately 10 miles northwest of Ukiah,
on Reeves Canyon Road, in 2015. Broad-leafed upland
forest and cismontane woodland habitats, as well as
gravelly substrates habitats, suitable for this species, are
present within the project area.
Viburnum ellipticum
oval-leaved viburnum - - 2B. 3
Chaparral, cismontane woodland, lower
montane coniferous forest. 705 - 4595 feet in
elevation. Blooms May-June.
Not likely to occur. The nearest and most recent
observation of V. ellipticum (2021), was reported
approximately 75 miles southeast of Ukiah, near Burdell.
Closer observations range from 20-124 years ago.
Chaparral, cismontane woodland, and lower montane
coniferous forest habitats, suitable for this species, are
present within the project area.
* Special-status plant species that are herbaceous annual s, geophytes, moss, or lichen, and may occur within the project impact zone
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Other
Listing
Status1
Habitat Potential for Occurrence
Special-Status Wildlife
Northern goshawk
Accipiter gentilis – –
G5, S3 |
BLM | CDF
| CSSC |
ILC | USFS
Within, and in vicinity of, coniferous and
deciduous forests. Uses old nests and
maintains alternate sites. Usually nests on
north slopes, near water. Red fir, lodgepole
pine, Jeffrey pine, and aspens are typical nest
trees.
Not likely to occur. Year-round resident on heavily forested
areas in the northern 1/3 of the state. Project site is not
heavily forested with preferred tree species.
northwestern pond turtle
Actinemys marmorata PT –
G3G4, S3 |
BLM |
CSSC | IVU
| USFS
Ponds, marshes, rivers, streams, and irrigation
ditches, usually with aquatic vegetation, below
6000 ft elevation. Needs basking sites and
suitable (sandy banks or grassy open fields)
upland habitat up to 0.3 miles from water for
egg-laying.
May occur in lower elevation ponds within the project area.
Found in northern CA to British Columbia (west of
Cascades/ Sierra crest).
Tricolored blackbird
Agelaius tricolor – Threatened
G1G2,
S1S2 | BLM
| CSSC |
IUCN |
NRWL |
UBCC
Highly colonial species, most numerous in
Central Valley and vicinity. Largely endemic
to California. Requires open water, protected
nesting substrate, and foraging area with insect
prey within a few miles of the colony.
Not likely to occur. Mainly endemic to California, where
over 95% of the population breeds in the Central Valley in
freshwater marshes and wetlands. Typically require large
freshwater wetlands or extensive agricultural fields with
nearby foraging areas. Habitat in the project area provides
limited suitability for foraging and nesting.
Grasshopper sparrow
Ammodramus savannarum – – G5, S3 |
CSSC | ILC
Dense grasslands on rolling hills, lowland
plains, in valleys and on hillsides on lower
mountain slopes. Favors native grasslands
with a mix of grasses, forbs, and scattered
shrubs. Loosely colonial when nesting.
May occur in the project area as this species is a summer
resident from Mendocino, Trinity, and Tehama counties
south, west of the Cascade–Sierra Nevada axis and south-
eastern deserts, to San Diego County. Limited grasslands in
project area limits regular occurrence for nesting.
Pallid bat
Antrozous pallidus – –
G4, S3 |
BLM |
CSSC | ILC
| USFS
Deserts, grasslands, shrublands, woodlands
and forests. Most common in open, dry
habitats with rocky areas for roosting. Roosts
must protect bats from high temperatures.
Roost in caves, mines, buildings, crevices, and
basal hollows (large conifer snags and bole
cavities in oaks). Very sensitive to disturbance
of roosting sites.
May occur. Statewide range that was once common now
uncommon. Rock outcrops in the vicinity of the project may
provide habitat for roosting.
Sonoma tree vole
Arborimus pomo – – G3, S3 |
CSSC | INT
Inhabits coniferous forest dominated by
Douglas-fir. Have also been observed in
redwood, and montane hardwood-conifer
forests. Nests are typically built in larger-sized
trees found on the landscape and are usually
constructed out of clipped Douglas fir
branches and lined with resin ducts from
consumed needles. Feeds almost exclusively
on Douglas-fir needles. Will occasionally take
needles of grand fir, hemlock, Bishop pine or
spruce.
Not likely to occur as the project site is not a Douglas-fir
dominated forest nor is site fog influenced. Distributed
along coast from Sonoma Co. to Oregon border; restricted
to fog belt.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Other
Listing
Status1
Habitat Potential for Occurrence
Sacramento perch
Archoplites interruptus – –
G1, S1 |
ATH |
CSSC |
IUCN
Historically found in the sloughs, slow-
moving rivers, and lakes of the Central Valley.
Prefers warm water. Aquatic vegetation is
essential for young. Tolerates wide range of
physio-chemical water conditions.
Not likely to occur in the Russian River watershed. Creeks
within the project area are out of known range and are
unsuitable habitat. Known in the Sacramento and San
Joaquin watersheds.
Great blue heron
Ardea herodias – – G5, S4 |
CDF | ILC
Colonial nesters in tall trees, cliffsides, and
sequestered spots on marshes. Rookery sites
near foraging areas: marshes, lake margins,
tide-flats, rivers and streams, wet meadows.
Individuals May occur in drainages within the project area,
but nesting colony unlikely to occur. Statewide range.
Obscure bumble bee
Bombus caliginosus – – G2G3,
S1S2 | IVU
Coastal areas. Food plant genera include
Baccharis, Cirsium, Lupinus, Lotus, Grindelia
and Phacelia.
Not likely to occur as the project is outside of the coastal
influence. Known from coastal zones in Santa Barbara Co.
north to Washington state, with scattered records from the
east side of CA's Central Valley.
Western bumble bee
Bombus occidentalis – Candidate
Endangered
G2G3, S1 |
IVU | USFS
Found in a range of habitats, including mixed
woodlands, farmlands, urban areas, montane
meadows and into the western edge of the
prairie grasslands. Historically found in much
of California is now thought to be limited to
mostly high elevation meadows and coastal
areas. Preferred habitat are those areas of
grassland, open meadows, and other wet areas,
that provide abundant foraging of flowering
resources, shelter for nesting and
overwintering, and connectivity of resources.
Once common and widespread, this species
has declined precipitously, perhaps from
disease.
May occur as species is known to inhabit areas from Central
CA to southern B.C. Suitable habitat exists on site to support
this species.
Townsend's big-eared bat
Corynorhinus townsendii – –
G4, S2 |
BLM |
CSSC | ILC
| USFS
Found in a wide variety of habitats. Most
common in mesic sites. Highly correlated with
caves, abandoned mines, undisturbed spaces
in buildings and more rarely basal hollows of
large trees. Roosts in the open, hanging from
walls and ceilings. Roosting sites limiting.
Extremely sensitive to human disturbance.
May occur as individual roosting in larger patches of
forested areas within the project area. Can also be found in
caves, mines, tunnels, and sometimes abandoned structures.
Project unlikely to support maternity roosts as large trees
with cavities were not found to be present. Found statewide,
once considered common now uncommon.
California giant salamander
Dicamptodon ensatus – –
G2G3,
S2S3 |
CSSC | INT
Humid coastal forests and live in or near
streams. Terrestrial adults found under surface
litter and in underground tunnels. Aquatic
larvae and adults are found in cold, clear, slow
flowing streams, occasionally in lakes and
ponds. Adults known from wet forests under
rocks and logs near streams and lakes.
May occur in drainages and ponds within the project area.
Known from wet coastal forests near streams and seeps from
Mendocino County south to Monterey County, and east to
Napa County.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Other
Listing
Status1
Habitat Potential for Occurrence
American peregrine falcon
Falco peregrinus anatum Delisted Delisted
G4T4, S3S4
| CDF | CFP
| FD | CD
Near wetlands, lakes, rivers, or other water; on
cliffs, banks, dunes, mounds; also, human-
made structures. Nest consists of a scrape or a
depression or ledge in an open site. Uses
bodies of water in open areas with cliffs and
canyons nearby for cover and nesting. Prey
mostly on birds (in flight). Man-made
structures used; abandoned raptor nests and
tree cavities occasionally used.
May occur as species is found statewide. Species within the
project area are likely foraging only as suitable nest
structures were not found within the project.
Western ridged mussel
Gonidea angulata – – G3, S1S2 |
IVU
Primarily creeks and rivers and less often
lakes.
Not likely to occur due to state extirpation. Originally in
most of state, now extirpated from Central and Southern
California.
Bald eagle
Haliaeetus leucocephalus Delisted Endangered
G5, S3 |
BLM | CDF
| CFP | ILC |
USFS | FD |
CE
Ocean shore, lake margins, and rivers for both
nesting and wintering. Most nests are within a
mile of water. Nests in large, old-growth, or
dominant live tree with open branches,
especially ponderosa pine. Roosts
communally in winter.
Not likely to occur despite being found statewide. Project
area does not support large live trees for nesting.
Pomo bronze shoulderband
Helminthoglypta arrosa pomoensis – – G2G3T1,
S1 | IDD
Found near the coast in heavily timbered
redwood canyons of Mendocino County.
Found under redwoods.
Not likely to occur as the project area does not support
heavily timbered redwood canyons.
Clear Lake tule perch
Hysterocarpus traskii lagunae – – G5T3, S3 |
CSSC
Aquatic. Breeds late winter.
No potential to occur as species is only found in Clear
Lake.
Hoary bat
Lasiurus cinereus – – G3G4, S4 |
ILC
Prefers open habitats or habitat mosaics, with
access to trees for cover and open areas or
habitat edges for feeding. Roosts in dense
foliage of medium to large trees. Feeds
primarily on moths. Requires water.
May occur throughout the project area as both roosting
individuals and foraging individuals.
Clear Lake hitch
Lavinia exilicauda chi – Threatened
G4T1, S1 |
AVU |
USFS
Spawns in streams flowing into Clear Lake.
Adults found in the limnetic zone. Juveniles
found in the nearshore shallow-water habitat
hiding in the vegetation.
No potential to occur. Found only in Clear Lake and
tributaries of Lake County.
Double-crested cormorant
Nannopterum auritum – – G5, S4 |
CWL | ILC
Colonial nesters on coastal cliffs, offshore
islands, and along lake margins in the interior
of the state. Nests along coast on sequestered
islets, usually on ground with sloping surface,
or in tall trees along lake margins.
No potential to occur within the project area despite being
found statewide as the water sources on the project area are
too small to support this species.
Coho salmon - central California
coast ESU
Oncorhynchus kisutch pop. 4
Endangered Endangered
G5T2Q, S2
| AED | FE |
CE
Requires beds of loose, silt-free, coarse gravel
for spawning. Also need cover, cool water,
and sufficient dissolved oxygen.
Not likely to occur as the federally listed populations occur
between Punta Gorda and San Lorenzo River. State listed
populations occur south of Punta Gorda.
Steelhead - northern California DPS
Oncorhynchus mykiss irideus pop. 16 Threatened –
G5T2T3Q,
S1 | ATH |
FT
Deep low-velocity pools for winter habitat and
gravel substrates free of excessive silt for
spawning.
May occur as this DPS includes all naturally spawned
populations in coastal river basins from Redwood Creek in
Humboldt County to the Gualala River, CA. Project area
would only be suitable in winter when rains keep creeks
flowing.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
43
Species
Listing
Status1
Federal
Listing
Status1
State
Other
Listing
Status1
Habitat Potential for Occurrence
Oncorhynchus mykiss irideus pop. 48 Threatened Endangered
Summer run steelhead that require deep low-
velocity pools for winter habitat and gravel
substrates free of excessive silt for spawning.
No potential to occur as the range of this DPS includes
Redwood Creek, the Mad River, the Mattole River
(Humboldt and Mendocino Counties), and parts of the Eel
River watershed including the Middle Fork Eel River and
the Van Duzen River in Mendocino County.
Osprey
Pandion haliaetus – –
G5, S4 |
CDF | CWL
| ILC
Associated strictly with large, fish-bearing
waters, including rivers, lakes, bays, estuaries,
and surf zones, primarily in ponderosa pine
through mixed conifer habitats. Preys mostly
on fish. Large nests built in treetops within 15
miles of a good fish-producing body of water.
Not likely to occur despite being found statewide. Project
area does not support suitable habitat of large trees for
perching or nesting.
Fisher
Pekania pennanti – –
G5, S2S3 |
BLM |
CSSC | ILC
| USFS
Intermediate to large-tree stages of coniferous
forests and deciduous-riparian areas with high
percent canopy closure. Uses cavities, snags,
logs and rocky areas for cover and denning.
Needs large areas of mature, dense forest.
Not likely to occur as species is found in the coniferous
forests in the Northern Coastal Range, Klamath Mtns,
southern Cascades, and Sierra Nevada mtn. range. Suitable
habitat is not present on site.
Purple martin
Progne subis – – G5, S3 |
CSSC | ILC
Inhabits woodlands, low elevation coniferous
forest of Douglas-fir, ponderosa pine, and
Monterey pine. Nests in old woodpecker
cavities mostly; also, in human-made
structures. Nest often located in tall, isolated
tree/snag.
May occur as species is documented inland and along
central & southern coast. Breeds locally in Modoc Plateau,
Cascade Range, & Sierra Nevada, and throughout most of
central coast region. Cavities in pockets of forest may be
suitable for nesting individuals.
Foothill yellow-legged frog - north
coast DPS
Rana boylii pop. 1
– –
G3TNRQ,
S4 | BLM |
CSSC |
USFS
Permanent partly shaded shallow streams and
riffles with a rocky substrate in a variety of
habitats. Needs at least some cobble-sized
substrate in slow moving waters near stream
edges for egg-laying and at least 15 weeks to
attain metamorphosis.
May occur as suitable habitat is present and project area is
within range of Northern Coast Ranges of the SF Bay
Estuary, Klamath Mtns, and Cascade Range.
Red-bellied newt
Taricha rivularis – – G2, S2 |
CSSC | ILC
Lives in terrestrial habitats, juveniles
generally underground, adults active at surface
in moist environments. Will migrate over a
mile to breed, typically in streams with
moderate flow and clean, rocky substrate.
May occur as habitat is present and project area is within
range of Humboldt Co. south to Sonoma Co., inland to Lake
Co. Isolated pop. of uncertain origin in Santa Clara Co.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
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Species
Listing
Status1
Federal
Listing
Status1
State
Other
Listing
Status1
Habitat Potential for Occurrence
Northern spotted owl
Strix occidentalis caurina Threatened Threatened
G3TNRQ,
S2S3 | BLM
| CSSC |
USFS
Habitat consists of primarily of old growth
forest. Generally, prefers older, complex
forests with a high canopy closure for nesting
and roosting. Structurally, high-quality habitat
includes a multilayered, multispecies canopy,
large conifer overstory trees, shade-tolerant
understory conifers or hardwoods, moderate to
high canopy closure, live coniferous trees with
deformities (e.g., cavities, broken tops,
mistletoe infections), large snags, and large
logs and other woody debris on the forest
floor.
Not likely to occur due to the lack of contiguous complex
conifer stands with complex characteristics preferred by
NSO in the project area and did not appear in CNDDB
search. Neither enough acreage of suitable nesting nor
foraging habitat is present. Portions of the project area are
adjacent to forest habitat that may provide some habitat.
There is one known spotted owl Activity Center (MEN629)
located two miles northwest of the project area. Low
intensity burns proposed by the project will not result in any
existing NSO habitat modification. In addition, treatment
activities will not impact the existing habitat function for
potential future use by the NSO, as proposed activities
would not result in the removal of trees or snags greater than
12 inches DBH and would retain canopy cover at 60% or
greater within the forest habitat.
American badger
Taxidea taxus – – G5, S3 -
CSSC | ILC
Most abundant in drier open stages of most
shrub, forest, and herbaceous habitats, with
friable soils. Needs sufficient food, friable
soils, and open, uncultivated ground. Preys on
burrowing rodents. Digs burrows.
May occur as species is known to be statewide except for
humid coastal forests of Del Norte Co. and portion of
Humboldt Co.
1. Legal Status Definitions:
California Rare Plant Ranks (CRPR):
1B Plant species considered rare or endangered in California and elsewhere (protected under CEQA, but not legally protected under ESA or CESA). 2B Plant species considered rare or
endangered in California but more common elsewhere (protected under CEQA, but not legally protected
under ESA or CESA).
CRPR Threat Ranks:
0.1 Seriously threatened in California (over 80% of occurrences threatened, high degree and immediacy of threat)
0.2 Moderately threatened in California (20-80% occurrences threatened, moderate degree and immediacy of threat)
0.3 Not very threatened in California (less than 20% of occurrences threatened / low degree and immediacy of threat or no current threats known)
State: FP Fully Protected (legally protected)
SSC Species of Special Concern (no formal protection other than CEQA consideration)
SE State Listed as Endangered (legally protected)
ST State Listed as Threatened (legally protected)
SD State Delisted
Federal: FE Federally Listed as Endangered (legally protected)
FT Federally Listed as Threatened (legally protected)
FD Federally Delisted
PT Federally Proposed as Threatened
CESA = California Endangered Species Act; CEQA = California Environmental Quality Act; CRPR = California Rare Plant Rank; DPS=distinct population segment; ESA = Endangered
Species Act; ESU=evolutionarily significant unit
Sources: CNDDB 2023; CNPS 2023; Edwards, pers. comm. 2021; USFWS 2023
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IMPACT BIO-1
Treatment activities including prescribed burning, manual treatments (i.e., handline construction), and mechanical treatments
(i.e., control line construction, pretreatment, or maintenance) could result in direct or indirect adverse effects on special -status
plant species either directly or through habitat modifications. In accordance with SPR BIO-1, a qualified botanist conducted a
comprehensive data review of biological resources specific to the project wherein thirteen special-status plant species ‘may
occur’, three species are ‘likely to occur’, one was found to be ‘present within the project area’, twelve not likely to occur, and
four with no potential to occur as described in Table 4.5-1: Potential for Special-Status Plant & Wildlife Species to Occur in
the Treatment Areas.
Pursuant to SPR BIO-7, special-status plant habitats where impacts cannot be avoided by a treatment must have protocol-level
surveys conducted prior to implementation of manual, mechanical, or prescribed burning treatment s. If special-status plant
species are observed during SPR BIO-7, Mitigation Measure BIO-1a for listed special-status plants under California
Endangered Species Act (CESA) and federal Endangered Species Act (ESA), and Mitigation Measure BIO -1b for other non-
listed special-status will be implemented SPR BIO-7 applies to all treatment activities.
Surveys would not be required for special-status plants not listed under the CESA or ESA if the target special-status plant
species is an herbaceous annual species, stump-sprouting species, or geophyte species, and the specific treatments may be
carried out during the dormant season for that species or when the species has completed its annual life cycle, provided the
treatment would not alter habitat in a way that would make it unsuitable for the special-status plants to reestablish following
treatment, or destroy seedbanks, stumps, or roots, rhizomes, bulbs and other underground parts of special -status plants. If it is
infeasible to conduct treatments during the dormant season, focused surveys will be conducted in those areas where ground-
disturbing activities (i.e., dozer line) may occur.
Seven of the thirteen special-status plant species that may occur within the project area are herbaceous annual species,
geophytes, mosses, or lichen (denoted with asterisks in Table 4.5-1). Impacts on these species would be avoided by
implementing non-ground-disturbing treatment activities (e.g., manual treatment activities) during the dormant season (i.e.,
when the plant has no aboveground parts), which would generally occur during the winter. Ground-disturbing treatment
activities (e.g., mechanical treatments, construction of control lines for broadcast burning) may result in impacts on these plant
species even when dormant and would not be conducted without prior implementation of SPR BIO-7. If non-ground-disturbing
treatments cannot be completed in the dormant season and would be implemented during the growing period of these annual
and geophyte species, protocol surveys (per SPR BIO-7) and avoidance of any identified plants (per BIO-1b) must be
implemented, as described below. The remaining three specia l-status plant species that have the potential to occur within the
project area are non-geophytic perennial species, which the qualified botanist has determined will benefit from project treatment
activities, hence, protocol-level surveys under SPR BIO-7 would not be necessary to identify them before implementing
treatment activities regardless of the timing of treatments.
Where special-status plants are identified during protocol-level surveys, MM BIO-1a or BIO-1b, depending on the species
status, a no-disturbance buffer of at least 50 feet will be established around the area occupied by the species within which
prescribed fire, and manual and mechanical treatment would not occur unless a qualified RPF or botanist determines, based on
substantial evidence, that the species would not be harmed or would benefit from treatment in the occupied habitat area. If
treatments are determined to be beneficial and would be implemented in areas occupied by special -status plants, under the
specific conditions described in MM BIO-1a for listed special-status and MM BIO-1b for non-listed special-status plants,
additional impact minimization and avoidance measures or design alternatives to reduce impacts may be identified. A qualified
RPF or botanist will evaluate the appropriate treatment design and frequency to maintain habitat function for the special -status
plants.
One special-status plant species – Raiche's manzanita – has been identified during the reconnaissance survey and is known to
occur within the project impact zone (see Figure 4.5-2). Habitat information for this species can be found in Table 4.5-1.
Impacts to this species’ habitat will be avoided through the implementation of MM BIO-1b. This information is to be used
during Biological Resource Training for Workers, per SPR BIO-2.
The potential for treatment activities to result in adverse effects on special -status plants was examined in the PEIR. This impact
on special-status plants is within the scope of the PEIR, because, within the boundary of the project area, habitat characteristics
are essentially the same within and outside the treatable landscape (e.g., no resource is affected on land outside the treata ble
landscape that would not also be similarly affected within the treatable landscape), and the treatment activities and intensity of
disturbance as a result of implementing treatment activities are consistent with those analyzed in the PEIR. The inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent
presented in the PEIR. However, within the boundary of the project area, the existing environmental conditions present in the
areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the p otential
impact on special-status plants is also the same, as described above. Biological resource SPRs that apply to project impacts
under Impact BIO-1 are SPRs BIO-1, SPR BIO-2, SPR BIO-6, SPR BIO-7, SPR BIO-9, SPR GEO-1, SPR GEO-3, SPR GEO-
4, SPR GEO-5, SPR GEO-7, SPR HYD-4, and SPR HYD-5. This determination is consistent with the PEIR and would not
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constitute a substantially more severe significant impact than what was covered in the PEIR.
IMPACT BIO-2
Treatment activities of prescribed burning, manual treatments (i.e., handline construction), and mechanical treatments (i.e.,
control line construction or maintenance) could result in direct or indirect adverse effects on special -status wildlife species
either directly or through habitat modifications. The proposed actions associated with this project are within the scope of
treatment activities analyzed in the PEIR. The SPRs and MMs are designed to identify habitat, consider critical life-history
periods for special-status species, and avoid significant adverse impacts to special-status wildlife species within treatment areas.
These SPRs and MMs will be followed during project planning activities and implementation and will result in less than
significant impacts.
Mitigation Measures BIO-2a and 2b will be employed to avoid mortality, injury, or disturbance to special status wildlife species
by:
• Avoiding treatment or disturbance activities within occupied habitats.
• Conducting treatment and/or disturbance activities outside the critical life history period (e.g., hibernation,
denning, rearing, breeding seasons, etc.).
• Designing treatments to maintain habitat function and essential structural elements (e.g., cavities, nests, dens,
resting structures, etc.) associated with a critical life-history periods (identified by a qualified RPF or other
qualified personnel).
• Establishing a no-operations disturbance buffer surrounding currently occupied sites. Buffer size determined by
established protocols and trustee agency guidance, or where relevant, by a qualified RPF or other qualified
personnel.
• If a northern spotted owl is detected at any point during the life of the project, a no-disturbance buffer of 0.25-
mile will be established around the detection and no treatment activities would be allowed within the buffer.
In accordance with SPR BIO-10, the qualified RPF determined that focused or protocol surveys for all special -status species
with potential to occur in the treatment area are not required, depending on the timing of the annual burn prescription . It is
anticipated that the treatment activities will not lead to loss of special -status wildlife that would substantially reduce the number
or restrict the range, or to degradation of occupied habitat. During pre -treatment walk-through of the annual burn area by the
RPF, within 14 days prior to any project preparation, any observations of special -status wildlife and nursery sites will be
recorded and considered for a no-disturbance buffer (50 to 150 feet based on the standard for that species).
California Giant Salamander and Red-Bellied Newt
California giant salamander and red-bellied newt have potential to occur in some of the treatment areas (Table 4.5-1; see Figure
4.5-4 Wetlands and Riparian Areas). Habitat potentially suitable for these species includes perennial and intermittent streams
and associated uplands, including forest habitat under leaf litter and logs. California giant salamanders are typically found
within approximately 165 feet of stream habitat. Red-bellied newts spend dry summer months in moist habitats (e.g., under
woody debris, rocks, animal burrows), which, based on dry conditions in the treatment areas observed during the September
14 and 15 reconnaissance surveys, would limit the species to areas relatively close to streams, ponds, and seeps (i.e.,
approximately 100 feet). WLPZs ranging from 50 to 150 feet adjacent to all Class I and Class II streams within the treatment
areas would be implemented per SPR HYD-4, also including its project-specific refinement to include the implementation of
no-disturbance buffers around all ponds (including ponds on adjacent private property where the buffer extends into a treatment
area). The potential for treatment activities and maintenance treatments to result in adverse effects on special -status amphibians
was examined in the PEIR.
Habitat function for California giant salamander and red-bellied newt would be maintained because treatment activities and
maintenance treatments would not occur within aquatic habitat, and treatments within WLPZs adjacent to treatment areas would
be limited pursuant to SPR HYD-4 (e.g., no mechanical treatment, retention of at least 75 percent surface cover, no treatment
within 50 to 150 feet of ponds). The potential for treatment activities to result in adverse effects on special -status amphibians
was examined in the PEIR. Pursuant to SPR HYD-4, a WLPZ width of 50 to 150 feet adjacent to all Class I and II streams and
lakes will be implemented for watercourse protection. Prior to treatment activities, a qualified RPF or biologist will survey the
treatment area to identify and map streams and wet areas.
Habitat function for the southern torrent salamander and the red-bellied newt would be maintained because pursuant to SPR
HYD-4, treatments within stream WLPZs in and adjacent to the treatment area would be limited. In addition, the largest downed
logs (up to three logs per acre) would be retained within the treatment areas. Ignitions will not occur in aquatic habitat and in
watercourses supporting these species. Watercourse protection measures shall be adhered to at all times . This impact of the
proposed project is consistent with the PEIR and would not constitute a substantially more severe significant impact than wha t
was included in the PEIR.
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Foothill Yellow-Legged Frog
Habitat potentially suitable for foothill yellow-legged frog includes perennial streams within treatment areas and associated
uplands. Foothill yellow-legged frog is known to occur within upland habitat up to approximately 200 feet away (CDFW
2018b), but typically no more than 40 feet away, from aquatic habitat (Bourque 2008). WLPZs ranging from 50 to 150 feet
adjacent to all Class I and Class II streams within the treatment areas would be implemented per SPR HYD-4, including its
project-specific refinement to include the implementation of no -disturbance buffers around all ponds (including ponds on
adjacent private property where the buffer extends into a treatment area). However, these measures may not result in fu ll
avoidance of foothill yellow-legged frogs if frogs are present further than 150 feet from stream habitat, or if manual activities
implemented within the WLPZ resulted in injury or mortality of this species. If a foothill yellow-legged frog is found during
treatments, it will receive a 50-ft buffer and be allowed to leave the project on its own.
Per SPR BIO-1, to fully avoid habitat potentially suitable for foothill yellow-legged frog, a 50 to 150-foot no-disturbance buffer
would be implemented prior to commencement of treatment activities by flagging along perennial streams (Class I and Class II)
adjacent to the treatment areas.
Habitat function for foothill yellow-legged frogs would be maintained because treatment activities and maintenance treatments
would not occur within aquatic habitat, and treatments within WLPZs adjacent to treatment areas would be limited pursuant to
SPR HYD-4 (e.g., no mechanical treatment, retention of at least 75 percent surface cover, no treatment within 50 to 150 feet
of ponds). The potential for treatment activities to result in adverse effects on special -status amphibians was examined in the
PEIR. Pursuant to SPR HYD-4, a WLPZ width of 50 to 150 feet adjacent to all Class I and II streams and lakes will be
implemented for watercourse protection. Prior to treatment activities, a qualified RPF or biologist will survey the treatment
area to identify and map streams and wet areas.
Habitat function for the foothill yellow-legged frogs would be maintained because pursuant to SPR HYD-4, treatments within
stream WLPZs in and adjacent to the treatment area would be limited. In addition, the largest downed logs (up to three logs per
acre) would be retained within the treatment areas. Ignitions will not occur in aquatic habitat and in watercourses supporting
these species. Watercourse protection measures shall be adhered to at all times.
Northwestern Pond Turtle
Aquatic habitat potentially suitable for the northwestern pond turtle is present within ponds and streams in and adjacent to the
treatment areas, and this species could use upland habitat within treatment areas in the vicinity of these features. WLPZs
ranging from 50 to 150 feet adjacent to all Class I and Class II streams within the treatment areas would be implemented per
SPR HYD-4, including its project-specific refinement to include the implementation of no- disturbance buffers around all
ponds (including ponds on adjacent private property where the buffer extends into a treatment area). However, these measures
may not avoid impacts on northwestern pond turtles, if turtles are present further than 150 feet from stream habitat or 50 to 150
feet from ponds, or if manual activities implemented within the WLPZ resulted in injury or mortality of this species.
Northwestern pond turtles may be present within upland habitat up to approximately 1,500 feet from water. Thus, existing
WLPZs and protective buffers would not fully prevent impacts on the species. SPR BIO-10 would apply, and focused visual
encounter surveys for northwestern pond turtle would be conducted within upland habitat areas suitable for the species prior to
ground-disturbing treatment activities (i.e., mechanical treatments) and prescribed burning. If northwestern pond turtles are
identified during focused surveys, Mitigation Measure BIO-2b for this species would be implemented.
Under MM BIO-2b, because the qualified RPF has determined that treatment activities would be beneficial to special-status
pond turtles, no compensatory mitigation will be required. The benefit of prescribed burning on the upland habitat of
northwestern pond turtle outweighs the cost of a severe, catastrophic wildfire that would destroy the woodland and grassland
habitat in the project area. Substantial evidence exists that habitat function of woodland is reasonably expected to improve with
implementation of the treatment. For grassland habitat, prescribed burns increase plant diversity and species richness,
particularly of native plants. The removal of the thatch layer increases light penetration, soil temperature, and nutrient
availability, supporting native endemic forbs which require light exposure to generate (DiTomaso and Johnson 2006).
The northwestern pond turtle would benefit from treatment in the occupied upland habitat area even though some of the species
may be killed, injured, or disturbed during treatment activities, and the proposed project approach would be an exception in
MM BIO-2b (CalVTP PEIR Sec. 3.6-149). The benefit of prescribed burning on the upland habitat of western pond turtle
outweighs the cost of a severe, catastrophic wildfire that would destroy the woodland and grassland habitat in the project area.
Habitat function for northwestern pond turtle would be maintained because treatment activities and maintenance treatments
would not occur within aquatic habitat, and pursuant to SPR HYD-4 no treatment would occur within 50 to 150 feet of ponds
and treatments within stream WLPZs adjacent to treatment areas would be limited (e.g., no mechanical treatment, retention of
at least 75 percent surface cover).
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Special-Status Birds
Five special-status bird species may occur within the treatment area: American peregrine falcon, grasshopper sparrow, purple
martin, and great blue heron (Table 4.5-1).
Treatment activities, including mechanical treatments, manual treatments, and prescribed burning conducted during the nesting
bird season (February 1–August 31) could result in direct loss of active nests if trees or shrubs containing nests are removed or
burned. For nests within vegetation that would not be removed, treatment activities including mechanical treatments, manual
treatments, prescribed burning, and herbicide application, could result in disturbance to active nests from auditory and visual
stimulus (e.g., heavy equipment, chain saws, vehicles, personnel) potentially resulting in abandonment and loss of eggs or
chicks.
Per SPR BIO-1, if it is determined that adverse effects on habitat suitable for nesting special-status birds can be clearly avoided
by physically avoiding habitat suitable the species or conducting treatments outside of the season of sensitivity (i.e., nest ing
bird season), then no mitigation would be required. Adverse effects on nesting special -status birds would be clearly avoided
for treatments that would occur outside of the nesting bird season (February 1–August 31).
If conducting some treatments outside of the nesting bird season is determined to be infeasible for certain treatments, then SPR
BIO-12 to survey for active bird nests would apply, and nesting bird surveys for the four species would be conducted prior to
implementation of treatment activities.
In the event that a northern spotted owl is detected, at any point during the life of the project, a no-disturbance buffer of 0.25-
mile will be established around the detection and no treatment activities would be allowed within the buffer. The buffer may
be revised in consultation with CDFW.
If no active bird nests are observed during nesting bird surveys per SPR BIO-10, then additional avoidance measures for these
species would not be required. If active special -status bird nests are observed (i.e., presence of eggs and/or chicks) or
determined to likely be present based on nesting bird behavior, then they shall be retained. The project proponent will
implement a feasible strategy to avoid disturbance of active nests (typically 100-500-ft buffer for raptors, as determined by
RPF or biologist based on site specific and species-specific factors, and 50ft for non-listed special status species) and no
treatment activities would occur within this buffer until the chicks have fledged as determined by a qualified biologist.
Habitat function for special-status birds would be maintained because treatment activities would not result in removal of trees
(i.e., conifers, hardwoods) or snags greater than 12 inches DBH, which would be the most likely features to be used by these
species due to the cover provided by larger trees and three to five snags would be retained per acre to provide wildlife habitat.
Additionally, treatments within riparian habitat (which provides nesting habitat for the special-status bird species that may
occur in the treatment areas) that is included within a WLPZ would be limited pursuant to SPR HYD-4 (e.g., no mechanical
treatment, retention of at least 75 percent surface cover). Pursuant to Mitigation Measure BIO -2a, this determination for
American peregrine falcon must be made by CAL FIRE in consultation with CDFW. Therefore, if Mitigation Measure BIO-
2a is required for treatment activities, CAL FIRE would contact CDFW to seek technical input on the determination that habitat
function would be maintained for American peregrine falcon. Those non-listed special-status wildlife would benefit from
treatment in the occupied habitat area even though some of the non -listed special-status wildlife may be killed, injured, or
disturbed during treatment activities, and the proposed project approach would be an exception in MM BIO-2b (CalVTP PEIR
Sec. 3.6-149). The benefit of prescribed burning on the habitat of these special-status birds outweighs the cost of a severe,
stand-altering wildfire that would kill the forest and woodland habitat in the project area.
Special-Status Fish
Only one special-status fish species may occur within the treatment area: steelhead – Central California coast DPS (Table 4.5-1,
refer to Figure 4.5-4).
Per SPR BIO-1, if it is determined that adverse effects on special-status fish can be clearly avoided by physically avoiding
habitat for these species, then mitigation would not be required. WLPZs ranging from 50 to 150 feet adjacent to all Class I a nd
Class II streams within the treatment areas would be implemented per SPR HYD-4. Adverse effects on special-status fish
would be clearly avoided through implementation of these SPRs and further mitigation would not be required.
Habitat function for special-status fish would be maintained because treatment activities and maintenance treatments would
not occur within aquatic habitat and treatments within WLPZs adjacent to treatment areas would be limited. Pursuant to SPR
HYD-4 (e.g., no mechanical treatment, retention of at least 75 percent surface cover) WLPZs ranging from 50 to 150 feet
adjacent to all Class I and II streams within the treatment areas will be implemented. At least 75 percent of surface cover will
be retained. Equipment limitation zones (ELZs) will be designated adjacent to Class III and IV watercourses with required
minimum widths per SPR HYD-4. A qualified RPF will describe the limitations of heavy equipment within the ELZ and will
include additional protection measures where appropriate. Any exposure of soil from burning or soil disturbed in a watercourse
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crossing of Class II, II, or III within a WLPZ shall be stabilized to the extent necessary to prevent the discharge of soil into
watercourses that would adversely affect steelhead.
American Badger
Potentially suitable habitat for American badger is present within grassland and open woodlands in the treatment areas.
Treatment activities, including mechanical treatments, could result in direct loss of active dens and potential loss of young.
Treatment activities including manual treatments, prescribed burning, and herbicide application treatments are not expected to
result in adverse effects on American badger dens due to badgers being primarily nocturnal and residing in dens during the day
when operations would be implemented. In addition, these treatments would typically occur within habitats where American
badger dens are unlikely to occur (e.g., forest habitat), and because personnel would conduct these activities on foot, and t he
likelihood of a den being inadvertently crushed or otherwi se destroyed would be very low.
If implementation of mechanical treatments in suitable habitat will occur during the American badger breeding season (between
March 1 and August 31), focused surveys per SPR BIO-10 will occur or presence will be assumed. If individuals or dens are
found within the treatment area or if presence is assumed, MM BIO-2b will be implementation to prevent adverse impacts. If
a den is discovered during this critical period, operations shall cease within 100 feet, and CDFW will be consulted for additional
avoidance measures, as appropriate.
Habitat function for American badger would be maintained because habitat suitable for the species (i.e., grasslands, open
woodlands) would be maintained and additional open woodland habitat would likely be restored through thinning and removal
of ladder fuels. The use of prescribed fire is not considered to have an adverse effect on badger populations, as it promotes the
healthy function and maintenance of oak woodland and grassland ecosystems. Additionally, potentially suitable habitat exists
throughout the project area and all habitat suitable for American badger will not be treated at once.
Western Bumble Bee
Suitable habitat for the western bumble bee is potentially present within grassland and open woodlands in the treatment areas.
Treatment activities, including mechanical treatments, prescribed burning, and herbicide treatments using UTVs could result
in direct loss of individuals and even colonies. Habitat requirements for the western bumble bee are meadows and grasslands
with abundant floral resources (Hatfield et. al. 2018). The project area contains habitat suitable for bumble bee nesting,
overwintering, and floral resources. Potential impacts associated with treatment activities could include temporary removal of
floral resources (especially invasive floral resources) or in trampling, crushing, or disturbing nesting or overwintering sites
(e.g., woody debris).
Because there is no seasonal timing that would prevent all potential impacts to Western bumble bee, SPR BIO-10 will be
implemented prior to mechanical treatments in suitable habitat or presence will be assumed. SPR BIO-10 would also be
required prior to prescribed burning or herbicide applications during the bumble bee flight season. If foraging individuals or
nests are observed, or presence is assumed, MM BIO-2g will be implemented. Per MM BIO-2g, prescribed burning within
occupied or suitable habitat for special-status bumble bees will occur from October through February to avoid the bumble bee
flight season, when feasible. Operationally this may not be feasible, as prescribed burning requires a narrow range of climatic
conditions to ensure control and to meet the project objectives. Additionally, treatment areas in occupied or suitable habitat
will be divided into a sufficient number of treatment units such that the entirety of the habitat is not treated within the s ame
year and treatments will be conducted in a patchy pattern to the extent feasible in occupied or suitable habitat, such that the
entirety of the habitat is not burned or removed and untreated portions of occupied or suitable habitat are retained (e.g., f ire
breaks will be aligned to allow for areas of unburned floral resources for special-status bumble bees within the treatment area).
Herbicides will not be applied to flowering native plants within occupied or suitable habitat to the extent feasible during t he
flight season (March through September). Lastly, if an active nest or overwintering queen is found, a 25-ft buffer will be utilized
to prevent impacts.
Prescribed burning is expected to have a positive effect on the richness and abundance of flowering plant species used by bee s
by increasing plant diversity, particularly of native plants. The removal of the thatch layer increases light penetration, so il
temperature, and nutrient availability, supporting native endemic forbs which require light exposure to generate (DiTomaso
and Johnson 2006). Greater floral diversity can benefit bee populations by providing a more balanced and continuous source
of nutrition. In addition, the overall long term habitat function for the western bumble bee would remain as prescribed burning,
and mechanical and manual treatment activities would retain large snags and logs, which would be the most likely nesting
features to be used by special-status bumble bees, as well as clearing away leaf litter and debris making it easier to excavate
and establish nests in the soil, and suitable habitat for the bumble bees in the project area would not be treated at once. Areas
of unburned habitat and floral resources will remain following prescribed burning as treatments are conducted in a mosaic
pattern designed to retain habitat and suitable floral resources proximate to the treatment area. If herbicide application is
necessary in suitable habitat to meet project objectives, application would be restricted to October through February to avoid
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bumble bee flight season and blooming resources.
Pursuant to MM BIO-2a, the final determination for habitat function maintenance will be made by the project proponent and
the project proponent may seek technical input from CDFW on their proposed measures to avoid injury to or mortality of these
species if found during pretreatment surveys or during operations. The PEIR concluded that impacts on special-status bumble
bees would be potentially significant and unavoidable because it addressed the entirety of the treatable landscape across the
state, so significant impacts cannot be ruled out. However, for this project, impacts would be less than significant and less
severe than asserted in the PEIR due to the implementation of focused surveys in suitable habitat, implementation of MM BIO-
2g, and the expected net increase in floral (foraging) resources following treatments.
Special-Status Bats
Habitat potentially suitable for three special-status bat species—pallid bat, Townsend’s big-eared bat, and hoary bat—is present
within forest habitat, rocky areas, and human-made structures (e.g., barns, bridges) in the treatment areas. Per SPR BIO-1, if it
is determined that adverse effects on special-status bats can be clearly avoided by conducting treatments outside of the season
of sensitivity (i.e., maternity season), then mitigation would not be required. Adverse effects on special-status bat maternity
roosts would be clearly avoided if treatment activities are implemented outside of the bat maternity season (April 1–August
31; California Department of Transportation 2004).
Treatment activities, including mechanical treatments, manual treatments, prescribed burning, and herbicide treatments using
UTVs, conducted within habitat suitable for bats during the bat maternity season (April 1–August 31) could disturb active bat
roosts from auditory and visual stimuli (e.g., heavy equipment, chain saws, vehicles, personnel) or smoke (e.g., prescribed
burning) potentially resulting in abandonment of the roost and loss of young. Some herbicide treatments would be limited to
ground-based methods, such as using a backpack sprayer or painting herbicide onto cut stems and would be conducted by crews
of one to five people; thus, these treatments would not be expected to result in substantial disturbance to special -status bat
roosts.
During nesting bird surveys, per SPR BIO-12, surveys for maternal nesting bat roosts will also be conducted. If an active roost
is observed, a no disturbance buffer of 100 feet would be established around the roost.
Substantial evidence exists that habitat function of forest and woodland is reasonably expected to improve with implementatio n
of the treatment. Historically, prior to fire suppression and logging, Douglas-fir-tanoak forests in the North Coast Range
experienced fire return intervals between 4 to 6 years, which likely promoted open forests with greater cover of understory
plant species. These non-listed special-status wildlife would benefit from treatment in the assumed occupied habitat area even
though some of the non-listed special-status wildlife may be killed, injured, or disturbed during treatment activities, and the
proposed project approach would utilize an exception described in MM BIO-2b (CalVTP PEIR Sec. 3.6-149). Furthermore,
the short-term potential impacts of low intensity prescribed burning on these special -status bats outweigh the cost of a severe,
stand-altering wildfire that would kill the forest and woodland habitat in the project area. Treatments will not result in impacts
to special status species based on implementation of applicable SPRs (BIO-1, BIO-12).
Habitat function for special-status bats would be maintained and, in some respects, improved. Treatment activities and
maintenance treatments would not result in removal of living trees (i.e., conifers, hardwoods) greater than 1 2 inches DBH
which would be the most likely features to be used by this species due to the cover provided by larger trees, and three to five
snags would be retained per acre to provide wildlife habitat. Fuels treatments would reduce understory density and increase
forest structural heterogeneity, which would improve foraging and movement conditions for bat species adapted to open and
edge habitats. In addition, implementation of the treatment would reduce the likelihood of high-severity wildfire, thereby
maintaining long-term availability of large trees and snags important for bat roosting habitat. Therefore, habitat function would be
retained or enhanced consistent with Mitigation Measure BIO-2b.
IMPACTS BIO-2 Conclusion
The potential for treatment activities to result in adverse effects on special -status wildlife was examined in the PEIR. This
proposed project’s impact on special-status wildlife is within the scope of the PEIR because the project consists of vegetation
treatment activities (e.g., prescribed fire, mechanical thinning, and/or manual treatments) that are analyzed in the VTP PEIR.
Treatment methods, equipment, treatment extents, and maintenance activities do not exceed the treatment descriptions,
intensity, or geographic scale evaluated in the PEIR for biological resources. The project incorporates all applicable VTP
biological SPRs and Mitigation Measures and habitat function for special-status wildlife species will be maintained through
avoidance, minimization, and habitat retention measures. Potential temporary disturbances to wildlife during treatment
activities are short-term and localized, as contemplated in the PEIR, and are mitigated through implementation of standard
VTP avoidance and timing measures. Accordingly, the project would not result in new or substantially more severe impacts to
special-status wildlife than those analyzed in the VTP PEIR.
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The project’s burn design practices will maintain or improve habitat function for special -status wildlife species, as treatment
units will occupy a small percentage of the landscape and are dispersed over a large area. Unburned refugia are maintained
close to treatment units, the burn prescription shall create a mosaic of burned and unburned habitat within treatment units, with
a small percentage of the treatment units burned annually, and key habitat structures and locations shall be retained and pro vided
mitigations where necessary.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landsc ape;
therefore, the potential impact on special-status wildlife is also the same, as described above. Biological resource SPRs that
apply to project impacts under Impact BIO-2 are SPR BIO-1 through SPR BIO-4, SPR BIO-8 through SPR BIO-11, SPR BIO-
12, SPR GEO-1, and SPR HYD-1, SPR HYD-3 through SPR HYD-5, and SPR HAZ-5 and SPR HAZ-6. This determination
is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in
the PEIR with the addition of MMs BIO 1a & 1b, BIO-2a through BIO-2h and MMs BIO-3a through BIO-3c.
IMPACT BIO-3
Initial vegetation treatments and subsequent maintenance treatments have the potential to result in direct or indirect advers e
effects on sensitive habitats, including designated sensitive natural communities. Maintenance treatments would involve the
same activities as initial treatments. While excessive retreatment could increase impacts, retreatment is required to control the
establishment and spread of non-native grasses, consistent with the Writ of Mandate issued by the Superior Court of San Diego
County on November 14, 2025 in California Chaparral Institute v. Board of Forestry and Fire Protection (Writ), and will be
implemented in compliance with applicable Standard Project Requirements and Mitigation Measures to minimize impacts on
sensitive vegetation. The potential for treatment activities adversely affect sensitive natural communities was evaluated in the
CalVTP PEIR.
Consistent with SPR BIO-3, CALVEG mapping and reconnaissance-level surveys conducted pursuant to SPR BIO-1 were
used to identify sensitive natural communities within the treatment areas. Sensitive natural communities documented or with
potential to occur in the treatment areas include chaparral (e.g., chamise and common manzanita), oak woodlands protected
under the Oak Woodlands Conservation Act (Public Resources Code Section 21083.4), including canyon live oak, interior live
oak, California black oak, and blue oak, redwood forests, and riparian habitats adjacent to streams. Grasslands mapped as
annual brome may contain localized occurrences of sensitive grassland or serpentine-associated communities; however, due to
the fine-scale heterogeneity and temporal variability of these habitats, they were not mapped as distinct vegetation type s.
Chaparral Habitat
Chaparral habitat (e.g., chamise chaparral and common manzanita chaparral) is present within the proposed treatment areas.
Pursuant to the 2025 writ, the PEIR may not be used for CEQA compliance for proposed vegetation treatments in chaparral
habitats unless the proposed treatments fall within specific, limited categories the Court determined to be severable from the
writ’s prohibitions. The proposed project qualifies under these severable categories, including Wildland-Urban Interface (WUI)
fuel reduction treatments and limited-width strategic fuel breaks, as defined by the writ.
The proposed project is a critical wildfire safety project designed to protect the community of Ukiah by reducing wildfire
hazards in the Wildland Urban Interface (WUI) and establishing and maintaining strategically located fuel breaks around the
community. Chaparral treatments within WUI areas will be designed to avoid type conversion and maintain chaparral habitat
structure and function to the extent feasible while achieving wildfire hazard reduction objectives. Fuel break treatments, are
intended to strategically modify vegetation to reduce fire behavior and improve firefighter and community protection and
therefore are not designed to retain chaparral habitat within the fuel break footprint. Fuel break widths will be limited to the
minimum necessary and will not exceed 300 feet in width, and long-term maintenance of flammable non-native vegetation will
be implemented to prevent unintended type conversion outside treated areas. Consistent with Public Resources Code section
4483 and SPR Bio-5, the treatments will not result in type conversion.
Oak Woodlands and Redwood Forests
CAL FIRE will, to the extent feasible, and consistent with project objectives, retain mature madrone, true oaks, redwood, big-
leaf maple, native shrubs (e.g., gooseberry and snowberry) and other desirable species (e.g., California rose, native wildflowers)
within the WUI and shaded fuel break treatment types. Various natural communities have evolved to depend on periodic fire,
and as such, the project’s burn design practices will not result in loss or degradation of these sensitive natural communities.
The low intensity burn prescription shall result in a partial removal of understory or groundcover vegetation and create a mosaic
of burned and unburned habitat within treatment units. The proposed project will also lower the risks to natural communities
associated with a larger, uncontrolled wildfire.
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Riparian Habitat
Riparian habitat is present adjacent to streams in treatment areas. Under SPR HYD -4, WLPZs ranging from 50 to 150 feet
would be established adjacent to all Class I and Class II streams for manual, mechanical, herbicide, and pile burning treatme nts,
which would limit the extent of treatment activities within riparian habitat. While this SPR would reduce potential impacts on
riparian habitat, the extent of riparian habitat within the treatment areas has not been mapped and riparian habitat may be
present outside of the areas incorporated within WLPZs. As a result, prior to the implementation of treatment activities, SPR
BIO-3 would need to be implemented to identify and map the extent of riparian habitat within the treatment areas. As required
under SPR BIO-4, treatments in riparian habitats would retain at least 75 percent of the overstory and 50 percent of the
understory canopy of native riparian vegetation and would largely be limited to removal of uncharacteristic fuel loads (e.g.,
dead or dying vegetation, invasive plants, encroaching uplands species). Additionally, prior to any treatments in riparian habitat
subject to California Fish and Game Code 1602, CAL FIRE would notify CDFW when required, as explained in SPR BIO-4.
Mitigation Measure BIO-3a
For sensitive natural communities and oak woodlands not subject to the 2025 writ limitations, a qualified RPF or biologist
would determine the natural fire regime, condition class, and fire return interval pursuant to Mitigation Measure BIO-3a. Initial
and maintenance treatment activities within these applicable sensitive natural communities and oak woodlands would be
designed to restore or maintain vegetation composition, structure, and ecological function consistent with their natural fire
regimes, where doing so does not conflict with project objectives. If, for applicable sensitive natural communities or oak
woodlands, habitat function would not be maintained through implementation of Mitigation Measure BIO-3a, then Mitigation
Measure BIO-3b would apply, and unavoidable losses of those resources would be compensated through restoration or
preservation of the affected vegetation types within or outside of th e treatment areas.
The potential for treatment activities to result in adverse effects on sensitive habitats, as described above, was examined i n the
PEIR. This impact on sensitive habitats is within the scope of the PEIR, because, within the boundary of the project area,
habitat characteristics are essentially the same within and outside the treatable landscape (e.g., no resource is affected on l and
outside the treatable landscape that would not also be similarly affected within the treatable landscape), and the treatment
activities and intensity of disturbance as a result of implementing treatment activities are consistent with those analyzed in the
PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a chang e
to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landsc ape;
therefore, the potential impact on sensitive habitats is also the same, as described above. Biological resource SPRs that appl y
to project impacts under Impact BIO-3 are SPR BIO-1 through SPR BIO-9, SPR GEO-1, SPR GEO-3, SPR GEO-4, SPR GEO-
5, SPR GEO-7, SPR HAZ-5, SPR HAZ-6, SPR HYD-4, and SPR HYD-5. This determination is consistent with the PEIR and
would not constitute a substantially more severe significant impact than what was covered in the PEIR. Potential adverse effects
on chaparral habitat from treatment activities are expected to be short-term, localized, and consistent with the Writ and CalVTP
PEIR analysis.
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Table 4.5-2 Sensitive Natural Communities Documented or with Potential to Occur in the Treatment Areas
Sensitive Natural Community1
Rarity
Rank2 CALVEG Type Occurrence
Potential Habitats Present
California Bay Forest S3 Coastal mixed hardwood,
California bay
Potential to
Occur
Inland ridges, steep north-facing slopes,
and rocky outcrops.
Tanoak Forest S3.2 Tanoak Known to
Occur
Terraces, slopes, and ridges of all
aspects. Deep and well-drained soils.
Oregon White Oak Forest S3 Coastal mixed hardwood,
Oregon white oak
Potential to
Occur
Terraces, slopes, and ridges of all
aspects.
Redwood Forest S3 Redwood-Douglas-fir,
Redwood
Known to
Occur
Ridges, as well as all slopes and
aspects.
Valley Oak Woodland S3 Valley Oak Potential to
Occur
Gentle to somewhat steep, lower to
upper slopes and ridgetops. Loam and
clay soils. Alluvial or residual soils.
Common Manzanita Chaparral S3 Manzanita chaparral Known to
Occur
Mid to upper slopes and ridges in
transitional settings between grassland
and oak woodland or coniferous forest
or associated with extensive old growth
chaparral. Sandy to clayey loam soils,
often derived from sandstone.
California brome - blue wildrye prairie S3 Perennial grasses and forbs Potential to
Occur
Terraces, steep mesic slopes, and forest
openings.
Onion - twistflower - dwarf-flax
serpentinite rock outcrop S2S3
Barren, Ultramafic mixed shrub,
Annual grasses and forbs,
Ultramafic mixed conifer
Potential to
Occur
Rocky serpentine slopes, ridges, and
outcrops. Soils poorly developed with
coarse sandy texture.
1 These are designated sensitive natural communities with a state rarity rank of S1 (critically imperiled), S2 (imperiled), or S3 (vulnerable).
2 Older ranks, which need to be updated, may still contain a decimal "threat" rank of .1, .2, or .3, where .1 indicates very threatened status, .2
indicates moderate threat, and .3 indicates few or no current known threats .
Source: A Manual of California Vegetation, Online Edition. Accessed in 2023.
IMPACT BIO-4
Initial vegetation treatments and maintenance treatments will not result in direct or indirect adverse effects on state or federally
protected wetlands as none have been identified in the project area.
Based on review and survey of project-specific biological resources (SPR BIO-1), some portions of the treatment areas contain
small segments of perennial, intermittent, and ephemeral streams that could be protected under federal and/or state government
jurisdiction. Under SPR HYD-4, WLPZs ranging from 50 to 150 feet would be established adjacent to all Class I and Class II
streams within the treatment areas, and WLPZs of sufficient size to avoid degradation of downstream beneficial uses of water
would be established adjacent to all Class III streams within the treatment areas for manual, mechanical, herbicide, and pile
burning treatments. Additionally, SPR HYD-4 will be refined to include the implementation of no-disturbance buffers of 50 to
150 feet around all ponds (including ponds on adjacent private property where the buffer extends into a treatment area). The
establishment of WLPZs and buffers would result in the avoidance of all stream and pond habitat for manual, mechanical,
herbicide, and pile-burning treatments.
Broadcast burning would be implemented in all treatment areas and may occur within areas that contain seasonal freshwater
emergent wetlands, springs, seeps, or stream habitats. Mitigation Measure BIO-4 would apply in treatment areas that contain
state or federally protected wetlands where broadcast burning would occur. Under Mitigation Measure BIO-4, the boundary of
jurisdictional features would be delineated, and broadcast burning may be implemented in wetland habitats if a qualified RPF
or biologist determines that the wetland habitat does not support special-status plants (i.e., through implementation of SPR
BIO-7) or wildlife species (i.e., through implementation of SPR BIO-10), that wetland habitat function would be maintained,
and that the broadcast burn is within the normal fire return interval for the wetland vegetation types present. Additionally, no
fire ignition (and associated use of accelerants) will occur within wetland habitat or within WLPZs surrounding wetland
habitats.
The potential for treatment activities to result in adverse effects on state or federally protected wetlands was examined in the
PEIR. This impact on wetlands is within the scope of the PEIR, because, within the boundary of the project area, habitat
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characteristics are essentially the same within and outside the treatable landscape (e.g., no resource is affected on land ou tside
the treatable landscape that would not also be similarly affected within the treatable landscape), and the treatment activiti es
and intensity of disturbance as a result of implementing treatment activities are consistent with those analyzed in the PEIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the potential impact on wetlands is also the same, as described above. Biological resource SPRs that apply to proj ect
impacts under Impact BIO-4 are SPR BIO-1, SPR BIO-2, SPR BIO-3, SPR BIO-4, SPR BIO-9, SPR GEO-1, SPR GEO-3, SPR
GEO-4, SPR GEO- 5, SPR GEO-7, SPR HAZ-5, SPR HAZ-6, SPR HYD-1, SPR HYD-4, and SPR HYD-5. This determination
is consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in
the PEIR.
IMPACT BIO-5
Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse effects on wildlife movement
corridors and nurseries because habitat suitable for wildlife is present in treatment areas. Potential impacts resulting from
maintenance activities would be like those resulting from initial vegetation treatments because the same treatment activities are
proposed. The potential for treatment activities to result in adverse effects on wildlife movement corridors and nurseries was
examined in the PEIR.
Portions of the treatment area may occur within landscape features that function as wildlife movement corridors, including
streams and associated riparian areas. However, the proposed WUI and fuel break fuel -hazard reduction treatments are designed
to reduce hazardous vegetation conditions while largely maintaining existing site conditions that facilitate wildlife movement.
Implementation of these treatment activities would not result in substantial changes to corridor continuity, topography, or
vegetation structure that would impede wildlife movement through the treatment areas.
WUI and fuel break treatments would focus on reducing surface, ladder, and aerial fuels through thinning of small -diameter
trees, removal of excessive standing dead vegetation, and reduction of dense understory vegetation where fuel loading
contributes to elevated wildfire risk near developed areas and along strategic fuel break locations. Treatments would be
selective and spatially limited, retaining larger trees and overall canopy connectivity to the extent feasible while achievin g fuel-
reduction and fire-behavior-modification objectives. Any incidental effects on native vegetation structure would be secondary
to the primary purpose of wildfire risk reduction, protection of communities, and maintenance of effective fuel break functio n.
These treatments would not be expected to reduce the ability of wildlife to move through treated areas and may reduce the ris k
of movement disruption by lowering the likelihood of high-severity wildfire that could otherwise result in large-scale habitat
loss or corridor fragmentation. Additionally, no known wildlife nursery sites or evidence of nursery use, such as deer fawning
habitat or potential rookery trees indicated by whitewash, were identified within treatment areas during implementation of SPR
BIO-1.
The potential for treatment activities to result in adverse effects on wildlife movement corridors and nurseries was examined
in the PEIR. This impact is within the scope of the PEIR, because, within the boundary of the project area, habitat characteristics
are essentially the same within and outside the treatable landscape (e.g., no resource is affected on land outside the treatable
landscape that would not also be similarly affected within the treatable landscape), and the treatment activities and extent of
expected disturbance as a result of implementing treatment activities are consistent with those analyzed in the PEIR. The
inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the potential impact on wildlife movement corridors is also the same, as described above. Habitat function within
treatment areas would be maintained because treatment activities, including maintenance treatments, would not result in
removal of living trees (i.e., conifers, hardwoods) greater than 12 inches DBH and 3–5 snags would be retained per acre to
provide wildlife habitat, which would promote connectivity. Additionally, WLPZs ranging from 50 to 150 feet would be
implemented adjacent to all Class I and Class II streams in treatment areas, which could function as wildlife movement
corridors, pursuant to SPR HYD-4. Biological resource SPRs that apply to project impacts under Impact BIO-5 are SPR BIO-
1, SPR BIO-4, SPR BIO-10, SPR BIO-11, and SPR HYD-1 and SPR HYD-4. Additionally, MM BIO-5 will mitigate any
potential impacts as well. This determination is consistent with the PEIR and would not constitute a substantially more severe
significant impact than what was covered in the PEIR.
IMPACT BIO-6
Initial vegetation treatments and maintenance treatments could result in direct or indirect adverse effects resulting in reduction
of habitat or abundance of common wildlife, including nesting birds, because habitat suitable for these species is present
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throughout treatment areas. Treatment activities, including mechanical treatments, manual treatments, prescribed burning, and
herbicide application, conducted during the nesting bird season (February 15– August 15) could result in direct loss of active
nests or disturbance to active nests from auditory and visual stimulus (e.g., heavy equipment, chain saws, vehicles, personne l)
potentially resulting in abandonment and loss of eggs or chicks. The potential for treat ment activities, including maintenance
treatments, to result in adverse effects on these resources was examined in the PEIR.
SPR BIO-12 would apply, and for treatments implemented during the nesting bird season, a survey for common nesting birds
will be conducted within the treatment area by a qualified RPF or biologist prior to treatment activities. If no active bird nests
are observed during focused surveys, then additional avoidance measures would not be required. If active nests of common
birds or raptors are observed during surveys, disturbance to the nests will be avoided by establishing an appropriate buffer
around the nests, modifying treatments to avoid disturbance to the nests, or deferring treatment until the nests are no longer
active as determined by a qualified RPF or biologist. Trees with visible raptor nests, whether occupied or not, will be retained
and a 100-500-ft avoidance buffer, as determined by RPF or biologist based on site specific and species-specific factors, shall
be implemented.
The qualified RPF determined that common nesting bird populations occupying project habitat will benefit from treatment in
those areas even if the common nesting birds may be killed, injured, or disturbed during treatment activities. The project’s burn
design practices will maintain or improve habitat function for common nesting birds and raptors, as treatment units will occupy
a small percentage of the landscape and are dispersed over a large area. Unburned refugia are maintained close to treatment
units, the burn prescription shall create a mosaic of burned and unburned habitat within treatment areas, and key habitat
structures and locations shall be retained and provided mitigations where necessary.
As included in the CalVTP PEIR Sec. 3.6-126, implementation of avoidance strategies for common nesting birds does not
preclude completing the prescribed burning treatment within the project -specific burn season (February through May), during
which vegetation moisture, weather, wind, and other physical conditions are suitable.
The potential for treatment activities to result in adverse effects on these resources was examined in the PEIR. The potentia l
for adverse effects on common wildlife, including nesting birds, is within the scope of the PEIR, because, within the boundar y
of the project area, habitat characteristics are essentially the same within and outside the treatable landscape (e.g., no resou rce
is affected on land outside the treatable landscape that would not also be similarly affected within the treatable landscape), and
the treatment activities and extent of expected disturbance as a result of implementing treatment activities are consistent with
those analyzed in the PEIR. Biological resource SPRs that apply to project impacts under Impact BIO-6 are SPR BIO-1 through
SPR BIO-4, and SPR BIO-12. This determination is consistent with the PEIR and would not constitute a substantially more
severe significant impact than what was covered in the PEIR.
IMPACT BIO-7
The potential for treatment activities to result in conflicts with local policies or ordinances was examined in the PEIR. The project
area is partially within the bounds of City of Ukiah and partially in unincorporated areas of Mendocino County. The land use
planning in unincorporated areas Mendocino County is governed by the Mendocino County General Plan (Mendocino County
2009). A number of General Plan goals and policies specifically address the need to protect and preserve riparian and instream
habitat values, to support fish populations, particularly native anadromous fish species such as Chinook salmon and steelhead.
These include:
• Policy RM-89: Conserve and enhance watercourses to protect habitat, fisheries, soil, and water quality.
• Policy RM-90: Conserve and enhance streamside (riparian) vegetation through development design and standards.
• Policy RM-91: Stream restoration and maintenance programs shall conserve riparian vegetation and the floodwater
carrying capacity of river and stream channels.
• Policy RM-92: Whenever possible, use riparian vegetation in conjunction with natural or appropriate structural
materials to achieve a natural appearance.
• Policy RM-93: Encourage public agencies and private property owners to protect fishery habitat and participate in
fishery enhancement projects (including removal of barriers to fish passage) for coastal and inland waterways of
Mendocino County.
Applicable local ordinances relevant to biological resources within the City of Ukiah are the Tree Management Guidelines, the
Municipal Code, and the Creek Maintenance Policies and Procedures. Section 6.9 of the Tree Management Guidelines, Hazardous
Tree Management, applies to the parts of the project area classified as urban forest within the City of Ukiah and requires crews who
remove or trim trees under emergency conditions to notify and provide an after-action review to the horticulturist or Director of
Community Services (City of Ukiah, 2023). The Municipal Code addresses Tree Preservation and Planting Requirements in Section
9229, stating however that the removal of protected trees is exempt from the provisions this section under emergency situations (i.e.,
substantial, imminent risk or hazard to the public), if documentation of the emergency situation be provided to the Planning Department as
soon as possible (Div. 9, Ch. 2; Article 18, 9229.1 – 9229.12). The project would fall under the purview of an emergency situation and this
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document will be provided to the Planning Department. Several of the policies listed in the Creek Maintenance Policies and
Procedures specifically address the need to protect and preserve riparian habitat. These include the following, which entail that
creek maintenance activities shall not:
• discharge pollutants or deposit new material into creeks.
• result in modifications to the natural flow of water or result in a reduction of the water-carrying capacity.
• result in increased flooding.
• adversely affect the riparian corridor, including riparian vegetation and wildlife.
The section encompassing vegetation management outlines procedures that ensure that storm water runoff is not obstructed,
and that flooding does not occur. It is unlikely that any creeks within the project area would be disturbed by treatment activities and
impacts would be less than significant. The submission of this document covers the Notification Requirements outlined in Appendix
D of the Creek Maintenance Policies and Procedures.
The potential for the proposed treatments to conflict with local policies is within the scope of the PEIR because vegetation
treatment locations, types, and activities are consistent with those analyzed in the PEIR. In addition, all projects implemen ted
under the CalVTP that are subject to local policies or ordinances would be required to comply with them, per SPR AD-3. This
impact of the proposed project is consistent with the PEIR and would not constitute a substantially more severe significant
impact than what was covered in the PEIR. This determination is consistent with the PEIR and would not constitute a
substantially more severe significant impact than what was covered in the PEIR.
IMPACT BIO-8
This impact does not apply to the proposed project because the treatment areas are not within the plan area of any adopted ha bitat conservation
plan or natural community conservation plan. Therefore, this impact does not apply to the proposed project. This determination is consistent
with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
NEW BIOLOGICAL RESOURCE IMPACTS
The proposed treatment is consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined that they are
consistent with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.5.1,
“Environmental Setting,” and Section 3.5.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to biological resources that are present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment
project are also consistent with those considered in the PEIR. No changed circumstances are present, and the inclusion of areas
outside of the CalVTP treatable landscape would not give rise to any new significant impacts not addressed in the PEIR.
Therefore, no new impact related to biological resources would occur that is not covered in the PEIR.
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4.6 GEOLOGY, SOILS, PALEONTOLOGY & MINERAL RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact GEO-1: Result in
Substantial Erosion or Loss of
Topsoil?
LTS
Impact GEO-1,
pp. 3.7-26 –
3.7-29
Yes
AQ-4
AQ-5
GEO-1
through
GEO-8
HYD-4
NA LTS No Yes
Impact GEO-2: Increase Risk of
Landslide? LTS
Impact GEO-
2, pp. 3.7-29 –
3.7-30
Yes
AQ-4
GEO-1
through
GEO-8
HYD-4
NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Geology, Soils, Paleontology, and Mineral Resource Impacts: Would the
treatment result in other impacts to geology, soils, paleontology, and mineral
resources that are not evaluated in the CalVTP PEIR?
Yes
No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.6.1 Geology, Soils, Paleontology & Mineral Resources Discussion
The project area (PIZ) is in the geomorphic province of the Northern Coastal Range and is underlain generally by Central and
Coastal Belt rocks known as the Franciscan Complex Mélange (65 -200 Ma; Sydnor 1991). These are typically marine
sedimentary rocks that have accreted to the North American Continent and have been uplifted and heavily deformed by both
accretion and the San Andreas Fault System. The primary rock types are graywacke sandstone, shale, chert, serpentine and
blueschist (see Appendix F). These rock types are generally resistant to weathering but are jointed and foliated, creating large
broken blocks (Sydnor 1991). Serpentine outcrops exist within the project area, particularly in the lower elevations north of
Gibson Creek, near Low Gap Park (Sydnor 1991; Rubin 2022). The main rock unit within the project is the Lookout Peak
graywacke formation, named by David M. Orchard in 1979 (Cretaceous-66-145 Ma). Mélange units border this unit to the
north and south. The Maacama Fault, a right -lateral strike slip fault, is the northernmost segment of the Hayward fault
subsystem to the San Andreas Fault (Larsen 2008) and runs through the Ukiah Valley to the east of the project area. The
Lookout Peak Fault is located off the backside (west side) of the main t rending ridge in the project area, which contains Spanish
Mountain and separates the Lookout Peak Formation with the Robinson Creek Mélange. The soils derived from this parent
material includes many well drained, sandy loam soils, but depth to bedrock is shallow in many areas. The Soil Survey of
Mendocino County, Eastern Part, and Trinity County, Southwestern Part (1991), specifies that prescribed burning in small to
moderately sized blocks improves wildlife habitat, improves wildlife access and water production, and reduces th e risk of
wildfire in these soil types. Large landslide features do exist within the project area, which can be identified in the lidar imagery
in Figure 4.6-1, and their boundaries are mapped in Figure 4.6-2, estimated from previous mapping in the area.
Serpentine outcrops are common in the greater Franciscan Complex, and in the area surrounding the PIZ, but are not as common
in the specific project area. There are two recently mapped, relatively small outcroppings of serpentine within the lower
elevations of the project area (Rubin 2022). The first and more substantial area is near Orrs Creek, north of Gibson Creek.
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Within this portion of the Project Implementation Zone (PIZ), a control line treatment area overlaps an existing linear featu re
that may traverse serpentine soils near a mapped outcrop. Serpentine soil areas within the existing fuel break, which may hav e
the potential to contain naturally occurring asbestos (NOA), would not be subject to additional ground disturbance beyond
existing conditions, to the extent feasible.
A second area within the PIZ is located along a ridge within the Spanish Creek Watershed, where Oak Knoll Road—also part
of a control line treatment area—crosses a serpentine outcrop. While soils mapped by the Soil Conservation Service do not
identify serpentine or NOA within the treatment areas, Mendocino County soil mapping indicates that portions of the ridge
may consist of serpentine soils. As a result, it is possible that serpentine soils, and associated NOA, may be present within
limited portions of the PIZ. Treatment activities in these areas would be limited to existing roads and control lines and would
avoid new ground disturbance where serpentine soils are present or suspected. Implementation would comply with applicable
CalVTP standard project requirements and best management practices designed to minimize soil disturbance and potential
exposure to NOA. The locations of the serpentine outcrops and associated control lines are shown on Figure 4.6 -2, and mapped
soil types are shown on Figure 4.6-3.
A notification letter was emailed to Kevin Doherty (Senior Engineering Geologist) of the California Geological Survey -Forest
and Watershed Geology Program on January 7, 2026, with project description, protection measures, and project maps. He was
invited to share information or any concerns regarding potential impacts from geological hazards. As of February 19,, 2026,
CGS recommends that if ground disturbing activities occur in areas identified as likely to contain naturally occur ring asbestos
(NOA) that CAL FIRE contact Mendocino County AQMD to develop an Asbestos Dust Control Plan consistent with the
requirements of SPR AQ-5.
Topography
The project area is located on a generally northeast facing slope, with multiple drainages that bisect the main ridge from east-
west, including Gibson Creek, Doolin Creek and Spanish Creek. The faces of the drainages have north and south aspects. There
is a trending ridgeline that is angled northwest, with sub ridges extending to the east. The highest elevation in the projec t area
is around 2,800 feet, and the lowest is around 600 feet near Robinson Creek near the south portion of the project area. Most of
the PIZ is steep- over 65%. Flatter areas within the project (>30%) are confined to the upper trending ridge and benches on the
mid and lower slopes caused by old landslide features. Most of the control lines and skid trails used for vegetation treatment
are located on ridges where the slopes are less than 50%. Some slopes within the treatment areas are over 50%.
Soil
Soils within the project area have been evaluated regarding soil type, erosion hazard, land suitability, permeability, and runoff
rate. Please see Figure 4.6-3. Soils located in this project area include the Bearwallow-Hellman-Witherell complex, 30 to 50
percent slopes; Cummiskey gravelly loam, 30 to 75 percent slopes; the Feliz loam, 0 to 2 percent slopes; the Hopland -Maymen-
Etsel complex, 50 to 75 percent slopes; Hopland-Wohly loams, 50 to 75 percent slopes and 30 to 50 percent slopes; Hopland-
Woodin complex, 30 to 50 percent slopes; Hopland loam, 50 to 75 percent slopes; Kekawaka -Casabonne-Wohly complex, 30
to 50 percent slopes; Maymen-Etsel-Snook complex, 30 to 75 percent slopes; Pardaloe-Kekawaka-Casabonne complex, 50 to
75 percent slopes; Pinole gravelly loam, 2 to 8 percent slopes; Redvine sandy clay loam, 15 to 30 percent slopes; Squawrock -
Witherell complex, 50 to 75 percent slopes; Witherell -Hopland-Squawrock complex, 50 to 75 percent slopes; the Yorktree-
Yorkville loams, 15 to 30 percent slopes; and the Yorkville-Yorktree-Squawrock complex, 30 to 50 percent slopes.
The ridges of the project area, where much of the treatment area s are located, generally contain the Hopland loam, Maymen-
Etsel-Snook complex, and the Hopland-Maymen-Etsel complex soils. Mendocino County maps these soils as serpentine soils,
but serpentine is not discussed in the soil descriptions. These soils are typically well drained but have slow permeability and
lower capacities for water. Therefore, they are subject to rilling and gullying as their erosion hazard ratings are high and the
runoff rates are rapid. Deep soil disturbance activities can cause land sliding and road failure (USDA 1991).
These soils have evolved with fire as a natural, periodic ecosystem component. Prescribed fire will have little effect on soi l
characteristics if burning is conducted within prescription. The use of a mosaic burn pattern, combined with unit size
limitations, will minimize the overall impact to soils. Ignition will not occur within riparian zones & will avoid unstable soils
and landslide prone areas. Treatment of fuels associated with these soil types will lower the probability of large wildfires
occurring under peak burning conditions.
Landslides
A review of the CGS Preliminary Geologic Map for the Elledge Peak Quadrangle (2022) and Ukiah Quadrangle (2020), lidar
imagery, and the Division of Mines and Geology, Open-File Report 91-16 and Landslide Hazard Identification Map No. 24
revealed multiple large unstable areas within the project area (Figure 4.6.2). These include mostly pre -historic or ancient
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features, particularly in Gibson Creek, Spanish Creek, and Robinson Creek Watersheds. Note that the CGS map used for
reference in this assessment is a preliminary map that should not be considered as an authoritative or comprehensive source for
landslide and seismic hazard data. However, the features used here largely overlap with past reports by Sydnor (1991) and
were considered to be helpful in addressing the impacts of this project.
Gibson Creek headwaters is located within the northern portion of the project area. There is a large ancient feature mapped
here (Sydnor 1991), in which an existing jeep trail traverses to the bottom where it connects to the road in Gibson Canyon. O n
the hillshade image, this feature is characterized by very smooth ground, with some depressions and hummocky nature, as well
as some older incised gullies along the margins.
Moving south, other smaller features have been mapped within the watercourse channels and hillsides of the drainages flowing
east towards Ukiah Valley. The southern part of the project area has one large ancient feature, recently remapped by Rubin
(2022) that flows northeast into Spanish Canyon, with the headscarp being the east -southeast side of Spanish Mountain. Oak
Knoll Road traverses through the body of the more northern portion of the feature and connects to the ridgeline. On the hillshade
image, the ground appears hummocky and disrupted, and has disorganized drainage patterns.
The third large feature is in the very southwest corner of the PIZ within the Robinson Creek Watershed and Robinson Creek
Mélange. There is an existing control line treatment area within this feature that traverses from Hwy 253 up the hill through
the feature. Landslide deposits are composed of rock fragments, finer sediment, soil, and biological matter and can have
flowing mixtures, dropped blocks, or rotated blocks.
IMPACT GEO-1
Mechanical disturbance activities in this project will include masticating target vegetation and chipping biomass from manual
and mechanical treatment activities. Equipment would include tracked equipment, such as tractors/skidders, chippers, and
masticators. Equipment would be operated on or within 100 feet of existing roads or skid trails in fuel break treatment areas
and on existing roads or skid trails or on flat to moderate slopes in WUI treatment areas. Where trails are located on slopes
over 50% within treatment areas, SPR GEO-7 prohibits heavy equipment use. Trails over 50% slope shall be avoided with
heavy equipment and would be limited to manual vegetation treatments. As stated in the CalVTP PEIR Section 2.5.2,
mechanical treatments may cut, uproot, crush/compact, or chop existing vegetation using masticators and other methods of
application. This project proposes to limit mastication to the cutting or chopping of above -ground vegetation with the intent of
keeping masticating heads out of duff laye rs and minimizing direct disturbance to subsurface soil layers, allowing intact root
systems to resprout. Understory debris would be masticated or chipped on-site within the treated areas or piled and subsequently
burned during wet periods of the year to dispose of accumulated biomass, pursuant to the standards defined in the PEIR
(CalVTP Final PEIR Volume II Section 2.5.2, 22-24).
Vegetation treatments would include manual and mechanical treatments, prescribed burning, and burn piles to remove biomass,
which could result in varying levels of soil disturbance, including the exposure to people of fugitive dust emissions contain ing
naturally occurring asbestos (discussed in Section 4.3), and have the potential to increase rates of erosion and loss of topsoil.
The potential for these treatment activities to cause substantial erosion or loss of topsoil was examined in the PEIR. Mechan ical
treatments using heavy machinery are the most likely to cause soil disturbance that could lead to substantial erosion or loss of
topsoil, especially in areas which have previously burned in wildfires, and in areas containing steep slopes. Equipment used to
create piles for burning may also increase the risk of soil disturbance. This impact is within the scope of the PEIR because the
use of and type of equipment, extent of vegetation removal, and intensity of prescribed burning are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape
constitutes a change to the geographic extent presented in the PEIR. However, the soil characteristics of the project area ar e
essentially the same within and outside the treatable landscape; therefore, the potential impact related to soil erosion is also the
same, as described above. SPRs applicable to this treatment project are GEO-1 through GEO-8, HYD-4, and AQ-4. This
determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than what
was covered in the PEIR.
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The soil types within the PIZ have a High erosion hazard rating (EHR). The table below shall be used to determine the
maximum distance between waterbreaks for all existing dozer lines, native soil road surfaces and skid trails. Any new trails
lines created with heavy equipment shall have erosion control structures installed as per this table. Where there are locations
that show evidence of past soil loss such as rilling or where potential serpentine soils occur, the Extreme EHR standard shal l
be applied.
IMPACT GEO-2
Treatment activities would include manual and mechanical vegetation removal, prescribed burning, as well as the creation of
burn piles, in varied topography, which could decrease the stability of slopes and increase the risk of landslides. There are three
larger “ancient” landslide features identified within the treatment areas (Sydnor 1991 and Rubin 2022). These are located on
slopes generally less than 50% and are not known to have existing active erosion issues and have existing stable infrastructure
located within their boundaries such as roads and developed pads. As per SPR GEO-8, an RPF or licensed Geologist shall
identify in the field any unstable areas located within treatment areas with over 50% slopes prior to project implementation.
Where identified features are unavoidable and will be potentially directly or indirectly affected by the treatment, a licensed
geologist (P.G. or C.E.G.) will determine the potential for landslide, erosion, of other issue re lated to unstable soils and identity
measures (e.g., those in SPR GEO-7) that will be implemented by the project proponent such that substantial erosion or loss of
topsoil would not occur. This SPR applies only to mechanical treatment activities and WUI fuel reduction, and non-shaded
fuel breaks treatment types, including treatment maintenance. There were no unstable areas identified from the lidar imagery
within treatment areas where slopes are greater than 50% but have not been ground-truthed and shall be reviewed by an RPF
or licensed geologist prior to project implementation. Given the variable topography, soil and rock types, active faulting, and
prior wildfires that are natural to the treatment areas, risk of landslide activity remains. The potential for treatment acti vities to
increase landslide risk was examined in the PEIR. This impact is within the scope of the PEIR because the extent of vegetation
removal, intensity of prescribed burning, and characteristics of the geographical terrain are consiste nt with those analyzed in
the PEIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, within the boundary of the project area, the range of slopes and landslide
conditions present in the areas outside the treatable landscape are essentially the same as those within the treatable landsc ape.
Therefore, the potential impact related to landslide risk is also the same, as describ ed above. SPRs applicable to the proposed
project are GEO-1 through GEO-8, and AQ-3. This determination is consistent with the PEIR and would not constitute a
substantially more severe significant impact than what was covered in the PEIR.
NEW GEOLOGY, SOILS, PALEONTOLOGY & MINERAL RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.7.1,
“Environmental Setting,” and Section 3.7.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to geology and soils that are present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment
project are also consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of areas
outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact relate d
to geology and soils would occur.
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4.7 GREENHOUSE GAS EMISSIONS (GHG)
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact GHG-1: Conflict with
Applicable Plan, Policy, or
Regulation of an Agency
Adopted for the Purpose of
Reducing the Emissions of
GHGs?
LTS
Impact GHG-
1, pp. 3.8-10 –
3.8-11
Yes GHG-1 NA LTS No Yes
Impact GHG-2: Generate GHG
Emissions through
Treatment Activities?
PSU
Impact GHG-
2, pp. 3.8-11 –
3.8-17
Yes AQ-3 MM
GHG-2 PSU No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact. None: there are SPRs and/or MMs identified in the PEIR for this
impact, but none are applicable to the treatment project.
New GHG Emissions Impacts: Would the treatment result in other impacts to GHG
emissions that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.7.1 Greenhouse Gas Emissions (GHG) Discussion
The potential for generation of GHG emissions was evaluated for this project. Prescribed burning and the use of vehicles and
equipment during treatment activities will emit greenhouse gases. This project will utilize prescribed fire for WUI treatments
and is consistent with applicable plans to reduce greenhouse gas emissions statewide as it aims to reduce the likelihood of
catastrophic wildfires. Such an event would create immense GHG emissions in a short time span. This impact is within the
scope of the PEIR because the proposed activities, associated equipment, duration of use, and the resulting GHG emissions are
consistent with those analyzed in the PEIR.
GHG EMISSIONS FROM GRASSLAND BURNS
The above-ground carbon cycle in annual grasslands is essentially a one -year cycle in California’s Mediterranean climate.
Grass sprouts in the fall or winter following adequate precipitation to initiate germination. Grass grows based on environmental
factors such as temperature, soil moisture, and soil fertility. These same factors influence the rate of decay of the previous
year’s grass crop. Most annual grasses mature in 60-120 days. As grass grows, they sequester carbon. As the previous grass
crop decays, it releases the stored carbon. While the active growth of the grass is the only time that carbon is sequestered,
release of carbon can take place at any time. The main carbon release mechanisms are decay, digestion (grazing), and fire.
While small amounts of carbon may be added to the carbon stored in the soil, the majority is released back to the atmosphere
where it is available to be sequestered by the next crop. Each day, more than 10% of the soluble carbohydrate pool degrades
to CO2, about 0.34% of the cellulose pool degrades, and less than 0.1% of the lignin. Because annual grasslands do not
generally carry biomass for more than a year, they are essentially carbon neutral on an annual basis. Prescribed burning of
grassland units is generally completed in one or two days. The daily release of greenhouse gases during the proposed burning
will be far greater than the normal daily emission from decay or digestion. The annual release would be essentially the same.
Perennial grasslands maintain a portion of their biomass for more than a year. Most of the biomass of each year’s growth is
released back to the atmosphere by decay or digestion. The carbon sequestration and release processes are essentially the sa me
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as those of the annual grassland. When perennial grasslands are burned, they may have a greater annual release of carbon tha n
an unburned area, proportional to fire intensity. In higher intensity grass fires, where significant amounts of the thatch a re
burned, it may take two or three years to sequester the amount of carbon released in the year of the burn. Therefore, with
respect to burning perennial grasslands, they are carbon neutral after two or three years.
Wildfires generally have higher fire intensities than the controlled burns used in prescribed fire. In grassland
habitats, prescribed fire can reduce flame lengths and rates of spread during subsequent wildfires by
modifying vegetation structure and continuity. Prescribed burning removes accumulated thatch, thereby
reducing the potential for a “ladder ef fect” that could carry flames into shrubs and ornamental vegetation.
In addition, prescribed fire can enhance access and safety zones for firefighting perso nnel and support the
development of defensible space and fuel break systems that remain effective beyond a single growing
season. Within the wildland–urban interface, these benefits may persist for more than one year, as reduced
fire behavior potential and improved tactical suppression opportunities continue to support wildfire risk
mitigation. All of this leads to lower greenhouse gas emissions from catastrophic wildfire s.
GHG EMISSIONS FROM CHAPARRAL BURNS
Prescribed burning in chaparral vegetation results in short -term GHG emissions from the combustion of live and dead plant
material. These emissions are temporary and occur over a limited duration during ignition and active burning. Although
prescribed fire produces carbon dioxide, methane, and nitrous oxide, the magnitude of emissions is substantially lower than
those generated during unmanaged wildfires in comparable fuel types. Conversely, wildfires in chaparral typically burn at
higher intensities, consume a greater proportion of available biomass, and generate significantly higher GHG emissions per
acre due to uncontrolled combustion conditions.
Implementation of prescribed fire reduces long-term GHG emissions by lowering fuel loads and associated fire hazard by
interrupting the accumulation of dense chaparral stands that contribute to extreme wildfire behavior. By reducing the potenti al,
size, and severity of future wildfires, prescribed fire can offset a portion of the short -term GHG emissions through avoided
wildfire emissions over time. This effect is particularly relevant in chaparral ecosystems, which naturally experience stand -
replacing fire and can store large amounts of carbon that are rapidly released during high-severity wildfire events.
In addition, prescribed fire promotes a more resilient vegetation structure that regenerates post-burn and begins re-sequestering
carbon within a relatively short timeframe. This cyclical carbon uptake helps balance the temporary emissions from the
prescribed burn. When implemented as part of a strategic fuels management program, prescribed fire can therefore provide a
net climate benefit by mitigating the likelihood of catastrophic wildfire emissions, supporting long -term carbon stability, and
improving landscape resilience to future climate-driven fire conditions.
When evaluated in terms of avoided wildfire emissions, post -burn carbon recovery, and improved ecosystem resilience,
prescribed burning in chaparral habitats is anticipated to result in substantial ecological and climate benefits.
AIR RESOURCES BOARD (ARB) GHG INVENTORY WORK
ARB has undertaken an extensive inventory documentation and refinement exercise to develop a draft updated statewide GHG
emissions inventory and corresponding documentation. This statewide GHG inventory is an aggregate, "top -down" inventory
for the period 1990-2004. The Board approved a 2020 emissions limit of 427 million metric tonnes of CO2 equivalent in
December 2007. The 2020 emissions limit is equivalent to the 1990 emissions level (ARB 20 23).
In California, the annual fossil fuel burning (FFB) emissions inventory of CO2 is 362 million metric tonnes CO2 per year
averaged from 1990–2003. As such, the annual averaged emissions of CO2 from wildfires are significant (24 million metric
tonnes CO2 per year; equivalent to 6% of the FFB emission estimates). Although the ratio of annual state -level CO2 emissions
from fires to FFB sources is low, it is highly variable. By the end of October 2003, wildfires burned more than 750,000 acres,
producing the equivalent of 49% of the monthly CO2 emitted by FFB sources for the state. Similarly, major wildfires in
September 2006, including the Day Fire in Southern California, produced an estimated 16 million metric tons CO2 in that one
month alone, equivalent to approximately 50% of estimated total monthly FFB emissions for the entire state (Wiedinmyer and
Neff 2007). Far more acres are burned each year in wildfires than are burned in prescribed fires. To the extent that prescr ibed
fire can lessen the intensity or reduce the acres burned in wildfires, prescribed fire can temporarily reduce the carbon emissions
from the wildland.
An important cause of carbon loss is catastrophic wildfires, especially in fire -adapted ecosystems (Helms 2007). Fire is one
of the largest potential risks to loss of stored terrestrial carbon, and it is a loss pathway that is difficult to quantify due to the
high degree of spatial and temporal variation in fire emissions. At multi-decadal time scales, wildfires have a near neutral effect
on atmospheric CO2: vegetation regrowth balances punctuated carbon losses due to combustion, if fire return intervals remain
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constant (Wiedinmyer and Neff 2007). Fuel reduction projects that do not change the vegetation type are carbon neutral over
time. The time needed to sequester the amount of carbon released by the treatment is determined by the amount of carbon
released and the subsequent regrowth of the vegetation.
California’s wildlands are going to burn, and the carbon is going to be released. Through prescribed fire land managers can
have a say in the timing and quantity of some of those releases. Land managers can also lessen the impacts or provide benefi ts
for other environmental resources. Fire hazard reduction may be an objective of prescribed fire; however, other objectives
such as, control of invasive species, wildlife habitat improvement, or range improvement are often also objectives. If a wil dfire
does happen to enter an area that was treated, the wildfire may be contained sooner with reduced area burned and consequently
reduced carbon emissions. The reduced number of acres or fire intensity may have benefits to other resource areas besides the
reduction of carbon emissions. The reduced wildfire size or intensity may also have benefits to environmental resources, pub lic
health, as well as public and firefighter safety.
IMPACT GHG-1
The First Order Fire Effects Model (FOFEM) was used to determine the amount and type of emissions likely to occur with
prescribed burning. Emission calculations for prescribed burning are based on factors including fuel models, fuel conditions
and expected fuel consumption in tons per acre. Emission calculations for motorized equipment and vehicles are based on the
California Air Resource Board emissions modeling tools, OFFROAD2021 ORION and the EMFAC2014. Initial burn units
will produce 9,138 tons of CO2 from treatment activities and 27 tons of CO2 from motorized exhaust for a total annual average
of 9,165 tons.
Use of vehicles and mechanical equipment and prescribed burning during initial and maintenance treatments would result in
GHG emissions. Consistency of treatments under the CalVTP with applicable plans, policies, and regulations aimed at reducing
GHG emissions was examined in the PEIR. Consistent with the PEIR, although GHG emissions would occur from equipment
and vehicles used to implement treatments, the purpose of the proposed project is to reduce wildfire risk, which could reduce
GHG emissions and increase carbon sequestration over the long term. This impact is within the scope of the PEIR because the
proposed activities, as well as the associated equipment, duration of use, and resultant GHG emissions, are consistent with
those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape
constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the
same plans, policies, and regulations adopted to reduce GHG emissions apply in the areas outside the treatable landscape, as
well as areas within the treatable landscape; therefore, the GHG impact is also the same, as described above. SPR GHG -1 is
not applicable to the proposed project because this project is not a registered offset project under the Board’s Assembly Bill
1504 Carbon Inventory Process. This determination is consistent with the PEIR and would not constitute a substantially more
severe significant impact than what was covered in the PEIR.
IMPACT GHG-2
Use of vehicles and mechanical equipment and prescribed burning during initial and maintenance treatments would result in
GHG emissions. The potential for treatments under the CalVTP to generate GHG emissions was examined in the PEIR. This
impact is within the scope of the PEIR because the proposed activities, as well as the associated equipment and duration of use,
and the intent of the treatments to reduce wildfire risk and GHG emissions related to wildfire are consistent with those analyzed
in the PEIR. Mitigation Measure GHG-2 would be implemented and would reduce GHG emissions associated with the
prescribed burning. However, emissions generated by the treatments would still contribute to the annual emissions generated
by the CalVTP, and this impact would remain significant and unavoidable, consistent with, and for the same reasons described
in, the PEIR. SPR AQ-3 is also applicable to this treatment and will contain the description of feasible GHG reduction
techniques implemented per Mitigation Measure GHG-2. The inclusion of land in the proposed treatment area that is outside
the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the
boundary of the project area, the climate conditions present in the areas outside the treatable landscape are essentially the same
as those within the treatable landscape; therefore, the GHG impact is also the same, as described above. This determination is
consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the
PEIR.
NEW IMPACTS RELATED TO GHG EMISSIONS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable regulatory and environmental conditions presented in the CalVTP PEIR (refer to Section 3.8.1, “Regulatory
Setting,” and Section 3.8.2, “Environmental Setting,” in Volume II of the Final PEIR). The project proponent has also
determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
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environmental conditions pertinent to the climate conditions that are present in the areas outside the treatable landscape ar e
essentially the same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described
above, impacts of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances
are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant
impacts. Therefore, no new impact related to GHG emissions would occur.
4.7.2 GHG Emissions Summary
All CAL FIRE prescribed burns receive a Smoke Management Permit from the Local Air District. A Smoke Management
Plan is developed for each project, to further minimize smoke impacts. Burning is done on approved burns days as determined
by the Air District. This process minimizes public health smoke impacts from the project.
Prescribed burn projects undertaken by CAL FIRE are a strategic land management tool designed to reduce the risk of large-
scale wildfires which can release substantially higher amounts of greenhouse gases than prescribed burns. By reducing fuel
loads in grasslands, chaparral, and other working landscapes, these projects increase wildfire resilience while keeping the l and
available to sequester carbon over the long term. Conversion of land to other uses such as factories or subdivisions would have
a much greater increase in carbon emissions. Prescribed fires are also designed to achieve the landowners’ objectives, are
carefully planned to minimize the area treated, and to consume the amounts of fuel necessary to meet the prescribed burn
objectives. Prescribed burns are not initiated without specific burning objectives to be achieved.
Because prescribed burns prevent larger, uncontrolled wildfires, they serve as a proactive climate mitigation strategy. As a
result, it is not expected that prescribed burning of grasslands, oak woodlands or chaparral will cause a significant net increase
in greenhouse gas emissions, and they contribute to reducing potential long-term GHG releases from catastrophic wildfires.
We do not believe prescribed burning associated with this project will have a significant net effect on the annual release of
greenhouse gases, nor will prescribed burning result in an increase in the long-term release of greenhouse gases from grassland,
oak woodland or chaparral landscapes.
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4.8 ENERGY RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact ENG-1: Result in
Wasteful, Inefficient, or
Unnecessary Consumption of
Energy?
LTS
Impact ENG-
11, pp. 3.9-7 –
3.9-8
Yes NA NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Energy Resource Impacts: Would the treatment result in other impacts to
energy resources that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.8.1 Energy Resources Discussion
IMPACT ENG-1
Use of vehicles and mechanical equipment during initial treatment and treatment maintenance activities would result in the
consumption of energy using fossil fuels. The use of fossil fuels for equipment and vehicles was examined in the PEIR. The
consumption of energy during implementation of the treatment project is within the scope of the PEIR because the types of
activities, as well as the associated equipment and duration of proposed use, are consistent with those analyzed in the PEIR.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, the existing energy consumption is essentially the same within and outside
the treatable landscape; therefore, the energy impact is also the same, as described above. No SPRs are applicable to this impact.
This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than
covered in the PEIR.
NEW ENERGY RESOURCE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable regulatory and environmental conditions presented in the CalVTP PEIR (refer to Section 3.9.1, “Regulatory
Setting,” and Section 3.9.2, “Environmental Setting,” in Volume II of the Final PEIR). The project proponent has also
determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as thos e
within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with those considered
in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable landscape would
not give rise to any new significant impacts. Therefore, no new impact r elated to energy resources would occur.
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4.9 HAZARDOUS MATERIALS, PUBLIC HEALTH & SAFETY
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered In the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact HAZ-1: Create a
Significant Health Hazard from
the Use of Hazardous
Materials?
LTS
Impact HAZ-
1, pp. 3.10-14
– 3.10-15
Yes HAZ-1 NA LTS No Yes
Impact HAZ-2: Create a
Significant Health Hazard from
the Use of Herbicides?
LTS
Impact HAZ-
2, pp. 3.10-
15 – 3.10-18
Yes
HAZ-5
HAZ-6
HAZ-7
HAZ-8
HAZ-9
NA LTS No Yes
Impact HAZ-3: Expose the
Public or Environment to
Significant Hazards from
Disturbance to Known
Hazardous Material Sites?
LTS
Impact HAZ-
3, pp. 3.10-
18 – 3.10-19
Yes NA MM
HAZ-3 LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Hazardous Materials, Public Health and Safety Impacts: Would the treatment
result in other impacts related to hazardous materials, public health and safety that are
not evaluated in the CalVTP PEIR?
Yes
No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.9.1 Hazardous Materials, Public Health & Safety Discussion
IMPACT HAZ-1
Initial and maintenance treatments would include mechanical treatments, manual treatments, herbicide application, and
prescribed burning. These treatment activities would require the use of fuels and related accelerants, which are hazardous
materials. The potential for treatment activities to cause a significant health hazard from the use of hazardous materials was
examined in the PEIR. This impact is within the scope of the PEIR because the types of treatments and associated equipment
and types of hazardous materials that would be used are consistent with those analyzed in the PEIR. The inclusion of land in
the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent
presented in the PEIR. However, the exposure potential and regulatory conditions are essentially the same within and outside
the treatable landscape; therefore, the hazardous material impact is also the same, as described above. SPR HAZ-1 is applicable
to this treatment. This determination is consistent with the PEIR and would not constitute a substantially more severe significant
impact than what was covered in the PEIR.
Project treatment activities require the transportation, use, and storage of petroleum products (fuels, oils, and lubricants) which
are known hazardous materials and could cause significant health hazards to humans and the environment. CAL FIRE will
apply SPR-HAZ 1 to minimize leaks and the risk of resultant contaminants from entering the environment. CAL FIRE requires
daily safety inspections and a regular maintenance plan for all equipment to ensure that equipment is safe, functional, and f ree
of leaks. Spill kits are kept with vehicles and equipment to contain fuel and/or hydraulic leaks should they occur. Locations
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used for fueling the helicopter or servicing fire ignition systems are established in areas where spills can be easily and ra pidly
contained (i.e. level ground) that are also outside of Watercourse and Lake Protection Zones and other sensitive areas. Most
fueling activities for the project will occur offsite at CAL FIRE stations. The types of treatment, including equipment and t he
use of hazardous materials, are consistent with the analysis in the PEIR and expected to be less than significant.
IMPACT HAZ-2
Initial and maintenance treatments would include herbicide application to target plant species using ground -based methods,
such as using a UTV or backpack sprayer or painting herbicide onto cut stems. No aerial spraying of herbicides would occur.
The potential for treatment activities to cause a significant health hazard from the use of herbicides was examined in the PEIR.
This impact is within the scope of the PEIR because the types of herbicides (e.g., glyphosate) and application methods that
would be used, which are limited to ground-based applications, are consistent with those analyzed in the PEIR. In addition,
herbicides would be applied by licensed applicators in compliance with all laws, regulations, and herbicide label instructions,
consistent with herbicide use described in the PEIR. The inclusion of land in the proposed treatment area that is outside the
CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary
of the project area, the exposure potential is essentially the same within and outside the treatable landscape; therefore, the
hazardous materials impact is also the same, as described above. SPRs HAZ -5 through HAZ-9 are applicable to this treatment.
This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact than
what was covered in the PEIR.
IMPACT HAZ-3
Initial and maintenance treatments would include soil disturbance and prescribed burning, which could expose workers, the
public, or the environment to hazardous materials if a contaminated site is present within the project area. The potential fo r
workers participating in treatment activities to encounter contamination that could expose them, the public, or the environment
to hazardous materials was examined in the PEIR. This impact was identified as potentially significant in the PEIR because
hazardous materials sites could be present within treatment sites throughout the large geographic extent of the treatable
landscape, and the feasibility of implementing mitigation for exposure of people or the environment to hazards resulting from
soil disturbance or burning in a hazardous materials site was uncertain.
As directed by Mitigation Measure HAZ-3, database searches for hazardous materials sites within the project area have been
conducted (Figure 4.9-1). The Coast Wood Preserving site (SEMS EPA ID CAD063015887), located in the Ukiah Valley, on
the eastern side of Hwy 101, approximately ½ mile from the nearest project dozer control line , is the only Federal Superfund
project listed near the project site. Past lumber manufacturing activities for this site introduced contaminants, arsenic and
chromium VI, into the surrounding soil and aquifer. Remediation is ongoing and includes soil monitoring and removal. The
last remediation activities took place in 2019 (CalEPA 2023). Five other sites were listed for the SEMS search of Ukiah,
however none of them are active. Eight other sites were listed for the EnviroSTOR search of Ukiah, of which three were listed
as ‘Evaluation’1 sites, one was listed as ‘Corrective Action’2, two were listed as ‘School Investigation’3, one was listed as ‘Non-
Operating’4, and one was listed as ‘Voluntary Cleanup’5 (DTSC 2023). After the implementation of MM HAZ-3, it was
determined that no hazardous materials sites would be disturbed by treatments and impacts would be less than significant.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, within the boundary of the project area, the potential to encounter hazardo us
materials and the regulatory conditions present in the areas outside the treatable landscape are essentially the same as those
within the treatable landscape; therefore, the hazardous materials impact is also the same, as described above. No SPRs are
applicable to this impact, and no additional mitigation is required. This determination is consistent with the PEIR and would
not constitute a substantially more severe significant impact than what was covered in the PEIR.
1 ‘Evaluation’ project types identify suspected, but unconfirmed, contaminated sites.
2 ‘Corrective Action’ project types identify facilities that treat, store, dispose, and/or transfer hazardous waste.
3 ‘School Investigation’ project types identify proposed and existing school sites that are being evaluated by DTSC for possible hazardous
materials contamination.
4 ‘Non-Operating’ project types identify a Treatment, Storage, Disposal or Transfer Facility (TSDTF) with no operating hazardous was te
management unit(s).
5 ‘Voluntary Cleanup’ project types identify sites with either confirmed or unconfirmed releases, and the project proponents ha ve requested
that DTSC oversee evaluation, investigation, and/or cleanup activities and have agreed to provide coverage for DTSC’s costs.
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NEW HAZARDOUS MATERIALS, PUBLIC HEALTH & SAFETY IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.10.1, “Environmental
Setting,” and Section 3.10.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has also determine d
that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and
regulatory conditions pertinent to hazardous materials that are present in the areas outside the treatable landscape are essentially
the same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described above,
impacts of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances are
present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts.
Therefore, no new impact related to hazardous materials, public health, or safety would occur.
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4.10 HYDROLOGY & WATER QUALITY RESOURCES
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact HYD-1: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface or
Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
the Implementation of prescribed
burning?
LTS
Impact HYD-1,
pp. 3.11-25 –
3.11-27
Yes
HYD-1
HYD-4
BIO-4
BIO-5
GEO-4
GEO-6
AQ-3
AQ-4
MM
BIO-3b LTS No Yes
Impact HYD-2: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface
or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
the Implementation of Manual
or Mechanical Treatment
Activities?
LTS
Impact HYD-
2, pp. 3.11-27
– 3.11-29
Yes
HYD-1
HYD-2
HYD-4
HYD-5
HYD-6
GEO-1
through
GEO-5
GEO-7
GEO-8
AQ-4
BIO-1
HAZ-1
HAZ-5
HAZ-6
HAZ-8
NA LTS No Yes
Impact HYD-3: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface
or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
Prescribed Herbivory?
LTS Impact HYD-
3, p. 3.11-29 No HYD-3 NA NA No Yes
Impact HYD-4: Violate Water
Quality Standards or Waste
Discharge Requirements,
Substantially Degrade Surface
or Ground Water Quality, or
Conflict with or Obstruct the
Implementation of a Water
Quality Control Plan Through
the Ground Application of
Herbicides?
LTS
Impact HYD-
4, pp. 3.11-30
– 3.11-31
Yes
HYD-1
HYD-5
BIO-4
HAZ-5
HAZ-6
HAZ-7
HAZ-8
NA LTS No Yes
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Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the Treatment
Project1
List
MMs
Applicabl
e to the
Treatmen
t Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Impact HYD-5: Substantially
Alter the Existing Drainage
Pattern of a Treatment Site or
Area?
LTS
Impact HYD-
5, p. 3.11-
31
Yes
HYD-4
HYD-6
GEO-1
GEO-2
GEO-5
NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Hydrology and Water Quality Impacts: Would the treatment result in other
impacts to hydrology and water quality that are not evaluated in the CalVTP
PEIR?
Yes
No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.10.1 Hydrology & Water Quality Resources Discussion
Several of the impacts below (i.e., HYD-1 through 4) evaluate compliance with water quality standards or waste discharge
requirements. All include implementation of SPR HYD-1, which requires compliance with such water quality regulations. The
State Water Resources Control Board is requiring all projects utilizing the CalVTP PEIR to follow the requirements of their
Vegetation Treatment General Order, which would meet the requirements of SPR HYD-1. Users of the CalVTP PSA process
are automatically enrolled in the General Order and are required to implement all applicable SPRs and mitigation measures
from the PEIR. In addition, the General Order requires project proponents to comply with any appli cable Basin Plan
prohibitions.
A letter was sent to Jim Burke (Senior Engineering Geologist) of the North Coast Regional Water Quality Control Board
(NCRWQCB) on February 19, 2024. That letter was then forward to Michael Hanks (Senior Environmental Scientist with the
NCRWQCB), and a response was received on March 26, 2024. The response letter highlighted the standard project
requirements (SPRs) for the project that are applicable to water quality impacts. These SPRs are included in Attachment A.
IMPACT HYD-1
Initial and maintenance treatments would include prescribed burning. Ash and debris from treatment areas could be washed by
runoff into adjacent drainages and streams. Although most treatment areas have been designed to avoid streams and
watercourses, WLPZs ranging from 50 to 150 feet will be implemented for Class I and Class II streams that are within treatment
areas pursuant to SPR HYD-4. Many water features have been identified during surveys and a pre-treatment walk-through of
treatment areas will be conducted by a qualified RPF to identify unstable areas, equipment exclusion zones (EEZs), equipment
limitation zones (ELZs), and any additional measures to protect water quality. Fire ignitions shall occur outside watercourse and
lake protection zones but may be allowed to back into these areas. Prescribed burning will be managed to stay within the treatment
areas to create a mosaic of habitat ranging from low to moderate burn intensities such that islands of unburned habitat will provide
adequate ground cover for water filtration during precipitation events. Hence, high overland water flow and nutrient loss of soil
will be avoided, and vegetation type conversion will not occur. The potential for prescribed burning activities to cause runoff
and violate water quality regulations or degrade water quality was examined in the PEIR. This impact is within the scope of
the PEIR because the use of low-intensity prescribed burns and associated impacts to water quality are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape
constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the
surface water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact
from prescribed burning is also the same, as described above. SPRs applicable to this treatment are HYD-1 through HYD-4,
BIO-4, GEO-4, GEO-6, AQ-3 and AQ-4 as well as MM Bio-3b. This determination is consistent with the PEIR and would not
constitute a substantially more severe significant impact than what was covered in the PEIR.
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IMPACT HYD-2
Initial treatment would include mechanical and manual treatments. Although most treatment areas have been designed to avoid
streams and watercourses, WLPZs ranging from 50 to 150 feet will be implemented for any watercourses that are within
treatment areas pursuant to SPR HYD-4. Ground disturbance will be limited during precipitation, and heavy equipment will not operate
over saturated soils (SPR GEO-1 & -2). Equipment operation will be limited on steep or unstable slopes (SPR GEO-7 and SPR GEO-8).
Treatment areas will be inspected for erosion and remediated prior to the rainy season and following the first large rainfall event (SPR
GEO-4). The potential for mechanical and manual treatment activities to violate water quality regulations or degrade water
quality was examined in the PEIR. This impact is within the scope of the PEIR because the use of heavy equipment and hand-
held tools to remove vegetation and associated impacts to water quality are consistent with those analyzed in the PEIR. The
inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the surface water conditions are
essentially the same within and outside the treatable landscape; therefore, the water quality impact from manual and mechanical
treatments is also the same, as described above. SPRs applicable to this treatment are HYD-1, HYD-2, HYD-4 through HYD-6,
GEO-1 through GEO-5, GEO-7, GEO-8, AQ-4, BIO-1, HAZ-1, HAZ-5, HAZ-6, and HAZ-8. This determination is consistent
with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
IMPACT HYD-3
This impact does not apply to the proposed project because prescribed herbivory is not a proposed treatment activity.
IMPACT HYD-4
Initial and maintenance treatments would include the use of herbicides to manage invasive plant species and resprouting native
tree species within the project area. Herbicide application would be limited to ground-based methods, such as using targeted
spray from a backpack or reservoir carried by a UTV, or painting herbicide onto cut stems. All herbicide applications would
comply with EPA and California Department of Pesticide Regulation label standards. The potential for the use of herbicides to
violate water quality regulations or degrade water quality was examined in the PEIR. This impact is within the scope of the
PEIR because the use of herbicides to remove vegetation and associated impacts to water quality are consistent with those
analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape
constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, surface
water conditions are essentially the same within and outside the treatable landscape; therefore, the water quality impact from
use of herbicides is also the same, as described above. SPRs applicable to this treatment are HYD-1, HYD-5, BIO-4, HAZ-5,
HAZ-6, HAZ-7, and HAZ-8. This determination is consistent with the PEIR and would not constitute a substantially more
severe significant impact than what was covered in the PEIR.
IMPACT HYD-5
Initial and maintenance treatments could cause ground disturbance and erosion, which could directly or indirectly modify
existing drainage patterns. Prescribed burning, and mechanical and manual vegetation removal for this project will have minor
effects on site drainage. Control line preparation will require heavy equipment or hand crews. Waterbreaks will be installed
and maintained on roads and skid trails, used for firing operations, and establishing control lines, to minimize soil loss utilizing
the spacing and erosion control guidelines set forth in SPR HYD-4 and Impact GEO-1. This will ensure watercourses are
hydrologically disconnected from sediment runoff. Existing drainage systems will be avoided and maintained at pre -treatment
drainage conditions (SPR HYD-6). Many water features were identified during the biological survey, and a qualified RPF,
qualified biologist, or their designee will walk through individual burn areas, prior to treatment activities, to identify an d map
unstable drainage infrastructure. The potential for treatment activities to substantially alter the existing drainage pattern of a
project site was examined in the PEIR. This impact to site drainage is within the scope of the PEIR because the types of
treatments and treatment intensity are consistent with those analyzed in the PEIR. The inclusion of land in the proposed
treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the
PEIR. However, within the boundary of the project area, surface water conditions are essentially the same within and outside
the treatable landscape; therefore, the impact related to alteration of site drainage patterns is also the same, as described above.
SPRs applicable to this treatment are HYD-4, HYD-6, GEO-1, GEO-2, and GEO-5. This determination is consistent with the
PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
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NEW HYDROLOGY & WATER QUALITY IMPACTS
The proposed treatment is consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.11.1,
“Environmental Setting,” and Section 3.11.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to hydrology and water quality that are present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment
project are also consistent with those covered in the PEIR. No changed circumstances are present, and the inclusion of areas
outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no new impact related
to hydrology and water quality would occur.
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4.11 LAND USE & PLANNING, POPULATION & HOUSING
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact LU-1: Cause a
Significant Environmental
Impact Due to a Conflict with a
Land Use Plan, Policy, or
Regulation?
LTS
Impact LU-
1, pp. 3.12-
13 – 3.12-14
No AD-3
AD-9 NA LTS No Yes
Impact LU-2: Induce
Substantial Unplanned
Population Growth?
LTS
Impact LU-2,
pp. 3.12-14 –
3.12-15
No NA NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Land Use and Planning, Population and Housing Impacts: Would the treatment
result in other impacts to land use and planning, population and housing that are not
evaluated in the CalVTP PEIR?
Yes
No
If yes, complete row(s)
below and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.11.1 Land Use & Planning, Population & Housing Discussion
These treatment types are consistent with land use and regulation and do not conflict with any land use plan, policy, or
regulation. Any applicable county land use plan, policy, or regulation will be adhered to. The proposed project is consistent
with the CAL FIRE Mendocino Unit 2023 Fire Plan.
IMPACT LU-1
Vegetation treatment activities would occur within Mendocino County. SPR AD-3 requires CAL FIRE to comply with
applicable county plans, policies, and ordinances, such as those pertaining to noise, biological resources, and water resourc es.
This impact is within the scope of the PEIR because proposed treatment types and activities are consistent with those examined
in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a
change to the geographic extent considered in the PEIR. However, land uses in the project area are essentially the same within
and outside the treatable landscape; therefore, the land use impact is also the same, as described above. No conflict would occur
because the project proponent would adhere to AD-3. This determination is consistent with the PEIR and would not constitute
a substantially more severe significant impact than covered in the PEIR.
IMPACT LU-2
The potential for initial treatments and maintenance treatments to lead to substantial population growth due to increased demand
for employees. Prescribed burning treatment activities would necessitate between 10 and 50 crew members, depending on the
size of the burn unit. Mechanical treatment activities may be conducted by up to four crews across each of the preserves.
Herbicide treatments would typically use a one - to five-person crew, and manual treatments would be implemented by crews
of approximately 8-20 members. Crew sizes would be consistent with those analyzed in the PEIR. Impacts associated with
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short-term increases in the demand for workers during implementation of the treatment project are within the scope of the PEIR
because the number of workers required for implementation of the treatments is consistent with the crew sizes analyzed in the
PEIR for the types of treatments proposed. In addition, the proposed project would not require the hiring of new employees.
The inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to t he
geographic extent presented in the PEIR. However, the population and housing characteristics of the project area are essentially
the same within and outside the treatable landscape; therefore, the population and housing impact is also the same, as described
above. No SPRs apply to this impact. This determination is consistent with the PEIR and would not constitute a substantially
more severe significant impact than covered in the PEIR.
NEW LAND USE AND PLANNING, POPULATION & HOUSING IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.3.1,
“Environmental Setting,” and Section 3.3.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable l andscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions present in the areas outside the treatable landscape are essentially the same as those
within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with those cover ed
in the PEIR. No changed circumstances are present, and the inclusion of areas outsid e of the CalVTP treatable landscape would
not give rise to new significant impacts not addressed in the PEIR. Therefore, no new impact related to land use and planning
would occur that is not covered in the PEIR.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
76
4.12 NOISE
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact NOI-1: Result in a
Substantial Short-Term
Increase in Exterior Ambient
Noise Levels During Treatment
Implementation?
LTS
Impact NOI-
11, pp. 3.13-9
– 3.13-12;
Appendix
NOI-1
Yes
AD-3
NOI-1
through
NOI-6
NA LTS No Yes
Impact NOI-2: Result in a
Substantial Short-Term
Increase in Truck-Generated
Single-Event Noise Levels
During Treatment Activities?
LTS Impact NOI-2,
p. 3.13-12 Yes NOI-1 NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact. None: there are SPRs and/or MMs identified in the PEIR for this
impact, but none are applicable to the treatment project.
New Noise Impacts: Would the treatment result in other noise-related impacts that
are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.12.1 Noise Discussion
IMPACT NOI-1
Initial and maintenance treatments would require heavy, noise-generating equipment. The potential for a substantial short-term
increase in ambient noise levels from use of heavy equipment was examined in the PEIR. This impact is within the scope of the
PEIR because the number and types of equipment proposed, and the duration of equipment use, are consistent with those
analyzed in the PEIR. The proposed treatments would require limited use of helicopters during the active burn operations. While
there is the potential for some prescribed burning to occur during nighttime and weekend hours, all treatment activities using
equipment would be limited to daytime hours Monday through Friday, which would avoid the potential to cause sleep disturbance
to residents during the more noise- sensitive evening and nighttime hours. In addition, treatments would be dispersed among the
four preserves so that noise increases at any one sensitive receptor would be limited. Treatments would be within the preserves,
which contain very few sensitive receptors, and use of equipment would be temporary and sporadic. Although Pole Mountain
Preserve is open to the public for hiking, treatment activities would not take place near the same people for an extended period.
SPR AD-1 is applicable to this treatment as well as NOI-1 through NOI-6. The inclusion of land in the proposed treatment area
that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However,
within the boundary of the project area, the exposure potential to any sensitive receptors present in the areas outside the treatable
landscape are essentially the same as those within the treatable landscape; therefore, the noise impact is also the same, as
described above. This determination is consistent with the PEIR and would not constitute a substantially more severe significant
impact than what was covered in the PEIR.
Consistent with SPR NOI-1 the project proponent will require that operation of heavy equipment associated with treatment
activities (heavy off-road equipment, tools, delivery of equipment and materials, and limited helicopter operation) will occur
during daytime hours if such noise is audible to receptors. Treatment activities will be limited to regular business hours, 0800 -
1700 hours, Monday through Friday.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
77
Consistent with SPR NOI-2 all CAL FIRE vehicles and equipment are regularly maintained on a schedule and checked daily
to ensure that all equipment is safe and compliant with all local, state, and federal laws governing noise and emissions.
Consistent with SPR NOI-3 the project proponent will require that engine shrouds be closed during equipment operation. This
SPR applies only to mechanical treatment activities and all treatment types.
Consistent with SPR NOI-4 staging areas will be placed away from residences and other noise sensitive receptors. All staging
areas will be decided on by the project proponent and applicable landowner.
Consistent with SPR NOI-5 the project proponent will require that all motorized equipment be shut down when not in use,
Idling of equipment and haul trucks will be limited to 5 minutes. This applies to all treatment activities and treatment type s.
Consistent with SPR NOI-6 the majority of the project area is situated on rural parcels upslope of the Ukiah Valley. Most
treatment activities are well over 1,500 feet away from noise-sensitive receptors. However, should shaded fuel break work
occur within 1,500 feet of a residence, school, or place of worship the project proponent will notify noise-sensitive receptors.
IMPACT NOI-2
Initial and maintenance treatments would involve large trucks hauling heavy equipment to the project area. These haul truck
trips would be dispersed on area roadways providing access to the project site including SR 128 and Franz Valley Road. Vehicle
traffic on area highways is not expected to generate a noticeable increase in traffic-related noise. Haul truck trips on the local
roadways would pass by residential receptors and the event of each truck passing by could increase the single event noise levels
(SENL). The potential for a substantial short-term increase in Single-Event Noise Levels was examined in the PEIR. This
impact is within the scope of the PEIR because the number and types of equipment proposed are consistent with those analyzed
in the PEIR. The haul trips associated with the treatment would occur during daytime hours (NOI-1), which would avoid the
potential to cause sleep disturbance to residents during the more noise -sensitive evening and nighttime hours. The inclusion of
land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent
presented in the PEIR. However, within the boundary of the project area, the exposure potential is essentially the same within
and outside the treatable landscape; therefore, the noise impact is also the same, as described above. This determination is
consistent with the PEIR and would not constitute a substantially more severe significant impact than what was covered in the
PEIR.
Consistent with SPR NOI-1 the project proponent will require that operation of heavy equipment associated with treatment
activities (heavy off-road equipment, tools, delivery of equipment and materials, and limited helicopter operation) will occur
during daytime hours if such noise is audible to receptors. Treatment activities will be limited to regular business hours, 0800-
1700 hours, Monday through Friday.
NEW NOISE IMPACTS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.13.1, “Environmental
Setting,” and Section 3.13.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has also determined
that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and
regulatory conditions pertinent to noise that are present in the areas outside the treatable landscape are essentially the sa me as
those within the treatable landscape; therefore, the impacts are the same and, for the reasons described above, impacts of the
proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances are present, and the
inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant impacts. Therefore, no
new impact related to noise would occur.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
78
4.13 PUBLIC SERVICES, UTILITIES & SERVICE SYSTEMS
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact Analysis
in the PEIR
Does the
Impact Apply
to the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact UTIL-1: Result in
Physical Impacts
Associated with Provision
of Sufficient Water
Supplies, Including Related
Infrastructure Needs?
LTS Impact UTIL-1,
p. 3.16-9 Yes NA NA LTS No Yes
Impact UTIL-2: Generate
Solid Waste in Excess of
State Standards or Exceed
Local Infrastructure
Capacity?
PSU
Impact UTIL-2-
2 pp. 3.16-10 –
3.16-12
No UTIL-1 NA LTS No Yes
Impact UTIL-3: Comply
with Federal, State, and
Local Management and
Reduction Goals, Statutes,
and Regulations Related to
Solid Waste?
LTS Impact UTIL-2
p. 3.16-12 Yes UTIL-1 NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Public Services, Utilities and Service System Impacts: Would the treatment
result in other impacts to public services, utilities and service systems that are not
evaluated in the CalVTP PEIR?
Yes
No
If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.13.1 Public Services, Utilities & Service Systems Discussion
IMPACT UTIL-1
Initial and maintenance treatments would include prescribed burning, which may require an on -site water supply if the burn
goes out of prescription. If needed, water would be supplied from water trucks. The potential increased demand for water was
examined in the PEIR. This impact is within the scope of the activities and impacts addressed in the PEIR because the size of
the area proposed for prescribed burn treatments, amount of water required for prescribed burning, and water source type are
consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outsid e the CalVTP
treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the
project area, the water supplies present in the areas outside the treatable landscape are essentially the same as thos e within the
treatable landscape; therefore, the water supply impact is also the same, as described above. No SPRs are applicable to this
impact. This determination is consistent with the PEIR and would not constitute a substantially more severe significant impact
than what was covered in the PEIR.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
79
IMPACT UTIL-2
Initial and maintenance treatments would generate biomass because of vegetation removal within the treatment areas. Biomass
generated by mechanical and manual treatments would be disposed of with pile burning or mulching or lopping and scattering
biomass in areas where material cannot safely be burned. Invasive plant and noxious weed biomass would also be treated onsite
(e.g., prescribed burning), when possible, to eliminate seed and propagules; however, invasive plants and noxious weeds will
not be chipped and spread, scattered, or mulched onsite. If invasive plant biomass cannot be treated onsite, there is the pot ential
for a small amount to be disposed of offsite at an appropriate waste collection facility. This impact was identified as potentially
significant and unavoidable in the PEIR because biomass hauled off-site could exceed the capacity of existing infrastructure
for handling biomass. For the proposed treatment project, little to no biomass would be hauled off-site; therefore, the amount
of biomass generated is not expected to exceed the capacity of existing infrastructure. SPR UTIL -1 would be applicable to the
proposed treatments if biomass is hauled off-site. Implementation of this SPR would maintain impacts at less than significant,
and mitigation is not required. The inclusion of land in the proposed treatment area that is outside the CalVTP treatable
landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary of the project
area, conditions related to biomass in the areas outside the treatable landscape are essentially the same as those within the
treatable landscape; therefore, impacts related to biomass are also the same, as described above.
IMPACT UTIL-3
As discussed above, initial and maintenance treatments would generate biomass because of vegetation removal within the
treatment areas. Biomass generated by mechanical and manual treatments would be disposed of with pile burning or mulching
or lopping and scattering biomass in areas where material cannot safely be burned. Invasive plant and noxious weed biomass
would also be treated onsite, when possible. If invasive plant biomass cannot be treated onsite, there is the potential for a small
amount to be disposed of offsite at an appropriate waste collection facility. If offsite disposal is required, CAL FIRE would
comply with all federal, state, and local management and reduction goals, statutes, and regulations r elated to solid waste.
Compliance with reduction goals, statutes, and regulations related to solid waste was examined in the PEIR. This impact is
within the scope of the activities and impacts addressed in the PEIR because the type and amount of biomass that may need to
be hauled off-site are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is
outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within
the boundary of the project area, the biomass conditions in the areas outside the treatable landscape are essentially the sam e as
those within the treatable landscape; therefore, impacts related to biomass are also the same, as described above. SPR UTIL-1
would be applicable to the proposed treatments if biomass is hauled off-site. This determination is consistent with the PEIR and
would not constitute a substantially more severe significant impact than what was covered in the PEIR.
NEW IMPACTS ON PUBLIC SERVICES, UTILITIES & SERVICE SYSTEMS
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.16.1, “Environmental
Setting,” and Section 3.16.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has also determine d
that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and
regulatory conditions pertinent to public services and utilities that are present in the areas outside the treatable landscape are
essentially the same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described
above, impacts of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances
are present, and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significant
impacts. Therefore, no new impact related to public services, utilities, or service systems would occur.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
80
4.14 RECREATION
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact REC-1: Directly or
Indirectly Disrupt Recreational
Activities within Designated
Recreation Areas?
LTS
Impact REC-1
pp. 3.14-6 –
3.14-7
Yes (Low
Gap City
and
County
Park)
REC-1 NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Recreation Impacts: Would the treatment result in other impacts to recreation
that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.14.1 Recreation Discussion
IMPACT REC-1
Low Gap City and County Park is open to the public for hiking and the Ukiah Municipal Golf Course is also open to the public
for use (Figure 4.14-1). Treatment activities could result in temporary closure of or limit access to the public trail and golf
course if treatment activities are occurring in the vicinity of either recreational use open space lands. Initial and maintenance
treatments would not restrict access to or otherwise affect the other adjacent recreation sites or facilities. The potential for
vegetation treatment and maintenance activities to disrupt recreation activities was examined in the PEIR. The potential for the
proposed treatment project to impact recreation is within the scope of the PEIR because the treatment activities and intensity
are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the CalV TP
treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, the availability of
recreational resources within the project area is essentially the same within and outside the treatable landscape; therefore, the
impact on recreation is also the same, as described above. The SPR applicable to this treatment is REC-1. This determination
is consistent with the PEIR and would not constitute a substantially more severe significant impact than covered in the PEIR.
NEW RECREATION IMPACTS
The proposed project is consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.14.1,
“Environmental Setting,” and Section 3.14.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent
has also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas co nstitutes
a change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental conditions pertinent to recreation that are present in the areas outside the treatable landscape are essentially the
same as those within the treatable landscape; therefore, the impacts of the proposed treatment project are also consistent with
those covered in the PEIR. No changed circumstances are present, and the inclusion of areas outside of the CalVTP treatable
landscape would not give rise to any new significant impacts. Therefore, no new impact related to recreation would occur.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
81
4.15 TRANSPORTATION
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact TRAN-1: Result in
Temporary Traffic Operations
Impacts by Conflicting with a
Program, Plan, Ordinance, or
Policy Addressing Roadway
Facilities or Prolonged Road
Closures?
LTS
Impact TRAN-
1, pp. 3.15-9 –
3.15-10
Yes
AD-3
AD-4
AD-5
TRAN-1
NA LTS No Yes
Impact TRAN-2: Substantially
Increase Hazards due to a
Design Feature or
Incompatible Uses?
LTS
Impact TRAN-
2, pp. 3.15-10
– 3.15-11
Yes
AD-3
HYD-2
TRAN-1
NA LTS No Yes
Impact TRAN-3: Result in a Net
Increase in VMT for the
Proposed CalVTP?
SU
Impact TRAN-
3, pp. 3.15-11
– 3.15-13
Yes NA NA LTSM No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Transportation Impacts: Would the treatment result in other impacts to
transportation that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.15.1 Transportation Discussion
IMPACT TRAN-1
Initial and maintenance treatments would temporarily increase vehicular traffic along several roads in the project area, including
Highway 101, State Route 128, and Franz Valley Road. The potential for a temporary increase in traffic to conflict with a
program, plan, ordinance, or policy addressing roadway facilities or prolonged road closures was examined in the PEIR. The
proposed treatments would be short term, and temporary increases in traffic related to treatments are within the scope of the
PEIR because the treatment duration and limited number of vehicles (i.e., heavy equipment transport, crew vehicles for crew
members) associated with the proposed treatments are consistent with those analyzed in the PEIR. In addition, the proposed
treatments would not all occur concurrently, and increases in vehicle trips associated with the treatments would be dispersed
on multiple roadways in two different geographic areas (i.e., coastal preserves and Russian River Watershed preserves). The
inclusion of land in the proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing transportation
conditions (e.g., roadways and road use) present in the areas outside the treatable landscape are essentially the same as those
within the treatable landscape; therefore, the transportation impact is also the same, as described above. SPRs applicable to this
treatment are AD-3, AD-4, AD-5, and TRAN-1. This determination is consistent with the PEIR and would not constitute a
substantially more severe significant impact than what was covered in the PEIR.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
82
IMPACT TRAN-2
Initial and maintenance treatments would not require the construction or alteration of any roadways. However, the proposed
treatments would include prescribed burning, which would produce smoke and could potentially affect visibility along nearby
roadways such that a transportation hazard could occur. The potential for smoke to affect visibility along roadways during
implementation of the treatment project was examined in the PEIR. This impact is within the scope of the activities and impac ts
addressed in the PEIR because the burn duration is consistent with that analyzed in the PEIR. The inclusion of land in the
proposed treatment area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presente d
in the PEIR. However, within the boundary of the project area, the existing transportation conditions (e.g., roadways and road
use) present in the areas outside the treatable landscape are essentially the same as those within the treatable landscape;
therefore, the transportation impact is also the same, as described above. SPRs applicable to this treatment are AD -3, HYD-2,
and TRAN-1. This determination is consistent with the PEIR and would not constitute a substantially more severe significant
impact than what was covered in the PEIR.
IMPACT TRAN-3
Initial and maintenance treatments could temporarily increase vehicle miles traveled (VMT) above baseline conditions because
the treatment areas are in remote locations and would require vehicle trips to access the treatment areas. This impact was
identified as potentially significant and unavoidable in the PEIR because implementation of the CalVTP would result in a net
increase in VMT. However, as noted under Impact TRAN-3 in the PEIR, individual vegetation treatment projects under the
CalVTP are reasonably expected to generate fewer than 110 trips per day, which would cause a less -than-significant
transportation impact for specific later activities, as described in the Technical Advisory on Evaluating Transportation Impacts,
published by the Governor’s Office of Planning and Research (OPR 2018). Initial treatments are expected to require up to 50
crew members, which would not exceed 110 trips per day.
Temporary increases in VMT are within the scope of the activities and impacts addressed in the PEIR because the number and
duration of increased vehicle trips is consistent with that analyzed in the PEIR. The inclusion of land in the proposed treat ment
area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR.
However, within the boundary of the project area, the existing transportation conditions (e.g., roadways and road use) present
in the areas outside the treatable landscape are essentially the same as those within the treatable landscape; therefore, the
transportation impact is also the same, as described above. This determination is consistent with the PEIR and would not
constitute a less than significant impact.
NEW IMPACTS TO TRANSPORTATION
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatments and determined they are consistent with
the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.15.1, “Environmental
Setting,” and Section 3.15.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has also determine d
that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a change to the
geographic extent presented in the PEIR. However, within the boundary of the project area, the existing environmental and
regulatory conditions pertinent to transportation that are present in the areas outside the treatable landscape are essential ly the
same as those within the treatable landscape; therefore, the impacts are the same and, for the reasons described above, impacts
of the proposed treatment project are also consistent with those covered in the PEIR. No changed circumstances are present,
and the inclusion of areas outside of the CalVTP treatable landscape would not give rise to any new significan t impacts.
Therefore, no new impact related to transportation would occur.
Docusign Envelope ID: 01DE84EB-A9BB-4CCC-ACAC-8D119FF98BE9
83
4.16 WILDFIRE
Impact in the PEIR Project-Specific Checklist
Environmental Impact
Covered in the PEIR
Identify
Impact
Significance
in the PEIR
Identify
Location of
Impact
Analysis in the
PEIR
Does the
Impact
Apply to
the
Treatment
Project?
List SPRs
Applicable to
the
Treatment
Project1
List MMs
Applicable
to the
Treatment
Project1
Identify
Impact
Significance
for
Treatment
Project
Would This Be
a Substantially
More Severe
Significant
Impact than
Identified in the
PEIR?
Is This
Impact
within the
Scope of
the PEIR?
Would the project:
Impact WIL-1: Substantially
Exacerbate Fire Risk and
Expose People to Uncontrolled
Spread of a Wildfire?
LTS
Impact WIL-1,
pp. 3.17-14 –
3.17-15
Yes
HAZ-2
HAZ-3
HAZ-4
NA LTS No Yes
Impact WIL-2: Expose People
or Structures to Substantial
Risks Related to Postfire
Flooding or Landslides?
LTS
Impact WIL-2,
pp. 3.17-15 –
3.17-16
Yes
AQ-3
GEO-3
GEO-4
GEO-5
GEO-8
NA LTS No Yes
1NA: not applicable; there are no SPRs and/or MMs identified in the PEIR for this impact.
New Wildfire Impacts: Would the treatment result in other impacts related to
wildfire that are not evaluated in the CalVTP PEIR? Yes No If yes, complete row(s) below
and discussion
Potentially
Significant
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
[identify new impact here, if applicable; add rows as needed]
4.16.1 Wildfire Discussion
IMPACT WIL-1
Vegetation treatment activities proposed would include mechanical, manual, herbicide application, and prescribed burn
treatments. Vegetation treatment involving motorized equipment could pose a risk of accidental ignition. Temporary increases
in risk associated with uncontrolled fire from prescribed burnings could also occur. As discussed in Section 3.17.1,
“Environmental Setting,” in Volume II of the Final PEIR, under “Prescribed Burn Planning and Implementation,”
implementing a prescribed burn requires extensive planning, including the preparation of prescription burn plans, smo ke
management plans, site-specific weather forecasting, public notifications, safety considerations, and ultimately favorable
weather conditions so a burn can occur on a given day. Prior to implementing a prescribed burn, fire containment lines would
be established by clearing vegetation surrounding the designated burn area to help prevent the accidental escape of fire. Water
containers and safety equipment would be staged on site as necessary.
The potential increase in exposure to wildfire during implementation of treatments was examined in the PEIR. Increased
wildfire risk associated with the use of heavy equipment in vegetated areas and with prescribed burns is within the scope of the
PEIR because the types of equipment and treatment duration and the types of prescribed burn methods proposed as part of the
project are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment area that is outside the
CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR. However, within the boundary
of the project area, the wildfire risk of the project area is essentially the same within and outside the treatable landscape;
therefore, the wildfire impact is also the same, as described above. SPRs HAZ -2, HAZ-3, and HAZ-4, pertaining to preparation
of burn plans in accordance with CAL FIRE requirements, equipment safety requirements, keeping fire extinguishers, and
prohibiting smoking in vegetated areas, apply to the proposed treatments. This impact of the proposed project is consistent with
the PEIR and would not constitute a substantially more severe significant impact than what was covered in the PEIR.
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IMPACT WIL-2
Vegetation treatment types would include mechanical and manual vegetation treatment, herbicide application, and prescribed
burning, which could exacerbate fire risk as described in Impact WIL -1 above. The potential for post-fire landslides and
flooding was evaluated in the PEIR. The potential exposure of people or structures to post -fire landslides and flooding are
within the scope of the activities and impacts covered in the PEIR because the equipment types and duration, and methods of
prescribed burn implementation are consistent with those analyzed in the PEIR. The inclusion of land in the proposed treatment
area that is outside the CalVTP treatable landscape constitutes a change to the geographic extent presented in the PEIR.
However, within the boundary of the project area, the wildfire risk of the project area is essentially the same within and outside
the treatable landscape; therefore, the wildfire impact is also the same, as described above. SPRs applicable to this impact are
AQ-3 GEO-3 through GEO-5, and GEO-8. Although most mechanical treatment would occur from existing roads or skid trails
or on flat to moderate slopes, SPR GEO-8 would apply if a treatment area contained steep slopes. Furthermore, because the
treatments reduce wildfire risk, they would also decrease post wildfire landslide and flooding risk in areas that could otherwise
burn in a high-severity wildfire without treatment. This impact of the proposed project is consistent with the PEIR and would
not constitute a substantially more severe significant impact than what was covered in the PEIR.
NEW IMPACTS ON WILDFIRE
The proposed treatments are consistent with the treatment types and activities considered in the CalVTP PEIR. The project
proponent has considered the site-specific characteristics of the proposed treatment project and determined they are consistent
with the applicable environmental and regulatory conditions presented in the CalVTP PEIR (refer to Section 3.17.1,
“Environmental Setting,” and Section 3.17.2, “Regulatory Setting,” in Volume II of the Final PEIR). The project proponent has
also determined that including land from outside the CalVTP treatable landscape in the proposed treatment areas constitutes a
change to the geographic extent presented in the PEIR. However, within the boundary of the project area, the existing
environmental and regulatory conditions pertinent to wildfire that are present in the areas outside the treatable landscape are
essentially the same as those within the treatable landscape; therefore, the impacts of the proposed treatment project are also
consistent with those covered in the PEIR. No changed circumstances would give rise to new significant impacts not addressed
in the PEIR. Therefore, no new impact related to wildfire would occur that is not covered in the PEIR.
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5 LIST OF PREPARERS
Mendocino County Fire Safe Council (Wildfire Prevention Grantee)
Scott Cratty .......................................................................................................................................... ……Project Director
NCRM, Inc. (CEQA Compliance)
Stephanie Martin .............................................................................................................. ..Senior Project Manager/ Ecologist
Kate Cahill, RPF #3031 ............................................................................................................................... ....Senior Forester
Laura Moreno and Lhasa Summers ........................................................................................................................... Botanists
Madeline Green, RPF #3069………………………………………………………………………………………...Senior Forester
Kevin Britton ....................................................................................................................................................GIS Analyst
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Attachment A – Standard Project Requirements and Mitigation
Measures Checklist
Instructions: Review the standard project requirements and mitigation measures and verify that those that are applicable will
be implemented. Provide information for each column as follows:
Applicable (Yes/No). Document whether the SPR or mitigation measure is applicable to the initial treatment and/or
treatment maintenance (Yes or No), and whether it is applicable to initial treatment and/or treatment maintenance. The
applicability should be substantiated in the Environmental Checklist Discussion.
Timing. This column identifies the time frame in which the SPR or mitigation measure will be implemented (e.g., prior to
treatment, during treatment, etc.).
Implementing Entity. The implementing entity is the agency or organization responsible for carrying out the requirement.
This could include the project proponent’s project manager, a technical specialist (e.g., archeologist or biologist), a veget ation
management contractor, a partner agency or organization, or other entities that are primarily responsible for carrying out each
project requirement.
Verifying/Monitoring Entity. The verifying/monitoring entity is the agency or organization responsible for ensuring that
the requirement is implemented. The verifying/monitoring entity may be different from the implementing entit y.
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