STONEBRAE COUNTRY CLUB 2017 ANNUAL REPORT ANNUAL REPORT MARCH 2018 STONEBRAE COUNTY CLUB HAYWARD,...

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March 2018 STONEBRAE COUNTRY CLUB 2017 ANNUAL REPORT U.S. ARMY CORPS OF ENGINEERS FILE NO. 21586S U.S. FISH AND WILDLIFE SERVICE FILE NO. 1-1-01-F-0275 CALIFORNIA DEPARTMENT OF FISH AND GAME ENDANGERED SPECIES TAKE PERMIT NO. 2081-2000-035-3 CALIFORNIA DEPARTMENT OF FISH AND GAME STREAMBED ALTERATION AGREEMENT NO. R3-2000-0260 SAN FRANCISCO REGIONAL WATER QUALITY CONTROL BOARD WASTE DISCHARGE ORDER NO. 01-025 CITY OF HAYWARD CONDITIONS OF APPROVAL, TRACTS #5354 & #7736

Transcript of STONEBRAE COUNTRY CLUB 2017 ANNUAL REPORT ANNUAL REPORT MARCH 2018 STONEBRAE COUNTY CLUB HAYWARD,...

March 2018

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U.S. ARMY CORPS OF ENGINEERS FILE NO. 21586S U.S. F ISH AND WILDLIFE SERVICE FILE NO. 1-1-01-F-0275

CALIFORNIA DEPARTMENT OF FISH AND GAME ENDANGERED SPECIES TAKE PERMIT NO. 2081-2000-035-3

CALIFORNIA DEPARTMENT OF FISH AND GAME STREAMBED ALTERATION AGREEMENT NO. R3-2000-0260

SAN FRANCISCO REGIONAL WATER QUALITY CONTROL BOARD WASTE DISCHARGE ORDER NO. 01-025

CITY OF HAYWARD CONDITIONS OF APPROVAL, TRACTS #5354 & #7736

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S T O N E B R A E C O U N T R Y C L U B

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U.S. ARMY CORPS OF ENGINEERS FILE NO. 21586S U.S. F ISH AND WILDLIFE SERVICE FILE NO. 1-1-01-F-0275

CALIFORNIA DEPARTMENT OF FISH AND GAME ENDANGERED SPECIES TAKE PERMIT NO. 2081-2000-035-3

CALIFORNIA DEPARTMENT OF FISH AND GAME STREAMBED ALTERATION AGREEMENT NO. R3-2000-0260

SAN FRANCISCO REGIONAL WATER QUALITY CONTROL BOARD WASTE DISCHARGE ORDER NO. 01-025

CITY OF HAYWARD CONDITIONS OF APPROVAL, TRACTS #5354 & #7736

Submitted to:

Stonebrae LP 23 Stonebrae Country Club Drive

Hayward, California 94542 510.728.7878

Prepared by:

LSA 157 Park Place

Point Richmond, California 94801 510.236.6810

Project No. YCS830

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TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................... 1 1.1 MITIGATION STATUS ............................................................................................................ 1 1.2 RESPONSIBLE PARTIES AND REPORT PREPARERS ................................................................ 3

2.0 MITIGATION MONITORING ................................................................................. 5 2.1 PONDS .................................................................................................................................. 5

2.1.1 Hydrology and Vegetation ..................................................................................................... 6 2.1.2 Wildlife................................................................................................................................... 7

2.2 SEASONAL WETLANDS ......................................................................................................... 7 2.2.1 Hydrology .............................................................................................................................. 7 2.2.2 Vegetation ............................................................................................................................. 8 2.2.3 Soil Organic Matter ................................................................................................................ 8

2.3 RIPARIAN ENHANCEMENT ................................................................................................... 8 2.3.1 Channel Stability and Development ...................................................................................... 8 2.3.2 Vegetation ............................................................................................................................. 9

2.4 ROCK OUTCROPS AND SCRUB ENHANCEMENT ................................................................. 10 2.4.1 Vegetation ........................................................................................................................... 10 2.4.2 Wildlife................................................................................................................................. 10

3.0 SPECIAL STATUS SPECIES ................................................................................... 13 3.1 ALAMEDA WHIPSNAKE....................................................................................................... 13 3.2 CALIFORNIA RED-LEGGED FROG ........................................................................................ 13

3.2.1 Habitat Monitoring .............................................................................................................. 13 3.2.2 Water Quality ...................................................................................................................... 13 3.2.3 Exotic Species Monitoring ................................................................................................... 15

4.0 OTHER HABITAT MANAGEMENT ACTIVITIES ...................................................... 17 4.1 WEED ABATEMENT ............................................................................................................ 17 4.2 FERAL PIG CONTROL ........................................................................................................... 17 4.3 GRAZING ............................................................................................................................. 17

5.0 SUMMARY OF RECOMMENDATIONS ................................................................. 19

6.0 REFERENCES ...................................................................................................... 21

APPENDICES A: MITIGATION MONITORING AND REPORTING PROGRAM SUMMARY TABLE

TABLES Table A: Summary of Mitigation to Date ................................................................................................ 1 Table B: 2016-2017 Rainfall Summary ................................................................................................... 2 Table C: Summary of Rock Outcrop Mitigation and Scrub Enhancement .............................................. 5 Table D: Observed CRLF activity at Stonebrae Mitigation Ponds by Year ............................................ 14 Table E: Observed CRLF activity at Stonebrae Enhanced Existing Ponds by Year ................................ 14

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1.0 INTRODUCTION

On behalf of our client, Stonebrae LP (formerly Hayward 1900, Inc.), LSA Associates, Inc. (LSA) submits this report detailing the activities and post-construction conditions of the Stonebrae (formerly Blue Rock) Country Club Project (project). The project is located on Walpert Ridge in the City of Hayward in the hills of western Alameda County, California. This report discusses compliance with the specifications presented in the Final Mitigation and Monitoring Plan for Blue Rock Country Club, Alameda County, California (LSA May 16, 2002; MMP), submitted to and approved by the Department of the Army, San Francisco District, U.S. Army Corps of Engineers (Corps), California Department of Fish and Wildlife (CDFW), U.S. Fish and Wildlife Service (USFWS), and San Francisco Regional Water Quality Control Board (RWQCB).

1.1 MITIGATION STATUS

Constructed wetland and riparian mitigation is summarized in Table A below. Additional detail is provided in the following sections.

Table A: Summary of Mitigation to Date

Aquatic Area Impacts (acres)1

In-Kind Mitigation Commitment2 2:1 (acres)

Mitigation Constructed/ Enhanced to Date (acres)

Mitigation Constructed/ Enhanced to Date (percent)

Ponds 0.59 1.18 1.64 constructed

192% 0.63 enhanced

Wetlands 8.01 16.02 16.97 constructed 106%

Streams/Riparian 0.57 1.14 2.28 enhanced3

200% 5,910 linear feet (1:1)4 6,610 linear feet

TOTAL 9.17 18.345 21.52 117% 1 Incorporates updated impacts (reductions and increases) due to golf course design adjustments and permitted offsite fill on the Carden

property. 2 The 2002 MMP targets acreages in excess of the 2:1 mitigation commitment in order to allow for variability in design, construction, and

performance of restored and enhanced wetlands. Mitigation for impacts to linear feet of stream/riparian habitat was established at a 1:1 ratio.

3 Bio-technical structural work has been completed on approximately 6,610 linear feet and riparian vegetation has been planted in portions of the repaired channels. Acreage estimate is derived from the MMP assumptions of average riparian habitat width (5 to 10 feet along each channel bank/average 15 feet) at maturity.

4 The listed in-kind mitigation commitment is based on the 2002 MMP and associated permits from the Corps and CDFW for the project. RWQCB Order 01-025 specifies a 1:1 mitigation ratio but specifies 6,800 linear feet of channel and 1.5 acres of acres of stream/riparian habitat.

5 Final Mitigation Commitment will be fulfilled by 18.34 acres of total successful Aquatic Area mitigation.

In 2017 the following mitigation maintenance and monitoring actions were implemented:

• Mitigation ponds, mitigation wetlands, enhanced riparian areas, and rock outcrops were surveyed for compliance with MMP performance criteria.

• Surveys were conducted for CRLF activity and the presence of exotic species at designated habitat preserves within the project site.

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• Feral pig control using box traps was conducted within the open space areas of the project site.

• Site-specific sheep grazing was used in March and early April to control invasive weeds and reduce thatch accumulation within and adjacent to mitigation sites and private open space lands.

• Stonebrae maintenance crews mowed portions of wetland mitigation areas that contained high concentrations of invasive weeds.

• Stinkwort (Dittrichia graveolens) was sprayed with herbicide within mitigation wetlands and surrounding areas by weed abatement contractor Hanford ARC.

• LSA monitored the livestock grazing in the public open space lands for compliance with grass height requirements and control of weed growth as specified in the MMP and the RMP.

A summary table of the status of compliance with the CDFW Mitigation Monitoring and Reporting Program (MMRP) is provided in Appendix A.

The performance of mitigation features is being monitored annually. Results from quantitative and qualitative performance monitoring are used to plan management activities (e.g., weed control, erosion repair, revegetation, and other remedial actions) for the mitigation sites in an ongoing effort to maintain and improve performance.

Results of the ongoing monitoring at Stonebrae in 2017 as in past years is significantly influenced by the amount and timing of annual rainfall. While annual rainfall for the 2015-2016 and 2016-2017 water years were above long-term average for the region (as shown in Table B), the rainfall followed an extended drought and many of the mitigation sites are just now showing a recovery from the dry conditions that have dominated the region during the previous 4 water years (from late 2011 through early 2015).

Table B: 2016-2017 Rainfall Summary

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Ann.

2016-2017 5.45 2.07 4.62 10.02 6.58 2.90 2.01 0.02 0.07 0.00 0.00 0.11 33.85 2015-2016 0.11 2.60 4.28 4.76 0.73 4.91 1.5 0.26 0.01 0.00 0.01 0.03 19.20 2014-2015 0.59 2.47 8.92 0.02 2.64 0.12 0.73 0.03 0.00 0.00 0.00 0.02 15.54 2013-2014 0.00 1.05 0.43 0.13 3.41 2.18 1.18 0.02 0.00 0.00 0.02 0.65 9.07 2012-2013 0.91 0.44 5.40 0.41 0.64 0.53 0.55 0.00 0.00 0.00 0.00 0.49 9.37 2011-2012 1.58 1.55 0.22 1.72 0.91 3.90 3.00 0.02 0.11 0.03 0.03 0.00 13.07 Long-term Average 0.83 1.71 2.53 2.97 3.01 2.37 1.04 0.50 0.11 0.00 0.02 0.15 15.24

Sources: 2011-2017 data from Union City CIMIS #171. Long-term average from NEWARK.C (NCDC #6144), 1951-2016 (UC IPM 2018). (http://www.ipm.ucdavis.edu/calludt.cgi/WXSTATIONDATA?STN=NEWARK.C

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1.2 RESPONSIBLE PARTIES AND REPORT PREPARERS The following are the firms and contacts who were involved in the activities described in this report:

Permittee: Stonebrae LP, 23 Stonebrae Country Club Drive, Hayward, CA 94542 Contact: Joanna Callenbach, (510) 728-7881

Biologist: LSA Associates, Inc., 157 Park Place, Point Richmond, CA 94801 Contact: Steve Foreman, (510) 236-6810

Contractor: Rural Pig Management, Inc., 4648 Crow Canyon Place, Castro Valley, CA 94552 Contact: Dick Seever, (510) 258-1610

Contractor: Hanford ARC, 596 First St. E. Sonoma, CA 95476 Contact: Will Johnson, (707) 766-4905

Licensee: A&R Livestock, 2239 Morrison Canyon Road, Fremont, CA 94539 Contact: Larry Forero, (530) 244-4691

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2.0 MITIGATION MONITORING

All monitoring activities described below were performed by qualified biologists. A summary of aquatic mitigation (ponds, wetlands and riparian habitat) is provided in Table A. A summary of rock outcrop mitigation and scrub enhancement is provided in Table C.

Table C: Summary of Rock Outcrop Mitigation and Scrub Enhancement

Year Constructed

Location/ Scrub Enhancement Method

Rock Outcrops

with Scrub Mitigation

(acres)

Percent Rock/Scrub Mitigation Complete

Additional Rock Outcrops

without Scrub Enhancement1

(acres)

Total Rock Outcrop

Areas (acres)

No. Rock Piles per

Area

MMP Goal 2 36.0 - - - 108 2004 Conservation Area:

Pilot Planting Effort 1.74 5% - 1.74 14+

2006 Golf Course: 14.88 94+ a) 163 rock outcrop areas

drill seeded in 2006; 6 of 16 augmented with container plantings in 2009

13.663 38% -

b) 4 rock outcrop areas without scrub enhancement

- 0% 1.22

2006 Conservation Area: 31.54 480+ a) 6 rock outcrop areas drill

seeded 26.64 74% -

b) 3 rock outcrop areas without scrub enhancement

- 0% 4.90

Total Complete 42.043 117% 6.12 48.16 588+ 4 1 Scrub enhancement not required at additional rock outcrops. 2 MMP identified 15 mitigation rock outcrop areas ranging in size from 0.5 to 14 acres, totaling 36 acres of mitigation.

MMP recommended an average density of 3 rock piles per acre (i.e., 108 rock piles). 3 Quantity underreported in 2009 Annual Report. 4 Average density as-built is 12 rock piles per acre among 34 mitigation rock outcrop areas.

2.1 PONDS

As reported in previous annual reports, 13 new ponds covering 1.64 acres have been constructed and 7 existing ponds covering 0.63 acres have been enhanced/repaired to date. Together, new pond construction and pond enhancement totals 2.27 acres of aquatic mitigation, or approximately 192 percent of the mitigation commitment for the combined construction and enhancement of ponds (see Table A). In 2017, as in previous years, mitigation ponds (constructed in 2003, 2005, and 2006) and existing ponds (repaired in 2003, 2004, 2006, and 2008) were monitored for hydrologic function, vegetation establishment and the presence of wildlife.

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2.1.1 Hydrology and Vegetation

Constructed Ponds. Eleven of the 13 constructed mitigation ponds (3-P, 4-P, 6-P, 7-P, 9-P, 15-P, 16-P, 17-P, 19-P, 20-P, and, 21-P) met vegetation performance criteria in 2017 as stated in the MMP for California red-legged frog (Rana aurora draytonii1; CRLF) mitigation habitat. These ponds support a combination of emergent vegetation and open water wherein one component does not occupy more than two-thirds of the pond area. The total area of constructed mitigation ponds meeting MMP vegetation performance criteria is 1.51 acres, or 128 percent of the 2:1 in-kind mitigation commitment. The remaining constructed ponds (1-P, and 18-P) contained only sparse vegetation and did not meet vegetation performance criteria. These ponds (1-P and 18-P) were designed as shallow ponds that seep towards constructed mitigation wetlands. Although pond 18-P did not meet MMP vegetation performance criteria, CRLF use was documented at this pond in 2017 (see section 3.2 California Red Legged Frog below).

During surveys conducted in 2017, native plant species observed growing within and around the mitigation ponds were similar to those observed in previous years and included willows (Salix spp.), cattails (Typha spp.), bulrush (Schoeneoplectus [Scirpus] spp.), rushes (Juncus effusus and J. patens), spike rush (Eleocharis sp.) sedges (Carex spp.), blue-eyed grass, (Sisyrinchium bellum), and iris-leaf rush (Juncus xiphioides).

All of the constructed mitigation ponds at the project site met hydrology performance criteria by drying out before mid-October; however none of the constructed mitigation ponds held the MMP performance requirement of 1 meter of water on July 1 in 2017. In previous normal rainfall years not following a drought (most recently 2011), all of the constructed mitigation ponds, except Pond 15-P, have typically achieved both vegetation and hydrology performance criteria.

LSA monitored erosion repairs at ponds 1-P, and 17 P in 2017. These areas remained stable and no additional maintenance is necessary at this time for the constructed ponds.

Enhanced Ponds. In 2017, all of the enhanced existing ponds at the project site met hydrology performance criteria by drying out before mid-October. As with the constructed ponds, none of the enhanced ponds held the MMP minimum requirement of 1 meter of water on July 1. In previous normal rainfall years not following a drought, all of these ponds, with the exception of shallow pond 9-P, have typically achieved the MMP hydrologic performance criteria.

LSA monitored the erosion repair at the Pond 10 spillway in 2017 and the area has remained stable. No additional maintenance is necessary at this time for the enhanced ponds.

1 The official common and scientific names of reptiles and amphibians have been updated (Crother 2008); however, the previous

nomenclature (Stebbins 2003) is used in this report for consistency with previous reports and state and federal listing designations. The currently recognized scientific name for California red-legged frog is Rana draytonii.

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2.1.2 Wildlife

The constructed mitigation and enhanced existing ponds at the project site provide suitable habitat for a variety wildlife species. Wildlife regularly observed using the ponds include Pacific tree frog2 (Pseudacris regilla), California newt (Taricha torosa), aquatic garter snake (Thamnophis atratus), western fence lizard (Sceloporus occidentalis), and numerous other bird and invertebrate species.

The primary target of wildlife habitat creation and enhancement at new and existing ponds is for CRLF. Pond construction and enhancement resulted in an increase in CRLF observations/population indices since prior to construction. Prior to the recent drought, population levels in constructed ponds appear to have stabilized and observations had fluctuated between 31 and 35 CRLF observations during surveys conducted in 2010-2012 at these ponds (see additional discussion in Section 3.2 below). These observations suggest that pond creation and enhancement activities have succeeded in preserving and expanding CRLF habitat at the project site as designed. CRLF observations and breeding activity in 2017 were comparable to the number of observations recorded in previous highly productive years for CRLF at the project site (there were 83 total observations of CRLF at the project site in 2017, a total of 63 in 2016, and a total of 75 in 2012). The occurrence of CRLF breeding populations at the vast majority of constructed and enhanced mitigation ponds has been observed during all normal rainfall years within the past 8 years of monitoring. The number of CRLF observations at the project site is expected to be maintained in years to come with normal variations in totals according to non-project related environmental factors including rainfall.

2.2 SEASONAL WETLANDS The total area of seasonal wetland mitigation constructed at the project site to date, including sub-drain seasonal wetlands identified in 2012, is 16.97 acres, or 106% of the 2:1 in-kind mitigation commitment (see Table A). Weed control activities, including mowing and herbicide application to control Harding grass (Phalaris aquatica) and stinkwort (Dittrichia graveolens), has been conducted at the mitigation sites in an ongoing effort to improve native plant cover.

As in previous years, monitoring of hydrology in the mitigation wetlands was conducted in 2017. The MMP required monitoring of vegetation parameters has been fulfilled as of 2016 and will be resumed in 2019 in an effort to track long term performance trends (see section 2.2.2 Vegetation below).

2.2.1 Hydrology

During the last water year (October 1, 2016-September 30, 2017) all but one of the mitigation wetlands monitored (13 of the wetlands constructed) for hydrology met the wetland performance criteria. The mitigation wetlands supported inundation at the surface and/or saturation in the upper 12-18 inches of soil for more than two consecutive weeks; a period that shows progress toward

2 The official common and scientific names of reptiles and amphibians have been updated (Crother 2008); however, the

previous nomenclature (Stebbins 2003) is used in this report. The new name for Pacific tree frog in the bay area is Sierran tree frog (Pseudacris sierra).

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emulating hydrologic conditions measured in reference wetlands. All three reference wetlands monitored for hydrology met the performance criteria.

2.2.2 Vegetation

As of 2016, vegetation parameters have been monitored annually within the mitigation wetlands for 10 consecutive years. Despite 4 consecutive years of below average rainfall during this monitoring period, these areas demonstrated recent trends towards achieving the minimum threshold values required by the MMP. Vegetation parameters will be monitored again at the mitigation wetlands in 2019 along with the completion of an analysis of long term mitigation wetland performance trends in reference to the MMP mitigation wetland vegetation criteria/goals.

2.2.3 Soil Organic Matter

Mitigation wetland performance is expected to exhibit a positive trend in soil organic matter content over the 10 year monitoring period. In 2016 (year 7 of the monitoring period), measurements of soil organic matter at the majority of sampled mitigation wetlands showed similar concentrations of soil organic matter compared to previous years. One third (1/3) of the sampled mitigation wetlands showed a slight decrease in soil organic matter in 2016 along with all of the reference wetlands sampled. The slight decrease in soil organic matter at both some of the mitigation wetlands and at all of the reference wetlands could be attributed to the dry conditions experienced at the wetlands for the previous 4 water years. When soil sampling has been conducted following previous normal water years (most recently 2011) increases or stability in soil organic matter has been observed at all of the mitigation and reference wetlands sampled. It is expected that as the effects of normal and near-normal annual precipitation patterns return to the project site, soil organic matter within the mitigation wetlands will continue to exhibit increases or stability in soil organic matter. Soil organic matter sampling was not conducted at the site in 2017, but will be continued at designated mitigation wetlands in the fall of 2019.

2.3 RIPARIAN ENHANCEMENT The structural activities necessary to achieve the MMP riparian enhancement mitigation commitment of 1.14 acres have been implemented. This mitigation addresses pre-project eroded channels and moderates potential project-related effects on water quality and downstream beneficial uses. To date, various biotechnical structural measures and riparian planting have been implemented along approximately 6,610 linear feet of channel and over 1,600 trees and shrubs have been planted and/or passively recruited within restored and preserved riparian areas at the project site.

2.3.1 Channel Stability and Development

In 2017, the 6,610 linear feet of enhanced riparian areas were surveyed for evidence of new erosion, and each of the installed biotechnical structures was checked for stability and function. Qualitative assessments of riparian enhancement performance are conducted at various times of year, by visually inspecting the drainages on foot and photographing the conditions of plantings, structures and bank stability.

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Results from the qualitative surveys indicate that the majority of biotechnical structures installed at the project site continue to function and promote channel stability. Many structural features, such as brushy check dams, have deteriorated as designed after establishing stabilized channel sections. The above average precipitation during the 2016-2017 water year had triggered minor sloughing at numerous locations throughout the reaches, however, the vast majority of channels remain relatively stable. Erosion at a portion of Reach B south (B8c) was more significant than at other areas surveyed. A 5’ high headcut and associated plunge pool has developed within the lower portion of this reach. Steep banks of up to 10’ high lead to the plunge pool however the areas surrounding the eroded site remain heavily vegetated with sedges (Carex sp.) and other riparian species. The down cutting within this portion of the channel has reached bedrock and is anticipated to stabilize without the need for remediation. This area will be monitored in 2018 for the occurrence of any further erosion.

From 2014 through 2017, discharges from the City of Hayward water tank outfall, created gullies and head cuts along Reach C East (C2a-d) up to 8 feet in depth. In September of 2017, Stonebrae contractors used a mixture of large rocks and soil to fill the gullies and repair the area. Upon completion of the repair work, the area was sprayed with a hydromulch binder and native seed mix consisting of Molate blue fescue (Festuca rubra), Idaho fescue (Festuca idahoenisis), and western fescue (Festuca occidentalis). Native plantings including coast live oak (Quercus agrifolia), California buckeye (Aesculus californica), California rose (Rosa californica), and California sage (Artemisia californica) with an associated watering system were installed in early 2018 within the repaired area. The area is currently stable and will be monitored for any future erosion in 2018.

In 2011, 2012, and 2013, channel stability throughout the open space at the project site was monitored quantitatively during each water year by surveying eighteen geomorphic cross sections located within three restored drainages at the project site and six geomorphic cross sections within one reference (preserved) drainage. Per the MMP, geomorphic surveys are to be conducted following any occurrence of a significant storm (defined as equal to or exceeding 3.29 inches of precipitation in a 24-hour period). During the 2016-2017 water year no significant storms meeting this criteria occurred at the project site. Geomorphic channel monitoring at the project site will continue in seasons following any significant storm.

2.3.2 Vegetation

In the winter of 2017 LSA biologists counted the number of container plantings and volunteer recruits within the 6,610 linear feet of riparian enhancement areas at the project site and found 1,128 trees and shrubs alive and in good condition. The riparian vegetation in the restoration areas is on target to achieve the MMP assumptions of 5 to 10 feet of additional riparian habitat to be established along each bank at maturity (or an average of 7.5 feet per bank or 15 feet total width per linear foot of restored channel). The currently implemented structural work and planting yields an estimated 2.28 acres of riparian enhancement/establishment, or 200 percent of the MMP mitigation commitment (Table A).

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2.4 ROCK OUTCROPS AND SCRUB ENHANCEMENT Rock outcrop and scrub mitigation exceeds the MMP acreage requirements (see Table C). Thirty-four (34) mitigation rock outcrop areas (totaling 48.2 acres and more than 588 individual rock piles) have been constructed and 27 of these areas included scrub enhancement (totaling 42.0 acres, or 6 acres over the 36 acres required by the MMP). Mitigation rock outcrop construction and scrub enhancement was implemented in 2004, 2006, and 2009.

2.4.1 Vegetation

In 2016, thirty mitigation rock outcrops with and without scrub enhancement (i.e., planting and/or seeding of native scrub species suitable for Alameda whipsnake habitat) were monitored. Results from the 2016 monitoring indicate that the scrub vegetation establishment has progressed, providing shade for portions of almost all outcrops surveyed. Native shrubs with a cover class of 3 or higher were observed at 14 rock outcrops and native grasses with a cover class of 3 or higher were observed at 12 rock outcrops, indicating that 86 percent of the rock outcrops monitored met the success criteria for vegetation as required by the MMP (that the percent cover and species diversity of vegetation in the rock outcrops are within 25 percent of cover and species diversity of the reference rock outcrops). Although native shrub and grass cover around rock outcrops provide a desirable food source for wildlife, shade cover and food is also provided by non-native plants observed at the rock outcrops.

Native scrub establishment within the rock outcrop and scrub enhancement areas is expected to benefit from grazing as non-native grasses and thatch are reduced. Livestock grazing was reintroduced into portions of the conservation in 2009/2010 and continued seasonally in 2011 through 2017.

The original intent of rock outcrop mitigation is to provide for increased cover and foraging habitat in order to promote Alameda whipsnake movement though grassland areas between core scrub habitat areas. The scrub component of the rock outcrop performance and success standards was primarily intended to measure establishment of rock outcrops that would be visually similar to the rock outcrops removed by the Stonebrae project. The actual value or need for scrub to be present in the rock outcrops with respect to use by Alameda whipsnakes is unknown; however, the mitigation outcrops are now, in 2017, visually similar to the natural outcrops.

2.4.2 Wildlife

The annual monitoring for wildlife in the expanded 48 acres of mitigation rock outcrops in 2005, 2006, 2010, and 2012 showed consistent use by the target performance criteria species. The MMP states that the purpose of wildlife monitoring is to assess the colonization of the mitigation rock outcrops by western fence lizards (Sceloporus occidentalis3), a primary prey item of the Alameda whipsnake (Masticophis lateralis euryxanthus). The MMP states that, after two years of monitoring, if the mitigation rock outcrops achieve performance criteria, no additional monitoring will occur until year 5 and then again in years 7 (2012) and 10 (2015). Year 10 wildlife monitoring was 3 The official common and scientific names of reptiles and amphibians have been updated (Crother 2008); however, the previous

nomenclature (Stebbins 2003) is used in this report. The new name for Alameda whipsnake is Alameda striped racer (Coluber lateralis euryxanthus).

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conducted in October 2015 at the mitigation rock outcrops. Results from the monitoring indicated that western fence lizards continue to utilize the outcrops and this use is expected to remain unchanged. In terms of providing movement cover and increased food availability, the constructed rock outcrops greatly exceed final success criteria: all constructed rock outcrops are inhabited by fence lizards (compared to a success criterion of 50 percent of the rock outcrops) and 588+ rock piles have been established over 48 acres compared to a planned 108 rock piles over 36 acres. To date, wildlife monitoring at mitigation rock outcrops is considered complete.

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3.0 SPECIAL STATUS SPECIES

3.1 ALAMEDA WHIPSNAKE

All whipsnake traps have been removed from the project site. Non-mitigation related construction at the project site continues to be limited to work within the developed residential areas, which are surrounded by the completed golf course. Monitoring of mitigation habitat for whipsnakes (i.e., grassland, rock outcrops and scrub enhancement) will continue as required. No whipsnakes were observed by LSA biologists or Stonebrae staff in the golf course or open space areas in 2017.

3.2 CALIFORNIA RED-LEGGED FROG

3.2.1 Habitat Monitoring

Twenty ponds within the designated habitat preserves in the project area are surveyed bi-annually by LSA biologists for an on-going species count of CRLF adults, larvae, and egg masses. In 2017, 16 ponds provided documented CRLF presence and 15 of these ponds provided documented breeding activity. The number of ponds providing evidence of breeding in 2017 was the highest recorded in the previous 14 monitoring years and two ponds (15-P and 18-P) provided evidence of breeding for the first time. The number of CRLF observed within the constructed mitigation ponds in 2017 was consistent with other productive years and the number of CRLF observed within the enhanced ponds was the highest recorded in the previous 14 monitoring years (see Tables D and E).

In 2017, adult CRLF were observed at the following six pre-project breeding locations: pond 4 (up to 3 observed), pond 5 (up to 5 observed), pond 7 (up to 23 observed), pond 10 (up to 5 observed), pond 11 (up to 2 observed), and the cistern (up to 3 observed). Adult CRLF were also observed in the following ten created breeding locations: pond 3-P (up to 2 observed), pond 4-P (up to 2 observed), pond 6-P (up to 8 observed), pond 7-P (up to 6 observed), pond 9-P (up to 2 observed), pond 15-P (up to 2 observed), pond 16-P (up to 6 observed), pond 18 P (up to 2 observed), pond 20-P (up to 2 observed), and pond 21 P (up to 2 observed). Calling male CRLF, CRLF egg masses, or CRLF larvae were observed in five existing ponds (4, 5, 7, 10, and 11) and at ten mitigation ponds (3-P, 4-P, 6-P, 7-P, 9-P, 15-P, 16-P, 18-P, 20-P, and 21-P). Tables D and E (below) summarize all observed CRLF individuals and breeding activities at mitigation ponds and enhanced ponds (respectively) by year. All 2017 adult CRLF and/or breeding activity was observed at ponds that did not meet hydrologic and/or vegetation performance criteria discussed above.

3.2.2 Water Quality

In accordance with the project SWMP and MMP, implementation of a water quality monitoring program focused on chemicals found in urban and golf course runoff that might be deleterious to CRLF and other amphibians was completed in 2016 (see 2016 Annual Report). The detected concentrations of chemicals, nutrients, and sediment in the waters during each year testing was required appeared to represent background and/or seasonally-variable concentrations at the project site. The results of the water quality monitoring program indicate that chemical application and irrigation on the golf course does not pose a risk to amphibian health. To date, water quality monitoring at the project site is considered complete.

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Table D: Observed CRLF activity at Stonebrae Mitigation Ponds by Year

Mitigation Pond

Year Constructed

Number of Adult CRLF Observed CRLF Egg

Masses and/or

Tadpoles Observed?

2004-2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

6-P 2003 4 5 2 3 4 1 0 0 2 8 8 2008-2010, 2012, 2013, 2015-2017

7-P 2003 0 1 0 3 2 2 27 0 1 4 6 2012, 2013, 2015-2017

9-P 2003 4 1 4 4 1 6 0 0 0 2 2 2010-2011, 2013, 2015-

2017

3-P 2005 0 2 5 5 10 1 0 0 12 0 2 2011-2013, 2015-2017

4-P 2005 0 0 1 3 0 1 0 0 0 5 2 2009-2013, 2015-2017

1-P 2006 0 0 0 0 0 0 0 0 0 0 0 No 15-P 2006 0 0 0 0 0 0 0 0 0 0 2 2017

16-P 2006 0 10 2 6 6 7 2 4 4 0 6 2010-2013, 2015, 2017

17-P 2006 0 0 0 0 0 0 0 0 0 1 0 No 18-P 2006 0 0 1 0 0 0 0 0 0 0 2 2017 19-P 2006 1 0 0 1 1 1 0 0 0 10 0 2010

20-P 2006 0 1 1 1 3 5 0 0 1 5 2 2011-2013, 2015-2017

21-P 2006 1 8 10 5 8 7 3 3 8 4 2 2008-2013, 2016. 2017

Total Observed 10 28 26 31 35 31 32 7 28 39 34

Table E: Observed CRLF activity at Stonebrae Enhanced Existing Ponds by Year

Existing Enhanced

Pond/ Feature

Year Constructed

Number of Adult CRLF Observed CRLF Egg Masses and/or Tadpoles

Observed? 2004-2007 2008 2009 2010 2011 2012 2013 2014 20

15 2016 2017

P-7 2003 10 3 1 2 3 2 10 0 0 3 23 2006, 2009-2013, 2015-2017

P-4 2005 9 5 4 5 3 10 0 0 4 4 3 2006-2013, 2015-2017

P-5 2006 21 15 5 4 0 4 0 0 2 0 5 2006-2013, 2017

P-9 2006 0 0 0 0 0 0 0 0 0 0 0 No

P-10 2006 5 8 3 3 1 4 4 0 3 4 5 2006-2011, 2016, 2017

P-11 2006 10 5 0 1 0 2 2 0 4 2 2 2006-2011, 2015, 2016, 2017

P-171 2003 3 5 2 3 4 1 0 0 2 8 8 2008-2010, 2012-2013, 2015-2017

Cistern (Reach A) 20062, 2009 10 6 5 5 5 4 3 4 4 3 3 No

Total Observed 68 47 20 23 16 27 19 4 17 24 49 1 Incorporated into new pond 6-P. 2 New lid constructed with ramp and escape hole for wildlife entry and exit.

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3.2.3 Exotic Species Monitoring

As prescribed in the MMP, all ponds on the project site are surveyed at least twice annually to detect the presence of bullfrogs and/or predatory fishes. To date, no bullfrogs or predatory fishes (e.g., gambusia, carp, sunfish) have been observed in any pond on the project site.

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4.0 OTHER HABITAT MANAGEMENT ACTIVITIES

4.1 WEED ABATEMENT

Sheep grazing of mitigation wetlands and rock outcrops within and around the golf course open space was conducted at the project site in March and early April 2017. Cattle grazing occurred within the northern and southern conservation areas throughout 2017. The use of sheep and cattle grazing within the golf course open space and other conservation areas is expected to enhance weed management efforts within the mitigation rock outcrops and seasonal wetlands. Weed abatement including goat or sheep and cattle grazing of selected open space/conservation areas will continue to be implemented in 2018.

The seasonal mowing and/or the use of herbicide to control populations of Harding grass and other invasive plant species has been conducted on an ongoing basis at the project since 2011. In 2017, the mowing and herbicide (Aquamaster Custom) spraying of Harding grass and stinkwort was conducted within 10 acres of dense populations of these species occurring within and surrounding mitigation wetlands. The effects of mowing and spaying these areas will be assessed in 2018 and future treatments will be prescribed accordingly.

4.2 FERAL PIG CONTROL Feral pig control was conducted on the property by Rural Pig Management, Inc., under CDFG permit #85388. A varying number of box traps were active on the property throughout 2017 and 32 pigs were caught and disposed of on site. Eighteen of the pigs caught were males and 14 were females. Feral pig control will continue in 2018 as needed.

4.3 GRAZING The project's Resource Management Plan (LSA May 16, 2002; RMP) includes grazing as a grassland management tool for providing for dispersal of young whipsnakes in the fall and, secondarily, for potential whipsnake breeding/egg laying in the spring. In accordance with the RMP, grazing continued in remote open space areas (i.e., away from the golf course and other developed areas) in 2017.

In the spring of 2017, LSA biologists analyzed grassland monitoring data (grass height and estimate residual dry matter (RDM) measurements) collected at 15 monitoring sites (five in Parcel A and ten in Section 32) on April 26. Evidence of grazing use was found to be moderate to light at the monitoring sites. Robel pole readings using the visual obstruction measurement method ranged from 4 to 18-inches and estimated RDM measurements averaged 900 to 1,500 pounds per acre at 14 of the monitoring sites. One (1) of the monitoring sites, located near a water source, had RDM measurements as low as 700 pounds per acre during the April visit. However, grazing pressure was localized within this area and generally not representative of the remaining open space. Due to the low number of cattle present within the grazed areas and acceptable monitoring results, the grazing of Parcel A and Section 32 was prescribed throughout the summer. Grazing through the summer months is intended to reduce the build-up of thatch throughout the open space areas to reduce

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wildfire loads. The resulting reduction in grass thatch is also anticipated to increase overall grassland productivity.

A second qualitative assessment of the grazing areas was conducted on August 24, 2017. RDM levels observed during the August visit were lower than those observed during in April visit however still above the targets set by the RMP for November through March (2 to 4 inch Robel readings and RDM levels of 800 pounds per acre). Estimated RDM measurements during this visit ranged from 1,000 to 1,500 pounds per acre. Because of the moderate to high RDM levels observed during in August, grazing continued at the site for the remainder of 2017.

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5.0 SUMMARY OF RECOMMENDATIONS

The following is a summary of measures recommended for maintaining or improving the performance of mitigation features and other habitats at Stonebrae in 2018.

Mitigation Seasonal Wetlands

• Continue to monitor and document the effects of precipitation levels in 2018 on hydrology.

• Continue mowing/grazing and spraying of Harding grass and stinkwort within the mitigation wetlands and prescribe additional treatments as necessary.

• Expand invasive plant species control efforts for problematic weed species including fennel (Foeniculum vulgare), bull thistle (Cirsium vulgare), Italian thistle (Carduus pycnocephalus) and milk thistle (Silybum marianum) in upland areas.

Riparian Enhancement/Channel Restoration

• Monitor riparian plantings and biotechnical structures within riparian areas. Augment riparian plantings to promote woody riparian vegetation establishment as needed.

• Employ electric fencing as warranted to protect riparian areas if livestock are grazed outside of the standard grazing season allowed in the RMP.

• Monitor the repaired area at Reach C East (C2a-d) below the City’s 1530 water tank outfall for any new erosion.

• Monitor for continued erosion at Reach B South (B8c). Implement appropriate restoration within this section of reach as necessary.

Rock Outcrops/Scrub Enhancement Zones

• Continue weed abatement at mitigation rock outcrops within the golf course open space area. Nonnative thistles and grass should be cleared from the rock piles prior to going to seed.

Weed Abatement

• Continue to implement weed abatement in and adjacent to mitigation areas in the golf course and open space.

Feral Pig Control

• Continue to implement feral pig control in the golf course and open space areas on an as needed basis.

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6.0 REFERENCES

Crother, B.I. (ed). 2008. Scientific and Standard English Names of Amphibians and Reptiles of North America North of Mexico, pp. 1-84. SSAR Herpetological Circular 37.

LSA Associates, Inc. (LSA). May 16, 2002. Mitigation and Monitoring Plan for Blue Rock Country Club (Corps File No. 21586S).

LSA Associates, Inc. (LSA). May 16, 2002. Blue Rock Habitat Areas Resource Management Plan.

Stebbins, R.C. 2003. A Field Guide to Western Reptiles and Amphibians. Third edition. Houghton Mifflin Co. Boston, Massachusetts.

United States Fish and Wildlife Service (USFWS). July 12, 2002. Formal Consultation (Biological Opinion) on the Proposed Blue Rock Country Club Project, Hayward, Alameda County, California (Corps File No. 21586S).

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APPENDIX A

MITIGATION MONITORING AND REPORTING PROGRAM

SUMMARY TABLE

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Mitigation Monitoring and Reporting Program (MMRP) Summary Table – Stonebrae Country Club, 2017 Annual Report

Mitigation Measure Source Implementation Schedule

Responsible Party Status / Date / Initials

1 Permittee shall immediately notify the Department in writing if it determines that any of the mitigation measures were not implemented during the period indicated in the MMRP, or if Permittee anticipates for any reason that measures may not be implemented within the time period indicated.

Permit Entire project Permittee Mitigation measures are being implemented. 2:1 mitigation construction is complete; performance monitoring and management is ongoing.

2 For the duration of construction activities, Permittee shall conduct compliance inspections at least once a week to assess compliance with all construction-phase impact minimization and mitigation measures, especially those requiring creation and maintenance of exclusion zones.

Permit During construction Permittee Not applicable – No applicable construction in 2017

3 Every month for the duration of construction activities, Permittee shall provide the Department with a written Compliance Report to communicate observations made during compliance monitoring, as well as other information obtained by Permittee.

Permit During construction Permittee Full compliance through 12/07. With completion of first phase of project construction, monthly reports ceased in 2008.

4 Beginning with issuance of the Permit and continuing for the life of the project, Permittee shall provide the Department an annual Status Report no later than January 31 of every year. Each Status Report shall include, at a minimum: 1) a general description of the status of the project, including actual or projected completion dates, if known; 2) a copy of the attached table with notes showing the current implementation status of each mitigation measure; and 3) an assessment of the effectiveness of each completed or partially completed mitigation measure in minimizing and compensating for project impacts.

Permit Entire project Permittee First annual report submitted to Department 1/31/05. Second annual report submitted 1/31/06. Third annual report submitted 1/31/07. Fourth annual report submitted 1/31/08. Fifth annual report submitted 1/31/09. Sixth annual report submitted 1/31/10. Seventh annual report submitted 1/31/11. Eighth annual report submitted1/31/12. Ninth annual report submitted 4/28/13. Tenth annual report submitted 3/20/14. Eleventh annual report submitted 1/30/15. Twelfth annual report submitted 3/21/16. Thirteenth annual report submitted 3/15/17.

5 No later than 45 days after completion of the project, including completion of all mitigation measures, Permittee shall provide the Department with a Final Mitigation Report. The Final Mitigation Report shall be prepared by a knowledgeable, experienced biologist and shall include, at a minimum: 1) a copy of the attached table with notes showing when each of the mitigation measures was implemented; 2) all available information about project-related incidental take of species named in the Permit; 3) information about other project impacts on the species named in the Permit; 4) construction dates; 5) an assessment of the effectiveness of each mitigation measure in minimizing and compensating for project impacts; 6) recommendations on how mitigation measures might be changed to more effectively minimize and mitigate the impacts of future projects on the species; and 7) any other pertinent information. Permittee’s monitoring and reporting obligations under this MMRP will end only after the Department accepts the Final Mitigation Report as complete.

Permit Post-project Permittee The golf course has been completed and has been operational since 2007. Portions of the residential area have been completed and rough grading and infrastructure has been completed for the remainder of the development area. Habitat mitigation actions (grading, planting, etc.) have been implemented to achieve mitigation commitments pending successful performance. On-going performance is being monitored and will continue to at least 2019 in order to complete the minimum 10 year performance standards.

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Mitigation Measure Source Implementation Schedule

Responsible Party Status / Date / Initials

6 The Department accepts the Final Mitigation Report as complete. Permit Post-project Department of Fish and Game

Monitoring is ongoing; Final Mitigation Report not submitted.

7 The Department may, at its sole discretion, verify compliance with any mitigation measure or independently assess the effectiveness of any mitigation measure.

Permit Entire project Department of Fish and Game

8 Permittee shall fully cooperate with the Department in its efforts to verify compliance with or effectiveness of mitigation measures.

Permit Entire project Permittee Ongoing – annual reports have been provided.

9 Permittee shall submit annually a snake barrier fencing plan, trapping protocol, and take avoidance protocols for review and approval by the Department prior to any ground disturbing activities.

Permit During construction Permittee 2003: See 1/8/04 report to CDFG. 2004: Swaim trapping protocol approved by CDFG 2/4/04; LSA protection protocols approved 5/17/04. Condition completed by 2007.

10 Permittee shall install snake barrier fencing in place no later than March 31 of each year that trapping occurs and in each that mass grading adjacent to scrub habitat occurs.

Permit During construction Permittee Installation completed by 3/31/04. Monitoring and maintenance discontinued in 2007 due to completion of mass grading adjacent to scrub habitat. Some sections removed near golf course in 2007.

11 In areas where sections of scrub habitat must be cleared for the installation of snake barrier fencing, all scrub habitat to be cleared for this purpose shall first be inspected by a permitted biologist to identify and avoid any impacts to Alameda whipsnakes and shall then be cleared with the use of hand tools such as axes, machetes, and chain saws.

Permit During construction Permittee Full compliance when fence installed in 2004.

12 All trapping for Alameda whipsnakes in areas described in the Department approved trapping protocol shall occur prior to initiation of grading or other project construction. Trapping shall be initiated between April 10 and September 15 unless otherwise approved by the Department. Trapping in grassland habitat and grassland with rock outcrops shall occur for a minimum of 30 days immediately prior to the initiation of grading or other project construction. Trapping in scrub habitat will occur for a minimum of 35 days immediately prior to initiation of grading or other project construction.

Permit During construction Permittee Full compliance with pre-construction trapping in 2004. No new whipsnake territory affected by construction since 2006, therefore pre-construction trapping was not required in 2017.

13 Grading activities including clearing and grubbing to remove all surface vegetation, burrows, and rock outcrops in areas where fencing or trapping has occurred shall be completed at the location of each individual trap line within 2 days of removal of the trap line equipment.

Permit During construction Permittee No such activity occurred in 2017 in areas where fencing or trapping occurred.

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Mitigation Measure Source Implementation Schedule

Responsible Party Status / Date / Initials

14 A biological monitor shall be present in areas where clearing and grubbing of the project site is occurring and whenever mass grading activities area being conducted in areas adjacent to scrub habitat. The biological monitor shall have the authority and ability to halt grading and other construction activities as necessary to move to a safe location any Alameda whipsnakes encountered. The biological monitor shall be given any equipment necessary to communicate with grading personnel to ensure that the monitor can immediately stop work, if necessary, during grading activities.

Permit During construction Permittee No grading or grubbing adjacent to scrub occurred in 2017.

15 A biological monitor shall brief the construction crew on the potential presence of Alameda whipsnakes in the project area, and educate onsite workers in the identification and habitat requirements of Alameda whipsnakes, measures implemented to avoid and minimize take of Alameda whipsnakes, including the biological monitor’s authority to halt grading and construction activities, and the ramifications of take of listed species.

Permit During construction Permittee Full compliance. Grading adjacent to scrub habitat completed by 2007.

16 Permittee shall place rock outcrops across the 180 acre habitat area to connect Alameda whipsnake habitat areas and facilitate a movement corridor. Permittee shall also place elevated cart paths over several Alameda whipsnake movement corridors to facilitate movement through the rock outcrop areas to habitat areas. Plans for these activities shall be developed by Permittee in consultation with the Department and shall be reviewed and approved by the Department prior to any grading associated with golf course development.

Permit Entire Project Permittee Plans approved by CDFG 2/04/04. Mitigation rock outcrop construction completed 12/06. Installation of elevated cart paths over corridors completed in 2005. Scrub enhancement augmented with plantings in 2009-2011.

17 Permittee shall permanently conserve 1,021 acres of habitat adjacent to the Project to be managed for Alameda whipsnake. Fee title to the 1,021 acres may be transferred to an entity approved by the Department after conservation easements over the property are recorded. Permittee shall also establish a conservation easement over 180 acres of habitat within the golf course boundary to permanently conserve the area. Fee title to the 180 acres may be transferred to an entity approved by the Department after conservation easements over the property are recorded.

Permit Entire project Permittee Ongoing (See #18)

18 Permittee shall record conservation easements to preserve in perpetuity all on-site and off-site habitats set aside for the protection of Alameda whipsnakes and their habitat prior to any groundbreaking, grading, or equipment staging, including that relating to construction of all lots, roads, and utility construction. The conservation easements shall be approved by the Department and the Service prior to recording. The easement shall be held by the Department or an entity approved by the Department that is eligible under state law to hold conservation easements. The easement shall include a list of prohibited activities that are inconsistent with the maintenance of the preserve for the listed species.

Permit Entire Project Permittee An Offer to Dedicate that provides for placement of USFWS- and CDFG-approved conservation easements over the habitat areas was recorded 11/03/04. The final Conservation Easement language is under CDFG review.

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S T O N E B R A E C O U N T Y C L U B H A Y W A R D , A L A M E D A C O U N T Y , C A L I F O R N I A

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Mitigation Measure Source Implementation Schedule

Responsible Party Status / Date / Initials

19 Permittee shall enter into a formal agreement with a Department and Service-approved preserve manager to implement a Management Plan described below. Implementation of a Management Plan shall begin no later than the start of project groundbreaking.

Permit Entire Project Permittee Per minor amendment to 2081 issued by CDFG on September 1, 2004, Permitee entered into an Agreement prior to the issuance of the first building permit. LSA is acting as interim preserve manager.

20 Permittee shall prepare a Management Plan for the on-site endangered species habitat protection areas for review and approval by the Department and the Service prior to groundbreaking.

Permit Entire Project Permittee The Mitigation and Monitoring Plan (finalized in 2002) includes a Management Plan.

21 Permittee shall establish an adequate endowment fund or other Department approved funding mechanism for monitoring and perpetual management and maintenance of the 1,021 acre and 180 acre conserved habitat areas. The principal in the endowment shall be non-wasting and sufficient to generate enough revenue to cover the costs as outlined in a Department approved Management Plan. This endowment shall be provided to the Department. Specific actions covered under the endowment shall be addressed in a Department approved Management Plan.

Permit Entire Project Permittee Per minor amendment to 2081 issued by CDFG on September 1, 2004, the endowment was fully funded by April 1, 2006.

22 Trails shall not be enhanced, modified, or constructed within open space areas of the project without prior review and approval from the Department of an appropriate take avoidance program. Routine maintenance of existing trails shall not require approval and implementation of a take avoidance protocol.

Permit Entire Project Permittee/ Preserve Manager

No new trails have been constructed or enhanced.

23 Prior to groundbreaking, Permittee shall deliver to the Department security in a form approved by the Department to ensure funding for compliance and effectiveness of required monitoring and reporting. The security shall be delivered to the Department’s General Counsel for approval as to form. The term of the security shall be for a period of not less than the term of this permit. Security shall be returned to the permittee following completion and funding of the actions identified.

Permit Entire Project Permittee Security was issued to CDFG’s satisfaction 8/20/04 and renewed in 2007.