HomeMy Public PortalAboutResolution - 22-48- 20221109 - RWC FEIRRESOLUTION NO. 22-48
RESOLUTION CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT,
MAKING CERTAIN FINDINGS OF FACT, APPROVING A STATEMENT OF
OVERRIDING CONSIDERATIONS, AND A MITIGATION MONITORING AND
REPORTING PLAN APPROVING THE REDWOOD CABIN REMOVAL PROJECT
WHEREAS, the Midpeninsula Regional Open Space District (the District) is a lead
agency, as provided for under §21067 of the California Environmental Quality Act; and
WHEREAS, the District desires to approve the Redwood Cabin Removal Project
(Project); and
WHEREAS, the District determined that the Project may have a significant effect on the
environment and concluded that an environmental impact report (EIR) would be needed to
satisfy the requirements of the California Environmental Quality Act with respect to informing
the public and the Board of Directors of the Midpeninsula Regional Open Space District (Board
of Directors) as to the environmental impacts, mitigating measures, and alternatives to said
Project; and
WHEREAS, a Notice of Preparation (NOP) was filed with the California Office of
Planning and Research on June 9, 2021 and distributed to involved public agencies and
interested parties for a 30 -day public review period that concluded on July 9, 2021, to initiate the
EIR process and collect written comments on the scope of issues to be addressed in the Draft
EIR; and
WHEREAS, a public scoping meeting was held on June 23, 2021 to gather public input
on the environmental issues to be addressed in the Draft EIR; and
WHEREAS, a Notice of Availability and Notice of Completion of a Draft EIR were
published on April 14, 2022; and
WHEREAS, a public hearing on the Draft EIR was held on April 27, 2022 to gather
public comments on the Draft EIR; and
WHEREAS, the Draft EIR was circulated for a 45 -day period that concluded on May 31,
2022; and
WHEREAS, during the public review period, the District received written comments on
the Draft EIR, and responses to these comments have been prepared and included in the Final
Environmental Impact Report for the Project ("Final EIR"), as follows, and attached hereto and
incorporated herein as Exhibit A:
a) The Draft EIR, including all of its appendices,
b) A list of persons, organizations, and public agencies commenting on the Draft EIR,
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Resolutions/2022/R-22-48 RWC FE1R
c) Copies of all letters received by the District during the Draft EIR public review period
and responses to significant environmental concerns in the Draft EIR raised in the
review process,
d) Revisions to the Draft EIR; and
WHEREAS, the EIR identified certain impacts that have the potential to be significant,
but are mitigated to a less than significant level through adoption and implementation of the
mitigation measures proposed as part of the Project and the monitoring requirements included in
the Mitigation Monitoring and Reporting Program ("MMRP"); and
WHEREAS, the Board's adoption of the MMRP, which is attached hereto as Exhibit C
and incorporated herein by reference, will ensure that all mitigation measures relied on in the
findings are fully implemented; and
WHEREAS, certain Project impacts related to historic resources would remain
significant and unavoidable, even after the application of all feasible mitigation measures to
lessen these impacts, due to the demolition of the Redwood Cabin that is eligible for individual
listing on the California Register of Historic Resources, resulting in a significant impact to
cultural resources, which cannot be fully mitigated; and
WHEREAS, CEQA requires that the District determine whether specific economic,
legal, social, technological, or other considerations may outweigh any significant, unavoidable
environmental effects of the Project, which cannot be fully mitigated; and
WHEREAS, staff has analyzed such benefits and summarized them in the Statement of
Overriding Considerations, attached hereto and incorporated herein as Exhibit B:
WHEREAS, on October 28, 2022, the Final EIR was published and addressed all
comments raised on the environmental issues associated with the project; and
WHEREAS, on November 9, 2022, the Board of Directors, as lead agency under the
California Environmental Quality Act, now finds that:
1. Notice has been given in the time and in the manner required by state law, and
2. The Final EIR for the Redwood Cabin Removal Project was presented to the Board of
Directors. The Board of Directors has independently reviewed and considered the
information contained in the Final EIR, including comments received from the public,
before approving the Redwood Cabin Removal Project or any elements thereof, and
3. The Final EIR was completed in compliance with the California Environmental
Quality Act and is attached hereto as Exhibit A and incorporated herein by this
reference, and
4. The Final EIR identifies all potentially significant environmental impacts of the
Project, specifically, potentially significant impacts to Biological Resources and
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Cultural Resources, which impacts can and will be avoided or Mitigated to a less than
significant level through adoption and implementation of the mitigation measures
proposed as part of the Project and included in the MMRP, which is attached hereto
as Exhibit C and incorporated herein by this reference; and
5. The Final EIR identifies certain impacts of the Project related to Cultural Resources
that will remain significant and unavoidable, even after the application of all Project
mitigation measures to lessen those impacts, as discussed in the Statement of
Overriding Considerations, which is attached hereto as Exhibit 13 and incorporated
herein by this reference; and
6. The Final EIR reflects the Board of Directors' independent judgment and analysis.
BE IT RESOLVED AND CERTIFIED by the Board of Directors that the Board hereby
acts as follows:
A. Directs that the Clerk of the Board and the District are collectively designated as the
location and custodian of the documents and other material constituting the record of
proceedings upon which this decision is based; and
B. Determines that the social, recreational, environmental, and other benefits of the
Project described herein and in the Statement of Overriding Considerations outweigh
the unavoidable environmental impacts, and so the environmental impacts are
acceptable; and
C. Certifies the Final EIR for the Project and adopts the MMRP; and
D. Adopts the Findings of Fact and Statement of Overriding Considerations; and
E. Approves the Redwood Cabin Removal Project.
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
PASSED AND ADOPTED by the Board of Directors of the Midpeninsula Regional
Open Space District on November 9, 2022, at a regular meeting thereof, by the following vote:
AYES: CYR, ITASSETT, IIOLMAN, KERSTEEN-TUCKER, RIFFLE, SIEMENS
NOES: NONE
ABSTAIN: NONE
ABSENT: KISHIMOTO
ATTEST:
,61/ce.c.,
Karen Holman, Secretary
Board of Directors
APPROVED:
Zoe Kersteen-Tucker, President
Board of Directors
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Rcsolulions/2O22/R-22-46 RWC FHB
APPROVED AS TO FORM:
Hilary Stevenson, General Counsel
I, the Deputy District Clerk of the Midpeninsula Regional Open Space District, hereby
certify that the above is a true and correct copy of a resolution duly adopted by the Board of
Directors of the Midpeninsula Regional Open Space District by the above vote at a meeting
thereof duly held and called on the above day.
EXHIBITS TO THIS RESOLUTION
Exhibit A:
Exhibit B:
Exhibit C:
•
aria Soria, Deo aria Deputy District Clerk
Redwood Cabin Removal Project Final Environmental Impact Report
Findings of Fact and Statement of Overriding Considerations
Mitigation Monitoring and Reporting Program
4
Resolu2ions,2G22:R-22=19 RWC WEIR
FINAL ENVIRONMENTAL IMPACT REPORT
Redwood Cabin Removal Project
Prepared for
Midpeninsula Regional Open Space District
5050 El Camino Real
Los Altos, CA 94022
October 21, 2022
Exhibit A
FINAL ENVIRONMENTAL IMPACT REPORT
Redwood Cabin Removal Project
Prepared for:
Midpeninsula Regional Open Space District
5050 El Camino RealLos Altos, CA 94022
Prepared by
Ascent Environmental, Inc.
455 Capitol Mall, Suite 300
Sacramento, CA 95814
October 21, 2022
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Final EIR i
TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS ........................................................................................................................................................................... II
1 INTRODUCTION ........................................................................................................................................................................ 1-1
1.1 Purpose and Intended Uses of this Final EIR ............................................................................................................1-1
1.2 Project Location ..................................................................................................................................................................1-1
1.3 Project Objectives .............................................................................................................................................................. 1-4
1.4 Summary Description of the Project ........................................................................................................................... 1-4 1.5 Major Conclusions of the Environmental Analysis ................................................................................................. 1-4
1.6 CEQA Public Review Process ......................................................................................................................................... 1-5
1.7 Organization of the Final EIR ......................................................................................................................................... 1-5
2 RESPONSES TO COMMENTS .................................................................................................................................................2-1
2.1 List of Commenters on the Draft EIR .......................................................................................................................... 2-1
2.2 Comments and Responses ............................................................................................................................................. 2-1
3 REVISIONS TO THE DRAFT EIR ..............................................................................................................................................3-1
4 REFERENCES .............................................................................................................................................................................. 4-1
5 LIST OF PREPARERS ..................................................................................................................................................................5-1
Figures
Figure 1-1 Project Vicinity and Location ......................................................................................................................................... 1-2
Figure 1-2 Project Site ........................................................................................................................................................................... 1-3
Appendices
Appendix A Comments Received on the Draft EIR
Exhibit A
List of Abbreviations Ascent Environmental
Midpeninsula Regional Open Space District ii Redwood Cabin Project Final EIR
LIST OF ABBREVIATIONS
Board Board of Directors
CEQA California Environmental Quality Act
CRHR California Register of Historical Resources
Draft EIR draft environmental impact report
Final EIR final environmental impact report
GHG greenhouse gas
HABS Historic American Building Survey
Midpen Midpeninsula Regional Open Space District
Preserve La Honda Creek Open Space Preserve
project Redwood Cabin Removal Project
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Final EIR 1-1
1 INTRODUCTION
This final environmental impact report (Final EIR) has been prepared by Midpeninsula Regional Open Space District
(Midpen), as lead agency, in accordance with the requirements of the California Environmental Quality Act (CEQA)
and the State CEQA Guidelines (CCR Section 15132). This Final EIR contains responses to comments received on the
draft environmental impact report (Draft EIR) for the Redwood Cabin Removal Project (project). The Final EIR consists of the Draft EIR and this document (response to comments document), which includes comments on the Draft EIR
and responses to those comments.
1.1 PURPOSE AND INTENDED USES OF THIS FINAL EIR
CEQA requires a lead agency that has prepared a Draft EIR to consult with and obtain comments from responsible
and trustee agencies that have jurisdiction by law with respect to the project, and to provide the public with an
opportunity to comment on the Draft EIR. The Final EIR is the mechanism for responding to these comments. This
Final EIR has been prepared to respond to comments received on the Draft EIR, which are reproduced in this
document. The Final EIR will be used to inform Midpen’s decision regarding whether to approve or disapprove the
Redwood Cabin Removal Project.
This Final EIR will also be used by CEQA responsible and trustee agencies to ensure that they have met their
requirements under CEQA before deciding whether to approve or permit project elements over which they have
jurisdiction. It may also be used by other state, regional, and local agencies that may have an interest in resources
that could be affected by the project or that have jurisdiction over portions of the project.
Responsible, trustee, and interested agencies may include:
State Water Resources Control Board / San Francisco Bay Regional Water Quality Control Board
County of San Mateo
Bay Area Air Quality Management District
1.2 PROJECT LOCATION
The Redwood Cabin is situated within the upper portion of the La Honda Creek Open Space Preserve (Preserve). The
Preserve encompasses 6,142 acres in the Santa Cruz Mountains within unincorporated San Mateo County,
approximately 5 miles east of the Pacific Ocean (see Figure 1-1). The Preserve is bounded by Highway 35 (Skyline
Boulevard) to the north, by Highway 84 (La Honda Road) to the east and south, and by Bogess Creek to the west.
The Redwood Cabin occupies a portion of Assessor’s Parcel Number 075-330-260 and is located west of the
community of Skylonda, California. The project site is designated for Forest/Timber Production land uses under the San Mateo County General Plan and is zoned as Timber Land Preserve District under the San Mateo County Zoning
Ordinance. Access to the Redwood Cabin is provided via an unpaved road accessible from Skyline Boulevard, which
travels through two locked gates; the area surrounding the Redwood Cabin is closed to public access. The final
segment of this unpaved road requires a four-wheel drive vehicle or access by foot (see Figure 1-2); access roads
leading to the Redwood Cabin are not open to public use.
The project site is located in a wooded area within the northernmost portion of the Preserve that is currently not
open to the public. The building is situated atop sloped terrain overlooking a circular dirt driveway that surrounds a small grove of redwood trees.
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-2 Redwood Cabin Project Final EIR
Source: Data received from Midpeninsula Regional Open Space District in 2020
Figure 1-1 Project Vicinity and Location
Exhibit A
Ascent Environmental Introduction
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 1-3
Source: Data received from Midpeninsula Regional Open Space District in 2021
Figure 1-2 Project Site
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-4 Redwood Cabin Project Final EIR
1.3 PROJECT OBJECTIVES
The proposed project is intended to achieve the following primary objectives, in alignment with Midpen’s mission:
Remove physical hazards to ensure public safety,
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate surroundings,
Reduce structure and wildland fire risk by removing a structure with a history of vandalism,
Improve natural visual character and scenic open space qualities at the site, and
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district.
1.4 SUMMARY DESCRIPTION OF THE PROJECT
The project would entail demolition of the Redwood Cabin and removal of associated features onsite, including the stone retaining walls and barbeque and fire pits. Prior to demolition activities, lead-based paint present within the
structure would be properly removed and disposed of.
While it is expected that excavation of posts and bases associated with the structure would be approximately 2 feet
below grade, it is possible that maximum depth of excavation could reach up to 5 feet. During demolition of the
structure, it is estimated that approximately 60 tons of material would be removed from the project site (ZFA 2020).
Tree removal will not be required to facilitate demolition activities, although some brush clearing along the access
road may be necessary.
Following completion of demolition activities, disturbed areas would be recontoured and erosion control applied to
the site to ensure adequate site drainage. All demolition and recontoured areas would be compacted to 75 percent
relative compaction. Native grass seed mix would be spread in the disturbed areas and weed free or native grass
straw would be placed in the disturbed areas, on top of the native grass seed mix, to assist with soil stabilization and
erosion control. Any wood chips or mulch generated from unsalvageable building materials may also be used to stabilize disturbed areas but will not be more than 3 inches in depth. Midpen may also conduct the following activities on the project site after demolition and recontouring:
soil decompaction activities outside of critical rootzones,
soil testing and, if needed, spot application of amendments such as fertilizers, lime, or organic materials, and
revegetation or plantings.
Midpen also conducts early detection rapid response surveys for up to 3 years at revegetation sites and treats any invasive plant species on the early detection rapid response list. Other priority integrated pest management target
species, including slender false brome may be treated before and after construction. Slender false brome is an
invasive weed of high concern at the project site; due to Midpen’s mandatory quarantine of this weed, all slender
false brome in the area will be treated before any work being completed.
Current activity at the project site consists of occasional visits from Midpen staff for inspections. Once removal of
the structure and site recontouring/erosion control activities are complete, no additional maintenance or
operational activities would be required at the project site except for invasive plant species treatment, if needed.
The site would remain closed to the public.
1.5 MAJOR CONCLUSIONS OF THE ENVIRONMENTAL ANALYSIS
The Draft EIR identified the following significant impacts related to the project. Potentially significant impacts, which
implementation of feasible mitigation measures would reduce to a less-than-significant level, were identified for
biological resources (special-status species and associated habitats) and archaeological resources.
Exhibit A
Ascent Environmental Introduction
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 1-5
Significant impacts were identified for cultural resources for which further mitigation is not available and the impact
remains significant and unavoidable. Specifically, the proposed project would result in demolition of a structure that
has been recommended eligible for listing in the California Register of Historical Resources. Although mitigation
measures require documentation of the building before removal, because the building would be lost, the impact is
considered significant and no additional feasible mitigation measures are available. This is also considered a
significant contribution to a cumulative impact.
See Section 3.1, “Cultural Resources” and Section 3.2, “Biological Resources” of the Draft EIR for a more detailed
summary of the impact conclusions and mitigation measures identified.
1.6 CEQA PUBLIC REVIEW PROCESS
On April 14, 2022, Midpen released the Draft EIR for a 45-day public review and comment period. The Draft EIR was
submitted to the State Clearinghouse for distribution to reviewing agencies; posted on Midpen’s website
(https://www.openspace.org/who-we-are/public-notices); and was made available at Midpen’s Administrative Office
and the Woodside Library. A notice of availability of the Draft EIR was published in the Half Moon Bay Review and the
Bay Area News Group.
A public hearing was held on April 27, 2022, to receive input from agencies and the public on the Draft EIR. The
hearing was held during Midpen’s regularly scheduled Board of Director’s (Board) meeting at 7:00 p.m. The hearing
was recorded and is available at https://www.openspace.org/about-us/meetings/bod-20220427.
As a result of these notification efforts, written and verbal comments were received from individuals and members of
the Board on the content of the Draft EIR. Chapter 2, “Responses to Comments,” identifies these commenting parties,
their respective comments, and responses to these comments. None of the comments received, or the responses
provided, constitute “significant new information” by CEQA standards (State CEQA Guidelines CCR Section 15088.5).
1.7 ORGANIZATION OF THE FINAL EIR
This Final EIR is organized as follows:
Chapter 1, “Introduction,” describes the purpose of the Final EIR, summarizes the Redwood Cabin Removal Project
and the major conclusions of the Draft EIR, provides an overview of the CEQA public review process, and describes
the content of the Final EIR.
Chapter 2, “Responses to Comments,” contains a list of all parties who submitted comments on the Draft EIR during
the public review period, copies of the comment letters received, and responses to the comments, including those
received during the public hearing.
Chapter 3, “Revisions to the Draft EIR,” presents minor revisions to the Draft EIR text made to correct typographical
errors. Changes in the text are signified by strikeouts where text is removed and by underline where text is added.
Chapter 4, “References,” identifies the documents used as sources for the analysis.
Chapter 5, “List of Preparers,” identifies the lead agency contacts as well as the preparers of this Final EIR.
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-6 Redwood Cabin Project Final EIR
This page intentionally left blank.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Final EIR 2-1
2 RESPONSES TO COMMENTS
This chapter contains comment letters received during the public review period for the Draft EIR, which concluded on
5/31/2022, including comments received during the 4/27/2022 Board of Directors public hearing. In conformance
with Section 15088(a) of the State CEQA Guidelines, written responses were prepared addressing comments on
environmental issues received from reviewers of the Draft EIR.
2.1 LIST OF COMMENTERS ON THE DRAFT EIR
Table 3-1 presents the list of commenters, including the numerical designation for each comment letter received, the
author of the comment letter, and the date of the comment letter.
Table 3-1 List of Commenters
Letter No. Commenter Date
INDIVIDUALS
I1 John and Shannon Harney April 18, 2022
I2 Sheila Brady April 26, 2022
I3 Maureen O'Connor May 18, 2022
I4 Laura Jones May 30, 2022
I5 Shani Kleinhaus May 31, 2022
PUBLIC HEARING ON THE DRAFT EIR (4/27/2022)
PH1 Board Member 1 —
PH2 Board Member 2 —
PH3 Board Member 3 —
2.2 COMMENTS AND RESPONSES
The verbal and written individual comments received on the Draft EIR and the responses to those comments are
provided below. The comment letters and verbal comments made at the public hearing are reproduced in their
entirety and are followed by the response(s). Where a commenter has provided multiple comments, each comment is
indicated by a line bracket and an identifying number in the margin of the comment letter. Written comments are
also provided in Appendix A.
2.2.1 Individuals
Letter I1 John and Shannon Harney
April 18, 2022
Comment I1-1 We are opposed to the cabin removal APN:075-330-260. There are only a handful of these cabins left. The owners
new what they had. They need to put money into it like the other owners of other historic cabins in Skylonda have.
Thanks.
Response I1-1 The comment expresses opposition to the removal of the Redwood Cabin and advocates for the investment of
historic cabins; the comment does not address the adequacy of the Draft EIR analysis.
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-2 Redwood Cabin Project Final EIR
Midpen completed an assessment of various alternatives for the Redwood Cabin with estimated costs, which was
presented to the Board of Directors in April 2020. After considering the remote nature of the site, the public safety
and fire risk concerns, as well as costs for the various alternatives, the Board of Directors directed the General
Manager to evaluate the environmental effects that would result from removing the Redwood Cabin. The Draft EIR
includes an evaluation of the potential impact of the project on historic resources (see Impact 3.2-3 in Section 3.2,
“Cultural Resources”) and concludes that the impact is significant and unavoidable. The comment is included in the
record.
Letter I2 Sheila Brady
April 26, 2022
Comment I2-1 When I heard about the "Reimagining of Big Basin" project, I forwarded the Page & Turnbull, Inc. Historic Resource
Evaluation to assess the Redwood Cabin’s eligibility for listing in the California Register of Historical Resources (CRHR). I
received a note back from the Reimagining Big Basin Team describing the idea of re-locating the cabin to Big Basin as
an intriguing suggestion. You can see the notes regarding this in the appendix at the bottom of this email.
I do not know if further evaluation of that possibility was ever completed. I have copied both the Reimagine Big Basin
team and the Midpen team on this note. It would be great if there was an assessment of whether it could make any
sense to relocate the Log Cabin to Big Basin thus in one move, save a historic cabin, and replace some of the
wonderful historic architecture that we lost in the Big Basin fire.
I realize that there would probably need to be an initial assessment of deconstructing, moving, and reconstructing
the cabin in Big Basin and I’d be willing to spearhead fundraising to get that assessment done.
I think that the fact that it is within current memory that rustic houses like the Old Redwood Cabin were heavily in use
is important to realize and remember. We take so much for granted about the ease of our existence. It is good to
share the tactile memories that a house like this one elicits with our children. And the history of the hard work and courage that it took to build on this land is also an important memory to cherish and respect. There is something
about looking at the axe strokes on the end of a log, one of many that make up a building, which says much more
than words about how tough it is to survive on the land. Just as a lot of the excellent discussion in the Reimagining Big Basin project centered around the importance of integrating the Native American experience of caring for the
land and recognition of the intelligent land and wildlife management used by the native tribes, I think that replacing the old Big Basin cabins which were destroyed in the fire with another cabin of the same age will help us to tie
ourselves to that history and recognition of that age.
Response I2-1 The comment proposes that the Redwood Cabin be moved to Big Basin Redwoods State Park as part of the
“Reimagining of Big Basin” project; the comment does not address the adequacy of the Draft EIR analysis. Midpen
staff recently spoke with staff from California State Parks (State Parks) to discuss if their agency would have interest in
relocating the cabin to Big Basin Redwoods State Park. While they appreciated the idea, State Parks affirmed that they are not interested in relocating the cabin to Big Basin. State Parks staff stated that they are currently undergoing
a planning process to reimagine Big Basin following the 2020 CZU lightning complex fire and that relocation of the
cabin to Big Basin Redwoods State Park would be inconsistent with Reimagining Big Basin project’s guiding principles
established through the visioning process, particularly related to the desired location of new buildings and goals
around the future resiliency of new buildings. Given the fire risk in the region, and the devastating fire loss
experienced in the CZU Fire, new structures at Big Basin Redwoods State Park are now planned to be fire resistant to
minimize loss in the event of future fire.
The Draft EIR’s alternatives analysis (Chapter 4) identifies a “Relocate and Stabilize” alternative that would involve relocation of the structure either within La Honda Creek Open Space Preserve or to a site not owned by Midpen. As
discussed on page 4-3 of the Draft EIR, in order to retain the structure’s historic integrity and therefore its eligibility for listing in the CRHR, the new site would have to be in a forested setting, similar to the current location. The
“Relocate and Stabilize” alternative was considered but dismissed from further evaluation because it contradicts one
Exhibit A
Ascent Environmental Responses to Comments
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 2-3
project objective and fails to meet a second objective. Relocating the structure to another forested setting contradicts
Objective 2, enhance habitat at the Redwood Cabin site and immediate surroundings, because preparing a new
building site for the Redwood Cabin would likely disturb and impact new areas of undisturbed, natural forested
habitat. This could result in significant impacts to biological resources. Objective 6, implement a fiscally sustainable
project, would not be met because relocating the cabin would significantly increase costs to disassemble, move,
prepare new site and reconstruct the building, which would then require additional stabilization improvements to
ensure public safety. Thus, this alternative would not achieve a fiscally sustainable project (see page 4-3 of the Draft
EIR). The comment is included in the record.
Comment I2-2 I also note that it seems that a paragraph is missing in the notice:
https://www.openspace.org/sites/default/files/Notice%20of%20Availability_Draft%20EIR%20for%20Redwood%20Cabi
n%20Removal%20Project.pdf
In paragraph 2 of the section titled “Purpose and Objectives” the cabin is described as:
"The Redwood Cabin appears to be one of few remaining examples of a permanent recreational cabin in the Santa
Cruz Mountains from the 1920s with a high degree of historic integrity— historic integrity refers to a building’s
original character and materials, not the physical condition of the building—and is representative of the peak of
recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1). It is also a unique
example of a rustic recreational cabin in the surrounding area (CRHR Criterion 3).”
This is immediately followed by a paragraph that describes how the cabin was going to be demolished. Isn’t there
something missing there?
A paragraph like, “Unfortunately, in spite of the uniqueness of this cabin as described above, the Midpen Board of Directors has done an evaluation which shows that there is no budget set aside to repair it for use, there is no access
to the area, there is no intention in Midpen’s plans that there will ever be access to the area, and as the uniqueness of
the cabin and its surrounds is a magnet for vandals there is a fear that a fire could be started there where there is no
budget for regular patrols. So Midpen’s Board of Directors have determined that, in spite of its historic significance,
the cabin’s removal and complete destruction is the best thing for the community.”
I apologize if my rewording of the primary objectives of the project doesn’t correctly capture the goals.
My Dad was a City Planner for the City of Berkeley for many years. I fully understand that compromise is the only way
that we can live together and have a civilized society. I realize that with minimal budget Midpen has done and continues to do a great job of protecting the lands and the wildlife of the Midpen districts. I am very grateful for the
efforts and the quality of the fine Midpen rangers I have dealt with over the 27 years I have lived up in Skylonda. The reason that vandals hang out in that cabin or around it, is because it is an intriguing and beautiful piece of our local
history and it is a magical spot. The fire danger is serious and I fully appreciate Midpen’s efforts to protect my community from fire danger, but if the cabin were moved to a place where it would be welcome, and looked after, maybe it would still be able to cast it’s magic spell there?
Thanks very much for giving me the opportunity to comment.
Response I2-2 The comment does not address the adequacy of the Draft EIR analysis, but suggests that text is missing from the
Notice of Availability to explain the considerations taken into account for the potential demolition of a historic
structure. The purpose of a Notice of Availability is to announce that a Draft EIR is available for public review and is
not meant to include all information related to project evaluation and decisions. Though this exact information is not
included in the Notice of Availability, the details are provided in Chapter 2, “Project Description,” of the Draft EIR, on
pages 2-1 and 2-4. Although the Notice of Availability does not contain the suggested text, it does state that there is
no public access to the site (page 3), and that it poses a site safety hazard and has been the site of numerous
trespassing and vandalism incidents, including fire ignitions (page 2).
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-4 Redwood Cabin Project Final EIR
Prior to directing the General Manager to prepare an analysis of the environmental effects of removing the Redwood
Cabin, the Midpen Board of Directors examined various options for the Redwood Cabin. After considering the remote
nature of the site, the public safety and fire risk concerns, as well as costs for the various alternatives, the Board of
Directors then directed the General Manager to evaluate the environmental effects of the proposed project per
CEQA. The comment is included in the record.
Letter I3 Maureen O'Connor
May 18, 2022
Comment I3-1 I was at the HRAB meeting today and appreciated your input on the above referenced project. I went to the EIR
report. It is quite extensive.
I could not find 3.2-1A nor could I find any reference to HAPS or HABS using the search option. I hope you can help
me with this.
Response I3-1 The comment requests assistance with locating information in the Draft EIR; Midpen has replied to this comment via
email. Mitigation Measure 3.2-1a, which outlines the requirements for the Historic American Building Survey (HABS),
can be found on page 3.2-15 of the Draft EIR.
Comment I3-2 Also I have a public comment/suggestion:
The EIR contains some photos of the cabin as it is now. Perhaps Midpen has some additional photos of it now and
also in its early historic period. These could be put into a document to preserve its history in hard copy since it will be
torn down. This document could be given to the Peninsula Library System and to the local historical
museum/association for future reference. The document could include the EIR also since it describes the care that
Midpen took in making the decision to tear it down.
If there is any distinctive hardware still on the property, that could be saved and donated to an historical museum in
the area near it’s former location along with a copy of the document I mentioned earlier.
Response I3-2 The comment suggests steps for preservation documentation. As described on page 3.2-15 of the Draft EIR,
Mitigation 3.2-1a, Document historic buildings prior to removal, includes the compilation of written history, plans and drawings, and photographs to be submitted to the San Mateo County Library, the San Mateo County Historical
Association, the Northwest Information Center, and the Midpen office. Mitigation 3.2-1b, Redwood Cabin
interpretation, would require an interpretive resource document outlining the Redwood Cabin’s historic status,
historic context, and significance. This would include historic photographs, as suggested by the commenter.
Additionally, Mitigation Measure 3.2-1c, Salvage of useable materials, states that if any of the demolished structure
materials are found to be in acceptable condition (i.e., no lead paint, minimal dry rot), Midpen shall reserve materials
for potential future uses and/or salvage. Therefore, the commenter’s recommendations are, in general, already
required as part of the mitigation measures identified in the Draft EIR.
Letter I4 Laura Jones
May 30, 2022
Comment I4-1 I am writing as a friend and neighbor of the District, and as a professional archaeologist and historic preservation
advocate. I am disappointed by the proposal to demolish the cabin, and by the flimsy analysis presented to justify this
action in the DEIR. Although there is insufficient information to support a robust decision-making process in the DEIR, it is clear that the minimum the District should do is to stabilize the hundred-year-old historic log cabin, identified in
the DEIR as the “Environmentally Superior Alternative.”
Exhibit A
Ascent Environmental Responses to Comments
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 2-5
Response I4-1 The commenter believes that even though the Draft EIR contains insufficient information with which to make a decision, Midpen should select the Environmentally Superior Alternative. The commenter does not identify which
information is believed to be missing or what additional information is believed to be necessary in the Draft EIR. The
Draft EIR and Final EIR provide findings of the environmental analysis for the proposed project as well as information
on a variety of project alternatives, including the Environmentally Superior Alternative (see Draft EIR Chapter 4,
“Alternatives,” page 4-6 for a detailed discussion of the Environmentally Superior Alternative).
Comment I4-2 The 2014 Vision Plan clearly identified cultural resources as scenic resources, and as assets that merit preservation.
The Vision Plan includes goals such as
“Protect immediately at-risk, culturally significant resources and promote their responsible stewardship.”
“Maintain a sense of place by protecting and increasing access to locally significant, iconic natural or cultural
features.”
The Draft EIR for the Redwood Cabin Removal Project ignores these goals, which are not included as “project objectives.” Instead, the “project objectives” were carefully engineered to disregard these goals. Two of the objectives
are essentially identical: remove physical hazards and reduce structure and wildfire risk.
Response I4-2 The comment states that the project objectives ignore the objectives of the 2014 Vision Plan. The 2014 Vision Plan is a
long-range overarching plan for all the preserves in Midpen’s jurisdiction. As stated on the title page of the Vision
Plan, “The mission of the Midpeninsula Regional Open Space District is to acquire and preserve a regional greenbelt
of open space land in perpetuity, protect and restore the natural environment, and provide opportunities for
ecologically sensitive public enjoyment and education.” On the coast, Midpen has an expanded mission to acquire
and preserve agricultural land of regional significance, preserve rural character and encourage viable agricultural uses
of land resources. Because the Redwood Cabin poses a safety hazard and has been the site of numerous trespassing
and vandalism incidents (including fire ignitions), the project objectives are designed to implement other goals stated
in the 2014 Vision Plan, including: “Reduce or eliminate safety hazards and promote safe use of the preserves” and “Restore the natural environment, control invasive plants and animals, and limit the spread of pathogens.” In this case, the public safety risk and potential risk of wildfire ignition (which could be detrimental to the surrounding
natural resources and property and community at large) are of greater concern, outweighing the goals for preserving the cultural resource. The comment is included in the record.
Comment I4-3 The analysis in the Draft EIR is internally contradictory on the objective improve scenic qualities. For example, the
cabin is identified as having no scenic value because it cannot currently be seen by the public, but removing it is
assumed to improve scenic open space qualities. If the site has no scenic value because no one sees it, and public
visual access is not a component of the project, then how can scenic value change as a result of the project? The
conclusion that demolishing the historic cabin meets the objective of “improving scenic open space qualities” is not
supported.
Response I4-3 It appears the commenter is referencing the project objective related to improving the natural visual character and
scenic open space qualities at the site (emphasis added). The objective is not focused on preserving the existing built
visual character but on improving the site’s scenic character from a natural and open space perspective—regardless
of the viewer. This differs from the question identified in the Aesthetics section of the Initial Study (included as
Appendix B of the Draft EIR) that relates to visual character or quality of the views as seen by the public of the site
and its surroundings. (The Initial Study defines “public views” as those that are experienced from publicly accessible
vantage points.) Therefore, there is no contradiction, just a different focus.
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-6 Redwood Cabin Project Final EIR
Comment I4-4 A second example of contradictory and unsupported findings occurs in the brief discussion of the “No Project Alternative” where the DEIR finds that “therefore, no impact to biological resources would occur,” but also that “the
No Project Alternative would result in Slightly Greater Impact to biological resources than the proposed project.” This
“slightly greater” impact is due to the lost opportunity to “restore” the site’s natural character. There is no actual
analysis of the relative biological benefits of stabilizing the cabin in place, or relocating it, in contrast to the minimal
restoration activities described in the project description.
Response I4-4 The commenter summarizes the EIR’s discussion related to the project and the No Project Alternative’s impact to
biological resources. The commenter then indicates that there is no actual analysis regarding “relative biological
benefits” associated with stabilizing or relocating the cabin “in contrast to” the restoration activities described in the
EIR’s project description. It is unclear how the commenter’s discussion of the No Project Alternative relates to the
issue raised with the Stabilize Alternative and the Relocation Alternative that was not identified for further evaluation
in the Draft EIR. As described in the Draft EIR on page 4-5, the Stabilize Alternative would be expected to result in a slightly greater impact to biological resources compared to the project (similar to the No Project Alternative) due, in
part, to the lost opportunity in removing a built structure that is located within forested habitat, restoring the building
footprint with native seed, as well as allowing for natural reforestation processes (i.e., natural emergence of native
forest vegetation and tree saplings). As such, the Stabilize Alternative would not provide the long-term opportunity
to improve biological resources that the proposed project does. It should be noted that the alternative envisioning relocation of the cabin was rejected early in the environmental review from further consideration due to the alternative’s inability to meet project objectives (see Draft EIR page 4-3); therefore, a comparison of the
environmental impacts to the project was not provided.
Comment I4-5 The exclusion of the Relocation alternative is also unsupported. The assumption that the site for reinstallation must
be “undisturbed” and therefore would involve significant impacts is not supported by substantial evidence. One can
easily imagine a partially disturbed site in an appropriate setting for the cabin: a parking area next to a trailhead, for
example. The DEIR’s conclusion is unsupported.
Response I4-5 The comment expresses the opinion that the exclusion of the Relocate and Stabilize Alternative is unsupported. As
stated on page 4-3 of the Draft EIR, “In order to retain the structure’s historic integrity and therefore its eligibility for
listing in the [California Register of Historical Resources] CRHR, the site would have to be in a similar setting to the
current location.” A property must have both significance and integrity to be considered eligible for listing in the
CRHR. Loss of integrity, if sufficiently great, can severely diminish the historical significance of a resource and render it
ineligible. The seven factors of integrity can be roughly grouped into three types of integrity considerations. Location
and setting relate to the relationship between the property and its environment. Design, materials, and workmanship,
as they apply to historic buildings, relate to construction methods and architectural details. Feeling and association
are the least objective of the seven factors and pertain to the overall ability of the property to convey a sense of the
historical time and place in which it was constructed. The Historic Resource Evaluation prepared by Page & Turnbull 2020 (see Appendix D of the Draft EIR) defines the integrity of the Redwood Cabin as follows:
Location
The La Honda Creek Redwood Cabin retains integrity of location as it has remained in its original location since construction.
Setting The La Honda Creek Redwood Cabin retains integrity of setting. The cabin remains in a rural setting, set within a heavily forested area. The immediate area remains remarkably undeveloped, even with a more
heavily trafficked Skyline Boulevard nearby. The cabin retains its subtle landscaping features including the stone walls and circular dirt driveway. It is also still accessed by a semi-rural dirt road. The general area also
retains similar use, functioning as a day-use recreational area and year-round home.
Exhibit A
Ascent Environmental Responses to Comments
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 2-7
Design
The La Honda Creek Redwood Cabin retains integrity of design. It does not appear to have any major design
alterations or additions. The building retains its large, rectangular footprint, rustic log construction, doors and
casement windows, stone and wood staircase, stone site features, side-gable roof, and log fascia. The
aluminum skylights are likely alterations; however, the original design remains legible. The wraparound porch
appears predominantly intact, although the rear porch projection is no longer standing, and the building is
still able to convey its rustic style.
Materials
The La Honda Creek Redwood Cabin retains integrity of materials. It does not appear to have any major alterations and many original elements remain, including the barked redwood logs, plank decking, rustic
deck posts and railing, stone staircase and site elements, stone chimney, wood doors and windows. The
wraparound porch is mostly intact, except for the northern porch and northwest projecting deck. The porch at the primary façade remains intact, as does the entry staircase. Most material components appear to
remain from the building’s initial construction.
Workmanship The La Honda Creek Redwood Cabin retains integrity of workmanship. The building remains representative
of workmanship common to rural recreation cabins constructed in the early twentieth century. The construction and design of the cabin reflect the workmanship of a local builder, such as the rustic log
construction, saddle notches, vertically set log posts, and stone chimney. The building’s retention of such features is evidence of remaining workmanship.
Feeling The La Honda Creek Redwood Cabin retains integrity of feeling as a recreational cabin constructed in a rural setting in the 1920s, during the rise of the automobile era and recreation boom in the country. The subject
building continues to express its historic aesthetic character, as evidenced by its retention of a rural setting away from development and within a heavily forested area, and its historic materials and rustic workmanship
associated with its era of construction.
Association
The La Honda Creek Redwood Cabin retains integrity of association. Originally constructed as a recreational cabin for W. B. Allen and his family in the 1920s, the cabin no longer operates as such and is currently vacant. While the cabin no longer serves as a retreat for the Allen family, it does remain in a recreational setting.
Acquired by the Midpeninsula Regional Open Space District, the property continues to be surrounded by a recreational area and away from any development. The property continues to communicate its rural setting.
Overall, the cabin retains sufficient enough integrity of association.
If the Redwood Cabin were to be relocated to a partially or fully disturbed site, such as a developed residential parcel or other unvegetated site, it would lose integrity of location, setting, feeling, and would also likely lose integrity of
association. Under this scenario, the building would no longer retain its overall integrity and would no longer be eligible for listing in the CRHR. The Relocate and Stabilize alternative would also not meet project Objective 6,
implement a fiscally sustainable project, because relocating the cabin would significantly increase costs to disassemble, move, prepare the new site, and then reconstruct and stabilize the building. For all of these reasons, the
Relocate and Stabilize Alternative was eliminated from further evaluation in the Draft EIR.
Comment I4-6 The assessment of biological impacts is also circular in its logic – the report finds that there are no special status
botanical species on the site, but then suggests that the project will result in an increase in habitat for such species
because of mitigation measures that are not required because there are no special-status species (p. 3.1-8). This
circular logic pervades the report.
The DEIR relies upon minimal restoration activities – erosion control covering 0.7 acres of land within a 6,142 acre
preserve --- to support a finding of “enhanced ecological function.” There is no analysis of whether these activities
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-8 Redwood Cabin Project Final EIR
will enhance ecological function. Unirrigated grass seed covered with straw and mulch have little likelihood for
success – and the fire danger associated with this treatment is also unanalyzed. The biological benefits of this minimal
erosion control treatment are trivial, although little basis is giving for any findings in this regard. There is no
substantial basis for finding that the proposed project meets the objective of enhancing “habitat and natural
ecological function.”
Response I4-6 It is not contradictory to conclude that no special status plant species currently occur on a site and simultaneously
indicate that a project, which includes ecological enhancement activities, could enhance habitat for such species to
create improved biological conditions that promote special status species migration to the site. The “mitigation
measures” identified by the commenter are actually not mitigation measures but instead components of the project
and fulfill existing requirements from other Midpen plans. Also, it is unclear what the commenter means by the Draft
EIR’s reliance on described restoration activities to “support a finding” regarding enhanced ecological function. CEQA
does not require such a finding. Chapter 2, “Project Description,” of the Draft EIR includes a detailed description of
the proposed site recontouring and revegetation (page 2-8) and also includes a detailed description of the various
environmental protection measures that the project would be implemented. The project is designed to meet the
objective related to enhancing habitat and natural ecological function. The potential for wildfire-related impacts is
discussed in the Initial Study, included as Appendix B of the Draft EIR. The Initial Study concludes that the project would result in less-than-significant impacts related to wildfire. It should also be noted that, overall, the project would
eliminate a potential wildfire ignition risk associated with trespassing at the existing structure where prior trespassing occurrences have included the illegal setting of fire within the structure.
Comment I4-7 The analysis of potential impacts to cultural resources is inadequate for archaeological resources. A hundred-year-old
remote log cabin site will have buried features, and Native American sites and belongings may be present whether or
not the site was disturbed by construction of the cabin. A Record Search is not a substitute for a site inspection and
testing by a qualified professional archaeologist. There is no evidence that any archaeologist ever visited the site. This
is not an adequate level of effort for identification of potential resources.
It is also not a best practice to have the construction contractor be responsible for identifying cultural resources
during construction and ONLY THEN implementing cultural resource protocols. If MPROSD is going to disregard
archaeological site preservation as a goal, at least a minimal program of full-time construction monitoring of all earth
disturbing activities by a qualified professional should be required.
Response I4-7 The comment states that the analysis of potential impacts to archaeological resources is inadequate. Although an
archaeological survey was not conducted for the project, a cultural resources management professional did visit the
site and noted that ground visibility was less than five percent due to the accumulation of redwood duff; thus, a
standard archeological pedestrian survey would not have produced much additional information. Also, the project
includes minimal ground disturbance and none beyond what has previously been disturbed. Because the only
ground to be disturbed is related to removing the wooden posts that support the Redwood Cabin and the accessory
features (retaining wall, barbeque, and fire pit which have been thoroughly documented) a survey would not have
revealed archaeological material under these structures. The protection measures included in the Draft EIR are
standard for this level of demolition. EPG CUL-1, Protocol for Unexpected Discovery of Archaeological and
Paleontological Cultural Materials, which calls for discovery protocol such as stopping work within 30 feet of the discovery, notifying a qualified professional, and implementing methods to protect the find (e.g., fencing) until the
significance of the find is determined and a treatment plan can be identified and implemented, is detailed on page 3.2-5 of the Draft EIR. Regarding testing, standard practice is to conduct shovel test pits only when there is a known
archaeological site (which is not the case for this project as detailed in the Draft EIR, Section 3.2, “Cultural Resources,” page 3.2-11) or visible surface manifestations.
Exhibit A
Ascent Environmental Responses to Comments
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 2-9
Comment I4-8 It is clear that some in the District consider the Log Cabin a nuisance for a number of reasons and would prefer to remove it over investing in its preservation. The DEIR presents a sketchy, weak and predetermined justification for its
preferred action. The cultural resource impacts are multiple, significant, avoidable and poorly mitigated.
Many of us who participated in the Vision Plan process, as I did, clearly communicated the importance of cultural
resources and a balanced and diverse view of open space stewardship. MPROSD has an opportunity to demonstrate
the goals of the Vison Plan by stabilizing the Log Cabin, with a long-term objective of its rehabilitation in service of
public education and enjoyment. I urge you to adopt the Environmentally Superior Alternative and stabilize the
Redwood Cabin.
Response I4-8 This comment is noted.
Letter I5 Shani Kleinhaus
May 31, 2022
Comment I5-1 I thank the Midpeninsula Open Space District (Midpen) for providing the opportunity to review the Draft EIR for the
Redwood Cabin Removal Project (Project). I reviewed the objectives of the project, potential environmental impacts and mitigations, and the proposed alternatives. I ask Midpen to proceed with the environmentally superior alternative
(Alternative 2, Stabilize Alternative), and abandon the efforts to remove the structure.
In this era of climate change and loss of biodiversity, government agencies (especially those charged with the
protection of our natural resources) should avoid imposing significant, unavoidable or irreversible impacts to our
environment. Impacts are often small, but our climate and biodiversity are experiencing the injuries of billions of little
cuts. Any project that can reduce its toll on our water and energy resources and avoid using fossil fuels - should do
so.
The project would result in the irreversible and irretrievable commitment of energy and material resources during
construction and operation, including the following: water supply for project construction activities; and energy
expended in the form of electricity, natural gas, diesel fuel, gasoline, and oil for equipment and transportation
vehicles that would be needed for project construction activities.
The EIR proposes that these nonrenewable resources may represent only a very small portion of the resources available in the region and would affect the availability of these resources for other needs within the region. We see this argument contradictory to the mission of Midpen “to protect and restore the natural environment”. Midpen’s
vision statement is absolute regardless of “the resources available in the region”, and in our opinion it mandates that the environmentally superior alternative should be chosen.
Response I5-1 The comment states the opinion that the environmentally superior alternative should be chosen because the project
would result in the use of energy and material resources during demolition activities. Although CEQA only requires a
full evaluation of the project description and an overview evaluation of the project alternatives, it is important to note
for the commenter that the Environmentally Superior Alternative does propose the use of energy and material
resources over the long-term. If the structure were to remain in place and stabilized for public safety, energy would
need to be expended in the form of electricity, natural gas, diesel fuel, gasoline, and oil for equipment and
transportation vehicles as well as for construction repair materials to conduct the stabilization work. Moreover, over the long-term, additional fuel would need to be expended to conduct more frequent patrols, provision of defensible
space, and maintenance inspections for security purposes, and to address any potential future trespassing, fire safety
concerns and periodic structural maintenance needs. The comment is included in the record.
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-10 Redwood Cabin Project Final EIR
Comment I5-2 CEQA does not require that all objectives of a project be met. In our opinion, the ecological enhancement of the log cabin footprint does not justify the irreversible adverse impacts of the project. We also question the benefits of
“biological resources through invasive plant treatment, soil decompaction and amendments, or revegetation at the
site”, especially in light of the statement that habitat restoration is not included in this project.
Response I5-2 The comment questions the ecological enhancement activities of decompacting and revegetating the log cabin
footprint; however, the comment does not address the adequacy of the Draft EIR analysis. The project does include
the removal of a built structure located within a forested habitat and returning the natural open space values back to
the site through the decompaction of the building footprint, revegetation of the highly disturbed area via reseeding
of native Santa Cruz Mountain species, and the removal of invasive plants.
Comment I5-3 In addition, I believe that an alternative that includes stabilization combined with placing an aesthetically-pleasing
fence around the log cabin can allow the achievement of most of the objectives (Remove physical hazards to ensure public safety; Reduce structure and wildland fire risk by removing a structure with a history of vandalism; Improve the
natural visual character and scenic open space qualities at the site; and Implement a fiscally sustainable project
consistent with Midpen’s mission as an open space district.
Response I5-3 The comment suggests a stabilize alternative with an aesthetically pleasing fence be considered. Chapter 4, “Alternatives,” of the Draft EIR includes Alternative 2: “Stabilize Alternative.” This alternative includes stabilizing the
existing structure and installing cyclone fencing. Midpen has installed security fences at other preserves and these
fences have failed to keep vandals out of buildings. Because the Redwood Cabin is located in a remote location with
infrequent visits by Midpen staff, continued vandalism and risk of fire, either to the structure itself or to both the
structure and surrounding area, is still expected. Given Midpen’s experience with trespassing issues even when a
fence (and other measures) are installed, installing an aesthetically pleasing fence would not remove physical hazards
or sufficiently address public safety issues. Nonetheless, the commenter’s suggested alternative for a fence (or physical barrier) is, generally, already included as an alternative discussed in the Draft EIR; it is, in fact, identified as the
Environmentally Superior Alternative. The comment is included in the record.
Letter PH1 Board Member 1
April 27, 2022
Comment PH1-1 The oral comment is summarized as: There is currently no public access, but the Paulin Bridge replacement is in the
table of costs. Does that mean there will be future access to the site? No public access seems to be a temporary
situation.
Response PH1-1 During the public meeting, Midpen staff explained that while the Master Plan does include additional trails in the
northern area of La Honda Creek Open Space Preserve for public access, the timing is currently unknown. Future
public access planning of the Redwood Cabin area is not included in the current 3-year Capital Improvement Action
Plan. This is also stated in Chapter 4, “Alternatives,” of the Draft EIR, on page 4-7. Construction of new trails and
opening of this same area to the general public is also not included in the Measure AA 5-Year Project List or Optional
Project List that prioritizes Measure AA projects between fiscal year 2023-24 and fiscal year 2027-28.
Comment PH1-2 The oral comment is summarized as: The Draft EIR did not analyze air quality and greenhouse gas (GHG) impacts.
The demolition may result in up to 60 tons of waste to haul to Kettleman Hills Landfill, 180 miles from the site. Even
40 tons would create a huge amount of CO2 and methane. Hauling of 180 miles roundtrip would also create
emissions which were not calculated. There are more considerations than just cultural resources.
Exhibit A
Ascent Environmental Responses to Comments
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 2-11
Response PH1-2 The issues identified were evaluated in the Initial Study checklist included as Appendix B of the EIR. Impacts related to air quality and GHG were determined by modeling the demolition activity, including haul trucks. Based on the
modeling results it was determined that the project construction emissions for all criteria pollutants fall below the Bay
Area Air Quality Management District average daily thresholds of significance. Air quality and GHG modeling results
are included as Attachment A of the Initial Study checklist.
Comment PH1-3 The oral comment is summarized as: When we looked at this before, we thought there were all kinds of log cabins in
the area. But the report says there aren’t, so this makes it more important.
Response PH1-3 Page 3.2-17 of the Draft EIR states that “a small number of other redwood cabins are located in the Bay Area;
however, they do not appear to have been evaluated for CRHR- or NRHP-eligibility, and, therefore, it is not known if
they are historical resources under CEQA.”
Midpen staff conducted supplemental online research on comparable log cabins within the vicinity of the Redwood Cabin that appear to be remaining examples of a permanent recreational cabin from the 1920s that possess a high
degree of integrity, and which are individually representative of the peak of recreational development in the Santa
Cruz Mountains during a transition time from tent camps to permanent cabins. Staff research and interviews of
longtime local residents generated a list of approximately 20 redwood or log cabins in the greater Bay Area (five
cabins are in the Santa Cruz Mountains), and one subdivision of approximately 15 cabins built with redwood railroad
ties in the Skylonda community. Of the 35 identified properties in the Santa Cruz Mountains, nine (9) comparable log
cabins appear to possess comparable traits associated with the construction method, materials and use as a
recreational cabin as well as the cabin retaining its integrity to its original design as a redwood or log cabin. While the age and historic status of some cabins vary or could not be determined through this preliminary research, the District
was able to identify 9 comparable log cabins from the original 35 (Page and Turnbull 2022). This additional information does not change the EIR analysis and findings. The comment is included in the record.
Letter PH2 Board Member 2
April 27, 2022
Comment PH2-1 The oral comment is summarized as: The Director expressed strong familiarity of the cabin, having visited and
inspected the structure in the past, then states that there are numerous other cabins in the Skylonda area that were
developed as summer homes. Probably more than they can remember.
Response PH2-1 The comment presents information based on personal knowledge of the local area. Page 3.2-17 of the Draft EIR states that “a small number of other redwood cabins are located in the Bay Area; however, they do not appear to
have been evaluated for CRHR- or NRHP-eligibility, and, therefore, it is not known if they are historical resources
under CEQA.”
Midpen staff conducted supplemental online research on comparable log cabins within the vicinity of the Redwood
Cabin that appear to be remaining examples of a permanent recreational cabin from the 1920s that possess a high
degree of integrity, and which are individually representative of the peak of recreational development in the Santa
Cruz Mountains during a transition time from tent camps to permanent cabins. Staff research and interviews of longtime local residents generated a list of approximately 20 redwood or log cabins in the greater Bay Area (five
cabins are in the Santa Cruz Mountains), and one subdivision of approximately 15 cabins built with redwood railroad
ties in the Skylonda community. Of the 35 identified properties in the Santa Cruz Mountains, nine (9) comparable log
cabins appear to possess comparable traits associated with the construction method, materials and use as a
recreational cabin as well as the cabin retaining its integrity to its original design as a redwood or log cabin. While the age and historic status of some cabins varies or could not be determined through this preliminary research, the
Exhibit A
Responses to Comments Ascent Environmental
Midpeninsula Regional Open Space District 2-12 Redwood Cabin Project Final EIR
District was able to identify 9 comparable log cabins from the original 35 (Page and Turnbull 2022). This additional
information does not change the EIR analysis and findings. The comment is included in the record.
Letter PH3 Board Member 3
April 27, 2022
Comment PH3-1 The oral comment is summarized as: In April 2020, we thought it was potentially eligible for the historic register but
now we have the Page & Turnbull evaluation. Where can I get a copy of the Page & Turnbull report?
Response PH3-1 During the public meeting, Midpen staff explained that the Historic Resources Evaluation Report is posted with the
Draft EIR as Appendix D. The April 8, 2020 Board report on the item (R-20-35) also explained that:
A final Historic Resource Evaluation Report is being prepared and will be available in early April 2020 for the
La Honda Creek Redwood Cabin. At present, preliminary results indicate that the Redwood Cabin is eligible
for individual listing in the California Register of Historical Resources.
Therefore, the Board was notified in April 2020 of the anticipated historic eligibility of the structure based on
preliminary findings that Midpen received from qualified historic consultants at that time. Please see the following
website for the full text of the Board report: https://www.openspace.org/about-us/meetings/bod-20200408.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Final EIR 3-1
3 REVISIONS TO THE DRAFT EIR
This chapter presents specific text changes made to the Draft EIR since its publication and public review. These are
minor, staff-initiated changes to correct typographical errors. The changes are presented in the order in which they
appear in the original Draft EIR and are identified by the Draft EIR page number. Text deletions are shown in
strikethrough, and text additions are shown in underline.
The information contained within this chapter clarifies information in the Draft EIR and does not constitute “significant
new information” requiring recirculation. (See Public Resources Code Section 21092.1; CEQA Guidelines Section
15088.5.)
Revisions to Appendix B, the Initial Study
To provide clarification, the checkbox for bullet “b” on page 2-5 of Appendix B of the Draft EIR is revised as follows:
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
III. Air Quality.
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied on to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or state ambient air quality
standard?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
To provide clarification, the first paragraph under bullet “b” on page 2-10 of Appendix B of the Draft EIR is revised as
follows:
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or state ambient air quality standard?
Less than significant with mitigation incorporated. Under a project level analysis, the BAAQMD CEQA
Guidelines identify whether a project would result in a cumulatively considerable net increase of any
criteria pollutant for which the project region is non-attainment under an applicable federal or state
ambient air quality standard through average pounds per day significance thresholds. The project
level thresholds were developed to bring the SFBAAB into attainment for the NAAQS and CAAQS
and to be protective of human health.
Exhibit A
Revisions to the Draft EIR Ascent Environmental
Midpeninsula Regional Open Space District 3-2 Redwood Cabin Project Final EIR
To provide clarification, the second paragraph under Table 2.3-4 on page 2-11 of Appendix B of the Draft EIR is
revised as follows:
The project would implement BMP AQ-1, as described in Section 2.7.3, “Project Specific BMPs” of
Chapter 2, “Project Description” of the accompanying EIR. With the implementation of project-
specific BMP AQ-1, which contains BMPs required by BAAQMD but not provided in EPG AQ-1, the
project would be consistent with the BMPMs required by BAAQMD and reduce emissions from
construction activities. This impact would be less than significant with mitigation.
Revisions to Chapter ES, Executive Summary
The second sentence of the first paragraph under heading “ES.2.2 Project Background,” on page ES-1 of the Draft EIR
is revised as follows:
The Redwood Cabin was constructed by W.B. Allen from 1927-1928 and served as a recreational retreat for
Allen’s family and guests, including the YMCA and Rotary Club (LSA Associates 2018; Midpen 2020). The
Redwood Cabin was acquired by Midpen in 2002 1988 and has since been uninhabited.
Mitigation Measure 3.1-3, beginning on page ES-7 of the Draft EIR is revised as follows:
Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet
To avoid disturbance and loss of the nests of marbled murrelet Midpen will implement the conservation
measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement
on Midpen preserves (USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that meet the Pacific
Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected,
Midpen will notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter mile from the project
site, the following will apply:
If possible, work within the project site shall be confined to September 15 to November 1.
If work is scheduled to be performed during the breeding season (March 24 to September 15),
disturbance minimization buffers determined by the sound level anticipated from the project will be
implemented based on sound level monitoring studied, submitted to USFWS and the table below.
Buffer distance in feet based on anticipated project sound levels and ambient sound conditions
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project
Sound Level (dB)1
Moderate
(71-80)
High
(81-90)
Very High
(91-100)
Extreme
(101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the project site stie prior to the project,
and not related to the project.
2 Project-generated sound levels measured at 50 feet from the source
3 “Natural Ambient” refers to sound levels generally experienced in habitats not substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special considerations for ambient sound level.
Source: USFWS 2016; USFWS 2020.
Exhibit A
Ascent Environmental Revisions to the Draft EIR
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 3-3
Project activities shall not be conducted within a visual line-of-sightsite distance of 132 feet from a suitable
nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest
trees during the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15) regardless of the
distance to potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset
to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the habitat is occupied
by marbled murrelet, the seasonal and distance work restrictions may be lifted with written approval from
the USFWS.
Revisions to Chapter 2, Project Description
The second sentence of the first paragraph under heading “2.3.1 Background,” on page 2-4 of the Draft EIR is revised
as follows:
The Redwood Cabin is a large, side-gabled log cabin with a rectangular plan. The Redwood Cabin was
constructed by W.B. Allen from 1927-1928 and served as a recreational retreat for Allen’s family and guests,
including the YMCA and Rotary Club (LSA Associates 2018; Midpen 2020). The Redwood Cabin was acquired
by Midpen in 2002 1988 and has since remained uninhabited. Today, the Redwood Cabin stands in a deteriorated state, posing a significant site safety hazard and has been the site of numerous trespassing and
vandalism incidents (including fire ignitions) that raise concerns regarding overall public safety and fire risk
within a very high fire severity zone.
Revisions to Section 3.1, Biological Resources
Mitigation Measure 3.1-3, Preconstruction surveys and nest buffers marbled murrelet, beginning on page 3.1-10 of the
Draft EIR is revised as follows:
Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet
To avoid disturbance and loss of the nests of marbled murrelet Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement
on Midpen preserves (USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that meet the Pacific
Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected,
Midpen will notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter mile from the project
site, the following will apply:
If possible, work within the project site shall be confined to September 15 to November 1.
If work is scheduled to be performed during the breeding season (March 24 to September 15),
disturbance minimization buffers determined by the sound level anticipated from the project will be
implemented based on sound level monitoring studied, submitted to USFWS and the table below.
Exhibit A
Revisions to the Draft EIR Ascent Environmental
Midpeninsula Regional Open Space District 3-4 Redwood Cabin Project Final EIR
Buffer distance in feet based on anticipated project sound levels and ambient sound conditions
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project
Sound Level (dB)1
Moderate
(71-80)
High
(81-90)
Very High
(91-100)
Extreme
(101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the project site stie prior to the project, and not related to the project.
2 Project-generated sound levels measured at 50 feet from the source
3 “Natural Ambient” refers to sound levels generally experienced in habitats not substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special considerations for ambient sound level.
Source: USFWS 2016; USFWS 2020
Project activities shall not be conducted within a visual line-of-sightsite distance of 132 feet from a suitable
nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest
trees during the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15) regardless of the
distance to potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset
to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the habitat is occupied
by marbled murrelet, the seasonal and distance work restrictions may be lifted with written approval from
the USFWS.
Revisions to Section 3.2, Cultural Resources
The last sentence of the first paragraph under the heading “Project Site History” beginning on page 3.2-10 of the
Draft EIR is revised as follows:
Project Site History
The Redwood Cabin is situated on land within the boundary of the former Rancho San Gregorio and is near
the site of former lumber mills, including Harrington Mill. According to Midpen’s records, the Redwood Cabin
was constructed by W.B. Allen as a family retreat from 1927-1928. Allen settled in Palo Alto in 1903 and
owned and operated Palo Alto Hardware. By 1918, he purchased 400 acres in La Honda including the subject
parcel. With the assistance of Norwegian laborers, Allen constructed the lodge on a bedrock foundation
using local timber pieced together without nails. In addition to the lodge, Allen imported stones from the
coast to construct walls, stairs, and numerous stone-lined hiking trails throughout the property. In the 1930s,
the California Conservation Corps assisted with the improvement of some roads near the property. The Allen
family as well as local groups, including the YMCA and the rotary club, used the lodge as a summer retreat
for decades. The property remained in the Allen (Paulin) family until 2002 1988 when Midpen purchased it.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 4-1
4 REFERENCES
Chapter 1 Introduction
ZFA. 2020 (March). Redwood Cabin Structure Stabilization Basis of Design.
Chapter 2 Responses to Comments
Page & Turnbull. 2022 (September). La Honda Redwood Cabin Comparative Analysis. Prepared for Ascent
Environmental.
Exhibit A
References Ascent Environmental
Midpeninsula Regional Open Space District 4-2 Redwood Cabin Removal Project Final EIR
This page intentionally left blank
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Project Final EIR 5-1
5 LIST OF PREPARERS
Midpeninsula Regional Open Space District (Lead Agency)
Jane Mark ................................................................................................................................................................................Planning Manager
Jared Hart ....................................................................................................................................................................................... Senior Planner
Alex Casbara ........................................................................................................................................................................................... Planner III
Melissa Borgesi ....................................................................................................................................................................................... Planner II
Ascent Environmental, Inc. (CEQA Compliance)
Mike Parker ................................................................................................................................................................................................ Principal
Alta Cunningham ..................................................................................................................................................................... Project Manager
Lisa Merry ...................................................................................................................................................... GIS Specialist/Resource Analyst
Brian Perry .................................................................................................................................................................................................. Graphics
Gayiety Lane ....................................................................................................................................................................... Publishing Specialist
Michele Mattei ................................................................................................................................................................... Publishing Specialist
Exhibit A
List of Preparers Ascent Environmental
Midpeninsula Regional Open Space District 5-2 Redwood Cabin Removal Project Final EIR
This page intentionally left blank.
Exhibit A
Appendix A
Comments Received on the Draft EIR
Exhibit A
Jared Hart
From:
Sent:
To:
Subject:
John Harney
Monday, April 18, 2022 10:33 AM
Jared Hart
Cabin removal
[You don't often get email from
http://aka.ms/LearnAboutSenderldentification.]
. Learn why this is important at
EXTERNAL
We are opposed to the cabin removal APN:075-330-260. There are only a handful of these cabins left. The owners new
what they had. They need to put money into it like the other owners of other historic cabins in Skylonda have. Thanks 1-1
John and Shannon Harney
Sent from my iPad
1
Exhibit A
Jared Hart
From:
Sent:
To:
Cc:
Subject:
Sheila Brady
Tuesday, April 26, 2022 3:52 PM
Reimagining Big Basin; Jared Hart
Jay Chamberlin; Tracy Bliss
Redwood Cabin Removal Project EIR Comment
You don't often get email fro� Learn why this is important
EXTERNAL
Hi all,
When I heard about the "Reimagining of Big Basin" project, I forwarded the Page & Turnbull, Inc.
Historic Resource Evaluation to assess the Redwood Cabin's eligibility for listing in the California
Register of Historical Resources (CRHR). I received a note back from the Reimagining Big Basin
Team describing the idea of re-locating the cabin to Big Basin as an intriguing suggestion. You can
see the notes regarding this in the appendix at the bottom of this email.
I do not know if further evaluation of that possibility was ever completed. I have copied both the
Reimagine Big Basin team and the Mid pen team on this note. It would be great if there was an
assessment of whether it could make any sense to relocate the Log Cabin to Big Basin thus in one
move, save a historic cabin, and replace some of the wonderful historic architecture that we lost
in the Big Basin fire.
I realize that there would probably need to be an initial assessment of deconstructing, moving,
and reconstructing the cabin in Big Basin and I'd be willing to spearhead fundraising to get that
assessment done.
I think that the fact that it is within current memory that rustic houses like the Old Redwood Cabin
were heavily in use is important to realize and remember. We take so much for granted about the
ease of our existence. It is good to share the tactile memories that a house like this one elicits
with our children. And the history of the hard work and courage that it took to build on this land is
also an important memory to cherish and respect. There is something about looking at the axe
strokes on the end of a log, one of many that make up a building, which says much more than
words about how tough it is to survive on the land. Just as a lot of the excellent discussion in the
Reimagining Big Basin project centered around the importance of integrating the Native American
experience of caring for the land and recognition of the intelligent land and wildlife management
used by the native tribes, I think that replacing the old Big Basin cabins which were destroyed in
the fire with another cabin of the same age will help us to tie ourselves to that history and
recognition of that age.
1
2-1
Exhibit A
2
I also note that it seems that a paragraph is missing in the
notice: https://www.openspace.org/sites/default/files/Notice%20of%20Availability Draft%20EIR
%20for%20Redwood%20Cabin%20Removal%20Project.pdf
In paragraph 2 of the section titled “Purpose and Objectives” the cabin is described as:
"The Redwood Cabin appears to be one of few remaining examples of a permanent recreational cabin in the Santa Cruz
Mountains from the 1920s with a high degree of historic integrity— historic integrity refers to a building’s original
character and materials, not the physical condition of the building—and is representative of the peak of recreational
development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1). It is also a unique example of a
rustic recreational cabin in the surrounding area (CRHR Criterion 3).”
This is immediately followed by a paragraph that describes how the cabin was going to be
demolished. Isn’t there something missing there?
A paragraph like, “Unfortunately, in spite of the uniqueness of this cabin as described above, the
Midpen Board of Directors has done an evaluation which shows that there is no budget set aside
to repair it for use, there is no access to the area, there is no intention in Midpen’s plans that
there will ever be access to the area, and as the uniqueness of the cabin and its surrounds is a
magnet for vandals there is a fear that a fire could be started there where there is no budget for
regular patrols. So Midpen’s Board of Directors have determined that, in spite of its historic
significance, the cabin’s removal and complete destruction is the best thing for the community.”
I apologize if my rewording of the primary objectives of the project doesn’t correctly capture the
goals.
My Dad was a City Planner for the City of Berkeley for many years. I fully understand that
compromise is the only way that we can live together and have a civilized society. I realize that
with minimal budget Midpen has done and continues to do a great job of protecting the lands and
the wildlife of the Midpen districts. I am very grateful for the efforts and the quality of the fine
Midpen rangers I have dealt with over the 27 years I have lived up in Skylonda. The reason that
vandals hang out in that cabin or around it, is because it is an intriguing and beautiful piece of our
local history and it is a magical spot. The fire danger is serious and I fully appreciate Midpen’s
efforts to protect my community from fire danger, but if the cabin were moved to a place where it
would be welcome, and looked after, maybe it would still be able to cast it’s magic spell there?
Thanks very much for giving me the opportunity to comment.
Sincerely,
Sheila Brady
Attachments:
2-2
Exhibit A
3
Email history with Re-Imagining Big Basin
Begin forwarded message:
From: Reimagining Big Basin <reimagining.bigbasin@parks.ca.gov>
Subject: RE: Old Log cabin
Date: September 8, 2021 at 9:54:39 AM PDT
To: Sheila Brady
Dear Shella:
Thank you for your interest in the Big Basin Reimagining project. Big Basin Redwoods
State Park is a beloved park for Californians, and ensuring recovery and
reestablishment is a high priority for California State Parks.
Also, thank you for sharing your ‘intriguing’ suggestion regarding the re-use of the
historic cabin and for including the Page/Turnbull Historic Structures Report. I love
the cabin aesthetics and State Parks has worked with Page/Turnbull on similar
projects.
The Reimagining Big Basin project is being conducted to define a renewed vision for
Big Basin Redwoods State Park, and your input is critical to this process. While this
project will define the short- and long-term vision for Park reestablishment, on-the-
ground efforts are being carried out to address more immediate recovery needs. In
addition to seeking public input regarding the future of Big Basin, this project will
provide updates on the park’s conditions and recovery efforts and informational and
educational resources regarding the challenges and opportunities of
reestablishment.
Recovery updates, educational materials, and opportunities will be posted on
the Reimagining Big Basin website, and we have added you to our contact list to
receive email updates regarding upcoming events and opportunities to participate.
Thank you again for sharing your thoughts, and we look forward to hearing from you
more throughout the Reimagining process.
Sincerely,
Reimagining Big Basin Planning Team
From: Sheila Brady
Sent: Friday, September 3, 2021 1:39 PM
Exhibit A
4
To: Reimagining Big Basin <reimagining.bigbasin@parks.ca.gov>
Subject: Old Log cabin
Hi there,
I like the Reimagine Big Basin project planning website. It looks like the process is
going to be very inclusive! Which is great!
There is an old log cabin on San Mateo County park land that is slated to be
destroyed. It is located near the crossroads of 84 and 35. It is a cool old thing, but I
believe that it is isolated enough that few people can get to it, and there isn’t any
nearby parking, and it has structural issues so that there is the possibility of someone
getting hurt when they climbed on it, and of course maintenance is costly.
But it is historic, and has been there for 100 years. Here is an assessment made of
the cabin:
I was wondering if it might be a cool thing to move to Big Basin as a part of the
reconstruction. The logs that I can see don’t look ruined at all. It is just in an
inconvenient location, and it takes money to maintain it.
Maybe it would be nice to have another historic log cabin in Big Basin to replace
some of the treasures that we lost?
I have mentioned this idea to a few local friends who would be willing to do fund-
raising to see about getting this cabin moved.
Anyway - for your thought!
Cheers!
Sheila Brady
Exhibit A
Jared Hart
From:
Sent:
To:
Cc:
Subject:
Hi Maureen-
Jared Hart
----:OSPM
Jane Mark; Melissa Borgesi
RE: Redwood Cabin Removal Project DEIR
Thank you for your interest and comments on the Redwood Cabin Removal Project, Midpen will consider your
suggestions below.
Mitigation Measure 3.2-la is described in the Environmental Impacts and Mitigation Measures section of the Draft EIR
on page 3.2-15, and would require Midpen to complete Historic American Building Survey documentation of the cabin
prior to demolition. Please let me know if you aren't able to locate the mitigation measure within the document and I
will email you a description of the mitigation measure (page 3.2-15) as a standalone document.
Regards,
Jared
Jared Hart, AICP, CPSWQ
Senior Planner
Midpeninsula Regional Open Space District
330 Distel Circle, Los Altos, CA 94022
650.625.6535 (office)
openspace.org
0@000
From SO to Forever: Caring for the land that cares for us -By creating Mid pen 50
years ago, our community prioritized clean air and water, healthy habitats for
diverse native plants and animals, ecosystems that are resilient to the effects of our
changing climate, and places for people to connect with nature -that's what
Midpen provides in perpetuity. Celebrate with us all year long at openspace.org/50-
years
From
Sent: Wednesday, May 18, 2022 5:15 PM
To: Jared Hart <jhart@openspace.org>
Cc: Maureen O'Connor
Subject: Redwood Cabin Removal Project DEIR
You don't often get email fro� Learn why this is important
EXTERNAL
1
Exhibit A
Dear Jane,
I was at the HRAB meeting today and appreciated your input on the above referenced project.
I went to the EIR report. It is quite extensive.
I could not find 3.2-lA nor could I find any reference to HAPS or HABS using the search option.
I hope you can help me with this.
Also I have a public comment/suggestion:
The EIR contains some photos of the cabin as it is now. Perhaps Midpen has some additional
photos of it now and also in its early historic period. These could be put into a document to
preserve its history in hard copy since it will be torn down. This document could be given to
the Peninsula Library System and to the local historical museum/association for future
reference. The document could include the EIR also since it describes the care that Midpen
took in making the decision to tear it down.
If there is any distinctive hardware still on the property, that could be saved and donated to an
historical museum in the area near it's former location along with a copy of the document I
mentioned earlier.
Thank you and Midpen for your work on this project.
Sincerely,
Maureen O'Connor
613 F Street, Colma CA 94014
2
3-1
3-2
Exhibit A
May 30, 2022 Jared Hart, Senior Planner Midpeninsula Regional Open Space District 330 Distel Ave Los Altos, CA 94022 Comments on Draft Environmental Impact Report for the Redwood Cabin Removal
Project I am writing as a friend and neighbor of the District, and as a professional archaeologist and historic preservation advocate. I am disappointed by the proposal to demolish the cabin, and by the flimsy analysis presented to justify this action in the DEIR. Although there is insufficient information to support a robust decision-making process in the DEIR, it is clear that the minimum the District should do is to stabilize the hundred
year-old historic log cabin, identified in the DEIR as the "Environmentally Superior
Alternative." The 2014 Vision Plan clearly identified cultural resources as scenic resources, and as assets that merit preservation. The Vision Plan includes goals such as "Protect immediately at-risk, culturally significant resources and promote their responsible stewardship. 11 "Maintain a sense of place by protecting and increasing access to locally significant, iconic natural or cultural features. 11 The Draft EIR for the Redwood Cabin Removal Project ignores these goals, which are not included as "project objectives." Instead, the "project objectives" were carefully engineered to disregard these goals. Two of the objectives are essentially identical: remove physical hazards and reduce structure and wildfire risk. The analysis in the Draft EIR is internally contradictory on the objective improve
scenic qualities. For example, the cabin is identified as having no scenic value because 4-1
4-2it cannot currently be seen by the public, but removing it is assumed to improve scenic 4-3open space qualities. If the site has no scenic value because no one sees it, and public visual access is not a component of the project, then how can scenic value change as a result of the project? The conclusion that demolishing the historic cabin meets the
objective of "improving scenic open space qualities" is not supported.
Exhibit A
A second example of contradictory and unsupported findings occurs in the brief
discussion of the "No Project Alternative" where the DEIR finds that "therefore, no
impact to biological resources would occur," but also that "the No Project Alternative
would result in Slightly Greater Impact to biological resources than the proposed 4-4
project." This "slightly greater" impact is due to the lost opportunity to "restore" the
site's natural character. There is no actual analysis of the relative biological benefits
of stabilizing the cabin in place, or relocating it, in contrast to the minimal restoration
activities described in the project description.
The exclusion of the relocation alternative is also unsupported. The assun1ption that the
site for reinstallation must be "undisturbed" and therefore would involve significant 4-5
impacts is not supported by substantial evidence. One can easily imagine a partially
disturbed site in an appropriate setting for the cabin: a parking area next to a trailhead,
for example. The DEIR's conclusion is unsupported.
The assessment of biological impacts is also circular in its logic -the report finds that
there are no special status botanical species on the site, but then suggests that the project
will result in an increase in habitat for such species because of mitigation measures that
are not re4uired because there are no special-status species (p. 3.1-8). This circular logic
pervades the report.
The DEIR relies upon minimal restoration activities -erosion control covering 0.7 acres 4-6
of land within a 6,142 acre preserve ---to support a finding of "enhanced ecological
function." There is no analysis of whether these activities will enhance ecological
function. Unirrigated grass seed covered with straw and mulch have little likelihood
for success -and the fire danger associated with this treatment is also unanalyzed. The
biological benefits of this minimal erosion control treatment are trivial, although little
basis is giving for any findings in this regard. There is no substantial basis for finding
that the proposed project meets the objective of enhancing "habitat and natural
ecological function."
The analysis of potential impacts to cultural resources is inadequate for
archaeological resources. A hundred-year-old remote log cabin site will have buried
features, and Native American sites and belongings may be present whether or not the 4-7
site was disturbed by construction of the cabin. A Record Search is not a substitute for a
site inspection and testing by a qualified professional archaeologist. There is no
evidence that any archaeologist ever visited the site. This is not an adequate level of
effort for identification of potential resources.
Exhibit A
It is also not a best practice to have the construction contractor be responsible for
identifying cultural resources during construction and ONLY THEN implementing
cultural resource protocols. If MPROSD is going to disregard archaeological site
preservation as a goal, at least a minimal program of full-time construction monitoring
of all earth disturbing activities by a qualified professional should be required.
Summary
It is clear that some in the District consider the Log Cabin a nuisance for a number of
reasons and would prefer to remove it over investing in its preservation. The DEIR
presents a sketchy, weak and predetermined justification for its preferred action. The
cultural resource impacts are multiple, significant, avoidable and poorly mitigated.
Many of us who participated in the Vision Plan process, as I did, clearly communicated
the importance of cultural resources and a balanced and diverse view of open space
stewardship. MPROSD has an opportunity to demonstrate the goals of the Vison Plan
by stabilizing the Log Cabin, with a long-term objective of its rehabilitation in service of
public education and enjoyment. I urge you to adopt the Environmentally Superior
Alternative and stabilize the Redwood Cabin.
Respectfully,
Laura Jones
4-7cont.
4-8
Exhibit A
Jared Hart
From:
Sent:
To:
Subject:
You don't often get email from
May 31st, 2022
Jared Hart, Senior Planner
jhart@openspace.org
Shani Kleinhaus
Tuesday, May 31, 2022 5:02 PM
Jared Hart
Comments on DEIR -Redwood Cabin Removal Project
Learn wh this is im ortant
EXTERNAL
Midpeninsula Regional Open Space District
Re: Redwood Cabin Removal Project
I thanks the Midpeninsula Open Space District (Midpen) for providing the opportunity to review the Draft EIR for
the Redwood Cabin Removal Project (Project). I reviewed the objectives of the project, potential environmental
impacts and mitigations, and the proposed alternatives. I ask Midpen to proceed with the environmentally
superior alternative ( Alternative 2, Stabilize Alternative), and abandon the efforts to remove the structure.
In this era of climate change and loss of biodiversity, government agencies (especially those charged with the
protection of our natural resources) should avoid imposing significant, unavoidable or irreversible impacts to our
environment. Impacts are often small, but our climate and biodiversity are experiencing the injuries of billions of
little cuts. Any project that can reduce its toll on our water and energy resources and avoid using fossil fuels -
should do so.
The project would result in the irreversible and irretrievable commitment of energy and material resources during
construction and operation, including the following: water supply for project construction activities; and energy
expended in the form of electricity, natural gas, diesel fuel, gasoline, and oil for equipment and transportation
vehicles that would be needed for project construction activities.
The EIR proposes that these nonrenewable resources may represent only a very small portion of the resources
available in the region and would affect the availability of these resources for other needs within the region. We
see this argument contradictory to the mission of Midpen"to protect and restore the natural environment".
Midpen's vision statement is absolute regardless of "the resources available in the region", and in our opinion it
mandates that the environmentally superior alternative should be chosen.
CEQA does not require that all objectives of a project be met. In our opinion, the ecological enhancement of the
log cabin footprint does not justify the irreversible adverse impacts of the project. We also question the benefits
of "biological resources through invasive plant treatment, soil decompaction and amendments, or revegetation
5-1
at the site", especially in light of the statement that habitat restoration is not included in this project.
5-2
In addition, I believe that an alternative that includes stabilization combined with placing an aesthetically-pleasing
fence around the log cabin can allow the achievement of most of the objectives (Remove physical hazards to
ensure public safety; Reduce structure and wildland fire risk by removing a structure with a history of
vandalism; Improve the natural visual character and scenic open space qualities at the site; and Implement a
fiscally sustainable project consistent with Midpen's mission as an open space district.
5-3
Respectfully,
Shani Kleinhaus
Palo Alto
1
Exhibit A
DRAFT ENVIRONMENTAL IMPACT REPORT
Redwood Cabin Removal Project
Prepared for
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
April 14, 2022
Exhibit A
DRAFT ENVIRONMENTAL IMPACT REPORT
Redwood Cabin Removal Project
Prepared for:
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
Prepared by
Ascent Environmental, Inc.
455 Capitol Mall, Suite 300
Sacramento, CA 95814
April 14, 2022
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR i
TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS .......................................................................................................................................................................... III
EXECUTIVE SUMMARY ......................................................................................................................................................................... ES-1
ES.1 Introduction .................................................................................................................................................................. ES-1 ES.2 Summary Description of the Project ..................................................................................................................... ES-1
ES.3 Environmental Impacts and Recommended Mitigation Measures ............................................................. ES-2 ES.4 Alternatives to the Proposed Project ................................................................................................................... ES-4
ES.5 Areas of Controversy and Issues to be Resolved ............................................................................................. ES-4
1 INTRODUCTION ........................................................................................................................................................................ 1-1 1.1 Project Requiring Environmental Analysis .............................................................................................................. 1-1
1.2 Purpose and Intended Uses of this Draft EIR ........................................................................................................ 1-1 1.3 Scope of this Draft EIR ................................................................................................................................................. 1-2
1.4 Public Review Process .................................................................................................................................................. 1-2 1.5 Agency Roles and Responsibilities ........................................................................................................................... 1-3 1.6 Draft EIR Organization ................................................................................................................................................. 1-3
2 PROJECT DESCRIPTION ........................................................................................................................................................... 2-1 2.1 Introduction .................................................................................................................................................................... 2-1
2.2 Project Location and Setting ..................................................................................................................................... 2-1 2.3 Description of the Project Site ................................................................................................................................. 2-4
2.4 Description of the Project .......................................................................................................................................... 2-7 2.5 Construction Access, Equipment, Staging, and Logistics ................................................................................. 2-8 2.6 Permits and Approvals ............................................................................................................................................... 2-9
2.7 Best Management Practices .................................................................................................................................... 2-10
3 ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ........................................................................................ 3-1
3.1 Biological Resources ................................................................................................................................................. 3.1-1 3.2 Cultural Resources ..................................................................................................................................................... 3.2-1
4 ALTERNATIVES .......................................................................................................................................................................... 4-1 4.1 Introduction .................................................................................................................................................................... 4-1 4.2 Summary of Environmental Impacts ...................................................................................................................... 4-2
4.3 Alternatives Considered but not evaluated further ........................................................................................... 4-2 4.4 Alternatives Selected for Detailed Analysis .......................................................................................................... 4-3
4.5 Environmentally Superior Alternative .................................................................................................................... 4-6
5 OTHER CEQA SECTIONS ......................................................................................................................................................... 5-1 5.1 Growth Inducement ..................................................................................................................................................... 5-1
5.2 Significant and Unavoidable Adverse Impacts .................................................................................................... 5-2 5.3 Significant and Irreversible Environmental Changes ......................................................................................... 5-2
6 REPORT PREPARERS ................................................................................................................................................................. 6-1
7 REFERENCES ............................................................................................................................................................................... 7-1
Exhibit A
Table of Contents Ascent Environmental
Midpeninsula Regional Open Space District ii Redwood Cabin Project Draft EIR
Appendices (included in a USB on back cover)
Appendix A – Notice of Preparation and Comments
Appendix B – Initial Study Appendix C – Special-Status Species Tables
Appendix D – Cultural Resource Reports
Figures
Figure 2-1 Project Vicinity and Location .................................................................................................................................... 2-2
Figure 2-2 Project Site ..................................................................................................................................................................... 2-3 Figure 2-3 Representative Photographs .................................................................................................................................... 2-5 Figure 2-4 Representative Photographs .................................................................................................................................... 2-6
Figure 3.1-1 Landcover and Invasive Plants in the Project Site and Vicinity .................................................................... 3.1-5
Tables
Table ES-1 Summary of Impacts and Mitigation Measures ................................................................................................ ES-5 Table ES-2 Summary Environmental Impacts of the Alternatives Relative to the Redwood Cabin Project ....... ES-14
Table 2-1 Potential Waste Disposal Facilities .......................................................................................................................... 2-9 Table 2-2 Potential Permits and Approvals ............................................................................................................................. 2-9
Table 4-1 Summary of Environmental Effects of the Alternatives Relative to the Proposed Redwood Cabin Project ................................................................................................................................................................. 4-7 Table 4-2 Objectives Achieved by Project Alternatives ....................................................................................................... 4-7
Exhibit A
Ascent Environmental List of Abbreviations
Midpeninsula Regional Open Space District Redwood Cabin Project Draft EIR iii
LIST OF ABBREVIATIONS
BMP Best Management Practices
Board Midpen Board of Directors
CA-MUTCD California Manual on Uniform Traffic Control Devices
CCR California Code of Regulations
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFR Code of Federal Regulations
CNDDB California Natural Diversity Database
CNPS California Native Plant Society Inventory of Rare and Endangered plants
Coroner County Medical Examiner
CRHR California Register of Historical Resources
CWA Clean Water Act
DPR Department of Parks and Recreation
Draft EIR draft environmental impact report
EIR environmental impact report
EPG environmental protection guidelines
ESA Endangered Species Act
FGC Fish and Game Code
GHG greenhouse gasses
IPMP Integrated Pest Management Program
IS Initial Study
IS/MND Initial Study/Mitigated Negative Declaration
MBTA Migratory Bird Treaty Act
Midpen Midpeninsula Regional Open Space District
MLD Most Likely Descendant
NABP Native American Burial Plan
NAHC Native American Heritage Commission
Exhibit A
List of Abbreviations Ascent Environmental
Midpeninsula Regional Open Space District iv Redwood Cabin Project Draft EIR
NHPA National Historic Preservation Act
NOP Notice of Preparation
NRHP National Register of Historic Places
NWIC Northwest Information Center
PRC Public Resources Code
Preserve La Honda Creek Open Space Preserve
project Redwood Cabin Removal Project
RWQCB Regional Water Quality Control Board
USACE U.S. Army Corps of Engineers
USFWS U.S. Fish and Wildlife Service
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Project Draft EIR ES-1
EXECUTIVE SUMMARY
ES.1 INTRODUCTION
This summary is provided in accordance with California Environmental Quality Act Guidelines (State CEQA Guidelines) Section 15123. As stated in Section 15123(a), “an EIR [environmental impact report] shall contain a brief summary of
the proposed action and its consequences. The language of the summary should be as clear and simple as reasonably practical.” As required by the guidelines, this chapter includes (1) a summary description of the Redwood Cabin Removal Project (project), (2) a synopsis of environmental impacts and recommended mitigation measures
(Table ES-1), (3) identification of the alternatives evaluated and of the environmentally superior alternative, and (4) a discussion of the areas of controversy associated with the project.
ES.2 SUMMARY DESCRIPTION OF THE PROJECT
ES.2.1 Project Location
The Redwood Cabin is situated within the upper portion of the La Honda Creek Open Space Preserve (Preserve). The Preserve encompasses 6,142 acres in the Santa Cruz Mountains within unincorporated San Mateo County, approximately 5 miles east of the Pacific Ocean. The Preserve is bounded by Highway 35 (Skyline Boulevard) to the
north, by Highway 84 (La Honda Road) to the east and south, and by Bogess Creek to the west. The Redwood Cabin occupies a portion of Assessor’s Parcel Number 075-330-260 and is located west of the community of Skylonda, California.
ES.2.2 Project Background
The Redwood Cabin was constructed by W.B. Allen from 1927-1928 and served as a recreational retreat for Allen’s
family and guests, including the YMCA and Rotary Club (LSA Associates 2018; Midpen 2020). The Redwood Cabin was acquired by Midpen in 1988 and has since been uninhabited.
In 2020, Page & Turnbull, Inc. prepared a Historic Resource Evaluation to assess the Redwood Cabin’s eligibility for listing in the California Register of Historical Resources (CRHR). The Historic Resource Evaluation determined that the Redwood Cabin is an historic resource per CEQA because it appears to be eligible for listing in the CRHR. The Redwood Cabin appears to be one of few remaining examples of a permanent recreational cabin from the 1920s, in the general area, with a high degree of historic integrity—historic integrity refers to a building’s original character and
materials, not the physical condition of the building—and is representative of the peak of recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1); and is a unique example of a rustic
recreational cabin in the surrounding area (CRHR Criterion 3).
On April 8, 2020, the Midpen Board of Directors directed the General Manager to evaluate the environmental effects that would result from removing the Redwood Cabin and implementing habitat enhancements to reflect native ecological conditions.
ES.2.3 Project Objectives
The proposed project is intended to achieve the following primary objectives, in alignment with Midpen’s mission:
Remove physical hazards to ensure public safety;
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate surroundings;
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-2 Redwood Cabin Removal Project EIR
Reduce structure and wildland fire risk by removing a structure with a history of vandalism;
Improve the natural visual character and scenic open space qualities at the site; and
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district.
ES.2.4 Characteristics of the Project
The project would entail demolition of the Redwood Cabin and removal of associated features onsite, including the stone retaining walls and barbeque and fire pits. Prior to demolition activities, lead-based paint present within the
structure would be properly removed and disposed of.
While it is expected that excavation of posts and bases associated with the structure would be approximately 2 feet
below grade, it is possible that maximum depth of excavation could reach up to 5 feet. During demolition of the structure, it is estimated that approximately 60 tons of material would be removed from the project site (ZFA 2020). Tree removal will not be required to facilitate demolition activities, although some brush clearing along the access
road may be necessary.
Following completion of demolition activities, disturbed areas would be recontoured and erosion control applied to the site to ensure adequate site drainage. All demolition and recontoured areas would be compacted to 75 percent relative compaction. Native grass seed mix would be spread in the disturbed areas and weed free or native grass straw would be placed in the disturbed areas, on top of the native grass seed mix, to assist with soil stabilization and erosion control. Any wood chips or mulch generated from unsalvageable building materials may also be used to stabilize disturbed areas but will not be more than 3 inches in depth. Midpen may also conduct the following
activities on the project site after demolition and recontouring:
soil decompaction activities outside of critical rootzones,
soil testing and, if needed, spot application of amendments such as fertilizers, lime, or organic materials, and
revegetation or plantings.
Midpen also conducts early detection rapid response surveys for up to 3 years at revegetation sites and treats any invasive plant species on the early detection rapid response list. Other priority integrated pest management target species, including slender false brome may be treated prior to and after demolition. Slender false brome is an
invasive weed of high concern at the project site; due to Midpen’s mandatory quarantine of this weed, all slender false brome in the area will be treated prior to any work being completed.
Current activity at the project site consists of occasional visits from Midpen staff for inspections. Once removal of the structure and site recontouring/erosion control activities are complete, no additional maintenance or operational activities would be required at the project site except for invasive plant species treatment, if needed. The site would
remain closed to the public.
ES.3 ENVIRONMENTAL IMPACTS AND RECOMMENDED MITIGATION
MEASURES
ES.3.1 Project-Specific Impacts
This EIR has been prepared pursuant to the CEQA (Public Resources Code [PRC] Section 21000 et seq.) and the State CEQA Guidelines (California Code of Regulations, Title 14, Chapter 3, Section 1500, et seq.) to evaluate the physical environmental effects of the project. Midpen is the lead agency for the project and has the principal responsibility for
approving and carrying out the project and for ensuring that the requirements of CEQA have been met. After the Final EIR is prepared and the EIR public-review process is complete, the Midpen Board of Directors (Board) is the party responsible for certifying that the EIR adequately evaluates the impacts of the project.
Exhibit A
Ascent Environmental Executive Summary
Agency/Client Redwood Cabin Removal Project EIR ES-3
Table ES-1, presented at the end of this chapter, provides a summary of the environmental impacts for the project.
The table provides the level of significance of the impact before mitigation, recommended mitigation measures, and the level of significance of the impact after implementation of the mitigation measures.
ES.3.2 Significant-and-Unavoidable Impacts and Cumulative Impacts
The Redwood Cabin Project would result in significant and unavoidable impacts related to historical resources.
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would involve demolition of the Redwood Cabin and removal of associated site
features, including the stone retaining wall, barbeque, and fire pits. The demolition of the Redwood Cabin would result in a substantial adverse change in the significance of this historical resource because the building would no
longer exist. Because associated site features were determined not to possess individual historic significance and do not comprise a historic landscape, removal of these features, in tandem with the Redwood Cabin would not result in an adverse change to the significance of a historic resource. Because the Redwood Cabin structure was recommended eligible for listing in the CRHR under criterion 1 and 3, and project activities would result in an adverse change in the significance of a CEQA historic resource, impacts would be significant.
Mitigation Measure 3.2-1a requires completion of Historic American Building Survey documentation of the Redwood Cabin before commencement of any demolition work. Mitigation Measure 3.2-1b requires creation of an interpretive resource outlining the Redwood Cabin’s historic status, historic context, and significance, which would be available in a digital and/or physical format for public engagement and may be shared with a relevant local organization such as the San Mateo County Historical Association. Mitigation Measure 3.2-1c requires salvage and reuse of acceptable
demolished structure materials in compliance with Midpen’s waste diversion requirements outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. Implementation of Mitigation Measures 3.2-1a, 3.2-1b, and 3.2-1c would lessen the impacts related to the loss of the Redwood Cabin, however, these measures would not reduce the project’s impact associated with an adverse change to the significance of a historical resource. Because the historically eligible structure would no longer exist, impacts to the Redwood Cabin would remain significant and unavoidable after application of all feasible mitigation measures.
Impact 3.2-3: Potential to Contribute to a Significant Cumulative Impact to Cultural
Resources
Implementation of EPG CUL-1 would avoid potential adverse effects to archaeological resources by ensuring proper identification, evaluation, and treatment of previously unidentified archaeological material, such that impacts would be less than significant. Therefore, implementation of the project would not contribute to a cumulative loss of
archaeological resources. Similarly, other projects under Midpen’s jurisdiction would be required to implement EPG CUL-1 to avoid/reduce impacts to archaeological resources.
As described in Impact 3.2-1, the Redwood Cabin is an eligible historic architectural resource. As such, implementation of the project would result in removal of a historical resource under CEQA as well as one of the few remaining structures representative of recreational development in the region. Implementation of Mitigation Measures 3.2-1a,3.2-1b, and 3.2-
1c would lessen the impacts related to the loss of the Redwood Cabin, however, these measures would not reduce the project’s impact associated with an adverse change to the significance of a historical resource. This permanent loss in
the resource would result in a cumulative contribution to a historic impact.
Therefore, although cumulative impacts to archaeological resources would be less than significant, cumulative impacts to cultural resources as a whole would be significant and unavoidable.
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-4 Redwood Cabin Removal Project EIR
ES.4 ALTERNATIVES TO THE PROPOSED PROJECT
The following provides brief descriptions of the alternatives evaluated in this Draft EIR. Table ES-2 presents a comparison of the environmental impacts between the alternatives and the proposed project.
Alternative 1: No Project Alternative assumes no demolition of the existing structure. The project site would remain in its current condition.
Alternative 2: Stabilize Alternative assumes no demolition of the existing structure but includes stabilizing the
building and site.
Alternative 3: Repair and Rehabilitate Alternative assumes the repair and rehabilitation of the building for
eventual reuse as a retreat space, meeting space, or hikers hut (or similar use).
ES.4.1 Environmentally-Superior Alternative
Alternative 2, Stabilize Alternative, would be the environmentally superior alternative. The Redwood Cabin would not
be removed, which would result in the loss of opportunity to improve biological resources through invasive plant treatment, soil decompaction and amendments, or revegetation at the site. This would result in slightly greater
impacts to biological resources but the alternative would avoid the proposed project’s significant and unavoidable cultural resource impact. This significant and unavoidable impact would not be avoided under the No Project Alternative, and impacts to biological resources would be slightly greater under the No Project Alternative, for the same reason as under the Stabilize Alternative, than under the proposed project because it would not provide the long-term opportunity to improve biological resources by removing a built structure to help restore the natural
biological values of a mixed evergreen forest. However, the Stabilize Alternative meets only one of the objectives: removing physical hazards to ensure public safety. The remaining four objectives would not be met by this alternative. Therefore, while the Stabilize Alternative would be the environmentally superior action alternative, it would not meet several of the project objectives.
ES.5 AREAS OF CONTROVERSY AND ISSUES TO BE RESOLVED
A notice of preparation (NOP) was distributed for the Redwood Cabin Project on June 9, 2021, to responsible agencies, interested parties, and organizations, as well as private organizations and individuals that may have an
interest in the project. A public scoping meeting was held on Wednesday, June 23, 2021 at 7:00 pm. The purpose of the NOP and the scoping meeting was to provide notification that an EIR for was being prepared for the project and
to solicit input on the scope and content of the environmental document. The NOP and responses to the NOP are included in Appendix A of this Draft EIR. Key concerns and issues that were expressed during the scoping process included the following:
Historic value and significance of the Redwood Cabin;
AB 52 consultation; and
Construction traffic control plan
These issues are each addressed in this Draft EIR and accompanying Initial Study. With the exception of historical
resource impacts, any impacts related to these issues are either identified as less than significant, or less than significant after mitigation.
Exhibit A
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR ES-5
Table ES-1 Summary of Impacts and Mitigation Measures
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
NI = No impact LTS = Less than significant PS = Potentially significant S = Significant SU = Significant and unavoidable
Biological Resources
Impact 3.1-1: Loss or Degradation of Habitat for Special-Status Botanical Species
Suitable habitat for special-status botanical species is present within the project
site; however, no special-status botanical species were identified during surveys of
the site in 2020, and no loss of individual special-status plants is anticipated. With
the removal of the cabin, the recontouring of the project site, and implementation
of EPG BIO-10, the project would result in an increase in suitable habitat for
special-status botanical species. In addition, the implementation of IPMP BMPs would avoid habitat degradation that may result from the introduction and spread of invasive plants. Therefore, the project would have a less-than-significant impact on special-status botanical species.
LTS No mitigation is required for this impact. LTS
Impact 3.1-2: Injury or Mortality of Special-Status Amphibians
Special-status amphibians may be found within the project site. The recontouring of the site and implementation of EPG BIO-10 would ensure that there is no loss of habitat for these species. Project activities including the demolition of the Redwood Cabin and associated structures, recontouring, and staging of materials could result in the injury or mortality of special-status amphibians, and any injury or mortality of individual special-status amphibians would be a significant impact.
S Mitigation 3.1-2a: Protection Measures for California Red-Legged Frog
To avoid loss of individual California red-legged frog, Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Activities including the use of mechanical equipment, excavating, and bulldozing will require pre-activity visual surveys as well as monitoring during the activities.
All maintenance activity proposals involving mechanized equipment and
associated monitoring proposals will be approved by CDFW and USFWS prior to
implementation of the project.
Biological monitors will check for any listed species under vehicles and
equipment parked for more than 30 minutes.
Refueling of equipment will be conducted using heavy-gauge tarps made of chemically resistant polypropylene or other impervious material with vertical sides for spill containment. These containment tarps will be set up under the equipment prior to servicing or refueling. Once the work is completed, the tarp
and its contents must be immediately removed from the property and all
contaminants properly disposed of off-site. Standard operating procedures will
be implemented immediately in case of fuel spillage.
All vehicles must stay on designated roads, paved and unpaved, and if it is
necessary for a vehicle to travel off the designated road (paved or 2 track
LTS
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-6 Redwood Cabin Removal Project EIR
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
unpaved), a monitor will precede the vehicle to clear wildlife from the pathway
of the vehicle.
Prior to the start of work, an educational program regarding the sensitivity of the California red-legged frog and its habitat will be conducted for all personnel.
Prior to the start of work, areas will be identified by the biological monitor and approved by the USFWS and CDFW as acceptable locations for the relocation of California red-legged frog if the species is encountered within the project site. Relocation areas will be a minimum of 500-feet from the boundary of the project site and will not include staging areas or roads. No California red-legged
frog will be removed from Midpen property or maintained in captivity overnight
without prior notification and written approval from the USFWS and CDFW
unless the animal is in need of emergency medical assistance. Medical
assistance will be provided by a USFWS-approved, certified wildlife veterinarian
familiar with amphibian care.
If a California red-legged frog enters the project site, all work shall stop until the
animal leaves on its own. If the frog does not leave on its own, a biological
monitor specifically authorized by the USFWS and CDFW will be allowed to handle and relocate the California red-legged frog to the pre-approved relocation area.
Mitigation 3.1-2b: Biological Monitoring for California Giant Salamander and Santa Cruz Black Salamander
To avoid loss of individual California giant salamander and Santa Cruz black
salamander, Midpen will implement the following measures.
Prior to the start of demolition each day, the access road and portions of the
project site where activities will occur will be surveyed by a qualified biologist for the presence of California giant salamander and Santa Cruz black salamander. The survey will include the inspection of any debris from demolition or materials staged overnight for the presence of these species.
If individual California giant salamanders or Santa Cruz black salamanders are discovered during daily inspections, work shall stop until the individual salamander moves on its own to a point where it is no longer at risk of incidental injury or death from project activities, or until the individual salamander is moved outside of the project site by a qualified biologist.
Exhibit A
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR ES-7
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Impact 3.1-3: Disturbance of Nesting Marbled Murrelet
The nearest mapped nesting habitat for marbled murrelet (Brachyramphus
marmoratus) is located approximately one-half mile west of the project site.
However, unmapped nesting habitat could occur within a quarter mile of the
project site, and implementation of the project could result in loss of eggs and
young from nest disturbance during the breeding season (March 24 – September
15) . If nesting marbled murrelets are within a quarter mile of the project site, the project would have a significant impact on this species.
S Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet
To avoid disturbance and loss of the nests of marbled murrelet Midpen will
implement the conservation measures found within the 2016 Biological Opinion on
the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves
(USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that meet the Pacific Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected, Midpen will notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter mile from the project site, the following will apply:
If possible, work within the project site shall be confined to September 15 to
November 1.
If work is scheduled to be performed during the breeding season (March 24
to September 15), disturbance minimization buffers determined by the sound
level anticipated from the project will be implemented based on sound level
monitoring studied, submitted to USFWS and the table below.
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project
Sound Level (dB)1
Moderate
(71-80)
High
(81-90)
Very High
(91-100)
Extreme
(101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the
project stie prior to the project, and not related to the project.
2 Project-generated sound levels measured at 50 feet from the source
3 “Natural Ambient” refers to sound levels generally experienced in habitats not
substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special
considerations for ambient sound level.
Source: USFWS 2016; USFWS 2020
LTS
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-8 Redwood Cabin Removal Project EIR
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Project activities shall not be conducted within a visual line-of-site distance of 132 feet from a suitable nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest trees during the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15) regardless of the distance to potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the habitat is occupied by marbled murrelet, the seasonal and distance work restrictions may be lifted with written approval from the USFWS.
Impact 3.1-4: Disturbance of Common Raptor and Other Common Bird Nests
The project site provides suitable nesting habitat for common raptors and other common nesting birds, and project activities could result in the disturbance of active nests if demolition occurs during the nesting season. The disturbance of active nests could result in the abandonment of nests and the mortality of eggs and young, which would be a potentially significant impact.
PS Mitigation 3.1-4: Preconstruction surveys and nest buffers for common raptors and
other nesting birds
To avoid disturbance and loss of the nests of common raptors and other nesting birds Midpen will implement the following measures.
If work is scheduled to be performed during the nesting season (the specific start and end dates of the season will be determined by a qualified biologist but are typically February 15 to August 30), a pre-demolition survey will be
performed within 1,000 feet of the project site, no more than 14 days prior to the
start of demolition related activities. If no active nests are detected during
surveys, no further mitigation is required.
If active nests are found during the pre-demolition survey, a buffer will be
established around each nest. No project activity will occur within a buffer of
1,000-feet around large raptor nests (e.g., buteos) 500-feet around small
common raptor nests (e.g., accipiters) and 250-feet around the nests of other common bird species. The size of the buffer around any individual nest maybe reduced by a qualified biologist in consultation with CDFW, depending on screening of the nest from project activities and other site-specific conditions. These buffers will be maintained until a qualified biologist determines that any young have fledged, and the nest is no longer active.
LTS
Exhibit A
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR ES-9
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Impact 3.1-5: Loss of San Francisco Dusky-Footed Wood Rat Nests
The Redwood Cabin contains multiple San Francisco dusky-footed wood rat
(Neotoma fuscipes annectens) nests. The demolition of the cabin would destroy
these nests and could result in the injury or mortality of young woodrats if
demolition occurs during the rearing season (approximately April 1 to July 15). The
destruction of these nests and the injury or mortality of young woodrats would be
a significant impact
S Mitigation 3.1-5: Minimize impacts from loss of San Francisco dusky-footed wood rat nests
To avoid loss of San Francisco dusky-footed wood rat during demolition, work will be conducted outside of the rearing season (before April 1 or after July 15).
Prior to demolition, debris piles will be constructed outside of and adjacent to the project footprint to provide shelter for wood rats that are displaced by demolition. These debris piles will be constructed under the guidance of a qualified biologist and will consist of dead branches of various sizes (0.5 to 6 inches in diameter) collected from the surrounding area. Each pile will be
approximately 3 to 5 feet high by 8 to 10 feet in diameter. The number of debris
piles will be determined by a qualified biologist based on the number of nests in
the Redwood Cabin prior to demolition.
To avoid death of wood rats, wood rat nest materials will be removed by hand
from the Redwood Cabin prior to demolition of the structure.
If wood rats are observed during demolition, work will stop until the animal leaves the area on its own, or until a qualified biologist determines that work can continue without harm to the animal.
LTS
Impact 3.1-6: Loss of Bat Roosts and Mortality of Individuals
The Redwood Cabin provides potential roosts for common and special-status bats.
The demolition of the Redwood Cabin could result in disturbance of active bat
roosts, which could result in the loss of adult and young bats. The loss of individual
special-status bats, or the loss of a maternity roost of any bat species would be a
potentially significant impact
PS Mitigation 3.1-6: Pre-demolition surveys and measures to reduce impacts to bat roosts and special-status bats
A pre-demolition bat roost survey shall be conducted at the project site by a qualified biologist no more than two days prior to the start of demolition.
In addition, if demolition is anticipated to occur during the bat wintering period (from November 16 through February 15), a pre-demolition winter roost survey shall be conducted by a qualified biologist.
If individual nonbreeding and non-special-status bats are roosting within the
structure, a qualified biologist may remove the bats and work may proceed during any time of the year. If special-status bats or a maternity roost of any bat species is detected, demolition will not be allowed to occur during the April through August maternity season; outside of the maternity season, bats shall be excluded and provided alternate roost sites before demolition.
Midpen will develop a project specific bat roost deterrent plan if special-status bats or a maternity roost of any bat species is detected in the Redwood Cabin. The deterrent plan will be submitted to CDFW for approval and will include measures such as acoustic deterrents and one-way bat doors installed outside of the maternity season (April through August), and other similar methods.
LTS
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-10 Redwood Cabin Removal Project EIR
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Demolition will occur when forecast nighttime lows are not below 50 degrees
Fahrenheit.
The materials around crevices that may provide roosting sites within the structure will be first demolished with hand tools to minimize the potential risk of injuring bats.
Initial demolition will be performed in the early evening after sunset, or if evening work is not feasible, the work shall be initiated in the afternoon to ensure that any bats present are not in torpor and unable to escape. Once demolition has been started, further work may be performed at any point in the day. A qualified bat biologist will be present at the initiation of demolition to
capture and temporarily hold any bats present for release the evening of the
same day.
Impact 3.1-7: Disturbance or Loss of Special-Status Mammal Den Sites (American Badger and Ringtail)
The project site and adjacent redwood forest provide potential denning sites for
special-status mammals. The demolition of the Redwood Cabin could result in
disturbance of active dens and the injury or mortality of pups if the demolition
occurs during the breeding season. The loss of active dens and injury of mortality
of special-status mammal pups would be a potentially significant impact
PS Mitigation 3.1-7: Pre-demolition surveys and den buffers for American badger and ringtail
If the project occurs during the period when pups are potentially in the den February 15 through July 1, a qualified biologist shall conduct pre-demolition surveys within 100 feet of the project site for potential American badger and
ringtail dens. The survey will occur no more than 7-days prior to implementation
of demolition activities.
If any potentially occupied American badger dens are located during surveys, no
work shall be performed within a 100-foot buffer around dens during the period
when pups are potentially in the den (February 15 through July 1).
If any potentially occupied ringtail dens (e.g., brush piles, appropriately sized burrows, hollow logs, hollow trees) are located during surveys, the same buffers as described for American badger will be applied during breeding season for
ringtail (May 1 through June 30).
LTS
Impact 3.1-8: Disturbance or Loss of Riparian Habitat or Other Sensitive Natural Communities
The project does not contain riparian woodland; however, herbaceous riparian
habitat is present along the adjacent La Honda Creek. The project would not
directly affect this habitat and the implementation of EPG WQ-2 would avoid and
minimize impacts from the runoff of sediment from the project. The site also
contains a CDFW-designated sensitive natural community, Redwood Forest;
however, this community would not be adversely affected by the project because
the project would not remove any trees, would treat on-site invasive species, and
LTS No mitigation is required for this impact. LTS
Exhibit A
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR ES-11
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
would restore the area disturbed by the project through the implementation of
EPG BIO-10. Therefore, the impact of the project on riparian habitat and other
sensitive natural communities would be less than significant.
Impact 3.1-9: Degradation or loss of protected wetlands and other waters
The access road to the project site crosses La Honda Creek and an un-named tributary. A temporary bridge may be required to move equipment across the tributary; however, no dredge or fill of the creek or tributary will occur as a result of the project. In addition, EPG WQ-2 will be implemented to avoid and minimize impacts to La Honda Creek and its tributary due to runoff from the project site. Therefore, the impact to protected wetlands and other waters would be less than significant.
LTS No mitigation is required for this impact. LTS
Impact 3.1-10: Potential to Interfere with Wildlife Movement and Nursery Sites
The demolition of the Redwood Cabin would not result in any changes in habitat
or new structures that would interfere with wildlife movement. The noise and
human activity associated with the project could result in temporary impacts to
wildlife movement that would not be substantial, due to the short duration and
limited footprint of the project in relation to other habitat in the vicinity. Therefore,
the projects impact would be less than significant.
LTS No mitigation is required for this impact. LTS
Impact 3.1-11: Potential to Contribute to a Significant Cumulative Impact to
Biological Resources
Implementation of the proposed project in the context of historical effects on the landscape and in combination with other cumulative projects in the area could result in impacts to biological resources. However, through the implementation of EPGs, BMPs, and mitigation measures, the contribution of the project would be less than cumulatively considerable. Therefore, this impact would be less than significant.
LTS No mitigation is required for this impact. LTS
Exhibit A
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District ES-12 Redwood Cabin Removal Project EIR
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Cultural Resources
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would result in a substantial adverse change in the
significance of a recommended-eligible historical resource. This would result in a
significant impact as described in State CEQA Guideline 15064.5(b)(1).
S Mitigation 3.2-1a: Document historic buildings prior to removal.
Midpen shall complete Historic American Building Survey documentation of the
Redwood Cabin before any demolition work is conducted. Documentation shall
consist of written history of the property, plans and drawings of the historic
resources, and photographs, as described below:
Written History. The report shall be reproduced on archival bond paper.
Plans and Drawings. An architectural historian (or historical architect, as appropriate) shall conduct research into the availability of plans and drawings of the Redwood Cabin as the building currently exists. If such plans/drawings exist,
their usefulness as documentation for the building shall be evaluated by the
architectural historian. If deemed adequate, the plans/drawings shall be reproduced on archival mylar. If no plans/drawings are available, or if the existing plans/drawings are not found to be useful in documenting the historic resource, a historical architect shall prepare dimensioned plans and exterior elevations of the building. A combination of existing and new drawings is acceptable. All drawings shall be reproduced on archival mylar.
The architectural historian shall conduct research into the existence of the original architectural plans and drawings of the building. If found, the plans shall be reproduced on archival mylar. Alternatively, the architectural plans can be scanned and saved as TIFF files. The scanning resolution shall be not less than 300 dpi.
All digital files, including drawing files, shall be saved on media and labeled following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital Photography Specifications.
Photographs. Digital photographs shall be taken of the Redwood Cabin following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital Photography Standards.
The documentation shall be prepared by an architectural historian, or historical architect as appropriate, meeting the Secretary’s Standards and Guidelines for Archeology and Historic Preservation, Professional Qualification Standards. The documentation shall be submitted to the San Mateo County Library, the San Mateo County Historical Association, the Northwest Information Center, and the Midpen office in Los Altos.
SU
Exhibit A
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR ES-13
Impacts
Significance
before
Mitigation
Mitigation Measures
Significance
after
Mitigation
Mitigation 3.2-1b: Redwood Cabin interpretation.
Midpen will create an interpretive resource outlining the Redwood Cabin’s historic
status, historic context, and significance. This resource will be available in a digital
and/or physical format for public engagement and may be shared with a relevant
local organization such as the San Mateo County Historical Association. Mitigation
Measure 3.2-1c: Salvage of useable materials.
Should any of the demolished structure materials (i.e., redwood logs) be in acceptable condition, Midpen shall reserve materials for potential future uses and/or salvage in compliance with Midpen’s waste diversion requirements outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. If these materials are free of pests, Midpen will coordinate with a local historic salvage organization, such as Garden City Recycle and Salvage in Santa Cruz, Whole House Building Supply & Salvage in San Mateo, or Heritage Salvage in Petaluma for their reuse.
Impact 3.2-2: Cause a Substantial Adverse Change in the Significance of Unique Archaeological Resources
Project-related ground-disturbing activities could result in discovery or damage of
yet undiscovered archaeological resources as defined in State CEQA Guidelines
Section 15064.5. However, because project excavation activities would occur in
previously disturbed areas, the potential for encountering archaeological material
is low. Additionally, because EPG CUL-1 would be implemented in the event of a
discovery, this would be a less-than-significant impact.
LTS No mitigation is required for this impact. LTS
Impact 3.2-3: Potential for the project, in combination with other development, to
contribute to a significant cumulative impact to cultural resources.
The project, in combination with other cumulative development in the area, could result in impacts to cultural resources in the area. Through the implementation of environmental protection measures, the contribution of the project would not be cumulatively considerable with respect to archaeological resources. However, because the project would result in permanent removal of a historic architectural resource, impacts to historical resources would be significant. Therefore, cumulative impacts to cultural resources would be significant.
S Mitigation Measures, 3.2-1a, 3.2-1b, and 3.2-1c, described above. SU
Exhibit A
Executive Summary Screencheck Draft – For Internal Review and Deliberation Ascent Environmental
Midpeninsula Regional Open Space District ES-14 Redwood Cabin Removal Project EIR
Table ES-2 Summary Environmental Impacts of the Alternatives Relative to the Redwood Cabin Project
Environmental Topic Proposed Project Alternative 1: No Project Alternative Alternative 2: Stabilize Alternative Alternative 3: Repair and Rehabilitate Alternative
Biological Resources LTSM Slightly Greater Slightly Greater Greater
Cultural Resources SU Slightly Less Less Less
Source: Compiled by Ascent in 2021
Notes: LTSM = Less Than Significant with Mitigation SU = Significant and Unavoidable
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Project Draft EIR 1-1
1 INTRODUCTION
This draft environmental impact report (Draft EIR) evaluates the environmental impacts of the proposed Redwood
Cabin Removal Project (project) and has been prepared under the direction of Midpeninsula Regional Open Space District (Midpen) in accordance with the requirements of the California Environmental Quality Act (CEQA) (Public
Resources Code [PRC] Section 21000-21177) and the State CEQA Guidelines (California Code of Regulations [CCR], Title 14, Division 6, Chapter 3, Sections 15000-15387) (“CEQA Guidelines”).
This chapter of the Draft EIR provides information on the following:
project requiring environmental analysis (synopsis);
type, purpose, and intended uses of the Draft EIR;
scope of the Draft EIR;
agency roles and responsibilities; and
standard terminology.
1.1 PROJECT REQUIRING ENVIRONMENTAL ANALYSIS
The following is a synopsis of the project characteristics. For further information on the proposed project, see
Chapter 2, “Project Description.”
The project would entail demolition of the Redwood Cabin and removal of associated features onsite, including
retaining walls and barbeque pits. After demolition, the site would be left to return to its natural condition. Disturbed portions of the site would be recontoured and erosion control applied to the site to ensure adequate site drainage. The site would be revegetated with native grass seed mix. Excavations that extend below finish grade would be backfilled, compacted, and would entail minor grading as necessary for drainage and erosion control. No public access facilities would be constructed as part of this project.
1.2 PURPOSE AND INTENDED USES OF THIS DRAFT EIR
CEQA requires that public agencies consider the potentially significant adverse environmental effects of projects over
which they have discretionary approval authority before taking action on those projects (PRC Section 21000 et seq.). CEQA also requires that each public agency avoid or mitigate to less-than-significant levels, wherever feasible, the significant adverse environmental effects of projects it approves or implements. If a project would result in significant
and unavoidable environmental impacts (i.e., significant effects that cannot be feasibly mitigated to less-than-significant levels), the project can still be approved, but the lead agency’s decision-maker, in this case the Midpen Board of Directors, must prepare findings and issue a “statement of overriding considerations” explaining in writing the specific economic, social, or other considerations that they believe, based on substantial evidence, make those significant effects acceptable (PRC Section 21002, CCR Section 15093).
According to CCR Section 15064(f)(1), preparation of an EIR is required whenever a project may result in a significant adverse environmental impact. An EIR is an informational document used to inform public agency decision makers
and the general public of the significant environmental effects of a project, identify possible ways to mitigate or avoid the significant effects, and describe a range of reasonable alternatives to the project that could feasibly attain most of the basic objectives of the project while substantially lessening or avoiding any of the significant environmental impacts. Public agencies are required to consider the information presented in the EIR when determining whether to approve a project.
Because it will carry out the project, Midpen is the lead agency, as defined by CEQA, for this EIR. Other public agencies with jurisdiction over the project are listed below in Section 1.5, “Agency Roles and Responsibilities.”
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-2 Redwood Cabin Removal Project Draft EIR
1.3 SCOPE OF THIS DRAFT EIR
This Draft EIR includes an evaluation of the following two environmental issue areas as well as other CEQA-mandated issues (e.g., cumulative impacts, growth-inducing impacts, significant unavoidable impacts, alternatives):
Biological Resources, and
Cultural Resources.
Under the CEQA statutes and the State CEQA Guidelines, a lead agency may limit an EIR’s discussion of
environmental effects when such effects are not considered potentially significant (PRC Section 21002.1[e]; State CEQA Guidelines Sections 15128, 15143). Information used to determine which impacts would be potentially
significant was derived from review of the Redwood Cabin Removal Project; review of applicable planning documents and CEQA documentation; field work; comments received during a public scoping meeting held on June 23, 2021; and comments received on the Notice of Preparation (NOP) (see Appendix A of this Draft EIR). Applicable
documentation includes the La Honda Creek Open Space Preserve Master Plan (2012); La Honda Creek Open Space Preserve Master Plan IS/MND (2012); and the White Barn Stabilization Project Addendum (2021). These documents
are available on Midpen’s website, respectively:
https://www.openspace.org/sites/default/files/La%20Honda%20Creek%20Preserve%20Master%20Plan.pdf https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf https://www.openspace.org/sites/default/files/Addendum%20to%20the%20Master%20Plan%20IS-MND.pdf
The NOP was distributed on June 9, 2021, to responsible agencies, interested parties, and organizations, as well as
private organizations and individuals that may have an interest in the project. The purpose of the NOP and the scoping meeting was to provide notification that an EIR for the project was being prepared and to solicit input on the
scope and content of the environmental document. As a result of the review of existing information and the scoping process, it was determined that each of the issue areas listed above should be evaluated fully in this Draft EIR. Further information on the NOP and scoping process is provided below in Section 1.4, “Public Review Process.”
1.4 PUBLIC REVIEW PROCESS
As identified above in Section 1.3, “Scope of this Draft EIR,” in accordance with CEQA regulations, an NOP was
distributed on June 9, 2021, to responsible agencies, interested parties and organizations, and private organizations and individuals that could have interest in the project. The NOP was available on Midpen’s website and was
distributed to responsible agencies, nearby jurisdictions, adjacent landowners, and local resource protection organizations.
Midpen hosted a virtual public scoping meeting to inform stakeholders about the project and solicit input regarding
environmental topics and alternatives to be evaluated in the EIR. The scoping meeting was held during the Midpen Board of Directors meeting on June 23, 2021.
The purpose of the NOP was to provide notification that an EIR for the project was being prepared and to solicit input on the scope and content of the document. The NOP and responses to the NOP are included in Appendix A of this Draft EIR.
This Draft EIR is being circulated for public review and comment for a period of 45 days. During this period, comments from the general public as well as organizations and agencies on environmental issues may be submitted
to the lead agency.
A virtual public meeting will be held on the Draft EIR on April 27, 2022, at 7 p.m. Upon completion of the public review and comment period, a Final EIR (Final EIR) and Mitigation Monitoring and Reporting Plan (MMRP) will be prepared that will include both written and oral comments on the Draft EIR received during the public-review period, responses to those comments, and any revisions to the Draft EIR made in response to public comments. The Draft EIR
and Final EIR will comprise the EIR for the project.
Exhibit A
Ascent Environmental Introduction
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 1-3
Before approving the Redwood Cabin Removal Project, the lead agency, is required to certify that the EIR has been
completed in compliance with CEQA, that the decision-making body reviewed and considered the information in the EIR, and that the EIR reflects the independent judgment of the lead agency.
1.5 AGENCY ROLES AND RESPONSIBILITIES
This Draft EIR will be used by Midpen and CEQA responsible and trustee agencies to ensure that they have met their requirements under CEQA before deciding whether to approve or permit project elements over which they have
jurisdiction. It may also be used by other state and local agencies, which may have an interest in resources that could be affected by the project, or that have jurisdiction over portions of the project.
As the lead agency pursuant to CEQA, Midpen is responsible for considering the adequacy of the EIR and determining if the project should be approved.
Under CEQA, a responsible agency is a public agency, other than the lead agency, that has responsibility to carry out
or approve a project (PRC Section 21069). A trustee agency is a state agency that has jurisdiction by law over natural resources that are held in trust for the people of the State of California (PRC Section 21070).
The following agencies may serve as responsible agencies for the project:
State
State Water Resources Control Board / San Francisco Bay Regional Water Quality Control Board
Local
County of San Mateo
Bay Area Air Quality Management District
1.6 DRAFT EIR ORGANIZATION
This Draft EIR is organized into chapters, as identified and briefly described below. Chapters are further divided into sections (e.g., Chapter 3, “Environmental Impacts and Mitigation Measures” and Section 3.2, “Cultural Resources”):
The “Executive Summary”: This chapter introduces the project; provides a summary of the environmental review process, effects found not to be significant, and key environmental issues; and lists significant impacts and mitigation measures to reduce or avoid significant impacts.
Chapter 1, “Introduction”: This chapter provides a description of the lead and responsible agencies, the legal authority and purpose for the document, and the public review process.
Chapter 2, “Project Description”: This chapter describes the location, background, and goals and objectives for the Redwood Cabin Removal Project and describes the project elements in detail.
Chapter 3, “Environmental Impacts and Mitigation Measures”: The sections within this chapter evaluate the expected
environmental impacts generated by the project and are arranged by subject area. Within each subsection of Chapter 3, the regulatory background, existing conditions, analysis methodology, and thresholds of significance are described. The anticipated changes to the existing conditions after development of the project are then evaluated for each subject area. For any significant or potentially significant impact that would result from project implementation, mitigation measures are presented and the resulting level of impact significance after implementation of mitigation is identified. Environmental impacts are numbered sequentially within each section (e.g., Impact 3.2-1, Impact 3.2-2, etc.). Any required mitigation measures are numbered to correspond to the impact numbering; therefore, the
mitigation measure for Impact 3.2-2 would be Mitigation Measure 3.2-2.
Chapter 4, “Alternatives”: This chapter evaluates alternatives to the project, including alternatives considered but eliminated from further consideration, the No Project Alternative, and two alternative development options. The environmentally superior alternative is identified.
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-4 Redwood Cabin Removal Project Draft EIR
Chapter 5, “Other CEQA Sections”: This chapter evaluates growth-inducing impacts and irreversible and irretrievable
commitment of resources and discloses any significant and unavoidable adverse impacts.
Chapter 6, “Report Preparers”: This chapter identifies the preparers of the document.
Chapter 7, “References”: This chapter identifies the organizations and persons consulted during preparation of this Draft EIR and the documents and individuals used as sources for the analysis.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-1
2 PROJECT DESCRIPTION
2.1 INTRODUCTION
The Midpeninsula Regional Open Space District (Midpen) is an independent special district in the San Francisco Bay Area that has preserved nearly 65,000 acres of public land and manages 26 open space preserves. Midpen’s mission
is to acquire and preserve a regional greenbelt of open space land; protect and restore the natural environment; and provide opportunities for ecologically sensitive public use and education. On the San Mateo County coast, Midpen’s mission is expanded to include the preservation of agricultural lands and protection and restoration of the natural
environment.
The Redwood Cabin Removal Project (project) site is located within the upper La Honda Creek Open Space Preserve (Preserve) in San Mateo County, California. The approximately 100-year-old building is currently vacant and in disrepair. The project would remove the existing Redwood Cabin and other human-made features (i.e., retaining walls, fire/barbeque pits) within the project site to remove physical hazards and improve site safety, address ongoing trespassing and vandalism issues, and restore natural resource and open space/scenic values of the surrounding mixed evergreen forest. After demolition and removal activities, site recontouring and erosion control measures
would ensure soil stabilization within disturbed portions of the site. No public access facilities would be constructed as part of this project.
2.2 PROJECT LOCATION AND SETTING
The Redwood Cabin is situated within the upper portion of the Preserve. The Preserve encompasses 6,142 acres in the Santa Cruz Mountains within unincorporated San Mateo County, approximately 5 miles east of the Pacific Ocean (see
Figure 2-1). The Preserve is bounded by Highway 35 (Skyline Boulevard) to the north, by Highway 84 (La Honda Road) to the east and south, and by Bogess Creek to the west.
The Redwood Cabin occupies a portion of Assessor’s Parcel Number 075-330-260 and is located west of the community of Skylonda, California. The project site is designated for Forest/Timber Production land uses under the San Mateo County General Plan and is zoned as Timber Land Preserve District under the San Mateo County Zoning Ordinance. Access to the Redwood Cabin is provided via an unpaved road accessible from Skyline Boulevard, which travels through two locked gates. The final segment of this unpaved road requires a four-wheel drive vehicle or
access by foot (see Figure 2-2).
The project site is located in a wooded area within a portion of the Preserve that is currently not open to the public. The building is situated atop sloped terrain overlooking a circular dirt driveway that surrounds a small grove of redwood trees.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-2 Redwood Cabin Removal Project EIR
Source: Data received from Midpeninsula Regional Open Space District in 2020
Figure 2-1 Project Vicinity and Location
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-3
Source: Data received from Midpeninsula Regional Open Space District in 2021
Figure 2-2 Project Site
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-4 Redwood Cabin Removal Project EIR
2.3 DESCRIPTION OF THE PROJECT SITE
2.3.1 Background
The Redwood Cabin is a large, side-gabled log cabin with a rectangular plan. The Redwood Cabin was constructed by
W.B. Allen from 1927-1928 and served as a recreational retreat for Allen’s family and guests, including the YMCA and Rotary Club (LSA Associates 2018; Midpen 2020). The Redwood Cabin was acquired by Midpen in 1988 and has since remained uninhabited. Today, the Redwood Cabin stands in a deteriorated state, posing a significant site safety
hazard and has been the site of numerous trespassing and vandalism incidents (including fire ignitions) that raise concerns regarding overall public safety and fire risk within a very high fire severity zone.
In 2020, Page & Turnbull, Inc. prepared a Historic Resource Evaluation to assess the Redwood Cabin’s eligibility for listing in the California Register of Historical Resources (CRHR). The Historic Resource Evaluation determined that the Redwood Cabin is an historic resource per CEQA because it appears to be eligible for listing in the CRHR. The
Redwood Cabin appears to be one of few remaining examples of a permanent recreational cabin in the Santa Cruz Mountains from the 1920s with a high degree of historic integrity—historic integrity refers to a building’s original character and materials, not the physical condition of the building—and is representative of the peak of recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1); and is a unique example of a rustic recreational cabin in the surrounding area (CRHR Criterion 3).
On April 8, 2020, the Midpen Board of Directors directed the General Manager to evaluate the environmental effects that would result from removing the Redwood Cabin and implementing habitat enhancements to reflect native
ecological conditions.
STRUCTURE CONDITION
The Redwood Cabin has an approximately 2,000-square-foot footprint and is constructed of barked redwood logs with saddle notches. The cabin is supported by large rustic wood posts, some of which are set in concrete and others
of which are set on grade. The main entry is centered on the eastern façade and features a thick redwood burl door. Double casement windows of various sizes are present throughout all façades of the structure. The roof consists of a
side-gable design with five skylights present on the east-facing roof gable. Representative photographs are shown in Figures 2-3 and 2-4. A wood plank floored deck supported by pressure treated timber previously wrapped around all four façades of the Redwood Cabin.
There is a central interior stone chimney that connects to an expansive interior fireplace. The interior of the Redwood Cabin contains a large stone fireplace in its living room, two small bedrooms, a bathroom, and a kitchen. On either side
of the wall separating the two bedrooms are middens of San Francisco dusky-footed woodrat built around corner lavatories. A midden was also observed inside the kitchen cabinetry in the southwest corner of the Redwood Cabin.
In 2020, ZFA Structural Engineers prepared a Structure Stabilization Basis of Design report (Basis of Design Report). The Basis of Design Report indicates that the Redwood Cabin is in generally poor-to-fair structural condition with obvious structural damage and apparent deterioration. Findings within the Basis of Design Report also revealed the
presence of lead-based paint as well as several potential seismic deficiencies (ZFA 2020).
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-5
Source: Midpen in 2021
Photo 1: Redwood Cabin, eastern façade.
Source: Ascent Environmental in 2021
Photo 2: Fire pit at front, barbeque at rear.
Figure 2-3 Representative Photographs
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-6 Redwood Cabin Removal Project EIR
Source: Midpen in 2021
Photo 3: Redwood Cabin, northern façade.
Source: Ascent Environmental in 2021
Photo 4: Redwood Cabin, western façade.
Figure 2-4 Representative Photographs
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-7
VANDALISM
The Redwood Cabin has a history of periodic trespass including recent vandalism events in 2021. Given the deteriorating condition of the structure, trespassing incidents raise concerns regarding public safety. On February 16,
2021, Midpen staff visited the Redwood Cabin and observed signs of recent vandalism: broken locks, smashed windows, and deliberate dismantlement of the deck and railing. In some cases, a remote location can protect an
unoccupied structure from trespass and vandalism, but with the Redwood Cabin, it is clear that numerous people are aware of its location. Evidence of fires have been found in the past in the nonfunctional fireplaces in the Redwood Cabin, which raise concerns regarding potential fire risk given the site’s located within a very high fire severity zone. The difficult access to this location makes regular patrol challenging, and any illegal activity unlikely to be observed and reported by the public.
To prevent future unauthorized entry, Midpen installed plywood boards over window and door openings that could provide ingress into the Redwood Cabin. Midpen also posted new signage around the Redwood Cabin to convey its status as a “hazardous closed area,” which elevates the trespass penalty to a misdemeanor (code MROSD 802.2[b]). After trespass and vandalism were observed in April 2021, Midpen removed portions of the building’s wraparound deck that were in a highly dilapidated and collapsible condition to address exterior public safety concerns
OTHER SITE FEATURES
Much of the area surrounding the Redwood Cabin is wooded. The driveway is partially delineated by stone walls and a staircase that previously connected to the Redwood Cabin deck. Various remnants of the prior use of the Redwood Cabin are scattered throughout the property, including horseshoe pits, as well as a stone barbeque pit and a brick
planter (also referred to as fire pit) located east of the Redwood Cabin. Additionally, several stone retaining walls are present to the east and west of the structure.
2.3.2 Project Objectives
The proposed project is intended to achieve the following primary objectives, in alignment with Midpen’s mission:
Remove physical hazards to ensure public safety,
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate surroundings,
Reduce structure and wildland fire risk by removing a structure with a history of vandalism,
Improve natural visual character and scenic open space qualities at the site, and
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district.
2.4 DESCRIPTION OF THE PROJECT
2.4.1 Redwood Cabin Removal
The project would entail demolition of the Redwood Cabin and removal of associated features onsite, including the
stone retaining walls and barbeque and fire pits. Prior to demolition activities, lead-based paint present within the structure would be properly removed and disposed.
While it is expected that excavation of posts and bases associated with the structure would be approximately 2 feet below grade, it is possible that maximum depth of excavation could reach up to 5 feet. During demolition of the structure, it is estimated that approximately 60 tons of material would be removed from the project site (ZFA 2020). Tree removal will not be required to facilitate demolition activities, although some brush clearing along the access road may be necessary.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-8 Redwood Cabin Removal Project EIR
2.4.2 Site Recontouring and Revegetation
Following completion of demolition activities, disturbed areas would be recontoured and erosion control applied to the site to ensure adequate site drainage. All demolition and recontoured areas would be compacted to 75 percent
relative compaction. Native grass seed mix would be spread in the disturbed areas and weed free or native grass straw would be placed in the disturbed areas, on top of the native grass seed mix, to assist with soil stabilization and erosion control. Any wood chips or mulch generated from unsalvageable building materials may also be used to
stabilize disturbed areas but will not be more than 3 inches in depth. Midpen may also conduct the following activities on the project site after demolition and recontouring:
soil decompaction activities outside of critical rootzones,
soil testing and, if needed, spot application of amendments such as fertilizers, lime, or organic materials, and
revegetation or plantings.
Midpen also conducts early detection rapid response surveys for up to 3 years at revegetation sites and treats any invasive plant species on the early detection rapid response list. Other priority integrated pest management target
species, including slender false brome may be treated prior to and after construction. Slender false brome is an invasive weed of high concern at the project site; due to Midpen’s mandatory quarantine of this weed, all slender false brome in the area will be treated prior to any work being completed.
Current activity at the project site consists of occasional visits from Midpen staff for inspections. Once removal of the structure and site recontouring/erosion control activities are complete, no additional maintenance or
operational activities would be required at the project site except for invasive plant species treatment, if needed. The site would remain closed to the public.
2.5 CONSTRUCTION ACCESS, EQUIPMENT, STAGING, AND LOGISTICS
Project construction activities are estimated to begin in Fall 2023 over a duration of 10 weeks. The project would be
implemented by crews consisting of approximately eight personnel. Construction activities (i.e., demolition and revegetation work) would typically occur between 7:00 a.m. and 3:30 p.m. Monday through Friday, and no work would occur on Sundays or holidays. Consistent with Section 4.88.360 of the San Mateo County Noise Ordinance for
construction, any work occurring on Saturday would begin no earlier than 9:00 a.m.
Equipment and vehicles would access the project area from Highway 35 (via Highways 92 or 84), then to the unpaved driveway extended from Highway 35 to the project site. Project construction activities would not require any road closures. However, because it is uncertain if southbound Highway 35 provides adequate sight distance/stopping distance in the vicinity of where heavy vehicles would need turning access to the project site, Midpen will prepare a
temporary traffic control plan to ensure the safety of Highway 35 road users and construction workers.
The California Manual on Uniform Traffic Control Devices (CA-MUTCD), Part 6: Temporary Traffic Control provides principles and guidance for the implementation of temporary traffic control to ensure the provision of reasonably safe and effective movement of roadway users through or around temporary traffic control zones while reasonably protecting road users, workers, responders to traffic incidents, and equipment. Thus, the anticipated elements of the temporary traffic control plan listed below shall be developed and implemented consistent with guidance provided in CA-MUTCD, Part 6: Temporary Traffic Control and all applicable industry standards.
At a minimum, the temporary traffic control plan will include the following elements:
Emergency services access to local land uses shall be maintained at all times for the duration of construction activities.
Signage along Highway 35 to notify local traffic of a construction access point.
Roadside safety protocols shall be complied with to reduce the risk of accident.
Use flaggers to direct traffic as necessary to ensure adequate stopping distance.
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-9
Construction equipment, materials, and vehicle staging would occur within the driveway area of the project site. The
construction staging area is identified in Figure 2-2. The following pieces of equipment and vehicles are anticipated:
excavator,
manlift(s),
skidsteer,
water truck,
boom truck,
forklift, and
haul truck(s).
An existing bridge is located east of the Redwood Cabin on the unpaved road that provides access to the project site. A temporary bridge may be required to span this existing bridge due to limitations in the bridge’s current load
capacity. The temporary bridge would be placed over the existing bridge deck to span the drainage without temporary or permanent encroachments into the streambank. The temporary bridge would be removed after construction.
The total acreage of the project (which includes the staging area and project site boundaries) is identified in Figure 2-2 (approximately 0.7 acres). All construction-related hazardous materials and waste will be covered and secured at
the end of each working day. The secure location shall be determined by the Midpen project manager and should be positioned away from sources of water. Waste generated by project construction activities would be disposed of offsite. If the building materials are in good condition, Midpen will conduct salvage operations per the process outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. Likely waste disposal locations are provided below in Table 2-1 and have been used by Midpen on past projects.
Table 2-1 Potential Waste Disposal Facilities
Waste Facility Location Waste Facility Information
Republic Services Ox Mountain Sanitary Landfill 12310 San Mateo Road, Half Moon Bay, CA
Ox Mountain is a Class III landfill that accepts motor oil and most solid wastes, including clean metals, recyclables, construction debris, and greenwaste; it does not accept hazardous wastes.
Waste Management Kettleman Hills Landfill 35251 Old Skyline Road, Kettleman City, CA
1,600-acre hazardous waste treatment, storage, and disposal facility. Accepts municipal solid waste and most types of hazardous wastes as defined by the USEPA and/or state of California (e.g., Class I hazardous wastes, asbestos debris, petroleum and/or metal contaminated soils/debris, various sludges)
Source: City of Half Moon Bay 2014; Waste Management 2020
2.6 PERMITS AND APPROVALS
Table 2-2 below discloses the potential permits and approvals that may be required to implement the project.
Table 2-2 Potential Permits and Approvals
Permit/Approval Agency Purpose/Applicability
Project Approval Midpen Midpen Board of Directors – approval of the project
General Construction Permit RWQCB Regional Water Quality Control Board – general construction permit
Building County of San Mateo San Mateo County Planning and Building Department – demolition and grading permits
Construction BAAQMD Bay Area Air Quality Management District – register all portable equipment permits with BAAQMD; notify BAAQMD of all demolition activities 10 days prior to occurrence of activity.
Compiled by Ascent in 2021.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-10 Redwood Cabin Removal Project EIR
2.7 BEST MANAGEMENT PRACTICES
Midpen has adopted numerous best management practices (BMPs) that are intended to avoid and minimize environmental impacts and comply with applicable laws and regulations. For the purposes of these guidelines,
references to “Midpen” also encompasses any contractors hired to implement the treatments. These BMPs would be incorporated into the design of the project.
2.7.1 La Honda Creek Open Space Preserve Master Plan EPGs
The environmental protection guidelines (EPGs) listed below are identified in Midpen’s La Honda Creek Open Space Preserve Master Plan and the associated 2012 Initial Study/Mitigated Negative Declaration (IS/MND) (Midpen 2012a;
2012b), many of which were based on, and therefore reference, the San Mateo Coastal Annexation EIR. The Project is not located within the designated Coastal Area; however the EPG’s can be applied, if appropriate. The EPGs below have minor text modifications (shown in strike-through and underline) to reflect subsequent changes in Midpen’s
guidelines, such as adoption of the Integrated Pest Management Program (IPMP), since the time the 2012 IS/MND and Master Plan were approved. These minor changes were addressed in the White Barn Stabilization Project Addendum (Ascent 2021) and do not affect the effectiveness of the measures, but instead provide clarity and specificity. Additional project-specific revisions to the EPGs (shown in double strike-through and double underline) are included to increase their direct application to the current project and thereby enhance their effectiveness. Explanations for the revisions are shown as footnotes. These revisions will not apply to future Midpen projects.
AIR QUALITY
EPG AQ-1: Midpen shall insure that the following measures are included in all future as part of construction contracts
to control fugitive dust emissions:
Water all active construction areas at least twice daily and more often during windy periods. Active areas adjacent to existing land uses shall be kept damp at all times, of shall be treated with non-toxic stabilizers or dust palliatives;1
Cover all trucks hauling soil, sand and other 2 loose materials and/or require all trucks to maintain at least two feet of freeboard;
Pave or, aApply water up to three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking areas and staging areas for construction sites;3
Sweep daily (preferably with water sweepers) all paved access roads if visible soil material is carried onto paved access roads, parking areas and staging areas at construction sites;4
Sweep streets daily (preferably with water sweepers) if visible soil material is carried onto adjacent public streets;
Hydroseed or apply non-toxic soil stabilizers to inactive construction areas;
Enclose, cover, or water twice daily or apply non-toxic soil binders to any exposed stockpiles (dirt, sand, etc.);
Limit traffic speeds on unpaved roads to 15 mph;
Install sandbags or other wildlife friendly erosion control measures to prevent silt runoff to public roadways;
Replant vegetation in disturbed areas as quickly as possible with locally appropriate native plants;
Suspend excavation and grading activity whenever the wind is so high that it results in visible dust plumes despite control efforts.
1 There are no existing land uses adjacent to the project site.
2 No sand or soil will be hauled during project implementation.
3 Paving is not occurring with the project and the project site does not include paved parking or staging areas.
4 The project site does not include paved parking or staging areas.
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-11
BIOLOGICAL RESOURCES
EPG BIO-10: Revegetation and/or enhancement shall be undertaken where any sensitive habitat or special-status species habitat will be disturbed or destroyed by facility construction. The project includes rRevegetation work to
enhance the natural open space values of the site shall be implemented prior to or concurrently with the development. The design of an appropriate revegetation work program shall will be designed to return native species
to the site, including the areas underlying footprint of where the Redwood Cabin structure and other accessory structure currently stand.5 fully compensate for the lost habitat, with no net loss of habitat functions and values.
Riparian and wetland habitat impacts will typically be mitigated at a 3:1 ratio for high quality habitat areas and at lower ratios where lower habitat quality justifies a lower ratio. A lower ratio may also be justified if habitat mitigation is implemented and verified as successful prior to the occurrence of impacts. Mitigation shall be based on in-kind
replacement of impacted habitat with habitat of equal or better biotic value. 6The revegetation program work shall will be designed by a qualified District-approved biologist or ecologist and submitted to the appropriate regulatory
or trustee agency for approval, if required. At a minimum, the revegetation program shall include a description of project impacts, mitigation calculations, the mitigation site, revegetation techniques, maintenance measures, a long-term monitoring program, and contingency measures. Native plant materials suited to the site will be utilized in all
mitigation work.7
CULTURAL RESOURCES
EPG CUL-1: Midpen will apply the Standard Protocol for Unexpected Discovery of Archaeological and Paleontological
Cultural Materials:
Protocol for Unexpected Discovery of Archaeological and Paleontological Cultural Materials. In the event that any cultural resources are exposed during construction, work at the location of the find will halt immediately within 10
meters (30 feet) of the find. If an archaeologist is not present at the time of the discovery, Midpen will contact an archaeologist for identification and evaluation in accordance with CEQA criteria.
A reasonable effort will be made by Midpen and archaeologist to avoid or minimize harm to the discovery until significance is determined and an appropriate treatment can be identified and implemented. Methods to protect finds include fencing, covering remains with protective material and culturally sterile soil or plywood. If vandalism
is a threat, 24-hour security shall be provided. During this evaluation period, construction operations outside of the find location can continue preferably with an archaeologist monitoring any subsurface excavations.
If the resource cannot be avoided, the archaeologist will develop an appropriate Action Plan for treatment within 48 hours to minimize or mitigate the adverse effects. Midpen will not proceed with construction activities that could affect the discovery until the Action Plan has been reviewed and approved. The treatment effort required to mitigate the inadvertent exposure of significant cultural resources will be guided by a research design appropriate to the discovery and potential research data inherent in the resource in association with suitable
archaeological field techniques and analytical strategies. The recovery effort will be detailed in a professional report in accordance with current archaeological standards. Any non-grave associated artifacts will be curated with an appropriate repository.
EPG CUL-2: Application of the Native American Burial Plan (NABP) will be applied:
Native American Burial Plan
1. In the event of an inadvertent discovery of human remains and cultural items during project construction, the field crew supervisor shall take immediate steps, if necessary, to secure and protect any remains and cultural
materials. This shall include but is not limited to such measures as (a) temporary avoidance by construction
5 Restoration is not proposed as part of the project. Seeding of native species is considered revegetation and will not lead to increased ecological function such as with full restoration.
6 Biological mitigation for loss of habitat is not required for this project. As described in Section 3.1, “Biological Resources,” the impact to riparian
and wetland habitat is less than significant.
7 Because mitigation for habitat loss is not required, these items are not applicable.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-12 Redwood Cabin Removal Project EIR
until the remains and items can be removed; (b) posting a security person; (c) placement of a security fence
around the area of concern; or, (d) some combination of these measures. Any such measures employed will depend upon the nature and particular circumstances of the discovery.
2. The County Medical Examiner (Coroner) shall be notified by the field crew supervisor or other designated Midpen manager and informed of the find and of any efforts made to identify the remains as Native American. If the remains are identified as a prehistoric Native American by either a professional archaeologist
under contract to Midpen or the Medical Examiner’s forensic archaeologist, the Medical Examiner is responsible for contacting the Native American Heritage Commission (NAHC) within 24 hours of notification of the find. The Medical Examiner may choose to document and remove the remains at his/her discretion depending on the circumstances of the discovery. The NAHC then designates and notifies a Most Likely Descendant (MLD). The MLD has 24 hours to consult and provide recommendations for the treatment or
disposition, with proper dignity, of the human remains and grave goods [Note: Other culturally affiliated Native Americans [Indians] may be consulted by the MLD during the consultation and recommendation
process to determine treatment of the skeletal remains].
3. Each burial and associated cultural items shall be stored as a unit in a secure facility, which shall be accessible to the MLD and other Native American representative(s) or their designated alternates upon prior arrangement.
4. The remains and associated cultural items shall be reburied in a secure location as near as possible to the area of their discovery or at an off-site location acceptable to the MLD that has minimal potential for future
disturbance. The reburial shall be done in a manner that shall discourage or deter future disturbance. Reburial shall be conducted by persons designated by the MLD, with the assistance, if requested, of Midpen’s field crew. The location shall be fully documented, filed with the NAHC and the California Historical
Resources Information System, Northwest Information Center, California State University, Sonoma and treated as confidential information.
5. If the NAHC is unable to identify a MLD, or the MLD fails to make a recommendation, or Midpen or designate rejects the recommendation of the MLD and mediation (as per Section 5097.94 subdivision (k)) fails, reinterment of the human remains and associated cultural items associated shall take place with appropriate dignity on the property in a location not subject to further subsurface disturbance.
6. For security reasons, no news releases, including but not limited to photographs, videotapes, written articles, or
other such means that contains information about human remains or burial-related items of Native American origin shall be released by any party during the discovery, recovery and reburial unless approved by the MLD.
7. Any disputes that arise among the MLD and representatives of affected Native American groups and/or between Midpen or designee designate and the MLD concerning cultural affiliation or the ultimate
disposition of Native American human remains and associated funerary objects and unassociated funerary objects shall be resolved according to the dispute resolution procedures in Section 5097.94 of the State of
California Public Resources Code.
8. The Archaeological Data Recovery/Native American Burial Treatment Report(s) shall be prepared by professional archaeologists. The report shall include, but not be limited to, the following: project overview;
ethnographic section; previous archaeological research in the region and on-site; circumstances of discovery; recovery procedures and techniques; artifact analysis; faunal analysis; osteological analysis and interpretation;
and, conclusions. The MLD and other interested Native American representative(s) shall be provided an opportunity to review the report and submit comments within the same time period as accorded any other reviewers.
9. Objects not associated with the human remains and recovered from private land shall be transferred to Midpen. If curation of any objects is required, curation will be at repository approved by Midpen.
Repositories can include the History Museums of San Jose collections, the Tiburon Archaeological Research Group, San Francisco State University and the Collections Facility, Department of Anthropology, Sonoma State University, Rohnert Park.
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-13
EPG CUL-3: The protocol for determining if structures are of historic value is as follows:
1. The property and building types will be identified and evaluated by a qualified cultural consultant;
2. The cultural consultant will determine if the structures in question are currently included in a local register of
historic resources, on the California Register of Historic Resources or on the National Register of Historic Places;
3. If it is determined that the structures in question are not currently included in a local register of historic resources, on the California Register of Historic Resources or on the National Register of Historic Places, a
DPR 523 form issued by the California Department of Parks and Recreation (DPR) will be completed by the cultural consultant and the structural and building data sent to a qualified architectural historian.
4. The following measure applies only to the Southern La Honda Creek Area: As required by Mitigation CUL-1a(4) of the San Mateo Coastal Annexation EIR, if it is determined that the structures in question are currently on the California Register of Historic Resources or if the building has been determined to be of
historic value, there are two options that would mitigate any impact to the historic values:
a) Retain and rehabilitate the building according to the Secretary of the Interior’s Standards and
Guidelines for Rehabilitating Historic Buildings (U.S. Department of Interior 1990). New construction near this building should be consistent with its historic character; or
b) Move the building to a different location on its current parcel or to a different parcel appropriate to its historic character.8
HAZARDS AND HAZARDOUS MATERIALS
Although the La Honda Creek Open Space Preserve Master Plan does not contain specific hazardous material EPGs
that apply to this specific project, the document does list the following required hazards BMPS:
1. Remove all trash and construction-related waste to a secured, covered location at the end of each working
day to maintain a clean worksite. Dispose of hazardous materials according to all specified regulations.
2. Store chemicals in a non-reactive container. Store bagged, dry reactive materials in a secondary container. Protect storage areas from vandalism.
3. Mix concrete no closer than 25 feet from any waterway or open ditches. Concrete shall be mixed in secure containments. Cleaning of tools shall occur in secured containments; no concrete cleaning is allowed in
drainages or water bodies. All concrete waste shall be off hauled; concrete is allowed to first evaporate in containments for ease of off haul.9
4. Good housekeeping practices shall be followed to minimize storm water contamination from any petroleum
products or other chemicals. Maintain spill cleanup materials where readily accessible during use.
5. Conduct proper & timely maintenance of vehicles and equipment. Cleaning or equipment maintenance shall
be prohibited except in designated areas located near preserve entrances. If fueling must occur onsite, use designated areas located away from drainages and a drip pan to catch spills. Place drip pans under heavy equipment stored onsite overnight.
6. Instruct all personnel regarding the correct procedure for spill prevention and control, waste disposal, use of chemicals, and storage of materials.
8 This applies to the Southern La Honda Creek Area only and therefore is not relevant to the project.
9 The project does not include the use of concrete.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-14 Redwood Cabin Removal Project EIR
EPG HAZ-9: In order to reduce fire ignition risk, Midpen shall require the following measures for all maintenance and
construction activities within the Preserve:
All equipment to be used during construction and maintenance demolition10 activities must have an approved
spark arrestor.
Grass and fuels around construction demolition sites where construction 11 vehicles are allowed to be parked will be cut or reduced.
Mechanical construction12 equipment that can cause an ignition will not be used when the National Weather Service issues a Red Flag Warning for the San Francisco Bay Area.
Hired contractors will be required to:
Provide water to suppress potential fires caused by the work performed.
Remind workers that smoking is prohibited at the work site and on any District land per contract conditions
and District Ordinance.
Maintain working ABC fire extinguishers on all vehicles in the work area.
Contact both Mountain View Dispatch at (650) 968-4411 and CAL FIRE, Skylonda, at (650) 851-1860 for emergency response in the event of a fire.
HYDROLOGY AND WATER QUALITY
EPG WQ-2: Storm water quality Best Management Practices (BMPs) as listed in this section shall be implemented to
reduce potential water quality impacts. BMPs include:
1. Flow of runoff from drainage structures will be directed to vegetated areas, away from creeks and drainages
as is practical.
2. Conduct any trail maintenance work during low flow periods. 13
3. Use erosion and sediment control measures to minimize water quality impacts and ensure no sediment at
heavily traveled trails flows into creeks. To the extent feasible, all measures will be 100 percent biodegradable and/or certified weed-free. These measures include:
Silt Fences
Straw Bale Barriers
Brush or Rock Filters
Storm Drain Inlet Protection
Sediment Traps
Sediment Basins
Erosion Control Blankets and Mats
Midpen shall prevent erosion on steep slopes by using erosion control material according to manufacturer’s specifications.
4. If soil is to be stockpiled for any reason at creeksides, no run-off will be allowed to flow back to the creek.
10 No new construction is proposed. The project entails demolition activities.
11 No new construction is proposed. The project entails demolition activities.
12 No new construction is proposed. The project entails demolition activities.
13 The project does not include trail maintenance.
Exhibit A
Ascent Environmental Project Description
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 2-15
Additional required Best Management Practices to project water quality:
5. Schedule project during the dry season to avoid erosion due to surface runoff during the construction phase demolition and site revegetation activities. 14
6. Construct rolling dips in areas where trail gradients exceed five percent to reduce runoff concentration; outslope trail surfaces where feasible. 15
7. Implement road and trail seasonal closures to vehicles and our recreation use, where and when
appropriate.16
NOISE AND VIBRATION
EPG NOI-1: Midpen will ensure that all construction activity associated with implementation of the Master Plan will occur during the less sensitive daytime hours between 7:00 a.m. and 5:00 p.m. daily.
2.7.2 Integrated Pest Management Program BMPs
In addition, the BMPs listed below from Midpen’s 2014 IPMP (Midpen 2014) and subsequent 2019 IPMP (Midpen
2019) addendum would be incorporated into the design of the project.
IPMP BMP 11: Sanitation and Prevention of Contamination -All personnel working in infested areas shall take appropriate precautions to not carry or spread weed seed or SOD-associated spores outside of the infested area.
Such precautions will consist of, as necessary based on site conditions, cleaning of soil and plant materials from tools, equipment, shoes, clothing, or vehicles prior to entering or leaving the site.
IPMP BMP 12: All staff, contractors, and volunteers shall be properly trained to prevent spreading weeds and pests to other sites.
IPMP BMP 14: Midpen staff shall ensure that rental equipment and project materials (especially soil, rock, erosion control material and seed) are free of invasive plant material prior to their use at a worksite.
IPMP BMP 21: A Midpen-approved biologist shall survey all selected treatment sites shortly before work to determine
site conditions and develop any necessary site-specific measures. Treatment sites are defined as areas where IPM activity, including manual, mechanical, and chemical treatment, is expected to occur. In addition, on a repeating basis,
grassland treatment sites shall be surveyed by a Midpen-approved biologist once every five years and brushy and wooded sites shall be surveyed once every five years. Brush removal on rangelands will require biological surveys before work is conducted in any year. Site inspections shall evaluate existing conditions at a given treatment site including the presence, population size, growth stage, and percent cover of target weeds and pests relative to native plant cover and the presence of special-status species and their habitat, or sensitive natural communities.
In addition, annual worker environmental awareness training shall be conducted for all treatment field crews and contractors for special-status species and sensitive natural communities determined to have the potential to occur on
the treatment site by a Midpen approved biologist. The education training shall be conducted prior to starting work at the treatment site and upon the arrival of any new worker onto sites with the potential for special-status species or sensitive natural communities. The training shall consist of a brief review of life history, field identification, and habitat
requirements for each special-status species, their known or probable locations in the vicinity of the treatment site, potential fines for violations, avoidance measures, and necessary actions if special-status species or sensitive natural
communities are encountered.
14 No new construction is proposed with the project.
15 No new construction is proposed with the project.
16 There is currently no public access to the project site.
Exhibit A
Project Description Ascent Environmental
Midpeninsula Regional Open Space District 2-16 Redwood Cabin Removal Project EIR
2.7.3 Project Specific BMPs
In addition, to the La Honda Creek Open Space Preserve Master Plan EPGs and the IPMP BMPs, Midpen has identified additional BMPs that are specific to this project to avoid and minimize environmental impacts and comply
with applicable laws and regulations. For the purposes of these guidelines, references to “Midpen” also encompasses any contractors hired to implement the treatments. These BMPs would be incorporated into the design of the project.
BMP AQ-1: Midpen is responsible for implementing the following Basic Construction Mitigation Measures in addition
to EPG AQ-1 to reduce emissions from construction-related activities and to satisfy BAAQMD’s BMP requirements.
Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling
time to 5 minutes (as required by the California airborne toxics control measure CCR Title 13, Section 2485). Clear signage shall be provided for construction workers at all access points.
All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s
specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. BAAQMD’s phone number shall
also be visible to ensure compliance with applicable regulations.
BMP GHG-1: To satisfy GHG emission reduction measures provided by BAAQMD, the project contractor is responsible for using alternative fueled (e.g., biodiesel, electric) construction vehicles/equipment for at least 15 percent of the
fleet. An exemption from this requirement may be granted if the contractor documents that alternative fuel is not reasonably available within the County.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3-1
3 ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
APPROACH TO THE ENVIRONMENTAL ANALYSIS
This draft environmental impact report (Draft EIR) evaluates and discloses the environmental impacts associated with the Redwood Cabin Removal Project, in accordance with the California Environmental Quality Act (CEQA) (Public
Resources Code [PRC] Section 21000, et seq.) and the State CEQA Guidelines (California Code of Regulation, Title 14, Chapter 3, Section 1500, et seq.). Sections 3.1 and 3.2 of this Draft EIR present a discussion of regulatory background, existing conditions, environmental impacts associated with construction and operation of the project, mitigation
measures to reduce the level of impact, and residual level of significance (i.e., after application of mitigation, including impacts that would remain significant and unavoidable after application of all feasible mitigation measures). Issues evaluated in these sections consist of the environmental topics identified for review in the Redwood Cabin Removal Project Initial Study (IS) (see Appendix B). Sections 3.1 and 3.2 of this Draft EIR also include a “Cumulative Impacts” discussion which presents an analysis of the project’s impacts considered together with other past, present, and probable future projects producing related impacts, as required by Section 15130 of the State CEQA Guidelines. Chapter 4, “Alternatives,” presents a reasonable range of alternatives and evaluates the environmental effects of
those alternatives relative to the proposed project, as required by Section 15126.6 of the State CEQA Guidelines. Chapter 5, “Other CEQA Sections,” includes an analysis of the project’s growth inducing impacts, as required by Section 21100(b)(5) of CEQA.
STANDARD TERMINOLOGY
This Draft EIR uses the following standard terminology:
“No impact” means no change from existing conditions (no mitigation is needed).
“Less-than-significant impact” means no substantial adverse change in the physical environment (no mitigation is
needed).
“Potentially significant impact” means an impact that might cause a substantial adverse change in the environment
(mitigation is recommended because potentially significant impacts are treated as significant).
“Significant impact” means an impact that would cause a substantial adverse change in the physical environment
(mitigation is recommended).
“Significant and unavoidable impact” means an impact that would cause a substantial adverse change in the physical environment and that cannot be avoided, even with the implementation of all feasible mitigation.
INTRODUCTION TO THE ANALYSIS
In accordance with Section 15126.2 of the State CEQA Guidelines, this Draft EIR identifies and focuses on the
significant direct and indirect environmental effects of the project, giving due consideration to both its short-term and its long-term effects. Short-term effects are generally those associated with construction, and long-term effects are generally those associated with project operations. As part of the IS prepared for the project and provided in
Appendix B, the project was determined to have either less-than-significant impacts with mitigation incorporated, less-than-significant impacts, or no impact for the majority of environmental resource categories. The following discussion summarizes the analysis conducted for these resource categories, and presents any mitigation determined to be necessary to reduce impacts to less than significant. Refer to Appendix B for further clarification.
Exhibit A
Approach to Environmental Analysis Ascent Environmental
Midpeninsula Regional Open Space District 3-2 Redwood Cabin Removal Project Draft EIR
ENVIRONMENTAL RESOURCE CATEGORIES NOT EVALUATED FURTHER
CEQA allows a lead agency to limit the detail of discussion of the environmental effects that are not considered potentially significant (PRC Section 21100, CCR Sections 15126.2[a] and 15128). Effects dismissed in an IS as clearly
insignificant and unlikely to occur need not be discussed further in the EIR unless the lead agency subsequently receives information inconsistent with the finding in the IS (CCR Section 15143).
Based on comments received as part of the public scoping process (Appendix A) and a review of the information
presented in the IS prepared for the project (Appendix B), as well as additional research and analysis of relevant project data during preparation of this Draft EIR, the following were identified as resources that would not experience any significant environmental impacts from the project.
Aesthetics
Agriculture and Forest Resources
Air Quality
Energy
Geology / Soils
Greenhouse Gas Emissions
Hazards / Hazardous Materials
Hydrology / Water Quality
Land Use / Planning
Mineral Resources
Noise
Population / Housing
Public Services
Recreation
Transportation
Tribal Cultural Resources
Utilities / Service Systems
Wildfire
As described in the IS, project impacts related to air quality (discussed on pages 3-5 through 3-12), energy (discussed on pages 3-18 through 3-19), and greenhouse gasses (discussed on pages 3-24 through 3-27) were determined to be
less than significant with implementation of project-specific BMPs, as described in Section 2.7.3 of Chapter 2, “Project Description.”
ENVIRONMENTAL RESOURCE CATEGORIES EVALUATED FURTHER
This EIR’s analysis provides a more detailed evaluation of the following two environmental resource topics that require or merit additional explanation beyond what is provided in the IS:
Section 3.1, Biological Resources
Section 3.2, Cultural Resources
Sections 3.1 and 3.2 of this Draft EIR each include the following components as they relate to the two environmental resource topics:
Regulatory Setting: This subsection presents information on the laws, regulations, plans, and policies that relate
to the issue area being discussed. Regulations originating from the federal, state, and local levels are each discussed as appropriate.
Environmental Setting: This subsection presents the existing environmental conditions on the project site and in the surrounding area as appropriate, in accordance with State CEQA Guidelines Section 15125. The discussions of
the environmental setting focus on information relevant to the issue under evaluation. The extent of the environmental setting area evaluated (the project study area) differs among resources, depending on the locations where impacts would be expected.
Environmental Impacts and Mitigation Measures: This subsection presents thresholds of significance and discusses potentially significant effects of the project on the existing environment, including the environment
beyond the project boundaries, in accordance with State CEQA Guidelines Section 15126.2. The methodology for
Exhibit A
Ascent Environmental Approach to the Environmental Analysis
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3-3
impact analysis is described, including technical studies upon which the analyses rely. The thresholds of
significance are defined and thresholds for which the project would have no impact are disclosed and dismissed from further evaluation. Project impacts and mitigation measures are numbered sequentially in each subsection
(Impact 3.2-1, Impact 3.2-2, Impact 3.2-3, etc.). A summary impact statement precedes a more detailed discussion of the environmental impact. The discussion includes the analysis, rationale, and substantial evidence upon which conclusions are drawn. The determination of level of significance of the impact is defined in bold text. A “less-
than-significant” impact is one that would not result in a substantial adverse change in the physical environment. A “potentially significant” impact or “significant” impact is one that would result in a substantial adverse change in the physical environment; both are treated the same under CEQA in terms of procedural requirements and the need to identify feasible mitigation. Mitigation measures are identified, as feasible, to avoid, minimize, rectify, reduce, or compensate for significant or potentially significant impacts, in accordance with the State CEQA
Guidelines Section 15126.4. Unless otherwise noted, the mitigation measures presented are recommended in the EIR for consideration by Midpen’s Board of Directors to adopt as conditions of approval.
Where an existing law, regulation, or permit specifies mandatory and prescriptive actions about how to fulfill the regulatory requirement as part of the project definition, leaving little discretion in its implementation, and would avoid an impact or maintain it at a less-than-significant level, the environmental protection afforded by the regulation is considered before determining impact significance. Where existing laws or regulations specify a mandatory permit process for future projects, performance standards without prescriptive actions to accomplish
them, or other requirements that allow substantial discretion in how they are accomplished, or have a substantial compensatory component, the level of significance is determined before applying the influence of the regulatory requirements. In this circumstance, the impact would be potentially significant or significant, and the regulatory
requirements would be included as a mitigation measure.
This subsection also describes whether mitigation measures would reduce project impacts to less-than-significant levels. Significant-and-unavoidable impacts are identified as appropriate in accordance with State CEQA Guidelines Section 15126.2(b). Significant-and-unavoidable impacts are also summarized in Chapter 5, “Other CEQA Sections.”
Exhibit A
Approach to Environmental Analysis Ascent Environmental
Midpeninsula Regional Open Space District 3-4 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-1
3.1 BIOLOGICAL RESOURCES
This section addresses common and sensitive biological resources that could be affected by implementation of the Redwood Cabin Project.
No comment letters were received in response to the Notice of Preparation (see Appendix A) that expressed concerns related to biological resources.
3.1.1 Regulatory Setting
FEDERAL
Federal Endangered Species Act
Pursuant to the federal Endangered Species Act (ESA) (16 U.S.C. Section 1531 et seq.), the U.S. Fish and Wildlife Service (USFWS) regulates the taking of species listed in the ESA as threatened or endangered. In general, persons subject to ESA (including private parties) are prohibited from “taking” endangered or threatened fish and wildlife species on
private property, and from “taking” endangered or threatened plants in areas under federal jurisdiction or in violation of state law. Under Section 9 of the ESA, the definition of “take” is to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” USFWS has also interpreted the definition of “harm” to include significant habitat modification that could result in take.
Section 10 of the ESA applies if a non-federal agency is the lead agency for an action that results in take and no other federal agencies are involved in permitting the action. Section 7 of the ESA applies if a federal discretionary action is required (e.g., a federal agency must issue a permit), in which case the involved federal agency consults with USFWS.
Clean Water Act
Section 404 of the Clean Water Act (CWA) requires project proponents to obtain a permit from the U.S. Army Corps of Engineers (USACE) before performing any activity that involves any discharge of dredged or fill material into
waters of the United States, including wetlands. Waters of the United States include navigable waters of the United States, interstate waters, tidally influenced waters, and all other waters where the use, degradation, or destruction of
the waters could affect interstate or foreign commerce, tributaries to any of these waters, and wetlands that meet any of these criteria or that are adjacent to any of these waters or their tributaries. Many surface waters and wetlands in California meet the criteria for waters of the United States.
In accordance with Section 401 of the CWA, projects that apply for a USACE permit for discharge of dredged or fill material must obtain water quality certification from the appropriate regional water quality control board (RWQCB) indicating that the action would uphold state water quality standards.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA), first enacted in 1918, provides for protection of international migratory birds
and authorizes the Secretary of the Interior to regulate the taking of migratory birds. The MBTA provides that it will be unlawful, except as permitted by regulations, to pursue, take, or kill any migratory bird, or any part, nest, or egg of any such bird. Under the MBTA, “take” is defined as “to pursue, hunt, shoot, wound, kill, trap, capture, or collect, or
any attempt to carry out these activities.” A take does not include habitat destruction or alteration, as long as there is not a direct taking of birds, nests, eggs, or parts thereof. The current list of species protected by the MBTA can be found in Title 50 of the Code of Federal Regulations (CFR), Section 10.13 (50 CFR 10.13). The list includes nearly all birds native to the United States.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-2 Redwood Cabin Removal Project Draft EIR
STATE
California Endangered Species Act
Pursuant to the California Endangered Species Act (CESA), a permit from CDFW is required for projects that could
result in the “take” of a plant or animal species that is listed by the state as threatened or endangered. Under CESA, “take” is defined as an activity that would directly or indirectly kill an individual of a species, but does not include “harm” or “harass,” as does the federal definition. As a result, the threshold for take is higher under CESA than under
the federal ESA. Authorization for take of state-listed species can be obtained through a California Fish and Game Code Section 2081 incidental take permit.
California Fish and Game Code Sections 3503 and 3503.5—Protection of Bird Nests and
Raptors
Section 3503 of the Fish and Game Code states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird. Section 3503.5 of the California Fish and Game Code states that it is unlawful to take, possess, or
destroy any raptors (i.e., species in the orders Falconiformes and Strigiformes), including their nests or eggs. Typical violations include destruction of active nests as a result of tree removal or disturbance caused by project construction or other activities that cause the adults to abandon the nest, resulting in loss of eggs and/or young.
Fully Protected Species under the California Fish and Game Code
Protection of fully protected species is described in Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code. These statutes prohibit take or possession of fully protected species and do not provide for
authorization of incidental take.
Porter-Cologne Water Quality Control Act
The Porter-Cologne Act requires that each of the nine RWQCBs prepare and periodically update basin plans for water
quality control. Each basin plan sets forth water quality standards for surface water and groundwater and actions to control nonpoint and point sources of pollution to achieve and maintain these standards. Basin plans offer an opportunity to protect wetlands through the establishment of water quality objectives. The RWQCB’s jurisdiction
includes waters of the United States, as well as areas that meet the definition of “waters of the state.” “Waters of the state” is defined as any surface water or groundwater, including saline waters, within the boundaries of the state. The RWQCB has the discretion to take jurisdiction over areas not federally protected under CWA Section 404 provided they meet the definition of waters of the state and the State Water Resources Control Board published a new set of procedures for discharges of dredged or fill material into waters of the state on March 22, 2019. Mitigation requiring no net loss of wetlands functions and values of waters of the state typically is required by the RWQCB.
The State Water Resources Control Board has adopted the following definition of wetlands:
An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater or shallow surface water or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.
California Fish and Game Code Section 1602—Streambed Alteration
All diversions, obstructions, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake in California that supports wildlife resources are subject to regulation by CDFW under Section 1602 of the California Fish and Game Code. Under Section 1602, it is unlawful for any person, governmental agency, or public utility to do the
following without first notifying CDFW:
substantially divert or obstruct the natural flow of, or substantially change or use any material from, the bed,
channel, or bank of any river, stream, or lake; or
deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it
may pass into any river, stream, or lake.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-3
The regulatory definition of a stream is a body of water that flows at least periodically or intermittently through a bed
or channel that has banks and supports fish or other aquatic life. This definition includes watercourses with a surface or subsurface flow that supports or has supported riparian vegetation. CDFW’s regulatory authority within altered or
artificial waterways is based on the value of those waterways to fish and wildlife. A CDFW streambed alteration agreement must be obtained for any action that would result in an impact on a river, stream, or lake.
LOCAL
La Honda Creek Open Space Preserve Master Plan
The La Honda Creek Open Space Preserve (Preserve) Master Plan, prepared in June 2012, represents a long-term
comprehensive planning effort for the Preserve. The Biological Resource Management section of the Master Plan provides biological resource protection measures, which are identified in Chapter 2, “Project Description,” and listed below. As explained in Chapter 2, “Project Description,” the Environmental Protection Guidelines (EPGs) below have
minor text modifications. Those shown in single strike-through and underline reflect changes in Midpen’s guidelines and were adopted with Midpen Board approval of the White Barn Stabilization Project Addendum (Ascent 2021). Additional project-specific revisions to the EPGs (shown in double strike-through and double underline) are included to increase their direct application to the current project and thereby enhance their effectiveness. Explanations for the revisions are shown as footnotes. These revisions will not apply to future Midpen projects.
EPG BIO-10: Revegetation and/or enhancement shall be undertaken where any sensitive habitat or special-status species habitat will be disturbed or destroyed by facility construction. The project includes rRevegetation work to
enhance the natural open space values of the site shall be implemented prior to or concurrently with the development. The design of an appropriate revegetation work program shall will be designed to return native
species to the site, including the areas underlying the footprint of where the Redwood Cabin structure and other accessory structure currently stand.1 fully compensate for the lost habitat, with no net loss of habitat functions and values. Riparian and wetland habitat impacts will typically be mitigated at a 3:1 ratio for high quality habitat
areas and at lower ratios where lower habitat quality justifies a lower ratio. A lower ratio may also be justified if habitat mitigation is implemented and verified as successful prior to the occurrence of impacts. Mitigation shall
be based on in-kind replacement of impacted habitat with habitat of equal or better biotic value. 2The revegetation program work shall will be designed by a qualifiedMidpen-approved biologist or ecologist and
submitted to the appropriate regulatory or trustee agency for approval, if required. At a minimum, the revegetation program shall include a description of project impacts, mitigation calculations, the mitigation site, revegetation techniques, maintenance measures, a long-term monitoring program, and contingency measures.
Native plant materials suited to the site will be utilized in all mitigation work.3
EPG WQ-2: Storm water quality Best Management Practices (BMPs) as listed in this section shall be implemented
to reduce potential water quality impacts. BMPs include:
1. Flow of runoff from drainage structures will be directed to vegetated areas, away from creeks and drainages
as is practical.
2. Conduct any trail maintenance work during low flow periods. 4
1 Restoration is not part of the project. Seeding of native species is considered revegetation and will not lead to increased ecological function
such as with full restoration.
2 Biological mitigation for loss of habitat is not required for this project. As described in Section 3.1, “Biological Resources,” the impact to riparian and wetland habitat is less than significant.
3 Because mitigation for habitat loss is not required, these items are not applicable.
4 The project does not include trail maintenance.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-4 Redwood Cabin Removal Project Draft EIR
3. Use erosion and sediment control measures to minimize water quality impacts and ensure no sediment at
heavily traveled trails flows into creeks. To the extent feasible, all measures will be 100 percent biodegradable and/or certified weed-free. These measures include:
Silt Fences
Straw Bale Barriers
Brush or Rock Filters
Storm Drain Inlet Protection
Sediment Traps
Sediment Basins
Erosion Control Blankets and Mats
Midpen shall prevent erosion on steep slopes by using erosion control material according to
manufacturer’s specifications.
4. If soil is to be stockpiled for any reason at creeksides, no run-off will be allowed to flow back to the creek.
3.1.2 Environmental Setting
LAND COVER AND COMMON WILDLIFE SPECIES
The project site is located entirely within the north coast coniferous forest land cover type (Figure 3.1-1). Coast redwood (Sequoia sempervirens) is the dominant species, which together with Douglas fir (Psuedotsuga menziezii),
make up the upper forest canopy. A lower canopy of tan oak (Notholithocarpus densiflorus), big leaf maple (Acer macrophyllum), and California bay (Umbellularia californica) is also present. The understory within the project site is
relatively sparse due to the dense tree canopy and includes shrubs and vines such as California blackberry (Rubus ursinus), California hazelnut (Corylus cornuta), and blood current (Ribes sanquineum). Herbaceous species found under the redwood canopy on the project site include those adapted to deep shade including redwood sorrel (Oxalis
oregana), fetid adderstongue (Scoliopus bigelovii), western swordfern (Polystichum munitum), trail plant (Adenocaulon bicolor) and trillium (Trillium spp.). Invasive and non-native plants within the project site include French broom (Genista monspessulana), vinca (Vinca spp.), English ivy (Hedera helix) and broadleaved forget-me-not (Myosotis latifolia) (Figure 3.1-1). Vegetation along the portion of La Honda Creek within the project area is limited and patchy due to the steep banks of the creek, but includes Thimbleberry (Rubus parviflorus), giant chain fern (Woodwardia fimbriata), sedges (Carex spp.) and giant horsetail (Equisetum telmateia) (Vollmar Natural Lands Consulting 2020). Additionally, slender false brome (Brachypodium sylvaticum) has historically been identified at the project site.
Midpen has been treating it with the objective of eradication within the site.
The project site provides habitat for many common wildlife species. Common birds that may be present within the project site include acorn woodpecker (Melanerpes formicivorus), Steller’s jay (Cyanocitta stelleri), dark-eyed junco (Junco hyemalis), red-shouldered hawk (Buteo lineatus), and band-tailed pigeon (Patagioenas fasciata). Common amphibians and reptiles that may be found within the project site include Santa Cruz gartersnake (Thamnophis
atratus atratus), California slender salamander (Batrachoseps attenuates), and rough-skinned newt (Taricha granulosa granulosa). Mammals that may commonly occur within the project site include Columbian black-tailed deer
(Odocoileus hemionus columbianus), racoon (Procyon lotor), and striped skunk (Mephitis mephitis).
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-5
Source: Image produced and provided by Vollmar Natural Lands Consulting 2020, adapted by Ascent Environmental 2021
Figure 3.1-1 Landcover and Invasive Plants in the Project Site and Vicinity
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-6 Redwood Cabin Removal Project Draft EIR
SENSITIVE BIOLOGICAL RESOURCES
Special-Status Species
Special-status species are legally protected or otherwise considered sensitive by federal, state, or local resource
agencies. Special-status species are species, subspecies, or varieties that fall into one or more of the following categories, regardless of their legal or protection status:
species listed or proposed for listing as threatened or endangered under ESA (50 CFR 17.12 for listed plants, 50
CFR 17.11 for listed animals, and various notices in the Federal Register for proposed species) or candidates for possible future listing as threatened or endangered under ESA (75 CFR 69222);
species listed or candidates for listing by the State of California as threatened or endangered under CESA (14 CCR Section 670.5);
species identified by CDFW as Species of Special Concern;
species listed as Fully Protected under the California Fish and Game Code (FGC) (Section 3511 for birds, Section 4700 for mammals, Section 5050 for reptiles and amphibians, and Section 5515 for fish);
plants listed as rare under the California Native Plant Protection Act (FGC Section 1900 et seq.);
species ranked by the Western Bat Working Group as ‘high’ or ‘medium’ on the Regional Priority Matrix;
species afforded protection under local or regional plans, policies, or ordinances;
plants considered by CDFW to be “rare, threatened or endangered in California” (California Rare Plant Ranks of 1A, presumed extinct in California and either rare or extinct elsewhere; 1B, considered rare or endangered in
California and elsewhere; 2A, presumed extinct in California but common elsewhere; 2B, considered rare or endangered in California but more common elsewhere; 3, about which more information is needed; and 4 of
limited distribution). Note that while these rankings do not afford the same type of legal protection as ESA or CESA, the uniqueness of these species requires special consideration under Section 15380 of the CEQA Guidelines (14 CCR Section 15000 et seq.); or
taxa (i.e., taxonomic category or group) that otherwise meet the definition of rare or endangered under Section 15380 of the CEQA Guidelines (14 CCR Section 15000 et seq.).
The term “California species of special concern” is applied by CDFW to animals not listed under ESA or CESA, but that are considered to be declining at a rate that could result in listing, or that historically occurred in low numbers and
known threats to their persistence currently exist. CDFW’s fully protected status was California’s first attempt to identify and protect animals that were rare or facing extinction. Most species listed as fully protected were eventually listed as threatened or endangered under CESA; however, some species remain listed as fully protected but do not have
simultaneous listing under CESA. Fully protected species may not be taken or possessed at any time and no take permits can be issued for these species except for scientific research purposes or for relocation to protect livestock.
Appendix C provides a list of special-status species potentially occurring in the project vicinity. The list was developed through a review of biological studies previously conducted in the area and a query of the California Native Plant Society Inventory of Rare and Endangered plants (CNPS); and the California Natural Diversity Database (CNDDB), a statewide inventory of the locations and conditions of the state’s rarest plant and animal taxa and vegetation types. The query of the CNDDB and CNPS was conducted for the following U.S. Geological Survey 7.5’ quadrangles
surrounding the project site: Montara Mountain, San Mateo, Redwood Point, Half Moon Bay, Woodside, Palo Alto, San Gregorio, La Honda, and Mindego Hill. The CNDDB is based on actual recorded occurrences and does not constitute an exhaustive inventory of every resource.
Based on a review of the CNPS and CNDDB, there are six special-status botanical species, three special-status amphibians, one special-status bird, and six special-status mammals that are known to occur or could occur in the
project site (CNPS 2021; CNDDB 2021). Refer to Appendix C for the full list of special-status species known to occur within the IPM Program Area region and the potential for each species to occur within the IPM Program Area.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-7
Sensitive Natural Communities
Sensitive natural communities include those that are of special concern to resource agencies or are afforded specific
consideration through CEQA or other federal or state laws. Sensitive natural communities may be of special concern to regulatory agencies and conservation organizations for a variety of reasons, including their locally or regionally
declining status, or because they provide important habitat to common and special-status species. Many of these communities are tracked in CDFW’s CNDDB. The north coast coniferous forest within the project site consists of coast redwood that meets the definition of Redwood Forest in the Manual of California Vegetation (Vollmar Natural Lands
Consulting 2020) and is classified by CDFW as a sensitive natural community (CDFW 2020).
3.1.3 Environmental Impacts and Mitigation Measures
METHODOLOGY
This impact evaluation is based on a visit to the project site on February 1, 2021; the La Honda Creek Preserve, Sierra
Azul Preserve, Purisima Uplands, and Rancho San Antonio Preserve – Structural Surveys for Special-Status Mammal Species (Swaim Biological 2019); the Botanical Resources Survey Report, La Honda Structural Stabilization Project, La
Honda Creek Open Space Preserve, San Mateo County, California (Vollmar Natural Lands Consulting 2020); a review of aerial photographs of the project site and vicinity; a search of the CNDDB (CNDDB 2021); CNPS (CNPS 2021); and other relevant data sources.
THRESHOLDS OF SIGNIFICANCE
An impact on biological resources is considered significant if implementation of the project would do any of the following:
have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS;
have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local
or regional plans, policies, or regulations or by CDFW or USFWS;
have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; or
interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
ISSUES NOT DISCUSSED FURTHER
All potential biological resource issues identified in the significance criteria are evaluated below.
ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 3.1-1: Loss or Degradation of Habitat for Special-Status Botanical Species
Suitable habitat for special-status botanical species is present within the project site; however, no special-status
botanical species were identified during surveys of the site in 2020, and no loss of individual special-status plants is anticipated. With the removal of the cabin, the recontouring of the project site, and implementation of EPG BIO-10, the project would result in an increase in suitable habitat for special-status botanical species. In addition, the
implementation of IPMP BMPs would avoid habitat degradation that may result from the introduction and spread of invasive plants. Therefore, the project would have a less-than-significant impact on special-status botanical species.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-8 Redwood Cabin Removal Project Draft EIR
The project site provides suitable habitat for six special-status botanical species (Appendix C). Of these six species,
Western leatherwood (Dirca occidentalis), Dudley's lousewort (Pedicularis dudleyi), and white-flowered rein orchid (Piperia candida) are considered rare or endangered in California and elsewhere and are moderately threatened
(CRPR 1B.2). The remaining three special-status botanical species, California bottle-brush grass (Elymus californicus), harlequin lotus (Hosackia gracilis), and Methuselah's beard lichen (Usnea longissimi) are of limited distribution and moderately threatened (CRPR 4.2). Although, the project site provides habitat for these species, no special-status
botanical species were observed during protocol-level botanical surveys conducted of the project site in 2020 (Vollmar Natural Lands Consulting 2020). If project implementation does not occur before the current survey results expire (i.e., after 5 years or changed site conditions), another botanical survey would occur, and avoidance and/or other measures (e.g., consultation with CDFW, seed collection, transplantation) would be implemented, as required by the La Honda Creek Open Space Preserve Master Plan and the associated 2012 Initial Study/Mitigated Negative
Declaration (Section 2.7.1).
The proposed removal of the Redwood Cabin and associated features, regrading, and staging of equipment would
result in temporary ground disturbance; however, no special-status botanical species were detected during the 2020 protocol survey and therefore it is unlikely that any special-status botanical species would be crushed or removed by project activities. In addition, the project would result in an increase in habitat for special-status botanical species through the removal of the Redwood Cabin, regrading of the site, and the implementation of applicable measures from EPG BIO-10, which requires that revegetation and/or enhancement shall be undertaken where any sensitive
habitat or special-status species habitat will be disturbed or destroyed.
Ground disturbance during project implementation could potentially lead to the spread of invasive plants that occur
on the project site (e.g., English ivy, French broom, slender false brome) (Vollmar Natural Lands Consulting 2020) (Figure 3.1-1) and introduction of new invasive plants that could degrade the habitat and outcompete special-status
plants for space and nutrients should they occur on the project site in the future. However, these potential impacts would be avoided by the implementation of the IPMP BMPs, such as staff and contractor training, use of weed free material, and cleaning of tools and equipment (Section 2.7.2 of Chapter 2, “Project Description”). The project would
not have direct impacts to individual special-status botanical species during project activities, EPG BIO-10 would require restoration of the site, and the implementation of IPMP BMPs would avoid habitat degradation of the site through the introduction and spread of invasive plants; therefore, the impact of the project on special-status botanical species would be less than significant.
Mitigation Measures
No mitigation is required for this impact.
Impact 3.1-2: Injury or Mortality of Special-Status Amphibians
Special-status amphibians may be found within the project site. The recontouring of the site and implementation of
EPG BIO-10 would ensure that there is no loss of habitat for these species. Project activities including the demolition of the Redwood Cabin and associated structures, recontouring, and staging of materials could result in the injury or
mortality of special-status amphibians, and any injury or mortality of individual special-status amphibians would be a significant impact.
Three special-status amphibians could be found on the project site; the California red-legged frog (Rana draytonii), which is
listed as threatened under the ESA and is a CDFW species of special concern; as well as the California giant salamander (Dicamptodon ensatus) and Santa Cruz black salamander (Aneides flavipunctatus niger), which are both CDFW species of
special concern. The project would not include any construction activities within aquatic habitat for California red-legged frog within La Honda Creek; however, California red-legged frogs may use the project site seasonally for migration, sheltering, and foraging when summer rains and fogs provide adequate moisture (Bulger et al. 2003). The deep redwood
forest habitat would also be suitable habitat for both California giant salamander and Santa Cruz black salamander. The project would not result in a reduction of suitable habitat for these species, because the site would be recontoured following demolition, and Midpen would apply EPG BIO-10, which requires that revegetation and/or enhancement shall be undertaken where any sensitive habitat or special-status species habitat will be disturbed or destroyed.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-9
Special-status amphibians may use vegetation, leaf litter, or logs and debris within the project area for shelter and
may also shelter in staged materials associated with the project. Therefore, the movement of equipment and materials, the demolition of the Redwood Cabin, and recontouring of the site may result in the injury or mortality of
special-status amphibians. The mortality of individual special-status amphibians would be a potentially substantial adverse effect on the local populations of these species and the impact would therefore be significant.
Mitigation Measures
Mitigation 3.1-2a: Protection Measures for California Red-Legged Frog
To avoid loss of individual California red-legged frog, Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS
2016). These include the following measures.
Activities including the use of mechanical equipment, excavating, and bulldozing will require pre-activity visual
surveys as well as monitoring during the activities. All maintenance activity proposals involving mechanized equipment and associated monitoring proposals will be approved by CDFW and USFWS prior to implementation of
the project.
Biological monitors will check for any listed species under vehicles and equipment parked for more than 30 minutes.
Refueling of equipment will be conducted using heavy-gauge tarps made of chemically resistant polypropylene or
other impervious material with vertical sides for spill containment. These containment tarps will be set up under the equipment prior to servicing or refueling. Once the work is completed, the tarp and its contents must be
immediately removed from the property and all contaminants properly disposed of off-site. Standard operating procedures will be implemented immediately in case of fuel spillage.
All vehicles must stay on designated roads, paved and unpaved, and if it is necessary for a vehicle to travel off the
designated road (paved or 2 track unpaved), a monitor will precede the vehicle to clear wildlife from the pathway of the vehicle.
Prior to the start of work, an educational program regarding the sensitivity of the California red-legged frog and its habitat will be conducted for all personnel.
Prior to the start of work, areas will be identified by the biological monitor and approved by the USFWS and CDFW
as acceptable locations for the relocation of California red-legged frog if the species is encountered within the project site. Relocation areas will be a minimum of 500-feet from the boundary of the project site and will not
include staging areas or roads. No California red-legged frog will be removed from Midpen property or maintained in captivity overnight without prior notification and written approval from the USFWS and CDFW unless the animal is in need of emergency medical assistance. Medical assistance will be provided by a USFWS-approved, certified wildlife veterinarian familiar with amphibian care.
If a California red-legged frog enters the project site, all work shall stop until the animal leaves on its own. If the frog
does not leave on its own, a biological monitor specifically authorized by the USFWS and CDFW will be allowed to handle and relocate the California red-legged frog to the pre-approved relocation area.
Mitigation 3.1-2b: Biological Monitoring for California Giant Salamander and Santa Cruz Black Salamander
To avoid loss of individual California giant salamander and Santa Cruz black salamander, Midpen will implement the
following measures.
Prior to the start of demolition each day, the access road and portions of the project site where activities will occur will be surveyed by a qualified biologist for the presence of California giant salamander and Santa Cruz black
salamander. The survey will include the inspection of any debris from demolition or materials staged overnight for the presence of these species.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-10 Redwood Cabin Removal Project Draft EIR
If individual California giant salamanders or Santa Cruz black salamanders are discovered during daily inspections,
work shall stop until the individual salamander moves on its own to a point where it is no longer at risk of incidental injury or death from project activities, or until the individual salamander is moved outside of the project site by a
qualified biologist.
Significance after Mitigation Implementation of Mitigation Measures 3.1-2a and 3.1-2b would reduce the impacts to special-status amphibians to a
less-than-significant level, because these measures would survey for the presence of special-status amphibians on a daily basis during project activities; monitor for these species during project activities; stop work that may harm these
species until the individual leaves on its own, or is moved by a biologist; and provide for other measures to address the protection of California red-legged frog.
Impact 3.1-3: Disturbance of Nesting Marbled Murrelet
The nearest mapped nesting habitat for marbled murrelet (Brachyramphus marmoratus) is located approximately one-half mile west of the project site. However, unmapped nesting habitat could occur within a quarter mile of the
project site, and implementation of the project could result in loss of eggs and young from nest disturbance during the breeding season (March 24 – September 15). If nesting marbled murrelets are within a quarter mile of the project
site, the project would have a significant impact on this species.
Marbled murrelet is listed under ESA as threatened and under CESA as endangered. Marbled murrelets forage at sea off the coast during the winter and nest in conifer forests within the coast range of California from approximately
April through September. During incubation and prior to chicks fledging, adults continue to fly to and from the nest location to the sea to forage (H.T. Harvey 2007). Marbled murrelets do not build actual nests, but rather lay eggs
directly on a branch of a large tree. Trees within the project site are not currently large enough to provide suitable nesting habitat for marbled murrelet, and the project would not remove trees that could adversely affect the quantity of future suitable habitat in the project site. However, there are areas of suitable nesting trees located on the preserve
approximately one-half mile of the project site (H.T. Harvey 2007). While the distance from the project site to the nearest mapped suitable murrelet nesting habitat makes it unlikely that demolition activities would result in nest disturbance within this mapped habitat, other unmapped nesting habitat may be present within a quarter mile of the project site. If unmapped nesting habitat occurs within a quarter mile of the project site and project implementation occurs during the breeding season (March 24 to September 15), the flushing of adults off of the nest and disturbance
of feeding could occur and result in a loss of eggs and young. Any loss of eggs or young as a result of nest disturbance would be a significant impact on the species.
Mitigation Measures
Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet
To avoid disturbance and loss of the nests of marbled murrelet Midpen will implement the conservation measures
found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that meet the Pacific Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected, Midpen will
notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter mile from the project site, the
following will apply:
If possible, work within the project site shall be confined to September 15 to November 1.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-11
If work is scheduled to be performed during the breeding season (March 24 to September 15), disturbance
minimization buffers determined by the sound level anticipated from the project will be implemented based on sound level monitoring studied, submitted to USFWS and the table below.
Buffer distance in feet based on anticipated project sound levels and ambient sound conditions
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project Sound Level (dB)1 Moderate (71-80) High (81-90) Very High (91-100) Extreme (101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the project stie prior to the project, and not related
to the project.
2 Project-generated sound levels measured at 50 feet from the source
3 “Natural Ambient” refers to sound levels generally experienced in habitats not substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special considerations for ambient sound level.
Source: USFWS 2016; USFWS 2020
Project activities shall not be conducted within a visual line-of-site distance of 132 feet from a suitable nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest trees during
the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15) regardless of the distance to
potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the habitat is occupied by
marbled murrelet, the seasonal and distance work restrictions may be lifted with written approval from the USFWS.
Significance after Mitigation Implementation of Mitigation Measure 3.1-3 would reduce the impacts to nests of marbled murrelets to a less-than-significant level because it would require surveys for the presence of nest trees and active nests and no-activity
buffers around active nests to avoid disturbance during the nesting season.
Impact 3.1-4: Disturbance of Common Raptor and Other Common Bird Nests
The project site provides suitable nesting habitat for common raptors and other common nesting birds, and project
activities could result in the disturbance of active nests if demolition occurs during the nesting season. The disturbance of active nests could result in the abandonment of nests and the mortality of eggs and young, which
would be a potentially significant impact.
The redwood forest on the project site, and potentially the cabin itself, provides nesting habitat for common raptors and other nesting bird species including red-shouldered hawk, acorn woodpecker, Steller’s jay, dark-eyed junco, and
band-tailed pigeon. The proposed removal of the Redwood Cabin and associated features, regrading, and staging of equipment could result in the removal or disturbance of the active nests of common raptors and other nesting birds,
if the activities occur during the nesting season (approximately February 15 to August 30). The removal or disturbance
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-12 Redwood Cabin Removal Project Draft EIR
of nests could result in nest abandonment by adults and the mortality of eggs and chicks. The mortality of eggs and
chicks may be a substantial adverse effect on the local populations of some bird species and therefore this impact would be potentially significant.
Mitigation Measures
Mitigation 3.1-4: Preconstruction surveys and nest buffers for common raptors and other nesting birds
To avoid disturbance and loss of the nests of common raptors and other nesting birds Midpen will implement the
following measures.
If work is scheduled to be performed during the nesting season (the specific start and end dates of the season will be determined by a qualified biologist but are typically February 15 to August 30), a pre-demolition survey will be
performed within 1,000 feet of the project site, no more than 14 days prior to the start of demolition related activities. If no active nests are detected during surveys, no further mitigation is required.
If active nests are found during the pre-demolition survey, a buffer will be established around each nest. No project activity will occur within a buffer of 1,000-feet around large raptor nests (e.g., buteos) 500-feet around small common raptor nests (e.g., accipiters) and 250-feet around the nests of other common bird species. The size of the
buffer around any individual nest maybe reduced by a qualified biologist in consultation with CDFW, depending on screening of the nest from project activities and other site-specific conditions. These buffers will be maintained until
a qualified biologist determines that any young have fledged, and the nest is no longer active.
Significance after Mitigation Implementation of Mitigation Measure 3.1-4 would reduce the impacts to nests of common raptors and other
common nesting birds to a less-than-significant level, because it would require surveys for the presence of active nests and no-activity buffers around active nests to avoid disturbance during the nesting season.
Impact 3.1-5: Loss of San Francisco Dusky-Footed Wood Rat Nests
The Redwood Cabin contains multiple San Francisco dusky-footed wood rat (Neotoma fuscipes annectens) nests. The
demolition of the cabin would destroy these nests and could result in the injury or mortality of young woodrats if demolition occurs during the rearing season (approximately April 1 to July 15). The destruction of these nests and the
injury or mortality of young woodrats would be a significant impact.
The San Francisco dusky-footed wood rat is a CDFW species of special concern that builds nests of sticks and other similar materials that may be used by multiple generations. The Redwood Cabin contains multiple San Francisco
dusky-footed wood rat nests and other signs of occupancy (Swaim Biological 2019); however, no nests were observed outside of the cabin on the project site. Demolition of the Redwood Cabin would remove these woodrat nests and may also result in the injury or mortality of young woodrats in the nest if demolition occurs during the rearing season
(approximately April 1 to July 15). The loss of multiple woodrat nests and injury or mortality of young woodrats would be an adverse effect on the local population of San Francisco dusky-footed wood rat and therefore the impact of the
project on the species would be significant.
Mitigation Measures
Mitigation 3.1-5: Minimize impacts from loss of San Francisco dusky-footed wood rat nests
To avoid loss of San Francisco dusky-footed wood rat during demolition, work will be conducted outside of the rearing season (before April 1 or after July 15).
Prior to demolition, debris piles will be constructed outside of and adjacent to the project footprint to provide
shelter for wood rats that are displaced by demolition. These debris piles will be constructed under the guidance of a qualified biologist and will consist of dead branches of various sizes (0.5 to 6 inches in diameter) collected from
the surrounding area. Each pile will be approximately 3 to 5 feet high by 8 to 10 feet in diameter. The number of
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-13
debris piles will be determined by a qualified biologist based on the number of nests in the Redwood Cabin prior to
demolition.
To avoid death of wood rats, wood rat nest materials will be removed by hand from the Redwood Cabin prior to
demolition of the structure.
If wood rats are observed during demolition, work will stop until the animal leaves the area on its own, or until a qualified biologist determines that work can continue without harm to the animal.
Significance after Mitigation Implementation of Mitigation Measure 3.1-5 would reduce the impacts to San Francisco dusky-footed wood rat to a
less-than-significant level, because it would ensure that nest removal does not occur during the rearing season when the project could result in the death of young wood rats, and it would require the construction of debris piles that
provide shelter for wood rats that are displaced by demolition of the structure.
Impact 3.1-6: Loss of Bat Roosts and Mortality of Individuals
The Redwood Cabin provides potential roosts for common and special-status bats. The demolition of the Redwood
Cabin could result in disturbance of active bat roosts, which could result in the loss of adult and young bats. The loss of individual special-status bats, or the loss of a maternity roost of any bat species would be a potentially significant
impact.
The Redwood Cabin was surveyed for bats and bat roosts in 2019 (Swaim Biological 2019). This survey did not detect either pallid bat (Antrozous pallidus) or Townsend’s big-eared bat (Corynorhinus townsendii), which are both CDFW
species of special concern and considered special-status species in this analysis. However, both pallid bat and Townsend’s big-eared bat have been documented to occur on the preserve and these species may occur within the
project site at the time of demolition. The 2019 acoustic survey did detect fringed myotis (Myotis thysanodes) in the vicinity of the cabin, but no bats were observed emerging from the cabin and no bat sign was observed. While no bats or bat signs were found, the cabin and large trees on the project site provide potential roosting habitat that may
be occupied at the time of demolition. Due to the deep shade on the site, the cabin is not likely to be warm enough to support a bat maternity roost (Swaim Biological 2019).
The project would not remove any trees, and therefore no tree roosts would be removed. If bats are roosting in the cabin during demolition, these individuals may be injured or killed by equipment or crushed between materials that are removed from the cabin. While unlikely due to the deep shade on the project site, if the cabin is used as a
maternity roost during demolition, the death of young bats may also occur. The loss of pallid bat or Townsend’s big-eared bat individuals, or the loss of a maternity roost of any bat species would be a potentially substantial adverse
effect on the local population of these species and would therefore be a potentially significant impact.
Mitigation Measures
Mitigation 3.1-6: Pre-demolition surveys and measures to reduce impacts to bat roosts and special-status bats
A pre-demolition bat roost survey shall be conducted at the project site by a qualified biologist no more than two days prior to the start of demolition.
In addition, if demolition is anticipated to occur during the bat wintering period (from November 16 through February 15), a pre-demolition winter roost survey shall be conducted by a qualified biologist.
If individual nonbreeding and non-special-status bats are roosting within the structure, a qualified biologist may
remove the bats and work may proceed during any time of the year. If special-status bats or a maternity roost of any bat species is detected, demolition will not be allowed to occur during the April through August maternity
season; outside of the maternity season, bats shall be excluded and provided alternate roost sites before demolition.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-14 Redwood Cabin Removal Project Draft EIR
Midpen will develop a project specific bat roost deterrent plan if special-status bats or a maternity roost of any bat
species is detected in the Redwood Cabin. The deterrent plan will be submitted to CDFW for approval and will include measures such as acoustic deterrents and one-way bat doors installed outside of the maternity season (April
through August), and other similar methods.
Demolition will occur when forecast nighttime lows are not below 50 degrees Fahrenheit.
The materials around crevices that may provide roosting sites within the structure will be first demolished with hand
tools to minimize the risk of injuring bats.
Initial demolition will be performed in the early evening after sunset, or if evening work is not feasible, the work shall
be initiated in the afternoon to ensure that any bats present are not in torpor and unable to escape. Once demolition has been started, further work may be performed at any point in the day. A qualified bat biologist will be present at the initiation of demolition to capture and temporarily hold any bats present for release the evening of
the same day.
Significance after Mitigation Implementation of Mitigation Measure 3.1-6 would reduce the impacts to special-status and common bat species to a less-than-significant level, because it would ensure that the project does not result in disturbance of hibernacula or
maternity roots and applies measures such as the timing of demolition and bat exclusion methods that would minimize the risk of injury or death of special-status and common bat species.
Impact 3.1-7: Disturbance or Loss of Special-Status Mammal Den Sites
The project site and adjacent redwood forest provide potential denning sites for special-status mammals. The demolition of the Redwood Cabin could result in disturbance of active dens and the injury or mortality of pups if the
demolition occurs during the breeding season. The loss of active dens and injury of mortality of special-status mammal pups would be a potentially significant impact.
The Southern California/Central Coast evolutionary significant unit of the mountain lion (Puma concolor) is listed
under the CESA as candidate threatened species, and mountain lions have been detected in the project area and vicinity (Santa Cruz Puma Project 2021). However, the project site is not likely to be used by mountain lions as nursery
habitat due to its proximity to residential development and recreational use. The project site may be used for foraging habitat by mountain lions, and although there would be no permanent loss of habitat due to project activities, mountain lions would likely avoid the project site during demolition, resulting in a temporary loss of
foraging habitat. This temporary loss of foraging habitat would not be substantial given the relatively small area of the project when compared to the available foraging habitat in the vicinity.
Unlike mountain lion, the CDFW fully protected ringtail (Bassariscus astutus), and CDFW species of special concern American badger (Taxidea taxus) may use the project site as denning and foraging habitat. While ringtail has not
been reported to occur within the project site or vicinity, this species is not tracked in the CNDDB. It is a nocturnal species that may often go unobserved. Ringtails use boulder piles, underground cavities, brush piles, or hollow trees or tree cavities for denning, often in riparian areas (Belluomini 1980). American badger, which dens underground, is
most often associated with grassland habitats, but may be found in forested habitats as well. American badger has been documented to occur on the preserve (CNDDB 2021). As discussed for mountain lion, loss of foraging habitat for ringtail and American badger from implementation would be temporary and not a substantial loss of habitat. However, demolition of the Redwood Cabin and associated features could result in disturbance of ringtail or American badger den sites if any are located within or adjacent to the project site. If the disturbance of dens occurs during the breeding season when pups are potentially in the den, this could result in injury or death of the pups. Any loss of pups would be a substantial adverse effect to the local populations of these species, and therefore the project
has a potential for a potentially significant impact to ringtail and American badger.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-15
Mitigation Measures
Mitigation 3.1-7: Pre-demolition surveys and den buffers for American badger and ringtail
If the project occurs during the period when pups are potentially in the den February 15 through July 1, a qualified biologist shall conduct pre-demolition surveys within 100 feet of the project site for potential American badger and
ringtail dens. The survey will occur no more than 7-days prior to implementation of demolition activities.
If any potentially occupied American badger dens are located during surveys, no work shall be performed within a
100-foot buffer around dens during the period when pups are potentially in the den (February 15 through July 1).
If any potentially occupied ringtail dens (e.g., brush piles, appropriately sized burrows, hollow logs, hollow trees) are located during surveys, the same buffers as described for American badger will be applied during breeding season
for ringtail (May 1 through June 30).
Significance after Mitigation Implementation of Mitigation Measure 3.1-7 would reduce the impacts to ringtail and American badger to a less-than-significant level, because it would ensure that the project does not result in disturbance of natal dens that could result in the death of pups though pre-demolition survey and the establishment of buffers where work would not occur.
Impact 3.1-8: Disturbance or Loss of Riparian Habitat or Other Sensitive Natural Communities
The project does not contain riparian woodland; however, herbaceous riparian habitat is present along the adjacent
La Honda Creek. The project would not directly affect this habitat and the implementation of EPG WQ-2 would avoid and minimize impacts from the runoff of sediment from the project. The site also contains a CDFW-designated
sensitive natural community, Redwood Forest; however, this community would not be adversely affected by the project because the project would not remove any trees, would treat on-site invasive species, and would restore the area disturbed by the project through the implementation of EPG BIO-10. Therefore, the impact of the project on
riparian habitat and other sensitive natural communities would be less-than-significant.
The riparian zone along La Honda Creek does not form a true riparian woodland and is limited in area due to the steep banks, cobbled stream bed, and dense canopy of the north coast coniferous forest. A relatively small band of
wetland riparian herbaceous vegetation (e.g., sedges and giant horsetail) is present within the creek banks below the bridge where the access road crosses the creek and along a swale adjacent to the access road (Vollmar Natural Lands
Consulting 2020). The limited riparian habitat along La Honda Creek would not be directly modified by implementation of the project. In addition, sedimentation due to runoff of disturbed soils on the project site would be minimized or avoided by the implementation of EPG WQ-2. As described in Chapter 2, “Project Description,” EPG WQ-2 includes measures such as the use of silt fences, straw bale barriers, and other erosion and sediment control measures.
The Redwood Forest that makes up the vegetation community on the project site is identified as a CDFW-designated sensitive natural community (CDFW 2020). The project would not remove any trees or result in any substantial removal of vegetation on site. The habitat function of Redwood Forest would be maintained with implementation of the project. In addition, following recontouring of the site, EPG BIO-10 would be implemented, which requires that revegetation and/or enhancement shall be undertaken where any sensitive habitat or special-status species habitat will be disturbed or destroyed. Further, the Redwood Cabin Removal Project would provide the opportunity to improve biological resources at the site through invasive plant treatment, soil decompaction and amendments, or
revegetation, which could improve the quality of the habitat.
Due to the lack of tree removal; avoidance of disturbance to riparian habitats along La Honda Creek; implementation
of EPG WQ-2, which would avoid or minimize runoff to riparian habitat; maintenance of Redwood Forest habitat function; and implementation of EPG BIO-10, which would restore the area disturbed by the project, the impact of the
project on riparian habitat and other sensitive natural communities would be less than significant.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-16 Redwood Cabin Removal Project Draft EIR
Mitigation Measures
No mitigation is required for this impact.
Impact 3.1-9: Degradation or loss of protected wetlands and other waters
The access road to the project site crosses La Honda Creek and an un-named tributary. A temporary bridge may be
required to move equipment across the tributary; however, no dredge or fill of the creek or tributary will occur as a result of the project. In addition, EPG WQ-2 will be implemented to avoid and minimize impacts to La Honda Creek and its tributary due to runoff from the project site. Therefore, the impact to protected wetlands and other waters
would be less than significant.
La Honda Creek is located outside of the project site and adjacent to the unpaved access road to the site. La Honda
Creek, associated swales, and its un-named tributary are potential waters of the United States, and waters of the state, and the only potential waters of the United States and the state on or adjacent to the project site. The access road crosses the creek and an un-named tributary between the site and Highway 35 over a pair of bridges. As
described in Chapter 2, “Project Description, section 2.5, “Construction Access, Equipment, Staging, and Logistics,” a temporary bridge may be installed over the existing bridge across the un-named tributary of La Honda Creek due to load limitations of the current structure. The temporary bridge would be placed over the existing bridge and would not disturb the bed or bank of the tributary. No disturbance or fill would occur in either La Honda Creek or its un-named tributary as a result of the project. In addition, indirect effects from runoff of disturbed soils on the project site would be minimized or avoided by the implementation of EPG WQ-2, which includes measures such as the use of silt fences, straw bale barriers, and other erosion and sediment control measures. Due to the avoidance of disturbance to
La Honda Creek and its un-named tributary and implementation of EPG WQ-2, which would avoid or minimize runoff to these waters, the impact of the project on protected wetlands and other waters would be less than significant.
Mitigation Measures
No mitigation is required for this impact.
Impact 3.1-10: Potential to Interfere with Wildlife Movement and Nursery Sites
The demolition of the Redwood Cabin would not result in any changes in habitat or new structures that would interfere with wildlife movement. The noise and human activity associated with the project could result in temporary impacts to wildlife movement that would not be substantial, due to the short duration and limited footprint of the
project in relation to other habitat in the vicinity. Therefore, the projects impact would be less than significant.
The demolition of the Redwood Cabin, demolition of associated structures, and site recontouring would not modify
or remove natural habitats to the extent that these habitats would be unsuitable for wildlife movement. In addition, the project does not include the construction of any permanent barriers that could obstruct wildlife movement. The project would instead remove a structure from an otherwise natural habitat. However, the noise and human activity
that would occur during demolition of the Redwood Cabin and associated structures would cause wildlife to avoid the area and could result in temporary interference with wildlife movement and foraging activity (see Impact 3.1-7 for additional discussion of special-status mammal movement). Due to the short duration of the demolition and the overall availability of natural habitats in the project vicinity this interference with wildlife movement would not be substantial. Other than the San Francisco dusky footed woodrat nests that occur within the Redwood Cabin and the
potential bat roosts that may also be present (see Impact 3.1-5 and Impact 3.1-6 for mitigation measures to reduce impacts on these special-status species to less than significant), there are no additional wildlife nursery sites documented to occur within or adjacent to the project site. Therefore, due to the temporary and non-substantial interference with wildlife movement and the lack of other nursery sites in the project site and vicinity, the impact of the project would be less than significant.
Mitigation Measures
No mitigation is required for this impact.
Exhibit A
Ascent Environmental Biological Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.1-17
Impact 3.1-11: Potential to Contribute to a Significant Cumulative Impact to Biological
Resources
Implementation of the proposed project in the context of historical effects on the landscape and in combination with other cumulative projects in the area could result in impacts to biological resources. However, through the
implementation of EPGs, BMPs, and mitigation measures, the contribution of the project would not have a cumulative impact. Therefore, this impact would be less than significant.
The cumulative context for the analysis of biological resources is the portion of the Santa Cruz Mountains that
extends approximately from the Purisima Creek Redwoods Preserve and Phleger Estate in the North, South to the Skyline Ridge Open Space Preserve, and west to the San Mateo County Coast. This portion of the Santa Cruz
Mountains was subject to extensive logging that extended from the mid 1800’s to the early 1900’s, and the majority of the habitats in the area reflect this history of logging. The southern portion of this area, was burned during the CZU Complex Fire in 2020 and habitat for many species, including marbled murrelet, was adversely affected by the fire.
Currently, this portion of the Santa Cruz Mountains contains limited residential and commercial development, consisting of mostly single-family homes, confined to the corridor around the major roads in the area. There is also an extensive network of public land in the area, including several Midpen preserves, Huddart County Park, and lands owned by the San Francisco Public Utility Commission. The majority of these lands are open for recreational uses. The area west to the San Mateo County Coast remains mostly agricultural with little development south of Half Moon Bay.
The proposed project in combination with other projects in the area, such as San Francisco Public Utility Commission’s South Skyline Ridge Trail Extension; Midpen’s Fuel Reduction Implementation projects; and natural
resource protection and restoration projects, infrastructure improvement projects, and Integrated Pest Management Program projects on Midpen preserves, could contribute to cumulative impacts to biological resources.
All potential cumulative projects must comply with federal, state, and local regulations, including ESA, CESA, CWA, and CEQA regarding listed or other protected species and habitats. Potential impacts to special-status plants, special-status wildlife, and sensitive natural communities will require mitigation to reduce project impacts to a less-than-
significant level on each of these projects. In addition, cumulative projects on the La Honda Creek Open Space Preserve would be subject to the BMPs discussed in Chapter 2, “Project Description.
The proposed project could have adverse effects on special-status botanical species, special-status amphibians, marbled murrelet, common nesting birds, bats, mountain lion, American badger, ringtail, redwood forest, waters of
the US and state, and wildlife movement. However, these adverse effects would be temporary, and very limited in scope due to the small footprint of the project. As discussed above the EPGs, BMPs, and mitigation measures would reduce or avoid project related impacts to such an extent that they are not expected to not result in a considerable
contribution to a cumulative impact. In addition, the Redwood Cabin Removal Project would provide the opportunity to improve biological resources at the site through invasive plant treatment, soil decompaction and amendments, or revegetation. Therefore, the project would not result in a cumulatively considerable incremental contribution to a cumulatively significant biological resource impact; the cumulative impact would be less than significant.
Mitigation Measures
No mitigation is required for this impact.
Exhibit A
Biological Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.1-18 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-1
3.2 CULTURAL RESOURCES
This section analyzes and evaluates the potential impacts of the project on known and unknown cultural resources. Cultural resources include districts, sites, buildings, structures, or objects generally older than 50 years and considered
to be important to a culture, subculture, or community for scientific, traditional, religious, or other reasons. They include pre-historic resources and historic-era resources.
Archaeological resources are locations where human activity has measurably altered the earth or left deposits of
prehistoric or historic-era physical remains (e.g., stone tools, bottles, former roads, house foundations). Historical (or architectural) resources include standing buildings (e.g., houses, barns, outbuildings, cabins) and intact structures (e.g., dams, bridges, roads, districts), or landscapes. A cultural landscape is defined as a geographic area (including both cultural and natural resources and the wildlife therein), associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values.
Comment letters received in response to the Notice of Preparation (see Appendix A) expressed concerns related to the historic value of the Redwood Cabin. Additionally, the Native American Heritage Commission (NAHC) requested AB 52 and SB 18 compliance information; SB 18 does not apply to the project because there is no General Plan amendment associated with the project (which is the trigger for SB 18 compliance), and SB 18 is not a CEQA requirement and therefore is not discussed in this section. For project information related to AB 52 and tribal consultation, please refer to Section 3.18, “Tribal Cultural Resources,” of the Initial Study, provided in Appendix B.
3.2.1 Regulatory Setting
FEDERAL
Section 106 of the National Historic Preservation Act
Federal protection of resources is legislated by (a) the National Historic Preservation Act (NHPA) of 1966 as amended by 16 U.S. Code 470, (b) the Archaeological Resource Protection Act of 1979, and (c) the Advisory Council on Historical Preservation. These laws and organizations maintain processes for determination of the effects on historical
properties eligible for listing in the National Register of Historic Places (NRHP).
Section 106 of the NHPA and accompanying regulations (36 Code of Federal Regulations [CFR] Part 800) constitute the main federal regulatory framework guiding cultural resources investigations and require consideration of effects on properties that are listed in or may be eligible for listing in the NRHP. The NRHP is the nation’s master inventory of known historic resources. It is administered by the National Park Service and includes listings of buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archaeological, and cultural districts that are considered significant at the national, state, or local level.
The formal criteria (36 CFR 60.4) for determining NRHP eligibility are as follows:
1. The property is at least 50 years old (however, properties under 50 years of age that are of exceptional importance or are contributors to a district can also be included in the NRHP);
2. It retains integrity of location, design, setting, materials, workmanship, feeling, and associations; and
3. It possesses at least one of the following characteristics:
Criterion A Association with events that have made a significant contribution to the broad patterns of history (events).
Criterion B Association with the lives of persons significant in the past (persons).
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-2 Redwood Cabin Removal Project Draft EIR
Criterion C Distinctive characteristics of a type, period, or method of construction, or represents the work of a
master, or possesses high artistic values, or represents a significant, distinguishable entity whose components may lack individual distinction (architecture).
Criterion D Has yielded, or may be likely to yield, information important to prehistory or history (information potential).
Listing in the NRHP does not entail specific protection or assistance for a property but it does guarantee recognition
in planning for federal or federally-assisted projects, eligibility for federal tax benefits, and qualification for federal historic preservation assistance. Additionally, project effects on properties listed in the NRHP must be evaluated under CEQA.
The National Register Bulletin also provides guidance in the evaluation of archaeological site significance. If a heritage property cannot be placed within a particular theme or time period, and thereby lacks “focus,” it is considered not
eligible for the NRHP. In further expanding upon the generalized National Register criteria, evaluation standards for linear features (such as roads, trails, fence lines, railroads, ditches, flumes, etc.) are considered in terms of four related
criteria that account for specific elements that define engineering and construction methods of linear features: (1) size and length; (2) presence of distinctive engineering features and associated properties; (3) structural integrity; and (4) setting. The highest probability for National Register eligibility exists within the intact, longer segments, where multiple criteria coincide.
Cultural and Historic Landscapes Under the NRHP, historic properties may be defined as sites, buildings, structures (such as bridges or dams), objects, or districts, including cultural or historic landscapes. A cultural landscape differs from a historic building or district in
that it is understood through the spatial organization of the property, which is created by the landscape’s cultural and natural features. Some features may create viewsheds or barriers (such as a fence), and others create spaces or “rooms” (such as an arrangement of buildings and structures around a lawn area). Some features, such as grading
and topography, underscore the site’s development in relationship to the natural setting. To be listed in the NRHP, a cultural landscape must meet one of the four evaluation criteria and must retain its integrity.
Historic landscapes include residential gardens and community parks, scenic highways, rural communities, institutional grounds, cemeteries, battlefields and zoological gardens. They are composed of a number of character-defining features which individually or collectively contribute to the landscape’s physical appearance as they have evolved over time. In addition to vegetation and topography, cultural landscapes may include water features, such as ponds, streams, and fountains; circulation features, such as roads, paths, steps, and walls; buildings; and furnishings,
including fences, benches, lights, and sculptural objects.
A cultural landscape is defined as “a geographic area, including both cultural and natural resources and the wildlife or domestic animals therein, associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values.” There are four general types of cultural landscapes, not mutually exclusive: historic sites, historic designed landscapes, historic vernacular landscapes, and ethnographic landscapes (NPS 1994).
Historic Designed Landscape—a landscape that was consciously designed or laid out by a landscape architect, master gardener, architect, or horticulturist according to design principles, or an amateur gardener working in a
recognized style or tradition. The landscape may be associated with a significant person(s), trend, or event in landscape architecture; or illustrate an important development in the theory and practice of landscape architecture.
Aesthetic values play a significant role in designed landscapes. Examples include parks, campuses, and estates.
Historic Vernacular Landscape—a landscape that evolved through use by the people whose activities or occupancy shaped that landscape. Through social or cultural attitudes of an individual, family or a community,
the landscape reflects the physical, biological, and cultural character of those everyday lives. Function plays a significant role in vernacular landscapes. They can be a single property such as a farm or a collection of
properties such as a district of historic farms along a river valley. Examples include rural villages, industrial complexes, and agricultural landscapes.
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-3
Historic Site—a landscape significant for its association with a historic event, activity, or person. Examples include
battlefields and president’s house properties.
Ethnographic Landscape—a landscape containing a variety of natural and cultural resources that associated people
define as heritage resources. Examples are contemporary settlements, religious sacred sites, and massive geological structures. Small plant communities, animals, subsistence, and ceremonial grounds are often components.
Secretary of the Interior’s Standards The Secretary of the Interior’s Standards for the Treatment of Historic Properties (Secretary’s Standards) provide guidance for working with historic properties. The Secretary’s Standards are used by lead agencies to evaluate
proposed rehabilitative work on historic properties. The Secretary’s Standards are a useful analytic tool for understanding and describing the potential impacts of proposed changes to historic resources. Projects that comply with the Secretary’s Standards benefit from a regulatory presumption that they would not result in a significant
impact to a historic resource.
In 1992 the Secretary’s Standards were revised so they could be applied to all types of historic resources, including landscapes. They were reduced to four sets of treatments to guide work on historic properties: Preservation, Rehabilitation, Restoration, and Reconstruction. The four distinct treatments are defined as follows:
Preservation focuses on the maintenance and repair of existing historic materials and retention of a property’s form as it has evolved over time.
Rehabilitation acknowledges the need to alter or add to a historic property to meet continuing or changing uses
while retaining the property’s historic character.
Restoration depicts a property at a particular period of time in its history, while removing evidence of other periods.
Reconstruction re-creates vanished or non-surviving portions of a property for interpretive purposes.
STATE
California Register of Historical Resources
All properties in California that are listed in or formally determined eligible for listing in the NRHP are eligible for the CRHR. The CRHR is a listing of State of California resources that are significant within the context of California’s history.
The CRHR is a statewide program of similar scope and with similar criteria for inclusion as those used for the NRHP. In addition, properties designated under municipal or county ordinances are also eligible for listing in the CRHR.
A historic resource must be significant at the local, state, or national level under one or more of the criteria defined in the California Code of Regulations (CCR) Title 15, Chapter 11.5, Section 4850 to be included in the CRHR. The CRHR criteria are similar to the NRHP criteria and are tied to CEQA because any resource that meets the criteria below is
considered a significant historical resource under CEQA. As noted above, all resources listed in or formally determined eligible for the NRHP are automatically listed in the CRHR.
The CRHR uses four evaluation criteria:
1. Is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.
2. Is associated with the lives of persons important to local, California, or national history.
3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the
work of a master, or possesses high artistic values.
4. Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.
Similar to the NRHP, a resource must meet one of the above criteria and retain integrity. The CRHR uses the same seven aspects of integrity as the NRHP.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-4 Redwood Cabin Removal Project Draft EIR
California Environmental Quality Act
CEQA requires public agencies to consider the effects of their actions on “historical resources” and “unique
archaeological resources.” Pursuant to PRC Section 21084.1, a “project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” Section
21083.2 requires agencies to determine whether projects would have effects on unique archaeological resources.
Historical Resources “Historical resource” is a term with a defined statutory meaning (PRC, Section 21084.1; determining significant impacts
to historical and archaeological resources is described in the State CEQA Guidelines, Sections 15064.5[a] and [b]). Under State CEQA Guidelines Section 15064.5(a), historical resources include the following:
1. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (PRC, Section 5024.1).
2. A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public
agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
3. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided
the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource will be considered by the lead agency to be historically significant if the resource meets the criteria for
listing in the California Register of Historical Resources (Public Resources Code, Section 5024.1).
4. The fact that a resource is not listed in or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to Section 5020.1(k) of the Public Resources Code), or identified in a historical resources survey (meeting the criteria in Section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource
as defined in PRC Section 5020.1(j) or 5024.1.
Unique Archaeological Resources CEQA also requires lead agencies to consider whether projects will impact unique archaeological resources. Public Resources Code, Section 21083.2, subdivision (g), states that unique archaeological resource means an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of
knowledge, there is a high probability that it meets any of the following criteria:
1. Contains information needed to answer important scientific research questions and that there is a demonstrable
public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.
California Native American Historical, Cultural, and Sacred Sites Act
The California Native American Historical, Cultural, and Sacred Sites Act applies to both state and private lands. The Act requires that upon discovery of human remains, construction or excavation activity cease and the County coroner
be notified. If the remains are of a Native American, the coroner must notify NAHC, which notifies and has the authority to designate the most likely descendant (MLD) of the deceased. The Act stipulates the procedures the
descendants may follow for treating or disposing of the remains and associated grave goods.
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-5
Health and Safety Code, Sections 7050.5 and 7052
Section 7050.5 of the Health and Safety Code requires that construction or excavation be stopped in the vicinity of
discovered human remains until the coroner can determine whether the remains are those of a Native American. If determined to be Native American, the coroner must contact the NAHC. Section 7052 states that the disturbance of
Native American cemeteries is a felony.
Public Resources Code, Section 5097
PRC Section 5097 specifies the procedures to be followed in the event of the unexpected discovery of human
remains on nonfederal land. The disposition of Native American burial falls within the jurisdiction of the NAHC. Section 5097.5 of the Code states the following:
No person shall knowingly and willfully excavate upon, or remove, destroy, injure, or deface any historic or
prehistoric ruins, burial grounds, archaeological or vertebrate paleontological site, including fossilized footprints, inscriptions made by human agency, or any other archaeological, paleontological or historical feature, situated on public lands, except with the express permission of the public agency having jurisdiction over such lands. Violation of this section is a misdemeanor.
LOCAL
La Honda Creek Open Space Preserve Master Plan
The La Honda Creek Open Space Preserve (Preserve) Master Plan, prepared in June 2012, represents a long-term
comprehensive planning effort for the Preserve. The Cultural Resource Management section of the Master Plan provides cultural resource protection measures, which are identified Chapter 2, “Project Description,” and listed below.
EPG CUL-1: Midpen will apply the Standard Protocol for Unexpected Discovery of Archaeological and Paleontological
Cultural Materials:
Protocol for Unexpected Discovery of Archaeological and Paleontological Cultural Materials. In the event that any
cultural resources are exposed during construction, work at the location of the find will halt immediately within 10 meters (30 feet) of the find. If an archaeologist is not present at the time of the discovery, Midpen will contact an
archaeologist for identification and evaluation in accordance with CEQA criteria.
A reasonable effort will be made by Midpen and archaeologist to avoid or minimize harm to the discovery until significance is determined and an appropriate treatment can be identified and implemented. Methods to protect
finds include fencing, covering remains with protective material and culturally sterile soil or plywood. If vandalism is a threat, 24-hour security shall be provided. During this evaluation period, construction operations outside of the find
location can continue preferably with an archaeologist monitoring any subsurface excavations.
If the resource cannot be avoided, the archaeologist will develop an appropriate Action Plan for treatment within 48 hours to minimize or mitigate the adverse effects. Midpen will not proceed with construction activities that could affect the discovery until the Action Plan has been reviewed and approved. The treatment effort required to mitigate the inadvertent exposure of significant cultural resources will be guided by a research design appropriate to the
discovery and potential research data inherent in the resource in association with suitable archaeological field techniques and analytical strategies. The recovery effort will be detailed in a professional report in accordance with current archaeological standards. Any non-grave associated artifacts will be curated with an appropriate repository.
EPG CUL-2: Application of the Native American Burial Plan (NABP) will be applied:
Native American Burial Plan 1. In the event of an inadvertent discovery of human remains and cultural items during project construction, the field crew supervisor shall take immediate steps, if necessary, to secure and protect any remains and cultural
materials. This shall include but is not limited to such measures as (a) temporary avoidance by construction until the remains and items can be removed; (b) posting a security person; (c) placement of a security fence around
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-6 Redwood Cabin Removal Project Draft EIR
the area of concern; or, (d) some combination of these measures. Any such measures employed will depend
upon the nature and particular circumstances of the discovery.
2. The County Medical Examiner (Coroner) shall be notified by the field crew supervisor or other designated Midpen
manager and informed of the find and of any efforts made to identify the remains as Native American. If the remains are identified as a prehistoric Native American by either a professional archaeologist under contract to Midpen or the Medical Examiner’s forensic archaeologist, the Medical Examiner is responsible for contacting the
Native American Heritage Commission (NAHC) within 24 hours of notification of the find. The Medical Examiner may choose to document and remove the remains at his/her discretion depending on the circumstances of the discovery. The NAHC then designates and notifies a Most Likely Descendant (MLD). The MLD has 24 hours to consult and provide recommendations for the treatment or disposition, with proper dignity, of the human remains and grave goods [Note: Other culturally affiliated Native Americans [Indians] may be consulted by the
MLD during the consultation and recommendation process to determine treatment of the skeletal remains].
3. Each burial and associated cultural items shall be stored as a unit in a secure facility, which shall be accessible to
the MLD and other Native American representative(s) or their designated alternates upon prior arrangement.
4. The remains and associated cultural items shall be reburied in a secure location as near as possible to the area of their discovery or at an off-site location acceptable to the MLD that has minimal potential for future disturbance. The reburial shall be done in a manner that shall discourage or deter future disturbance. Reburial shall be conducted by persons designated by the MLD, with the assistance, if requested, of Midpen’s field crew. The
location shall be fully documented, filed with the NAHC and the California Historical Resources Information System, Northwest Information Center, California State University, Sonoma and treated as confidential
information.
5. If the NAHC is unable to identify a MLD, or the MLD fails to make a recommendation, or Midpen or designate rejects the recommendation of the MLD and mediation (as per Section 5097.94 subdivision (k)) fails, reinterment
of the human remains and associated cultural items associated shall take place with appropriate dignity on the property in a location not subject to further subsurface disturbance.
6. For security reasons, no news releases, including but not limited to photographs, videotapes, written articles, or other such means that contains information about human remains or burial-related items of Native American origin shall be released by any party during the discovery, recovery and reburial unless approved by the MLD.
7. Any disputes that arise among the MLD and representatives of affected Native American groups and/or between Midpen or designee and the MLD concerning cultural affiliation or the ultimate disposition of Native American human remains and associated funerary objects and unassociated funerary objects shall be resolved according to the dispute resolution procedures in Section 5097.94 of the State of California Public Resources Code.
8. The Archaeological Data Recovery/Native American Burial Treatment Report(s) shall be prepared by professional
archaeologists. The report shall include, but not be limited to, the following: project overview; ethnographic section; previous archaeological research in the region and on-site; circumstances of discovery; recovery procedures and techniques; artifact analysis; faunal analysis; osteological analysis and interpretation; and, conclusions. The MLD and other interested Native American representative(s) shall be provided an opportunity to review the report and submit comments within the same time period as accorded any other reviewers.
9. Objects not associated with the human remains and recovered from private land shall be transferred to Midpen. If curation of any objects is required, curation will be at repository approved by Midpen. Repositories can include
the History Museums of San Jose collections, the Tiburon Archaeological Research Group, San Francisco State University and the Collections Facility, Department of Anthropology, Sonoma State University, Rohnert Park.
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-7
EPG CUL-3: The protocol for determining if structures are of historic value is as follows:
1. The property and building types will be identified and evaluated by a qualified cultural consultant;
2. The cultural consultant will determine if the structures in question are currently included in a local register of
historic resources, on the California Register of Historic Resources or on the National Register of Historic Places;
3. If it is determined that the structures in question are not currently included in a local register of historic resources, on the California Register of Historic Resources or on the National Register of Historic Places, a DPR 523 form
issued by the California Department of Parks and Recreation (DPR) will be completed by the cultural consultant and the structural and building data sent to a qualified architectural historian.
4. The following measure applies only to the Southern La Honda Creek Area: As required by Mitigation CUL-1a(4) of the San Mateo Coastal Annexation EIR, if it is determined that the structures in question are currently on the California Register of Historic Resources or if the building has been determined to be of historic value, there are
two options that would mitigate any impact to the historic values:
a) Retain and rehabilitate the building according to the Secretary of the Interior’s Standards and
Guidelines for Rehabilitating Historic Buildings (U.S. Department of Interior 1990). New construction near this building should be consistent with its historic character; or
b) Move the building to a different location on its current parcel or to a different parcel appropriate to its historic character.1
5. If it is determined that the structures in question are currently listed on or are eligible for listing on the California
Register of Historic Resources, Midpen may retain and either mothball or rehabilitate the structure per Secretary of the Interior’s Standards and Guidelines for Rehabilitating Historic Buildings (U.S. Department of Interior 1990).
OR Midpen may move the structure to a different location on its current parcel or to a different parcel appropriate to its historic character and mothball or rehabilitate the structure per Secretary of the Interior’s Standards.
County of San Mateo General Plan
Chapter 5 of the San Mateo County General Plan Policies document (January 2013) contains goals and policies related to historical and archaeological resources. Applicable policies related to the Redwood Cabin Removal Project are
listed below:
Policy 5.11a: Identify high priority resources in the comprehensive inventory and apply for their designation as
State Point of Historic Interest, State Historical Landmark, or inclusion in the National Register of Historic Places.
Policy 5.12: Encourage the rehabilitation and recycling of historic structures.
Policy 5.13: Encourage the use of innovative techniques such as density transfer, facade easements, etc., to protect historic structures.
Policy 5.14: Recommend State and/or national register status for significant archaeological/paleontological sites.
Policy 5.16: Discourage the demolition of any designated historic district or landmark
Policy 5.19a: Encourage compatible and adaptive residential, commercial or public uses of historic structures as a
means for their protection.
Policy 5.21: (a) Encourage the protection and preservation of archaeological sites; (b) Temporarily suspend construction work when archaeological/paleontological sites are discovered. Establish procedures which allow for
the timely investigation and/or excavation of such sites by qualified professionals as may be appropriate. (c) Cooperate with institutions of higher learning and interested organizations to record, preserve, and excavate sites.
1 This applies to the Southern La Honda Creek Area only and therefore is not relevant to the project.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-8 Redwood Cabin Removal Project Draft EIR
Policy 5.22b: Expand and maintain a comprehensive inventory of all historic resources located in both
unincorporated and incorporated areas.
Policy 5.23: Encourage and coordinate efforts with groups to acquire structures of historic merit in order to
prevent their loss and/or promote their adaptation for other uses.
Policy 5.25: Maintain and update a comprehensive archaeological/paleontological data base.
3.2.2 Environmental Setting
REGIONAL PREHISTORY
The regional prehistory setting, discussed below, is informed by the San Francisco Bay-Delta Regional Context and Research Design for Native American Archaeological Resources, prepared for Caltrans District 4 in 2017 (Caltrans 2017).
Human occupation in the San Francisco Bay-Delta is generally subdivided into distinct time periods, each of which is
marked by various adaptive patterns and geographical distributions. San Francisco Bay-Delta archaeology is divided among three patterns: Terminal Pleistocene (13,500–11,700 calibrated years before present [cal BP]), Early Holocene (11,700–8200 cal BP), Middle Holocene (8200–4200 cal BP), and Late Holocene (4200 cal BP, onward).
Terminal Pleistocene (13,500–11,700 cal BP)
The Terminal Pleistocene is largely contemporaneous with the Clovis and Folsom periods of the Great Plains and the
Southwest and is generally considered to be represented by wide-ranging, mobile hunters and gatherers who periodically exploited large game. Throughout California, Terminal Pleistocene occupation is infrequently encountered and poorly understood, and most often represented by isolated fluted points. No fluted points or
archaeological deposits dated to the Terminal Pleistocene have been documented in the Bay-Delta Area. The Borax Lake site, situated near Clear Lake in the North Coast Ranges, is the nearest locality where fluted points are reported.
The absence of Terminal Pleistocene archaeological remains is undoubtedly the result of several factors, most notably the likelihood that initial human populations were small, highly mobile, and traveled rapidly across the continent. Therefore, their archeological signature on the landscape was generally faint and wide-spaced. For coastal areas, sea
level rise, coastal erosion, and localized subsidence have further reduced the likelihood of documenting initial occupation of the region, and some sites may be preserved under water.
Early Holocene (11,700–8,200 cal BP)
It is typically thought that evidence for Early Holocene human occupation in central California is the product of semi-mobile hunter-gatherers exploiting a wide range of plant and animal foods from marine, lacustrine, and terrestrial
contexts. Early Holocene assemblages often include stemmed points, crescents, and steepedged formed flake tools that share many attributes with contemporaneous material in the Great Basin and southern North Coast Ranges. However, milling tools (handstones and millingslabs) are ubiquitous in these early deposits, a characteristic which
distinguishes Early Holocene occupations in California from those in the Great Basin.
There are only four Early Holocene deposits archaeologically documented in the Bay-Delta Area, resulting in few and poorly established patterns. No sites from this time span have been documented as yet in paleo-bay or paleo-outer coast settings, in part because these contexts are now submerged making them difficult to discover.
Diverse resource exploitation is indicated by artifact and ecofact assemblages from these sites. They include handstones and millingslabs (but not mortars and pestles), large, flaked cores and cobble tools, flake tools, well-made bifaces, and a single flaked stone crescent. Trace amounts of marine shellfish have been recovered from some inland
sites, while faunal assemblages are varied and include deer, elk, rabbit, ground squirrel, coyote, and grizzly bear. Carbonized plant remains are dominated by acorn, which is indicative of fall-winter occupation.
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-9
Middle Holocene (8,200–4,200 cal BP)
More than 60 Bay-Delta Area archaeological sites have produced radiocarbon dates indicating occupation during the
Middle Holocene. Both surface and buried deposits are present, including a number of substantial residential settlements. Notably, the Middle Holocene includes a series of buried sites with diverse cultural assemblages and
occasional burials. In addition, several isolated human burials have been found in buried contexts, including several in the northern Santa Clara Valley of the South Bay and along the edge of the bay in the Southwest region.
Artifact assemblages are varied and include ground stone (some only with millingslabs and handstones, some with
mortars and pestles, and some with both); side-notched dart points; cobble-based chopping, scraping, and pounding implements; and shell beads and ornaments. Current evidence suggests that the mortar and pestle were in use by 6000 cal BP, primarily at sites in the Amador-Livermore, Kellogg Creek, and San Ramon Valleys in the East Bay region. Mortars and pestles were the predominant milling tools used thereafter throughout the East and South Bay regions. The first evidence for extensive use of estuarine resources occurs during the middle Holocene with the expansion of San Francisco Bay’s mud flats, and tidal marshes.
Shellfish exploitation included bay oyster (Ostrea) and mussel (Mytilus), while inland East Bay sites include freshwater
shellfish. Faunal remains reveal diverse, local, niche-based exploitation strategies that included hunting seasonal waterfowl and capture of estuary, anadromous, and freshwater fish. Archaeobotanical assemblages from Middle Holocene contexts are varied.
Evidence for long-distance exchange, greater investment in processing technologies (e.g., mortar and pestle), and extensively occupied habitation sites, including the basal layers of many bay shore shell mounds, suggest higher
population levels, more complex adaptive strategies, and longer seasonal occupation that took place during the Early Holocene. Along with burial by alluviation, undoubtedly pre-6000 cal BP sites situated along the bay margin would
have been inundated by subsequent sea level rise. In part, this may explain why habitation sites from between about 8000 and 7000 cal BP are extremely rare in the wider Bay-Delta Area.
Late Holocene (4200–180 cal BP)
The Late Holocene is generally divided into the following five main time periods: Early (4200–2550 cal BP), Early/Middle Transition (2550–2150 cal BP), Middle (2150–930 cal BP), Middle/Late Transition (930–685 cal BP), and Late (685–180 cal BP). The Late Holocene is very well-documented in the Bay-Delta Area, with more than 240
radiocarbon-dated sites reflecting widespread occupation. Over the last 4,000 years it is generally thought that regional human population increased and there was an upward trend in social, political, and economic complexity, in
part reflected by distinct, geographically specific cultural traditions.
The Early Period (+4050–2550 cal BP) marks the establishment or expansion of a number of large shell mounds. The earliest shell mound artifact assemblages consisted of stemmed and short, broad leaf projectile points; square-based knife blades; mortars (both unshaped and cylindrical), pestles (short and sturdy, cylindrical); crescentric stones; perforated charmstones; bone awls; polished ribs; notched and grooved net sinkers; rectangular and spire lopped
Olivella beads; rectangular abalone (Haliotis sp.) beads and various pendant types; antler wedge; and stone bars or “pencils.” Bay margin sites reveal a strong emphasis on marine shellfish, marine fishes, and marine mammals. Nuts,
berries, and small seeds appear to have been particularly important plant foods.
Very large cemeteries first occur in the Late Holocene, and graves are common at most sites. Burials are almost exclusively found in a loose to tightly flexed position in Bay margin and Santa Clara Valley sites, and the regular occurrence of grave offerings, including shell beads and ornaments, bone objects, and charmstones, suggests well-developed mortuary practices. Artifacts recovered mostly from burial contexts reflect extensive trade networks,
providing access to finely crafted implements made of obsidian originating east of the Sierra Nevada and from Napa County. Haliotis (abalone) and Olivella (olive snail) beads and ornaments also represent trade items, since manufacturing sites are undocumented in the local region. Multi-season plant and animal foods, residential
structures, cemeteries, mortars and pestles, and evidence for regular exchange, all suggest that relatively sedentary communities had emerged by the Early Period.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-10 Redwood Cabin Removal Project Draft EIR
The Middle Period (2150–930 cal BP) is often considered to have witnessed greater settlement permanence—
characterized by either sedentary or multi-season occupation. This time interval is also often considered to have been the heyday of mound building (as many of the bay margin shell mounds have dates within this time span) and
correlated with greater social complexity and ritual elaboration. A series of changes in artifact types has been documented, including barbless and single-barbed bone fishing spears; large, shaped mortars and equally large pestles; and ear spools and varied forms of Haliotis and Olivella beads and ornaments. Mortuary practices were often
highly ritualized, and some individuals, typically males, were buried with thousands of shell beads. Terrestrial resources appear to have been more heavily exploited than previously, based on food remains and isotopic analysis of human bone. Shifts in resource emphasis included greater use of deer; less reliance on oysters and more on mussels, clams or horn snail; and increased acorn exploitation.
The Late Period (685–180 cal BP) is the best-documented era, and current evidence suggests that Bay-Delta Area
populations grew in size, sedentary villages flourished, and material signatures of ritual activity increased. Artifact assemblages at the end of this period included clamshell disk beads, distinctive Haliotis pendants, flanged steatite
pipes, chevron-etched bone whistles and tubes, and needle-sharp coiled basketry awls.” The bow and arrow also are first documented in the region circa 700 cal BP, near the start of the Late Period. Funerary rituals were strongly patterned and included flexed interments and intentionally broken grave offerings, along with occasional cremations.
HISTORIC SETTING
Regional History
The Redwood Cabin is situated on land that was historically occupied by the Ohlone peoples prior to Spanish and Mexican settlement. The Redwood Cabin is located in the former Rancho San Gregorio, which stretched from the
coast of the Pacific Ocean up to the forested heights of the Santa Cruz Mountains.
The California Gold Rush and the rapid development of the city of San Francisco triggered a logging boom in the Santa Cruz Mountains. By the late 1800s and early 1900s, commercial timber logging in the Santa Cruz Mountains had
subsided. Beginning in the mid 1800s, the Santa Cruz Mountains were becoming a prime area for recreation, including camping, hunting, and fishing. The area’s proximity to San Francisco and other Bay Area cities, paired with the rise of the personal automobile in the early twentieth century made the forests of the San Francisco Peninsula ideal locations for middle-class and wealthy families to vacation. Tourism became the livelihood of La Honda, a nearby former logging town located south of the Redwood Cabin. Lodges and hotels were also constructed during this period to accommodate non-campers and long-term visitors.
During the early 1920s, San Francisco, San Mateo, Santa Clara and Santa Cruz counties established a joint highway
district in order to build Skyline Boulevard. Following the construction of Skyline Boulevard, the area was made more accessible to both visitors and year-round residents. The 1920s and 1930s brought the peak of residential development for the area. Developments like Skylonda (located directly east of the Redwood Cabin on Skyline Boulevard), Cuesta La Honda, the Middleton Tract, Sierra Morena Woods, Kings Mountain Park, and La Honda Park followed in the subsequent two decades, bringing hundreds of summer houses and cabins to the immediate area.
Despite their early popularity, most of the lodges and hotels along Skyline Ridge and in La Honda did not remain open past the Depression. As other recreation areas became accessible, the popularity of La Honda and the Santa
Cruz Mountains waned. With the rise of the conservation movement in the 1970s, the remaining forests, coastal areas, and open spaces of the Santa Cruz Mountains were preserved. As a result, much of the surrounding area, including the Redwood Cabin, has been incorporated into local and state parks and open space preserves. Today, the area
serves yet again as a popular day recreation area and the occasional permanent residence or vacation home (Page & Turnbull 2020).
Project Site History
The Redwood Cabin is situated on land within the boundary of the former Rancho San Gregorio and is near the site of former lumber mills, including Harrington Mill. According to Midpen’s records, the Redwood Cabin was
constructed by W.B. Allen as a family retreat from 1927-1928. Allen settled in Palo Alto in 1903 and owned and
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-11
operated Palo Alto Hardware. By 1918, he purchased 400 acres in La Honda including the subject parcel. With the
assistance of Norwegian laborers, Allen constructed the lodge on a bedrock foundation using local timber pieced together without nails. In addition to the lodge, Allen imported stones from the coast to construct walls, stairs, and
numerous stone-lined hiking trails throughout the property. In the 1930s, the California Conservation Corps assisted with the improvement of some roads near the property. The Allen family as well as local groups, including the YMCA and the rotary club, used the lodge as a summer retreat for decades. The property remained in the Allen (Paulin)
family until 1988 when Midpen purchased it.
By the early 1940s, Skyline Boulevard had been fully constructed along the Peninsula and a dirt road extended south, partially along the footprint of the road that connects to the Redwood Cabin. The Redwood Cabin first appeared on a USGS topographic map in 1961. During this time, the Skylonda development had grown and a section of Allen Road that connected the Redwood Cabin to Dyer Ranch and the White Barn was converted to a “Jeep trail,” (i.e., an
unimproved dirt road). A 1991 USGS topographic map shows the Redwood Cabin on the access road to Skyline Boulevard and a re-configured Allen Road.
An appraisal report from the San Mateo County Assessor’s Office, dated June 10, 1953 and July 21, 1954, is the earliest and only known official record of the Redwood Cabin on file at the County of San Mateo. The record lists the date of construction as approximately 1920 and indicates a 66-foot by 30-foot rectangular building labeled “lodge” with a wraparound open plank deck and a larger rear deck. The lodge is described as a 6-room building with one bathroom and redwood log walls; light shake roof; exposed rustic along rake of rafters; mud sills and large rustic posts; pine
floor; large natural stone fireplace; and deck pillars set on concrete piers. Three other buildings accompany the lodge on the appraisal report and are noted as being removed in 1966. The buildings appear to have been situated around the circular driveway and included two garages and a caretaker’s cabin with an open deck at the front. The
caretaker’s cabin and two garages are no longer extant on the site, and it is unknown whether they were demolished or relocated.
RECORDS SEARCHES AND REPORTS
A cultural resources literature search was conducted in July 2021 by the Northwest Information Center (NWIC) of the California Historical Resources Information System at Sonoma State University. The records search was conducted to
determine if prehistoric or historic cultural resources had been previously recorded within the project site, the extent to which the project site had been previously surveyed, and the number and type of cultural resources within a 0.25-mile radius of the project site. The following information was reviewed as part of the records search:
NRHP and CRHR,
California Office of Historic Preservation Historic Property Directory,
California Inventory of Historic Resources,
California State Historic Landmarks,
California Points of Historical Interest, and
Historic properties reference map.
The NWIC records search indicated that no resources were located within the project area or within a 0.25-mile
radius of the project area.
As described in Chapter 2, “Project Description,” the La Honda Creek Redwood Cabin Historic Resources Evaluation
Report (Historic Resources Evaluation) was prepared for the Redwood Cabin structure by Page & Turnbull, Inc. in 2020. The report indicated that the building was not included in the San Mateo County Inventory of County Historic Resources (Page & Turnbull 2020).
CRHR criteria were used to evaluate the significance of the historic features and archaeological sites. The CRHR is discussed in more detail above in Section 3.2.1, “Regulatory Setting.” Eligibility for listing in the CRHR rests on twin factors of significance and integrity. A resource must have both significance and integrity to be considered eligible.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-12 Redwood Cabin Removal Project Draft EIR
Loss of integrity, if sufficiently great, will become more important than the historical significance a resource may
possess and render it ineligible. Likewise, a resource can have complete integrity, but if it lacks significance, it must also be considered ineligible.
California Register of Historical Resources Eligibility
Findings of the Historic Resources Evaluation determined that the Redwood Cabin is a historical resource per CEQA because it appears to be eligible for listing in the CRHR under the following criteria:
Criterion 1. The La Honda Creek Redwood Cabin does appear to be significant under Criterion 1 (Events) as a property
associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States. The cabin was constructed at a peak of outdoor recreation in
the Santa Cruz Mountains. The Redwood Cabin’s construction appears representative of a broader pattern of recreational development in the Santa Cruz Mountains following the San Francisco Peninsula’s logging boom, specifically at a time when recreation shifted from camps to cabins and early subdivisions. While the cabin does not appear to be one of the earliest recreational cabins (from the late 1800s and early 1900s), it appears to be one of the last remaining ones intact from the transition era to permanent structures. Most of the original lodges and hotels
appear nonextant. The Redwood Cabin appears to be a rare building typology and retains its original rural setting. Therefore, the property does appear to be individually eligible for listing under Criterion 1 with its period of significance, 1927-1928, the years of its construction.
Criterion 3. The La Honda Creek Redwood Cabin does appear to be individually eligible for listing in the California Register under Criterion 3 (Architecture) as a building that embodies the distinctive characteristics of a type, period,
region, or method of construction, or that represents the work of a master or possesses high artistic values. The Redwood Cabin is a large, one-story side-gabled rectangular log cabin. It is constructed of barked redwood logs of
various sizes, with saddle notches that are set unconventionally and upside down. The cabin is supported by large rustic wood posts, some of which are set in concrete and others of which are set on grade. The cabin features a large, centered stone chimney that connects to an expansive interior fireplace, its foundation visible from beneath the cabin. Its openings consist of what appear to be original wood sash multi-lite windows, a large, handmade redwood door with iron details, and paneled one-lite wood doors and wood multi-lite French doors throughout. Much of the
cabin appears to be original. The building clearly utilizes local materials, and while its construction method appears slightly “primitive,” it appears indicative of the rural, woodsy character of the area and the period in which the region was transitioning to more permanent recreational structures. As such, the Redwood Cabin does appear to be a unique property type or architectural style such that it would rise to the level of individual significance within a local context (Page & Turnbull 2020).
Integrity
As determined in the Historic Resources Evaluation, the Redwood Cabin retains sufficient historic integrity to be
eligible for listing in the CRHR as an individual resource under each of the following categories:
Location,
Setting,
Design,
Materials,
Workmanship,
Feeling, and
Association.
In summary, CRHR eligibility was determined for the Redwood Cabin because it appears to be one of few remaining examples of a permanent recreational cabin from the 1920s with a high degree of integrity and is representative of the peak of recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1); and
is an example of an uncommon rustic recreational cabin in the Bay Area (CRHR Criterion 3). Further, the Historic Resource Evaluation determined that the Redwood Cabin retains a sufficient historic integrity to be eligible for listing in the CRHR as an individual resource (Page & Turnbull 2020).
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-13
Historic Landscape
In 2021, the La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum (memo) was
prepared by Page & Turnbull. The memo indicates that while the Redwood Cabin, itself, was constructed around 1927 to 1928 for owner W.B. Allen, research has not definitively revealed the original date of construction, builder, use, and
any other historic associations of the individual landscape features on the site. Without this information, it is not known whether these features contribute to the property’s overall significance under Criteria 1 and 3 for listing on the CRHR. The features are clustered around the cabin and most likely served a support function for the cabin and its
occupants. Due to their ancillary nature, the historic significance of these landscape features is likely to be dependent upon and inextricably connected to the cabin. Thus, removing the cabin but retaining the surrounding contributing landscape features would result in a loss of any associative historic significance that the landscape features may possess, as well.
Furthermore, the landscape features at the Redwood Cabin property do not appear to be individually historically significant as separate entities from the Redwood Cabin. The stone walls along the circular driveway, as well as the stairs leading up to the cabin and various hiking trails throughout the site, were reportedly constructed by W.B. Allen,
using stones imported from the California coast. There is speculation that the Civilian Conservation Corps may have assisted with the construction of these walls and helped improve other roads in the surrounding area in the 1930s. However, no clear documentary evidence has been uncovered to date that confirms that the Civilian Conservation Corps did, in fact, construct the walls or any other features at the La Honda Creek Redwood Cabin property.
Ultimately, the features do not appear to possess individual historic significance apart from the Redwood Cabin and
do not comprise a historic landscape. The landscape features were likely built as auxiliary features that served the Redwood Cabin and its occupants; therefore, any potential historic significance they may possess is likely to be as site
features associated with the cabin itself (Page & Turnbull 2021).
3.2.3 Impacts and Mitigation Measures
METHODOLOGY
The impact analysis for archaeological and historical resources is based on the findings and recommendations of the
La Honda Creek Redwood Cabin Historic Resources Evaluation Report (Page &Turnbull 2020) as well as the La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum (Page & Turnbull 2021). The analysis is also
informed by the provisions and requirements of federal, state, and local laws and regulations that apply to cultural resources.
Section 21083.2 of the State CEQA Guidelines defines “unique archaeological resource” as an archeological artifact,
object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets one or more of the following CRHR-related criteria: 1) that it contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; 2) that it as a special and particular quality, such as being the oldest of its type or the best available example of its type; or 3) that it is directly associated with a scientifically recognized important prehistoric or historic event or person. An impact on a “nonunique resource” is not a significant environmental impact under CEQA (State CEQA Guidelines Section 15064.5[c][4]). If an archaeological resource qualifies as a resource under
CRHR criteria, then the resource is treated as a unique archaeological resource for the purposes of CEQA.
In addition, according to PRC Section 15126.4(b)(1), if a project adheres to the Secretary of the Interior’s Standards for the Treatment of Historic Properties, the project’s impact “will generally be considered mitigated below the level of a significance and thus is not significant”.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-14 Redwood Cabin Removal Project Draft EIR
THRESHOLDS OF SIGNIFICANCE
Based on Appendix G of the State CEQA Guidelines, the project would result in a significant impact on cultural
resources if it would:
cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5 of the State CEQA Guidelines; or
cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 of the State CEQA Guidelines.
ISSUES NOT DISCUSSED FURTHER
All potential archaeological and historical resource issues identified in the significance criteria are evaluated below.
ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would result in a substantial adverse change in the significance of a recommended-eligible historical resource and would not implement Preserve Master Plan EPG CUL-3 No. 5, as stated. This would
result in a significant impact as described in State CEQA Guideline 15064.5(b)(1).
As discussed previously, the Redwood Cabin was evaluated for CRHR eligibility in 2020. The Historic Resources Evaluation concluded that the structure appears eligible for listing in the CRHR because it appears to be one of few
remaining examples of a permanent recreational cabin from the 1920s with a high degree of integrity and is representative of the peak of recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR
Criterion 1); and is an example of an uncommon rustic recreational cabin in the Bay Area (CRHR Criterion 3) (Page & Turnbull 2020).
As described in Section 3.2.2, “Environmental Setting,” the La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum concluded that landscape features surrounding the project site do not appear to possess individual historic significance apart from the Redwood Cabin and do not comprise a historic landscape. These
landscape features were likely built as auxiliary features that served the Redwood Cabin and its occupants; therefore, any potential historic significance they may possess is likely to be as site features associated with the cabin itself (Page & Turnbull 2021).
Implementation of the project would involve demolition of the Redwood Cabin and removal of associated site features, including the stone retaining wall, barbeque, and fire pits. The demolition of the Redwood Cabin would
result in a substantial adverse change in the significance of this historical resource because the building would no longer exist. Because associated site features were determined not to possess individual historic significance and do not comprise a historic landscape, removal of these features, in tandem with the Redwood Cabin would not result in an adverse change to the significance of a historic resource.
EPG CUL-3 No. 5 of the Preserve Master Plan calls for retaining/mothballing or moving historical resources. However, the Master Plan recommends historical and structural evaluations of the Redwood Cabin for future Midpen Board of Directors consideration on the disposition of the structure. Consistent with the Master Plan, historical and structural
evaluations for the Redwood Cabin were prepared in 2020. Based on those evaluations, the Midpen Board of Directors directed the General Manager to evaluate the environmental effects that would result from removing the Redwood Cabin.
Because the Redwood Cabin structure was recommended eligible for listing in the CRHR under criterion 1 and 3, and project activities would result in an adverse change in the significance of a CEQA historic resource, impacts would be
significant.
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-15
Mitigation 3.2-1a: Document historic buildings prior to removal.
Midpen shall complete Historic American Building Survey documentation of the Redwood Cabin before any demolition work is conducted. Documentation shall consist of written history of the property, plans and drawings of the historic
resources, and photographs, as described below:
Written History. The report shall be reproduced on archival bond paper.
Plans and Drawings. An architectural historian (or historical architect, as appropriate) shall conduct research into the
availability of plans and drawings of the Redwood Cabin as the building currently exists. If such plans/drawings exist, their usefulness as documentation for the building shall be evaluated by the architectural historian. If deemed
adequate, the plans/drawings shall be reproduced on archival mylar. If no plans/drawings are available, or if the existing plans/drawings are not found to be useful in documenting the historic resource, a historical architect shall prepare dimensioned plans and exterior elevations of the building. A combination of existing and new drawings is acceptable. All drawings shall be reproduced on archival mylar.
The architectural historian shall conduct research into the existence of the original architectural plans and drawings
of the building. If found, the plans shall be reproduced on archival mylar. Alternatively, the architectural plans can be scanned and saved as TIFF files. The scanning resolution shall be not less than 300 dpi.
All digital files, including drawing files, shall be saved on media and labeled following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital Photography Specifications.
Photographs. Digital photographs shall be taken of the Redwood Cabin following the Secretary’s Standards and
Guidelines for Archeology and Historic Preservation Digital Photography Standards.
The documentation shall be prepared by an architectural historian, or historical architect as appropriate, meeting the
Secretary’s Standards and Guidelines for Archeology and Historic Preservation, Professional Qualification Standards. The documentation shall be submitted to the San Mateo County Library, the San Mateo County Historical Association, the
Northwest Information Center, and the Midpen office in Los Altos.
Mitigation 3.2-1b: Redwood Cabin interpretation.
Midpen will create an interpretive resource outlining the Redwood Cabin’s historic status, historic context, and
significance. This resource will be available in a digital and/or physical format for public engagement and may be shared with a relevant local organization such as the San Mateo County Historical Association.
Mitigation Measure 3.2-1c: Salvage of useable materials.
Should any of the demolished structure materials (i.e., redwood logs) be found to be in acceptable condition (i.e., no lead paint, minimal dry rot), Midpen shall reserve materials for potential future uses and/or salvage in compliance with
Midpen’s waste diversion requirements outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. If these materials are free of pests, Midpen will coordinate with local historic salvage organization, such as Garden City Recycle and Salvage in Santa Cruz, Whole House Building Supply & Salvage in San
Mateo, or Heritage Salvage in Petaluma for their reuse.
Significance after Mitigation Implementation of Mitigation Measures 3.2-1a,3.2-1b, and 3.2-1c would lessen the impacts related to the loss of the Redwood Cabin through structure documentation, creation of an interpretive resource, and salvage of useable materials. However, because the historically eligible structure would no longer exist, impacts to the Redwood Cabin
would remain significant and unavoidable.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-16 Redwood Cabin Removal Project Draft EIR
Impact 3.2-2: Cause a Substantial Adverse Change in the Significance of Unique
Archaeological Resources
Project-related ground-disturbing activities could result in discovery or damage of yet undiscovered archaeological resources as defined in State CEQA Guidelines Section 15064.5. However, because project excavation activities would
occur in previously disturbed areas, the potential for encountering archaeological material is low. Additionally, because EPG CUL-1 would be implemented in the event of a discovery, this would be a less-than-significant impact.
As previously described, result of the NWIC records search indicated that no resources were located within the
project area or within a 0.25-mile radius of the project area. Implementation of the project would result in demolition of the Redwood Cabin, removal of associated site features (e.g., stone retaining wall and barbeque and fire pits), and
site recontouring activities post-construction. Demolition activities and staging associated with project implementation would result in ground disturbance at the project site. As described in Chapter 2, “Project Description,” the wooden posts that support the Redwood Cabin structure would be removed as part of structure
demolition. Removal of these wood posts would involve excavation of up to 2 to 5 feet in an area that had been disturbed during the installation of these posts. The project site is relatively disturbed from previous site uses, such as the construction of the retaining wall, and as indicated by the negative NWIC records search results, no known archaeological resources are present within the project site. Nevertheless, because the project would result in earth-moving activities, there is the potential that previously undiscovered archaeological materials could be encountered during construction.
In the event of that unanticipated archaeological materials are encountered during construction, Midpen and the
construction contractor would implement EPG CUL-1, Protocol for Unexpected Discovery of Archaeological and Paleontological Cultural Materials as identified in Section 3.2.1, “Regulatory Setting,” and originally described in the La Honda Creek Open Space Preserve Master Plan. CUL-1 includes discovery protocol such as stopping work within 30 feet of the discovery, notifying a qualified professional, and implementing methods to protect the find (e.g., fencing) until the significance of the find is determined and a treatment plan can be identified and implemented.
Because excavation would occur previously disturbed areas of the project, the potential for encountering archaeological material is low, and because EPG CUL-1 would be implemented in the event of a discovery, project
impacts related to archaeological resources would be less than significant.
Mitigation Measures
No mitigation is required for this impact.
Impact 3.2-3: Potential to Contribute to a Significant Cumulative Impact to Cultural
Resources
The project, in combination with other cumulative development in the area, could result in impacts to cultural resources in the area. Through the implementation of environmental protection measures, the contribution of the project would not be cumulatively considerable with respect to archaeological resources. However, because the
project would result in permanent removal of a historic architectural resource, impacts to historical resources would be significant. Therefore, cumulative impacts to cultural resources as a whole would be significant.
The cumulative context for the cultural resources analysis considers a broad regional system of which the resources are a part. The cumulative context for archaeological resources is the San Francisco Bay-Delta region, where archaeologists have developed a taxonomic framework describing patterns characterized by technology, particular
artifacts, economic systems, trade, burial practices, and other aspects of culture. The cumulative context for historical resources includes recreational development in the Santa Cruz Mountains.
Because all significant cultural resources are unique and nonrenewable members of finite classes, meaning there are a limited number of significant cultural resources, all adverse effects erode a dwindling resource base. The loss of any one archaeological site could affect the scientific value of others in a region because these resources are best
Exhibit A
Ascent Environmental Cultural Resources
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 3.2-17
understood in the context of the entirety of the cultural system of which they are a part. The cultural system is
represented archaeologically by the total inventory of all sites and other cultural remains in the region. As a result, a meaningful approach to preserving and managing cultural resources must focus on the likely distribution of cultural
resources, rather than on a single project or parcel boundary.
Archaeological Resources No known unique archaeological resources are located within the boundaries of the proposed project site;
nonetheless, project-related earth-disturbing activities could damage undiscovered archaeological resources. The proposed project in combination with other projects in the area, such as Midpen’s Fuel Reduction Implementation
projects, Agricultural Workforce Housing at La Honda Creek Open Space Preserve, and bridge replacement and repair projects in the Preserve, could contribute to ongoing substantial adverse changes in the significance of unique archaeological resources. As described above, implementation of EPG CUL-1, would avoid potential adverse effects to
archaeological resources by ensuring proper identification, evaluation, and treatment of previously unidentified archaeological material, such that impacts would be less than significant. Therefore, implementation of the project would not contribute to a cumulative loss of archaeological resources. Similarly, cumulative project under Midpen’s jurisdiction would be required to implement EPG CUL-1 to avoid/reduce impacts to archaeological resources.
Historical Resources The Redwood Cabin was constructed during a peak of outdoor recreation activities in the Santa Cruz Mountains. The Redwood Cabin’s construction appears representative of a broader pattern of recreational development in the Santa
Cruz Mountains following the San Francisco Peninsula’s logging boom, specifically at a time when recreation shifted from camps to cabins and early subdivisions. A small number of other redwood cabins are located in the Bay Area;
however, they do not appear to have been evaluated for CRHR- or NRHP-eligibility, and, therefore, it is not known if they are historical resources under CEQA. While the Redwood Cabin does not appear to be one of the earliest recreational cabins (from the late 1800s and early 1900s), it appears to be one of the last remaining ones intact from
the transition era to permanent structures, in the area. Additionally, as described in Impact 3.2-1, the Redwood Cabin is an eligible historic architectural resource. As such, implementation of the project would result in removal of a CEQA historical resource as well as one of the few remaining structures representative of recreational development in the region. Implementation of Mitigation Measures 3.2-1a, 3.2-1b, and 3.2-1c would lessen the impacts related to the loss of the Redwood Cabin, however, would not reduce the project’s impact associated with an adverse change to the significance of a historical resource. This permanent loss in the resource would result in a cumulatively considerable contribution to a historic impact.
Conclusion Therefore, although cumulative impacts to archaeological resources would be less than significant, cumulative
impacts to cultural resources as a whole would be significant and unavoidable.
Exhibit A
Cultural Resources Ascent Environmental
Midpeninsula Regional Open Space District 3.2-18 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 4-1
4 ALTERNATIVES
4.1 INTRODUCTION
The California Code of Regulations (CCR) Section 15126.6(a) (State CEQA Guidelines) requires EIRs to describe “… a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of
the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather, it must consider a range of potentially feasible alternatives that will avoid or substantially lessen the
significant adverse impacts of a project and foster informed decision making and public participation. An EIR is not required to consider alternatives that are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.” This section of the State CEQA Guidelines also provides guidance regarding what the alternatives analysis should consider. Subsection (b) further states the purpose of the alternatives analysis is as follows:
Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the
environment (Public Resources Code [PRC] Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.
The State CEQA Guidelines require that the EIR include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects
of the alternative must be discussed, but in less detail than the significant effects of the project as proposed (CCR Section 15126.6[d]).
The range of alternatives studied in an EIR is governed by the “rule of reason,” requiring evaluation of only those
alternatives “necessary to permit a reasoned choice” (State CEQA Guidelines Section 15126.6[f]). Further, an agency “need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative” (State CEQA Guidelines Section 15126.6[f][3]). The analysis should focus on alternatives that are feasible (i.e., that may be accomplished in a successful manner within a reasonable period of time, taking economic, environmental, social, and technological factors into account). Alternatives that are remote or speculative
or that do not feasibly meet most of the project objectives need not be discussed. Furthermore, the alternatives analyzed for a project should focus on reducing or avoiding significant environmental impacts associated with the
project, as proposed.
The proposed project is intended to achieve the following primary objectives, in alignment with Midpen’s mission:
Remove physical hazards to ensure public safety;
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate surroundings;
Reduce structure and wildland fire risk by removing a structure with a history of vandalism;
Improve natural visual character and scenic open space qualities at the site; and
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district.
Exhibit A
Alternatives Ascent Environmental
Midpeninsula Regional Open Space District 4-2 Redwood Cabin Removal Project Draft EIR
4.2 SUMMARY OF ENVIRONMENTAL IMPACTS
The purpose of this section is to briefly summarize the significant impacts to the environment with implementation of the Redwood Cabin Removal Project, as identified in Chapter 2 of this document. Potentially significant impacts,
which implementation of feasible mitigation measures would reduce to a less-than-significant level, were identified for biological resources (special-status species and associated habitats) and archaeological resources.
Significant impacts were identified for cultural resources for which further mitigation is not available and the impact
remains significant and unavoidable. Specifically, the proposed project would result in demolition of a structure that has been recommended eligible for listing in the California Register of Historical Resources (CRHR). Although mitigation measures require documentation of the building before removal, because the building would be lost, the impact is considered significant and no additional feasible mitigation measures are available. This is also considered a significant contribution to a cumulative impact.
See Section 3.1, “Cultural Resources” and Section 3.2, “Biological Resources” of this Draft EIR for a more detailed summary of the impact conclusions and mitigation measures identified.
4.3 ALTERNATIVES CONSIDERED BUT NOT EVALUATED FURTHER
As described above, State CEQA Guidelines Section 15126.6(c) provides that the range of potential alternatives for the
project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. Alternatives that fail to meet the fundamental project purpose need not be addressed in detail in an EIR. (In re Bay-Delta Programmatic Environmental Impact Report
Coordinated Proceedings (2008) 43 Cal.4th 1143, 1165-1167.)
In determining what alternatives should be considered in the EIR, it is important to acknowledge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are crucial to the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is feasible or infeasible is made by lead agency decision maker(s). (See Pub. Resources Code, § 21081(a)(3).) At the time of action on the project, the decision maker(s) may consider evidence beyond that found in this EIR in addressing
such determinations. The decision maker(s), for example, may conclude that a particular alternative is infeasible (i.e., undesirable) from a policy standpoint, and may reject an alternative on that basis provided that the decision maker(s) adopts a finding, supported by substantial evidence, to that effect, and provided that such a finding reflects a reasonable balancing of the relevant economic, environmental, social, and other considerations supported by substantial evidence. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; California Native Plant
Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 998.)
The EIR should also identify any alternatives that were considered by the lead agency but were rejected during the
planning or scoping process and briefly explain the reasons underlying the lead agency’s determination. The following alternatives were considered but are not evaluated further in this Draft EIR.
4.3.1 Retain Site Elements Alternative
The Retain Site Elements Alternative would be similar to the proposed project in that it would remove the Redwood Cabin, but this alternative would retain other site elements outside of the immediate cabin footprint, such as the
horseshoe pit, barbeque, and stone retaining walls. No long-term operations and maintenance would occur to manage the features left on site. This alternative was mentioned by a Midpen Board of Director’s member during a
June 2021 Board scoping meeting.
The horseshoe pit, barbeque, and stone retaining walls do not have historical significance on their own and, as described in Section 3.1, “Cultural Resources,” are not recommended eligible for listing in the CRHR as landscape
features. This alternative was eliminated from further consideration because it would not avoid project-related
Exhibit A
Ascent Environmental Alternatives
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 4-3
significant and unavoidable impacts associated with removal of historic structures and would also not meet the
project objectives. For these reasons discussed, the Retain Site Elements Alternative has been eliminated from further consideration in this Draft EIR.
4.3.2 Relocate and Stabilize Alternative
This alternative involves relocating the Redwood Cabin to a new location, either within La Honda Creek Open Space Preserve or to a site not owned by Midpen, if a feasible site were identified, as allowed by EPG CUL-3. Currently, there
is no public access to or around the Redwood Cabin; the Relocate and Stabilize Alternative would select a location that would allow public viewing and historic interpretation of the cabin. In order to retain the structure’s historic
integrity and therefore its eligibility for listing in the CRHR, the site would have to be in a similar setting to the current location. Under the Relocate and Stabilize Alternative, the Redwood Cabin would be stabilized so that visitors could walk around the perimeter and view the structure up close; however, interior access would not be permitted.
This alternative was eliminated from further consideration because it fails to meet two project objectives. Objective 2, enhance habitat at the Redwood Cabin site and immediate surroundings, would not be met because preparing a new building site for the Redwood Cabin would expand the disturbed project footprint by impacting new areas of undisturbed, natural habitat. This could result in significant impacts to biological resources. Objective 6, implement a fiscally sustainable project, would not be met because relocating the cabin would significantly increase costs to disassemble, move and reconstruct the building, which would then require additional stabilization improvements to reduce public safety hazards at the relocation site. Thus, this alternative would not achieve a fiscally sustainable
project. For these reasons discussed, the Relocate and Stabilize Alternative has been eliminated from further consideration in this Draft EIR.
4.4 ALTERNATIVES SELECTED FOR DETAILED ANALYSIS
California Code of Regulations Section 15126.6(e) (1) requires that the no project alternative be described and
analyzed “to allow decision makers to compare the impacts of approving the project with the impacts of not approving the project.” The no project analysis is required to discuss “the existing conditions at the time the notice of preparation is published…as well as what would be reasonably expected to occur in the foreseeable future if the
project were not approved, based on current plans and consistent with available infrastructure and community services” (Section 15126.6[e][2]). “If the project is… a development project on identifiable property, the ‘no project’ alternative is the circumstance under which the project does not proceed. Here the discussion would compare the environmental effects of the property remaining in its existing state against environmental effects that would occur if the project is approved. If disapproval of the project under consideration would result in predictable actions by
others, such as the proposal of some other project, this ‘no project’ consequence should be discussed. In certain instances, the no project alternative means ‘no build’ wherein the existing environmental setting is maintained. However, where failure to proceed with the project will not result in preservation of existing environmental conditions, the analysis should identify the practical result of the project’s non-approval and not create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment.” (Section 15126[e][3][B].)
The following alternatives are evaluated in this Draft EIR.
Alternative 1: No Project Alternative assumes no demolition of the existing structure. The project site would remain in its current condition.
Alternative 2: Stabilize Alternative assumes no demolition of the existing structure but includes stabilizing the building and site.
Alternative 3: Repair and Rehabilitate Alternative assumes the repair and rehabilitation of the building for
eventual reuse as a retreat space, meeting space, or hikers hut (or similar use).
Exhibit A
Alternatives Ascent Environmental
Midpeninsula Regional Open Space District 4-4 Redwood Cabin Removal Project Draft EIR
Further details on these alternatives, and an evaluation of environmental effects relative to the proposed project, are
provided below.
4.4.1 Alternative 1: No Project Alternative
Under Alternative 1, the No Project Alternative, no actions would be taken by Midpen and the project site would remain unchanged. The Redwood Cabin would remain vacant and in its current deteriorated condition. The No Project Alternative would not meet the project objectives. However, as required by CEQA, the No Alternative is
evaluated in this Draft EIR. This alternative would not meet any of the objectives identified in Section 4.1.
Biological Resources. The No Project Alternative includes no demolition or excavation activities and no changes in the
current activities at the project site. Therefore, no impact to biological resources would occur. However, this alternative does not provide the long-term opportunity to improve biological resources that the proposed project does. No invasive plant treatment would occur as part of this alternative, nor would site enhancements, including soil
decompaction and amendments, or revegetation. The proposed project includes environmental protection guidelines, best management practices, and requires mitigation measures to reduce construction-related impacts to special-status species and habitat. Because of this loss of opportunity to improve biological resources if the Redwood Cabin were retained, compared to the proposed project, the No Project Alternative would result in Slightly Greater impact to biological resources than the proposed project.
Cultural Resources. No sub-surface archaeological resources would have the potential to be affected by implementation of the No Project Alternative because it includes no excavation or other ground-disturbing activities.
However, the proposed project includes EPGs to reduce construction-related impacts to archaeological resources. The existing historical resource on the site, the Redwood Cabin, would not be demolished. Although implementation
of the No Project Alternative might appear to avoid the significant impact of the proposed project by avoiding demolition of a CRHR-eligible building, further deterioration under the No Project Alternative would likely ultimately result in an overall similar impact because over time, this deterioration and on-going vandalism would further compromise the already deteriorating nature of the building. It is likely that the cabin would become so greatly deteriorated, it would no longer be able to convey its historical significance and no longer be eligible for listing in the
CRHR. Compared to the proposed project, the No Project Alternative would, in the long-term, result in Slightly Less impact to cultural resources than the proposed project and would not ultimately substantially reduce or avoid the significant impact since the structure would continue to fall in disrepair over time.
4.4.2 Alternative 2: Stabilize Alternative
The Stabilize Alternative would address structural deficiencies to retain and stabilize the structure over the long term.
The goal of this alternative is to freeze or reduce building deterioration over time while preserving as many of the exterior character-defining features as possible. The stabilize alternative would require incurring short- and long-term
costs to maintain the site.
The stabilization methods under the Stabilize Alternative target only the gravity related structural deficiencies and would not allow for re-occupancy of the building. The following methods would be implemented under this alternative:
Mothball the structure per Secretary of the Interior’s standards: board up and secure the structure’s windows,
doors, skylights, and openings/gaps; restrict access to the interior of the structure; provide passive ventilation to the interior; develop and implement a maintenance and monitoring plan. Mothballing also includes wildlife
exclusion plans. The mothballing plan would also include hazardous material abatement to encapsulate or remove the existing lead paint in the structure.
Exterior: remove collapsed and unsafe portions of the porch framing, and handrail – replace only what is
necessary for ongoing maintenance of the structure; repair the roof for waterproofing; repair the chinking
Exhibit A
Ascent Environmental Alternatives
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 4-5
between the exterior logs for waterproofing and treating for insects. Additional site security, including cyclone
fencing and no trespassing signs would likely be needed.
Site preparation: prepare the subfloor and surrounding area for foundation repairs, stabilize the underside of the
structure with wood box cribbing, remove shrubs and weeds adjacent to the structure, remove five trees that are either dead, growing at a heavy lean towards the structure, or unhealthy.
Wildlife management: pest control, preconstruction surveys for bats and woodrats prior to stabilization activities,
removal of wildlife in the structure.
Utilities: disconnect and remove power, electrical panel, and plumbing.
This alternative would achieve only one of the project objectives identified in Section 4.1. Because the Redwood Cabin would not be removed under the Stabilize Alternative, it would not enhance the habitat of the site and surroundings or improve natural visual character and scenic qualities to the degree of the proposed project. Although some habitat
improvement activities would occur under this option, such as shrub, weed, and dead tree removal, they would be limited to areas outside the footprint of the building. Additionally, because the cabin would not be removed,
continued vandalism and risk of fire, either to the structure itself or to both the structure and surrounding area, would remain. Stabilizing the Redwood Cabin would remove physical hazards for improved public safety.
Biological Resources. The Stabilize Alternative includes no demolition or excavation activities and no changes in the current activities at the project site. Bats and woodrats exclusion activities would occur prior to stabilization activities as part of the mothballing plan; however, long-term exclusion would require on-going inspection and maintenance and is
unlikely to be effective, given the frequency the building has been vandalized. Invasive plant treatment would occur under this alternative, however, any additional site enhancements, including soil decompaction and amendments, or revegetation would only occur under Midpen’s Invasive Pest Management Program or the Wildland Fire Resiliency Program. Therefore, this alternative does not provide the long-term opportunity to improve biological resources that the proposed project does. This alternative would also include the environmental protection guidelines, best management practices, and similar mitigation measures to the proposed project to reduce construction-related impacts to special-status species, including bats and woodrats. Because of this loss of opportunity to improve biological
resources if the Redwood Cabin were retained, compared to the proposed project, the Stabilize Alternative would result in Slightly Greater impact to biological resources than the proposed project.
Cultural Resources. No sub-surface archaeological resources are likely to be affected by implementation of the Stabilization Alternative because it includes only minor ground-disturbing activities in previously disturbed areas (i.e., foundation repair, utility removal). The alternative would include EPGs to reduce any potential impacts to
archaeological resources. The existing historical resource on the site, the Redwood Cabin, would not be demolished thereby avoiding a significant and unavoidable impact. Stabilization of the Redwood Cabin would reduce building deterioration over time. Through up front and ongoing stabilization repairs and maintenance investments, the building would retain its historical significance and remain eligible for listing in the CRHR. Compared to the proposed project, the Stabilize Alternative would result in Less impact to cultural resources than the proposed project.
4.4.3 Alternative 3: Repair and Rehabilitate Alternative
Under Alternative 3, the Repair and Rehabilitate Alternative, the building would be rehabilitated for eventual reuse as
a retreat space, meeting space, or hikers hut (or similar use). Under this alternative, the Redwood Cabin would remain off-limits to the public. The building would be rehabilitated following the recommendations of the Secretary of the
Interior’s Standards for the Treatment of Historic Properties. Rehabilitating the structure to allow for a retreat space, meeting space, or hikers hut, would likely require upgrades and alterations of several building and site elements. The Repair and Rehabilitate Alternative would require substantial investment and ongoing costs to improve and maintain the structure.
Exterior: Fully reconstruct porch and railing; repair the roof for waterproofing; repair the chinking between the
exterior logs for waterproofing and treat for insects; prepare hazardous material abatement plan to encapsulate or remove the existing lead paint in the structure.
Exhibit A
Alternatives Ascent Environmental
Midpeninsula Regional Open Space District 4-6 Redwood Cabin Removal Project Draft EIR
Foundation: remove and replace the lower three courses of horizontal logs on the exterior; lift the foundation
back to its original level and pin the underside for stability; pour concrete footings for each post that extends into the ground.
Wildlife management: pest control, preconstruction surveys for bats and woodrats prior to stabilization activities; remove wildlife in the structure; prepare a wildlife exclusion plan.
Interior finishes: remodel bathroom and kitchen for reuse.
Site utilities: install a new septic system; provide a safe drinking water source by verifying viability of existing water source for reuse or drilling for a new water source; replace interior plumbing and electrical.
This alternative would achieve only two of the project objectives identified in Section 4.1. Because the Redwood Cabin would not be removed under the Repair and Rehabilitate Alternative, it would not enhance the habitat of the site and surroundings or improve natural visual character and scenic qualities to the degree of the proposed project.
Rehabilitating the Redwood Cabin would remove physical hazards to ensure public safety. Additionally, by eventually activating the project site, the potential for vandalism and associated fire risk would be reduced, but not eliminated
since the building would remain vacant for extended periods of time between occupancy.
Biological Resources. The Repair and Rehabilitate Alternative includes construction and excavation activities related to
the installation of new concrete footings, site utilities, and a new septic system which were not included in the proposed project. Invasive plant treatment would occur under this alternative, however, any additional site enhancements, including soil decompaction and amendments, or revegetation would only occur under Midpen’s
Invasive Pest Management Program or the Wildland Fire Resiliency Program. Therefore, this alternative does not provide the long-term opportunity to improve biological resources that the proposed project does. This alternative would also include the environmental protection guidelines, best management practices, and similar mitigation measures to the proposed project to reduce construction-related impacts to special-status species and habitat. However, unlike the proposed project or other alternatives, this alternative includes an eventual operational component—opening the structure for limited gatherings—that could result in additional effects related to biological resources. Intensifying use in this area as a destination site that accommodates gatherings, especially with the use of
an operational kitchen, would generate food waste, which could attract invasive wildlife species (especially birds and rodents), which could affect the ecology of the site and negatively impact future marbled murrelet nesting success. Compared to the proposed project, the Repair and Rehabilitate Alternative would result in Greater impacts to biological resources than the proposed project.
Cultural Resources. Because the Repair and Rehabilitate Alternative includes ground-related construction activities
associated with the installation of concrete footings, site utilities and a septic system, potential impacts to sub-surface archaeological resources would be slightly greater than the proposed project. However, the alternative would include
EPGs to reduce construction-related impacts to archaeological resources. The existing historical resource on the site, the Redwood Cabin, would not be demolished thereby avoiding a significant and unavoidable impact. Rehabilitation of the Redwood Cabin would be consistent with recommendations of the Secretary of the Interior’s Standards for the Treatment of Historic Properties. The building would retain its historical significance and remain eligible for listing in the CRHR. Compared to the proposed project, the Repair and Rehabilitate Alternative would result in Less impact to
cultural resources than the proposed project.
4.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
As illustrated in Table 4-1, below, the Stabilize Alternative would be the environmentally superior alternative. It would result in slightly greater impacts to biological resources but would avoid the proposed project’s significant and
unavoidable cultural resource impact. This significant and unavoidable impact would not be avoided under the No Project Alternative, and impacts to biological resources would be slightly greater under the No Project Alternative than under the proposed project because it would not provide the long-term opportunity to improve biological
resources.
Exhibit A
Ascent Environmental Alternatives
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 4-7
The Repair and Rehabilitate Alternative would also avoid the proposed project’s significant and unavoidable cultural
resource impact, however, impacts to biological resources would be greater under this alternative. As with the Stabilize Alternative, the Repair and Rehabilitate Alternative does not provide the long-term opportunity to improve
biological resources that the proposed project does. Additionally, although the site is not currently open to the public, there would be a greater area of ground disturbance once the site is open to the public. The Master Plan identified this area for future public access opportunities, but the timeline for opening this area of La Honda Creek
Open Space Preserve is many multiple years out given other public access priorities for the preserve.
Table 4-1 Summary of Environmental Effects of the Alternatives Relative to the Proposed Redwood Cabin Project
Environmental Topic Proposed Project Alternative 1: No Project Alternative Alternative 2: Stabilize Alternative Alternative 3: Repair and Rehabilitate Alternative
Biological Resources LTSM Slightly Greater Slightly Greater Greater
Cultural Resources SU Slightly Less Less Less
Notes: LTSM = Less Than Significant with Mitigation SU = Significant and Unavoidable
Source: Compiled by Ascent in 2021
Table 4-2 identifies which project objectives are met by the alternatives described above. As described in Section
4.4.2, the Stabilize Alternative meets only one of the objectives: removing physical hazards to ensure public safety. The remaining four objectives would not be met by this alternative. Therefore, while the Stabilize Alternative would be the environmentally superior action alternative, it would not meet the objectives of the project as presented above
in Section 4.1.
Table 4-2 Objectives Achieved by Project Alternatives
Project Objective Objective Met? Alternative 1: No Project
Alternative
Objective Met? Alternative 2: Stabilize
Alternative
Objective Met? Alternative 3: Repair and
Rehabilitate Alternative
Remove physical hazards to ensure public safety No Yes Yes
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate surroundings No No No
Reduce structure and wildland fire risk by removing a structure with a history of vandalism No No Yes
Improve natural visual character and scenic open space qualities at the site No No No
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district No No No
Source: Compiled by Ascent in 2021
Exhibit A
Alternatives Ascent Environmental
Midpeninsula Regional Open Space District 4-8 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 5-1
5 OTHER CEQA SECTIONS
5.1 GROWTH INDUCEMENT
California Environmental Quality Act (CEQA) Section 21100(b)(5) specifies that the growth-inducing impacts of a project must be addressed in an environmental impact report (EIR). Section 15126.2(d) of the State CEQA Guidelines
provides the following guidance for assessing growth-inducing impacts of a project:
Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in
this are projects which would remove obstacles to population growth (a major expansion of a wastewater treatment plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also, discuss the characteristics of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
A project can induce growth directly, indirectly, or both. Direct growth inducement would result if a project involved construction of new housing. Indirect growth inducement would result, for instance, if implementing a project resulted in any of the following:
substantial new permanent employment opportunities (e.g., commercial, industrial, or governmental enterprises);
substantial short-term employment opportunities (e.g., construction employment) that indirectly stimulates the need for additional housing and services to support the new temporary employment demand; and/or
removal of an obstacle to additional growth and development, such as removing a constraint on a required public
utility or service (e.g., construction of a major sewer line with excess capacity through an undeveloped area).
Growth inducement itself is not an environmental effect but may foreseeably lead to environmental effects. If
substantial growth inducement occurs, it can result in secondary environmental effects, such as increased demand for housing, demand for other community and public services and infrastructure capacity, increased traffic and noise, degradation of air or water quality, degradation or loss of plant or animal habitats, conversion of agricultural and
open-space land to urban uses, and other effects.
5.1.1 Growth-Inducing Impacts of the Project
Project construction activities would involve construction crews of approximately eight people over a period of 10 weeks. It is anticipated that construction crews would be part of the existing workforce in the greater San Mateo
County area and therefore would not result in the need to hire new construction employees within the region. Once project construction activities are complete, the project site would remain inaccessible to the public. Implementation of the Redwood Cabin Removal Project would not induce population growth because it would not introduce new
land uses associated with population increases (e.g., housing, employment centers.) The project would not include land uses that would result in people relocating to the area and would not displace housing units or people. Additionally, project activities would not extend utilities to an area not currently served, and would, therefore, not contribute to future growth of the project area. As such, implementation of the project would not cause growth inducing impacts.
Exhibit A
Other CEQA Sections Ascent Environmental
Midpeninsula Regional Open Space District 5-2 Redwood Cabin Removal Project Draft EIR
5.2 SIGNIFICANT AND UNAVOIDABLE ADVERSE IMPACTS
The State CEQA Guidelines Section 15126.2(b) requires EIRs to include a discussion of the significant environmental effects that cannot be avoided if the proposed project is implemented. As documented throughout Chapter 3
(project level and cumulative impacts) of this Draft EIR, after implementation of the recommended mitigation measures, most of the impacts associated with the Redwood Cabin Removal Project would be reduced to a less-than-significant level. The following impact is considered significant and unavoidable; that is, no feasible mitigation is
available to reduce the project’s impacts to a less-than-significant level.
5.2.1 Cultural Resources
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would involve removal of the Redwood Cabin which has been recommended eligible for listing in the California Register of Historical Resources. Thus, the project would adversely result in significant
changes to a CEQA historical resource. Mitigation Measure 3.2-1 requires Midpen to complete documentation of the structure, which involves preparation of written history for the property, plans and drawings of the historical resource, and photographs. However, even after implementation of Mitigation Measure 3.2-1, the project would still result in a
significant and unavoidable impact because the historical resource would no longer exist.
5.3 SIGNIFICANT AND IRREVERSIBLE ENVIRONMENTAL CHANGES
The State CEQA Guidelines requires a discussion of any significant irreversible environmental changes that would be caused by the project. Specifically, the State CEQA Guidelines section 15126.2(c) states:
Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible,
since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generation to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.
The project would result in the irreversible and irretrievable commitment of energy and material resources during construction and operation, including the following:
water supply for project construction activities; and
energy expended in the form of electricity, natural gas, diesel fuel, gasoline, and oil for equipment and
transportation vehicles that would be needed for project construction activities.
These nonrenewable resources would represent only a very small portion of the resources available in the region and
would not affect the availability of these resources for other needs within the region.
Construction activities would not result in inefficient use of energy or natural resources. Demolished materials would be salvaged, reused, and/or recycled as feasible. During removal of the Redwood Cabin, construction contractors
would use best available engineering techniques, construction and design practices, and equipment operating procedures. Once construction activities are complete, the project site would be vacant, would not be accessible to the public, and would not result in any consumption of energy and natural resources above what is currently used for periodic monitoring, and fuel reduction activities.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 6-1
6 REPORT PREPARERS
Midpeninsula Regional Open Space District (Lead Agency)
Jane Mark ............................................................................................................................................................................ Planning Manager
Jared Hart .................................................................................................................................................................................. Senior Planner Alex Casbara ...................................................................................................................................................................................... Planner III
Melissa Borgesi .................................................................................................................................................................................. Planner II Coty Sifuentes-Winter ........................................................................................................... Senior Resource Management Specialist Matthew Sharp Chaney .................................................................................................................. Resource Management Specialist II Paul Kvam .......................................................................................................................................................... Capitol Project Manager III Craig Beckman ........................................................................................................................................................... Skyline Area Manager
Ascent Environmental, Inc. (CEQA Compliance)
Mike Parker .......................................................................................................................................................................................... Principal Alta Cunningham ................................................................................................................................................................. Project Manager
Kirsten Burrowes ................................................................................................... Assistant Project Manager/Environmental Planner Ted Thayer ............................................................................................................................................................................................ Biologist
Lara Rachowicz ....................................................................................................................................................................... Senior Biologist Lisa Merry .................................................................................................................................................. GIS Specialist/Resource Analyst Brian Perry ............................................................................................................................................................................................ Graphics
Gayiety Lane ................................................................................................................................................................... Publishing Specialist Michele Mattei ............................................................................................................................................................... Publishing Specialist
Page & Turnbull (Historical Resources)
Christina Dikas .................................................................................................................................................................. Associate Principal Sarah Brummett ................................................................................................................................................................... Senior Associate
Exhibit A
Report Preparers Ascent Environmental
Midpeninsula Regional Open Space District 6-2 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 7-1
7 REFERENCES
Executive Summary
LSA Associates. 2018. Historic Resource Evaluation of the Dyer Barn. Prepared for Midpeninsula Regional Open Space
District.
Midpen. See Midpeninsula Regional Open Space District.
Midpeninsula Regional Open Space District. 2020 (October). Memorandum to Midpeninsula Regional Open Space District from Matt Sharp Chaney, Resource Management Specialist II, regarding La Honda Creek White Barn
Bat Habitat. Available: https://www.openspace.org/sites/default/files/IPM_EIR_Addendum.pdf
ZFA. 2020 (March). Redwood Cabin Structure Stabilization Basis of Design.
Chapter 1 Introduction
None
Chapter 2 Project Description Ascent Environmental. 2021. White Barn Stabilization Project Addendum. Prepared for Midpeninsula Regional Open Space District.
City of Half Moon Bay. 2014 (July). Existing Conditions, Trends, and Opportunities Assessment.
LSA Associates. 2018. Historic Resource Evaluation of the Dyer Barn. Prepared for Midpeninsula Regional Open Space
District.
Midpen. See Midpeninsula Regional Open Space District.
Midpeninsula Regional Open Space District. 2012a. La Honda Creek Open Space Preserve Master Plan. Available: https://www.openspace.org/sites/default/files/2012.08.21.LHCMP_.pdf.
———. 2012b. La Honda Creek Open Space Preserve Master Plan. Available: https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf.
———. 2014. Integrated Pest Management Program. Available: https://www.openspace.org/sites/default/files/IPM_Guidance_Manual.pdf.
———. 2019. Integrated Pest Management Program Addendum to the Environmental Impact Report. Available: https://www.openspace.org/sites/default/files/IPM_EIR_Addendum.pdf.
———. 2020 (October). Memorandum to Midpeninsula Regional Open Space District from Matt Sharp Chaney, Resource Management Specialist II, regarding La Honda Creek White Barn Bat Habitat. Available: https://www.openspace.org/sites/default/files/IPM_EIR_Addendum.pdf.
U.S. Department of Interior. 1990. The Secretary of the Interior's Standards for Rehabilitation with Guidelines for Applying the Standards. Originally issued in 1976, updated in 1990 by by Gary L. Hume, H. Ward Jandl, and Kay D. Weeks.
Waste Management. 2020. Facility Overview. Available: https://kettlemanhillslandfill.wm.com/fact-sheets/2011/facility-overview.jsp. Accessed: 12/1/2020.
ZFA. 2020 (March). Redwood Cabin Structure Stabilization Basis of Design.
Chapter 3 Environmental Impacts and Mitigation Measures None
Section 3.1 Biological Resources Belluomini, L. 1980 (June). Status of the Ringtail in California. The State of California Resources Agency, Department of Fish and Game, Nongame Wildlife Investigations.
Exhibit A
References Ascent Environmental
Midpeninsula Regional Open Space District 7-2 Redwood Cabin Removal Project Draft EIR
Bulger, J. B., N. J. Scott jr., R. B. Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands. Biological Conservation. 110: 85-95.
California Department of Fish and Wildlife. 2020. List of California Sensitive Natural Communities. September 9, 2020.
California Native Plant Society, Rare Plant Program. 2021. Inventory of Rare and Endangered Plants (online edition, v8-02). Search of the Mindego Hill, La Honda, San Gregorio, Palo Alto, Woodside, Half Moon Bay, Redwood Point, San Mateo, and Montara Mountain USGS 7.5’ quadrangles. California Native Plant Society, Sacramento, CA. Available: http://www.rareplants.cnps.org. Accessed February 2021.
California Natural Diversity Database. 2021. Rarefind 5. Commercial Version. Online Subscription Database. Search of the Mindego Hill, La Honda, San Gregorio, Palo Alto, Woodside, Half Moon Bay, Redwood Point, San Mateo, and Montara Mountain USGS 7.5’ quadrangles. California Natural Heritage Division, California Department of Fish and Wildlife. Sacramento, CA. Accessed, February 2021.
CDFW. See California Department of Fish and Wildlife.
CNDDB. See California Natural Diversity Database.
CNPS. See California Native Plant Society.
H.T. Harvey and Associates. 2007. Marbled Murrelet Habitat Assessment and Management Recommendations, Phase I – Preliminary Review and Recommendations. Prepared for: Midpeninsula Regional Open Space District. Los Altos, CA. Prepared by: H.T. Harvey and Associates. San Jose, CA. March 2007.
Santa Cruz Puma Project. 2021. Puma Tracker. Available: http://www.santacruzpumas.org/puma-tracker/ Accessed: February 2021.
Swaim Biological Inc. 2019. La Honda Creek Preserve, Sierra Azul Preserve, Purisima Uplands, and Rancho San Antonio Preserve – Structural Surveys for Special-Status Mammal Species. Prepared for: Midpenisula Regional Open Space District. Los Altos, California. Prepared by: Swaim Biological Incorporated. Livermore, CA. June 2019.
U.S. Fish and Wildlife Service. 2016. Intra-Service Biological Opinion on the issuance of a 10(a)1(A) permit to the Midpeninsula Regional Open Space District for the San Francisco Garter Snake and California Red-Legged Frog Habitat Enhancement Projects at their Opens Space Preserves in San Mateo and Santa Clara counties, California. Sacramento Fish and Wildlife Office, U.S. Fish and Wildlife Service. Sacramento, California. December 2016.
———. 2020. Revised Transmittal of Guidance: Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California.
USFWS. See U.S. Fish and Wildlife Service.
Vollmar Natural Lands Consulting. 2020. 2020 Botanical Resources Survey Report, La Honda Structural Stabilization Project, La Honda Creek Open Space Preserve, San Mateo County, California. Prepared for: Midpeninsula
Regional Open Space District. Los Altos, CA. Prepared by: Vollmar Natural Lands Consulting. Berkeley, CA. November 2020.
Section 3.2 Cultural Resources Caltrans. See California Department of Transportation.
California Department of Transportation. 2017 (June). San Francisco Bay-Delta Regional Context and Research Design for Native American Archaeological Resources, Caltrans District 4.
Page & Turnbull. 2020 (March). La Honda Creek Redwood Cabin Historic Resource Evaluation Report.
———. 2021 (September). La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum.
San Mateo County. 2013. County of San Mateo General Plan Policies. Accessed August 31, 2021. Available: https://planning.smcgov.org/documents/general-plan-policies.
Exhibit A
Ascent Environmental References
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Draft EIR 7-3
National Park Service. 1994 (September). Preservation Brief 36, Protecting Cultural Landscapes: Planning, Treatment, and Management of Historic Landscapes. Prepared by Charles A. Birnbaum. Available: https://www.nps.gov/tps/how-to-preserve/briefs/36-cultural-landscapes.htm.
NPS. See National Park Service.
U.S. Department of Interior. 1990. The Secretary of the Interior's Standards for Rehabilitation with Guidelines for Applying the Standards. Originally issued in 1976, updated in 1990 by Gary L. Hume, H. Ward Jandl, and Kay D. Weeks.
Chapter 4 Alternatives None
Chapter 5 Other CEQA Sections None
Exhibit A
References Ascent Environmental
Midpeninsula Regional Open Space District 7-4 Redwood Cabin Removal Project Draft EIR
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Exhibit A
Appendix A
Notice of Preparation and Comments
Exhibit A
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Exhibit A
Exhibit A
From: Chris MacIntosh <chrismac@alumni.upenn.edu>
Sent: Friday, July 9, 2021 12:27 PM
To: Alex Casbara <acasbara@openspace.org>
Subject: Comment on La Honda cabin
EXTERNAL
Dear Alex Casbara,
I would like to request that the redwood cabin at upper La Honda Open Space Preserve not be
demolished.
It has historic value, as noted in the report.
We remove so much that is too expensive or inconvenient to preserve, and then in later decades
people regret that that was done. That is likely to be the case here:
This cabin is a testament to the building skills of 20th century immigrants who built it, and the
generations who've lived and recreated in the Skyline area.
I understand and appreciate that MROSD is not in the building management business. However, if
MROSD could partner with another organization, the cabin has great potential for continued use:
perhaps as an event center, for nature education, a visitor center for the Sky Londa and Skyline
region, or a combination of all.
MROSD preserves natural habitats for future generations: let's find a way to preserve this piece of
human history for future generations also.
I urge the Board to reconsider the recommendation for demolition.
Thank you.
Chris MacIntosh
chrismac@alumni.upenn.edu
Exhibit A
County of Santa Clara
Roads and Airports Department
Planning, Land Development and Survey
101 Skyport Drive
San Jose, CA 95110-1302
(408) 573-2460 FAX 441-0276
Board of Supervisors: Mike Wasserman, Otto Lee, Susan Ellenberg, S. Joseph Simitian, Cindy Chavez
County Executive: Jeffrey V. Smith
July 1, 2021
Alex Casbara,
Planner Ill
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
acasbara@openspace.org
SUBJECT: Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for the Redwood Cabin
Removal Project
The County of Santa Clara Roads and Airports Department (The County) appreciates the opportunity to review the Notice
of Preparation (NOP) of an Environmental Impact Report (EIR) for the Redwood Cabin Removal Project, and is
submitting the following comments:
• Please have the project to provide construction Traffic Control Plan (TCP) for County to review if any
County roads are included in the hauling routes.
If you have any questions or concerns about these comments, please contact me at 408-573-2462 or
ben.aghegnehu@rda.sccgov.org
Thank you.
Exhibit A
From: Karyn Ellis <karyn@karynhunt.com>
Sent: Sunday, July 4, 2021 6:34 PM
To: Alex Casbara <acasbara@openspace.org>
Subject: Comment on the Redwood Cabin
EXTERNAL
I’m writing to oppose demolition of the Redwood Cabin in La Honda Creek Open Space Preserve.
Because the report on the cabin finds that it has historical significance, and because we have so little
of our history preserved in the Skylonda area, it would be a shame to let this remaining piece go. The
history of logging and summer camps in the Skylonda area is rich and significant to the development
of the Peninsula. Please try to save this one piece for future generations to study and enjoy.
Karyn Ellis
Karyn Ellis
415-279-4868
KarynHunt.org
“I never saw a discontented tree.” John Muir
Exhibit A
NATIVE AMERICAN HERITAGE COMMISSION
June 9, 2021
Alex Casbara
CHAIRPERSON
Laura Miranda
Luiser5o
Midpeninsula Regional Open Space District
330 Dispel Circle
Los Altos, CA 94022
Re: 2021060146, Redwood Cabin Removal Project, San Mateo County
VICE CHAIRPERSON
Reginald Pagaling
Chumash
Dear Mr. Casbara:
SECRETARY
Meni lopez-Keifer
Luiserro
PARLIAMENT ARIAN
Russell Attebery
Karuk
COMMISSIONER
William Mungary
Paiute/White Mountain
Apache
The Native American Heritage Commission (NAHC) has received the Notice of Preparation
(NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project
referenced above. The California Environmental Quality Act (CEQA) (Pub. Resources Code
§21000 et seq.), specifically Public Resources Code §21084.1, states that a project that may
cause a substantial adverse change in the significance of a historical resource, is a project that
may have a significant effect on the environment. (Pub. Resources Code § 21084.1; Cal. Code
Regs., tit.14, §15064.5 (b) (CEQA Guidelines §15064.5 (b)). If there is substantial evidence,in
light of the whole record before a lead agency, that Cl project may have a significant effect on
the environment, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources
Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)(1) (CEQA Guidelines §15064 (a)(1)).
In order to determine whether a project will cause Cl substantial adverse change in the
significance of a historical resource, a lead agency will need to determine whether there are
historical resources within the area or potential effect (APE).
COMMISSIONER
Julie Tumamait-
Stenslie
Chumash
COMMISSIONER
[Vacant]
COMMISSIONER
[Vacant]
COMMISSIONER
[Vacant]
EXECUTIVE SECRETARY
Christina Snider
Pomo
CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of
2014) (AB 52) amended CEQA to create a separate category of cultural resources, "tribal
cultural resources" (Pub. Resources Code §21074) and provides that a project with an effect
that may cause a substantial adverse change in the significance of a tribal cultural resource is
a project that may have a significant effect on the environment. (Pub. Resources Code
§21084.2). Public agencies shall, when feasible, avoid damaging effects to any tribal culturol
resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice
of preparation, a notice of negative declaration, or a mitigated negative declaration is filed on
or affer July 1, 2015. If your project involves the adoption of or amendment to a general plan or
C! specific plan, or the designation or proposed designation of open space, on or after March 1,
2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).
Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the
federal National Environmental Policy Act (42 u.s.c. § 4321 et seq.) (NEPA), the tribal
consultation requirements of Section 106 of the National Historic Preservation Act of 1966 (154
u.s.c. 300101, 36 C.F.R. §800 et seq.) may also apply.
NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramenfo,
California 95691
(916) 373-3710
nahc@nahc.ca.qov
NAHC.ca.gov
The NAHC recommends consultation with California Native American tribes that are
traditionally and culturally affiliated with the geographic area of your proposed project as early
as possible in order to avoid inadvertent discoveries of Native American human remains and
best protect tribal cultural resources. Below is a brief summary of of AB 52 and SB 18 as
well as the NAHC's recommendations for conducting cultural resources assessments.
Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with
any other applicable laws.
Page 1 of 5
Exhibit A
AB 52
AB 52 has added to CEQA the additional requirements listed below, along with many other requirements:
1. Fourteen Day Period to Provide Notice of Completion of an Application/Decision to Undertake a Project:
Within fourteen (14) days of determining that an application for a project is complete or of a decision by a public
agency to undertake a project, Cl lead agency shall provide formal notification to a designated contact of, or
tribal representative of, traditionally and culturally affiliated California Native American tribes that have
requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.
Resources Code §21080.3.1 (d)).
d. A "California Native American tribe" is defined as a Native American tribe located in California that is
on the contact list maintained by the NAHC for the purposes of Chapter 905 of Statutes of 2004 (SB 18).
(Pub. Resources Code §21073).
2. Beqin Consultation Within 30 Days of Receivinq a Tribe's Request for Consultation and Before Releasinq a
Neqative Declaration, Mitiqated Neqative Declaration, or Environmental Impact Report: A lead agency sha
begin the consultation process within 30 days of receiving a request for consultation from a California Native
American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.
(Pub. Resources Code §21080.3.i subds. (d) and (e)) and prior to the release of a negative declaration,
mitigated negative declaration or Environmental Impact Report. (Pub. Resources Code §21080.3.1(b)).
a. For purposes of AB 52, "consultation shall have the same meaning as provided in Gov. Code §65352.4
(SB18). (Pub. Resources Code §21080.3.1 (b)).
3. Mandatory Topics of Consultation If Requested by C) Tribe: The following topics of consultation, if a tribe
requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
c. Significant effects. (Pub. Resources Code §21080.3.2 (a)).
4. Discretionary Topics of Consu(fation: The folfowing topics are discrefionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project's impacts on tribal cultural resources.
d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe
may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).
5. Confidentiali+y of Information Submitted by a Tribe Durinq the Environmental Review Process: With some
exceptions, any information, including but not limited to, the location, description, and use of tribal cultural
resources submitted by a California Native American tribe during the environmemal review process shall not be
included in the environmental document or otherwise disclosed by the lead agency or any other public agency
to the public, consistent with Government Code §6254 (r) and §6254.10. Any information submitted by a
California Native American tribe during the consultation or environmental review process shall be published in a
confidential appendix to the environmental document unless the tribe that provided the information consents, in
writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3 (c) (1 )).
6. Discussion of Impacts to Tribal Cultural Resources in the Environmental Document: If a project may have a
significant impact on a tribal cultural resource, the lead agency's enyironmental document shall discuss both of
the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource.
b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed
to pursuant to Public Resources Code §21082.3, subdivision (C)), avoid or substantially lessen the impact on
the identified tribal cultural resource. (Pub. Resources Code §21082.3 (b)).
Page 2 of 5
Exhibit A
7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the
following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on
o tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot
be reached. (Pub. Resources Code §21080.3.2 (b)).
8. Recommendinq Mitiqa+ion Measures Aqreed Upon in Consultation in the Environmental Document: Any
mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code §21080.3.2
shall be recommended for inclusion in the environmental document and in an adopted mitigation monitoring
and reporting program,if determined to avoid or lessen the impact pursuant to Public Resources Code §21082.3,
subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §21082.3 (a)).
9. Required Consideration of Feasible Mitiqation: If mitigation measures recommended by the staff of the lead
agency as a result of the consultation process are not included in the environmemal document or if there are no
agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if
substan+iol evidence demonstrates thot 0 project will cause o significant effect to a tribal cultural resource, the
lead agency shall consider feasible mitigation pursuant to Public Resources Code §21084.3 (b). (Pub. Resources
Code §21082.3 (e)).
10. Examples of Mitiqation Measures That, If FeOsibleH May Be Considered to Avoid or Minimize Significant Adverse
Impacts to Tribal Cultural Resources:
a. Avoidance and preservation of the resources in place, including, but not limited to:
i. Planning and construction to avoid the resources and protect the cultural and natural
context.
ii. Planning greenspace, parks, or other open space, to incorporate the resources with culturally
appropriate protection and management criteria.
b. Treating the resource with culturally appropriate dignity, +aking into account the tribal cultural values
and meaning of the resource, including, but not limited to, the following:
i. Protecting the cultural character and integrity of the resource.
ii. Protecting the traditional use of the resource.
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easements or other interests in real property, with culturally appropriate
management criteria for the purposes of preserving or utilizing the resources or places.
d. Protecting the resource. (Pub. Resource Code §21084.3 (b)).
e. Please note that a federally recognized California Native Am'erican tribe or a non-federally
recognized California Native Americqn tribe.that is on the contact list maintained by the NAHC to protect
a California prehistoric, archaeological, cultural, spiritual, or ceremonial place may acquire and hold
conservation easemen+s if the conservation easement is voluntarily conveyed. (Civ. Code §815.3 (c)).
f. Please note that it is the policy of the state that Native American remains and associated grave
artifacts shall be repatriated. (Pub. Resources Code §5097.991).
11. Prerequisites for Certifyinq an Environmental Impact Report or Adoptinq a Mitiqated Neqative Declaration or
Neqative Declaration with a Siqnificant Impact on an Identified Tribal Cultural Resource: An Environmental
Impact Report may not be certified, nor may a mitigated negative declaration or a negative declaration be
adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public
Resources Code §21080.3.1 and §21080.3.2 and concluded pursuant to Public Resources Code
§21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise
failed to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources
Code §21080.3.1 (d) and the tribe failed to request consultation within 30 days. (Pub. Resources Code
§21082.3 (d)).
The NAHC's PowerPoin+ presentation titled, "Tribal Consultation Under AB 52: Requirements and Best Practices" may
be found online at: http://nahc.ca.qov/wp-content/uploads/2015/10/AB52TribalConsultation ColEPAPDF.pdf
Page 3 of 5
Exhibit A
-SB18
SB 18 applies to local governments and requires 10CC)I governments to contact, provide notice to, refer plans to, and
consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of
open space. (Gov. Code §65352.3). Local governments should consult the Governor's Office of Planning and
Research's "Tribal Consultation Guidelines," which can be found online at:
ht+ps://www.opr.ca.qov/docs/09 14 05 Updated Guidelines 922.pdf.
Some of SB 18's provisions include:
1. Tribal Consultation: l'f a local government considers o proposal to adopt or amend o general plan or a
specific plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC
by requesting Cl "Tribal Consultation List." If a tribe, once contacted, requests consultation the IOCC)I government
must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification to
requestconsultationunlessashortertimeframehasbeenagreedtobythetribe. (Gov.Code§65352.3
(a)(2)).
2. No Statutory Time Limit on SB '18 Tribal Consultation. There is no statutory time limit on SB 18 tribal consultation.
3. Confidentiality: Consistent with the guidelines developed and adopted by the Office of Planning and
Research pursuant to Gov. Code §65040.2, the city or county shall protect the confidentiali+y of the information
concerning the specific ideritity, location, charactm, and use of places, features and objects described in Public
Resources Code §5097.9 and §5097.993 that are'within the city's or county's jurisdiction. (Gov. Code §65352.3
(b)).
4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures
for preservation or mitigation; or
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes
that mutual agreement c,annot be reached concerning the appropriate measures of preservation or
mitigation. (Tribal Consultation Guidelines, Governor's Office of Planning and Research (2005) at p. 18).
Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initioting tribal consultation with
tribes that are traditionally and culturally affiliated with t.hei2urisdic+ions before the timeframes provided in AB 52 and
SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and "Sacred Lands
File" searched from tte NAHC. The request forrrts can be found online at: h+tp://nahc.ca.qov/resources/forms/.
NAHC Recommendations for Cultural Resources Assessments
To adequately assess the exis'tence and significance of tribal cultural resources and plan for avoidance, preservation
in place, or barring both, mitigation of project-related impacts to tribal cultural resources, the NAHC recommends
the following actions:
1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center
(http://ohp.parks.ca.qov/'.paqe id=l068) for an archaeological records search. The records search will
determine:
a. If part or Call of the APE has been previously surveyed for cultural resources.
b. If any known cultural resources have already been recorded on or adjacent to the APE.
c. If the probabiiity is low, moderate, or high that cutfural resources are located in the APE.
d. If a survey is required to determine whether previously unrecorded cultural resources are present.
2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report
detailing the findings and recommendations of the records search and field survey.
a. The final report containing site forms, site significance, and mitigation measures should be submitted
immediately to the p(anning department. All information regarding site locations, Native American
human remains, and associated funerary objects should be in a separate confidential addendum and
not be made ovailable for public disclosure.
b. The finat written report should be submitted within 3 months after work has been completed to the
appropriate regional CHRIS center.
Page 4 of 5
Exhibit A
3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the
Sacred Lands File, nor are they required to do so. A Sacred Lands File search is not a substitute for
consultation with tribes that are traditionally and culturally affiliated with the geographic area of the
project's APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the
project site ond to assist in planning for avoidance, preservation in place, or, failing both, mitigation
measures.
4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources)
does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for
the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code
Regs., tit. 1 4, §15064.5(f) (CEQA Guidelines §15064.5(f) ). In areas of identified archaeological sensitivity, a
certified archaeologist and a culturally affiliated Native American with knowledge of cultural resources
should monitor all ground-disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the disposition of recovered cultural items that are not burial associalied in consultation with culturally
affiliated Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions
for the treatment and disposition of inadvertently discovered Native Americqn human remains. Health
and Safety Code §7050.5, Public Resources Code §5097.98, and CC)I. Code Regs., tit. 14, §15064.5,
subdivisions (d) and (e) (CEQA Guidelines §15064.5, subds. (d) and (e)) address the processes to be
followed in the event of an inadvertent discovery of any Native American human remains and
associated grave goods in a location other than a dedicated cemetery.
If you have any questions or need additional information, please contact me at my email address:
Sarah.Fonseca@nahc.ca.qov.
Sincerely,
Sarah Fonseca
Cultural Resources Analayst
cc: State Clearinghouse
Page 5 of 5
Exhibit A
Appendix B
Initial Study
Exhibit A
INITIAL STUDY
Redwood Cabin Removal Project
Prepared for
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
April 2022
Exhibit A
INITIAL STUDY
Redwood Cabin Removal Project
Prepared for:
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
Prepared by
Ascent Environmental, Inc.
455 Capitol Mall, Suite 300
Sacramento, CA 95814
April 2022
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study i
TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS ........................................................................................................................................................................... II
1 INTRODUCTION ........................................................................................................................................................................ 1-1
1.1 Project Overview ............................................................................................................................................................ 1-1 1.2 Purpose of this Document .......................................................................................................................................... 1-1 1.3 Document Organization .............................................................................................................................................. 1-1
1.4 Summary of Findings ................................................................................................................................................... 1-2
2 ENVIRONMENTAL CHECKLIST ............................................................................................................................................... 2-1 2.1 Aesthetics ........................................................................................................................................................................ 2-1
2.2 Agriculture and Forest Resources ........................................................................................................................... 2-3 2.3 Air Quality ...................................................................................................................................................................... 2-5 2.4 Biological Resources .................................................................................................................................................. 2-13
2.5 Cultural Resources ...................................................................................................................................................... 2-16 2.6 Energy ............................................................................................................................................................................ 2-18
2.7 Geology and Soils ...................................................................................................................................................... 2-20 2.8 Greenhouse Gas Emissions ..................................................................................................................................... 2-24 2.9 Hazards and Hazardous Materials ........................................................................................................................ 2-28
2.10 Hydrology and Water Quality ................................................................................................................................. 2-31 2.11 Land Use and Planning ............................................................................................................................................ 2-35
2.12 Mineral Resources ...................................................................................................................................................... 2-37 2.13 Noise .............................................................................................................................................................................. 2-38
2.14 Population and Housing .......................................................................................................................................... 2-42 2.15 Public Services ............................................................................................................................................................ 2-43 2.16 Recreation .................................................................................................................................................................... 2-45
2.17 Transportation ............................................................................................................................................................ 2-46 2.18 Tribal Cultural Resources ......................................................................................................................................... 2-48
2.19 Utilities and Service Systems .................................................................................................................................. 2-50 2.20 Wildfire .......................................................................................................................................................................... 2-52
2.21 Mandatory Findings of Significance ..................................................................................................................... 2-54
3 REFERENCES ............................................................................................................................................................................... 3-1
4 REPORT PREPARERS ................................................................................................................................................................ 4-1
Attachments
A Air Quality and Greenhouse Gas Emissions Modeling Results
B Energy Modeling Results C Noise Modeling Results
Tables
Table 2.3-1 Air Pollutants ................................................................................................................................................................. 2-6 Table 2.3-2 Attainment Status Designations for San Mateo County .................................................................................. 2-7
Table 2.3-3 BAAQMD Air Quality Significance Thresholds .................................................................................................... 2-9 Table 2.3-4 Summary of Average Daily Pounds Per Day Construction Emissions of Criteria Pollutants and
Precursor Emissions .................................................................................................................................................... 2-11 Table 2.8-1 2005 Unincorporated San Mateo County GHG Emissions Inventory ......................................................... 2-25 Table 2.8-2 2018 Midpen GHG Emissions Inventory .............................................................................................................. 2-25
Table 2.13-1 Noise Emission Levels from Construction Equipment .................................................................................... 2-40
Exhibit A
List of Abbreviations Ascent Environmental
Midpeninsula Regional Open Space District ii Redwood Cabin Removal Project Initial Study
LIST OF ABBREVIATIONS
AB Assembly Bill
BAAQMD Bay Area Air Quality Management District
BMP best management practices
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
Cal EPA California Environmental Protection Agency
CAL FIRE California Department of Forestry and Fire Protection
CalEEMod California Emissions Estimator Model
CAP Climate Action Plan
CARB California Air Resources Board
CCAA California Clean Air Act
CCR California Code of Regulations
CEC California Energy Commission
CH4 methane
CHRIS California Historical Resources Information System
CO carbon monoxide
CO2 Carbon dioxide
CRHR California Register of Historical Resources
DTSC Department of Toxic Substances Control
EECAP Energy Efficiency Climate Action Plan
EIA U.S. Energy Information Administration
EIR environmental impact report
EO Executive Order
EPA U.S. Environmental Protection Agency
EPG environmental protection guideline
FEMA Federal Emergency and Management Agency
GHG greenhouse gases
GHG greenhouse gases
H2S hydrogen sulfide
HAP hazardous air pollutants
HFC hydrofluorocarbons
in/sec inches per second
IPCC Intergovernmental Panel on Climate Change
IS Initial Study
Exhibit A
Ascent Environmental Introduction
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study iii
Leq Equivalent Continuous Sound Level
Lmax Maximum Sound Level
Midpen Midpeninsula Regional Open Space District
MTCO2e metric tons of CO2 equivalents
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NO2 nitrogen dioxide
NOX nitrogen oxides
OEHHA Office of Environmental Health Hazard Assessment
PFC perfluorocarbons
PM10 Particulate matter 10 micrometers or less in diameter
PM2.5 Particulate matter 2.5 micrometers or less in diameter
PPV peak particle velocity
PRC Public Resources Code
Preserve La Honda Creek Open Space Preserve
Program Wildland Fire Resiliency Program
project Redwood Cabin Removal Project
RMS root-mean-square
ROG reactive organic gases
RPS Renewables Portfolio Standard
SB Senate Bill
SF6 sulfur hexafluoride
SFBAAB San Francisco Bay Area Air Basin
SO2 sulfur dioxide
SPL sound pressure level
TAC toxic air contaminants
TPZ Timber Land Preserve District
VdB decibel notation
VMT vehicle miles traveled
Exhibit A
List of Abbreviations Ascent Environmental
Midpeninsula Regional Open Space District iv Redwood Cabin Removal Project Initial Study
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 1-1
1 INTRODUCTION
1.1 PROJECT OVERVIEW
This Initial Study (IS) has been prepared by the Midpeninsula Regional Open Space District (Midpen) to evaluate potential environmental effects resulting from the Redwood Cabin Removal Project (project). The approximately 100-
year-old structure is currently vacant. The project would remove the existing Redwood Cabin structure and other human-made features (i.e., retaining walls, fire/barbeque pits) within the project site. After demolition and removal activities, site recontouring would ensure soil stabilization and erosion control within disturbed portions of the site.
No public access facilities would be constructed as part of this project. Please see Chapter 2, “Project Description,” in the accompanying environmental impact report (EIR) for detailed information about the project.
1.2 PURPOSE OF THIS DOCUMENT
This document has been prepared in accordance with the California Environmental Quality Act (CEQA) (Public
Resources Code [PRC] Section 21000 et seq.) and the CEQA Guidelines (California Code of Regulations [CCR] Section 15000 et seq.). Under CEQA, an IS can be prepared by a lead agency to determine if a project may have a significant effect on the environment (CEQA Guidelines Section 15063[a]), and thus to determine the appropriate environmental
document. In this circumstance, the lead agency has prepared the following analysis that identifies potential environmental impacts requiring further evaluation and preparation of an EIR. Under CEQA, the lead agency is the public agency with primary responsibility over approval of the project; therefore, Midpen is the CEQA lead agency for this project. This IS is being made available to the public and is included as Appendix B within the Redwood Cabin Removal Project EIR.
1.3 DOCUMENT ORGANIZATION
This IS is organized as follows:
Chapter 1: Introduction. This chapter introduces the environmental review process, describes the purpose and organization of this document, and presents a summary of findings.
Chapter 2: Environmental Checklist. This chapter presents an analysis of a range of environmental issues identified in the CEQA Environmental Checklist and determines if project actions would result in no impact, a less-than-significant impact, a less-than-significant impact with mitigation incorporated, or a potentially significant impact. If any impacts
were determined to be potentially significant, an EIR would be required.
Chapter 3: References. This chapter lists the references used in preparation of this IS.
Chapter 4: Report Preparers. This chapter identifies report preparers.
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-2 Redwood Cabin Removal Project Initial Study
1.4 SUMMARY OF FINDINGS
The environmental factors checked below would be potentially affected by this project, involving at least two impacts that are “Potentially Significant Impacts” as indicated by the checklist on the following pages. Where
checked below, the topic with a potentially significant impact will be addressed in an EIR.
Aesthetics Agriculture and Forest Resources Air Quality
Biological Resources Cultural Resources Energy
Geology / Soils Greenhouse Gas Emissions Hazards / Hazardous Materials
Hydrology / Water Quality Land Use / Planning Mineral Resources
Noise Population / Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities / Service Systems Wildfire Mandatory Findings of Significance
None None with Mitigation Incorporated
As indicated above, potentially significant impacts were identified for cultural resources and mandatory findings of significance. Impacts to air quality and biological resources were identified to be less than significant with mitigation
incorporated. The project’s potential environmental effects to biological and cultural resources, and mandatory findings of significance are addressed in an EIR. Impacts to air quality are addressed in Section 2.3 of this Initial Study.
Exhibit A
Ascent Environmental Introduction
Midpeninsula Regional Open Space District
Redwood Cabin Removal Project Initial Study 1-3
DETERMINATION (To be completed by the Lead Agency)
On the basis of this initial evaluation:
I find that the proposed project could not have a significant effect on the environment, and a
NEGATIVE DECLARATION will be prepared.
I find that although the proposed project COULD have a significant effect on the environment, there
WILL NOT be a significant effect in this case because revisions in the project have been made by or
agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a “potentially significant impact” or “potentially significant
unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed
in an earlier document pursuant to applicable legal standards, and 2) has been addressed by
mitigation measures based on the earlier analysis as described on attached sheets. An
ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be
addressed.
I find that although the proposed project could have a significant effect on the environment, because
all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE
DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to
that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are
imposed upon the proposed project, nothing further is required.
Signature Date
6XVDQQD&KDQ $VVLVWDQW*HQHUDOManager
Midpeninsula Regional Open Space District
Exhibit A
Introduction Ascent Environmental
Midpeninsula Regional Open Space District 1-4 Redwood Cabin Removal Project Initial Study
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-1
2 ENVIRONMENTAL CHECKLIST
2.1 AESTHETICS
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
I. Aesthetics.
Except as provided in Public Resources Code section 21099 (where aesthetic impacts shall not be considered significant for qualifying residential, mixed-use residential, and employment centers), would the project:
a) Have a substantial adverse effect on a scenic vista?
b) Substantially damage scenic resources, including, but
not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage points.) If the project is in an urbanized area, would
the project conflict with applicable zoning and other regulations governing scenic quality?
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area?
2.1.1 Environmental Setting
As described in Chapter 2, “Project Description,” of the accompanying EIR, the project site is located within the upper portion of the La Honda Creek Open Space Preserve (Preserve), west of the community of Sky Londa, California and
south of Skyline Boulevard/Highway 35. The project site includes the approximate 2,000 square foot Redwood Cabin, a circular dirt driveway, a small grove of redwood trees, as well as several stone retaining walls, a stone barbeque pit,
and a fire pit. No existing sources of light are present within the project site and public access is not currently available.
Overall, the visual character of the Preserve, as well as scenic vistas from and onto the Preserve, are generally very high quality (Midpen 2012a). The visual character of the project site consists of the existing Redwood Cabin, sloped terrain, and heavily wooded surroundings. Because of these visual obstructions, views to and from the site are unavailable from any publicly accessible area or property not owned by Midpen. For the same reasons, the project site is not
visible from Highway 35, which is an officially-designated State Scenic Highway located approximately 800 feet north of the project site (Caltrans 2018).
2.1.2 Discussion
a) Have a substantial adverse effect on a scenic vista?
No impact. A scenic vista is generally defined as a distant public view along or through an opening or corridor that is
recognized and valued for its scenic quality, or a natural or cultural resource that is indigenous to the area. As
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-2 Redwood Cabin Removal Project Initial Study
described above, various locations within the Preserve offer views of scenic vistas both to and from the Preserve.
However, due to the dense wooded area surrounding the project site, long distance views are limited. For this reason, there are no scenic vistas visible to or from the project site. Project demolition and site recontouring activities would
therefore not result in adverse effects on a scenic vista; the project would restore the site to its natural state. No impact would occur, and no mitigation would be required.
b) Substantially damage scenic resources, including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
Less-than-significant impact. Highway 35, which is an officially designated State Scenic Highway, is located approximately 800 feet north of the project site (Caltrans 2018). The Redwood Cabin has been evaluated as appearing eligible for listing in the California Register of Historical Resources (CRHR) and is therefore a historical resource under
CEQA. As described in Criterion (a), views to and from the project site are limited due to the surrounding wooded areas. Further, the project site, including the Redwood Cabin, is not visible from Highway 35. Therefore, although project activities would include demolition of the Redwood Cabin and recontouring within the project site, it would not substantially damage scenic resources, within a state scenic highway because the project site is not visible from the state scenic highway. Impacts would be less than significant, and no mitigation would be required.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are
experienced from publicly accessible vantage points.) If the project is in an urbanized
area, would the project conflict with applicable zoning and other regulations
governing scenic quality?
Less-than-significant impact. As previously described, the visual character of the site consists of the existing Redwood
Cabin, sloped terrain, and surrounding wooded area which shields views towards and from the project site. No public access to the site is currently permitted and as such, no public views towards the site are available. Project activities would alter the visual character of the project site through removal of the existing Redwood Cabin. Once the structure
has been demolished and materials have been removed from the site, disturbed areas would be revegetated and recontoured to ensure adequate erosion control and site drainage. No maintenance or operational activities would be required at the project site after construction and the site would remain closed to the public. Because the project site is not visible or accessible to the public, and would remain closed once project activities are complete, implementation of the project would not degrade the existing visual character or quality of public views of the site and its surroundings. Impacts would be less than significant, and no mitigation would be required.
d) Create a new source of substantial light or glare which would adversely affect day or
nighttime views in the area?
No impact. Construction activities associated with removal of the Redwood Cabin structure and site recontouring would occur during daylight hours and would not require nighttime lighting. Construction equipment is unlikely to
have reflective surfaces, other than what is required for safety purposes, and would not create a substantial source of glare in the area. Once construction activities are complete, the site would remain undeveloped, secured and closed to
the public; no sources of light or glare would be present at the project site. Therefore, no impact would occur, and no mitigation would be required.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-3
2.2 AGRICULTURE AND FOREST RESOURCES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. Agriculture and Forest Resources.
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997, as updated) prepared by the
California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland.
In determining whether impacts to forest resources, including timberland, are significant environmental effects,
lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest
Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
b) Conflict with existing zoning for agricultural use or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of,
forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government
Code section 51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use?
e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or
conversion of forest land to non-forest use?
2.2.1 Environmental Setting
While areas suitable for grazing are identified within the Preserve (Midpen 2012a: 3-12), no areas identified as Important Farmland, meaning Farmland of Statewide or Local Importance, Unique Farmland, or Prime Farmland are
identified within the Preserve. No grazing land, Important Farmland, or land under Williamson Act contract is present within the project site (CDOC 2021). The parcel containing the project site is classified as “other land.”
According to the San Mateo County General Plan land use map, the project site is within an area zoned for Forest
resources and Timber Production (TPZ) (San Mateo County 2021). However, no logging or other timber harvest activities currently occur on or adjacent to the project site.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-4 Redwood Cabin Removal Project Initial Study
2.2.2 Discussion
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non-agricultural use?
No impact. No Important Farmland is located within the Preserve or on the project site. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation.
Therefore, the project would not result in conversion of designated Important Farmland, and there would be no impact.
b) Conflict with existing zoning for agricultural use or a Williamson Act contract?
No impact. No parcels with active Williamson Act Contracts are present within or adjacent to the project site. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation. Therefore, the project would not conflict with any agricultural land uses or Williamson Act Contracts
and would have no impact.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland (as defined by Public Resources Code
section 4526), or timberland zoned Timberland Production (as defined by Government
Code section 51104(g))?
No impact. The parcel containing the project site does contain forest resources and is designated as a Timber Production Zone per the San Mateo County General Plan. No timber harvest occurs on the project site. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, grading and
recontouring, and site revegetation. The project does not propose zoning or land use changes, and project activities would not substantially limit availability or affect quality of forest or timber resources within the vicinity of the project. Therefore, the project would have no impact.
d) Result in the loss of forest land or conversion of forest land to non-forest use?
No impact. See discussion under item c) above.
e) Involve other changes in the existing environment, which, due to their location or
nature, could result in conversion of Farmland to non-agricultural use or conversion of
forest land to non-forest use?
No impact. No agricultural or forestry operations are located adjacent to or within the project vicinity. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site
revegetation; the project does not propose any land use or zoning changes. Implementation of the project would not involve any uses that would impede or otherwise alter agricultural or forestry operations. For this reason, project activities would not result in a direct or indirect conversion of existing or surrounding land uses into non-agricultural
use and would not impact the availability of forest resources. Therefore, the project would have no impact.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-5
2.3 AIR QUALITY
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
III. Air Quality.
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied on to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of people?
2.3.1 Environmental Setting
The project site is located in the San Francisco Bay Area Air Basin (SFBAAB) within the County of San Mateo. The SFBAAB is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). The existing air quality
conditions in the area are determined by such natural factors as topography, meteorology, and climate, in addition to the amount of emissions released by existing air pollutant sources.
CLIMATE AND TOPOGRAPHY
The climate of the SFBAAB is determined largely by a high-pressure system that is often present over the eastern
Pacific Ocean. High-pressure systems are characterized by an upper layer of dry air that warms as it descends, restricting the mobility of cooler marine-influenced air near the ground surface, resulting in subsidence inversions
restricting the dispersion of air masses. During summer and fall, locally generated emissions can, under the restraining influences of topography and subsidence inversions, cause conditions that are conducive to the formation of photochemical pollutants, such as ozone and secondary particulates (e.g., nitrates and sulfates). In the winter, the Pacific high-pressure system shifts southward, allowing storms to pass through the area (BAAQMD 2017a).
AMBIENT AIR QUALITY
Air Pollutants
As required by the federal Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) has identified National
Ambient Air Quality Standards (NAAQS) for six criteria air pollutants: ozone, carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), respirable and fine particulate matter (PM10 and PM2.5, which are particulate matter 10 microns or less in diameter and 2.5 microns or less in diameter, respectively), and lead. The State of California has also
established California Ambient Air Quality Standards (CAAQS) for these six pollutants as well as sulfates, hydrogen sulfide (H2S), vinyl chloride, and visibility reducing particles. NAAQS and CAAQS were established to protect the public
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-6 Redwood Cabin Removal Project Initial Study
from adverse health impacts caused by exposure to air pollution. A brief description of the criteria air pollutants and
their effects on health is provided in Table 2.3-1.
Table 2.3-1 Air Pollutants
Pollutant Sources Effects
Ozone Ozone is a secondary air pollutant produced in the atmosphere
through a complex series of photochemical reactions involving
reactive organic gases (ROG), also sometimes referred to as
volatile organic compounds by some regulating agencies) and
nitrogen oxides (NOX). The main sources of ROG and NOX, often
referred to as ozone precursors, are products of combustion
processes (including motor vehicle engines) and the evaporation
of solvents, paints, and fuels.
Ozone causes eye irritation, airway constriction, and
shortness of breath and can aggravate existing respiratory
diseases such as asthma, bronchitis, and emphysema.
Carbon
monoxide
CO is usually formed as the result of the incomplete combustion
of fuels. The single largest source of CO is motor vehicle
engines; the highest emissions occur during low travel speeds,
stop-and-go driving, cold starts, and hard acceleration.
Exposure to high concentrations of CO reduces the
oxygen-carrying capacity of the blood and can cause
headaches, nausea, dizziness, and fatigue; impair central
nervous system function; and induce angina (chest pain) in
persons with serious heart disease. Very high levels of CO
can be fatal.
Particulate
matter
Some sources of particulate matter, such as wood burning in
fireplaces, demolition, and construction activities, are more local
in nature, while others, such as vehicular traffic, have a more
regional effect.
Scientific studies have suggested links between fine
particulate matter and numerous health problems,
including asthma, bronchitis, and acute and chronic
respiratory symptoms, such as shortness of breath and
painful breathing. Recent studies have shown an
association between morbidity and mortality and daily
concentrations of particulate matter in the air.
Nitrogen
dioxide
NO2 is a reddish-brown gas that is a by-product of combustion
processes. Automobiles and industrial operations are the main
sources of NO2.
Aside from its contribution to ozone formation, NO2 can
increase the risk of acute and chronic respiratory disease
and reduce visibility.
Sulfur
dioxide
SO2 is a combustion product of sulfur or sulfur-containing fuels
such as coal and diesel. SO2 is also a precursor to the formation
of particulate matter, atmospheric sulfate, and atmospheric
sulfuric acid formation that could precipitate downwind as acid
rain.
Exposure can lead to the irritation of upper respiratory
tract and heighten asthma symptoms.
Lead Leaded gasoline, lead-based paint, smelters (metal refineries),
and the manufacture of lead storage batteries have been the
primary sources of lead released into the atmosphere, with lead
levels in the air decreasing substantially since leaded gasoline
was eliminated in the United States.
Lead has a range of adverse neurotoxic health effects.
Notes: CO = carbon monoxide; NO2 = nitrogen dioxide; NOX = oxides of nitrogen; ROG = reactive organic gases; SO2 = sulfur dioxide.
Sources: EPA 2018
Attainment Area Designations
The CAA and the California Clean Air Act (CCAA) require all areas of California to be classified as attainment, non-attainment, or unclassified as to their status relative to the NAAQS and CAAQS. Under the CAA and the CCAA, the
California Air Resources Board (CARB) designates portions of the state based on air quality monitoring data. Attainment statuses for San Mateo County are shown in Table 2.3-2. San Mateo County is designated as nonattainment for ozone, PM10, and PM2.5 with respect to the CAAQS and ozone and PM2.5 with respect to the NAAQS.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-7
Table 2.3-2 Attainment Status Designations for San Mateo County
Pollutant NAAQS CAAQS
Ozone Attainment (1-hour)1 Nonattainment (1-hour) Classification2 Nonattainment (8-hour)3 Classification – Marginal Nonattainment (8-hour) Nonattainment (8-hour)3 Classification – Marginal Nonattainment (24-hour)
Respirable particulate matter (PM10) Attainment (24-hour) Nonattainment (24-hour) Attainment (24-hour) Nonattainment (Annual)
Fine particulate matter (PM2.5) Nonattainment (24-hour) (No State Standard for 24-Hour) Nonattainment (Annual) Nonattainment (Annual)
Carbon monoxide (CO) Attainment (1-hour) Attainment (1-hour) Attainment (8-hour) Attainment (8-hour)
Nitrogen dioxide (NO2) Unclassified/Attainment (1-hour) Attainment (1-hour) Unclassified/Attainment (Annual) Attainment (Annual)
Sulfur dioxide (SO2)4 (Attainment) (1-Hour) Attainment (1-hour) Attainment (3-month rolling avg.) Attainment (24-hour)
Lead (Particulate) Attainment (3-month rolling avg.) Attainment (30-day average)
Hydrogen Sulfide Unclassified (1-hour)
Sulfates No Federal Standard Attainment (24-hour)
Visibly Reducing Particles Unclassified (8-hour)
Vinyl Chloride Unclassified (24-hour)
Notes: NAAQS = national ambient air quality standards; CAAQS = California ambient air quality standards
1 Air Quality meets federal 1-hour Ozone standard (77 FR 64036). EPA revoked this standard, but some associated requirements still apply.
2 Per Health and Safety Code Section 40921.5(c), the classification is based on 1989–1991 data, and therefore does not change.
3 2015 Standard.
4 2010 Standard.
Source: EPA 2019; CARB 2018
Air Quality Planning
The BAAQMD is responsible for ensuring that the federal and State ambient air quality standards are attained and maintained in the SFBAAB. The BAAQMD is also responsible for adopting and enforcing rules and regulations
concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions,
awarding grants to reduce motor vehicle emissions, conducting public education campaigns, as well as many other activities. BAAQMD updates its Clean Air Plan every three years to reflect progress in meeting the NAAQS and CAAQS and to incorporate new information regarding the feasibility of control measures and new emission inventory data. BAAQMD’s record of progress in implementing previous measures must also be reviewed. BAAQMD prepared these plans in cooperation with the Metropolitan Transportation Commission and the Association of Bay Area Governments.
On April 19, 2017, BAAQMD adopted the most recent revision to the Clean Air Plan, titled the 2017 Clean Air Plan: Spare the Air, Cool the Climate (BAAQMD 2017b). This plan serves to:
define a vision for transitioning the region to a post-carbon economy needed to achieve 2030 and 2050 greenhouse gas reduction targets;
decrease emissions of air pollutants most harmful to Bay Area residents, such as particulate matter, ozone, and
toxic air contaminants (TACs);
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-8 Redwood Cabin Removal Project Initial Study
reduce emissions of methane and other potent climate pollutants; and
decrease emissions of carbon dioxide by reducing fossil fuel combustion.
Projects located in the SFBAAB are subject to BAAQMD’s rules and regulations. Specific rules applicable to the project include:
Regulation 2, Rule 1, General Permit Requirements. Includes criteria for issuance or denial of permits, exemptions,
appeals against decisions of the Air Pollution Control Officer and BAAQMD actions on applications.
Regulation 6, Rule 1, General Requirements. Limits the quantity of particulate matter in the atmosphere by controlling emission rates, concentration, visible emissions and opacity.
Regulation 7, Odorous Substances. Regulation 7 places general limitations on odorous substances and specific emission limitations on certain odorous compounds. A person (or facility) must meet all limitations of this
regulation, but meeting such limitations shall not exempt such person from any other requirements of BAAQMD, state, or national law. The limitations of this regulation shall not be applicable until BAAQMD receives odor complaints from 10 or more complainants within a 90-day period, alleging that a person has caused odors
perceived at or beyond the property line of such person and deemed to be objectionable by the complainants in the normal course of their work, travel, or residence. When the limits of this regulation become effective, as a
result of citizen complaints described above, the limits shall remain effective until such time as no citizen complaints have been received by BAAQMD for 1 year. The limits of this Regulation shall become applicable again if BAAQMD receives odor complaints from five or more complainants within a 90-day period. BAAQMD staff investigate and track all odor complaints it receives and make attempts to visit the site and identify the source of the objectionable odor and assist the owner or facility in finding a way to reduce the odor.
TOXIC AIR CONTAMINANTS
TACs, or in federal parlance, hazardous air pollutants (HAPs), are a defined set of airborne pollutants that are known to pose a present or potential hazard to human health. A TAC is defined as an air pollutant that may cause or contribute to an increase in mortality or in serious illness, or that may pose a hazard to human health. TACs are usually present in
minute quantities in the ambient air, however, their high toxicity or health risk may pose a threat to public health even at low concentrations.
According to the 2013 Edition of the California Almanac of Emissions and Air Quality, health risks from TACs can largely be attributed to relatively few compounds, the most important being diesel PM (CARB 2013:5-2 to 5-4). Diesel PM differs from other TACs in that it is not a single substance, but rather a complex mixture of hundreds of substances. Although diesel PM is emitted by diesel-fueled internal combustion engines, the composition of the emissions varies depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emissions control
system is being used. Unlike other TACs, no ambient monitoring data are available for diesel PM because no routine measurement method currently exists. However, CARB has made preliminary concentration estimates based on a PM exposure method. This method uses the CARB emissions inventory’s PM10 database, ambient PM10 monitoring data, and the results from several studies to estimate concentrations of diesel PM. In addition to diesel PM, the TACs for which data are available that pose the greatest existing ambient risk in California are benzene, 1,3-butadiene,
acetaldehyde, carbon tetrachloride, hexavalent chromium, para-dichlorobenzene, formaldehyde, methylene chloride, and perchloroethylene. However, diesel PM poses the greatest health risk among the ten TACs mentioned. Overall,
levels of most TACs, except para-dichlorobenzene and formaldehyde, have decreased since 1990 (CARB 2013).
ODORS
Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory
effects, nausea, vomiting, and headache). Odor sources of concern include wastewater treatment plants, sanitary landfills, composting facilities, recycling facilities, petroleum refineries, chemical manufacturing plants, painting
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-9
operations, rendering plants, and food packaging plants (BAAQMD 2017a). None of these odorous land uses are
within proximity to the project site.
SENSITIVE RECEPTORS
Sensitive receptors are generally considered to include those land uses where exposure to pollutants could result in health-related risks to sensitive individuals, such as children or the elderly. Residences, schools and school yards, parks
and playgrounds, daycare centers, nursing homes, and medical facilities are of primary concern because of the presence of individuals particularly sensitive to pollutants and/or the potential for increased and prolonged exposure
of individuals to pollutants.
The closest sensitive receptors are the private residences off Highway 35. The closest residence is located approximately 840 feet north of the project boundary.
BAAQMD Thresholds
The BAAQMD’s significance thresholds in the May 2017 CEQA Air Quality Guidelines for a project-level analysis are the most appropriate thresholds for use in determining air quality impacts of the proposed project. Table 2.3-3 presents
the significance thresholds for construction and operations-related criteria air pollutant and precursor emissions used for this analysis. These thresholds were developed by BAAQMD to achieve and maintain the NAAQS and CAAQS,
which are standards intended to protect the public health. The thresholds represent the levels at which a project’s individual emissions of criteria air pollutants or precursors would result in a cumulatively considerable contribution to the SFBAAB’s existing nonattainment air quality conditions.
Table 2.3-3 BAAQMD Air Quality Significance Thresholds
Pollutant Construction Average Daily
Emissions (lb/day)
Operational Average Daily
Emissions (lb/day)
Operational Maximum Annual
Emissions (typ)
Reactive Organic Compounds (ROG) 54 54 10
Oxides of Nitrogen (NOX) 54 54 10
Respirable Particulate Matter (PM10) 82 (Exhaust) 82 15
Fine Particulate Matter (PM2.5) 54 (Exhaust) 54 10
Notes: tpy = tons per year; lb/day = pounds per day. PM10 and PM2.5 fugitive dust emissions require implementation of best management practices (BMPs).
Source: BAAQMD 2017a
BAAQMD has not adopted quantitative thresholds for fugitive dust emissions during construction. Instead, the BAAQMD recommends best management practices (BMPs) be implemented to reduce fugitive dust emissions. The 2012 La Honda Creek Open Space Preserve Master Plan EIR requires projects to implement BMPs consistent with the
BAAQMD Basic Construction Mitigation Measures. These measures would be part of the standards condition of approval for project construction.
BAAQMD has established the following Thresholds of Significance for local community risks and hazards associated with TACs and PM2.5 for assessing individual source impacts at a local level. Impacts would be significant if:
The project would result in an increased cancer risk of > 10 in one-millions
The project would result in an increased non-cancer (i.e., Chronic or Acute) risk of > 1.0 Hazard Index
The project would result in an ambient PM2.5 concentration increase of > 0.3 micrograms per cubic meters (µg/m3)
annual average
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-10 Redwood Cabin Removal Project Initial Study
A project would be considered to have a cumulatively considerable impact if the aggregate total of current and
proposed TAC sources within a 1,000 feet radius of the project fence-line in addition to the project would exceed the Cumulative Thresholds of Significance. Thresholds would be exceeded if:
The project would result in an increased cancer risk of > 100 in one million
The project would result in an increased non-cancer (i.e., Chronic or Acute) risk of > 10 Hazard Index
The project would result in an ambient PM2.5 concentration increase of > 0.8 µg/m3 annual average
Excess cancer risks are defined as those occurring in excess of or above and beyond those risks that would normally be associated with a location or activity if toxic pollutants were not present. Non-carcinogenic health effects are
expressed as a hazard index, which is the ratio of expected exposure levels to an acceptable reference exposure level.
The BAAQMD provides minimum distances for siting of new odor sources in Table 3-3 of their CEQA Guidelines document. The odor screening distances in Table 3-3 of the BAAQMD CEQA Guidelines should not be used as
absolute screening criteria, rather as information to consider along with the odor parameters and complaint history. BAAQMD does not provide guidance or recommendations to assess odors from construction activities, thus these
odors are discussed qualitatively for informational purposes.
2.3.2 Discussion
a) Conflict with or obstruct implementation of the applicable air quality plan?
Less-than-significant impact. The emission inventories used to develop a region’s air quality attainment plans are based primarily on projected population growth and vehicle miles traveled (VMT) for the region that are determined, in part, based on the planned growth identified in regional and community plans. Therefore, projects that would result
in population or employment growth beyond that projected in regional or community plans could result in increases in VMT and overall emissions above that planned in the attainment plan, further resulting in emissions that could conflict with a region’s air quality planning efforts. Increases in VMT and emissions beyond that projected in the air quality attainment plans generally would be considered to have a significant adverse incremental effect on the region’s ability to attain or maintain the CAAQS and NAAQS.
The project involves the demolition of a vacant cabin and would not result in any new long-term employment opportunities or new housing, and it would not change the amount of development projected in the SFBAAB.
Therefore, it would be consistent with the population growth and VMT projections used in BAAQMD’s 2017 Clean Air Plan. Also, as discussed below under criterion (b), the project would not result in any short-term construction
emissions or new stationary sources of emissions that would result in a significant impact. Thus, implementation of the project would not conflict with or obstruct implementation of the BAAQMD 2017 Clean Air Plan and the impact would be less than significant.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which
the project region is non-attainment under an applicable federal or state ambient air
quality standard?
Less than significant with mitigation incorporated. Under a project level analysis, the BAAQMD CEQA Guidelines
identify whether a project would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard through average pounds per day significance thresholds. The project level thresholds were developed to bring the SFBAAB into
attainment for the NAAQS and CAAQS and to be protective of human health.
Project construction would involve demolition and recontouring that have the potential to generate air pollutant
emissions. Project activities may also include soil decompaction and revegetation, as described in Section 2.4.2 of Chapter 2, “Project Description,” of the accompanying EIR. Construction emissions were modeled using the California Emissions Estimator Model (CalEEMod) Version 2020.4.0 computer program (CAPCOA 2021). Attachment A includes
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-11
modeling inputs and parameters used for this analysis. Table 2.3-4 summarizes the estimated average daily emissions of
ROG, NOX, PM10 (exhaust) and PM2.5 (exhaust) during project construction. As shown in Table 3.3-4, project construction emissions for all criteria pollutants would be below the BAAQMD average daily thresholds of significance. It should be
noted that this project only requires the demolition and recontouring of the site, thus, no operational emissions were evaluated. To reduce operational fugitive dust and help with erosion control the project would spread native grass seed mix in the disturbed areas and weed free or native grass straw would be placed on the disturbed areas.
Table 2.3-4 Summary of Average Daily Pounds Per Day Construction Emissions of Criteria Pollutants and Precursor Emissions
Emissions Source ROG NOx CO PM10 PM2.5 SOX
2023 1 10 12 <1 <1 <1
Average Daily Emissions 1 10 12 <1 <1 <1
BAAQMD Emissions Threshold 54 54 N/A 821 541 N/A
Notes: CO = Carbon Monoxide; ROG = Reactive Organic Gases; NOx = Oxides of Nitrogen; PM10 = Particulate matter 10 micrometers or less in
diameter; PM2.5 = Particulate matter 2.5 micrometers or less in diameter; SOX = Sulfur Dioxide.
1 Exhaust emissions only
Source: Ascent Environmental, Inc. 2021
Fugitive Dust Emissions The construction activities of demolition and recontouring would result in fugitive dust emissions from soil movement and equipment use. For all proposed projects, BAAQMD recommends the implementation of all BMPs, whether or not
construction-related emissions exceed applicable thresholds of significance. To satisfy this requirement and to reduce emissions from construction-related sources, the project would implement environmental protection guideline (EPG)
AQ-1, Minimize Air Pollutant Emissions, as outlined in Chapter 2, “Project Description” of the accompanying EIR. While EPG AQ-1 contains many of the BMPs required by BAAQMD, such as watering exposed surfaces twice daily and covering haul trucks, not all BMPs are provided in EPG AQ-1. Therefore, this impact would be potentially significant.
The project would implement BMP AQ-1, as described in Section 2.7.3, “Project Specific BMPs” of Chapter 2, “Project Description” of the accompanying EIR. With the implementation of project-specific BMP AQ-1, which contains BMPs required by BAAQMD but not provided in EPG AQ-1, the project would be consistent with the BPMs required by BAAQMD and reduce emissions from construction activities. This impact would be less than significant with mitigation.
c) Expose sensitive receptors to substantial pollutant concentrations?
Less-than-significant impact. As discussed previously, sensitive receptors are generally considered to include those land uses where exposure to pollutants could result in health-related risks to sensitive individuals, such as children or the elderly. The closest sensitive receptor is a residence off Highway 35, located approximately 840 feet north of the
project boundary.
The potential cancer risk from inhaling diesel PM outweighs the potential for all other diesel PM–related health
impacts (i.e., non-cancer chronic risk, short-term acute risk) and health impacts from other TACs (CARB 2003:K-1). With regard to exposure to diesel PM, the dose to which receptors are exposed is the primary factor used to determine health risk. Dose is a function of the concentration of a substance or substances in the environment and the duration
of exposure to the substance. Dose is positively correlated with time, meaning that a longer exposure period would result in a higher level of health risk for any exposed receptor. Thus, the risks estimated for an exposed individual are higher if a fixed exposure occurs over a longer period. According to the Office of Environmental Health Hazard Assessment (OEHHA), when a health risk assessment is prepared to project the results of exposure of sensitive receptors to selected compounds, exposure of sensitive receptors to TAC emissions should be based on a 70- or 30-year exposure period, however, such assessments should be limited to the duration of activities associated with the proposed project if emissions occur for shorter periods (OEHHA 2015:5-23, 5-24).
Construction-related activities would result in temporary, intermittent emissions of diesel PM from the exhaust of off-road, heavy-duty diesel equipment. Construction activities would occur at a minimum of 840 feet away from the
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-12 Redwood Cabin Removal Project Initial Study
nearest sensitive receptor. On-road diesel-powered haul trucks traveling to and from the construction area to deliver
materials and equipment are also a source of diesel PM, however, their operations would be dispersed throughout the roadway network in the plan area, and they would not operate at any one location for extended periods of time such
that they would expose a single receptor to excessive diesel PM emissions.
The results of emissions modeling show that average daily emissions of exhaust PM2.5, of which diesel PM is a subset, would not exceed 1 lb/day during construction. Additionally, movement of haul trucks would occur near a sensitive
receptor intermittently over a 10-week period.
Considering the highly dispersive properties of diesel PM, the relatively low mass of diesel PM emissions that would be
generated at any single place during project construction, the relatively short period during which diesel PM–emitting construction activities would take place, and the fact that the nearest sensitive receptor (occupied residence) is 840 feet away, construction-related TACs would not expose sensitive receptors to an incremental increase in cancer risk
that exceeds 10 in one million or a Health Index greater or equal to 1.0. As a result, this impact would be less than significant.
d) Result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people?
Less-than-significant impact. The proposed project is the demolition of a vacant cabin and would not result in the introduction of any new permanent sources of odors to the area. Because construction-related odors would be
intermittent, temporary, and would disperse rapidly with distance from the source, construction-related odors would not result in the frequent exposure of a substantial number of individuals to objectionable odors. Short-term exposure
to odorous emissions would therefore be considered less than significant. For these reasons, odorous emissions generated during construction under the project would also be less than significant.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-13
2.4 BIOLOGICAL RESOURCES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IV. Biological Resources.
Would the project:
a) Have a substantial adverse effect, either directly or
through habitat modifications, on any species identified as a candidate, sensitive, or special-status
species in local or regional plans, policies, or regulations, or by the California Department of Fish
and Wildlife or the U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, or regulations or by the California Department of Fish
and Wildlife or the U.S. Fish and Wildlife Service?
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other
means?
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or
with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery
sites?
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state
habitat conservation plan?
2.4.1 Environmental Setting
A Botanical Resources Survey Report was prepared in November 2020 for an area encompassing the project site. Findings of the Botanical Resources Survey Report indicate that the project site encompasses a single plant community, a North Coast Coniferous Forest. The understory of the forest features a mix of native and introduced
plants, including a number of invasive species. The underlying shrub and vine layer consists largely of native California blackberry (Rubus ursinus), California hazelnut (Corylus cornuta), and blood current (Ribes sanguineum). Invasive French broom, English ivy, and vinca were found primarily along historically graded or otherwise disturbed areas. Thimbleberry (Rubus parviflorus) is fairly common along the margins of La Honda Creek, and western burning bush (Euonymus occidentalis var. occidentalis) is a reflection of the relatively high level of moisture even in upland habitats—the species is known only from coastal and montane habitats and does not occur south of Santa Cruz County. As with
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-14 Redwood Cabin Removal Project Initial Study
the shrub/vine stratum, the most common herbs observed in this habitat are primarily those well adapted to the deep
shade of the tree canopy. Most of them typically feature broad or highly dissected leaves that spread out parallel to the forest floor, allowing for maximum absorption of the briefly available stippled sun. The only widespread introduced
plant was broadleaved forget-me-not (Myosotis latifolia), which was observed primarily along the access road and leveled areas. Herbaceous plants that were found only below or along the banks of La Honda Creek include giant chain fern (Woodwardia fimbriata), sedges (e.g., Carex amplifolia and C. bolanderi), and giant horsetail (Equisetum
telmateia). Such wetland plants were relatively sparse as a result of the generally steep stream banks and limited floodplain as well as the paucity of sunlight and the high cover of cobbles and boulders within the stream. (Vollmar
Natural Lands Consulting 2020).
A Marbled Murrelet Habitat Assessment and Management Recommendations Report was prepared for Midpen in 2007. Findings of the report indicate that Marbled Murrelet (Brachyramphus marmoratus), a seabird listed as federally-
threatened under the Federal Endangered Species Act, may nest in coniferous forests on Midpen lands (H.T. Harvey and Associates 2007). Additionally, a report on sensitive amphibian and reptiles was prepared for Midpen in 2007. The
report concluded that California red-legged frog (Rana aurora draytonii) and western pond turtle (Emys marmorata) were present within Midpen preserves. Further, though San Francisco garter snake was not observed during the surveys, the report indicated that the possibility of San Francisco garter snake occurrence cannot be ruled out due to the presence of appropriate habitat within Midpen’s property (Richard Seymour and Associates 2007).
No signs of roosting bats were detected during a 2019 biological survey of the Redwood Cabin, however, four dusky-
footed woodrat nest structures were observed inside the structure. Although no bats were observed emerging from the Redwood Cabin, acoustic recordings identified fringed myotis (Myotis thysanodes) foraging calls in the vicinity
(Swaim 2019).
La Honda Creek, a semi-perennial stream that supports some wetland habitat as well as open water, is located directly north of the project site (Vollmar Natural Lands Consulting 2020).
2.4.2 Discussion
a) Have a substantial adverse effect, either directly or through habitat modifications, on
any species identified as a candidate, sensitive, or special-status species in local or
regional plans, policies, or regulations, or by the California Department of Fish and
Wildlife or the U.S. Fish and Wildlife Service?
Less than significant with mitigation incorporated. The project area has the potential to support sensitive species. As such, project activities could result in substantial adverse effect to candidate, sensitive, or special-status species within the project vicinity. Midpen has adopted standard mitigation measures as part of the Preserve Master Plan and its
various land management program, which continue to be used onsite to reduce impacts to candidate, sensitive, or special-status species to a less than significant level. Therefore, these impacts would be less than significant with
mitigation incorporated and will be discussed further in the Biological Resources section of the EIR.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, or regulations or by the
California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
Less than significant with mitigation incorporated. The project area has the potential to support sensitive natural
communities. As such, project activities could result in substantial adverse effect to riparian habitat and sensitive communities within the project vicinity. Midpen has previously adopted standard mitigation measures as part of the
Preserve Master Plan and its various land management programs that will reduce impacts to riparian habitat and sensitive communities within the project vicinity to a less than significant level. These impacts would be less than significant with mitigation incorporated and will be discussed further in the Biological Resources section of the EIR.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-15
c) Have a substantial adverse effect on state or federally protected wetlands (including,
but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
Less than significant with mitigation incorporated. As described above, La Honda Creek, which supports wetland
habitat as well as open water, is located directly north of the project site. As such, project activities could result in substantial adverse effect to federally protected wetlands. Midpen has adopted standard mitigation measures as part
of the Preserve Master Plan and its various land management program, which continue to be used onsite that will reduce impacts to federally protected wetlands to a less than significant level. Therefore, these impacts would be less than significant with mitigation incorporated and will be discussed further in the Biological Resources section of the EIR.
d) Interfere substantially with the movement of any native resident or migratory fish or
wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
Less than significant with mitigation incorporated. The project area has the potential to support migratory wildlife species. As such, project activities could result in interference with wildlife species within the project vicinity. Midpen has adopted standard mitigation measures as part of the Preserve Master Plan and its various land management
program, which continue to be used onsite that will reduce interference with wildlife species within the project vicinity to a less than significant level. Therefore, these impacts would be less than significant with mitigation incorporated and
will be discussed further in the Biological Resources section of the EIR.
e) Conflict with any local policies or ordinances protecting biological resources, such as a
tree preservation policy or ordinance?
No impact. Implementation of the project would comply with existing policies and ordinances related to the protection
of biological resources. Further, the project would not involve any tree removal, such that conflicts related to tree preservation would occur. As such, no impact would occur and no mitigation is required.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
No impact. The project site is not within an area designated under a habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. Therefore, the proposed
project would have no impact on adopted habitat conservation plans and no mitigation is required.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-16 Redwood Cabin Removal Project Initial Study
2.5 CULTURAL RESOURCES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
V. Cultural Resources.
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to Section 15064.5?
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
c) Substantially disturb human remains, including those interred outside of formal cemeteries?
2.5.1 Environmental Setting
As described in Chapter 2, “Project Description,” of the accompanying EIR, the Historic Resource Evaluation prepared by Page & Turnbull, Inc. in 2020 determined that the Redwood Cabin is a historical resource per CEQA because it
appears to be eligible for listing in the CRHR. CRHR eligibility was determined for the Redwood Cabin because it appears to be one of few remaining examples of a permanent recreational cabin from the 1920s with a high degree of
integrity and is representative of the peak of recreational development in the Santa Cruz Mountains in the nineteenth century (CRHR Criterion 1); and is a unique example of a rustic recreational cabin in the surrounding area (CRHR Criterion 3) (Page & Turnbull 2020).
A cultural resources literature search was conducted in July 2021 by the Central California Information Center (NWIC) of the California Historical Resources Information System (CHRIS) at Sonoma State University. The records search was
conducted to determine if prehistoric or historic cultural resources had been previously recorded within the project site, the extent to which the project site had been previously surveyed, and the number and type of cultural resources within a 0.25-mile radius of the project area. The NWIC records search indicated that no resources were located within the project area or within a 0.25-mile radius of the project area.
2.5.2 Discussion
a) Cause a substantial adverse change in the significance of a historical resource pursuant
to Section 15064.5?
Potentially significant impact. Because the Redwood Cabin is considered eligible for listing in the CRHR and is therefore considered a resource under CEQA, impacts related to the project could be potentially significant. This issue
will be analyzed further in the EIR.
b) Cause a substantial adverse change in the significance of an archaeological resource
pursuant to Section 15064.5?
Potentially significant impact. Ground-disturbing activities could damage previously unrecorded archaeological
resources. This would be a potentially significant impact. This issue will be analyzed further in the EIR.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-17
c) Substantially disturb human remains, including those interred outside of formal
cemeteries?
Less-than-significant impact. No human remains have been found previously on the project site. However, the
potential for human remains to occur below the ground surface in the project area is currently unknown. Implementation of the project would involve soil disturbance during construction, which could result in impacts on any
interred on-site human remains.
California law recognizes the need to protect Native American human burials, skeletal remains, and items associated
with Native American burials from vandalism and inadvertent destruction. The procedures for the treatment of Native American human remains are contained in California Health and Safety Code Sections 7050.5 and PRC Section 5097.
These statutes require that, if human remains are discovered during any construction activities, potentially damaging
ground-disturbing activities in the area of the remains shall be halted immediately, and the San Mateo County coroner and Native American Heritage Commission (NAHC) shall be notified immediately, in accordance with to PRC Section 5097.98 and Section 7050.5 of California’s Health and Safety Code. If the remains are determined by NAHC to be Native American, the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. Following the coroner’s findings, the archaeologist, the NAHC-designated Most Likely Descendant, and the landowner shall determine
the ultimate treatment and disposition of the remains and take appropriate steps to ensure that additional human interments are not disturbed. The responsibilities for acting upon notification of a discovery of Native American human
remains are identified in PRC Section 5097.94.
Compliance with California Health and Safety Code Sections 7050.5 and PRC Section 5097 would provide an opportunity to avoid or minimize the disturbance of human remains, and to appropriately treat any remains that are discovered. Therefore, this impact would be less than significant, and no mitigation is required.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-18 Redwood Cabin Removal Project Initial Study
2.6 ENERGY
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VI. Energy.
Would the project:
a) Result in potentially significant environmental impact
due to wasteful, inefficient, or unnecessary consumption of energy resources, during project
construction or operation?
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
2.6.1 Environmental Setting
California relies on a regional power system composed of a diverse mix of natural gas, petroleum, renewable,
hydroelectric, and nuclear generation resources:
Natural gas: Almost two-thirds of California households use natural gas for home heating, and about half of
California’s utility-scale net electricity generation is fueled by natural gas (U.S. Energy Information Administration [EIA] 2021).
Petroleum: Petroleum products (gasoline, diesel, jet fuel), which are consumed almost exclusively by the
transportation sector, account for almost 99 percent of the energy used in California by the transportation sector, with the rest provided by ethanol, natural gas, and electricity (Bureau of Transportation Statistics 2017). Gasoline
and diesel fuel sold in California for motor vehicles is refined in California to meet specific formulations required by the California Air Resources Board (CARB) (EIA 2021).
Electricity and renewables: The California Energy Commission (CEC) estimates that 34 percent of California’s retail electricity sales in 2018 were provided by Renewables Portfolio Standard (RPS)-eligible renewable resources (EIA 2021).
Alternative fuels: Conventional gasoline and diesel may be replaced (depending on the capability of the vehicle) with many alternative transportation fuels (e.g., biodiesel, hydrogen, electricity). Use of alternative fuels is encouraged
through various statewide regulations and plans (e.g., Low Carbon Fuel Standard, California’s 2017 Climate Change Scoping Plan [2017 Scoping Plan]).
The project would not require use of natural gas or electricity because the project would only require demolition and
recontouring of the site.
San Mateo County adopted an Energy Efficiency Climate Action Plan (EECAP) in June 2013 to align with the State’s
GHG emission reductions set by Assembly Bill 32 of a 15 percent reduction below 1990 levels by 2020. The EECAP established the goals of achieving a 17 percent reduction in GHG emissions from 2005 levels by 2020. To reach its goals, the EECAP established several GHG reduction measures that would reduce the county’s overall energy use from both residential and nonresidential sources through increasing efficiency. The EECAP includes Measure 15.1 which is specific to this project’s construction activities by minimizing idling times from equipment and utilizing cleaner fuels.
In October 2018, Midpen adopted a Climate Action Plan (CAP) to reduce its operational GHG emissions 20 percent by 2022, 40 percent by 2030, and 80 percent by 2050 from 2016 levels to be in line with State GHG emission reduction goals. To reach its goals, the CAP advises Midpen to reduce emissions from its vehicle fleets, equipment, and business-related travel, employee commutes, buildings and facilities, and adoption of renewable electricity by its residences. In
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-19
addition to these strategies, Midpen proposes to reduce or offset livestock emissions, enhance carbon sequestration,
reduce visitor transportation emissions, and increase staff and visitor awareness and action on climate change.
2.6.2 Discussion
a) Result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or
operation?
Less-than-significant impact. Energy would be required to operate and maintain construction equipment and transport construction materials. The one-time energy expenditure required for demolition associated with the project
would be nonrecoverable. Most energy consumption would result from operation of off-road construction equipment and on-road vehicle trips associated with commutes by construction workers and haul trucks trips. It should be noted that the demolition material may contain hazardous material. Although it is possible that some of the historical
materials from the cabin would be salvaged, for a conservative estimate, it is assumed that all material would be disposed at the Kettleman Hills Landfill located approximately 180 miles from the project site. See Attachment B for modeling inputs and parameters. An estimated 207 gallons of gasoline and 2,327 gallons of diesel fuel would be used during construction of the project (see Attachment B).
The energy needs for project construction would be temporary and are not anticipated to require additional capacity
or substantially increase peak or base period demands for electricity and other forms of energy. Associated energy consumption would be typical of that associated with demolition projects of this size in a rural setting. Automotive
fuels would be consumed to transport people and materials to and from the project site. There is no atypical construction-related energy demand associated with the proposed project. Non-renewable energy would not be consumed in a wasteful, inefficient or unnecessary manner when compared to other construction activity in the region. This impact would be less than significant.
b) Conflict with or obstruct a state or local plan for renewable energy or energy
efficiency
Less than significant. Because the proposed project would only include demolition, site recontouring, and possible soil decompaction and revegetation, it would only require fuel use from construction equipment and commutes from workers and haul trucks. The proposed removal of the cabin would remove any potential future energy use of the site.
The energy use associated with the project would be subject to BAAQMD’s requirements, the County’s EECAP, and Midpen’s CAP. As discussed in Section 2.3, “Air Quality,” while EPG AQ-1 contains many of the BMPs required by BAAQMD, not all BMPs are provided in EPG AQ-1. Therefore, Midpen would adhere to project-specific BMP AQ-1, as described in Section 2.7.3, “Project Specific BMPs,” of Chapter 2, “Project Description,” of the accompanying EIR.
Project-specific BMP AQ-1 would minimize equipment idling times and requires all equipment to be properly tuned to
meet manufacturer specifications as advised by BAAQMD’s CEQA Guidelines. BMP AQ-1 would ensure that the project would also be consistent with the County’s EECAP which requires minimization of idling to no more than five minutes.
In addition, off- and on-road vehicles would be subject to State and federal regulations regarding fuel efficiency standards for vehicles which would not conflict with the vehicle emission reduction provided in the Midpen CAP. Therefore, the project would not conflict with or obstruct plans for renewable energy or energy efficiency. This impact would be less than significant.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-20 Redwood Cabin Removal Project Initial Study
2.7 GEOLOGY AND SOILS
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VII. Geology and Soils.
Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a known fault? (Refer to California Geological Survey
Special Publication 42.)
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of topsoil?
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated),
creating substantial direct or indirect risks to life or property?
e) Have soils incapable of adequately supporting the use
of septic tanks or alternative waste water disposal systems where sewers are not available for the
disposal of waste water?
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
2.7.1 Environmental Setting
A geotechnical investigation was prepared by Romig Engineers in August 2019. The investigation determined that the
Preserve is not included in current Alquist-Priolo fault zone maps, however, noted that the Preserve is located within a seismically active region of the San Andreas Fault System, and that the La Honda Fault bisects the preserve, but is not
within or adjacent to the project site. The San Andreas Fault is located to the northeast of the Preserve, approximately 2 miles from the project site, and that no faults are mapped within or adjacent to the project site. The report determined that the potential for fault-related ground rupture at the project site was low, but that the project site
would “undoubtably” experience strong ground shaking during a seismic event (Romig 2019:6).
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-21
The report noted that the project site is located in an area that is potentially susceptible to “Earthquake-Induced
Landslides” per the State Seismic Hazards Map of the Woodside Quadrangle, and that the topography of the project vicinity indicates previous “movement of material in the downslope direction”, but that landslides were not observed
within approximately 50 feet from the cabin (Romig 2019:4-5). The investigation determined that soils present at and around the project site revealed that soils at the site consisted of “stiff” sandy clay with moderate to low potential for expansion. Groundwater was not encountered during the investigation, however, groundwater levels were assumed to
vary with season, drainage, and precipitation levels.
2.7.2 Discussion
a) Directly or indirectly cause potential substantial adverse effects, including the risk of
loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on
other substantial evidence of a known fault? (Refer to California Geological Survey
Special Publication 42.)
Less-than-significant impact. The project site is located within a seismically active region. The nearest fault line to the project site is the San Andreas Fault, which runs approximately north-south and is located approximately two miles
east of the project site and the Preserve. The geotechnical report prepared for the project site determined that the potential for fault-related ground rupture at or adjacent to the project site was low.
The existing character of the project site and surrounding areas are remote and rural. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation.
The project would not place development such as homes, commercial facilities, or other structures or land uses that could increase the potential for fault rupture or otherwise result in harm, loss, injury, or death in the event of fault rupture.
Since potential for fault rupture at the site was determined to be low, and project activities would not result in development on the site, the project would therefore not substantially increase risk of loss, injury, or death resulting
from fault rupture on the project site. This impact would be less than significant.
ii) Strong seismic ground shaking?
Less-than-significant impact. The project site is located within a seismically active region. The geotechnical investigation conducted for the project determined that the project site may be subject to strong ground shaking in the event of a
nearby seismic event. However, project activities would not result in development on the site, and the project would therefore not substantially increase the potential for seismic ground shaking or otherwise increase the risk of loss, injury,
or death resulting from seismic shaking on the project site. This impact would be less than significant.
iii) Seismic-related ground failure, including liquefaction?
Less-than-significant impact. The project site is located within a seismically active region. The geotechnical
investigation conducted for the proposed project determined that the project site may be subject to strong ground shaking in the event of a nearby seismic event.
Factors such as groundwater level, soil type, and shaking potential can affect the potential of a site to experience
ground failure such as liquefaction. Groundwater was not encountered at the project site during the time of the investigation; however, the geotechnical report mentioned that groundwater and soil water levels would likely vary by
season and precipitation (Romig 2019:4). The potential for soils at the site to undergo liquefaction was not determined by the soil report. However, given the potential for strong shaking at the site, variable topography, seasonally varying
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-22 Redwood Cabin Removal Project Initial Study
water levels, and evidence of material movement at the project site, the possibility of seismic related ground failure
such as liquefaction does exist.
Project activities would not result in development on the site, and the project would therefore not substantially
increase liquefaction potential or potential for other types of seismic-related ground failure. The project would not otherwise increase risk of loss, injury, or death resulting from ground failure on the project site in the event of a seismic event. This impact would be less than significant.
iv) Landslides?
Less-than-significant impact. The geotechnical investigation found evidence of landslides and downslope movement in vicinity of the project site. The existing character of the project site and surrounding areas are remote and rural.
Besides the Redwood Cabin and associated features, the project site does not contain additional structures, residences, or other development. The site is not accessible to the public.
Project activities would not result in new development on the site. Therefore, the project would not substantially increase landslide potential or otherwise increase the risk of loss, injury, or death resulting from landslides on the project site. This impact would be less than significant.
b) Result in substantial soil erosion or the loss of topsoil?
Less-than-significant impact. Demolition of the Redwood Cabin, construction staging, and waste removal, would result in some disturbance of topsoil on the site. Removal of the wooden posts supporting the Redwood Cabin may require
excavation of 2 to 5 feet. After demolition of the Cabin, disturbed areas under the structure would be graded and recontoured as necessary to ensure adequate erosion control and site drainage. All demolition and graded areas
would be compacted to 75 percent relative compaction. Native grass seed mix would be spread in the disturbed areas, and weed free or native grass straw would be placed in the disturbed areas, on top of the native grass seed mix, to assist with soil stabilization and erosion control. Any wood chips or mulch generated from unsalvageable building
materials may also be used to stabilize disturbed areas.
Site recontouring and revegetation would reduce the potential for erosion at the site that may result from project
activities. After completion of demolition, recontouring, and revegetation, the project would not involve any additional operation or maintenance activities at the site. The project site would remain closed off from public access. Due to the limited nature of soil disturbance at the project site, and site recontouring and revegetation activities that would occur,
the project would not result in substantial erosion of topsoil, and this impact would be less than significant.
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as
a result of the project, and potentially result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction, or collapse?
Less-than-significant impact. According to the geotechnical investigation and report prepared, the project site may be
subject to strong shaking and ground movement such as landslides during a seismic event (Rowig 2019:6, 8). However, the project consists of demolition and revegetation activities, and would not place additional structures, development,
or land uses on the project site. After completion of demolition, recontouring, and revegetation, the project would not involve any additional operation or maintenance activities at the site. The project site would remain closed to public access. Therefore, this impact would be less than significant.
D) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code
(1994, as updated), creating substantial direct or indirect risks to life or property?
Less-than-significant impact. The geotechnical report prepared for the project indicated that soil on the project site
had a low to moderate potential for expansion (Romig 2019: 3). Project activities would remove an existing structure on the project site and would not result in additional development on the project site that could increase risk of damage from expansive soils. Therefore, this impact would be less than significant.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-23
e) Have soils incapable of adequately supporting the use of septic tanks or alternative
waste water disposal systems where sewers are not available for the disposal of waste
water?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. The suitability of the soils at the project sit for septic tanks was not evaluated, however, the project does not propose addition of septic tanks and would not result in development that may
generate wastewater requiring septic tanks.
f) Directly or indirectly destroy a unique paleontological resource or site or unique
geologic feature?
Less-than-significant impact. The University of California Museum of Paleontology Specimen Data search reflected that
there are 1,696 known records of paleontological specimens within San Mateo County (UCMP 2021). Most of the specimens listed were microfossils, and were found in areas of the County outside the Preserve, such as Moss Beach,
San Bruno, and Oil Creek, which are approximately 14 miles northwest, 20 miles northeast, and 10 miles southwest of the project site, respectively. No unique geologic features are identified within the project area. While no known paleontological resources are known to occur within ¼ miles of the project site, potential for unexpected discovery of
paleontological exists.
Demolition of the Redwood Cabin, construction staging, and waste removal, would result in some ground disturbance
at the project site. In order to remove the wooden posts that support the Redwood Cabin structure, excavation of up to 2-5 feet would be required. As excavation would occur in areas of the project site which have already been
disturbed, the potential for encounter of paleontological material is low.
However, in the event of that unanticipated paleontological resources are encountered during construction, Midpen and the construction contractor would implement EPG CUL-1, Protocol for Unexpected Discovery of Archaeological and Paleontological Cultural Materials as described in Chapter 2, “Project Description” of the accompanying EIR and as originally outlined in the La Honda Creek Open Space Preserve Master Plan. CUL-2 includes steps such as stopping work within 30 feet of the discovery, notifying a qualified professional, and implementing methods to protect the resources (such as fencing) until the significance of the resources is determined and a treatment plan can be identified and implemented.
Potential for encounter of paleontological material at the project site is low, given that excavation would be limited to previously disturbed areas of the project site, However, if paleontological materials are discovered, implementation of CUL-2 would minimize impacts. Therefore, the project would have a less-than-significant impact.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-24 Redwood Cabin Removal Project Initial Study
2.8 GREENHOUSE GAS EMISSIONS
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VIII. Greenhouse Gas Emissions.
Would the project:
a) Generate greenhouse gas emissions, either directly or
indirectly, that may have a significant impact on the environment?
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
2.8.1 Environmental Setting
Certain gases in the earth’s atmosphere, classified as greenhouse gases (GHGs), play a critical role in determining the
earth’s surface temperature. Solar radiation enters the earth’s atmosphere from space. Most solar radiation passes through GHGs, however, infrared radiation is absorbed by these gases. As a result, radiation that otherwise would have
escaped back into space is instead “trapped,” resulting in a warming of the atmosphere. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate on earth.
Prominent GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
hydrofluorocarbons (HFC), perfluorocarbons (PFC), and sulfur hexafluoride (SF6). GHG emissions contributing to global climate change are attributable, in large part, to human activities associated with on-road and off-road transportation,
industrial/manufacturing, electricity generation by utilities and consumption by end users, residential and commercial on-site fuel usage, and agriculture and forestry. It is “extremely likely” that more than half of the observed increase in
global average surface temperature from 1951 to 2010 was caused by the anthropogenic increase in GHG concentrations and other anthropogenic factors together (Intergovernmental Panel on Climate Change [IPCC] 2014: 5).
Climate change is a global problem. GHGs are global pollutants because even local GHG emissions contribute to
global impacts. GHGs have long atmospheric lifetimes (one to several thousand years) and persist in the atmosphere long enough to be dispersed around the globe. Although the lifetime of any particular GHG molecule is dependent on multiple variables and cannot be determined with any certainty, it is understood that more CO 2 is emitted into the atmosphere than is sequestered by ocean uptake, vegetation, and other forms of sequestration (IPCC 2013:467).
GREENHOUSE GAS EMISSION SOURCES AND SINKS
As discussed previously, GHG emissions are attributable in large part to human activities. CO2 is the main byproduct of
fossil fuel combustion. Methane, a highly potent GHG, primarily results from off-gassing (the release of chemicals from nonmetallic substances under ambient or greater pressure conditions) and is largely associated with agricultural practices, organic material decomposition in landfills, and the burning of forest fires (Black et al. 2017). Nitrous oxide
emissions are largely attributable to agricultural practices and soil management. CO2 sinks, or reservoirs, include vegetation and the ocean, which absorb CO2 through sequestration and dissolution (CO2 dissolving into the water);
respectively, these are the two of the most common processes for removing CO2 from the atmosphere.
The total GHG inventory for the unincorporated San Mateo County in 2005 was 782,080 metric tons of CO2
equivalents (MTCO2e) (San Mateo County 2013). The 2005 and most recent local GHG inventory for the unincorporated San Mateo County is presented in Table 2.8-1 to provide context for the GHG emissions associated with the project.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-25
Table 2.8-1 2005 Unincorporated San Mateo County GHG Emissions Inventory
Sector Emissions MTCO2e Percent
Transportation 479,400 61
Commercial and Industrial Energy 160,900 21
Residential Energy 93,100 12
Off-Road 35,800 5
Solid Waste 8,380 1
Agriculture 3,000 <1
Water and Wastewater 1,500 <1
Total 782,080 100
Source: San Mateo County 2013
The Midpen inventory of administrative GHG emissions in 2018 was 1,307 MTCO2e (Midpen 2019). Table 2.8-2 presents
the breakdown of Midpen’s emissions.
Table 2.8-2 2018 Midpen GHG Emissions Inventory
Sector Emissions MTCO2e Percent
Vehicles, Equipment, Business Travel 608 46
Employee Commute 389 30
Facilities 170 13
Tenant Residences 139 11
Total 1,307 100
Source: Midpen 2019
Statewide GHG Emission Targets and the Climate Change Scoping Plan
Reducing GHG emissions in California has been the focus of the State government for approximately two decades (State of California 2018). GHG emission targets established by the State legislature include reducing statewide GHG
emissions to 1990 levels by 2020 (Assembly Bill 32 [AB 32] of 2006) and reducing them to 40 percent below 1990 levels by 2030 (Senate Bill 32 [SB 32] of 2016). Executive Order (EO) S-3-05 calls for statewide GHG emissions to be reduced to 80 percent below 1990 levels by 2050. EO B-55-18 calls for California to achieve carbon neutrality by 2045 and
achieve and maintain net negative GHG emissions thereafter. These targets align with the scientifically established levels needed globally to limit the rise in global temperature to no more than 2 degrees Celsius, the warming threshold at which major climate disruptions, such as super droughts and rising sea levels, are projected; these targets also pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius (UN 2015:3).
The 2017 Climate Change Scoping Plan (2017 Scoping Plan), prepared by CARB, outlines the main strategies California
will implement to achieve the legislated GHG emission target for 2030 and “substantially advance toward our 2050 climate goals” (CARB 2017:1, 3, 5, 20, 25–26). It identifies the reductions needed by each GHG emission sector (e.g., transportation, industry, electricity generation, agriculture, commercial and residential, pollutants with high global warming potential, and recycling and waste). The State has also passed more detailed legislation addressing GHG emissions associated with industrial sources, transportation, electricity generation, and energy consumption.
Bay Area Air Quality Management District
BAAQMD is the primary agency responsible for addressing air quality concerns in the San Francisco Bay Area, including San Mateo County. BAAQMD also recommends methods for analyzing project-related GHGs in CEQA
analyses and recommends multiple GHG reduction measures for land use development projects. BAAQMD developed thresholds of significance to provide a uniform scale to determine the CEQA significance of GHG emissions associated
with land use and stationary source projects that align with the statewide GHG target mandated by AB 32 (BAAQMD 2017). BAAQMD’s goals in developing GHG thresholds include ease of implementation; use of standard analysis tools; and emissions mitigation consistent with AB 32.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-26 Redwood Cabin Removal Project Initial Study
The proposed project’s GHG emissions are primarily related to construction activities, however, BAAQMD has not
adopted thresholds for evaluating GHG emissions from construction activities. Nevertheless, BAAQMD recommends that the lead agency quantify and disclose GHG emissions that would occur during construction and make a
determination on the significance of these construction-generated GHG emission impacts in relation to meeting AB 32 GHG reduction goals. Furthermore, BAAQMD does not advise that a project should be consistent with the State’s latest GHG emission reduction targets established by SB 32 (i.e., 40 percent below 1990 levels by 2030). Because
BAAQMD has not adopted a threshold under SB 32 targets, a project generated GHG emissions threshold was estimated to evaluate the project in a statewide context. Thus, this analysis presumes that a 40 percent reduction in the BAAQMD’s existing bright-line threshold (resulting in 660 MT CO2e) is necessary to achieve the State’s 2030 GHG reduction goal (which is a 40 percent reduction below 1990 GHG emissions levels). This threshold is presented to
demonstrate the progress required under SB 32.
Also as previously discussed in Section 2.6, “Energy,” San Mateo County has adopted an EECAP to be in line with the State’s GHG emission reductions and Midpen has adopted a CAP to reduce its operational GHG emissions
2.8.2 Discussion
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a
significant impact on the environment?
Less than significant. BAAQMD’s bright-line threshold of 1,100 MTCO2e was developed with the intention of attributing
an appropriate share of GHG emission reductions necessary to reach AB 32 goals for proposed land use development projects in BAAQMD’s jurisdiction under CEQA. However, AB 32’s GHG reduction target date of 2020 has passed and
GHG emission reduction are now to be analyzed in meeting updated targets provided by SB 32. At the time of preparing this analysis, BAAQMD has not updated its bright-line threshold to be consistent with SB 32 reduction targets. Thus, a project-specific threshold was developed by applying SB 32’s reduction target of 40 percent below
1990 GHG emissions level to the 1,100 MTCO2e bright-line threshold, which equates to 600 MTCO2e. This threshold is presented to demonstrate the progress required under SB 32. This linear reduction approach oversimplifies the
threshold development process. It is not the intent of this document to propose the adoption of this threshold as a mass emissions limit or CEQA GHG threshold for general use, but rather to provide this additional information to put
the project-generated GHG emissions in the appropriate statewide context.
The proposed project would result in construction activities associated with demolition and recontouring of the site. Construction-related GHG emissions would result from the use of construction equipment (haul trucks, excavator,
forklifts, etc.) and vehicle trips from construction workers over a 10-week construction period. The proposed construction activities were estimated to generate a total of 46 MTCO2e which is under the project-specific threshold
of 660 MTCO2e per year.
In addition to comparing the project to a threshold consistent with State targets, BAAQMD’s CEQA Guidelines encourage Lead Agencies to incorporate BMPs which include using alternative fueled (e.g., biodiesel, electric)
construction vehicles/equipment for at least 15 percent of the fleet; using local building materials for at least 10 percent of materials required; and recycling or reusing at least 50 percent of construction waste or demolition materials. The project would implement BMP GHG-1, as described in Section 2.7.3, “Project Level BMPs” of Chapter 2, “Project Description,” of the accompanying EIR.
With incorporation of BMP GHG-1, the project would be consistent with the BMPs required by BAAQMD and reduce emissions from construction activities. This impact would be less than significant.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of
reducing the emissions of greenhouse gases?
Less-than-significant impact. Midpen’s CAP evaluated the operational emissions of the agency. Because the project
would not result in any long-term operational emissions, the proposed project would not conflict with any of the GHG
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-27
emission reduction efforts provided in the CAP. Furthermore, the project would not exceed the project-related
threshold and is consistent with the State’s latest reduction goals of the 2017 Scoping Plan and SB 32. Thus, the project would not have a significant impact on the environment or conflict with an applicable plan, policy, or regulation
adopted for the purposes of reduction the emissions of GHGs. This impact would be less than significant.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-28 Redwood Cabin Removal Project Initial Study
2.9 HAZARDS AND HAZARDOUS MATERIALS
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IX. Hazards and Hazardous Materials.
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous materials?
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and/or accident conditions involving the release of
hazardous materials into the environment?
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the
project area?
f) Impair implementation of or physically interfere with
an adopted emergency response plan or emergency evacuation plan?
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury, or death involving wildland fires?
2.9.1 Environmental Setting
An Asbestos and Lead Survey was prepared by Terracon Consultants for the Redwood Cabin in November 2019. No
asbestos containing material were detected in any of the samples collected from the Redwood Cabin, however, several sources of paint within the cabin were determined to contain lead (ZFA 2020). Considering the historic use of the Redwood Cabin as a temporary recreational residence, it is possible that residential hazardous materials such as paint
and cleaning solutions/materials were used at the site and could be present within the soils.
No known hazardous waste sites are located within the project site or surrounding area (DTSC 2021; SWRCB 2021a). There are two former leaking underground storage tank sites within the community of Sky Londa, however, both sites have been considered closed for over 10 years (SWRCB 2021b; SWRCB 2021c).
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-29
The nearest school, Portola Valley Elementary School, is located over 2.5 miles southeast of the project site. No public
airports or private airstrips are within 2 miles of the project site. The San Carlos Airport is located approximately 8.5 miles northeast of the project site.
Fire protection within Midpen’s boundaries is provided by the jurisdictional local fire departments and CAL FIRE. Midpen works cooperatively with these jurisdictional fire agencies to reduce fire risk. According to the California Department of Forestry and Fire Protection (CAL FIRE) Fire Hazard Severity Zone Viewer, the project site is within a
zone of high fire hazard severity in a State Responsibility Area (CAL FIRE 2021). In May 2021, Midpen released the Wildland Fire Resiliency Program (Program) which includes a Vegetation Management Plan, Prescribed Fire Plan, Wildland Pre-Fire Plan/Resource Advisor Maps, and Monitoring Plan. Section 6 of the Program, “Wildland Pre-Fire Plan/Resource Advisor Maps,” includes guidance for Open Space Preserves within Midpen’s jurisdiction to include in their Wildland Pre-Fire Plan. Specifically, guidance related to emergency access and evacuation elements as well as
best management practices to be implemented during and post-fire activities are identified (Midpen 2021).
2.9.2 Discussion
a,b) Create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials? Create a significant hazard to the
public or the environment through reasonably foreseeable upset and/or accident
conditions involving the release of hazardous materials into the environment?
Less-than-significant impact. Project activities would involve the use of hazardous materials, such as fuels, solvents, gasoline, asphalt, and oil. Further, demolition of the Redwood Cabin would require removal of existing lead-containing
materials present in the structure. The use, disposal, and storage of these materials could potentially expose and adversely affect workers, the public, or the environment as a result of improper handling or use, accident,
environmentally unsound disposal methods, fire, explosion, or other emergencies, resulting in adverse health or environmental effects. Project operation would not involve the use of hazardous materials.
Disturbance of lead-containing paints and materials would occur in accordance with CCR Title 8, Section 1532, which
provides requirements related to removal and disturbance of lead and lead containing materials. The California Highway Patrol and Caltrans are responsible for enforcing regulations related to the transportation of hazardous
materials on local roadways, and the use of these materials is regulated by the California Department of Toxic Substances Control (DTSC), as outlined in CCR Title 22. Midpen and its construction contractors would be required to comply with the California Environmental Protection Agency’s (Cal EPA’s) Unified Program, which protects Californians from hazardous waste and hazardous materials by ensuring consistency throughout the state regarding the implementation of administrative requirements, permits, inspections, and enforcement at the local regulatory level.
Regulated activities would be managed by the San Mateo County Environmental Health Services, which is the designated Certified Unified Program Agency, and in accordance with the regulations included in the Unified Program (e.g., hazardous materials release response plans and inventories, California Uniform Fire Code hazardous material management plans and inventories). Such compliance would reduce the potential for accidental release of hazardous materials during project construction.
The project would be required to comply with existing laws and regulations regarding the transportation, use, and disposal of hazardous materials. These regulations are specifically designed to protect the public health and the
environment and must be adhered to during project construction and operation. Compliance with applicable regulations would ensure that this impact would be less than significant, and no mitigation is required.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school?
No impact. As described above, there are no schools within one-quarter miles of the project site. Because the nearest school, Portola Valley Elementary School, is located over 2.5 miles southeast of the project site, the project would not
emit hazardous emissions or handle hazardous materials within the one-quarter mile of the project site. Further, as
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-30 Redwood Cabin Removal Project Initial Study
discussed under criterion (a), the project would be required to comply with existing regulations associated with the
transport, use, and disposal of hazardous materials. No impact would occur, and no mitigation is required.
D) Be located on a site which is included on a list of hazardous materials sites compiled
pursuant to Government Code §65962.5 and, as a result, would it create a significant
hazard to the public or the environment?
No impact. Government Code Section 65962.5 requires that DTSC compile and maintain a list of hazardous waste
facilities subject to corrective action, land designated as hazardous waste property, or hazardous waste disposals on public land. This list is known as the Cortese List, which can be accessed on Cal EPA’s website. As described above,
there are no hazardous materials sites located within the project site or surrounding area. Therefore, the project site is not listed within the Cortese list database. No impact would occur, and no mitigation is required.
e) For a project located within an airport land use plan or, where such a plan has not
been adopted, within two miles of a public airport or public use airport, would the
project result in a safety hazard or excessive noise for people residing or working in
the project area?
No impact. The San Carlos Airport is located approximately 8.5 miles northeast of the project site. The project site is not located within an airport land use plan or within 2 miles of a public airport or public use airport, or within the vicinity of a private airstrip, and implementing the project would not result in an aviation-related safety hazard for
people residing or working in the project area. Therefore, no impact would occur, and no mitigation is required.
f) Impair implementation of or physically interfere with an adopted emergency response
plan or emergency evacuation plan?
Less-than-significant impact. The project includes demolition and site recontouring activities and does not include any
modification to an adopted emergency plan. During construction, the eastern portion of the project site would be utilized for staging activities. The project would not result in any temporary closures of Highway 35 for construction
vehicle trips or staging and public access is not permitted within the project site. However, because Highway 35 is a windy, two-lane road, it is possible that construction vehicles turning off Highway 35 could temporarily interfere with traffic, which has the potential to reduce emergency access. As described in Chapter 2, “Project Description,” of the accompanying EIR, a traffic control plan would be developed and followed. Emergency services access to local land uses shall be maintained at all times and require the use of flaggers to direct traffic. This impact would be less than
significant.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss,
injury, or death involving wildland fires?
Less-than-significant impact. As described above, the project site is located within a very-high fire hazard severity
zone. Project activities would involve removal of the Redwood Cabin structure and site recontouring activities to ensure adequate erosion control and drainage within the site. The operation of construction-related vehicles and
equipment has the potential for fire ignition risk. As described in Section 2.7.1, “La Honda Creek Open Space Preserve Master Plan EPGs,” EPG HAZ-9 requires that all equipment used during construction have an approved spark arrestor, that grass and fuels where construction vehicles are allowed to be parked be cut or reduced, and that construction
equipment that can cause an ignition will not be used when the National Weather Service issues a Red Flag Warning for the San Francisco Bay Area. Once the structure has been removed and site recontouring activities have been completed, no public access would be permitted within the project site. Project implementation would not include construction of any new inhabitable structures or facilities such that significant risks associated with wildland fire occur. Therefore, impacts would be less than significant, and no mitigation is required.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-31
2.10 HYDROLOGY AND WATER QUALITY
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
X. Hydrology and Water Quality.
Would the project:
a) Violate any water quality standards or waste discharge
requirements or otherwise substantially degrade surface or groundwater quality?
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater
management of the basin?
c) Substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial on- or offsite erosion or siltation;
ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
iii) Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv) Impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater management plan?
2.10.1 Environmental Setting
The Preserve is located within the San Gregorio Creek watershed, which drains an area of approximately 53 square miles in southwestern San Mateo County. Three major creek tributaries of San Gregorio flow through its center (La
Honda, Harrington, Weeks); and Bogess Creek flows along the western boundary. The creeks reach their confluence with San Gregorio Creek to the south of the Driscoll Ranch area. The creek and its tributaries are sediment-impaired
by accelerated rates of erosion and sedimentation resulting from natural geological and climatic processes and augmented by human land use practices. The largest anthropogenic sources of sediment are believed to be active and abandoned roads on unstable slopes near stream channels and hillside gullies on agricultural and range lands in the lower watershed, formed primarily as a result of hillside row cropping in the 1930’s (Midpen 2012a:3-58).
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-32 Redwood Cabin Removal Project Initial Study
There are nearly four miles of intermittent or ephemeral tributary streams within Preserve boundaries. While some of
these may dry by late summer, they experience significant flows during the wet months. Although it is considered a perennial stream, low gradient reaches within La Honda Creek may also go dry in certain conditions. There are a
number of natural springs and seeps in the Preserve. Several springs were improved to serve as watering sources for cattle and provide year-round flows. Twenty-three permanent and seasonal ponds are located on the Preserve, all but three of which are associated with providing a water source for the cattle operation on Driscoll Ranch (Midpen
2012a:3-58).
The project site is located within the La Honda Creek Watershed, approximately 200 feet south of the La Honda Creek. The Redwood Cabin is located approximately 60 feet above the creek in elevation at its nearest point (refer to Figure 2-2, Project Site in Chapter 2, “Project Description,” of the accompanying EIR). The distance from La Honda Creek to the Redwood Cabin in densely vegetated, rural in nature, and does not contain any impervious surfaces.
Water quality and hydrology policies applicable to the project includes EPG WQ-2 from the 2012 La Honda Creek Preserve Master Plan. EPG WQ-2 outlines storm water quality BMPs, including directing runoff flow to vegetated areas
and away from creeks and drainages, conducting trail maintenance during low flow periods, using erosion and sediment control features such as silt fences, straw bale barriers, brush/rock filters, inlet protection, etc.
The project is located in an area of minimal flood hazard per the Federal Emergency and Management Agency (FEMA)’s National Flood Hazard Layer Viewer tool (FEMA 2021).
2.10.2 Discussion
a) Violate any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or groundwater quality?
Less-than-significant impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation. After demolition is complete, site recontouring would be
implemented to reduce potential runoff, erosion, and to ensure proper site drainage consistent with the surrounding drainage patterns.
Furthermore, best management practices included in the project from the La Honda Creek Open Space Preserve Master Plan would minimize water quality impacts. As outlined in Chapter 2, “Project Description,” of the accompanying EIR, BMPs included in EPG WQ-2 include: directing flow toward vegetated areas away from creeks as
practical; using erosion and sediment control measures such as silt fences, straw bale barriers, sediment traps, or other materials, to minimize sediment flow into creeks; and conducting work during low flow periods to reduce potential runoff impacts. The project would not increase impervious area on the site or otherwise result in development that could impact water quality. Therefore, the project would not violate applicable water quality requirements or degrade surface or groundwater quality. This impact would be less than significant.
b) Substantially decrease groundwater supplies or interfere substantially with
groundwater recharge such that the project may impede sustainable groundwater
management of the basin?
No impact. During the geotechnical investigation conducted for the project, no groundwater was encountered at the
project site (Rowig 2019:4). However, the report noted that water levels may vary depending on season and precipitation levels. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation, and would not require extraction of groundwater. No structures or other
development requiring a water supply exists on or adjacent to the project site. By their nature, project activities would not create demand for groundwater extraction. Therefore, the project would not decrease groundwater supplies, and
this impact would be less than significant.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-33
c) Substantially alter the existing drainage pattern of the site or area, including through
the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would:
i) Result in substantial on or offsite erosion or siltation;
Less-than-significant impact. Project activities such as removal of the Redwood Cabin and subsequent site contouring and revegetation may alter the drainage patterns at the project site compared to existing conditions. However, site recontouring activities and revegetation would be implemented with the purpose of reducing site run off, siltation, and
erosion. The project would not alter or otherwise disturb the course of a stream or river and would not add impervious surfaces.
Furthermore, best management practices included in the project from the La Honda Creek Open Space Preserve Master Plan would minimize potential impacts related to runoff or erosion. As outlined in Chapter 2, “Project Description,” of the accompanying EIR, BMPs included in EPG WQ-2 include: directing flow toward vegetated areas
away from creeks as practical; using erosion and sediment control measures such as silt fences, straw bale barriers, sediment traps, or other materials, to minimize sediment flow into creeks; and conducting work during low flow periods to reduce runoff flows that may occur during project activities. Implementation of these measures would reduce potential erosion or siltation at the project site, and this impact would be less than significant.
ii) Substantially increase the rate or amount of surface runoff in a manner which would
result in flooding on- or offsite;
Less-than-significant impact. The project would conduct recontouring to maintain adequate site drainage and would not add impervious surfaces on the site. After completion of demolition activities, the project would not result in any
additional land uses that may increase the rate or amount of surface run off. Revegetation activities would reduce potential run off from the site. Furthermore, best management practices included in the project from the La Honda Creek Open Space Preserve Master Plan would minimize potential impacts related to runoff or erosion. As outlined in
Chapter 2, “Project Description,” of the accompanying EIR, BMPs included in EPG WQ-2 include: directing flow toward vegetated areas away from creeks as practical; using erosion and sediment control measures such as silt fences, straw bale barriers, sediment traps, or other materials, to minimize sediment flow into creeks; and conducting work during low flow periods to reduce potential runoff impacts. The project does not propose activities or substantially altered drainage patterns that would increase opportunities for increased run-off or flooding. Therefore, this impact would be
less than significant.
iii) Create or contribute runoff water which would exceed the capacity of existing or
planned stormwater drainage systems or provide substantial additional sources of
polluted runoff; or
No impact. The setting of the project is rural. No built stormwater drainage systems exist on or in vicinity of the project
site. The project does not propose development that would result in increased sources of pollution on the project site. Therefore, there would be no impact.
iv) Impede or redirect flood flows?
No impact. No regular flood flows are known to occur for the project site. The project does not proposed activities that could impede or redirect flood flows. Therefore, the project would have no impact.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project
inundation?
No impact. The project is located in an area of minimal flood hazard per FEMA’s National Flood Hazard Layer mapping tool (FEMA 2019). The project site is not located in an area with notable risk for tsunamis or seiches, as the
Preserve is more than 200 feet above sea level at its lowest point and the Pacific Ocean is located more than seven
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-34 Redwood Cabin Removal Project Initial Study
miles to the west. Furthermore, the project would not result in permanent sources of pollution or hazardous waste on
the project site. Therefore, there would be no impact.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan?
No impact. The proposed project is not located within the plan area of an existing water quality control plan or a
sustainable groundwater quality control plan. The project would therefore not conflict with the implementation of any such plan, and there would be no impact.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-35
2.11 LAND USE AND PLANNING
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XI. Land Use and Planning.
Would the project:
a) Physically divide an established community?
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an environmental effect?
2.11.1 Environmental Setting
The Redwood Cabin was historically used as a temporary, recreational residence. However, the structure is no longer in use and does not have any future long-term uses. The project site is in a rural, remote setting, and no additional
residential structures or other built communities are present within or adjacent to the project site. No other residential structures or other built communities exist on or adjacent to the project site.
According to the County of San Mateo Planning and Building Map Viewer, the project site is within the “Forest/Timber Production” land use designation and is zoned as Timber Land Preserve District (TPZ) (San Mateo County 2021). The project site, located in the northern portion of the Preserve, south of Highway 35, is within the State Scenic Corridor
portion of Highway 35. See Section 2.1, “Aesthetics,” of this document for a discussion of potential impacts of the project on scenic resources.
The project site is also within the plan area of the La Honda Creek Open Space Preserve Master Plan (Midpen 2012b). The project is consistent with Theme 8 from the Master Plan “Address the presence of existing and potential hazards” by “removing dilapidated structures that can become a nuisance…” (Midpen 2012b: 27).
2.11.2 Discussion
a) Physically divide an established community?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. The project site does not contain residential structures or any form of established living community. The project does not propose any activities that would result in the division of an established
community. Therefore, there would be no impact.
b) Cause a significant environmental impact due to a conflict with any land use plan,
policy, or regulation adopted for the purpose of avoiding or mitigating an
environmental effect?
No impact. The project is consistent with the activities proposed in the La Honda Creek Open Space Master Plan and
analyzed in the Master Plan IS/MND (Midpen 2012a). The Master Plan recommends historical and structural evaluations of the Redwood Cabin for future Midpen Board of Directors consideration on the disposition of the
structure. Consistent with the Master Plan, historical and structural evaluations for the Redwood Cabin were prepared in 2020. Based on those evaluation, the Midpen Board of Directors directed the General Manager to evaluate the environmental effects that would result from removing the Redwood Cabin. The project does not propose changes in
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-36 Redwood Cabin Removal Project Initial Study
the Open Space Master Plan or in the County’s land use designation or zoning of the site. The project also does not
propose any activities that may conflict with the land use designation or zoning. Therefore, there would be no impact.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-37
2.12 MINERAL RESOURCES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XII. Mineral Resources.
Would the project:
a) Result in the loss of availability of a known mineral
resource that would be of value to the region and the residents of the state?
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?
2.12.1 Environmental Setting
The 2012 La Honda Creek Open Space Preserve Master Plan IS/MND identified one Significant Mineral Resource Area
in the southwestern portion of the preserve, within the area formerly known as Driscoll Ranch. This site was known as the La Honda Oil Field and is no longer active (Midpen 2012a:3-67). It was sealed in 1985 and the availability of oil
from this resource is unknown. No mineral resource extraction is currently occurring within the preserve. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation. No other mineral resources are identified within or adjacent to the project site (CDOC 2018).
2.12.2 Discussion
a) Result in the loss of availability of a known mineral resource that would be of value to
the region and the residents of the state?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. No known mineral resources are identified within or adjacent to the project site. Demolition and removal of materials, from the project site may involve excavation of up to 5 feet required to remove
posts and bases that are associated with the existing structure (see Chapter 2, “Project Description” of the accompanying EIR).
Due to the nature of project activities, the project would not impact the existing potential for mineral resource
extraction within the preserve in the event that resources are discovered or extraction is permitted. Excavation required to remove subsurface posts and foundation associated with the structure would be limited to 5 feet and
would be unlikely to disturb or otherwise impact mineral resources within the area, given that the occurrence of mineral resources in the area is unknown, and given the limited extent of excavation.
Since mineral resources are not known to occur within the project area, and since project activities would not impact future availability of mineral resources, the project would have no impact.
b) Result in the loss of availability of a locally important mineral resource recovery site
delineated on a local general plan, specific plan, or other land use plan?
No impact. As discussed above, mineral resources are not known to occur within the project site, and the site is not zoned for mineral resource recovery according to the County’s General Plan, or the La Honda Creek Preserve Open Space Preserve Master Plan. Therefore, there would be no impact.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-38 Redwood Cabin Removal Project Initial Study
2.13 NOISE
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIII. Noise.
Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local
general plan or noise ordinance, or in other applicable local, state, or federal standards?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area
to excessive noise levels?
2.13.1 Environmental Setting
ACOUSTIC FUNDAMENTALS
In the science of acoustics, the fundamental model consists of a sound (or noise) source, a receiver, and the
propagation path between the two. Sound is the mechanical energy of a vibrating object transmitted by pressure waves through a liquid or gaseous medium (e.g., air) to a human ear. Noise is defined as loud, unexpected, annoying,
or unwanted sound. As sound travels through the atmosphere from the source to the receiver, noise levels attenuate (i.e., decrease) depending on a variety of factors, including geometric spreading (i.e., spherical or cylindrical spreading), ground absorption (i.e., hard versus soft sites), atmospheric conditions (e.g., wind direction and speed, air temperature, humidity, turbulence), and shielding by natural or human-made features.
The amplitude of pressure waves generated by a sound source determines the loudness of that source, also called the
sound pressure level (SPL). SPL is most commonly described by using decibels (dB) because this logarithmic unit best corresponds to the way the human ear interprets sound pressures. However, the decibel scale does not adequately characterize how humans perceive noise because the human ear is not equally sensitive to loudness at all frequencies (i.e., pitch) in the audible spectrum. To approximate the response of the human ear, sound levels of individual frequency bands are weighted, depending on the human sensitivity to those frequencies. Then, an “A-weighted” sound level (expressed in units of A-weighted decibels or dBA) can be computed based on this information. All sound levels discussed in this section are expressed in A-weighted decibels.
Because decibels are logarithmic units, SPLs expressed in dB cannot be added or subtracted through ordinary arithmetic. Under the decibel scale, a doubling of sound energy corresponds to a 3-dB increase. In typical noisy environments, changes in noise of 1–2 dB are generally not perceptible. However, it is widely accepted that people can begin to detect sound level increases of 3 dB in typical noisy environments. Further, a 5-dB increase is generally perceived as a distinctly noticeable increase, and a 10-dB increase is generally perceived as a doubling of loudness
(Caltrans 2013:2-10).
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-39
Various noise descriptors have been developed to describe time-varying noise levels. The noise descriptors used in
this chapter include:
Equivalent Continuous Sound Level (Leq): Leq represents an average of the sound energy occurring over a specified
period. In effect, Leq is the steady-state sound level containing the same acoustical energy as the time-varying sound level that occurs during the same period (Caltrans 2013:2-48). For instance, the 1-hour equivalent sound level, also referred to as the hourly Leq, is the energy average of sound levels occurring during a 1-hour period.
Maximum Sound Level (Lmax): Lmax is the highest instantaneous sound level measured during a specified period (Caltrans 2013:2-48; FTA 2018:207–208).
GROUND VIBRATION
Vibration is the periodic oscillation of a medium or object with respect to a given reference point. Groundborne
vibration is vibration of and through the ground. Sources of ground-borne of vibration include natural phenomena (e.g., earthquakes, volcanic eruptions, sea waves, landslides) and those introduced by human activity (e.g., explosions,
machinery, traffic, trains, construction equipment). Vibration sources may be continuous, (e.g., operating factory machinery) or transient in nature (e.g., explosions).
Ground-borne vibration amplitudes are commonly expressed in peak particle velocity (PPV) or root-mean-square
(RMS) vibration velocity. PPV and RMS vibration velocity are normally described in inches per second (in/sec) but can also be expressed in decibel notation (VdB), which is used mainly in evaluating human response to vibration.
EXISTING NOISE SOURCES
Because the project site is located in a heavily forested area within the upper La Honda Creek Open Space Preserve,
there are few existing noise sources. The most predominant noise source in the vicinity of the project site is vehicular traffic along Highway 35 which is approximately 495 feet north of the project site.
NOISE AND VIBRATION-SENSITIVE RECEPTORS
Noise-sensitive land uses are generally considered to include those uses where noise exposure could result in health-
related risks to individuals, as well as places where quiet is an essential element of their intended purpose. Residential dwellings are of primary concern because of the potential for increased and prolonged exposure of individuals to both
interior and exterior noise levels, and because of the potential for nighttime noise to result in sleep disruption. Vibration-sensitive land uses are generally considered to be buildings or structures that could be damaged due to vibration or land uses where vibration levels could interfere with operations or cause human annoyance. The nearest noise-sensitive receptor is a single-family residence located on the opposite side of Highway 35 from the project site, approximately 840 feet north of the project site boundary. The Bechtel House, the second closest residence, shown on Figure 2-2 of Chapter
2, “Project Description,” of the accompanying EIR is located approximated 1,250 feet northeast of the project site boundary.
2.13.2 Discussion
a) Generation of a substantial temporary or permanent increase in ambient noise levels in
the vicinity of the project in excess of standards established in the local general plan
or noise ordinance, or in other applicable local, state, or federal standards?
Less-than-significant impact. Temporary noise would result from the use of heavy-duty equipment for demolition of
the existing Redwood Cabin structure and other features (i.e., retaining walls, fire/barbeque pits) and site recontouring. No permanent increases in ambient noise levels would occur after these activities are completed because the project
would not involve any operational activities. Demolition noise would be short-term and temporary, and operation of
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-40 Redwood Cabin Removal Project Initial Study
heavy-duty construction equipment would be intermittent throughout the day during construction. The types of
equipment that would be used for demolition activities include an excavator, manlift, boom truck, skid steer, water truck, forklift, and haul trucks. Reference noise levels for these types of equipment are shown in Table 2.13-1.
Table 2.13-1 Noise Emission Levels from Construction Equipment
Equipment Type Typical Noise Level (dBA) at 50 Feet
Boom Truck/Crane 85
Excavator 85
Forklift/Manlift 85
Haul Truck 84
Skid Steer/Front End Loader 80
Water Truck1 82
1 Noise level of a concrete pump truck was used to represent the noise level for a water truck, as these pieces of equipment provide similar tasks
and produce similar noise levels.
Source: FHWA 2006:3
For noise modeling conducted, it was conservatively assumed that the loudest three pieces of equipment (a boom
truck/crane, an excavator, and a forklift/manlift) would operate simultaneously in close proximity to each other, combining to generate a maximum possible noise level from construction activity. Note that pieces of construction equipment move around a construction site and generally are not close to each other for safety reasons; thus, noise
levels would fluctuate throughout the day, depending on the actual activity taking place and equipment used at any one location on the site.
Within San Mateo County, the County Code Section 4.88.360 exempts certain activities, including demolition activities, from the County’s noise standards as long as the activities are limited to the hours of 7 a.m. to 6 p.m. on weekdays and 9 a.m. to 5 p.m. on Saturdays. All project demolition activity would occur during the daytime hours when
construction noise is exempt.
Assuming simultaneous operation of a boom truck/crane, an excavator, and a forklift/manlift and accounting for typical use factors of individual pieces of equipment and activity types along with typical attenuation rates, on-site construction-related activities could result in hourly average noise levels of approximately 84 Leq and 90 dBA Lmax at 50
feet. As described above, the nearest sensitive land uses are residences located approximately 840 feet north of the project site. At this distance, noise from the use of heavy-duty equipment would attenuate, from distance alone, to 52 dBA Leq and 58 dBA Lmax. Refer to Attachment C for detailed calculations. The County’s daytime noise standards for
single-family residential land uses are 55 dB Leq and 75 dB Lmax. Because the County’s applicable noise standards would not be exceeded at the nearest residential receptors and demolition activities would be exempt per Section 4.88.360
of the County Code, this impact would be less than significant, and no mitigation is required.
b) Generation of excessive groundborne vibration or groundborne noise levels?
Less-than-significant impact. Project demolition would not involve the use of ground vibration–intensive activities,
such as pile driving and blasting. Activities involving pile driving and blasting typically generate the highest vibration levels compared to other construction methods and are, therefore, of greatest concern when evaluating construction-related vibration impacts. Pieces of equipment that generate lower levels of ground vibration, such as excavators and
haul trucks, would be used during demolition. These types of common construction equipment do not generate substantial levels of ground vibration that could result in structural damage, except at extremely close distances (i.e., within at least 10 feet). Because demolition activities would occur at least 840 feet away from all adjacent residential land uses, would not require vibration-intensive equipment, and would be limited to the hours of 7 a.m. to 6 p.m. on weekdays and 9 a.m. to 5 p.m. on Saturdays, project demolition would also not result in human annoyance. Therefore,
this impact would be less than significant, and no mitigation is required.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-41
c) For a project located within the vicinity of a private airstrip or an airport land use plan
or, where such a plan has not been adopted, within two miles of a public airport or
public use airport, would the project expose people residing or working in the project
area to excessive noise levels?
No impact. The project is not located within an airport land use plan or within two miles of a public airport or public use airport. Additionally, the project is not located within two miles of a private airstrip. San Carlos Airport is the closest airport and is located approximately 8 miles north of the project site. Also, the project would not include any
new land uses where people would live or work. Thus, the project would have no impact regarding the exposure of people residing or working in the project area to excessive aircraft-related noise levels, and no mitigation is required.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-42 Redwood Cabin Removal Project Initial Study
2.14 POPULATION AND HOUSING
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIV. Population and Housing.
Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for example, through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement housing elsewhere?
2.14.1 Environmental Setting
San Mateo County was estimated to have a population of 766,573 in 2018 (US Census Bureau 2019). The project site is located within the La Honda Creek Open Space Preserve. While some residential properties are scattered within and
adjacent to the preserve, no housing is located on or adjacent to the project site. The Redwood Cabin is not currently used as a residential structure.
2.14.2 Discussion
a) Induce substantial unplanned population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for example, through
extension of roads or other infrastructure)?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. No housing is located on the project site. Project activities would not result in any changes that could directly or indirectly induce population growth in vicinity of the project site or elsewhere.
As described in Chapter 2, “Project Description,” of the accompanying EIR, public access to the project site is limited, and there are no paved roadways leading to the project site. The project does not propose new or expanded roadways, additional housing, commercial facilities, or other development that could induce population growth.
Therefore, the project would not result in unplanned population growth, and no impact would occur.
b) Displace substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere?
No impact. The project would remove the Redwood Cabin, which was historically used as a recreational retreat, but
has been uninhabited since at least 1988. No other housing or other community is present on the project site. Project activities would therefore not displace existing communities or people, and the construction of replacement housing
would not be required. There would be no impact.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-43
2.15 PUBLIC SERVICES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XV. Public Services.
Would the project:
a) Result in substantial adverse physical impacts
associated with the provision of new or physically altered governmental facilities, or the need for new
or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
2.15.1 Environmental Setting
Fire protection for the Preserve is provided by collaboration of Midpen with other agencies, including the jurisdictional fire agencies of CAL FIRE/County of San Mateo Fire Department (CAL FIRE/County Fire) and La Honda Fire Brigade.
First response is typically provided by Midpen Ranger Staff (Midpen 2012a).
Police protection for the preserve is provided by the San Mateo County Sherriff’s Department.
Recreational uses such as hiking and horseback riding, are permitted in the Preserve; however the portion of the Preserve where the Redwood Cabin is located is closed to the public. The El Corte De Madera Creek Preserve is located approximately one mile northwest of the project site. Wunderlich County Park is located 1300 feet north of the
project site, on the other side of Highway 35. The Thornwood Open Space Preserve is located approximately 1 mile east of the project site.
The Preserve is served by multiple school districts. The project site and nearby areas are within the service areas of the Portola Valley School District and the Sequoia Valley Elementary School District.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-44 Redwood Cabin Removal Project Initial Study
2.15.2 Discussion
a) Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times,
or other performance objectives for any of the public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
Less-than-significant impact. Project activities include demolition of the Redwood Cabin, removal of materials and
associated features, recontouring, and site revegetation. The project would not introduce new housing, commercial facilities, roadways, or other development such that the provision of new or expansion of existing public services
including fire protection, police protection, schools, parks, or other public facilities would be required beyond existing levels.
Construction activities may temporarily increase risk of fire within the project area, due to presence of motorized
vehicles and construction equipment on site. The operation of construction-related vehicles and equipment has the potential for fire ignition risk. As described in Section 2.7.1, “La Honda Creek Open Space Preserve Master Plan EPGs,”
EPG HAZ-9 requires that all equipment used during construction have an approved spark arrestor, that grass and fuels where construction vehicles are allowed to be parked be cut or reduced, and that construction equipment that can cause an ignition will not be used when the National Weather Service issues a Red Flag Warning for the San Francisco
Bay Area. Fire services in the event of an emergency would be met with existing services. Access by fire response and other emergency services such as medical emergency and police responders would be maintained during construction activities to minimize delays to the project site. The project’s potential need for fire response or protection services would be temporary and would not require expanded fire response services. Therefore, this impact would be less than significant.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-45
2.16 RECREATION
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVI. Recreation.
Would the project:
a) Increase the use of existing neighborhood and
regional parks or other recreational facilities such that substantial physical deterioration of the facility would
occur or be accelerated?
b) Include recreational facilities or require the construction or expansion of recreational facilities
that might have an adverse physical effect on the environment?
2.16.1 Environmental Setting
In addition to the Preserve itself, three recreational areas or preserves are located near the project site. The El Corte De
Madera Creek Preserve is located approximately one mile northwest of the project site. Wunderlich County Park is located 1300 feet north of the project site, on the other side of Highway 35. Thornwood Open Space Preserve is located approximately 1 mile east of the project site. Several equestrian and hiking trails are present within the
northern portion of the preserve. Within La Honda Creek Preserve, the Cielo Trail and the Coho Vista Loop trail are located approximately 2,000 and 400 feet south of the project site, respectively. Redwood Cabin is located within a portion of the Preserve that is closed to the public.
2.16.2 Discussion
a) Increase the use of existing neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be
accelerated?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, recontouring, and site revegetation. The project site does not currently support public recreational use.
The project does not propose new housing, commercial facilities, roadway, or other development that may increase use of nearby trails, parks, or other recreational facilities. Project activities are designed to improve and maintain the habitat and reduce hazards associated with the Redwood Cabin project site. Therefore, the project would not result in
increased use or deterioration of recreational facilities, and there would be no impact.
b) Include recreational facilities or require the construction or expansion of recreational
facilities that might have an adverse physical effect on the environment?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. These activities are intended to maintain and improve quality, safety, and environmental quality of nearby recreational facilities. The project would not require the construction of additional
recreational features and there would be no impact.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-46 Redwood Cabin Removal Project Initial Study
2.17 TRANSPORTATION
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVII. Transportation.
Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
2.17.1 Environmental Setting
Access to the Redwood Cabin is provided via an unpaved road accessible from Highway 35, which travels through two locked gates. The final segment of this unpaved road requires a four-wheel drive vehicle or access by foot. Generally,
the project site is rural in nature, and vehicle traffic within the Preserve is limited.
The Preserve is within the plan areas of the San Mateo Countywide Transportation Plan, which primarily addresses transportation issues and policies within the urbanized areas of San Mateo County. The La Honda Creek Open Space
Preserve Master Plan does not contain policies that specifically pertain to transportation or circulation within the preserve.
2.17.2 Discussion
a) Conflict with a program, plan, ordinance or policy addressing the circulation system,
including transit, roadway, bicycle, and pedestrian facilities?
Less-than-significant impact. Equipment and vehicles would access the project area from Highway 35 (via Highways 92 or 84), then to the unpaved driveway extended from Highway 35 to the project site. Construction equipment,
materials, and vehicle staging would occur within the driveway area of the project site. Project activities may temporarily increase use of the unpaved road used to access the site. Project activities may result in vehicle trips to
transport equipment, materials, and waste on and off of the project site, which would not result in permanent traffic increase on any nearby roadways or trail. Impacts of construction to traffic would be temporary and limited in nature. Therefore, the project would not conflict with any applicable plans or policies addressing the local circulation system,
and this impact would be less than significant.
b) Conflict or be inconsistent with CEQA Guidelines section 15064.3(b), which pertains to
vehicle miles travelled?
Less-than-significant impact. Project activities include demolition of the Redwood Cabin, removal of materials and
associated features, recontouring, and site revegetation. Potential trips generated from project activities could result from transport of materials on and off site, transport of construction vehicles, and commute trips from construction
workers.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-47
The project would generate limited trips during construction activities because only 8 crew members are expected to
be onsite for a period of 10 weeks. Additionally, because there is no construction associated with the project, the only daily hauling would be associated with the removal of demolition debris. These trips would be temporary and would
not directly or indirectly result in a permanent increase in vehicle miles traveled. Therefore, this impact would be less than significant.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses (e.g., farm equipment)?
No impact. Project activities would not construct additional roadways or alter existing ones. Therefore, the project would not increase hazards related to geometric roadway design. There would be no impact.
d) Result in inadequate emergency access?
Less-than-significant impact. Access to the project site is provided by an unpaved road that may be accessed from
Highway 35. The project site is located in a rural setting with no adjacent housing, commercial areas, or other facilities that require consistent emergency access. Demand for emergency services within the vicinity of the project is therefore
low, however, temporary reduction of emergency vehicle access may occur as materials and construction equipment are transported on and off site. As described in Chapter 2, “Project Description,” of the accompanying EIR, a traffic control plan would be developed. Emergency services access to local land uses shall be maintained at all times and require the use of flaggers to direct traffic. This impact would be less than significant.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-48 Redwood Cabin Removal Project Initial Study
2.18 TRIBAL CULTURAL RESOURCES
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVIII. Tribal Cultural Resources.
Has a California Native American Tribe requested consultation in accordance with Public Resources Code
section 21080.3.1(b)?
Yes No
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California
Native American tribe, and that is:
a) Listed or eligible for listing in the California Register
of Historical Resources, or in a local register of historical resources as defined in Public Resources
Code section 5020.1(k)?
b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the
resource to a California Native American tribe?
2.18.1 Environmental Setting
Under PRC section 21080.3.1 and 21082.3, Midpen must consult with tribes traditionally and culturally affiliated with the project area that have requested formal notification and responded with a request for consultation. The parties must
consult in good faith. Consultation is deemed concluded when the parties agree to measures to mitigate or avoid a significant effect on a tribal cultural resource when one is present or when a party concludes that mutual agreement cannot be reached. Mitigation measures agreed on during the consultation process must be recommended for
inclusion in the environmental document.
On June 9, 2021, Midpen sent notification letters that the project was being addressed under CEQA, as required by
PRC 21080.3.1, to the following Native American tribal representatives:
Muwekma Ohlone Indian Tribe of the SF Bay Area, Monica Arellano, Vice Chairwoman
Amah Mutsun Tribal Band of Mission San Juan Bautista, Irene Zwierlein, Chairperson
Muwekma Ohlone Indian Tribe of the SF Bay Area, Charlene Nijmeh, Chairperson
Indian Canyon Mutsun Band of Costanoan, Kanyon Sayers-Roods, MLD Contact
Indian Canyon Mutsun Band of Costanoan, Ann Marie Sayers, Chairperson
Rumšen Am:a Tur:ataj Ohlone, Dee Dee Ybarra, Chairperson
The Ohlone Indian Tribe, Andrew Galvan
Costanoan Rumsen Carmel Tribe, Tony Cerda, Chairperson
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-49
On June 11, 2021, an email from Kanyon Konsulting on behalf of the Indian Canyon Band of Costanoan Ohlone People,
was received in response to Midpen’s AB 52 tribal consultation notification. Midpen responded on July 9, 2021 and again on August 2, 2021 requesting additional information from Kanyon Konsulting, however, no response was
received.
As described in Section 2.5, “Cultural Resources,” the NWIC records search indicated that no resources were located within the project site or within a 0.25-mile radius.
2.18.2 Discussion
Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in Public Resources Code section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the
landscape, sacred place, or object with cultural value to a California Native American tribe,
and that is:
a, b) Listed or eligible for listing in the California Register of Historical Resources, or in a
local register of historical resources as defined in Public Resources Code section
5020.1(k)? A resource determined by the lead agency, in its discretion and supported
by substantial evidence, to be significant pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section 5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider
the significance of the resource to a California Native American tribe?
Less-than-significant impact. As described above, no additional consultation between Midpen and Kanyon Konsulting has occurred. Therefore, there are no known tribal cultural resources as defined in PRC Section 21074 present within
the project area. The project would involve demolition of the Redwood Cabin and site recontouring activities. As discussed in Chapter 2, “Project Description,” of the accompanying EIR, it is expected that excavation of posts and
bases associated with the structure would be approximately 2 feet below grade, however, it is possible that maximum depth of excavation could reach up to 5 feet. Excavation would occur within the footprint of the disturbed footings, which is unlikely to yield any significant materials and/or features.
Because no known tribal cultural resources are located within the project site or surrounding area and project excavation activities would occur within existing disturbed portions of the Redwood Cabin footprint, the potential for
disturbance or destruction of tribal cultural resources, such that a substantial adverse change in the significance of a resource occur, would be less than significant. No mitigation is required.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-50 Redwood Cabin Removal Project Initial Study
2.19 UTILITIES AND SERVICE SYSTEMS
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. Utilities and Service Systems.
Would the project:
a) Require or result in the relocation or construction of
construction of new or expanded water, wastewater treatment or stormwater drainage, electric power,
natural gas, or telecommunication facilities, the construction or relocation of which could cause
significant environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry and multiple dry years?
c) Result in a determination by the wastewater
treatment provider that serves or may serve the project that it has adequate capacity to serve the
project’s projected demand, in addition to the provider’s existing commitments?
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management and reduction statutes and regulations related to
solid waste?
2.19.1 Environmental Setting
The project site is located in a remote rural setting. Water, wastewater electricity and gas connections exist at the project site, however these utility connections have not been used since 1988.
2.19.2 Discussion
a) Require or result in the relocation or construction of construction of new or expanded
water, wastewater treatment or stormwater drainage, electric power, natural gas, or
telecommunication facilities, the construction or relocation of which could cause
significant environmental effects?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. The project would not introduce new housing, commercial facilities, roadway, or other development such that the provision of new or expanded water, wastewater, electric power, gas,
telecommunications, or other utilities or service systems would be required. The existing utility lines would be abandoned in place. Therefore, the project would have no impact.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-51
b) Have sufficient water supplies available to serve the project and reasonably
foreseeable future development during normal, dry and multiple dry years?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features,
recontouring, and site revegetation. The project would not introduce new housing, commercial facilities, roadways, or other development that would create new demand for water on the project site; there would be no impact.
c) Result in a determination by the wastewater treatment provider that serves or may
serve the project that it has adequate capacity to serve the project’s projected
demand, in addition to the provider’s existing commitments?
No impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, grading and recontouring, and site revegetation. The project would not introduce new housing, commercial facilities,
roadway, or other development that would generate wastewater. The project would therefore not exceed local wastewater provision capacity, and there would be no impact.
d, e) Generate solid waste in excess of State or local standards, or in excess of the capacity
of local infrastructure, or otherwise impair the attainment of solid waste reduction
goals? Comply with federal, state, and local management and reduction statutes and
regulations related to solid waste?
Less-than-significant impact. Project activities include demolition of the Redwood Cabin, removal of materials and associated features, grading and recontouring, and site revegetation. The project would not introduce new housing,
commercial facilities, roadway, or other development that would generate operational solid waste. However, demolition of the Redwood Cabin and associated site features may result in up to 60 tons of waste removal from the project site. Per Chapter 4.105 “Recycling and Diversion of Debris from Construction and Demolition,” of the San
Mateo County Code, demolition projects in unincorporated San Mateo County would be required to submit a Waste Management Plan to assist in the County’s goal of the diversion of inert solids such as concrete and untreated wood waste, or waste that is not treated with hazardous preservatives. Additionally, if the building materials are in good condition, Midpen will conduct salvage operations per the process outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. Although it is possible that some of the historical materials from the cabin would be salvaged, for a conservative estimate it is assumed that all material would be disposed at the Kettleman Hills Landfill located approximately 180 miles from the project site. For additional information on the
disposal of hazardous materials, refer to Section 2.9, “Hazards and Hazardous Materials”. The project would be required to comply with all applicable local, state, and federal regulations regarding the production of solid construction waste and would not generate waste in excess of standards or capacity. This impact would be less than significant.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-52 Redwood Cabin Removal Project Initial Study
2.20 WILDFIRE
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. Wildfire.
Is the project located in or near state responsibility areas or lands classified as high fire hazard severity zones?
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would
the project:
Yes No
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
c) Require the installation of associated infrastructure (such as roads, fuel breaks, emergency water
sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary
or ongoing impacts to the environment?
d) Expose people or structures to significant risks, including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope instability, or drainage changes?
2.20.1 Environmental Setting
According to the CAL FIRE Fire Hazard Severity Zone Viewer, the project site is within a zone of high fire hazard severity in a State Responsibility Area (CAL FIRE 2021). As described in Chapter 2, “Project Description,” of the
accompanying EIR, the project site is located in a heavily wooded area within a portion of the Preserve and is situated atop sloped terrain.
Fire protection within Midpen’s boundaries is provided by the jurisdictional local fire departments and CAL FIRE. Midpen works cooperatively with these jurisdictional fire agencies to reduce fire risk. In May 2021, Midpen released the Wildland Fire Resiliency Program (Program) which includes a Vegetation Management Plan, Prescribed Fire Plan, Wildland Pre-Fire Plan/Resource Advisor Maps, and Monitoring Plan. Section 6 of the Program, “Wildland Pre-Fire Plan/Resource Advisor Maps,” includes guidance for Open Space Preserves within Midpen’s jurisdiction to include in
their Wildland Pre-Fire Plan. Specifically, guidance related to emergency access and evacuation elements as well as best management practices to be implemented during and post-fire activities are identified (Midpen 2021).
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-53
2.20.2 Discussion
a) Substantially impair an adopted emergency response plan or emergency evacuation
plan?
Less-than-significant impact. The project includes demolition and site recontouring activities within the northern portion of the Preserve. During construction, the eastern portion of the project site would be utilized for temporary
staging activities. The project site is accessed via an unpaved driveway off Highway 35. As described in Chapter 2, “Project Description,” of the accompanying EIR, a traffic control plan would be developed to insure that emergency services access to local land uses shall be maintained at all times. The project would not result in any temporary
closures of Highway 35 for construction vehicle trips or staging and public access is not permitted within the project site. Therefore, project implementation is not expected to substantially impair or interfere with emergency response or
evacuation plans within the area. As such, no impact would occur, and no mitigation is required.
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and
thereby expose project occupants to pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire?
Less-than-significant impact. The project includes demolition and recontouring activities within the project site. The
operation of construction-related vehicles and equipment has the potential for fire ignition risk. As described in Section 2.7.1, “La Honda Creek Open Space Preserve Master Plan EPGs,” EPG HAZ-9 requires that all equipment used
during construction have an approved spark arrestor, that grass and fuels where construction vehicles are allowed to be parked be cut or reduced, and that construction equipment that can cause an ignition will not be used when the National Weather Service issues a Red Flag Warning for the San Francisco Bay Area. Once construction activities are
complete, the project site would remain vacant and inaccessible by the public. Though the project site is situated atop sloped terrain, project implementation does not include new structures or facilities that would be occupied. Further, site recontouring activities would ensure soil stabilization and erosion control within the project site. Therefore, the project would not result in exposure to pollutant concentrations from wildfire. No impact would occur, and no mitigation is required.
c) Require the installation of associated infrastructure (such as roads, fuel breaks,
emergency water sources, power lines or other utilities) that may exacerbate fire risk
or that may result in temporary or ongoing impacts to the environment?
No impact. The project involves removal of existing site structures as well as site recontouring and does not include
installation of any utility infrastructure. Once project activities are complete, the site would remain closed and would not be accessible by the public. As such, the project would not exacerbate fire risks associated with the installation of utility infrastructure. No impact would occur, and no mitigation is required.
d) Expose people or structures to significant risks, including downslope or downstream
flooding or landslides, as a result of runoff, post-fire slope instability, or drainage
changes?
No impact. As described in Chapter 2, “Project Description,” of the accompanying EIR, following completion of demolition activities, disturbed areas underneath the Redwood Cabin and within the staging area would be graded
and/or recontoured to ensure adequate erosion control and site drainage. Once site recontouring activities are complete, no additional maintenance or operational activities would be required at the project site and no public
access would be available. As such, the project would not result in the exposure of people or structures to significant risks as a result of runoff, post-fire slope instability and drainage changes. No impact would occur, and no mitigation is required.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-54 Redwood Cabin Removal Project Initial Study
2.21 MANDATORY FINDINGS OF SIGNIFICANCE
ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. Mandatory Findings of Significance.
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause
a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or
animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory?
b) Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects.)
c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly?
2.21.1 Discussion
a) Does the project have the potential to substantially degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish
or wildlife population to drop below self-sustaining levels, threaten to eliminate a
plant or animal community, substantially reduce the number or restrict the range of an
endangered, rare, or threatened species, or eliminate important examples of the
major periods of California history or prehistory?
Potentially significant. The project could affect sensitive species, sensitive communities, and protected wetlands, and interfere with wildlife species, however Midpen has previously adopted, and will implement, standard mitigation measures as part of the Preserve Master Plan and its various land management program that would reduce these
potential impacts to a less-than-significant level. Additional evaluation is necessary to determine whether the project with the proposed removal of the Redwood Cabin would result in substantial adverse effects to historic and archaeological resources. Impacts to cultural resources would be potentially significant and will be analyzed further in the EIR.
Exhibit A
Ascent Environmental Environmental Checklist
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 2-55
b) Does the project have impacts that are individually limited, but cumulatively
considerable? (“Cumulatively considerable” means that the incremental effects of a
project are considerable when viewed in connection with the effects of past projects,
the effects of other current projects, and the effects of probable future projects.)
Potentially significant. Generally, due to the limited scope of the project, implementation would not result in cumulatively considerable contributions to cumulative cultural and biological resource effects in the project area. Evaluation of the project’s contribution to cumulative impacts related to cultural and biological resources will be
evaluated once the project impacts are characterized in the EIR. This impact would be potentially significant, and this issue will be analyzed further in the EIR.
c) Does the project have environmental effects that will cause substantial adverse effects
on human beings, either directly or indirectly?
Less than significant. Effects on human beings associated with the project include air quality, hazards, and noise impacts. As described in this IS, impacts related noise would be less than significant because the County’s applicable
noise standards would not be exceeded at the nearest residential receptors and demolition activities would be exempt per Section 4.88.360 of the County Code. The project would be required to comply with existing laws and regulations regarding the transportation, use, and disposal of hazardous materials. Also as described in Chapter 2, “Project
Description,” of the accompanying EIR, a traffic control plan would be prepared to ensure the safety of Highway 35 road users. These actions would ensure that hazards impacts would be less than significant. Air quality impacts would be reduced to a less-than-significant level with the implementation of BMP AQ-1 to reduce emissions from construction activities. Therefore, this impact would be less than significant.
Exhibit A
Environmental Checklist Ascent Environmental
Midpeninsula Regional Open Space District 2-56 Redwood Cabin Removal Project Initial Study
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Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 3-1
3 REFERENCES
2.1 Aesthetics
Midpeninsula Regional Open Space District. 2012a. La Honda Creek Open Space Preserve Master Plan Initial
Study/Mitigated Negative Declaration. Available: https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf.
California Department of Transportation. 2018. California State Scenic Highway System Map. Available:
https://www.arcgis.com/home/webmap/viewer.html?url=http%3A%2F%2Fgisdata.dot.ca.gov%2Farcgis%2Frest%2Fservices%2FHighway%2FScenic_Highways%2FMapServer&source=sd. Accessed on June 23, 2021.
2.2 Agriculture and Forest Resources
Midpeninsula Regional Open Space District. 2012a. La Honda Creek Open Space Preserve Master Plan Initial Study/Mitigated Negative Declaration. Available:
https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf.
California Department of Conservation. 2021. Important Farmland Finder. Available:
https://www.conservation.ca.gov/dlrp/fmmp. Accessed August 6 2021.
San Mateo County. 2021. Planning and Building Map Viewer. General Plan Land Use Maps. Available online: https://gis.smcgov.org/Html5Viewer/Index.html?configBase=https://gis.smcgov.org/Geocortex/Essentials/REST/sites/publicplanning/viewers/HTML52110/virtualdirectory/Resources/Config/Default. Accessed August 6, 2021.
2.3 Air Quality
BAAQMD. See Bay Area Air Quality Management District.
Bay Area Air Quality Management District. 2017. CEQA Air Quality Guidelines. Available: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed July 22, 2021.
California Air Resources Board. 2003 (December). HARP User Guide. Sacramento, CA. Available:
https://www.arb.ca.gov/toxics/harp/harpug.htm. Accessed July 22, 2021.
———. 2013. California Almanac of Emissions and Air Quality—2013 Edition. Available:
https://www.arb.ca.gov/aqd/almanac/almanac13/almanac2013all.pdf. Accessed July 22, 2021.
———. 2018. Air Quality Standards and Area Designations Homepage. Page last reviewed June 12, 2018. Available:
https://ww3.arb.ca.gov/desig/desig.htm. Accessed July 22, 2021.
CARB. See California Air Resources Board.
EPA. See U.S. Environmental Protection Agency.
Office of Environmental Health Hazard Assessment. 2015. Risk Assessment Guidelines: Guidance Manual for
Preparation of Health Risk Assessments. Available: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed July 22, 2021.
OEHHA. See Office of Environmental Health Hazard Assessment.
U.S. Environmental Protection Agency. 2018. Criteria Air Pollutants Homepage. Last updated February 8, 2019.
Available: https://www.epa.gov/criteria-air-pollutants. Accessed July 22, 2021.
———. 2019. Current Nonattainment Counties for All Criteria Pollutants. Last Updated April 30, 2019. Available: https://www3.epa.gov/airquality/greenbook/ancl.html. Accessed July 22, 2021.
Exhibit A
References Ascent Environmental
Midpeninsula Regional Open Space District 3-2 Redwood Cabin Removal Project Initial Study
2.4 Biological Resources
Vollmar Natural Lands Consulting. 2020. Botanical Resources Survey Report.
H.T. Harvey and Associates. 2007 (March). Marbled Murrelet Habitat Assessment and Management
Recommendations Report.
Richard Seymour and Associates. 2007 (June). Report on 2006 Surveys for Sensitive Amphibian and Reptile Species
on Lands of the Midpeninsula Regional Open Space District.
Swaim Biological, Inc. 2019 (June). La Honda Creek Preserve, Sierra Azul Preserve, Purisima Uplands and Rancho San
Antonio Preserve – Structural Surveys for Special-Status Mammal Species.
2.5 Cultural Resources
Page & Turnbull. 2020 (March). La Honda Creek Redwood Cabin Historic Resource Evaluation Report.
2.6 Energy
Bureau of Transportation Statistics. 2017. Transportation Statistics Annual Report 2017. Available:
https://www.bts.dot.gov/sites/bts.dot.gov/files/docs/browse-statistical-products-and-data/transportation-statistics-annual-reports/215041/tsar-2017-rev-2-5-18-full-layout.pdf. Accessed July 22, 2021.
California Air Resources Board. 2017. California’s 2017 Climate Change Scoping Plan. Available:
https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/scoping_plan_2017.pdf?_. Accessed July 22, 2021.
California Energy Commission and California Air Resources Board. 2003 (August). Reducing California’s Petroleum Dependence. Available: https://www.arb.ca.gov/fuels/carefinery/ab2076final.pdf. Accessed July 22, 2021.
CARB. See California Air Resources Board.
CEC and CARB. See California Energy Commission and California Air Resources Board.
EIA. See U.S. Energy Information Administration.
National Highway Traffic Safety Administration and U.S. Environmental Protection Agency. 2020. Safer Affordable
Fuel-Efficient Vehicles Rule. Available: https://www.nhtsa.gov/corporate-average-fuel-economy/safe#:~:text=The%20Safer%20Affordable%20Fuel%2DEfficient%20(SAFE)%20Vehicles%20Rule%2C,model%20years%202021%20through%202026. Accessed July 22, 2021.
NHTSA and EPA. See National Highway Traffic Safety Administration and U.S. Environmental Protection Agency.
U.S. Energy Information Administration. 2021. California State Profile and Energy Estimates. Available: https://www.eia.gov/state/analysis.php?sid=CA#115. Accessed July 22, 2021.
2.7 Geology and Soils
Rowig Engineers. 2019 (October). Geotechnical Investigation for the Redwood Cabin Structural Stabilization. Prepared
for: ZFA Structural Engineers and the Midpeninsula Open Space District.
UC Museum of Paleontology. 2021. Specimen search. Available: https://ucmpdb.berkeley.edu/. Accessed August 13, 2021.
2.8 Greenhouse Gas Emissions
Bay Area Air Quality Management District. 2017. CEQA Air Quality Guidelines. Available: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-
pdf.pdf?la=en. Accessed July 22, 2021.
BAAQMD. See Bay Area Air Quality Management District.
Exhibit A
Ascent Environmental References
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 3-3
Black, Carolyn, Yohannes Tesfaigzi, Jed A. Bassein, and Lisa A. Miller. 2017. Wildfire Smoke Exposure and Human
Health: Significant Gaps in Research for a Growing Public Health Issue. Environmental Toxicology and Pharmacology. 55 pp. 186–195.
California Air Resources Board. 2017 (November). California’s 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Target. Available:
https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed July 22, 2021.
CARB. See California Air Resources Board.
Midpeninsula Regional Open Space District. 2019. 2018 Greenhouse Gas Inventory Report. Available:
https://www.openspace.org/sites/default/files/2018_Greenhouse_Gas_Inventory.pdf. Accessed August 5, 2021.
San Mateo County. 2013. Energy Efficiency Climate Action Plan. Available:
https://planning.smcgov.org/sites/planning.smcgov.org/files/documents/files/SanMateoCounty_EECAP_FINAL_06-04-2013.pdf. Accessed August 5, 2021.
Intergovernmental Panel on Climate Change. 2013. Chapter 6, Carbon and Other Biogeochemical Cycles. Pages 465–570 in Climate Change 2013: The Physical Science Basis. Working Group I Contribution to the Fifth
Assessment Report of the Intergovernmental Panel on Climate Change. Available: http://www.climatechange2013.org/images/report/WG1AR5_ALL_FINAL.pdf. Accessed July 22, 2021.
———. 2014. Climate Change 2014 Synthesis Report: Summary for Policymakers. Available: https://www.ipcc.ch/pdf/assessment-report/ar5/syr/AR5_SYR_FINAL_SPM.pdf. Accessed July 22, 2021.
IPCC. See Intergovernmental Panel on Climate Change.
State of California. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. Available: http://www.climateassessment.ca.gov/state/. Accessed August 5, 2021.
UN. See United Nations.
United Nations. 2015 (December 13). Historic Paris Agreement on Climate Change: 195 Nations Set Path to Keep Temperature Rise Well Below 2 Degrees Celsius. Available: https://unfccc.int/news/finale-cop21. Accessed
July 22, 2021.
2.9 Hazards and Hazardous Materials
ZFA. 2020 (March). Redwood Cabin Structure Stabilization Basis of Design.
DTSC 2021. Envirostor Database. Available : https://www.envirostor.dtsc.ca.gov/public/map/?global_id=38330005. Accessed on June 25, 2021.
SWRCB. See State Water Resources Control Board.
State Water Resources Control Board. 2021a. Geotracker Database. Available:
https://geotracker.waterboards.ca.gov/map/?myaddress=California&from=header&cqid=1458371818. Accessed on June 25, 2021.
State Water Resources Control Board. 2021b. Geotracker Database – Skywood Market. Available:
https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0608100502. Accessed on June 25, 2021.
State Water Resources Control Board. 2021c. Geotracker Database – Skylonda Corners. Available: https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0608100574. Accessed on June 25, 2021.
CAL FIRE 2021. Fire Hazard Severity Zone Viewer. Available: https://egis.fire.ca/FHSZ/. Accessed on June 25, 2021.
Exhibit A
References Ascent Environmental
Midpeninsula Regional Open Space District 3-4 Redwood Cabin Removal Project Initial Study
Midpeninsula Regional Open Space District. 2021. Wildland Fire Resiliency Program. Available:
https://www.openspace.org/our-work/projects/wfrp. Accessed May 20, 2021.
2.10 Hydrology and Water Quality
Midpeninsula Regional Open Space District. 2012a. La Honda Creek Open Space Preserve Master Plan Initial Study/Mitigated Negative Declaration. Available: https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf
Federal Emergency and Management Agency. 2021. FEMA’s National Flood Hazard Layer Viewer. Available: https://msc.fema.gov/nfhl. Accessed August 13, 2021.
2.11 Land Use and Planning
San Mateo County. 2021. Planning and Building Map Viewer. General Plan Land Use Maps. Available online: https://gis.smcgov.org/Html5Viewer/Index.html?configBase=https://gis.smcgov.org/Geocortex/Essentials/REST/
sites/publicplanning/viewers/HTML52110/virtualdirectory/Resources/Config/Default. Accessed August 6, 2021.
Midpeninsula Regional Open Space District. 2012a. La Honda Creek Open Space Preserve Master Plan Initial
Study/Mitigated Negative Declaration. Available: https://www.openspace.org/sites/default/files/20160629_LHC_IS_MND.pdf.
Midpeninsula Regional Open Space District. 2012b. La Honda Creek Open Space Preserve Master Plan. Available: https://www.openspace.org/sites/default/files/2012.08.21.LHCMP_.pdf.
2.12 Mineral Resources
California Department of Conservation. 2018. Mineral Land Classification Interactive Web Map. Available: https://maps.conservation.ca.gov/mineralresources/. Accessed August 2021.
2.13 Noise
California Department of Transportation. 2013 (September). Technical Noise Supplement. California Department of Transportation Division of Environmental Analysis. Sacramento, CA. Prepared by ICF Jones & Stokes,
Sacramento, CA.
Caltrans. See California Department of Transportation.
Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. Washington, DC. Available: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf. Accessed January 23, 2020.
FTA. See Federal Transit Administration.
2.14 Population and Housing
United States Census Bureau. 2019. American Community Survey Estimates: Table ID B01003. Available: https://data.census.gov/cedsci/table?q=Population,%20San%20Mateo%20County,%20CA&tid=ACSDT1Y2019
.B01003.
2.20 Wildfire
CAL FIRE 2021. Fire Hazard Severity Zone Viewer. Available: https://egis.fire.ca/FHSZ/. Accessed on June 25, 2021.
Midpeninsula Regional Open Space District. 2021. Wildland Fire Resiliency Program. Available: https://www.openspace.org/our-work/projects/wfrp. Accessed May 20, 2021.
Exhibit A
Midpeninsula Regional Open Space District Redwood Cabin Removal Project Initial Study 4-1
4 REPORT PREPARERS
Midpeninsula Regional Open Space District (Lead Agency)
Craig Beckman ........................................................................................................................................................... Skyline Area Manager
Paul Kvam ........................................................................................................................................................... Capital Project Manager III Jane Mark ............................................................................................................................................................................ Planning Manager Jared Hart .................................................................................................................................................................................. Senior Planner
Alex Casbara ...................................................................................................................................................................................... Planner III Melissa Borgesi .................................................................................................................................................................................. Planner II Coty Sifuentes-Winter ........................................................................................................... Senior Resource Management Specialist Matthew Sharp Chaney .................................................................................................................. Resource Management Specialist II
Ascent Environmental, Inc. (CEQA Compliance)
Mike Parker .......................................................................................................................................................................................... Principal Alta Cunningham ................................................................................................................................................................. Project Manager
Kirsten Burrowes ................................................................................................... Assistant Project Manager/Environmental Planner Masury Lynch .......................................................................................................................................................................... Noise Specialist
Richa Nanavati.......................................................................................................................................................... Environmental Planner Alyssa Way ......................................................................................................................................... Air Quality/Climate Change Analyst Lisa Merry ................................................................................................................................................. GIS Specialist/Resource Analyst
Brian Perry ............................................................................................................................................................................................ Graphics Michele Mattei ............................................................................................................................................................... Publishing Specialist
Exhibit A
Report Preparers Ascent Environmental
Midpeninsula Regional Open Space District 4-2 Redwood Cabin Removal Project Initial Study
This page intentionally left blank.
Exhibit A
Attachment A
Air Quality and Greenhouse Gas
Emissions Modeling Results
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
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MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
MidPen Redwood Cabin Demo
San Mateo County, Annual
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
User Defined Recreational 1.00 User Defined Unit 0.70 0.00 0
1.2 Other Project Characteristics
Urbanization
Rural
Wind Speed (m/s)
2.2
Precipitation Freq (Days)
70
Climate Zone
5
Operational Year
2025
Utility Company
Pacific Gas and Electric Company
CO2 Intensity
(lb/MWhr)
203.98
CH4 Intensity
(lb/MWhr)
0.033
N2O Intensity
(lb/MWhr)
0.004
1.3 User Entered Comments & Non-Default Data
Project Characteristics -
Land Use - Site acreage = 0.7
Construction Phase - 10 week construction timeframe
Trips and VMT - 8 workers; 2 trips/day for water trucks
On-road Fugitive Dust - No paved roads
Demolition -
Grading -
Construction Off-road Equipment Mitigation - BAAQMD BMPs
Off-road Equipment - Client provided equipment
Off-road Equipment - Client provided equipment
Table Name Column Name Default Value New Value
tblConstDustMitigation CleanPavedRoadPercentReduction 0 9
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
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Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
tblConstDustMitigation WaterUnpavedRoadMoistureContent 0 0.5
tblConstDustMitigation WaterUnpavedRoadVehicleSpeed 0 15
tblConstructionPhase NumDays 10.00 42.00
tblConstructionPhase NumDays 2.00 9.00
tblConstructionPhase NumDaysWeek 5.00 6.00
tblConstructionPhase NumDaysWeek 5.00 6.00
tblGrading AcresOfGrading 0.00 6.75
tblLandUse LotAcreage 0.00 0.70
tblOffRoadEquipment LoadFactor 0.38 0.38
tblOffRoadEquipment LoadFactor 0.31 0.31
tblOffRoadEquipment LoadFactor 0.37 0.37
tblOffRoadEquipment LoadFactor 0.20 0.20
tblOffRoadEquipment LoadFactor 0.29 0.29
tblOffRoadEquipment LoadFactor 0.38 0.38
tblOffRoadEquipment LoadFactor 0.31 0.31
tblOffRoadEquipment LoadFactor 0.37 0.37
tblOffRoadEquipment LoadFactor 0.29 0.29
tblOffRoadEquipment LoadFactor 0.20 0.20
tblOffRoadEquipment OffRoadEquipmentType Excavators
tblOffRoadEquipment OffRoadEquipmentType Aerial Lifts
tblOffRoadEquipment OffRoadEquipmentType Skid Steer Loaders
tblOffRoadEquipment OffRoadEquipmentType Forklifts
tblOffRoadEquipment OffRoadEquipmentType Cranes
tblOffRoadEquipment OffRoadEquipmentType Excavators
tblOffRoadEquipment OffRoadEquipmentType Aerial Lifts
tblOffRoadEquipment OffRoadEquipmentType Skid Steer Loaders
tblOffRoadEquipment OffRoadEquipmentType Cranes
tblOffRoadEquipment OffRoadEquipmentType Forklifts
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
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Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOnRoadDust HaulingPercentPave 100.00 0.00
tblOnRoadDust HaulingPercentPave 100.00 0.00
tblOnRoadDust VendorPercentPave 100.00 0.00
tblOnRoadDust VendorPercentPave 100.00 0.00
tblOnRoadDust WorkerPercentPave 100.00 0.00
tblOnRoadDust WorkerPercentPave 100.00 0.00
tblProjectCharacteristics UrbanizationLevel Urban Rural
tblTripsAndVMT HaulingTripLength 20.00 181.00
tblTripsAndVMT VendorTripNumber 0.00 2.00
tblTripsAndVMT VendorTripNumber 0.00 2.00
2.0 Emissions Summary
2.1 Overall Construction
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year
tons/yr MT/yr
2023 0.0207 0.2165 0.2592 5.1000e-
004 5.9646 8.7600e-
003 5.9734 0.5954 8.0600e-
003 0.6035 0.0000 45.0579 45.0579 0.0132 4.9000e-
004 45.5353
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 4 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Maximum 0.0207
0.2165
0.2592
5.1000e-
004
5.9646
8.7600e-
003
5.9734
0.5954
8.0600e-
003
0.6035
0.0000
45.0579
45.0579
0.0132
4.9000e-
004
45.5353
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year
tons/yr MT/yr
2023 0.0207 0.2165 0.2592 5.1000e-
004 3.6514 8.7600e-
003 3.6602 0.3641 8.0600e-
003 0.3721 0.0000 45.0579 45.0579 0.0132 4.9000e-
004 45.5352
Maximum 0.0207
0.2165
0.2592
5.1000e-
004
3.6514
8.7600e-
003
3.6602
0.3641
8.0600e-
003
0.3721
0.0000
45.0579
45.0579
0.0132
4.9000e-
004
45.5352
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction
0.00
0.00
0.00
0.00
38.78
0.00
38.73
38.86
0.00
38.34
0.00
0.00
0.00
0.00
0.00
0.00
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter)
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 5 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
1 9-25-2023 9-30-2023 0.0240 0.0240
Highest 0.0240 0.0240
2.2 Overall Operational
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Area 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
1.0000e-
005
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2.0000e-
005
2.0000e-
005
0.0000
0.0000
2.0000e-
005
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 6 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated Operational
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Area 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
1.0000e-
005
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2.0000e-
005
2.0000e-
005
0.0000
0.0000
2.0000e-
005
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3.0 Construction Detail
Construction Phase
Phase
Number Phase Name Phase Type Start Date End Date Num Days
Week Num Days Phase Description
1 Demolition Demolition 9/25/2023 11/11/2023 6 42
2 Grading Grading 11/13/2023 11/22/2023 6 9
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 7 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 6.75
Acres of Paving: 0
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating – sqft)
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Rubber Tired Dozers 0 1.00 247 0.40
Demolition Tractors/Loaders/Backhoes 0 6.00 97 0.37
Grading Graders 0 6.00 187 0.41
Grading Rubber Tired Dozers 0 6.00 247 0.40
Grading Tractors/Loaders/Backhoes 0 7.00 97 0.37
Demolition Excavators 1 8.00 158 0.38
Demolition Aerial Lifts 2 8.00 63 0.31
Demolition Skid Steer Loaders 1 8.00 65 0.37
Demolition Forklifts 1 8.00 89 0.20
Demolition Cranes 1 8.00 231 0.29
Grading Excavators 1 8.00 158 0.38
Grading Aerial Lifts 2 8.00 63 0.31
Grading Skid Steer Loaders 1 8.00 65 0.37
Grading Cranes 1 8.00 231 0.29
Grading Forklifts 1 8.00 89 0.20
Trips and VMT
Phase Name
Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 8 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Demolition
6
15.00
2.00
6.00
10.80
6.60
181.00
LD_Mix
HDT_Mix
HHDT
Grading
6
15.00
2.00
0.00
10.80
6.60
20.00
LD_Mix
HDT_Mix
HHDT
3.1 Mitigation Measures Construction
Water Exposed Area
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
3.2 Demolition - 2023
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Fugitive Dust 6.4000e-
004 0.0000 6.4000e-
004 1.0000e-
004 0.0000 1.0000e-
004 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0163 0.1729 0.2058 3.8000e-
004 7.1700e-
003 7.1700e-
003 6.6000e-
003 6.6000e-
003 0.0000 32.9496 32.9496 0.0107 0.0000 33.2161
Total 0.0163
0.1729
0.2058
3.8000e-
004
6.4000e-
004
7.1700e-
003
7.8100e-
003
1.0000e-
004
6.6000e-
003
6.7000e-
003
0.0000
32.9496
32.9496
0.0107
0.0000
33.2161
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 9 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Hauling 4.0000e-
005 3.8400e-
003 1.1100e-
003 2.0000e-
005 0.6460 3.0000e-
005 0.6460 0.0645 3.0000e-
005 0.0645 0.0000 1.7956 1.7956 1.8000e-
004 2.9000e-
004 1.8864
Vendor 4.0000e-
005 1.8300e-
003 6.7000e-
004 1.0000e-
005 0.3298 1.0000e-
005 0.3298 0.0329 1.0000e-
005 0.0329 0.0000 0.8120 0.8120 5.0000e-
005 1.2000e-
004 0.8490
Worker 6.8000e-
004 4.4000e-
004 6.1200e-
003 2.0000e-
005 4.0468 1.0000e-
005 4.0468 0.4039 1.0000e-
005 0.4039 0.0000 1.8662 1.8662 5.0000e-
005 5.0000e-
005 1.8811
Total 7.6000e-
004
6.1100e-
003
7.9000e-
003
5.0000e-
005
5.0226
5.0000e-
005
5.0226
0.5013
5.0000e-
005
0.5014
0.0000
4.4738
4.4738
2.8000e-
004
4.6000e-
004
4.6165
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Fugitive Dust 2.9000e-
004 0.0000 2.9000e-
004 4.0000e-
005 0.0000 4.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0163 0.1729 0.2058 3.8000e-
004 7.1700e-
003 7.1700e-
003 6.6000e-
003 6.6000e-
003 0.0000 32.9496 32.9496 0.0107 0.0000 33.2160
Total 0.0163
0.1729
0.2058
3.8000e-
004
2.9000e-
004
7.1700e-
003
7.4600e-
003
4.0000e-
005
6.6000e-
003
6.6400e-
003
0.0000
32.9496
32.9496
0.0107
0.0000
33.2160
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 10 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Hauling 4.0000e-
005 3.8400e-
003 1.1100e-
003 2.0000e-
005 0.3955 3.0000e-
005 0.3956 0.0395 3.0000e-
005 0.0395 0.0000 1.7956 1.7956 1.8000e-
004 2.9000e-
004 1.8864
Vendor 4.0000e-
005 1.8300e-
003 6.7000e-
004 1.0000e-
005 0.2019 1.0000e-
005 0.2020 0.0202 1.0000e-
005 0.0202 0.0000 0.8120 0.8120 5.0000e-
005 1.2000e-
004 0.8490
Worker 6.8000e-
004 4.4000e-
004 6.1200e-
003 2.0000e-
005 2.4778 1.0000e-
005 2.4778 0.2470 1.0000e-
005 0.2470 0.0000 1.8662 1.8662 5.0000e-
005 5.0000e-
005 1.8811
Total 7.6000e-
004
6.1100e-
003
7.9000e-
003
5.0000e-
005
3.0753
5.0000e-
005
3.0753
0.3066
5.0000e-
005
0.3067
0.0000
4.4738
4.4738
2.8000e-
004
4.6000e-
004
4.6165
3.3 Grading - 2023
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Fugitive Dust 3.5800e-
003 0.0000 3.5800e-
003 3.9000e-
004 0.0000 3.9000e-
004 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 3.4900e-
003 0.0371 0.0441 8.0000e-
005 1.5400e-
003 1.5400e-
003 1.4100e-
003 1.4100e-
003 0.0000 7.0606 7.0606 2.2800e-
003 0.0000 7.1177
Total 3.4900e-
003
0.0371
0.0441
8.0000e-
005
3.5800e-
003
1.5400e-
003
5.1200e-
003
3.9000e-
004
1.4100e-
003
1.8000e-
003
0.0000
7.0606
7.0606
2.2800e-
003
0.0000
7.1177
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 11 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 1.0000e-
005 3.9000e-
004 1.4000e-
004 0.0000 0.0707 0.0000 0.0707 7.0600e-
003 0.0000 7.0600e-
003 0.0000 0.1740 0.1740 1.0000e-
005 3.0000e-
005 0.1819
Worker 1.5000e-
004 1.0000e-
004 1.3100e-
003 0.0000 0.8672 0.0000 0.8672 0.0866 0.0000 0.0866 0.0000 0.3999 0.3999 1.0000e-
005 1.0000e-
005 0.4031
Total 1.6000e-
004
4.9000e-
004
1.4500e-
003
0.0000
0.9378
0.0000
0.9379
0.0936
0.0000
0.0936
0.0000
0.5739
0.5739
2.0000e-
005
4.0000e-
005
0.5850
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Fugitive Dust 1.6100e-
003 0.0000 1.6100e-
003 1.7000e-
004 0.0000 1.7000e-
004 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 3.4900e-
003 0.0371 0.0441 8.0000e-
005 1.5400e-
003 1.5400e-
003 1.4100e-
003 1.4100e-
003 0.0000 7.0606 7.0606 2.2800e-
003 0.0000 7.1177
Total 3.4900e-
003
0.0371
0.0441
8.0000e-
005
1.6100e-
003
1.5400e-
003
3.1500e-
003
1.7000e-
004
1.4100e-
003
1.5800e-
003
0.0000
7.0606
7.0606
2.2800e-
003
0.0000
7.1177
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 12 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 1.0000e-
005 3.9000e-
004 1.4000e-
004 0.0000 0.0433 0.0000 0.0433 4.3200e-
003 0.0000 4.3200e-
003 0.0000 0.1740 0.1740 1.0000e-
005 3.0000e-
005 0.1819
Worker 1.5000e-
004 1.0000e-
004 1.3100e-
003 0.0000 0.5310 0.0000 0.5310 0.0529 0.0000 0.0529 0.0000 0.3999 0.3999 1.0000e-
005 1.0000e-
005 0.4031
Total 1.6000e-
004
4.9000e-
004
1.4500e-
003
0.0000
0.5742
0.0000
0.5742
0.0573
0.0000
0.0573
0.0000
0.5739
0.5739
2.0000e-
005
4.0000e-
005
0.5850
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 13 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
User Defined Recreational 0.00 0.00 0.00
Total 0.00 0.00 0.00
4.3 Trip Type Information
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
User Defined Recreational
14.70
6.60
6.60
0.00
0.00
0.00
0
0
0
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
User Defined Recreational 0.465403 0.073585 0.235906 0.146720 0.025583 0.006412 0.010355 0.002060 0.001446 0.000572 0.028871 0.000432 0.002657
5.0 Energy Detail
Historical Energy Use: N
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 14 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
5.1 Mitigation Measures Energy
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Electricity
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Electricity
Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGas
Use ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use
kBTU/yr tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 15 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated
NaturalGas
Use ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use
kBTU/yr tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
5.3 Energy by Land Use - Electricity
Unmitigated
Electricity
Use Total
CO2 CH4 N2O CO2e
Land Use
kWh/yr tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 16 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated
Electricity
Use Total
CO2 CH4 N2O CO2e
Land Use
kWh/yr tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
6.0 Area Detail
6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Mitigated 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Unmitigated 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 17 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory
tons/yr MT/yr
Architectural
Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Total 0.0000
0.0000
1.0000e-
005
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2.0000e-
005
2.0000e-
005
0.0000
0.0000
2.0000e-
005
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 18 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated
ROG NOx CO SO2 Fugitive
PM10 Exhaust
PM10 PM10
Total Fugitive
PM2.5 Exhaust
PM2.5 PM2.5
Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory
tons/yr MT/yr
Architectural
Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0000 0.0000 1.0000e-
005 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e-
005 2.0000e-
005 0.0000 0.0000 2.0000e-
005
Total 0.0000
0.0000
1.0000e-
005
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
2.0000e-
005
2.0000e-
005
0.0000
0.0000
2.0000e-
005
7.0 Water Detail
7.1 Mitigation Measures Water
Total
CO2 CH4 N2O CO2e
Category
tons/yr MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 19 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
7.2 Water by Land Use
Unmitigated
Indoor/Outdoor
Use Total
CO2 CH4 N2O CO2e
Land Use
Mgal tons/yr MT/yr
User Defined
Recreational 0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 20 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
Mitigated
Indoor/Outdoor
Use Total
CO2 CH4 N2O CO2e
Land Use
Mgal tons/yr MT/yr
User Defined
Recreational 0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
8.0 Waste Detail
8.1 Mitigation Measures Waste
Category/Year
Total
CO2 CH4 N2O CO2e
tons/yr MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 21 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
8.2 Waste by Land Use
Unmitigated
Waste
Disposed Total
CO2 CH4 N2O CO2e
Land Use
tons tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
Mitigated
Waste
Disposed Total
CO2 CH4 N2O CO2e
Land Use
tons tons/yr MT/yr
User Defined
Recreational 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000
0.0000
0.0000
0.0000
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
Exhibit A
CalEEMod Version: CalEEMod.2020.4.0
Page 22 of 22
Date: 7/29/2021 9:48 AM
MidPen Redwood Cabin Demo - San Mateo County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
11.0 Vegetation
Exhibit A
Redwood Cabin Project Emissions Calculations
Total and Annual Emissions Summary - Construction - Unmitigated (for AQ and GHG Analysis)
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
Total 0.02 0.22 0.26 0.00 3.65 0.01 3.66 0.36 0.01 0.37 45.06 0.01 0.00 45.54
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
Total Onsite 0.02 0.21 0.25 0.00 0.00 0.01 0.01 0.00 0.01 0.01 40.01 0.01 0.00 40.33
Total Offsite 0.00 0.01 0.01 0.00 3.65 0.00 3.65 0.36 0.00 0.36 5.05 0.00 0.00 5.20
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
Total 2023 0.02 0.22 0.26 0.00 3.65 0.01 3.66 0.36 0.01 0.37 45.06 0.01 0.00 45.54
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
2023 Onsite 0.02 0.21 0.25 0.00 0.00 0.01 0.01 0.00 0.01 0.01 40.01 0.01 0.00 40.33
2023 Offsite 0.00 0.01 0.01 0.00 3.65 0.00 3.65 0.36 0.00 0.36 5.05 0.00 0.00 5.20
MT/year
tons/year MT/year
MTtons
tons MT
tons/year
Exhibit A
SUMMARY OF MODELING RESULTS
Demolition - 2023
Unmitigated Construction
Category ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
Fugitive Dust 0.0003 0.0000 0.0003 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0163 0.1729 0.2058 0.0004 0.0072 0.0072 0.0066 0.0066 32.9496 0.0107 0.0000 33.2160
Hauling 0.0000 0.0038 0.0011 0.0000 0.3955 0.0000 0.3956 0.0395 0.0000 0.0395 1.7956 0.0002 0.0003 1.8864
Vendor 0.0000 0.0018 0.0007 0.0000 0.2019 0.0000 0.2020 0.0202 0.0000 0.0202 0.8120 0.0001 0.0001 0.8490
Worker 0.0007 0.0004 0.0061 0.0000 2.4778 0.0000 2.4778 0.2470 0.0000 0.2470 1.8662 0.0001 0.0001 1.8811
Total 0.0171 0.1790 0.2137 0.0004 3.0755 0.0072 3.0829 0.3067 0.0067 0.3133 37.4234 0.0110 0.0005 37.8350
TOTAL ONSITE 0.0163 0.1729 0.2058 0.0004 0.0003 0.0072 0.0075 0.0000 0.0066 0.0066 32.9496 0.0107 0.0000 33.2160
TOTAL OFFSITE 0.0008 0.0061 0.0079 0.0001 3.0752 0.0001 3.0754 0.3067 0.0001 0.3067 4.4738 0.0003 0.0005 4.6165
Grading (Recontouring) - 2023
Unmitigated Construction
Category ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total CO2 CH4 N2O CO2e
Fugitive Dust 0.0016 0.0000 0.0016 0.0002 0.0000 0.0002 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0035 0.0371 0.0441 0.0001 0.0015 0.0015 0.0014 0.0014 7.0606 0.0023 0.0000 7.1177
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0004 0.0001 0.0000 0.0433 0.0000 0.0433 0.0043 0.0000 0.0043 0.1740 0.0000 0.0000 0.1819
Worker 0.0002 0.0001 0.0013 0.0000 0.5310 0.0000 0.5310 0.0529 0.0000 0.0529 0.3999 0.0000 0.0000 0.4031
Total 0.0037 0.0376 0.0456 0.0001 0.5759 0.0015 0.5775 0.0574 0.0014 0.0588 7.6345 0.0023 0.0000 7.7039
TOTAL ONSITE 0.0035 0.0371 0.0441 0.0001 0.0016 0.0015 0.0032 0.0002 0.0014 0.0016 7.0606 0.0023 0.0000 7.1177
TOTAL OFFSITE 0.0002 0.0005 0.0015 0.0000 0.5743 0.0000 0.5743 0.0572 0.0000 0.0572 0.5739 0.0000 0.0000 0.5850
MT/yrtons/yr
tons/yr MT/yr
Exhibit A
Average Daily Emissions Summary - Construction - Unmitigated
Construction Schedule
Start Date End Date Hours per
Day
2023 9/25/2023 11/22/2023 8
Total Working Days 9/25/2023 11/22/2023 8
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Average Daily Emissions
(Calculated from total
construction emissions)
0.96 10.07 12.06 0.02 169.83 0.41 170.25 16.94 0.37 17.31
BAAQMD Threshold 54 54 NA NA BMP 82 NA BMP 54 NA
Exceeds Threshold No No NA NA NA No NA NA No NA
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Total Onsite 0.92 9.77 11.62 0.02 0.09 0.41 0.49 0.01 0.37 0.38
Total Offsite 0.04 0.31 0.43 0.00 169.74 0.00 169.75 16.93 0.00 16.93
ROG NOx CO SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Total 2023 0.96 10.07 12.06 0.02 169.83 0.41 170.25 16.94 0.37 17.31
43
lb/day
Working Days
(5 Days per week)
43
Exhibit A
Greenhouse Gas Emissions Summary
Construction
Construction MT/yr
Unmitigated Const.
2023 46
Total Construction 46
Exhibit A
Attachment B
Energy Modeling Results
Exhibit A
Energy Calculations Summary
Construction Fuel Usage Summary
Diesel Gasoline Diesel Diesel
Construction
Year
Off-road
Equipment
(gallons)
On-road
(gallons)
On-road
(gallons)Combined
2023 2,146 207 181 2,327
Total Gasoline 207 gallons
Total Diesel 2,327 gallons
Exhibit A
2022 Construction Offroad Equipment
Phase Name Offroad
Equipment
Type
Amount Usage
Hours
Horse Power Load Factor Number of
days
Average Daily
Factor
Diesel Fuel
Usage Year Start Date End Date Network Days
Demolition Excavators 1 8.00 158 0.38 35 0.6 504 Demolition 2023 9/25/2023 11/11/2023 35
Demolition Aerial Lifts 2 8.00 63 0.31 35 0.6 328 Grading (Recontouring)2023 11/13/2023 11/22/2023 8
Demolition Skid Steer
Loaders
1 8.00 65 0.37 35 0.6 202
Demolition Forklifts 1 8.00 89 0.20 35 0.6 150
Demolition Cranes 1 8.00 231 0.29 35 0.6 563
Grading Excavators 1 8.00 158 0.38 8 0.6 115
Grading Aerial Lifts 2 8.00 63 0.31 8 0.6 75
Grading Skid Steer
Loaders
1 8.00 65 0.37 8 0.6 46
Grading Cranes 1 8.00 231 0.29 8 0.6 129
Grading Forklifts 1 8.00 89 0.20 8 0.6 34
TOTAL 2,146
Trips and VMT
2023
Phase Name Daily
Worker Trip
Days per
Year
Total
Worker
Trips
Total Vendor
Trips
Total
Hauling
Trips
Worker Trip
Length
(miles)
Vendor Trip
Length (miles)
Haul Trip
Length (miles)
Total
Worker Trip
Length
(miles)
Total Vendor
Trip Length
(miles)
Total Haul Trip
Length (miles)
Total gallons of gasoline Total
gallons of
diesel
Demolition 15 35 525 2 6 10.80 6.60 181.00 5670 13.2 1086 207 181
Grading
(Recontouring)
15 8 120 2 0 10.80 6.60 20.00 1296 13.2 0 47 2
TOTAL 207 181
Notes: Consistent with CalEEMod, worker vehicles assumed to be gasoline and 50% LDA, 25% LDT1, and 25% LDT2. Vendor and haul trips are assumed to be 100% diesel Heavy-Duty Trucks (T7).
Exhibit A
Source: EMFAC2021 (v1.0.1) Emissions Inventory
Region Type: County
Region: San Mateo
Calendar Year: 2023
Season: Annual
Vehicle Classification: EMFAC2011 Categories
Units: miles/day for CVMT and EVMT, trips/day for Trips, kWh/day for Energy Consumption, tons/day for Emissions, 1000 gallons/day for Fuel Consumption
Region CalYr VehClass MdlYr Speed Fuel Population VMT Trips Fuel gas Diesel gas
miles/hr vehicles miles/day trips/day 1,000 gallons/day 1,000 gallons/day
San Mateo 2023 LDA Aggregate Aggregate Gasoline 240378.7755 7727537.252 1129354.924 259.343852 0.00 29.80
San Mateo 2023 LDT1 Aggregate Aggregate Gasoline 24557.61445 732297.8125 111855.32 28.87343542 0.00 25.36
San Mateo 2023 LDT2 Aggregate Aggregate Gasoline 139222.3344 4716888.169 668266.1465 192.6175289 0.00 24.49
San Mateo 2023 T7 Tractor Aggregate Aggregate Diesel 173.2071705 13783.10051 2516.700187 0.00 2.267454612 6.08
Notes: Consistent with CalEEMod, worker vehicles assumed to be gasoline and 50% LDA, 25% LDT1, and 25% LDT2. Vendor and haul trips are assumed to be 100% diesel Heavy-Duty Trucks (T7).
Miles per
gallon
Gasoline miles per
gallon
Diesel miles per
gallon
27.36 6.08
Exhibit A
Attachment C
Noise Modeling Results
Exhibit A
Construction Source Noise Prediction Model
Location
Distance to
Nearest Receptor
in feet Equipment
Usage
Factor1
Crane 0.16
Single-family residences in the Tahoe Park East neighborhood 840 Excavator 0.4
Man Lift 0.2
Ground Type soft
Source Height 8
Receiver Height 5
Ground Factor2 0.63
Predicted Noise Level
Crane 77.0
Excavator 81.0
Man Lift 78.0
Sources:
1 Obtained from the FHWA Roadway Construction Noise Model, January 2006. Table 1.
2 Based on Table 4-26 from the Federal Transit Noise and Vibration Impact Assessment, 2018 (pg 86).
3 Based on the following from the Federal Transit Noise and Vibration Impact Assessment, 2018 (pg 176 and 177).
Leq(equip) = E.L.+10*log (U.F.) - 20*log (D/50) - 10*G*log (D/50)
Where: E.L. = Emission Level;
U.F.= Usage Factor;
G = Constant that accounts for topography and ground effects (FTA 2018: pg 86); and
D = Distance from source to receiver.
83.8
Reference Noise Levels
(Lmax) at 50 feet1
85
85
51.5
Combined Predicted
Noise Level (Leq dBA)
Combined Predicted Noise Level (Leq dBA at 50 feet)
Leq dBA at 50 feet3
85
Exhibit A
Construction Source Noise Prediction Model
Location
Distance to Nearest
Receptor in feet Equipment
Usage
Factor1
Crane 1
Phoenix Sacramento apartment complex 840 Excavator 1
Man Lift 1
Ground Type soft
Source Height 8
Receiver Height 5
Ground Factor2 0.63
Predicted Noise Level 3
Crane 85.0
Excavator 85.0
Man Lift 85.0
Sources:
1 Obtained from the FHWA Roadway Construction Noise Model, January 2006. Table 1.
2 Based on Table 4-26 from the Federal Transit Noise and Vibration Impact Assessment, 2018 (pg 86).
3 Based on the following from the Federal Transit Noise and Vibration Impact Assessment, 2018 (pg 176 and 177).
Leq(equip) = E.L.+10*log (U.F.) - 20*log (D/50) - 10*G*log (D/50)
Where: E.L. = Emission Level;
U.F.= Usage Factor;
G = Constant that accounts for topography and ground effects (FTA 2018: pg 86); and
D = Distance from source to receiver.
Combined Predicted Noise Level (Lmax dBA at 50 feet)
89.8
Leq dBA at 50 feet3
85
57.5 85
Combined Predicted
Noise Level (Lmax dBA)
Reference Emission Noise
Levels (Lmax) at 50 feet1
85
Exhibit A
Equipment
Description
Acoustical
Usage
Factor (%)
Spec
721.560
Lmax @
50ft (dBA
slow)
Actual
Measured
Lmax @
50ft
(dBA slow)
No. of
Actual Data
Samples
(count)
Spec
721.560
LmaxCalc
Spec
721.560
Leq
Distance
Actual
Measured
LmaxCalc
Actual
Measured
Leq
Auger Drill Rig 20 85 84 36 79.0 72.0 100 78.0 71.0
Backhoe 40 80 78 372 74.0 70.0 100 72.0 68.0
Bar Bender 20 80 na 0 74.0 67.0 100
Blasting na 94 na 0 88.0 100
Boring Jack Power Unit 50 80 83 1 74.0 71.0 100 77.0 74.0
Chain Saw 20 85 84 46 79.0 72.0 100 78.0 71.0
Clam Shovel (dropping)20 93 87 4 87.0 80.0 100 81.0 74.0
Compactor (ground)20 80 83 57 74.0 67.0 100 77.0 70.0
Compressor (air) 40 80 78 18 74.0 70.0 100 72.0 68.0
Concrete Batch Plant 15 83 na 0 77.0 68.7 100
Concrete Mixer Truck 40 85 79 40 79.0 75.0 100 73.0 69.0
Concrete Pump Truck 20 82 81 30 76.0 69.0 100 75.0 68.0
Concrete Saw 20 90 90 55 84.0 77.0 100 84.0 77.0
Crane 16 85 81 405 79.0 71.0 100 75.0 67.0
Dozer 40 85 82 55 79.0 75.0 100 76.0 72.0
Drill Rig Truck 20 84 79 22 78.0 71.0 100 73.0 66.0
Drum Mixer 50 80 80 1 74.0 71.0 100 74.0 71.0
Dump Truck 40 84 76 31 78.0 74.0 100 70.0 66.0
Excavator 40 85 81 170 79.0 75.0 100 75.0 71.0
Flat Bed Truck 40 84 74 4 78.0 74.0 100 68.0 64.0
Front End Loader 40 80 79 96 74.0 70.0 100 73.0 69.0
Generator 50 82 81 19 76.0 73.0 100 75.0 72.0
Generator (<25KVA, VMS signs)50 70 73 74 64.0 61.0 100 67.0 64.0
Gradall 40 85 83 70 79.0 75.0 100 77.0 73.0
Grader 40 85 na 0 79.0 75.0 100
Grapple (on Backhoe)40 85 87 1 79.0 75.0 100 81.0 77.0
Horizontal Boring Hydr. Jack 25 80 82 6 74.0 68.0 100 76.0 70.0
Hydra Break Ram 10 90 na 0 84.0 74.0 100
Impact Pile Driver 20 95 101 11 89.0 82.0 100 95.0 88.0
Jackhammer 20 85 89 133 79.0 72.0 100 83.0 76.0
Man Lift 20 85 75 23 79.0 72.0 100 69.0 62.0
Mounted Impact Hammer (hoe ram)20 90 90 212 84.0 77.0 100 84.0 77.0
Pavement Scarafier 20 85 90 2 79.0 72.0 100 84.0 77.0
Paver 50 85 77 9 79.0 76.0 100 71.0 68.0
Pickup Truck 40 55 75 1 49.0 45.0 100 69.0 65.0
Pneumatic Tools 50 85 85 90 79.0 76.0 100 79.0 76.0
Pumps 50 77 81 17 71.0 68.0 100 75.0 72.0
Refrigerator Unit 100 82 73 3 76.0 76.0 100 67.0 67.0
Rivit Buster/chipping gun 20 85 79 19 79.0 72.0 100 73.0 66.0
Rock Drill 20 85 81 3 79.0 72.0 100 75.0 68.0
Roller 20 85 80 16 79.0 72.0 100 74.0 67.0
Sand Blasting (Single Nozzle)20 85 96 9 79.0 72.0 100 90.0 83.0
Scraper 40 85 84 12 79.0 75.0 100 78.0 74.0
Shears (on backhoe)40 85 96 5 79.0 75.0 100 90.0 86.0
Slurry Plant 100 78 78 1 72.0 72.0 100 72.0 72.0
Slurry Trenching Machine 50 82 80 75 76.0 73.0 100 74.0 71.0
Soil Mix Drill Rig 50 80 na 0 74.0 71.0 100
Tractor 40 84 na 0 78.0 74.0 100
Vacuum Excavator (Vac-truck)40 85 85 149 79.0 75.0 100 79.0 75.0
Vacuum Street Sweeper 10 80 82 19 74.0 64.0 100 76.0 66.0
Ventilation Fan 100 85 79 13 79.0 79.0 100 73.0 73.0
Vibrating Hopper 50 85 87 1 79.0 76.0 100 81.0 78.0
Vibratory Concrete Mixer 20 80 80 1 74.0 67.0 100 74.0 67.0
Exhibit A
Equipment
Description
Acoustical
Usage
Factor (%)
Spec
721.560
Lmax @
50ft (dBA
slow)
Actual
Measured
Lmax @
50ft
(dBA slow)
No. of
Actual Data
Samples
(count)
Spec
721.560
LmaxCalc
Spec
721.560
Leq
Distance
Actual
Measured
LmaxCalc
Actual
Measured
Leq
Vibratory Pile Driver 20 95 101 44 89.0 82.0 100 95.0 88.0
Warning Horn 5 85 83 12 79.0 66.0 100 77.0 64.0
Welder / Torch 40 73 74 5 67.0 63.0 100 68.0 64.0
Source:
FHWA Roadway Construction Noise Model, January 2006. Table 9.1
U.S. Department of Transportation
CA/T Construction Spec. 721.560
Exhibit A
Appendix C
Special-Status Species Tables
Exhibit A
Methods
The species tables in this appendix were developed through a review of relevant databases and a botanical
resources survey report conducted for the project site (Vollmar 2020). CDFW’s California Natural Diversity Database (CNDDB) (CNDDB 2021) was reviewed for specific information on documented observations of
special-status species previously recorded in the IPM Program Area and vicinity. A search of the CNDDB and the California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants (CPNS 2021) was conducted for the following U.S. Geological Survey 7.5’ quadrangles surrounding the project site: Montara
Mountain, San Mateo, Redwood Point, Half Moon Bay, Woodside, Palo Alto, San Gregorio, La Honda, and Mindego Hill.
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
San Mateo thorn-
mint
Acanthomintha
duttonii
E E 1B.1
Chaparral, valley and foothill grassland.
Uncommon serpentinite vertisol clays; in
relatively open areas. 160–980 feet in elevation.
Blooms April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species. There are no
serpentine soils on the project site.
Blasdale's bent
grass
Agrostis blasdalei
1B.2
Coastal dunes, coastal bluff scrub, coastal
prairie. Sandy or gravelly soil close to rocks;
often in nutrient-poor soil with sparse
vegetation. 20–1,200 feet in elevation. Blooms
May–July.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Franciscan onion
Allium peninsulare
var. franciscanum
1B.2
Cismontane woodland, valley and foothill
grassland. Clay soils; often on serpentine;
sometimes on volcanics. Dry hillsides. 20–1,150
feet in elevation. Blooms May–June and as early
as April in some locations.
Not expected to occur: Although
suitable habitat for the species is
present within the preserve
(Vollmar2020), the north coast
coniferous forest that covers the
project site does not provide habitat
for this species.
Bent-flowered
fiddleneck
Amsinckia lunaris
1B.2
Cismontane woodland, valley and foothill
grassland, coastal bluff scrub. 10–2,600 feet in
elevation. Blooms March–June.
Not expected to occur: Although
suitable habitat for the species is
present within the preserve
(Vollmar2020), the north coast
coniferous forest that covers the
project site does not provide habitat
for this species.
Anderson's
manzanita
Arctostaphylos
andersonii
1B.2
Broadleaved upland forest, chaparral, north
coast coniferous forest. Open sites, redwood
forest. 200–2,500 feet in elevation. Blooms
November–May.
Not expected to occur: Suitable
habitat for this species is found within
the preserve (Vollmar 2020); however,
the north coast coniferous forest that
covers the project site does not
contain sufficient openings to provide
habitat for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Montara manzanita
Arctostaphylos
montaraensis
1B.2 Chaparral, coastal scrub. Slopes and ridges. 900–
1,510 feet in elevation. Blooms January–March.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Kings Mountain
manzanita
Arctostaphylos
regismontana
1B.2
Broadleaved upland forest, chaparral, north
coast coniferous forest. Granitic or sandstone
outcrops. 790–2,310 feet in elevation. Blooms
December–April.
Not expected to occur: The species is
documented to occur within the
preserve and north coast coniferous
forest is suitable habitat for the
species (Vollmar 2020); however, the
north coast coniferous forest that
covers the project site does not
contain sufficient openings to provide
habitat for this species.
Coastal marsh milk-
vetch
Astragalus
pycnostachyus var.
pycnostachyus
1B.2
Coastal dunes,marshes and swamps, coastal
scrub. Mesic sites in dunes or along streams or
coastal salt marshes. 0–510 feet in elevation.
Blooms April–October.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Brewer’s
calandrinia
Calandrinia breweri
4.2
Coastal scrub, disturbed sites and burns on
sandy or loamy soils. 30 – 4,000 feet in
elevation. Blooms March – June and as early as
January in some locations.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Congdon's tarplant
Centromadia parryi
ssp. congdonii
1B.1
Valley and foothill grassland. Alkaline soils,
sometimes described as heavy white clay. 0–760
feet in elevation. Blooms May–October and as
late as November in some locations.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Pappose tarplant
Centromadia parryi
ssp. parryi
1B.2
Chaparral, coastal prairie, meadows and seeps,
coastal salt marsh, valley and foothill grassland.
Vernally mesic, often alkaline sites. 7–1378 feet
in elevation. Blooms May–November.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Point Reyes salty
bird's-beak
Chloropyron
maritimum ssp.
palustre
1B.2
Usually in coastal salt marsh with Salicornia,
Distichlis, Jaumea, Spartina, etc. 0–375 feet in
elevation. Blooms June–October.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
San Francisco Bay
spineflower
Chorizanthe
cuspidata var.
cuspidata
1B.2
Coastal bluff scrub, coastal dunes, coastal
prairie, coastal scrub. Closely related to C.
pungens. Sandy soil on terraces and slopes. 10–
705 feet in elevation. Blooms April–July (August).
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Franciscan thistle
Cirsium andrewsii 1B.2
Coastal bluff scrub, broadleaved upland forest,
coastal scrub, coastal prairie. Serpentine seeps.
0–490 feet in elevation. Blooms March–July.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Santa Clara red
ribbons
Clarkia concinna
ssp. automixa
4.3
Chaparral and cismontane Woodland. 300 –
4,920 feet in elevation. Blooms as early as April
and as late as July in some locations, but
primarily May - June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Crystal Fountain
thistle
Cirsium fontinales
var. fontinale
E E 1B.1
Valley and foothill grassland, chaparral,
cismontane woodland, meadows and seeps,
ultramafic, wetland. Serpentine seeps and
grassland. 150–610 feet in elevation. Blooms
(April), May–October.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Lost thistle
Cirsium praeteriens 1A
Little information exists on this plant; it was
collected from the Palo Alto area at the turn of
the 20th Century. Although not seen since 1901,
this Cirsium is thought to be quite distinct from
other Cirsiums acc. to D. Keil. 0–330 feet in
elevation. Blooms June–July.
Not expected to occur: The species
has not been recorded since 1901.
The north coast coniferous forest that
covers the project site does not
provide habitat for this species.
Santa Clara red
ribbons Clarkia
concinna ssp.
automixa
4.3
Cismontane woodland, chaparral. On slopes and
near drainages. 300–4,920 feet in elevation.
Blooms (April), May–June (July).
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Round-headed
Chinese-houses
Collinsia corymbosa
1B.2 Coastal dunes. 30–100 feet in elevation. Blooms
April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
San Francisco
collinsia
Collinsia multicolor
1B.2
Closed-cone coniferous forest, coastal scrub. On
decomposed shale (mudstone) mixed with
humus; sometimes on serpentine. 100–820 feet
in elevation. Blooms (February), March–May.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Western
leatherwood
Dirca occidentalis
1B.2
Broadleafed upland forest, chaparral, closed-
cone coniferous forest, cismontane woodland,
north coast coniferous forest, riparian forest,
riparian woodland. On brushy slopes, mesic
sites; mostly in mixed evergreen and foothill
woodland communities. 80–1,390 feet in
elevation. Blooms January–March (April).
Could occur: Documented to occur
within the preserve and suitable north
coast coniferous forest habitat is
present within the project site.
California bottle-
brush grass
Elymus californicus
4.2
Broadleaf upland forest, cismontane woodland,
north coast coniferous forest, and riparian
woodland. 50-1,540 feet. Blooms May-August
(November).
Could occur: Suitable north coast
coniferous forest habitat is present
within the project site.
San Mateo woolly
sunflower
Eriophyllum
latilobum
E E 1B.1
Cismontane woodland, coastal scrub, lower
montane coniferous forest. Often on roadcuts;
found on and off of serpentine. 98–2,000 feet in
elevation. Blooms May–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Hoover's button-
celery Eryngium
aristulatum var.
hooveri
1B.1
Vernal pools, wetland. Alkaline depressions,
vernal pools, roadside ditches and other wet
places near the coast. 0–160 feet in elevation.
Blooms June -August.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Jepson's coyote-
thistle
Eryngium jepsonii
1B.2 Vernal pools, valley and foothill grassland. Clay.
10–980 feet in elevation. Blooms April–August.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Minute pocket
moss
Fissidens
pauperculus
1B.2
North coast redwood forest. Moss growing on
damp soil along the coast. In dry streambeds and
on stream banks. 30–3,360 feet in elevation.
Could occur: Suitable north coast
coniferous forest and stream habitat
for minute pocket moss occurs within
project site.
Hillsborough
chocolate lily
Fritillaria biflora
var. ineziana
1B.1
Cismontane woodland, valley and foothill
grassland. Probably only on serpentine; most
recent site is in serpentine grassland. 300–530
feet in elevation. Blooms March–April.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Fragrant fritillary
Fritillaria liliacea 1B.2
Coastal scrub, valley and foothill grassland,
coastal prairie, cismontane woodland. Often on
serpentine; various soils reported though usually
on clay, in grassland. 10–1,300 feet in elevation.
Blooms February–April.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
San Francisco
gumplant Grindelia
hirsutula var.
maritima
3.2
Coastal scrub, coastal bluff scrub, valley and
foothill grassland. Sandy or serpentine slopes,
sea bluffs. 50–1,000 feet in elevation. Blooms
June–September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Short-leaved evax
Hesperevax
sparsiflora var.
brevifolia
1B.2
Coastal bluff scrub, coastal dunes, coastal
prairie. Sandy bluffs and flats. 0–700 feet in
elevation. Blooms March–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Marin western flax
Hesperolinon
congestum
T T 1B.1
Chaparral, valley and foothill grassland. In
serpentine barrens and in serpentine grassland
and chaparral. 200–1,210 feet in elevation.
Blooms April–July.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Kellogg's horkelia
Horkelia cuneata
var. sericea
1B.1
Closed-cone coniferous forest, coastal scrub,
coastal dunes, chaparral. Old dunes, coastal
sandhills; openings. 20–700 feet in elevation.
Blooms April–September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not contain sufficient
openings to provide habitat for this
species.
Point Reyes
horkelia
Horkelia marinensis
1B.2
Coastal dunes, coastal prairie, coastal scrub.
Sandy flats and dunes near coast; in grassland or
scrub plant communities. 10–2,540 feet in
elevation. Blooms May–September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Harlequin lotus
Hosackia gracilis 4.2
Broadleaf upland forest, coastal bluff scrub,
closed-cone coniferous forest, cismontane
woodland, coastal prairie, coastal scrub,
meadows and seeps, marshes and swamps,
north coast coniferous forest, and valley and
foothill grassland. 0-2,300 feet in elevation.
Blooms March – July.
Could occur: Suitable north coast
coniferous forest habitat is present
within the project site.
Island tube lichen
Hypogymnia
schizidiata
1B.3
Chaparral, closed-cone coniferous forest. On
bark and wood of hardwoods and conifers.
1,180–1,330 feet in elevation.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Coast Iris
Iris longipetala 4.2
Coastal prairie. Lower montane coniferous
forest, meadows and seeps. 0-1,970 feet in
elevation.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Perennial goldfields
Lasthenia
californica ssp.
macrantha
1B.2
Coastal bluff scrub, coastal dunes, coastal scrub.
20–610 feet in elevation. Blooms January–
November.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Legenere Legenere
limosa 1B.1 Vernal pools, wetland. In beds of vernal pools.
0–2,890 feet in elevation. Blooms April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Coast yellow
leptosiphon
Leptosiphon
croceus
SC 1B.1 Coastal bluff scrub, coastal prairie. 30–490 feet
in elevation. Blooms April–May.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Rose leptosiphon
Leptosiphon
rosaceus
1B.1 Coastal bluff scrub. 30–460 feet in elevation.
Blooms April–July.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Crystal Springs
lessingia Lessingia
arachnoidea
1B.2
Coastal sage scrub, valley and foothill grassland,
cismontane woodland. Grassy slopes on
serpentine; sometimes on roadsides. 300–660
feet in elevation. Blooms July–October.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Ornduff's
meadowfoam
Limnanthes
douglasii ssp.
ornduffii
1B.1 Meadows and seeps, agricultural fields. 30–70
feet in elevation. Blooms November–May.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Arcuate bush-
mallow
Malacothamnus
arcuatus
1B.2
Chaparral, cismontane woodland. Gravelly
alluvium. 0–2,410 feet in elevation. Blooms
April–September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide sufficient
open habitat for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Marsh microseris
Microseris paludosa 1B.2
Closed-cone coniferous forest, cismontane
woodland, coastal scrub, valley and foothill
grassland. 20–980 feet in elevation. Blooms
April–June and as late as July in some locations.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Woodland
woollythreads
Monolopia
gracilens
1B.2
Chaparral, valley and foothill grassland,
cismontane woodland, broadleafed upland
forest, north coast coniferous forest. Grassy
sites, in openings; sandy to rocky soils. Often
seen on serpentine after burns but may have
only weak affinity to serpentine. 330–3,940 feet
in elevation. Blooms March–July and as early as
February in some locations.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not contain sufficient
openings to provide habitat for this
species.
Dudley's lousewort
Pedicularis dudleyi 1B.2
Chaparral, north coast coniferous forest, valley
and foothill grassland. Deep shady woods of
older coast redwood forests; also, in maritime
chaparral. 200–2,950 feet in elevation. Blooms
April–June.
Could occur: Suitable north coast
coniferous forest habitat for Dudley's
lousewort occurs within project site.
White-rayed
pentachaeta
Pentachaeta
bellidiflora
E E 1B.1
Valley and foothill grassland, cismontane
woodland. Open dry rocky slopes and grassy
areas, often on soils derived from serpentine
bedrock. 120–2,000 feet in elevation. Blooms
March–May.
Not expected to occur: The north
coast coniferous forest that covers the
project ste does not provide habitat
for this species.
White-flowered
rein orchid
Piperia candida
1B.2
North coast coniferous forest, lower montane
coniferous forest, broadleafed upland forest.
Sometimes on serpentine. Forest duff, mossy
banks, rock outcrops, and muskeg. 150–5,300
feet in elevation. Blooms May–September and as
early as March in some locations.
Could occur: Suitable north coast
coniferous forest and stream habitat
for White-flowered rein orchid occurs
within project site.
Choris'
popcornflower
Plagiobothrys
chorisianus var.
chorisianus
1B.2
Chaparral, coastal scrub, coastal prairie. Mesic
sites. 50–525 feet in elevation. Blooms March–
June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Oregon
polemonium
Polemonium
carneum
2B.2
Coastal prairie, coastal scrub, lower montane
coniferous forest. 0–6,000 feet in elevation.
Blooms April–September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Hickman's
cinquefoil Potentilla
hickmanii
E E 1B.1
Coastal bluff scrub, closed-cone coniferous
forest, meadows and seeps, marshes and
swamps. Freshwater marshes, seeps, and small
streams in open or forested areas along the
coast. 20–410 feet in elevation. Blooms April–
August.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Chaparral ragwort
Senecio aphanactis 2B.2
Chaparral, cismontane woodland, coastal scrub.
Drying alkaline flats. 70–2,810 feet in elevation.
Blooms January–April and as late as May in some
locations.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Scouler's catchfly
Silene scouleri ssp.
scouleri
2B.2
Coastal bluff scrub, coastal prairie, valley and
foothill grassland. 0–1,9670 feet in elevation.
Blooms as early as March–May in some
locations. In most locations blooms June–August
and sometimes as late as September.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
San Francisco
campion
Silene verecunda
ssp. verecunda
1B.2
Coastal scrub, valley and foothill grassland,
coastal bluff scrub, chaparral, coastal prairie.
Often on mudstone or shale; one site on
serpentine. 100–2,120 feet in elevation. Blooms
March–June; although, may bloom as early as
February and as late as August.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Slender-leaved
pondweed
Stuckenia filiformis
ssp. alpina
2B.2
Marshes and swamps. Shallow, clear water of
lakes and drainage channels. 980–7,050 feet in
elevation. Blooms May–July.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Two-fork clover
Trifolium amoenum E 1B.1
Valley and foothill grassland, coastal bluff scrub.
Sometimes on serpentine soil, open sunny sites,
swales. Most recently cited on roadside and
eroding cliff face. 20–1,020feet in elevation.
Blooms April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Santa Cruz clover
Trifolium
buckwestiorum
1B.1
Coastal prairie, broadleafed upland forest,
cismontane woodland. Moist grassland. Gravelly
margins. 340–2,000 feet in elevation. Blooms
April–October.
Not expected to occur: The preserve
does contain suitable habitat for this
species; however, the north coast
coniferous forest that covers the
project site does not provide habitat
for this species.
Saline clover
Trifolium
hydrophilum
1B.2
Marshes and swamps, valley and foothill
grassland, vernal pools. Mesic, alkaline sites. 0–
980 feet in elevation. Blooms April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
San Francisco owl's-
clover Triphysaria
floribunda
1B.2
Coastal prairie, coastal scrub, valley and foothill
grassland. On serpentine and non-serpentine
substrate (such as at Pt. Reyes). 5–490 feet in
elevation. Blooms April–June.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Coastal triquetrella
Triquetrella
californica
1B.2
Coastal bluff scrub, coastal scrub. Grows within
30m from the coast in coastal scrub, grasslands
and in open gravels on roadsides, hillsides, rocky
slopes, and fields. On gravel or thin soil over
outcrops. 30–330 feet in elevation.
Not expected to occur: The north
coast coniferous forest that covers the
project site does not provide habitat
for this species.
Exhibit A
Table A-1 Special-Status Botanical Species Known to Occur in the Project Region and their Potential for Occurrence
in the Redwood Cabin Project site
Species Status 1 Habitat and Blooming Period Potential for Occurrence 2 Federal State CRPR
Methuselah's beard
lichen Usnea
longissima
4.2
Old growth redwood forest, broadleafed upland
forest. Grows in the "redwood zone" on tree
branches of a variety of trees, including big leaf
maple, oaks, ash, Douglas fir, and bay. 150–
4,800 feet in elevation.
Could occur: Suitable north coast
coniferous forest habitat for
Methuselah’s beard occurs within
project site.
Notes: CRPR = California Rare Plant Rank; CNPS California Native Plant Society; ESA = Federal Endangered Species Act; CESA = California Endangered Species Act;
1 Legal Status Definitions
Federal :
E Endangered (legally protected by ESA)
T Threatened (legally protected by ESA)
C Candidate (legally protected by ESA)
State:
E Endangered (legally protected by CESA)
T Threatened (legally protected by CESA)
California Rare Plant Ranks:
1B Plant species considered rare or endangered in California and elsewhere
(protected under CEQA, but not legally protected under ESA or CESA)
2 Plant species considered rare or endangered in California but more common
elsewhere (protected under CEQA, but not legally protected under ESA or CESA)
3 Plants about which more information is needed (a review list) (may be protected
under CEQA, but not legally protected under ESA or CESA)
4 Plants of limited distribution (a watch list) (may be protected under CEQA, but not
legally protected under ESA or CESA)
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)
2 Potential for Occurrence Definitions
Not expected to occur: Species is unlikely to be present on the project site due to poor habitat quality, lack of suitable habitat features, or restricted current distribution of
the species.
Could occur: Suitable habitat is available at the project site; however, there are little to no other indicators that the species might be present.
Known to occur: The species, or evidence of its presence, was observed at the project site during reconnaissance surveys, or was reported by others.
Sources: CNPS 2021; Vollmar 2020.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
Invertebrates
Bay checkerspot
butterfly
Euphydryas
editha bayensis
T
Coastal dunes, ultramafic, valley and foothill grassland.
Restricted to native grasslands on outcrops of serpentine soil in
the vicinity of San Francisco Bay. Plantago erecta is the primary
host plant; Orthocarpus densiflorus and O. purpurscens are the
secondary host plants.
Not expected to occur: The project
site does not contain suitable
serpentine grassland habitat for Bay
checkerspot butterfly. Not
documented to occur in the Santa
Cruz Mountain portions of San
Mateo or Santa Clara Counties
(CNDDB 2021).
Crotch bumble
bee
Bombus crotchii
S1S2*
Coastal California east to the Sierra-Cascade crest and south
into Mexico in grassland and woodland habitats. Food plant
genera include Antirrhinum, Phacelia, Clarkia, Dendromecon,
Eschscholzia, and Eriogonum.
Not expected to occur: The project
site does not contain suitable
grassland and woodland habitat
with sufficient nectar resources for
the Crotch bumblebee.
Mission blue
butterfly Plebejus
icarioides
missionensis
E
Coastal prairie. Inhabits grasslands of the San Francisco
peninsula. Three larval host plants: Lupinus albifrons, L.
variicolor, and L. formosus, of which L. albifrons is favored.
Not expected to occur: The project
site does not contain suitable
grassland habitat for the mission
blue butterfly.
Monarch -
California
overwintering
population
Danaus plexippus
C
Winter roost sites extend along the coast from northern
Mendocino to Baja California, Mexico. Roosts located in wind-
protected tree groves (eucalyptus, Monterey pine, cypress),
with nectar and water sources nearby.
Not expected to occur:
Overwintering roost sites for
monarchs are found an average of
1.5 miles from the coast, which
makes it unlikely that the species
overwinters in the project site.
Myrtle's
silverspot
butterfly
Speyeria zerene
myrtleae
E
Coastal dunes. Restricted to the foggy, coastal dunes/hills of the
Point Reyes peninsula; extirpated from coastal San Mateo
County. Larval foodplant thought to be Viola adunca.
Not expected to occur: The project
site does not contain suitable
coastal habitat for Myrtle’s
silverspot butterfly. Extirpated from
coastal San Mateo County
San Bruno elfin
butterfly
Callophrys mossii
bayensis
E
Valley and foothill grassland. Coastal, mountainous areas with
grassy ground cover, mainly in the vicinity of San Bruno
Mountain, San Mateo County. Colonies are located on steep,
north-facing slopes within the fog belt. Larval host plant is
Sedum spathulifolium.
Not expected to occur: The project
site does not contain suitable
grassland habitat for San Bruno elfin
butterfly. Project is outside of the
range of the species which is
restricted to Northern San Mateo
County.
western bumble
bee Bombus
occidentalis
S1S2*
Meadows and grasslands with nectar and pollen from floral
resources throughout the duration of the colony period (spring,
summer, and fall), and suitable overwintering sites for the
queens.
Not expected to occur: The project
site does not contain suitable
grassland and woodland habitat
with sufficient nectar resources for
the species.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
Fish
Longfin smelt
Spirinchus
thaleichthys
C SC
Found in open waters of estuaries, mostly in middle or bottom
of water column. Prefer salinities of 15-30 ppt, but can be found
in completely freshwater to almost pure seawater.
Not expected to occur: The project
site does not contain the estuary
habitat suitable for this species.
Coho Salmon-
Central CA Coast
ESU
Oncorhynchus
kisutch
E E
Clear, cool, perennial sections of relatively undisturbed low
gradient streams, with high dissolved oxygen levels. Prefer
streams with dense canopy over without rooted or aquatic
vegetation. Require stream temperatures between 40 degrees
and 58 degrees F. Gravel substrates are needed for spawning
habitat.
Not expected to Occur: La Honda
Creek adjacent to the project site is
above a total barrier that prevents
passage upstream by salmon (CDFW
2021).
Steelhead -
central California
coast DPS
Oncorhynchus
mykiss irideus
pop. 8
T
Clear, cool, perennial sections of relatively undisturbed low
gradient streams, with high dissolved oxygen levels. Prefer
streams with dense canopy over without rooted or aquatic
vegetation. Require stream temperatures between 40 degrees
and 58 degrees F. Gravel substrates are needed for spawning
habitat. Rearing habitat contains pools formed by logjams and
loose woody debris.
Not expected to Occur: La Honda
Creek adjacent to the project site is
above a total barrier that prevents
passage upstream by steelhead
(CDFW 2021).
Tidewater goby
Eucyclogobius
newberryi
E SC
Brackish water habitats along the California coast from Agua
Hedionda Lagoon, San Diego County to the mouth of the Smith
River. Found in shallow lagoons and lower stream reaches, they
need fairly still but not stagnant water and high oxygen levels.
Not expected to occur: The project
site does not contain the lagoon and
lower stream reaches that are
suitable for this species.
Amphibians and Reptiles
California giant
salamander
Dicamptodon
ensatus
SC
Known from wet coastal forests near streams and seeps from
Mendocino County south to Monterey County and east to Napa
County. Aquatic larvae found in cold, clear streams, occasionally
in lakes and ponds. Adults known from wet forests under rocks
and logs near streams and lakes.
Could Occur: La Honda Creek
adjacent to the project site could
support California giant salamander
and the project site itself could
provide upland habitat for the
species. Species is known to occur
on the preserve (CNDDB 2021).
California red-
legged frog Rana
draytonii
T SC
Found in artificial flowing waters, artificial standing waters,
freshwater marsh, marsh and swamp, riparian forest, riparian
scrub, riparian woodland, Sacramento/San Joaquin flowing
waters, Sacramento/San Joaquin standing waters, and south
coast flowing waters. Lowlands and foothills in or near
permanent sources of deep water with dense, shrubby or
emergent riparian vegetation. Requires 11-20 weeks of
permanent water for larval development. Must have access to
estivation habitat.
Could Occur: Suitable aquatic and
upland habitat present in the
project site. Documented to occur
on the preserve in multiple
locations (CNDDB 2021). The project
is located within designated critical
habitat for the species.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
California tiger
salamander
Ambystoma
californiense
T T
Cismontane woodland, meadow and seep, riparian woodland,
valley and foothill grassland, vernal pool, and wetlands. Central
Valley DPS federally listed as threatened. Santa Barbara and
Sonoma counties DPS federally listed as endangered. Need
underground refuges, especially ground squirrel burrows, and
vernal pools or other seasonal water sources for breeding.
Not expected to occur: The project
site does not contain suitable
woodland and grassland habitat for
California tiger salamander. Not
documented to occur in the Santa
Cruz Mountain portions of San
Mateo or Santa Clara Counties
(CNDDB 2021).
foothill yellow-
legged frog Rana
boylii
CE
Aquatic, chaparral, cismontane woodland, coastal scrub,
Klamath/north coast flowing waters, lower montane coniferous
forest, meadow and seep, riparian forest, riparian woodland,
and Sacramento/San Joaquin flowing waters. Partly-shaded,
shallow streams and riffles with a rocky substrate in a variety of
habitats. Need at least some cobble-sized substrate for egg-
laying. Need at least 15 weeks to attain metamorphosis.
Not expected to occur: La Honda
Creek adjacent to the project site is
potentially suitable habitat for this
species. However, foothill yellow-
legged frog has not been detected
within the San Gregorio Creek/La
Honda Creek drainage since 1951
(CNDDB 2021), and surveys
conducted on the preserve
concluded that the species is not
likely to be present (MidPen 2012).
Red-bellied newt
Taricha rivularis SC
Broadleaved upland forest, north coast coniferous forest,
redwood, riparian forest, and riparian woodland. Coastal
drainages from Humboldt County south to Sonoma County,
inland to Lake County. Isolated population of uncertain origin in
Santa Clara County. Lives in terrestrial habitats, juveniles
generally underground, adults active at surface in moist
environments. Will migrate over 1 km to breed, typically in
streams with moderate flow and clean rocky substrate.
Not expected to occur: Occurrences
south of Sonoma County are
isolated within the drainage of
Steven’s Creek approximately 9
miles south of the project site
(CNDDB 2021).
San Francisco
gartersnake
Thamnophis
sirtalis
tetrataenia
E E FP
Artificial standing waters, marsh and swamp, Sacramento/San
Joaquin standing waters, wetland. Vicinity of freshwater
marshes, ponds and slow-moving streams in San Mateo County
and extreme northern Santa Cruz County. Prefers dense cover
and water depths of at least one foot. Upland areas near water
are also very important.
Not expected to occur: La Honda
Creek within the project site does
not contain the deep, slow-moving
stream, marsh, or pond habitat with
dense vegetation need for this
species. The nearest suitable
aquatic habitat is greater than 0.25
mile from the project site;
therefore, the site is not suitable
upland habitat for the species.
Santa Cruz black
salamander
Aneides niger
SC
Mixed deciduous and coniferous woodlands and coastal
grasslands in San Mateo, Santa Cruz, and Santa Clara counties.
Adults found under rocks, talus, and damp woody debris.
Could Occur. Suitable habitat is
present within the project site for
this species, and the project site is
within the range of the species.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
western pond
turtle
Actinemys
marmorata
SC
Aquatic, artificial flowing waters, Klamath/north coast flowing
waters, Klamath/north coast standing waters, marsh and
swamp, Sacramento/San Joaquin flowing waters,
Sacramento/San Joaquin standing waters, South coast flowing
and standing waters. A thoroughly aquatic turtle of ponds,
marshes, rivers, streams and irrigation ditches, usually with
aquatic vegetation, below 6,000 feet elevation. Need basking
sites and suitable (sandy banks or grassy open fields) upland
habitat up to 0.5 km from water for egg-laying.
Not expected to occur: La Honda
Creek adjacent to the project site
could support western pond turtle;
however, the deeply shaded nature
of the site does not provide basking
sites for the species or open upland
habitat for egg laying. Species is
known to occur on the preserve
(CNDDB 2021).
Birds
Alameda song
sparrow
Melospiza
melodia pusillula
SC
Salt marsh. Resident of salt marshes bordering south arm of San
Francisco Bay. Inhabits Salicornia marshes; nests low in
Grindelia bushes (high enough to escape high tides) and in
Salicornia.
Not expected to occur: Suitable salt
marsh habitat for the species is not
found within the project site.
American
peregrine falcon
Falco peregrinus
anatum
D D FP
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.
Not expected to occur: Buildings,
cliffs, or other elevated places
needed for nesting habitat are not
found within the project site.
bald eagle
Haliaeetus
leucocephalus
D E FP
Lower montane coniferous forest, old growth. Ocean shore,
lake margins, and rivers for both nesting and wintering. Most
nests within 1 mile of water. Nests in large, old-growth, or
dominant live tree with open branches, especially ponderosa
pine. Roosts communally in winter.
Not expected to occur: Trees that
could support nests are present
within the project site; however, the
project site is too far from
waterbodies of sufficient size to
support nesting.
bank swallow
Riparia riparia T
Riparian scrub, riparian woodland. Colonial nester; nests
primarily in riparian and other lowland habitats west of the
desert. Requires vertical banks/cliffs with fine-textured/sandy
soils near streams, rivers, lakes, ocean to dig nesting hole.
Not expected to occur: Vertical cut
banks and cliffs needed for nesting
habitat are not found within the
project site.
burrowing owl
Athene
cunicularia
SC
Coastal prairie, coastal scrub, Great Basin grassland, Great Basin
scrub, Mojavean desert scrub, Sonoran desert scrub, and valley
and foothill grassland. Open, dry annual or perennial grasslands,
deserts and scrublands characterized by low-growing
vegetation. Subterranean nester, dependent upon burrowing
mammals, most notably, the California ground squirrel.
Not expected to occur: Suitable
habitat for the species is not found
within the project site.
California black
rail
Laterallus
jamaicensis
coturniculus
T FP
Brackish marsh, freshwater marsh, marsh and swamp, salt
marsh, wetland. Inhabits freshwater marshes, wet meadows
and shallow margins of saltwater marshes bordering larger
bays. Needs water depths of about 1 inch that do not fluctuate
during the year and dense vegetation for nesting habitat.
Not expected to occur: Suitable
marsh or swamp habitat for the
species is not found within the
project site.
California least
tern
Sternula
antillarum
browni
E E FP
Alkali playa, wetland. Nests along the coast from San Francisco
Bay south to northern Baja California. Colonial breeder on bare
or sparsely vegetated, flat substrates: sand beaches, alkali flats,
landfills, or paved areas.
Not expected to occur: Suitable
habitat for the species is not found
within the project site.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
Long-eared owl
Asio otus SSC
Cismontane woodland, Great Basin scrub, riparian forest,
riparian woodland, and upper montane coniferous forest.
Riparian bottomlands grown to tall willows and cottonwoods;
also, belts of live oak paralleling stream courses. Require
adjacent open land productive of mice and the presence of old
nests of crows, hawks, or magpies for breeding.
Not Likely to Occur: One historical
(1987) occurrence within San Mateo
County. Suitable Long-eared owl
nesting habitat is not present in the
project site, due to a lack of
adjacent open habitat.
Marbled
murrelet
Brachyramphus
marmoratus
T E
Lower montane coniferous forest, old growth, redwood. Feeds
near-shore; nests inland along coast from Eureka to Oregon
border and from Half Moon Bay to Santa Cruz. Nests in old-
growth redwood-dominated forests, up to six miles inland,
often in Douglas-fir.
Could Occur: The redwood forest
within the project footprint does
not contain trees that provide the
large branches suitable for nesting;
however, suitable marbled murrelet
nesting habitat has been
documented within ½ mile of the
project site (MidPen 2007).
Northern harrier
Circus cyaneus SC
Coastal scrub, Great Basin grassland, marsh and swamp,
riparian scrub, valley and foothill grassland, and wetlands.
Coastal salt and fresh-water marsh. Nest and forage in
grasslands, from salt grass in desert sink to mountain cienagas.
Nests on ground in shrubby vegetation, usually at marsh edge;
nest built of a large mound of sticks in wet areas.
Not expected to occur: The densely
forested habitat in the project site
does not provide the open
marshland and grassland habitat
needed for this species.
Saltmarsh
common
yellowthroat
Geothlypis
trichas sinuosa
SC
Marsh and swamp. Resident of the San Francisco Bay region, in
fresh and salt water marshes. Requires thick, continuous cover
down to water surface for foraging; tall grasses, tule patches,
willows for nesting.
Not expected to occur: Suitable
marsh or swamp habitat for the
species is not found within the
project site.
Short-eared owl
Asio flammeus SSC
Great Basin grassland, marsh and swamp, meadow and seep,
valley and foothill grassland, and wetlands. Found in swamp
lands, both fresh and salt; lowland meadows; irrigated alfalfa
fields. Tule patches/tall grass needed for nesting/daytime
seclusion. Nests on dry ground in depression concealed in
vegetation.
Not expected to occur: Suitable
grasslands, marsh, or swamp
habitat for the species is not found
within the project site.
Western snowy
plover
Charadrius
alexandrinus
nivosus
T SC
Great Basin standing waters, sand shore, wetland. Sandy
beaches, salt pond levees and shores of large alkali lakes. Needs
sandy, gravelly or friable soils for nesting.
Not expected to occur: Suitable
habitat for the species is not found
within the project site.
White-tailed kite
Elanus leucurus FP
Cismontane woodland, marsh and swamp, riparian woodland,
valley and foothill grassland, and wetlands. Rolling foothills and
valley margins with scattered oaks and river bottomlands or
marshes next to deciduous woodland. Open grasslands,
meadows, or marshes for foraging close to isolated, dense-
topped trees for nesting and perching.
Not expected to occur: The densely
forested habitat in the project site
does not provide the open
woodland and grassland habitat
needed for this species.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
yellow rail
Coturnicops
noveboracensis
SC
Freshwater marsh, meadow and seep. Summer resident in
eastern Sierra Nevada in Mono County. Fresh-water
marshlands.
Not expected to occur: Suitable
marsh, wet meadow, or seep
habitat for the species is not found
within the project site.
Mammals
American badger
Taxidea taxus SC
Alkali marsh, alkali playa, alpine, alpine dwarf scrub, bog a fen,
brackish marsh, broadleaved upland forest, chaparral,
chenopod scrub, cismontane woodland, closed-cone coniferous
forest, coastal bluff scrub, coastal dunes, coastal prairie. 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.
Could Occur: The species has been
documented on the preserve
(CNDDB 2021); although more often
found within grassland and
chaparral habitats, could occur
within the project site.
Big free-tailed
bat Nyctinomops
macrotis
SSC
Low-lying arid areas in Southern California. Need high cliffs or
rocky outcrops for roosting sites. Feeds principally on large
moths.
Not expected to occur: Only one
documented historical occurrence
within San Mateo County (CNDDB
2021). No high cliffs or rocky
outcrops for roosting habitat in the
project site or vicinity.
Mountain lion-
Southern
California/Centra
l Coast
evolutionary
significant unit
Puma concolor
CT
Found in most habitats within Central California. Uses caves,
other natural cavities, and brush thickets for cover and denning,
often within riparian habitats.
Known to Occur: A male mountain
lion was documented to be using
the project site in 2012 (Sant Cruz
Puma Project 2021). Suitable
habitat exists in the project site.
pallid bat
Antrozous
pallidus
SC
Chaparral, coastal scrub, desert wash, Great Basin grassland,
Great Basin scrub, Mojavean desert scrub, riparian woodland,
Sonoran desert scrub, upper montane coniferous forest, valley
and foothill grassland. Deserts, grasslands, shrublands,
woodlands and forests. Most common in open, dry habitats
with rocky areas for roosting. Roosts must protect bats from
high temperatures. Very sensitive to disturbance of roosting
sites.
Could Occur: A survey of the
redwood cabin in 2019 (Swaim
2019) did not find evidence of
roosting bats, and acoustic
recordings did not identify the
species in the project site. However,
the species is known to occur on the
preserve (CNDDB 2021), and could
use the redwood cabin during
project implementation.
ringtail
Bassariscus
astutus
FP Riparian habitats, forest habitats, and shrub habitats in lower to
middle elevations.
Could Occur: Suitable habitat for
the species is found within the
project site.
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
Salt-marsh
harvest mouse
Reithrodontomys
raviventris
E E FP
Marsh and swamp, wetland. Only in the saline emergent
wetlands of San Francisco Bay and its tributaries. Pickleweed is
primary habitat, but may occur in other marsh vegetation types
and in adjacent upland areas. Does not burrow, build loosely
organized nests. Requires higher areas for flood escape.
Not expected to occur: Suitable
marsh or swamp habitat for the
species is not found within the
project site.
Salt-marsh
wandering shrew
Sorex vagrans
halicoetes
SC
Marsh and swamp, wetland. Salt marshes of the south arm of
San Francisco Bay. Medium high marsh 6-8 feet above sea level
where abundant driftwood is scattered among Salicornia.
Not expected to occur: Suitable
marsh or swamp habitat for the
species is not found within the
project site.
San Francisco
dusky-footed
woodrat
Neotoma
fuscipes
annectens
SC
Chaparral, redwood. Forest habitats of moderate canopy and
moderate to dense understory. May prefer chaparral and
redwood habitats. Constructs nests of shredded grass, leaves
and other material. May be limited by availability of nest-
building materials.
Known to Occur: A survey of the
redwood cabin in 2019 (Swaim
2019) discovered woodrat nests
within the structure.
Santa Cruz
kangaroo rat
Dipodomys
venustus
venustus
Chaparral. Silverleaf manzanita mixed chaparral in the Zayante
Sand Hills ecosystem of the Santa Cruz Mountains. Needs soft,
well-drained sand.
Not expected to occur: Suitable
chaparral habitat for the species is
not found within the project site,
which occurs outside of the Zayante
Sand Hills ecosystem.
Steller
(=northern) sea-
lion
Eumetopias
jubatus
D
Marine intertidal and splash zone communities, protected
deepwater coastal communities, rock shore. Breeds on Ano
Nuevo, San Miguel and Farallon islands, Pt. St. George, and
Sugarloaf. Hauls-out on islands and rocks. Needs haul-out and
breeding sites with unrestricted access to water, near aquatic
food supply and with no human disturbance.
Not expected to occur: Suitable
habitat for the species is not found
within the project site, which occurs
above the intertidal zone.
Townsend's big-
eared bat
Corynorhinus
townsendii
SC
Broadleaved upland forest, chaparral, chenopod scrub, Great
Basin grassland, Great Basin scrub, Joshua tree woodland, lower
montane coniferous forest, meadow and seep, Mojavean desert
scrub, riparian forest, riparian woodland, Sonoran desert scrub.
Throughout California in a wide variety of habitats. Most
common in mesic sites. Roosts in the open, hanging from walls
and ceilings. Roosting sites limiting. Extremely sensitive to
human disturbance.
Could Occur: A survey of the
redwood cabin in 2019 (Swaim
2019) did not find evidence of
roosting bats, and acoustic
recordings did not identify the
species in the project site. However,
the species is known to occur on the
preserve (CNDDB 2021), and could
use the redwood cabin during
project implementation.
Note: CNDDB = California Natural Diversity Database; USFWS = U.S. Fish and Wildlife Service; ESU = Evolutionary Significant Unit; DPS= Distinct Population Segment
* This species is included as special-status species due to the previous listing as Candidate Endangered by the California Fish and Game Commission. This candidate status
was overturned by the courts in 2020; however, the species still warrants consideration under CEQA (see Section 3.3, Biological Resources).
1 Legal Status Definitions
Federal:
E Endangered (legally protected)
T Threatened (legally protected)
C Candidate (no formal protection)
D Delisted
State:
FP Fully protected (legally protected)
SC Species of special concern (no formal protection other than CEQA consideration)
CE Candidate Endangered (legally protected)
E Endangered (legally protected)
T Threatened (legally protected)
Exhibit A
Table A-2 Special-Status Animal Species Known to Occur in the Project Region and their Potential for Occurrence in
the Redwood Cabin Project site
Species Status 1 Habitat Potential for Occurrence 2
Federal State
S1 Critically Imperiled (no formal protection other than CEQA consideration)
S2 Imperiled (no formal protection other than CEQA consideration)
Other:
WBWG: M Western Bat Working Group - Medium
2 Potential for Occurrence Definitions
Not expected to occur: Species is unlikely to be present in the project site due to poor habitat quality, lack of suitable habitat features, or restricted current distribution of the
species.
Could occur: Suitable habitat is available in the project site; however, there are little to no other indicators that the species might be present.
Known to occur: The species, or evidence of its presence, has been reported by others.
Source: Authority 2010; CNDDB 2021; Midpen 2012; Santa Cruz Puma Project 2021; Swaim 2019
Exhibit A
Appendix D
Cultural Resource Reports
Exhibit A
imagining change in historic environments through design, research, and technology
Page & Turnbull
LA HONDA CREEK REDWOOD CABIN
HISTORIC RESOURCE EVALUATION REPORT
SAN MATEO COUNTY, CALIFORNIA
[19019A]
PREPARED FOR:
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
MARCH 26, 2020
DRAFT
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 Page & Turnbull, Inc.
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................... 1
I. INTRODUCTION ...................................................................................................... 2
METHODOLOGY ................................................................................................................................ 3
SUMMARY OF FINDINGS .................................................................................................................... 3
II. EXISTING HISTORIC STATUS .............................................................................. 4
NATIONAL REGISTER OF HISTORIC PLACES .................................................................................... 4
CALIFORNIA REGISTER OF HISTORICAL RESOURCES ...................................................................... 4
CALIFORNIA HISTORICAL RESOURCE STATUS CODE ..................................................................... 4
SAN MATEO COUNTY INVENTORY OF COUNTY HISTORIC RESOURCES ................................... 4
III. ARCHITECTURAL DESCRIPTION ........................................................................ 6
EXTERIOR ............................................................................................................................................ 6
SITE FEATURES ................................................................................................................................... 13
IV. HISTORIC CONTEXT .......................................................................................... 15
EARLY RECREATION IN THE SANTA CRUZ MOUNTAINS ............................................................. 16
V. PROJECT SITE HISTORY ...................................................................................... 19
SITE DEVELOPMENT ......................................................................................................................... 19
SELECT BUILDER, OWNER, AND OCCUPANT HISTORY ............................................................... 26
VI. EVALUATION ....................................................................................................... 32
CALIFORNIA REGISTER OF HISTORICAL RESOURCES .................................................................... 32
INTEGRITY ......................................................................................................................................... 33
CHARACTER-DEFINING FEATURES OF THE LA HONDA CREEK REDWOOD CABIN .................. 35
VII. CONCLUSION .................................................................................................... 37
VIII. REFERENCES CITED.......................................................................................... 38
APPENDIX ................................................................................................................. 40
APPENDIX A – PREPARER QUALIFICATIONS ................................................................................... 40
APPENDIX B – APPRAISAL REPORT, SAN MATEO COUNTY ASSESSOR’S OFFICE ......................... 41
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 2 - Page & Turnbull, Inc.
I. INTRODUCTION
This Historic Research Evaluation has been prepared at the request of the Midpeninsula Regional
Open Space District (“District,” “MROSD”) for the La Honda Creek Redwood Cabin (“Redwood
Cabin”) (San Mateo County APN 075-330-260)1 (Figure 1). The Redwood Cabin is situated within
the La Honda Creek Open Space Preserve and is under the jurisdiction of the Midpeninsula Regional
Open Space District. The subject building is located in unincorporated San Mateo County, just west
of the town of Woodside, California.
Figure 1. Approximate location of the La Honda Creek Redwood Cabin. Route 35 is also known as
Skyline Boulevard. Source: La Honda Creek Open Space Preserve Master Plan, August 2012. Edited
by Page & Turnbull.
Figure 2. San Mateo County Assessor’s Map. Approximate location of subject building marked by
orange arrow. Source: San Mateo County Property Maps Portal. Edited by Page & Turnbull.
1 There is currently not a formal address commonly associated with the Redwood Cabin.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 3 - Page & Turnbull, Inc.
The La Honda Creek Redwood Cabin is not currently listed in the National Register of Historic
Places (National Register) or the California Register of Historical Resources (California Register).
According to the District, the cabin has not been previously evaluated.
METHODOLOGY
This report provides a summary of the current historic status, a building description, historic context,
and an evaluation for the La Honda Creek Redwood Cabin for listing in the California Register. Page
& Turnbull prepared this report using research collected at various local repositories, including the
Palo Alto Historical Association, San Mateo County History Museum Archives, as well as various
online sources including Ancestry.com and the California Digital Newspaper Collection. Key primary
sources consulted and cited in this report include San Mateo County Assessor-County Clerk-
Recorder records, historical newspapers and photographs, local historic accounts, and USGS
topographical maps. Due to its rural location in a heavily forested area, aerial photographs did not
provide useful information regarding the Redwood Cabin and Sanborn maps appear to not have
been drawn for this area.
All photographs in this report were taken by Page & Turnbull during a site visit on February 20,
2020, unless otherwise noted.
SUMMARY OF FINDINGS
This HRE finds that the La Honda Creek Redwood Cabin appears to qualify as an eligible
historic resource for the purposes of review under the California Environmental Quality Act
(CEQA).
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 4 - Page & Turnbull, Inc.
II. EXISTING HISTORIC STATUS
The following section examines the national, state, and local historic status currently assigned to the
La Honda Creek Redwood Cabin.
NATIONAL REGISTER OF HISTORIC PLACES
The National Register of Historic Places (National Register) is the nation’s most comprehensive
inventory of historic resources. The National Register is administered by the National Park Service
and includes buildings, structures, sites, objects, and districts that possess historic, architectural,
engineering, archaeological, or cultural significance at the national, state, or local level.
The La Honda Creek Redwood Cabin is not currently listed in the National Register of Historic
Places.
CALIFORNIA REGISTER OF HISTORICAL RESOURCES
The California Register of Historical Resources (California Register) is an inventory of significant
architectural, archaeological, and historical resources in the State of California. Resources can be
listed in the California Register through a number of methods. State Historical Landmarks and
National Register-listed properties are automatically listed in the California Register. Properties can
also be nominated to the California Register by local governments, private organizations, or citizens.
The evaluative criteria used by the California Register for determining eligibility are closely based on
those developed by the National Park Service for the National Register of Historic Places.
The La Honda Creek Redwood Cabin is not currently listed in the California Register of Historical
Resources.
CALIFORNIA HISTORICAL RESOURCE STATUS CODE
Properties listed or under review by the State of California Office of Historic Preservation are
assigned a California Historical Resource Status Code (Status Code) of “1” to “7” to establish their
historical significance in relation to the National Register of Historic Places (National Register or
NR) or California Register of Historical Resources (California Register or CR). Properties with a
Status Code of “1” or “2” are either eligible for listing in the California Register or the National
Register or are already listed in one or both of the registers. Properties assigned Status Codes of “3”
or “4” appear to be eligible for listing in either register, but normally require more research to
support this rating. Properties assigned a Status Code of “5” have typically been determined to be
locally significant or to have contextual importance. Properties with a Status Code of “6” are not
eligible for listing in either register. Finally, a Status Code of “7” means that the resource has not
been evaluated for the National Register or the California Register, or needs reevaluation.
The La Honda Creek Redwood Cabin is not listed in the California Office of Historic Preservation
(OHP) Historic Property Data File for San Mateo County with a Status Code. The most recent
update to the Historic Property Data File for San Mateo County that lists the Status Codes was in
April 2012.
SAN MATEO COUNTY INVENTORY OF COUNTY HISTORIC RESOURCES
San Mateo County maintains an inventory of historic resources (“inventory”) located in
unincorporated San Mateo County. The 1986 San Mateo County General Plan state that:
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 5 - Page & Turnbull, Inc.
The inventory was compiled by the County Historic Resources Advisory Board and is based
on earlier research don by a previous bod, the County Historic Sites Advisory Committee.
The Inventory contains all resources that are designated National or State Historic
Landmarks, and those listed in the National Register of Historic Places, the Historic
American Building Survey, the Historic American Engineering Record, and the State
Inventor of Historic Resources. It is by no means a ‘final’ list. It represents the beginnings of
an inventory in the county and provides a basis for work on a more comprehensive survey to
be completed later.2
However, the San Mateo County Historic Resources Inventory does not appear to have been
updated since 1986. The inventory contains a list of 69 historic and archeological resources, and a list
of 49 cultural resources “found within the San Mateo County Coastal Zone.”3 The inventory was
adopted “by reference as part of the Historic Resources Element.”4
The La Honda Creek Redwood Cabin is not included in the San Mateo County Inventory of County
Historic Resources.
2 “Chapter 5 – Historic and Archaeological Resources,” in San Mateo County General Plan, prepared by Environmental Services Agency for
the San Mateo County Planning & Building Division (November 1986), 5.6A, accessed online March 4, 2020,
https://planning.smcgov.org/sites/planning.smcgov.org/files/SMC-GP%201986.pdf.
3 Ibid, 5.25A.
4 Ibid, 5.25A.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 6 - Page & Turnbull, Inc.
III. ARCHITECTURAL DESCRIPTION
EXTERIOR
The La Honda Creek Redwood Cabin is a large, side-gabled log cabin with a rectangular plan and an
open wraparound plank deck (Figure 3). The Redwood Cabin measures approximately 66 feet long
by 30 feet wide. It is constructed solely of barked redwood logs of various sizes, with saddle notches
that are set unconventionally (Figure 4).5 The east and west façades are each composed of four bays,
some delineated by a vertical set log or opening. 6 The cabin and deck are supported by large rustic
wood posts, some of which are set in concrete and others of which are set on grade. The side-gabled
roof has exposed rafter tails of various widths, with full barked logs set as decorative fascia, and is
topped with wood shingles and five skylights (Figure 12). There is also a central interior stone
chimney that connects to an expansive interior fireplace, whose foundation is visible from beneath
the cabin (Figure 5). The cabin has wood sash multi-lite double casement windows of various sizes
throughout all façades, hereafter referred to as “typical” windows. There are multiple paneled one-lite
wood doors and wood multi-lite French doors throughout the north, east, and west façades.
The deck previously wrapped around all four façades. Two sections of the wraparound deck have
rotted and collapsed, the north façade deck and the open deck that extended from the northwest
corner. At the south façade and part of the west façade the deck is on grade, and elsewhere it is
elevated by the large rustic wood posts. The deck has wood plank flooring and is supported by
pressure treated timber. Horizontal rustic log railing is set between the large rustic support logs; the
railing wraps around the entire primary (east) façade and part of the south façade. A U-shaped wood
and stone staircase is located at the northeast corner and connects the driveway to deck. It features a
lower flight made of large stones and an upper flight of redwood treads and railing.
Figure 3. Primary (east) façade, facing southwest from the circular driveway.
5 According to the Basis of Design and Alternative Evaluation by Page & Turnbull, the cabin notches appear to be saddle notched yet
“assembled with the notches facing up rather than down.”
6 The cabin is not oriented true north; for the purpose of this report, façade directions will be referred to as true cardinal directions. Façade
directions are based on USGS topographical maps.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 7 - Page & Turnbull, Inc.
Figure 4. Close up of the cabin’s typical saddle notching, facing northeast.
Figure 5. View of stone chimney foundation and on-grade cabin piers.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 8 - Page & Turnbull, Inc.
Primary (East) Façade
The primary (east) façade of the Redwood Cabin overlooks the driveway downhill. The façade is
primarily characterized by the large rustic support piers and the wraparound deck (Figure 5 and
Figure 7). The façade has four sets of log bays, two of which are separated by vertically set logs. The
main entry is centered on the façade and features a thick redwood burl door with ironwork and
decorative ironwork hardware (Figure 8 and Figure 9). A set of divided-lite wood French doors is
situated at the south end of the east façade. There are five sets of typical windows along the entire
façade (Figure 10). The five skylights are evident on the east-facing roof gable and are aligned with
window and door openings along the primary façade (Figure 11).
Figure 6. View of terrain, site features, and primary façade (right) and partial view of the south façade
(left), facing north.
Figure 7. Primary (east) façade, facing northwest. Driveway stone walls are in the forefront.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 9 - Page & Turnbull, Inc.
Figure 8. Front entry door and three typical wood
casement windows, as seen from the interior,
facing east.
Figure 9. Detail of front entry door and
ironwork.
Figure 10. Typical wood sash casement window,
as seen from the interior, facing southeast.
Figure 11. Typical aluminum skylight, as seen
from the interior.
South Façade
The south façade of the Redwood Cabin is located on grade, at the top of the steep terrain. The
driveway spur rises up the steep terrain and terminates next to the façade. There are three typical
divided wood sash casement windows, one of which is shorter and is located at the east side (Figure
12). Various mechanical and electrical hookups that lead to the interior are attached to the south
façade. The wraparound porch is partially intact at the south façade. The railing is only evident at the
southeast corner, where a safety sign and railings restrict access to the rest of the porch.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 10 - Page & Turnbull, Inc.
Figure 12. South elevation of the Redwood Cabin, facing northeast from top of hill.
Rear (West) Façade
The rear (west) façade of the Redwood Cabin is similar to the east façade. It has four bays, each with
an entry door and an accompanying typical window (Figure 13). Many of the windows and
doorways are currently boarded with plywood or have a screen covering. The rear (west) section of
the wraparound porch appears to be hidden under ground cover and has no railing (Figure 14 and
Figure 15).
Figure 13. View of west façade (left), and south façade (right), facing northeast.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 11 - Page & Turnbull, Inc.
Figure 14. Close-up of south end of west façade, facing southeast.
Figure 15. North half of west façade, facing north. Wraparound porch planks are located on
grade, below ground cover.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 12 - Page & Turnbull, Inc.
North Façade
The north façade is set above grade, supported by large rustic wood posts, and the north section of
the wraparound porch has been intentionally removed within the past year as a safety precaution
(Figure 16 and Figure 17). The north façade has one partially glazed wood door, which is currently
not accessible from the exterior as the porch has been removed. There are two typical windows, one
of which has a storm window. Remnants of the rear porch projection are located at the northwest
corner (Figure 18). The main exterior U-shaped stone and wood staircase can be seen from the
north façade (Figure 19).
Figure 16. North façade, facing east. The wraparound porch along this façade and the porch
projection (right) are no longer extant.
Figure 17. North façade, facing southwest from entry staircase.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 13 - Page & Turnbull, Inc.
Figure 18. Remnants of rear porch
projection at the northwest façade.
Figure 19. Entry staircase at northeast corner of the Redwood
Cabin, facing southeast.
SITE FEATURES
The Redwood Cabin is located in a heavily wooded rural area, within a section of the La Honda
Creek Open Space Preserve that is currently not accessible to the general public. The building is
accessed via a narrow dirt road that connects to Skyline Boulevard. The Redwood Cabin is situated
on top of sloped terrain, overlooking a circular dirt driveway to the east that surrounds a small grove
of redwood trees (Figure 20). A spur splits from the southeast corner of the circular driveway, rises
up the slope, and terminates next to the south façade of the cabin (Figure 21). The driveway is
partially delineated by stone walls (Figure 22). A stone staircase rises from the driveway to the east
and connects to the wood deck of the Redwood Cabin (Figure 23). Various remnants of the
Redwood Cabin’s recreational history are scattered throughout the property; these include a
horseshoe pit, a stone barbeque pit, and a brick planter or pit (Figure 24 through Figure 26).
Figure 20. View of the Redwood Cabin from the dirt driveway approach, facing west.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 14 - Page & Turnbull, Inc.
Figure 21. Spur, facing northeast towards the
rest of the circular driveway and grove.
Figure 22. One of multiple stone walls that
delineate the circular driveway.
Figure 23. View of the U-shaped entry staircase,
facing north.
Figure 24. Remnants of horseshoe pit at rear of
property.
Figure 25. Barbeque pit located at rear of
property.
Figure 26. Brick planter or pit, located at rear of
property.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 15 - Page & Turnbull, Inc.
IV. HISTORIC CONTEXT
The Redwood Cabin is located in unincorporated San Mateo County, within the Santa Cruz
Mountains of the San Francisco Peninsula. The cabin is situated on the land that was historically
occupied by the Ohlone peoples prior to Spanish and Mexican settlement. After Mexico gained
independence from Spain in 1821, the land that encompasses present-day San Mateo County was
parceled out in a number of land grants known as ranchos (Figure 27). The Redwood Cabin is
located in the former Rancho San Gregorio, which stretched from the coast of the Pacific Ocean up
to the forested heights of the Santa Cruz Mountains.
Figure 27. Map of ranchos, or land grants, in San Mateo County. Source: Frank M. Stanger, South
From San Francisco (San Mateo, CA: San Mateo County Historical Association, 1963), 50.
The California Gold Rush and the rapid development of the city of San Francisco triggered a logging
boom in the Santa Cruz Mountains. Home to old-growth redwoods and Douglas firs, lumber mills
soon inundated the area and became the primary catalyst for the development of small towns in the
hills along the peninsula, including nearby Woodside and La Honda that were established in the latter
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 16 - Page & Turnbull, Inc.
half of the nineteenth century.7 By 1853, 15 mills were operating on Kings Mountain, northwest of
Woodside.8
EARLY RECREATION IN THE SANTA CRUZ MOUNTAINS
By the late 1800s and early 1900s, commercial timber logging in the Santa Cruz Mountains had
subsided.9 Meanwhile, beginning in the mid 1800s, the Santa Cruz Mountains were becoming a prime
area for recreation, including camping, hunting, and fishing. The area’s proximity to San Francisco
and other Bay Area cities, paired with the rise of the personal automobile in the early twentieth
century made the forests of the San Francisco Peninsula ideal locations for middle-class and wealthy
families to vacation. Tourism became the livelihood of La Honda, a nearby former logging town
located south of the subject Redwood Cabin. By the 1890s, several camps were located in the vicinity
of La Honda, including the Cozy Nook Camp, the Bohemian Camp, Maplewood Camp, and Jonah
Camp (Figure 28).10 Some camps had as many as 300 campers at a time. Lodges and hotels were
also constructed during this period to accommodate non-campers and long-term visitors.
The area was accessed by several roads and logging trails that connected up through the San
Francisco Peninsula. During the early 1920s, San Francisco, San Mateo, Santa Clara and Santa Cruz
counties established a joint highway district in order to build Skyline Boulevard.11 The route would
become a major local route and would run along much of the spine of the San Francisco Peninsula.12
By 1923, approximately 30 miles of the road had been completed between the city of San Francisco
and La Honda Road, which formed a junction with Skyline Boulevard close to the Redwood Cabin.
Figure 28. Camp Boheme, ca. 1900, one of many camps located near La Honda. Photograph by Gus
Zanoni. Source: Milton Cavalli Collection, San Mateo County Historical Association.
7 Frank Stanger, Sawmills in the Redwoods: Logging on the San Francisco Peninsula, 1849-1967, (San Mateo: San Mateo County Historical
Association, 1967), 77.
8 Stacy Trevenon, Kings Mountain (Charleston, SC: Arcadia Publishing, 2008), 29.
9 Bob Dougherty, La Honda, (Charleston, SC: Arcadia Publishing, 2007), 33.
10 Ibid., 86.
11 “Skyline: Santa Cruz Mountains Area Study,” Department of Environmental Management, Planning and Development Division, San
Mateo County, California, Hearing Draft July 1982, 1.2-1.4.
12 Bob Dougherty, La Honda, 80.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 17 - Page & Turnbull, Inc.
One of the first subdivisions recorded along the Skyline Ridge was Redwood Park in 1908. Following
the construction of Skyline Boulevard, the area was made more accessible to both visitors and year-
round residents. The 1920s and 1930s brought the peak of residential development for the area, with
new construction in unincorporated San Mateo County peaking in 1930.13 Developments like Sky
Londa (located directly east of the Redwood Cabin on Skyline Boulevard), Cuesta La Honda, the
Middleton Tract, Sierra Morena Woods, Kings Mountain Park, and La Honda Park followed in the
subsequent two decades, bringing hundreds of summer houses and cabins to the immediate area
(Figure 29 and Figure 30).14 15 A 1931 sales pamphlet describes the appeal of the area:
La Honda Park, in the midst of miles of giant redwoods, a restful retreat for which you have
been looking; not far from home, yet far enough to help you forget the troubles and cares of
business. The most beautiful spot in San Mateo County. Pure spring water piped to camps
and cabins. Picnicking, boating, camping, swimming. Parking fee 50 cents per car; camp
tents $7.00 per week. Cabin lots, creek and woods, $400 up.16
Figure 29. Advertisement for Sky Londa cabins, San Francisco Examiner, August 10, 1929.
13Historic Development Totals (Unincorporated San Mateo County), County of San Mateo Assessor’s Standards Division records, page 88,
on file at the San Mateo County Historical Association Archives.
14 Bob Dougherty, La Honda, 33.
15 “Skyline: Santa Cruz Mountains Area Study,” 1.2-1.4.
16 Bob Dougherty, La Honda, 99.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 18 - Page & Turnbull, Inc.
Despite their early popularity, most of the lodges and hotels along Skyline Ridge and in La Honda
did not remain open past the Depression.17 As other recreation areas became accessible, the
popularity of La Honda and the Santa Cruz Mountains waned.18 With the rise of the conservation
movement in the 1970s, the remaining forests, coastal areas, and open spaces of the Santa Cruz
Mountains were preserved. As a result, much of the surrounding area, including that of the subject
property, has been incorporated into local and state parks and open space preserves. Today, the area
serves yet again as a popular day recreation area and the occasional permanent residence or vacation
home.
Figure 30. Sky Londa advertisement, San Francisco Examiner, September 14, 1929.
17 Bob Dougherty, La Honda, 99.
18 Ibid., 88.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 19 - Page & Turnbull, Inc.
V. PROJECT SITE HISTORY
SITE DEVELOPMENT
The Redwood Cabin is situated on land within the boundary of the former Rancho San Gregorio and
is near the site of former lumber mills, including Harrington Mill (Figure 28 and Figure 29). In
1894, the land in which the cabin would be built was owned by F.M.L. Peters and J. Kubler (Figure
30). The land transferred hands, and in 1909 was owned by J.F. Peters, M.T. Maison, C.H. Souther,
and J. Palmer with nearby lots owned by the Virginia Timber & Lumber Company (Figure 31). In
1927, the land was owned by William O. Harabin and W.B. Allen and a portion of Skyline Boulevard
had been constructed through said land (Figure 32). According to District records, the Redwood
Cabin was constructed by W.B. Allen from 1927-1928. By the early 1940s, Skyline Boulevard had
been fully constructed along the Peninsula and a dirt road extended south, partially along the
footprint of the road that now connects to the cabin (Figure 33 and Figure 34). The development
of the Sky Londa neighborhood, which had been underway for a decade, is also evident.
Additionally, the road that connected the Redwood Cabin to Skyline Boulevard was named Allen
Road at this time and wrapped south and then westward toward Bear Gulch Road, connecting to
Allen Lookout and the former Dyer Ranch and White Barn (Figure 35). It was not until 1961 that
the subject building appeared on a USGS topographic map. During this time the Sky Londa
development had grown and the section of Allen Road that connected the cabin to Dyer Ranch and
the White Barn was converted to a “Jeep trail,” or in other words, an unimproved dirt road (Figure
36). A 1991 USGS topographic map shows the cabin on the access road to Skyline Boulevard and a
re-configured Allen Road (Figure 37).
An appraisal report from the San Mateo County Assessor’s Office, dated June 10, 1953 and July 21,
1954, is currently the earliest and only known official record of the Redwood Cabin on file at the
County of San Mateo. The record notes a 66’x30’ rectangular building labeled “lodge” with a
wraparound open plank deck and a larger rear deck (Appendix B and Figure 38).19 The lodge is
described as a 6-room building with one bathroom and redwood log walls; light shake roof; exposed
rustic along rake of rafters; mud sills and large rustic posts; pine floor; large natural stone fireplace;
and deck pillars set on concrete piers.
The date of construction is listed as “est. 1920” on the appraisal report. Three other buildings
accompany the lodge on the appraisal report and are noted as being “removed to parcel #075-330-
010, dated 1/17/1966.” The buildings appear to have been situated around the circular driveway and
included two garages and a caretaker’s cabin with an open deck at the front. Both garages are noted
as being constructed in 1953. The caretaker’s cabin and two garages are no longer extant on the site,
and it is unknown whether they were demolished or relocated.
The following list details known dates and details on the site history of the La Honda Creek
Redwood Cabin:
19 San Mateo County Assessor’s Office Property Appraisal Report for parcel number (APN) 075-330-220, a former parcel number that was
previously consolidated into the current number.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 20 - Page & Turnbull, Inc.
Table 1. Site Development
Date(s) Site History Source
Ca. 1920s The Redwood Cabin is constructed on
former timber land near La Honda Creek,
presumably as a recreation cabin for W.B.
Allen and his family.
1953-1954 San Mateo County
Assessor Appraisal Record
Ca. 1953 Redwood Cabin – Roof is replaced with
composite shingles, new deck underpinning
and pins.
Garage 1 and Garage 2 – Constructed
Caretaker’s Cabin – Constructed at an
unknown date. Two rooms added in 1953.
1953-1954 San Mateo County
Assessor Appraisal Record
Ca. 1/17/1966 Garage 1, Garage 2, and the Caretaker’s
Cabin are “removed to parcel #075-330-
010.”
1953-1954 San Mateo County
Assessor Appraisal Record
Unknown Aluminum skylights are added. It is unclear
whether or not they replaced original
skylights or were additions.
Figure 31. 1868 map of approximate future location of the Redwood Cabin, marked with orange arrow.
Source: 1868 Official Map of the County of San Mateo, California, on file at the San Mateo County
History Museum Archives. Edited by Page & Turnbull.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 21 - Page & Turnbull, Inc.
Figure 32. 1868 view of La Honda Creek area. Approximate future location of cabin marked with
orange arrow. Source: 1868 Official Map of the County of San Mateo, California, on file at the San
Mateo County History Museum Archives. Edited by Page & Turnbull.
Figure 33. 1894 view of landholdings along the La Honda Creek. Future landholdings of W.B. Allen
and William O. Horabin are outlined in blue. Approximate future location of cabin marked by orange
arrow. Davenport Bromfield, County Surveyor, Official Map of San Mateo County, California, 1894.
Source: Stanford Libraries. Edited by Page & Turnbull.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 22 - Page & Turnbull, Inc.
Figure 34. 1909 view of private and timber landholdings along the La Honda Creek. Future
landholdings of W.B. Allen and William O. Horabin are outlined in blue. Approximate future location
of cabin marked by orange arrow. J.V. Neumann, County Surveyor, Official Map of San Mateo
County, California, 1909. Source: Stanford Libraries. Edited by Page & Turnbull.
Figure 35. 1927 view of W.B. Allen and William O. Horabin’s land holdings, outlined in blue.
Approximate location of cabin is marked by orange arrow. Woodside Country and Portola Woods, two
developments, can be seen to east. George A. Kneese, County Surveyor, Official Map of San Mateo
County, California, 1927. Source: Stanford Libraries. Edited by Page & Turnbull.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 23 - Page & Turnbull, Inc.
Figure 36. 1940 USGS Topographic Map of Half Moon Bay area. Approximate location of subject
property marked by orange arrow. Source: USGS TopoView.
Figure 37. 1943 USGS Topographic Map of Half Moon Bay area. Approximate location of subject
property marked by orange arrow. Source: USGS TopoView.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 24 - Page & Turnbull, Inc.
Figure 38. 1953 USGS Topographic Map of Woodside area. Approximate location of subject property
marked by orange arrow. Source: USGS TopoView.
Figure 39. 1961 USGS Topographic Map of Woodside area. Location of subject property marked by
orange arrow. Source: USGS TopoView.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 25 - Page & Turnbull, Inc.
Figure 40. 1991 USGS Topographic Map of Woodside area. Location of subject property marked by
orange arrow. Source: USGS TopoView.
Figure 41. 1953-1954 site drawing from appraisal report of the La Honda Creek Redwood Cabin.
Source: San Mateo County Assessor’s Office.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 26 - Page & Turnbull, Inc.
SELECT BUILDER, OWNER, AND OCCUPANT HISTORY
The Redwood Cabin was constructed by W. B. Allen in 1927-28 as a family retreat:
Allen settled in Palo Alto in 1903 and owned and operated Palo Alto Hardware. By 1918, he
purchased 400 acres in La Honda including the subject parcel. With the assistance of two
Norwegian laborers, Allen constructed the lodge on a bedrock foundation using local timber
pieced together without nails.20 In addition to the lodge, Allen imported stones from the
coast to construct walls, stairs, and numerous stone-lined hiking trails throughout the
property. In the 1930s, the California Conservation Corps assisted with the improvement of
some roads near the property. The Allen family as well as local groups, including the YMCA
and the rotary club, used the lodge as a summer retreat for decades. The property remained
in the Allen (Paulin) family until 1988 when the MROSD purchased it.21
It is unclear who designed the building or definitively aided W.B. Allen with the construction of the
cabin. Lee Erickson, a Finnish immigrant, and his sons were known local builders of rustic log cabins
and could be responsible for the construction of the cabin. Furthermore, a cabin constructed by
Erickson in the 1920s with substantial similarities is extant. According to George Bordi, a lifelong La
Honda farmer and resident, Lee Erickson and his two sons helped his grandfather, Antone Bordi,
construct a rectangular log cabin on the Bordi Farm near La Honda in the 1920s.22 It is constructed
of barked redwood set in a saddle notch configuration with angled corners on a minimal foundation,
similar to the Redwood Cabin (Figure 39 and Figure 40). The cabin is front gabled with a small
porch and multi-paned casement windows. The front door was broad-axed out of an old redwood
burl, in similar fashion to the unique front door of the Redwood Cabin. The Bordi Cabin measures
approximately 66 feet long by 30 feet wide, the same dimensions of the subject building.23 Both men
are discussed in detail in the following biography sections.
Table 2. Owner and Occupancy of the Redwood Cabin
Date Owner(s) Occupant(s)
Ca. 1927-1964 W.B. Allen, Winifred Allen Allen Family
Ca. 1964-1988 Allen & Paulin Family Allen & Paulin Family
1988-present Midpeninsula Regional Open
Space District
n/a
20 The quoted context is based on oral histories; some details, such as that of specifically Norwegian laborers, may be incorrect.
21 Jones & Stokes, “Final Biological and Cultural Resources Technical Memo and Opportunities and Constraints Analysis,” 2004, 45;
Midpeninsula Regional Open Space District. 2002. Meeting Notes, June 26, 2002, R-02-79; Joan Paulin, personal communication, October
4, 2004; La Honda Creek Open Space Preserve Master Plan, Midpeninsula Regional Open Space District, August 2012.
22 The Bordi Farm is currently located at 1355 Portola State Park Road in La Honda, California.
23 Google Earth, 2020.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 27 - Page & Turnbull, Inc.
Figure 42. The Bordi Cabin, ca. 2011. The Bordi Cabin has many similar attributes to the Redwood
Cabin. Source: George and Mary Bordi, “Meet George and Mary Bordi,” The La Honda Voice ,
January 29, 2011.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 28 - Page & Turnbull, Inc.
Figure 43. Antone Bordi, Lee Erickson and sons constructing the Bordi Cabin, ca. 1920s. Source:
George and Mary Bordi, “Meet George and Mary Bordi,” The La Honda Voice , January 29, 2011.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 29 - Page & Turnbull, Inc.
Builder Biography: Lee Erickson and Sons
Leander “Lee” Erickson (1864-1938) was a Finnish carpenter and the presumptive builder of the
Redwood Cabin. Erickson arrived in the U.S. circa 1882. After marrying Ida Sofia Hendrikson (1865-
1948) in Michigan, the couple moved to the Santa Cruz area where they would remain for the rest of
their lives. The two settled on Big Basin Road in the rural community of Boulder Creek and had four
children, Lydia (1894-1955), Robert (1895-1962), Jennie (1897 – ca. 1907), and Rugner (1903-1969).
Erickson was a skilled axe-ma, working at nearby lumber camps, and was a carpenter and
stonemason.24 In later years, sons Robert (“Rupert”) and Rugner would join their father on projects
in La Honda and Boulder Creek.25 A 1931 Santa Cruz Evening News article details a summer home
built by Erickson with similar components to the Redwood Cabin, such as “bark-covered logs on the
outside and the interior,” “a cobblestone fireplace,” and “large porch with rustic railings” (Figure
41). According to George Bordi, a lifelong La Honda farmer and resident, this similar log cabin was
constructed in the 1920s by his grandfather, Antone Bordi, with the help of Lee Erickson and his
two sons. The front door was broad-axed out of an old redwood burl, in similar fashion to the
unique front door of the Redwood Cabin. Bordi claims that Erickson went on to build several cabins
in the Middleton Tract, an early development of year-round and summer cabins and residences
located southwest of the town of La Honda.26
Figure 44. Santa Cruz Evening News, June 20, 1931. Newspaper clipping detailing summer home
constructed by Lee Erickson in nearby Boulder Creek.
24 1910 and 1920 U.S. Federal Census Records accessed via Ancestry.com; “Boulder Creek,” Santa Cruz Sentinel, March 1, 1911; “Leander
Erickson Funeral Services Set For Monday,” Santa Cruz Evening News, May 14, 1938.
25 Santa Cruz Evening News, October 8, 1927; Santa Cruz Evening News, October 13, 1927.
26 County of San Mateo, Master Index Map, Revision 2, June 1985, (Redwood City, California: County of San Mateo Assessor), 40-41.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 30 - Page & Turnbull, Inc.
Owner Biography: W.B. Allen
William Benjamin Allen (1878-1964) was born to a prominent Palo Alto pioneer family (Figure 42).
In 1903 he opened the Palo Alto Hardware Company at the corner of University Avenue and Bryant
Street in Palo Alto. Allen would own the store until his retirement in 1951, and over the course of 48
years would operate one of Palo Alto’s most prominent businesses.27
W. B. Allen married Winifred Alecia Jeffreys (1878-1976) in 1901, and they had two children, Lloyd
(1902-1979) and Edith (1906-1995). W. B. and Lloyd were both known outdoorsmen, skilled in
hunting and fishing, and traveled throughout the state and the Santa Cruz Mountains in their outdoor
pursuits (Figure 43). Lloyd would later go on to own and operate a sporting goods store in
Sacramento.28 An excerpt from the 1952 Palo Alto Community Book mentions W. B. Allen’s cabin,
presumed to be the subject La Honda Redwood Cabin, following Allen’s retirement: “Ben Allen has
always been an ardent hunter and fisherman an in later years his main hobby has been work about his
cabin in the redwoods.”29
Figure 45. W.B. Allen, ca. 1920s. Photograph by Newton Studios, Palo Alto, California. Source: Palo
Alto Historical Association.
27 “New apostle called to serve LDS Church,” Ukiah Daily Journal, January 27, 1976.
28 Guy C. Miller and Hugh Enochs, eds. Palo Alto Community Book (Palo Alto: Arthur H. Cawston, 1952), 219.
29 Ibid., 220.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 31 - Page & Turnbull, Inc.
Figure 46. Lloyd Allen featured in the San Francisco Chronicle , January 14, 1923.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 32 - Page & Turnbull, Inc.
VI. EVALUATION
CALIFORNIA REGISTER OF HISTORICAL RESOURCES
The California Register of Historical Resources (California Register) is an inventory of significant
architectural, archaeological, and historical resources in the State of California. Resources can be
listed in the California Register through a number of methods. State Historical Landmarks and
National Register-listed properties are automatically listed in the California Register. Properties can
also be nominated to the California Register by local governments, private organizations, or citizens.
The evaluative criteria used by the California Register for determining eligibility are closely based on
those developed by the National Park Service for the National Register of Historic Places.
In order for a property to be eligible for listing in the California Register, it must be found significant
under one or more of the following criteria.
Criterion 1 (Events): Resources that are associated with events that have made a
significant contribution to the broad patterns of local or regional history, or the
cultural heritage of California or the United States.
Criterion 2 (Persons): Resources that are associated with the lives of persons important
to local, California, or national history.
Criterion 3 (Architecture): Resources that embody the distinctive characteristics of a
type, period, region, or method of construction, or represent the work of a master,
or possess high artistic values.
Criterion 4 (Information Potential): Resources or sites that have yielded or have the
potential to yield information important to the prehistory or history of the local
area, California, or the nation.
The following section examines the eligibility of the La Honda Creek Redwood Cabin for
individual listing in the California Register.
Criterion 1 (Events)
The La Honda Creek Redwood Cabin does appear to be significant under Criterion 1 (Events) as a
property associated with events that have made a significant contribution to the broad patterns of
local or regional history, or the cultural heritage of California or the United States. According to
various accounts, the Redwood Cabin was constructed in the 1927-1928 by Palo Alto businessman
W. B. Allen with the aid of labormen. The cabin was constructed at a peak of outdoor recreation in
the Santa Cruz Mountains. The Redwood Cabin’s construction appears representative of a broader
pattern of recreational development in the Santa Cruz Mountains following the San Francisco
Peninsula’s logging boom, specifically at a time when recreation shifted from camps to cabins and
early subdivisions. While the cabin does not appear to be one of the earliest recreational cabins (from
the late 1800s and early 1900s), it appears to be one of the last remaining ones intact from the
transition era to permanent structures. Most of the original lodges and hotels appear nonextant. Due
to the rural nature of the area, not all nearby properties were surveyed; however, those that were
appeared not age eligible or altered. The Redwood Cabin appears to be a rare building typology and
retains its original rural setting. Therefore, the property does appear to be individually eligible for
listing under Criterion 1 with its period of significance, 1927-1928, the years of its construction.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 33 - Page & Turnbull, Inc.
Criterion 2 (Persons)
The La Honda Creek Redwood Cabin does not appear to be significant under Criterion 2 (Persons)
for its association with the lives of persons important to local, state, or national history. W. B. Allen,
original and longtime owner of the cabin, was a well-known Palo Alto businessman. From 1903 to
1951, Allen owned and operated the Palo Alto Hardware Company, a prominent business within
Palo Alto and San Mateo County. Allen also came from a renowned local pioneer family, and he and
his wife Winifred were active in the Palo Alto community. While W.B. Allen appears to be significant
locally in Palo Alto, the Redwood Cabin was not the most significant property tied to Allen and
instead, served as a secondary residence. While no longer extant, the Palo Alto Hardware Company
formerly located at the corner of University Avenue and Bryant Street in Palo Alto was more directly
connected to W. B. Allen and his achievements. His longtime residence, 909 Hamilton Avenue in
Palo Alto, is extant and would be a more ideal candidate. Therefore, the La Honda Creek Redwood
Cabin does not appear to be individually eligible for listing under Criterion 2.
Criterion 3 (Architecture)
The La Honda Creek Redwood Cabin does appear to be individually eligible for listing in the
California Register under Criterion 3 (Architecture) as a building that embodies the distinctive
characteristics of a type, period, region, or method of construction, or that represents the work of a
master or possesses high artistic values. The Redwood Cabin is a large, one-story side-gabled
rectangular log cabin with an open wraparound plank deck. It is constructed of barked redwood logs
of various sizes, with saddle notches that are set unconventionally and upside down. The cabin and
deck are supported by large rustic wood posts, some of which are set in concrete and others of which
are set on grade. The cabin features a large centered stone chimney that connects to an expansive
interior fireplace, its foundation visible from beneath the cabin. Its openings consist of what appear
to be original wood sash multi-lite windows, a large, handmade redwood door with iron details, and
paneled one-lite wood doors and wood multi-lite French doors throughout. It is unclear who
designed the cabin, and if it was the result of an architect or kit plan. According to district records, it
was constructed in 1927-1928 by businessman W.B. Allen with the help of two laborers. Research
suggests that the building could have been constructed by Finnish builder Lee Erickson, a local
builder of similar cabins. W.B. Allen and Lee Erickson do not appear to be master architects or
builders. Much of the cabin appears to be original. The building clearly utilizes local materials, and
while its construction method appears slightly “primitive,” it appears indicative of the rural, woodsy
character of the area and the period in which the region was transitioning to more permanent
recreational structures. As such, the Redwood Cabin does appear to be a unique property type or
architectural style such that it would rise to the level of individual significance within a local context.
In conclusion, the La Honda Creek Redwood Cabin does appear to be individually eligible for listing
under Criterion 3.
Criterion 4 (Information Potential)
The “potential to yield information important to the prehistory or history of California” typically
relates to archeological resources, rather than built resources. When California Register Criterion 4
(Information Potential) does relate to built resources, it is relevant for cases when the building itself
is the principal source of important construction-related information. The analysis of the Redwood
Cabin for eligibility under Criterion 4 is beyond the scope of this report.
INTEGRITY
In order to qualify for listing in any local, state, or national historic register, a property or landscape
must possess significance under at least one evaluative criterion as described above and retain
integrity. Integrity is defined by the California Office of Historic Preservation as “the authenticity of
an historical resource’s physical identity evidenced by the survival of characteristics that existed
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 34 - Page & Turnbull, Inc.
during the resource’s period of significance,” or more simply defined by the National Park Service as
“the ability of a property to convey its significance.”30
Page & Turnbull uses established integrity standards outlined by the National Register Bulletin: How to
Apply the National Register Criteria for Evaluation. Seven variables, or aspects, that define integrity are
used to evaluate a resource’s integrity—location, setting, design, materials, workmanship, feeling, and
association. A property must possess most or all of these aspects in order to retain overall integrity. If
a property does not retain integrity, it can no longer convey its significance and is therefore not
eligible for listing in local, state, or national registers.
The seven aspects that define integrity are defined as follows:
Location is the place where the historic property was constructed or the place where
the historic event occurred;
Setting addresses the physical environment of the historic property inclusive of the
landscape and spatial relationships of the building(s);
Design is the combination of elements that create the form, plan, space, structure,
and style of the property;
Materials refer to the physical elements that were combined or deposited during a
particular period of time and in a particular pattern or configuration to form the
historic property;
Workmanship is the physical evidence of the crafts of a particular culture or people
during any given period in history or prehistory;
Feeling is the property’s expression of the aesthetic or historic sense of a particular
period of time; and
Association is the direct link between an important historic event or person and the
historic property.
Location
The La Honda Creek Redwood Cabin retains integrity of location as it has remained in its original
location since construction.
Setting
The La Honda Creek Redwood Cabin retains integrity of setting. The cabin remains in a rural setting,
set within a heavily forested area. The immediate area remains remarkably undeveloped, even with a
more heavily trafficked Skyline Boulevard nearby. The cabin retains its subtle landscaping features
including the stone walls and circular dirt driveway. It is also still accessed by a semi-rural dirt road.
The general area also retains similar use, functioning as a day-use recreational area and year-round
home.
30 California Office of Historic Preservation, Technical Assistance Series No. 7: How to Nominate a Resource to the California Register of Historical
Resources (Sacramento: California Office of State Publishing, September 4, 2001) 11; and U.S. Department of the Interior, National Park
Service, National Register Bulletin: How to Apply the National Register Criteria for Evaluation (Washington, D.C.: National Park Service, 1995) 44.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 35 - Page & Turnbull, Inc.
Design
The La Honda Creek Redwood Cabin retains integrity of design. It does not appear to have any
major design alterations or additions. The building retains its large, rectangular footprint, rustic log
construction, doors and casement windows, stone and wood staircase, stone site features, side-gable
roof, and log fascia. The aluminum skylights are likely alterations; however, the original design
remains legible. The wraparound porch appears predominantly intact, although the rear porch
projection is no longer standing, and the building is still able to convey its rustic style.
Materials
The La Honda Creek Redwood Cabin retains integrity of materials. It does not appear to have any
major alterations and many original elements remain, including the barked redwood logs, plank
decking, rustic deck posts and railing, stone staircase and site elements, stone chimney, wood doors
and windows. The wraparound porch is mostly intact, except for the northern porch and northwest
projecting deck. The porch at the primary façade remains intact, as does the entry staircase. Most
material components appear to remain from the building’s initial construction.
Workmanship
The La Honda Creek Redwood Cabin retains integrity of workmanship. The building remains
representative of workmanship common to rural recreation cabins constructed in the early twentieth
century. The construction and design of the cabin reflect the workmanship of a local builder, such as
the rustic log construction, saddle notches, vertically set log posts, and stone chimney. The building’s
retention of such features is evidence of remaining workmanship.
Feeling
The La Honda Creek Redwood Cabin retains integrity of feeling as a recreational cabin constructed
in a rural setting in the 1920s, during the rise of the automobile era and recreation boom in the
country. The subject building continues to express its historic aesthetic character, as evidenced by its
retention of a rural setting away from development and within a heavily forested area, and its historic
materials and rustic workmanship associated with its era of construction.
Association
The La Honda Creek Redwood Cabin retains integrity of association. Originally constructed as a
recreational cabin for W. B. Allen and his family in the 1920s, the cabin no longer operates as such
and is currently vacant. While the cabin no longer serves as a retreat for the Allen family, it does
remain in a recreational setting. Acquired by the Midpeninsula Regional Open Space District, the
property continues to be surrounded by a recreational area and away from any development. The
property continues to communicate its rural setting. Overall, the cabin retains sufficient enough
integrity of association.
Overall Integrity
The La Honda Creek Redwood Cabin retains sufficient historic integrity to be eligible for listing in
the California Register for Historical Resources as an individual resource.
CHARACTER-DEFINING FEATURES OF THE LA HONDA CREEK REDWOOD CABIN
For a property to be eligible for national, state or local designation under one of the significance
criteria, the essential physical features (or character-defining features) that enable the property to
convey its historic identity must be evident. To be eligible, a property must clearly retain enough of
those characteristics, and these features must also retain a sufficient degree of integrity. Character-
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 36 - Page & Turnbull, Inc.
defining features can be expressed in terms of form, proportion, structure, plan, style, materials, and
ornamentation.
The following character-defining features have been identified for the La Honda Creek Redwood
Cabin and relate to the building’s period of significance, its date of construction, 1927-1928:31
Siting on steep topography in a grove of redwood trees
One-story, rectangular massing and open character under the building
Side-gable roof with exposed rafter tails and barked log fascia
Barked log construction with saddle notched log corners and chinking
Large rustic wood support posts
Massive central stone chimney
Wraparound porch with rustic log railing
Generally symmetrical door and window placement on the east and west façades
Paired wood casement windows with divided lites and unornamented wood surrounds
Wide, solid wood entrance door with decorative iron hardware
Two-panel redwood stile and rail wood doors at secondary entrances, each with an
undivided glazed top panel.
31 Page & Turnbull, Inc., “Basis of Design and Alternative Evaluation: Redwood Cabin,” San Francisco, November 22, 2019.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 37 - Page & Turnbull, Inc.
VII. CONCLUSION
The La Honda Creek Redwood Cabin was constructed circa 1927-1928 by W.B. Allen with the help
of laborers, presumably including local builder Lee Erickson. The subject property appears to be one
of few remaining examples of a permanent recreational cabin from the 1920s with a high degree of
integrity, and which is individually representative of the peak of recreational development in the
Santa Cruz Mountains in the nineteenth century. The cabin does not appear to be significant for an
association with the lives of persons important to local, state, or national history. The cabin’s
longtime owner, W. B. Allen, was a prominent businessman in Palo Alto; however, the cabin was a
secondary residence and does not reflect his business achievements nor his association with the Palo
Alto community. Neither Allen, nor Lee Erickson, appear to be master architects or builders. The
building retains much of its original components and fully articulates its rustic style and is a unique
example of a rustic recreational cabin in the surrounding area. Overall, the La Honda Creek
Redwood Cabin does appear to be locally significant and individually eligible for listing in the
California Register of Historical Resources.
In conclusion, the La Honda Creek Redwood Cabin does appear to be an historic resource for the
purposes of CEQA review.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 38 - Page & Turnbull, Inc.
VIII. REFERENCES CITED
Published Works & Reports
California Office of Historic Preservation. Technical Assistance Series No. 7: How to Nominate a Resource to
the California Register of Historical Resources. Sacramento: California Office of State Publishing,
September 4, 2001.
California Office of Historic Preservation. Technical Assistance Bulletin No. 8: User’s Guide to the
California Historical Resource Status Codes & Historic Resources Inventory Directory. Sacramento:
California Office of State Publishing. November 2004. Accessed October 22, 2018,
http://ohp.parks.ca.gov/pages/1069/files/tab8.pdf.
Dougherty, Bob. La Honda. Charleston, SC: Arcadia Publishing, 2007.
Jones & Stokes. “Final Biological and Cultural Resources Technical Memo and Opportunities and
Constraints Analysis.” 2004.
“La Honda Creek Open Space Preserve Master Plan.” Midpeninsula Regional Open Space District.
August 2012.
Miller, Guy C. and Hugh Enochs, eds. Palo Alto Community Book. Palo Alto: Arthur H. Cawston,
1952.
National Park Service. National Register Bulletin Number 15: How to Apply the National Register Criteria for
Evaluation. Washington, D.C.: National Park Service.
Page & Turnbull, Inc. “Basis of Design and Alternative Evaluation: Redwood Cabin.” San Francisco,
November 22, 2019.
“San Mateo County General Plan.” Environmental Services Agency, San Mateo County Planning &
Building Division. November 1986. Accessed online March 4, 2020,
https://planning.smcgov.org/sites/planning.smcgov.org/files/SMC-GP%201986.pdf.
“Skyline: Santa Cruz Mountains Area Study.” Department of Environmental Management, Planning
and Development Division. San Mateo County, California, July 1982.
Stanger, Frank M. South From San Francisco. San Mateo, CA: San Mateo County Historical
Association, 1963.
---------- Sawmills in the Redwoods: Logging on the San Francisco Peninsula, 1849-1967. San Mateo: San
Mateo County Historical Association, 1967.
Trevenon, Stacy. Kings Mountain. Charleston, SC: Arcadia Publishing, 2008.
Newspapers & Periodicals
Advertisement. San Francisco Examiner. September 14, 1929.
Advertisement. San Francisco Examiner. August 10, 1929.
“Boulder Creek.” Santa Cruz Sentinel. March 1, 1911
“Leander Erickson Funeral Services Set For Monday.” Santa Cruz Evening News. May 14, 1938.
“Lloyd Allen Boasts of a Very Successful Record With Fishing Rod and Gun.” San Francisco Chronicle.
January 14, 1923.
“New apostle called to serve LDS Church.” Ukiah Daily Journal. January 27, 1976.
Santa Cruz Evening News. October 8, 1927.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 39 - Page & Turnbull, Inc.
Santa Cruz Evening News. October 13, 1927.
“Summer Home Is Being Completed In Boulder Creek.” Santa Cruz Evening News. June 20, 1931.
Public Records
California Historical Resource Information System (CHRIS), Historic Property Data File for San
Francisco County. March 4, 2012.
Meeting Notes. Midpeninsula Regional Open Space District. June 26, 2002, R-02-79.
Paulin, Joan. Personal communication. October 4, 2004.
San Mateo County Office of the Assessor-Record Parcel Maps.
San Mateo County Department of Building Inspection.
United States Census. Accessed via Ancestry.com.
U.S. Geological Survey Topographic Maps. Accessed via U.S.G.S. TopoView.
Archival Records
Bromfield, Davenport, County Surveyor. Official Map of San Mateo County, California. 1894.
County of San Mateo, Master Index Map, Revision 2, June 1985. Redwood City, California: County
of San Mateo Assessor.
Historic Development Totals (Unincorporated San Mateo County). County of San Mateo Assessor’s
Standards Division Records. On file at the San Mateo County Historical Association
Archives.
Kneese, George A., County Surveyor. Official Map of San Mateo County, California. 1927.
Neumann, J.V., County Surveyor. Official Map of San Mateo County, California. 1909.
Official Map of the County of San Mateo, California. 1868. On file at the San Mateo County History
Museum Archives.
Sanborn Fire Insurance Maps. Accessed via San Francisco Public Library.
San Francisco City Directories. San Francisco Public Library.
Internet Sources
Google Earth. 2020.
Google Street View. 2007-2020.
“Meet George and Mary Bordi.” The La Honda Voice. January 29, 2011. Accessed February 22, 2020,
https://lahonda.typepad.com/the_voice/2011/01/meet-george-and-mary-bordi.html.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 40 - Page & Turnbull, Inc.
APPENDIX
APPENDIX A – PREPARER QUALIFICATIONS
This Historic Resource Evaluation was prepared by Page & Turnbull of San Francisco, California.
Page & Turnbull staff responsible for this report include Peter Birkholz, AIA, LEED AP, Principal-
in-charge; Sarah Brummett, Associate AIA, Project Manager; and Alicia Sanhueza, Cultural
Resources Planner and primary author. All professional staff working on this report meet or exceed
the Secretary of the Interior’s Professional Qualification Standards for Historic Architecture,
Architectural History, or History.
Exhibit A
Historic Resource Evaluation - Draft La Honda Creek Redwood Cabin
[19019] La Honda Creek Open Space Preserve
Midpeninsula Regional Open Space
March 26, 2020 - 41 - Page & Turnbull, Inc.
APPENDIX B – APPRAISAL REPORT, SAN MATEO COUNTY ASSESSOR’S OFFICE
Exhibit A
Exhibit A
417 S. Hill Street, Suite 211
Los Angeles, California 90013
213.221.1200 / 213.221.1209 fax
2401 C Street, Suite B
Sacramento, California 95816
916.930.9903 / 916.930.9904 fax
170 Maiden Lane, 5th Floor
San Francisco, CA 94108
415.362.5154 / 415.362.5560 fax
ARCHITECTURE
PLANNING & RESEARCH
PRESERVATION TECHNOLOGY
www.page-turnbull.com
Exhibit A
170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
Imagining change in historic environments through
design, research, and technology
MEMORANDUM
DATE September 8, 2021 PROJECT
NUMBER
20230
TO Alta Cunningham
Ascent Environmental
PROJECT OSP White Barn and
Redwood Cabin CEQA
Consultation
OF 455 Capitol Mall, Suite 300
Sacramento, CA 95814
916.306.2635
Alta.cunningham@ascentenvironmental.com
FROM Christina Dikas, Associate
Principal, Page & Turnbull;
Clare Flynn, Cultural
Resources Planner, Page &
Turnbull
REGARDING La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum
INTRODUCTION
This Landscape Evaluation Commentary Memorandum has been prepared for Ascent Environmental
and the Midpeninsula Regional Open Space District to evaluate the need for a historic evaluation of
the landscape components at the La Honda Creek Redwood Cabin property. The property is located
in the La Honda Creek Open Space Preserve in an unincorporated area of San Mateo County, just
west of the town of Woodside, California.
HISTORIC SIGNIFICANCE OF LA HONDA CREEK REDWOOD CABIN
In March 2020, Page & Turnbull prepared a Historic Resource Evaluation Report (HRE) for the La
Honda Creek Redwood Cabin and found the property to be eligible for listing on the California
Register of Historical Resources (California Register) under Criterion 1 (Events) and Criterion 3
(Architecture). The significance evaluation for the property under these criteria are excerpted below:
Criterion 1 (Events)
The La Honda Creek Redwood Cabin does appear to be significant under Criterion 1
(Events) as a property associated with events that have made a significant
contribution to the broad patterns of local or regional history, or the cultural
heritage of California or the United States. According to various accounts, the
Redwood Cabin was constructed in the 1927-1928 by Palo Alto businessman W. B.
Allen with the aid of labormen. The cabin was constructed at a peak of outdoor
recreation in the Santa Cruz Mountains. The Redwood Cabin’s construction appears
Exhibit A
La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum
Page 2 of 5
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
representative of a broader pattern of recreational development in the Santa Cruz
Mountains following the San Francisco Peninsula’s logging boom, specifically at a
time when recreation shifted from camps to cabins and early subdivisions. While the
cabin does not appear to be one of the earliest recreational cabins (from the late
1800s and early 1900s), it appears to be one of the last remaining ones intact from
the transition era to permanent structures. Most of the original lodges and hotels
appear nonextant. Due to the rural nature of the area, not all nearby properties were
surveyed; however, those that were appeared not age eligible or altered. The
Redwood Cabin appears to be a rare building typology and retains its original rural
setting. Therefore, the property does appear to be individually eligible for listing
under Criterion 1 with its period of significance, 1927-1928, the years of its
construction.
Criterion 3 (Architecture)
The La Honda Creek Redwood Cabin does appear to be individually eligible for listing
in the California Register under Criterion 3 (Architecture) as a building that embodies
the distinctive characteristics of a type, period, region, or method of constructio n, or
that represents the work of a master or possesses high artistic values. The Redwood
Cabin is a large, one-story side-gabled rectangular log cabin with an open
wraparound plank deck. It is constructed of barked redwood logs of various sizes,
with saddle notches that are set unconventionally and upside down. The cabin and
deck are supported by large rustic wood posts, some of which are set in concrete
and others of which are set on grade. The cabin features a large centered stone
chimney that connects to an expansive interior fireplace, its foundation visible from
beneath the cabin. Its openings consist of what appear to be original wood sash
multi-lite windows, a large, handmade redwood door with iron details, and paneled
one-lite wood doors and wood multi-lite French doors throughout. It is unclear who
designed the cabin, and if it was the result of an architect or kit plan. According to
district records, it was constructed in 1927-1928 by businessman W.B. Allen with the
help of two laborers. Research suggests that the building could have been
constructed by Finnish builder Lee Erickson, a local builder of similar cabins. W.B.
Allen and Lee Erickson do not appear to be master architects or builders. Much of
the cabin appears to be original. The building clearly utilizes local materials, and
while its construction method appears slightly “primitive,” it appears indicative of the
rural, woodsy character of the area and the period in which the region was
transitioning to more permanent recreational structures. As such, the Redwood
Cabin does appear to be a unique property type or architectural style such that it
would rise to the level of individual significance within a local context. In conclusion,
the La Honda Creek Redwood Cabin does appear to be individually eligible for listing
under Criterion 3.1
1 Page & Turnbull, “La Honda Creek Redwood Cabin Historic Resource Evaluation Report,” 2020, 31-32.
Exhibit A
La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum
Page 3 of 5
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
Based on this evaluation, the property appears to be a historic resource under CEQA.
EXISTING LANDSCAPE FEATURES
The significance evaluation contained in the 2020 HRE by Page & Turnbull focused primarily on the
Redwood Cabin building. The La Honda Creek Redwood Cabin property also includes several
landscape and site features. Existing landscape features described in the 2020 HRE include the
following:
▪ Heavily wooded, rural surroundings
▪ Sloping terrain
▪ Narrow dirt access road that leads to the site from Skyline Boulevard
▪ Circular dirt driveway that surrounds a small grove of redwoods
▪ Stone walls that partially delineate the driveway’s outer edges
▪ Stone stairs leading to the cabin
▪ Horseshoe pit
▪ Stone barbeque pit
▪ Brick planter or pit
Other site features, including two garages and a caretaker’s cabin that were formerly located around
the circular driveway, were relocated in 1966. The garages were constructed in 1953; research has
not revealed the date of construction of the caretaker’s cabin. The current location and status of
these features is unknown.
LANDSCAPE EVALUATION COMMENTARY
The 2020 HRE by Page & Turnbull included a brief physical description of site features at the La
Honda Creek Redwood Cabin property but focused primarily on evaluating the cabin itself. The
following discussion provides a brief summary of known information about the existing landscape
features on the site and assesses the need for further historic evaluation of these features.
While the Redwood Cabin, itself, was constructed around 1927 to 1928 for owner W.B. Allen,
research has not definitively revealed the original date of construction, builder, use, and any other
historic associations of the individual landscape features on the site. Without this information, it is
not known whether these features contribute to the property’s overall significance under Criteria 1
and 3 for listing on the California Register. The features are clustered around the cabin and most
likely served a support function for the cabin and its occupants. Due to their ancillary nature, the
historic significance of these landscape features is likely to be dependent upon and inextricably
connected to the cabin. Thus, removing the cabin but retaining the surrounding contributing
landscape features would result in a loss of any associative historic significance that the landscape
features may possess, as well.
Exhibit A
La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum
Page 4 of 5
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
Furthermore, the landscape features at the La Honda Creek Redwood Cabin property do not appear
to be individually historically significant as separate entities from the Redwood Cabin. The stone
walls along the circular driveway, as well as the stairs leading up to the cabin and various hiking
trails throughout the site, were reportedly constructed by W.B. Allen, using stones imported from
the California coast. There is speculation that the Civilian Conservation Corps (CCC) may have
assisted with the construction of these walls and helped improve other roads in the surrounding
area in the 1930s.2 However, no clear documentary evidence has been uncovered to date that
confirms that the CCC did, in fact, construct the walls or any other features at the La Honda Creek
Redwood Cabin property. The CCC’s involvement with a project on privately owned land seems
unlikely, given that the program’s primary focus was to employ young men in conservation work on
public land, most of which consisted of National Forests, throughout the United States. The CCC,
originally known as the Emergency Conservation Work (ECW) program, was established in 1933 as a
New Deal era program during the Great Depression. In 1937, the program was formally renamed
the Civilian Conservation Corps.3 The ECW/CCC’s primary focus on completing projects on public
land is spelled out in the act that established the ECW program, which authorized:
[…] employing citizens in the construction, maintenance and carrying on of works of
a public nature in connection with the forestation of lands belonging to the United
States or to the several States which are suitable for timber production, the
prevention of forest fires, floods and soil erosion, plant pest and disease control, the
construction, maintenance or repair of paths, trails and fire-lanes in the national
parks and national forest, and such other work on the public domain, national and
State, and Government reservations incidental to or necessary in connection with
any projects of the character enumerated, as the President may determine to be
desirable: Provided, that the President may in his discretion extend the provisions of
this Act to lands owned by counties and municipalities and lands in private
ownership, but only for the purpose of doing thereon such kinds of cooperative work
as are not provided for by Acts of Congress in preventing and controlling forest fires
and the attacks of forest tree pests and diseases and such work as is necessary in
the public interest to control floods.4
2 The 2012 La Honda Creek Open Space Preserve Master Plan states that it was the California Conservation Corps that
assisted with the construction of these walls. As the California Conservation Corps was created in the 1970s under Governor
Jerry Brown, this appears to refer to California’s branch of the New Deal-era Civilian Conservation Corps, which was active
from 1933 to 1942.
3 John C. Paige, “The Civilian Conservation Corps and The National Park Service, 1933-1942, An Administrative History,
(Washington, DC: National Park Service, U.S. Department of the Interior, 1985), 24.
4 “An act for the relief of unemployment through the performance of useful public work, and for other purposes,” March 31,
1933, Public No. 5, 73d Congress.
Exhibit A
La Honda Creek Redwood Cabin Landscape Evaluation Commentary Memorandum
Page 5 of 5
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
Although this act indicates that some ECW/CCC projects may have occurred on private lands, such
projects seem to have been relatively rare. Typically, such cases occurred when it was necessary to
expand projects that had started on public land onto immediately adjacent private properties in
order to fully and adequately complete the planned work. In such instances, each case was
evaluated and granted permission by the Office of the Director of the Emergency Conservation
Work.5 The construction of stone walls along a private road does not appear to fall under the
requirement that work by the CCC on private lands was intended to prevent or control forest fires,
pests, or floods. Furthermore, as there are no National Parks, National Forests, or State Parks in the
immediate vicinity of the La Honda Creek Redwood Cabin site, such an exemption for ECW/CCC
work to occur on private land appears unlikely. It is possible that the stone walls and stairs at the La
Honda Creek Redwood Cabin property were constructed with the assistance of individuals who had
at some point been involved with the CCC; however, there is currently no evidence to support this.
Even if evidence proved that the CCC did construct walls or other features on the property, every
landscape feature, piece of infrastructure, or other improvement constructed by the CCC across the
country is not automatically considered historic or individually significant. A relatively small and
discrete expanse of stone wall and stair located on a private property is not likely to rise to the level
of an individually significant example of the CCC’s work.
Similar arguments can be made with regard to the individual significance of the horseshoe pit,
barbeque pit, brick planter or pit, circular driveway, and narrow dirt access road. The features do not
appear to have historic significance apart from their association with th e Redwood Cabin.
Demolishing the Redwood Cabin, which serves as the primary focal point for the property, but
retaining these features would impair the setting, design, association, and feeling that characterize
the integrity of these features.
CONCLUSION
Based on this review, Page & Turnbull finds that a separate historic evaluation of the landscape
features at the La Honda Creek Redwood Cabin property is unnecessary. The features do not appear
to possess individual historic significance apart from the Redwood Cabin. The landscape features
were likely built as auxiliary features that served the Redwood Cabin and its occupan ts; therefore,
any potential historic significance they may possess is likely to be as site features associated with the
cabin itself.
5 Paige, 19-20.
Exhibit A
Page 1
Redwood Cabin Removal Project Findings of Fact and
Midpeninsula Regional Open Space District Statement of Overriding Considerations
CEQA FINDINGS OF FACT
and
STATEMENT OF OVERRIDING CONSIDERATIONS
OF THE MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
for the
REDWOOD CABIN REMOVAL PROJECT
ENVIRONMENTAL IMPACT REPORT
SEPTEMBER 30, 2022
Exhibit B
Page 2
Redwood Cabin Removal Project Findings of Fact and
Midpeninsula Regional Open Space District Statement of Overriding Considerations
I. INTRODUCTION
On October 28, 2022, the final environmental impact report (EIR) prepared on behalf of Midpeninsula
Regional Open Space District (Midpen) was released. Pursuant to Public Resources Code section 21081,
Midpen, acting through its Board of Directors, adopts the following findings for the Redwood Cabin
Removal Project (project) in accordance with the California Environmental Quality Act (CEQA) (Pub.
Resources Code, § 21000 et seq.) and the CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.).
This document is organized as follows:
Section I introduces the findings.
Section II describes the project proposed for approval, and the approval actions to be taken.
Section III describes the environmental review process for the project, including public scoping and
review of the project.
Section IV identifies the Record of Proceedings for this matter, including the administrative record upon
which Midpen’s approval of the project is based upon and the location of records.
Section V provides general guidance regarding Midpen’s adoption of these findings.
Section VI includes Midpen’s findings with respect to the project’s potentially significant impacts.
Attached to these findings is a table summarizing the findings for each environmental impact evaluated,
including specific mitigation measures, to be adopted by Midpen in connection with its approval of the
project. Attachment 1 to the Board Report includes the full text of each mitigation measure adopted by the
Disctrict. Section VI also addresses mitigation measures and project modifications proposed by
commenters, and Midpen’s findings with respect to these proposals.
Section VII adopts and incorporates the Mitigation Monitoring and Reporting Program (“MMRP”) for
the mitigation measures that have been proposed for adoption. In adopting these findings, Midpen hereby
adopts and commits to implement the MMRP. The measures set forth in the MMRP represent binding
commitments to which the project applicant must comply.
Section VIII sets forth Midpen’s findings with respect to recirculation of the Draft EIR.
Section IX sets forth Midpen’s findings with respect to alternatives to the project. These findings are
adopted pursuant to Public Resources Code sections 21002 and 21081, subdivision (a)(3).
Section X sets forth Midpen’s statement of overriding considerations concerning the project. These
findings are adopted pursuant to Public Resources Code section 21081, subdivision (b).
The findings and determinations contained herein are based on the competent and substantial evidence,
both oral and written, contained in the entire record relating to the project and the EIR. The findings and
determinations constitute the independent findings and determinations by Midpen in all respects and are
fully and completely supported by substantial evidence in the record as a whole.
Although the findings below identify specific pages within the Draft EIR and Final EIR documents
(which, together, constitute the Final EIR) in support of various conclusions reached below, Midpen
incorporates by reference and adopts as its own, the reasoning set forth in the Final EIR, and thus relies
on that reasoning, even where not specifically mentioned or cited below, in reaching the conclusions set
forth below, except where additional evidence is specifically mentioned. Midpen further intends that if
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these findings fail to cross-reference or incorporate by reference any other part of these findings, any
finding required or permitted to be made by Midpen with respect to any particular subject matter of the
project must be deemed made if it appears in any portion of these findings or findings elsewhere in the
record.
These Findings, along with the Statement of Overriding Considerations set forth in Section X, the table of
findings set forth below, and the Mitigation Monitoring and Reporting Program (“MMRP”) set forth in
Attachment 1 to the Board Report, are made with respect to the project approvals for the project and state
the findings of Midpen’s Board of Directors relating to the potentially significant environmental effects of
the project in accordance with the project approvals. The following Findings, along with the Statement of
Overriding Considerations, and MMRP are hereby adopted by Midpen Board of Directors as required by
the California Environmental Quality Act, Public Resources Code Sections 21002, 21081, 21081.5 and
21081.6, and CEQA Guidelines sections 15091 through 15093.
II. PROJECT DESCRIPTION
The following text briefly describes the project. See Chapter 2, Project Description, of the Draft EIR for a
complete and detailed description of the project.
A. Project Location
The project site is located within the upper portion of the La Honda Creek Open Space Preserve
(Preserve) in San Mateo County, California. The Redwood Cabin is situated within the upper portion of
the Preserve. The Preserve encompasses 6,142 acres in the Santa Cruz Mountains within unincorporated
San Mateo County, approximately 5 miles east of the Pacific Ocean. The Preserve is bounded by
Highway 35 (Skyline Boulevard) to the north, by Highway 84 (La Honda Road) to the east and south, and
by Bogess Creek to the west.
The Redwood Cabin occupies a portion of Assessor’s Parcel Number 075-330-260 and is located west of
the community of Skylonda, California. The project site is designated for Forest/Timber Production land
uses under the San Mateo County General Plan and is zoned as Timber Land Preserve District under the
San Mateo County Zoning Ordinance. Access to the Redwood Cabin is provided via an unpaved road
accessible from Skyline Boulevard, which travels through two locked gates. The final segment of this
unpaved road requires a four-wheel drive vehicle or access by foot.
The project site is located in a wooded area within a portion of the Preserve that is currently not open to
the public. The building is situated atop sloped terrain overlooking a circular dirt driveway that surrounds
a small grove of redwood trees.
B. Project Overview
The Redwood Cabin is a large, side-gabled log cabin with a rectangular floor plan. The Redwood Cabin
was constructed by W.B. Allen from 1927-1928 and served as a recreational retreat for Allen’s family and
guests, including the YMCA and Rotary Club. The Redwood Cabin was acquired by the Midpeninsula
Regional Open Space District (Midpen) in 1988 and has since remained uninhabited. Today, the
Redwood Cabin stands in a deteriorated state, posing a significant site safety hazard and has been the site
of numerous trespassing and vandalism incidents (including fire ignitions) that raise concerns regarding
overall public safety and fire risk within a very high fire severity zone. The project would entail
demolition of the Redwood Cabin and removal of associated features onsite, including the stone retaining
walls, barbeque and fire pits. Prior to demolition activities, lead-based paint present within the structure
would be properly removed and disposed of.
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While it is expected that excavation of posts and bases associated with the structure would be
approximately 2 feet below grade, it is possible that maximum depth of excavation could reach up to 5
feet. During demolition of the structure, it is estimated that approximately 60 tons of material would be
removed from the project site. Tree removal will not be required to facilitate demolition activities,
although some brush clearing along the access road may be necessary.
Following completion of demolition activities, disturbed areas would be recontoured and erosion control
applied to the site to ensure adequate site drainage. All demolition and recontoured areas would be
compacted to 75 percent relative compaction. Native grass seed mix would be spread in the disturbed
areas and weed free or native grass straw would be placed in the disturbed areas, on top of the native
grass seed mix, to assist with soil stabilization and erosion control. Any wood chips or mulch generated
from unsalvageable building materials may also be used to stabilize disturbed areas but will not be more
than 3 inches in depth. Midpen may also conduct the following activities on the project site after
demolition and recontouring:
soil decompaction activities outside of critical rootzones,
soil testing and, if needed, spot application of amendments such as fertilizers, lime, or organic
materials, and
revegetation or plantings.
Midpen also conducts early detection rapid response surveys for up to 3 years at revegetation sites and
treats any invasive plant species on the early detection rapid response list. Other priority integrated pest
management target species, including slender false brome may be treated prior to and after demolition.
Slender false brome is an invasive weed of high concern at the project site; due to Midpen’s mandatory
quarantine of this weed, all slender false brome in the area will be treated prior to any work being
completed.
Midpen has adopted numerous best management practices (BMPs) that are intended to avoid and
minimize environmental impacts and comply with applicable laws and regulations. These BMPs would
be incorporated into the design of the project and include environmental protection guidelines (EPGs)
identified in Midpen’s La Honda Creek Open Space Preserve Master Plan and the associated 2012 Initial
Study/Mitigated Negative Declaration; BMPs from Midpen’s 2014 Integrated Pest Management Program
(IPMP) and subsequent 2019 IPMP addendum, and additional BMPs that are specific to this project to
avoid and minimize environmental impacts and comply with applicable laws and regulations. These
include BMPs related to air quality, biological resources, cultural resources, greenhouse gas emissions,
hazardous materials, hydrology and water quality, and noise.
Current activity at the project site consists of occasional visits from Midpen staff for inspections. Once
removal of the structure and site recontouring/erosion control activities are complete, no additional
maintenance or operational activities would be required at the project site except for invasive plant
species treatment, if needed. The site would remain closed to the public.
C. Project Objectives
The proposed project is intended to achieve the following primary objectives, in alignment with Midpen’s
mission:
Remove physical hazards to ensure public safety,
Enhance habitat and natural ecological function at the Redwood Cabin site and immediate
surroundings,
Reduce structure and wildland fire risk by removing a structure with a history of vandalism,
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Improve natural visual character and scenic open space qualities at the site, and
Implement a fiscally sustainable project consistent with Midpen’s mission as an open space district.
D. Discretionary Approvals
Project approval requires Midpen, as lead agency under CEQA, as well as certain “responsible agencies”
to take various planning and regulatory actions to approve the overall project. Described below are
discretionary actions necessary to carry out the project. In addition to Midpen’s certification of the Final
EIR and adoption of these Findings and MMRP (CEQA requirements), the project may be subject to the
permitting requirements of County of San Mateo, San Francisco Bay Regional Water Quality Control
Board, and the Bay Area Air Quality Management District.
III. ENVIRONMENTAL REVIEW PROCESS
In accordance with section 15082 of the CEQA Guidelines, Midpen prepared and distributed an NOP for
this EIR on June 9, 2021. The NOP provided a brief description of the project, a map of the project
location, and an overview of the environmental review process. The purpose of the NOP was to provide
notification that an EIR for the project would be prepared and to solicit guidance on the scope and content
of the document. The NOP invited all interested parties to provide comments during a 30-day period. The
NOP was available on Midpen’s website and was distributed to responsible agencies, nearby jurisdictions,
adjacent landowners, and local resource protection organizations.
Midpen hosted a virtual public scoping meeting to inform stakeholders about the project and solicit input
regarding environmental topics and alternatives to be evaluated in the EIR. The scoping meeting was held
during the Midpen Board of Directors meeting on June 23, 2021. The comments received on the NOP and
at the scoping meeting were addressed, as applicable, in each technical section of the Draft EIR.
Appendix A of the Draft EIR contains a copy of the NOP and comment letters received on the NOP.
Under the CEQA statutes and the State CEQA Guidelines, a lead agency may limit an EIR’s discussion of
environmental effects when such effects are not considered potentially significant (Public Resources Code
Section 21002.1[e]; State CEQA Guidelines Sections 15128, 15143). The EIR includes an analysis of the
following issue areas:
Biological Resources; and
Cultural Resources.
On April 14, 2022, the Draft EIR was released for a 45-day public review and comment period that ended
on May 31, 2022 (this public review period is consistent with the review period set forth in Section 15105
of the CEQA Guidelines). The Draft EIR was submitted to the State Clearinghouse, posted on Midpen’s
website (https://www.openspace.org/who-we-are/public-notices ), and made available at the Midpen
Administrative Office and the Woodside Public Library. In addition, a notice of availability of the Draft
EIR was distributed to public agencies (including potential responsible and trustee agencies), adjacent
landowners, and interested parties and organizations. The notice of availability of the Draft EIR was also
published in the Half Moon Bay Review and the Bay Area News Group.
On October 28, 2022, Midpen released the Final EIR for the project. The Final EIR includes comments on
the Draft EIR, responses to those comments, revisions to the text of the Draft EIR, and other information
required by CEQA.
On November 9, 2022, Midpen held a duly noticed public hearing to consider the Final EIR. The Board
received public comment and concluded the public hearing. The Board of Directors has reviewed and
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considered, as a whole, the evidence and analysis presented in the Draft EIR, in the comments on the
Draft EIR, and in the Final EIR, the information submitted on the Final EIR, and the reports prepared by
the experts who prepared the EIR, Midpen’s planning consultants, and by staff, and after receiving and
considering public comment, makes the findings set forth herein.
IV. RECORD OF PROCEEDINGS
In accordance with Public Resources Code section 21167.6, subdivision (e), the record of proceedings for
Midpen’s decision on the project includes the following documents:
The NOP and all other public notices issued by Midpen in conjunction with the project;
All comments submitted by agencies or members of the public during the comment period on the
NOP;
The Draft EIR for the project (April 2022) and all appendices;
All comments submitted by agencies or members of the public during the comment period on the
Draft EIR;
The Final EIR for the project, including comments received on the Draft EIR, and responses to those
comments and appendices (October 2022);
Documents cited or referenced in the Final EIR;
The MMRP for the project;
All findings and resolutions adopted by Midpen in connection with the project and all documents
cited or referred to therein;
All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the
project prepared by Midpen, consultants to Midpen, as well as responsible or trustee agencies with
respect to Midpen’s compliance with the requirements of CEQA and with respect to Midpen’s action
on the project;
All documents submitted to Midpen by other public agencies or members of the public in connection
with the project, up through the close of the Board’s public hearing on November 9, 2022;
Any minutes and/or verbatim transcripts of all information sessions, public meetings, and public
hearings held by Midpen in connection with the project;
Any documentary or other evidence submitted to Midpen at such information sessions, public
meetings, and public hearings;
Any and all resolutions adopted by Midpen regarding the project, and all staff reports, analyses, and
summaries related to the adoption of those resolutions;
Matters of common knowledge to Midpen, including, but not limited to federal, state, and local laws
and regulations;
Any documents expressly cited in these findings, in addition to those cited above; and
Any other materials required for the record of proceedings by Public Resources Code section
21167.6, subdivision (e).
Midpen has relied on all of the documents listed above in reaching its decision on the project, even if not
every document was formally presented to Midpen. Without exception, any documents set forth above not
so presented fall into one of two categories. Many of them reflect prior planning or legislative decisions
with which Midpen was aware in approving the project. Other documents influenced the expert advice
provided to Planning Department staff or consultants, who then provided advice to the Board of
Directors. For that reason, such documents form part of the underlying factual basis for Midpen’s
decisions relating to the adoption of the project.
The record of proceedings does not include documents or other materials subject to the attorney/client
privilege, the common-interest doctrine, the deliberative process privilege, or other privileges recognized
by statute or common law. Administrative draft documents that were prepared at Midpen’s direction, but
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were not provided to the public or other agencies, and intra-County communications with respect to such
administrative draft documents, are not part of the record of proceedings; rather, such documents reflect
Midpen’s deliberative process, and reflect initial drafts of documents that later appeared in final form in
the record of proceedings. Because these initial working drafts do not reflect the final evidence and
analysis relied upon by Midpen, they are not part of the record of proceedings. In adopting these findings,
Midpen does not waive its right to assert applicable privileges.
Pursuant to Public Resource Code §15091, Midpen is the custodian of the documents and other materials
that constitute the record of proceedings upon which the decision is based, and such documents and other
materials are located at Midpen’s Administrative Office, 5050 El Camino Real, Los Altos, CA 94022.
Copies of the Draft and Final EIRs are also available on Midpen’s website at
https://www.openspace.org/who-we-are/public-notices.
V. FINDINGS REQUIRED UNDER CEQA
The California Environmental Quality Act, Public Resources Code §§ 21000 et seq. and the regulations
implementing that statute, Cal. Code Regs. tit. 14, §§ 15000 et seq. (the “CEQA Guidelines”)
(collectively, the act and the CEQA Guidelines are referred to as “CEQA”) require public agencies to
consider the potential effects of their discretionary activities on the environment and, when feasible, to
adopt and implement mitigation measures that avoid or substantially lessen the effects of those activities
on the environment. Specifically, Public Resources Code section 21002 provides that “public agencies
should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures
available which would substantially lessen the significant environmental effects of such projects[.]” The
same statute states that the procedures required by CEQA “are intended to assist public agencies in
systematically identifying both the significant effects of proposed projects and the feasible alternatives or
feasible mitigation measures which will avoid or substantially lessen such significant effects.” Section
21002 goes on to state that “in the event [that] specific economic, social, or other conditions make
infeasible such project alternatives or such mitigation measures, individual projects may be approved in
spite of one or more significant effects thereof.”
The mandate and principles announced in Public Resources Code Section 21002 are implemented, in part,
through the requirement that agencies must adopt findings before approving projects for which EIRs are
required. (See Pub. Resources Code, § 21081, subd. (a); CEQA Guidelines, § 15091, subd. (a).) For each
significant environmental effect identified in an EIR for a proposed project, the approving agency must
issue a written finding reaching one or more of three permissible conclusions. The three possible findings
are:
(1) Changes or alterations have been required in, or incorporated into, the project which
mitigate or avoid the significant effects on the environment.
(2) Those changes or alterations are within the responsibility and jurisdiction of another
public agency and have been, or can and should be, adopted by that other agency.
(3) Specific economic, legal, social, technological, other considerations, including
considerations for the provision of employment opportunities for highly trained
workers, make infeasible the mitigation measures or alternatives identified in the
environmental impact report.
(Pub. Resources Code, § 21081, subd (a); see also CEQA Guidelines, § 15091, subd. (a).)
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Public Resources Code section 21061.1 defines “feasible” to mean “capable of being accomplished in a
successful manner within a reasonable period of time, taking into account economic, environmental,
social and technological factors.” CEQA Guidelines section 15364 adds another factor: “legal”
considerations. (See also Citizens of Goleta Valley v. Board of Supervisors (Goleta II) (1990) 52 Cal.3d
553, 565.)
The concept of “feasibility” also encompasses the question of whether a particular alternative or
mitigation measure promotes the underlying goals and objectives of a project. (City of Del Mar v. City of
San Diego (1982) 133 Cal.App.3d 401, 417 (City of Del Mar).) “[F]easibility” under CEQA encompasses
‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic,
environmental, social, and technological factors.” (Ibid.; see also Sequoyah Hills Homeowners Assn. v.
City of Oakland (1993) 23 Cal.App.4th 704, 715 (Sequoyah Hills); see also California Native Plant
Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001 [after weighing “‘economic,
environmental, social, and technological factors’ … ‘an agency may conclude that a mitigation measure
or alternative is impracticable or undesirable from a policy standpoint and reject it as infeasible on that
ground’”].)
With respect to a project for which significant impacts are not avoided or substantially lessened, a public
agency, after adopting proper findings, may nevertheless approve the project if the agency first adopts a
statement of overriding considerations setting forth the specific reasons why the agency found that the
project's “benefits” rendered “acceptable” its “unavoidable adverse environmental effects.” (CEQA
Guidelines, §§ 15093, 15043, subd. (b); see also Pub. Resources Code, § 21081, subd. (b).)
In making these findings and the determination regarding the project approvals, the Board of Directors
recognizes that the project implicates potentially controversial environmental issues and that a range of
technical and scientific opinion exists with respect to those issues. The Board of Directors has acquired an
understanding of the range of this technical and scientific opinion by its review of the EIR, the comments
received on the Draft EIR and the responses to those comments in the Final EIR, as well as testimony,
letters and reports regarding the Final EIR and the merits of the project. The Board of Directors has
reviewed and considered, as a whole, the evidence and analysis presented in the Draft EIR, in the
comments on the Draft EIR, and in the Final EIR, the information submitted on the Final EIR, and the
reports prepared by the experts who prepared the EIR, Midpen’s technical consultants, and by staff,
addressing these comments. In particular, the Board of Directors has considered the alternatives presented
in the EIR, as well as the proposed comments submitted by various commenters and the responses of the
EIR preparers and staff to those comments. The Board of Directors has gained a comprehensive and well-
rounded understanding of the environmental issues presented by the project. In turn, that understanding
has enabled the Board of Directors to make its decisions after weighing and considering the various
viewpoints on these important issues. Accordingly, the Board of Directors certifies that its findings are
based on a full appraisal of all of the evidence contained in the Final EIR, as well as the evidence and
other information in the record addressing the Final EIR.
These findings provide the written analysis and conclusions of the Board of Directors regarding the
environmental impacts of the project and the mitigation measures included as part of the Final EIR and
adopted by the Board of Directors as part of the project. To avoid duplication and redundancy, and
because the Board of Directors agrees with, and hereby adopts, the conclusions in the Final EIR, these
findings will not always repeat the analysis and conclusions in the Final EIR, but instead incorporates
them by reference herein and relied upon them as substantial evidence supporting these findings.
Because the EIR identified significant effects that may occur as a result of the project, and in accordance
with the provisions of the CEQA presented above, the Board of Directors hereby adopts these findings as
part of the approval of the Redwood Cabin Removal Project. These findings constitute the Board of
Directors’ best efforts to set forth the evidentiary and policy bases for its decision to approve the project
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in a manner consistent with the requirements of CEQA. These findings, in other words, are not merely
informational, but rather constitute a binding set of obligations that come into effect with the Board of
Directors’ approval of the project.
VI. POTENTIALLY SIGNIFICANT EFFECTS AND MITIGATION MEASURES
The EIR identified a number of significant and potentially significant environmental effects (or impacts)
that the project will cause or contribute to. These significant effects can be avoided or substantially
lessened through the adoption of feasible mitigation measures.
Midpen Board of Directors’ findings with respect to the project’s significant effects and mitigation
measures are summarized in a table herein below. The table does not attempt to describe the full analysis
of each environmental impact contained in the Final EIR. Instead, the table provides a summary
description of each impact, describes the applicable mitigation measures identified in the Final EIR and
adopted by Midpen, and states Midpen’s findings on the significance of each impact after imposition of
the adopted mitigation measures. A full explanation of these environmental findings and conclusions can
be found in the Draft EIR and Final EIR. Midpen has adopted all of the mitigation measures identified in
the table. Some of the measures identified in the table are also within the jurisdiction and control of other
agencies. To the extent any of the mitigation measures are within the jurisdiction of other agencies,
Midpen finds those agencies can and should implement those measures within their jurisdiction and
control.
A. Significant and Unavoidable Effects
For this project, the following impacts were identified as significant and unavoidable. That is, these
impacts remain significant, despite the incorporation of all feasible mitigation measures to substantially
lessen or avoid these impacts:
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would involve removal of the Redwood Cabin which has been
recommended eligible for listing in the California Register of Historical Resources. Thus, the project
would adversely result in significant changes to a historical resource, as defined by CEQA. Mitigation
Measure 3.2-1 requires Midpen to complete documentation of the structure, which involves preparation of
written history for the property, plans and drawings of the historical resource, and photographs. However,
even after implementation of Mitigation Measure 3.2-1, the project would still result in a significant and
unavoidable impact because the historical resource would no longer exist.
VII. MITIGATION MONITORING AND REPORTING PROGRAM
Midpen has prepared a MMRP for the project. A copy of the MMRP is included as Attachment 1.c. of the
Board Report. Midpen, in adopting these findings, also approves the MMRP. Midpen will use the MMRP
to track compliance with project mitigation measures. The MMRP will remain available for public review
during the compliance period. The MMRP is attached to and incorporated into the project and is approved
in conjunction with certification of the EIR and adoption of these Findings of Fact. In the event of any
conflict between these findings and the MMRP with respect to the requirements of an adopted mitigation
measure, the more stringent measure shall control, and shall be incorporated automatically into both the
findings and the MMRP.
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VIII. RECIRCULATION OF DRAFT EIR
In the course of responding to comments received during the public review and comment period on the
Draft EIR, certain portions of the Draft EIR have been modified to add clarification. No information has
revealed the existence of: (1) a significant new environmental impact that would result from the project or
an adopted mitigation measure; (2) a substantial increase in the severity of an environmental impact; (3) a
feasible project alternative or mitigation measure not adopted that is considerably different from others
analyzed in the Draft EIR that would clearly lessen the significant environmental impacts of the project;
or (4) information that indicates that the public was deprived of a meaningful opportunity to review and
comment on the Draft EIR. Consequently, Midpen finds that the amplifications and clarifications made to
the Draft EIR in the Final EIR do not collectively or individually constitute significant new information
within the meaning of Public Resources Code §21092.1 and CEQA Guidelines §15088.5. Recirculation
of the Draft EIR or any portion thereof, is therefore not required.
IX. PROJECT ALTERNATIVES
A. Findings Regarding Project Alternatives
Public Resources Code section 21002 provides that “public agencies should not approve projects as
proposed if there are feasible alternatives or feasible mitigation measures available which would
substantially lessen the significant environmental effects of such projects[.]” The same statute states that
the procedures required by CEQA “are intended to assist public agencies in systematically identifying
both the significant effects of proposed projects and the feasible alternatives or feasible mitigation
measures which will avoid or substantially lessen such significant effects.”
All of the environmental impacts associated with the project may be substantially lessened or avoided
with the adoption of the mitigation measures set forth in these findings, with the exception of Impact
3.2-1, “Cause a Substantial Adverse Change in the Significance of a Historical Resource.”
The Draft EIR discussed several alternatives to the project in order to present a reasonable range of
options. To be suitable for consideration in the EIR, alternatives must be “potentially” feasible and “attain
most of the basic objectives of the project.” (CEQA Guidelines, § 15126.6, subd. (a).) The alternatives
analyzed in detail in the EIR are:
Alternative 1: No Project Alternative
Alternative 2: Stabilize Alternative
Alternative 3: Repair and Rehabilitate Alternative
B. Alternatives Analyzed in the Draft EIR and Final EIR
Midpen adopts the following findings with respect to each alternative.
Alternative 1: No Project
Under the No Project Alternative, no actions would be taken by Midpen and the project site would remain
unchanged. The Redwood Cabin would remain vacant and in its current deteriorated condition.
Biological Resources Impacts associated with the No Project Alternative are slightly greater than those
that would occur with the project because this alternative does not provide the long-term opportunity to
improve biological resources that the proposed project does. Impacts to Cultural Resources would be
slightly less under the No Project Alternative, because no sub-surface archaeological resources would
have the potential to be affected. However, this alternative would not ultimately substantially reduce or
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avoid the significant impact since the Redwood Cabin would continue to fall in disrepair over time.
Furthermore, as shown in Table 4-2 of the Draft EIR, the No Project Alternative would not meet any of
the project objectives, including (but not limited to) addressing wildfire risk, public safety, and enhancing
habitat and natural ecological function.
Because Alternative 1 is not environmentally superior to the project and would not meet any of the
project objectives, Midpen rejects Alternative 1.
Alternative 2: Stabilize Alternative
The Stabilize Alternative would address structural deficiencies to retain and stabilize the structure over
the long term. The goal of this alternative is to freeze or reduce building deterioration over time while
preserving as many of the exterior character-defining features as possible. The stabilize alternative would
require incurring short- and long-term costs to maintain the site. The stabilization methods under the
Stabilize Alternative target only the gravity related structural deficiencies and would not allow for re-
occupancy of the building.
Biological Resources Impacts associated with the Stabilize Alternative are slightly greater than those that
would occur with the project because this alternative does not provide the long-term opportunity to
improve biological resources that the proposed project does. However, overall impacts to cultural
resources are less under the Stabilize Alternative, because the Redwood Cabin would not be demolished
thereby avoiding a significant and unavoidable impact. Stabilization of the Redwood Cabin would reduce
building deterioration over time; however, the public still would not be able to access the site. Because
the Redwood Cabin would still be located onsite with no regular Midpen staff or public access, the
building would remain a public safety and fire risk. In addition to short-term capital improvement costs to
stabilize the structure, the Stabilize Alternative would also require on-going capital and personnel costs
associated with long-term maintenance of the Redwood Cabin. In terms of project objectives, the
Stabilize Alternative meets the objective of removing physical hazards to ensure public safety, but does
not meet any of the other objectives.
Therefore, while the Stabilize Alternative is environmentally superior to the project, it does not meet the
majority of the objectives, and for this reason Midpen rejects Alternative 2.
Alternative 3: Repair and Rehabilitate Alternative
Under the Repair and Rehabilitate Alternative, the building would be rehabilitated for eventual reuse as a
retreat space, meeting space, or hikers hut (or similar use). Under this alternative, the Redwood Cabin
would remain off-limits to the public. The building would be rehabilitated following the
recommendations of the Secretary of the Interior’s Standards for the Treatment of Historic Properties.
Rehabilitating the structure to allow for a retreat space, meeting space, or hikers hut, would likely require
upgrades and alterations of several building and site elements. The Repair and Rehabilitate Alternative
would require substantial investment and ongoing costs to improve and maintain the structure.
While the Repair and Rehabilitate Alternative would result in reduction in impacts related to cultural
resources because the existing historical resource on the site would not be demolished, impacts to
biological resources would be greater. In addition to not providing the long-term opportunity to improve
biological resources that the proposed project does, this alternative includes an eventual operational
component—opening the structure for limited gatherings—that could result in additional effects related to
biological resources. Intensifying use in this area as a destination site that accommodates gatherings,
especially with the use of an operational kitchen, would generate food waste, which could attract invasive
wildlife species (especially birds and rodents), which could affect the ecology of the site and negatively
impact future marbled murrelet nesting success. In addition to capital improvement costs to rehabilitate
the structure for reuse and site upgrades needed to facilitate public access, the Repair and Rehabilitate
Alternative would also require on-going capital and personnel costs associated with long-term upkeep of
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the Redwood Cabin for continued occupation. In terms of project objectives, the Repair and Rehabilitate
Alternative meets the objective of removing physical hazards to ensure public safety, and reducing
structure and wildland fire, but none of the other objectives.
Because Alternative 3 is not environmentally superior to the project and would not meet most of the
project objectives, Midpen rejects Alternative 3.
C. Other Alternatives
State CEQA Guidelines Section 15126.6(c) provides that an EIR “should also identify any alternatives
that were considered by the lead agency but rejected as infeasible during the scoping process and briefly
explain the reasons underlying the lead agency’s determination.” The following alternatives were
considered, but were dismissed from further consideration, as explained below. Midpen adopts the
following findings with respect to these alternatives.
Retain Site Elements Alternative. The Retain Site Elements Alternative would be similar to the proposed
project in that it would remove the Redwood Cabin, but this alternative would retain other site elements
outside of the immediate cabin footprint, such as the horseshoe pit, barbeque, and stone retaining walls.
No long-term operations and maintenance would occur to manage the features left on site. This alternative
was mentioned by a Midpen Board of Directors’ member during a June 2021 Board scoping meeting. The
horseshoe pit, barbeque, and stone retaining walls do not have historical significance on their own and, as
described in Section 3.1, “Cultural Resources” of the Draft EIR, are not recommended eligible for listing
in the CRHR as landscape features. This alternative was eliminated from further consideration because it
would not avoid project-related significant and unavoidable impacts associated with removal of historic
structures and would also not meet the project objectives. For these reasons discussed, the Retain Site
Elements Alternative was eliminated from further consideration in the Draft EIR.
Relocate and Stabilize Alternative. This alternative involves relocating the Redwood Cabin to a new
location, either within La Honda Creek Open Space Preserve or to a site not owned by Midpen, if a
feasible site were identified, as allowed by EPG CUL-3. Currently, there is no public access to or around
the Redwood Cabin; the Relocate and Stabilize Alternative would select a location that would allow
public viewing and historic interpretation of the cabin. In order to retain the structure’s historic integrity
and therefore its eligibility for listing in the CRHR, the site would have to be in a similar setting to the
current location. Under the Relocate and Stabilize Alternative, the Redwood Cabin would be stabilized so
that visitors could walk around the perimeter and view the structure up close; however, interior access
would not be permitted. This alternative was eliminated from further consideration because it fails to meet
two project objectives. Objective 2, enhance habitat at the Redwood Cabin site and immediate
surroundings, would not be met because preparing a new building site for the Redwood Cabin would
expand the disturbed project footprint by impacting new areas of undisturbed, natural habitat. This could
result in significant impacts to biological resources. Objective 6, implement a fiscally sustainable project,
would not be met because relocating the cabin would significantly increase costs to disassemble, move
and reconstruct the building, which would then require additional stabilization improvements to reduce
public safety hazards at the relocation site. Thus, this alternative would not achieve a fiscally sustainable
project. For these reasons discussed, the Relocate and Stabilize Alternative was eliminated from further
consideration in this Draft EIR.
D. Environmentally Superior Alternative
The Stabilize Alternative would be the environmentally superior alternative. It would result in slightly
greater impacts to biological resources but would avoid the proposed project’s significant and
unavoidable cultural resource impact. This significant and unavoidable impact would not be avoided
under the No Project Alternative and impacts to biological resources would be slightly greater. The
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Repair and Rehabilitate Alternative would also avoid the proposed project’s significant and unavoidable
cultural resource impact, however, impacts to biological resources would be greater under this alternative.
Additionally, although the site is not currently open to the public, there would be a greater area of ground
disturbance once the site is open to the public, though the timeline for opening this area of La Honda
Creek Open Space Preserve is many multiple years out.
However, the Stabilize Alternative meets only one of the objectives: removing physical hazards to ensure
public safety. The remaining four objectives would not be met by this alternative. Therefore, while the
Stabilize Alternative would be the environmentally superior action alternative, it would not meet the
objectives of the project.
The Board finds that because none of the project alternatives would avoid a significant effect of the
proposed project while meeting the basic project objectives, the proposed project is considered
environmentally superior.
X. STATEMENT OF OVERRIDING CONSIDERATIONS
CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social,
technological, or other benefits of a project against its unavoidable risks when determining whether to
approve a project. If the specific economic, legal, social, technological, or other benefits of the project
outweigh the unavoidable adverse environmental effects, those effects may be considered acceptable.
CEQA requires the agency to support, in writing, the specific reasons for considering a project acceptable
when significant impacts are not avoided or substantially lessened. Those reasons must be based on
substantial evidence in the EIR or elsewhere in the administrative record.
Midpeninsula Regional Open Space District has made a reasonable good faith effort to eliminate or
substantially mitigate the environmental impacts resulting from the proposed project. Midpen recognizes,
however, that even with implementation of all feasible mitigation measures, the project will have
significant and unavoidable impacts. In particular, the proposed project would result in significant
unavoidable impacts to historic resources, from the demolition of the Redwood Cabin, which has been
recommended eligible for listing in the California Register of Historical Resources. These significant
unavoidable impacts are identified and discussed in Section VI of these Findings and in a table included
herein below. Midpen further specifically finds that these significant unavoidable impacts are outweighed
by the proposed project’s benefits and constitutes an overriding consideration warranting approval of the
proposed project. Midpen also notes that implementation of the No Project Alternative would not avoid
the significant impact.
Midpen finds that any one of the benefits set forth below is sufficient by itself to warrant approval of the
proposed project, and justify the unavoidable adverse environmental impacts from the project. This
determination is based on the findings herein and the evidence in the record. Having balanced the
unavoidable adverse environmental impacts against each of the benefits, pursuant to CEQA section 21081
and CEQA Guideline 15093, Midpen adopts this Statement of Overriding Considerations, for the
following reasons:
A. Social Benefits
The Redwood Cabin Removal Project provides social and recreational benefits by removing a significant
site safety hazard. Although the area is not currently open to the public, the project site has been the site
of numerous trespassing and vandalism incidents (including fire ignitions) that raise concerns regarding
overall public safety and fire risk within a very high fire severity zone. In some cases, a remote location
can protect an unoccupied structure from trespass and vandalism, but with the Redwood Cabin, it is clear
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that numerous people are aware of its location. The difficult access to this location makes regular patrol
challenging, and any illegal activity unlikely to be observed and reported by the public. A wildfire in this
area would be detrimental to the La Honda Creek Open Space Preserve and larger community, potentially
closing down portions that are currently open to the public.
B. Environmental Benefits
A fundamental objective of the Redwood Cabin Removal Project is to protect and enhance the natural
environment. Following completion of demolition activities and removal of lead-based paint present
within the structure, disturbed areas would be recontoured and erosion control applied to the site to ensure
adequate site drainage. Native grass seed mix would be spread in the disturbed areas and weed free or
native grass straw would be placed in the disturbed areas, on top of the native grass seed mix, to assist
with soil stabilization and erosion control. Midpen may also conduct soil decompaction activities outside
of critical rootzones; soil testing and, if needed, spot application of amendments such as fertilizers, lime,
or organic materials; revegetation or plantings. Additionally, the project would improve the natural visual
character and scenic open space qualities at the site by returning the site back to a native forest habitat.
C. Economic Benefits
The Redwood Cabin Removal Project will allow for social, recreational, and environmental benefits as
discussed in Sections A and B, while preserving Midpen’s limited available funds by removing a safety
hazard. Due to vandalism and fires, Midpen staff has been required to perform tasks that should not be
prioritized for an open space district. Midpen has installed plywood boards over window and door
openings that could provide ingress into the Redwood Cabin. After trespass and vandalism were observed
in April 2021, which included deliberate dismantling of the building’s wraparound deck and railing,
Midpen removed portions of the deck that were in a highly dilapidated and collapsible condition to
address exterior public safety concerns. Similar activities and expenditures of time and resources would
be expected to continue if the Redwood Cabin were to remain.
D. Policy
Consistent with Board Policy 4.09, Factors to Consider for Disposition, Midpen evaluated the Redwood
Cabin Removal Project in a comprehensive and thorough decision making process to ensure the
disposition of the structure considered significant factors such as the Board policies, compatibility with
the open space character of the site, historic and educational value, potential financial cost, including
liability and management, existing condition of the structure and many other factors. In addition, Midpen
evaluated the Project in relation to the Board approved La Honda Creek Open Space Preserve Master Plan
(Master Plan) policies, which establishes a vision for habitat preservation and management, and
ecologically sensitive public access in the Preserve. The Master Plan includes goals and objectives that
reflect the larger vision for the La Honda Creek Open Space Preserve. The Redwood Cabin Removal
Project would be consistent with and support the Master Plan goals and objectives for Natural Resource,
Maintenance and Operations and Public Access, Recreation and Environmental Education, as reflected in
the following:
Natural Resource Goal NR-5: Protect and enhance native grassland vegetation
o Objective 5.4: Protect and, where appropriate, enhance forest habitat.
Maintenance and Operations Goal 2: Reduce fire risk
o Objective MO-2.1: Implement practices to manage wildland fuels and reduce fire hazards.
Public Access, Recreation and Environmental Education Goal PA-6: Educate the public about
Preserve resources
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o Objective PA-6.1: Interpret the natural and cultural resources of La Honda Creek OSP to
expand public understanding of the Preserve’s local and regional role and how past land uses
have shaped the current condition of the landscape
Conclusion
Located in a remote area currently not open to the public, the Redwood Cabin has been the site of
numerous trespassing and vandalism incidents (including fire ignitions) that raise concerns regarding
overall public safety and fire risk within a very high fire severity zone. A wildfire in this area would be
detrimental to the Preserve and overall surrounding community, potentially closing down portions of the
Preserve that are currently open to the public. With this key consideration, the Redwood Cabin Removal
Project presents multiple benefits that include social and recreational benefits by removing a significant
site safety hazard. In addition, the Project would result in the opportunity to improve the natural visual
character and scenic open space qualities at the site by returning the site back to a native forest habitat
associated with the removal of a hazardous structure and site improvements that include soil stabilization
and erosion control. In addition, removal of the dilapidated structure would allow Midpen to use public
funds wisely to avoid expending extensive funds for continued long term operational and maintenance if
the Redwood Cabin were to remain. Furthermore, the Project would be consistent with and support Board
policies that include the La Honda Creek Master Plan goals and objectives. For these reasons, the
significant and unavoidable impacts on Cultural Resources are outweighed by the benefits of the removal
of the Redwood Cabin, site recontouring/erosion control activities and revegetation of the site.
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Summary of Impacts and Mitigation Measures
Impacts Mitigation Measures Significance after Mitigation Findings of Fact
Biological Resources
Impact 3.1-1: Loss or Degradation of Habitat for Special-Status Botanical Species
Suitable habitat for special-status botanical species is present within the project site; however, no special-status botanical species were identified during surveys of the site in 2020, and no loss of individual special-status plants is anticipated. With the removal of the cabin, the recontouring of the project site, and implementation of EPG BIO-10, the project would result in an increase in suitable habitat for special-status botanical species. In addition, the implementation of IPMP BMPs would avoid habitat degradation that may result from the introduction and spread of invasive plants. Therefore, the project would have a less-than-significant impact on special-status botanical species.
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
Impact 3.1-2: Injury or Mortality of Special-Status Amphibians
Special-status amphibians may be found within the project site. The recontouring of the site and implementation of EPG BIO-10 would ensure that there is no loss of habitat for these species. Project activities including the demolition of the Redwood Cabin and associated structures, recontouring, and staging of materials could result in the injury or mortality of special-status amphibians, and any injury or mortality of individual special-status amphibians would be a significant impact.
Mitigation 3.1-2a: Protection Measures for California Red-Legged Frog
To avoid loss of individual California red-legged frog, Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Activities including the use of mechanical equipment, excavating, and bulldozing will require pre-activity visual surveys as well as monitoring during the activities. All maintenance activity proposals involving mechanized equipment and associated monitoring proposals will be approved by CDFW and USFWS prior to implementation of the project.
Biological monitors will check for any listed species under vehicles and equipment parked for more than 30 minutes.
Refueling of equipment will be conducted using heavy-gauge tarps made of chemically resistant polypropylene or other impervious material with vertical sides for spill containment. These containment tarps will be set up under the equipment prior to servicing or refueling. Once the work is completed, the tarp and its contents must be immediately removed from the property and all contaminants properly
LTS Finding: Compliance with Mitigation Measures 3.1-2a and 3.1-2b, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to special-status amphibians during construction. Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid the potentially significant environmental effects as identified in the EIR.
Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to California red-legged frog, California giant salamander, and Santa Cruz black salamander. Mitigation Measure 3.1-2a would require the implementation of the conservation
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disposed of off-site. Standard operating procedures will be implemented immediately in case of fuel spillage.
All vehicles must stay on designated roads, paved and unpaved, and if it is necessary for a vehicle to travel off the designated road (paved or 2 track unpaved), a monitor will precede the vehicle to clear wildlife from the pathway of the vehicle.
Prior to the start of work, an educational program regarding the sensitivity of the California red-legged frog and its habitat will be conducted for all personnel.
Prior to the start of work, areas will be identified by the biological monitor and approved by the USFWS and CDFW as acceptable locations for the relocation of California red-legged frog if the species is encountered within the project site. Relocation areas will be a minimum of 500-feet from the boundary of the project site and will not include staging areas or roads. No California red-legged frog will be removed from Midpen property or maintained in captivity overnight without prior notification and written approval from the USFWS and CDFW unless the animal is in need of emergency medical assistance. Medical assistance will be provided by a USFWS-approved, certified wildlife veterinarian familiar with amphibian care.
If a California red-legged frog enters the project site, all work shall stop until the animal leaves on its own. If the frog does not leave on its own, a biological monitor specifically authorized by the USFWS and CDFW will be allowed to handle and relocate the California red-legged frog to the pre-approved relocation area.
Mitigation 3.1-2b: Biological Monitoring for California Giant Salamander and Santa Cruz Black Salamander
To avoid loss of individual California giant salamander and Santa Cruz black salamander, Midpen will implement the following measures.
Prior to the start of demolition each day, the access road and portions of the project site where activities will occur will be surveyed by a qualified biologist for the presence of California giant salamander and Santa Cruz black salamander. The survey will include the inspection of any debris from demolition or materials staged overnight for the presence of these species.
If individual California giant salamanders or Santa Cruz black salamanders are discovered during daily inspections, work shall stop until the individual salamander moves on its own to a point where it is
measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves for California red-legged frog.
Mitigation Measure 3.1-2b would generally limit the potential for disturbance to, or loss of, California Giant Salamander and Santa Cruz Black Salamander to a less-than-significant level by requiring surveys for the presence of special-status amphibians on a daily basis during project activities; monitoring for these species during project activities; stopping work that may harm these species until the individual leaves on its own or is moved by a biologist.
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no longer at risk of incidental injury or death from project activities, or until the individual salamander is moved outside of the project site by a qualified biologist.
Impact 3.1-3: Disturbance of Nesting Marbled Murrelet
The nearest mapped nesting habitat for marbled murrelet (Brachyramphus marmoratus) is located approximately one-half mile west of the project site. However, unmapped nesting habitat could occur within a quarter mile of the project site, and implementation of the project could result in loss of eggs and young from nest disturbance during the breeding season (March 24 – September 15). If nesting marbled murrelets are within a quarter mile of the project site, the project would have a significant impact on this species.
Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet
To avoid disturbance and loss of the nests of marbled murrelet Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that meet the Pacific Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected, Midpen will notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter mile from the project site, the following will apply:
If possible, work within the project site shall be confined to September 15 to November 1.
If work is scheduled to be performed during the breeding season (March 24 to September 15), disturbance minimization buffers determined by the sound level anticipated from the project will be implemented based on sound level monitoring studied, submitted to USFWS and the table below.
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project Sound Level (dB)1 Moderate (71-80) High (81-90) Very High (91-100) Extreme (101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the project stie prior to the project, and not related to the project.
2 Project-generated sound levels measured at 50 feet from the source
LTS Finding: Compliance with Mitigation Measure 3.1-3, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to marbled murrelet (ESA-threatened and CESA-endangered) during construction. Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid the potentially significant environmental effects as identified in the EIR.
Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to nests of marbled murrelet. Mitigation Measure 3.1-3 would require surveys for the presence of nest trees and active nests and no-activity buffers around active nests to avoid disturbance during the nesting season.
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3 “Natural Ambient” refers to sound levels generally experienced in habitats not substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special considerations for ambient sound level. Source: USFWS 2016; USFWS 2020
Project activities shall not be conducted within a visual line-of-site distance of 132 feet from a suitable nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest trees during the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15) regardless of the distance to potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the habitat is occupied by marbled murrelet, the seasonal and distance work restrictions may be lifted with written approval from the USFWS.
Impact 3.1-4: Disturbance of Common Raptor and Other Common Bird Nests
The project site provides suitable nesting habitat for common raptors and other common nesting birds, and project activities could result in the disturbance of active nests if demolition occurs during the nesting season. The disturbance of active nests could result in the abandonment of nests and the mortality of eggs and young, which would be a potentially significant impact.
Mitigation 3.1-4: Preconstruction surveys and nest buffers for common raptors and other nesting birds
To avoid disturbance and loss of the nests of common raptors and other nesting birds Midpen will implement the following measures.
If work is scheduled to be performed during the nesting season (the specific start and end dates of the season will be determined by a qualified biologist but are typically February 15 to August 30), a pre-demolition survey will be performed within 1,000 feet of the project site, no more than 14 days prior to the start of demolition related activities. If no active nests are detected during surveys, no further mitigation is required.
If active nests are found during the pre-demolition survey, a buffer will be established around each nest. No project activity will occur within a buffer of 1,000-feet around large raptor nests (e.g., buteos) 500-feet around small common raptor nests (e.g., accipiters) and 250-feet around the nests of other common bird species. The size of the buffer
LTS Finding: Compliance with Mitigation Measure 3.1-4, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to nesting habitat for common raptors and other common nesting birds. Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid the potentially significant environmental effects as identified in the EIR.
Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to nesting habitat for common raptors and other nesting bird species including red-
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around any individual nest maybe reduced by a qualified biologist in consultation with CDFW, depending on screening of the nest from project activities and other site-specific conditions. These buffers will be maintained until a qualified biologist determines that any young have fledged, and the nest is no longer active.
shouldered hawk, acorn woodpecker, Steller’s jay, dark-eyed junco, and band-tailed pigeon. Mitigation Measure 3.1-4 would require surveys for the presence of active nests and no-activity buffers around active nests to avoid disturbance during the nesting season.
Impact 3.1-5: Loss of San Francisco Dusky-Footed Wood Rat Nests
The Redwood Cabin contains multiple San Francisco dusky-footed wood rat (Neotoma fuscipes annectens) nests. The demolition of the cabin would destroy these nests and could result in the injury or mortality of young woodrats if demolition occurs during the rearing season (approximately April 1 to July 15). The destruction of these nests and the injury or mortality of young woodrats would be a significant impact
Mitigation 3.1-5: Minimize impacts from loss of San Francisco dusky-footed wood rat nests
To avoid loss of San Francisco dusky-footed wood rat during demolition, work will be conducted outside of the rearing season (before April 1 or after July 15).
Prior to demolition, debris piles will be constructed outside of and adjacent to the project footprint to provide shelter for wood rats that are displaced by demolition. These debris piles will be constructed under the guidance of a qualified biologist and will consist of dead branches of various sizes (0.5 to 6 inches in diameter) collected from the surrounding area. Each pile will be approximately 3 to 5 feet high by 8 to 10 feet in diameter. The number of debris piles will be determined by a qualified biologist based on the number of nests in the Redwood Cabin prior to demolition.
To avoid death of wood rats, wood rat nest materials will be removed by hand from the Redwood Cabin prior to demolition of the structure.
If wood rats are observed during demolition, work will stop until the animal leaves the area on its own, or until a qualified biologist determines that work can continue without harm to the animal.
LTS Finding: Compliance with Mitigation Measure 3.1-5, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to dusky-footed wood rat (CDFW species of special concern). Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid the potentially significant environmental effects as identified in the EIR.
Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to San Francisco dusky-footed wood rat nests. Mitigation Measure 3.1-5 would ensure that nest removal does not occur during the rearing season when the project could result in the death of young wood rats, and it would require the construction of debris piles that provide shelter for wood rats that are displaced by demolition of the structure.
Impact 3.1-6: Loss of Bat Roosts and Mortality of Individuals
The Redwood Cabin provides potential roosts for common and special-status bats. The demolition of the Redwood Cabin could result in disturbance of active bat roosts, which could result in the loss of adult and young bats. The loss of individual special-status bats, or the loss of a maternity roost of any
Mitigation 3.1-6: Pre-demolition surveys and measures to reduce impacts to bat roosts and special-status bats
A pre-demolition bat roost survey shall be conducted at the project site by a qualified biologist no more than two days prior to the start of demolition.
In addition, if demolition is anticipated to occur during the bat wintering period (from November 16 through February 15), a pre-demolition winter roost survey shall be conducted by a qualified biologist.
LTS Finding: Compliance with Mitigation Measure 3.1-6, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to bat roosts and special-status bats. Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid
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bat species would be a potentially significant impact If individual nonbreeding and non-special-status bats are roosting within the structure, a qualified biologist may remove the bats and work may proceed during any time of the year. If special-status bats or a maternity roost of any bat species is detected, demolition will not be allowed to occur during the April through August maternity season; outside of the maternity season, bats shall be excluded and provided alternate roost sites before demolition.
Midpen will develop a project specific bat roost deterrent plan if special-status bats or a maternity roost of any bat species is detected in the Redwood Cabin. The deterrent plan will be submitted to CDFW for approval and will include measures such as acoustic deterrents and one-way bat doors installed outside of the maternity season (April through August), and other similar methods.
Demolition will occur when forecast nighttime lows are not below 50 degrees Fahrenheit.
The materials around crevices that may provide roosting sites within the structure will be first demolished with hand tools to minimize the potential risk of injuring bats.
Initial demolition will be performed in the early evening after sunset, or if evening work is not feasible, the work shall be initiated in the afternoon to ensure that any bats present are not in torpor and unable to escape. Once demolition has been started, further work may be performed at any point in the day. A qualified bat biologist will be present at the initiation of demolition to capture and temporarily hold any bats present for release the evening of the same day.
the potentially significant environmental effects as identified in the EIR.
Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to individual special-status bats or maternity roosts of any bat species. Mitigation Measure 3.1-6 would ensure that the project does not result in disturbance of hibernacula or maternity roots and applies measures such as the timing of demolition and bat exclusion methods that would minimize the risk of injury or death of special-status and common bat species.
Impact 3.1-7: Disturbance or Loss of Special-Status Mammal Den Sites (American Badger and Ringtail)
The project site and adjacent redwood forest provide potential denning sites for special-status mammals. The demolition of the Redwood Cabin could result in disturbance of active dens and the injury or mortality of pups if the demolition occurs during the breeding season. The loss of active dens and injury of mortality of special-status mammal pups would be a potentially significant impact
Mitigation 3.1-7: Pre-demolition surveys and den buffers for American badger and ringtail
If the project occurs during the period when pups are potentially in the den February 15 through July 1, a qualified biologist shall conduct pre-demolition surveys within 100 feet of the project site for potential American badger and ringtail dens. The survey will occur no more than 7-days prior to implementation of demolition activities.
If any potentially occupied American badger dens are located during surveys, no work shall be performed within a 100-foot buffer around dens during the period when pups are potentially in the den (February 15 through July 1).
If any potentially occupied ringtail dens (e.g., brush piles, appropriately sized burrows, hollow logs, hollow trees) are located during surveys, the
LTS Finding: Compliance with Mitigation Measure 3.1-7, which has been required as part of the project, will reduce this impact to a less-than-significant level, by requiring avoidance and minimization of impacts to American badger (CDFW species of special concern) and ringtail (CDFW fully protected). Midpen hereby adopts these mitigation measures. Midpen, therefore, finds that changes or alterations have been required in, or incorporated into, the project that avoid the potentially significant environmental effects as identified in the EIR.
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same buffers as described for American badger will be applied during breeding season for ringtail (May 1 through June 30). Explanation/Facts in Support of Finding: Project construction activities could result in potential impacts to the disturbance of active dens and the injury or mortality of pups for special-status mammals. Mitigation Measure 3.1-7 would ensure that the project does not result in disturbance of natal dens that could result in the death of pups though pre-demolition survey and the establishment of buffers where work would not occur.
Impact 3.1-8: Disturbance or Loss of Riparian Habitat or Other Sensitive Natural Communities
The project does not contain riparian woodland; however, herbaceous riparian habitat is present along the adjacent La Honda Creek. The project would not directly affect this habitat and the implementation of EPG WQ-2 would avoid and minimize impacts from the runoff of sediment from the project. The site also contains a CDFW-designated sensitive natural community, Redwood Forest; however, this community would not be adversely affected by the project because the project would not remove any trees, would treat on-site invasive species, and would restore the area disturbed by the project through the implementation of EPG BIO-10. Therefore, the impact of the project on riparian habitat and other sensitive natural communities would be less than significant.
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
Impact 3.1-9: Degradation or loss of protected wetlands and other waters
The access road to the project site crosses La Honda Creek and an un-named tributary. A temporary bridge may be required to move equipment across the tributary; however, no dredge or fill of the creek or tributary will occur as a result of the project. In addition, EPG WQ-2 will be implemented to avoid and minimize impacts to La
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
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Honda Creek and its tributary due to runoff from the project site. Therefore, the impact to protected wetlands and other waters would be less than significant.
Impact 3.1-10: Potential to Interfere with Wildlife Movement and Nursery Sites
The demolition of the Redwood Cabin would not result in any changes in habitat or new structures that would interfere with wildlife movement. The noise and human activity associated with the project could result in temporary impacts to wildlife movement that would not be substantial, due to the short duration and limited footprint of the project in relation to other habitat in the vicinity. Therefore, the projects impact would be less than significant.
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
Impact 3.1-11: Potential to Contribute to a Significant Cumulative Impact to Biological Resources
Implementation of the proposed project in the context of historical effects on the landscape and in combination with other cumulative projects in the area could result in impacts to biological resources. However, through the implementation of EPGs, BMPs, and mitigation measures, the contribution of the project would be less than cumulatively considerable. Therefore, this impact would be less than significant.
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
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Cultural Resources
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Implementation of the project would result in a substantial adverse change in the significance of a recommended-eligible historical resource. This would result in a significant impact as described in State CEQA Guideline 15064.5(b)(1).
Mitigation 3.2-1a: Document historic buildings prior to removal.
Midpen shall complete Historic American Building Survey documentation of the Redwood Cabin before any demolition work is conducted. Documentation shall consist of written history of the property, plans and drawings of the historic resources, and photographs, as described below:
Written History. The report shall be reproduced on archival bond paper.
Plans and Drawings. An architectural historian (or historical architect, as appropriate) shall conduct research into the availability of plans and drawings of the Redwood Cabin as the building currently exists. If such plans/drawings exist, their usefulness as documentation for the building shall be evaluated by the architectural historian. If deemed adequate, the plans/drawings shall be reproduced on archival mylar. If no plans/drawings are available, or if the existing plans/drawings are not found to be useful in documenting the historic resource, a historical architect shall prepare dimensioned plans and exterior elevations of the building. A combination of existing and new drawings is acceptable. All drawings shall be reproduced on archival mylar.
The architectural historian shall conduct research into the existence of the original architectural plans and drawings of the building. If found, the plans shall be reproduced on archival mylar. Alternatively, the architectural plans can be scanned and saved as TIFF files. The scanning resolution shall be not less than 300 dpi.
All digital files, including drawing files, shall be saved on media and labeled following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital Photography Specifications.
Photographs. Digital photographs shall be taken of the Redwood Cabin following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital Photography Standards.
The documentation shall be prepared by an architectural historian, or historical architect as appropriate, meeting the Secretary’s Standards and Guidelines for Archeology and Historic Preservation, Professional Qualification Standards. The documentation shall be submitted to the San Mateo County Library, the San Mateo County Historical Association, the Northwest Information Center, and the Midpen office in Los Altos.
SU Finding: Specific economic, legal, social, or other considerations, make infeasible mitigation measures or alternatives beyond those identified in the Draft EIR. However, Midpen finds that specific overriding economic, legal, social, or other benefits of the project outweigh the project’s impacts on changing the significance of a historical resource, as more fully stated in the Statement of Overriding Considerations.
Explanation/Facts in Support of Finding: The Redwood Cabin has been recommended eligible for listing in the California Register or Historical Resources. Demolition of historic resources would result in a significant impact because the historical resource would no longer exist.
Implementation of Mitigation Measures 3.2-1a through 3.2-1c would lessen the impacts related to the loss of the Redwood Cabin, however the structure would no longer exist. This impact is significant and unavoidable.
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Mitigation 3.2-1b: Redwood Cabin interpretation.
Midpen will create an interpretive resource outlining the Redwood Cabin’s historic status, historic context, and significance. This resource will be available in a digital and/or physical format for public engagement and may be shared with a relevant local organization such as the San Mateo County Historical Association.
Mitigation Measure 3.2-1c: Salvage of useable materials.
Should any of the demolished structure materials (i.e., redwood logs) be in acceptable condition, Midpen shall reserve materials for potential future uses and/or salvage in compliance with Midpen’s waste diversion requirements outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. If these materials are free of pests, Midpen will coordinate with a local historic salvage organization, such as Garden City Recycle and Salvage in Santa Cruz, Whole House Building Supply & Salvage in San Mateo, or Heritage Salvage in Petaluma for their reuse.
Impact 3.2-2: Cause a Substantial Adverse Change in the Significance of Unique Archaeological Resources
Project-related ground-disturbing activities could result in discovery or damage of yet undiscovered archaeological resources as defined in State CEQA Guidelines Section 15064.5. However, because project excavation activities would occur in previously disturbed areas, the potential for encountering archaeological material is low. Additionally, because EPG CUL-1 would be implemented in the event of a discovery, this would be a less-than-significant impact.
No mitigation is required for this impact. LTS Under CEQA, no mitigation measures are required for impacts that are less than significant. (Pub. Resources Code, § 21002; CEQA Guidelines, §§ 15126.4, subd. (a)(3), 15091.)
Impact 3.2-3: Potential for the project, in combination with other development, to contribute to a significant cumulative impact to cultural resources.
The project, in combination with other cumulative development in the area, could result in impacts to cultural resources in the area. Through the implementation of environmental protection
Mitigation Measures, 3.2-1a, 3.2-1b, and 3.2-1c, described above. SU Finding: Specific economic, legal, social, or other considerations, make infeasible mitigation measures or alternatives beyond those identified in the Draft EIR. However, Midpen finds that specific overriding economic, legal, social, or other benefits of the project outweigh the project’s impacts on changing the significance of
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measures, the contribution of the project would not be cumulatively considerable with respect to archaeological resources. However, because the project would result in permanent removal of a historic architectural resource, impacts to historical resources would be significant. Therefore, cumulative impacts to cultural resources would be significant.
a historical resource, as more fully stated in the Statement of Overriding Considerations.
Explanation/Facts in Support of Finding: The Redwood Cabin has been recommended eligible for listing in the California Register or Historical Resources. Demolition of historic resources would result in a significant impact because the historical resource would no longer exist. Additionally, while the Redwood Cabin does not appear to be one of the earliest recreational cabins (from the late 1800s and early 1900s), it appears to be one of the last remaining ones intact from the transition era to permanent structures, in the area. This permanent loss in the resource would result in a cumulatively considerable contribution to a historic impact.
Implementation of Mitigation Measures 3.2-1a through 3.2-1c would lessen the impacts related to the loss of the Redwood Cabin, however the structure would no longer exist. No additional mitigation is available. This impact is significant and unavoidable.
Midpeninsula Regional Open Space District Redwood Cabin Project Draft EIR 1
MITIGATION MONITORING AND REPORTING PROGRAM
INTRODUCTION
CEQA and the State CEQA Guidelines (PRC Section 21081.6 and State CEQA Guidelines Sections 15091[d] and 15097)
require public agencies “to adopt a reporting and monitoring program for changes to the project which it has
adopted or made a condition of project approval to mitigate or avoid significant effects on the environment.” A Mitigation Monitoring and Reporting Program (MMRP) is required for the Redwood Cabin Removal Project (project)
because the EIR identifies potential significant adverse impacts related to the project implementation, and mitigation
measures have been identified to reduce those impacts.
COMPLIANCE CHECKLISTS
The intent of the MMRP is to ensure the effective implementation and enforcement of adopted mitigation measures
and permit conditions. The MMRP is intended to be used by Midpeninsula Regional Open Space District (Midpen)
staff and mitigation monitoring personnel to ensure compliance with mitigation measures during project
implementation. Mitigation measures identified in this MMRP were developed in the EIR prepared for the proposed
project. Midpen will provide for monitoring of construction activities as necessary and in-the-field identification and
resolution of environmental concerns.
Additionally, Midpen has adopted numerous best management practices (BMPs) from the 2014 Integrated Pest
Management Program (IPMP) and subsequent 2019 IPMP addendum. They also include environmental protection guidelines (EPGs) identified in Midpen’s La Honda Creek Open Space Preserve Master Plan, the associated 2012 Initial
Study/Mitigated Negative Declaration, and project specific BMPs. These measures are intended to avoid and
minimize environmental impacts, comply with applicable laws and regulations, and would be incorporated into the
design of the project as environmental commitments. As described in Chapter 2, “Project Description,” of the Draft
EIR, some of these have been revised to increase their direct application to the current project and thereby enhance their effectiveness. These revisions will not apply to future Midpen projects.
Monitoring and documenting the implementation of mitigation measures and BMPs will be coordinated by Midpen.
The table attached to this report identifies the mitigation measure, the responsible agency for the monitoring action, and timing of the monitoring action. Midpen will be responsible for fully understanding and effectively implementing
the mitigation measures contained within the MMRP and for ensuring compliance.
Mitigation Monitoring and Reporting Plan
The categories identified in the attached MMRP table are described below.
Impact – This column provides the verbatim text of the identified impact.
Mitigation Measure – This column provides the verbatim text of the adopted mitigation measure
Implementation Responsibility – This column identifies the party responsible for implementing the mitigation
measure.
Timing – This column identifies the time frame in which the mitigation will be implemented.
Verification – This column is to be dated and signed by the person (either project manager or his/her designee) responsible for verifying compliance with the requirements of the mitigation measure.
Exhibit C
Mitigation Monitoring and Reporting Program Ascent Environmental
Midpeninsula Regional Open Space District 2 Redwood Cabin Removal Project EIR
Best Management Practices Checklist
The categories identified in the attached Best Management Practices Checklist table are described below.
Best Management Practices – This column provides the revised text of the adopted BMPs and EPGs. As described in
the Draft EIR, the EPGs below have minor text modifications (shown in strike-through and underline) to reflect
subsequent changes in Midpen’s guidelines, such as adoption of the IPMP, since the time the 2012 IS/MND and La
Honda Creek Open Space Preserve Master Plan were approved.
Implementation Responsibility – This column identifies the party responsible for implementing the mitigation
measure.
Timing – This column identifies the time frame in which the mitigation will be implemented.
Verification – This column is to be dated and signed by the person (either project manager or his/her designee)
responsible for verifying compliance with the requirements of the mitigation measure.
Ascent Environmental Mitigation Monitoring and Reporting Program
Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 3
Mitigation Monitoring and Reporting Plan
Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
Biological Resources
Impact 3.1-2: Injury or Mortality of Special-Status Amphibians
Mitigation 3.1-2a: Protection Measures for California Red-Legged Frog. To avoid loss of individual California red-legged frog, Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Activities including the use of mechanical equipment, excavating, and bulldozing will require pre-activity visual surveys as well as monitoring during the activities. All
maintenance activity proposals involving mechanized equipment and associated
monitoring proposals will be approved by CDFW and USFWS prior to implementation
of the project.
Biological monitors will check for any listed species under vehicles and equipment
parked for more than 30 minutes.
Refueling of equipment will be conducted using heavy-gauge tarps made of chemically resistant polypropylene or other impervious material with vertical sides for spill containment. These containment tarps will be set up under the equipment prior
to servicing or refueling. Once the work is completed, the tarp and its contents must
be immediately removed from the property and all contaminants properly disposed
of off-site. Standard operating procedures will be implemented immediately in case
of fuel spillage.
All vehicles must stay on designated roads, paved and unpaved, and if it is necessary
for a vehicle to travel off the designated road (paved or 2 track unpaved), a monitor
will precede the vehicle to clear wildlife from the pathway of the vehicle.
Prior to the start of work, an educational program regarding the sensitivity of the
California red-legged frog and its habitat will be conducted for all personnel.
Prior to the start of work, areas will be identified by the biological monitor and approved by the USFWS and CDFW as acceptable locations for the relocation of California red-legged frog if the species is encountered within the project site.
Relocation areas will be a minimum of 500-feet from the boundary of the project site
and will not include staging areas or roads. No California red-legged frog will be
removed from Midpen property or maintained in captivity overnight without prior
notification and written approval from the USFWS and CDFW unless the animal is in need of emergency medical assistance. Medical assistance will be provided by a USFWS-approved, certified wildlife veterinarian familiar with amphibian care.
Midpen
USFWS and CDFW, as appropriate
Prior to and during demolition
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Midpeninsula Regional Open Space District 4 Redwood Cabin Removal Project EIR
Mitigation Measure Measure Description Implementation
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If a California red-legged frog enters the project site, all work shall stop until the
animal leaves on its own. If the frog does not leave on its own, a biological monitor
specifically authorized by the USFWS and CDFW will be allowed to handle and
relocate the California red-legged frog to the pre-approved relocation area.
Mitigation 3.1-2b: Biological Monitoring for California Giant Salamander and Santa Cruz Black Salamander. To avoid loss of individual California giant salamander and Santa Cruz black salamander, Midpen will implement the following measures.
Prior to the start of demolition each day, the access road and portions of the project site where activities will occur will be surveyed by a qualified biologist for the
presence of California giant salamander and Santa Cruz black salamander. The survey
will include the inspection of any debris from demolition or materials staged
overnight for the presence of these species.
If individual California giant salamanders or Santa Cruz black salamanders are
discovered during daily inspections, work shall stop until the individual salamander
moves on its own to a point where it is no longer at risk of incidental injury or death
from project activities, or until the individual salamander is moved outside of the
project site by a qualified biologist.
Midpen Prior to and during demolition
Impact 3.1-3: Disturbance of Nesting Marbled Murrelet Mitigation 3.1-3: Preconstruction surveys and nest buffers marbled murrelet. To avoid disturbance and loss of the nests of marbled murrelet Midpen will implement the conservation measures found within the 2016 Biological Opinion on the ESA Section 10(a)(A) permit for habitat enhancement on Midpen preserves (USFWS 2016). These include the following measures.
Pre-demolition nest tree survey within a quarter mile of the project site for trees that
meet the Pacific Seabird Group definition of potential murrelet nesting trees.
If a potential nesting tree is detected within 300 feet of the project site or if a murrelet nest is detected, Midpen will notify the USFWS before work begins.
If a potential nesting tree is detected greater than 300 feet and less than a quarter
mile from the project site, the following will apply:
If possible, work within the project site shall be confined to September 15 to
November 1.
If work is scheduled to be performed during the breeding season (March 24 to September 15), disturbance minimization buffers determined by the sound level anticipated from the project will be implemented based on sound level monitoring
studied, submitted to USFWS and the table below.
Midpen Prior to demolition
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Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
Anticipated Project-Generated Sound Level (dB)2
Ambient Pre-Project
Sound Level (dB)1
Moderate
(71-80)
High
(81-90)
Very High
(91-100)
Extreme
(101-110)
Natural Ambient (≤50)3 50 (165)4,5 150 (500) 400 (1,320) 400 (1,320)
Very Low (51-60) 0 100 (300) 250 (825) 400 (1,320)
Low (61-70) 0 50 (165) 250 (825) 400 (1,320)
Moderate (71-80) 0 50 (165) 100 (330) 400 (1,320)
High (81-90) 0 50 (165) 50 (165) 150 (500)
1 Ambient sound level includes all natural and human-induced sounds occurring at the
project site prior to the project, and not related to the project.
2 Project-generated sound levels measured at 50 feet from the source
3 “Natural Ambient” refers to sound levels generally experienced in habitats not
substantially influenced by human activities
4 All distances are given in meters, with rounded equivalent feet in parentheses.
5 For murrelets, activities conducted during the dawn and dusk periods have special
considerations for ambient sound level.
Source: USFWS 2016; USFWS 2020
Project activities shall not be conducted within a visual line-of-sight distance of 132 feet from a suitable nest tree as designated by a qualified biologist.
If a sound study is not conducted, no project activities shall occur within a quarter mile of potential nest trees during the marbled murrelet breeding season (March 24 to September 15).
If project activity takes place during the breeding season (March 24 to September 15)
regardless of the distance to potential nest trees, activity will be restricted to 2 hours after sunrise and 2 hours before sunset to minimize disturbance to murrelets that may be flying over the project site to forage at the coast.
If marbled murrelet protocol level surveys are conducted and do not indicate that the
habitat is occupied by marbled murrelet, the seasonal and distance work restrictions
may be lifted with written approval from the USFWS.
Impact 3.1-4: Disturbance of Common Raptor and Other Common Bird Nests
Mitigation 3.1-4: Preconstruction surveys and nest buffers for common raptors and other nesting birds. To avoid disturbance and loss of the nests of common raptors and other nesting birds Midpen will implement the following measures.
If work is scheduled to be performed during the nesting season (the specific start and
end dates of the season will be determined by a qualified biologist but are typically
February 15 to August 30), a pre-demolition survey will be performed within 1,000
Midpen
CDFW, as appropriate
Prior to demolition
Mitigation Monitoring and Reporting Plan Ascent Environmental
Midpeninsula Regional Open Space District 6 Redwood Cabin Removal Project EIR
Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
feet of the project site, no more than 14 days prior to the start of demolition related
activities. If no active nests are detected during surveys, no further mitigation is
required.
If active nests are found during the pre-demolition survey, a buffer will be established around each nest. No project activity will occur within a buffer of 1,000-feet around
large raptor nests (e.g., buteos) 500-feet around small common raptor nests (e.g.,
accipiters) and 250-feet around the nests of other common bird species. The size of
the buffer around any individual nest maybe reduced by a qualified biologist in consultation with CDFW, depending on screening of the nest from project activities and other site-specific conditions. These buffers will be maintained until a qualified biologist determines that any young have fledged, and the nest is no longer active.
Impact 3.1-5: Loss of San
Francisco Dusky-Footed Wood
Rat Nests
Mitigation 3.1-5: Minimize impacts from loss of San Francisco dusky-footed wood rat
nests
To avoid loss of San Francisco dusky-footed wood rat during demolition, work will be
conducted outside of the rearing season (before April 1 or after July 15).
Prior to demolition, debris piles will be constructed outside of and adjacent to the
project footprint to provide shelter for wood rats that are displaced by demolition.
These debris piles will be constructed under the guidance of a qualified biologist and
will consist of dead branches of various sizes (0.5 to 6 inches in diameter) collected from the surrounding area. Each pile will be approximately 3 to 5 feet high by 8 to 10 feet in diameter. The number of debris piles will be determined by a qualified biologist based on the number of nests in the Redwood Cabin prior to demolition.
To avoid death of wood rats, wood rat nest materials will be removed by hand from
the Redwood Cabin prior to demolition of the structure.
If wood rats are observed during demolition, work will stop until the animal leaves
the area on its own, or until a qualified biologist determines that work can continue
without harm to the animal.
Midpen Prior to and during
demolition
Impact 3.1-6: Loss of Bat Roosts and Mortality of Individuals
Mitigation 3.1-6: Pre-demolition surveys and measures to reduce impacts to bat roosts and special-status bats
A pre-demolition bat roost survey shall be conducted at the project site by a qualified biologist no more than two days prior to the start of demolition.
In addition, if demolition is anticipated to occur during the bat wintering period (from November 16 through February 15), a pre-demolition winter roost survey shall be conducted by a qualified biologist.
If individual nonbreeding and non-special-status bats are roosting within the structure, a qualified biologist may remove the bats and work may proceed during
Midpen
CDFW, as appropriate
Prior to demolition of structure
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Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 7
Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
any time of the year. If special-status bats or a maternity roost of any bat species is
detected, demolition will not be allowed to occur during the April through August
maternity season; outside of the maternity season, bats shall be excluded and
provided alternate roost sites before demolition.
Midpen will develop a project specific bat roost deterrent plan if special-status bats
or a maternity roost of any bat species is detected in the Redwood Cabin. The
deterrent plan will be submitted to CDFW for approval and will include measures
such as acoustic deterrents and one-way bat doors installed outside of the maternity
season (April through August), and other similar methods.
Demolition will occur when forecast nighttime lows are not below 50 degrees
Fahrenheit.
The materials around crevices that may provide roosting sites within the structure will be first demolished with hand tools to minimize the potential risk of injuring bats.
Initial demolition will be performed in the early evening after sunset, or if evening work is not feasible, the work shall be initiated in the afternoon to ensure that any bats present are not in torpor and unable to escape. Once demolition has been started, further work may be performed at any point in the day. A qualified bat biologist will be present at the initiation of demolition to capture and temporarily
hold any bats present for release the evening of the same day.
Impact 3.1-7: Disturbance or Loss of Special-Status Mammal Den Sites (American Badgerand Ringtail)
Mitigation 3.1-7: Pre-demolition surveys and den buffers for American badger, and ringtail
If the project occurs during the period when pups are potentially in the den February 15 through July 1, a qualified biologist shall conduct pre-demolition surveys within 100 feet of the project site for potential American badger and ringtail dens. The survey
will occur no more than 7-days prior to implementation of demolition activities.
If any potentially occupied American badger dens are located during surveys, no work shall be performed within a 100-foot buffer around dens during the period when pups are potentially in the den (February 15 through July 1).
If any potentially occupied ringtail dens (e.g., brush piles, appropriately sized burrows, hollow logs, hollow trees) are located during surveys, the same buffers as described for American badger will be applied during breeding season for ringtail (May 1 through June 30).
Midpen Prior to demolition of structure
Mitigation Monitoring and Reporting Plan Ascent Environmental
Midpeninsula Regional Open Space District 8 Redwood Cabin Removal Project EIR
Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
Cultural Resources
Impact 3.2-1: Cause a Substantial Adverse Change in the Significance of a Historical Resource
Mitigation 3.2-1a: Document historic buildings prior to removal. Midpen shall complete Historic American Building Survey documentation of the Redwood Cabin before any demolition work is conducted. Documentation shall consist of written history of the property, plans and drawings of the historic resources, and photographs, as described below:
Written History. The report shall be reproduced on archival bond paper.
Plans and Drawings. An architectural historian (or historical architect, as appropriate) shall conduct research into the availability of plans and drawings of the Redwood Cabin as the building currently exists. If such plans/drawings exist, their usefulness as documentation for the building shall be evaluated by the architectural historian. If deemed adequate, the plans/drawings shall be reproduced on archival mylar. If no plans/drawings are available, or if the existing plans/drawings are not found to be
useful in documenting the historic resource, a historical architect shall prepare
dimensioned plans and exterior elevations of the building. A combination of existing
and new drawings is acceptable. All drawings shall be reproduced on archival mylar.
The architectural historian shall conduct research into the existence of the original
architectural plans and drawings of the building. If found, the plans shall be
reproduced on archival mylar. Alternatively, the architectural plans can be scanned
and saved as TIFF files. The scanning resolution shall be not less than 300 dpi.
All digital files, including drawing files, shall be saved on media and labeled following
the Secretary’s Standards and Guidelines for Archeology and Historic Preservation
Digital Photography Specifications.
Photographs. Digital photographs shall be taken of the Redwood Cabin following the Secretary’s Standards and Guidelines for Archeology and Historic Preservation Digital
Photography Standards.
The documentation shall be prepared by an architectural historian, or historical
architect as appropriate, meeting the Secretary’s Standards and Guidelines for
Archeology and Historic Preservation, Professional Qualification Standards. The
documentation shall be submitted to the San Mateo County Library, the San Mateo
County Historical Association, the Northwest Information Center, and the Midpen
office in Los Altos.
Midpen Prior to demolition of structure
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Midpeninsula Regional Open Space District Redwood Cabin Removal Project EIR 9
Mitigation Measure Measure Description Implementation
Responsibility Timing Verification
Mitigation 3.2-1b: Redwood Cabin interpretation. Midpen will create an interpretive resource outlining the Redwood Cabin’s historic status, historic context, and significance. This resource will be available in a digital and/or physical format for public engagement and may be shared with a relevant local organization such as the San Mateo County Historical Association.
Midpen
Prior to or following demolition of structure
Mitigation Measure 3.2-1c: Salvage of useable materials. Should any of the demolished structure materials (i.e., redwood logs) be in acceptable condition, Midpen shall reserve materials for potential future uses and/or salvage in compliance with Midpen’s waste diversion requirements outlined in Midpen’s Board of Directors Policy 4.08 - Construction and Demolition Waste Diversion. If these materials are free of pests, Midpen will coordinate with a local historic salvage organization, such as Garden City Recycle and Salvage in Santa Cruz, Whole House Building Supply & Salvage in San Mateo, or Heritage Salvage in Petaluma for their reuse.
Midpen Prior to demolition of structure
Mitigation Monitoring and Reporting Plan Ascent Environmental
Midpeninsula Regional Open Space District 10 Redwood Cabin Removal Project EIR
Best Management Practices Checklist
BMPs Implementation Responsibility Timing Verification
Air Quality
EPG AQ-1: Midpen shall insure that the following measures are included in all future as part of construction
contracts to control fugitive dust emissions:
Water all active construction areas at least twice daily and more often during windy periods. Active areas adjacent to existing land uses shall be kept damp at all times, of shall be treated with non-toxic stabilizers or dust palliatives;1
Cover all trucks hauling soil, sand and other 2 loose materials and/or require all trucks to maintain at least two feet of freeboard;
Pave or, aApply water up to three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads,
parking areas and staging areas for construction sites;3
Sweep daily (preferably with water sweepers) all paved access roads if visible soil material is carried onto paved
access roads, parking areas and staging areas at construction sites;4
Sweep streets daily (preferably with water sweepers) if visible soil material is carried onto adjacent public streets;
Hydroseed or apply non-toxic soil stabilizers to inactive construction areas;
Enclose, cover, or water twice daily or apply non-toxic soil binders to any exposed stockpiles (dirt, sand, etc.);
Limit traffic speeds on unpaved roads to 15 mph;
Install sandbags or other wildlife friendly erosion control measures to prevent silt runoff to public roadways;
Replant vegetation in disturbed areas as quickly as possible with locally appropriate native plants;
Suspend excavation and grading activity whenever the wind is so high that it results in visible dust plumes despite control efforts.
Midpen Prior to and during
demolition of structure
BMP AQ-1: Midpen is responsible for implementing the following Basic Construction Mitigation Measures in
addition to EPG AQ-1 to reduce emissions from construction-related activities and to satisfy BAAQMD’s BMP
requirements.
Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling
time to 5 minutes (as required by the California airborne toxics control measure CCR Title 13, Section 2485). Clear
signage shall be provided for construction workers at all access points.
Midpen Prior to and during
demolition of structure
1 There are no existing land uses adjacent to the project site.
2 No sand or soil will be hauled during project implementation.
3 Paving is not occurring with the project and the project site does not include paved parking or staging areas.
4 The project site does not include paved parking or staging areas.
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All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications.
All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to
operation.
Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust
complaints. This person shall respond and take corrective action within 48 hours. BAAQMD’s phone number shall
also be visible to ensure compliance with applicable regulations.
Biological Resources
EPG BIO-10: Revegetation and/or enhancement shall be undertaken where any sensitive habitat or special-status species habitat will be disturbed or destroyed by facility construction. The project includes rRevegetation work to
enhance the natural open space values of the site shall be implemented prior to or concurrently with the
development. The design of an appropriate revegetation work program shall will be designed to return native
species to the site, including the areas underlying footprint of where the Redwood Cabin structure and other accessory structure currently stand.5 fully compensate for the lost habitat, with no net loss of habitat functions and values. Riparian and wetland habitat impacts will typically be mitigated at a 3:1 ratio for high quality habitat areas and at lower ratios where lower habitat quality justifies a lower ratio. A lower ratio may also be justified if habitat mitigation is implemented and verified as successful prior to the occurrence of impacts. Mitigation shall be based on in-kind replacement of impacted habitat with habitat of equal or better biotic value. 6The revegetation program work shall will be designed by a qualified District-approved biologist or ecologist and submitted to the
appropriate regulatory or trustee agency for approval, if required. At a minimum, the revegetation program shall
include a description of project impacts, mitigation calculations, the mitigation site, revegetation techniques,
maintenance measures, a long-term monitoring program, and contingency measures. Native plant materials
suited to the site will be utilized in all mitigation work.7
Midpen Prior to and during demolition of structure, and site recontouring and revegetation
IPMP BMP 11: Sanitation and Prevention of Contamination -All personnel working in infested areas shall take appropriate precautions to not carry or spread weed seed or SOD-associated spores outside of the infested area. Such precautions will consist of, as necessary based on site conditions, cleaning of soil and plant materials from tools, equipment, shoes, clothing, or vehicles prior to entering or leaving the site.
Midpen Prior to and during demolition of structure, and site recontouring and revegetation
IPMP BMP 12: All staff, contractors, and volunteers shall be properly trained to prevent spreading weeds and pests to other sites. Midpen Prior to and during demolition of structure, and site recontouring and revegetation
5 Restoration is not proposed as part of the project. Seeding of native species is considered revegetation and will not lead to increased ecological function such as with full restoration.
6 Biological mitigation for loss of habitat is not required for this project. As described in Section 3.1, “Biological Resources,” the impact to riparian and wetland habitat is less than significant.
7 Because mitigation for habitat loss is not required, these items are not applicable.
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IPMP BMP 14: Midpen staff shall ensure that rental equipment and project materials (especially soil, rock, erosion
control material and seed) are free of invasive plant material prior to their use at a worksite. Midpen Prior to and during demolition of structure, and site recontouring and revegetation
IPMP BMP 21: A Midpen-approved biologist shall survey all selected treatment sites shortly before work to
determine site conditions and develop any necessary site-specific measures. Treatment sites are defined as areas
where IPM activity, including manual, mechanical, and chemical treatment, is expected to occur. In addition, on a
repeating basis, grassland treatment sites shall be surveyed by a Midpen-approved biologist once every five years and brushy and wooded sites shall be surveyed once every five years. Brush removal on rangelands will require biological surveys before work is conducted in any year. Site inspections shall evaluate existing conditions at a given treatment site including the presence, population size, growth stage, and percent cover of target weeds and pests relative to native plant cover and the presence of special-status species and their habitat, or sensitive natural communities.
In addition, annual worker environmental awareness training shall be conducted for all treatment field crews and contractors for special-status species and sensitive natural communities determined to have the potential to occur on the treatment site by a Midpen approved biologist. The education training shall be conducted prior to starting work at the treatment site and upon the arrival of any new worker onto sites with the potential for special-status
species or sensitive natural communities. The training shall consist of a brief review of life history, field
identification, and habitat requirements for each special-status species, their known or probable locations in the
vicinity of the treatment site, potential fines for violations, avoidance measures, and necessary actions if special-
status species or sensitive natural communities are encountered.
Midpen Prior to and during demolition of structure, and site recontouring and revegetation
Cultural Resources
EPG CUL-1: Midpen will apply the Standard Protocol for Unexpected Discovery of Archaeological and
Paleontological Cultural Materials:
Protocol for Unexpected Discovery of Archaeological and Paleontological Cultural Materials. In the event that any cultural resources are exposed during construction, work at the location of the find will halt immediately within 10
meters (30 feet) of the find. If an archaeologist is not present at the time of the discovery, Midpen will contact an
archaeologist for identification and evaluation in accordance with CEQA criteria.
A reasonable effort will be made by Midpen and archaeologist to avoid or minimize harm to the discovery until significance is determined and an appropriate treatment can be identified and implemented. Methods to
protect finds include fencing, covering remains with protective material and culturally sterile soil or plywood.
If vandalism is a threat, 24-hour security shall be provided. During this evaluation period, construction
operations outside of the find location can continue preferably with an archaeologist monitoring any
subsurface excavations.
Midpen Prior to and during
ground disturbing
activities
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If the resource cannot be avoided, the archaeologist will develop an appropriate Action Plan for treatment
within 48 hours to minimize or mitigate the adverse effects. Midpen will not proceed with construction
activities that could affect the discovery until the Action Plan has been reviewed and approved. The treatment effort required to mitigate the inadvertent exposure of significant cultural resources will be guided by a research design appropriate to the discovery and potential research data inherent in the resource in association with suitable archaeological field techniques and analytical strategies. The recovery effort will be detailed in a professional report in accordance with current archaeological standards. Any non-grave associated artifacts will be curated with an appropriate repository.
EPG CUL-2: Application of the Native American Burial Plan (NABP) will be applied:
Native American Burial Plan
1. In the event of an inadvertent discovery of human remains and cultural items during project construction, the field crew supervisor shall take immediate steps, if necessary, to secure and protect any
remains and cultural materials. This shall include but is not limited to such measures as (a) temporary
avoidance by construction until the remains and items can be removed; (b) posting a security person; (c)
placement of a security fence around the area of concern; or, (d) some combination of these measures.
Any such measures employed will depend upon the nature and particular circumstances of the discovery.
2. The County Medical Examiner (Coroner) shall be notified by the field crew supervisor or other designated
Midpen manager and informed of the find and of any efforts made to identify the remains as Native
American. If the remains are identified as a prehistoric Native American by either a professional
archaeologist under contract to Midpen or the Medical Examiner’s forensic archaeologist, the Medical Examiner is responsible for contacting the Native American Heritage Commission (NAHC) within 24 hours of notification of the find. The Medical Examiner may choose to document and remove the remains at his/her discretion depending on the circumstances of the discovery. The NAHC then designates and notifies a Most Likely Descendant (MLD). The MLD has 24 hours to consult and provide recommendations for the treatment or disposition, with proper dignity, of the human remains and grave
goods [Note: Other culturally affiliated Native Americans [Indians] may be consulted by the MLD during
the consultation and recommendation process to determine treatment of the skeletal remains].
3. Each burial and associated cultural items shall be stored as a unit in a secure facility, which shall be accessible to the MLD and other Native American representative(s) or their designated alternates upon
prior arrangement.
4. The remains and associated cultural items shall be reburied in a secure location as near as possible to the area of their discovery or at an off-site location acceptable to the MLD that has minimal potential for future disturbance. The reburial shall be done in a manner that shall discourage or deter future
disturbance. Reburial shall be conducted by persons designated by the MLD, with the assistance, if
requested, of Midpen’s field crew. The location shall be fully documented, filed with the NAHC and the
California Historical Resources Information System, Northwest Information Center, California State
University, Sonoma and treated as confidential information.
Midpen
County Coroner, as appropriate
NAHC, as appropriate
Prior to and during ground disturbing activities
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5. If the NAHC is unable to identify a MLD, or the MLD fails to make a recommendation, or Midpen or
designate rejects the recommendation of the MLD and mediation (as per Section 5097.94 subdivision (k))
fails, reinterment of the human remains and associated cultural items associated shall take place with
appropriate dignity on the property in a location not subject to further subsurface disturbance.
6. For security reasons, no news releases, including but not limited to photographs, videotapes, written
articles, or other such means that contains information about human remains or burial-related items of
Native American origin shall be released by any party during the discovery, recovery and reburial unless
approved by the MLD.
7. Any disputes that arise among the MLD and representatives of affected Native American groups and/or
between Midpen or designee designate and the MLD concerning cultural affiliation or the ultimate
disposition of Native American human remains and associated funerary objects and unassociated
funerary objects shall be resolved according to the dispute resolution procedures in Section 5097.94 of
the State of California Public Resources Code.
8. The Archaeological Data Recovery/Native American Burial Treatment Report(s) shall be prepared by
professional archaeologists. The report shall include, but not be limited to, the following: project
overview; ethnographic section; previous archaeological research in the region and on-site; circumstances of discovery; recovery procedures and techniques; artifact analysis; faunal analysis; osteological analysis and interpretation; and, conclusions. The MLD and other interested Native American representative(s) shall be provided an opportunity to review the report and submit comments within the same time period as accorded any other reviewers.
9. Objects not associated with the human remains and recovered from private land shall be transferred to Midpen. If curation of any objects is required, curation will be at repository approved by Midpen. Repositories can include the History Museums of San Jose collections, the Tiburon Archaeological Research Group, San Francisco State University and the Collections Facility, Department of Anthropology, Sonoma State University, Rohnert Park.
EPG CUL-3: The protocol for determining if structures are of historic value is as follows:
1. The property and building types will be identified and evaluated by a qualified cultural consultant;
2. The cultural consultant will determine if the structures in question are currently included in a local register of historic resources, on the California Register of Historic Resources or on the National Register of Historic Places;
3. If it is determined that the structures in question are not currently included in a local register of historic resources, on the California Register of Historic Resources or on the National Register of Historic Places, a DPR 523 form issued by the California Department of Parks and Recreation (DPR) will be completed by the cultural consultant and the structural and building data sent to a qualified architectural historian.
4. The following measure applies only to the Southern La Honda Creek Area: As required by Mitigation CUL-1a(4) of the San Mateo Coastal Annexation EIR, if it is determined that the structures in question are
Midpen Steps 1 and 2 are complete.
DPR form to be
completed concurrent
with Mitigation 3.2-1a.
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currently on the California Register of Historic Resources or if the building has been determined to be of
historic value, there are two options that would mitigate any impact to the historic values:
a) Retain and rehabilitate the building according to the Secretary of the Interior’s Standards and Guidelines for Rehabilitating Historic Buildings (U.S. Department of Interior 1990). New
construction near this building should be consistent with its historic character; or
b) Move the building to a different location on its current parcel or to a different parcel appropriate to its historic character.8
Greenhouse Gas Emissions
BMP GHG-1: To satisfy GHG emission reduction measures provided by BAAQMD, the project contractor is responsible for using alternative fueled (e.g., biodiesel, electric) construction vehicles/equipment for at least 15 percent of the fleet. An exemption from this requirement may be granted if the contractor documents that alternative fuel is not reasonably available within the County.
Midpen Prior to and during
demolition of structure
Hazards and Hazardous Materials
Although the La Honda Creek Open Space Preserve Master Plan does not contain specific hazardous material EPGs that apply to this specific project, the document does list the following required hazards BMPS:
1. Remove all trash and construction-related waste to a secured, covered location at the end of each
working day to maintain a clean worksite. Dispose of hazardous materials according to all specified
regulations.
2. Store chemicals in a non-reactive container. Store bagged, dry reactive materials in a secondary
container. Protect storage areas from vandalism.
3. Mix concrete no closer than 25 feet from any waterway or open ditches. Concrete shall be mixed in secure containments. Cleaning of tools shall occur in secured containments; no concrete cleaning is allowed in drainages or water bodies. All concrete waste shall be off hauled; concrete is allowed to first
evaporate in containments for ease of off haul.9
4. Good housekeeping practices shall be followed to minimize storm water contamination from any petroleum products or other chemicals. Maintain spill cleanup materials where readily accessible during use.
5. Conduct proper & timely maintenance of vehicles and equipment. Cleaning or equipment maintenance shall be prohibited except in designated areas located near preserve entrances. If fueling must occur
Midpen Prior to and during
demolition of structure
8 This applies to the Southern La Honda Creek Area only and therefore is not relevant to the project.
9 The project does not include the use of concrete.
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onsite, use designated areas located away from drainages and a drip pan to catch spills. Place drip pans
under heavy equipment stored onsite overnight.
6. Instruct all personnel regarding the correct procedure for spill prevention and control, waste disposal, use of chemicals, and storage of materials.
EPG HAZ-9: In order to reduce fire ignition risk, Midpen shall require the following measures for all maintenance and construction activities within the Preserve:
All equipment to be used during construction and maintenance demolition10 activities must have an approved
spark arrestor.
Grass and fuels around construction demolition sites where construction11 vehicles are allowed to be parked will
be cut or reduced.
Mechanical construction12 equipment that can cause an ignition will not be used when the National Weather Service issues a Red Flag Warning for the San Francisco Bay Area.
Hired contractors will be required to:
Provide water to suppress potential fires caused by the work performed.
Remind workers that smoking is prohibited at the work site and on any District land per contract conditions and District Ordinance.
Maintain working ABC fire extinguishers on all vehicles in the work area.
Contact both Mountain View Dispatch at (650) 968-4411 and CAL FIRE, Skylonda, at (650) 851-1860 for emergency response in the event of a fire.
Midpen Prior to and during demolition of structure
Hydrology and Water Quality
EPG WQ-2: Storm water quality Best Management Practices (BMPs) as listed in this section shall be implemented to reduce potential water quality impacts. BMPs include:
1. Flow of runoff from drainage structures will be directed to vegetated areas, away from creeks and drainages as is practical.
2. Conduct any trail maintenance work during low flow periods. 13
3. Use erosion and sediment control measures to minimize water quality impacts and ensure no sediment
at heavily traveled trails flows into creeks. To the extent feasible, all measures will be 100 percent
biodegradable and/or certified weed-free. These measures include:
Midpen Prior to and during demolition of structure and site recontouring and revegetation
10 No new construction is proposed. The project entails demolition activities.
11 No new construction is proposed. The project entails demolition activities.
12 No new construction is proposed. The project entails demolition activities.
13 The project does not include trail maintenance.
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Silt Fences
Straw Bale Barriers
Brush or Rock Filters
Storm Drain Inlet Protection
Sediment Traps
Sediment Basins
Erosion Control Blankets and Mats
Midpen shall prevent erosion on steep slopes by using erosion control material according to manufacturer’s specifications.
4. If soil is to be stockpiled for any reason at creeksides, no run-off will be allowed to flow back to the creek.
Additional required Best Management Practices to project water quality:
5. Schedule project during the dry season to avoid erosion due to surface runoff during the construction phase demolition and site revegetation activities. 14
6. Construct rolling dips in areas where trail gradients exceed five percent to reduce runoff concentration;
outslope trail surfaces where feasible. 15
7. Implement road and trail seasonal closures to vehicles and our recreation use, where and when
appropriate.16
Midpen Prior to and during demolition of structure and site recontouring and revegetation
Noise and Vibration
EPG NOI-1: Midpen will ensure that all construction activity associated with implementation of the Master Plan will occur during the less sensitive daytime hours between 7:00 a.m. and 5:00 p.m. daily. Midpen Prior to and during demolition of structure
14 No new construction is proposed with the project.
15 No new construction is proposed with the project.
16 There is currently no public access to the project site.