HomeMy Public PortalAbout20190227 - Agenda Packet - Board of Directors (BOD) - 19-04
SPECIAL AND REGULAR MEETING
BOARD OF DIRECTORS OF THE
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
Administrative Office
330 Distel Circle
Los Altos, CA 94022
Wednesday, February 27, 2019
Regular Meeting starts at 7:00 PM*
A G E N D A
7:00 REGULAR MEETING OF THE BOARD OF DIRECTORS OF THE MIDPENINSULA
REGIONAL OPEN SPACE DISTRICT
ORAL COMMUNICATIONS
The Board President will invite public comment on items not on the agenda. Each speaker will
ordinarily be limited to three minutes; however, the Brown Act (Open Meeting Law) does not allow
action by the Board of Directors on items not on the agenda. If you wish to address the Board, please
complete a speaker card and give it to the District Clerk. Individuals are limited to one appearance
during this section.
ADOPTION OF AGENDA
CONSENT CALENDAR
All items on the Consent Calendar may be approved without discussion by one motion. Board members,
the General Manager, and members of the public may request that an item be removed from the Consent
Calendar during consideration of the Consent Calendar.
1. Approve February 13, 2019 Minutes
2. Claims Report
3. Approval of Changes to the Classification and Compensation Plan (R-19-23)
Staff Contact: Candice Basnight, Human Resources Manager
General Manager’s Recommendations: Adopt a resolution to amend the Classification and
Compensation Plan to include one new classification and title changes for three existing
classifications.
BOARD BUSINESS
The President will invite public comment on agenda items at the time each item is considered by the
Board of Directors. Each speaker will ordinarily be limited to three minutes. Alternately, you may
comment to the Board by a written communication, which the Board appreciates.
Meeting 19-04
Rev. 1/3/19
4. Resolution Approving an Addendum to the Final Environmental Impact Report for the
Integrated Pest Management Program and Related Minor Project Modifications (R-19-11)
Staff Contact: Coty Sifuentes-Winter, Senior Resource Management Specialist, Natural Resources
General Manager’s Recommendation: Adopt a resolution approving an addendum to the certified
Final Environmental Impact Report for the Integrated Pest Management Program and related minor
project modifications.
INFORMATIONAL MEMORANDUM
• Award of Contract for Literature Review on the Use of Pesticides in the Integrated Pest
Management Program
INFORMATIONAL REPORTS – Reports on compensable meetings attended. Brief reports or
announcements concerning activities of District Directors and staff; opportunity to refer public or Board
questions to staff for information; request staff to report to the Board on a matter at a future meeting; or
direct staff to place a matter on a future agenda. Items in this category are for discussion and direction to
staff only. No final policy action will be taken by the Board.
Committee Reports
Staff Reports
Director Reports
ADJOURNMENT
SPECIAL MEETING OF THE BOARD OF DIRECTORS OF THE MIDPENINSULA
REGIONAL OPEN SPACE DISTRICT – CLOSED SESSION
ROLL CALL
1. CONFERENCE WITH REAL PROPERTY NEGOTIATORS (Government Code Section
54956.8)
Property: San Mateo County APN(s): 079-080-090 and 079-080-080 (portions)
Agency Negotiator: Brian Malone, Assistant General Manager
Negotiating Party: Jim and Patty White
Under Negotiation: Lease Terms
ADJOURNMENT
*Times are estimated and items may appear earlier or later than listed. Agenda is subject to change of order.
In compliance with the Americans with Disabilities Act, if you need assistance to participate in this meeting,
please contact the District Clerk at (650) 691-1200. Notification 48 hours prior to the meeting will enable the
District to make reasonable arrangements to ensure accessibility to this meeting.
Written materials relating to an item on this Agenda that are considered to be a public record and are distributed
to Board members less than 72 hours prior to the meeting, will be available for public inspection at the District’s
Administrative Office located at 330 Distel Circle, Los Altos, California 94022.
CERTIFICATION OF POSTING OF AGENDA
I, Jennifer Woodworth, District Clerk for the Midpeninsula Regional Open Space District (MROSD), declare that
the foregoing agenda for the special and regular meetings of the MROSD Board of Directors was posted and
Rev. 1/3/19
available for review on February 22, 2019, at the Administrative Offices of MROSD, 330 Distel Circle, Los Altos
California, 94022. The agenda and any additional written materials are also available on the District’s web site at
http://www.openspace.org.
Jennifer Woodworth, MMC
District Clerk
February 13, 2019
Board Meeting 19-03
SPECIAL AND REGULAR MEETING
BOARD OF DIRECTORS
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
Administrative Office
330 Distel Circle
Los Altos, CA 94022
February 13, 2019
DRAFT MINUTES
SPECIAL MEETING – CLOSED SESSION
President Siemens called the special meeting of the Midpeninsula Regional Open Space District
to order at 6:00 p.m.
ROLL CALL
Members Present: Jed Cyr, Larry Hassett, Zoe Kersteen-Tucker, Pete Siemens, and Curt
Riffle
Members Absent: Karen Holman, and Yoriko Kishimoto
Staff Present: General Manager Ana Ruiz, General Counsel Hilary Stevenson, Assistant
General Manager Brian Malone, Assistant General Manager Susanna
Chan, Real Property Manager Mike Williams, Senior Real Property Agent
Allen Ishibashi
Public comments opened at 6:00 p.m.
No speakers present.
Public comments closed at 6:00 p.m.
1. CONFERENCE WITH LEGAL COUNSEL – EXISTING LITIGATION
(Government Code Section 54956.9(d)(1))
Name of Case: Burkhart v. Midpeninsula Regional Open Space District; Santa Clara
County Superior Court Case Number 18CV 334473.
ADJOURNMENT
President Siemens adjourned the special meeting of the Board of Directors of the Midpeninsula
Regional Open Space District at 6:55 p.m.
Meeting 19-03 Page 2
REGULAR MEETING
President Siemens called the regular meeting of the Midpeninsula Regional Open Space District
to order at 7:00 p.m.
President Siemens reported the Board met in closed session, and no reportable action was taken.
ROLL CALL
Members Present: Jed Cyr, Larry Hassett, Zoe Kersteen-Tucker, Pete Siemens, and Curt
Riffle
Members Absent: Karen Holman, and Yoriko Kishimoto
Staff Present: General Manager Ana Ruiz, General Counsel Hilary Stevenson, Assistant
General Manager Brian Malone, Assistant General Manager Susanna
Chan, Real Property Manager Mike Williams, Senior Real Property Agent
Allen Ishibashi, District Clerk/Assistant to the General Manager Jennifer
Woodworth, Budget & Analysis Manager Carmen Narayanan, Public
Affairs Manager Korrine Skinner, Public Affairs Specialist II Cydney
Bieber, Natural Resources Manager Kirk Lenington, Senior Resource
Management Specialist Coty Sifuentes-Winter
ORAL COMMUNICATIONS
No speakers present.
ADOPTION OF AGENDA
Motion: Director Riffle moved, and Director Cyr seconded the motion to adopt the agenda.
VOTE: 5-0-0
CONSENT CALENDAR
Public comment opened at 7:02 p.m.
No speakers present.
Public comment closed at 7:02 p.m.
Motion: Director Cyr moved, and Director Hassett seconded the motion to approve the Consent
Calendar.
VOTE: 5-0-0
1. Approve January 23, 2019 Minutes
Meeting 19-03 Page 3
2. Claims Report
3. _ Renewal of Agreement with Grassroots Ecology for the Hendrys Creek Stream
Restoration Project at Sierra Azul Open Space Preserve (R-19-18)
General Manager’s Recommendations:
1. Authorize the General Manager to renew an agreement with Grassroots Ecology (formerly
Acterra Stewardship) in an amount of $107,000 for native plant restoration, vegetation
monitoring, and grant administration work associated with the grant-funded Hendrys Creek
Stream Channel Restoration Project (Project) at Sierra Azul Open Space Preserve. The
agreement, including this renewal, is eligible for full reimbursement by a Santa Clara Valley
Water District grant through June 2020.
2. Authorize an additional allowance of $40,000 for optional hand watering, contingent upon
need at the District’s sole discretion, for a total not-to-exceed contract price of $147,000.
4. Maintenance and Indemnification Agreement between the County of Santa Clara
and Midpeninsula Regional Open Space District (R-19-17)
General Manager’s Recommendation: Adopt a resolution approving the Maintenance and
Indemnification Agreement between the County of Santa Clara and Midpeninsula Regional
Open Space District and authorizing the General Manager to execute and record the Agreement
BOARD BUSINESS
5. Alpine Road Trail Memorandum of Understanding with the County of San Mateo,
Coal Creek Open Space Preserve (R-19-19)
Real Property Manager Michael Williams provided the staff report summarizing the chronology
of ownership and failures along Alpine Road Trail and described the location of the trail. Mr.
Williams described the terms and conditions of the proposed Memorandum of Understanding
with San Mateo County, including assessment and design of long term repairs for use as a public
trail; use of County grading exemptions and permit waivers; right of entry for work to improve
the trail; and eventual transfer of the trail to the District.
Director Riffle inquired whether the trail crosses private property.
Mr. Williams described the private properties that have partial ownership of Alpine Road Trail,
and the private property owners would continue to be responsible for maintaining access to their
own standards.
Director Kersteen-Tucker requested additional information regarding the Board’s decision to
maintain a six-foot trail and whether this width is acceptable for San Mateo County.
Mr. Williams reported representatives have not raised any concerns regarding the six-foot trail
width.
Assistant General Manager Brian Malone reported that the Board decided in March 2018 to
maintain a six-foot trail width, which will not allow for patrol and emergency access.
Meeting 19-03 Page 4
Director Hassett commented on the high cost for repair and maintenance for a twelve-foot trail
width.
Public comments opened at 7:24 p.m.
No speakers present
Public comments closed at 7:24 p.m.
Motion: Director Riffle moved, and Director Hassett seconded the motion to authorize the
General Manager to enter into a Memorandum of Understanding with the County of San Mateo
for the repair and future negotiations to transfer ownership and management of the Alpine Road
Trail.
VOTE: 5-0-0
6. Fiscal Year 2018-19 Quarter 2 Budget Amendments (R-19-21)
Budget & Analysis Manager Carmen Narayanan presented the staff reports describing the
quarterly budget amendment process, proposed revenue and expenditure amendments, and
administrative transfer requests.
Public comments opened at 7:35 p.m.
Yvonne Tryce inquired regarding funding for the Hawthorns property nature buildings
commenting on the delays to work on the buildings due to trail planning.
Planning Manager Jane Mark provided an update on the timeline for public access at the
Hawthorns property.
Public comments closed at 7:37 p.m.
Motion: Director Riffle moved, and Director Kersteen-Tucker seconded the motion to adopt a
resolution approving the proposed Fiscal Year 2018-19 Budget Quarter 2 amendments (revenues
and expenses).
VOTE: 5-0-0
7. 2019 Special Park Districts Forum (R-19-20)
Public Affairs Specialist II Cydney Bieber provided an update on the 2019 Special Park Districts
Forum (SPDF) being cohosted by the District and the East Bay Regional Park District (EBRPD).
Ms. Bieber described the purpose of the SPDF and events being hosted by the District. Finally,
Ms. Bieber explained how to participate in the SPDF.
Director Hassett commented on the importance of providing information to participants as they
are traveling to the various locations.
Meeting 19-03 Page 5
Director Kersteen-Tucker commented on the need to publicize the event to local and regional
partners.
Ms. Bieber reported the EBRPD is handling publicity and several regional agencies have been
invited.
Director Cyr encouraged staff members to attend since the SPDF is local.
Public comments opened at 7:55 p.m.
No speakers present
Public comments closed at 7:55 p.m.
No Board action required.
8. Informational Update on the Development of the Prescribed Fire Program (R-19-
16)
Mr. Malone explained that the prescribed fire program will help the District respond to the
increasing wildfire dangers in California and described the District’s current activities,
equipment, and procedures aimed at preventing and responding to wildfires. In addition to fire
response and prevention, the District does work through its integrated pest management and
grazing programs to reduce fuel.
Senior Resource Management Specialist Coty Sifuentes-Winter described the objective and goals
of the prescribed fire program, including public safety and education, wildfire response training,
and agricultural use of land resources. Mr. Sifuentes-Winter explained development of the
prescribed fire program is ongoing and includes stakeholder and public meetings, policy review,
site visits, and consultation with the Bay Area Air Quality Management District. At the Board’s
retreat in December, the Board approved a new strategic objective to work with fire agencies and
surrounding communities to strengthen the prevention of, preparation for, and response to
wildland fires. This represents an increased scope, so additional review and development is
needed. As the District and its consultants inventory and monitor wildland fuels, they share the
information with other land management agencies. Finally, Mr. Sifuentes-Winter reviewed the
proposed timeline for the prescribed fire program development.
Director Riffle requested additional clarification regarding training District staff on wildfire
response.
Mr. Sifuentes-Winter described all of the various District classifications that already receive this
training.
Director Riffle commented on the potential cost of the prescribed fire program.
Mr. Sifuentes-Winter explained that as part of the consultant’s contract, they will be
investigating the potential cost of implementation and the most effective use of funds.
Additionally, staff is seeking grant funds to supplement District funds.
Meeting 19-03 Page 6
Director Siemens suggested the prescribed fire program may be able to be folded into the
restoration forestry program.
Public comments opened at 8:34 p.m.
Rich Sampson with CalFire Resource Management expressed his pleasure that the District is
moving forward with the prescribed fire program and the reduction of wildland fuels. Mr.
Sampson expressed the desire of CalFire to continue to work with the District moving forward
and encouraged working through CEQA requirements on a project-by-project basis.
Jim Wickett landowner in the Woodside area spoke regarding the need to prepare for emergency
access to District and nearby lands during wildfires. Mr. Wickett spoke in favor of expanding the
current project scope to reduce fuel loads and in favor of restoration forestry.
Denise Enea of the Woodside Protection District spoke in favor of fuel reduction to reduce
wildfire risk and decrease wildfire intensity. Ms. Enea spoke in favor of prescribed burning in
the grassland areas and expressed concern regarding prescribed burns in the eastern area of the
Woodside Protection District.
Patty Ciesla Executive Director of the Santa Clara County FireSafe Council commented on
upcoming projects in Santa Clara County to protect roadways for public safety and exit routes.
Ms. Ciesla recommended the District pursue projects along roadways to maintain safe exit
routes. Ms. Ciesla reported the FireSafe Council contracts with the City of Palo Alto to complete
similar work, and suggested the District consider a similar contract. Finally, Ms. Ciesla
encouraged increasing defensible space around homes and other buildings.
Public comments closed at 8:55 p.m.
No Board action required.
INFORMATIONAL MEMORANDUM
• Customer Relationship Management System and General Information Emails
• Highway 17 Wildlife and Regional Trail Crossings Final Revised Alternatives Report,
Summary of Public Comments, and Next Steps
• District Permit Exemption Legislation Update
INFORMATIONAL REPORTS
A. Committee Reports
Director Hassett reported the Legislative, Funding, and Public Affairs Committee met on
February 5, 2019.
B. Staff Reports
General Manager Ana Ruiz reported the District will be receiving a Community Partnership
award from the San Jose Conservation Corps and Charter School. On Tuesday, the District
received the Integrated Pest Management Achievement Award from the California
Meeting 19-03 Page 7
Environmental Protection Agency. The District recently received a letter from the City of
Saratoga requesting additional funds for the Saratoga to the Sea Trail, and additional information
will be provided to the Board at the upcoming Board retreat.
C. Director Reports
The Board members submitted their compensatory reports.
Director Riffle commented on a current opening for the San Francisco Restoration Authority and
suggested the Board discuss this at an upcoming Board meeting. Recently the neighbors in the
Kings Mountain area requested dog access at Purisima Creek and asked staff to return with
options for responding to the request.
By consensus, the Board directed staff to return with a future Board agenda item on the topic.
Director Kersteen-Tucker announced a new agency is proposed for San Mateo County to address
the challenges of flooding, sea level rise, and coastal erosion. The District may want to consider
acting as a collaborator with the agency, similar to the San Mateo Resource Conservation
District.
President Siemens reported his attendance at the District’s legislative lunch in Sacramento.
ADJOURNMENT
President Siemens adjourned the regular meeting of the Board of Directors of the Midpeninsula
Regional Open Space District at 9:14 p.m.
________________________________
Jennifer Woodworth, MMC
District Clerk
page 1 of 3
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
CLAIMS REPORT
MEETING # 19-04
MEETING DATE: February 27, 2019 Fiscal Year to date EFT:20.69%
Payment
Number
Payment
Type
Payment
Date
Notes Vendor No. and Name Invoice Description Payment
Amount
79762 Check 02/22/2019 10343 - GRANITE ROCK COMPANY Bear Creek Redwoods Public Access Project 198,032.86
468 EFT 02/22/2019 10005 - GRASSROOTS ECOLOGY Hendrys Creek Restoration Project 82,040.80
79753 Check 02/22/2019 *10720 - CITY OF MOUNTAIN VIEW - REC Annual Deer Hollow Farm Support Agreement 75,000.00
79721 Check 02/15/2019 11998 - HANFORD APPLIED RESTORATION & CONSERVATION Mindego Ranch Ponds Enhancement Project 58,304.08
478 EFT 02/22/2019 11432 - SAN MATEO COUNTY RESOURCE CONSERVATION DISTRICT Control of Slender False Brome 22,629.86
79758 Check 02/22/2019 10463 - DELL BUSINESS CREDIT 5 Ruggedized Laptops for Field Use 15,227.99
470 EFT 02/22/2019 11177 - HARRIS CONSTRUCTION Repair Roof On Barn at Tunitas Creek Ranch 11,937.00
79714 Check 02/15/2019 12030 - Container Stop, Inc.40' Storage Container & Modification (FFO) 11,550.00
475 EFT 02/22/2019 10086 - PHYTOSPHERE RESEARCH Sudden Oak Death Research - July 1 - Dec 31, 2018 10,414.92
79769 Check 02/22/2019 11523 - PGA DESIGN, INC.PGA - Alma College Cultural Landscape Rehab thru December 31, 218 9,597.50
466 EFT 02/22/2019 10642 - Forensic Analytical Consulting Services, Inc.Lead & Asbestos Testing at Multiple Sites 9,177.00
79768 Check 02/22/2019 11129 - PETERSON TRUCKS INC.Quarterly Inspections - M228, M17, T07, M29, M226, M26 8,282.85
79774 Check 02/22/2019 10099 - SAN FRANCISCO BAY BIRD OBSERVATORY American Badger and Burrowing Owl Habitat Suitability Study 7,525.50
444 EFT 02/15/2019 11748 - ENVIRONMENTAL AND ENERGY CONSULTING Consulting and lobbying: January 2019 7,500.00
79727 Check 02/15/2019 10925 - Papé Machinery Equipment Repair - T34 7,430.52
79719 Check 02/15/2019 11805 - GOLDEN HOUR RESTORATION INSTITUTE Mt. Um Native Plant Installation & Volunteer Workshop Planning 6,300.00
79712 Check 02/15/2019 11148 - BALANCE HYDROLOGICS, INC.Aldercroft Stables Monitoring - Water Rights related 6,093.85
79760 Check 02/22/2019 11701 - ERIC GOULDSBERRY ART DIRECTION Design and production of Midpen MAA Bond Accountability Report 5,310.00
79747 Check 02/22/2019 10826 - BARTEL ASSOCIATES, LLC Progress billing on OPEB Valuation Report 4,336.00
79754 Check 02/22/2019 11678 - COGSTONE RESOURCE MANAGEMENT, INC.Hawthorne Archeo Evaluation 11/1/18 - 12/31/18 4,319.75
482 EFT 02/22/2019 *11118 - Wex Bank Fuel for District Vehicles 4,168.28
79728 Check 02/15/2019 11129 - PETERSON TRUCKS INC.Quarterly Inspection & Service - M22, WT02, M207 4,008.11
79717 Check 02/15/2019 12015 - Dudek Development and Submittal of CDFW Prop 68 App 3,897.50
79773 Check 02/22/2019 11064 - ROSEMARY L. CAMERON Communications Support - Sep 2018 - Jan 2019 3,825.00
79739 Check 02/15/2019 10146 - TIRES ON THE GO Tires Service & Installation of New Tires - M221, ATV17, WT2, P86 3,600.12
79767 Check 02/22/2019 10253 - PETERSON TRACTOR CO Auger (Cat Excavator) 3,238.72
79770 Check 02/22/2019 *10211 - PUBLIC POLICY ADVOCATES 2019 Monthly Fee - Legislative Advocacy Services for February 2019 2,924.34
464 EFT 02/22/2019 10032 - DEL REY BUILDING MAINTENANCE Janitorial Services & Supplies - RSA, SFO & AO 2,543.10
446 EFT 02/15/2019 11593 - H.T. HARVEY & ASSOCIATES Alma College Bat Relocation & Habitat Replacement & Ravenswood Bay Trail - Professional Services Dec 2018 2,516.52
440 EFT 02/15/2019 11349 - BAY NATURE INSTITUTE 2019 Local Hero Awards Dinner Sponsorship 2,500.00
79746 Check 02/22/2019 11799 - AZTEC LEASING, INC.Printer/Copier leases - 6 machines 2,326.07
79720 Check 02/15/2019 10287 - GRAINGER INC Steel Door (SA) 2,299.61
79716 Check 02/15/2019 11058 - DIAMOND CRANE COMPANY, INC.Annual Well Servicing and Maintenance 2,025.98
458 EFT 02/22/2019 10969 - BANK OF NEW YORK MELLON TRUST CO NA Escrow Agent & Admin Fees 2,000.00
476 EFT 02/22/2019 *10212 - PINNACLE TOWERS LLC Tower Rental - Skeggs Point - March 2019 1,945.05
79779 Check 02/22/2019 10338 - THE ED JONES CO INC Flat Badges + 3 Uniform Badges 1,938.85
450 EFT 02/15/2019 10140 - PINE CONE LUMBER CO INC Treated Lumber for Stock - FFO 1,910.02
456 EFT 02/22/2019 10001 - AARON'S SEPTIC TANK SERVICE Sanitation Services - Windy Hill (2 vaults), Pulgas Ridge & PCR 1,845.00
449 EFT 02/15/2019 11144 - Peninsula Motorsports Annual Service - (ATV6) & Replaced Bad Ignitor (ATV1) 1,796.96
79723 Check 02/15/2019 11327 - JOINT VENTURE SILICON VALLEY 2019 Sponsorship of State of the Valley Conference 1,750.00
79713 Check 02/15/2019 10141 - BIG CREEK LUMBER CO INC Bridge & Puncheon Repair Material 1,601.83
79729 Check 02/15/2019 12031 - Ray & Jan's Mobile Truck Service Chipper service (M18) & Maintenance Service (T32) 1,512.07
79742 Check 02/15/2019 *10213 - VISION SERVICE PLAN-CA Vision Premium - February 2019 1,481.06
79771 Check 02/22/2019 12031 - Ray & Jan's Mobile Truck Service Annual Service & Inspection - T23, M14 1,467.54
79748 Check 02/22/2019 10141 - BIG CREEK LUMBER CO INC Lumber for shop - SFO 1,424.78
448 EFT 02/15/2019 10222 - HERC RENTALS, INC.Equipment Rental (BCR) 1,414.79
445 EFT 02/15/2019 10187 - GARDENLAND POWER EQUIPMENT Equipment Supplies - Brush Cutter Parts, Pole & Chain Saw Repairs 1,238.81
79777 Check 02/22/2019 10580 - SHARP BUSINESS SYSTEMS Printing Costs for Sharp Copiers 12/28/18 - 1/29/19 1,191.96
79744 Check 02/22/2019 10294 - AmeriGas - 0130 SFO Propane 1,191.11
480 EFT 02/22/2019 *10952 - SONIC.NET, INC.AO Internet 3/01 - 3/31/19 1,170.00
79722 Check 02/15/2019 10423 - HARRINGTON INDUSTRIAL PLASTICS Water filters and supplies 1,086.52
79735 Check 02/15/2019 *10136 - SAN JOSE WATER COMPANY Water Service (RSACP), (BCR) 1,061.36
79776 Check 02/22/2019 11224 - SANTA CLARA COUNTY - COMMUNICATIONS DEPT Radio Tower Repair 1,042.50
439 EFT 02/15/2019 10001 - AARON'S SEPTIC TANK SERVICE Septic Tank Service (SA-MT UM) 950.00
79780 Check 02/22/2019 10146 - TIRES ON THE GO Tires Service - P88 931.35
471 EFT 02/22/2019 11906 - LAW OFFICES OF GARY M. BAUM Special Legal Counsel Services Jan 2019 868.00
Finance has started to roll out electronic funds transfer (EFT) for accounts payable
disbursements to reduce check printing and mailing, increase payment security, and
ensure quicker receipt by vendors
page 2 of 3
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
CLAIMS REPORT
MEETING # 19-04
MEETING DATE: February 27, 2019 Fiscal Year to date EFT:20.69%
Payment
Number
Payment
Type
Payment
Date
Notes Vendor No. and Name Invoice Description Payment
Amount
Finance has started to roll out electronic funds transfer (EFT) for accounts payable
disbursements to reduce check printing and mailing, increase payment security, and
ensure quicker receipt by vendors
79763 Check 02/22/2019 *11551 - GREEN TEAM OF SAN JOSE Garbage Service (RSA), (SAO) 848.06
79741 Check 02/15/2019 10403 - UNITED SITE SERVICES INC Temporary Fencing Rental SA-Mt. Um & Sanitation Services Lower PC Restroom 777.53
79745 Check 02/22/2019 11048 - ARC 8 Posters Printed on Foamcore for Legislative Presentation 768.56
479 EFT 02/22/2019 10447 - SIMMS PLUMBING & WATER EQUIPMENT Annual on Demand Hot Water Heater & Replace Toilet at Rental Property 752.25
461 EFT 02/22/2019 10352 - CMK AUTOMOTIVE INC Maintenance Service & Repairs - P108, P81, P82, M202, M209 732.98
79734 Check 02/15/2019 10151 - SAFETY KLEEN SYSTEMS INC SFO Parts & Tool Cleaner Service, Waste Disposal 699.14
79724 Check 02/15/2019 10119 - KWIK KEY LOCK & SAFE CO INC Spare Keys 669.91
79726 Check 02/15/2019 *10180 - P G & E Gas & Electric for 7 locations 658.32
79715 Check 02/15/2019 10027 - CRESCO EQUIPMENT RENTALS Trash Pump - BCR 629.03
443 EFT 02/15/2019 10352 - CMK AUTOMOTIVE INC P86 Service / Repair 604.65
79782 Check 02/22/2019 11586 - WH DEMPSEY ENGINEERING Clear Drain Line at Bergman 585.00
79750 Check 02/22/2019 10723 - Callander Associates Ravenswood Bay Trail Connection Design & Construction Mgmt 565.47
467 EFT 02/22/2019 11882 - Goettelmann's Ryan's Sport Shop Uniform boots - Barshow 519.93
79718 Check 02/15/2019 11882 - Goettelmann's Ryan's Sport Shop Uniform boots - Smutnak 519.93
79775 Check 02/22/2019 11484 - SAN JOSE STATE UNIVERSITY RESEARCH FOUNDATION Grant for Fire Weather Outreach 500.00
79756 Check 02/22/2019 10544 - CORELOGIC INFORMATION SOLUTION Property Research Services - January 2019 463.50
79743 Check 02/22/2019 10261 - ADT LLC (Protection One)Alarm Services 452.29
79755 Check 02/22/2019 11989 - CONIFER CREATIVE, INC.Photo contest flyer and Predator Animals brochure design 450.00
451 EFT 02/15/2019 10447 - SIMMS PLUMBING & WATER EQUIPMENT Hot Water Heater Repairs at October Farm 447.69
481 EFT 02/22/2019 10143 - SUMMIT UNIFORMS Ranger Uniforms / Downing 443.56
79751 Check 02/22/2019 10014 - CCOI GATE & FENCE Gate Service (RSACP) 400.00
477 EFT 02/22/2019 11479 - Rootid, LLC Website Maintenance - 4 retainer hours 378.00
79752 Check 02/22/2019 10168 - CINTAS Shop Towel Service (FFO & SFO) 364.76
79772 Check 02/22/2019 *10093 - RENE HARDOY AO Gardening Services 325.00
442 EFT 02/15/2019 11319 - CHANCE, MARIANNE Per Diem for Certified Interpretive Guide Training 303.00
455 EFT 02/15/2019 11816 - Trumper, Megan Per Diem for Certified Interpretive Guide Training 303.00
79738 Check 02/15/2019 11055 - SYSTEMS FOR PUBLIC SAFETY Background check-Ranger candidate 300.00
79731 Check 02/15/2019 10932 - RDO EQUIPMENT COMPANY Equipment Motor 280.02
79761 Check 02/22/2019 11607 - GFOA GFOA Member Dues - 3/01/19 through 2/29/20 280.00
79733 Check 02/15/2019 11526 - REPUBLIC SERVICES Monthly Garbage Service 275.43
452 EFT 02/15/2019 10683 - STERZL, OWEN Tuition Reimbursement - Foothill College 264.65
473 EFT 02/22/2019 11144 - Peninsula Motorsports ATV 2 Service 264.24
469 EFT 02/22/2019 *10173 - GREEN WASTE SFO Recycle and Garbage 245.66
79711 Check 02/15/2019 10261 - ADT LLC (Protection One)Alarm Repair (FFO) 217.79
441 EFT 02/15/2019 11907 - BORGESI, MELISSA Travel Expense Reimburse - Intro to Planning Class 209.71
454 EFT 02/15/2019 10152 - Tadco Supply Janitorial Supplies (RSA&CP) 207.32
474 EFT 02/22/2019 10505 - PENNINGTON, BRAD Per Diem for Field Training Officer Supervisor Course 203.00
79766 Check 02/22/2019 10422 - PEREZ, MIKE Per Diem for Field Training Officer Supervisor Course 203.00
472 EFT 02/22/2019 11326 - LEXISNEXIS Online subscription service Jan 2019 198.00
79781 Check 02/22/2019 11324 - UNITED CHIMNEY SERVICE INC Chimney Sweep at Rental Property 198.00
460 EFT 02/22/2019 10170 - CASCADE FIRE EQUIPMENT COMPANY Patrol truck fire pumper repair parts 197.08
79764 Check 02/22/2019 11758 - HALF MOON BAY COASTSIDE CHAMBER OF COMMERCE Annual Membership for Half Moon Bay Chamber of Commerce 192.00
462 EFT 02/22/2019 10021 - COASTAL CHIMNEY SWEEP Chimney Sweep at Rental Property 140.00
79725 Check 02/15/2019 10260 - LUND PEARSON MCLAUGHLIN Fire Sprinkler Inspection 140.00
79765 Check 02/22/2019 *10664 - MISSION TRAIL WASTE SYSTEMS AO Garbage Services 135.16
79778 Check 02/22/2019 10302 - STEVENS CREEK QUARRY INC Base Rock for Stock - FFO 129.49
465 EFT 02/22/2019 11151 - FASTENAL COMPANY Shop Supplies 128.15
79737 Check 02/15/2019 11627 - SOUTH BAY ACCESS SOLUTIONS Gate Service / adjustment 125.00
79736 Check 02/15/2019 11429 - SAN MATEO COUNTY PARKS DEPARTMENT Magnetic Sign Board Printing Services 122.87
79757 Check 02/22/2019 10517 - CSMFO 2019 CSMFO Muni. Membership - S. Jaskulak 110.00
457 EFT 02/22/2019 10240 - ACE FIRE EQUIPMENT & SERVICE INC Hydrotest O2 Clyinders 100.00
453 EFT 02/15/2019 10107 - SUNNYVALE FORD P114 5K SERVICE 94.13
79749 Check 02/22/2019 *10172 - CALIFORNIA WATER SERVICE CO-3525 Water Service - Windy Hill 55.86
79732 Check 02/15/2019 10194 - REED & GRAHAM INC Trail Restoration Material (FOOSP) 54.63
79759 Check 02/22/2019 11642 - Elias Khoury Level II Parking Citation Hearing 50.00
79740 Check 02/15/2019 11596 - TOSHIBA BUSINESS SOLUTIONS Printing Costs for Plotter 12/16/18 - 1/15/19 40.15
page 3 of 3
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
CLAIMS REPORT
MEETING # 19-04
MEETING DATE: February 27, 2019 Fiscal Year to date EFT:20.69%
Payment
Number
Payment
Type
Payment
Date
Notes Vendor No. and Name Invoice Description Payment
Amount
Finance has started to roll out electronic funds transfer (EFT) for accounts payable
disbursements to reduce check printing and mailing, increase payment security, and
ensure quicker receipt by vendors
463 EFT 02/22/2019 11210 - DATA SAFE AO Shredding Services 40.00
447 EFT 02/15/2019 11475 - HEBERT, AARON,Mileage Reimbursement 1/18/19 37.76
459 EFT 02/22/2019 10183 - BARRON PARK SUPPLY CO INC Supplies For Silva House 29.81
79730 Check 02/15/2019 10134 - RAYNE OF SAN JOSE Water Service (FOOSP) 28.25
Grand Total 653,162.11$
*Annual Claims
**Hawthorn Expenses
A### = Administrative Office Vehicle GP = General Preserve PCR = Purisima Creek Redwoods SCNT = Stevens Creek Nature Trail
AO2, AO3, AO4 = Leased Office Space HR = Human Resources PIC= Picchetti Ranch SCS = Stevens Creek Shoreline Nature Area
BCR = Bear Creek Redwoods LH = La Honda Creek PR = Pulgas Ridge SFO = Skyline Field Office
CAO = Coastal Area Office LR = Long Ridge RR = Russian Ridge SG = Saratoga Gap
CC = Coal Creek LT = Los Trancos RR/MIN = Russian Ridge - Mindego Hill SJH = Saint Joseph's Hill
DHF = Dear Hollow Farm M### = Maintenance Vehicle RSA = Rancho San Antonio SR= Skyline Ridge
ECdM = El Corte de Madera MB = Monte Bello RV = Ravenswood T### = Tractor or Trailer
ES = El Sereno MR = Miramontes Ridge SA = Sierra Azul TC = Tunitas Creek
FFO = Foothills Field Office OSP = Open Space Preserve SAO = South Area Outpost TH = Teague Hill
FOOSP = Fremont Older Open Space Pres.P### = Patrol Vehicle SAU = Mount Umunhum TW = Thornewood
Abbreviations
Rev. 1/3/18
R-19-23
Meeting 19-04
February 27, 2019
AGENDA ITEM 3
AGENDA ITEM
Approval of Changes to the Classification and Compensation Plan
GENERAL MANAGER’S RECOMMENDATION(S)
Adopt a resolution to amend the Classification and Compensation Plan to include one new
classification and title changes for three existing classifications.
SUMMARY
The General Manager recommends adding a new Environmental Education Specialist position in
the Classification and Compensation Plan (“Plan”), which the Board of Directors (Board)
previously approved as a part of the Fiscal Year 2018-19 Budget. In addition, the General
Manager recommends changing titles for three other positions as follows:
•Change Docent Program Manager to Interpretation & Education Program Manager;
•Change Public Affairs Program Coordinator to Visitor Services Program Coordinator
and;
•Change Grants Specialist to Grants Program Manager.
There is no cost associated with the proposed three title changes.
DISCUSSION
New Classification - Environmental Education Specialist in Visitor Services
In May 2018, the Board accepted the final report for the Docent and Volunteer Programs
Structure Study conducted by the consultant Conservation by Design. The study recommended
that the Midpeninsula Regional Open Space District (District) “staff the outdoor environmental
education program with one or more professionally trained Environmental Education
Specialist(s).” The recommendation was included to enhance the environmental education
capabilities and capacity of the District’s formal school-focused educational programming
(grades elementary through high school; junior college).
The new Environmental Education Specialist position will focus on school programming and
support the development of youth outreach programs. Primary responsibilities of the
Environmental Education Specialist include coordination and scheduling of school field trips,
and enhancing docent coaching and training. The new position will expand the capacity of the
Interpretation & Education Program Manager (formerly known as the Docent Program Manager)
to enhance environmental youth programs in response to high public interest (2018 Preserve Use
Survey results) through new partnerships, enhanced program delivery, improved messaging, and
program tracking. This position will also further the Board’s Diversity, Inclusion, and Equity
R-19-23 Page 2
goals by increasing outreach efforts and engagement amongst local children and teenagers. The
Board approved this new position in the Fiscal Year 2018-19 Budget (R-18-63). Human
Resources staff researched the level of compensation based on the job specifications for the
classification for inclusion in the classification and compensation plan.
Classification Name Changes
Interpretation & Education Program Manager
The Docent and Volunteer Programs Structure Study included a recommendation for renaming
the “Docent Program” to the “Interpretation and Education Program” to “clarify the nature and
focus of the program using more common language for the public’s benefit.” The recommended
title change from Docent Program Manager to Interpretation & Education Program Manager
reflects this change in terminology. There is no cost associated with this title change.
Visitor Services Program Coordinator
The Financial and Operational Sustainability Model (FOSM) recommended organization-wide
restructuring. As part of the implementation, the Docent Program moved from the Public Affairs
Department to the Visitor Services Department in April 2016. The Public Affairs Program
Coordinator classification name remained unchanged. The General Manager recommends
changing the title of Public Affairs Program Coordinator to Visitor Services Program
Coordinator to reflect the current organizational reporting structure. There is no cost associated
with this title change.
Grants Program Manager
A portion of the Grants Specialist’s duties includes working with external entities to build the
case for funding, developing funding partnerships, and executing projects in tandem with other
organizations and agencies. In doing so, the incumbent has found that non-governmental
organizations are unfamiliar with the term “Specialist,” and are unable to interpret the role
correctly. External organizations often interpret this title as a “coordinator” or “assistant”, which
leads them to assume that they should be communicating with a manager supervising the Grants
Specialist position in order to make decisions. A title change from Grants Specialist to Grants
Program Manager will assist external entities to identify the main point of contact for grants-
related items and more accurately reflect the role of this position in the District. Furthermore,
the proposed title change enables the incumbent to have more effective and productive
interactions with external colleagues. There is no cost associated with this title change.
FISCAL IMPACT
There is no fiscal impact associated with the recommended title changes. Budget for the new
Environmental Education Specialist position was approved as a part of the adoption of the Fiscal
Year 2018-19 Budget & Action Plan (R-18-63) on June 13, 2018. There remains sufficient
budget to cover the cost of this new classification.
BOARD COMMITTEE REVIEW
The Board discussed changes to the Docent and Volunteer Program Structure at the May 9, 2018
Board meeting. An informational memorandum from the General Manager to the Board of
Directors regarding the implementation of changes to these two programs was included in the
January 9, 2019 regular meeting agenda. No additional committee review is necessary.
R-19-23 Page 3
PUBLIC NOTICE
Public notice was provided as required by the Brown Act.
CEQA COMPLIANCE
This item is not a project subject to the California Environmental Quality Act
NEXT STEPS
If the Board approves the General Manager’s recommendations, staff will implement the
changes to the Classification and Compensation Plan with an effective date of February 27,
2019.
Attachment(s)
1. Resolution Approving Changes to the District Classification and Compensation Plan
2.Revised Classification and Compensation Plan
Responsible Department Head:
Stefan Jaskulak, Chief Financial Officer/Administrative Services Director
Prepared by:
Candice Basnight, Human Resources Manager
Attachment 1
Resolutions/2019/19-__Amend Interp&Grants 1
RESOLUTION NO. 19-__
RESOLUTION OF THE BOARD OF DIRECTORS OF THE
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT AMENDING
THE CLASSIFICATION & COMPENSATION PLAN BY ADDING ONE
NEW CLASSIFICATION SPECIFICATION AND AMENDING THREE
EXISTING CLASSIFICATION SPECIFICATIONS
WHEREAS, the General Manager has proposed an amendment to the Midpeninsula
Regional Open Space District Classification and Compensation Plan (“Plan”) to add the new job
classification of Environmental Education Specialist and associated salary range; and
WHEREAS, the General Manager proposes amending the Plan to rename three existing
job classifications to accurately reflect their respective roles in the organization.
NOW, THEREFORE, the Board of Directors of Midpeninsula Regional Open Space
District does hereby resolve as follows:
1.The Plan shall be amended by adding the new job classification title of
Environmental Education Specialist, with the classification specifications and salary
range as set forth in the attached exhibits.
2.The Plan shall be amended to replace the following job classification titles: Docent
Program Manager, Public Affairs Program Coordinator and Grants Specialist
respectively with the following new job classification titles: Interpretation &
Education Program Manager, Visitor Services Program Coordinator and Grants
Program Manager. Classification specifications and salary ranges for these respective
classifications remain unchanged and are set forth in the attached exhibits.
3. Except as herein modified, the Classification and Compensation Plan, Resolution No.
18-22 as amended, shall remain in full force and effect.
4. This resolution shall be effective February 27, 2019.
PASSED AND ADOPTED by the Board of Directors of the Midpeninsula Regional
Open Space District on _____, 2019, at a regular meeting thereof, by the following vote:
* * * * * * * * * * * * * * * * * * * *
AYES:
NOES:
ABSTAIN:
ABSENT:
ATTEST: APPROVED:
Attachment 1
Resolutions/2019/19-__Amend Interp&Grants 2
Secretary
Board of Directors
President
Board of Directors
APPROVED AS TO FORM:
General Counsel
I, the 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.
District Clerk
Step Full/PT
Range #Minimum Maximum Minimum Maximum Minimum Maximum Time
Seasonal Open Space Technician 6 20.7030 25.8490 3,589 4,481 43,062 53,766 PT
Seasonal Ranger Aide 6 20.7030 25.8490 3,589 4,481 43,062 53,766 PT
Seasonal Ranger 16 26.4254 32.9917 4,580 5,719 54,965 68,623 PT
Administrative Assistant 20 29.1351 36.3669 5,050 6,304 60,601 75,643 FT
Farm Maintenance Worker 20 29.1351 36.3669 5,050 6,304 60,601 75,643 FT
Open Space Technician*20 29.1351 36.3669 5,050 6,304 60,601 75,643 FT
Accounting Technician 22 30.5791 38.1853 5,300 6,619 63,605 79,425 FT
Human Resources Technician 22 30.5791 38.1853 5,300 6,619 63,605 79,425 FT
Information Technology Technician I 22 30.5791 38.1853 5,300 6,619 63,605 79,425 FT
GIS Technician 23 31.3516 39.1479 5,434 6,786 65,211 81,428 FT
Facilities Maintenance Specialist 24 32.1063 40.1046 5,565 6,951 66,781 83,418 FT
Lead Open Space Technician*24 32.1063 40.1046 5,565 6,951 66,781 83,418 FT
Risk Management Coordinator 24 32.1063 40.1046 5,565 6,951 66,781 83,418 FT
Senior Administrative Assistant 24 32.1063 40.1046 5,565 6,951 66,781 83,418 FT
Visitor Services Program Coordinator 25 32.9144 41.1029 5,705 7,125 68,462 85,494 FT
Volunteer Program Lead 25 32.9144 41.1029 5,705 7,125 68,462 85,494 FT
Ranger 26 33.7107 42.1013 5,843 7,298 70,118 87,571 FT
Senior Finance & Accounting Technician 26 33.7107 42.1013 5,843 7,298 70,118 87,571 FT
Executive Assistant 27 34.5545 43.1590 5,989 7,481 71,873 89,771 FT
Information Technology Technician II 27 34.5545 43.1590 5,989 7,481 71,873 89,771 FT
Public Affairs Specialist I 27 34.5545 43.1590 5,989 7,481 71,873 89,771 FT
Equipment Mechanic/Operator 28 35.4043 44.2048 6,137 7,662 73,641 91,946 FT
Lead Ranger 28 35.4043 44.2048 6,137 7,662 73,641 91,946 FT
Property Management Specialist I 28 35.4043 44.2048 6,137 7,662 73,641 91,946 FT
Real Property Specialist I 28 35.4043 44.2048 6,137 7,662 73,641 91,946 FT
Executive Assistant/Deputy District Clerk 29 36.2897 45.3101 6,290 7,854 75,483 94,245 FT
Planner I 29 36.2897 45.3101 6,290 7,854 75,483 94,245 FT
Data Analyst I 30 37.1751 46.4213 6,444 8,046 77,324 96,556 FT
Resource Management Specialist I 30 37.1751 46.4213 6,444 8,046 77,324 96,556 FT
Accountant 31 38.1021 47.5741 6,604 8,246 79,252 98,954 FT
Capital Project Manager II 31 38.1021 47.5741 6,604 8,246 79,252 98,954 FT
Environmental Education Specialist 31 38.1021 47.5741 6,604 8,246 79,252 98,954 FT
Planner II 31 38.1021 47.5741 6,604 8,246 79,252 98,954 FT
Management Analyst I 31 38.1021 47.5741 6,604 8,246 79,252 98,954 FT
Data Analyst II 34 40.9782 51.1811 7,103 8,871 85,235 106,457 FT
Resource Management Specialist II 34 40.9782 51.1811 7,103 8,871 85,235 106,457 FT
Interpretation & Education Program Manager 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Grants Program Manager 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Maintenance, Construction & Resource Supv.35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Management Analyst II 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Procurement & Contracting Agent/Specialist 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Property Management Specialist II 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Real Property Specialist II 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Supervising Ranger 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Training & Safety Specialist 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Volunteer Program Manager 35 42.0002 52.4528 7,280 9,092 87,360 109,102 FT
Applications Engineer 36 43.0342 53.7363 7,459 9,314 89,511 111,771 FT
Midpeninsula Regional Open Space District - CLASSIFICATION & COMPENSATION PLAN
Fiscal Year 2018/2019 - Effective 2/27/2019 (Pay Period 19-06)
Last revised: 2/27/2019, 12/12/2018, 11/19/2018, 10/10/2018, 9/26/18, 8/8/18, 6/13/2018, 1/24/2018, 12/13/2017, 7/1/17
Classification Title Hourly Range $Monthly Range $Annual Range $
ATTACHMENT 2
Public Affairs Specialist II 36 43.0342 53.7363 7,459 9,314 89,511 111,771 FT
Data Administrator 38 45.1794 56.4341 7,831 9,782 93,973 117,383 FT
Governmental Affairs Specialist 38 45.1794 56.4341 7,831 9,782 93,973 117,383 FT
Senior Technologist 38 45.1794 56.4341 7,831 9,782 93,973 117,383 FT
Facilities Maintenance Supervisor 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Capital Projects Field Manager 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Capital Project Manager III 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Planner III 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Public Affairs Specialist III 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Resource Management Specialist III 39 46.3084 57.8246 8,027 10,023 96,321 120,275 FT
Special Projects Manager 40 47.4434 59.2448 8,224 10,269 98,682 123,229 FT
Senior Accountant 41 48.6200 60.7304 8,427 10,527 101,130 126,319 FT
Senior Management Analyst 41 48.6200 60.7304 8,427 10,527 101,130 126,319 FT
Area Manager 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Area Superintendent 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
District Clerk/Assistant to General Manager 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
GIS Program Administrator 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Information Technology Program Administrator 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Human Resources Supervisor 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Senior Capital Project Manager 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Senior Planner 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Senior Property Management Specialist 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Senior Real Property Specialist 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Senior Resource Management Specialist 43 51.0563 63.7669 8,850 11,053 106,197 132,635 FT
Budget & Analysis Manager 48 57.6642 72.0148 9,995 12,483 119,941 149,791 FT
Finance Manager 48 57.6642 72.0148 9,995 12,483 119,941 149,791 FT
Human Resources Manager 48 57.6642 72.0148 9,995 12,483 119,941 149,791 FT
Information Systems & Technology Manager 48 57.6642 72.0148 9,995 12,483 119,941 149,791 FT
Engineering & Construction Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Land & Facilities Services Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Natural Resources Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Operations Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Planning Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Public Affairs Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Real Property Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Visitor Services Manager 51 62.0555 77.5055 10,756 13,434 129,075 161,211 FT
Assistant General Counsel I 53 65.1574 81.3799 11,294 14,106 135,527 169,270 FT
Assistant General Counsel II 55 68.4197 85.4504 11,859 14,811 142,313 177,737 FT
Assistant General Manager 59 75.4376 94.2093 13,076 16,330 156,910 195,955 FT
Chief Financial Officer/Director Administrative
Services 59 75.4376 94.2093 13,076 16,330 156,910 195,955 FT
* OST will receive an additional 1% stipend for Class A or B license; Lead OST 1% for Class A.
Board Appointee Group Compensation Hourly Monthly Annual Effective
General Manager $108.1731 $18,750 $225,000 6/13/2018
Controller - Part-time position $87.5243 $3,792 $45,512 12/12/2018
General Counsel $98.5577 $17,083 $205,000 7/11/2018
Elected Officials Compensation
Board Director
Last Revised
12/13/2017
12/13/2017
12/13/2017
$100.00 $500.00
The District’s Personnel Policies and Procedures provide that the compensation for an employee’s temporary out-of-class / Acting Assignment
shall be at least 5% but not more than 10% more than her/his current salary. Pursuant to Government Code 20480, out of class appointments
shall not exceed a total of 960 hours in each fiscal year.
1/1/2006
Effective DateMonthly MaximumPer Meeting
Rev. 1/3/18
R-19-11
Meeting 19-04
February 27, 2019
AGENDA ITEM 4
AGENDA ITEM
Resolution Approving an Addendum to the Final Environmental Impact Report for the Integrated
Pest Management Program and Related Minor Project Modifications
GENERAL MANAGER’S RECOMMENDATION
Adopt a resolution approving an addendum to the certified Final Environmental Impact Report
for the Integrated Pest Management Program and related minor project modifications.
SUMMARY
The Board of Directors (Board) approved the Final Environmental Impact Report (EIR) and
Mitigation Monitoring Plan (MMP) on December 10, 2014 for the Integrated Pest Management
(IPM) Program (R-14-148; Attachment 1 – Executive Summary of the 2014 EIR and MMP). The
complete EIR is available on the District website at
https://www.openspace.org/sites/default/files/IPM_EIR.pdf).
Staff recently identified several discretionary elements for inclusion into the IPM Program,
including additional invasive species treatment methods, an increase in treatment acreage for
manual and mechanical methods, and three new pesticides that provide better control of certain
target species than current pesticides. In addition, the Department of Fish and Wildlife has
identified two new species of special concern (2018) that need to be folded into the EIR review.
The attached Addendum to the 2014 EIR analyzes these minor modifications and inclusions to
the IPM Program, as required by the California Environmental Quality Act (CEQA), and finds
that no significant effect on the environment will result from these changes (Exhibit A to the
resolution - Addendum to the 2014 EIR).
BACKGROUND
As part of the California Floristic Province and recognized as one of twenty-five botanical
hotspots in the world, the Santa Cruz Mountains contain an extraordinary high biodiversity. The
biodiversity of the region is threatened by non-native plant introductions to California that began
in the 1500s with the first European settlers. By 1900, settlers introduced at least 34 non-native
plants, largely as ornamentals, to California that are now listed by the California Invasive
Species Council as having moderate or high impacts to wildlands. Other species introductions
were for cattle forage or erosion control, or accidentally introduced via contamination of other
materials (such as imported soils, food, or ballast water from ships). Non-native invasive plant
species do not support as many native wildlife species, and do not provide the same resources or
connectivity to the ecosystem as their native counterparts. Invasive plants can displace native
ecosystems and replace diverse plant communities with plant communities dominated by one
R-19-11 Page 2
plant species. The truly alarming invasive plants are ‘transformer’ species that not only out-
compete specialized rare species, but also alter the environment, ecosystem structure, or soil
chemistry to make it uninhabitable for native plants and wildlife.
Native species richness still account for 71% of all species in the Santa Cruz Mountains.
Although the native species richness is still high, the population size (abundance) of 223 non-
native species, as ranked by the California Invasive Species Council, has grown to dominate
many ecosystems. Of the 223 non-native species, a small percentage have proven to be highly
invasive and the Midpeninsula Regional Open Space District’s (District) IPM program targets
them for control.
The presence of invasive plants can also negatively affect ecological stability. Three measures
define ecological stability: the ability of species populations to recover quickly after a
disturbance (resilience), low variance in total biomass over time, and consistent species richness
and abundance (biodiversity). The District’s IPM Program is the front-line defense against loss
of biodiversity. Through the management of the most invasive species in high value habitats, the
District can prevent the loss of important native plant communities and the wildlife species they
support. Low abundance of certain species can lead to extirpation (localized extinction from the
area) and in the case of rare species, possible extinction. Approximately 42 percent of threatened
or endangered species are at risk due to impacts from invasive species. By protecting our
region’s biodiversity, the District works to preserve the resilience of local ecological systems,
which is particularly critical at this time given the changing climate.
District’s IPM Program
The Board certified the 2014 EIR and MMP for the IPM Program in December 2014. Since
then, staff have implemented a number of Program components, including the hiring of a new
IPM Coordinator, development of a pest database with CalFlora, refinements to the project
ranking system, a review of all grazing properties for compliance with the IPM Program, and the
development of an annual IPM Plan and Report.
Staff has provided Annual IPM Reports to the Board since the certification of the Program. At
the July 11, 2018 Board Meeting, staff presented the 2017 IPM Annual Report (R-18-28). The
report described methods used by staff, contractors, and volunteers to combat invasive species.
Table 1 presents a summary of the manual, mechanical, and chemical treatment methods and
hours for 2017.
Table 1: Treatment Methods and Hours for 2017 within Natural Areas
Treatment
Method
Hours Total
% of Total
Staff Contractor Volunteer
Brush Cut 13 242 - 255 4 %
Cut 42 34 172 247 4 %
Dig 27 268 211 506 8 %
Flame - 56 - 56 1 %
Herbicide 217 515 - 732 12 %
Mow - 14 - 14 0 %
Pull 324 1778 2176 4278 70 %
TOTAL 623 2907 2559 6089
% of Total 10 % 48 % 42 %
R-19-11 Page 3
Manual removal of weeds via pulling remained the most prevalent treatment method at 70% of
all hours; herbicide use accounted for 12% of all hours.
Process for Updating the IPM Program
The IPM Program is an adaptive management program that responds to pests on District lands in
real time. Each year the IPM Coordinator and IPM Coordination Team determine the IPM
activities that the District implements on District lands and reviews those activities against those
included in the IPM Guidance Manual and evaluated in the EIR to develop an Annual IPM Work
Plan. Staff, contractors, and volunteers use this Annual IPM Work Plan for all IPM related
activities. The inclusion of new activities into the IPM Program may require an amendment to
the IPM Guidance Manual and subsequent/supplemental environmental review documents.
Examples include the inclusion of new, substantially different IPM activities; an expansion in the
acreage of land actively managed per the IPM Program; or the inclusion of new chemicals with
different active ingredients.
Regarding pesticides, the IPM Program’s List of Approved Pesticides was developed with the
expectation that it would change over time as the science of pest control advances and more
effective, safer, and less harmful pesticides are developed; as manufacturers update, discontinue,
or substitute products; and as the District’s target pests change over time. The IPM Guidance
Manual and section 3.2.1 of the EIR describes in detail the process for updating the List of
Approved Pesticides.
Pesticides on the List of Approved Pesticides are:
• Screened for human toxicology, ecological toxicity, environmental fate and transport, and
proven efficacy against target pests;
• Reviewed annually by the District’s IPM Coordinator and IPM Coordination Team;
• Reviewed and approved by the Board of Directors;
• Presented for public comments at public hearings; and
• Included in the environmental documentation and public notification procedures (i.e., the
list is adopted as part of environmental review and approval process).
To inform the consideration of pesticides for inclusion into the Program, staff review the
approved pesticide lists of other public agencies within the San Francisco Bay Area (i.e. National
Park Service, East Bay Parks, California State Parks, City and County of San Francisco) as well
as non-profit, professional societies (i.e. California Invasive Species Council, California Native
Grass Association). Staff also subscribe to the Pesticide Research Institute to assess the human
and ecological risk of each pesticide. In addition, staff review research articles from the Impacts
of Pesticides on Invertebrates, a database provided by the Xerces Society for Invertebrate
Conservation, an international nonprofit organization that protects wildlife through the
conservation of invertebrates and their habitats. Once the first screening is complete, pesticides
undergo a more thorough toxicological screening by an outside consultant.
The use of glyphosate and other pesticides has been a topic of public concern. The recommended
changes to the IPM Program would expand upon existing best management practices (BMPs, see
Attachment 2 – Best Management Practices) to increase the safety of workers/pesticide
applicators and the public, as well as result in a net reduction in glyphosate (the main active
ingredient in Roundup®) use. At the July 11, 2018 Board meeting, staff and a consultant
presented a toxicological report on the potential human health and environmental impacts
associated with the use of glyphosate and a review the latest data regarding the District’s use
R-19-11 Page 4
within the IPM Program (R-18-28). Based on the human health effects, environmental fate, and
the risk evaluation findings, glyphosate was determined to pose no significant harm to
employees, visitors, or the environment when following both label directions and District current
and enhanced BMPs.
At the October 9, 2018 Planning and Natural Resources Committee meeting, community
members provided research papers that raised concerns about the use of pesticides. The
following is a short analysis of these papers:
Impacts of glyphosate on soil health
Researchers published a paper in February 2016, which examined the response of bacterial
community composition in corn and soybean crops to glyphosate, and found that the relative
abundance of a specific bacterium decreased while others increased. The authors of the study
stated that they could not determine if the impacts to soil microbial community was ecologically
significant. Glyphosate use on both corn and soybean crops has increased dramatically over the
years, reaching over 80,000 tons of product application in 2010 with a frequency of 3 to 4
applications in a season. District land managers apply glyphosate on natural lands at a much
lower frequency and with dramatically higher levels of selectivity than in agricultural
applications (which typically apply herbicides to crops via a tractor mounted broadcast spray
application. The District applies glyphosate with a spot spray method, where applicators only
spray targeted invasive plant species (as opposed to broadcast spraying). Typical percent cover
of species treated in an area is 5 to 25 percent, and application of herbicide is typically only
applied to a site once in any given year, as opposed to 4 applications of the agricultural
operations evaluated in the research.
Impacts of glyphosate on honeybees
Researchers published a paper in October of 2018 that examined the response to the gut
community of honeybees and found that exposure can disrupt the beneficial gut microbiota,
“potentially affecting bee health and their effectiveness as pollinators.” Researchers treated
honeybees with either 5 mg/L or 10 mg/L of glyphosate; the typical range in the environment is
1.4 to 7.6 mg/L. Other research shows that native bumblebees have microbiomes similar to
honeybees so it is likely that glyphosate would affect them in a similar way. However, research
has shown that “wild bees, and managed bees in some cases, prefer to forage on native plants in
hedgerows over co-occurring weedy, exotic plants”, therefore judicious invasive plant removal
can be beneficial to bee populations. The District strives to apply glyphosate to target invasive
species prior to flowering, when treatments are more effective. Bees and other pollinators are
unlikely to be in the area at this time and are not expected to have significant exposure to
glyphosate. At this time, there is only one known location of an apiary on District lands, the
Chestnut Orchard in the Skyline Ridge Open Space Preserve.
Impacts of Garlon on wildlife
Marin Municipal Water District (MMWD) drafted a Vegetation Management Plan in 2008 that
included an herbicide risk assessment of Garlon. The risk assessment recommends restricting
the use of Garlon “to very small treatment areas distant from water bodies.” The Board of
Directors of MMWD ultimately decided against the use of all herbicides as there are
“documented toxicity that herbicide present to aquatic creatures and habitat.” While Garlon has
been found to be toxic to fish and other aquatic organisms, the District has BMPs in place that
greatly reduce if not eliminate potential exposure to aquatic systems, including maintaining no-
spray buffers around aquatic features and restricting herbicide use when a treatment site is wet.
R-19-11 Page 5
Other agencies in the Bay Area (i.e. National Park Service, East Bay Regional Park District, City
and County of San Francisco) continue to use pesticides, including Garlon and glyphosate, in
natural areas with BMPs to minimize impacts. The recommended updates to the original 2014
BMPs help to further protect wildlife and mitigate potential impacts.
Pesticide Research
Researchers publish new pesticide research and review papers on a regular basis, including
information on the efficacy, human health and safety, environmental fate, and impacts to the
environment. District staff regularly monitor the professional literature to remain informed of
current scientific findings. Agricultural activities account for approximately 90% of all pesticide
use in the United States. Due to the quantity of pesticide use in agriculture, the vast majority of
research focuses on agricultural pesticide practices, which tend to utilize much higher quantities
of pesticides at much higher frequencies than the District’s targeted wildland IPM program. For
example, in February 2019, the peer-reviewed journal Mutation Research, accepted a manuscript
that showed a 41% increase in non-Hodgkin's lymphoma rates versus the general public for those
who were exposed to high doses of glyphosate. The research used “limited published data
available for inclusion” to present a potential link between a high exposure of glyphosate and
cancer. Given the District’s low and targeted use of pesticides and protective BMPs, potential
glyphosate exposure of District staff and visitors is well below the high exposure doses called
out by Mutation Research.
DISCUSSION
Staff recently identified several minor modifications to the IPM Program to better “protect and
restore the natural environment” and to adapt and update the IPM Program to reflect and
incorporate the most current pest control science. The list below summarizes the recommended
minor modifications to the program (details of the modifications can be found Exhibit A to the
resolution - Addendum to the 2014 EIR, with specific locations identified in parenthesis):
• Inclusion of three new pesticides to the Approved Pesticide List (listed by trade name):
a. Wasp Freeze II;
b. Garlon 4 Ultra; and
c. Capstone;
• New pesticide application methods that reduce pesticide drift and/or increase efficacy
(section 3.1, page 18);
• New manual and mechanical treatment methods for use in Natural Areas (section 3,
pages 11-12);
• Modifications to treated acreage amounts in both Natural and Fuel Management Areas
(section 3, pages 14-16) ; and,
• Inclusion of and protections for two new Species of Special Concern (California giant
salamander and the Santa Cruz black salamander) (section 3.3, pages 25-26).
These program modifications align with the District’s mission to “restore and protect the natural
environment” by increasing environmental protections through additional best management
practices (BMP) and mitigation measures. Additionally, these modifications provide the District
with more effective tools to accomplish the goals of the IPM program, which is to control pests
by consistent implementation of IPM principles to protect and restore the natural environment
and provide for human safety and enjoyment while on District lands. The addition of new pest
control methods and techniques, including the inclusion of three pesticides to the Approved
R-19-11 Page 6
Pesticide List, will allow for more effective treatment methods of invasive pests, which can lead
to a reduced environmental impact from IPM implementation. For more details on each item
listed above, please refer to the Addendum to the 2014 EIR (Exhibit A to the resolution) in
Exhibits 3a and 3b.
In March of 2017, the District contracted with Blankinship and Associates to perform a
toxicological review of four (4) candidate pesticides to be included in the IPM Program, listed
below by their trade name, with the active ingredient listed in parentheses:
• Wasp Freeze II (Prallethrin)
BASF, the manufacturer, discontinued Wasp Freeze, which was approved by the Board
during the original EIR. The replacement, Wasp Freeze II, is safer for the environment
and humans while also being more effective on target species. District staff use Wasp
Freeze II only for human health and safety along recreational facilities (i.e. trails,
restrooms, and parking lots) where closure of these areas is not desirable.
• Python Dust (Zeta-cypermethrin, S-enantiomer, and Piperonyl Butoxide)
The District’s Rangeland Ecologist recommends this insecticide for use on cattle within
the Conservation Grazing Program. The insecticide protects against all major livestock
ectoparasites.
• Garlon 4 Ultra (Triclopyr BEE)
This product provides superior control of certain woody plants (i.e. French broom) than
products already listed on the Approved Pesticide List. This product will also allow the
District to reduce its reliance on glyphosate.
• Capstone (Triclopyr TEE)
This product provides long-lasting control of certain plants (i.e. stinkwort) compared to
products already listed on the Approved Pesticide List. The product is a premixed
formulation of Milestone (already on the list of Approved Pesticides) and Garlon, thus
reducing the risk of exposure and/or human error during the mixing process. This
product will also allow the District to reduce its reliance on glyphosate.
After reviewing the Blankinship and Associate’s toxicological report in July of 2017 along with
the analysis from the Pesticide Research Institute, the IPM Coordination Team recommend
removing one (1) pesticide, Python Dust, from further analysis due to both human safety and
ecological concerns.
While there are some documented negative effects of pesticide use when not carefully controlled
through the use of strict BMPs, the professional judgement of Natural Resource staff is that the
benefits to the overall ecological stability within treatment sites (specifically to resiliency and
increased biodiversity) mitigate potential negative effects with the District’s judicious use of
pesticides. In addition, the pesticide application methods employed by staff and contractors
minimize the use of pesticides and any potential negative effects. Furthermore, the District
emphasizes training and safety to ensure implementation of the IPM Program BMPs. Staff will
continue to review all scientific data as it becomes available and make recommendation to
change the IPM Program as necessary. At this time, the District is in negotiations with an
independent consultant to provide an annotated bibliography and analysis of newest research on
all chemicals listed on the Approved Pesticide List.
R-19-11 Page 7
BOARD COMMITTEE REVIEW
The Planning and Natural Resources Committee held a meeting on October 9, 2018 with
interested members of the public to review the use of glyphosate as part of the District’s IPM
Program. Two members of the Committee attended, and two members of the public attended. As
discussed above, members of the public provided comment and concerns related to the impacts
of glyphosate (currently already on the List of Approved Pesticides as certified by the original
EIR of the IPM Program) on both human and ecological health and safety. At this meeting, the
Committee reviewed additional BMPs that were suggested by District staff that are above and
beyond standard land management practices. One recommended BMP was the addition of the
three (3) pesticides, discussed above, to the Approved Pesticide List. This would reduce the
District’s reliance on glyphosate and provide more effective tools for the IPM program to
accomplish its goals. The Planning and Natural Resources Committee supported forwarding to
the Board the additional BMPs for the Integrated Pest Management Program to further enhance
public and staff safety by a vote of 2-0.
FISCAL IMPACT
There are no direct fiscal impacts from approving the Addendum.
PUBLIC NOTICE
Public notice was provided as required by the Brown Act. Public notice was sent to 102
interested parties by postal or electronic mail.
CEQA COMPLIANCE
The Addendum evaluates the potential environmental consequences associated with aesthetics,
agriculture and forestry resources, air quality and greenhouse gas emissions, biological
resources, cultural resources and tribal cultural resources, geology and soils, hazards and
hazardous materials, hydrology and water quality, land use and planning, mineral resources,
noise, population and housing, public services and utilities, recreation, and traffic and
transportation. All proposed program modifications would be located within the Program Area
analyzed in the 2014 EIR.
The proposed minor modifications to the program would not alter any of the conclusions of the
2014 EIR. Additionally, the IPM Program, together with the proposed modifications would have
no significant impacts on the two additional Species of Special Concern. No new significant
environmental effects or a substantial increase in the severity of previously identified significant
effects would result.
The additions also would not affect any of the mitigation measures, including their feasibility or
implementation, although one mitigation measure has been clarified. The 2014 EIR included
mitigation measures to protect special status reptiles and amphibians, including pre-treatment
surveys and consultation with regulatory agencies, as appropriate. While the 2014 EIR identified
each of the special status amphibians and reptiles that the California Department of Fish and
Wildlife had listed at the time of certification, this Addendum includes the two newly listed
additional Species of Special Concern. These revisions are not a result of newly identified
adverse impacts and do not substantially affect the current IPM Program or other proposed
program modifications.
R-19-11 Page 8
In accordance with CEQA Guidelines section 15162(a), no new significant environmental
effects, and no substantial increase in the severity of previously identified significant effects,
would result from the project modifications. Moreover, the proposed minor changes would not
affect any of the mitigation measures, including their feasibility of implementation, contained
within the MMP. Therefore, the differences between the approved Project described in the 2014
EIR and the modification of the Program as currently proposed and described in the attached
Addendum are minor technical changes, and the Addendum, considered together with the 2014
EIR and MMP, addresses the potential environmental impacts of the project modifications and
provides sufficient environmental documentation. There is no requirement for the preparation of
a Supplemental or Subsequent EIR under the Guidelines (section 15162) because there have not
been substantial changes to the Project requiring major revision of the EIR; there have not been
substantial changes occurring with respect to the circumstances under which the project is
undertaken, and no new information of substantial importance has been discovered which would
require preparation of a Supplemental or Subsequent EIR.
As detailed above, the District concludes that the Project’s minor modifications will not have a
significant effect on the environment. The environmental analysis revealed no potentially
significant impacts for the discretionary items as described in the Addendum. The Addendum,
considered together with the 2014 EIR and MMP, addresses the potential environmental impacts
of the Project modifications, and there is no substantial increase in the severity of previously
identified significant impacts; therefore, no new mitigation measures are required.
NEXT STEPS
If approved, the District will file a Notice of Determination with the Santa Clara, San Mateo, and
Santa Cruz County Clerk Recorder’s Offices, which initiates the 30-day public notification
period. Staff will also file a Notice of Determination with the State Clearinghouse within five
(5) days of Board action. A copy of the EIR Addendum would be available for public review at
the District’s Administrative Office and a copy would be posted to the District’s website. In
addition, staff will implement the minor technical modifications to the Project. Staff will present
the 2018 Annual IPM Report to the Board in spring of 2019, anticipated June, 2019. In addition,
Natural Resource staff will continue to analyze new research as it becomes available on the
human and environmental health and effects as they relate to the implementation of the IPM
Program.
Attachment(s)
1. Executive Summary of the 2014 Final Environmental Impact Report and Mitigation
Monitoring Plan
2. Best Management Practices
3. Resolution adopting Addendum to the 2014 EIR
Responsible Department Head:
Kirk Lenington, Natural Resources
Prepared by:
Coty Sifuentes-Winter, Senior Resource Management Specialist, Natural Resources
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-1
2 EXECUTIVE SUMMARY
2.1 INTRODUCTION
Midpeninsula Regional Open Space District (District) proposes to implement an Integrated Pest
Management Program (IPMP) or “project” which would comprehensively direct management of all pests on
District properties. The project is intended to formalize and streamline guidelines and procedures for careful
management of pests throughout the District’s open space preserves (OSPs) while protecting natural
resources and public health. The project would be primarily a vegetation management program in wild lands;
however, it will also include some rodent and insect pest management strategies at District-owned
structures.
The EIR has been prepared in compliance with the California Environmental Quality Act (CEQA) and the State
CEQA Guidelines. CEQA requires that state and local government agencies consider the environmental
effects of projects over which they have discretionary authority before taking action on those projects. CEQA
requires that each public agency avoid or mitigate to less-than-significant levels, wherever feasible, the
significant environmental effects of projects it approves or implements. The purpose of an EIR, under the
provisions of CEQA, is “to identify the significant effects on the environment of a project, to identify
alternatives to the project, and to indicate the manner in which those significant effects can be mitigated or
avoided” (Public Resources Code [PRC] Section 21002.1[a]). If a project would result in significant and
unavoidable environmental impacts that cannot be feasibly mitigated to less-than-significant levels, the
project can still be approved, but the lead agency’s decision-maker (i.e., Board of Directors) must issue a
“statement of overriding considerations” explaining, in writing, the specific economic, social, or other
considerations that they believe make those significant effects acceptable (PRC Section 21002; California
Code of Regulations [CCR] Section 15093 of the State CEQA Guidelines).
2.1.1 Integrated Pest Management Program
The District proposes to implement a formal IPMP to comprehensively direct management of all pests on
District properties. IPM is a process for efficiently managing pests while protecting human health and
environmental quality. IPM is a long-term, science-based, decision-making system that uses a specific
methodology to manage damage from pests. IPM requires monitoring site conditions before, during, and after
treatment to determine if objectives are being met and if methods need to be revised. IPM requires that non-
chemical methods be considered in addition to chemical methods (i.e., pesticides, herbicides, insecticides). If
chemical methods are necessary to meet a pest control objective, the potential for harm to the public and
workers are carefully considered, as are effects on the environment, and then the least toxic and most
effective, efficient, and target-specific method is chosen. Treatment methods under the District’s proposed
IPMP are summarized below in Section 3.4 and described in detail in Chapters 6 through 10 of Appendix B).
The IPMP must be consistent with the District’s mission 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. Exhibit 3-1 illustrates the District’s proposed annual
IPM decision-making process which is based on following the more detailed, site-specific procedures in the
IPM Guidance Manual (Appendix B). The overall methodology of the IPMP includes correct identification of
the pest and understanding of its life cycle; determining and mapping the extent of the problem or
infestations; establishing the tolerance level for control actions; utilizing the least toxic suite of treatment
methods to control the pest at vulnerable stages of its life cycle; and the monitoring of pest populations and
effectiveness of treatment methods.
ATTACHMENT 1
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-2 Integrated Pest Management Program EIR
A new goal and policies related to IPM (Chapter 2) and an IPM Guidance Manual (Appendix B of this EIR) will
be considered by the Board of Directors for adoption. These documents provide a comprehensive IPM
approach to pest management that would be implemented throughout the District’s properties. In general,
the proposed IPM policies identify the District’s Board of Directors’ goals and direction for pest management,
and the Guidance Manual identifies the pests and the actions and strategies staff will use to control them.
2.1.2 IPM Guidance Manual
The IPM Guidance Manual is included in this EIR as Appendix B. The Guidance Manual identifies specific
pest management actions including: preventative and maintenance measures; damage assessment
procedures; tolerance levels and thresholds for action; and treatment options. Within the District, the
situations that trigger the need for pest control fall into five distinct management categories: (1) buildings;
(2) recreational facilities; (3) fuel managment areas; (4) rangelands and agriculture properties; and (5)
natural areas. Once adopted, the Guidance Manual is intended to have a ten-year planning timeframe and
would be updated as needed.
2.1.3 Previous Environmental Documentation
As a short term strategy, the District previously conducted CEQA review of a few dozen IPM-related projects
in priority natural areas to halt or minimize the spread of certain pest species where substantial progress
has been made towards eradication. This approach has enabled the District to avoid losing substantial
progress already made in protecting priority preserve resources by controlling invasive plants or pests until
the proposed District-wide IPM program, analyzed in this EIR, could be developed.
2.2 SUMMARY OF ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
This EIR has been prepared based on public scoping to identify potential environmental issues and extensive
environmental evaluation. Issues that were determined not to be significant are described in Chapter 1,
“Introduction.” By dismissing certain resources section for detailed evaluation in the EIR, this document uses
a focused approach to determine the potential environmental issues. These issues are discussed in Chapter
4, Environmental Setting, Environmental Impacts, and Mitigation Measures. Table 2-1, located at the end of
this chapter, provides a summary of the potential environmental impacts of the project, level of significance
before mitigation, recommended mitigation measures, and the level of significance after the application of
mitigation measures.
2.3 SUMMARY OF ALTERNATIVES
Because the project is a program intended to formalize and improve the consistency, comprehensiveness,
and efficiency of IPM on District lands, the alternatives analysis is tailored to variations in the program. As a
result the following three alternatives are evaluated:
No-Project Alternative; involves a case-by-case, individual evaluation of pest management issues on
District lands.
Early Detection and Rapid Response (EDRR) Alternative, dedicates additional resources to EDRR
strategies to identify and reduce new pest populations.
Pesticide Avoidance in Buildings Alternative would eliminate chemical control treatments in buildings.
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-3
2.3.1 Environmentally Superior Alternative
The EDRR Alternative would be environmentally superior to the project. It would meet all project objectives,
would result in the same environmental impacts as the project, and would lead to greater reductions in pest
populations on a potentially faster schedule than would occur with the project.
2.4 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS
Detailed mitigation measures are identified in Chapter 4 of the EIR that are intended to mitigate project
effects to the extent feasible. All of these mitigation measures are identified in Table 2-1. After
implementation of the proposed mitigation measures, all of the adverse effects associated with the project
would be reduced to a less-than-significant level. No significant and unavoidable impacts would occur with
implementation of the IPMP.
2.5 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
The State CEQA Guidelines require a discussion of the significant irreversible environmental changes that
could occur should the project be implemented. An example of significant irreversible environmental change
is the irreversible and irretrievable commitment of resources (i.e., the permanent loss of resources for future
or alternative purposes). Irreversible and irretrievable resources are those that cannot be recovered or
recycled or those that are consumed or reduced to unrecoverable forms. The project would result in the
irreversible and irretrievable commitment of energy and material resources during project implementation,
including the following:
removal of flammable vegetation and other wildland and forest litter, and
use of gasoline and lubricants for mechanical equipment.
The use of these nonrenewable resources is expected to account for a minimal portion of the State’s
resources and would not affect the availability of these resources for other needs within the region. Long-
term operational energy and natural resource consumption is expected to be minimal and would not exceed
the capacity of energy suppliers to meet local demand. IPM activities would be relatively minor in magnitude
and would not result in inefficient use of energy or natural resources. Contractors selected to implement IPM
strategies would use best available engineering techniques, design practices, and equipment operating
procedures.
2.6 SUMMARY OF CUMULATIVE IMPACTS
The geographic area considered in the analysis of cumulative impacts is generally limited to Santa Clara
County, San Mateo County, and Santa Cruz County. However, within those counties, the geographic area that
could be affected by the project varies depending upon the resource being considered. As described in
Chapter 5 of this EIR, in addition to the District, there are a number of other agencies, special districts, and
other organizations located within cumulative impact study area that acquire and manage open space lands.
These parks and open space managers direct management of pests on their lands using similar treatment
options in restoration and maintenance activities.
As described in Section 1.3 of this EIR, the analysis conducted for this document determined that the project
would result in certain effects found not to be significant, and therefore, those effects would not need
detailed discussion. Effects on resource areas found not to be significant, for which the IPM program would
make no contribution or a less than considerable contribution to significant cumulative impacts are
agriculture and forestry, air quality and climate change, geology and soils, land use, mineral resources,
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-4 Integrated Pest Management Program EIR
noise, population and housing, public services and utilities, and traffic and transportation. The EIR examines
the potential for the project to contribute to significant cumulative impacts related to aesthetic resources,
biological resources, cultural resources, hazards and hazardous materials, and hydrology and water quality.
The cumulative impact analysis presented in Chapter 5 concludes that with the implementation of the best
management practices (BMPs) included in the project, and implementation of biological and cultural
resource mitigation measures, the project would not make a considerable contribution to any identified
significant cumulative impact. Additionally, the project would not contribute to an existing cumulative
condition that would result in a significant cumulative impact. Biological resources mitigation measures 4.2-
1a through 4.2-1d include provisions to reduce, avoid, and/or compensate for impacts in accordance with
the requirements of ESA and CESA and other regulatory programs that protect habitats and special-status
species. Cultural resources mitigation measures 4.3-1 an 4.3-2 include provisions for a built environment
survey prior to implementation of building retrofits or barriers, for structures of historic-age (50 years); and
require cessation of ground disturbing activities if human remains are encountered. Therefore, the project
would result in less-than-significant cumulative impacts.
2.7 GROWTH INDUCING IMPACTS
2.7.1 State CEQA Guidelines
State CEQA Guidelines Section 2100(b)(5) specifies that growth-inducing impacts of a project must be
addressed in an EIR. Section 15126(d) states that a proposed project is growth-inducing if it could “foster
economic or population growth, or the construction of additional housing, either directly or indirectly, in the
surrounding environment.” Included in the definition are projects that would remove obstacles to population
growth. Examples of growth-inducing actions include developing water, wastewater, fire, or other types of
services in previously unserved areas; extending transportation routes into previously undeveloped areas;
and establishing major new employment opportunities. The following is a summary of the direct and indirect
growth-inducing impacts that could result with implementation of the IPMP.
2.7.2 Growth Inducing Impacts of the Project
The District employs approximately 100 full-time staff in its Administrative Services, Operations, Planning,
Public Affairs, Natural Resources and Real Property departments. Approximately 20 part-time and seasonal
employees are also employed by the District. No construction activities or residences are proposed as part of
the project. Although the increase in population in the region would increase trail use demand over time, this
increase in users would not be attributed to the IPMP, considering that no new District facilities would be
provided. The proposed IPMP would not induce population growth because it would not involve any
alteration of existing land uses or the introduction of new land uses associated with population increases
(e.g., housing, employment centers). Moreover, the project would not involve new infrastructure or services
that would draw new residents to the area. Because the project would not alter existing land uses, it would
not displace housing units or people. Therefore, implementation of the IPMP would not cause growth
inducing impacts.
2.8 AREAS OF CONTROVERSY AND ISSUES TO BE RESOLVED
Section 15123(b) of the State CEQA Guidelines requires the summary section of an EIR to include “areas of
controversy known to the lead agency” and issues to be resolved. No letters were received on the NOP, and
therefore there are currently no areas of controversy and issues to be resolved.
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-5
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
4.1 Aesthetics and Views
4.1-1 Adverse effects on scenic vistas or substantial degradation of existing
visual character or quality. Manual and mechanical IPM treatments for
recreational facilities and fuel management would affect limited areas
adjacent to trails, roads, and other recreational facilities and adjacent to
structures. These treated areas would not be dominant in panoramic
views that provide scenic vistas. Mechanical IPM treatments for
vegetation management on rangelands, agricultural lands, and natural
lands have the potential to affect larger areas yet would be subject to
best management practice (BMP) 28 that requires erosion control be
applied to areas that are susceptible to runoff or erosion, and this would
likewise prevent degradation of visual resources. Chemical IPM
treatments around buildings and recreational facilities would be limited in
area; treatments on rangelands, agricultural areas, and natural lands
would be selectively applied to target species. Therefore, IPM chemical
treatments would not result in visual changes over large areas that would
be dominant in panoramic views and scenic vistas.
Less-than--
significant
No mitigation measures are required. Less-than-
significant
4.1-2 Impacts to scenic resources within a state scenic highway. Manual and
mechanical IPM treatments for pest control and fire prevention would
affect limited areas adjacent to structures, along trails, and at recreation
facilities. These treated areas would not be dominant in views from state
scenic highways. Manual and mechanical treatments for invasive plants
on rangelands, agricultural lands, and natural lands may affect broader
areas and some may occur near or be visible from scenic highways.
However, those mechanical treatment methods that have the potential to
affect large areas would be subject to BMP 28 that requires erosion
control be applied to areas that are susceptible to runoff or erosion, which
would prevent degradation of visual resources. Chemical treatment
options around buildings and recreational facilities would be limited in
area; treatments on rangelands, agricultural areas, and natural lands
would be selectively applied to target pest species. The treatment options
would restore scenic integrity of working and natural landscapes. These
activities, which are limited in scale, are currently occurring throughout
District lands. Under the IPMP these activities would continue to be
implemented in a similar manner and at a similar scale to control pests.
Less-than--
significant
No mitigation measures are required Less-than--
significant
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-6 Integrated Pest Management Program EIR
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
Therefore, implementation of the proposed IPM program would not cause
a substantial adverse effect on scenic resources within a state scenic
highway.
4.2 Biological Resources
4.2-1 Impacts to special-status wildlife species. Manual, mechanical, or
chemical treatments could result in direct mortality of special-status
amphibian, reptile or fish species, or impacts to their federally designated
critical habitat. Manual or mechanical treatment of host plants or
chemical application of pyrethrin could result in direct mortality of special-
status invertebrates. Manual treatments could result in direct mortality
through trapping within structures and loss of occupied roosting habitat
for special-status bats. As a result the project would result in potentially
significant impacts to special-status amphibian and reptile species
(California red-legged frog, foothill yellow-legged frog, northern western
pond turtle, San Francisco garter snake, California tiger salamander),
special-status fish (tidewater goby, central California coast steelhead,
central California coast coho salmon), special-status invertebrate species
(bay checkerspot butterfly, Callippe silverspot butterfly, Smith’s blue
butterfly, and Zayante band-winged grasshopper), and special-status bat
species (Townsend’s big-eared bat, western red bat, fringed myotis, hoary
bat, long-eared myotis, long-legged myotis, and pallid bat, San Francisco
dusky-footed woodrat and Santa Cruz kangaroo rat).
Potentially
significant
Mitigation Measure 4.2-1a: Mitigation for impacts to special-status amphibian and
reptile species (California red-legged frog, foothill yellow-legged frog, northern
western pond turtle, San Francisco gartersnake, California tiger salamander).
Prior to conducting any mechanical or chemical IPM treatments in an area
that is both federally designated critical habitat and suitable aquatic
habitat for California red-legged frog, foothill yellow-legged frog, northern
western pond turtle, San Francisco gartersnake, or California tiger
salamander, the District will consult with the USFWS and CDFW as
appropriate pursuant to ESA/CESA. Appropriate measures will be
developed in consultation with USFWS and CDFW to ensure there is no
loss of critical habitat for these species, or that unavoidable loss of critical
habitat will be replaced through habitat enhancement or restoration. Such
measures may include may include avoidance of breeding habitat, limiting
activities to manual removal of vegetation, conducting activities outside
the breeding season, or relocation and mitigation.
Prior to conducting any mechanical or chemical IPM treatments within 15
feet of occupied habitat for California red-legged frog, foothill yellow-
legged frog, northern western pond turtle, San Francisco gartersnake, or
California tiger salamander, the District will consult with USFWS and
CDFW. Appropriate measures will be developed in consultation with
USFWS and CDFW to ensure there is no take of these species, or that
unavoidable take is fully compensated for through for through habitat
enhancement or restoration activities, or purchase of mitigation credits.
Shooting, trapping, and gigging of aquatic species will be conducted only
by a qualified biologist with experience in the identification of frog and
turtle species. Inadvertently trapped California red-legged frogs, foothill
yellow-legged frogs or northern western pond turtles will be released
immediately upon discovery.
If permanent loss of federally designated critical habitat cannot be
avoided, compensation will be provided through protection and
enhancement of habitat within the District open space, purchase of off-
site mitigation credits, and/or contribution to regional conservation and
recovery efforts for the species as determined in consultation with the
Less-than-
significant
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-7
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
USFWS and CDFW.
Mitigation Measure 4.2-1b. Mitigation for impacts to special-status fish (tidewater
goby, central California coast coho salmon, central California coast steelhead).
All mechanical or chemical IPM treatments will be avoided within
estuarine marshes, lagoons, or adjacent stream reaches that provide
suitable habitat for tidewater goby. If manual, mechanical or chemical IPM
treatments are required in areas where suitable habitat for tidewater goby
is present, the District will conduct protocol level surveys for tidewater
goby before implementation of IPM such treatments. If tidewater goby is
identified during these surveys only manual IPM treatments will be
implemented. Manual IPM treatments will not occur during the tidewater
goby spawning period (spring through summer). Prior to conducting any
mechanical or chemical IPM treatments in an area that is federally
designated critical habitat for central California coast coho salmon or
central California coast steelhead, the District will consult with the
USFWS, NMFS and CDFW as appropriate pursuant to ESA/CESA.
Prior to conducting any mechanical or chemical IPM treatments in
occupied habitat of central California coast coho salmon or central
California coast steelhead, the District will consult with USFWS, NMFS,
and CDFW.
If permanent loss of federally designated, critical habitat, or occupied
habitat outside of federally designated critical habitat, cannot be avoided,
compensation will be provided through protection and enhancement of
habitat within the District open space, purchase of offsite mitigation
credits, and/or contribution to regional conservation and recovery efforts
for the species as determined in consultation with the USFWS, NMFS, and
CDFW.
Mitigation Measure 4.2-1c: Mitigation for impacts to special-status invertebrates.
To avoid impacts to special-status invertebrates from pyrethrin spray, all
District staff and contractors using pyrethrin spray will be trained in the
identification of problem wasps and special-status invertebrates to ensure
that proper species are being targeted. If special-status invertebrates are
observed, pyrethrin treatment will not be used in these areas.
Prior to conducting any manual, mechanical, or chemical IPM treatment in
serpentine habitats surveys will be conducted for dwarf plantain (Plantago
erecta), purple owl's clover (Castilleja densiflora), and exserted paintbrush
(Castilleja exserta) during the appropriate blooming period and host
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-8 Integrated Pest Management Program EIR
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
plants containing eggs, larva, or pupa of bay checkerspot butterfly will not
be treated.
Prior to conducting any manual, mechanical, or chemical IPM treatment in
suitable dune habitats, surveys will be conducted for host buckwheats
(Eriogonum latifolium and Eriogonum parvifolium) during the appropriate
blooming period, and host plants containing eggs, larva, or pupa of
Smith's blue butterfly will not be treated.
Prior to conducting any manual, mechanical, or chemical IPM treatment in
Zayante sandhills, surveys will be conducted for Zayante band-winged
grasshopper and they will be avoided by treatments.
Mitigation Measure 4.2-1d: Mitigation for impacts to special-status bats.
To mitigate for IPM activities to remove roosting bats in buildings:
If removal of bats is necessary in a human-occupied building or prior
to demolition or major renovation of a building in which signs of bats
are evident, a qualified biologist will conduct surveys for roosting
bats. Surveys will consist of daytime pedestrian surveys to look for
visual signs of bats (e.g., guano), and if determined necessary,
evening emergence surveys to note the presence or absence of
bats. If evidence of bat roosting is found, the number and species of
roosting bats will be determined. If no evidence of bat roosts is
found, then no further study will be required.
When bat roosting sites are located in buildings, exclusion of bats
from the building will occur outside of the April through August
nursery season.
If roosts of special-status bats are determined to be present and
must be removed, a bat exclusion plan will be prepared and
submitted to CDFW. The exclusion plan will describe the method of
exclusion, which may include the use of one-way doors at roost
entrances (bats may leave but not re-enter), or sealing roost
entrances when the site can be confirmed by a bat expert to contain
no bats. No bats will be excluded until the plan is approved by CDFW
and alternative roosting habitat is available. The bats will be
excluded from the roosting site before the site is closed.
To mitigate for removal of large trees during the April through August
nursery season to tree roosting bats:
Avoid removal of trees greater than sixteen inches dbh during the
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-9
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
April through August nursery season when possible.
If removal of trees greater than sixteen inches dbh during the April
through August nursery season cannot be avoided, a qualified
biologist will conduct surveys for roosting bats where suitable large
trees are to be removed. Surveys will consist of daytime pedestrian
surveys to look for visual signs of bats (e.g., guano), and if
determined necessary, evening emergence surveys to note the
presence or absence of bats. If evidence of roosting bats is found,
the number and species of roosting bats will be determined. If no
evidence of bat roosts is found, then no further study will be
required.
If bat roosting sites are located in trees to be removed, such
removal will occur outside of the April through August nursery
season if possible.
If roosts of special-status bats are determined to be present
and must be removed during the April through August nursery
season, a bat exclusion plan shall be prepared and submitted
to CDFW. The exclusion plan will describe the method of
exclusion, which may include the use of one-way doors at roost
entrances (bats may leave but not re-enter), or sealing roost
entrances when the site can be confirmed by a bat expert to
contain no bats. No bats will be excluded until the plan is
approved by CDFW and alternative roosting habitat is available.
The bats will be excluded from the roosting site before the site
is closed.
Mitigation Measure 4.2-1e: Mitigation for Impacts to San Francisco dusky-footed
woodrat and Santa Cruz kangaroo rat.
The District will consult with CDFW in areas where IPM treatments require
removal of San Francisco dusky-footed woodrats occupying buildings or
require removal of woodrat nests located within 100 feet of buildings.
Consultation will occur prior to removal of woodrats or their nests.
Management actions will be determined in consultation with CDFW and
may include the live capture and relocation of woodrats to suitable
adjacent habitats, and removal of nesting sites within buildings. Nest
middens will be dismantled by hand under the supervision of a biologist. If
young are encountered during the dismantling process, the material will
be placed back on the nest, and the nest will remain undisturbed for two
to three weeks in order to give the young enough time to mature and
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-10 Integrated Pest Management Program EIR
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
leave the nest on their own accord. After two to three weeks, the empty
nest can be dismantled. Nest material will be moved to suitable adjacent
areas within the mixed oak woodland that will not be disturbed. As
woodrats exhibit high site fidelity, buildings with previous woodrat nests
will be regularly inspected for potential intrusion to prevent infestation.
The District will consult with CDFW on management in areas where Santa Cruz
kangaroo rat is found occupying buildings, or nests located within 100 feet of
buildings must be removed, prior to nest removal occurring. Management
actions will be determined in consultation with agencies.
4.2-2 Impacts to riparian habitat or other sensitive natural communities.
Manual and mechanical treatment methods used for pest control and fire
prevention would affect limited areas of sensitive habitats where they
occur adjacent to structures, along trails, and at recreation facilities.
Manual and mechanical and methods used for invasive plants and other
pests on rangelands, agricultural lands, and natural lands would improve
habitat function and ensure continued success of sensitive natural
communities. Because the District restores natural conditions of riparian
habitat and other sensitive natural communities to ensure no loss of
habitat function, no net loss of sensitive habitat function would occur.
Less-than-
significant
No mitigation measures are required Less-than-
significant
4.2-3 Impacts to federally protected wetlands. Application of herbicides
adjacent to or within wetlands or other waters, the discharge of dredge or
fill during manual and mechanical activities, and the conversion of
wetland habitats from stock ponds to ephemeral wetlands may alter the
chemical and biological integrity of wetland and other waters, and result
in a change to wetland type, function, and overall acreage.
Potentially
significant
Mitigation Measure 4.2-3: Mitigation for impacts to federally protected wetlands.
When seeking a change in habitat type from stock pond to ephemeral wetland to
control bull frogs and non-native fishes, the District will implement the following
measures to compensate for the loss of wetlands and other waters of the United
States:
The District will prepare a wetland delineation and will determine the
exact acreage of waters of the United States and waters of the state that
would be affected as a result of project implementation.
The District will replace on a "no net loss" basis (minimum 1:1 ratio) (in
accordance with USACE and/or RWQCB) the acreage and function of all
wetlands and other waters that would be permanently removed, lost, or
degraded as a result of project implementation. Wetland habitat will be
replaced at an acreage and location agreeable to USACE and the RWQCB
and as determined during the Section 401 and Section 404 permitting
processes. Compensatory mitigation will be approved by USACE and
RWQCB.
Less-than-
significant
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-11
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
The District will obtain a USACE Section 404 Permit and RWQCB Section
401 certification before fill or dredge of wetlands or water of the United
States. The District will implement all permit conditions.
When conducting manual and mechanical treatments within waters, the District will
implement the following measures to compensate for the loss of wetlands and other
waters of the United States:
The District will estimate the quantity of dredge or fill material that may be
discharged incidental to these activities and coordinate permitting with
the USACE, including application for coverage under the Nationwide
Permit program as appropriate.
If activities will result in permanent impacts to waters, the District will
replace or restore on a "no net loss" basis (minimum 1:1 ratio) (in
accordance with USACE and/or RWQCB) the acreage and function of all
wetlands and other waters that would be removed, lost, or degraded as a
result of project implementation. Wetland habitat will be replaced at an
acreage and location agreeable to USACE and the RWQCB and as
determined during the Section 401 and Section 404 permitting
processes. Compensatory mitigation will be approved by USACE and
RWQCB.
When conducting chemical treatments within or with potential to affect waters and
with the potential to discharge directly or indirectly to waters of the United States,
the District will implement the following measures to compensate for the loss of
wetlands and other waters of the United States:
The District must consult with the San Francisco Bay RWQCB which may
require the District to submit a Notice of Intent to Discharge, develop an
Aquatic Pesticide Application Plan. The permit includes design and
operational BMPs that must be implemented to reduce the level of
contaminated runoff, including monitoring and reporting to document and
minimize pollutant discharge and ensure pollutants do not adversely affect
waters. If pollutants are found to be exceeding water quality standards
application must stop, or additional BMPs must be developed to bring the
activities into compliance.
4.2-4 Interfere with 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. Manual, mechanical,
and chemical IPM activities would not impede wildlife use of corridors or
Less-than-
significant
No mitigation measures are required Less-than-
significant
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-12 Integrated Pest Management Program EIR
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
interfere with wildlife movement in the region because no loss of habitat
would occur and no barriers would be constructed. Therefore, proposed
IPM activities would not conflict with any local policies or ordinances.
4.2-5 Conflict with local policies, ordinances protecting biological resources.
The manual, mechanical, and chemical IPM activities would be consistent
with and would further implementation of the District’s goals and policies
adopted for the protection and restoration of the natural environment.
Less-than-
significant
No mitigation measures are required Less-than-
significant
4.2-6 Conflict with the provisions of an adopted habitat conservation plan,
natural community conservation plan, or other approved local, regional,
or state habitat conservation plan. The Santa Clara Valley Habitat Plan
covers a small area within the District. The area is in an urban area where
IPM activities would not be applied. Therefore, the project would not
conflict with an adopted habitat conservation plan (HCP), natural
community conservation plan (NCCP), or other HCP.
Less-than-
significant
No mitigation measures are required Less-than-
significant
4.3 Cultural Resources
4.3-1 Change the significance of an historic structure. The project includes
manual and mechanical IPM activities for buildings that could change the
significance of an historical resource by incorporating barriers or building
retrofits to buildings or structures that have not been evaluated for
historical significance.
Potentially
significant
Mitigation Measure 4.3-1: Built-environment survey.
Prior to implementation of building retrofits or barriers that are visible on the exterior
and not consistent with the vernacular nature of rural buildings, historic-age (50
years) structures will be surveyed by an architectural historian who meets the
Secretary of the Interior’s Standards. The structure will be evaluated for eligibility for
listing on the California Register of Historic Resources. If structures are determined
to be eligible for the California Register of Historic Resources, building retrofits or
barriers will follow the Secretary of the Interior’s Standards for the Treatment of
Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and
Reconstructing Historic Buildings, or the Secretary of the Interior’s Standards for
Rehabilitation and Guidelines for Rehabilitating Historic Buildings.
Less-than-
significant
4.3-2 Cause a substantial change in the significance of an archaeological
resource. It is unlikely that unknown archaeological resources would be
disturbed by earth-disturbing activities associated with the project
because of their limited area and techniques which are limited to shallow
soil disturbance. BMP 26 requires that District staff at each site receive
training in the recognition of sensitive cultural resources and that in the
event of a find, work in the area is halted until a qualified archaeologist
can evaluate the significance of the find. Because appropriate BMP
Less-than-
significant
No mitigation measures are required Less-than-
significant
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-13
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
measures are in place to recognize and avoid cultural resources at
selected IPM sites.
4.3-3 Disturb human remains. It is unlikely that unknown human remains
would be unearthed by earth-disturbing activities associated with pest
management activities because of their limited area and techniques
which are limited to shallow soil disturbance. Nevertheless, the potential
exists for previously undiscovered human remains to be discovered when
soils are disturbed.
Potentially
significant
Mitigation Measure 4.3-3: Halt ground-disturbing activity.
If human remains are encountered, all work within 100 feet of the remains will
cease immediately. The District will contact the appropriate county coroner (San
Mateo County, Santa Clara County, or Santa Cruz County) to evaluate the remains,
and follow the procedures and protocols set forth in §15064.5(e) of the CEQA
Guidelines. No further disturbance of the site or any nearby area reasonably
suspected to overlie adjacent remains will occur until the County Coroner has made
a determination of origin and disposition, which will be made within two working
days from the time the Coroner is notified of the discovery, pursuant to State Health
and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. If
the remains are determined to be Native American, the Coroner will notify the Native
American Heritage Commission (NAHC) within 24 hours, which will determine and
notify the Most Likely Descendant (MLD). The MLD may recommend within 48 hours
of their notification by the NAHC the means of treating or disposing of, with
appropriate dignity, the human remains and grave goods. In the event of difficulty
locating a MLD or failure of the MLD to make a timely recommendation, the human
remains and grave goods shall be reburied with appropriate dignity on the property
in a location not subject to further subsurface disturbance
Less-than-
significant
4.3-4 Destroy a unique paleontological resource. It is unlikely that
paleontological resources would be disturbed by earth-disturbing
activities associated with the IPM because of their limited area and
techniques which are limited to shallow soil disturbance. Archaeological
resources typically occur at significant depths (i.e., greater than 5 feet).
Nonetheless, BMP 26 requires that District staff at each site receive
training in the recognition of sensitive cultural resources and that in the
event of a find, work in the area is halted until a qualified archaeologist
can evaluate the significance of the find.
Less-than-
significant
No mitigation measures are required Less-than-
significant
4.4 Hydrology and Water Quality
4.4-1 Violate water quality standards or waste discharge requirements. Manual
control methods used for pests in buildings, recreational facilities, fuel
management areas, rangeland and agricultural fields, and natural areas
would not result in discharge of sediments into aquatic areas. Erosion
control measures required by BMP 28 would be implemented on sites
Less-than--
significant
No mitigation measures are required Less-than--
significant
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-14 Integrated Pest Management Program EIR
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
with loose or unstable soils, steep slopes (greater than 30 percent),
where a large percentage of the groundcover would be removed, or near
aquatic features that could be adversely affected by an influx of
sediment.
Chemical control options, when used, would be implemented consistent
with Pest Control Recommendations prepared annually by a licensed Pest
Control Advisor, would be conducted in accordance with proposed BMPs.
BMPs would require that chemical control operations be conducted under
the supervision of a person holding a Qualified Applicator License or
Qualified Applicator Certificate for pesticides; require all storage, loading
and mixing of herbicides be set back at least 300 feet from any aquatic
feature and all mixing and transferring occur within a contained area;
require that application cease when weather parameters exceed label
specifications, when wind at site of application exceeds seven miles per
hour (MPH), or when precipitation (rain) occurs or is forecasted with
greater than a 40 percent probability in the next 24-hour period; and
Therefore, implementation of the IPM program would not result in
violation of water quality standards or waste discharge requirements.
4.4-2 Result in on- or off-site flooding. The project does not involve earthmoving
or recontouring of land. Ground disturbance would be limited to mowing,
discing, and weed or brush pulling. No manual or chemical treatment
options for any of the treatment categories would result in the alteration
of drainage patterns or stream courses.
If needed, placement of ground cover, or seeding of native perennial
grasses and pasture grasses would occur to stabilize exposed soils and to
reduce the potential for increased runoff as a result of this project as
required under BMP 28. With implementation of this BMP, no significant
erosion or siltation impacts would occur. The project would not cause an
increase in runoff that would result in flooding.
Less-than--
significant
No mitigation measures are required Less-than--
significant
4.5 Hazards, Hazardous Material, and Public Health
4.5-1 Expose the public or environment to hazardous materials. Manual,
mechanical, and chemical treatment options associated with the IPMP
would result in activities that could require the transportation, use, and
storage of various pesticides (see Table 4.5-2 and 4.5-3) and other
hazardous materials (e.g., fuel, paint, and other household hazardous
Less-than--
significant
No mitigation measures are required Less-than--
significant
Ascent Environmental Executive Summary
Midpeninsula Regional Open Space District
Integrated Pest Management Program EIR 2-15
Table 2-1 Summary of Impacts and Mitigation Measures
Impact No. Impact Description
Level of
Significance
Before Mitigation
Mitigation Measure
Level of
Significance
After Mitigation
chemicals). Existing measures and regulatory requirements currently in
place to address spills and accidents would be sufficient for the IPMP
such that the project would not result in adverse exposure conditions to
hazardous materials. The District complies with all relevant regulatory
requirements pertaining to the handling of hazardous materials including
pesticides. Further, the District would implement several BMPs (BMPs 1
through 10, 19, 20, Table 3-4) to minimize the potential for unwanted
adverse impacts to non-target species (i.e., humans, animals, and
special-status species). Thus, treatment options, manual, mechanical or
chemical, that would require the transportation, use, and storage of
hazardous materials associated with the IPMP would not result in the
exposure of the public or environment to adverse conditions associated
with the use of these materials,
4.5-2 Wildland fire hazard. Manual, mechanical, and chemical treatment
options associated with the IPMP would result in activities that would
require the transportation, use, and storage of various pesticides (see
Table 4.5-2 and 4.5-3) and transportation and use of mechanical
equipment (e.g., mowers, chippers, chainsaws, Jawz, etc.). Heat or sparks
from equipment activity could ignite dry vegetation and cause fire.
Further, handling of flammable materials including pesticides could
increase fire ignition hazards. However, the District implements strict
practices for operation of this equipment and appropriately trains staff
and volunteers in fire suppression techniques in the event operation of
equipment results in inadvertent fire ignition. Appropriate fire suppression
equipment (e.g., extinguishers) would be provided at the work sites and
the project would result in an overall reduction in fuel loads through the
removal of pest species from District lands.
Less-than--
significant
No mitigation measures are required Less-than--
significant
Executive Summary Ascent Environmental
Midpeninsula Regional Open Space District
2-16 Integrated Pest Management Program EIR
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Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
20 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
1
All pesticide use shall be implemented consistent with written Pest Control Recommendations prepared
annually by a licensed Pest Control Advisoer. The Pest Control Adviser shall ensure that all pesticide
applications are performed at the time of year and phenological window for maximum effectiveness, thereby
increasing treatment efficacy and reducing the need for follow-up applications.
2 Surfactants and other A
Recommendations.
3
Applicators shall follow all pesticide label requirements and refer to all other BMPs regarding mandatory
measures to protect sensitive resources and employee and public health during pesticide application. All
District field crew who perform herbicide treatments shall have specialized experience and training in pesticide
safety, IPM principles, and special status species.
4
Pesticide applicators shall have or work under the direction of a person with a Qualified Applicator License
(QAL) or Qualified Applicator Certificate (QAC). As appropriate, the District shall implement QAC certification
requirements for additional field staff to enhance field crew training. Contractors and grazing and agricultural
tenants may apply approved pesticides herbicides after review and approval by the District and under the
direction of QAL/QAC field supervisors. After review and approval by the District and under the direction of
QAL/QAC, contractors may apply approved fungicides to District preserves for the research and control of
Sudden Oak Death (SOD). As needed for the control of mosquitos, cattle grazing rangers may apply District-
approved bacterial pathogens to water troughs in District preserves. Employees, contractors and tenants may
install approved ant and roach bait stations inside buildings in tamper-proof containers without review by a
QAL/QAC. Tenants may not use rodenticides; only qualified District staff or District contractors may use
approved rodenticides and these should only be used in the event of an urgent human health issue, in a
manner consistent with the product label, and in anchored, tamper-proof containers inside buildings.
5
All storage, loading and mixing of pesticides shall be set back at least 300 feet from any aquatic feature or
special-status species or their habitat or sensitive natural communities. Applicators shall use an air gap or anti-
siphon device to prevent backflow while loading. All mixing and transferring shall occur within a contained area.
Any transfer or mixing on the ground shall be within containment pans or over protective tarps and away from
drain inlets, culverts, wells, areas with porous or erosion-prone soil, or other features that may allow for runoff.
6
As deemed necessary by the Pest Control Adviser, QAL, or QAC, Aappropriate, non-toxic colorants or dyes shall
be added to the herbicide mixture to determine treated areas and prevent over-spraying, particularly in public
areas.
7
Application Requirements - The following general application parameters shall be employed during herbicide
pesticide application:
Application shall cease when weather parameters exceed label specifications, when wind at site of
application exceeds 7 miles per hour (MPH), or when precipitation (rain) occurs or is forecasted with
greater than a 40 percent probability in the next 24-hour period to prevent sediment and herbicides
from entering the loss of efficacy and lessen the potential for pesticides to enter surface water via
surface runoff;
All restrictions and limitations, including those on irrigation, cultivation, re-entry, etc., as described on
the pesticide product label shall be followed for sites treated with pesticides;
Spray nozzles shall be configured to produce a relatively large droplet size;
Low nozzle pressures (30-70 pounds per square inch [PSI]) shall be observed;
Spray nozzles shall be kept within 24 inches of vegetation during spraying;
Application equipment shall be calibrated periodically per manufacturer specifications or frequently
enough such that equipment is applying pesticides according to label directions;
Drift and overspray avoidance measures shall be used to prevent drift in all locations. Particular
attention shall be paid to areas where target weeds and pests are in proximity to special-status species
or their habitat. Such measures can consist of, but would not be limited to the use of plastic shields
around target weeds and pests and adjusting the spray nozzles of application equipment to limit the
spray area selecting and using appropriate spray nozzles and pressures. Spray areas may also be
limited by using application methods such as spot treatments and thin line treatments of one-inch wide
or less.
ATTACHMENT 2
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 21
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
Due to the potential presence of temperature inversion layers, no spraying shall be conducted on
8
Notification of Pesticide Application Signs shall be posted notifying the public, employees, and contractors of
signal word, product name,
signal word, and manufacturer, active ingredient,; and EPA registration number; target pest; preserve name;
treatment location in preserve; date and time of application; date which notification sign may be removed; and
contact person with telephone number. Signs shall generally be posted 24 hours before the start of treatment
and notification shall remain in place for 72 hours after treatment ceases. In no event shall a sign be in place
longer than 14 days without dates being updated. See the IPM Guidance Manual for details on posting
locations, posting for pesticide use in buildings and for exceptions.
9
Disposal of Pesticide Containers Disposal Cleanup of all herbicide pesticide and adjuvant containers shall
follow the product label and local waste disposal regulations. This generally consists of be triple rinsing with
clean water at an approved site and the rinsate shall be disposed of by placing it in adding the rinsate to the
batch tank for application. Used containers shall be punctured on the top and bottom to render them unusable,
wed. Disposal of non-recyclable containers shall be at legal dumpsites.
Equipment shall not be cleaned and personnel shall not bathe in a manner that allows contaminated water to
directly enter any body of water within the treatment areas or adjacent watersheds. Disposal of all pesticide
containers shall follow label requirements and local waste disposal regulations.
10
All appropriate laws and regulations pertaining to the use of pesticides and safety standards for employees and
the public, as governed by the U.S. Environmental Protection Agency, the California Department of Pesticide
Regulation, and local jurisdictions shall be followed. All applications shall adhere to label directions for
application rates and methods, storage, transportation, mixing, and container disposal. All contracted
applicators shall be appropriately licensed by the state. District staff shall coordinate with the County
Agricultural Commissioners, and all required licenses and permits shall be obtained prior to pesticide
application.
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.
12 All staff, contractors, and volunteers shall be properly trained to prevent spreading weeds and pests to other
sites.
13 District staff shall appropriately maintain facilities where tools, equipment, and vehicles are stored free from
invasive plants.
14 District 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.
15 Suitable onsite disposal areas shall be identified to prevent the spread of weed seeds.
16
Invasive plant material shall be rendered nonviable when being retained onsite. Staff shall desiccate or
decompose plant material until it is nonviable (partially decomposed, very slimy, or brittle). Depending on the
type of plant, disposed plant material can be left out in the open as long as roots are not in contact with moist
soil, or can be covered with a tarp to prevent material from blowing or washing away.
17 District staff shall monitor all sites where invasive plant material is disposed on-site and treat any newly
emerged invasive plants.
18
When transporting invasive plant material off-site for disposal, the plant material shall be contained in enclosed
bins, heavy-duty bags, or a securely covered truck bed. All vehicles used to transport invasive plant material
shall be cleaned after each use.
19
Aquatic Areas Shortly before treatment, Aa District-approved qualified biologist or other District-approved
personnel shall survey allthe treatment sites prior to work to determine whether any aquatic features are
located onsite. In addition, oOn a repeating basis, grassland treatment sites shall be surveyed once every five
years and brushy and wooded sites shall be surveyed by a District-approved biologist once every five years.
Brush removal on rangelands will require biological surveys before work is conducted in any year. Aquatic
features are defined as any natural or manmade lake, pond, river, creek, drainage way, ditch, spring, saturated
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
22 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
soils, or similar feature that holds water at the time of treatment or typically becomes inundated during winter
rains. Treatment sites are defined as areas where IPM activity, including manual, mechanical, and chemical
treatment, is expected to occur. If during the survey it is found that aquatic features are present within 15 feet
of the proposed treatment area, the District shall either eliminate all treatment activities within 15 feet of the
aquatic feature from the project (i.e. do not implement treatment actions in those areas) or if the District
chooses to continue treatment actions in these areas, it shall use pesticides and adjuvants labeled for aquatic
use and follow the requirements of the mitigation measure for special-status wildlife species and the CDFW
Streambed Alteration Agreement.
20
Application of herbicides pesticides shall be conducted in accordance with the California Red-Legged Frog
Injunction (Center For Biological Diversity v. U.S. Environmental Protection Agency (2006) Case No.: 02-1580-
JSW) in known or potential California red-legged frog habitat specifically by: not applying specified pesticides
within 15 feet of aquatic features (including areas that are wet at time of spraying or areas that are dry at time
of spraying but subsequently might be wet during the next winter season); utilizing only spot-spraying
techniques and equipment by a certified applicator or person working under the direct supervision of a certified
applicator; and not spraying during precipitation or if precipitation is forecast to occur within 24 hours before or
after the proposed application. Preserves in which these precautions must be undertaken are: Miramontes
Ridge, Purisima Creek Redwoods, El Corte de Madera, La Honda Creek, Picchetti Ranch, Russian Ridge, Sierra
Azul, Tunitas Creek, Skyline Ridge, Rancho San Antonio, Monte Bello and Coal Creek OSPs and Toto Ranch.
21
A District-approved biologist shall survey all selected treatment sites prior to 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 District-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 District 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.
22
Nesting Birds - For all IPM activities that could result in potential noise and other land disturbances that could
affect nesting birds (e.g., tree removal, mowing during nesting season, mastication, brush removal on
rangelands), treatment sites shall be surveyed within two weeks prior to initiating activity to evaluate the
potential for nesting birds. Tree removal will be limited, whenever feasible, based on the presence or absence
of nesting birds. For all other treatments, if birds exhibiting nesting behavior are found within the treatment
sites during the bird nesting season: March 15 August 30 for smaller bird species such as passerines and
February 15 - August 30 for raptors, impacts on nesting birds will be avoided by the establishment of
appropriate buffers around active nests. The distance of the protective buffers surrounding each active nest
site are: 500 1,000 feet for large raptors such as buteos, 250 500 feet for small raptors such as accipiters,
and 250 feet for passerines. The size of the buffer may be adjusted by a District biologist in consultation with
CDFW and USFWS depending on site specific conditions. Monitoring of the nest by a District biologist during
and after treatment activities will be required if the activity has potential to adversely affect the nest. These
areas can be subsequently treated after a District biologist or designated biological monitor confirms that the
young have fully fledged, are no longer being fed by the parents and have left the nest site. For IPM activities
that clearly would not have adverse impacts to nesting birds (e.g. treatments in buildings and spot spraying with
herbicides), no survey for nesting birds would be required.
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 23
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
23
San Francisco dusky-footed woodrat and Santa Cruz kangaroo rat All District staff, volunteers or contractors
who will implement treatment actions shall receive training from a qualified biologist on the identification of
dusky-footed woodrat, Santa Cruz kangaroo rat, and their nests or burrows. Generally, all San Francisco dusky-
footed woodrat and their nests, and Santa Cruz kangaroo rat and their burrows nests will be avoided and left
undisturbed by proposed work activities. If a nest site or burrow will be affected, the District will consult with
CDFW. Rodenticides, snap traps, and glue boards shall not be used in buildings within 100 feet of active San
Francisco dusky-footed woodrat nests or Santa Cruz kangaroo rat nests burrows; instead rodent control in
these areas will be limited to non-lethal exclusion and relocation activities including relocation of nests if
approved by CDFW. Tenants will contact the District for assistance in managing rat populations in buildings and
under no circumstances will be allowed to use rodenticides.
24 Where appropriate, equipment modifications, mowing patterns, and buffer strips shall be incorporated into
manual treatment methods to avoid disturbance of grassland wildlife.
25
Rare Plants Shortly before treatment, aAll selected treatment sites shall be surveyed by District-approved
personnel with environmental awareness training (BMP #20) prior to work to determine the potential presence
of special-status plants. Rare plant surveys shall also be conducted during the appropriate season to assess
the occurrence, if any, of dormant or overwintering plant species that may not be visible during the pre-
treatment survey. If special-status plants are reported, information such as species and location shall be
uploaded into an electronic inventory system and a biomonitor shall be present to oversee the planned IPM
treatment. On a repeating basis, grassland treatment sites shall be surveyed by a District-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. Treatment sites are defined as
areas where IPM activity, including manual, mechanical, and chemical treatment, is expected to occur. A 1530-
foot buffer shall be established from special-status plants. No application of herbicides shall be allowed within
this buffer. Non-herbicide methods can be used within 1530 feet of rare plants but they shall be designed to
avoid damage to the rare plants (e.g., pulling).
26
Cultural Resources District staff, volunteer crew leaders, and contractors implementing treatment activities
shall receive training on the protection of sensitive archaeological, paleontological, or historic resources (e.g.,
projectile points, bowls, baskets, historic bottles, cans, trash deposits, or structures). In the event volunteers
would be working in locations with potential cultural resources, staff shall provide instruction to protect and
report any previously undiscovered cultural artifacts that might be uncovered during hand-digging activities. If
archaeological or paleontological resources are encountered on a treatment site and the treatment method
consists of physical disturbance of land surfaces (e.g., mowing, brush cutting, pulling, or digging), work shall
avoid these areas or shall not commence until the significance of the find can be evaluated by a qualified
archeologist. This measure is consistent with federal guidelines 36 CFR 800.13(a), which protects such
resources in the event of unanticipated discovery.
27
Post-Treatment Monitoring District staff shall monitor IPM activities within two months after herbicide
treatment (except for routine minor maintenance activities which can be evaluated immediately after
treatment) to determine if the target pest or weeds were effectively controlled with minimum effect impact to
the environment and non-target organisms. Future treatment methods in the same season or future years shall
be designed to respond to changes in site conditions.
28
Erosion Control and Revegetation - For sites with loose or unstable soils, steep slopes (greater than 30
percent), where a large percentage of the groundcover will be removed, or near aquatic features that could be
adversely affected by an influx of sediment, erosion control measures shall be implemented before or after
treatment as appropriate. These measures could consist of the application of forest duff or mulches, straw
bales, straw wattles, other erosion control material, seeding, or planting of appropriate native plant species to
control erosion, restore natural areas, and prevent the spread or reestablishment of weeds. Prior to the start of
the winter storm season, these sites shall be inspected to confirm that erosion control techniques are still
effective. When possible, applicators may select vegetation control techniques select herbicides to maintain
sufficient vegetative cover to mitigate erosion.
29
Operation of noise-generating equipment (e.g., chainsaws, wood chippers, brush-cutters, pick-up trucks) shall
abide by the time-of-day restrictions established by the applicable local jurisdiction (i.e., City and/or County) if
such noise activities would be audible to receptors (e.g., residential land uses, schools, hospitals, places of
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
24 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
worship) located in the applicable local jurisdiction. If the local, applicable jurisdiction does not have a noise
ordinance or policy restricting the time-of-day when noise-generating activity can occur, then the noise-
generating activity shall be limited to two hours after sunrise and two hours before sunset, generally Monday
through Friday. Additionally, if noise-generating activity would take place on a site that spans over multiple
jurisdictions, then the most stringent noise restriction, as described in this BMP or in a local noise regulation,
would apply.
(see attachment) if noise-generating activities would occur during its breeding season (March 24 to September
15), the IPM activities would be subject to the noise requirements listed in the most current in the CDFW RMA
issued to the District (see attachment).
30 All motorized equipment shall be shut down when not in use. Idling of eEquipment and off-highway vehicles
idling will be limited to 5 minutes.
31 Grazing Animals Some herbicides, such as Milestone, Transline, and Capstone contain label language
restricting grazing and/or use of compost. Always read and follow label directions.
32
Surface and Groundwater Protection Applicators shall use BMPs regarding the prevention of drift, runoff,
erosion, and water quality impairment. All work shall be in compliance with the 3 CCR § 6800 (Groundwater
Protection). When possible, plant covers such as landscaping shall be established on bare soil and hillsides to
minimize pesticide and sediment runoff. Pesticides without an aquatic label shall not be applied to: 1)
permeable soils, soils prone to or with evidence of erosion without containment strategies (e.g., vegetative
buffers, sediment barriers); or 2) in areas where aquatic habitats are located within 15 feet of the application
site. In no cases should pesticides be applied to surface water bodies unless appropriate permits are obtained.
33
Application of glyphosate and cholecalciferol shall be conducted in accordance with the Goby -11 Injunction
(Center for Biological Diversity v. EPA, Case No. 07-2794-JCS (N.D. Cal.), May 30, 2007) in applicable and
relevant habitats for those species named in the Injunction that occur within the District. Applicable habitats for
each species named in the Injunction are defined in the 2010 court order for the Center for Biological Diversity
v. EPA. Because the interim protective measures (i.e., no-use buffer zones adjacent to certain features within
certain geographic areas) established in the 2010 order vary depending on the species at issue and the
pesticide being used, the USEPA webpage should be consulted: https://www.epa.gov/endangered-
species/interim-use-limitations-eleven-threatened-or-endangered-species-san-francisco-bay. In addition, District
internal special status species mapping resources, buffer zones established on the CNDDB webpage, and an
interactive species location map (https://www.epa.gov/endangered-species/san-francisco-bay-area-map-tool-
identify-interim-pesticide-use-limitations) should be consulted. The interim use limitations remain in effects until
USEPA completes effects determinations for four pesticides named under the 2015 revised settlement
agreement for the Center for Biological Diversity v. EPA. The effects determinations are expected to be
completed by 2020.
34
Glyphosate Use Reduction Where feasible, the District shall reduce the use of glyphosate in its preserves. For
IPM projects currently utilizing glyphosate as a management tool, the District shall identify suitable sites to
implement alternative treatment methods. The District shall seek to replace glyphosate with the safest
available, broad-spectrum, post-emergent herbicide with minimal residual soil activity.
35 Trails To reduce potential staff and visitor exposure to pesticides, no-spray trail buffers shall be established at
least 5 feet from any trails, trailheads, or parking lots unless a 24-hour trail closure is observed.
36
Annual Pesticide Literature Review To inform updates to the IPM Program, the District shall conduct an
annual pesticide literature review of all newly published toxicological research and court proceedings related to
In addition, the Mitigation Measure 4.2-1a has been modified because the list of Species of Special
Concern, for which the mitigation measure was intended to be all-inclusive, is no longer accurate in light of
the listing of California giant salamander, and Santa Cruz black salamander (changes shown in
underline/strikeout):
ATTACHMENT 3
Resolutions/2019/19-__IPMP EIR Addendum 1
RESOLUTION NO. 19-__
RESOLUTION OF THE BOARD OF DIRECTORS OF MIDPENINSULA REGIONAL
OPEN SPACE DISTRICT APPROVING AN ADDENDUM TO THE CERTIFIED FINAL
ENVIRONMENTAL IMPACT REPORT FOR THE INTEGRATED PEST
MANAGEMENT PROGRAM AND MINOR PROJECT MODIFICATIONS
WHEREAS, pursuant to the California Environmental Quality Act (Public Resources
Code § 21000 et seq.) (“CEQA”), the Midpeninsula Regional Open Space District (the
“District”) is the lead agency for environmental review of the Integrated Pest Management
(“IPM”) Program (the “Project”); and
WHEREAS, in December 2014, the District Board of Directors (the “Board”) certified
the Final Environmental Impact Report (“EIR” or “2014 EIR”) for the Project by approving
Resolution No. 14-37; and
WHEREAS, subsequent to the certification of the 2014 EIR, the District has identified
certain modifications to the previously approved Project, including the addition of three new
pesticides to the Project, two new pesticide application methods, consideration of two new
species of special concern, and clarification to the District’s Best Management Practices
(“BMPs”) and one measure from the EIR (“Project Modifications”); and
WHEREAS, the District has prepared an Addendum to the 2014 EIR in accordance with
CEQA section 21166 and CEQA Guidelines section 15164(a) to describe the Modifications,
attached hereto as Exhibit A (the “Addendum”); and
WHEREAS, the Modifications to the Project associated with the Addendum are
desirable to the District because adding three new pesticides and modifying the approved
application and treatment methods furthers the policy objectives of the Project by providing
more effective treatment methods and minimizing the overall environmental impacts of the
Project; and
WHEREAS, the Addendum concludes that there would be no significant impacts to the
two new species of special concern, the California giant salamander (Dicamptodon ensatus) and
the Santa Cruz black salamander (Aneides flavipunctatus niger), that are considered in this
Addendum; and
WHEREAS, the Modifications constitute minor technical changes and would not alter
any of the conclusions, or result in new significant impacts to the environment, there is no
substantial increase in the severity of previously identified significant impacts, and no new
mitigation measures are required.
NOW, THEREFORE, BE IT RESOLVED AND APPROVED by the Board of Directors as
follows:
1. The Addendum to the 2014 EIR fully describes the proposed minor changes to the
Project and has been prepared in compliance with CEQA (Cal. Public Resources
ATTACHMENT 3
Resolutions/2019/19-__IPMP EIR Addendum 2
Code section 21000 et seq.) and the CEQA Guidelines (Cal. Code of Regs.
section 15000 et seq.)
2. The Addendum reflects the Board’s independent judgment and analysis.
3. In accordance with CEQA Guidelines section 15164, the Addendum, considered
together with the 2014 EIR, adequately addresses the potential environmental
impacts associated with the Modifications.
4. The documents and other materials constituting the administrative record of the
proceedings upon which the Board’s decision is based are located at the
Midpeninsula Regional Open Space District, Administration Office, 330 Distel
Circle, Los Altos, CA 94022.
5. The Addendum is hereby approved by the Board and shall be considered a part of
the District’s environmental review of the Project.
6. The minor technical changes to the Project evaluated in the Addendum are hereby
approved.
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
PASSED AND ADOPTED by the Board of Directors of the Midpeninsula Regional
Open Space District on February____, 2019, at a Regular Meeting thereof, by the following
vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
ATTEST: APPROVED:
Secretary
Board of Directors
President
Board of Directors
APPROVED AS TO FORM:
General Counsel
I, the 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.
District Clerk
ATTACHMENT 3
Resolutions/2019/19-__IPMP EIR Addendum 3
Exhibit A: Addendum to the Final EIR
Addendum to the Environmental Impact Report
Integrated Pest Management Program
SCH# 2013092033
PREPARED FOR:
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
January 9, 2019
Exhibit A
Exhibit A
Addendum to the Environmental Impact Report
Integrated Pest Management Program
SCH# 2013092033
LEAD AGENCY:
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
Contact: Coty Sifuentes-Winter, Senior Resource Management Specialist
Phone: (650) 691-1200
Fax: (650) 691-0485
PREPARED BY:
Blankinship & Associates, Inc.
1615 5th Street
Davis, CA 95616
Contact: Mike Blankinship, Project Manager
January 9, 2019
Exhibit A
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District i
TABLE OF CONTENTS
Section Page
TABLE OF CONTENTS ........................................................................................................................................... I
ACRONYMS AND ABBREVIATIONS ..................................................................................................................... III
1 INTEGRATED PEST MANAGEMENT PROGRAM OVERVIEW ..................................................................... 1
1.1 Purpose of This Document ............................................................................................................. 1
1.2 District Background ........................................................................................................................ 2
1.3 Project History ................................................................................................................................. 5
2 CEQA GUIDANCE REGARDING PREPARATION OF AN ADDENDUM TO THE EIR ................................... 10
3 DESCRIPTION OF PROPOSED PROJECT MODIFICATIONS .................................................................... 11
3.1 Pesticide Use ................................................................................................................................ 17
3.2 Best Management Practices and Mitigation Measures ............................................................. 19
3.3 Species of Special Concern ......................................................................................................... 25
4 ENVIRONMENTAL CONSEQUENCES OF PROPOSED PROJECT MODIFICATIONS ................................. 28
4.1 Aesthetics...................................................................................................................................... 28
4.2 Agriculture and Forestry Resources ............................................................................................ 28
4.3 Air Quality and Greenhouse Gas Emissions................................................................................ 29
4.4 Biological Resources .................................................................................................................... 29
4.5 Cultural Resources and Tribal Cultural Resources ..................................................................... 32
4.6 Geology and Soils ......................................................................................................................... 32
4.7 Hazards and Hazardous Materials .............................................................................................. 33
4.8 Hydrology and Water Quality ........................................................................................................ 34
4.9 Land Use and Planning ................................................................................................................ 37
4.10 Mineral Resources ....................................................................................................................... 37
4.11 Noise ............................................................................................................................................. 38
4.12 Population and Housing ............................................................................................................... 38
4.13 Public Services and utilities ......................................................................................................... 38
4.14 Recreation ..................................................................................................................................... 39
4.15 Traffic and Transportation ........................................................................................................... 39
5 CONCLUSION ........................................................................................................................................ 39
6 REFERENCES ....................................................................................................................................... 40
List of Tables
Table 1 District 2016-2017 Pesticide Use Summary
Table 2 District Integrated Pest Management Program Treatment Actions and Estimates
Table 3
Table 4 District BMPs for IPMP
Table 5 Comparison of District Salamander Species
Table 6 Summary of Proposed Pesticide Active Ingredient Human Toxicity
Table 7 Summary of Pesticide Active Ingredient Environmental Fate Properties
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
ii Midpeninsula Regional Open Space District
List of Figures
Figure 1 Midpeninsula Regional Open Space District Vicinity Map
Figure 2 2017 Midpeninsula Regional Open Space District Pesticide Use Map
Appendices
Appendix 1 Screening-Level Ecological Risk Assessment: Integrated Pest Management Program
(Updated)
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District iii
ACRONYMS AND ABBREVIATIONS
ATV All-terrain vehicle
BMP Best Management Practice
Bti Bacillus thuringiensis var. israelensis
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
District Midpeninsula Regional Open Space District
DPR California Department of Pesticide Regulation
EIR Environmental Impact Report
HCP Habitat Conservation Plan
IPA Isopropylamine (salt)
IPM Integrated Pest Management
IPMP Integrated Pest Management Program
K Potassium (salt)
MEA Monoethanolamine (salt)
MLA Mixer/loader/applicator
MND Mitigated negative declaration
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
OSHA Occupational Safety & Health Administration
PPE Personal Protective Equipment
PT Phenothrin
QAC Qualified Applicator Certificate
QAL Qualified Applicator License
RWQCB Regional Water Quality Control Board
TCP 3,5,6-Trichloro-2-pyridinol
TEA Triethylamine (salt)
TIPA Triisopropanolamine (salt)
TMP 3,5,6-Trichloro-2-methoxypyridine
Triclopyr BEE Triclopyr-2-butoxyethyl ester
USEPA U.S. Environmental Protection Agency
WPS Worker Protection Standard
Exhibit A
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 1
1 INTEGRATED PEST MANAGEMENT PROGRAM OVERVIEW
1.1 PURPOSE OF THIS DOCUMENT
In December 2014, the Midpeninsula Regional Open Space District (District) Board of Directors certified the
Environmental Impact Report (EIR) (State Clearinghouse No. 2013092033) for the Integrated Pest
Management (IPM) Program (herein referred to as the 2014 EIR). The 2014 EIR analyzed a proposed
program that included implementing cultural, biological, manual/mechanical, and chemical IPM practices in
buildings, recreational facilities, fuel management areas, rangelands and agricultural properties, and natural
lands within District boundaries. The 2014 EIR evaluated the significant or potentially significant adverse
effects on the physical environment resulting from implementation of the IPM Program (IPMP); described
feasible measures, as needed, to mitigate any significant or potentially significant adverse effects; and
considered alternatives that may lessen one or more of the significant or potentially significant adverse
effects. The 2014 EIR determined adverse effects after consideration of District Best Management Practices
(BMPs) incorporated into the IPMP.
: (1) the addition of three
new pesticides to the IPMP, (2) three new pesticide application methods, and (3) three new Best
Management Practices (BMPs) along with clarification to other BMPs and one mitigation measure from the
EIR. The District is also proposing minor modifications to the acreages to be treated on an annual basis
using certain pest management methods. Finally, this proposed Addendum considers changed
circumstances under which the project would be undertaken, specifically, the potential presence of two new
Species of Special Concern.
Specifically, the project modifications would include the use of the following pesticides: 1) Garlon ® 4 Ultra
[triclopyr-2-butoxyethyl ester (triclopyr BEE)] and 2) Capstone ® [triclopyr triethylamine (TEA) salt and
aminopyralid triisopropanolamine (TIPA) salt] for the control of broadleaf weeds and woody plants, and 3)
PT® Wasp-Freeze® II (prallethrin) for the control of wasps and hornets. Garlon 4 Ultra would be applied in fuel
management areas, natural lands, and rangelands and agricultural properties via spot spray, cut-stump, and
basal bark application for the control of vegetation. Capstone would be applied in natural lands and
rangelands and agricultural properties via spot spray, cut-stump, and frill/injection for the control of
vegetation. PT Wasp-Freeze II would be used outside of buildings and in recreational facilities via aerosol
spray to control wasps and hornets.
Basal bark, frill/injection, and wick applications are new pesticide application methods for the control of
vegetation that were not part of the previously approved project. In addition to the use of these application
methods, some previously evaluated application methods are proposed for additional use for pesticides that
were approved in the 2014 EIR. The IPMP modifications also include some minor modifications to the
amounts of chemicals used and the acreages treated. In almost all cases, the differences in treatment area
or amount of product used would be de minimis.
Further, some manual/mechanical treatment methods would additionally be used in natural lands,
including: brushcutters, chainsaws, chippers, masticators, jawz implement, and pole pruners. These
methods were previously approved in the 2014 EIR for use in fuel management areas. The District is also
proposing some minor modifications to the acreages to be treated using manual/mechanical treatment
methods for natural lands and fuel management areas.
Project modifications include the addition of three new BMPs to the IPMP to reduce reliance on glyphosate
and further enhance visitor and worker safety. The updated BMPS are included in Table 4.
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
2 Midpeninsula Regional Open Space District
Changed circumstances under which the IPMP would be undertaken include the addition of the California
giant salamander (Dicamptodon ensatus) and the Santa Cruz black salamander (Aneides flavipunctatus
niger)
(Thomson et al., 2016). Refer to Section 3 of this Addendum for a more detailed description of these
proposed project modifications and changed circumstances. The project objectives identified in Section 3.5,
page 3-8, of the 2014 EIR remain unchanged.
The purpose of this proposed Addendum is to consider whether these modifications to the project would
meet any of the criteria listed in section 15152 of the California Environmental Quality Act (CEQA)
Guidelines, resulting in the need for a subsequent or supplemental mitigated negative declaration (MND) or
EIR under CEQA (Public Resources Code, section 21166; CEQA Guidelines, sections 15162, 15164).
As demonstrated in Section 4 below, the project modifications do not meet any of the criteria listed in
section 15162 of the CEQA Guidelines. This means: (1) the modifications would not result in any new
significant environmental effects or a substantial increase in severity of previously evaluated significant
effects that result from either a substantial change to the project or changes to the project circumstances;
(2) there is no new information of substantial importance since certification of the 2014 EIR that shows the
modifications will have new significant effects or more severe effects than previously evaluated; and (3) no
mitigation measures or alternatives found to be infeasible in the 2014 EIR, which are capable of
substantially reducing a significant environmental effect, would now be feasible. Therefore, pursuant to
section 15164 of the CEQA Guidelines, the differences between the approved project described in the 2014
EIR and the proposed modified project as currently described represent minor technical changes. For these
reasons, an addendum to the 2014 EIR is the appropriate mechanism to address proposed modifications to
the project.
This document concludes that the proposed addition of three new pesticides and the three new pesticide
application methods would not alter any of the conclusions of the 2014 EIR. Minor changes in treatment
acreage and chemical use were contemplated by and approved in the 2014 EIR. In addition, there would be
no significant impacts to the two new species of special concern that are considered in this Addendum. No
new significant environmental effects or a substantial increase in the severity of previously identified
significant effects would result. The additions also would not affect any of the mitigation measures, including
their feasibility or implementation. As mentioned above, none of the conditions listed in section 15162 of
the CEQA Guidelines exist for the project modification described herein. Therefore, pursuant to section
15164 of the CEQA Guidelines, the differences between the approved project described in the 2014 EIR and
the modification of the project as currently proposed and described in this addendum are minor and this
addendum provides sufficient environmental documentation.
1.2 DISTRICT BACKGROUND
The District is a regional greenbelt system which manages over 62,000 acres of open space in 26 preserves.
District preserves vary in size from 59 acres to over 17,000 acres. The District provides protection for local
wildlife habitats necessary to sustain plant and animal life and natural resources and practices IPM to safely
and effectively control pests while minimizing risk of adverse impacts to non-target receptors.
The District is located on the San Francisco Peninsula with boundaries that enclose an area of 227,900
acres in northwestern Santa Clara and southern/central San Mateo Counties, and a small portion of Santa
Cruz County (Figure 1)
expand, includes an additional 12,333 acres. District preserves include redwood, oak, and fir forests;
chaparral-covered hillsides; riparian corridors; grasslands; and wetlands along the San Francisco Bay. The
District also participates in cooperative efforts, including regional trail systems in the Bay Area that overlap
with District lands such as the Bay Trail, Ridge Trail, and Skyline-to-the-Sea Trail.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 3
District lands protect a variety of habitats rich in both numbers and variety of plants and animals. The
District preserves include tidal salt marshes in the east, which are used by thousands of migratory birds and
are home to the endangered rail and salt marsh harvest mouse. The heart of the District is
separated by the eastern and western flanks of the Santa Cruz Mountains. These lands are covered in a
diverse mix of oak woodland, grassland, chaparral, coastal scrub, and evergreen and coniferous forests.
Creeks and streams that run through District lands provide refuge area for federally and California
endangered coho salmon and federally threatened steelhead.
Exhibit A
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 5
1.2.1 Land Use
District properties include over 182 buildings, including an administrative office, three field offices, a nature
center, residences, and numerous outbuildings such as barns, sheds, and water tanks in the preserves.
Residential land uses adjacent to all District preserves total approximately 75 acres of land.
Human use is typically concentrated on preserves at the recreational facilities provided by the District.
Recreational facilities within District preserves currently include approximately 479 miles of access road and
trails as well as associated infrastructure (i.e., bridges, culverts, drainage ditches, parking lots, gates, stiles),
picnic areas, one campground, off-leash dog zones, managed turf and landscaped recreation areas, pond
viewing and dam areas, and Deer Hollow Farm.
Some District lands encompass rangelands, crop fields, and orchards that are actively managed as grazing
or agricultural operations. Rangeland and agriculture activities on District preserves are primarily managed
by lessees who typically operate under a Rangeland Management Plan or Agricultural Management Plan that
is attached to their lease. These site-specific management plans guide the rangeland and agricultural
activities to ensure compatibility with natural resource protection and low-intensity public recreation.
Natural areas make up the majority of District lands, and typically experience minimal levels of human use.
1.3 PROJECT HISTORY
protect and restore the natural environment, and provide opportunities for ecologically sensitive public
implementation of IPM principles to protect and restore the natural environment and provide for human
safety and enjoyment while visiting and working on District lands. This section describes both the IPMP itself
1.3.1 Description and History of the IPMP
The IPMP is primarily a vegetation management program in wild lands; however, it also includes
management of invasive animals on preserves, flammable vegetation near facilities, and rodents and
insects in District-owned buildings. The IPMP provides the District with an objective evaluation tool and
process to effectively and efficiently make IPM decisions while providing for safe recreational use of the
preserves and protecting their natural and cultural resources. The IPMP is intended to be used for 10 years.
The District has identified the following five (5) distinct management categories for the IPMP:
Buildings
Recreational facilities
Fuel management areas
Rangelands and agriculture properties
Natural areas
Specific pest control strategies used by the District vary by management category and include a combination
of mechanical (e.g., mowing, pulling, discing, physical barriers), cultural (e.g., sanitation, prevention,
mulching), and biological controls (e.g., hairy weevil), and, as needed, chemical controls (i.e., pesticides,
bacterial pathogens). Whenever possible, the least harmful method(s) to control identified pests are used. If
pesticides are deemed necessary to meet a pest control objective, products are applied according to label
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
6 Midpeninsula Regional Open Space District
instructions and all necessary measures are taken to protect the environment, the health and safety of
visitors, employees, neighbors, and the surrounding natural areas, including water and soil resources.
In 2017, the District (2017a) conducted 1,005 non-pesticide treatments and 314 pesticide treatments for
vegetation management. The non-pesticide methods included brush cutting, cutting, digging, flaming,
mowing, and pulling of non-desirable or invasive vegetation (e.g., stinkwort, French broom, goat grass, yellow
star thistle) across more than 285 acres (>0.46%) of District property. No data on area treated was available
for 281 (28%) of the 1,005 non-pesticide treatments. Furthermore, approximately 10,000 acres (16%) of
District land is managed by conservation grazing techniques annually (Sifuentes-Winter, C., District 2017,
Pers comm).
Refer to Table 1 for a summary of District pesticide use during 2016 and 2017 and Figure 2 for a geographic
interpretation of District pesticide use in 2017. As indicated in Table 1 and illustrated in Figure 2, herbicides
were applied to approximately 328 acres (0.5%) of District property in 2017. All herbicides were applied via
spot spray or cut stump in discrete locations.
Table 1. District 2016-2017 Pesticide Use Summary 1,2
Year Pesticide
Category Active Ingredient (Product) Amount Product Used
(oz) Area Treated (ac)
2016
Herbicides
Aminopyralid TIPA (Milestone) 7.71 26.86
Clopyralid MEA (Transline) 3.08 2.10
Imazapyr IPA (Polaris) 170.75 16.21
Glyphosate IPA (Roundup Custom) 3.00 0.49
Glyphosate K (Roundup ProMax) 498.30 32.813
Insecticides D-trans Allethrin/Phenothrin
(PT® Wasp-Freeze®) - NDA4
2017
Herbicides
Aminopyralid TIPA (Milestone) 17.79 150.05
Clopyralid MEA (Transline) 12.49 5.25
Glyphosate IPA (Roundup Custom) 0.25 0.0031
Glyphosate K (Roundup ProMax) 2185.34 172.72
Insecticides D-trans Allethrin/Phenothrin
(PT Wasp-Freeze) 87.50 NDA4
1 Not shown: Bacterial pathogen ( var. ) applications of 250 disks per year.
2 Abbreviations: ounces (oz), acres (ac), triisopropanolamine (TIPA) salt, monoethanolamine (MEA) salt, isopropylamine (IPA) sa lt, potassium (K) salt.
3 Area shown is an underestimation of total area treated due to incomplete dataset.
4 No data available on area treated.
Sources: District, 2016, 2017a; Sifuentes-Winter, C., District 2017, Pers comm, Email RE: CEQA - Insecticide Reported Use
Exhibit A
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
8 Midpeninsula Regional Open Space District
insecticides and rodenticides may also be used after non-chemical methods (e.g., trapping, manual removal)
have been considered, if the insects or rodents cause a human health and safety risk (e.g., occur in high traffic
areas). When needed, insecticides such as d-trans allethrin and phenothrin (PT Wasp-Freeze) are applied to
wasp and hornet nests located along preserve trails. For mosquito control, the bacterial pathogen Bacillus
thuringiensis var. israelensis (Bti) is applied monthly to water troughs by rangers in open preserves. Bti may
also be applied by residents who live on District land and receive annual label and usage training. Rodenticides
were not applied on District land during 2016-2018 If rodenticide use is required, products may be applied by
District staff or approved contractors in indoor residential areas via tamper-resistant box after prior District
approval.
Refer to Table 3-1 in the 2014 EIR for all potential treatment actions permitted in the IPMP in 2014.
In September 2014, the District (2014a) released an IPM Guidance Manual for the IPMP. The IPM Guidance
Manual includes several proposed program policies and identifies specific pest management actions
including: preventative and maintenance measures, damage assessment procedures, tolerance levels and
thresholds for action, and treatment options. The proposed IPM policy statements presented in the IPM
Guidance Manual have sin (2014b) Resource
Management Policies, published in December 2014. Appendix A of the IPM Guidance Manual is entitled
on 14 pesticide active
ingredients (glyphosate, aminopyralid, clopyralid, imazapyr, clethodim, potassium salts of phosphorus acid,
cholecalciferol, d-trans allethrin, phenothrin, indoxacarb, hydroprene, fipronil, sodium tetraborate
decahydrate, diatomaceous earth) and 4 adjuvants/surfactants (modified vegetable oil, lecithin, alcohol
ethoxylates, alkylphenol ethoxylate) currently permitted for use within the IPMP.
1.3.2 IPMP CEQA Process and History
On September 16, 2013, the District issued a Notice of Preparation (NOP) (State Clearinghouse
No. 2013092033) to inform agencies and the general public that a Draft EIR was being prepared and invited
comments on the scope and content of the EIR and participation at a public scoping meeting. The NOP was
posted with the State Clearinghouse, posted on the District website, and distributed to public agencies,
interested parties and organizations. A determination of which impacts would be potentially significant was
made for this project based on review of the information presented in the NOP, comments received as part of
the public review process for the project, and additional research and analysis of relevant project data during
preparation of the Draft EIR.
A series of public meetings on the project were held during preparation of the Draft EIR, beginning in
September 2013. A public scoping meeting on the issues to be addressed in the Draft EIR was held on
September 30, 2013. In addition, early consultation with relevant agencies, organizations, and individuals
assisted in the preparation of the Draft EIR. After filing a Notice of Completion with the State Clearinghouse
, the Draft EIR was subject to a 45-day public comment
period, beginning September 26, 2014, and ending November 10, 2014. A public information meeting on
the Draft EIR was held during the review period on October 21, 2014.
The 2014 EIR analyzed a proposed program that included implementing cultural, biological,
manual/mechanical, and chemical IPM practices in buildings, fuel management areas, natural lands,
rangelands and agricultural properties, and recreational facilities within District boundaries. The Draft EIR
evaluated the significant or potentially significant adverse effects on the physical environment resulting from
implementation of the IPM Program; described feasible measures, as needed, to mitigate any significant or
potentially significant adverse effects; and considered alternatives that may lessen one or more of the
significant or potentially significant adverse effects. Adverse effects were determined after consideration of
District Best Management Practices (BMPs) incorporated into the project. The District developed BMPs for
the IPMP to protect human health and prevent significant environmental effects. The BMPs are applied to
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 9
IPM projects District-
BMPs, known regulatory requirements, and evaluation of the IPMP activities. District BMPs for the IPMP are
presented in Table 3-4 of the 2014 EIR. The project objectives identified in Section 3.5, page 3-8, of the
2014 EIR remain unchanged.
After consideration of the BMPs, the 2014 EIR determined the following categories of environmental effects
Aesthetics
Biological resources
Cultural resources
Hydrology and water quality
Hazards and hazardous materials
Effects found not to be significant include:
Agriculture and forestry resources
Air quality
Geology and soils
Greenhouse gas emissions
Land use and planning
Mineral resources
Noise
Population and housing
Public services
Recreation
Transportation and traffic
Utilities
existing visual resources that would result from project implementation. Potential impacts on biological
resources resulting from implementation of the IPMP were determined by evaluating the use of IPM techniques
in relation to the habitat characteristics of the project, quantifying potential loss of common and sensitive
habitats, and evaluating potential effects to common and special-status species that could result from this
habitat loss. Special status species considered in the 2014 EIR include:
3 amphibian species
32 bird species
4 invertebrate species
3 fish species
8 mammalian species
3 reptile species
45 plant species
Cultural resource impact analysis considered the known cultural resource environmental setting in District
lands, the potential for previously undocumented resources, and physical effects (i.e., disturbance, material
alteration, demolishment) to known and previously undocumented cultural and paleontological resources that
could result from implementation of the project. Evaluation of potential hydrologic and water quality impacts
was based on a review of documents available from federal, state and local government to establish existing
impacts was based on the range and nature of foreseeable hazardous materials use, storage, and disposal
resulting from the project and identified the primary ways that these hazardous materials could expose
individuals or the environment to health and safety risks.
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
10 Midpeninsula Regional Open Space District
On December 3, 2014, the Final 2014 EIR (State Clearinghouse No. 2013092033) was published and
consisted of the Draft EIR, public comments and responses, and clarifications and revisions to the Draft EIR
text. On December 10, 2014, a public hearing to certify the 2014 EIR was held.
In June 2017, the District reviewed toxicity data on four additional pesticides (Garlon 4 Ultra, Capstone, Python
Dust, and PT Wasp-Freeze II) for potential inclusion in the IPMP. The District determined that the following
three chemicals would be evaluated for a CEQA Addendum as candidates for addition to the IPMP: triclopyr
BEE (Garlon 4 Ultra), triclopyr TEA (Capstone), and prallethrin (PT Wasp-Freeze II). Note that Capstone contains
2 active ingredients: triclopyr TEA and aminopyralid TIPA. Aminopyralid TIPA was analyzed previously in the
2014 EIR. Further, the District determined that it would consider in its evaluation two new species of special
concern: the California giant salamander and the Santa Cruz black salamander. These two species have
al Concern (Thomson et al., 2016).
2 CEQA GUIDANCE REGARDING PREPARATION OF
AN ADDENDUM TO THE EIR
If, after certification of an EIR, there are changes or additions to a project that will require new discretionary
actions, CEQA provides three possible mechanisms to address these changes: a subsequent MND or EIR, a
supplemental MND or EIR, or an addendum to an EIR.
Section 15162 (a) of the CEQA Guidelines provides that when an EIR has been certified for a project, no
subsequent or supplemental MND or EIR shall be prepared for that project unless the lead agency
determines, on the basis of substantial evidence in light of the whole record, that one or more of the
following conditions is met:
(1) substantial changes are proposed in the project which will require major revisions of the previous EIR
due to the involvement of new significant environmental effects or a substantial increase in the severity
of previously identified significant effects;
(2) substantial changes occur with respect to the circumstances under which the project is undertaken which
will require major revisions of the previous EIR due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant effects; or
(3) new information of substantial importance, which was not known and could not have been known with
the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of
the following:
(A) the project will have one or more significant effects not discussed in the previous EIR;
(B) significant effects previously examined will be substantially more severe than shown in the previous EIR;
(C) mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and
would substantially reduce one or more significant effects of the project, but the project proponents
decline to adopt the mitigation measures or alternatives; or
(D) mitigation measures or alternatives which are considerably different from those analyzed in the
previous EIR would substantially reduce one or more significant effects on the environment, but the
project proponents decline to adopt the mitigation measures or alternatives.
Section 15164 of the CEQA Guidelines states that a lead agency or a responsible agency shall prepare an
addendum to a previously certified EIR if some changes or additions are necessary, but none of the
conditions described above in section 15162(a), calling for preparation of a subsequent or supplemental
MND or EIR, have occurred.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 11
CEQA allows lead and subsequent responsible agencies issuing additional discretionary approvals for a
project to restrict their review of modifications to a previously approved project to the incremental effects
associated with the proposed modifications, compared against the anticipated effects of the previously
approved project at build-out. In other words, if the project under review constitutes a modification of a
previously approved project which was subject to prior final environmental review, the baseline for
purposes of CEQA is adjusted such that the originally approved project is assumed to exist.
The District is proposing minor modifications to the approved project; these changes are described in
Section 3 of this Addendum. As demonstrated in detail below, the project modifications do not meet any of
the criteria listed in section 15162. First, the modifications would not result in any new significant
environmental effects or a substantial increase in severity of previously evaluated significant effects that
result from either a substantial change to the project or changes to the project circumstances. Second, there
is no new information of substantial importance since certification of the 2014 EIR that shows the
modifications will have new significant effects or more severe previously evaluated effects. Finally, no
mitigation measures or alternatives, which were found to be infeasible in the 2014 EIR and which are
capable of substantially reducing a significant environmental effect, would now be feasible. Therefore,
pursuant to section 15164 of the CEQA Guidelines, the differences between the approved project described
in the 2014 EIR and the refined elements of the project as they are currently proposed are considered minor
technical changes. Furthermore, the 2014 EIR and associated mitigation monitoring and reporting program
remain valid for mitigating the identified significant impacts that would result from implementation of the
project, including the proposed modifications. For these reasons, an addendum to the 2014 EIR is the
appropriate mechanism to address modifications to the project.
3 DESCRIPTION OF PROPOSED PROJECT MODIFICATIONS
pesticides to the IPMP and three new pesticide application methods based on anticipated vegetation control
work. More specifically, the project includes the use of: 1) Garlon 4 Ultra (triclopyr BEE) and 2) Capstone
(triclopyr TEA, aminopyralid TIPA) for the control of broadleaf weeds and woody plants, and 3) PT Wasp-
Freeze II (prallethrin) for the control of wasps and hornets. Garlon 4 Ultra would be applied in fuel
management areas, natural lands, and rangelands and agricultural properties via spot spray, cut-stump, and
basal bark application. Capstone would be applied in natural lands and rangelands and agricultural
properties via spot spray, cut-stump, and frill/injection. PT Wasp-Freeze II would be used outside of buildings
and in recreational facilities via aerosol spray.
Basal bark, frill/injection, and wick applications are new pesticide application methods for the control of
vegetation that were not part of the previously approved project. In addition to the use of these application
methods, some previously evaluated application methods are proposed for use for additional pesticides that
were approved in the 2014 EIR. Cut-stump, basal bark, and frill/injection applications for the control of
vegetation are also proposed for Milestone (aminopyralid TIPA) use in natural lands and rangelands and
agricultural properties. Roundup ProMax (glyphosate K) is proposed to be applied as needed via cut-stump,
frill/injection, and wick applications in recreational facilities, fuel management areas, rangelands and
agricultural properties, and natural lands. These application methods are similarly proposed for treatments
of Roundup Custom (glyphosate IPA) in recreational facilities, rangelands and agricultural properties, and
natural lands. Proposed application methods for Transline (clopyralid MEA) treatments in recreational
facilities, rangelands and agricultural properties, and natural lands include cut-stump and frill/injection.
These application methods are also proposed for treatments of Polaris (imazapyr IPA) in recreational
facilities and natural lands. Note that aminopyralid TIPA (Milestone, Capstone) and the cut-stump and spot
spray application methods for the control of vegetation were previously evaluated in the 2014 EIR and are
therefore not discussed further in this Addendum.
In addition, some previously approved manual/mechanical treatment methods for fuel management areas
are proposed for use in natural lands, including: brushcutters, chainsaws, chippers, masticators, jawz
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
12 Midpeninsula Regional Open Space District
implement, and pole pruners. Because they were previously evaluated in the 2014 EIR and some of the
already contained within natural lands, the utilization of these tools in
natural lands is not discussed further.
The District has also proposed some minor modifications to the acreages that would be treated using
various treatment methods, the amounts of herbicides that might be used on an annual basis, and the
timing of work for certain treatment methods. Some of these modifications result in an increase in treated
acreage or herbicide quantity, and some represent a decrease. In most cases, the differences in treatment
area or amount of product used would be de minimis and the changes in timing of work would be
inconsequential. The 2014 EIR recognized that the IPMP is an adaptive management program, and that
there would be minor changes from year to year that would not require changes to the EIR. As a general
matter, the modifications to acreage, product quantity, and timing of work do not require further discussion.
The only notable changes are the proposed increase in the use of manual/mechanical treatment methods in
natural lands from 2 acres to 10 acres annually and the proposed adjustment in timing of
manual/mechanical treatment methods in fuel management areas from April through June to any time
during the year. Because these treatment methods involve generation of noise and could conceivably disrupt
sensitive species, this Addendum considers the expansion of their use.
A summary of the treatment actions permitted in the IPMP including the proposed modifications is
presented in Table 2 (changes shown in underline/strikeout).
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 13
r
Table 2. District Integrated Pest Management Program Treatment Actions and Estimates
IPM Management
Category
Treatment
Type Treatment Method Method of Application1 Purpose Annual Application2 Timing of Work3 Frequency of
Work4
Buildings
Manual
Sanitation Structural pests, stray
wildlife, pets 103 buildings
Habitat
modification Structural pests, stray
wildlife, pets 103 buildings
Physical barriers Structural pests, stray
wildlife, pets 103 buildings
Traps Sticky, electric, snap, box,
glue boards, water, lures
Structural pests, stray
wildlife, pets 103 buildings
Building retrofits Structural pests, stray
wildlife, pets Spring/summer/fall
Prevention Structural pests, stray
wildlife, pets
Chemical
Insecticidal soap Spray Structural pests 103 buildings Spring/summer/fall
Diatomaceous
earth Crack & crevice Structural pests 103 buildings Spring/summer/fall
Boric acid Crack & crevice Structural pests 103 buildings Spring/summer/fall
S-Hydroprene Disc Structural pests
15 fl oz over 8
applications over 103
buildings
Spring/summer/fall
Indoxacarb (0.1%) Crack & crevice Structural pests
7 fl oz over 20
applications over 103
buildings
Spring/summer/fall
Indoxacarb (0.5%) Crack & crevice Structural pests
51 fl oz over 23
applications over 103
buildings
Spring/summer/fall
Sodium tetraborate
decahydrate Bait station Structural pests
11 fl oz over 17
applications over 103
buildings
Spring/summer/fall
Fipronil Bait station Structural pests
16 fl oz over 7
applications over 103
buildings
Spring/summer/fall
Cholecalciferol Bait station Vertebrate pests 50 oz over 103
buildings Spring/summer/fall
Prallethrin Spray Stinging insects 70 oz (4 cans of spray) Spring/summer/fall
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
14 Midpeninsula Regional Open Space District
Table 2. District Integrated Pest Management Program Treatment Actions and Estimates
IPM Management
Category
Treatment
Type Treatment Method Method of Application1 Purpose Annual Application2 Timing of Work3 Frequency of
Work4
Recreational
Facilities
Manual
Sanitation Stinging insects Spring/summer/fall
Habitat
modification Stinging insects, mosquitos,
stray wildlife, pets Spring/summer/fall
Traps Water/lure Stinging insects, mosquitos,
stray wildlife, pets Spring/summer/fall
Nest removal Stinging insects Summer
Manual and
Mechanical Digging & mowing
Hand shovels, brushcutters
(manual method in creeks
with salmonids)
Ponds, bridges, culverts 1 acre 1x per year
Mechanical
Mowing Tractors Roads & road-width trails,
facilities 580 acres May through August 1.5x per year
Brushcutters Single track trails 85 acres May through August 1.5x per year
Cutting
Chainsaws Hazard & downed tree
removal 50 to 150 trees
Chippers Hazard & downed tree
removal 50 to 150 trees
Chemical
D-trans Allethrin/
Phenothrin Spray Stinging insects 420 oz (24 cans of
spray) Spring/summer/fall
Prallethrin Spray Stinging insects 350 oz (20 cans of
spray) Spring/summer/fall
Bacterial
pathogens
Bacillus thuringiensis var.
israelensis Mosquitos 250 disks May through
September
1 disk per
30 days
Glyphosate IPA Cut-stump, spot spray, wick,
frill/injection
Dam faces, parking lots,
gates & stiles, facilities 2.4 3 gal over 40 acres Spring/summer/fall 1x per year
Glyphosate K Cut-stump, spot spray, wick,
frill/injection
Roads, trails, parking lots,
gates & stiles, facilities 1 gal over 54.6 acres Spring/summer/fall 1x per year
Clopyralid MEA Spot spray, cut-stump,
frill/injection
Parking lots, gates & stiles,
facilities 0.3 gal over 22.9 acres May through August 1x per year
Imazapyr IPA Cut-stump, spot spray,
frill/injection
Roads, trails, parking lots,
gates & stiles, facilities 0.4 gal over 54.6 acres Spring/summer/fall
Fuel Management Manual and
Mechanical Mowing & cutting
Tractors, brushcutters, pole
pruner, chainsaws, chippers,
masticators, jawz implement
Defensible space, fuel break,
emergency helicopter landing
zones
136 140 acres April through June
1x per year
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 15
Table 2. District Integrated Pest Management Program Treatment Actions and Estimates
IPM Management
Category
Treatment
Type Treatment Method Method of Application1 Purpose Annual Application2 Timing of Work3 Frequency of
Work4
Discing & cutting Tractor-pulled instrument,
pole pruner Disc lines 75 acres April through May 1x per year
Chemical
Glyphosate K Cut-stump, spot spray, wick,
frill/injection
Defensible space, disc lines,
fuel break
7.2 3.6 gal over 14
acres April through June 1x per year
Triclopyr BEE Spot spray, cut-stump, basal
bark
Defensible space, disc lines,
fuel break 3.6 gal over 14 acres Summer/fall 1x per year
Rangelands and
Agricultural
Properties Manual
Weeding,
weedmats, crop
rotation, mulching
Hand tools Agricultural weeds 360 acres Spring/summer 1x per year
Sanitation, physical
barriers, traps Snap, box traps Vertebrate pests 360 acres
Mechanical Mowing, discing,
cutting, flaming
Tractors, brushcutters,
brushrakes, flame equipment
Rangeland weeds,
agricultural weeds, brush
control
725 acres Spring/summer/fall 1x per year
Chemical
Aminopyralid TIPA Spot spray, cut-stump, basal
bark, wick, frill/injection
Rangeland weeds, invasive
plant control
1.6 2.1 gal over 154
174 acres
Spring/summer
1x per year
Clopyralid MEA Spot spray, cut-stump,
frill/injection
Rangeland weeds, invasive
plant control 1.6 gal over 154 acres Spring/summer 1x per year
Glyphosate IPA Spot spray, cut-stump, wick,
frill/injection
Rangeland weeds, brush
control, agricultural weeds,
invasive plant control
1 gal over 100 acres Spring/summer 1x per year
Glyphosate K Spot spray, cut-stump, wick,
frill/injection
Rangeland weeds, brush
control, agricultural weeds,
invasive plant control
57.6 gal over 154
acres Spring/summer 1x per year
Triclopyr BEE5 Spot spray, cut-stump, basal
bark
Rangeland weeds, brush
control, agricultural weeds,
invasive plant control
6.6 gal over 154 acres Spring/summer/fall 1x per year
Triclopyr TEA/
Aminopyralid TIPA
Spot spray, cut-stump,
frill/injection
Rangeland weeds, invasive
plant control 20 gal over 174 acres 1x per year
Natural Lands
Manual
Digging, hoeing,
hand pulling Invasive plant control 30 50 acres 1x per year
Biocontrol insects Hairy weevils Invasive plant control 800 acres 1x per year
Sanitation Invasive plant control
Prevention Invasive plant control
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
16 Midpeninsula Regional Open Space District
Table 2. District Integrated Pest Management Program Treatment Actions and Estimates
IPM Management
Category
Treatment
Type Treatment Method Method of Application1 Purpose Annual Application2 Timing of Work3 Frequency of
Work4
Habitat
modification Invasive plant control
Traps Invasive animal control
Manual and
Mechanical Cutting
Weed wrenches, hand saws,
clippers, brushcutters, pole
pruner, chainsaws, chippers,
masticators, jawz implement
Sudden oak death, invasive
plant control 2 10 acres 1x per year
Mechanical
Flaming Invasive plant control 2 acres
Mowing Tractors, mowers,
brushcutters Invasive plant control 10 acres
Chemical
Glyphosate IPA Spot spray, cut-stump, wick,
frill/injection Invasive plant control 1 gal over 100 acres Spring/summer 1x per year
Glyphosate K Spot spray, cut-stump, wick,
frill/injection
Invasive plant control,
sudden oak death
119.2 71.5 gal over
955 acres Spring/summer 1x per year
Clethodim Spot spray Invasive plant control 1.8 gal over 243 acres Spring/summer 1x per year
Aminopyralid TIPA Spot spray, cut-stump, basal
bark, wick, frill/injection Invasive plant control 1.7 2 gal over 164
174 acres
Spring/summer
1x per year
Clopyralid MEA Spot spray, cut-stump,
frill/injection Invasive plant control 1.7 gal over 164 acres Spring/summer 1x per year
Imazapyr IPA Spot spray, cut-stump,
frill/injection
Invasive plant control,
sudden oak death 0.35 gal over 8 acres Spring/summer 1x per year
Phosphite K Salts,
mono-/di- Spray, inject Sudden oak death 45 gallons concentrate
over 30 acres
April/May or
October/November 1x per year
Triclopyr BEE5 Spot spray, cut-stump, basal
bark Invasive plant control 54.6 gal over 955
acres Spring/summer/fall 1x per year
Triclopyr TEA/
Aminopyralid TIPA
Spot spray, cut-stump,
frill/injection Invasive plant control 17.5 gal over 164
acres 1x per year
1 All applications are made according to product label instructions and may include methods not listed here.
2 Herbicide quantities are expressed as volume of concentrate, i.e. volume of undiluted product.
3 No value indicates treatment method may be applied anytime during the year
4 No value indicated treatment method may be applied multiple times throughout the year as needed
5 See Garlon® 4 Ultra label - must be used in other sites that are within a rangeland. Cows not to be lactated for one season.
Source: District 2014c; Sifuentes-Winter, C., District 2017, Pers comm, Email RE: CEQA - Table 3-1 Update
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 17
This Addendum also includes clarifications to the BMPs (Draft EIR, Table 3-4, p. 3-36 - 3-39) and one
mitigation measure, as well as the addition of six new BMPs. The purpose of the proposed BMP and
mitigation measure modifications is to clarify existing language, outline practices already being carried out
by District staff, further increase the protection and safety of humans and the environment, and further
reduce the level of impact associated with impacts that were already considered less than significant in light
of these BMPs and mitigation measures. As such, it is important to note that these revisions are not a result
of newly identified adverse impacts and do not substantially affect the current IPMP or other proposed
program modifications.
This proposed Addendum also considers potential impacts of the IPMP on the California giant salamander
and the Santa Cruz black salamander.
The purpose of this proposed Addendum is to consider whether these modifications to the project or
changed conditions would result in the need for a subsequent or supplemental MND or EIR under CEQA
(Public Resources Code, section 21166; CEQA Guidelines, sections 15162, 15164). An environmental
checklist (based on Appendix G of the CEQA Guidelines) has been used to analyze potential environmental
impacts associated with the above modifications to the project and changed circumstances under which it
would be undertaken, determine whether any new impacts could occur compared to those identified in the
prior EIR, and evaluate the mitigation measures adopted for the previously approved project to determine
which one(s) is/are applicable to the modified project.
As previously mentioned, the IPMP is intended to be used for at least 10 years. During that time period, it is
to
accommodate the purchase of additional land. This increase is considered in the current analysis.
The following provides a description of the proposed modifications to the previously approved project, and
the newly listed Species of Special Concern which constitute changed circumstances under which the
project would be undertaken. All proposed project modifications are located on previously affected land
located within the project site analyzed in the 2014 EIR.
3.1 PESTICIDE USE
The p include use of two new herbicidal active ingredients
triclopyr BEE (Garlon 4 Ultra) and triclopyr TEA (Capstone) and one new insecticidal active ingredient
prallethrin (PT Wasp-Freeze II) on District lands.
The pyridine herbicides triclopyr BEE and triclopyr TEA are derived from triclopyr acid and used to control
annual and perennial broadleaf weeds and woody plants in agricultural and nonagricultural areas (Capstone
Label, 2015; Garlon 4 Ultra Label, 2008). Both active ingredients act as plant growth regulators that
function by mimicking the auxin growth hormone in plants and disrupting normal plant growth. Triclopyr BEE
and triclopyr TEA are both selective, post-emergent, systemic herbicides; however, triclopyr TEA may also be
used as a pre-emergent herbicide and is labeled for use near water. Note that the triclopyr TEA product
intended to be used by the District, Capstone, contains both triclopyr TEA and aminopyralid TIPA. In contrast,
triclopyr TEA is the sole active ingredient in products such as Garlon ® 3A. When the use of Capstone is
considered, information on both triclopyr TEA and aminopyralid should be reviewed. The District intends to
apply Garlon 4 Ultra via spot spray, cut-stump, and basal bark treatment, and Capstone via spot spray, cut-
stump, and frill/injection. Note that aminopyralid was previously evaluated in the 2014 EIR.
Prallethrin is a synthetic pyrethroid insecticide used to control bees, hornets, yellowjackets, spiders, and
wasps. In agricultural settings, prallethrin is registered for use for applications over, near, and around
agricultural areas as a wide-area mosquito adulticide (USEPA, 2014). Prallethrin causes paralysis in insects
by modulating sodium channels and disrupting nerve impulses. The District intends to use PT Wasp-Freeze II
as needed and in a manner similar to its current use of PT Wasp-Freeze (i.e., via aerosol spray). It would only
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
18 Midpeninsula Regional Open Space District
be used if the insects are a health and safety risk to District employees or the public. The previously
approved product PT Wasp-Freeze would no longer be used under the IPMP.
Pesticide application methods proposed for use under the IPMP include:
Basal bark application: Using this treatment method, an oil mixture containing herbicide would be
applied to the lower 12 to 15 inches of brush and tree trunks (including the entire stem, root collar area,
and exposed roots) via low-pressure backpack sprayer. This method would be used to selectively control
woody plants with basal stems less than six inches in diameter.
Wick application: A wick or rope would be saturated in herbicide and attached to a reservoir containing a
concentrated herbicide solution. The wick or rope is used to wipe herbicide directly onto target plants,
typically weeds that are taller than surrounding non-target plants. Wick applicators may range in size
from hand-held to truck-mounted.
Frill/injection application: A drill or sharp tool such as a hatchet would be used to create holes or cuts
through the exterior bark of a tree and into the sapwood. Each penetration point into the sapwood is
then filled with the label-recommended amount of concentrated herbicide solution using an injection
system, squirt bottle, or brush. This application method is often used for the control of trees that cannot
be managed via basal bark application.
All proposed pesticide uses would occur within previously treated land within District boundaries. Refer to
Table 3 for a summary of modes of action and intended purposes of active ingredients already in use and
proposed for use under the IPMP. The proposed pesticides are similar in both mode of action and purpose to
pesticides already in use by the District. The additional proposed pesticide application methods do not differ
substantially from methods used by the District and approved by the 2014 EIR.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 19
Table 3.
Pesticide
Category
Active
Ingredient
Product Formulations
(Manufacturer) Mode of Action Purpose
Adjuvants/
Surfactants
Alcohol
Ethoxylate
Liberate®
(Loveland Products, Inc.)
Enhances uptake of herbicides
and pesticides
Increase delivery and efficacy of
pesticides to targets
Alkylphenol
Ethoxylate
Pentra-Bark®
(Quest) Enhances uptake of Agri-Fos Increase delivery of Agri-Fos to trees
Lecithin Liberate
(Loveland Products, Inc.)
Enhances uptake of herbicides
and pesticides
Increase delivery and efficacy of
pesticides to targets
Canola Oil,
Ethyl and
Methyl Esters
Competitor®
(Wilbur-Ellis)
Decrease surface tension,
increase herbicide uptake,
enhance wetting and spreading
Increase delivery and efficacy of
pesticides to targets
Fungicides Phosphite K
Salts, mono-/di-
Agri-Fos®
(AgBio)
Fungal oxidative
phosphorylation inhibitor Prevents sudden oak death
Herbicides
Aminopyralid
TIPA
Milestone
(Dow AgroSciences) Auxin growth hormone mimic Nonselective post-emergent broad-
spectrum weed control
Clethodim Envoy PlusTM
(Valent) Fatty acid synthesis inhibitor Selective post-emergent grass weed
control
Clopyralid MEA Transline
(Dow AgroSciences) Auxin growth hormone mimic Selective broadleaf weed control
Glyphosate IPA Roundup Custom
(Monsanto) Amino acid synthesis inhibitor Nonselective post-emergent broad-
spectrum weed and tree control
Glyphosate K Roundup ProMax
(Monsanto) Amino acid synthesis inhibitor Nonselective post-emergent broad-
spectrum weed and tree control
Imazapyr IPA Polaris (Nufarm),
Stalker® (BASF) Amino acid synthesis inhibitor Nonselective pre-and post-emergent
broad-spectrum weed and tree control
Triclopyr BEE Garlon 4 Ultra
(Dow AgroSciences) Auxin growth hormone mimic Selective post-emergent woody plant,
broadleaf weed, and tree control
Triclopyr TEA Capstone
(Dow AgroSciences) Auxin growth hormone mimic
Selective pre- and post-emergent
broadleaf weed, woody plant, and tree
control
Insecticides
Diatomaceous
Earth Diatomaceous Earth Water balance disruptor Structural pest control (e.g., ants,
cockroaches)
D-trans Allethrin PT Wasp-Freeze
(BASF)
Voltage-gated sodium channel
interference Wasp and hornet control
Fipronil Maxforce® Bait Stations
(Bayer)
GABA-gated chloride channel
blocker Ant control
Indoxacarb Advion® Gel Baits
(DuPont) Sodium channel blocker Structural pest control (e.g., ants,
cockroaches)
Phenothrin PT Wasp-Freeze
(BASF)
Voltage-gated sodium channel
interference Wasp and hornet control
Prallethrin PT Wasp-Freeze II
(BASF)
Voltage-gated sodium channel
interference Wasp and hornet control
S-Hydroprene Gentrol Point Source®
(Wellmark International) Juvenile growth hormone mimic Pest control (e.g., cockroaches, beetles,
moths)
Sodium
Tetraborate
Decahydrate
Prescription Treatment
Baits (BASF),
Terro® Ant Killer II (Terro)
Water balance disruptor Ant control
Rodenticides Cholecalciferol Cholecalciferol baits Calcification of soft tissues Rodent pest control (e.g., rats, mice)
3.2 BEST MANAGEMENT PRACTICES AND MITIGATION MEASURES
The BMPs which appear in Table 3-4 of the EIR have been modified in Table 4 as follows (changes shown in
underline/strikeout):
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
20 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
1
All pesticide use shall be implemented consistent with written Pest Control Recommendations prepared
annually by a licensed Pest Control Advisoer. The Pest Control Adviser shall ensure that all pesticide
applications are performed at the time of year and phenological window for maximum effectiveness, thereby
increasing treatment efficacy and reducing the need for follow-up applications.
2 Surfactants and other A
Recommendations.
3
Applicators shall follow all pesticide label requirements and refer to all other BMPs regarding mandatory
measures to protect sensitive resources and employee and public health during pesticide application. All
District field crew who perform herbicide treatments shall have specialized experience and training in pesticide
safety, IPM principles, and special status species.
4
Pesticide applicators shall have or work under the direction of a person with a Qualified Applicator License
(QAL) or Qualified Applicator Certificate (QAC). As appropriate, the District shall implement QAC certification
requirements for additional field staff to enhance field crew training. Contractors and grazing and agricultural
tenants may apply approved pesticides herbicides after review and approval by the District and under the
direction of QAL/QAC field supervisors. After review and approval by the District and under the direction of
QAL/QAC, contractors may apply approved fungicides to District preserves for the research and control of
Sudden Oak Death (SOD). As needed for the control of mosquitos, cattle grazing rangers may apply District-
approved bacterial pathogens to water troughs in District preserves. Employees, contractors and tenants may
install approved ant and roach bait stations inside buildings in tamper-proof containers without review by a
QAL/QAC. Tenants may not use rodenticides; only qualified District staff or District contractors may use
approved rodenticides and these should only be used in the event of an urgent human health issue, in a
manner consistent with the product label, and in anchored, tamper-proof containers inside buildings.
5
All storage, loading and mixing of pesticides shall be set back at least 300 feet from any aquatic feature or
special-status species or their habitat or sensitive natural communities. Applicators shall use an air gap or anti-
siphon device to prevent backflow while loading. All mixing and transferring shall occur within a contained area.
Any transfer or mixing on the ground shall be within containment pans or over protective tarps and away from
drain inlets, culverts, wells, areas with porous or erosion-prone soil, or other features that may allow for runoff.
6
As deemed necessary by the Pest Control Adviser, QAL, or QAC, Aappropriate, non-toxic colorants or dyes shall
be added to the herbicide mixture to determine treated areas and prevent over-spraying, particularly in public
areas.
7
Application Requirements - The following general application parameters shall be employed during herbicide
pesticide application:
Application shall cease when weather parameters exceed label specifications, when wind at site of
application exceeds 7 miles per hour (MPH), or when precipitation (rain) occurs or is forecasted with
greater than a 40 percent probability in the next 24-hour period to prevent sediment and herbicides
from entering the loss of efficacy and lessen the potential for pesticides to enter surface water via
surface runoff;
All restrictions and limitations, including those on irrigation, cultivation, re-entry, etc., as described on
the pesticide product label shall be followed for sites treated with pesticides;
Spray nozzles shall be configured to produce a relatively large droplet size;
Low nozzle pressures (30-70 pounds per square inch [PSI]) shall be observed;
Spray nozzles shall be kept within 24 inches of vegetation during spraying;
Application equipment shall be calibrated periodically per manufacturer specifications or frequently
enough such that equipment is applying pesticides according to label directions;
Drift and overspray avoidance measures shall be used to prevent drift in all locations. Particular
attention shall be paid to areas where target weeds and pests are in proximity to special-status species
or their habitat. Such measures can consist of, but would not be limited to the use of plastic shields
around target weeds and pests and adjusting the spray nozzles of application equipment to limit the
spray area selecting and using appropriate spray nozzles and pressures. Spray areas may also be
limited by using application methods such as spot treatments and thin line treatments of one-inch wide
or less.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 21
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
Due to the potential presence of temperature inversion layers, no spraying shall be conducted on
8
Notification of Pesticide Application Signs shall be posted notifying the public, employees, and contractors of
signal word, product name,
signal word, and manufacturer, active ingredient,; and EPA registration number; target pest; preserve name;
treatment location in preserve; date and time of application; date which notification sign may be removed; and
contact person with telephone number. Signs shall generally be posted 24 hours before the start of treatment
and notification shall remain in place for 72 hours after treatment ceases. In no event shall a sign be in place
longer than 14 days without dates being updated. See the IPM Guidance Manual for details on posting
locations, posting for pesticide use in buildings and for exceptions.
9
Disposal of Pesticide Containers Disposal Cleanup of all herbicide pesticide and adjuvant containers shall
follow the product label and local waste disposal regulations. This generally consists of be triple rinsing with
clean water at an approved site and the rinsate shall be disposed of by placing it in adding the rinsate to the
batch tank for application. Used containers shall be punctured on the top and bottom to render them unusable,
wed. Disposal of non-recyclable containers shall be at legal dumpsites.
Equipment shall not be cleaned and personnel shall not bathe in a manner that allows contaminated water to
directly enter any body of water within the treatment areas or adjacent watersheds. Disposal of all pesticide
containers shall follow label requirements and local waste disposal regulations.
10
All appropriate laws and regulations pertaining to the use of pesticides and safety standards for employees and
the public, as governed by the U.S. Environmental Protection Agency, the California Department of Pesticide
Regulation, and local jurisdictions shall be followed. All applications shall adhere to label directions for
application rates and methods, storage, transportation, mixing, and container disposal. All contracted
applicators shall be appropriately licensed by the state. District staff shall coordinate with the County
Agricultural Commissioners, and all required licenses and permits shall be obtained prior to pesticide
application.
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.
12 All staff, contractors, and volunteers shall be properly trained to prevent spreading weeds and pests to other
sites.
13 District staff shall appropriately maintain facilities where tools, equipment, and vehicles are stored free from
invasive plants.
14 District 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.
15 Suitable onsite disposal areas shall be identified to prevent the spread of weed seeds.
16
Invasive plant material shall be rendered nonviable when being retained onsite. Staff shall desiccate or
decompose plant material until it is nonviable (partially decomposed, very slimy, or brittle). Depending on the
type of plant, disposed plant material can be left out in the open as long as roots are not in contact with moist
soil, or can be covered with a tarp to prevent material from blowing or washing away.
17 District staff shall monitor all sites where invasive plant material is disposed on-site and treat any newly
emerged invasive plants.
18
When transporting invasive plant material off-site for disposal, the plant material shall be contained in enclosed
bins, heavy-duty bags, or a securely covered truck bed. All vehicles used to transport invasive plant material
shall be cleaned after each use.
19
Aquatic Areas Shortly before treatment, Aa District-approved qualified biologist or other District-approved
personnel shall survey allthe treatment sites prior to work to determine whether any aquatic features are
located onsite. In addition, oOn a repeating basis, grassland treatment sites shall be surveyed once every five
years and brushy and wooded sites shall be surveyed by a District-approved biologist once every five years.
Brush removal on rangelands will require biological surveys before work is conducted in any year. Aquatic
features are defined as any natural or manmade lake, pond, river, creek, drainage way, ditch, spring, saturated
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
22 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
soils, or similar feature that holds water at the time of treatment or typically becomes inundated during winter
rains. Treatment sites are defined as areas where IPM activity, including manual, mechanical, and chemical
treatment, is expected to occur. If during the survey it is found that aquatic features are present within 15 feet
of the proposed treatment area, the District shall either eliminate all treatment activities within 15 feet of the
aquatic feature from the project (i.e. do not implement treatment actions in those areas) or if the District
chooses to continue treatment actions in these areas, it shall use pesticides and adjuvants labeled for aquatic
use and follow the requirements of the mitigation measure for special-status wildlife species and the CDFW
Streambed Alteration Agreement.
20
Application of herbicides pesticides shall be conducted in accordance with the California Red-Legged Frog
Injunction (Center For Biological Diversity v. U.S. Environmental Protection Agency (2006) Case No.: 02-1580-
JSW) in known or potential California red-legged frog habitat specifically by: not applying specified pesticides
within 15 feet of aquatic features (including areas that are wet at time of spraying or areas that are dry at time
of spraying but subsequently might be wet during the next winter season); utilizing only spot-spraying
techniques and equipment by a certified applicator or person working under the direct supervision of a certified
applicator; and not spraying during precipitation or if precipitation is forecast to occur within 24 hours before or
after the proposed application. Preserves in which these precautions must be undertaken are: Miramontes
Ridge, Purisima Creek Redwoods, El Corte de Madera, La Honda Creek, Picchetti Ranch, Russian Ridge, Sierra
Azul, Tunitas Creek, Skyline Ridge, Rancho San Antonio, Monte Bello and Coal Creek OSPs and Toto Ranch.
21
A District-approved biologist shall survey all selected treatment sites prior to 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 District-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 District 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.
22
Nesting Birds - For all IPM activities that could result in potential noise and other land disturbances that could
affect nesting birds (e.g., tree removal, mowing during nesting season, mastication, brush removal on
rangelands), treatment sites shall be surveyed within two weeks prior to initiating activity to evaluate the
potential for nesting birds. Tree removal will be limited, whenever feasible, based on the presence or absence
of nesting birds. For all other treatments, if birds exhibiting nesting behavior are found within the treatment
sites during the bird nesting season: March 15 August 30 for smaller bird species such as passerines and
February 15 - August 30 for raptors, impacts on nesting birds will be avoided by the establishment of
appropriate buffers around active nests. The distance of the protective buffers surrounding each active nest
site are: 500 1,000 feet for large raptors such as buteos, 250 500 feet for small raptors such as accipiters,
and 250 feet for passerines. The size of the buffer may be adjusted by a District biologist in consultation with
CDFW and USFWS depending on site specific conditions. Monitoring of the nest by a District biologist during
and after treatment activities will be required if the activity has potential to adversely affect the nest. These
areas can be subsequently treated after a District biologist or designated biological monitor confirms that the
young have fully fledged, are no longer being fed by the parents and have left the nest site. For IPM activities
that clearly would not have adverse impacts to nesting birds (e.g. treatments in buildings and spot spraying with
herbicides), no survey for nesting birds would be required.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 23
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
23
San Francisco dusky-footed woodrat and Santa Cruz kangaroo rat All District staff, volunteers or contractors
who will implement treatment actions shall receive training from a qualified biologist on the identification of
dusky-footed woodrat, Santa Cruz kangaroo rat, and their nests or burrows. Generally, all San Francisco dusky-
footed woodrat and their nests, and Santa Cruz kangaroo rat and their burrows nests will be avoided and left
undisturbed by proposed work activities. If a nest site or burrow will be affected, the District will consult with
CDFW. Rodenticides, snap traps, and glue boards shall not be used in buildings within 100 feet of active San
Francisco dusky-footed woodrat nests or Santa Cruz kangaroo rat nests burrows; instead rodent control in
these areas will be limited to non-lethal exclusion and relocation activities including relocation of nests if
approved by CDFW. Tenants will contact the District for assistance in managing rat populations in buildings and
under no circumstances will be allowed to use rodenticides.
24 Where appropriate, equipment modifications, mowing patterns, and buffer strips shall be incorporated into
manual treatment methods to avoid disturbance of grassland wildlife.
25
Rare Plants Shortly before treatment, aAll selected treatment sites shall be surveyed by District-approved
personnel with environmental awareness training (BMP #20) prior to work to determine the potential presence
of special-status plants. Rare plant surveys shall also be conducted during the appropriate season to assess
the occurrence, if any, of dormant or overwintering plant species that may not be visible during the pre-
treatment survey. If special-status plants are reported, information such as species and location shall be
uploaded into an electronic inventory system and a biomonitor shall be present to oversee the planned IPM
treatment. On a repeating basis, grassland treatment sites shall be surveyed by a District-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. Treatment sites are defined as
areas where IPM activity, including manual, mechanical, and chemical treatment, is expected to occur. A 1530-
foot buffer shall be established from special-status plants. No application of herbicides shall be allowed within
this buffer. Non-herbicide methods can be used within 1530 feet of rare plants but they shall be designed to
avoid damage to the rare plants (e.g., pulling).
26
Cultural Resources District staff, volunteer crew leaders, and contractors implementing treatment activities
shall receive training on the protection of sensitive archaeological, paleontological, or historic resources (e.g.,
projectile points, bowls, baskets, historic bottles, cans, trash deposits, or structures). In the event volunteers
would be working in locations with potential cultural resources, staff shall provide instruction to protect and
report any previously undiscovered cultural artifacts that might be uncovered during hand-digging activities. If
archaeological or paleontological resources are encountered on a treatment site and the treatment method
consists of physical disturbance of land surfaces (e.g., mowing, brush cutting, pulling, or digging), work shall
avoid these areas or shall not commence until the significance of the find can be evaluated by a qualified
archeologist. This measure is consistent with federal guidelines 36 CFR 800.13(a), which protects such
resources in the event of unanticipated discovery.
27
Post-Treatment Monitoring District staff shall monitor IPM activities within two months after herbicide
treatment (except for routine minor maintenance activities which can be evaluated immediately after
treatment) to determine if the target pest or weeds were effectively controlled with minimum effect impact to
the environment and non-target organisms. Future treatment methods in the same season or future years shall
be designed to respond to changes in site conditions.
28
Erosion Control and Revegetation - For sites with loose or unstable soils, steep slopes (greater than 30
percent), where a large percentage of the groundcover will be removed, or near aquatic features that could be
adversely affected by an influx of sediment, erosion control measures shall be implemented before or after
treatment as appropriate. These measures could consist of the application of forest duff or mulches, straw
bales, straw wattles, other erosion control material, seeding, or planting of appropriate native plant species to
control erosion, restore natural areas, and prevent the spread or reestablishment of weeds. Prior to the start of
the winter storm season, these sites shall be inspected to confirm that erosion control techniques are still
effective. When possible, applicators may select vegetation control techniques select herbicides to maintain
sufficient vegetative cover to mitigate erosion.
29
Operation of noise-generating equipment (e.g., chainsaws, wood chippers, brush-cutters, pick-up trucks) shall
abide by the time-of-day restrictions established by the applicable local jurisdiction (i.e., City and/or County) if
such noise activities would be audible to receptors (e.g., residential land uses, schools, hospitals, places of
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
24 Midpeninsula Regional Open Space District
Table 4. District BMPs for IPMP
BMP ID# Best Management Practices
worship) located in the applicable local jurisdiction. If the local, applicable jurisdiction does not have a noise
ordinance or policy restricting the time-of-day when noise-generating activity can occur, then the noise-
generating activity shall be limited to two hours after sunrise and two hours before sunset, generally Monday
through Friday. Additionally, if noise-generating activity would take place on a site that spans over multiple
jurisdictions, then the most stringent noise restriction, as described in this BMP or in a local noise regulation,
would apply.
(see attachment) if noise-generating activities would occur during its breeding season (March 24 to September
15), the IPM activities would be subject to the noise requirements listed in the most current in the CDFW RMA
issued to the District (see attachment).
30 All motorized equipment shall be shut down when not in use. Idling of eEquipment and off-highway vehicles
idling will be limited to 5 minutes.
31 Grazing Animals Some herbicides, such as Milestone, Transline, and Capstone contain label language
restricting grazing and/or use of compost. Always read and follow label directions.
32
Surface and Groundwater Protection Applicators shall use BMPs regarding the prevention of drift, runoff,
erosion, and water quality impairment. All work shall be in compliance with the 3 CCR § 6800 (Groundwater
Protection). When possible, plant covers such as landscaping shall be established on bare soil and hillsides to
minimize pesticide and sediment runoff. Pesticides without an aquatic label shall not be applied to: 1)
permeable soils, soils prone to or with evidence of erosion without containment strategies (e.g., vegetative
buffers, sediment barriers); or 2) in areas where aquatic habitats are located within 15 feet of the application
site. In no cases should pesticides be applied to surface water bodies unless appropriate permits are obtained.
33
Application of glyphosate and cholecalciferol shall be conducted in accordance with the Goby -11 Injunction
(Center for Biological Diversity v. EPA, Case No. 07-2794-JCS (N.D. Cal.), May 30, 2007) in applicable and
relevant habitats for those species named in the Injunction that occur within the District. Applicable habitats for
each species named in the Injunction are defined in the 2010 court order for the Center for Biological Diversity
v. EPA. Because the interim protective measures (i.e., no-use buffer zones adjacent to certain features within
certain geographic areas) established in the 2010 order vary depending on the species at issue and the
pesticide being used, the USEPA webpage should be consulted: https://www.epa.gov/endangered-
species/interim-use-limitations-eleven-threatened-or-endangered-species-san-francisco-bay. In addition, District
internal special status species mapping resources, buffer zones established on the CNDDB webpage, and an
interactive species location map (https://www.epa.gov/endangered-species/san-francisco-bay-area-map-tool-
identify-interim-pesticide-use-limitations) should be consulted. The interim use limitations remain in effects until
USEPA completes effects determinations for four pesticides named under the 2015 revised settlement
agreement for the Center for Biological Diversity v. EPA. The effects determinations are expected to be
completed by 2020.
34
Glyphosate Use Reduction Where feasible, the District shall reduce the use of glyphosate in its preserves. For
IPM projects currently utilizing glyphosate as a management tool, the District shall identify suitable sites to
implement alternative treatment methods. The District shall seek to replace glyphosate with the safest
available, broad-spectrum, post-emergent herbicide with minimal residual soil activity.
35 Trails To reduce potential staff and visitor exposure to pesticides, no-spray trail buffers shall be established at
least 5 feet from any trails, trailheads, or parking lots unless a 24-hour trail closure is observed.
36
Annual Pesticide Literature Review To inform updates to the IPM Program, the District shall conduct an
annual pesticide literature review of all newly published toxicological research and court proceedings related to
In addition, the Mitigation Measure 4.2-1a has been modified because the list of Species of Special
Concern, for which the mitigation measure was intended to be all-inclusive, is no longer accurate in light of
the listing of California giant salamander, and Santa Cruz black salamander (changes shown in
underline/strikeout):
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 25
Mitigation Measure 4.2-1a: Mitigation for impacts to special-status amphibian and reptile species
(California red-legged frog, foothill yellow-legged frog, northern western pond turtle, San Francisco
garter snake, California tiger salamander, California giant salamander, Santa Cruz black
salamander).
Prior to conducting any mechanical or chemical IPM treatments in an area that is both federally
designated critical habitat and suitable aquatic habitat for California red-legged frog, foothill yellow-
legged frog, northern western pond turtle, San Francisco garter snake, or California tiger
salamander, the District will consult with the USFWS and CDFW as appropriate pursuant to
ESA/CESA. Appropriate measures will be developed in consultation with USFWS and CDFW to ensure
there is no loss of critical habitat for these species, or that unavoidable loss of critical habitat will be
replaced through habitat enhancement or restoration. Such measures may include avoidance of
breeding habitat, limiting activities to manual removal of vegetation, conducting activities outside the
breeding season, or relocation and mitigation.
Prior to conducting any mechanical or chemical IPM treatments within 15 feet of occupied habitat for
California red-legged frog, foothill yellow-legged frog, northern western pond turtle, San Francisco
garter snake, California tiger salamander, California giant salamander, or Santa Cruz black
salamander, the District will consult with USFWS and CDFW. Appropriate measures will be developed
in consultation with USFWS and CDFW to ensure there is no take of these species, or that
unavoidable take is fully compensated for through habitat enhancement or restoration activities, or
purchase of mitigation credits. Shooting, trapping, and gigging of aquatic species will be conducted
only by a qualified biologist with experience in the identification of frog and turtle species.
Inadvertently trapped California red-legged frogs, foothill yellow-legged frogs or northern western
pond turtles will be released immediately upon discovery.
If permanent loss of federally designated critical habitat cannot be avoided, compensation will be
provided through protection and enhancement of habitat within the District open space, purchase of
offsite mitigation credits, and/or contribution to regional conservation and recovery efforts for the
species as determined in consultation with the USFWS and CDFW.
3.3 SPECIES OF SPECIAL CONCERN
Changed circumstances under which would be implemented include two salamanders
recently listed by CDFW as Species of Special Concern: the California giant salamander and the Santa Cruz
black salamander (CDFW, 2017).
California giant salamanders can be found in north-central California, primarily in or near streams within
humid coastal forests with Douglas fir, redwood, red fir, and montane and valley-foothill riparian habitats
(CDFW, 1997). Within these habitats, California giant salamanders are often found hiding between
streambed rocks, under fallen leaves, or in underground burrows. Terrestrial adults feed on invertebrates
such as snails and slugs and small vertebrates such as mice. In aquatic habitats, adults and larvae may prey
on aquatic invertebrates, fish, and other amphibians. California giant salamanders breed in spring and lay
eggs in concealed locations within cold, slow-flowing streams (CDFW, 1997; Nussbaum and Clothier, 1973).
Aquatic larvae transform to terrestrial adults one to two years after hatching (Nussbaum and Clothier, 1973).
California giant salamanders are primarily nocturnal (CDFW, 1997).
The terrestrial Santa Cruz black salamanders occur in the mesic forests and woodlands of the Santa Cruz
Mountains in western Santa Clara, northern Santa Cruz, and southern San Mateo Counties (Thomson et al.,
2016). They are often found in shallow standing water or seeps within moist streamside microhabitats. They
have been seen under stones along stream edges and in talus formations or rock rubble. No information is
available on the feeding behavior of Santa Cruz black salamanders; however, they are presumed to be
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
26 Midpeninsula Regional Open Space District
generalized predators of small arthropods and other invertebrates. Females lay eggs underground during the
summer and stay with eggs until they hatch.
While the 2014 EIR evaluated potential impacts to biological resources from the perspective of habitat
modification, the current analysis would also consider direct effects that both proposed and existing
pesticides in the IPMP have on special status species or their surrogates by evaluating risk as it relates to
toxicity and exposure. The California giant salamander and Santa Cruz black salamander have similar diets,
habitats, and distribution as the California tiger salamander, which was included in the 2014 EIR analysis.
Table 5 provides a comparison of various characteristics of the salamander species known to occur on
District lands.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 27
Table 5. Comparison of District Salamander Species
Characteristics California Tiger Salamander
()
Santa Cruz Black Salamander
()
California Giant Salamander
()
Life Stages Eggs hatch in ~10-14 d. Larvae
require significantly more time to
transform into juveniles than
other amphibians. Around late
spring, salamanders leave the
ponds to find burrows. Adults
reach sexual maturity in 4-5 yr.
They are large and stocky with a
broad, rounded snout. They are
black in color with white or pale
yellow spots.
Little is published on the
ecological and life history of this
species. Eggs undergo direct
development, and fully formed
juveniles appear at the surface
shortly after the onset of fall
rains, often in October or
November. Juveniles have
brassy dorsal coloration with
white or light blue spots. Adults
are either solid black or black
with a few small white flecks.
The larval stage lasts ~18 mo.
Larval dorsal coloration is light
brown with a pale eye strip behind
each eye. Larvae reach 10 cm
within a year of hatching and
metamorphose in late summer.
Adults are tan to light reddish
brown with coppery tan to dark
brown irregular marbling. Marbling
coloration is often brighter in young
metamorphs than in adults.
Diet Adults mostly eat insects. Larvae
eat things such as algae,
mosquito larvae, tadpoles and
insects.
No diet information has been
published. It is presumed that
this species is a generalized
predator of small arthropods and
other invertebrates.
Adults feed on vertebrates such as
other salamanders, lizards, mice,
shrews, and voles, and
invertebrates such as land snails,
beetles, and crickets. Larvae are
presumed to consume aquatic
insects and other invertebrates.
Habitat Restricted to vernal pools and
seasonal ponds, including many
constructed stock ponds, in
grassland and oak savannah
plant communities,
predominantly from sea level to
2,000 ft. Prefer natural
ephemeral pools or ponds that
mimic them. Live underground,
using burrows made by
burrowing mammals.
Restricted to mesic forests in the
fog belt of the outer Coast
Range. Occur in moist
streamside microhabitats and
found in shallow standing water
or seeps, under stones along
stream edges and boards near
creeks. Also occur in talus
formations or rock rubble. Spend
the majority of time
underground.
Occur in mesic coastal forests (oak
woodland and coniferous forest)
and coastal chaparral habitats.
Adults are occasionally found
surface active or under cover
objects in wet conditions.
Travel/Activity Enter a dormant state called
estivation during the dry months.
They come out of their burrow
around November. Nocturnal.
Most active on the surface at
night, and more so during rain
events.
Primarily nocturnal, but may also
be active during daytime. Most
active during rain events.
Breeding Emerge from burrows for pond
breeding in November,
commonly during heavy rainfall.
Females lay as many as 1,300
eggs, singly or in small groups.
Eggs are usually attached to
vegetation.
Females lay eggs underground in
July or early August.
Breeding and larval development
occur in cold permanent and semi
permanent streams during the
rainy season and in the spring.
Females lay eggs during spring and
likely guard nests through hatching.
Distribution Scattered in the Coastal region
from Sonoma Co. in the northern
San Francisco Bay Area to Santa
Barbara Co. up to 3,500 ft in
elevation, and in the Central
Valley and Sierra Nevada foothills
from Yolo to Kern Co. up to
2,000 ft in elevation.
Endemic to CA and have a small
range in the woodlands of the
Santa Cruz Mts in western Santa
Clara, northern Santa Cruz, and
southernmost San Mateo Co.
Occur from Sonoma Co. north
along the coast into
southwestern Oregon and east
to Shasta Co.
Endemic to CA, occupying a small
range from sea level to 3,000 ft in
elevation along the coast in two
isolated areas near San Francisco
Bay. South of the Bay, they occur in
the Santa Cruz Mts in San Mateo,
Santa Clara, and Santa Cruz Co.
Sources: CDFW, 1997; Thomson et al., 2016; USEPA, 2010; USFWS, 2009, 2017
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
28 Midpeninsula Regional Open Space District
4 ENVIRONMENTAL CONSEQUENCES OF
PROPOSED PROJECT MODIFICATIONS
This addendum is intended to provide CEQA compliance for proposed modifications and changed
circumstances related to the project evaluated in the approved 2014 EIR. This addendum is organized by
environmental issue area and is intended to consider all environmental topic areas that could be affected by
modifications to the project description and/or any changes in circumstances, as compared to the approved
2014 EIR, and determine whether such modifications/changes would result in new significant impacts.
The purpose of this discussion below is to evaluate the environmental issue areas in terms of any changed
condition (i.e., changed circumstances, project changes, or new information of substantial importance) that
may result in a different environmental impact significance conclusion from the certified 2014 EIR. Each
resource issue area is addressed below.
4.1 AESTHETICS
The 2014 EIR identified less than significant impacts associated with impacts on scenic vistas, changes in
visual character, and damage to scenic resources within a state scenic highway corridor. The EIR identified
no impacts associated with nighttime lighting.
Project modifications do not include nighttime work and would not create any new impacts associated with
nighttime lighting. Control of insects using prallethrin (PT Wasp-Freeze II) would primarily take place in
recreational areas. Treatment would allow greater access to scenic views because it would allow trails and
recreational areas to remain safe and open to the public.
Basal bark application of herbicides to control vegetation would take place in natural lands and around
agricultural areas and rangelands. The applications would be of same general type and scale (e.g.,
backpack, ATV, truck) as other IPM methods analyzed in the 2014 EIR and would be short-term in nature.
Use of wick or frill/injection herbicide application techniques would occur in recreational areas, rangelands,
and natural lands. These applications would be of similar scale and type as those analyzed in the 2014 EIR.
These application techniques would not result in erosion or create changes that detract from scenic vistas or
substantially alter the landscape. Use of herbicides to control vegetation would benefit visual resources by
eliminating invasive vegetation that encroaches on recreational facilities and detracts from natural
landscapes.
Based on the above discussion, the project modifications evaluated in this proposed Addendum are visually
consistent with the project as proposed in the 2014 EIR. There would be no new significant effects
compared to the environmental evaluation of aesthetic resources provided in the approved 2014 EIR as a
result of implementation of the proposed project modifications.
4.2 AGRICULTURE AND FORESTRY RESOURCES
As discussed in Chapter 1 of the 2014 EIR (Draft EIR, p. 1-2), the pest management actions that would
result from implementation of the IPMP on District lands would not result in conversion of important
farmland to non-agricultural uses or cause changes that would result in the conversion of important
farmland. Farmlands that are currently managed and leased by the District would continue similar
operations with implementation of the project. Similarly, the IPMP would not and does not result in the loss
of forest land or convert forestry land to non-forestry use. Similarly, the proposed project modifications would
not convert agricultural or forestry uses and would therefore have no impact on these resources and would
result in no change to conclusions of the 2014 EIR.
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 29
4.3 AIR QUALITYAND GREENHOUSE GAS EMISSIONS
The 2014 EIR found that result in any short-term
construction-related emissions of criteria air pollutants or precursors of greenhouse gases because the
program does not involve construction activities. Additionally, because of the nature of IPMP activities and
the fact that similar IPM activities were and are continuing to be performed within District boundaries, the
2014 EIR found that there would be no increase in operational emissions that would result in violation of air
quality plans or standards. The project similarly did not result in an increase in staff commuting to and from
work sites. The 2014 EIR found that any air quality impacts would be less than significant.
The proposed modifications would increase the use of manual and mechanical IPM methods in fuel
management areas from 136 acres to 140 acres, and would increase the use of manual and mechanical
IPM methods in natural lands from 2 to 10 acres. In the fuel management areas, this would include the use
of small power tools such as mowers and brushcutters as well as larger equipment such as tractors and
masticators. In natural areas, activities would be conducted primarily using small power tools. If needed,
larger tools such as masticators would be used for less than 1% of treatment areas. The increases in
acreage for both natural lands and fuel management areas would result in the increased use of the small
power tools, rather than larger equipment used for masticators, such as tractors, excavators or dozers. The
2014 EIR discussed the use of all of these types of equipment for use as part of the IPMP (see Draft EIR, pp
3-26, 3-27). The 2014 EIR found that the use of these types of equipment would not result in significant
impacts on air quality. The proposed modifications represent only a minor increase in the overall use of
small power tools in natural lands and fuel management areas, which would not be considered a new effect
or a substantial increase in a previously identified effect.
The proposed modifications would not result in new or more severe impacts to air quality because the
activities are fundamentally the same as those being performed under the existing program, and would not
lead to an increase in the extent or intensity of emission-generating activities. The modifications in
chemicals used for chemical control, and differences in application procedures do not result in any
significant impacts to air quality.
4.4 BIOLOGICAL RESOURCES
The 2014 EIR identified potentially significant impacts to special status wildlife species as a result of the
IPMP. Specifically, manual and mechanical treatment methods in buildings would affect special-status bats
through inadvertent trapping, or removal of habitat if buildings are demolished, resulting in a potentially
significant impact. Manual and mechanical treatments for recreational facilities, for fuel management areas,
in rangelands and agricultural properties, and in natural lands would result in potentially significant impacts
to central California coast coho salmon ESU, central California coast steelhead DPS, tidewater goby,
California red-legged frog, foothill yellow-legged frog, California tiger salamander, San Francisco gartersnake,
and northern western pond turtle through removal of egg masses and larva, conversion of aquatic habitat, or
removal of food sources. The 2014 EIR also found that pesticide use for recreational facilities, for fuel
management areas, in rangelands and agricultural properties, and in natural lands could result in the loss of
host plants, and the direct mortality of larva and individuals of bay checkerspot butterfly, callippe silverspot
-winged grasshopper and would result in a potentially
significant impact. These impacts would be reduced to a less-than-significant level with implementation of
Mitigation Measures 4.2.1a through 4.2.1d, and the proposed changes to the project would not alter these
conclusions.
The 2014 EIR also found that alterations to the hydrology of ponds, including the conversion of ponds to
ephemeral wetlands, would result in a change in wetland type and acreage would have a potentially
significant impact on federally protected wetlands. Pesticide use in recreational facilities, fuel management
areas, rangelands and agricultural properties, and natural lands occurring adjacent to or within wetlands
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
30 Midpeninsula Regional Open Space District
could results in the discharge of pollutants (sediment, herbicides) to wetlands and would also be a
potentially significant impact. These impacts would be reduced to a less-than-significant level with
implementation of Mitigation Measure 4.2.3, and the proposed changes to the project would not alter these
conclusions.
The EIR found that there would be less than significant impacts to riparian habitat or sensitive natural
communities, or to the movement of native residents or migratory fish or wildlife species. There would also
be no conflict with local policies or ordinances protecting biological resources or with any habitat
conservation plan. The proposed changes to the project would not alter these conclusions.
As described in Section 3 of this Addendum, the proposed modifications to the IPMP include three additional
modes of pesticide application and three additional pesticides. The three additional modes of herbicide
application, basal bark application, wick application, and frill/injection would not differ substantially from
application methods examined in the 2014 EIR. In basal bark applications, an herbicide would be applied to
the lower 12 to 15 inches of brush and tree trunks via low-pressure backpack sprayer. Wick application
would consist of direct application herbicide using a rope wick. Frill/injection application would involve
making a cut or hole in the target plant or tree using hand tools, and applying herbicide to the cut using an
injection system, squirt bottle, or brush. The 2014 EIR examined potential effects to biological resources as
a result of other IPM measures, including mowing and brush cutting with motorized equipment including
mowers and chainsaws, green flaming with propane torches, herbicide spray applications using backpacks
or ATVs with mounted tanks and hose sprayers. The 2014 EIR found that with implementation of the
mitigation measures, there would be no significant impacts on biological resources. Because the IPM
methods included in the proposed modifications are substantially similar to the methods in the approved
project, there would be no new or substantially different impacts.
As described in Section 3, the District also proposes to modify the IPMP to expand the annual use of manual
and mechanical treatment types in natural lands, including the use of pole pruner, chainsaws, chippers, and
jawz implements, from 2 acres to 10 acres. If required, larger equipment, such as masticators, may be used
in natural areas for up to 1% of the treatment area. The use of pole pruner, chainsaws, chippers,
masticators, and jawz implements was analyzed in the 2014 EIR. The EIR found that with implementation of
BMPs and mitigation measures, including pre-treatment surveys and buffers for sensitive species and
nesting birds, there would be no significant impacts to biological species. In addition, while the proposed
modifications represent an expansion of acreage that may be treated using manual and mechanical
treatments, the EIR envisioned such expansion. The use of these manual and mechanical treatment types
was approved in the EIR and the proposed modifications would not create any new or substantially different
impacts.
The other proposed modifications and changed circumstances to the IPMP were evaluated in the Screening-
Level Ecological Risk Assessment (SLERA) prepared by Ardea Consulting and Blankinship and Associates
(see Appendix 1). The SLERA evaluated the potential risk for California giant salamanders and Santa Cruz
black salamanders resulting from applications of pesticide active ingredients previously analyzed in the
2014 EIR. The SLERA also evaluated the potential risk to terrestrial and aquatic species following such
The SLERA was conducted by performing a qualitative exposure assessment, which first evaluated the
application sites of the 15 active ingredients that were analyzed in the 2014 EIR to assess the potential for
overlap with the habitat requirements of California giant salamanders and Santa Cruz black salamanders.
The SLERA then considered the application techniques for these same 15 active ingredients to determine
the degree of exposure possible when there was a potential for overlap with the habitat of these salamander
species. When exposure was deemed possible, the SLERA considered toxicity data for salamanders (or
surrogate species) to reach a conclusion about whether the degree of exposure along with the severity of
toxicity could result in a level of risk suggesting potentially significant impacts.
For each of the risk analyses, the SLERA concluded that the use and application of the 15 active ingredients
examined posed either low risk or no risk to the two additional special status species. In some cases, the
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 31
chemicals examined were of very low or practically no toxicity to the salamanders, and therefore posed low
to no risk to the subject species. In other cases, the SLERA found that the species was unlikely to have any
contact with the application site. Therefore, there would be no new or more significant adverse impacts to
California giant salamanders and Santa Cruz black salamanders.
A similar qualitative approach was used in the SLERA to consider the potential for adverse effects following
applications of the three new pesticide active ingredients in the proposed IPMP modifications: triclopyr BEE,
triclopyr TEA, and prallethrin. Since there were only three pesticide active ingredients to consider, the
severity of the toxicity for different taxonomic groups was evaluated first to narrow down those species that
could be harmed if they were exposed following an application. For those species with high sensitivity, the
application sites and application techniques were considered to determine whether the degree of exposure
could be sufficient to produce adverse effects following a pesticide application.
Triclopyr BEE, an herbicide used for vegetation management in natural lands and at the wildland urban
interface, was found to be moderately toxic to aquatic-phase amphibians, moderately toxic to freshwater
aquatic invertebrate species, and highly toxic to freshwater fish. However, the SLERA found that the District
BMPs are designed to greatly reduce, if not eliminate, movement to surface water. Because of this, actual
impacts to aquatic invertebrates or birds and mammals that feed in aquatic habitats are anticipated to be
minimal.
Triclopyr BEE was found to exhibit low toxicity to terrestrial animals and birds and practically nontoxic to
bees. Although there is a greater chance of exposure to herbicides for special-status terrestrial animals, the
low toxicity of the formulation led the SLERA to conclude that terrestrial special-status species are not at risk
from its use.
The herbicide triclopyr TEA is intended for use in rangeland and agricultural properties as a spot spray
treatment. It was found to be practically nontoxic to aquatic-phase amphibians, freshwater aquatic
invertebrate species, freshwater fish, terrestrial-phase amphibians and reptiles, birds, mammals, and bees.
Because of its low toxicity, the SLERA found that there was a low potential for adverse effects from its use.
As noted above, prallethrin is intended for use around buildings and in recreational facilities, primarily for
control of stinging insects such as wasp or yellow jackets. Treatments in recreational facilities could include
treatment of ground nests along hiking trails. Some insecticides exhibit high toxicity to ecological receptors,
mostly aquatic species. However, their restricted uses to in and around buildings limits exposure such that it
can be concluded that adverse impacts will not occur. Because of the targeted nature of prallethrin
applications to stinging insect nests, only those stinging insect species would be directly exposed. Most
insects, such as flying insects, would receive no exposure following an application to a wasp or hornet nest.
Thus, most insects and insectivorous species are anticipated to be exposed to very limited amounts of
prallethrin, leading to a conclusion that no special-status species are at risk.
The three new IPM application methods contained in the proposed modifications are substantially the same
as those examined in the 2014 EIR. In addition, the SLERA found that there would not be any significant
risks as a result of the project modifications, either from the introduction of three new pesticides to species
already evaluated, or to the two new species of special concern.
pesticides are used in a manner that is protective of biological resources.
Mitigation Measures 4.2.1a through 4.2.1d require additional protections for special status species
including pre-treatment surveys and consultation with USFWS, NMFS, and CDFW, as appropriate. These
mitigation measures were intended to apply to all species which were listed and/or of special concern at the
time of the 2014 EIR; as a result, the list included in Mitigation Measure 4.2.1a in the 2014 EIR is out of
date due to the two newly listed Species of Special Concern, the California giant salamander and Santa Cruz
black salamander. The text of this mitigation measure has been clarified to reflect this; this clarification does
not constitute a new mitigation measure.
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
32 Midpeninsula Regional Open Space District
With implementation of the District BMPs and Mitigation Measures 4.2.1a through 4.2.1d, no new or more
significant impacts to biological resources would result from implementation of the proposed project
modifications evaluated in this Addendum.
4.5 CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES
The District maintains in-house records regarding the confidential locations of all known cultural resources
within its boundaries. The District has compiled this information over time through direct information
provided by qualified archaeologists as well as a variety of reports and record searches that have been
performed for many projects throughout the District. Effects to cultural resources were previously considered
to be Less Than Significant or Less Than Significant With Mitigation Incorporated.
As described in the 2014 EIR:
Chemical treatment options would be applied by spray application, wipe application, or
cut-stump application. All methods of spraying under this project would be selective, that
is, the operator (who is trained in identifying invasive plants) is in direct control of the
sprayer, points the spray tip directly at the target weed or pest, and turns the spray
equipment on and off to control the amount and direction of spray. Under the wipe-
application treatment, herbicide is applied to the target plant using a sponge or rope wick
applicator for selective treatment. With cut-stump application, herbicide is immediately
applied to the circle of living cells after a woody plant has been cut close to the ground.
These treatments would not involve earth-disturbing activities or affect any built-
environment structures. Therefore, chemical treatment options would not adversely affect
cultural resources and this topic is not discussed further in this EIR.
As described above, the new application techniques in the proposed modifications are substantially the
same as those examined in the 2014 EIR and do not include any ground disturbing activities. The basal bark
application involves applying herbicide to brush and tree trunks using a backpack sprayer, similar to the cut-
stump application procedure. Wick application would consist of direct application herbicide using a rope
wick, which was contemplated in the EIR description cited above. Frill/injection application would involve
making a cut or hole in the target plant or tree using hand tools, and applying herbicide to the cut using an
injection system, squirt bottle, or brush and would not involve any earth disturbance or disturbance of
structures. The increased area designated for manual and mechanical IPM treatments would be in natural
areas and would involve activities addressed in the 2014 EIR. As described in the
BMPs require that District staff conducting treatment activities receive training on the protection of sensitive
archaeological, paleontological, or historic resources, and halt work if any cultural resources are encountered.
There would be no new or more severe impacts to cultural resources.
4.6 GEOLOGY AND SOILS
The 2014 project would not include any ground disturbing work on
steep hillsides, or the construction of new structures, or other grading activities that would be subject to
seismic hazards, unstable geologic conditions, or expansive soils, there would be no impacts to geology and
soils.
The proposed modifications would also not result in ground disturbing work on steep hillsides, construction
of new structures, or other grading activities, and therefore would also not result in any impacts to geology
and soils. While some of the pest management activities would result in the removal of targeted invasive
species, potentially exposing soil to increased erosion hazards, the District as a standard practice would
implement erosion control measures in BMP #28 (Table 4). BMP #28 would be implemented on sites with
loose or unstable soils, steep slopes (greater than 30 percent), where a large percentage of the groundcover
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 33
will be removed, or near aquatic features that could be adversely affected by an influx of sediment. Erosion
control measures could consist of application of forest duff or mulches, seeding, or planting of appropriate
native plant species to control erosion. Therefore, with implementation of the previously identified BMPs
when implementing the proposed modifications, no significant soil erosion impacts would occur.
4.7 HAZARDS AND HAZARDOUS MATERIALS
The 2014 EIR identified less-than-significant impacts related to human (i.e., mixer/loader/applicator,
general public) exposure to existing hazardous materials use, storage, and disposal during manual,
mechanical, and pesticide application control methodologies. Impacts associated with adverse effects on
8
s potential adverse effects on waterways, runoff, storm drainage, and flood control.
The proposed project modifications would include use of three new pesticide active ingredients (i.e., triclopyr
BEE, triclopyr TEA, prallethrin) and three new herbicide application methods (i.e., basal bark, wick,
frill/injection) for pest control activities within proposed areas of disturbance that were analyzed in the 2014
EIR. Pesticide applications associated with IPM around buildings and in recreational facilities could result in
transportation, use, and storage of prallethrin. Similarly, chemical treatments associated with IPM in
vegetation management areas could result in transportation, use, and storage of triclopyr BEE. Vegetation
management associated with IPM in rangelands and agricultural properties could result in transportation,
use, and storage of triclopyr BEE and triclopyr TEA. For the reasons described in the 2014 EIR (Draft EIR, p.
4.5-11 4.5-12), issues not resulting in adverse impacts will not be addressed further in this Addendum.
Active ingredients associated with pesticides proposed for use under the IPMP have moderate to very low
toxicity to humans. Table 6 provides a summary of the human toxicity associated with triclopyr BEE, triclopyr
TEA, and prallethrin.
Table 6. Summary of Proposed Pesticide Active Ingredient Human Toxicity
Active Ingredient Mammalian Oral LD50
(mg/kg)1
Mammalian Dermal
LD50 (mg/kg)2
Mammalian Inhalation
LC50 (mg/L)1 USEPA Toxicity Category3
HERBICIDES
Triclopyr BEE 803 >2,000 >4.8 Oral, Dermal (III)
Inhalation (IV)
Triclopyr TEA 1,847 >2,000 >2.6 Oral, Dermal (III)
Inhalation (IV)
INSECTICIDES
Prallethrin 640male
460female >5,000 0.29male
0.33female
Oral, Inhalation (II)
Dermal (IV)
1 Values are for rats.
2 Values are for rabbits.
3 Toxicity categories: High Toxicity (I), Moderate Toxicity (II), Low Toxicity (III), Very Low Toxicity (IV).
Sources: USEPA, 1998, 2002, 2016
Application of the proposed pesticides could result in varying degrees of exposure to both pesticide handlers
(i.e., mixer/loader/applicators [MLAs]) and the general public within and downwind of District preserves. For
example, MLAs can be exposed to pesticides via inhalation or by inadequate use of personal protective
equipment (PPE). Because all District pesticide applicators must have or work under the direction of a
person with a California Department of Pesticide Regulation (DPR) Qualified Applicator License (QAL) or
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
34 Midpeninsula Regional Open Space District
Qualified Applicator Certificate (QAC) per BMP #4 (Table 4), oral exposure is not expected due to the
assumption that the MLA is properly trained not to consume pesticide.
As described in the 2014 EIR, the U.S. Environmental Protection Agency (USEPA) oversees pesticide use
through the Worker Protection Standard (WPS), a regulation for agricultural pesticides for the purpose of
reducing the risk of pesticide poisonings and injuries among agricultural workers and pesticide handlers (i.e.,
MLAs). The WPS contains requirements for pesticide safety training, notification of pesticide applications,
use of personal protective equipment, restricted-entry intervals after pesticide application, decontamination
supplies, and emergency medical assistance. Furthermore, the Occupational Safety & Health Administration
(OSHA) provides general information on respirator use and OSHA standards that may apply with the use of
other chemicals.
In addition to existing regulations that reduce potential effects of exposure of pesticides on MLAs, numerous
BMPs (BMPs 1--10 and 34-36, Table 4) have been incorporated into the IPMP to minimize the potential for
adverse impacts on both MLAs and the general public, including District workers who perform hand labor
tasks in areas that have been treated with pesticides. In summary, the BMPs require that pesticides be
applied under the guidance of QALs/QACs and according to the District
requirements; storage, loading, and mixing be conducted away from aquatic features, special status species
or their habitat, and sensitive natural communities; application be restricted during times with high wind or
when precipitation is likely or is occurring; drift avoidance measures be employed; application notification
signs be posted prior to and following application for a specified period; cleanup of used containers be
conducted according to guidelines that prevent contamination of any body of water within the treatment
areas or adjacent watersheds; all appropriate laws and regulations pertaining to the use of pesticides and
safety standards for employees and the public be followed, as governed by USEPA, DPR, and local
jurisdictions; alternative treatment methods be considered for IPM projects currently utilizing glyphosate as a
management tool; no-spray trail buffers are established; and annual pesticide literature reviews be
conducted. These BMPs would also reduce the potential for increased risk of fire through the use of
herbicides because this use reduces the buildup of flammable vegetation. Furthermore, removal of
flammable vegetation through the use of herbicides would reduce fire fuel loads on District lands, thereby
decreasing wildland fire hazards compared to existing conditions.
The general public within and near District preserves can be exposed to pesticides via inhalation, dermal
contact with treated areas, or hand-to-mouth behavior following dermal contact with treated areas; however,
these exposures are expected to be minimal or inconsequential due to the posting and notification
requirements required by BMP #8 (Table 4), which indicates that signs providing information pertaining to
planned pesticide applications shall be posted 24 hours prior to the start of treatment and remain in place
for 72 hours after treatment is complete. Notification signs must contain the following information: product
name, signal word, manufacturer, active ingredient, and USEPA registration number; target pest; preserve
name; treatment location in preserve; date and time of application; date which notification sign may be
removed; and contact person with telephone number. Furthermore, application requirements described in
BMP #7 (Table 4) reduce risk of pesticide off-site movement by identifying weather and spray nozzle
parameters which must be employed during herbicide applications. Once the applied pesticide has dried,
transfer of pesticide residue is unlikely.
The culmination of the protective measures and regulatory requirements provides a foundation for assuring
the most effective, yet relatively safe, use of pesticides when treatment is determined to be needed;
therefore, the proposed modifications to the project would not result in new or more significant impacts
compared to those disclosed in the 2014 EIR.
4.8 HYDROLOGY AND WATER QUALITY
The 2014 EIR identified potentially significant impacts related to potential manual control-related soil
erosion and water quality impairment and chemical control-related water quality impacts. These impacts
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 35
would be reduced to a less-than-significant impact with implementation of Mitigation Measure 4.2-3 of the
2014 EIR (Draft EIR, p. 4.2-23). The 2014 EIR identified a less-than-significant impact associated with
flooding of on- or off-site areas.
Proposed project modifications include use of three new pesticide active ingredients (i.e., triclopyr BEE,
triclopyr TEA, prallethrin) and three new herbicide application methods (basal bark, wick, frill/injection) for
pest control activities within proposed areas of disturbance that were analyzed in the 2014 EIR. None of the
proposed pesticide uses would result in the alteration of drainage patterns or stream courses. While the
proposed modifications expand the annual treatment area for removal of invasive species, no new
mechanical vegetation management, earthmoving, or recontouring activity is proposed. If needed,
placement of ground cover, or seeding of native perennial grasses and pasture grasses would occur after
herbicide use or manual or mechanical treatment to stabilize exposed soils and to reduce the potential for
increased runoff as a result of this project as required under BMP #28. With implementation of this BMP,
and appropriate timing of herbicide use or manual or mechanical treatment not to coincide with the rainy
season, no significant erosion or siltation impacts would occur. The project would not cause an increase in
runoff that would result in flooding; however, because the District may use herbicides on rare occasions in
wetlands (dry season) and along stream banks, the IPMP would have the potential to result in residual
aquatic pesticide discharges to Waters of the United States. Note, however, that BMPs 19, 20, and 32
mandate that no IPM activities occur within 15 feet of aquatic resources. If IPM activities must be
undertaken within 15 feet of aquatic resources, only pesticides and adjuvants approved for aquatic use can
be used. For the reasons described in the 2014 EIR (Draft EIR, p. 4.4-9 4.4-10), issues not resulting in
adverse impacts will not be addressed further in this Addendum.
Refer to Table 7 for a summary of the environmental fate properties of the active ingredients proposed for
inclusion in the IPMP.
Table 7. Summary of Pesticide Active Ingredient Environmental Fate Properties
Active Ingredient Solubility (mg/L)1 Water Half-Life (days) Soil Half-Life (days) KOC
HERBICIDES
Triclopyr BEE 7.4salt
440acid
0.5salt2
1.7acid3
<0.2salt4
8-18acid5
640-1,650salt
25-134acid
Triclopyr TEA 4.12x105salt
440acid
<0.01salt6
1.7acid3
5.6-13.7salt7
8-18acid5
24-144salt
25-134acid
INSECTICIDES
Prallethrin 8.03 0.578i 3-299 3,082
1 At 25oC unless otherwise specified.
2 Half-life via hydrolysis to triclopyr acid.
3 Half-life via photolysis in river water to oxamic acid. Stable to hydrolysis.
4 Half-life via hydrolysis to triclopyr acid.
5 Half-life via aerobic biotic metabolism to 3,5,6-trichloro-2-pyridinol (TCP) and 3,5,6-trichloro-2-methoxypyridine (TMP).
6 Half-life via dissociation to triclopyr acid.
7 Half-life via aerobic biotic metabolism to triclopyr acid.
8 Half-life via photolysis. Stable to hydrolysis.
9 Half-life of 3-9 days via aerobic biotic metabolism; half-life of 29 days via photolysis.
Sources: SERA, 2011; USEPA, 1998, 2009, 2014
Protection List, indicating that it is recognized as a chemical with the potential to pollute groundwater (3 CCR
§ 6800(b), 2014). Chemicals are added to the Groundwater Protection List if they are both mobile (i.e.,
solubility >3 mg/L, KOC <1,900) and persistent (i.e., hydrolysis half-life >14 days, aerobic soil metabolism
half-life >610 days, anaerobic soil metabolism half-life >9 days), and applied in certain ways (i.e., applied to
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
36 Midpeninsula Regional Open Space District
soil via ground-based application equipment or chemigation, or applications are followed by flood or furrow
irrigation; DPR, 2013). Because triclopyr BEE may be rapidly converted to triclopyr acid, the latter is typically
the focus of research pertaining to environmental fate. Triclopyr acid is moderately persistent and very
mobile, with persistence increasing with increasing anaerobic conditions. Its degradation product 3,5,6-
trichloro-2-pyridinol (TCP) is also relatively mobile and persistent and has the potential to degrade
groundwater in areas where soils are permeable, particularly where the water table is shallow. Such areas
are identified as Groundwater Protection Areas by DPR. No Groundwater Protection Areas have been
established in San Mateo, Santa Clara, or Santa Cruz Counties (DPR, 2018); therefore, use of products
containing triclopyr BEE are not expected to impact groundwater quality when used according to label
instructions within the District footprint. Furthermore, label language specifies that triclopyr BEE is not to be
applied directly to water, to areas where surface water is present, or to intertidal areas below the mean high-
water mark, and indicates that applicators must avoid contaminating surface water when cleaning
equipment or disposing of equipment wash waters (Garlon 4 Ultra Label, 2008). The potential for impacts to
surface water is further reduced by the requirements of BMP #19, which mandates the use of a 15-foot
buffer around aquatic features during herbicide application, and Mitigation Measure 4.2-3 of the 2014 EIR,
which states that the District shall obtain a National Pollutant Discharge Elimination System (NPDES) permit
from the San Francisco Bay Regional Water Quality Control Board (RWQCB) and comply with design and
operational BMPs required under the permit. The requirement for the District to obtain Statewide NPDES
Permit for Residual Aquatic Pesticide Discharges to Waters of the US from Algae and Aquatic Weed Control
Applications (General Permit # CAG 990005 and Water Quality Orders 2014-0078-DWQ and 2015-0029-
DWQ) would only be applicable if the District intends to make intentional applications of pesticides directly to
waters of the United States. If the District chooses to continue treatment actions within the designated
buffer zone, it shall use pesticides and adjuvants labeled for aquatic use and follow the requirements of the
mitigation measure for special-status wildlife species and the California Department of Fish and Wildlife
(CDFW) Streambed Alteration Agreement. Further, consistent with BMP #20, the District complies with the
California Red-Legged Frog Injunction that mandates that in known or potential California red-legged frog
habitat, specified pesticides including triclopyr shall not be applied within 15 feet of aquatic features
(including areas that are wet at time of spraying or areas that are dry at time of spraying but subsequently
might be wet during the next winter season), utilize only spot-spraying techniques and equipment by a
certified applicator or person working under the direct supervision of a certified applicator, and not be
sprayed during precipitation or if precipitation is forecast to occur within 24 hours before or after the
proposed application. Thus, use of products containing triclopyr BEE are not expected to result in
unacceptable risk relating to the impairment of surface water quality.
Triclopyr TEA is also included on the Groundwater Protection List per 3 CCR § 6800(b) (2014). Like triclopyr
BEE, triclopyr TEA may be rapidly converted to triclopyr acid and can further break down to TCP; however,
because no Groundwater Protection Areas have been established in San Mateo, Santa Clara, or Santa Cruz
Counties (DPR, 2018), use of products containing triclopyr TEA are not expected to impact groundwater
quality when used according to label instructions within the District footprint. Although triclopyr TEA as found
in Garlon 3A or other products containing triclopyr TEA as the sole active ingredient are registered for aquatic
use and may be applied directly to water, triclopyr TEA in Capstone is formulated with aminopyralid TIPA and
may not be applied directly to water, to areas where surface water is present, or to intertidal areas below the
mean high-water mark. Further, individuals using Capstone must avoid contaminating surface water when
cleaning equipment or disposing of equipment wash waters. Approved application sites for Capstone may
include seasonably dry wetlands (including flood plains, marshes, swamps, or bogs) and areas around
standing water on sites such as deltas and riparian areas (Capstone Label, 2015). This label language, in
conjunction with the requirements of BMP #19, BMP #20, and Mitigation Measure 4.2-3 of the 2014 EIR
described above, leads to a conclusion that the use of triclopyr TEA is not expected to result in unacceptable
risk relating to the impairment of surface water quality.
Because of its very limited mobility in soil (i.e., high KOC) and label language excluding application to soil,
prallethrin is not on the Groundwater Protection List (3 CCR § 6800(b), 2014) or expected to impact
groundwater quality when used according to label instructions within the District footprint. As with triclopyr
BEE, label language specifies that prallethrin is not to be applied directly to water, to areas where surface
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 37
water is present, or to intertidal areas below the mean high-water mark and indicates that applicators must
avoid contaminating surface water when cleaning equipment or disposing of equipment wash waters (PT
Wasp-Freeze II Label, 2013). This label language, in conjunction with its relatively low solubility and the
requirements of BMP #19 and Mitigation Measure 4.2-3 of the 2014 EIR described above, leads to a
conclusion that the use of products containing prallethrin is not expected to result in unacceptable risk
relating to the impairment of surface water quality.
In addition to the factors above, pesticide applications, when done, are implemented consistent with written
recommendations prepared annually by a DPR-licensed Pest Control Adviser (PCA) and conducted in
accordance with the BMPs presented in Table 4. The PCA recommendation addresses numerous topics
including the criteria used to determine the need for pesticide use, potential hazards and restrictions, crop
and site restrictions, proximity to people, pets and livestock and a statement indicating that alternatives and
mitigation measures that would substantially lessen any significant adverse impact on the environment have
been considered and if feasible, adopted. The BMPs also require that pesticide applications be conducted
under the supervision of a person holding a QAL or QAC for pesticides; require all storage, loading, and
mixing of herbicides be set back at least 300 feet from any aquatic feature and all mixing and transferring
occur within a contained area; require that application cease when weather parameters do not meet label
specifications, when wind at site of application exceeds seven miles per hour, or when precipitation occurs
or is forecasted with greater than a 40 percent probability in the next 24-hour period.
For the reasons described above, the proposed modifications to the project would not result in any new or
more severe impacts pertaining to hydrology and water quality.
4.9 LAND USE AND PLANNING
As described in Chapter 1 of the 2014 EIR (Draft EIR, p. 1-5), land use and planning impacts would occur if
the IPMP would physically divide an established community (e.g., a freeway dividing a populated residential
community), if it would conflict with a land use policy adopted for the purpose of avoiding an environmental
impact, or if it would conflict with an applicable habitat conservation plan or natural community conservation
plan. There are no approved habitat conservation plans or natural community conservation plans that apply
to District lands. Implementation of the project would not involve any new development that would physically
divide a community and actions covered under the proposed IPMP would not change the overall natural
landscape of the site and no impact would occur. Therefore, no impacts would occur.
protect, and restore lands forming a regional open space
greenbelt, preserve unspoiled wilderness, wildlife habitat, watershed, viewshed, and fragile ecosystems, and
provide opportunities for low-intensity recreation and environmental education. The primary objective of the
IPMP is to control damage from pests through formal and consistent implementation of IPM principles to
protect and restore the natural environment and provide for human safety and enjoyment while visiting and
working on District lands. The proposed modifications to the IPMP would not meaningfully differ in this
regard compared to the project as described in the 2014 EIR. Therefore, the proposed modifications to the
project would not result in new significant impacts to land use and planning.
4.10 MINERAL RESOURCES
As discussed in Chapter 1 of the 2014 EIR (Draft EIR, p. 1-6), there are no known mineral resource recovery
sites on District lands. Therefore, the proposed project modifications are not anticipated to alter the
availability of any economic mineral resources. As discussed in the 2014 EIR, the project would have no
impact on mineral resources and the project modifications do not alter this conclusion.
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
38 Midpeninsula Regional Open Space District
4.11 NOISE
Generally, District properties are located in rural parts of their respective counties and are not in close
proximity to sensitive receptors. Noise-sensitive receptors on or adjacent to District preserves would include
recreational visitors and occupied residences, although the latter are scattered in low-density development
patterns, primarily along SR-35. The 2014 EIR found that any noise impacts resulting from the IPMP would
be subject to BMP #29, which requires that any noise generating equipment, including vehicles and manual
and mechanical equipment such as chainsaws, brushcutters, or masticators, would need to abide by local
noise ordinances if the noise activities would be audible to any receptors. Any impacts would not be
significant. Further, the use of noise generating equipment for fuel management throughout the year would
not result in significant impacts as implementation of BMP #22 would prevent disturbance of nesting birds
by requiring nesting bird surveys prior to treatment, establishment of nest buffers during nesting bird
season, and nest monitoring by a District biologist during and after treatment activities if the activity has
potential to adversely affect the nest.
The activities contemplated by the proposed modification do not introduce any additional sources or noise or
increase the possibility of any impacts to sensitive receptors. Noise-generating equipment that may be used
under the proposed herbicide application modifications (trucks, ATVs, pumps, etc.) would be similar or
identical to those already used under the project, and would not generate increased noise in comparison to
the existing project. As discussed above in Section 4.4, the expansion of acreage for
manual and mechanical treatments was contemplated and approved in the 2014 EIR. For these reasons,
and with implementation of BMP #22 and BMP #29, the proposed modifications would not result in new
significant noise impacts.
4.12 POPULATION AND HOUSING
As discussed in Chapter 1 of the 2014 EIR (Draft EIR, p. 1-6 1-7), no elements of the project would alter
population growth. No construction activities or addition of residences are part of the IPMP. The IPMP does
not induce population growth because it does not involve any alteration of existing land uses or the
introduction of new land uses associated with population increases (e.g., housing, employment centers).
Moreover, the IPMP does not involve new infrastructure or services that would draw new residents to the
area.
The proposed project modifications include three new pesticide application methods and three additional
pesticide product formulations. Similar to the approved project, the proposed project modifications would
not necessitate the construction of replacement housing and would result in no impact related to population
and housing.
4.13 PUBLIC SERVICES AND UTILITIES
The 2014 EIR found that the IPMP would result in no significant impacts to public services. It concluded that
actions under the IPMP would not result in an increase in District employees or the number of visitors at
District preserves. Further, it determined that the project would not result in the construction of additional
housing, commercial, or industrial development, nor would the project directly or indirectly increase the local
population, and therefore, no new or altered governmental facilities would be needed to provide public
services as a result of the project, nor would the project result in increased demand for public services.
The 2014 EIR also found there would be no impacts to utilities as a result of the IPMP. It determined that
implementation of the IPMP would not be anticipated to result in any change in the level of solid waste
generated at a District preserve and therefore would not affect permitted capacity of local or regional solid
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 39
waste disposal services serving the District lands. District facilities are not typically served by municipal
storm drain facilities, so there would be no increased demand for storm water facilities.
The proposed modifications would similarly not result in any increases in District employees or visitors on
District lands, nor would it result in the construction of housing, commercial, or industrial development. In
addition, there would be no increased levels of solid waste or other utility services. The proposed
modifications would not result in any new or more significant impacts to public services and utilities.
4.14 RECREATION
Recreation is one of the predominant land uses on District preserves, including a 220-mile network of
hiking, bicycling, and equestrian trails on District lands. The IPMP is designed to include a long-term,
science-based decision-making system that uses a specific methodology to manage damage from pests, and
was developed in accordance with
open space land in perpetuity, protect and restore the natural environment, and provide opportunities for
ecologically sensitive public enjoyment and education. The IPMP is designed to enhance and preserve
recreational opportunities and would therefore have no adverse impacts to recreation.
The proposed modifications are similarly designed to manage pests and invasive species, consistent with
goals of enhancing and preserving recreation. There would be no new or more significant
impacts.
4.15 TRAFFIC AND TRANSPORTATION
As discussed in Chapter 1 of the 2014 EIR (Draft EIR, p.1-7 1-8), the IPMP would not have any significant
effects on traffic and transportation. The IPMP describes pest management activities. The 2014 EIR found
that these activities were consistent with existing levels of operation and maintenance activities and would
not substantially increase throughout the duration of the plan (approximately one percent increase in pest
management on an annual basis), and therefore would not result in any significant increases to traffic. The
District determined that activities under the IPMP would not create changes in air traffic patterns, result in
population increases that could adversely affect area traffic, or alter the level of emergency access. No
oversized equipment would be used requiring special transport precautions on local streets, roads, or
highways. No changes to access points or roadway design would occur with implementation of the IPMP. In
addition, there are no policies or plans within the District preserves that pertain to public transit, bicycle, or
pedestrian facilities.
The proposed modifications consist of three new pesticide formulations ,three additional methods of
pesticide application, and some minor acreage changes for some treatment types. All of the vehicles that
would be used as part of these modifications are already in use on District facilities and such use was
approved in the 2014 EIR. In addition, these applications would be infrequent and intermittent and would
not contribute substantially to any traffic, transportation, or emergency access. The proposed modifications
would have no new or more significant impacts.
5 CONCLUSION
The proposed addition of three additional pesticide active ingredients, three additional methods of pesticide
application, and treatment acreage and timing modifications would not alter any of the
conclusions of the 2014 EIR. Additionally, the IPMP together with the proposed modifications thereto would
have no significant impacts on the two additional Species of Special Concern. No new significant
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
40 Midpeninsula Regional Open Space District
environmental effects or a substantial increase in the severity of previously identified significant effects
would result.
The additions also would not affect any of the mitigation measures, including their feasibility or
implementation, although one mitigation measure has been clarified. As discussed above in Section 4.4, the
2014 EIR included mitigation measures to protect special status reptiles and amphibians, including pre-
treatment surveys and consultation with USFWS, NMFS, and CDFW, as appropriate. While the 2014 EIR
identified each of the special status amphibians and reptiles that were listed at the time of the EIR, this
Addendum includes the two newly listed additional Species of Special Concern. These revisions are not a
result of newly identified adverse impacts and do not substantially affect the current IPMP or other proposed
program modifications.
As described above, this Addendum also provides a revised list of BMPs that clarify existing language,
outline practices already being carried out by District staff, and further increase the protection and safety of
humans and the environment. These revisions are not a result of newly identified adverse impacts and do
not substantially affect the current IPMP or other proposed program modifications.
As mentioned above, none of the conditions listed in section 15162 of the CEQA Guidelines exist for the
project modification described herein. Therefore, pursuant to section 15164 of the CEQA Guidelines, the
differences between the approved project described in the 2014 EIR and the modification of the project as
currently proposed and described in this Addendum are minor and this Addendum provides sufficient
environmental documentation. No subsequent or supplemental MND or EIR is needed to address the project
modifications or additional Species of Special Concern.
6 REFERENCES
California Department of Fish and Wildlife (CDFW). 1997. California Giant Salamander, California Wildlife
Habitat Relationships System. Sacramento, CA.
California Department of Fish and Wildlife (CDFW). 2017. Special Animals List, Natural Diversity Database.
October 2017. Special Animals List. Periodic publication. 65 pp.
California Department of Pesticide Regulation (DPR). 2013. Guidelines for Identifying Pesticides to be Added
to and Removed from the Groundwater Protection List: Title 3, California Code of Regulations Section
6800(b). Sacramento, CA.
California Department of Pesticide Regulation (DPR). 2018. Ground Water Protection Area Lists. Available at:
http://www.cdpr.ca.gov/docs/emon/grndwtr/gwpa_lists.htm (Accessed: February 16, 2018).
Capstone® Label. 2015. Dow AgroSciences. Indianapolis, IN.
Continuing Education Requirements, 3 CCR § 6511 (2010).
Garlon® 4 Ultra Label. 2008. Dow AgroSciences. Indianapolis, IN.
Groundwater Protection List, 3 CCR § 6800 (2014).
Midpeninsula Regional Open Space District (District). 2014a. Integrated Pest Management Guidance
Manual. Available: https://www.openspace.org/sites/default/files/IPM_Guidance_Manual.pdf
(Accessed: January 19, 2018).
Exhibit A
Blankinship & Associates, Inc. Addendum to the Environmental Impact Report
Integrated Pest Management Program
Midpeninsula Regional Open Space District 41
Midpeninsula Regional Open Space District (District). 2014b. Resource Management Policies. Available:
https://www.openspace.org/sites/default/files/Resource_Management_Policies.pdf (Accessed:
January 19, 2018).
Midpeninsula Regional Open Space District (District). 2014c. Draft Environmental Impact Report for the
Midpeninsula Regional Open Space District Integrated Pest Management Program. Available:
https://www.openspace.org/sites/default/files/IPM_EIR.pdf (Accessed: February 7, 2018).
Midpeninsula Regional Open Space District (District). 2016. Monthly Summary Pesticide Use Reports: 2016.
Midpeninsula Regional Open Space District (District). 2017a. Vegetation Management Records: 2016-2017
(GIS shapefile).
Midpeninsula Regional Open Space District (District). 2017b. Special Status Species Binder. Updated
January 20, 2017.
Nussbaum, R.A. and G.W. Clothier. 1973. Population Structure, Growth, and Size of Larval Dicamptodon
ensatus (Eschscholtz). Northwest Science 47(4): 218-227.
PT® Wasp-Freeze® II Label. 2013. BASF Corporation. St. Louis, MO.
Syracuse Environmental Research Associates, Inc. (SERA). 2011. Triclopyr Human Health and Ecological
Risk Assessment Final Report. Available at: https://www.fs.fed.us/foresthealth/pesticide/pdfs/052-
25-03aTriclopyr.pdf (Accessed: March 9, 2017).
Thomson, R.C., A.N. Wright, and H.B. Shaffer. 2016. California Amphibian and Reptile Species of Special
Concern. University of California Press, Oakland, CA. 408 pp.
U.S. Environmental Protection Agency (USEPA). 1998. Reregistration Eligibility Decision (RED): Triclopyr.
Office of Prevention, Pesticides, and Toxic Substances. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2002. Federal Register: Triclopyr Pesticide Tolerance.
Available: https://www.gpo.gov/fdsys/pkg/FR-2002-09-18/pdf/02-23746.pdf (Accessed: March 18,
2017).
U.S. Environmental Protection Agency (USEPA). 2009. Risks of Triclopyr Use to Federally Threatened
California Red-legged Frog (Rana aurora draytonii). Office of Pesticide Programs. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2010. Endangered Species Facts: California Tiger
Salamander. Office of Pesticide Programs. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2014. Prallethrin: Revised Ecological Risk Assessment to
Support Proposed New Use Over, Near and Around Agricultural Areas. Office of Chemical Safety and
Pollution Prevention. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2016. Prallethrin Revised Draft Human Health Risk
Assessment for Registration Review. Office of Chemical Safety and Pollution Prevention. Washington,
D.C. Available: https://www.regulations.gov/document?D=EPA-HQ-OPP-2011-1009-0030 (Accessed:
March 15, 2017).
U.S. Fish and Wildlife Service (USFS). 2009. Species Account: California Tiger Salamander. Available:
https://www.fws.gov/sacramento/es_species/Accounts/Amphibians-
Reptiles/ca_tiger_salamander/documents/california_tiger_salamander.pdf (Accessed: January 23,
2018).
Exhibit A
Addendum to the Environmental Impact Report Blankinship & Associates, Inc.
Integrated Pest Management Program
42 Midpeninsula Regional Open Space District
U.S. Fish and Wildlife Service (USFS). 2017. Species Information: California Tiger Salamander. Available:
https://www.fws.gov/sacramento/es_species/Accounts/Amphibians-Reptiles/ca_tiger_salamander/
(Accessed: January 23, 2018).
Exhibit A
Appendix 1
Ardea Consulting 1 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Midpeninsula Regional Open Space District
Screening-Level Ecological Risk
Assessment
Integrated Pest Management Program
(Updated)
Prepared by:
Joseph P. Sullivan, Ph.D.
Primary Author
Ardea Consulting
10 1st Street
Woodland, CA 95695
and
Blankinship & Associates, Inc.
1615 5th Street
Davis, CA 95616
Contact:
Mike Blankinship
530-757-0941
January 9, 2019
Prepared for:
Midpeninsula Regional Open Space District
330 Distel Circle
Los Altos, CA 94022
Contact:
Coty Sifuentes-Winter
(650) 691-1200
Exhibit A
Appendix 1
Ardea Consulting 2 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................. 2
LIST OF TABLES ........................................................................................................................ 4
LIST OF FIGURES ...................................................................................................................... 4
LIST OF ABBREVIATIONS ...................................................................................................... 5
Executive Summary ...................................................................................................................... 7
1 Introduction ....................................................................................................................... 9
1.1 Purpose of the Screening Level Ecological Risk Assessment ......................................... 9
1.2 Approach .......................................................................................................................... 9
1.2.1 Assessment for California giant salamanders and Santa Cruz black salamanders ... 9
1.2.2 Assessment for Triclopyr BEE, Triclopyr TEA, and Prallethrin ............................ 10
2 Problem Formulation ..................................................................................................... 10
2.1 Application Scenarios .................................................................................................... 10
2.2 Active Ingredients and Adjuvants of Concern and Environmental Fate Properties ...... 13
2.3 Environmental and Ecological Settings ......................................................................... 15
2.4 Assessment Endpoints and Measures of Ecological Effect ........................................... 15
2.4.1 Assessment Endpoints ............................................................................................ 17
2.4.2 Measurement Endpoints.......................................................................................... 17
2.5 Conceptual Site Models ................................................................................................. 18
2.6 Analysis Plan .................................................................................................................. 18
3 Exposure Assessment ...................................................................................................... 18
3.1 Acute Exposure .............................................................................................................. 22
3.1.1 Acute Exposure in Terrestrial Species .................................................................... 22
3.1.2 Acute Exposure in Aquatic Species ........................................................................ 22
3.2 Chronic Exposure ........................................................................................................... 23
3.2.1 Chronic Exposure in Terrestrial Species ................................................................. 23
3.2.2 Chronic Exposure in Aquatic Species..................................................................... 23
4 Effects Assessment .......................................................................................................... 23
4.1 Adjuvants Considered for Toxicity to California Giant Salamander and Santa Cruz
Black Salamander .......................................................................................................... 24
4.1.1 Alcohol Ethoxylate ................................................................................................. 24
4.1.2 Alkylphenol Ethoxylate .......................................................................................... 26
4.1.3 Canola Oil, Ethyl and Methyl Esters ...................................................................... 27
4.1.4 Lecithin ................................................................................................................... 27
4.2 Pesticide Active Ingredients Considered for Toxicity to California Giant Salamander
and Santa Cruz Black Salamander ................................................................................. 27
4.2.1 Phosphite, mono-/di-potassium salts ...................................................................... 27
4.2.2 Aminopyralid Triisopropanolamine (TIPA) Salt .................................................... 27
4.2.3 Clethodim ................................................................................................................ 28
4.2.4 Clopyralid Monoethanolamine (MEA) Salt............................................................ 28
4.2.5 Glyphosate Isopropylamine (IPA) Salt ................................................................... 28
4.2.6 Glyphosate Potassium (K) Salt ............................................................................... 28
4.2.7 Imazapyr Isopropylamine (IPA) Salt ...................................................................... 28
4.2.8 Diatomaceous Earth ................................................................................................ 29
4.2.9 Fipronil .................................................................................................................... 29
Exhibit A
Appendix 1
Ardea Consulting 3 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
4.2.10 Indoxacarb............................................................................................................... 29
4.2.11 S-Hydroprene .......................................................................................................... 29
4.2.12 Sodium Tetraborate Decahydrate ........................................................................... 29
4.2.13 Cholecalciferol ........................................................................................................ 29
4.3 New Pesticide Active Ingredients Considered for Toxicity to All Special-Status Species
........................................................................................................................................ 30
4.3.1 Triclopyr BEE ......................................................................................................... 30
4.3.2 Triclopyr TEA ......................................................................................................... 30
4.3.3 Prallethrin ................................................................................................................ 30
5 Risk Characterization ..................................................................................................... 31
5.1 Potential for a Species to Be Present at the Application Site ......................................... 31
5.2 Foraging Diet.................................................................................................................. 31
5.3 Dilution and Degradation of Pesticide Active Ingredients and Adjuvants .................... 31
5.4 Risk Analysis for Pesticide Active Ingredients and Adjuvants Considered for Toxicity
to California Giant Salamander and Santa Cruz Black Salamander .............................. 32
5.4.1 Alcohol Ethoxylate ................................................................................................. 32
5.4.2 Alkylphenol Ethoxylate .......................................................................................... 32
5.4.3 Canola Oil, Ethyl and Methyl Esters ...................................................................... 33
5.4.4 Lecithin ................................................................................................................... 33
5.4.5 Phosphite, mono-/di-potassium salts ...................................................................... 33
5.4.6 Aminopyralid TIPA ................................................................................................ 33
5.4.7 Clethodim ................................................................................................................ 34
5.4.8 Clopyralid MEA...................................................................................................... 34
5.4.9 Glyphosate IPA ....................................................................................................... 34
5.4.10 Glyphosate K .......................................................................................................... 35
5.4.11 Imazapyr IPA .......................................................................................................... 35
5.4.12 Diatomaceous Earth ................................................................................................ 35
5.4.13 Fipronil .................................................................................................................... 35
5.4.14 Indoxacarb............................................................................................................... 35
5.4.15 S-Hydroprene .......................................................................................................... 36
5.4.16 Sodium Tetraborate Decahydrate ........................................................................... 36
5.4.17 Cholecalciferol ........................................................................................................ 36
5.5 Risk Analysis for New Active Ingredients Considered for Toxicity to All Special-Status
Species ........................................................................................................................... 36
5.5.1 Triclopyr BEE ......................................................................................................... 36
5.5.2 Triclopyr TEA ......................................................................................................... 37
5.5.3 Prallethrin ................................................................................................................ 37
6 Uncertainties .................................................................................................................... 38
6.1 Exposure Assessment Uncertainties............................................................................... 38
6.2 Effects Assessment Uncertainties .................................................................................. 39
6.2.1 Use of Surrogate Species Effects Data ................................................................... 39
6.2.2 Sublethal Effects ..................................................................................................... 39
6.2.3 Dermal or Inhalation Effects ................................................................................... 39
7 Conclusions ...................................................................................................................... 40
8 Literature ......................................................................................................................... 41
Exhibit A
Appendix 1
Ardea Consulting 4 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
LIST OF TABLES
Table Eco-1. List of pesticides and adjuvants included in the IPMP analyzed previously in
the 2014 EIR. ....................................................................................................................... 12
Table Eco-2. Environmental Fate and Transport of Active Ingredients Under
Consideration for Use by the District................................................................................ 13
Table Eco-3. Life history characteristics of the California tiger salamander, California
giant salamander, and the Santa Cruz black salamander. ............................................. 16
Table Eco-4. Acute Ecotoxicity Data for Terrestrial and Aquatic Organisms. .................... 25
Table Eco-5. Acute Ecotoxicity Categories for Terrestrial and Aquatic Organisms. .......... 26
LIST OF FIGURES
Figure Eco-1. Locations for California Giant Salamander and Santa Cruz Black Salamander
Throughout the District. ........................................................................................................ 14
Figure Eco-2. Conceptual Site Model for California Giant Salamander and Santa Cruz Black
Salamander Following Applications in and Around District Buildings ............................... 19
Figure Eco-3. Conceptual Site Model for California Giant Salamander and Santa Cruz Black
Salamander Following Applications in Managed, Natural, and Recreational Areas ........... 20
Figure Eco-4. Conceptual Site Model for Insecticides Following Applications Outside District
Buildings and Insecticides and Herbicides Following Applications in Managed, Natural, and
Recreational Areas ................................................................................................................ 21
Exhibit A
Appendix 1
Ardea Consulting 5 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
LIST OF ABBREVIATIONS
Ac ...................................................................Acre
a.i. ...................................................................Active Ingredient
ATSDR ..........................................................Agency for Toxic Substances Disease Registry
BMP ...............................................................Best Management Practices
Bti ...................................................................Bacillus thuringiensis var. israelensis
bw ...................................................................Body Weight
CAS RN .........................................................Chemical Abstract Service Registration Number
CDFW ............................................................California Department of Fish and Wildlife
CSM ...............................................................Conceptual Site Model
EC50 ................................................................Median Effective Concentration
ED50................................................................Median Effective Dose
EIR .................................................................Environmental Impact Report
FIFRA ............................................................Federal Insecticide, Fungicide and Rodenticide Act
HHRA ............................................................Human Health Risk Assessment
IPA .................................................................Isopropylamine (salt)
IPC .................................................................Integrated Pest Control
IPMP ..............................................................Integrated Pest Management Program
K .....................................................................Potassium (salt)
Kd ...................................................................Soil-Water Partition Coefficient
Koa ..................................................................Octanol-Air Partition Coefficient
Koc ..................................................................Organic Carbon Absorption Coefficient
Kow .................................................................Octanol-Water Partition Coefficient
LC50 ................................................................Median Lethal Concentration
LD50................................................................Median Lethal Dose
LO(A)EL/LOAEL..........................................Lowest Observable (Adverse) Effect Level
LOC................................................................Level of Concern
LOEC .............................................................Lowest Observable Effect Concentration
MEA ...............................................................Monoethanolamine (salt)
MW ................................................................Molecular Weight
NA ..................................................................Not Applicable
NDA ...............................................................No Data Available
Exhibit A
Appendix 1
Ardea Consulting 6 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
NMFS .............................................................National Marine Fisheries Service
NO(A)EL/ NOEL...........................................No Observable (Adverse) Effect Level
NOC ...............................................................Not Of Concern
NOEC .............................................................No Observable Effect Concentration
PUR ................................................................Pesticide Use Reporting
RED................................................................Reregistration Eligibility Decision
SLERA ...........................................................Screening Level Ecological Risk Assessment
SOD................................................................Sudden Oak Death
TEA ................................................................Triethylamine (salt)
TGAI ..............................................................Technical grade of the active ingredient
TIPA ...............................................................Triisopropanolamine (salt)
Triclopyr BEE ................................................Triclopyr-2-butoxyethyl ester
USEPA ...........................................................U.S. Environmental Protection Agency
USFWS ..........................................................U.S. Fish and Wildlife Service
Exhibit A
Appendix 1
Ardea Consulting 7 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Executive Summary
This Screening Level Ecological Risk Assessment (SLERA) is conducted as an addition to the
Ecological Risk Assessment conducted as part of the Environmental Impact Report (EIR)
prepared for Midpeninsula Regional Open Space District (District) in 2014. Three new pesticide
products that include three active ingredients that were not previously analyzed are proposed for
addition . Additionally, two
salamander species that reside in the District have been designated as special-status species since
the 2014 EIR was completed.
Two of the new active ingredients, triclopyr-2-butoxy-ethyl ester (BEE) and triclopyr
trimethylamine (TEA) salt, are herbicides that can be used to control a wide variety of weed
species. Triclopyr BEE is proposed for use as a spot spray, cut-stump, or basal bark treatment.
Triclopyr TEA is proposed for use as a spot spray, cut-stump, or frill/injection treatment. The
third new active ingredient is prallethrin that is an insecticide used to control stinging insects and
applied using an aerosol spray. The potential for exposure and adverse effects from these newly
added active ingredients are considered for all special-status species including the recently
designated special-status salamanders.
The salamander species recently designated as special-status species are the California giant
salamander and Santa Cruz black salamander. California giant salamanders breed in permanent
and semipermanent streams, and the larvae do not metamorphose for up to 18 months. Santa
Cruz black salamanders do not have an aquatic larval stage. Eggs are laid in moist burrows, and
the juveniles emerge from the egg appearing as fully formed small salamanders. The potential
for exposure and adverse effects for these salamanders are considered for all previously assessed
active ingredients and adjuvants as well as the newly added active ingredients.
The SLERA relied upon the three-stage process for risk assessments: problem formulation,
analysis, and risk characterization. In the problem formulation phase, the District identified the
appropriate scenarios to assess and the default data assumptions. The problem formulation stage
concluded with conceptual site models (CSMs) that identified the complete exposure pathways
carried forward in the analysis based on available information. During the analysis phase of the
SLERA, exposure was qualitatively estimated with conservative assumptions. Also in the
analysis phase, effect values were developed which incorporated the toxicity properties of the
pesticides and adjuvants. The risk characterization phase provided conclusions on the potential
for adverse effects to occur to ecological receptors. The risk characterization phase utilized a
qualitative assessment.
Several qualitative considerations typically result in a conclusion that the potential for adverse
effects would be low. This includes an assessment of the potential for species presence at an
application site, incorporation of foraging range and diet, in addition to fate and transport
processes of pesticides such as dilution and degradation.
The Best Management Practices (BMPs) and the Mitigation Measures from the 2014
EIR are designed to greatly reduce, if not eliminate, pesticide or adjuvant movement to surface
water. Therefore, actual impacts to aquatic invertebrates or birds and mammals that feed in
aquatic habitats are anticipated to be minimal. Those pesticides that are sufficiently toxic to
Exhibit A
Appendix 1
Ardea Consulting 8 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
terrestrial-phase amphibians are used in such a manner that the potential for exposure is so low,
no adverse effects are anticipated. For example, insecticides are either used in or around
buildings or as targeted applications of stinging insects, such as wasps or hornets. Herbicides
exhibit low toxicity to terrestrial animals. Although there is a greater chance of exposure for
special-status terrestrial animals from herbicides, the low toxicity leads to a conclusion that
terrestrial special-status species are not at risk.
This SLERA will be used to assist the District in assessing potential to affect particular species
and developing site-specific measures to protect these species.
Exhibit A
Appendix 1
Ardea Consulting 9 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
1
This Screening Level Ecological Risk Assessment (SLERA) is an addition to the Assessment
conducted as part of the previous Environmental Impact Report (EIR) (State Clearinghouse No.
2013092033) for the Integrated Pest Management Program (IPMP) (herein referred to as the
2014 EIR). Since the certification of the 2014 EIR, two species known to occur within the
Midpeninsula Regional Open Space District (District) boundaries have been classified as Species
of Special Concern by the California Department of Fish and Wildlife (Thomson et al., 2016).
These species are: California giant salamander (Dicamptodon ensatus) and Santa Cruz black
salamander (Aneides flavipunctatus niger ). Additionally, active ingredients in three new
pesticide products are to be included in the IPMP:
Example
Product
Name
Pesticide
Type
Pest(s)
Controlled
Pesticide Active
Ingredient(s)
Active
Ingredient
Abbreviation
Garlon 4
Ultra®
Herbicide
Broadleaf and
Woody Plants
Triclopyr-2-
butoxyethyl ester
Triclopyr BEE
Capstone® Herbicide Triclopyr triethylamine
(TEA) salt and
aminopyralid
triisopropanolamine
(TIPA) salt
Triclopyr TEA
PT® Wasp-
Freeze® II
Insecticide Wasps, Hornets Prallethrin Prallethrin
The active ingredient aminopyralid triisopropanolamine salt was previously analyzed in the 2014
EIR and is not analyzed in this SLERA. Keeping with the approach in the 2014 EIR, only active
ingredients were assessed in this SLERA. No inert ingredients were considered.
1.1 Purpose of the Screening Level Ecological Risk Assessment
The SLERA assesses potential future activities to be conducted as part of .
Specifically, the SLERA focuses on potential risk for California giant salamanders and Santa
Cruz black salamanders resulting from applications of pesticides previously analyzed in the 2014
EIR. The SLERA also evaluates the potential risk to terrestrial and aquatic species following
applications of the three new pesticides .
1.2 Approach
1.2.1 Assessment for California giant salamanders and Santa Cruz black salamanders
This SLERA was conducted by performing a qualitative exposure assessment. The application
sites of the active ingredients in thirteen pesticides and three adjuvants that were analyzed in the
2014 EIR were evaluated to assess the potential for overlap with the habitat requirements of
California giant salamanders and Santa Cruz black salamanders. One pesticide, PT ® Wasp-
Freeze®, is no longer used by District staff and is therefore not included in the current evaluation.
Exhibit A
Appendix 1
Ardea Consulting 10 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Additionally, the application techniques for these same pesticide products were considered to
determine the degree of exposure possible when there was a potential for overlap with the habitat
of these salamander species. When exposure was deemed possible, toxicity data for salamanders
or surrogate species were considered to reach a conclusion regarding whether the degree of
exposure along with the severity of toxicity could result in a level of risk suggesting adverse
effects following pesticide applications.
1.2.2 Assessment for Triclopyr BEE, Triclopyr TEA, and Prallethrin
A similar qualitative approach was used for the consideration of the potential for adverse effects
following applications of triclopyr BEE, triclopyr TEA, and prallethrin. Since there were only
three pesticides to consider, the severity of the toxicity for different taxonomic groups was
evaluated first to narrow down those species that could be harmed if they were exposed
following an application. For those species with high sensitivity to the active ingredients in these
pesticides, the application sites and application techniques were considered to determine whether
the degree of exposure could be sufficient to produce adverse effect following an application.
2
Problem formulation is the first step in the SLERA process. Its purpose is to establish the goals,
breadth, and focus of the assessment through a systematic process to identify the major factors to
be considered in the assessment. District staff provided details on past pesticide use in the
District. The IPMP was described initially in MROSD (2014a) and the environmental impacts
assessed in MROSD (2014b). This SLERA assesses the modification to the IPMP for the
potential for risk to the California giant salamander and Santa Cruz black salamander following
applications of any pesticide included in the IPMP and any potential for risk to all special-status
species in the District following applications of triclopyr BEE, triclopyr TEA, and prallethrin.
Problem Formulation integrates available information (sources, contaminants, effects, and
environmental setting) and serves to provide focus to the SLERA.
2.1 Application Scenarios
Details regarding the application of pesticides that impact the estimation of potential risk
include:
Type of pesticide
Concentration of pesticide
Application method (e.g., bait station, spraying)
Duration and frequency of applications
Rate of application
Area of application
Setting in which activity would occur (e.g., within a building, natural area)
The use of adjuvants, if any.
The District s IPMP includes implementing cultural, biological, manual/mechanical, and
chemical IPM practices in buildings, recreational facilities, fuel management areas, rangelands
Exhibit A
Appendix 1
Ardea Consulting 11 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
and agricultural properties, and natural lands within District boundaries. The 2014 EIR includes
Best Management Practices (BMPs) intended to minimize movement of pesticides to sensitive
areas and protect special-status species. The 2014 EIR also includes Mitigation Measures for the
protection of sensitive habitats and special-status species.
A modification to the IPMP is to include basal bark, wick, and frill/injection applications for
herbicides, in addition to spot spray applications and cut-stump treatments. These application
techniques are described in Section 3.1 of the Addendum Report. Depending on the treatment
goals, a wick application could be be made to areas similar to a spot spray applications or
uniformly across a larger area, but the potential for off-site movement is reduced. Basal bark and
frill/injection applications are comparable to cut-stump applications with regards to area treated
and potential for off-site movement. Other application techniques include aerosol spray of
insecticides around buildings and along trails, placement of insecticidal disks in water troughs,
bait and powdered insecticides used in and around buildings, bait boxes with rodenticides used
inside buildings, and spraying herbicides in agricultural and natural settings. Adjuvants can be
efficacy by allowing it to more readily penetrate the plan
adhesion, etc. It is not uncommon for adjuvants to be included with a pesticide active ingredient
in a pesticide product. In these cases, the adjuvant may be referred to as an inert ingredient. Refer
to the IPM Guidance Manual (MROSD, 2014a) for complete details.
Exhibit A
Appendix 1
Ardea Consulting 12 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Table Eco-1. List of pesticides and adjuvants included in the IPMP analyzed previously in
the 2014 EIR.
Pesticide
Category
Active
Ingredient
Product Formulations
(Manufacturer) Mode of Action Purpose
Adjuvants/
Surfactants
Alcohol
Ethoxylate
Liberate®
(Loveland Products, Inc.)
Enhances uptake of herbicides
and pesticides
Increase delivery and efficacy
of pesticides to targets
Alkylphenol
Ethoxylate
Pentra-Bark®
(Quest) Enhances uptake of Agri-Fos Increase delivery of Agri-Fos
to trees
Lecithin Liberate®
(Loveland Products, Inc.)
Enhances uptake of herbicides
and pesticides
Increase delivery and efficacy
of pesticides to targets
Canola Oil,
Ethyl and
Methyl Esters
Competitor®
(Wilbur-Ellis)
Decrease surface tension,
increase herbicide uptake,
enhance wetting and spreading
Increase delivery and efficacy
of pesticides to targets
Fungicides Phosphite K
Salts, mono-/di-
Agri-Fos®
(AgBio)
Fungal oxidative phosphorylation
inhibitor Prevents sudden oak death
Herbicides
Aminopyralid
TIPA
Milestone®
(Dow AgroSciences) Auxin growth hormone mimic Nonselective post-emergent
broad-spectrum weed control
Clethodim Envoy PlusTM
(Valent) Fatty acid synthesis inhibitor Selective post-emergent grass
weed control
Clopyralid MEA Transline®
(Dow AgroSciences) Auxin growth hormone mimic Selective broadleaf weed
control
Glyphosate IPA Roundup CustomTM
(Monsanto) Amino acid synthesis inhibitor Nonselective post-emergent
broad-spectrum weed control
Glyphosate K Roundup ProMax®
(Monsanto) Amino acid synthesis inhibitor Nonselective post-emergent
broad-spectrum weed control
Imazapyr IPA Polaris® (Nufarm),
Stalker® (BASF) Amino acid synthesis inhibitor
Nonselective pre-and post-
emergent broad-spectrum weed
control
Insecticides
Diatomaceous
Earth Diatomaceous Earth Water balance disruptor Structural pest control (e.g.,
ants, cockroaches)
D-trans
Allethrin
PT® Wasp-Freeze®
(BASF)
Voltage-gated sodium channel
interference Wasp and hornet control
Fipronil Maxforce® Bait Stations
(Bayer)
GABA-gated chloride channel
blocker Ant control
Indoxacarb Advion® Gel Baits
(DuPont) Sodium channel blocker Structural pest control (e.g.,
ants, cockroaches)
Phenothrin PT® Wasp-Freeze®
(BASF)
Voltage-gated sodium channel
interference Wasp and hornet control
S-Hydroprene Gentrol Point Source®
(Wellmark International) Juvenile growth hormone mimic Pest control (e.g., cockroaches,
beetles, moths)
Sodium
Tetraborate
Decahydrate
Prescription Treatment
Baits (BASF),
Terro® Ant Killer II
(Terro)
Water balance disruptor Ant control
Rodenticides Cholecalciferol Cholecalciferol baits Calcification of soft tissues Rodent pest control (e.g., rats,
mice)
Exhibit A
Appendix 1
Ardea Consulting 13 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Table Eco-2. Environmental Fate and Transport of Active Ingredients Under
Consideration for Use by the District.
Active Ingredient Air Water Soil
Triclopyr
butoxyethyl ester
> Relatively
nonvolatile (vapor
pressure = 3.6x10-6
mmHg)
> Relatively insoluble (solubility
= 7.4 mg/L)
> Rapid degradation via
> Degradant is stable to
hydrolysis
> Moderate sorption to soil;
remains in upper 7.5 cm of
soil (KOC = 640 to 1650)
> Primarily degraded by
microbes under aerobic
conditions (t½ < 0.2 days)
> Degradants are likely more
persistent and mobile in
soil
Triclopyr
triethylamine salt
> Nonvolatile (vapor
pressure = 1x10-8
mmHg)
> Very soluble (solubility =
412,000 mg/L)
> Dissipation within 1 minute
> Degradant is stable to
hydrolysis
> Mobile in soil (KOC = 24 to
144)
> Average aerobic t½ = 9.7
days
> Degradants are also
persistent and mobile in
soil
Prallethrin > Slightly volatile
(vapor pressure =
3.2x10-5 mmHg)
> Slightly soluble (8.03 mg/L)
> Very rapid degradation via
photolysis (t½ = 0.57 days)
> Rapid degradation in basic
waters (t½ = 4.9 days)
> Slow degradation in neutral to
acidic water
> High sorption and low
mobility in soil (KOC =
3,082)
> Microbial degradation
under aerobic conditions
(t½ = 3 to 9 days)
2.2 Active Ingredients and Adjuvants of Concern and Environmental Fate
Properties
Table Eco-1 includes those active ingredients and adjuvants assessed in the 2014 EIR. The
application scenarios analyzed in this SLERA were not substantially similar to any of the
previously analyzed scenarios. Two insecticidal active ingredients analyzed in the 2014 EIR
have been eliminated from the IPMP: d-trans allethrin and phenothrin, ingredients in PT Wasp-
Freeze. PT Wasp-active
ingredients in Table Eco-1 will be considered for adverse effect to the California giant
salamander and Santa Cruz black salamander. Environmental fate properties of the active
ingredients assessed are presented in IPM Guidance Manual Appendix A (MROSD, 2014a). The
potential for adverse effect for all special-status species will be assessed for the three new active
ingredients: triclopyr BEE, triclopyr TEA, and prallethrin. Environmental fate properties of the
three new active ingredients assessed here can be found in Table Eco-2.
Exhibit A
Appendix 1
Ardea Consulting 14 MROSD Integrated Pest Management Plan
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Source: California Natural Diversity Database.
Figure Eco-1. Locations for California Giant Salamander and Santa Cruz Black Salamander Throughout the District.
Exhibit A
Appendix 1
Ardea Consulting 15 MROSD Integrated Pest Management Plan
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2.3 Environmental and Ecological Settings
The setting has not dramatically changed from that assessed in the 2014 EIR. Refer to the 2014
EIR for a full description of the ecological setting for the District. The principal change to the
setting is the inclusion of California giant salamander and Santa Cruz black salamander as
species of special concern. Figure Eco-1 displays where these two species have been known to
occur within the District (CNDDB, 2017). Their widespread distribution indicates that there is a
high likelihood that some pesticide applications could be conducted in or near their habitats.
In the 2014 EIR, the California tiger salamander (Ambystoma californiense) was assessed. Some
important differences between the California tiger salamander and the two additional
salamanders involve habitat and breeding biology. California tiger salamander breeds in seasonal
pools and ponds which dry between rainy seasons. Therefore, the California tiger salamander
larvae need to metamorphose before the pools dry up. California giant salamanders breed in
permanent and semipermanent streams, and the larvae do not metamorphose for up to 18 months.
Santa Cruz black salamanders do not have an aquatic larval stage. Eggs are laid in moist
burrows, and the juveniles emerge from the egg appearing as fully formed small salamanders.
Life history information for these three salamander species is found in Table Eco-3.
2.4 Assessment Endpoints and Measures of Ecological Effect
An endpoint is the outcome of an effect on an ecological component, for instance, increased
mortality of fish due to a pesticide application. An assessment endpoint is the specific statement
of the environmental effect that is going to be protected, such as the prevention of fish mortality
due to a pesticide application. Measurement endpoints are measurable attributes used to evaluate
the risk hypotheses and are predictive of effects on the assessment endpoints (USEPA, 1998).
Since a specific individual of a species may have different mortality susceptibility compared to
other individuals of the same species, it is common to use a statistical representation to define
what is meant by the assessment endpoint. For instance, it is common to assess mortality by
using the lethal dose at which 50 percent of the population in a study failed to survive (LD 50).
Assessment endpoints are the ultimate focus in risk characterization and link the measurement
endpoints with the risk decision making process. The ecological effects that the SLERA intends
to evaluate are determined by the assessment endpoint which is characterized by a specific
measurement endpoint.
Exhibit A
Appendix 1
Ardea Consulting 16 MROSD Integrated Pest Management Plan
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Table Eco-3. Life history characteristics of the California tiger salamander, California
giant salamander, and the Santa Cruz black salamander.
Characteristics
California Tiger Salamander
(Ambystoma californiense)
Santa Cruz Black Salamander
(Aneides flavipunctatus niger )
California Giant Salamander
(Dicamptodon ensatus)
Life Stages Eggs hatch in ~10-14 d. Larvae
require significantly more time
to transform into juveniles than
other amphibians. Around late
spring, salamanders leave the
ponds to find burrows. Adults
reach sexual maturity in 4-5 yr.
They are large and stocky with
a broad, rounded snout. They
are black in color with white or
pale yellow spots.
Little is published on the
ecological and life history of
this species. Eggs undergo
direct development, and fully
formed juveniles appear at the
surface shortly after the onset
of fall rains, often in October
or November. Juveniles have
brassy dorsal coloration with
white or light blue spots.
Adults are either solid black or
black with a few small white
flecks.
The larval stage lasts ~18 mo.
Larval dorsal coloration is light
brown with a pale eye strip
behind each eye. Larvae reach
10 cm within a year of hatching
and metamorphose in late
summer. Adults are tan to light
reddish brown with coppery tan
to dark brown irregular
marbling. Marbling coloration
is often brighter in young
metamorphs than in adults.
Diet Adults mostly eat insects.
Larvae eat things such as algae,
mosquito larvae, tadpoles and
insects.
No diet information has been
published. It is presumed that
this species is a generalized
predator of small arthropods
and other invertebrates.
Adults feed on vertebrates such
as other salamanders, lizards,
mice, shrews, and voles, and
invertebrates such as land
snails, beetles, and crickets.
Larvae are presumed to
consume aquatic insects and
other invertebrates.
Habitat Restricted to vernal pools and
seasonal ponds, including
many constructed stock ponds,
in grassland and oak savannah
plant communities,
predominantly from sea level
to 2,000 ft. Prefer natural
ephemeral pools or ponds that
mimic them. Live
underground, using burrows
made by burrowing mammals.
Restricted to mesic forests in
the fog belt of the outer Coast
Range. Occur in moist
streamside microhabitats and
found in shallow standing
water or seeps, under stones
along stream edges and boards
near creeks. Also occur in talus
formations or rock rubble.
Spend the majority of time
underground.
Occur in mesic coastal forests
(oak woodland and coniferous
forest) and coastal chaparral
habitats. Adults are
occasionally found surface
active or under cover objects in
wet conditions.
Travel/Activity Enter a dormant state called
estivation during the dry
months. They come out of their
burrow around November.
Nocturnal.
Most active on the surface at
night, and more so during rain
events.
Primarily nocturnal, but may
also be active during daytime.
Most active during rain events.
Breeding Emerge from burrows for pond
breeding in November,
commonly during heavy
rainfall. Females lay as many
as 1,300 eggs, singly or in
small groups. Eggs are usually
attached to vegetation.
Females lay eggs underground
in July or early August.
Breeding and larval
development occur in cold
permanent and semipermanent
streams during the rainy season
and in the spring. Females lay
eggs during spring and likely
guard nests through hatching.
Distribution Scattered in the Coastal region
from Sonoma Co. in the
northern San Francisco Bay
Area to Santa Barbara Co. up
to 3,500 ft. in elevation, and in
the Central Valley and Sierra
Nevada foothills from Yolo to
Kern Co. up to 2,000 ft. in
elevation.
Endemic to CA and have a
small range in the woodlands
of the Santa Cruz Mountains in
western Santa Clara, northern
Santa Cruz, and southernmost
San Mateo Co. Occur from
Sonoma Co. north along the
coast into southwestern Oregon
and east to Shasta Co.
Endemic to CA, occupying a
small range from sea level to
3,000 ft. in elevation along the
coast in two isolated areas near
San Francisco Bay. South of
the Bay, they occur in the
Santa Cruz Mountains in San
Mateo, Santa Clara, and Santa
Cruz Co.
Sources: Kucera, 1997; Thomson et al., 2016; USEPA, 2010; USFWS, 2017
Exhibit A
Appendix 1
Ardea Consulting 17 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
2.4.1 Assessment Endpoints
Three principal criteria are used to select ecological characteristics that may be appropriate for
assessment endpoints: (1) ecological relevance, (2) susceptibility to known or potential stressors,
and (3) relevance to management goals. Of these, ecological relevance and susceptibility are
essential for selecting assessment endpoints that are scientifically defensible (USEPA, 1998a).
Although stressors can consist of many different environmental factors, the stressors addressed
in this SLERA are those effects related to pesticide active ingredient and adjuvant exposure. This
SLERA endpoints focus on organism-level outcomes. These include adverse effects such as
mortality, reproductive effects, and pathological changes (e.g., kidney or liver tissue damage)
(USEPA, 2003a).
The acute assessment endpoints selected in this SLERA for the IPMP include the prevention of
mortality in special-status terrestrial and aquatic invertebrates (including pollinator insects),
amphibians, fish, reptiles, birds, mammals, and plants.
The chronic assessment endpoints selected for the SLERA include the protection of survival and
reproduction of the same species groups.
Typically, reproduction is a more sensitive endpoint than survival. Thus, this endpoint has been
used over survival when it is available to result in a more conservative analysis. Adverse
reproductive effects generally do not materialize until chronic exposures have occurred.
2.4.2 Measurement Endpoints
In terms of measurement endpoints, qualitative estimates of exposure have been used to evaluate
levels at which exposure may occur whereas measures of effect (e.g., LD50) have been used to
evaluate the response of the assessment endpoints if exposed to stressors. Concentration of a
pesticide active ingredient or adjuvant in water is a measure of exposure for an aquatic species,
and daily intake of a pesticide active ingredient or adjuvant in dietary items is a measure of
exposure for terrestrial species. The concentration in water or the amount of daily ingestion of
pesticide active ingredient or adjuvant that causes adverse effects are measures of effects. The
likelihood of presence at the application site is addressed qualitatively in the risk
characterization.
Specific measurement endpoints used to estimate adverse effects include no observable adverse
effect levels (NOAELs), lowest observable adverse effects levels (LOAELs), and the median
lethal (or effective) dose or concentration (e.g., LD50, ED50, LC50, or EC50). For many
amphibians and reptiles, toxicity data from other taxonomic groups were used for effects
assessment. For the aquatic-phase for amphibians, fish, such as the rainbow trout, were often
used to derive an appropriate TRV. For reptiles and terrestrial-phase amphibians, bird toxicity
values act in place of specific toxicity values for reptile or terrestrial amphibian species (USEPA,
2004a).
Exhibit A
Appendix 1
Ardea Consulting 18 MROSD Integrated Pest Management Plan
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2.5 Conceptual Site Models
Development of conceptual site models (CSMs) is a fundamental part of the risk assessment
process, and their inclusion in the SLERA is intended to allow the reader to understand the
exposure pathways which were evaluated for the application scenarios. The CSM is a written and
visual representation of predicted relationships among stressors (e.g. a pesticide application),
exposure pathways (e.g. eating vegetation containing pesticide), and assessment endpoints (e.g.
mortality). It outlines the potential routes of exposure for each assessment endpoint and includes
a description of the complete exposure pathways. An exposure pathway demonstrates how a
pesticide active ingredient or adjuvant would be expected to travel from a source (application of
pesticide active ingredient or adjuvant) to a plant or animal that can be affected by that pesticide
active ingredient or adjuvant. An exposure pathway that is not complete means that it is unlikely
for that organism to be exposed to the pesticide active ingredient or adjuvant by that exposure
route. Application-specific CSMs are presented below (Figures Eco-2 to Eco-4).
The ecological CSM covers the multiple pathways through which ecological receptors could be
exposed to pesticide active ingredients and adjuvants that may be applied by the District. The
starting point of each CSM is the application technique, which determines the characteristics of
release of the pesticide active ingredient or adjuvant into the environment. Additionally, the site
at which the application occurs can greatly determine what species could be present and whether
exposure was likely.
2.6 Analysis Plan
This SLERA uses both reported values in the scientific literature and past pesticide use by the
District to estimate the exposures outlined by the CSM. In addition, effects data for the
measurement endpoints uses data available from the scientific literature. The analysis is
qualitative in that each scenario and setting is considered to determine whether the amount of
pesticide active ingredients and adjuvants applied will be sufficient to produce adverse effects.
The analysis plan with the CSMs has been implemented in the next phase of the ecological risk
assessment process: analysis. The analysis phase is subdivided into two sections: exposure
assessment and effects assessment.
3
The exposure assessment is part of the analysis phase of the risk assessment process which
follows the problem formulation phase described in Section 2. The exposure assessment provides
a description of the nature and magnitude of the interaction between pesticide active ingredient
or adjuvants in surface water, sediment, soil, or diet and the ecological receptors. The exposure
to a pesticide active ingredient or adjuvant within an environmental compartment (i.e. within
soil, water, plant tissue, or a specific organism) is based on estimates of quantities released,
discharge patterns and inherent disposition of the substance (i.e. fate and distribution), as well as
the nature of the specific receiving ecosystems. The results of the exposure assessment are
combined with the effects assessment to derive the risk characterization results in the final phase
of the risk assessment process.
Exhibit A
Appendix 1
Ardea Consulting 19 MROSD Integrated Pest Management Plan
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Figure Eco-2. Conceptual Site Model for California Giant Salamander and Santa Cruz Black Salamander Following
Applications in and Around District Buildings
Exhibit A
Appendix 1
Ardea Consulting 20 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc. Screening Level Ecological Risk Assessment
Figure Eco-3. Conceptual Site Model for California Giant Salamander and Santa Cruz Black Salamander Following
Applications in Managed, Natural, and Recreational Areas
Exhibit A
Appendix 1
Ardea Consulting 21 MROSD Integrated Pest Management Plan
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Figure Eco-4. Conceptual Site Model for Insecticides Following Applications Outside District Buildings and Insecticides and
Herbicides Following Applications in Managed, Natural, and Recreational Areas
Exhibit A
Appendix 1
Ardea Consulting 22 MROSD Integrated Pest Management Plan
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The exposure assessments are broken down between acute (short term) and chronic (long term)
exposures, described in detail below. Several assumptions are required to estimate the amount of
pesticide active ingredient or adjuvants that an organism is exposed to as the pesticide active
ingredient or adjuvant gets transported along the various exposure pathways. The assumptions
for acute and chronic exposures, for each receptor group in general, in aquatic and terrestrial
environments, and under each application scenario are included below.
Typical fate properties which tend to decrease the concentration of a pesticide active ingredient
or adjuvant include aerobic degradation, anaerobic degradation, photolysis, hydrolysis,
absorption, solubilization, and volatilization. Key transport properties that may not be accounted
for are dilution and partial transfer between media such as plants, soil, water, and air.
3.1 Acute Exposure
Pesticide active ingredients and adjuvants typically degrade or dissipate following their release
into the environment due to various fate and transport processes. Thus, peak residue levels
typically occur immediately following an application and are used to provide an upper bound
and conservative estimate for an acute exposure. In a typical SLERA, an acute exposure is
considered to be less than 14 days for fish mammals and birds. For other receptors, an acute
exposure lasts for less than 3 days (USEPA, 1999).
Under a scenario in which a single application is sufficient for the control of the pest, the
pesticide active ingredient and adjuvant residue shortly after the application is complete is used
to estimate the acute exposure. If multiple applications are required, the highest concentration
may occur following later applications due to the build-up of pesticide active ingredient and
adjuvants from previous application(s) prior to their complete transport or breakdown.
Dissipation in vegetation, soil, water, and other environmental media contributing to dietary
intake all occur similarly, although at different rates.
3.1.1 Acute Exposure in Terrestrial Species
The peak instantaneous residue for each environmental media have been used for acute exposure
estimates. Following a single application, the peak concentrations would occur immediately
following the application. Following multiple applications, the peak concentration could occur
following one of the later applications. Past use patterns and rates are used to qualitatively
estimate the level of pesticide active ingredient and adjuvant residues following an application.
For many application scenarios small amounts are used in isolated areas (e.g., spraying yellow
jacket ground nests). Under these scenarios, it is possible that there will be high concentrations
within that isolated area. Other application scenarios provide for applications over a larger area
(e.g., wick, or spot spraying for weeds). When applications are made over a larger area, the
potential for exposure increases as more individuals of a species could be present or move into
the treated area.
3.1.2 Acute Exposure in Aquatic Species
No treatment of aquatic weeds is
herbicide active ingredients and adjuvants in surface water would only be possible following an
Exhibit A
Appendix 1
Ardea Consulting 23 MROSD Integrated Pest Management Plan
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accidental spill. Mosquito treatments in watering trough include placements of Bacillus
thuringiensis var. israelensis (Bti) disk in the water. Fish and most aquatic invertebrates will
have no access to such water troughs, so exposure for aquatic species to Bti for mosquito control
will not occur.
3.2 Chronic Exposure
Chronic risk is based on the impacts resulting from long-term exposure to a pesticide active
ingredient or adjuvant. Chronic exposure is typically over many months. However, for short-
lived species such as some aquatic invertebrates, chronic exposure based on exposure across
critical life-stages is considered to be on the order of a few weeks.
3.2.1 Chronic Exposure in Terrestrial Species
Chronic exposure for pesticide active ingredient and adjuvant is to continuously diminishing
concentrations in environmental media. This is due to the fact that concentrations decrease over
time. Some species with small home ranges for foraging areas might be exposed continuously if
the treated area is greater than their home range. Other species with larger home ranges might
only be exposed periodically as they move into and out of the treated area. If a pesticide active
ingredient or adjuvant dissipates rapidly, species might not experience exposure for a sufficient
duration to constitute a chronic exposure.
3.2.2 Chronic Exposure in Aquatic Species
Chronic exposures for aquatic species would result from pesticide active ingredient and adjuvant
movement to water bodies from treated areas. Movement across soil surface or leaching through
soil from a treated site to a surface water body is possible. Mitigation Measures 4.2-1a and 4.2-
1b were discussed in the 2014 EIR to minimize movement of pesticide active ingredients and
adjuvants to surface water bodies by including a 15-foot buffer distance between surface water
and application sites. Best management practices (BMPs) included in the 2014 EIR also protect
surface water bodies by minimizing movement to surface water bodies. These include BMPs 19
(Aquatic Areas), 20 (California red-legged frog [Rana draytonii]) and 32 (Surface and
Groundwater Protection). These Mitigation Measures and BMPs all restrict pesticide
applications within 15 feet of surface water bodies. Therefore, surface water concentrations are
expected to be low or nonexistent such that chronic exposure following pesticide applications is
unlikely.
4
The effects assessment consists of an evaluation of available toxicity or other adverse effects
information that can be used to relate the exposures to pesticide active ingredients or adjuvants
and adverse effects in ecological receptors. Toxicity is a property of a pesticide active ingredient
or adjuvant, and its toxicity alone does not indicate its potential to harm a given organism. A key
to understanding the effects on an organism is the dosage of the pesticide active ingredient or
adjuvant that the organism receives or the concentration to which it is exposed. For example,
certain substances are considered toxic (e.g., caffeine), but are harmless in small dosages.
Exhibit A
Appendix 1
Ardea Consulting 24 MROSD Integrated Pest Management Plan
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Conversely, an ordinarily harmless substance (e.g., water) can be lethal if over-consumed. This
relationship between exposure and effect on an organism is called a dose-response effect and is
discussed in Section 5: Risk Characterization. Data that can be used to define the toxicity of a
pesticide active ingredient or adjuvant include literature-derived or site-specific single-chemical
toxicity data, site-specific ambient-media toxicity tests, and site-specific field surveys (Suter,
2007). For this SLERA, data were restricted to single pesticide active ingredient or adjuvant
toxicity data from literature sources because specific toxicity data for the mixtures of pesticide
active ingredient with adjuvants were not available. Available toxicity information for the active
Table Eco-4.
For certain pesticide active ingredients or adjuvants, no toxicity results are available for various
taxonomic groups. For example, toxicity testing of reptiles is rare, and although becoming more
common, many pesticides still lack toxicity test results for amphibians. USEPA (2004a)
guidance is to use bird toxicity values in place of specific toxicity values for reptile species and
terrestrial-phase amphibians when effects data were not available. USEPA commonly uses
freshwater fish such as the rainbow trout as the surrogate species for the aquatic-phase of
amphibians (USEPA, 2004a). The USEPA (2017) does not recommend applying any additional
uncertainty or safety factors when using avian or fish toxicity endpoints for other taxonomic
groups.
The USEPA has developed acute toxicity categories for pesticide active ingredients or adjuvants
nontoxic (Table Eco-5). These are strictly based on the results of laboratory acute
toxicity tests and do not reflect the exposure or dose received by an organism that determines if
there is an adverse effect following a pesticide application. This classification only gives a
description of the numerical toxicity property of the pesticide active ingredient or adjuvant. It is
not until it is combined with an estimate of exposure that adverse effects may occur. The detailed
description of the toxicity classification from Table Eco-5 for the various active ingredients and
adjuvants is provided for each application scenario below.
4.1 Adjuvants Considered for Toxicity to California Giant Salamander and Santa
Cruz Black Salamander
4.1.1 Alcohol Ethoxylate
Amphibian toxicity data were not available for alcohol ethoxylate (CAS RN 34398-01-1). For
aquatic-phase amphibians an LC50 of 4.59 mg/L for African clawed frogs (Xenopus laevis)
(Cardellini and Ometto, 2001) testing alcohol ethoxylate (CAS RN unstated) as a surrogate
chemical. Therefore, alcohol ethoxylate would be considered moderately toxic to aquatic-phase
amphibians. No bird toxicity data were available for alcohol ethoxylate to use for terrestrial-
phase amphibians. Using the mammalian LD50 of 1,400 mg/kg (Gingell and Lu, 1991) as the
next best toxicity value, alcohol ethoxylate would be considered slightly toxic to terrestrial-phase
amphibians.
Exhibit A
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Table Eco-4. Acute Ecotoxicity Data for Terrestrial and Aquatic Organisms.
Active Ingredient1
Mammalian
Oral LD50
(mg/kg)2
Avian LD50
(mg/kg)3
Honeybee
LD50 (µg/bee)
Reptilian
LD50
(mg/kg)4
Fish LC50
(mg/L)5
Amphibian
LC50 (mg/L)6
Aquatic Invert
EC50 (mg/L)7
ADJUVANTS/SURFACTANTS
Alcohol
Ethoxylate 1,400* NDA NDA NDA 0.59* 4.59* 0.2*
Alkylphenol
Ethoxylate 600* NDA NDA NDA 1.3* NDA 14*
Canola Oil, Ethyl
and Methyl Esters >5,000* NDA NDA NDA 95* NDA >100*
Lecithin >5,000* NDA NDA NDA 17.6* NDA 9.3*
FUNGICIDES
Phosphite K Salts,
mono-/di- >5,000 >1,060 >13.3 NDA >544.6 NDA >544.6
HERBICIDES
Aminopyralid
TIPA >5,000* >2,250* >100contact*
>117oral* NDA >100*
>95.2*
(N. leopard
frog)
>98.6*
Clethodim 1,360 >2,000 >100contact NDA 19 NDA 20.2
Clopyralid MEA >5,000* >1,465 >100contact
>100oral NDA 103.5 NDA 225
Glyphosate IPA >6,000
(mouse) >3,851 >100contact
>100oral NDA 11 7.6 5.3
Glyphosate K >4,800* >2,000* >100contact*
>100oral* NDA 45* 2.9
(wood frog) 134*
Imazapyr IPA >5,000* >2,150 >100contact* NDA 112 NDA 350
Triclopyr BEE 803 735 >100contact NDA 0.36 3.29
(leopard frog) 12
Triclopyr TEA 1,847 3,175 >100contact* NDA 240 159 775
INSECTICIDES
Diatomaceous
Earth >5,000 NDA NDA NDA NDA NDA NDA
D-trans Allethrin 900female*
2,150male* >2,000* 3.4contact*
4.6oral* NDA 0.0094 NDA 0.0089*
Fipronil 97 11.3 0.009contact
0.19oral 30 0.025 0.85 0.1
Indoxacarb 179 98 0.18contact
18.52oral NDA 0.65 NDA 0.064
Phenothrin >5,000 >2,510 0.067contact NDA 0.017 NDA 0.0044
Prallethrin 460 >1,000 0.028contact NDA 0.012 NDA 0.0062
S-Hydroprene >5,050 NDA NDA NDA >100* NDA 0.0029*
Sodium
Tetraborate
Decahydrate
4,550 >2,150* >362.58contact* NDA 27 420* 133*
RODENTICIDES
Cholecalciferol 25.24 >600 NDA NDA NDA NDA NDA
Exhibit A
Appendix 1
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Table Eco-4. Continued.
1 Surrogate chemicals were used when no ecotoxicity data were available for target chemicals. When no ecotoxicity data were
available for both target and surrogate chemicals, values are described as No Data Available (NDA). For each active
ingredient, the following surrogate chemicals were used to obtain ecotoxicity values (*):
Alcohol Ethoxylate: Alcohols, C9-11, ethoxylated (mammalian); Alcohols, C14-15, ethoxylated (fish, aquatic invert);
Alcohol ethoxylate, unspecified (amphibian)
Alkylphenol Ethoxylate (proprietary blend): Alkylphenol Ethoxylate (mammalian, fish, aquatic invert)
Canola Oil, Ethyl and Methyl Esters (proprietary blend): Competitor Formulation (mammalian, fish, aquatic invert)
Lecithin: Liberate Formulation (mammalian, fish, aquatic invert)
Aminopyralid TIPA: Aminopyralid (mammalian, avian, honeybee, fish, amphibian, aquatic invert)
Clopyralid MEA: Clopyralid (mammalian)
Glyphosate K: Glyphosate (mammalian, avian, honeybee, fish, aquatic invert)
Imazapyr IPA: Imazapyr (mammalian, honeybee)
Triclopyr TEA: Triclopyr (honeybee)
D-trans Allethrin: D-allethrin (mammalian); Allethrin (avian, honeybee, aquatic invert)
S-Hydroprene: Hydroprene (fish, aquatic invert)
Sodium Tetraborate Decahydrate: Boric acid (avian, honeybee, amphibian, aquatic invert)
2 Values are for rats unless otherwise specified.
3 Values are for mallard duck or bobwhite quail.
4 Values are for fringe-toed lizard.
5 Values are for rainbow trout or bluegill sunfish.
6 Values are for African clawed frog or Australian tree frog unless otherwise specified.
7 Values are for Daphnia magna or similar species.
* Value is derived from a surrogate chemical. See Footnote 1.
A No Observable Effect Level (NOEL) or No Observable Effect Concentration (NOEC) was used when no LD 50 or LC50
data, respectively, were available.
Sources: [Alcohol Ethoxylate: Gingell and Lu, 1991; Kline et al., 1996; Cardellini and Ometto, 2001; Morrall et al., 2003],
[Alkylphenol Ethoxylate: Hardin et al., 1987; Macek and Krzeminski, 1975; Dorn et al., 1993], [Canola Oil, Ethyl and Methyl
Esters: Wilbur-Ellis, 2010; WSDA, 2009], [Lecithin:Loveland Products, 2016; WSDA, 2009], [Phosphite K Salts, mono-/di-:
Health Canada PMRA, 2012], [Aminopyralid TIPA: USEPA, 2001a, 2001b, 2003b, 2003c, 2004, 2005a], [Clethodim: USEPA,
1986a, 1986b, 1986c, 1990a, 2014a], [Clopyralid MEA: SERA, 2004; USEPA, 1974a, 1974b, 1978b, 1980a, 1980b],
[Glyphosate IPA: McComb et al., 2008; USEPA, 1972a, 1972b, 1978b, 1980c, 1980d, 1995a], [Glyphosate K: USEPA, 1995b,
1995c, 1997a, 2015; Navarro-Martin et al., 2014], [Imazapyr IPA: USEPA, 1983, 1984a, 1984b, 1984c, 2005b], [Triclopyr
BEE: USEPA, 1980e, 1985a, 1991, 1993a, 1998b; Wojtaszek et al., 2005], [Triclopyr TEA: USEPA, 1973a, 1978c, 1978d,
1992a, 1998b; Perkins et al., 2000], [Diatomaceous Earth: USEPA, 1984d], [D-trans allethrin: WHO, 2002; USEPA, 1984e,
1992b, 1993b; Stevenson, 1986], [Fipronil: USEPA, 1990b, 1990c, 1992c, 2007; Zaluski et al., 2015; Peveling and Demba,
2003; Overmyer et al., 2007], [Indoxacarb: DPR, 2006; USEPA, 1979, 1994a, 1995d, 1997b, 2003d], [Phenothrin: USEPA,
1975, 1978e, 1989, 1994b, 2008], [Prallethrin: USEPA, 1989b, 1989c, 1989d, 1989e, 2014b], [S-Hydroprene: HSDB, 2016;
USEPA, 1973c; Oda et al., 2005], [Sodium Tetraborate Decahydrate: USEPA, 1982, 1984f, 1987, 2006; Birge and Black, 1977;
Bantle et al., 1999], [Cholecalciferol: Lam, 1992; USEPA, 2004d]
Table Eco-5. Acute Ecotoxicity Categories for Terrestrial and Aquatic Organisms.
Toxicity
Category
Avian: Acute Oral
LD50 (mg/kg)
Avian: Dietary
Concentration
(mg/kg-diet)
Aquatic
Organisms: Acute
LC50 (mg/L)
Wild Mammals:
Acute Oral LD50
(mg/kg)
Non-Target
Insects: Acute
LD50 (µg/bee)
very highly
toxic <10 <50 <0.1 <10
highly toxic 10-50 50 500 0.1 - 1 10 - 50 <2
moderately
toxic 51-500 501 1000 >1 - 10 51 - 500 2 - 11
slightly toxic 501-2000 1001 5000 >10 - 100 501 - 2000
practically
nontoxic >2000 >5000 >100 >2000 >11
Source: USEPA 2017
4.1.2 Alkylphenol Ethoxylate
Amphibian toxicity data were not available for alkylphenol ethoxylate. For aquatic-phase
amphibians an LC50 of 1.5 mg/L for bluegill sunfish (Lepomis macrochirus ) (Macek and
Exhibit A
Appendix 1
Ardea Consulting 27 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
Krzeminski, 1975 in ECOTOX, 2018) would indicate alkylphenol ethoxylate is moderately toxic
to aquatic-phase amphibians. No bird toxicity data were available for alkylphenol ethoxylate to
use for terrestrial-phase amphibians. Using the mammalian NOEL of 600 mg/kg in a formulated
product (Hardin et al., 1987 in ECOTOX, 2018) as the next best toxicity value, alkylphenol
ethoxylate would be considered at most slightly toxic to terrestrial-phase amphibians.
4.1.3 Canola Oil, Ethyl and Methyl Esters
Amphibian toxicity data were not available for canola oil. For aquatic-phase amphibians an LC 50
of 95 mg/L for rainbow trout (WSDA, 2009) testing modified vegetable (seed) oil, polyethylene
glycol fatty acid ester, polyoxyethylene sorbitan fatty acid ester as surrogate chemicals would
indicate canola oil is slightly toxic to aquatic-phase amphibians. No bird toxicity data were
available for canola oil to use for terrestrial-phase amphibians. Using the mammalian LD 50 of
>5,000 mg/kg (Wilbur-Ellis, 2010) testing modified vegetable oil as a surrogate as the next best
toxicity value, canola oil would be considered practically nontoxic to terrestrial-phase
amphibians.
4.1.4 Lecithin
Amphibian toxicity data were not available for lecithin. For aquatic-phase amphibians an LC 50 of
17.6 mg/L for rainbow trout (WSDA, 2009) testing a mixture of lecithin, methyl esters of fatty
acids, and alcohol ethoxylates as surrogate chemicals would indicate lecithin is slightly toxic to
aquatic-phase amphibians. No bird toxicity data were available for lecithin to use for terrestrial-
phase amphibians. Using the mammalian LD50 of >5,000 mg/kg (Loveland Products, 2016)
testing a mixture of lecithin, methyl esters of fatty acids, and alcohol ethoxylates as surrogates as
the next best toxicity value, canola oil would be considered practically nontoxic to terrestrial-
phase amphibians.
4.2 Pesticide Active Ingredients Considered for Toxicity to California Giant
Salamander and Santa Cruz Black Salamander
4.2.1 Phosphite, mono-/di-potassium salts
Amphibian toxicity data were not available for the monopotassium and dipotassium phosphite
salts. For aquatic-phase amphibians an LC50 of >544.6 mg/L for rainbow trout (PMRA, 2012)
would indicate the monopotassium and dipotassium phosphite salts are practically nontoxic to
aquatic-phase amphibians. Using the avian LD50 of >1,060 mg/kg for mallard ducks (Anas
platyrhynchos) (PMRA, 2012), the monopotassium and dipotassium phosphite salts would be
considered, at most, slightly toxic to terrestrial-phase amphibians.
4.2.2 Aminopyralid Triisopropanolamine (TIPA) Salt
For aquatic-phase amphibians, an LC50 of >95.2 mg/L for northern leopard frog (Lithobates
pipiens) (USEPA, 2003b in OPP Ecotox) testing aminopyralid as a surrogate would indicate
aminopyralid TIPA is, at most, slightly toxic to aquatic-phase amphibians. Using the avian LD 50
of >2,250 mg/kg for northern bobwhite (Colinus virginianus ) (USEPA, 2001a in OPP Ecotox),
Exhibit A
Appendix 1
Ardea Consulting 28 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
testing aminopyralid as a surrogate would indicate aminopyralid TIPA is practically nontoxic to
terrestrial-phase amphibians.
4.2.3 Clethodim
Amphibian toxicity data were not available for clethodim. For aquatic-phase amphibians, an
LC50 of 18 mg/L for rainbow trout (USEPA, 1986a in OPP Ecotox) would indicate clethodim is
slightly toxic to aquatic-phase amphibians. Using the avian LD 50 of >2,000 mg/kg for northern
bobwhite (USEPA, 1986b in OPP Ecotox) would indicate clethodim is practically nontoxic to
terrestrial-phase amphibians.
4.2.4 Clopyralid Monoethanolamine (MEA) Salt
Amphibian toxicity data were not available for clopyralid MEA. For aquatic-phase amphibians,
an LC50 of 103.5 mg/L for rainbow trout (USEPA, 1978a in OPP Ecotox) would indicate
clopyralid MEA is practically nontoxic to aquatic-phase amphibians. Using the avian LD 50 of
1,465 mg/kg for mallard duck (USEPA, 1980a in OPP Ecotox) would indicate clopyralid MEA
is slightly toxic to terrestrial-phase amphibians.
4.2.5 Glyphosate Isopropylamine (IPA) Salt
For aquatic-phase amphibians, an LC50 of 110.8 mg/L for Australian tree frog (Litoria moorei)
(USEPA, 1995a in OPP Ecotox) would indicate glyphosate IPA is practically nontoxic to
aquatic-phase amphibians. Using the avian LD50 of >3,851 mg/kg for northern bobwhite
(USEPA, 1978b in OPP Ecotox) would indicate glyphosate IPA is practically nontoxic to
terrestrial-phase amphibians.
4.2.6 Glyphosate Potassium (K) Salt
For aquatic-phase amphibians, an NOEC of 2.9 mg/L for wood frog (Lithobates sylvaticus)
(Navarro-Martin et al., 2014 in ECOTOX, 2018) would indicate glyphosate K is, at most,
moderately toxic to aquatic-phase amphibians. Using the avian LD50 of >2,000 mg/kg for
northern bobwhite (USEPA, 1997a in OPP Ecotox) using glyphosate as a surrogate would
indicate glyphosate K is practically nontoxic to terrestrial-phase amphibians.
4.2.7 Imazapyr Isopropylamine (IPA) Salt
Amphibian toxicity data were not available for imazapyr IPA. For aquatic-phase amphibians, an
LC50 of 112 mg/L for rainbow trout (USEPA, 1984a in OPP Ecotox) would indicate imazapyr
IPA (as the Arsenal formulation) is practically nontoxic to aquatic-phase amphibians. Using the
avian LD50 of >2,150 mg/kg for mallard duck (USEPA, 1984b in OPP Ecotox) would indicate
imazapyr IPA (as the Arsenal formulation) is practically nontoxic to terrestrial-phase
amphibians.
Exhibit A
Appendix 1
Ardea Consulting 29 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
4.2.8 Diatomaceous Earth
Almost no toxicity data were available for diatomaceous earth. No aquatic toxicity data were
available for any species. Therefore, no estimate is available for aquatic-phase amphibians.
However, the physical nature of diatomaceous earth suggests it is likely practically nontoxic to
aquatic-phase amphibians. Using the mammalian LD50 of >5,000 mg/kg (USEPA, 1984d) would
indicate diatomaceous earth is practically nontoxic to terrestrial-phase amphibians.
4.2.9 Fipronil
For aquatic-phase amphibians, an LC50 of 0.85 mg/L for African clawed frog (Overmyer et al.,
2007 in ECOTOX, 2018) would indicate fipronil is highly toxic to aquatic-phase amphibians.
Using the avian LD50 of 11.3 mg/kg for northern bobwhite (USEPA, 1990b in OPP Ecotox)
would indicate fipronil is highly toxic to terrestrial-phase amphibians.
4.2.10 Indoxacarb
Amphibian toxicity data were not available for indoxacarb. For aquatic-phase amphibians, an
LC50 of 0.65 mg/L for rainbow trout (USEPA, 1997b in OPP Ecotox) would indicate indoxacarb,
testing Indoxacarb (DPX-MP062-51A), is highly toxic to aquatic-phase amphibians. Using the
avian LD50 of 98 mg/kg for northern bobwhite (USEPA, 1997c in OPP Ecotox) would indicate
indoxacarb is moderately toxic to terrestrial-phase amphibians.
4.2.11 S-Hydroprene
Amphibian toxicity data were not available for S-hydroprene. For aquatic-phase amphibians, an
LC50 of >100 mg/L for bluegill sunfish (USEPA, 1973b in OPP Ecotox) using hydroprene
(Zoecon ZR-512 formulation) as a surrogate would indicate S-hydroprene is practically nontoxic
to aquatic-phase amphibians. Using the mammalian LD 50 of >5,050 mg/kg (HSDB, 2016) would
suggest S-hydroprene is practically nontoxic to terrestrial-phase amphibians.
4.2.12 Sodium Tetraborate Decahydrate
For aquatic-phase amphibians, an LC 50 of 420 mg/L for African clawed frog (Bantle et al., 1999
in ECOTOX, 2018) using boric acid as a surrogate would indicate sodium tetraborate
decahydrate is practically nontoxic to aquatic-phase amphibians. Using the avian LD 50 of >2,510
mg/kg for northern bobwhite (USEPA, 1982 in OPP Ecotox) would indicate sodium tetraborate
decahydrate is practically nontoxic to terrestrial-phase amphibians.
4.2.13 Cholecalciferol
No relevant aquatic toxicity data are available for any species. Therefore, no estimate is available
for aquatic-phase amphibians. Using the avian LD 50 of >600 mg/kg for mallard duck (USEPA,
2004d) would indicate cholecalciferol is, at most, slightly toxic to terrestrial-phase amphibians.
Exhibit A
Appendix 1
Ardea Consulting 30 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
4.3 New Pesticide Active Ingredients Considered for Toxicity to All Special-
Status Species
4.3.1 Triclopyr BEE
Triclopyr BEE is moderately toxic to aquatic-phase amphibians based the LC 50 of 3.29 mg/L for
northern leopard frogs (Wojtaszek et al., 2005 in ECOTOX, 2018). Triclopyr BEE is moderately
toxic to freshwater aquatic invertebrate species based on the LC 50 of 1.7 mg/L in water flea
(Daphnia magna) (USEPA, 1980e in OPP Ecotox). Triclopyr BEE is highly toxic to freshwater
fish based on the LC50 of 0.36 mg/L in bluegill sunfish (USEPA, 1993a in OPP Ecotox).
No toxicity information was available for terrestrial-phase amphibians or reptiles. The toxicity of
triclopyr BEE to terrestrial-phase amphibians and reptiles was considered similar to that in birds
(USEPA, 2017). Triclopyr BEE is slightly toxic to birds based on an LD 50 of 735 mg/kg
(USEPA, 1991 in OPP Ecotox) in northern bobwhite and slightly toxic to mammals based on an
LD50 of 803 mg/kg (USEPA, 1998). Triclopyr BEE is practically nontoxic to bees based on a
contact LD50 of >100 µg/bee (USEPA, 1985a in OPP Ecotox).
4.3.2 Triclopyr TEA
Triclopyr TEA is practically nontoxic to aquatic-phase amphibians based the LC 50 of 159 mg/L
for African clawed frogs (Perkins et al., 2000 in ECOTOX, 2018). Triclopyr TEA is practically
nontoxic to freshwater aquatic invertebrate species based on the LC 50 of 775 mg/L in water flea
(USEPA, 1978c in OPP Ecotox). Triclopyr TEA is practically nontoxic to freshwater fish based
on the LC50 of 240 mg/L in rainbow trout (USEPA, 1973a in OPP Ecotox).
No toxicity information was available for terrestrial-phase amphibians or reptiles. The toxicity of
triclopyr TEA to terrestrial-phase amphibians and reptiles was considered similar to that in birds
(USEPA, 2017). Triclopyr TEA is practically nontoxic to birds based on an LD 50 of 3,176 mg/kg
(USEPA, 1978d in OPP Ecotox) in mallard duck and slightly toxic to mammals based on an
LD50 of 1,847 mg/kg (USEPA, 1998b). Triclopyr TEA is practically nontoxic to bees based on a
contact LD50 of >100 µg/bee, testing triclopyr acid (USEPA, 1985b in OPP Ecotox).
4.3.3 Prallethrin
No toxicity information was available for aquatic-phase amphibians. Prallethrin is very highly
toxic to freshwater aquatic invertebrate species based on the LC 50 of 0.0062 mg/L in water flea
(USEPA, 1989b in OPP Ecotox). Prallethrin is very highly toxic to freshwater fish and aquatic-
phase amphibians based on the LC50 of 0.012 mg/L in rainbow trout (USEPA, 1989c in OPP
Ecotox).
No toxicity information was available for terrestrial-phase amphibians or reptiles. The toxicity of
prallethrin to terrestrial-phase amphibians and reptiles was considered similar to that in birds
(USEPA, 2017). Prallethrin is, at most, slightly toxic to birds based on an LD 50 of >1000 mg/kg
(USEPA, 1989d in OPP Ecotox) in mallard duck and moderately toxic to mammals based on an
LD50 of 460 mg/kg (USEPA, 2014b). Prallethrin is highly toxic to bees based on a contact LD 50
of 0.028 µg/bee (USEPA, 1989e in OPP Ecotox).
Exhibit A
Appendix 1
Ardea Consulting 31 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
5
Risk characterization is the final phase in the risk assessment process. The purpose of the risk
characterization phase is to integrate the two pieces from the analysis phase: exposure and effects
assessments. In risk characterization, exposure and effects data are integrated to allow the risk
assessor to draw conclusions concerning the presence, nature, and magnitude of effects that may
exist under the application scenarios. For this SLERA, qualitative assessments are relied upon to
characterize the risk assessment outcome.
5.1 Potential for a Species to Be Present at the Application Site
One of the first qualitative attributes to consider is the likelihood of the specific species being
present at a particular application site. Since species exist in particular habitats and not all
habitats can occur at a single application site, it is likely that a fraction of the entire list of
special-status species will possibly be present. For instance, if the application site does not
contain suitable foraging habitat for a particular species, it is relatively unlikely to come into the
area and be exposed to pesticide active ingredients or adjuvants by ingestion. Pollinating species
are less likely to be present if there are no plants in bloom present. Some locations are unlikely to
have any species present, such as in or around buildings. Marine/estuarine species would be
absent if the application site is not near the coastline.
standard practice prior to implementing any pesticide application scenario is to
identify whether any special-status species habitat is nearby, and if so, identify appropriate
measures to avoid adversely affecting the species. The District obtains technical assistance from
California Department of Fish and Wildlife (CDFW), National Marine Fisheries Service
(NMFS), and/or United States Fish and Wildlife Service (USFWS). These activities are included
in the mitigation measures and BMPs of the 2014 EIR. With implementation of these mitigation
measures and BMPs, the potential for adverse effects on species as a result of
pesticide applications would be low.
5.2 Foraging Diet
The extent to which a particular species consumes food from the application area will greatly
influence their exposure. Different species forage over vastly different areas. Species with large
foraging areas are unlikely to consume all their diet from within an application area. Long-term
exposures (chronic) are reduced or diluted in such species because a portion of their diets is
likely acquired off the application area.
5.3 Dilution and Degradation of Pesticide Active Ingredients and Adjuvants
Through time, concentrations of pesticide active ingredients and adjuvants following
applications generally decrease. This applies in particular to soil and water concentrations. In
addition to diminished concentrations due to breakdown, dilution (or reduction in concentration
when mixed) will occur when the pesticide active ingredient or adjuvant residues combine with
environmental media that is not contaminated. For instance, during a rain event that assists in
transporting pesticide active ingredient or adjuvant residue from foliage and soil to a waterbody,
additional, uncontaminated water will add to the volume of water in the waterbody itself. This
Exhibit A
Appendix 1
Ardea Consulting 32 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
also applies to water concentrations as the pesticide active ingredient or adjuvant continues to
move from various waterbodies, such as drainage ditches, streams, and rivers. Due to dilution
and low probability of application scenarios being adjacent to a marine/estuarine waterbody, the
potential for elevated concentrations in marine/estuarine waterbodies would be relatively low,
and the potential for adverse effects to marine/estuarine species would be correspondingly low.
5.4 Risk Analysis for Pesticide Active Ingredients and Adjuvants Considered for
Toxicity to California Giant Salamander and Santa Cruz Black Salamander
Santa Cruz black salamander do not have a fully aquatic larval stage, so toxicity testing of larval
amphibians will not portray the toxic impacts for Santa Cruz black salamander very well.
California giant salamander lay eggs and larvae develop in streams. The previous analysis for
California tiger salamander which lays eggs in vernal pools or temporary ponds does not
accurately reflect the potential for risk to aquatic phase Santa Cruz black salamander and
California giant salamander.
The analysis of terrestrial phase California tiger salamanders will reflect reasonably well the
potential for risk for California giant salamander since both species spend a lot of time in
underground burrows. However, Santa Cruz black salamander spend more time in streams, so
the analysis in the 2014 EIR for terrestrial-phase amphibians will not portray the potential for
risk for the Santa Cruz black salamander very well.
Mitigation measures and BMPs included in the 2014 EIR are designed to greatly minimize or
prevent pesticide active ingredients or adjuvants for reaching surface waters. These practices are
anticipated to be protective of aquatic-phase amphibians.
5.4.1 Alcohol Ethoxylate
Alcohol ethoxylate was classified as moderately toxic to aquatic-phase amphibians and slightly
toxic to terrestrial-phase amphibians. Alcohol ethoxylate is one of the ingredients in the adjuvant
Liberate which could be mixed with herbicides and spot sprayed or applied as a cut-stump, basal
bark, or frill/injection treatment or as a wick application. When applied as a cut-stump, basal
bark, or frill/injection treatment or as a wick application or spot spray treatment, the potential for
exposure to either terrestrial-phase or aquatic-phase amphibians is low. The greatest opportunity
for exposure for terrestrial-phase amphibians would be following a spot spray or wick
application made to a large stand of weeds. The potential for exposure to aquatic-phase
amphibians would be low since BMPs minimize or prevent any movement to surface waters.
Due to the low potential for exposure and the low toxicity, the potential for adverse effects is
also low.
5.4.2 Alkylphenol Ethoxylate
Alkylphenol ethoxylate was classified as moderately toxic to aquatic-phase amphibians and
slightly toxic to terrestrial-phase amphibians. Alkylphenol ethoxylate is a component of the
adjuvant Pentra-Bark and is only used to spray or inject tree trunks. Since it would only be
sprayed directly onto or injected into trees, the potential for exposure to terrestrial-phase
amphibians would be extremely low. The potential for exposure for aquatic-phase amphibians is
Exhibit A
Appendix 1
Ardea Consulting 33 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
also low since mitigation measures and BMPs minimize or prevent any movement to surface
waters. Due to the low potential for exposure and the low toxicity, the potential for adverse
effects is also low.
5.4.3 Canola Oil, Ethyl and Methyl Esters
Canola oil was classified as slightly toxic to aquatic-phase amphibians and practically nontoxic
to terrestrial-phase amphibians. Canola is one of the ingredients in the adjuvant Competitor
which could be sprayed with herbicides as a spot spray or applied as a cut-stump, basal bark, or
frill/injection treatment, or as a wick application. When applied as a cut-stump, basal bark, or
frill/injection treatment, or as a wick application or spot spray treatment, the potential for
exposure to either terrestrial-phase or aquatic-phase amphibians is low. The greatest opportunity
for exposure for terrestrial-phase amphibians would be following a spot spray or wick
application made to a large stand of weeds. The potential for exposure to aquatic-phase
amphibians would be low since mitigation measures and BMPs minimize or prevent any
movement to surface waters. Due to the low potential for exposure and the low toxicity, the
potential for adverse effects is also low.
5.4.4 Lecithin
Lecithin was classified as slightly toxic to aquatic-phase amphibians and practically nontoxic to
terrestrial-phase amphibians. Lecithin is one of the ingredients in the adjuvant Liberate which
could be sprayed with herbicides as a spot spray or applied as a cut-stump, basal bark, or
frill/injection treatment, or as a wick application. When applied as a cut-stump, basal bark, or
frill/injection treatment, or as a wick application or spot spray treatment, the potential for
exposure to either terrestrial-phase or aquatic-phase amphibians is low. The greatest opportunity
for exposure for terrestrial-phase amphibians would be following a spot spray or wick
application made to a large stand of weeds. The potential for exposure to aquatic-phase
amphibians would be low since mitigation measures and BMPs minimize or prevent any
movement to surface waters. Due to the low potential for exposure and the low toxicity, the
potential for adverse effects is also low.
5.4.5 Phosphite, mono-/di-potassium salts
Monopotassium and dipotassium phosphite salts were classified as practically nontoxic to
aquatic-phase amphibians and, at most, slightly toxic to terrestrial-phase amphibians. Products
containing phosphite salts are used solely in the District as a fungicide to treat sudden oak death
(SOD). The low toxicity for aquatic-phase amphibians and terrestrial-phase amphibians and the
limited use pattern lead to a conclusion that use of phosphite salts in the District would pose a
low potential for adverse effects for California giant salamander and Santa Cruz black
salamander.
5.4.6 Aminopyralid TIPA
Aminopyralid TIPA was classified as, at most, slightly toxic to aquatic-phase amphibians and
practically nontoxic to terrestrial-phase amphibians. Products containing aminopyralid TIPA as
the sole active ingredient (e.g. Milestone) could be used in the District for control of invasive
Exhibit A
Appendix 1
Ardea Consulting 34 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
weeds in rangeland, agricultural fields, or in natural lands via spot spray, cut-stump, basal bark,
wick, or frill/injection applications. Refer to Section 5.5.2 for information on use sites and
application methods associated with Capstone, which contains both aminopyralid TIPA and
triclopyr TEA as active ingredients. Despite the possibility of use in a wide variety of settings,
the low toxicity of aminopyralid TIPA to both aquatic-phase amphibians and terrestrial-phase
amphibians indicates it poses a low risk for California giant salamander and Santa Cruz black
salamander when used as a spot spray or wick application for control in invasive weeds or for
woody plants used as cut-stump, basal bark, or frill/injection applications in the District.
5.4.7 Clethodim
Clethodim was classified as slightly toxic to aquatic-phase amphibians and practically nontoxic
to terrestrial-phase amphibians. Clethodim could be used in the District for control of invasive
grass species in natural lands. Its use in natural lands suggests it could be spot sprayed near
salamander habitat. However, the low toxicity of clethodim to both aquatic-phase amphibians
and terrestrial-phase amphibians indicates it poses a low risk for California giant salamander and
Santa Cruz black salamander when used in the District.
5.4.8 Clopyralid MEA
Clopyralid MEA was classified as practically nontoxic to aquatic-phase amphibians and slightly
toxic to terrestrial-phase amphibians. Clopyralid MEA could be used in recreational facilities,
rangeland, agricultural fields, and natural lands as a spot spray or wick application for weeds
such as thistles and clover or for brush and woody plant control as cut-stump or frill/injection
applications. Its use in a variety of settings suggest it could be applied near salamander habitat.
However, the low toxicity of clopyralid MEA to both aquatic-phase amphibians and terrestrial-
phase amphibians indicates it poses a low risk for California giant salamander and Santa Cruz
black salamander when used in the District.
5.4.9 Glyphosate IPA
Glyphosate IPA was classified as moderately toxic to aquatic-phase amphibians and practically
nontoxic to terrestrial-phase amphibians. Glyphosate IPA is the active ingredient in the terrestrial
and aquatic herbicides containing glyphosate. Products containing glyphosate IPA can be used as
a spot spray, cut-stump, wick, or frill/injection treatment in recreational facilities (including on
dam faces), natural lands, and rangeland and agricultural properties. Therefore, there is the
potential for glyphosate IPA to be used near aquatic habitats where aquatic-phase amphibians
could occur. The mitigation measures and BMPs in the 2014 EIR require scouting aquatic
habitats prior to applying pesticides. Adherence to the mitigation measures and BMPs is
anticipated to minimize or prevent exposure of aquatic-phase amphibians. The limited potential
for exposure for aquatic phase Santa Cruz black salamander and the low toxicity of glyphosate
for terrestrial-phase amphibians indicates the potential is low for adverse effects for California
giant salamander and Santa Cruz black salamander following the use of glyphosate IPA for
control of a wide spectrum of weed species, including use as a spot spray, cut-stump, wick, or
frill/injection application in the District.
Exhibit A
Appendix 1
Ardea Consulting 35 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
5.4.10 Glyphosate K
Glyphosate K was classified as, at most, moderately toxic to aquatic-phase amphibians and
practically nontoxic to terrestrial-phase amphibians. Glyphosate K is the active ingredient in the
terrestrial-only herbicides containing glyphosate. Products containing glyphosate K can be
applied via spot spray, cut-stump, wick, or frill/injection treatment in recreational facilities, fuel
management sites, natural lands, and rangeland and agricultural properties. The mitigation
measures and BMPs in the 2014 EIR limit the use of glyphosate K near aquatic habitats.
Adherence to the mitigation measures and BMPs is anticipated to minimize or prevent exposure
of aquatic-phase amphibians. The limited potential for exposure for aquatic phase Santa Cruz
black salamander and the low toxicity of glyphosate for terrestrial-phase amphibians indicates
the low potential for adverse effects for California giant salamander and Santa Cruz black
salamander following the use of glyphosate K for control of a wide spectrum of weed species,
including use as a spot spray, cut-stump, wick, or frill/injection treatment in the District.
5.4.11 Imazapyr IPA
Imazapyr IPA was classified as practically nontoxic to aquatic-phase amphibians and practically
nontoxic to terrestrial-phase amphibians. Products containing imazapyr IPA can be used in
recreational facilities and natural lands for spot spray of a broad spectrum of invasive weeds or
cut-stump or frill/injection treatments. Since products containing imazapyr IPA could be used in
natural lands, it could be sprayed near salamander habitat. However, its low toxicity leads to a
conclusion that imazapyr IPA would pose a low potential for risk for California giant salamander
and Santa Cruz black salamander when used in the District.
5.4.12 Diatomaceous Earth
Diatomaceous earth is used within the District only for control of structural pests in and around
buildings. Therefore, it is unlikely that aquatic-phase amphibians could be exposed to
diatomaceous earth. Diatomaceous earth was classified practically nontoxic to terrestrial-phase
amphibians. The limited use of diatomaceous earth in and around buildings along with its low
toxicity leads to the conclusion that the use of diatomaceous earth in the District would pose low
to no risk for California giant salamander and Santa Cruz black salamander.
5.4.13 Fipronil
Fipronil was classified as highly toxic to aquatic-phase amphibians and terrestrial-phase
amphibians. However, within the District, fipronil is used only in and around buildings for
control of structural pests. The limited use of fipronil in and around buildings, despite its high
toxicity, leads to the conclusion that the use of fipronil in the District would pose low risk for
California giant salamander and Santa Cruz black salamander.
5.4.14 Indoxacarb
Indoxacarb was classified as highly toxic to aquatic-phase amphibians and moderately toxic to
terrestrial-phase amphibians. However, within the District, indoxacarb is used only in and around
buildings for control of structural pests. The limited use of indoxacarb in and around buildings,
Exhibit A
Appendix 1
Ardea Consulting 36 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
despite its moderate to high toxicity, leads to the conclusion that the use of indoxacarb in the
District would pose low risk for California giant salamander and Santa Cruz black salamander.
5.4.15 S-Hydroprene
S-Hydroprene was classified as practically nontoxic to aquatic-phase amphibians and terrestrial-
phase amphibians. S-Hydroprene is used within the District only for control of structural pests in
and around buildings. The limited use of S-hydroprene in and around buildings along with its
low toxicity leads to the conclusion that the use of S-hydroprene in the District would pose low
to no risk for California giant salamander and Santa Cruz black salamander.
5.4.16 Sodium Tetraborate Decahydrate
Sodium tetraborate decahydrate was classified as practically nontoxic to aquatic-phase
amphibians and terrestrial-phase amphibians. Sodium tetraborate decahydrate is used within the
District only for control of structural pests in and around buildings. The limited use of sodium
tetraborate decahydrate in and around buildings along with its low toxicity leads to the
conclusion that the use of sodium tetraborate decahydrate in the District would pose low to no
risk for California giant salamander and Santa Cruz black salamander.
5.4.17 Cholecalciferol
Cholecalciferol was classified as, at most, slightly toxic to terrestrial-phase amphibians and no
classification of toxicity was possible for aquatic-phase amphibians. Cholecalciferol is limited to
use for control of rodents inside buildings in the District. Use inside buildings precludes any
chance that aquatic-phase amphibians will be exposed. The low toxicity for terrestrial-phase
amphibians leads to the conclusion that use of cholecalciferol, on the slight chance an adult
salamander might wander into a building, poses a low to no potential for risk to California giant
salamander and Santa Cruz black salamander in the District.
5.5 Risk Analysis for New Active Ingredients Considered for Toxicity to All
Special-Status Species
5.5.1 Triclopyr BEE
Triclopyr BEE is intended for use for fuel management and invasive weed control in natural
lands and at the wildland urban interface, in rangeland and agricultural properties as a spot spray,
cut-stump, and basal bark treatment. The potential for use in a wide variety of habitats provides
an opportunity for many special-status species to be exposed following applications of triclopyr
BEE.
5.5.1.1 Risk to Aquatic Special-Status Species
Triclopyr BEE was classified as moderately toxic to aquatic-phase amphibians, moderately toxic
to freshwater aquatic invertebrate species, and highly toxic to freshwater fish. Mitigation
measures and BMPs in the 2014 EIR were incorporated to minimize or prevent the movement
into surface waters of any pesticides used in the District. Implementation of the mitigation
Exhibit A
Appendix 1
Ardea Consulting 37 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
measure and BMPs is anticipated to lead to a low potential for risk to aquatic special-status
species following the use of triclopyr BEE for invasive weed control and fuel management
within the District.
5.5.1.2 Risk to Terrestrial Special-Status Species
The toxicity of triclopyr BEE to terrestrial-phase amphibians and reptiles was considered similar
to that in birds. Triclopyr BEE was classified as slightly toxic to birds and mammals, and
practically nontoxic to bees. The wide variety of habitats where triclopyr BEE could be used
suggests a moderate to high potential for exposure to special-status species following
applications of triclopyr BEE for invasive weed control or fuels management. However, the low
toxicity leads to a conclusion of a low potential for risk for terrestrial special-status species in the
District.
5.5.2 Triclopyr TEA
Triclopyr TEA in Capstone is intended for use in natural lands and rangeland and agricultural
properties as a spot spray for the control of invasive weeds and cut-stump or frill/injection for
control of woody vegetation. The potential for use in multiple habitats provides an opportunity
for many special-status species to be exposed following applications of triclopyr TEA. Note that
Capstone contains both triclopyr TEA and aminopyralid TIPA. Refer to Section 5.4.6 for
information on use sites and application methods associated with only aminopyralid TIPA.
5.5.2.1 Risk to Aquatic Special-Status Species
Triclopyr TEA was classified as practically nontoxic to aquatic-phase amphibians, freshwater
aquatic invertebrate species, and freshwater fish. Implementation of the mitigation measures and
BMPs in the 2014 EIR along with the low toxicity lead to the conclusion of a low potential for
risk to aquatic special-status species following the use of triclopyr TEA for invasive weed
control within the District.
5.5.2.2 Risk to Terrestrial Special-Status Species
The toxicity of triclopyr TEA to terrestrial-phase amphibians and reptiles was considered similar
to that in birds. Triclopyr TEA was classified as practically nontoxic to birds, mammals, and
bees. Use of triclopyr TEA in multiple habitats suggests a moderate to high potential for
exposure to special-status species following applications of triclopyr TEA for invasive weed or
woody plant control. However, the low toxicity leads to a conclusion of a low potential for risk
for terrestrial special-status species in the District.
5.5.3 Prallethrin
Prallethrin is intended for use around buildings and in recreational facilities, for control of
stinging insects such as wasps or yellow jackets. Treatments in recreational facilities could
include treatment of ground nests along hiking trails.
Exhibit A
Appendix 1
Ardea Consulting 38 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
5.5.3.1 Risk to Aquatic Special-Status Species
Toxicity for aquatic-phase amphibians is anticipated to be similar to that determined for
freshwater fish. Prallethrin was classified as very highly toxic to freshwater aquatic invertebrate
species and freshwater fish. Despite being considered highly toxic to aquatic species, prallethrin
is not anticipated to pose a high risk to aquatic special-status species because of its very limited
use. The use being limited to around buildings and along trails in recreational areas indicates
such low potential for exposure of aquatic special-status species that the potential for risk is low.
5.5.3.2 Risk to Terrestrial Special-Status Species
The toxicity of prallethrin to terrestrial-phase amphibians and reptiles was considered similar to
that in birds. Prallethrin was classified as, at most, slightly toxic to birds, moderately toxic to
mammals, but highly toxic to bees. The limited nature of use of prallethrin to treatment around
buildings and to ground nests of stinging insects along hiking trails greatly limits the potential
for exposure for special-status terrestrial vertebrate species. Mitigation Measure 4-2.1c
specifically addresses special-status terrestrial invertebrate species. Adherence to Mitigation
Measure 4-2.1c and the very limited nature of the use pattern leads to a conclusion that the risk
from the use of prallethrin for control of stinging insects in the District is low.
6
Uncertainty in ecological risk assessment derives partly from biological variability. The response
of ecological receptors following exposure to contaminants will vary among individuals within a
species as well as across species. Also, literature values from various species are used to predict
the response of the species of interest in this SLERA. The differences among species always
introduces unavoidable uncertainty to a SLERA. Uncertainty regarding predictions in a risk
assessment may be due to inherent randomness, limited knowledge, or lack of knowledge (Suter,
2007).
6.1 Exposure Assessment Uncertainties
In this SLERA, exposure of ecological receptors could not be directly measured. The application
equipment, areal extent, and location were all considered in a qualitative assessment of exposure.
Past pesticide use information was used as a guide to likely future use, with the understanding
that the program is likely to expand (See Section 3 of the Addendum Report).
Pesticide application scenarios were based on descriptions provided by District staff. Past
pesticide use patterns provide an excellent indicator of likely future use. The most common
conditions under which applications have been made were evaluated, but some uncommon
conditions that could lead to greater or lesser exposure than the scenarios represented in the risk
assessment were not specifically considered. It is possible that smaller or larger application areas
than used in this SLERA could occur in the future.
Most herbicide applications are spot applications where only the target pest plants are treated.
Past records indicate the area in which the treatments were made and the amount of herbicide
Exhibit A
Appendix 1
Ardea Consulting 39 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
applied. However, the distribution within the treated area was not described, so the uniformity of
the application across the landscape is not known, nor can it be predicted for future applications.
This creates uncertainty regarding the concentrations of herbicides within small areas of the
larger treated area. It is possible that target weed species exhibited a clumped distribution and
might do so in the future which would produce an uneven distribution of herbicides across the
landscape.
Since this SLERA is attempting to address potential future applications of pesticides, the
proximity of application sites is not known. For species with large foraging areas, more than one
application site could
of application sites across a species foraging range, the appropriateness of any exposure
estimates cannot be known.
6.2 Effects Assessment Uncertainties
6.2.1 Use of Surrogate Species Effects Data
Toxicity data were rarely available for the special-status species considered in the risk
assessment. Use of effects data from species other than the species of concern inherently added
uncertainty to the assessment. When toxicity data for more than one species was available, the
more sensitive species was selected.
Toxicity data were not always available for all taxonomic groups. This was most common for
amphibians and reptiles. Bird or fish toxicity data were used when no data were available for
terrestrial-phase amphibians and reptiles or aquatic-phase amphibians, respectively. It was not
known when this approach might lead to an over or underestimation of risk.
6.2.2 Sublethal Effects
Sublethal effects were not specifically addressed, but when ecologically relevant sublethal
toxicity endpoints were available, they were included in the reference toxicity data.
6.2.3 Dermal or Inhalation Effects
In SLERAs, it is standard practice to only address effects from oral exposure to terrestrial
vertebrates. In general, focusing on effects from oral exposures is adequate (Suter, 2007: pp.
258-259). However, for terrestrial-phase amphibians, it is possible that dermal exposure to
pesticide active ingredient or adjuvants on surface soils might be readily absorbed and contribute
to adverse effects in these species. Effects data for this pathway do not exist, so any effects from
contact of terrestrial-phase amphibians to pesticide active ingredient or adjuvants in soils are
unknown. Also, inhalation exposure to airborne pesticide active ingredient or adjuvants can
occur. Effects data from inhalation exposure are also lacking for wildlife species. The inability to
include any potential risk derived from dermal or inhalation exposure will necessarily
underestimate total risk, but since these routes are thought to generally be negligible, exclusion
of exposure from these routes did not seriously affect the assessment of risk.
Exhibit A
Appendix 1
Ardea Consulting 40 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
7
This SLERA was conducted to determine the potential harm to ecological receptors from
implementation of previously assessed pesticide active ingredients and adjuvants to California
giant salamander and Santa Cruz black salamander. These two species were not considered
special-status species at the time of the 2014 EIR. This SLERA also considered the potential for
adverse effects from applications of products containing triclopyr BEE, triclopyr TEA, and
prallethrin for all special-status species that could occur within the District. The SLERA
consisted of a qualitative assessment of exposure and along with an evaluation of whether the
level of exposure might be sufficient to produce adverse effects, based on the toxicity of the
pesticide active ingredients and adjuvants. The SLERA relied upon the three-stage process for
risk assessments: problem formulation, analysis, and risk characterization. The problem
formulation stage concluded with a CSM that identified the complete exposure pathways carried
forward in the analysis based on information that was available to evaluate the potential exposure
pathways. During the analysis phase of the SLERA, qualitative exposure estimates were
considered based on application scenarios. Also in the analysis phase, effect values were
identified which incorporated the toxicity properties of the pesticide active ingredient or
adjuvants. The risk characterization phase provided conclusions on the potential for adverse
effects to occur to ecological receptors. The risk characterization phase utilized a qualitative
assessment.
Section 5 lists the results of the risk characterization phase for every species class. As described
in Section 5, the qualitative assessment considers the potential for species presence at an
application site, incorporation of foraging range and diet, and fate and transport processes such
as dilution and degradation.
BMPs are designed to greatly reduce, if not eliminate, movement to surface water.
Therefore, actual impacts to aquatic invertebrates or birds and mammals that feed in aquatic
habitats are anticipated to be minimal. Herbicides exhibit low toxicity to terrestrial animals.
Although there is a greater chance of exposure for special-status terrestrial animals, the low
toxicity leads to a conclusion that terrestrial special-status species are not at risk. Some
insecticides exhibit high toxicity to ecological receptors, mostly aquatic species. However, their
restricted uses to in and around buildings limits exposure such that it can be concluded that
adverse effects will not occur. Because of the targeted nature of prallethrin applications to
stinging insect nests, only those species would be directly exposed. Most insects, such as flying
insects, would receive no exposure following an application to a wasp or hornet nest. Thus, most
insects and insectivorous species are anticipated to be exposed to very limited amounts of
prallethrin, leading to a conclusion that no special-status species are at risk.
This SLERA along with the 2014 EIR will be used to assist the District in assessing the potential
to affect particular species and developing site-specific measures to protect these species. This
SLERA did not identify new significant environmental effects or substantial increases in the
severity of the significant effects identified in the 2014 EIR. No alterations to any of the
scenarios assessed in this SLERA that were not already indicated for other scenarios in the 2014
EIR are recommended for the protection of biological resources.
Exhibit A
Appendix 1
Ardea Consulting 41 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
8
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Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
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Ardea Consulting 44 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
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Appendix 1
Ardea Consulting 45 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
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January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1984a. Imazapyr IPA salt (as Arsenal
formulation) and rainbow trout, Pesticide Ecotoxicity Database. Office of Pesticide Programs.
USEPA. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
Exhibit A
Appendix 1
Ardea Consulting 46 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
U.S. Environmental Protection Agency (USEPA). 1984b. Imazapyr IPA salt (as Arsenal
formulation) and mallard duck, Pesticide Ecotoxicity Database. Office of Pesticide Programs.
USEPA. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1984c. Imazapyr Isopropylamine Salt and
Water flea, Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017.
Office of Pesticide Programs. Washington, D.C. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1984d. Diatomaceous earth TSS/IRB Safety
Review. Available:
https://archive.epa.gov/pesticides/chemicalsearch/chemical/foia/web/pdf/072605/072605-
009.pdf Accessed: January 26, 2018.
U.S. Environmental Protection Agency (USEPA). 1984e. Allethrin and Mallard Duck, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1984f. Boric Acid and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1985a. Triclopyr butoxyethyl ester and honey
bee, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1985b. Triclopyr acid and honey bee,
Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1986a. Clethodim and rainbow trout, Pesticide
Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1986b. Clethodim and bobwhite quail,
Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1986c. Clethodim and Honey bee, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1987. Boric Acid and Honey bee, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Exhibit A
Appendix 1
Ardea Consulting 47 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1989a. Phenothrin and Honey bee, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1989b. Prallethrin and water flea, Pesticide
Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1989c. Prallethrin and rainbow trout, Pesticide
Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1989d. Prallethrin and mallard duck, Pesticide
Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1989e. Prallethrin and honey bee, Pesticide
Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1990a. Clethodim and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1990b. Fipronil MB 46030 and bobowhite
quail, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1990c. Fipronil and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1991. Triclopyr butoxyethyl ester and
bobwhite quail, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1992a. Pesticide Ecotoxicity Database
(Formerly: Environmental Effects Database (EEDB)). Environmental Fate and Effects Division,
U.S.EPA, Washington, D.C. In: U.S. Environmental Protection Agency (USEPA). 2017.
ECOTOX Knowledgebase. Updated: December 14, 2017. Available:
https://cfpub.epa.gov/ecotox/ (Accessed: January 12, 2018).
Exhibit A
Appendix 1
Ardea Consulting 48 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
U.S. Environmental Protection Agency (USEPA). 1992b. Pesticide Ecotoxicity Database
(Formerly: Environmental Effects Database (EEDB)). Environmental Fate and Effects Division,
U.S.EPA, Washington, D.C. In: U.S. Environmental Protection Agency (USEPA). 2017.
ECOTOX Knowledgebase. Updated: December 14, 2017. Available:
https://cfpub.epa.gov/ecotox/ (Accessed: January 12, 2018).
U.S. Environmental Protection Agency (USEPA). 1992c. Fipronil and Rainbow trout, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1993a. Triclopyr butoxyethyl ester and
bluegill sunfish, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA.
Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1993b. Allethrin and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1994a. Indoxacarb and Honey bee Contact,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1994b. Phenothrin and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1995a. Glyphosate isopropylamine salt and
Australian tree frog, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA.
Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1995b. Glyphosate and Bluegill sunfish,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1995c. Glyphosate and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 1995d. Indoxacarb and Honey bee Oral,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
Exhibit A
Appendix 1
Ardea Consulting 49 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
U.S. Environmental Protection Agency (USEPA). 1997a. Glyphosate N-(phosphonomethyl)
glycine and bobwhite quail, Pesticide Ecotoxicity Database. Office of Pesticide Programs.
USEPA. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1997b. Indoxacarb (DPX-MP062-51A) and
rainbow trout, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1997c. Indoxacarb and bobwhite quail,
Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 1998a. Guidelines for ecological risk
assessment. Risk Assessment Forum. EPA/630/R-95/002F. 124 pp.
U.S. Environmental Protection Agency (USEPA). 1998b. Reregistration Eligibility Decision
(RED) triclopyr. Office of Prevention, Pesticides and Toxic Substances. Washington, D.C. EPA
738-R-98-011. 286 pp.
U.S. Environmental Protection Agency (USEPA). 1999. Screening level ecological risk
assessment protocol for hazardous waste combustion facilities. Solid Waste and Emergency
Response. EPA/530-D-99-001A. 46 pp. Available
http://www.epa.gov/osw/hazard/tsd/td/combust/ecorisk.htm
U.S. Environmental Protection Agency (USEPA). 2001a. Aminopyralid and bobwhite quail,
Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: January 10, 2018).
U.S. Environmental Protection Agency (USEPA). 2001b. Aminopyralid and Water flea,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 2003a. Generic Ecological Assessment
Endpoints (GEAEs) for ecological risk assessment. Washington, D.C: Risk Assessment Forum.
EPA/630/P-02/004F. 27 pp.
U.S. Environmental Protection Agency (USEPA). 2003b. Aminopyralid and northern leopard
frog, Pesticide Ecotoxicity Database. Office of Pesticide Programs. USEPA. Available
http://www.ipmcenters.org/Ecotox/index.cfm (Accessed: February 19, 2018).
U.S. Environmental Protection Agency (USEPA). 2003c. Aminopyralid and Bluegill sunfish,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 2003d. Indoxacarb and Water flea, Pesticide
Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of Pesticide
Exhibit A
Appendix 1
Ardea Consulting 50 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm (Accessed:
January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 2004a. Overview of the ecological risk
assessment process in the Office of Pesticide Programs, U.S. Environmental Protection Agency.
Endangered and Threatened Species Effects Determinations. U.S. Environmental Protection
Agency, Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs,
Washington, D.C. 92 pp.
U.S. Environmental Protection Agency (USEPA). 2004b. Aminopyralid and Honey bee Contact,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 2004c. Aminopyralid and Honey bee Oral,
Pesticide Ecotoxicity Database (OPP Ecotox Database). Updated: March 16, 2017. Office of
Pesticide Programs. Washington, D.C. Available http://www.ipmcenters.org/Ecotox/index.cfm
(Accessed: January 17, 2018).
U.S. Environmental Protection Agency (USEPA). 2004d. Potential Risks of Nine Rodenticides
to Birds and Nontarget Mammals: a Comparative Approach. Office of Pesticides Programs
Environmental Fate and Effects Division. Washington, DC. 230 pp.
U.S. Environmental Protection Agency (USEPA). 2005a. Environmental Fate and Ecological
Risk Assessment for the Registration of Aminopyralid. Office of Prevention, Pesticides, and
Toxic Substances. Washington D.C.
U.S. Environmental Protection Agency (USEPA). 2005b. Level I Screening Ecological Risk
Assessment for the Reregistration of Imazapyr. Office of Pesticide Programs. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2006. Report of the Food Quality Protection
Act (FQPA) Tolerance Reassessment Eligibility Decision (TRED) for Boric Acid/Sodium Borate
Salts. Office of Prevention, Pesticides, and Toxic Substances. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2007. Fipronil Environmental Fate and
Ecological Effects Assessment and Characterization for Section 18 Registration of In-Furrow
Applications to Rutabaga and Turnips. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2008. Reregistration Eligibility Decision for
d-Phenothrin. Office of Prevention, Pesticides, and Toxic Substances. Washington, D.C.
U.S. Environmental Protection Agency (USEPA). 2010. California tiger salamander. Endangered
Species Facts. Office of Pesticide Programs, Washington, DC. Available:
https://www.epa.gov/sites/production/files/2013-08/documents/ca-tiger-salamander_0.pdf
(Accessed: February 7, 2018).
U.S. Environmental Protection Agency (USEPA). 2014a. Ecological Risk Assessment for the
Registration Review of Clethodim. Office of Pesticide Programs. Washington, D.C.
Exhibit A
Appendix 1
Ardea Consulting 51 MROSD Integrated Pest Management Plan
Blankinship & Associates, Inc Screening Level Ecological Risk Assessment
U.S. Environmental Protection Agency (USEPA). 2014b. Prallethrin: Revised ecological risk
assessment to support proposed new use over, near and around agricultural areas. Office of
Pesticides Programs Environmental Fate and Effects Division. Washington, DC. 66 pp.
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Assessment in Support of the Registration Review of Glyphosate and Its Salts. Office of
Chemical Safety and Pollution Prevention. Washington, D.C.
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assessment. Available at https://www.epa.gov/pesticide-science-and-assessing-pesticide-
risks/technical-overview-ecological-risk-assessment-0 (Accessed: November 27, 2017)
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CALIFORNIA+TIGER+SALAMANDER&ie=utf-8&oe=utf-8&client=firefox-b-1 (Accessed:
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data for spray adjuvants allowed for use at aquatic sites in Washington (Revised 5/18/2009).
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2018).
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Motor and Behavioral Changes in Honey Bees (Apis mellifera) and Affects the Development of
Colonies Exposed to Sublethal Doses. Environ. Toxicol. Chem.34(5): 1062-1069. In: U.S.
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Exhibit A
DATE: February 27, 2019
MEMO TO: Board of Directors
THROUGH: Ana Ruiz, General Manager
FROM: Coty Sifuentes-Winter, Senior Resource Management Specialist
SUBJECT: Award of Contract for Literature Review on the Use of Pesticides in the
Integrated Pest Management Program
_____________________________________________________________________________
BACKGROUND
IPM Program
In December of 2014, the Midpeninsula Regional Open Space District’s (District) Board of
Directors (Board) certified the Final Environmental Impact Report for the Integrated Pest
Management (IPM) Program (R-14-148). Pesticides are one tool the District uses for pest
management. The District has a List of Approved Pesticides (Attachment 2) to ensure the safest,
most effective pesticides are used. This list will adjust over time as the science of pest control
advances; as manufacturers develop more effective, safer, and less harmful pesticides; as
manufacturers update, discontinue, or substitute products; and as the District’s target pests
change over time.
Consultants completed a comprehensive toxicological literature review for all pesticides listed on
the List of Approved Pesticides at the time of certification of the IPM Program in 2014. Due to
public concerns about the use of glyphosate (the active ingredient for Roundup®), staff amended
a contract with Blankinship and Associates in October of 2017 to review the environmental fate
of the chemical. In February of 2018, Staff amended the contract again to include a review of
impacts to human health.
In October of 2018, the Planning and Natural Resources Committee supported a
recommendation to update the IPM Program’s Best Management Practices (BMP) to conduct an
annual pesticide literature review of all newly published toxicological research and court
proceedings related to all pesticides listed on the District’s “List of Approved Pesticides” (R-18-
112). Although District staff stay up to date on pesticides via multiple sources of information, an
annual, objective, third party evaluation of the IPM Program would verify that the District uses
the least harmful and most effective tools for pest management. This annual literature review
would update District staff on the latest science in the following areas, at a minimum, as it relates
to pesticide use in natural areas or rangelands:
• Human health and safety;
• Water quality;
• Soil and microbial health;
• Wildlife health;
• Drift, and effects on non-target species;
• Biodiversity; and
• Efficacy and effectiveness.
This literature review would pick up from the last time a comprehensive toxicological review
was completed; and be holistic and balanced, while taking the weight of science and the
academic journal’s prestige and ranking into account.
Science Advisory Panel
At the annual Board Retreat in December 2018, staff presented the potential formation of a
Science Advisory Panel (SAP) to the Board (R-18-148). A SAP would enhance the scientific
validity of ecosystem management decisions and serve as an important resource to inform
regional management topics. Additionally, the SAP would also present an independent science-
based review of the District’s existing and ongoing land management practices and decisions.
The SAP would assist the District in reviewing the technical reports, findings, and IPM Program
recommendations that come forth from the annual literature review. The earliest the SAP could
be formed and have the ability to start reviewing the IPM Program would be August of 2019.
DISCUSSION
Staff issued a Request for Qualifications and Proposals (RFQP) on October 17, 2018 to solicit
expert consultants in completing an annual literature review of newly published toxicological
research and court proceedings related to all pesticides listed on the District’s “List of Approved
Pesticides”. Staff posted the RFQP on the District website and BidSync. The work required
under the contract does not require any travel and can be completed remotely by a consultant.
Twenty-nine (29) firms viewed the solicitation and seven (7) firms requested the full RFQP.
Two (2) firms submitted proposals. Due to the limited number of proposals received, staff
reached out to four (4) additional entities in the San Francisco Bay area with the results as
follows:
Entity Location Proposed Fee over
4 years
AECOM Oakland, CA Declined
Creekside Science Menlo Park, CA Declined
MIG San Jose, CA Declined
EnviroScience Stow, OH $40,577.99
Catalyst Environmental Solutions Santa Monica, CA $44,440
Sara Grove Santa Cruz, CA $45,000
Evaluation criteria included the quality of the proposal, implementation approach to the project,
and the implementation expertise of the firm. Staff deemed Sara Grove, a Research Associate
with the University of California at Santa Cruz, as the most qualified and best suited for the
project based on her response to the RFQP, proposed project approach, qualifications, and her
proposed fee is fair and reasonable. The General Manager will be executing a contract under the
Board’s delegated purchasing authority with Sara Grove, a Research Associate with the
University of California at Santa Cruz, for Fiscal Year 2018-19.
NEXT STEPS
The technical reports prepared under this contract will be reviewed by the District’s IPM
Coordination Team and suggested changes to the Program will be presented to the Board at the
time of the Annual IPM Report, or sooner if deemed necessary. Staff will provide a copy of the
technical report to the SAP, if formed, for use as a reference when evaluating District land
management practices. In addition, staff will post the technical reports on the District’s website
for partner and public review.
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