~ Biological Resources ~

3.2.3.2 METHODS
Baseline Information
Background materials and information were gathered from several sources. To determine whether sensitive animal or plant species occur in the study area, EIP consulted California Natural Diversity Data Base (CNDDB) 1996 records (Rarefind Report). Additional information on sensitive plants was obtained from the California Native Plant Society's (CNPS) Electronic Inventory and Inventory of Rare and Endangered Vascular Plants of California. The Timber Inventory & Management Plan prepared for the Brooktrails Township Community Services District (Township) Greenbelt Area was reviewed for information on plant communities in Brooktrails Township. Aerial photographs were used to delineate habitat types based on the dominant vegetation observed through field reconnaissance.

The DEIR for the proposed Willits Creek Reservoir was reviewed for information on plant and animal species and habitat present in the vicinity of Willits Creek. The Environmental Assessment, prepared by EIP in fall 1993, inventoried, described, and analyzed the environmental characteristics of the Township. Existing environmental conditions were mapped by environmental issue areas, including vegetation and wildlife, to assist in identifying opportunities and constraints for future development. Information from the Environmental Assessment provides background material to assist with preparation of the Specific Plan EIR.

Claire Wheeler, a contributor to the Flora of Mendocino County was counseled regarding her knowledge of sensitive plant species in the vicinity of Brooktrails Township.

Field Surveys
EIP biologists analyzed habitat during general field surveys of Brooktrails Township conducted for the Environmental Assessment in July 1990 and October 1993. Wildlife resources of Willits Creek and its headwaters, tributaries, riparian corridor, and channel were surveyed on foot between July 27 to 29, 1993. During field surveys, special emphasis was placed on identifying the presence of any State- or Federally-listed or proposed threatened or endangered plant or animal species, candidates for such listing, or plants or animals in various categories of sensitivity. A list of all plant and wildlife species observed during EIP's field surveys is contained in Appendix B.

In addition to daylight searches for wildlife and their artifacts (tracks, nests, scats, etc.), a small number (40) of Sherman-type live traps, 3 x 3 x 10 inches in size, were set along Willits Creek and in woodland and grassland habitats to obtain information on small mammal species present in the area on July 27 and 28, 1993. In the evenings of July 27 and 28, areas along roadways were searched from a vehicle using a hand-held 1 million-candle-power lamp.

A series of systematic searches for the northern spotted owl during daylight hours and through nocturnal calling surveys were conducted for two days and nights during the period of July 27 to 29, 1993, according to survey protocol provided by the U.S. Fish and Wildlife Service and the U.S. Forest Service.,, Additional field reconnaissance was conducted by EIP in August 1993.

3.2.3.3 SETTING
Regional Biological Setting
Brooktrails Township is located northwest of Willits in the coast ranges of northern California. Willits and Little Lake Valley mark the approximate boundary between the drier Inner North Coast Range and the moister Outer North Coast Range. The climate of the outer range is largely influenced by its proximity to the Pacific Ocean (Willits is about 20 air-miles from the Pacific). A number of resulting environmental factors determine the distribution of vegetation and wildlife in the area. These factors include more rainfall than occurs in areas to the east; the moderating effect of summer fog from the Pacific; generally cooler temperatures than in areas to the east, especially during the summer; and more moderate temperatures during the winter than in the interior portions of the range.

The elevation of the Brooktrails area ranges from just over 1,500 feet to about 2,700 feet above sea level. Slopes along the ridgetops and in valley bottoms are gentle to moderate, but slopes in some of the major drainages, such as along Willits Creek, are very steep, approaching 45 degrees or more. These slopes have the potential for severe erosion.

Willits Creek and Dutch Henry Creek provide the main drainage from the Brooktrails area. Several unnamed drainages associated with these two creeks flow east into Outlet Creek in Little Lake Valley and then north to the Eel River.

Most of the area has been extensively logged. Existing vegetation is dominated by trees in the 20- to 150-year-old range, where age is dependent on the time of logging and the history of fire.

Soils and Topography
Soils on the site are derived from Franciscan sandstone or Franciscan melange. A small serpentinite outcrop occurs along a road cut near the intersection of Crawford Road and Daphne Way, in the northeast corner of the subdivision. Serpentinite forms magnesium-rich soils which are favored by a characteristic suite of rare plants. It is likely that other serpentine areas occur elsewhere within the Specific Plan area.
Over most of the Township, the topography is composed of moderately to steeply sloping hillsides with gently sloping to flat-lying ridge crests and valleys. Between 25 and 30 percent of the Township contains slopes of 40 percent and greater.

Habitat
Wildlife Habitat
Habitat is the type of environment in which a plant or animal normally lives or grows, and in which all essentials for development and existence are present. Habitats differ in species composition and in their value to wildlife.

High quality habitat includes most or all of the resource values such as complex structure, shade, water, soils, lack of disturbance, or other resource characteristics that are necessary to function as habitat for plant or wildlife species.

Moderate quality habitat has many, but not all, of the resource values that are necessary to function as habitat for wildlife species.

Low or marginal habitat has only a few of the resource values that are necessary to function as habitat for wildlife species.

Suitable (or potential) habitat is defined as an area which contains most or all of the resources necessary for species use, and which is accessible, useable, and within the range of a species, whether or not the species has been observed to occur in the area.

Habitats are usually characterized either by physical features or by dominant plants, or both. Habitat types referred to in this EIR correspond to the plant communities present based on descriptions developed by Holland. This classification generally corresponds to the Wildlife Habitat/Relationships (WHR) system developed by Cheatham and Haller for the CDFG.

A delineation of habitat types is based on the dominant vegetation observed through field reconnaissance of the site and review of aerial photography. Habitat types occurring in Brooktrails Township are shown on Figure 3.2.3-1.

The following twelve habitat types/communities have been identified in Brooktrails Township:

Aquatic Habitat
Riverine/Fisheries Habitat
The majority of Brooktrails Township lies within the Eel River drainage basin, which is tributary to the Pacific Ocean. West of Sherwood Road, two perennial streams, Willits Creek and Dutch Henry Creek, flow southeasterly, traverse the central and eastern areas of the Township, and drain into Lake Emily, a potable water supply reservoir created by damming Willits Creek.

East of Sherwood Road, Upp Creek, an intermittent southeasterly drainage, collects runoff from the small area of Brooktrails township. Upp Creek bends sharply to the northeast after crossing Highway 101, and flows northward into Outlet Creek.

Flows in creeks are subject to seasonal rainfall patterns and are highly variable. The on-site streams have a rocky substrate and contain pools formed from water scouring or debris dams.

Downstream of Lake Emily, Willits Creek is used as a migration corridor by salmon and steelhead, anadromous forms of trout which spend their adult lives in salt water, some returning to freshwater creeks each year to spawn. Fish species known to occur in the Willits Creek drainage system within Brooktrails Township, include Sacramento sucker, California roach, brown bullhead, Pacific lamprey, green sunfish, bluegill, largemouth bass, Sacramento squawfish, rainbow trout winter steelhead trout, and fall-run chinook salmon; wood ducks, black phoebe, California towhee, spotted towhees and red-shouldered hawks occur in riparian creek corridors.

Lacustrine Habitat

In Brooktrails Township, lacustrine habitat includes the open water area of Lake Emily, Lake Ada Rose, and Summer Lake. Lake Emily has a surface area of approximately 17 acres and drains about 4.9 square miles. Lake Emily drains southeasterly into Summer Lake, which is not part of the potable water

Figure 3.2.3-1

Biological Resources collection system. EIP's wildlife biologist observed bullfrogs and northwestern pond turtles in Lake Emily on October 7, 1993. Fish species known to occur in the Willits Creek drainage would be expected to occur in Lake Emily.

Lake Ada Rose is a second potable water supply reservoir located approximately 4/5 mile southeast of Lake Emily. It has a surface area of approximately 7 acres. Lake Ada Rose receives flow from an un-named intermittent tributary to Willits Creek and runoff from approximately 0.7 square mile in the southwestern portion of the Township. Release from Lake Ada Rose passes through the water treatment plant and empties into Summer Lake.

When Lakes Emily and Ada Rose were created by damming existing drainages, surrounding riparian vegetation was inundated by rising waters. Under present conditions, mixed evergreen forest extends to the high water levels of the reservoirs. The fluctuating nature of water levels in the two reservoirs has prevented the establishment of wetland or riparian vegetation along most of the shorelines. At the upper end of Lake Emily, a small area of cat-tails has become established in the sandy delta formed by the confluence of Dutch Henry and Willits Creeks. Small, scattered areas of cat-tails also occur along the shoreline of Lake Ada Rose. The area of cat-tails would be expected to decrease with rising water levels and increase with falling water levels. The lakes provide habitat for resident waterfowl such as American Coot and Pied-Billed Grebe, and migratory waterfowl which are present in the winter months, such as ringed-neck duck and bufflehead.

Summer Lake drains into a tributary of Mill Creek, which continues southeasterly. Approximately two blocks west of Highway 101, Mill Creek bends sharply to the northeast, flows northward through the west central portion of Little Lake Valley, and joins Outlet Creek east of Brooktrails Township and Highway 101.

Wetlands Habitats - Springs, Ponds, and Marshes
A number of localized springs occur throughout the Township. In the northern section, there are also a few naturally occurring ponds and lakes, and wetlands at and surrounding Swamp Gulch. These wetland areas were not delineated or surveyed for plant or wildlife species because they occur in areas included in the Greenbelt area or other areas not included in residential lots. These wetlands provide an important year round source of water to wildlife.

Terrestrial Habitat
Due to the complexity of environmental factors and the nature of past and present disturbance, vegetation in Brooktrails Township is composed of a complex mosaic of plant communities and vegetation types. Forest communities are formed by an overstory of conifers and/or evergreen hardwoods, with a mid-story of shrubs, and an understory of herbs, ferns, and grasses. Conifers typically occur on the steeper, moister north- and east-facing slopes. Evergreen hardwoods occur on the drier south- and west-facing slopes. In Brooktrails Township, conifers and hardwoods are generally second or young-growth trees ranging in age from approximately 30 to 160 years. Both forest types contain a mixture of other species. Locations of plant communities in Brooktrails Township are shown on Figure 3.2.3-1. The following plant communities are components of the vegetation in Brooktrails Township:

Coniferous Forest
Coast Redwood/Douglas Fir Forest. This is a dominant plant community in Brooktrails Township. It is composed of Douglas fir and coast redwood in approximately equal numbers. Small numbers of residual or old-growth conifers are scattered throughout the Greenbelt area of Brooktrails Township. Some Douglas fir exceeding 42" dbh (diameter at breast height) were recorded in the timber harvest report. Most conifers do not exceed 28" dbh because of previous cutting in the Greenbelt. Snags (standing dead trees) and downed logs are very scarce throughout the forest, but are likely to increase in numbers with forest age. Snags provide habitat for cavity-nesting birds, including the northern spotted owl.

Coast redwoods (occurring as second-growth trees originating from sprouting stumps) are widely scattered throughout the Township. Most redwoods occur in drainage bottoms and on cooler north facing slopes. This may be indicative of coast redwood's natural density at the eastern limits of the coast redwood range (the eastern edge of the summer coastal fog belt) where it occurs as an element in the Douglas Fir Forest.

Douglas fir and coast redwood occur occasionally in the stream bottoms, however, they are more common at the outer edges of the riverine habitat in an abrupt up-slope transition to Douglas Fir Forest habitat.

The current structure and composition of the Redwood/Douglas Fir Forest habitat within Brooktrails Township is heavily influenced by logging, road construction, fire, and fire management activities. Following intense fire or logging, tanbark oak sprouts grow faster than Douglas fir seedlings and initially become the dominant species. Tanbark oak can form a nearly solid canopy for 60 to 100 years until natural mortality allows Douglas fir to become dominant. In the present post-disturbance state, widely spaced Douglas fir overtops tanbark oak but does not yet form a closed overstory canopy. Where second-growth forest clearing has occurred within the Township to accommodate the area's internal circulation system and residential sites, dense close-spaced, even aged stands of Douglas fir occur adjacent to Township roads. Some areas within the Douglas fir forest are dominated by dense stands of madrone which are similar in structure to the pure stands of tanbark oak.

Understory vegetation consists primarily of huckleberry, manzanita, and snowberry. Fire management, in the form of brush removal and controlled burns within the Brooktrails Township, has reduced or eliminated dense stands of understory shrubs from the site. This has resulted in a more open understory than would occur naturally. Actively managed areas are dominated by a complete canopy closure of tanbark oak and madrone. The open understory contains small amounts of manzanita.

Upland Coast Range Ponderosa Pine Forest. Scattered pockets of ponderosa or yellow pine and incense cedar occur on drier slopes and ridges. This forest type intermixes with Mixed Evergreen Forest on moister sites and Oak Woodland on drier sites. Black oak, Pacific madrone, tanbark oak, canyon live oak, and Douglas fir, are common associates.

Broadleaved hardwood forest
Mixed Evergreen Forest. Mixed Evergreen forest, composed of a mixture of broad-leaved evergreen
and deciduous trees, is the predominant hardwood forest type in Brooktrails Township. The composition of the Mixed Evergreen Forest is similar to the Redwood/Douglas Fir forest, except the number of coniferous trees is substantially lower. Douglas fir, and coast redwood occur in varied densities within this forest type. Dominant evergreen hardwood trees are tanbark oak, Pacific madrone, canyon live oak, California bay, and golden chinquapin.

Deciduous hardwoods such as big-leaf maple and black oak, are associated with Mixed Evergreen Forest and also occur as components of other communities. Understory shrubs include California huckleberry, snowberry, and species of manzanita. Ferns and a number of perennial and annual species make up the herbaceous understory.

Canyon Live Oak Forest. This is a dense evergreen hardwood forest type dominated by canyon live oak. It is transitional between low elevation broadleaved hardwood forest and higher elevation coniferous forest.

Riparian Woodland/Red Alder Forest. Riparian (streamside) Woodland occurs in a narrow linear corridor adjacent to creeks and drainages, typically extending to the limits of the ordinary high water mark of streamcourses within the bottoms of steep canyons. Riparian habitat is not well developed in Brooktrails Township. In the reach of Willits Creek downstream from Summer Lake, the areas in the vicinity of the fenced playing field and the tennis courts, and downstream between Birch Terrace on the east and Primrose Drive on the west is greatly disturbed and eroded. Through this area, there is some riparian habitat with high wildlife values, but much of the Creek had been degraded by human disturbances. EIP observed that some alders and tanbark oaks had been cut and cleared from some sections of the riparian corridor. This may have been done for flood control. Where trees were cut, the creek has been completely exposed and siltation has occurred in the Creek.

On-site, riparian habitat is characterized by open medium- to small-sized trees, a minimum amount of thicket-forming vegetation, and low growing ground cover. Tree species associated with Mixed Evergreen Forest, especially coast redwood, Douglas fir, and big-leaf maple, tend to grow down steep slopes and onto canyon bottoms. Where the canyon bottoms are narrow, riparian species are often limited to red alder. Where canyon bottoms flatten out, a number of other riparian species may be present, including yellow willow and arroyo willow. Willows form intermittent thickets, and varied amounts of big leaf maple occur along the streams.

Riparian understory shrubs include several species of blackberry, snowberry, and poison oak. Riparian herbaceous (non-woody) ground cover, including native grasses such as blue wildrye, occurs in openings in the riparian understory or adjacent to creek banks. Small marshy and meadow-like areas occurring on islands or ledges along the streams are dominated by herbaceous species such as horsetail, rushes, sedges, and grasses.

Chaparral. Chaparral is a shrub-dominated vegetation type that occurs on dry, rocky sites where the soil is too thin to support forest or woodland. In Northern California, chaparral commonly occurs in patches within other plant communities. At Brooktrails it occurs on steep, dry slopes associated with Mixed Evergreen Forest, Ponderosa Pine Forest, and Oak Woodland. Wrentits and western fence lizards occur in chaparral.

Oak Woodland/Savannah. Oak woodland may be dominated by one or more oak species. Oak woodlands tend to be more open and have less canopy cover than nearby forest vegetation. Black oak, interior live oak and Oregon oak may be present. Chaparral species commonly form parts of the understory, and grasses may be common in more open places. Oak Woodland occurs on drier sites, ridge tops, and valley bottoms. Oak woodlands/savannah represent a habitat which is diminishing in California due to agriculture and urban development.

Along the Sherwood Road corridor, oak woodland and annual grassland habitats occur as a mosaic. This area consists of a varied mixture of woodland or open grassland areas containing residences and pastures. The oak woodland component may occur as single trees or as dense stands of canyon oak with annual grassland occurring in open treeless areas as an herbaceous understory.

Grassland
In Brooktrails Township, Grassland habitat is composed of mostly non-native annual grasses and broad-leaf herbaceous species that have become dominant and eliminated or reduced the extent of native perennial species. Common grassland forbs include native perennial species such as blue-eyed grass, Ithuriel's spear, and annual non-native species such as cat's ear and microseris. Annual grassland occurs on serpentine soils in the vicinity of the intersection of Crawford Road and Daphne Way. Slender oatgrass is the dominant non-native grass in this community. Native perennial grasses occurring in grassland in Brooktrails Township include California oat grass, blue wildrye, and fescues.

Landscape Habitat
This habitat type applies to the Brooktrails golf course, which is vegetated primarily with irrigated turf grasses. Many native trees, including mature coast redwood, have been retained as landscape features.

WILDLIFE
The wide variety of vegetation, soils, and topographic forms present in Brooktrails Township has resulted in diversity among the plant and wildlife species present. Sixteen mammal, six amphibian, five reptile, forty-two bird, and eleven fish species were observed in Brooktrails Township during the survey period. A number of mule deer were observed during EIP's field surveys, in addition to many of the smaller mammals and birds expected to occur near human development. A list of wildlife species observed during the field surveys, including scientific names of animals referred to in this report, is contained in Appendix B.,

Many wildlife species utilize on-site habitats in Brooktrails Township for breeding, foraging, cover, and migration corridors. Other wildlife species require special habitat features such as cliffs, caves, or various stages of woody vegetation for breeding, resting, and escape cover which are not present in the Township. The use and value of habitat to a specific species can be affected by a number of physical characteristics. The value of nesting and foraging habitat for predators can be affected by the size of the habitat area, distance to foraging areas from nesting territories, density of the prey base, and the presence of elements that may disturb species using the habitat.

Fire management within forested areas and the distribution of residences and roads throughout Brooktrails Township reduce the general wildlife values of the area. Remote areas connected with undisturbed habitat outside the Township, steep forested hillsides, and perennial creek corridors provide the most valuable wildlife habitat within Brooktrails Township.

Riverine and Lacustrine habitats available along Willits Creek, Dutch Henry Creek, Upp Creek, and Lakes Emily and Ada Rose provide critically important water sources for wildlife. The small perennial creeks maintained good flows of high-quality water even in recent drought years. Populations of several species of fish occur in most of the creeks, and larvae of Pacific giant salamanders and rough-skinned newts are common in larger pools in creeks. Adult foothill yellow-legged frogs occur in the upper reaches of Willits creek. The diversity of aquatic vertebrates present attests to the high quality of creek habitats in the Brooktrails area.

The dense growth of Coniferous and Mixed Evergreen Hardwood Forest that covers most of Brooktrails Township is low in structural diversity. Where tree canopy is dense, insufficient sunlight penetrates to the forest floor to support growth of understory vegetation. As a result, animal species diversity and abundance are relatively low. During field surveys (an effort of 80 trap nights), no small mammals were captured in forested habitats. Nevertheless, the mixed conifer and oak ecosystems are valuable to wildlife due to the food value of their seeds. Pine seeds are included in the diets of more wildlife species than are seed of any other genus of trees except the oak. Conifer bark and foliage serve as important food sources for animals such as Douglas's squirrel, dusky-footed woodrat and mule deer. Conifers provide vital nesting cover for several bird species, such as white-breasted nuthatch, brown creeper, chestnut-backed chickadee, Steller's jay, and owls. Responses to nocturnal calls conducted by EIP biologists along preset transects in forested areas in July 1993, confirmed the presence of the western screech owl and flammulated owl. A flammulated owl was also observed near Buckeye Court during a night spotlighting search.

Openings in forested areas, near roadsides, and in clearings along creek banks are important wildlife habitat features. Small grassy areas with shrubby marginal growth are used heavily by larger mammals, especially mule deer. The opportunity for wildlife species to retreat from this open habitat into nearby forested areas further enhances its value. The value of this "edge effect" is reflected in the diversity of wildlife observed in these areas, which included most of the birds and mammals observed in Brooktrails Township by EIP biologists.

Plant species occurring in the riparian area provide high quality cover, nesting, and foraging habitat for wildlife. Riparian habitats are valuable for wildlife because of their vegetative structural and species diversity, abundant food resources, proximity to water, and linear cover conducive to wildlife and fish movement.

Considering the encroachment of urbanization, with its disturbance of habitats and wildlife species and the introduction of domestic and feral pets that harass and destroy many wild animals, the Township is well-used by wildlife. In general, the natural plant communities of Brooktrails Township provide good wildlife habitat value.

Fisheries
The Willits Creek system has been altered by prior dam construction at Lake Emily and Lake Ada Rose. These dams have created impassable barriers which impede the normal upstream and downstream movement of fish, particularly trout and other salmonids.

Minimum fish flow release requirements have been established by the California Department of Fish and Game for reaches between upper Willits Creek between the proposed reservoir and Lake Emily, and Willits Creek below Lake Emily. Between the proposed Willits Creek reservoir and Lake Emily, minimum November through June flows are set at 5 cfs (cubic feet per second); between July and October, the flows are 1 cfs. Minimum flows in Willits Creek below Lake Emily after construction of a new dam would be 1 cfs. The adequacy of these flows to provide for enhanced fisheries habitat in Willits Creek and Lake Emily is currently being evaluated in conjunction with the California Department of Fish and Game.

In October 1993, an EIP biologist observed hundreds of 3-5 inch fingerling largemouth bass migrating downstream from Summer Lake. As largemouth bass prey heavily on newly hatched fry, their presence precludes successful spawning by salmon or steelhead. Largemouth bass also prey on foothill yellow-legged frogs and newly hatched pond turtles.

SENSITIVE SPECIES
The California Natural Diversity Data Base Rarefind report lists occurrences of five sensitive plant species within the Burbeck USGS quadrangle and five adjacent quadrangles. The CDFG has concerns about the presence of potential habitat for north coast semaphore grass in Brooktrails Township. A list giving the scientific names, status, periods of bloom, and habitats of these species is contained in Table 3.2.3-1. Locations of sensitive species observed in Brooktrails Township are shown on Figure 3.2.3-1.

Milo Baker's lupine occurs in roadside ditches, dry gravelly areas along roads, and in small streams, at approximately 1,500 feet in elevation. The CNDDB considers its occurrence in 1986 along Highway 101, approximately 3.5 miles south of Longvale, to be an inadvertent introduction. It is unlikely that this species occurs in Brooktrails Township because there are no nearby native populations to provide a seed source.

Showy Indian clover is known historically from the vicinity of Brooktrails. Much of its habitat has been lost to agriculture and urbanization. For years, showy Indian clover was thought to be extinct. In 1993, a single plant was found in Sonoma County. Only limited or marginal habitat for showy Indian clover: rich swales, grasslands, and ditches, is present on the Brooktrails site. The occurrence of showy Indian clover in Brooktrails Township is unlikely.

Baker's meadowfoam is a vernal pool species known from several locations in Little Lake Valley. It grows in large colonies in seasonally moist or saturated sites within grassland, and in swales, roadside ditches and margins of marshy areas. Vernal pools and suitable habitat for Baker's meadowfoam are not present on the Brooktrails site.

Baker's navarretia grows in vernal pools of low meadows, flats, and swales in adobe or alkaline soils. A single collection from the vicinity of Willits was made in 1902. Baker's navarretia was last seen in the vicinity of Rocktree/Little Lake Valleys, northeast of Willits, in 1983. It was collected twice in Sherwood Valley, northwest of Willits in 1899 and 1900. Vernal pools and suitable habitat for Baker's navarretia are not present on the Brooktrails site.

Table 3.2.3-1 (Continued) Table 3.2.3-1 (Notes)

TABLE 3.2.3-1

Roderick's fritillary grows in dry hard-packed clay soil on grassy slopes and mesas. It was observed along the trail around Leonard Lake, southwest of Walker Valley, in 1991. Suitable habitat for Roderick's fritillary is not present on the sandstone or serpentine soils underlying grassy slopes in Brooktrails Township.

North coast semaphore grass is known from approximately twelve occurrences. None of these occurrences are located within the Burbeck USGS quadrangle, nor within the five surrounding quadrangles included in the CNDDB search conducted for this report. However, the CDFG is of the opinion that moist meadows in mixed evergreen forest in Brooktrails Township provide potential habitat for the species.

No plant surveys directed toward rare plant species have been conducted in Brooktrails Township. However, none of these sensitive plant species is reported by the CNDDB to occur in Brooktrails Township, none were observed during surveys conducted for the Timber Inventory nor EIP's field surveys, and no occurrences in Brooktrails of these or other sensitive plant species are noted in the Flora of Mendocino County. None of the sensitive plant species known to occur in the region would be expected to occur in Brooktrails Township because their specific habitats, such as vernal pools or clay soils, are not present.

Sensitive Animal Species
The California Natural Diversity Data Base Rarefind report lists occurrences of five special-status animal species: 3 birds, 1 amphibian, and 1 reptile, within the Burbeck USGS quadrangle and five adjacent quadrangles. In addition, 2 fish species observed in Willits Creek are proposed for Federal listing as Threatened. Hawks and owls observed in Brooktrails Township are considered species of special concern to the CDFG. A list giving the scientific names and status of these species is contained in Table 3.2.3-1.

Birds

Northern spotted owl. Brooktrails Township is within the range of the northern spotted owl, a Federally-listed Threatened subspecies. Because the CNDDB records nesting occurrences in the Redwood Creek drainage within approximately 2-5 miles from Willits Creek, EIP biologists conducted nocturnal call surveys for northern spotted owls, as described in the Methods Section. No northern spotted owls were observed or heard during daytime or nocturnal calling surveys. Therefore, the presence of northern spotted owls in Brooktrails Township at present appears unlikely.

Although this species was previously thought to be an exclusively old growth forest species, conversations with representatives of the U.S. Fish and Wildlife Service (USFWS) and CDFG have indicated that it also occupies second growth forests. Second growth areas occupied by the spotted owl typically have an established upper canopy of conifers, suitable nest substrate (snags and holes in trees), and an understory that supports an abundance of prey species (primarily woodrats). In the absence of the required habitat elements, spotted owl occupation is unlikely.

The most likely on-site habitat for the northern spotted owl is the early successional stage of Douglas Fir Forest composed predominantly of dense stands of tanbark oak with widely spaced conifers. A comprehensive conifer canopy closure, prey base, and nesting substrate analysis has not been conducted. Preliminary analysis based on general surveys of the area indicates that the necessary conifer canopy closure and nesting substrate are lacking or extremely limited.

Discussions with the CDFG and the USFWS have indicated that without a detailed habitat suitability analysis, they consider the project site to represent suitable nesting and/or foraging habitat within the range of the northern spotted owl. Even if the site is not currently occupied, it may become occupied by spotted owls at a later date as the on-site habitats mature.

Yellow warbler. The yellow warbler is a summer visitant which has a distributional range that includes the Brooktrails area. It is considered a species of special concern by the CDFG. Breeding yellow warblers are associated with riparian habitats where there is dense growth of willows. This species has not been observed during general field reconnaissance of Brooktrails Township. As very limited habitat of this type is available in Brooktrails Township, it is unlikely that breeding yellow warblers occur.

Yellow-breasted chat. The yellow-breasted chat is a large warbler which requires dense thickets and brush adjacent to riparian areas for breeding. It is considered a species of special concern by the CDFG. This species has not been observed during general field reconnaissance of Brooktrails Township. As very limited habitat of this type is available in Brooktrails Township, it is unlikely that breeding yellow-breasted chats occur.

Hawks and owls. Resident red-shouldered, and red-tailed hawks, and sharp-shinned hawks, winter visitants, were observed in Brooktrails Township during EIP's field surveys; Cooper's hawk would be expected to be resident in riparian woodland and forest communities. Western screech and flammulated owls were heard during EIP's nocturnal calling surveys. The sharp-shinned hawk is considered a species of special concern by the CDFG. Nesting hawks, owls, and their nest sites are fully protected under Section 3503.5 of the Fish and Game Code of California. Although no hawk or owl nests were observed during EIP's surveys, suitable nest sites exist in tall trees within Brooktrails Township.

Amphibians

Foothill yellow-legged frog. During EIP's wildlife surveys, 6 adult foothill yellow-legged frogs were observed basking on sunlit rocks in small pools in the upper reaches of Willits Creek. Disruption of creek habitats and the introduction of the bullfrog, several of which were observed in the lower reaches of Willits Creek by EIP biologists, threaten the continued existence of foothill yellow-legged frogs in the area. Bullfrogs out compete yellow-legged frogs in habitats in which they both occur. Adult bullfrogs prey directly upon yellow-legged frogs.

Reptiles

Northwestern pond turtle. The northwestern pond turtle, a Category 1 candidate for Federal listing as Endangered, requires pools and basking areas for summer habitat. During the rainy season, pond turtles may retreat into upland areas to avoid being swept away by flooding during storm events. Turtles retreat to upland areas to lay eggs. Preferred upland nesting sites have gradually sloping banks, friable soils, and a southern exposure. During EIP's wildlife surveys, several adult pond turtles were observed near the Lake Emily dam.

Fish

Fall-run chinook salmon and winter steelhead trout are sensitive fish species known to occur in the Willits Creek drainage system within Brooktrails Township. In August 1995, these species were proposed for Federal listing as Threatened.

Coho salmon are proposed for Federal listing as Threatened. A remnant of the Main Eel River coho salmon population presently survives in Outlet Creek, outside of Brooktrails Township.

REGULATORY BACKGROUND
A myriad of federal and state statutes provide a regulatory structure which guides the protection of biological resources. The following discussion provides a summary of those laws that are relevant to biological resources in the vicinity of the Township.

Federal Regulations
Clean Water Act - Section 404
Section 404 of the Clean Water Act (1972) prohibits filling jurisdictional "waters of the United States" without a permit issued by the Army Corps of Engineers under a Memorandum of Understanding with the Environmental Protection Agency. Waters of the United States are defined by list and include oceans, bays, lakes, ponds, rivers, their tributaries, adjacent wetlands, and isolated wetlands used for interstate commerce, including those subject to use by migratory birds. The limits of jurisdiction in non-tidal creeks such as the portion of Willits, Dutch Henry, and Upp Creeks, portions of their tributaries, and unnamed drainages in the Brooktrails Township are determined by the ordinary high water mark (OHWM). Below the OHWM these creeks and drainages would be defined as a "waters of the United States" and therefore under Corps jurisdiction.

Migratory Bird Treaty Act of 1918
Under 16 U.S.C. 703-711, the Migratory Bird Treaty Act makes it "unlawful to take" any migratory bird listed in 50 C.F.R. part 10, including "nests, eggs, or products." This regulation is pertinent to any tree removals required for the proposed residential development that could affect nesting migratory birds. Migratory bird species observed in the vicinity of the projects are listed in Appendix B.
Endangered Species Act (ESA)
The federal Endangered Species Act is administered by the U. S. Fish and Wildlife Service. Section 3 of the Act defines an endangered species as any species, including subspecies, "in danger of extinction throughout all or a significant portion of its range". This section defines threatened species as any species "likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range". "Federally-listed" or "listed" indicates that a species has been designated as endangered or threatened through publication of a final rule in the Federal Register. Designated endangered and threatened species, listed under Section 4 of the Act, receive the full protection of the ESA.

Proposed endangered and threatened species are those for which a proposed regulation, but not a final rule, has been published in the Federal Register. Proposed species are granted limited protection, and Candidate species are afforded no protection under the ESA. This regulation is not applicable to the proposed residential lot development program because it would not result in significant impacts to federally listed or species proposed for federal listing such as the California red-legged frog, northwestern pond turtle, winter steelhead, or Fall-Run chinook salmon.

State of California Regulations
Endangered Species Act (CESA)
The California Endangered Species Act declares that deserving species will be given protection by the State because they are of ecological, educational, historical, recreational, aesthetic, economic, and scientific value to the people of the State. CESA established that it is State policy to conserve, protect, restore, and enhance endangered species and their habitats.

Under State law, species may be formally designated rare, threatened, or endangered by official listing by the California Fish and Game Commission (CDFG). Listed plants are generally given greater attention during the land use planning process by local governments, public agencies, and landowners than are plants that have not been listed.

Species listed under the California Endangered Species Act (Fish and Game Code Section 2050 et seq.) cannot be "taken" without adequate mitigation and compensation. At present, "take" means to hunt, pursue, catch, capture or kill, or to attempt to do so. Based on the most recent Findings of the California Attorney General's Office, "take does not prohibit indirect harm by way of habitat modification. Typically, CDFG implements endangered species protection by entering into management agreements ("Section 2081 Management Agreements") with project applicants.

The provisions of the California Endangered Species Act are not directly relevant to the project at this time, because all of the sensitive species known to occur in the Brooktrails Township (Table 3.2.3-1) occur in aquatic habitats which will not be affected directly by residential lot development.

California Environmental Quality Act- Treatment of Sensitive Plant and Animal Species
Both the Federal and State Endangered Species Act protect only those species formally listed as threatened or endangered (or rare in the case of the State list). Section 15380 of the California Environmental Quality Act (CEQA), however, independently defines "endangered species of plants or animals as those whose survival and reproduction in the wild are in immediate jeopardy and "rare" species as those who are in such low numbers that they could become endangered if their environment worsens. Appendix G of the CEQA Guidelines states that a project will normally have a significant effect on the environment if it will "Substantially affect a rare or endangered species of animal or plant or the habitat of the species." The significance of impacts to a species under CEQA, therefore, may be based on analyzing actual rarity and threat of extinction despite legal status or lack thereof. This is relevant to any project features (especially the widening of Sand Hill Road Bridge) that could significantly impact a species meeting the CEQA definitions of rare or endangered, including any of the species listed in Table 4.x-x.

Fish and Game Code - Sections 1601-1603
The California Department of Fish and Game (CDFG) has direct jurisdiction under Fish and Game Code Sections 1601 - 1603 over any proposed activities that would divert or obstruct the natural flow or change the bed, channel, or bank of any stream. These regulations require that private landowners (Section 1601) or public agencies (Section 1603) obtain a "Streambed Alteration Agreement" from the CDFG prior to any alteration of a stream channel or its banks. None of the activities described will occur with residential lot development.

Fish and Game Code - Sections 3503, 3503.5, 3513
Fish and Game Code Sections 3503 states that it is "unlawful to take, possess, or needlessly destroy the nests or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto". Fish and Game Code Section 3503.5 protects all birds-of-prey (raptors) and their eggs and nests. Section 3513 states that it is unlawful to take or possess any migratory nongame bird as designated in the Migratory Bird Treaty Act. These regulations could require that elements of the proposed project (in particular tree removals) be reduced or eliminated during critical phases of the nesting cycle (March 1 - August 15 annually), unless it can be demonstrated that nests will not be disturbed, and subject to approval by the Department of Fish and Game. Disturbance that causes nest abandonment and/or loss of reproductive effort (killing or abandonment of eggs or young) is considered "taking". Such taking would also violate federal law protecting migratory birds (Migratory Bird Treaty Act).

Local Regulations
In 1992, the Mendocino County Board of Supervisors adopted an ordinance designating the Township Board of Directors as the Area Planning Commission. Among the Board's chief duties is preparation of a specific plan for the Brooktrails area. The Brooktrails Township Specific Plan will serve as a comprehensive planning document for the Township.

Mendocino County zoning ordinances require a 20 foot construction setback from the banks of watercourses. Due to the steep slopes present throughout the Township, this setback requirement is overcome by terrain characteristics.

Local Policies and Plans
Forest Land (F-L) and Timberland Production (T-P) Zoning District lands are located within the western portion of the Specific Plan area. Timberland Production lands extend further to the west outside of the Specific Plan area. Mendocino County General Plan Goals and Policies call for the maintenance and protection of commercial timberland and forestry resources (General Plan pages I-34 through I-36), along with seeking to make optimum use of the County's timber resources under sound forest management practices on both public and private lands. Other concerns include the conversion of viable timberland to other uses and parcelization of timberlands that reduce timber yields.
State and Federal regulations recognize the importance of forest lands that are potentially available for harvesting and establish regulations regarding forest practices that reduce the impact of timber harvesting operations on the site and streams. Fire protection is an additional concern. Any proposals for harvesting in such areas must take into account these regulations. Logging on non-federal lands is regulated by the California Department of forestry according to the Forest Practice Act of 1973.

A timber inventory was prepared for the Board of Directors of the Brooktrails Community Services District Greenbelt Area by Lawrence D. Camp & Associates in September, 1984. The Greenbelt is composed of undeveloped parcels ranging from 0.1 acre to 890 acres that were not divided when the subdivision was created in the mid-1960's. The total Greenbelt area (Public Facility-P.F.-zoned land) contains 2,817 acres, inclusive of the golf course and the two manmade reservoirs. Most of the Greenbelt suitable for forest management is located in the western half of the subdivision. One thousand eight hundred fifteen acres are judged suitable for management. An additional 150 acres in 49 separate parcels is considered unsuitable for management because of parcel size or location. In Brooktrails Township, forest management is a synthesis of the landowner's goals for the property and the biological conditions and limitations that exist. The benefits available through more intensive management are outlined in the timber management plan. The plan also provides information about the timber resource, regeneration problems, and selection of appropriate timber harvesting methods. Because the Greenbelt area is located within Brooktrails Community Services District, the open space or Greenbelt areas are zoned P-F, or Public Facility. County zoning regulations do not prohibit forest management on parcels zoned P-F.

The timber inventory resulted in a delineation of four forest stand classes (Figure 3.2.3-2): Lightly Cutover or Uncut Timber (stands in which merchantable conifers comprise 70 percent or more of the overstory canopy), Heavily Cutover Timber (stands in which merchantable conifers comprise 40-70 percent of the overstory canopy), Poorly Stocked Conifer (stands in which merchantable conifers comprise less than 40 percent of the forest canopy), and Stream Protection Zones (stands of variable conifer density which occur in close proximity to year round or seasonal streams; they will require additional logging restrictions).

The timber management plan which accompanies the timber inventory prepared by Lawrence D. Camp[ & Associates (1985), states that much of the existing erosion observed in the Greenbelt appears to be the result of older logging activity, along with road construction for the development, and natural geologic processes. The revised forest practice regulations of the Coast Forest Practice District, however, will not permit the type of logging practices which resulted in erosion to continue.

The management plan also recognizes the role of fire in the Douglas fir/redwood forest and mixed evergreen forest and the potential for periodic uncontrolled wildfires. It regards the risk of a major fire under present conditions in the next 50 years as high, especially because there is no evidence of a major fire within the last 25 years. The plan identifies two general approaches to fire prevention: vegetative management and fire suppression. Vegetative management is intended to reduce wildfire fuel loads by removal, controlled burning or alteration of fuel properties (such as piling of brush to provide breaks in continuity of fuel masses). Continuation of the aggressive fire hazard abatement program around structures and along subdivision streets is recommended, as is proper treatment and disposal of slash during logging operations, and fuelwood reduction at the interface between the Greenbelt and private lots. The management plan also recommends limiting firewood management to small areas along ridges that can be used as fuelbreaks. In these areas, it is recommended by the management plan that some Figure 3.2.3-2 hardwood stumps be treated with herbicide to reduce the number of trees. Sprouts from tree stumps to be retained for firewood should be pruned to allow only one or two sprouts to achieve dominance. However, it is recommended that the use of herbicides for the treatment of stumps be replaced with a manual program to reduce stump sproutings.

Management policies will recognize the importance of maintaining a high level of water quality, and reducing the current fire hazard within the Greenbelt and on adjacent private lots. Enhancement of wildlife habitat will be considered in development of management policies and implementation of management practices.

Future management policies are subject to continued revision as a result of changing ownership objectives, research findings, and the complex ciological interactions that occur in the forest ecosystem. The intensity and direction of future forest management is dependent upon the goals and objectives of the District's Board of Directors.

The California Department of Forestry (CDF) has primary responsibility for most activities within the Greenbelt, with a major emphasis on the regulation of timber harvesting. The Forest Practice Act and Sections 895 through 920, and 1000 through 1085.6 of Title 14 of the California Administrative Code are applicable to the harvest and sale of timber. The Act and its administrative rules are supervised by the local CDF resource offices in Ukiah and Willits.

If the District continues to participate in the California or Federal Forest Improvement Programs, CDF will have a supervisory role; however, the CDF has no regulatory authority if the District finances reforestation or thinning work without participating in the sharing programs.

The CDFG becomes involved in timber management as necessary to protect wildlife and wildlife habitat.

The North Coast Water Quality Control Board has broad authority to protect and enhance water quality. In the past, the agency has been very active in review of timber harvesting operations and has established its own protection measures. The board retains authority to establish discharge standards for all types of forest management activities including timber harvesting, site preparation, and application of herbicides when these activities may occur adjacent to streams or lakes.

The Mendcocino County Agricultural Commissioner has the primary responsibility for field supervision of restricted chemicals used against undesirable plants, insects, or animals. If restricted chemicals are used for forest management activities, the District will be required to obtain a permit form the agricultural Commissioner's office.

3.2.3-4 IMPACTS AND MITIGATION MEASURES

Brooktrails Township Specific Plan Policies
The Plan goals specifically related to biological resources in the Plan area appear in the Environmental Resources Chapter of the Plan as GOAL ER-6.3-1, and ER-6.3-2. The Policies for implementing the Goals are central to the issue of biological resources and are reiterated here to allow the reader easy reference to the actual language in the Plan.

VEGETATION AND WILDLIFE GOAL ER-6.3-1: Protect and enhance the Township's native vegetation and wildlife resources.

POLICY ER-6.3-1A: Protect and enhance botanical resources including native plants, trees, and wild flowers.

POLICY ER-6.3-1B: Promote the protection of rare and unique vegetation through appropriate management prescriptions.

POLICY ER-6.3-1C: Establish a Brooktrails subdivision-wide tree cutting policy except for Forest Land and Timberland Production designated areas. Trees shall not be harvested for the primary purpose of obtaining revenue, within District owned property.

POLICY ER-6.3-1D: Encourage native landscaping within the Township and the use of flowering native plants and wild flowers in landscaping. Discourage the introduction of non-native plant species.

POLICY ER-6.3-1E: Incorporate landscaping as part of any transportation corridor improvements.

POLICY ER-6.3-1F: Protect and enhance parklands and their biological diversity.
VEGETATION AND WILDLIFE GOAL ER-6.3-2: Ensure the survival and longevity of native wildlife and habitat.

• substantially reduce the habitat of a fish or wildlife species (CEQA Section 15065);
• cause a fish or wildlife population to drop below self-sustaining levels (CEQA Section 15065);
• threaten to eliminate a plant or animal community (CEQA Section 15065);
• reduce the number or restrict the range of a rare or endangered plant or animal (CEQA Section 15065);
• substantially affect a rare or endangered species of animal or plant or the habitat of the species (CEQA Guidelines, Appendix G);
• interfere substantially with the movement of any resident or migratory fish or wildlife species (CEQA Guidelines, Appendix G);
• be inconsistent with the goals or policies of the Mendocino County General Plan related to biological resources; or
• be inconsistent with the planning goals and policies, or ordinances related to biological resources of other local agencies with jurisdiction in the project areas;
• damage or reduce the size of an existing environmentally sensitive habitat area;
• result in contamination of an environmentally sensitive habitat area which has the potential to adversely affect health or reproduction of native plants or wildlife in the habitat area;
• eliminate mature native oak trees or specimen quality examples of other tree species or substantially reduce the number of smaller trees within a given area.

Among these trees are some large, and exceptionally large trees that would be considered "heritage trees" under some jurisdictions. These older trees are especially valuable as wildlife habitat. Project construction and disturbance in the vicinity could adversely affect wildlife use of these trees, and therefore would be considered a significant impact.

Tree removal would remove nesting habitat for birds, including sensitive species such as raptors and migrating songbirds.

Loss of the foraging, nesting, and roosting opportunities provided by these various habitats, habitat loss would cause the displacement of most wildlife presently residing on residential lots. As lots are developed, more mobile birds and mammals, such as coyote and mule deer, would disperse into nearby undeveloped areas. The outcome of this dispersal is uncertain, as undeveloped areas would be assumed to have existing populations of similar wildlife species. Less mobile mammals, reptiles, and amphibians could be destroyed during lot development. Some of the bird species accustomed to human disturbance may return to the site after project completion.

The loss of wildlife habitat in California, especially in this rapidly developing region affects a number of wildlife species dependent on these areas for most or all of their life requirements. In addition to the water, food, and shelter available in these rich habitats, riparian and forest corridors are used for concealment during daily passages to foraging and nesting sites and during seasonal migrations. Any activity that interrupts or blocks these corridors severely restricts or eliminates their use by wildlife. The loss of wildlife habitat must be considered under CEQA Section 15126(b) as a significant environmental affect that cannot be avoided if the lot development plan is implemented.

Mitigation Measure 3.2.3-1
Tree and native vegetation removal for lot development shall be minimized to the extent feasible. Fire-resistant native plant landscaping shall be encouraged to provide habitat with high value to wildlife that would act as a buffer to natural open space areas and retain the forest character of Brooktrails. These measures will be enforced during the development review process as called for in the Specific Plan (S).

Impact 3.2.3-2
Residential lot development could result in loss or damage to sensitive plant species (PS).

No sensitive plant species are known to occur in Brooktrails Township, and none were observed during field surveys. However, the CDFG is of the opinion that north coast semaphore grass could occur in Brooktrails Township because habitat for this species, moist meadows in mixed evergreen forest, is present. Loss or damage to northern semaphore grass would be considered a potentially significant impact.

Mitigation Measure 3.2.3-2
Surveys for north coast semaphore grass shall be conducted in May during lot development review and prior to the development of residential lots containing moist meadows. If north coast semaphore grass is found to occur, development shall be sited to avoid semaphore grass, reducing this to an insignificant impact.(1)

Impact 3.2.3-3
Lot development could result in the loss of or damage to nesting birds protected under the Migratory Bird Treaty Act and sensitive wildlife species, including (potentially) the northern spotted owl and nesting raptors (PS).

Although the northern spotted owl is not known to occur in Brooktrails Township at present, the CDFG and the USFWS are of the opinion that the Township could contain spotted owl habitat within the next 30 years. Direct impacts to nesting raptors and losses of nesting habitat would also be considered a significant impact. Impacts to spotted owl, nesting raptors or migratory birds from development through habitat loss would be considered significant impacts.

If spotted owl nesting territories are established within the Township, certain forest management and non-disturbance buffer zones will be required. The focus of CDFG and USFWS management protocols are associated with timber harvest activities that are considered temporary impacts. Mitigation guidelines for private land and permanent impacts are not clearly established. For the purposes of this analysis, the following summarizes the potential constraints associated with suitable habitat and impacts to an established nesting territory. The following mitigation measures will apply for tree removal associated with lot development.

Mitigation Measure 3.2.3-3
To avoid the nesting season of raptors, migratory birds and other sensitive birds, all tree removals shall take place between September 1 and February 1, if feasible.

a) If it is established (and confirmed by the agencies) that suitable habitat is not present on the project site, then no northern spotted owl constraints would be placed on project development. However, habitat could become suitable over the life of the project. Therefore, consideration should be given to the long-term management of the forest to accommodate this species should it become established. (1)

b) If it is established that suitable habitat exists on the project site, a forest management plan shall be implemented. A 50/11/40 formula has been established for timber management areas that can be used as a guideline. This formula suggests that 50 percent of the total project area be set aside with all conifers 11 inches or greater in diameter left with an average 40 percent canopy closure. (This formula is based on a forest dominated by conifers.) (1)

c) If an active nesting territory is established, non-disturbance buffer zones and limited impact areas will need to be established. In relation to timber harvest, a 70-acre management area would need to be established around an active nest site. This would require that no harvest be allowed within 18 acres around the nest and overstory canopy closure could not be reduced below 60 percent in the remaining 52 acres. No guidelines have been established for understory vegetation (e.g. stands of tanbark oak and madrone).(1)

d) Currently, the habitat areas with the most potential for spotted owl occurrences are the riparian corridors. Therefore, development in these areas shall be avoided and adequate buffer zones be established through permanent natural open space designation.(1)

If tree removal between February 1 and September 1 is required, a pre-construction season survey shall be conducted to identify the presence, or lack thereof, of nests of raptors, migratory birds or other protected species. If no nests are identified in trees to be removed, no further mitigation is necessary. If nests are identified, CDFG shall be contacted and appropriate protocols for nest relocation shall be implemented.

For species protected under the Endangered Species Act, appropriate protocol consists of nest removal during the non-nesting season (see 4.7-5(a)). For birds protected under the Migratory Bird Treaty, protocols do not exist in published regulations, and need to be developed on a case by case basis in consultation with the CDFG and the USFWS. (PS)

Removal of certain protected raptor species may require state and federal permits for incidental take (e.g. Section 10 or Section 2081). The requirement of these permits include providing habitat conservation plans, provision of mitigation lands, fees and a Memorandum of Understanding Documenting details of the removal and mitigation process.

Constraints associated with the potential occurrence of active nest sites would be associated with avoidance and the establishment of non-disturbance buffer zones while the nest is occupied by adults or young. Pre-construction breeding season surveys of trees to be removed may be necessary to avoid any take of Cooper's hawks.

Impact 3.2.3-4
Residential lot development could result in erosion which could cause loss or damage to aquatic species. (PS)

Sedimentation and contamination of the Creek could result from removal of vegetation, and excavation and grading during construction of houses. Frog eggs and larvae are particularly susceptible to affects of siltation resulting from construction-related erosion.

Lot construction could thereby adversely affect aquatic life, including sensitive animal species, such as foothill yellow-legged frog, pond turtle, and steelhead, in Lakes Emily and Ada Rose, and in Willits, Dutch Henry
and Upp Creeks, and their tributaries during construction. This would be considered a potentially significant impact.

Mitigation Measure 3.2.3-4
Implementation of the following mitigation measures would reduce the impact to an insignificant level by a) ensuring that measures would be implemented to control erosion and sedimentation (see Section 3.2.1, Soils, Geology and Seismicity), b) that disturbance to habitat of sensitive species would be avoided or minimized, and c) that construction would be timed to avoid disturbance of sensitive species during their breeding or migration seasons. (I)

Typical conditions would include the following: 1) areas cleared of vegetation, fill or other materials should be stabilized as quickly as possible after clearing and grading; 2) hay bales, silt screens or similar devices should be used as filters to prevent siltation; 3) to further protect the drainage system and prevent erosion, grading and construction should be completed during the dry summer months (see also Section 3.2.2, Hydrology and Water Quality).

Impact 3.2.3-5
Residential lot development could result in adverse affects to biological resources as a result of increased human presence. This is a potentially significant impact. (PS)

Increased development in the Township may put designated parklands and sensitive biological resources at increased risk to arson, poaching, controlled and uncontrolled feral animals, wildlife loss, invasion of foreign plants, and vandalism.

Lot development could increase human access resulting in disturbance and trampling damage to sensitive riparian habitat adjacent to creek and to the creek channels following construction.

Mitigation Measure 3.2.3-5
Implementation of the following mitigation measures would reduce the above impact to an insignificant level by ensuring protection of sensitive species and aquatic life in the creeks during construction: (I)

Implement the following Mitigation Measures to ensure reduction or avoidance of long-term sedimentation in creeks and other human disturbance impacts within Brooktrails Township.

a) Unauthorized trails leading into creek channels shall be obliterated by new plantings. Fencing and posting of signs shall be installed in consultation with CDFG, to educate the public and route access from sensitive areas.

b) Direct public access to creek banks and channels shall not be permitted except over crossings and for carefully sited view points.

Impact 3.2.3-6
Residential lot development could interfere with wildlife movement. (PS)

During construction, noise and activities could interfere with foraging, reproduction, and daily movements of animal species. However, construction noise is a short-term impact and wildlife in some areas of Brooktrails Township are already subjected to high levels of human intrusion due to residences and road traffic. More mobile species would be expected to avoid or move out of the area once construction begins, and return when construction is completed. This is considered a potentially significant impact.

Other species currently present appear to be adapted to the noise and activity level associated with the network of roads.

Increased human occupation of the area could degrade adjacent upland habitat used by pond turtles for egg-laying, and could increase direct take of adults by humans.

Mitigation Measure 3.2.3-6
Natural open space should be left in a configuration that would provide corridors and linkages with natural areas outside the Township, to allow the movement, migration, and dispersal of wildlife between areas. (I)

Cumulative Impacts and Mitigation Measures

Impact 3.2.3-7
Implementation of residential lot development projects, in conjunction with other proposed projects in the area would result in incremental losses of up to approximately 1,200 acres of conifer and mixed evergreen forest, oak woodland, open grassland, and the wildlife species that depend upon them. The animals lost as a result comprise primarily common and urban wildlife species, which are not significant in maintaining regional biodiversity. Migratory species which would use habitats in the project area, particularly the riparian and creek corridors of Willits, Dutch Henry, and Upp Creeks might come from distances exceeding 1,000 miles. Migratory songbirds, and migrating anadromous fish that occur over an extensive area may have brief, but nonetheless important dependent periods on the habitat and conditions of the creeks and lakes. Furthermore, these species are important to the local biological community and provide aesthetic values to local citizens. Losses of conifer and mixed evergreen hardwood forest habitat would not cause species extinctions or uninhabitable conditions. Construction, additional human access, erosion, and non-point source pollution associated with additional urbanization would all result in habitat and wildlife losses. The aesthetic and wildlife values, although relatively small, of this area would be lost with project implementation to the extent the impacts are not successfully mitigated. On a local level, this is considered a potentially significant impact.(PS)

Implementation of the following mitigation measures would avoid and minimize impacts to a level which is less-than-significant on a regional level. Local impacts will continue to be potentially significant.

Mitigation Measure 3.2.3-7
Mitigation measures 3.2.3-1, 3.2.3-2, 3.2.3-3, 3.2.3-4, 3.2.3-5, and 3.2.3-6, shall be implemented for the residential lot development projects proposed in Brooktrails Township.(PS)

ADDITIONAL CUMULATIVE MITIGATION RECOMMENDATIONS
Given the forest-type habitat that is prevalent throughout most of the project area, a significant amount of general habitat values can be associated with the Brooktrail Township. As houses, roads, and related infrastructure are developed within the area, the habitat values will be diminished because of tree removal and other vegetation clearing, partitioning and fragmentation of habitat areas, and increased disturbance from human activity. This may not directly jeopardize any one species or habitat, but it will contribute to a cumulative loss of available habitat for resident and migratory species that may utilize the area.

Mitigation Measures
Planning opportunities with respect to biological resources revolve around efforts to utilize planned open space to protect and enhance habitat for native plants and wildlife species. Planning opportunities should be further focused on ensuring that potential constraints associated with the above described special-status plant and wildlife species or their habitat are avoided and minimized to the extent feasible. Where conflicts are unavoidable, open space planning should include opportunities to compensate for the loss of general habitat values and loss of special-status species should any occur.

Brooktrails Township contains 2,817 acres of Public Facility open space, more than half the acreage of the Specific Plan area. Open space can be considered in a number of different ways such as golf courses, parks, other active or passive recreational uses, as well as a means of protecting habitat for plants and wildlife. While some recreational uses can be compatible with habitat protection, such as hiking and bicycle trails, it is important to make a distinction between the above open space uses and the use of open space to protect or enhance biological resources (natural open space). Therefore, the following planning concepts are intended to address the opportunities associated with open space planning for the protection of biological resources that will allow planned development to proceed within the Brooktrails Township with a minimum of constraints to biological resources.

Habitat-Based Ecosystem Approach
Open space planning should take into account creating areas of habitat that are large enough to contain all the ecosystem elements necessary to sustain the resident and migratory species that utilize the area. Designation of natural open space should be in areas that can develop habitat values through normal succession and also take into account wildlife needs for food, water, and cover. This can be accomplished through the:

Designation of natural open space in areas away from proposed development. (Avoid habitat fragmentation created from roads and lot development.)

Creation of large blocks of natural open space that are contiguous with open space outside the project area. (Avoid many small natural open space areas that are hard to manage and subject to an increased amount of human disturbance from cars, pets, and vegetation clearing.)

Where feasible, natural open space should protect populations of special-status species should they occur. Species-specific surveys and/or detailed habitat suitability studies may be required to assist in the delineation of natural open space areas that will reduce or avoid any potential constraints associated with special-status species and their habitat.

Establishment of corridors and linkages between natural open space within the project area, as well as those natural areas outside the project site. This will allow for movement, migration, and dispersal of wildlife between areas of natural open space.

Utilize riparian corridors as the framework for natural open space planning. This will accomplish sensitive species and habitat protection as well as minimize the need for regulatory permitting from the Corps and DFG. This will also contribute to minimizing water quality impacts by protecting the watershed of the creeks and drainages.

Develop a forest management plan that sets the policy framework for activities associated with the development of the project sites and management of the forest that are compatible with both human and wildlife species. As established above, the on-site forest is in the early successional stages of a Douglas Fir Forest that is dominated by dense stands of tanbark oak. Over time the conifer element (Douglas fir and coast redwood) will likely become the dominant vegetation. Therefore, the following elements should be considered in a forest management plan that will allow for habitat values to "succeed" along with the forest.

Fire management and the safety of life and property are most important when people reside in close proximity to wildlands. Vegetation removal and controlled burns should be limited to that necessary for safety purposes. Where safe and feasible, understory development should be allowed to provide habitat (food and cover) for understory species.

Where feasible and considered safe, snags (standing dead trees) and down logs should remain. This provides important habitat and is an essential element in natural forest succession.

Minimize tree removal and native vegetation removal for lot development. This will help to provide habitat values that can act as a buffer to areas of natural open space while keeping the "forest character" of the Brooktrails Township.

Establish provisions to ensure that trees with active raptor nests will not be removed for lot development. This may require pre-construction surveys of the trees to be removed as the lots are developed and avoidance of the nest tree during the breeding season (March - August).